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Home My WebLink About20190739.tiffCOLORADO Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 0 St PO Box 758 Greeley, CO 80632 February 8, 2019 Dear Sir or Madam: RECEIVED FEB 1 4 2019 WELD COUNTY COMMISSIONERS On February 14, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Rocky Mountain Midstream, LLC - Broomfield Compressor Station. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept of Public Health a Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S. John W. Hickenlooper, Governor Tublic9tAitew 2/25/i q , Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer CG PLC -r0, N L(3 -r) c L cZTt ►ERIC% Ic�� 2/141 t9 2019-0739 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Rocky Mountain Midstream, LLC - Broomfield Compressor Station - Weld County Notice Period Begins: February 14, 2019 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Rocky Mountain Midstream, LLC Facility: Broomfield Compressor Station Natural gas compressor station Section 29, T1 N, R67W Weld County The proposed project or activity is as follows: Applicant proposes to construct two (2) natural gas dehydration systems to support a new natural gas compressor station supplying 100 MMSCFD capacity for Rocky Mountain Midstream's gas gathering system in Weld County. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 18WE1160 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Bradley Eades Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 Colorado Air. Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package it: Received Date: Review Start Date: Bed Lades... '..389460,. 10/26/2018 "" 113/2019 Section 01- Facility Information Company Name: Rocky Mountain Midstream ELC County AIRS ID: 123 Plant AIRS ID: A009 Facility Name: Broomfield Compressor Station Physical Address/Location: County: Type of Facility: 'INaturafGanCompresso What industry segment?`0il&Natuuralits*Pro tctsoes&Pr Is this facility located in a NAAQS non -attainment area? Yen If yes, for what pollutant? ❑ Carbon Monoxide (CO) Section 29, Township 1N, Range 67W `Weld County Section 02 - Emissions Units In Permit Application ❑ Particulate Matter (PM) Quadrant Section Township Range 1N. 67 Ozone (NOx 6 VOC) AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 t?thplain) Cl Yes 1SWEI160 1 Yes Perrrtttfnitlak, Issuance ECDfor 001: 002 002 -- Dehydrator Dl Yes 18WE1160 1 Yes Permit Initial ` Issuance 003 `: Dehydrator D2 - Yes 18WE1160 1 - Yes' Permit m itial - Issuance Section 03 - Description of Project Applicant proposes to construct a new natural gas compressor station to provide 100 MMSCFD compression capacity for Rocky Mountain Midstream's gas gathering system in Weld County. This faciltty is a synthetic minor source. Three (3) natural gas fired engines are permitted under GP02 (application was submitted separately). Faciility also includes two (2) stop oil storage tanks, truck loading of slop, venting of gas during planned maintenance blowdaws, and fugitive component leaks, all of which are APEN exempt. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Synthetic Minor P Section 05 - Ambient Air Impact Analysis Requirement: Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Yes SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Is this stationary source a major source? If yes, explain what programs and which pollutants here SO2 Prevention of Significant Deterioration (P5D) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) NOx CO VOC PM2.5 PM10 TSP HAPs ❑ ❑ Separator Venting Emissions Inventory 011 Separator Venting Facility AIRs ID: County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates *98% control of VOC and HAP combusted by this equipment is requested. However, this point only accounts for secondary combustion emissions of NOx and CO. Primary Emissions - Combustion of dehydrator waste gas Pilot burners (2 @ 22scfh each)1,04!"14- Pilot + Purge scrn scfh (scfh MMscf per year scfh 0.04 MMscf per month *Process/Waste Gas �,I` r�:ZLi'A MMscf per year 1.74 MMscf per month TOTAL (Pilot+purge+waste) k,L Fuel (pilot and purge) LH Pilot and purge VOC % Pilot and purge MW *Waste Gas LHV *See analysis tabs for Poin Actual Throughput= I Requested Permit Limit Throughput 002 & Point 003 scfh btu/scf Ib/Ihmol btu/scf MMscf per year MMscf per year Requested Monthly Throughput = 1.77 MMscf per month 1.7727288 Potential to Emit (PTE) Throughput = Section 04- Emissions Factors & Methodologies Description Primary Control Device Pollutant 20.87 MMscf per year Uncontrolled Uncontrolled (Ib/MMBtu) lb/MMscf (Waste Heat Combusted) (Gas Throughput) Emission Factor Source PM10 PM2.5 50x NOx CO VOC Primary Control Device Pollutant PM10 PM2.5 SOx NOx CO 11.149 11.149 0.880 206.494 412.240 Uncontrolled Uncontrolled (lb/MMBtu) lb/MMscf (Waste Heat Combusted) gAtifabr (Gas Throughput) 9.597 Emission Factor Source 2 of 15 K:\PA\2018\18 W E1160.CP1.xls m Separator Venting Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 PM2.5 SOx NOx VOC - CO 0.12 0.00 0.00 0.12 0.12 20 0.12 0.00 0.00 0.12 0.12 20 0.01 • 0.00 0.00 0.01 0.01 2 2.15 0.00 0.00 2.15 2.15 365 - 0.09 0.00 - - - 0.00 0.09 0.09 15 4.29 0.00 0.00 4.29 4.29 729 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XVII.B, G (See regulatory applicability worksheet for detailed analysis) Source requires a permit Source is subject to Regulation 7, Section XVIl.B.2 Section 07 - Initial and Periodic Sampling and Testing Requirements The HHV of the fuel gas is based on a site -specific sample and the composition is not expected to vary significantly over the life of the plant. Therefore, an initial sample is not required for fuel gas. The HHV of the waste gas routed to this control device is based on the GlyCaic average waste gas heating value of flash tank overheads and still vent condenser vent streams from Point 012 and Point 013. Therefore, sampling will not be required with this stream. Section 08 - Technical Analysis Notes AIRS Point 001 Section 09 - Inventory SCC Coding and Emissions Factors Process # SCC Code 01 3-10-002-16 Flares Combusting Gases <1000 BTUlscf 01 3-10-002-16 Flares Combusting Gases <1000 BTU/scf The processes above areas follow: (i) 01- Combustion of still vent and flash tank waste gas, (S) 02- Combustion of pilot fuel. Uncontrolled Emissions Pollutant Factor Control % Units PM10 11.15 0% lb/MMSCF -_.. PM2.5 11.15 _0% lb/MMSCF SOx 0.88 0% lb/MMSCF NOx 206.49 0% lb/MMSCF CO 412.24 0% lb/MMSCF VOC 0.00 98% lb/MMSCF PM10 9.60 0% lb/MMSCF PM2.5 9.60 0% Ib/MMSCF SOx 0.76 0% lb/MMSCF NOx 177.74 0% lb/MMSCF CO - 354.84 0% lb/MMSCF - - VOC 432.46 0% Ib/MMSCF 3 of 15 K:\PA\2018\18WE1160.CP1xlsm Separator Venting Regulatory Analysis Worksheet CobraO 2 lafon 3 Parts Aand B -APE, and Permit Requirements 15ource is in Me Nnn.amiementArea ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this Ind.ldualsourcegreater-am 2TPY(Pegulatbn 3, Part A, Section 0.0.102 2. Are M. facility uncontrolled VOCemisslons greater than 5TPY, NOa greaMrthan'TOTPY or Co emissions greater than lO TPY(Regulation 3, Part %Section 11.0.3)2 'Notenough information NATTAINMENT L Are uncontrolled emissions from any cdbda pollutants from than lndiTdual source greater[haulT. (Regulation 3, Part A, Sectionli.0.Laj2 1 Are mml facnicy ummnwlled VOC emissions from the greater than 2 TPY, NOx greater than STPYor CO emissions greater than 10TPY(Regulation 3, Part B, sectionill.0.2)2 (Source requires a permit Colorado PAeulation>. ..on %VII I. Does this combustor control any equipments...Me Regulation T, Secgon XVIN (Source Cs... Regulation T, 5ection1NII.B.2 s di o XVII.B.2—General Provisloms For Air Pollution Control Equipment and Prevention of Emissions Section XVII.G-Erosion Uneol Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Ali Act its implementing regulations, and Air Quality Control Commission regulations This document Is not a rule or regulation, and Me analysis d contains may not ahoy to a hereaftersiNation based upon the individual facts end csamnstances This document doss not change or subsaute for anylaw, regulation, or any other legally binding requirement and is not legaly enforceable. In the event fany cord list between Me language ofdia document end the language of the Clean AlrP., ifs implementing regulations, and Air Quality Conine Commission eguladons, the language of the statute or regulation will canhoi. The useeducal-mandatoryintended to describe conholling requirements unearth. terms of the Clean Air Act end Air Quality Control Commission regulations but this document does not establish legally binding requirements In and of itself. $ti3 So ¢ Pequiresan=PEN.Goto thenestquezmn Yea: ii Sstrce RegOiOsa permit -.. 11".4a S rce Issubject,go to neat question Glycol Dehydrator Emissions Inventory 002 Dehydrator (Facility Al Rs ID: MIENMANNNEar ;MK Cieunty Plant Poln Section 02- Equipment Description Details Dehydrator Information Dehydrator Type: Make: Model: Serial Number. Design Capacity: 'Recirculation Pump Information Number of Pumps Pump Type Make: Model: Design/Mau Recirculation -Rate: Dehydrator Equipment Flash Tank Reboller Burner Stripping Gas Dehydrator Equipment Description Emission Control Device Description: MMscf/day gallons/minute , flasE tank, and mballer burner One (1) Triethylene glycol (TEG) natural gas dehydration unit (Make: TBD, Model: TBD, Serial Number. TBD) with design capacity of 50 MMscf per day. This emissions unit is equipped with 2 (Make: TBD, Model: TBD) electric driven glycol pump with a design capacity of 10 gallons per minute. This dehydration unit is equipped with a still vent, flash tank, and reboller burner. Emissions from the still vent are rooted to an air-cooled condenser, and then to the Enclosed Flare. Emissions from the flash tank are rooted directly to the Enclosed Flare. Section 03 -Processing Rate Information for Emissions Estimates Primary Emissions- Dehydrator Still Vent and Flash Tank (if present) Requested Permit Limit Throughput = min:0;45.0DRNMMscf per veer Potential to Emit(PTE) Throughput = 18,250 MMscf per year Requested Monthly Throughput= 1550 MMscdPer Month Secondary Emissions -Combustion Devices) for Air Pollution Control Still Vent Control Condenser: Condenser emission reduction claimed: Primary control device: Primary control device operation: Secondary control device: Secondary control device operation: Still Vent Gas Heating Value: Still Vent Waste Gas Vent Rate: Hash tank Control Primary control device: Primary control &vice operation: Secondary control device: Secondary control device operation: Flash Tank Gas Heating Value Flash Tank Waste Gas Vent Rate: °NOTE THAT COMBUSTION EMISSIONS ARE ACCOUNTED - ----- -TOTAL TO COMBUSTOR - 1,167.35 scfh --------- ---- Avg. LHV of waste gas 1,496.33 btu/scf Section 04- Emissions Factors Bc Methodologies Dehydrator Input Parameters Inlet Gas Pressure _Inlet Gas Temperature Requested Glycol Recirculate Rate STILL VENT Control Seabeds Primary Secondary Pollutant Uncontrolled (lb/hr) Controlled (lb/hr) Controlled (lb/hr) VOC KIA.4a 2„_--';%'I 0.4316 0 Benzene sts 37,83,.3/ %;, 0.0032 0 Toluene $';,i' 0.0575 0 Ethylbenzene 01,01-04041M0 0.006 0 xylenes %!l/z4i847rt`t ,,,,,•..'. 0.0093 0 n -Hexane .?'"nty 7Q36fti'=.:1:'. 0.0098 0 224-TMP fix 5O.B000 '>`-. V 0.000006 0 FLASH TANK Control Scenario Primary Secondary Pollutant ' Uncontrolled (lb/hr) Controlled (lb/hr) Controlled (lb/hr) VOC '. l''' c00)Lf5SY- _ 0.601104 0 Benzene' 0.004558 0 Toluene - '0."S712'ij 0.003424 0 Ethylbenzene r'°`s'° 0 , ` ` 0.000478 0 xylenes U'033" 0.000672 0 n -Hexane DA893. ":l„'.,,' 0.009786 0 224-TMP 0.000004 0 R q st dCe d Outlet Tamperetute: ;,�„il ilControl Efficiency% Requested TO Temp ;Control Efficiency % hr/yr hr./Yr Btu/scf scfh hr/yr Btu/scf cih Cantrell Efficiency % Control Efficiency % Degrees F Dry Gas Throughput: Still Vent Primary Control: 18,250.0 MMscf/yr Still Vent Secondary Control: 0.0 MMscf/yr Waste Gas Combusted: Still Vent Primary Control: 2.3 MMscf/yr, Still Vent Secondary Control: 0.0 MMscf/yr Dry Gas Throughout: Flash Tank Primary Control: 18,250.0 MMscf/yr Flash Tank Secondary Control: 0.0 AAMsef/yr' Waste Gas Combusted: Flash Tank Primary Control: 7.9 MMscf/yr Flash Tank Secondary Control: 0.0 MMsof/yr FOR WITH POINT 011. COMBUSTION INFORMATION AND STREAM FLOW ABOVE IS FOR INFORMATIONAL PURPOSES ONLY 1,550.0 0.2 Glycol Dehydrator Emissions Inventory Emission Factors Glycol Dehydrator Pollutant Uncontrolled (Ib/MMscf) (Dry Gas Throughput) Controlled (lb/MMscf) (Dry Gas Throughput) Emission Factor Source VOC 13.69 0.90 Benzene 4.085472 Toluene 0,04692384 0.02924352 0.00310944 0.00478656 0.00940128 0.0000048 4.623984 1.083216 2.103072 0.572592 0.00024 Ethylbenzene Xylene n -Hexane 224IMP Section 05 - Emissions Inventory Old operator request a buffer? Requested Buffer (%t Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 PM2.S Sox NO4 CO VOC 0.0 0.0 0.0 0.0 0.0 - 0 0.0 0.0 0.0 0.0 0.0 0 0.0 0.0 0.0 0.0 0.0 0 0.0 0.0 0.0 0.0 0.0 0 0.0 0.0 0.0 0.0 0.0 0 307.4 307.4 4.5 307.4 4.52 768 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled Ohs/year) (Ibs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 74550 74960 856 74960 856 84388 84388 534 84388 534 19769 19769 57 19769 57 38381 38381 87 38381 87 10450 10450 172 10450 172 4 4 0 4 0.09 Section 06- Regulatory Summary Analysts Regulation 3, Parts A, B Regulation 7, Section XVII.8,D Regulation 7, Section XVII.8.2.8 Regulation 7, Section 911.H Regulation 8, Part E, MALT Subpart HH (Area) Regulation 8, Part E, MACT Subpart HH (Major) Regulation 8, Part E, MALT Subpart HHH (See regulatory applicability worksheet for detailed analysis) Source requires a permit Dehydrator is subject to Regulation 7, Section XVII, B, D.3 The control device for this dehydrator Isnot subject to Regulaton 7, Section XVII.9.2.e Dehydrator is subject to Regulation 7, Section 011.5 The deity unit meets the benzene exemption You have indicated that this fadlity is not subject to Major Source requirements of MAR RH. You have indicated that this facility is not subject to MALT HHH. Section 07 - Initial end PeriodlcSampling and Testing Requirements Was the extended wet gas sample used in the GlyCalc model/Process model site -specific and collected within a year of application submittal? If no, the pemdt will contain an "Initial Compliance" testing requirement to demonstrate compliance with emission limits Does the company request a control device efficiency greater than 95% fora flare or combustion device? a. If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on Inlet and outlet concentration sampling tithe company has requested a control device efficiency greater than 95%, is athermal oxidizer ar regenerative thermal oxidizer being used to achieve It? If yes, the permit will contain a condition specldying the minimum combustion chamber temperature for tie thermal oxidizer No Is the company using a thermal oxidizer AND requesting a minimum combustion chamber temperature lower than 1,400 degrees F7 If yes, the permit will contain an "Initial Compliance" testing requirement AND a permit condition specifying the minimum combustion chamber temperature for the thermal oxidizer. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point k 002 Process R 01 SCC Code VOC CO Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP Uncontrolled Pollutant Emissions Factor Control % PM10 0.000 0.0 PM2.5 8.000 0.0 SOx 0.000 0.0 NOx 0.000 0.0 33.7 98.5 0.000 0.0 4.085 98.9 4.624 99.4 1.083 99.7 2.103 99.8 0.573 98.4 0.000 98.0 Units h/MMscf h/MMscf b/MMscf h/MMscf h/MMscf h/MMscf h/MMscf b/MMsct b/MMscf b/MMscf b/MMscf h/MMsct Dehydrator Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greaterthan 2 TPY (Regulation 3, Part A, Section ll.D.1.a)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section ll.D.3)? (You have indicated that source is in the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, Nes greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.D.2(0 (Source requires a permit Colorado Regulation 7, Section XII.H 1. Is this glycol natural gas dehydrator located in the 8 -hr ozone control area oaany ozone non -attainment area or attainment/maintenance area (Reg7, Section XII.H.1 and 2)? 2. Is this glycol natural gas dehydrator located at an oil and gas exploration anrhproduction operation', natural gas compressor station, natural gas drip station or gas -processing plant (Reg7 Section 3. Is the sum of actual uncontrolled emissions of VOC from any single dehydrator or group of dehydrators at a single stationary source equal to or greater than 15 tpy (Reg 7, Section XII.H.3.6)? 4. Are actual uncontrolled emissions of VOC from the Individual glycol natural gas dehydrator equal to or greater than 1 tpy (Reg 7, Section Xll.H.3.a)? Dehydrator is subject to Regulation 7, Section XII.H Section XII.H — Emission Reductions from glycol natural gas dehydrators MACT Analysis 1. Isthe dehydrator located at an oil and natural gas production facility that meets either of the following criteria: a. A facility that processes, upgrades or stores hydrocarbon Iiquids63.760(a)(2)); OR A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final b. end user' (63.760(a)(3))? 2. Is the dehydrator located at a facility that is a major source for HAPs? IGo to MACT HH Area Source Requirement section to determine3vtACT HH applicability Yes Yes Yes 40 CFR, Part 63, Subpart MACT HH, Oil and Gas Production Facilities Area Source Requirements 1. Is the dehydrator a triethylene glycol (TEG) dehydration unit (63.760(b))2))? Exemptions 2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 3.001747 MMscf per day (63.764(e)(1)(i)? 2b. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2 lb/yr (63.764(e)(1)(ii)? 3. Is the unit located inside of a UA plus offset and UC boundary area? 'The dehy unit meets the benzene exemption Subpart A, General provisions per §63.764 (a) Table 2 §63.765 - Emissions Control Standards Do Not Apply §63.773 - Monitoring Standards Do Not Apply §63.774 - Recordkeeping §63.775 - Reporting Standards Do Not Apply Major Source Requirements 1. Does the facility have a facility -wide actual annual average natural gas throughput less than 0.65 MMscf/day AND a facility -wide actual annual average hydrocarbon liquid throughput less than 249.7 Small or Lame Dehy Determination 2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 3.001747 MMscf per day (63.761)? 2b. Are actual annual average emissions of benzene from the glycol dehydration unit process ventto the atmosphere less than 1,984.2 Ib/yr(63.761)? Small Dehy Requirements 3. Did construction of the small glycol dehydration unit commence on or before August 23, 2011(63.760(b)(1)(i)(B) and (C)? 4. For this small dehy, is a control device required to meet the BTEX emission limit given by the applicable equation? Yes 'You have indicated that this facility is not subject to Major Source requirements of MACT HH. Subpart A, General provisions per §63.764 (a) Table 2 §63.765 - Emissions Control Standards §63.773 - Monitoring §63.774 - Recordkeeping §63.775 - Reporting 40 CFR, Part 63, Subpart MACT HHH, Natural Gas Transmission and Storage Facilities 1 Is the facility wide actual annual average natural gas throughput less than 0.9994051 MMscf/day and glycol dehydrators the only HAP emission source (63.1270(f))? Small or Large Dehy Determination 2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 9.994051 MMscf per day (63.1270(b)(2))? 2b. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2 lb/yr )63.1270(b((2)(? Small Dehy Requirements 3. Did construction of the small glycol dehydration unit commence on or before August 23, 2011 (63.1270(6)(2) and (3) )? 4. For this small dehy, is a control device required to meet the BTEX emission limit (standard?) given by the applicable equation? You have indicated that this facility is not subject to MACT HHH. Subpart A, General provisions per §63.1274 (a) Table 2 §63.1275 - Emissions Control Standards §63.1281 -Control Equipment Standards §63.1283 - Inspection and Monitoring §63.1284- Recordkeeping §63.1285 -Reporting Colorado Regulation 7, Section XVII.D 1. Is the dehydrator subject to an emissions control requirement under MACT HH or HHH (Regulation 7, Section XVII.B.5)? 2. Is this dehydrator located at a transmission/storage facility? 3. Is this dehydrator located at an oil and gas exploration and production operation , natural gas compressor station or gas processing plant (Reg 7, Section XVII.D.3)? 4. Was this glycol natural gas dehydrator constructed before May 1, 2015 (Reg 7 Section XVII.D.4.b)? If constructed prior to May 1, 2015, are uncontrolled actual emissions from a single glycol natural gas dehydrator equal to or greater then 6 tons per year VOC or 2 tpy VOC if the 4a. dehydrator is located within 1,320 feet of a building unit or designated outside activity area )Reg 7, Section XVII.D.4.b)? 5. If constructed on or after May 1, 2015, are uncontrolled actual emissions from a single glycol natural gas dehydrator equal to or greater than 2tpy VOC (Regulation 7, Section`XVII.D.4.a)? !Dehydrator is subject to Regulation 7, Section XVII, 8, 0.3 Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.D.3 - Emissions Reduction Provisions Alternative Emissions Control (Optional Section) 6. Is this glycol natural gas dehydrator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? 'The control device for this dehydrator is not subject to Regulation 7, Section XVII.B.2.e Section XVII.6.2.e—Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend," may,""should,"and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and required" am intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. No No Yes Glycol Dehydrator Emissions Inventory 002 Dehydrator Facility AIRs ID: C only Plant Point Section 02- Equipment Description Details Dehydrator Information Dehydrator Type: Make: Model: Serial Number: Design Capacity: Recirculation Pump information Number of Pumps Pump Type Make: Model: Design/Max Recirculation Rate: Dehydrator Equipment Flash Tank Reboller Burner Stripping Gas Dehydrator Equipment Description Emission Control Device Description: Msrf/day gallori/minute , flash -tank, and mboiler burner One (1) Triethyiene glycol (YEG) natural gas dehydration unit (Make: TBD, Model: TBD, Serial Number: TOD) with a design capacity of 50 MMscf per day. This emissions unit Is equipped with 2 (Matte: TOD, Model: Tao) elbctric driven glycol pump with a design capacity of 10 gallons per minute. This dehydration unit is equipped with a still vent, flash tank, and reboiler burner. Emissions from the still vent are routed to an air-c®led condenser, and then to the Enclosed Flare. Emissions from the flash tank are routed directly to the Enclosed Flare. Section03 - Processing Rate Information for Emissions Estimates Primary Emissions - Dehydrator Still Vent and Flash Tank (If present) Requested Permit Limit Throughput 4V1.11,250='0''__ MMscf per year Requested Monthly Throughput= Potential to Emit)PTE) Throughput = 18,250 MMscf per year Secondary Emissions - Combustion Device(s) for Air Pollution Control Stil Vent Control Condenser. Condenser emission reduction claimed: Primary control device: Primary control device operation: Secondary control device: Secondary control device operation: Still Vent Gas Heating Valuei Still Vent Waste Gas Vent Rate: Flash -tank Control Primary contra) device: Primary control device operation: Secondary control device: Secondary control device operation: Rash Tank Gas Heating Value Flash Tank Waste Gas Vent Rate: *NOTE THAT COMBUSTION EMISSIONS ARE ACCOUNTED --- --.--- TOTAL TO COMBUSTOR • - Avg. LHV of waste gas Section 04- Emissions Factors & Methodologies Dehydrator Input Parameters Inlet Gas Pressure Inlet Gas Temperature Requested Glycol Recirculate Rate Requested Condenser Outlet Temperature: 98%I Cantrd Efficiency % VaINNORMAContri Efficiency% r/yr Btu/scf cth RY, hr/yr Btu/scf Control Efficiency % Control Efficiency % 1550 MMscf per month Dry Gas Throughput: Still Vent Primary Control: 18,250.0 MMscf/yr Still Vent Secondary Control: 0.0 MMscf/yr Waste nos Combusted: Still Vent Primary Control: 2.3 MMscf/yr Still Vent Secondary Control: 0.0 MMscf/yr Dry GasThrouehput: Rash Tank Primary Control: 18,250.0 MMscf/yr Flash Tank Secondary Control: 0.0 MMscf/yr Waste Gas Combusted: Flash Tank Primary Control: 7.9 MMscf/yr Flash Tank Secondary Control: 0.0 MMscf/yr FOR WITH POINT 011. COMBUSTION INFORMATION AND STREAM FLOW ABOVE IS FOR INFORMATIONAL PURPOSES ONLY 1,167.35 scfh -. ____._. _.-. _. .._-- -_— • .-_ .__ _-.-- 1,496.33 btu/scf gF gpm STILL VENT Control Scenario. Primary Secondary Pollutant Uncontrolled (lb/hr) Controlled (lb/hr) CenHelied (lb/hr) VOC : 40'1`382 :i ^ 0.4316 0 Benzene ,42885,;..,-r'>, 0.0932 0 Toluene iRn5?3-,u, >".o`n 0.0575 0 Ethylbenzene getaggo*s*Ai 0.006 0 %Ylene5 ^�'4`8471M;ti 0.0093 0 n -Hexane ,ii".R.eQx`?�36.: .•a` 0.0098 0 224-TMP 0003,,,, ';.5: 0.000006 0 FLASH TANK Control Scenarim Primary • Secondary Pollutant Uncontrolled (lb/hr) Controlled (lb/hr) Cantmlled (lb/hr) VOC �-a, `80.0$62.,,.„'y 0.601104 0 Benzene .p,"�'($g' 0.004558 0 Toluene ""r `.dii,2> --4` 0.003424 0 Ethylbenzene ` sfill y. 0.000478 0 Xylenes 4 "'` 0.000672 0 n -Hexane 0.009786 0 224TMP �)('U.000. -IM`,'`≥'", 0.000004 0 0.802764 0.185670 0.189242 0.044466 0.086956 0.014072 0.000006 98.9% 98.9% 99.4% 99.7% 99.8% 98.6% 98.0% 1,550.0 0.2 Glycol Dehydrator Emissions Inventory Emission Factors Glycol Dehydrator Pollutant Uncontrolled (lb/MMscf) (Dry Gas Throughput) Controlled (Ib/MMsct) (Dry Gas Throughput) VOC 33.69 0.50 Benzene Toluene 4.065472 4.623984 1.083216 2.103072 0.572592, 0.00024 0.04692384 0.02924352 0.00310944 0.00478656 0.00940128 0.0000048 Ethylbenzene Xylene n -Hexane 224 IMP Emission Factor Source Section 05 - Emissions Inventory Did operator request a buffer? Requested Buffer ("A): Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tans/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (Ibs/month) PM10 PM2.5 5Ox NOx CO VOC 0.0 0.0 0.0 0.0 0.0 0 0.0 0.0 0.0 0.0 0.0 0 0.0 '0.0 0.0 0.0 0.0 0 0.0 0.0 0.0 0.0 0.0 0 0.0 0.0 0.0 0.0 0.0 0 307.4 307.4 9.5 307.4 4.52 768 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled . Controlled (lbs/year) fibs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP • 74560 74560 858 74560 856 84388 84388 534 84388 534 19769 19769 57 19769 57 38381 '38381 87 38381 87 10450 10450 172 10450 172 4 4 0 4 0.09 Section 06- Regulatory Summery Analysis Regulation 3, Parts A, B Regulation 7, Section 0011.0,0 Regulation 7, Section XVII.8.2.e Regulation 7, Section XII.H Regulation 8, Part E, MACT Subpart NH (Area) Regulation 8, Part E, MACT Subpart NH (Major) Regulation e, Part E, MACT Subpart HHH (See regulatory applicability worksheet for detailed analysis) Source requires a permit Dehydrator is subject to Regulation 7, Section XVII, B, 0.5 The control device for this dehydrator is not subject to Regulation 7, Section XVIl.8.2.e Dehydrator is sublectto Regulation 7, Section 011.9 The dehy unit meets the benzene exemption You have indicated that this facility is not subject to Major Source requirements of MACT tiff. You have indicated that this facility is not subject to MACT FINIS. Section 07 - Initial and Periodic Sampling and Testing Requirements Was the extended wet gas sample used in the GlyCelc model/Process model site -specific and collected within a year of application submittal? If ma, the permit will contain an "Initial Compliance" testing requirement to demonstrate compliance with emission limi Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the opmbustion device based on inlet and outlet concentration sampling -... If the company has requested a control device efficiency greater than 95%, is a thermal oxidizer or regenerative thermal oxidizer being used to achieve it? If yes,the permit -will contain acondition specifying theminimumcombustion chamber temperature far the thermal oxidizer !slit company using a thermal oxidizer AND requesting a minimum combustion chamber temperature lower than 1,400 degrees F? f +» if yes, the permit will contain an "Initial Compliance" testing requirement AND a permit condition specifying the minimum combustion chamber temperature for the thermal oxidizer. No Sec09_ Section 09 - Inventory SCC Coding and Emissions Factors IA 51ys,_Notas onionSiron'lcaml',i' ,n DiCfle de -`i" ' "' ulcular d from the:. AIRS Point it 003 used to demon entsforuait Process 4 01 SCC Code es Pollutant PM10 PM2.5 50x N0x VOC CO Benzene Toluene Ethylbenzene Xylene n -Hexane Uncontrolled Emissions Factor Control % 0.000 0.0 0.000 0.0 0,000 0.000 33.7 0.000 4.085 4.624 1.083 2.103 0.573 0.0 0.0 98.5 0.0 98.9 99.4 99.7 99.8 98,4 Units b/MMscf b/MMscf b/MMscf ' b/MMscf b/MMscf. b/MMscf b/MMscf b/MMscf b/MMscf b/MMsct b/MMscf 40 CFR, Part 63, Subpart MACT HH, Off and Gas Production Facilities Area Source Requirements 1. Is the dehydrator a triethylene glycol (TEG) dehydration unit (63.760(h)(2))? Exemptions 2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 3.001747 MMscf per day (63.764(e)(1)(i)? 2b. Are actual annual average emissions of benzene from therglycol dghyd ration unit process vent to the atmosphere less than 1,984.2 lb/yr (63.764(e)(1)(ii)? 3, Is the unit located inside of a UA plus offset and UC boundary area? Yes 'The dehy unit meets the benzene exemption Subpart A, General provisions per §63.764 (a) Table 2 §63.765 - Emissions Control Standards Do Not Apply §63.773 - Monitoring Standards Do Not Apply §63.774 - Recordkeeping §63.775 - Reporting Standards Do Not Apply Major Source Requirements 1. Does the facility have a facility -wide actual annual average natural gas throughput less than 0.65 MMscf/day AND a facility -wide actual annual average hydrocarbon liquid throughput lessthan 249.7 Small or LargeDehy Determination 2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 3.001747 MMscf per day (63.761)7 2b. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2 lb/yr (63.761)? Small Dehy Requirements 3. Did construction of the small glycol dehydration unit commence cm or before August 23, 2011 (63.760(b)(1)(i)(B) and (C )? 4. For this small dehy, is a control device required to meet the BTEX emission limit given by the applicable equation? You have indicated that this facility is not subject to Major Source requirements of MALT HH. Subpart A, General provisions per §63.764 (a) Table 2 $63.765 - Emissions Control Standards §63.773 -Monitoring §63.774 - Recordkeeping 363.775 - Reporting 40 CFR, Part 63, Subpart MACT HHH, Natural Gas Transmission and Storage Facilities 1 Is the facility wide actual annual average natural gas throughput less than 0.9994051 MMscf/day and glycol dehydrators the only HAP emission source (63.1270(f))? Small or Large Dehy Determination 2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 9.994051 MMscf per day )63.1270)b))2))? 2h. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2 lb/yr (83.1270)b))2))? Small Deily Requirements 3. Did construction of the small glycol dehydration unit commence an or before August 23, 2011 )63.1270(b)(2) and (3) )? 4. For this small dehy, is a control device required to meet the BTEX emission limit (standard?) given by the applicable equation? You have indicated that this facility is not subject to MACT HHH_ Subpart A, General provisions per §63.1274 (a) Table 2 §63.1275 - Emissions Control Standards §63.1281 -Control Equipment Standards §63.1283- Inspection and Monitoring §63.1284 -Recordkeeping --- §63.1285 - Reporting - - - --- - - - Colorado Regulation 7, Section XVII.D 1. Is the dehydrator subject to an emissions control requirement under MACE HH or HHH (Regulation 7, Section XVII.B.5)? 2. Is this dehydrator located at a transmission/storage facility? 3. Is this dehydrator located at an oil and gas exploration and production operation, natural gas compressor station or gas processing plant (Reg 7, Section XVII.D.3)? 4. Was this glycol natural gas dehydrator constructed before May 1, 2015 (Reg 7 Section XVII.D.4.b)? If constructed prior to May 1, 2015, are uncontrolled actual emissions from a single glycol natural gas dehydrator equal to or greater than 6 tons per year VOC or 2 tpy VOC if the 4a. dehydrator is located within 1,320 feet of a building unit or desigeated outside activity area (Reg 7, Section Xt/II.D.4.b)? 5, If constructed on or after May 1,2015, are uncontrolled actual emissions froua a single glycol natural gas dehydrator equal to or greater than 2 tpy VOC (Regulation 7, Section XVII.D.4.a)? 'Dehydrator is subject to Regulation 7, Section XVII, B, O.3 Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.D.3 - Emissions Reduction Provisions Alternative Emissions Control (Optional Section) 6. Is this glycol natural gas dehydrator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? 'The control device for this dehydrator is not subject to Regulatjat 7, Section XVIl.B.2.e Section XVII.B.2.e —Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is note rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substituae for any law, regulation, or any otherlegally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as 'recommend,""may," "should,"and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must"and "required" are intended to describe controlling requirements under the tens of the Clean Air Act and Air Quality Control commission regulations, but this document does not establish legally binding requirements in and of itself. No No Yes Dehydrator Regulatory Analysis Worksheet Colorado Re ulation 3 PartsA and B-APEN and: Permit Re. uirements source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than SO TPY or CO emissions greatet than 10 TPY (Regulation 3, Part B, Section 11.0.3)? You have indicated that: source is In the Non -Attainment Area NON -ATTAINMENT - - -- - - -- �- - 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than lO TPY (Regulation 3, Part B, Section 11.0.2)? ISource requires a permit Colorado Regulation 7, Section XII.H 1. Is this glycol natural gas dehydrator located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area (Reg 7, Section XII.H.1 and 2)? 2. Is this glycol natural gas dehydrator located at an oil and gas exploration and production operation', natural gas compressor station, natural gas drip station or gas -processing plant (Reg 7 Section 3. Is the sum of actual uncontrolled emissions of VOC from any single dehydrator or group of dehydratorsat a single stationary source equal to or greater than 15 tpy (Reg 7, Section XII.H.3.b)? 4. Are actual uncontrolled emissions of VOC from the individual glycol natural gas dehydrator equal to or greater than 1 tpy (Reg 7, Section Xll.H.3.a)? - Dehydrator is subject to Regulation 7, Section XII.H Section XII.H Emission Reductions from glycol natural gas dehydrators MACT Analysis 1. Is the dehydrator located at an oil and natural gas production facility thatmeets either of the following criteria: a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage sourcecategory or is delivered to a final b. end user' (53.760(a((3))? 2. Is the dehydrator located at a facility that is a major source for HAPs? IGo to MACT HH Area Source Requirement section to determine MACT HH applicability Yes- Yes [Yes COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name County AIRS ID Plant AIRS ID Facility Name Rocky Mountain Midstream, LLC 123 A009 Broomfield Compressor Station History File Edit Date Ozone Status 1/8/2019 Non -Attainment NS - Uncontrolled (tons Der year EMISSIONS With Controls (tons per year POINT AIRS ID PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO I Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 18WE1160 Enclosed Combustor 0.1 0.1 0.0 2.2 0.1 4.3 0.0 0.1 0.1 0.0 2.2 0.1 4.3 0.0 New ECD controlling TEG Dehys 002 18WE1160 TEG Dehy 50 MMSCFD 307.4 113.8 4.6 0.9 New TEG 003 1BWE1160 TEG Dehy 5D MMSCFD 307.4 113.8 4.6 0.9 New TEG TBD 2500 HP RICE 0.7 0.7 12.1 30.4 78.5 6.9 0.7 0.7 12.1 14.2 5.5 1.9 Pending (source will submit once serial numbers are attained) values from APCD102 TBD 2500 HP RICE 0.7 0.7 12.1 30.4 78.5 I 6.9 0.7 0.7 12.1 14.2 5.5 1.9 Pending (source will submit once serial numbers are attained) values from APCD102 TBD 2500 HP RICE 0.7 0.7 12.1 30.4 78.5 6.9 0.7 0.7 12.1 14.2 5.5 1.9 Pending (source will submit once serial numbers are attained) values from APCD102 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Insignificants 0.100 0.100 0.0 1.3 3.81 1.1 D.100 0.100 1.3 3.8 1.1 Reboiler burners, slop oil tanks, slop loadout, FACILITY TOTAL 2.3 2.3 0.0 0.0 39.7 709.9 0.0 240.9 248.3 2.3 2.3 0.0 0.0 39.8 55.7 0.0 21.9 7.4 VOC: Syn Minor (NANSR and OP) NOx: Minor CO: Syn Minor (OP) HAPS: Syn Minor B, T, X, HCHO & Total HH: Syn Minor + affected Area ZZZZ: Syn Minor Permitted Facility Total 2.2 2.2 0.0 0.0 38.5 706.1 0.0 239.8 248.3 2.2 2.2 0.0 0.0 38.5 51.9 0.0 20.8 7.4 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 2.2 2.2 0.0 0.0 38.5 51.9 0.0 20.8 Pubcom & modeling (not) required based on (A change in emissions) Note 1 Total VOC Facility Emissions (point and fugitive) (A) Change in Total Permitted VOC emissions (point and fugitive) 55.7 Facility is eligible for GP02 because < 90 tpy Protect emissions less than 25!50 tpy 51.9 Modeling was not required on permit 18WE1160 based on the proposed emission limits for NOx for the 2500 hp RICE's (per indication from operator). Those applications are not yet submitted since APEN Unit will not accept GP02 applications with a serial number "TBD" and the applicant has not yet obtained the specific engines to be located at the faciltiy. The proposed engines have proposed NOx emission rate of 0.5 g/hp-hr. Note 2 Page 13 of 15 Printed 2/8/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Rocky Mountain Midstream, LLC County AIRS ID 123 Plant AIRS ID A009 Facility Name Broomfield Compressor Station Emissions - uncontrolled'(Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 18WE1160 Enclosed Combustor 0.0 002 18WE1160 TEG Dehy 50 MMSCFD 74560 84388 19769 38381 10450 4 113.8 003 18WE1160 TEG Dehy 50 MMSCFD 74560 84388 19769 38381 10450 4 113.8 TBD 2500 HP RICE 11105 1224 753 64 60 6 27 163 366 37 6.9 TBD 2500 HP RICE 11105 1224 753 64 60 6 27 163 366 37 6.9 TBD 2500 HP RICE 11105 1224 753 64 60 6 27 163 366 37 6.9 0.0 0.0 0.0 0.0 0.0 0.0 TOTAL (tpy) 16.7 1.8 1.1 I 74.7 84.5 19.8 38.4 10.7 0.5 0.1 0.0 0.0 248.3 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus 14 18WE1160.CP1.xlsm 2/8/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Rocky Mountain Midstream, LLC County AIRS ID 123 Plant AIRS ID A009 Facility Name Broomfield Compressor Station Emissions with controls (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein I Benzene Toluene Ethylbenzene Xylenes n -Hexane MeOH 224 TMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 18WE1160 Enclosed Combustor 0.0 002 18WE1160 TEG Dehy 50 MMSCFD 856 534 57 87 172 0 0.9 003 18WE1160 TEG Dehy 50 MMSCFD 856 534 57 87 172 0 0.9 TBD 2500 HP RICE 1110 1224 753 64 60 6 27 163 366 37 1.9 TBD 2500 HP RICE 1110 1224 753 64 60 6 27 163 366 37 1.9 TBD 2500 HP RICE 1110 1224 753 I 64 60 6 27 163 366 37 1.9 0.0,, 0.0 0.0 0.0 0.0 0.0 TOTAL (tpy) 1.7 1.8 1.1 I 1.0 0.6 0.1 0.1 0.4 0.5 0.1 0.0 0.0 7.4 15 18WE1160.CP1.xlsm 2/8/2019 h & Environment CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 1 8WE1160 Issuance: 1 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Rocky Mountain Midstream, LLC Broomfield Compressor Station 123/A009 SEC 29 T1 N R67W Weld County Natural Gas Compressor Station Equipment or activity subject to this permit: Facility Equipment AIRS Point Equipment Description Emissions Control Description ID C1 001 Enclosed combustor controlling emissions from TEG dehydrators (Points 002 Et 003). N/A D1 002 One (1) triethylene glycol (TEG) natural gas dehydration unit (make/model/serial number: TBD) with a design capacity of 50 MMscf per day. This unit is equipped with two (2) electric driven glycol pumps (make, model: TBD) with a total design capacity of 10 gallons per minute. This emissions unit is equipped with a flash tank, still vent, and reboiler burner. Emissions from the still vent are routed to an air-cooled BTEX condenser, and then to the enclosed combustor (Point 001). Emissions from the flash tank are routed directly to the enclosed combustor (Point 001). D2 003 One (1) triethylene glycol (TEG) natural gas dehydration unit (make/model/serial number: TBD) with a design capacity of 50 MMscf per day. This unit is equipped with two (2) electric driven glycol pumps (make, Emissions from the still vent are routed to an air-cooled BTEX condenser, and then to the enclosed OLORADO lotion Control Division P liC }iC ItFv P1 iron rent Page 1 of 14 gn capacity of missions unit is till vent, and combustor (Point 001). Emissions from the flash tank are routed directly to the enclosed combustor (Point 001). This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, py submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self - certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit -self -certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The following information shall be provided to the Division within fifteen (15) days of the latter of commencement of operation or issuance of this permit. • The dehydrator manufacturer name, model number and serial number • The glycol circulation pump manufacturer name and model number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation Number 3, Part B, III.E.) 6. orization letter issued by the Division, most current construction permit. This nal authority for the operation of this EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Monthly Limits: Facility Equipment ID AIRS Point Pounds per Month Emission Type PM2.5 NOX VOC CO C1 001 --- 365 --- 729 Point D1 002 --- --- 768 --- Point D2 003 --- --- 768 --- Point Note: Monthly limits are based on a 31 -day month. The owner or operator shall calculate monthly emissions based on the calendar month. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 1,359 pounds per month. Facility -wide emissions of total hazardous air pollutants shall not exceed 3,398 pounds per month. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO C1 001 --- 2.2 --- 4.3 Point D1 002 --- --- 4.6 --- Point D2 003 --- --- 4.6 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. COLORADO Air Pollution Control Division psrtolent of Public Health u Envvnnrur;t Page 3 of 14 perati , compliance with both the monthly and After e first twelve (12) months of operation, itation is -quired. plian6V'th' ` nu or cri = . and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 8. Point 002, 003: Compliance with the emission limits in this permit shall be demonstrated by running the GRI GlyCalc model version 4.0 or higher for each dehydrator on a monthly basis using the most recent extended wet gas analysis and recorded operational values for each dehydrator, including: dry gas throughput, lean glycol recirculation rate, condenser outlet temperature, flash tank temperature and pressure, wet gas inlet temperature, and wet gas inlet pressure. Recorded operational values for each dehydrator, except for gas throughput, shall be averaged on a monthly basis for input into the model and be provided to the Division upon request. 9. Point 002, 003: On a monthly basis, the owner or operator shall monitor and record operational values for each TEG dehydration unit including: condenser outlet temperature, flash tank temperature and pressure, wet gas inlet temperature, and wet gas inlet pressure. These records shall be maintained for a period of five years. 10. Point 002, 003: For each dehydrator, the condenser outlet temperature shall not exceed 125 degrees F, on a rolling twelve-month average. The owner or operator shall calculate the rolling twelve-month average temperature by averaging all recorded condenser outlet temperature values as specified in this permit. 11. --The emission points in the table below shall be operated and -maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled D1 002 Still Vent: BTEX Condenser Et Enclosed Flare VOC and HAP Flash Tank: Enclosed Flare VOC and HAP D2 003 Still Vent: BTEX Condenser Et Enclosed Flare VOC and HAP Flash Tank: Enclosed Flare VOC and HAP PROCESS LIMITATIONS AND RECORDS 12. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shalt be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) COLORADO Air Pollution Control Division r }?UN 3! 3 UlaW, Erav4rarrav ei Page 4 of 14 F ili pm t I Al g oc NParame ' ' Annual Limit Monthly Limit (31 days) C1 001 Waste gas combusted 20.45 MMscf 1.74 MMscf Pilot and Purge gas combusted 0.42 MMscf 0.04 MMscf D1 002 Dry gas throughput 18,250.00 MMscf 1,550 MMscf D2 003 Dry gas throughput 18,250.00 MMscf 1,550 MMscf The owner or operator shall monitor monthly process rates based on the calendar month. The volume of dry gas throughput shall be measured by gas meter at the outlet of the dehydrator. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 13. Points 002, 003: Each unit shall be limited to the maximum lean glycol circulation rate of 10.0 gallons per minute. The lean glycol recirculation rate shall be recorded weekly in a log maintained on site and made available to the Division for inspection upon request. Glycol recirculation rate shall be monitored by one of the following methods: assuming maximum design pump rate, using glycol flow meter(s), or recording strokes per minute and converting to circulation rate. This maximum glycol circulation rate does not preclude compliance with the optimal glycol circulation rate (Lops) provisions under MACT HH. (Reference: Regulation Number 3, Part B, II.A.4) STATE AND FEDERAL REGULATORY REQUIREMENTS 14. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 15. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.1. Et 4.) 16. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 17. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) COLORADO Air Pollution Control Division Puist_ Hf;, h & E;;virorr?krt Page 5 of 14 18.gulation Number 7, Section XII.H. The rements of Section XII and, specifically, C• r�'"` "e ring, : .ring, reporting and emission control requirements for glycol natural gas dehydrators; and • Ensure uncontrolled actual emissions of volatile organic compounds from the still vent and vent from any gas -condensate -glycol (GCG) separator (flash separator or flash tank), if present, shall be reduced by at least 90 percent on a rolling twelve-month basis through the use of a condenser or air pollution control equipment. (Regulation Number 7, Section XII.H.1.) 19. Point 001, 002, 003: The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2 General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.17; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This control device must be equipped with an operational auto -igniter upon installation of the combustion device. 20. Points 001, 002, 003: The glycol dehydration unit covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.D.3. Beginning May 1, 2015, still vents and vents from any flash separator or flash tank on a glycol natural gas dehydrator located at an oil and gas exploration and production operation, natural gas compressor station, or gas -processing plant subject to control requirements pursuant to Section XVII.D.4., shall reduce uncontrolled actual emissions _ of f hydrocarbons by at least 95% on a rolling twelve-month basis through the use of a condenser or air pollution control equipment. 21. Point 002, 003: The glycol dehydration unit at this facility is subject to National Emissions Standards for Hazardous Air Pollutants for Source Categories from Oil and Natural Gas Production Facilities, Subpart HH. This facility shall be subject to applicable area source provisions of this regulation, as stated in 40 C.F.R Part 63, Subpart A and HH. (Regulation Number 8, Part E, Subpart A and HH) COLORADO Mr Pollution Control Division ie t,Envimnrrie t Page 6 of 14 MAHH •h -quire en area Source B zene missions exemption §63.764 - General Standards §6 764 1 he owne • r operator is exempt from the requiremen s o paragrap of this section if the criteria listed in paragraph (e)(1)(i) or (ii) of this section are met, except that the records of the determination of these criteria must be maintained as required in §63.774(d)(1). §63.764 (e)(1)(ii) - The actual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere are less than 0.90 megagram per year, as determined by the procedures specified in §63.772(b)(2) of this subpart. §63.772 - Test Methods, Compliance Procedures and Compliance Demonstration §63.772(b) - Determination of glycol dehydration unit flowrate or benzene emissions. The procedures of this paragraph shall be used by an owner or operator to determine glycol dehydration unit natural gas flowrate or benzene emissions to meet the criteria for an exemption from control requirements under §63.764(e)(1). §63.772(b)(2) - The determination of actual average benzene emissions from a glycol dehydration unit shall be made using the procedures of either paragraph (b)(2)(i) or (b)(2)(ii) of this section. Emissions shall be determined either uncontrolled, or with federally enforceable controls in place. §63.772(b)(2)(i) - The owner or operator shall determine actual average benzene emissions using the model GRI-GLYCalc TM, Version 3.0 or higher, and the procedures presented in the associated GRI-GLYCalc 'Technical Reference Manual. Inputs to the model shall be representative of actual operating conditions of the glycol dehydration unit and may be determined using the procedures documented in the Gas Research Institute (GRI) report entitled "Atmospheric Rich/Lean Method for Determining Glycol Dehydrator Emissions" (GRI-95/0368.1); or §63.772(b)(2)(ii) - The owner or operator shall determine an average mass rate of benzene emissions in kilograms per hour through direct measurement using the methods in §63.772(a)(1)(i) or (ii), or an alternative method according to §63.7(f). Annual emissions in kilograms per year shall be determined by multiplying the mass rate by the number of hours the unit is operated per year. This result shall be converted to megagrams per year. COLORADO I Mr Polutian control Division p rorr. svi Publz14u,,t+s Er,ar[vimo,Ic Page 7 of 14 §6 Recordkeeping Requirements wner operator of a glycol dehydration e-xemp :•n criteria in §63.764(e)(1)(i) or hall main in the records specified in paragraph (i)ph (d)of this section, as appropriate, for that glycol dehydration unit. §63.774 (d)(1)(ii) - The actual average benzene emissions (in terms of benzene emissions per year) as determined in accordance with §63.772(b)(2). OPERATING £t MAINTENANCE REQUIREMENTS 22. Point 002, 003: Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (0EtM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 23. Point 001: The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.17) 24. Point 002, 003: The owner or operator shall complete the initial extended wet gas analysis within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit. The owner or operator shall use this analysis to calculate actual emissions, as prescribed in the Emission Limitation and Records section of this permit, to verify initial compliance with the emission limits. The owner or operator shall submit the analysis and the emission calculation results to the Division as part of the self -certification process. (Reference: Regulation Number 3, Part B, Section III.E.) 25. Point 001, 002, 003: A source initial compliance test shall be conducted to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emissions limits specified in this permit and to demonstrate a minimum destruction efficiency of 98% for volatile organic Compounds (VOC). The test shall determine the mass emission rates of VOC at the inlet and outlet of the control device, which shall be used to determine the destruction efficiency during the test. The gas throughput, lean glycol recirculation rate, supplemental fuel flow rate and condenser outlet temperature shall be monitored and recorded during the test. The source shall use the measured outlet emission rates for VOC to demonstrate compliance with the sum of the VOC emission limits specified in this permit for Point 002 and Point 003.The source shall use the measured outlet emission rates of oxides of nitrogen and carbon monoxide to demonstrate compliance with the emission limits specified in this permit for Point 001. COLORADO Air Pollution Control Division Page 8 of 14 the requirements of the Air Pollution shall be submitted to the Division for leas' hirt '(30) days prior to testing. No compliance test shall rior�r� ��,.,,from ?, vision. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time. (Regulation Number 3, Part B., Section III.G.3) Volatile Organic Compounds using EPA approved methods Oxides of Nitrogen using EPA approved methods Carbon Monoxide using EPA approved methods Periodic Testing Requirements 26. Point 002, 003: The owner or operator shall complete an extended wet gas analysis prior to the inlet of the dehydration unit on an annual basis. Results of the wet gas analysis shall be used to calculate emissions of criteria pollutants and hazardous air pollutants per this permit and be provided to the Division upon request. ADDITIONAL REQUIREMENTS 27. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. COLORADO Pollution Control Division mnert JF RAP , -..7. tic Rhee E!r:Rnnrexnt Page 9 of 14 28. 9 he red it ,� - c '` of Co j o Reg n Nu er 3, Part D shall apply at such time that s a major stationary source or major n any enforceable limitation that was ity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). GENERAL TERMS AND CONDITIONS 29. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 30. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 31. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 32. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 33. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 34. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. ?COLORADO Air Pollution Control Division -.puttr eilt G7 Public Feu€cn u E'; rear rnt nt Page 10 of 14 35. By: rovisions of the Colorado Air Pollution f the AQCC may result in administrative, Sections 25-7-115 (enforcement), -121 nal penalties), C.R.S. Bradley Eades Permit Engineer Permit History Issuance Date Description Issuance 1 This issuance Issued to Rocky Mountain Midstream, LLC COLORADO Air Pollution Control Division Dewatfrttnt of 9u€iisw Page 11 of 14 Notes it iss nce: 1) ThW perms of -r equip: t� ay f �s •r the ocessing time for this permit. An invoice fo hes ees ill is ed a r t permit issued. The permit holder shall pay the withi dad`"` ece : `'"' invoi ilure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https: //www.colorado.gov/ pacific /cdphe/ agcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Facility Equipment ID AIRS point Pollutant - CAS # _ Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) D1 002 Benzene 71432 74,560 856 Toluene 108883 84,388 534 Ethylbenzene 100414 19,769 57 Xylenes 1330207 38,381 87 n -Hexane 110543 10,450 172 2,2,4- Trimethylpentane 540841 4 <1 D2 003 Benzene 71432 74,560 856 Toluene 108883 84,388 534 Ethylbenzene 100414 19,769 57 Xylenes 1330207 38,381 87 n -Hexane 110543 10,450 172 2,2,4- Trimethylpentane 540841 4 <1 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. COLORADO Air Pollution Control Division AfaeY MEYt '7 gh.if}d Y&.Vf `t (, E'NrtYJrJ?Yt�" Page 12 of 14 sed on the following emission factors: com • ti: result from the combustion of TEG dehydrator waste gas (Point 002 Et 003), purge gas, and pilot gas. Total actual emissions are based on the sum of the emissions calculated for the combustion of dehydrator waste gas (process 01) and the combustion of purge and pilot gas (process 02). Process 01: Combustion of dehydrator waste gas (Flash tank and still vent from Point 002 Et 003) CAS # Pollutant Emission Factors Uncontrolled lb/MMscf Emission Factors Controlled lb/MMscf Source NOx 206.49 206.49 TNRCC Flare Emissions Guidance CO 412.24 412.24 Note: The uncontrolled VOC and HAP emissions from process 01 are reported with Point 002 and Point 003. NOx and CO emission factors are based on an average net heating value of 1,496 Btu/scf based on waste stream composition calculated using GRI-GlyCalc 4.0. Actual emissions are calculated by multiplying the emission factors in the table above by the total gas flow (from Point 002 and 003) routed to this combustor as calculated in the monthly GlyCalc report required in this permit. Process 02: Combustion of purge and pilot fuel CAS # Pollutant Emission Factors -- - Uncontrolled lb/MMscf Emission Factors Controlled lb/MMscf Source NOx 177.74 177.74 TNRCC Flare Emissions Guidance CO 354.84 354.84 Note: The emissions from combustion of purge and pilot fuel were calculated based on plant residue gas heating value of 1,288 btu/scf, a purge rate of 4 scf/hr, and two (2) pilots each rated at 22 scf/hr. Actual emissions are calculated by multiplying the emission factors in the table above by the purge+pilot flow to the flare based on design rate (48 scf/hr). Point 002, 003: The emission levels contained in this permit are based on information provided in the application and the GRI GlyCalc 4.0 model. Controlled emissions are based on a combustor control efficiency of 98.0%. Total actual flash tank and still vent combustion emissions are based on the sum of the emissions for the still vent and flash tank. Total combustion emissions for Points 002 and 003 are reflected in the emission calculations for Point 001. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date COLORADO Air Pollution Control Division xpartmc .t u }u -a4 Wean 6 ErNirorment Page 13 of 14 t. For any questions regarding a specific )- 7) Th per ful is t' red= iremold a valinpermit reflecting the glycol dehydration asso" . 6d :"`' de "".'= "'"` e Col .. Oil and Gas Conservation Commission rule 805b(2)(B) when applicable. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, CO, formaldehyde, benzene, toluene, ethylbenzene, xylenes, n -hexane, total HAP NANSR Synthetic Minor Source of: VOC MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Applicable NSPS OOOOa Area Source Requirements: Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http: //ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division aparF Page 14 of 14 General APEN - Form APCD-200 Air Pollutant Emission Notice (APEN) and Application for Construction Permit } }�p OCT 2 6 2U18 4 Pca) 'r All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. There may be a more specific APEN for your source (e.g. boiler, mining operations, engines, etc.). A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: IgW5l I&6 AIRS ID Number: 123 /pi,goq/ 00 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name1: Site Name: Rocky Mountain Midstream, LLC Broomfield Compressor Station Site Location: Section 29, Township 1 N, R67W Mailing (m� ude p deg 3601 Stagecoach Road, Ste. 202 Longmont, CO 80504 Portable Source N/A Home Base: Site Location WIA eld County: NAICS or SIC Code: 213112 Contact Person: Matthew Norton Phone Number: (817) 455-5799 E -Mail Address2: mnorton@discoverymidstream.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-200 - General APEN - Revision 7/2018 389456 COLORADO 1 I A•_ lrepn.mrnr o[Wb:ie iiiiii � �� xenlv.E E.vaan�en Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit II and AIRS ID] Section 2 - Requested Action ✓❑ NEW permit OR newly -reported emission source (check one below) ❑✓ STATIONARY source O PORTABLE source -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment O Change company name3 O Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership4 O Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ▪ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) ❑ APEN submittal for permit exempt/grandfathered source --Additional Info Et Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Combustor used to control emissions from dehydrator flash tank and condenser vent streams Manufacturer: Leed Model No.: EC48-2S L30-0035-000 Company equipment Identification No. (optional): For existing sources, operation began on: Cl Serial No.: TBD For new or reconstructed sources, the projected start-up date is: 2/1/2019 El Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Seasonal use percentage: Dec -Feb: Mar -May: Form APCD-200 - General APEN - Revision 7/2018 days/week weeks/year Jun -Aug: Sep -Nov: 2 1 A:COLORADO «.o Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID} Section 4 - Processing/Manufacturing Information &t Material Use El Check box if this information is not applicable to source or process From what year is the actual annual amount? Description Design Process Rate (Specify Units) Actual Annual Amount (Specify Units) Requested Annual Permit Limits (Specify Units) Material Consumption: Finished Product(s): 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.0208,-104.909 ❑ Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Operator Stack ID No Discharge Height Above Ground Level (Feet) Temp (`F) Flow Rate (ACFM Velocity he ) C1 TBD TBD TBD TBD Indicate the direction of the stack1 outlet: (check one) ❑ Upward O Horizontal O Downward ❑ Other (describe): Indicate the stack opening and size: (check one) O Upward with obstructing raincap ❑✓ Circular Interior stack diameter (inches): TBD ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): Form APCD-200 - General APEN - Revision 7/2018 3IAWo (COLORADO V =t,`;:„ Permit Number: AIRS ID Number: [Leave blank uniess APCD has already assigned a permit # and AIRS ID] Section 6 - Combustion Equipment £t Fuel Consumption Information ❑ Check box if this information is not applicable to the source (e.g. there is no fuel -burning equipment associated with this emission source) Design Input Rate (MMBTU/hr) Actual Annual Fuel Use (Specify Units) Requested Annual Permit Limits (Specify Units) 3.56 20.87 MMscf/Yr From what year is the actual annua fuel use data? Indicate the type of fuel used6: o Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/SCF) ✓❑ Field Natural Gas Heating value: 1 288 BTU/SCF ❑ Ultra Low Sulfur Diesel (assumed fuel heating value of 138,000 BTU/gallon) ❑ Propane (assumed fuel heating value of 2,300 BTU/SCF) ❑ Coal Heating value: BTU/lb Ash content: Sulfur content: ® Other (describe): TEG Dehy Vapors Heating value (give units): 1400BTU/scf flash, 1879 BTU/scf regenerator Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 If fuel heating value is different than the listed assumed value, provide this information in the "Other" field. Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ❑ Yes 0 No If yes, describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Control Equipment Description Overall Collection Efficiency Overall Control Efficiency (% reduction in emissions) TSP (PM) PM10 PM2.s SOX NO. CO VOC Other: Form APCD-200 - General APEN - Revision 7/2018 � �,≥,yiCOLORADO 4 I V©fir k MF.EF�:v" Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] From what year is the following reported actual annual emissions data? Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Pollutant Uncontrolled Emission Factor (Specify Units) Emission Factor Source (AP -42, Mfg., etc.) Actual Annual Emissions Requested Annual Permit, Emission Limit(s)5 Uncontrolled tons/ ear ( y ) Controlled? (tons/year) Uncontrolled (tons/year) Controlled (tons/year) TSP (PM) PMto PMz.s SOx Gas GomposMon/DRE 0.0001 0.0001 NOx 0.138 RG-109 2.15 2.15 co 0.276 RG-109 4.29 4.29 VOC Gas Composition/ORE 0.0909 0.0909 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Section 8 - Non -Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non -criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? ❑ Yes O No If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source: CAS Number Chemical Name Overall Control Efficiency Uncontrolled Emission Factor (Specify Units) Emission Factor Source (AP 42, Mfg., etc.) Uncontrolled Actual Emissions (lbs/year) Controlled Actual Emissions Ohs/year) 7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-200 - General APEN - Revision 7/2018 COLORADO 5 1 • V 'i=;toF No-aF�k EF Vuof11�IM�1 Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. Signature of Legally Authorized Person (not a vendor or consultant) Date • /tia14 1t.) C Aiadovk E Sc.2rvi so+r Name (print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: / /www.colorado. gov/cdphe/apcd Form APCD-200 - General APEN - Revision 7/2018 6 COLOR ADO Glycol Dehydration Unit APEN Form APCD-202 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for glycol dehydration (dehy) units only. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. ©CT 262018 Permit Number: I O'wG I I 0 AIRS ID Number: 123 /no / dam [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Rocky Mountain Midstream, LLC Site Name: Broomfield Compressor Station Site Location: Section 29, Township 1N, R67W Mailing Address: (Include Zip Code) 3601 Stagecoach Road, Ste. 202 Longmont, CO 80504 Site Location County: Weld NAICS or SIC Code: 213112 Contact Person: Matthew Norton Phone Number: (817) 455-5799 E -Mail Address': mnorton@discoverymidstream.com Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on alt documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-202 - Glycol Dehydration Unit APEN - Revision 7/2018 389457 COLORADO uep_rm!en: efHz.ic Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 O Add point to existing permit ❑ Change permit limit O Transfer of ownership4 O Other (describe below) - OR O APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ID Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info & Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Triethylene glycol dehydrator used to dehydrate natural gas Company equipment Identification No. (optional): D1 For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 2/1/2019 ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source hours/day days/week Operation: Will this equipment be operated in any NAAQS nonattainment area? Q Yes O Is this unit located at a stationary source that is considered a Major Source of (HAP) Emissions? Form APCD-202 - Glycol Dehydration Unit APEN - Revision 7/2018 O Yes a weeks/year No No COLORADO 2 f u� m«nnelPuhIC NeauT E V,IMPtnml Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Dehydration Unit Equipment Information Manufacturer: TBD Dehydrator Serial Number: TBD Model Number: TBD Reboiler Rating: 1.5 MMBTU/hr Glycol Used: ❑ Ethylene Glycol (EG) ❑ DiEthylene Glycol (DEG) El TriEthylene Glycol (TEG) Glycol Pump Drive: ❑✓ Electric O Gas If Gas, injection pump ratio: / Acfm/gpm Pump Make and Model: TBD Glycol Recirculation rate (gal/min): Lean Glycol Water Content: Max: 10 0.15 Wt.% Requested: 10 # of pumps: 2 Dehydrator Gas Throughput: Design Capacity: 50 MMSCF/day Requested5: 18250 MMSCF/year Actual: MMSCF/year Inlet Gas: Pressure: 1098 psig Temperature: 80 Water Content: Wet Gas: °F lb/MMSCF ❑� Saturated Dry gas: 7.0 lb/MMSCF Flash Tank: Pressure: 65 psig Temperature: 145 °F ❑ NA Cold Separator: Pressure: Stripping Gas: (check one) psig Temperature: °F ❑ NA ❑✓ None ❑ Flash Gas ❑ Dry Gas ❑ Nitrogen Flow Rate: scfm Additional Required Information: ✓❑ Attach a Process Flow Diagram ✓❑ Attach GRI-GLYCaIc 4.0 Input Report £t Aggregate Report (or equivalent simulation report/test results) ❑✓ Attach the extended gas analysis (including BTEX Ft n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-202 - Glycol Dehydration Unit APEN - Revision 7/2018 COLORADO 3 I °« n� Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.0208,-104.909 operator Stack ID No Discharge Height Above Ground Level (feet) ,..: . Temp ('F) Flow Rate (ACFM) Velocity (ft/sec): D1 TBD TBD TBD TBD Indicate the direction of the stack outlet: (check one) ❑✓ Upward O Horizontal O Downward ❑ Other (describe): O Upward with obstructing raincap Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): TBD ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. ❑✓ Condenser: Used for control of: Regenerator Type: BTEX Make/Model: Maximum Temp: 160 ° F Average Temp: 125 Requested Control Efficiency: 98 ❑ VRU: Used for control of: Size: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed: ❑ Combustion Device: Used for control of: Condenser Vent & Flash Gas Rating: 3.56 MMBtu/hr Type: Combustor Make/Model: Requested Control Efficiency: 98 Manufacturer Guaranteed Control Efficiency: 98 % Lead EC4B-2S L30-0035-000 Minimum Temperature: °F Waste Gas Heat Content: Btu/scf Constant Pilot Light: 0 Yes O No Pilot Burner Rating: .0497 MMBtu/hr Closed ❑ Loop System: Used for control of: Description: System Downtime: % O Other: Used for control of: Description: Requested Control Efficiency: Form APCD-202 - Glycol Dehydration Unit APEN - Revision 7/2018 COLORADO 4 H tfl, rfvlt°y4, toI Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (%reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SOX NO. CO VOC BTEX Condenser and Combustor 98% HAPs BTEX Condenser and Combustor 98% Other: From what year is the following reported actual annual emissions data? Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Nfg., etc.) Uncontrolled Emissions (tons/year) Controlled _ Emissions 6 (tons/year) Uncontrolled . Emissions (tons/year) Controlled Emissions (tons/year) PM SOx NO. CO VOC 33.69 lb/MMSCF GRI-GlyCalc 307.4475 4.5230 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions 6 (pounds/year) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-202 - Glycol Dehydration Unit APEN - Revision 7/2018 COLORADO 5 1 Mo„t.t H�al�. F fn+�l!ermn+i Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit 11 and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. C •-/ gab Signature of Legally Authorized Person (not a vendor or consultant) Date fu444) C Ac egy Name (print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance ✓❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-202 - Glycol Dehydration Unit APEN - Revision 7/2018 6 I AVCOLORADO ' t ror„,,pzt, Glycol Dehydration Unit APEN Form APCD-202 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. OCT 2 a This APEN is to be used for glycol dehydration (dehy) units only. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.Rov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: I8WElitto AIRS ID Number: 1Z3 /Aqq /663 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Rocky Mountain Midstream, LLC Site Name: Broomfield Compressor Station Site Location: Section 29, Township 1 N, R67W Mailing Address: (Include Zip Code) 3601 Stagecoach Road, Ste. 202 Longmont, CO 80504 Site Location County: Weld NAICS or SIC Code: 213112 Contact Person: Matthew Norton Phone Number: (817) 455-5799 E -Mail Address': mnorton@discoverymidstream.com Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-202 - Glycol Dehydration Unit APEN - Revision 7/2018 389453 COLORADO Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit ft and AIRS ID] Section 2 - Requested Action El NEW permit OR newly -reported emission source -OR- ❑ MODIFICATION to existing permit (check each box below that applies) o Change fuel or equipment O Change company name3 O Add point to existing permit ❑ Change permit limit O Transfer of ownership4 O Other (describe below) OR ▪ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑✓ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info & Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Triethylene glycol dehydrator used to dehydrate natural gas Company equipment Identification No. (optional): D2 For existing sources, operation began ore For new or reconstructed sources, the projected start-up date is: 2/1/2019 ✓❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: Will this equipment be operated in any NAAQS nonattainment area? hours/day days/week Is this unit located at a stationary source that is considered a Major Source of (HAP) Emissions? Form APCD-202 - Glycol Dehydration Unit APEN - Revision 7/2018 O Yes Yes O a weeks/year No No COLORADO 2 I p panic µ of Yuo Ie bean), r. EIW I!!T I!�PRI Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Dehydration Unit Equipment Information Manufacturer: TBD Dehydrator Serial Number: TBD Model Number: TBD Reboiler Rating: 1.5 MMBTU/hr Glycol Used: ❑ Ethylene Glycol (EG) ❑ DiEthylene Glycol (DEG) ❑✓ TriEthylene Glycol (TEG) Glycol Pump Drive: ❑✓ Electric O Gas If Gas, injection pump ratio: / Acfm/gpm Pump Make and Model: TBD Glycol Recirculation rate (gal/min): Lean Glycol Water Content: Max: 10 0.15 Wt.% Requested: 10 # of pumps: 2 Dehydrator Gas Throughput: Design Capacity: 50 MMSCF/day Requested5: 18250 MMSCF/year Actual: MMSCF/year Inlet Gas: Pressure: 1098 psig Temperature: Water Content:_ Wet Gas: _ _ lb/MMSCF-- El Saturated Flash Tank: Pressure: 65 psig Cold Separator: Pressure: Stripping Gas: (check one) psig ❑✓ None ❑ Flash Gas O Dry Gas ❑ Nitrogen Flow Rate: scfm Temperature: Temperature: 80 °F Dry gas: 7.Q- lb/MMSCF 145 °F ❑ NA °F O NA Additional Required Information: 9 Attach a Process Flow Diagram 9 Attach GRI-GLYCalc 4.0 Input Report a Aggregate Report (or equivalent simulation report/test results) 9 Attach the extended gas analysis (including BTEX ft n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-202 - Glycol Dehydration Unit APEN - Revision 7/2018 iCOLORADO 3 I e=+!t. F €rvvonw°rm Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit k and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.0208,-104.909 Operator . Stack ID No. Discharge Height, Above Ground Level (feet) Temp. ('F) Flow Rate (ACFM) velocity (ft/sec)' D1 TBD TBD TBD TBD Indicate the direction of the stack outlet: (check one) ❑✓ Upward O Horizontal ❑ Downward ❑ Other (describe): O Upward with obstructing raincap Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): TBD ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): O Other (describe): Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. ✓❑ Condenser: Used for control of: Regenerator Type: BTEX Maximum Temp: 160 Make/Model: °F Average Temp: 125 °F Requested Control Efficiency: 98 ❑ VRU: Used for control of: Size: Requested Control Efficiency: VRU Downtime or Bypassed: Make/Model: ❑ Combustion Device: Used for control of: Condenser Vent & Flash Gas Rating: 3.56 MMBtu/hr Type: Combustor Make/Model: Leed EC48-2S L30-0035-000 Requested Control Efficiency: 98 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: °F Waste Gas Heat Content: Btu/scf Constant Pilot Light: Yes O No Pilot Burner Rating: .0497 MMBtu/hr Closed O Loop System: Used for control of: Description: System Downtime: O Other: Used for control of: Description: Requested Control Efficiency: % Form APCD-202 - Glycol Dehydration Unit APEN - Revision 7/2018 4 I A. .COLORADO nc n,, m °nvuU k�.h I. [n°UtTmtm Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit Y and AIRS ID] Section 7 - Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (%reduction): Pollutant Description of Control Methods P Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SOX NOX CO VOC BTEX Condenser and Combustor 98% HAPs BTEX Condenser and Combustor 98% Other: From what year is the following reported actual annual emissions data? Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s) t(s) - _ Uncontrolled Basis - -- Units - Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled _- Emissions6 (tons/year) - — Uncontrolled ed Emissions (tons/year) l l Controlled Emissions (tons/year) PM SOX NO. CO VOC 33.69 Ib/MMSCF GRI-GlyCalc 307.4475 4.5230 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions6 (pounds/year) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-202 - Glycol Dehydration Unit APEN - Revision 7/2018 �COIORADO S Ay Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. C 11/47 Signature of Legally Authorized Person (not a vendor or consultant) Date c. -t -LA) A1,4tp Name (print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance ID Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-202 - Glycol Dehydration Unit APEN - Revision 7/2018 ,COLOR ADO L a' hr kcrwmoo1 Hello