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Home My WebLink About20191655COLORADO 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 April 24, 2019 Dear Sir or Madam: RECEIVED APR 2 9 2019 WELD COUNTY COMMISSIONERS On April 25, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Discovery DJ Services - Lochbuie Compressor Station. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer 1'�b��c P P,e�l.e,.>J ac.L(TP� A..O1) oc3141iSkIC A 5/C9/19 L I2ghg 2019-1655 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Discovery DJ Services - Lochbuie Compressor Station - Weld County Notice Period Begins: April 25, 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: Discovery DJ Services Facility: Lochbuie Compressor Station Oil and Gas Compressor Station Section 21 T1 N, R65W, Weld County, Colorado Weld County The proposed project or activity is as follows: Source is requesting addition of 100 MMSCF/D of dehydration capacity as well as modification of emissions profile of existing dehydration system. Also, modification of permit blowdowns and combustors controlling dehydrators. Source has been transferred from Discovery DJ Services to Rocky Mountain Midstream LLC, but is being issued to the original owner, Discovery DJ Services. 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 17WE1195 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: Christian Lesniak 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 R: Received Date: Review Start Date: Christian Lesniak 385603 7125/2518 12/5/2018„ Section 01- Facility Information Company Name: Discovery DJ Services, LLC County AIRS ID: :123 Plant AIRS ID: 9F74 Facility Name: : Discovery Lochbuie Compressor Station Physical Address/Location: County: Type of Facility: ':Natural Des. Compressor Station What industry segment? Or7&Natural Gas Production & Processing Is this facility located in a NAA0S non -attainment area? Yes If yes, for what pollutant? 0 Carbon Manmade (CO) Section 21, Township 1N, Range 65W Weld County Section 02 - Emissions Units In Permit Application Quadrant Pam'cvlate Mamer(Pm) : - ' Were (Nex a vor) Section I Township 21 iN Range 65 AIRS Paint 0 Emissions Source Type Equipment Name Emissions Control? Permit N Issuance d Self Cert Required? Ashen Engineering Remarks 008 Other(Explain) _� CR-Blowdowns No 17WE1195 2-T' Yes Permit' Modification 005 Dehydrator D-3101 Yes 17WE1195 2 Yes Permit Modification new inlet gas analysis 006 Dehydrator --D-3111 Yes 17WE1195 2 Yes Permit Modification new inlet gas analysis 015 Process Flare EC Yes , 17WE1195 2 Yes Permit Initial Issuance ECD for D-3201- & D-3211 .016. "' Dehydrator D3201.: Yes - 17WE1195 2' Yes Permit InI Issuance New Dehy 017 - - - .' Dehydrator 0-3211. Yes 17WE1195: 2 Yes Permit Initial Issuance New Dehy Section 03 - Description of Project Discovery DJ Services, LLC (Discovery) submitted a construction permit application requesting modifications to existing equipment as well as addition of new equipment at an existing synthetic minor faciltiy in Adams County (non attainment). This modification will allow compression of up to 140 M MSCED of natural gas. (an increase of 100 MMSCFD capacity). The compressed natural gas from this faciltiy is transported to Fort Lupton Gas Plant for processing. A transfer of ownership application was received for this faciltiy during processing of this modification. However, since the transfer was not processed prior to issuance, the issued permit contains the company name "Discovery DJ Services, LLC" per guidance from the Division APEN Unit The initial issuance permitted the construction of equipment providing 40 MMSCFD of compression capacity. This permit was issue di n March 2018. Per the applicant, initial startup did not keep up with compression capacity commitments which led to the need of plantexpension associated with this project. As such, each project will be treated separately for purposes of this review. The modifications as wellas new equipment being added with this project are summarized below: Discovery Is requesting to modify the following existing points: *Modification to two (2) existing 20 MMSCFD TEG Dehydration units based on updated wet gas analysis and operating parameters *Modification to compressor biowdowns to increase estimated 14 of blowdowns based on, newly added. compressors Discovery is requesting to add the following equipment: *Two (2) new 50 MMSCFD TEG Dehydration units *One (1) enclosed combustionunit for control of new TED dehydrator emissions No changes have been made to the existing flare controlling the 20 MMSCFD dehydrators. NOTE TO INSPECTORS-Theroof landings (Point 013) for the existing floating roof tanks (Point 012) have been removed per a submittal from the operator together with this application that emissions were below APEN reporting levels (1 tpy VOC). Previously, two roof landings per year were permitted. Using the calculations from the previous issuance, this source can still have one roof landing per year and stay below the APEN threshold of 1 tpy VOC. However, a second roof landing would put the emissions above 1 tpy VOC, which would require the point to be permitted, Section 04- Public Comment Requirements Is Public Comment Required? If yes,why? Requesting Synthetic Minor Permit 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. Yes 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) No Yes S02 NOx CO VOC PM2.5 PM10 TSP HAPs TI L J I 1 1 A Is this stationary source a major source? No If yes, explain what programs and which pollutants hen SO2tNOx CO VOC PM2.5 PMSO TSP HAPs Prevention V Operating Permits (PSD) , 1 1] 11[ t g I I I Title V Operating Permits (OP) � 1I I Ir Non -Attainment New Source Review (NANSR) Glycol Dehydrator Emissions Inventory 003 Dehydrator (Facility AIRs ID: *Point 003 and 004 represent a dehydration system. Each point represents a different gas to glycol contactor. The analysis below applies to each point. Section 02 - Equipment Description Details Dehydrator Information Dehydrator Type: Make: - TBD Model: TBD Serial Number: 't8D Design Capacity: 20 MMscf/day 123 9}74 • 003-004 County Plant Point Recirculation Pump Information Number of Pumps Pump Type Make: Model: Design/Max Recirculation Rate: Dehydrator Equipment Flash Tank Reboiler Burner Stripping was Dehydrator Equipment Description Emission Control Device Description: , flash tank, and reboiler burner One (1) Trietbylene glycol (TED) natural gas dehydration unit (Make: TBD, Model: TOD, Serial Number: TBD) usdth a design capacity of 20 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 reboiler burner. Emissions from the still vent are routed to an air-cooled condenser, and then to the Enclosed Flare. Emissions from the flash tank are routed directiyto the Enclosed Flare. Section 03- Processing Rate Information for Emissions Estimates Primary Emissions- Dehydrator Still Vent and Hash Tank (if present) (Requested Permit Limit Throughput= Potential to Emit (PTE) Throughput = 7,300 MMscf per year ..'7,300.00 MMscf per year Requested Monthly Throughput= 620 MMscf per month Secondary Emissions - Combustion Device(s) for Air Pollution Control Still Vent Control Condenser: Condenser emission reduction claimed: Primary control device: Primary control device operation: Secondarycsntrol device: Secondary control device operation: Still Vent Gas Heating Value: still Vent Waste Gas Vent Rate: Flash tank Control Primary control device: Primary control device operation: Secondary control device: Secondary control device operation: Flash Tank Gas Heating Value Flash Tanl, Waste Gas Vent Rate: Section 04- Emissions Factors & Methodologies Requested Condenser Outlet Temperature: ' 98% Control Efficiency% hr/yr Requested TO Temp Control Efficiency % 0 hr/yr SVS3 B. ref 2.x2 02 cciv • 125 Degrees F N/A Degrees F Dry Gas Throughput: Still Vent Primary Control: 7,300.0 MMscf/yr Still Vent Secondary Control: 0.0 MMscf/yr Waste Gas Combusted: Still Vent Primary Control: 2.4 MMscf/yr Still Vent Secondary Control: 0.0 MMscf/yr Dry Gas Throughput: Flash Tank Primary Control: 7,300.0 MMscf/yr Flash Tank Secondary Control: 0.0 MMscf/yr Waste Gas Combusted: 51.09706 Flash Tank Primary Control: 7.6 MMscf/yr 10.293 Flash Tank Secondary Control: 0.0 MMscf/yr Dehydrator . Thos rc u dGRI Giy Ic4At.o timt mission V.[gas co p Ition,presure and temperature' are based site -specific extended wages• bnF lys IIcted 0/25/00.Yhem d [w ease. nth ta'ilawing ne ameteis: Input Parameters Inlet Gas Pressure Inlet Gas Temperature Requested Glycol Recirculate Rate 1100psig 78 deg F 42 gpm STILL VENT Control Scenario Primary* Secondary Pollutant Uncontrolled (Ib)hr) Controlled (lb/hr) Controlled (ib/hr) VOC%e 154077 0.0668.,':.":;.': 0 Benzene "'"4,0115 '. Toluene "'iL2.4516 0.031 r " 0 Ethylbenzene 1'. 0.3999 0.0015 0 Xylenes -' 3.0261 0.0065 '"- 0 n -Hexane ' 0.2086 0.0038 ` 0 224-TMP ,0.0002 0.0001 • • 0 includes small emission reduction from condenser FLASH TANK Control Scenario Primary Secondary Pollutant Uncontrolled llb/hr) Controlled (lb/hr) Controlled (ib/hr) VOC - ' 12.914 " 0.2583 ' - 0.0000 Benzene =0:1097'. 0.0022 0.0000 Toluene .0,0447 -'. 0.0009 0.0000 Ethylbenzene - 0.0022. 0.0000 0,0000 Xylenes - .0.0079 0.0002 - 0.0000 n -Hexane ' 0:1465 0.0029 0.0000 224-TMP ' ', 0.0001 0.0000 0.0000 20.32 4.12 2.50 0.20 1.03 0.36 0.00 TPY VOC Cont TPY VOC 000 Vent 67.49 1.09 Flash Tank 56.56 113 Total 124.0 2.2 Glycol Dehydrator Emissions Inventory Section 05 - Emissions Inventory Did operator request a buffer? Requested Buffer (%): Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tans/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (Ibs/month) PM10 PM2.5 SOx 000 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 0 124.0 124.0 2.2 124.05 2.22 377 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) )Ibs/year) Requested Pe mit Limits Uncontrolled Controlled (Ibs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224TMP 36102 36102 604 36102 604 21868 21868 279 21868 279 1770 1770 14 1770 14 9058 9058 58 9058 _ 58 3111 3111 59 3111 59 3 3 1 3 1 Section 06 - ReeulatarySamna Analysts Regulation 3, Parts A, B Regulation 7, Section 0911.B4O Regulation 7, Section XVII.B.2.e Regulation 7, Settler Sli.H Regulation 8, Part E, MACT Subpart HH (Area) Regulation 8, Part E, MACT Subpart HH (Major) Regulation 8, Part E, MAR Subpart HHH (See regulatoryappllcabilityworksheet for detailed analysis) Source requires a permit Dehydrator is subject to Regulation 7, Section XVII, B, D.3 The control device for this dehydrator is not subject to Regulation 7, Section XV11.8.2.e Dehydrator is subject to Regulation 7, Section XI I.5 The dehy unit meets thebenzene exemption you have Indicated that this facility is not sublectto Major Source requirements of MACT HH. You have indicated that this facility is not subject to MACT HMI. Section 07 - Initial and Pedodicnampling and Testing Requirements Was the extended wetgas sample used In the GlyCalc model/Process model site -specific and colleted within a year of application submittal? 5,2 If no, the permit will contain an "Initial Compliance" testing requirement to demonstrate compliance with emission limits Does the company request a control device efficiency greater than 95% for a flare or combustion device? t: lt7 lives, 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 If the company has requested a control device efficiency greater than 95%, is a thermal oxidizer ar regenerative thermal oxidizer being used to achieve it? If yes, the permit will contain a condition specifying the minimum combustion chamber temperature for the thermal oxidizer No Is the company using a thermal oxidizer AND requesting a minimum combustion chamber temperature lower than 1,400 degrees 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. OB. Tech ,Analysis Nptes *The 'process flare controlling emissions from these dehydf t is Point 00611 is an enclosed combustor, as confirmed by applicant Since the combustor has requested control efficiency of 98%, ICP01(1 q stack testing to demonstrate a minimum VOCcl stfutction efficient,/ of98%b d on ss ons of seconds combust) outlet vOC. Allc+ ° based o s secondary combustion (e.g. NOx add'C'.0) ac<opnted for with Point 006. This 'includes secondary combustion emissions from this amine waste gas stream as well as from combustion of purge gas, pilot gas andslop tank waste gas:. Emissions calculations for Point 006 are based on the combustor capacity and thus should provide aconservatve estimate. Still vent flow- and heating value reported on this sheet are for informational purposes only. *These dehydrators (Point 003 and 004) have a unique design in that they are comprised of e single contactor tower With three (3) separate sections. Please see email received 9/6/2018 for description of dehydration unit setup. Since there is not a prescribed method for determining emissions from this unique setup, the current method of compliance demonstration and emission point allocation will be maint cried That is, the dehydrator will be treated as two separate emissions points (although there is a single flash tank and a single still vent), one for each gas -to -glycol contactor section. The emissions for each will be modeled using GlyCalc and reported separately. I asked the source to use alternatNe means (to GIRT Ic) to estimate enlist nos from the dehy and the dehydrator manufacturer (Alco) Indicated that they helieye the emissions are accurately predicted by running two Glycalc reprots and summing the results. As such, I will include an initial compllancetest that will test for outlet VOC to demonstratethat total emissions from Point 003 and Point 004 are below the sum of the emission limits for those points. This demonstration will he in addition to the requirement to demonstrate 98% destruction efficiency for VOC. A ,.,single stack. test may he used to demonstrate compliance with both requirements. '.. *Applicant evaluated emissions of H2S basedon an inlet concentration e(4:ppm. resulting emissions of H25 are below reporting thresholds and are not included in the analysis above 'I mapped the facility coordinates using US Census Bureau website and found that this facillty is not located within a UA plus offset or UC bounden/. Therefore, in the event that actual benzene emissions from this equipment exceed 0.9 Mg/yr (19841b/yr),'it would he subject. to Lopt requrementswithin MACE HA. its my determination that since the dehydration system (both Points 003 and 004) consists of a single still vent stack and flash tank stack, the total emissions from both points should he considered when determining compliance with the benzene exemption. That is, BenzneF°"mpa+Ben tier°n000a must be less than 0.9 Mg/yr Otherwise, the dehydrator would be subject to Lopt requirements In: MACT HH 'Since Issuance 1 had monthly limits in units of tons per month,'I have carried through that format and included tons per month although lb/month is standard practice. section 09 - Inventory 5CC Coding and Emissions Factors AIRS Point It 003-004 Process g 01 5CC Code Uncontrolled Pollutant Emissions Factor Control % Units PM10 0.000 0.0 b/MMscf PM2.5 0.000 0.0 b/MMscf 50x 0.000 0.0 b/MMscf NOx 0.000 0.0 b/MMscf VOC 34.0 98.2 b/MMacd CO 0.000 0.0 b/MMscf Benzene 4.945 98.3 b/MMscf Toluene 2,996 98.7 b/MMscf Ethylbenzene 0.243 99.2 b/MMscf Xylene 1.241 99.4 b/MMscf n -Hexane 0.426 981 b/MMscf 224 TMP 0.000 66.0 b/MMscf Dehydrator Regulatory Analysts Worksheet eoloone oleg I(Se' 7,3 tun e-APENend PermIs Requirements okltfierJnnnttulnmxntAr.a TISIBLE 1. Are trolled actual emissions from any criteria pollutants from this individual sours greater than 2RP? (Regulation I. Part A Section II.D.1..17 2 Are total facility uncontrolled Voe emissions greater than 5 TPY, Non greater than to Tint or CO emissions greater Man. -WY (Regulation, Parte,5ecdon IT.11.0317 au have IM..I that son. h mMe Nun-Againnient Atea NOWATTAiNENT Mrolled emissionsfrom any<dterla pollutants from this Individual source greater than 1TPY (Regulation e, Part A,Section II.D.S.ela 2. Are total facility uncontrolled VOC emissions front Me urea ter than 2TPY,RCN greater thanTPY or CO emissions greater Man 10, (Regulation 3, Pert 0, Section ISOllsre requires penult Colora00 Regulation 7, Scotian %II.H 1. Is this glycol natural gas dehydrator located In the eihr ozone contr. area °canyomne non -attainment area or attainment/ma1area (Reg Section %II.N.t and 0)? 2. Is the glycol natural gas dehydrator looted at an all and gas exploration and preductoceadons, natural gas compiessormtion, natural gas drip station or as-prmesvng plant IReg? section g. in the sum of actual uncontrolled emissions of V. from any sIngledehydrator or groupofdehydrators at a singe stationarysourte equal to or greater then 15 tpy (RenDiSection %II.H.3.hf2 4. Are acwalummntrolled emissions ofVCC from the Individual glycol natural gas dehydrator equal to anteater Man l tpy(Reg7, section%II,H.3a)? I Der. rams iomhloct Nngulntioel, g'estinn fll.? Section KILN — Emission Reducdom from glycol natural gas dehydrators Source Requires an APEN. Go to the next question Source Requires a perm) Continue - You have indicated the attainment status on the Protect Summary Sheet. Continue —You have indicated e facility type on the Profectsummary sheet Go to the next question Dehydrator is subject to Regulation 7,5pcdon)(IAD MACT Analysis 1. Is the dehydrator lootedat an oil and natural gas production facility Mat meets either°, the following criteria; lone (Cu y sre - el object toMARHH requirements. You have Indicated the source category on the Project a. A facility that processes, upgrades or stores hydrocarhon ilqulds'(s3.7611a1I3));o SummarySheet. A Iac111y that Processes, upgrades or stores natural gas prior to the point et which natural gas enters the natural gas transmission and storage source eategory or Is delivered to a final end h, user'IDD.,E.ln)lrll7 t. Is the dehydrator located at a facility that Is a malorsource for HAPoT (0,11 MAc HN Area Source R<aulrement.tion ro deter.. MALT UN eppgrebitity ea CR , Para,. Subvert MAR haat' and Gas Produce* FxlMks Area Source Requirements 1. Is the dehydrator trlethylene glycol (TCG) dehydration unit (63arolb11t)l? E%emollou Is the actual annual average noo,e0e of natural gas to the glycol dehydration unit less than 3 W1747 MMscf perday I63.TM(el111111T Are eau, annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,904,316/yr(63.7041ellll(ll)T 3, tithe unit located inside of NA plus offset and uC boundary area, (The dehy unit emwiai subpertu. General provisions per 063.764 (e)Table3 463.765-E Cislons Control Sandardsty Not Apply 463,773 -Monitoring Standards Do Not Apply 463.774-Recordkeeping 463.775 -Reporting Standards Do Not Apply lnafor Source nenetrerrante 1. Does the facility haves) faclllry+Nde actual annual average natural gas throughput less than 0.65 MMscf/day AND a fadbty-wide actual annual average hydrocarbon liquid throughput less than 240.0 mellar tereevehv Determination Is the actual annual average Rowrate of natural gas to the glycol dehydration unit less than 3.011047 MMscf perday 163,76117 ab. Are actual annual average emisslons ofbenzene from thee,' dehydration unit process vent to the atmosphere,. than 1,984.216/yr 163,7611, Smell oohs, Reoulrements a. Did construction of the small glycol dehydration unit commence on or before August 23, to11(63.76gb1111(01B) and IC IT a. For Nineman dehy, Is control device required m Teets. VEX emission limit given by the applicable equation', eD m MAcf Ds, Area source appllohnity section (Yes (Continue - You have Indicated the dehydrator type on the dehydrator Inventory sheet. You haven...that !ib Icagy it not subiecs cu SAajorsoume requirements of nand Din Su* arta, General provisions per '263.764 is) Tables 463,765- Emissions Control Standards 463.473 -Monitoring §63,474-Recordkeeping 453.77 -Reporting flO coHHH, Subpart MACE Neural Gaels...slop end storage Penalties o the facllltywldeamralannualayerago natual gas throughputless than 0.09@4pgl MMscf/day and glyaal dehydrators the only HAP emission source (62.1170(1)? smaller!** rminatioq Is Me actual annual average nowrate of benzene gas to the glycol dehydration unit less than 9.9940.51 MMscf per day 4 thor 0034.ol', 1b. wd annual average missionsofbenzenefrom the glycol dehydration unit process veal to the atmosphere less than 1,904,tib/yr(63.1E7001(21)? Small Cahn Reautremenls 3. Did construction of the small glycol dehydration unit commence before Du(63.127o(b)yland1311T 4. Far thlssmall doh, is. control device required to meet theMXmission fruit(standard?) given by the applicable equation, (You hate itniicatedthet this facility... nub)aa to MAmtoN. Subpart A, General provisions per 463.12741e1 Table 40.[275- Emissions Control standards 463 trot Equipment standards 463 - Montm g 4631aa4 -RecordMerang 463,11,15-Reporting 1 colerade emulation 7. Seaon %VII.° 1. is the dehydrator subject to an emisslona control requirement under MAR HO or HHH Mann.. 7. Section %VII.0,5), 2. Is this dehydrator located at transmission/storage facility, 3. ts this dehydrator located elan ell and gas exploration and production operation, natural gasrnmpresSerstayonar gas pacessilgpian, WO, seD1lon%VII.D.31? 4. Wes this glycol natural gas dehydrator constructed before May1,20ls(Reg 7Setion%NI.O.4.hlt If constructed prior m May 1, 2015,ere uncontrolled actual emissionsfmm a single glycol natural gas dehydrator equal tooraeaor Man 6 tom peryearV0C or tpy VGC If the a. dehydrator's located within 0720(eetole building unitordesieated outside ***area IReg J. Section%tII.0.Ablf 5, If constructed on°rafter May 1,t015, are uncontrolled actual emissions from a :Ingle glycol natural gas dehydrator egos, to agree., than qsy UDC (Regulation 7,smnon xvll.l.4.a1? ICeltdramr is whim, to Ilegulatiun T.sectloll XVII, 2,00 anion%VII.B -General Provisions Mr Air Pollution Control tquip rat and Prevention of Emissions ***Wilma- Emit** **Won Provislo,e alternatMe emissions Conue'optional oat 6. ISMlsalycol natural as dehydmt,stormntrolled by a beck -up or alternate combuMon*Mee ll.e., not the pat* ronualdevleel MM. not erdomal IT* rented devka for this dehydrator isnrn suhlottt0Requladen T, 3milon 07llA.2e Section %VII.B.2.e-Alternative emissions **el equipment Claclolmer This douumen000eI01s operators will determiningeppecablely of certain requbementsollea Clean AIrAd its ImplemenlIng regulations, amine Quality Goebel Comisson regulations. Mis rbwmenlls not a rule or regulation, endeteenelysls generalns=plot apply to a perecuorsiElation based upon the individual facts are: cerumstencee This document does not change or substiletelorany law, regulation, or any oguelePaltybinning requirement and is not legally enrorcealee, In Die eventof any Gongicdbetween the language orgrls document and the language olfhe Clean Aired,. Its Implement g regulations, end An Quality Conbol Commisson regulations, the language Of Ilia 210171, or regulation will coned. Meuse of non -mandatory language such as "recommend,'Inay,"'sllovld,"and tan,"Is Intended to describe APCO Interpretations and recommendetons. Mandatory terminology such as "inuel"and "monied" are blo7dadlo describe canlmliteg requlremeels undergle terms°,ihe clean AlrAnt end Air DuagfyConlol Commission regulations. but gee document does not establish lae011ybk.(' requirements In and ollleell. ffo No Yes go to me next question The dehy unit meets Me benzene The **Is sulgt to the Loot mregmaments in 63.7.(d)(t) Continue - You have previously Indicated this In the MAC-isecann ContinueYou have previously Indicated this in the beginning of the MARseaon Continue -You have previously Indicated this in the Reg 7, section Xll detemdmtion So to questIon 5 Source Is subject Section 01 -Administrative Information Facility AIRS ID: County Plant Point Section 02- Equipment Description Details. This source vents natural gas from: 7 compressors vented to the atmosphere Emissions from this source are: Natural gas venting from 7 compressors during maintenance blowdown events (Point 001) and rod packing. Emissions from this source are vented to the atmosphere. Section 03 - Processing Rate Information for Emissions Estimates Emission Calculation Method EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3) Ex=Q*MW`Xx/C Ex= emissions of pollutant x Q = Volumetric flow rate/volume of gas processed MW = Molecular weight of gas = SG of gas * MW of air Xx = massfraction of x in gas C = molar volume of ideal gas (379 scf/Ib-mol) at 60F and 1 atm No of compressors: volume per compressors 1-3 volume per compressor 4: volume per compressors 5-7: No. events per compressor: Total No. of events: TOTAL VOLUME VENTED: 0.3132 MMSCF/yr 7 4.2 MSCF 3 MSCF 3.5 MSCF 12 84 Section 04- Emissions Factors & Methodologies MW Weight % Helium CO2 ,,. *:-3.74 N2 °„x9;6`0': methane x314. ethane propane 18: 0 isobutane ..'1 n -butane _-" --≥ 2i1z28 isopentane =221 n -pentane cyclopentane 'Y D.23. n -Hexane 4:40.'54 cyclohexane Other hexanes heptanes r`1:� :sW�a41,$�S: methylcyclohexane5`��'i`~S=71fi 224-TMP"n{ft10 Benzene .'."'0.12' Toluene ..5.07 Ethylbenzene '::: t0.01'. Xylenes C8+ Heavies a. ;5.54'.. Total VOC Wt % 100.0 41.44 Ib/Ib-mol Notes MW, and mass fractions from extended gas analysis of inlet gas (collected 4/2/18). Emissions are based on 8760 hours of operation per year. This volume is derived from piping and instrumentation diagrams of the compressors. 17WE1195.CP2.xlsm Section 01- Administrative Information Emissions Summary Section 05- Emissions nventory 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 (Ibs/month) PM10 PM2.5 sox NOx VOC CO 0.00 0.00 0.00 0.00 0.00 0 0.00 0.00 0.00 0.00 0.00 0 0.00 0.00 0.00 0.00 0,00 0 0.00 0.00 0.00 0.00 0.00 0 0.00 0.00 0.00 ' 4.53 4.53 770 0.00 0.00 0.00 0.00 0:00 0 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions( Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TM 0 0 0 27 27 0 0 0 16 16 0 0 0 1 1 0 0 0 5 5 _ 0 0 0 129 129 0 0 0 0 0 Section 06 - Regulatory Summary Analysis AQCC Regulation 2 Section I.A applies to all emission sources. "No person, wherever located, shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7) or more volumes of odor free air." Section 08 - Technical Analysis Notes i 17WE1195.CP2.xlsm Separator Venting Emissions Inventory 011 Separator Venting Facility AIRs ID: .,123 9F74 011 County Plant Point Section 02- Equipment Description Details Detailed Emissions Unit Description: Enclosed combustor used to control eniissionsfrom two (2) 50 MMSCFD TEG Dehydrators (Point 015 and Point 017). Enclosed combustor Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency%: Limited Process Parameter Gas meter Section 03- Processing Rate Information for Emissions Estimates • Primary Emissions - Combustion of dehydrator waste gas Pilot burners (2 @ 22scfh each) 44.00 soft: Purge Gas 4.00 scfh 48.00 seth Pilot+ Purge 0.42 MMscf per year 5,833.00 scfh Process/Waste Gas 51.10 MMscf per year TOTAL(Pilot+purge+waste) -=;-5,881.00 scfh Fuel (pilot and purge) HHV ,1,130.00 btq/scf Waste Gas HHV 1500 btu/scf MMscf per year 98 098% control of VOC and HAP combusted by this equipment is requested.However, this point only accounts for secondary combustion emissions of NOx and CO. Requested Permit Limit Throughput =351:52 MMscf per year Requested Monthly Throughput= 4.38 MMscf per month Potential to Emit (PTE) Throughput = Section 04 - Emissions Factors & Methodologies Description Emissions attributed to this equipment includes combustion emissions of NOx, CO, PM, SO2 associated with combustion of waste gas front TEG dehydrators associated. with Point 016 and Point 01'1 as welt as pilot and purge gas used for proper operation of the combustor. Emissions of VOC associated with uncombusted VOC in the dehydrator streams are accounted for with Point 016 and Point 017. Emissions of VOC reported below are only those assoicated with thecombustion of purge gas and pilot gas. 51.52 MMscf per year s 01: COmn67r'6E1`nRsa 5fi➢ Vent and Flash tom Point QS6(&tWhfffl7 !` Pollutant Primary Control Device Emission Factor Source Uncontrolled Uncontrolled (Ib/MMBtu) lb/MMscf (Waste Heat Combusted) (Gas Throughput) PM10 .'0.0075 ;r`- 11.176 ,�`"AP-42 Table 1.4-2(PM10/PM.25) of AP -42 Labia 1.4-2, P AP -42 Tabfe 1.4-2 PS .=42 Chapter 13.5 industrial Flares (NOx) AP -42 Chapter 13.5 Industrial tares (CO) PM2.5 0.0075 : ' 11.176 SOx 0.0006.. 0.882 NOx -0.0680 ' - 102.000 CO ;:0.3100 - : " 44465.000 Process 02: Combustion of pilotand purge fue4.,..,..:-,' _ =" :• ':'= Pollutant Primary Control Device Emission Factor Source Uncontrolled Uncontrolled (Ib/MMBtu) lb/MMscf (Waste Heat Combusted) (Gas Throughput) PM10 0.0075 8.420 AP e= AP -42 Table 1,&2 (PM10/PM.2.5) -42 Table 1.4-2iPM10!..n 2.5) '"Ta,,'-se T es(NO' �` PM2.5 0.0075 8.420 SOx 0.0006 0.665 NOx 0.0680 : 76.849 CO 0.3100 VOC -.0.0054 ''' 6.093 7 of 12 K:\PA\2017\ 17WE1195.CP2.xlsm 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 0.29 0.00 D.00 0.29 0.29 49 0.29 0.00 0.00 0.29 0.29 49 0.02 0.00 0.00 0.02 0.02 4 2.62 0.00 0.00 2.62 2.62 445 0.00 0.00 0.00 0.00 0.00 0 11.95 0.00 0.00 11.95 11.95 2030 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 XVII.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 GlyCa lc 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 • *VOC and HAP is not.included w th colt i atrons above because the VOC emissions associated with the amine tin point 012 and w rueuse 1' a c-ewa e aS om flou+i rate0se� o`tatculate emissions is based an the design capacity of the combustorwhen combystmgva `go rsy✓it a pat content of 15Q0 Btufscf Typically `j₹re waste gassom is estnmated based on the simulation used to estimate emissions from the source of emissions, in thiscase the TEG Dehydrators (point 012 and 013). However, the operator's estimated waste gas flow rate and he FF results in a conservative` estimate when compared to the information obtained from the GlyCalc simulation used to estiwateTEit dehydrator emissions For comparative pu-poses, the waste gas flow rate and he the GI Calcsl ul t o 'ay r fenenced0 the anal sins sheets for Point 012-013. . T.,1�.. �w,..,� �s � �� y Section 09- Inventory SCC Coding and Emissions Factors AIRS Point 011 mbustor that is used to control the still vent and flash to mal oxidizer is capable of achieving a 98% destruction eft' Process I* SCC Code 01 3-10-002-16 Flares Combusting Gases <1000 BTU/scf 01 3-10-002-16 Flares Combusting Gases <1000 BTU/scf The processes above are as follow: (i) 01- Combustion of still vent and flash tank waste gas, (ii) 02 - Combustion of pilot fuel. 1.2 0131 Since"`this control value is greater than the standard 95f cal .when controlling still vent and flash tank emissions from the dehyd Uncontrolled Emissions Pollutant Factor Control % Units PM10 11.18 0% Ib/MMSCF PM2.5 11.18 0% Ib/MMSCF SOx 0.88 0% Ib/MMSff N0x 102.00 0% Ib/MMSCF CO 465.00 0% Ib/MM5CF VOC 0.00 98% Ib/MMSCF PM10 8.42 PM2.5 8.42 SOx 0.66 NOx 76.84 CO 350.30 VOC 6.09 0% Ib/MMSCF 0% Ib/MMSCF 0% Ib/MMSCF 0% Ib/MMSCF 0% Ib/MMSCF 0% Ib/MMSCF 8 of 12 K:\PA\2017\17 W E1195.CP2.xlsm Separator Venting Regulatory Analysts Worksheet Colorado Re, ulatlan3 Parts Aand B -APE( and PermN Requiremems 15e rcelsfettlenon-Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants Con Ohiel lobuleource greater than 2 TM' (Regulation 3, Part A, Section ll.B.l.ali 2. Are total facility uncontrolled VOL emuslons greater than 5TPY, NOt'treater than lorry or CO emissions greater than lorry (Regulation 3, Part B,Section Il.g.3)1 Not enough information NON -ATTAINMENT 1. Are uncontrolled emissions Pore any Nterla pollutants from this Individual source greaterthanlTPY (Regulation 3,PartA, Section Il.0.1.a)P 2. Are total facility uncontrolled VC<emssions from the greater than 2TPY, NOR greaterthan 5TPY or CO emissions (peeler than sOTPh (Regulation 3, Part B,Secton ILo.21i Isource renyU moo Penn it Colorado Reculrtlnn T, 5ectlon mAI 1. Noes this combustor control any equipment subject to Regulation 7,Sectlon XVII? ISaurcc Is subject. Reputation 7, Section XVII.B.2 SeNon %111.8.2 —General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVI I.G - Emissions Control Disclaimer • This document assists operetots with determining appficabifityof certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not rule or regulation, and the analysis It contains may net apply to a particular situation based upon the individual facts end circumstances. This document does not change ar 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 thelanguage of the Clean AirAct„ its Implementing regulations, end 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 APCO Interpretation and recommendations. Mandatory terminology such as'musf and"requlred" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legalh, binding requirements in and of itself. Source Pequta an APEM. Go to the nestquestion source Requires a Mo. Q€ Source Is subject, go to next question Glycol Dehydrator Emissions Inventory 012 Dehydrator 'Facility Allis ID: 123 County SETA,: ` :. ' 012-019 Plant Point ',Point 012 and 013 represent two (2) distinct dehydration units. Each dehydrator has identical proposed operating conditions and processing rate.The analysis below applies to each point. Section 02- Equipment Description Details Dehydrator Information Dehydrator Type: Make: Model: Serial Number: Design Capacity:„,': '. `50"' : :'y:. ''"` MMscf/day Recirculation Pump information Number of Pumps Pump Type Make: Model: Design/Max Recirculation Rate: Dehydrator Equipment Flash Tank Reboller Bumer Stripping Gas Dehydrator Equipment Description Emission Control Device Description: TBD TBD TBD DO ' gallons/minute , flash tank, and reboiler burner One (1) Triethylene glycol (TEG) natural gas dehydration unit (Make: TBD, Model: TBD, Serial Number: TOD) with a design capacity of S0 MMscf per day. This emissions unit is equipped with 2 (Make: TOO, Model: TBD) electric driven glycol pump with a design capacity of 10 gallons per minute. This dehydration unit is equipped with a still vent, flesh tank, and reboiler burner. Emissions from the still vent are routed to an air-cooled condenser, and then to the Enclosed Flare. Emissions from the flash tank are routed 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= Potential to Emit (PTE) Throughput= 18,250 MMscf per year ,250,0 `" MMscf per year Requested Monthly Throughput= 1550 MMscf per month Secondary Emissions -Combustion Device(s) for Air Pallutlon 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: Flash tank Control Primary control device: - Primary control device operation: 8768 hr/yr Secondary control device: . Control Efficiency% Secondary control device operation: 0 hr/yr Flash Tank Gas Heating Value 1413.33 Btu/scf Flash Tank Waste Gas Vent Rate: 887.00' 99th °NOTE THAT COMBUSTION EMISSIONS ARE ACCOUNTED FOR WITH POINT 015. COMBUSTION INFORMATION AND STREAM FLOW ABOVE IS FOR INFORMATIONAL PURPOSES ONLY TOTAL TO COMBUSTOR 1,164.00 scfh Avg. HHV of waste gas 1,551.22 btu/scf Section 04- Emissions Factors & Methodologies Requested Condenser Outlet Temperature: 68% Control Efficiency % 8760 hr/yr Requested TO Temp Control Efficiency % hr/yr 1993- Btu/sef 277.00 scfh 125 Degrees F N/A 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: 2.4 MMscf/yr Still Vent Secondary Control: o.o MMscf/yr Dehydrator k:e5rg IfreeetlrCe� 8% Control Efficiency% GRTG19 ai 41ta stlmate eiufs ons.Wetgas raposii:on, pressure and temperature are based n site -specific emended wet gas c a a$1/27/18,tfienrtodelwas basedenthe following parameters: Input Parameters Inlet Gas Pressure Inlet Gas Temperature Requested Glycol Recirculate Rate 65 psig '145 r' degF 10 gpm STILL VENT Control Scenario Primary Secondary Pollutant Uncontrolled (lb/hr) Controlled (lb/hr) Controlled )Ib/hr) VOC Benzene '-' 9.56 0.16 -' 0.00 Toluene '.' 3.84 0.07 - 0,00 Ethylbenzene --.n 0.48 0.00..:....:: 0.00 XYlenes 2.45- -r' - - '." 0.00 4...,.,."... "'. 0.00 .'" n -Hexane 0.50 , 0.01"s '" 224-TMP '0.00 0'.00 - - 0.00 FLASH TANK Control Scenario Primary Secondary Pollutant Uncontrolled (lb/hr) Controlled llb/hr) Controlled (lb/hr) HOC 0:61 ':' °--' 0.00 Benzene 0.26. 9:01 "' 0.00 Toluene 0.31 - 0.00:: 0.00 -• Ethylbenzene 0.01. , ` 0.00., , 0.00 t' Xylenas ,t..•'' 0,02 -' :B:Do i.'r n -Hexane :.:0.35 0:01 224-TMP ="0.00 0.00 0.00 67.41 9.82 5.95 0.48 2.47 0.84 5.00 Emission Factors Glycol Dehydrator Pollutant Uncontrolled Controlled (lb/MMscf) )Ib/MMscf) (Dry Gas Throughput) (Dry Gas Throughput) Emission Factor Source VOC 32.36 0.58 Benzene Toluene 9.714272 0.0788304 2.855196 0.0964464 0.23112 0.00177792 L18344 0.00766944 0.40536 0.00766656 0.000336 0,00005088 Ethylbenzene Xylene n -Hexane 224 TMP Dry Gas Throughput: Flash Tank Primary Control: 18,250.0 MMscf/yr Flash Tank Secondary Control: 0.0 MMscf/yr Waste Gas Combusted: Flash Tank Primary Control: 7.8 MMscf/yr Flash Tank Secondary Control: 0.0 MMscf/yr Glycol Dehydrator Emissions Inventory Section 05 - Emissions Inventory Did operator request a buffer? Requested Buffer(%): Criteria Pollutants Potential to Emit Uncontrolled (tons/year? Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/Year) • Requested Monthly Limits Controlled (Ibs/month) PM10 PM2.5 SOx NOx Co VOC 0.0 0.0 0.0 0.0 0.0 0 0.0 0.0 0.0 0.0 0.0 0 0.0 0.0 0.0 0.0 0.0 0 0.0 0.0 0.0 0.0 0.0 0 0.0 0.0 0.0 0.0 0.0 0 295.3 295.3 5.3 295.3 5.29 898 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (Ibs/year) Requested Pe mit Limits Uncontrolled Controlled (Ibs/year) (Ibs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 86035 86035 1439 86035 1439 _ 52106 52106 665 52106 665 4218 , 4218 32 4218 32 21598 21598 140 21598 140 7398 7398 140 7398 140 6 6 1 6 1 Section 06- Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XVII.B,D Regulation 7, Section XVII.B.2.e Regulation 7, Section XII.H Regulation 8, Part E, MAR Subpart HH (Area) Regulation 8, Part E, MACE Subpart HH. (Major) Regulation 8, Part E, MAR Subpart Hoy (See regulatory applicability worksheet for detailed analysis) 43.02 26.05 2.11 10.80 3.70 0.00 0.72 0.33 0.02 0.07 0.07 0.00 Source requires a permit Dehydrator is subject to Regulation 7, Section XVII, 0, 0.3 The control device for this dehydrator Is not subject to Regulation 7, Session XVII.B.2.e Dehydrator is subjectto Regulation 7, Section 011.6 The dehy unit meets the benaene exemption You have indicated that this fadlityis not subject to Major Source requirements of MACE HH. You have Indicated that this facility u not subject to MACE HHH. Section 07 - Initial and Periodic Sampling and Testing Requirements Was the extended wet gas sample used in the GlyCalc model/Process model site -specific and colleted within a year of application submittal? if no, the permit will contain en "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? 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 lithe 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 a condition specifying the minimum combustion chamber temperature for the thermal oxidizer Is the company using a thermal oxidizer AND requesting a minimum combustion chamber temperature lower than 1,400 degrees F? qp 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 Section 08 -Technical Analysis Notes *Applicant indicated via email. on 11/1/18 that this dehydrator is of a traditional glycol dehyra+ion unit design (compared to design for Point 003 and 004) here o a single gas to glycol contactor wish a s gale flash tank and single still vent for each Point 012 and Point 01i0., 1 contactor, l fl -ash tank, 1 still vent per dehydrator) *Applicant evaluated emissions of H25 based on an inlet concentration of 4 ppm. resulting emissions of 1123 are below reporting thresholds and are not Included in the analysis above. *The combustor controlling emissions from these dehydrators is Point 011. It is an enclosed combustor, firmed by appi'icant. Since the combustor has a coquetted control efficiency of 90%, it will require initial stack testing to demonstrate a mini mum VOC destruction efficiency of 98% based on inlet vs outlet VOC All emissinsof secondary combustor emissions (e.g. NOx and CO) are accounted for Nth Point Oft Thisncludes secondary combutton emissions from this amine waste gas troarn as well as from combuston of purge gas and pilot ga,.Emissions catrlatIon, for Point 011 are based 0'1 tilf CO mbustor capacity and th. should provide conservative est(mate Stn vent flaw and heating value on this sheet are foriinformational purposes only. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 012-013 Process# SCC Code 01 Uncontrolled Pollutant Emissions Factor Control % PM10 0.000 PM2.5 0.000 Sox 0.000 N0x 0.000 VOC 32.4 CO 0.000 Benzene 4.714 Toluene 2.855 Ethylbenzene 0.281 Xylene 1.183 n -Hexane 0.405 0.0 0.0 0.0 0.0 98.2 0.0 98.3 98.7 99.2 99.4 98.1 Units b/MMscf b/MMscf b/MMsef b/MMscf b/MMscf b/MMsef b/MMsdf b/MMscf b/MMscf b/MMsef b/MMsef Dehydrator RegUM-WryAnalysis Worksheet rulaaae ev r7====-""-' 1. Are actual emtsslons from any,terra pollutants fromtnns rna,waual source greaterthan zew{Regulation a,Part T,5etrenlhoa.al? I. Are TTv(Regulation 3, Pa., Seaton ll.rsfal? =Y'. rte Rquraan TPEN. Gomt 1. .total uncontrolled VOL eminlons bona a grearertbatnxirr,axa greater than s tPl'orra emlsslona greater tnansomv[Regulation s, Part e,xelonll.oal? : q yes pmnrt ImsecewgNre.arormrt Is glycol natural gas dehydrator tone control area oranyozonenon-aaa.rnentarea or attammentimaIntenana area illeg 511? s ghoul natural gas dehydnturl n looted an eepinnaun anti production n t nadant(Reg� n a. is the surn of actual uncontrolled eross4ans of WC, rorn dehyrat dernyaamrs ss.C. ttanl. py eg seeia,xll.xab) 4. Area h uadyco natural gas dehg varatorwtto orgreater than 3twlax gT,emnxll.Nara1? 1442 Eedlon M11.1.1-MIsslon Reductions,rom ehaol natural gas dehydrators MARAnalysis 1. Is dehydatorlpa a o a natural get faalrty to nng3Irena. Ivy a. facility[batpromaesupgnaa orsores hydrocarbon((colas' 13.8.01211; Ggllw fadllrytbat pmmsa,upgraaes orstores natural gas odor to the pout atwhm natural gas enteameremalgae[nmmlssmnrdaeragesourcecategorvorgdellvenetlmafnal a. 14115de ydamrlwl5d41e,fa4ad t I I HAP Continue -You havelock.. the act t. continue you hae,ndnareatbe facaaytype on the project wmmarvueets w Dehydrator Is sublea to Rqulatron a, xll.N 'Continue -em,rceasubeamMAR H41 reeu1,4tie,is.vouhavelntlicatetlmesource category onthe Proje65ummarvsh87. Ga to MAR HI Area source apdra ntm„ect3n dehwat ran tdetmlene Alyce fiE41ad,Wntwn unit 1,3.76D.1121,1,namntnm 2b. Are al annual aver enelrom egncnl dehydration unnprocess vent totheatmaplerelean than sse4x'.IWyr(6316410111R11? 3. Istneunit lnntedtnndeofa urspwaoffset and uemendaroard? I yna (Continue-Youmyeinatnteatneaehvdratertvpeenthe denyatorlmemonaheet. and oroOns pergaa.>a4 414 g4x�55 emrssbns control standards 0o Not apply* §a3.?n - Monbodng Standards Go Nat Apply ?53.774-Ranmueep,ng §53.775-Repomnestandards ooNot An* 1. Dm the faAlty haxafadl4ywide actual annual average natural gas throughput lesstnan pus rtmssf/day MO famnymdeaaual annual average hydromqthroughput less than ma oriarn De. 0anm,imtlon 23. cal annual average Sown. of natural gas to Omghcol dd,ydnt ay(e 551? xb. Are actual annual avenge emisaons ofbenaenefrom the glycol aebydratfon unit process vent. the ratio ohere lets than1ya5.x.W..?511? 3. Dfcl dehydration umt commence on orM 011243.r501b111glIf4l and eel? 4. ro-this smadllxM, n a control Jerre repul,eim meet the 53Ex emisslunl ever, M theapdicade eouatlon? INou4244,4 2/440840 If 42444? XII, Subpart, General prwbrona per 481744(0 RMe0 P3.365-Emrzsmns Corona( Standards 483.745-Rco4kapine 48..775-544.44 1 Is the facility widea ctual annual average natural gas throughput less<ban 44394051 R4msR/davard4NWaehydra<ornthe only NAP emlssfonmurcele1443114? 2a. Is the actual annual average rlowrate of natural ea xto or Vont Deily DetannInat. =glycol dehydration day le web/Rll7 20. Are actual cal averageemsnons ofbenze,e from thegM1edaehydation unit process sent to the atmosphere less than 1,354al4ryr154.44741411411? Dehv Requirements ofthesmall §had dehydration met commence on cbefor4Augunv, DDTle31774Ib1Rl smite) it 4. rank: small 44h, fs a control derv. required toi 114441E4418 414nllmnlstandard?l elren by<heapd134145quahad subpar,,,General provisions per 441.1274 (arable ?5315-Emisslons Control Standards 453.1326famrol Eourpment standards 463.13®-Inspmron and Muntodng 453.12.4-ReoNRapme 453.1x88 -Reporting 1. Is Ole aebyaralorsugettu an eembslons control reiuIremen under MAR NH or HIIx(Reg„1ado,?,Eaiooxn15141? 3. !stiffs debydratorlocated at a tammission/stoageladlih? 3. Is tbls dehydrator Bated at an dl and 4saploanon and production opera.,, na12,514 04mpresastadone1 ga. vraaessingelan<IRegy, sacnanxvll.o31? 4. Was <blagh*i a!coated debdmorco, u/83574ettlpnx2R.0.42R e glycol dahyarat qualmorx,4a<7Gun 5 tons peryearw[ or4tpy 10[HMe dehydrato`414 1edvdtab1e=ax07051nas34e[ngun Drag4 1erlou fdel.n1Mm,8Nm«?`saalpnxvR.o.n.b1? s. Ifcoduet actual emsnomfrom a s,ngleglycol natural eaadefWalorepua1 tow areaterlbanlrw1041Regdarcan?.sealon,Wu.o.451? IDeb,,drotor4 51414 Raaulationo. S axon xvn.5.0.8 SectIon.,11.3 -General Provisions. rPolWaon control EqurpmentaM Prevent., Emhslms tool 5. Is.sgrycol natural gas dehydratcontrolledbra back, oraltematecomb.tioncep.e.,ncet p a nmiauaeltnaxis notenacdx I'M on?. Settbn4111152> Disclaimer This document assists operators isith applicability e/ certainrtgp.ements of the Clean Ah Act Psireplemerding regulations, and .440uality Control Ccennessen it regulations. This document Is 774 ml a rule a -regulation. and the rimy?/? 4 contains may not apply Ica -a 44171 Nrs2uatbn based upon fheiMivitlualhets anst s. This documanl does not cbange w subsl2u@ hva141ew, regulaflo4 or anyagie-legaly binding requirement and is no legalyenlorze4N#. In 412 Nanycomm�lheaveen the language of this document and lira langua3nf(he ekan 4141/. Hsimplamenhy regulatipru. arN.a40ualitycaibol event ammisson regulations the language of Ioe statN4 orreguhwn milconhol: The use of nommen .language such as'recommen 2 `mey'tshauld' and toms; Is Mar., descrem APCO lnterpetations a.reconcileMa...Stan., terminology such as "mush and limp ,are nemdeibaesmbe uon.Mh requirements uncle - the (emu of.Clean Air Act and a40ualfy Can. Commission regule.s, but this document sloes reef establish legally binding my... m and of Melt: No No Dusk Inaiatathie In me440R.xtla, nnue avea,dwou4Il444ydtnts lntbebaginningvf[ne MARsepl4, 2.0 havep1awomh 14414844 this In the Rag ?, Section wl determination Go to nuestIon 5 ,a is schlep Permit number: Date issued: Issued to: COLORADO Air Pollution Control Division Department of Public Health & Environment CONSTRUCTION PERMIT 17WE1195 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 2 Discovery DJ Services LLC Discovery Lochbuie Compressor and Pump Station 123/9F74 SEC 21 T1 N R65WE Weld County Natural Gas Compressor Station and Crude Oil Storage Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description C-210 001 One (1) Caterpillar, G3606 A4, SN: TBD, natural gas - fired, Turbocharged aspiration, 4SLB reciprocating internal combustion engine, site rated at 1875 \ horsepower. This engine shall be equipped with a non -selective catalytic reduction (NSCR) system and air -fuel ratio control. This emission unit is used for natural gas compression. Non -selective catalytic reduction (NSCR) system and air -fuel ratio control C-211 002 One (1) Caterpillar, G3606 A4, SN: TBD, natural gas - fired, Turbocharged aspiration, 4SLB reciprocating internal combustion engine, site rated at 1875 horsepower. This engine shall be equipped with a non -selective catalytic reduction (NSCR) system and air -fuel ratio control. This emission unit is used for natural gas compression. Non -selective catalytic reduction (NSCR) system and air -fuel ratio control C-212 003 One (1) Caterpillar, G3606 A4, SN: TBD, natural gas - fired, Turbocharged aspiration, 4SLB reciprocating internal combustion engine, site rated at 1875 horsepower. This engine shall be equipped with a non -selective catalytic reduction (NSCR) system and air -fuel ratio control. This emission unit is used for natural gas compression. Non -selective catalytic reduction (NSCR) system and air -fuel ratio control C-213 004 One (1) Caterpillar, G3516J A4, SN: TBD, natural gas - fired, Turbocharged aspiration, 4SLB reciprocating internal combustion engine, site rated at 1380 horsepower. This engine shall be equipped with a non -selective catalytic reduction (NSCR) system and air -fuel ratio control. This emission unit is used for natural gas compression. Non -selective catalytic reduction (NSCR) system and air -fuel ratio control COLORADO Air Pollution Control Division Oew rnent of t'ubttc He= a Enwon Inc Page 1 of 25 D-3101 005 One (1) Triethylene glycol (TEG) natural gas dehydration unit (make, model, serial number: TBD) with a design capacity of 20 MMscf per day. This emissions unit is equipped with two (2) Make and model TBD, glycol pump with a design capacity of 4.2 gallons per minute. This unit is equipped with a flash tank, reboiler and still vent. Emissions from the still vent are routed to an air-cooled BTEX condenser and then to the enclosed flare (Point 007). Emissions from the flash tank are routed to an enclosed flare (Point 007). D-3111 006 One (1) Triethylene glycol (TEG) natural gas dehydration unit (make, model, serial number: TBD) with a design capacity of 20 MMscf per day. This emissions unit is equipped with two (2) Make and model TBD, glycol pump with a design capacity of 4.2 gallons per minute. This unit is equipped with a flash tank, reboiler and still vent. Emissions from the still vent are routed to an air-cooled BTEX condenser and then to the enclosed flare (Point 007). Emissions from the flash tank are routed to an enclosed flare (Point 007). F-4101 007 One (1) enclosed process flare to control V0C and HAPs from the TEG dehydrators (Points 005 and 006) Enclosed Process Flare CB 008 Compressor blowdowns for the 4 compressor engines (Points 001-004) None FUG -2 011 Fugitives component leak emissions from the pump station None TK-1 012 One (1) 50,000 bbl external floating roof condensate storage tank None SR 014 Emissions associated with pipeline pigging MSS activity None EC 015 One (1) Leed EC48-2S, serial number: L30-0035-000, enclosed combustor used to control emissions from TEG dehydrators (Point 016 Et Point 017). None D-3201 016 One (1) triethylene glycol (TEG) natural gas dehydration unit (make/model/serial number: TBD) with a design capacity of 50 MMscf per day. This emissions unit is equipped with a flash tank, reboiler and still vent. Emissions from the still vent are routed to an air-cooled BTEX condenser and then to the enclosed combustor (Point 011). Emissions from the flash tank are routed directly to the enclosed combustor (Point 011). D-3211 017 One (1) triethylene glycol (TEG) natural gas dehydration unit (make/model/serial number: TBD) with a design capacity of 50 MMscf per day. This emissions unit is equipped with a flash tank, reboiler and still vent. Emissions from the still vent are routed to an air-cooled BTEX condenser and then to the enclosed combustor (Point 011). Emissions from the flash tank are routed directly to the enclosed combustor (Point 011). COLORADO Air Pollution Control Division l evartrnent ct Putoc Hva h b E.nArert leTlt Page 2 of 25 (Points 001-004): These engines may be replaced with another engine in accordance with the temporary engine replacement provision or with the manufacturer and model submitted to the Division per Requirements to Self -Certify for Final Authorization in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C. R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting- notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self- certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. Point 008: Upon commencement of operation, the operator shall install a dedicated flow meter to monitor and record volumetric flow rate of natural gas vented from the compressor blowdown events covered by this permit. 5. 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.) 6. Points 001-006, 016, 017: 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 reciprocating internal combustion engines manufacturer name, model number and serial number • 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.) 7. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. COLORADO Air Pollution Control Division t petment of PubtaC H Wit'^ v Envuonmerat Page 3 of 25 EMISSION LIMITATIONS AND RECORDS 8. 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 NO. VOC CO C-210 001 1,535 921 461 Point C-211 002 1,535 921 461 Point C-212 003 1,535 921 461 Point C-213 004 1,130 814 452 Point D-3101 005 --- 377 --- Point D-3111 006 --- 377 --- Point F-4101 007 904 --- 1,805 Point CB 008 --- 770 --- Point FUG -2 011 --- 401 --- Fugitive TK-1 012 --- 1,767 --- Point SR 014 --- 190 --- Point EC 015 445 --- 2030 Point D-3201 016 --- 898 --- Point D-3211 017 --- 898 --- 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. COLORADO Air Pollution Control Division Ntu rent M Pabgr Heaan & E;nurcfl rent Page 4 of 25 Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type NO X V0C CO C-210 001 9.1 5.5 2.8 Point C-211 002 9.1 5.5 2.8 Point C-212 003 9.1 5.5 2.8 Point C-213 004 6.7 4.8 2.7 Point D-3101 005 --- 2.2 --- Point D-3111 006 --- 2.2 --- Point F-4101 007 5.4 --- 10.7 Point CB 008 --- 4.5 --- Point FUG -2 011 --- 2.4 --- Fugitive TK-1 012 --- 10.4 --- Point SR 014 --- 1.2 --- Point EC 015 2.6 --- 12.0 Point D-3201 016 --- 5.3 --- Point D-3211 017 --- 5.3 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits, for criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. COLORADO Air Pollution Control Division DeUBr;"^. ;etit of Publtt 3tea,,•tr_ #r ERvrur,.:,c*nt Page 5 of 25 9. Points 005, 006, 016 Et 017: Compliance with the emission limits in this permit shall be demonstrated by running the GRI GlyCalc model version 4.0 or higher on a monthly basis using the most recent extended wet gas analysis and recorded operational values, including: gas throughput, lean glycol recirculation rate, condenser 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. 10. Points 005, 006, 016 Ft 017: 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. 11. Points 005, 006, 016 & 017: 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. 12. The owner or operator shall operate and maintain the emission points in the table below with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. The owner or operator shall operate this dehydration unit so as to prevent any emissions directly to the atmosphere. (Regulation Number 3, Part B, Section III. E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled C-210 001 Selective catalytic oxidation (SC0) system and air -fuel ratio control V0C, CO, Formaldehyde C-211 002 Selective catalytic oxidation (SC0) system and air -fuel ratio control V0C, CO, Formaldehyde C-212 003 Selective catalytic oxidation (SC0) system and air -fuel ratio control V0C, CO, Formaldehyde C-213 004 Selective catalytic oxidation (SC0) system and air -fuel ratio control V0C, CO, Formaldehyde D-3101 005 Still Vent: BTEX Condenser £t Enclosed Flare V0C and HAPs Flash Tank: Enclosed Flare V0C and HAPs D-3111 006 Still Vent: BTEX Condenser Et Enclosed Flare V0C and HAPs Flash Tank: Enclosed Flare V0C and HAPs D-3201 016 Still Vent: BTEX Condenser Ft Enclosed Flare V0C and HAPs Flash Tank: Enclosed Flare V0C and HAPs D-3211 017 Still Vent: BTEX Condenser Et Enclosed Flare V0C and HAPs Flash Tank: Enclosed Flare V0C and HAPs COLORADO Air Pollution Control Division L?^Uar;mmont of Putt He th it Enwonmen: Page 6 of 25 PROCESS LIMITATIONS AND RECORDS 13. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit Monthly Limit (31 days) C-210 001 Consumption of natural gas as a fuel 109.1 MMscf 9.3 MMscf C-211 002 Consumption of natural gas as a fuel 109.1 MMscf 9.3 MMscf C-212 003 Consumption of natural gas as a fuel 109.1 MMscf 9.3 MMscf C-213 004 Consumption of natural gas as a fuel 88.4 MMscf 7.5 MMscf D-3101 005 Natural Gas Throughput 7,300 MMscf 620 MMscf D-3111 006 Natural Gas Throughput 7,300 MMscf 620 MMscf F-4101 007 Natural Gas Throughput 51.6 MMscf 4.4 MMscf CB 008 Blowdown Events 0.32 MMscf --- TK-1 012 Condensate Throughput 18,250,000 bbl 1,550,000 bbl SR 014 Pigging Events 120 events 11 events EC 015 Waste gas combusted 51.10 MMscf 4.34 MMscf Pilot and Purge gas combusted 0.42 MMscf 0.04 MMscf D-3201 016 Dry gas throughput 18,250.00 MMscf 1,550 MMscf D-3211 017 Dry gas throughput 18,250.00 MMscf 1,550 MMscf 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. 14. Points 001 - 004: Fuel consumption shall be measured by one of the following methods: individual engine fuel meter or facility -wide fuel meter attributed to fuel consumption rating and hours of operation. COLORADO Air Pollution Control Division i>smrurenLet Public Hew,l b E^s5ror,-^,Sea: Page 7 of 25 15. Points 005 Et 006: This unit shall be limited to the maximum lean glycol circulation rate of 4.2 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) 16. Points 005 Et 006: The volume of dry gas throughput shall be measured by gas meter at the outlet of the dehydration system. The volume of gas metered at the outlet of Point 005 may be assumed to be equal to the dry gas throughput for Point 006. 17. Points 005, 006, 016 Ft 017: On a weekly basis, the owner or operator shall monitor and record operational values including: flash tank temperature and pressure, wet gas inlet temperature and pressure. These records shall be maintained for a period of five years. 18. Point 008: The owner or operator shall record the following information during each compressor blowdown. Records shall be maintained by the applicant and made available to the Division for inspection upon request. (Reference: Regulation No. 3 Part B, II.A.4) • Date and time of blowdown. • Estimated volume of each blowdown. In order to demonstrate compliance with the emission limitations of this permit, emissions due to blowdown activities shall be calculated on a monthly basis. The emissions calculations shall be based on the information collected above and the emission factors listed in the "Notes to Permit Holder" section of this permit. 19. Points 016 Et 017: 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 (Copt) provisions under MACT HH. (Reference: Regulation Number 3, Part B, II.A.4) 20. Point 016 Et 017: The volume of dry gas throughput shall be measured by gas meter at the outlet of the dehydration system. The volume of gas metered at the outlet of Point 017 may be assumed to be equal to the dry gas throughput for Point 016. STATE AND FEDERAL REGULATORY REQUIREMENTS 21. 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) 22. 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. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. Et 4.) 23. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 24. Points 001 - 004: This equipment is subject to the control requirements for stationary and portable engines in the 8 -hour ozone control area under Regulation No. 7, Section XVI.B.2. For lean burn reciprocating internal combustion engines, an oxidation catalyst shall be required. (COLORADO Air Pollution Control Division Deparek, of Rib l:[ tlea3th b Dvaronmeorlt Page 8 of 25 25. Points 005, 006, 016, 017: This source is subject to Regulation Number 7, Section XII.H. The operator shall comply with all applicable requirements of Section XII and, specifically, shall: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for glycol natural gas dehydrators; and • Ensure uncontrolled actual emissions of volatile organic compounds from the still vent and vent from any gas -condensate -glycol (GCG) separator (flash separator or flash tank), if present, shall be reduced by at least 90 percent on a rolling twelve-month basis through the use of a condenser or air pollution control equipment. (Regulation Number 7, Section XII.H.1.) 26. Point 011: Minor sources in designated nonattainment or attainment/maintenance areas that are otherwise not exempt pursuant to Regulation No. 3, Part B, Section II.D shall apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is nonattainment or attainment/maintenance (Reference: Regulation No. 3, Part B, III.D.2.a). This requirement to apply RACT shall be satisfied by installing/implementing the following emission controls: a. Directed Inspection Et Maintenance as described below shall satisfy the requirement to apply RACT. i. Auditory/visual/olfactory inspection (AVO) will be performed on a quarterly basis. ii. For each leak found in the AVO inspection, a gas detector may be used to determine the size of the leak. The gas detector shall be regularly calibrated. Component leaks greater than 10,000 ppm shall be managed in accordance with Item (vi) below, unless it is unfeasible to make the repair without shutting down the affected operation of the facility. Component leaks less than 10,000 ppm shall not require repair. For such component leaks that require a shutdown to be repaired, repair shall occur during the first shutdown of the affected operation after the leak is discovered. iii. For repair, valves adjacent to the equipment to be repaired will be closed if practicable, minimizing the volume released. iv. Repaired components shall be re -screened using AVO to determine if the leak is repaired. v. The following records shall be maintained for a period of two years: • The name of the site screened via AVO inspection and the name of the inspector. • Components evaluated with the gas detector. • Repair methods applied. • Dates of the AVO inspections, gas detector calibrations, attempted repairs, successful repairs, repair delays, and post -repair screenings. vi. Leaks shall be repaired as soon as practicable, but no later than 15 calendar days after detection, unless it is technically or operationally infeasible to make the repair within 15 calendar days. Records documenting the rationale shall be maintained if it is technically or operationally infeasible to make the repair within 15 calendar days. 27. Point 012: This source is subject to Regulation Number 7, Section XII. The operator shall comply with all applicable requirements of Section XII and, specifically, shall: COLORADO Air' Pollution Control Division Depart.^.+:ent or Pubi Envronnuvi, Page 9 of 25 • Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate storage tanks 28. Points 012: This source is subject to the New Source Performance Standards, Standards of Performance for Volatile Organic Liquid Storage Vessels for which construction, reconstruction or modification commenced after July 23, 1984, Subpart Kb. This facility shall be subject to all provisions of this regulation, as stated in 40 C.F.R Part 60, Subparts A and Kb. (Regulation Number 6, Part A, Subparts A and Kb) 29. Points 005, 006, 007, 015, 016, 017: The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2 General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.17; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter upon installation of the combustion device. 30. Points 005, 006, 007, 015, 016, 017: The glycol dehydration unit covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.D.3. Beginning May 1, 2015, still vents and vents from any flash separator or flash tank on a glycol natural gas dehydrator located at an oil and gas exploration and production operation, natural gas compressor station, or gas -processing plant subject to control requirements pursuant to Section XVII.D.4., shall reduce uncontrolled actual emissions of hydrocarbons by at least 95% on a rolling twelve-month basis through the use of a condenser or air pollution control equipment. COLORADO. Air Pollution Control Division throar rent nt Vubltc # ea':c^.. #r Ennranment Page 10 of 25 ' 31. Points 005, 006, 016, 017: 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) MACT HH Applicable Requirements Area Source Benzene emissions exemption 563.764 - General Standards $63.764 (e)(1) - The owner or operator is exempt from the requirements of paragraph (d) of this section if the criteria listed in paragraph (e)(1)(i) or (ii) of this section are met, except that the records of the determination of these criteria must be maintained as required in §63.774(d)(1). 563.764 (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. 563.772 - 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 TMTechnical Reference Manual. Inputs to the model shall be representative of actual operating conditions of the glycol dehydration unit and may be determined using the procedures documented in the Gas Research Institute (GRI) report entitled "Atmospheric Rich/Lean Method for Determining Glycol Dehydrator Emissions" (GRI-95/0368.1); or §63.772(b)(2)(ii) - The owner or operator shall determine an average mass rate of benzene emissions in kilograms per hour through direct measurement using the methods in §63.772(a)(1)(i) or (ii), or an alternative method according to §63.7(f). Annual emissions in kilograms per year shall be determined by multiplying the mass rate by the number of hours the unit is operated per year. This result shall be converted to megagrams per year. 563.774 - Recordkeeping Requirements §63.774 (d)(1) - An owner or operator of a glycol dehydration unit that meets the exemption criteria in §63.764(e)(1)(i) or §63.764(e)(1)(ii) shall maintain the records specified in paragraph (d)(1)(i) or paragraph (d)(1)(ii) of this section, as appropriate, for that glycol dehydration unit. §63.774 (d)(1)(ii) - The actual average benzene emissions (in terms of benzene emissions per year) as determined in accordance with §63.772(b)(2). COLORADO Air Pollution Control Division Dew.rtyreru of Pubbc En«rcn nern Page 11 of 25 OPERATING Et MAINTENANCE REQUIREMENTS 32. Points 001 - 006, 016, 017: Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the 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 33. Points 005, 006, 016, 017: 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.) 34. Point 005, 006, 007: 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 VOCs. The test shall determine the mass emission rates of volatile organic compounds at the inlet and outlet of the control device, which shall be used to determine the destruction efficiency during the test. The natural 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 rate for VOC to demonstrate compliance with the sum of the VOC emission limits specified in this permit for Point 005 and Point 006. 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 007. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. 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 COLORADO Air Pollution Control Division L: .rr.?rnc of Heakt^, u Envuorr±ent Page 12 of 25 35. Point 015, 016, 017: 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 natural 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 016 and Point 017.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 015. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. 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 36. Point 007, 015: 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.16) 37. Point 011: Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, the owner or operator shall complete the initial extended natural gas liquids analysis of liquids that are representative of volatile organic compound (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended liquids analyses shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. The operator shall submit the results of the liquids analyses and emission calculations to the Division as part of the self -certification process to ensure compliance with emissions limits. 38. Points 012: The owner or operator shall complete site specific sampling including a compositional analysis of the condensate routed to these storage tanks and an analysis to determine RVP and API gravity. Testing shall be in accordance with the guidance contained in PS Memo 05-01. Results of testing shall be used to determine site -specific emissions factors for VOC and Hazardous Air Pollutants using Division approved methods. Results of site -specific sampling and analysis shall be submitted to the Division as part of the self -certification and used to demonstrate compliance with the emissions factors chosen for this emissions point. Periodic Testing Requirements 39. Points 005, 006, 016, 017: 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. COLORADO Air Pollution Control Division la^a.r*nens ct Yubit[ :#ra1^,u Ens^.rar,mcv,, Page 13 of 25 ADDITIONAL REQUIREMENTS 40. All previous versions of this permit are cancelled upon issuance of this permit. 41. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NOx per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 42. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). GENERAL TERMS AND CONDITIONS 43. 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. 44. 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. COLORADO 1 Air Pollution Control Division De' arcmen, of Pubrc tle*th 8 E-anronmen Page 14 of 25 45. 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. 46. 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. 47. 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. 48. 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. 49. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Christian Lesniak Permit Engineer Permit Histo Issuance Date Description Issuance 1 March 20, 2018 Issued to Discovery DJ Services LLC Issuance 2 This Issuance Issued to Discovery DJ Services LLC. Removal of Modification to add 100 MMSCFD dehydration capacity Point 013 for being below reporting/permitting emitting threshold. Modified Emission Limits of Points 005, 006, 008. Added Points 015, 016, 017 Made administrative change to Points 001 - 004: Changed Non -Selective Catalytic Reduction in condition 012 (control table) to Selective Catalytic Oxidation to reflect that these engines are Lean Burn. COLORADO I Air Pollution Control Division L? p„r,:. t;:£ Ct FJbitC NraF(R b EriN.rori^iS: 1: Page 15 of 25 Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (Ib/yr) C-210 001 Formaldehyde 50000 7,242 724 Acetaldehyde 75070 1,030 1,030 Acrolein 107028 633 633 Methanol 67561 308 308 C-211 002 Formaldehyde 50000 7,242 724 Acetaldehyde 75070 1,030 1,030 Acrolein 107028 633 633 Methanol 67561 308 308 C-212 003 Formaldehyde 50000 7,242 724 Acetaldehyde 75070 1,030 1,030 Acrolein 107028 633 633 Methanol 67561 308 308 C-213 004 Formaldehyde 50000 11,460 933 Acetaldehyde 75070 834 834 Acrolein 107028 513 513 Methanol 67561 250 250 D-3101 005 Benzene 71432 36102 604 Toluene 108883 21868 279 COLORADO Air Pollution Control Division DgInrtment of F.rbi,r Nnatt.'t it Envuortment Page 16 of 25 Ethylbenzene 100414 1770 14 Xylenes 1330207 9058 58 n -Hexane 110543 3111 59 D-3111 006 Benzene 71432 36102 604 Toluene 108883 21868 279 Ethylbenzene 100414 1770 14 Xylenes 1330207 9058 58 n -Hexane 110543 3111 59 CB 008 n -Hexane 110543 129 129 TK-1 012 n -Hexane 110543 298 298 D-3201 016 Benzene 71432 86035 1439 Toluene 108883 52106 665 Ethylbenzene 100414 4218 32 Xylenes 1330207 21598 140 n -Hexane 110543 7398 140 224 TMP 540841 6 1 D-3211 017 Benzene 71432 86035 1439 Toluene 108883 52106 665 Ethylbenzene 100414 4218 32 Xylenes 1330207 21598 140 n -Hexane 110543 7398 140 224 TMP 540841 6 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. 5) The emission levels contained in this permit are based on the following emission factors: Points 001 - 003: CAS Pollutant Emission Factors lb/MMBtu - Uncontrolled g/bhp-hr Emission Factors lb/MMBtu - Controlled g/bhp-hr NOx --- 0.500 --- 0.500 CO --- 2.720 --- 0.150 VOC --- 1.500 --- 0.300 50000 Formaldehyde --- 0.200 --- 0.020 75070 Acetaldehyde 0.008 --- 0.008 -- 107028 Acrolein 0.005 --- 0.005 --- 67561 Methanol 0.0025 --- 0.0025 --- COLORADO Air Pollution Control Division rmens et Yuba tlee b Envnrcnment Page 17 of 25 Emission factors are based on a Brake -Specific Fuel Consumption Factor of 7500 Btu/hp-hr, a site -rated horsepower value of 1875, and a fuel heat value of 1130 Btu/scf. Point 004: CAS Pollutant Emission Factors lb/MMBtu - Uncontrolled g/bhp-hr Emission Factors lb/MMBtu - Controlled g/bhp-hr NOx --- 0.500 --- 0.500 CO --- 2.430 --- 0.200 VOC --- 0.910 --- 0.360 50000 Formaldehyde --- 0.430 --- 0.035 75070 Acetaldehyde 0.008 --- 0.008 -- 107028 Acrolein 0.005 --- 0.005 --- 67561 Methanol 0.0025 --- 0.0025 --- Emission factors are based on a Brake -Specific Fuel Consumption Factor of 7500 Btu/hp-hr, a site -rated horsepower value of 1380, and a fuel heat value of 1130 Btu/scf. Points 005 & 006: 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% and the use of a condenser with a condenser temperature not exceeding 125 degrees Fahrenheit. 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 003 & 004 are reflected in the emission calculations for Point 007. Point 007: CAS # Pollutant Uncontrolled Emission Factors lb/MMBtu Source N0x 0.138 TCEQ Flare Emission Factors CO 0.276 Point 008: CAS # Pollutant Weight Fraction of Gas (%) Uncontrolled Emission Factors (lb/MMSCF) Source V0C 41.44 28,945.47 Mass balance Emissions from this point are based on blowdowns of gas from seven (7) compressors. The volume of gas emitted per event is based on the following, as derived from engineering estimates: Compressors C1 -C3: 4.2 MSCF per event per compressor Compressor C4: 3.0 MSCF per event per compressor Compressors C5 -C7: 3.5 MSCF per event per compressor The total volume of gas is based on the sum of the volume emitted for each event and for each compressor in a given compliance period. COLORADO Air Pollution Control Division Dia:s^rrn:. cl Pabbc !leash L Env ronme 7[ Page 18 of 25 Point 011: The emission levels contained in this permit are based on the following emission factors: Component Gas Service Heavy Oil Light Oil SWater/Oil ervi Service Connectors --- --- 10 --- Flanges --- --- 100 --- Open-ended Lines --- --- 0 --- Pump Seals --- --- 3 --- Valves --- --- 50 --- Other* --- --- 9 --- VOC Content (wt.--- fraction) --- 100 Benzene Content (wt. fraction) --- 0.0038 --- Toluene Content (wt. fraction) _-- 0.0096 Ethylbenzene (wt.--- fraction) --- 0.0043 Xylenes Content (wt.--- fraction) --- 0.0043 n -hexane Content (wt. fraction) _- _ _ _ 0.0260 *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms, hatches, instrument meters, polish rods and vents TOC Emission Factors (kg/hr-component): Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 2.0E-04 7.5E-06 2.1E-04 1.1E-04 Flanges 3.9E-04 3.9E-07 1.1E-04 2.9E-06 Open-ended Lines 2.0E-03 1.4E-04 1.4E-03 2.5E-04 Pump Seals 2.4E-03 NA 1.3E-02 2.4E-05 Valves 4.5E-03 8.4E-06 2.5E-03 9.8E-05 Other 8.8E-03 3.2E-05 7.5E-03 1.4E-02 Source: EPA -453/R95-017 Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors listed in the table above with representative component counts, multiplied by the VOC content from the most recent liquids analyses. Point 012: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Source VOC 0.00114 EPA TANKS 4.0.9d 110543 n -Hexane 0.0000163 COLORADO Air Pollution Control Division Pubic Enhrorrnen[ Page 19 of 25 Point 014: CAS # Pollutant Uncontrolled Emission Factors lb/event Source VOC 18.55 AP -42 Point 016, 017: 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% and the use of a condenser with a condenser temperature not exceeding 125 degrees Fahrenheit. 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 016 and 017 are reflected in the emission calculations for Point 015. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692- 3150. 7) This permit fulfills, the requirement to hold a valid permit reflecting the glycol dehydration unit and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(B) when applicable. 8) This source is subject to 40 CFR, Part 60, Subpart 0000a - Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced after September 18, 2015 (See June 3, 2016 Federal Register posting - effective August 2, 2016.) This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available at the Office of the Federal Register website at: https://www.federalregister.gov/documents/2016/06/03/2016-11971 /oit-and-naturalias- sector-emission-standards-for-new-reconstructed-and -modified -sources 9) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor/Major Source of: CO, VOC, &t HAP NANSR Synthetic Minor/Major Source of: VOC MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Applicable MACT ZZZZ Major Source Requirements: Not Applicable Area Source Requirements: Applicable 10) 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/ COLORADO Air Pollution Control Division Re;a✓ rnert el Pubbc Hea'un 1, EIT'vtrvrrrnt Page 20 of 25 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 1ep;;rtr.vrs of N.4bi+e Heatt?t , En tror n ri Page 21 of 25 ATTACHMENT A ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES 1. Alternative Operating Scenarios The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility -Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS, and the owner or operator shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 1.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with an engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month period. "Permanent" is defined as in the same service for more than 90 operating days in any 12 month period. The 90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90 day total. The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit. All replacement engines are subject to all federally applicable and state -only requirements set forth in this permit (including monitoring and record keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5) years and made available to the Division upon request. The owner or operator shall maintain a log on -site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all Applicability Reports required under section 1.1.2 and make them available to the Division upon request. 1.1.1 The owner or operator may temporarily replace an existing engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other requirements applicable to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 1.2. 1.1.2 The owner or operator may permanently replace the existing engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 1.2. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability COLORADO AirPollution Control Division Doar;men of Pub Heath it E*14tironmm Page 22 of 25 Reports can be found at https://www.colorado.gov/pacific/cdphe/alternate-operating-scenario-aos-reporting- forms. This submittal shall be accompanied by a certification from the Responsible Official indicating that "based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. 1.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at: https://www.colorado.gov/pacific/sites/default/files/AP Portable-Analyzer-Monitoring-Protocol.pdf Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever applies. For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine will be subject to, the results of the test shall be converted to the appropriate units as described in the above -mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline. 1.3 Applicable Regulations for Permanent Engine Replacements 1.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B § II.D.2 COLORADO Air Pollution Control Division n,Darurefr,Env;ren. ,e?rt Page 23 of 25 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and to NOX and SO2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr. For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating internal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOX: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (5 60.331) and 40 CFR Part 72 (5 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 1.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State -Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified below: Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non -selective catalyst and air fuel controller to reduce emission. Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition 1.1.2. Emission Standards: Section XVII.E - State -only requirements Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Max Engine HP Construction or Relocation Date Emission Standards in G/hp-hr NOx CO VOC 100<Hp<500 January 1, 2008 January 1, 2011 2.0 1.0 4.0 2.0 1.0 0.7 500≤Hp July 1, 2007 July 1, 2010 2.0 1.0 4.0 2.0 1.0 0.7 The source shall submit copies of the relevant Applicability Reports required under Condition 1.1.2. 1.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ 1COLORADO Air Pollution Control Division Department of Njbec Health b Entror,^nesat Page 24 of 25 A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 1.1.2. Any testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition 1.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 1.2. Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ requirements). However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, § l.B (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. 1.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 1.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition 1.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 1.2. 1.4 Additional Sources The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site; an engine that is being installed as an entirely new emission point and not as part of an AOS-approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. COLORADO Air Pollution Control Division Dcwrzment of Pubttc tieatt�; #r E mfor mtn Page 25 of 25 Glycol Dehydration Unit APEN - Form APCD-202 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for Glycol Dehydration (Dehy) Units only. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: I7W E 1195 AIRS ID Number: 123 / 9F74 / t C RECEIVED JUL 2 5 2018 APCD Stationary SAN. rea4 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification: D-3101 [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Discovery DJ Services Site Name: Discovery Lochbuie Compressor Station Site Location: SEC 21 T1 N R65W Mailing Address: (Include Zip Code) 3601 Stagecoach Road, Ste. 202 Longmont, CO 80504 E -Mail Address2: mnorton@discoverymidstream.com Site Location County: NAICS or SIC Code: Ymagt, \13Q1A. 213112 Permit Contact: Matt Norton Phone Number: (817) 455-5799 'Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-202 - Glycol Dehydration Unit APEN - Revision 02/2017 385598 AY COLORADO Permit Number: 17W E 1195 AIRS ID Number: 123 /9F74/ [Leave blank unless APCD has already assigned a permit # 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) ❑ Change fuel or equipment ❑ Change company name El Add point to existing permit 0 Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below) - OR ▪ APEN submittal for update only (Please note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: The modification is to include revised emission calculations based on recent inlet gas data. 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: natural gas. TEG dehydrator for the removal of water from Facility equipment Identification: For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: D-3101 01 /01 /2018 / / ❑Q Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area Is this unit located at a stationary source that is considered a Major Source of (HAP) Emissions Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 CI days/week Yes Yes weeks/year No No 2 I V COLORADO aM• Hlen EF.�!vunnnv.n� Permit Number: 17WE1195 1195 AIRS ID Number: 123 /9F741 [Leave blank unless APCD has already assigned a permit ,H and AIRS ID] Section 4 - Dehydration Unit Equipment Information Manufacturer: Dehydrator Serial Number: Glycol Used: TBD TBD Ethylene Glycol (EG) El Model Number: TBD Reboiler Rating: 0.6 DiEthylene Glycol (DEG) Glycol Pump Drive:❑ Electric ❑ Gas If Gas, injection pump ratio: Pump Make and Model: TBD Glycol Recirculation rate (gal/min): Lean Glycol Water Content: Max: 10 GPM 0.10 Wt.% MMBTU/hr ❑ TriEthylene Glycol (TEG) Requested: 10 Acfm/gpm # of pumps: 2 Dehydrator Gas Throughput: Design Capacity: 20 MMSCF/day Requested: 7300 MMSCF/year Actual: MMSCF/year Inlet Gas: Pressure: 1,098 Water Content: Wet Gas: Flash Tank: Pressure: 65 Cold Separator: Pressure: Stripping Gas: (check one) None ❑ Flash Gas ❑ Dry Gas ❑ Nitrogen Flow Rate: scfm psig Temperature: lb/MMSCF ❑✓ Saturated Dry gas: 7 psig Temperature: psig Temperature: 80 145 °F lb/MMSCF °F ❑ NA °F ❑ NA Additional Required Information: • Attach a Process Flow Diagram ❑✓ Attach GRI-GLYCalc 4.0 Input Report a Aggregate Report (or equivalent simulation report/test results) ❑� Attach the extended gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 VCOLORADO Hnil:il uF ' Permit Number: 17W E 1195 AIRS ID Number: 123 /9F74/ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) Latitude 39.95903963/Longitude104.68078147 Operator Stack ID No_) Discharge Height Above Ground Level Ted t' Flow RateVelocity ) (ft/ TBD TBD TBD TBD TBD Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): ❑ 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): Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 ®Y u COLORADO Permit Number: 17WE1195 AIRS ID Number: 123 19F74/ [Leave blank unless APCD has already assigned a permit 11 and AIRS ID] Section 6 - Control Device Information Condenser: Used for control of: Regenerator Type: BTEX Make/Model: TBD p Maximum Temp 400 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: Regenerator Vent & Flash Gas Rating: 6.27 MMBtu/hr Type: Process Flare Make/Model: TBD Requested Control Efficiency: 98 % 1500 Btu/scf MMBtu/hr ■ Manufacturer Guaranteed Control Efficiency 98 % Minimum Temperature: Waste Gas Heat Content 0.0456 Constant Pilot Light: • Yes ■ No Pilot burner Rating Closed Loop System: Used for control of: Description: • System Downtime Other: Used for control of: Description: • Control Efficiency Requested ° Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 �� COLORADO 5 I �� Permit Number: 17W E 1195 AIRS ID Number: 123 /9F74 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) PM SOX NOx CO VOC BTEX Condenser and Flare 98% HAPs BTEX Condenser and Flare 98% Other: 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.) Uncontrolled Emission Emission Factor _-_- - _ fmic — - _ 1'rrnfi�s�_ Pollutant Emission Factor Source - _ — _ Factor Units ow.42, Mfg. etc) Uncontrolled (Tons/year) Controlled5 (Tons/year) Uncontrolled (Tons/year) Controlled (Tons/year) PM SOX NOx CO VOC `.`ii .9- Ibs/hr GRI-GLYCaIc t-4.65 P-, .a Benzene (4.1'). lbs/hr GRI-GLYCaIc ) 6IOa- (U;) 6()l4 Toluene ?—c70 lbs/hr GRI-GLYCaIc 71%6S(K) ..4.(1 Ethylbenzene 0.-3-0 lbs/hr GRI-GLYCaIc I:4O (lb) l,) N Xylenes . I.O-5 - lbs/hr GRI-GLYCaIc CIO9 (Ibj 515 n -Hexane b.1)(P lbs/hr GRI-GLYCaIc - 1l (lb) 59 2,2,4- Trimethylpentane Other: 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 5Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. tcie Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 COLORADO 6 I Aw- °vimaw� Permit Number: 17WE1195 AIRS ID Number: 123 /9F74/ [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. ifq,X; '7, 7 73-/9' Signature of Legally Authorized erson (not a vendor or consultant) Date Matthew T. Berghorn VP - Engineering & Constructs Name (please 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) Send this form along with $152.90 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 7 I A®COLORADO iaP.�aTr.., `r`e Glycol Dehydration Unit APEN - Form APCD-202 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for Glycol Dehydration (Dehy) Units only. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 17W E 1195 AIRS ID Number: 123 / 9F74 / DOt [Leave blank unless APCD has already assigned a permit ft and AIRS ID] Company equipment Identification: D-3111 [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Discovery DJ Services Site Name: Discovery Lochbuie Compressor Station Site Location: SEC 21 T1 N R65W Mailing Address: (Include Zip Code) 3601 Stagecoach Road, Ste. 202 Longmont, CO 80504 E -Mail Address2: mnorton@discoverymidstream.com Site Location County: \U NAICS or SIC Code: 213112 Permit Contact: Matt Norton Phone Number: (817) 455-5799 1Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-202 - Glycol Dehydration Unit APEN - Revision 02/2017 385599 1 I A COLORADO Permit Number: 17WE1195 1195 AIRS ID Number: 123 /9F74/ [Leave blank unless APCD has already assigned a permit II and AIRS ID] Section 2- Requested Action ❑ NEW permit OR newly -reported emission source -OR- l11 MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit ✓❑ Change permit limit ❑ Transfer of ownership3 El Other (describe below) - OR ❑ APEN submittal for update only (Please note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Notes: The modification is to include revised emission calculations based on recent inlet gas data. 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: natural gas. TEG dehydrator for the removal of water from Facility equipment Identification: For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: D-3111 01 / 01 /2018 / / 0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area Is this unit located at a stationary source that is considered a Major Source of (HAP) Emissions Form APCD-2O2 -Glycol Dehydration Unit APEN - Revision 02/2017 days/week Yes Yes 2 I AV weeks/year No No COLORADO Dnpvuveef of Y eUc Permit Number: 17WE1195 1195 AIRS ID Number: 123 /9F74/ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Dehydration Unit Equipment Information Manufacturer: Dehydrator Serial Number: Glycol Used: TBD TBD ❑ Ethylene Glycol (EG) Model Number: TBD Reboiler Rating: 0.6 ❑ DiEthylene Glycol (DEG) Glycol Pump Drive: Q Electric ❑ Gas If Gas, injection pump ratio: Pump Make and Model: TBD Glycol Recirculation rate (gal/min): Lean Glycol Water Content: Max: 10 GPM 0.10 Wt.% MMBTU/hr ❑ TriEthylene Glycol (TEG) Requested: 10 Acfm/gpm # of pumps: 2 Dehydrator Gas Throughput: Design Capacity: 20 MMSCF/day Requested: 7300 MMSCF/year Actual: MMSCF/year Inlet Gas: Pressure: 1,098 Water Content: Wet Gas: Flash Tank: Pressure: 65 psig Temperature: 80 lb/MMSCF 0 Saturated Dry gas: psig Cold Separator: Pressure: psig Stripping Gas: (check one) ❑� None ❑ Flash Gas ❑ Dry Gas ❑ Nitrogen Flow Rate: scfm Temperature: 145 Temperature: °F 7 lb/MMSCF °F ❑ NA °F ❑ NA Additional Required Information: ▪ Attach a Process Flow Diagram Attach GRI-GLYCalc 4.0 Input Report a Aggregate Report (or equivalent simulation report/test results) ❑✓ Attach the extended gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 AV COLORADO 3 I �°Pu :�v rleuo ival nFi� Permit Number: 17WE1195 AIRS ID Number: 123 /9F74/ [Leave blank unless APCD has already assigned a permit II and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or LITM) Latitude 39.95903963/Longitude104.68078147 Operator Stack ID No. Discharge Height Above Ground Level (Feet) Temp. ('t) Flow Rate- . (M) , Velocity (ft/sec) TBD TBD TBD TBD TBD Indicate the direction of the stack outlet: (check one) 0 Downward ❑ Other (describe): 0 Upward ❑ Horizontal Indicate the stack opening and size: (check one) 0 Upward with obstructing raincap E Circular Interior stack diameter (inches): TBD ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): El Other (describe): Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 4 I Ay/.y COLORADO :+.At Permit Number: 17WE1195 1195 AIRS ID Number: 123 /9F74/ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information ❑✓ Condenser: Used for control of: Regenerator Type: BTEX Make/Model: TBD Maximum Temp 400 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: Regenerator Vent & Flash Gas Rating: 6.27 MMBtu/hr hr Type: Process Flare Make/Model: TBD Requested Control Efficiency: 98 % Manufacturer Guaranteed Control Efficiency 98 % Minimum Temperature: Waste Gas Heat Content 1500 Btu/scf Constant Pilot Light: ✓❑ Yes ❑ No Pilot burner Rating 0.0456 MMBtu/hr Closed ❑ Loop System: Used for control of: Description: System Downtime ❑ Other: Used for control of: Description: Control Efficiency Requested 0 Form APCD-202.-Glycol Dehydration Unit APEN - Revision 02/2017 COLORADO 5 I Av an aa,,:,c mr;u� 1o.Ln Permit Number: 17WE1195 AIRS ID Number: 123 /9F74 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. - Is any emission control equipment or practice used to reduce emissions? LI Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) PM SOX NO,, CO VOC BTEX Condenser and Flare 98% HAPs BTEX Condenser and Flare 98% Other: 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 Emission Factor Units Emission Factor Source Source op -42, Mfg. etc) _q AlltiEm!ssions Annual Fermat - Uncontrolled (Tons/year) Controlled5 (Tons/year) Uncontrolled (Tons/year) Controlled (Tons/year) PM SOX NOX CO VOC ..f, 5), lbs/hr GRI-GLYCaIc )x4.05 a•? -a Benzene LI. t). lbs/hr GRI-GLYCaIc 3‘loa (t6) (o(}(} Toluene o` .5o lbs/hr GRI-GLYCaIc ?x$6`,3 (16) ;.31 Ethylbenzene ©.?O lbs/hr GRI-GLYCaIc )44° (Ib) 1 y Xylenes t_OZ, lbs/hr GRI-GLYCaIc 966 (a,) S q n -Hexane 0-- (o lbs/hr GRI-GLYCaIc 3000 59 2,2,4- Trimethylpentane Other: 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 5Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. (FL Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 6 I /AV COLORADO zwf, AV epv oaf l+�etic Hn.�_n eP wn.��u�.��ni Permit Number: 17WE1195 1195 AIRS ID Number: 123 /9F74/ [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. • ��-� `�- 2 3 Signature of Legally Authonze Person (not a vendor or consultant) Date Matthew T. Berghorn VP - Engineering & Constructer Name (please print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance E Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) Send this form along with $152.90 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 7 I AV CO LO RA 60 Glycol Dehydration Unit APEN - Form APCD-202 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for Glycol Dehydration (Dehy) Units only. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 17WE1195 1195 AIRS ID Number: 123 / 9F74 / 6/6 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification: D-3201 [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Discovery DJ Services Site Name: Discovery Lochbuie Compressor Station Site Location: SEC 21 T1 N R65W Mailing Address: (Include Zip code) 3601 Stagecoach Road, Ste. 202 Longmont, CO 80504 E -Mail Address2: mnorton@discoverymidstream.com Site Location County: Aqs \I3 A NAICS or SIC Code: 213112 Permit Contact: Matt Norton Phone Number: (817) 455-5799 'Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-202 - Glycol Dehydration Unit APEN - Revision 02/2017 385600 AVCOLORADO Permit Number: 17WE1195 AIRS ID Number: 123 /9F74/ [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 name Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Please note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ▪ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: natural gas. 50 MMscfd TEG dehydrator for the removal of water from Facility equipment Identification: D-3201 For existing sources, operation began on: / / For new or reconstructed sources, the projected start-up date is: TBD / / Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area Is this unit located at a stationary source that is considered a Major Source of (HAP) Emissions Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 days/week Yes Yes weeks/year No No -� COLORArDO 2 I �aPvuaeni cl V'nNJc Hr� ' F..•.v r Permit Number: 17WE1195 1195 AIRS ID Number: 123 /9F74/ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Dehydration Unit Equipment Information Manufacturer: Dehydrator Serial Number: Glycol Used: TBD TBD Ethylene Glycol (EG) Model Number: TBD Reboiler Rating: 1.0 ❑ (DEG) DiEthylene Glycol Glycol Pump Drive: 0 Electric ❑ Gas If Gas, injection pump ratio: Pump Make and Model: TBD Glycol Recirculation rate (gal/min): Lean Glycol Water Content: Max: 10 g pm 0.10 Wt.% MMBTU/hr ❑ TriEthylene Glycol (TEG) Requested: 10 # of pumps: Acfm/gpm 2 Dehydrator Gas Throughput: Design Capacity: 50 MMSCF/day Requested: 18,250 MMSCF/year Actual: MMSCF/year Inlet Gas: Pressure: 1,098 Water Content: Wet Gas: Flash Tank: Pressure: 65 Cold Separator: Pressure: Stripping Gas: (check one) ✓❑ None ❑ Flash Gas ❑ Dry Gas ❑ Nitrogen Flow Rate: scfm psig Temperature: 8O tb/MMSCF ❑✓ Saturated Dry gas: psig Temperature: 145 °F ❑ NA psig Temperature: °F 0 NA °F lb/MMSCF Additional Required Information: ▪ Attach a Process Flow Diagram ❑� Attach GRI-GLYCaIc 4.0 Input Report Et Aggregate Report (or equivalent simulation report/test results) ▪ Attach the extended gas analysis (including BTEX li n -Hexane, temperature, and pressure) Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 AVCOLORADO Permit Number: 17WE1195 1195 AIRS ID Number: 123 /9F74/ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) Latitude 39.95903963/Longitude -104.68078147 Opel otorDischarge Stack ID No. Height . Above Ground Level Ground Temp. C Flow Rate (� ... Velocity ) TBD TBD TBD TBD TBD Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Upward with obstructing raincap ❑✓ Circular Interior stack diameter (inches): TBD ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 AV COLORADO 4 I ioPaL rtPr:r n�i Permit Number: 17WE1195 AIRS ID Number: 123 /9F74/ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information O Condenser: Used for control of: Regenerator Type: BTEX Maximum Temp 400, Requested Control Efficiency Make/Model: TBD Average Temp 125 98 0 ❑ VRU: Used for control of: Size: Make/Model: Requested Control Efficiency % VRU Downtime or Bypassed % ❑ Combustion Device: Used for control of: Regenerator Vent & Flash Gas Rating: 8.82 MMBtu/hr Type: Enclosed Combustor Make/Model: LEED , EC48-2S L30-0035-000 Requested Control Efficiency: 98 % Manufacturer Guaranteed Control Efficiency 98+ % Minimum Temperature: Waste Gas Heat Content 1500 Btu/scf Constant Pilot Light: ❑ Yes ❑ No Pilot burner Rating 0.0456 MMBtu/hr Closed ❑ Loop System: Used for control of: Description: System Downtime ❑ Other: Used for control of: Description: Control Efficiency Requested Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 5 I 407 COLORADO Permit Number: 17WE1195 AIRS ID Number: 123 /9F74( [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) PM SOx NOx CO VOC BTEX Condenser and Enclosed Combustor 98% HAPs BTEX Condenser and Enclosed Combustor 98% Other: 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 Emission Factor Units Emission Factor Source (AP -42, Mfg_ etc) Actual A_____.4=4-___.,_„___— s .,-.4:,-1---1--=_,---- ..._--=.---_,._=-::_-_-:_-_---i--:-._=:-_---,:-..- Emasswn t atjs Uncontrolled (Tons/year) Controlled5 (Tons/year) Uncontrolled (Tons/year) Controlled (Tons/year) PM SOX NO. CO VOC (o l .t-) 1 lbs/hr GRI-GLYCaIc 259.S 5. -?-di Benzene `1 • g .?- lbs/hr GRI-GLYCaIc , 607,5 (1ta) V-1121 Toluene S .95 lbs/hr GRI-GLYCaIc S� loi,(lbl (0(05 Ethylbenzene 0.'0 lbs/hr GRI-GLYCaIc 4? -3 (Ib) b), Xylenes a .4-1- Ibs/hr GRI-GLYCaIc a(59S (10 140 n -Hexane 0 . cd LI lbs/hr GRI-GLYCaIc -i-3 °(S(Iel - H O 2,2,4- Trimethylpentane Other: 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 5Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 6 AVCOLORADO XnaCn eF.nv:rnnm.ni Permit Number: 17WE1195 AIRS ID Number: 123 /9F74/ [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. 'L4g.4. ure of Legally Authori / Pe rson erson (not a vendor or consultant) Matthew T. Berghorn 7- Z3' -S' Date VP - Engineering & Constructer Name (please print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) Send this form along with $152.90 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 AvCOLORADO 7 I e°L aF_vv kit..n Glycol Dehydration Unit APEN - Form APCD-202 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for Glycol Dehydration (Dehy) Units only. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.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: 17WE1195 1195 ApCD Stationan' 5purseg AIRS ID Number: 123 / 9F74 / 0 (7 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification: D-321 1 [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Discovery DJ Services Site Name: Discovery Lochbuie Compressor Station Site Location: SEC 21 T1 N R65W Mailing Address: (Include Zip Code) 3601 Stagecoach Road, Ste. 202 Longmont, CO 80504 E -Mail Address2: mnorton@discoverymidstream.com Site Location County: NAICS or SIC Code: 213112 Permit Contact: Matt Norton Phone Number: (817) 455-5799 1Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-202 - Glycol Dehydration Unit APEN - Revision 02/2017 1 385601 AV COLORADO Permit Number: 17W E 1195 AIRS ID Number: 123 /9F74/ [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 name ❑r Add point to existing permit O Change permit limit 0 Transfer of ownership3 0 Other (describe below) -OR - ❑ APEN submittal for update only (Please note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (Pit) ° Additional Info Et Notes: 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: natural gas. 50 MMscfd TEG dehydrator for the removal of water from Facility equipment Identification: D-3211 For existing sources, operation began on: / / For new or reconstructed sources, the projected start-up date is: TBD / / 0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area Is this unit located at a stationary source that is considered a Major Source of (HAP) Emissions days/week Yes Yes Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 2 AV weeks/year No No COLORADO ]np°rbar. J F clic Permit Number: 17WE1195 1195 AIRS ID Number: 123 / 9F74/ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Dehydration Unit Equipment Information Manufacturer: Dehydrator Serial Number: Glycol Used: TBD TBD Ethylene Glycol (EG) Model Number: TBD Reboiler Rating: 1 .0 ❑ DiEthylene Glycol (DEG) Glycol Pump Drive:❑ Electric ❑ Gas If Gas, injection pump ratio: Pump Make and Model: TBD Glycol Recirculation rate (gal/min): Lean Glycol Water Content: Max: 10 gpm 0.10 Wt.% MMBTU/hr ❑ TriEthylene Glycol (TEG) Requested: 10 # of pumps: Acfm/gpm 2 Dehydrator Gas Throughput: Design Capacity: 50 MMSCF/day Requested: 18,250 MMSCF/year Actual: MMSCF/year Inlet Gas: Pressure: 1,098 Water Content: Wet Gas: Flash Tank: Pressure: 65 Cold Separator: Pressure: Stripping Gas: (check one) E None ❑ Flash Gas ❑ Dry Gas ❑ Nitrogen Flow Rate: scfm psig Temperature: 80 lb/MMSCF 0 Saturated Dry gas: psig Temperature: 145 °F 0 NA psig Temperature: °F ❑ NA °F lb/MMSCF Additional Required Information: Attach a Process Flow Diagram 2 Attach GRI-GLYCaIc 4.0 Input Report Et Aggregate Report (or equivalent simulation report/test results) ❑✓ Attach the extended gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 3 I AV coLoeaoo vQuu�env o(FacSic Permit Number: 17W E 1195 AIRS ID Number: 123 /9F74/ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) Latitude 39.95903963/Longitude -104.68078147 Operator Stack ID No. Discharge Height :. Above Ground Level. . (Feet) Temp.Flow (-0 Rate .. (itcFM) Velocity (fu')�i` TBD TBD TBD TBD TBD Indicate the direction of the stack outlet: (check one) ❑� Upward El Horizontal ❑ Downward El Other (describe): Indicate the stack opening and size: (check one) ❑ Upward with obstructing raincap Circular Interior stack diameter (inches): TBD ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): El Other (describe): Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 (©AW COLORADO 4 1 iapl'uFirvrrr n�ni Permit Number: 17WE1195 1195 AIRS ID Number: 123 /9F74/ [Leave blank unless APCD has already assigned a permit II and AIRS ID] Section 6 - Control Device Information J Condenser: Used for control of: Regenerator Type: BTEX Maximum Temp 400 Make/Model: TBD 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: Regenerator Vent & Flash Gas Rating: 8.82 MMBtu/hr Type: Enclosed Combustor Make/Model: LEED , EC48-2S L30-0035-000 Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: 98 98+ % % Waste Gas Heat Content 1500 Btu/scf Constant Pilot Light: 0 Yes ❑ No Pilot burner Rating 0.0456 MMBtu/hr Closed ❑ Loop System: Used for control of: Description: System Downtime O Other: Used for control of: Description: Control Efficiency Requested Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 Ay COLORADO 5 I 4VY ,,pa _ e Permit Number: I7W E 1195 AIRS ID Number: 123 / 9F74( [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ['Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) PM Sax NOx CO VOC BTEX Condenser and Enclosed Combustor 98% HAPs BTEX Condenser and Enclosed Combustor 98% Other: 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 Emission Factor Units Emission Factor Source op -42, Mfg. etc) tual+ � Emissions Requested Annual Permit ueste on Pe Uncontrolled (Tons/year) Controlled' (Tons/year) Uncontrolled (Tons/year) Controlled (Tons/year) PM Sax NOx CO V0C /oi-.I (q I lbs/hr GRI-GLYCaIc ),�5.3 5. a9 Benzene 9.15)- lbs/hr GRI-GLYCaIc e 6035 ( lb) Iy3i Toluene 5. 95 lbs/hr GRI-GLYCaIc rj -1D(o (16\ (0(,5 Ethylbenzene d_..!-Fcb lbs/hr GRI-GLYCatc 14 ti (Ib) 5 P• Xylenes '- .M 9- lbs/hr GRI-GLYCaIc 2,I5gg(Ib) lyo n -Hexane O. c6 LA lbs/hr GRI-GLYCaIc 331( I61 1'40 2,2,4- Trimethylpentane Other: 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 5Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. 4(616 Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 ®V COLORADO 6 I �navraw e�cu� :tvL•F uF.•.V.rrnrnrr�ai Permit Number: 17WE1195 1195 AIRS ID Number: 123 /9F74/ [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. 7-25 47 Signature of Legally Authorizedjerson (not a vendor or consultant) Matthew T. Berghorn Date VP - Engineering & Constructs Name (please print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) Send this form along with $152.90 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 �Y COLORADO Hello