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HomeMy WebLinkAbout20194617.tiffCOLORADO Department of Public Health Et Environment Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 October 16, 2019 Dear Sir or Madam: RECEIVED OCT 2 3 2019 WELD COUNTY COMMISSIONERS On October 17, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for DCP Operating Company, LP - Enterprise Compressor Station. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health 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 Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director pub);c Review cc:P4.(rP),,Pw(IH/E&/CH/ck), l O%x/19 o6(7,4) 1 a/a.ut/l 9 2019-4617 41 TM Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: DCP Operating Company, LP - Enterprise Compressor Station - Weld County Notice Period Begins: October 17, 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: DCP Operating Company, LP Facility: Enterprise Compressor Station This facility is a natural gas compressor station. SWSW Section 30, T3N, R63W (6 miles northeast of Keenesburg) Weld County The proposed project or activity is as follows: Permit replacement dehydration unit and emissions increases to the stabilized condensate storage tanks and stabilized condensate loadout. 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 19WE0492 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: Elie Schuchardt Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 COLORADO Department of Public Health Er Exwircrimcnt COLORADO Air Pollution Control Division zrtrnent or Putt c Heath Et Enrcrerontnent Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 1 9WE0492 Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: Equip Issuance: 1 DCP Operating Company, LP Enterprise Compressor Station 123/0277 SWSW Sec 30, T3N, R63W ita County tural Gas Compressor Station subject to this permit: Emissions Control, Description Facility Equip dent P013 AIRS'' Point Equipment Description Eight (8) 300 barrel fixed roof stabilized condensate storage vessels Enclosed Combustor AtrCospheric'truck Loadout of stabilized condensate by submerged fill Enclosed Combustor D-3 077 One (1) Triethylene glycol (TEG) natural gas dehydration unit (make, model, serial number: not submitted) with a design capacity of 145 MMscf per day. This emissions unit is equipped with two (2) FMC Triplex glycol pumps (one primary, one backup) with a design capacity of 25 gallons per minute each. This unit is equipped with a flash tank, reboiler and still vent. Emissions from the still vent are routed to a condenser and then to an enclosed combustor (COMB -1), permitted 1% downtime annually. Emissions from the flash tank are routed directly to the VRU and recycled to plant inlet or routed to the enclosed combustor during permitted periods of VRU downtime, not to exceed 5% downtime annually. Point 077: The glycol pumps may be replaced with another pump in accordance with the provisions of the Alternate Operating Scenario (AOS) in this permit. Page 1 of 22 COLORADO, Air Pollution Control Division imer: or r;abtc Health (1. Er on n err Dedicated to protecting and improving the health and environment of the people of Colorado 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. Point 077: YOU MUST notify the Air Pollution Control Division (the Division) nolater 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/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions cot tained in this permit shall b.e demonstrated to the ;division °lt is the owner or operator's responsibility to ,self -certify compliance with the conditions ••"Failure to demonstrate compliance within 180 days may result ink revocation -of the' permit. A self certification form and guidance on how to self -certify compliance as required by this permit may beaobtained online'at www.colorado.coVicdphe/air- )Sermit-self-ceficati(oh. (Reference: 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 nor activity was scheduled to commence as set_fin the permit -application associated,. with this permit; (ii) discontinues construction fora 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. (Reference:'; Regulation Number 3, Part B, Section 4. Point 077: 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. (Reference: Regulation Number 3, Part B, Section III.E.) 5. Point 077: The following information shall be provided to the Division within fifteen (15) days of the latter of commencement of operation or issuance of this permit. • The dehydrator manufacturer name, model number and serial number • The glycol circulation pump manufacturer name and model number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation Number 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS Page 2 of 22 COLORADO Air Pollution Control Division ent of Pazst c Health & rnvtronment Dedicated to protecting and improving the health and environment of the people of Colorado 7. Emissions of air pollutants shall not exceed the following limitations. (Reference: Regulation Number 3, Part B, Section II.A.4.) Monthly Limits: Facility Equipment ID AIRS Point Process Pounds per Month Emission Type PM2.5 PM10 NO. V0C CO D-3 077 01 --- --- 85 3,751 386 Point 02 --- --- 165 316 753 03 --- --- 4 0.2 4 Note: Monthly limits are based on a 31 -day month. For Point 077, the following process designations apply: • (01) Dehydration Unit 2),`Combustor Assist.rGas (03) Combustor Pilot Gas A The owner or operator'shall calculate monthly emissions based on the calendar rn i tth. Point 063, 077: Emissions of each individual hazardous air pollutant from glycoldehydration its and storage vessels shalt not exceed 1,359 pounds per month •_ of dehydration units and Point 063, 077: Emissions of total hazardous air pollutants fray storage vessels:.shall not exceed 3,398 pounds per month. The facility wide emissions limitation for hazardous air pollutants shall apply to? the glycol dehydration unit and storage vessels at this facility only. Annual Limits: Facility Equipment ID AIRS Point Process Tons: per Year PM2.5 PM10 NO. V0C CO Emission Type P013 063 01 1.68 Point P016 066 01 0.94 Point D-3 077 01 0.50 22.08 2.27 02 0.97 1.86 4.43 03 0.02 0.001 0.02 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. For Point 077, the following process designations apply: • (01) Dehydration Unit • (02) Combustor Assist Gas • (03) Combustor Pilot Gas Point 063, 077: Emissions of each individual hazardous air pollutant from glycol dehydration units and storage vessels shall not exceed 8.0 tons per year. Page 3 of 22 COLORADO Air Pollution Control Division aramem of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado Point 063, 077: Emissions of total hazardous air pollutants from glycol dehydration units and storage vessels shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to the glycol dehydration unit and storage vessels at this facility only. Point 077: 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 both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 8. Point 063, 066: The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 9. Point 077: Compliance with the emission limits in this permit shall be demonstrated by running the GRI GlyCalc, model version 4.0 or higher on a monthly basis using the most recent extended wet gas analysis and recorded operational values, including: dry gas throughput, lean glycol recirculation rate, vapor`„recovery unit (VRU) downtime, ,enclosed combustor downtime, condenser outlet tem;peratur.e, flash ;,tank temperature and pressure, wet gas inlet temperature, and wet gas inlet pressure. Recorded operational values, except for gas throughput, VRU downtime and,enclosed combustor downtime, shall be averaged on a monthly basis for input into the model and be provided to the Division upon request. 10. Point 077: On a weekly basis, the owner or operator shall monitor and record operational values including: condenser outlet temperature, flash tank temperature and pressure, wet gas inlet temperature and pressure. These records shall be maintained for a period of five years and made available to the Division upon request. 11. Point 077: On a daily basis, the owner or operator shall monitor and record hours of VRU downtime in a log to be made available to the Division upon request. VRU downtime is defined as periods of time where the waste gas vented from the dehydration unit flash tank is routed to the enclosed combustor, rather than to the VRU. These records shall be maintained for a period of five years and made available to the Division upon request. 12. Point 077: On a daily basis, the owner or operator shall monitor and record hours of enclosed combustor downtime in a log to be made available to the Division upon request. Enclosed combustor downtime is defined as periods of time where the waste gas vented from the dehydration unit still vent is routed to atmosphere, rather than to the enclosed combustor. These records shall be maintained for a period of five years and made available to the Division upon request. 13. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Reference: Regulation Number 3, Part B, Section III.E.) Page 4 of 22 COL0RA0O Air Pollution Control Division. ent of *,attic Health ft En tronment Dedicated to protecting and improving the health and environment of the people of Colorado Facility Equipment ID AIRS Point Control Device Pollutants Controlled P013 063 Enclosed Combustor VOC and HAP P016 066 Enclosed Combustor VOC and HAP D-3 077 Still Vent: Enclosed Combustor (except during enclosed combustor downtime - up to 1% annually) VOC and HAP Flash Tank: Enclosed Combustor (during VRU downtime - up to 5% annually) VOC and HAP 14. Point 077 =The owner or operator shall operate and maintain.. the emission ;points in he table below as -a closed loopsystem and shall recycle 100% of emissions as described in the table below. (Reference: Regulation Number 3, Part B, Section III.E.) ) Facility Equipment ID AIRS Point Emissions Recycling Description Pollutants Recovered D-3 0 Flash Tank: Recycled to Plant Inlet with VRU (except during VRU downtime - up to 5% downtime annually) VOC ;and HAP: PROCESS LIMITATIONS AND RECORDS 16. 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. (Reference: Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Process Parameter Annual Limit Monthly Limit (31 days) P013 063 01 Stabilized Condensate Throughput 202,848 barrels --- P016 066 01 Stabilized Condensate Loaded 202,848 barrels --- D-3 077 01 Dry Gas Throughput 52,925 MMscf 4,495 MMscf/month 02 Assist Gas Throughput 28.0 MMscf 2.4 MMscf/month 03 Pilot Gas Throughput 0.44 MMscf 0.04 MMscf/month For Point 077, the following process designations apply: Page 5 of 22 ICOLORAQO Air Pollution Control Division 7ariment of Puz;l:c He k t 4 Et. won?nex t Dedicated to protecting and improving the health and environment of the people of Colorado • (01) Dehydration Unit • (02) Combustor Assist Gas • (03) Combustor Pilot Gas The owner or operator shall monitor monthly process rates based on the calendar month. Point 077: 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. 17. Point 077: The volume of drygas throughput shall be measured by gas meter at the outlet of the dehydrator. The owner or "operator shall use monthly throughput records'todemonstrate compliance with the processlimits contained in this permit and to calculate'.em ssions as •described i this permit. 18. Point 0.77: The; total amount ofIgas throughputto the dehydration unit during'hours of VRU downtime shall�not exceed 5% of the total gas throughput to the dehydration unition a rolling twelve (12) month basis. Compliance with- this limit will be monitored monthly using the monthly dehydration unit gas ` throughput; indicated by the gas meter•` in conjunction with the total monthly 'hours of VRU downtime Records demonstrating compliance with this limitation will be maintained an4. made'available tonne Division upon request. 19. Point 077: The total amount of gas throughput to the"dehydration unit during hourstof enclosed combustor downtime shall not exceed,1% the total "gas throughput to the dehydration unit on a rolling twelve (12)°month basis. Compliance with this limitwill be monitored monthly using the monthly dehydration unit gas.' throughput indicated ; by the gas meter in conjunction with the total monthly hours of enclosed combustor downtime. Records demonstrating compliance with this limitation will be maintained and made available to the Division upon request. 20. Point 077: This unit shall be limited to the maximum lean glycol circulation rate of 25 gallons per minute. The lean glycol recirculation rate shall be recorded daily 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 (Loft) provisions under MACT HH. (Reference: Regulation Number 3, Part B, II.A.4) STATE AND FEDERAL REGULATORY REQUIREMENTS 21. Points 063, 077: 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. (Reference: Regulation Number 3, Part B, Section III.E.) (State only enforceable) Page 6 of 22 COLORADO Air Pollution Control Division. brit of Publlc Health C I_,^,ionn-an€ Dedicated to protecting and improving the health and environment of the people of Colorado 22. Points 063, 066, 077: No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Reference: Regulation Number 1, Section II.A.5.) 23. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 24. Point 063: The storage tanks covered by this permit are subject to Regulation Number 7, Section XII.I. The owner or operator must do the following and maintain associated records and reports for a period of five years: • Document the maintenance of the air pollution control equipment according to manufacturer specifications; • Conduct an annual opacity observation once each year on the air pollution control equipment to verify opacity does not exceed 20% during normal operations; Maintain records of the monthly stabilized condensate' throughput and monthly actual VOCemissions; and • Report compliance with these requirements . to the Division annually. Reference: Regulation No. 7, Section XII.I.4) 25. Point 063: The combustion device controlling the condensate storage tanks covered by this permit is subject to Regulation Number 7, SectionXVII B 2ssGeneral 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 normatloperations, as defined under Regulation Number 7, XVII.A.17; an be designed so that an Observer can, by means of visual observation from . the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 26. Point 063: The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. Page 7 of 22 COLORADO Air Pollution Control Division Department or Public Health tr Environment Dedicated to protecting and improving the health and environment of the people of Colorado 27. Point 063: The storage tanks covered by this permit are subject to the capture requirements of Regulation Number 7, Section XVII.C.2.a. The owner or operator must route all hydrocarbon emissions to air pollution control equipment, and must operate without venting hydrocarbon emissions from the thief hatch (or other access point to the tank) or pressure relief device during normal operation, unless venting is reasonably required for maintenance, gauging, or safety of personnel and equipment. Compliance must be achieved in accordance with the schedule in Section XVII.C.2.b.(ii) and records must be maintained as required by Section XVII.C.3. 28. Point 066: This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III.D.2) 29. Point 066: All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained; so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable..` 30. Point 066: The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): The owner or operator shall inspect'onsite� loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor toss during loading and unloading. The inspectionshall occur at lest monthly. Each inspecti• on: shall be documented in a log available to the"Division on request. All compartment hatches at the acility (including o f hatches) shall be closed and latched at all. ;times when loading operation : are not active, except fad' periods of maintenance, gauging, o safety Of personnel and equipment. '^spect thief hatch seals annually for integrity and replace as necessary, FThief hatch covers shall be weighted and properly seated.` d. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs shall be set to release at a pressure that will ensure flashing, working and breathing losses are not vented through the PRD under normal operating conditions. e. Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. 31. Point 066: For this controlled loading operation, the owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. b. Include devices to prevent the release of vapor from vapor recovery hoses not in use. c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. Page 8 of 22 OLORADO Air Pollution Control Division ent of ueec Health -E Errtionment Dedicated to protecting and improving the health and environment of the people of Colorado d. Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. 32. Point 077: 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. (Reference: Regulation Number 7, Section XII.H.1.) 33. Point 077: The combustion device controlling the dehydration unit 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 o pounds 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 property'. This flare must be equipped with an operational auto ignitor according to the followinschedulc All combustion devices installed on nor after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; All combustion devices .installed before May 1, 2014, must be equipped with an rational auto -igniter by or before May 1, 201'6, or after the next combustion device awned shutdown, whichever comes first. 34. Point 077: 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. 35. Point 077: 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. (Reference: Regulation Number 8, Part E, Subpart A and HH) MACT HH Applicable Requirements Area Source Outside UA/UC boundary Page 9 of 22 COLORADO Air Pollution Control Division .parintent ct runic Re:atth h Ervtrt nmen;s Dedicated to protecting and improving the health and environment of the people of Colorado §63.760 - Applicability and designation of affected source §63.760 (f) - The owner or operator of an affected major source shall achieve compliance with the provisions of this subpart by the dates specified in paragraphs (f)(1) and (f)(2) of this section. The owner or operator of an affected area source shall achieve compliance with the provisions of this subpart by the dates specified in paragraphs (f)(3) through (f)(6) of this section. 563.764 - General Standar §63.764 (d)(2) -Each owner or operator of an area source not located in a UA plus offset and UC boundary (as defined in §63.761) shall comply with the provisions specified in paragraphs (d)(2(i) through (iii) of this section. §63.764 (d)(2)(i) - Determine the optimum glycol circulation rate using the following equation: 1.15*3.0 gaTEG *F*(I -O)\ lb 11,0 24hr / day Where: LOFT =.; Optimal circulation rate, gat/hr. F = Gas flowrate (MMSCF/D) I = Inlet water content (lb/MMSCF) 0 =cutlet water conteh lb/MMSCF 3.0 = The industry accepted rule of thumb for a TEG-to water 7 ratio (gal TEG/lbH2O) 1.15 = Adjustment factor included for a margin of safety. §63 x,64 (d)(2)(ii) - Operate the TEG dehydration unit such that the actual glycol circulation rate does not exceed the optimum glycol circulation rate determined in accordance with ;paragraph (d)(2)(i) of this section. If the TEG dehydration unit is unable to meet the sates gas specification for moisture content using the glycol circulation rate determined in accordance with paragraph (d)(2)(i), the owner or operator must calculate an alternate circulation rate using GRI-GLYCalcTM, Version 3.0 or higher. The owner or operator must document why the TEG dehydration unit must be operated using the alternate circulation rate and submit this documentation with the initial notification in accordance with §63.775(c)(7). §63.764 (d)(2)(iii) - Maintain a record of the determination specified in paragraph (d)(2)(ii) in accordance with the requirements in §63.774(f) and submit the Initial Notification in accordance with the requirements in §63.775(c)(7). If operating conditions change and a modification to the optimum glycol circulation rate is required, the owner or operator shall prepare a new determination in accordance with paragraph (d)(2)(i) or (ii) of Page 10 of 22 COLORADO Air Pollution Control Division artmenr o€ lies-faatth Er Envtronment Dedicated to protecting and improving the health and environment of the people of Colorado this section and submit the information specified under §63.775(c)(7)(ii) through (v). §63.774 - Recordkeepr�ng Requirements §63.774 (b) - Except as specified in paragraphs (c), (d), and (f) of this section, each owner or operator of a facility subject to this subpart shall maintain the records specified in paragraphs (b)(1) through (11) of this section §63.774 (b)(1) §63.774 (b)(1) - The owner or operator of an affected source subject to the provisions of this subpart shall maintain files of all information (including all reports and notifications) required by this subpart. The files shall be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report or period. °§63.774 (b)(1)(i) - All, applicable records shall such a manner that,they can be readily accesse §63 774 (b)(1)(i1) Tfle most recent 12 months of records shall be retained on site or shall be accessible from a central' location byAmputer or other means that provides access within 2 hours der a reques_ §63.774 (b)(1)(in) The remaining 4 years of records may be retained offsite. §63,x`74 (b)(1)(iv) - Records may be maintained in hard copy or computer -readable form including, but not limited to qn paper, microfilm,, computer, floppy disk;:` magnetic tape, or microfiche. §63.774 (f) - The owner or operator of an area source not located within a UA plus offset and UC boundary must keep a record of the calculation used to determine the optimum glycol circulation rate in accordance with §63.764(d)(2)(i) or §63.764(d)(2)(ii), as applicable §63.775 (c) - Except as provided in paragraph (c)(8), each owner or operator of an area source subject to this subpart shall submit the information listed in paragraph (c)(1) of this section. If the source is located within a UA plus offset and UC boundary, the owner or operator shall also submit the information listed in paragraphs (c)(2) through (6) of this section. If the source is not located within any UA plus offset and UC boundaries, the owner §63.775 - Reporting Requirements Page 11 of 22 COLORADO Air Pollution. Control Division }gar nent or Pubic Health 4 Fnrz¢ronn<.s n Dedicated to protecting and improving the health and environment of the people of Colorado or operator shall also submit the information listed within paragraph (c)(7). §63.775 (c)(1) - The initial notifications required under §63.9(b)(2) not later than January 3, 2008. In addition to submitting your initial notification to the addressees specified under §63.9(a), you must also submit a copy of the initial notification to EPA's Office of Air Quality Planning and Standards. Send your notification via e-mail to CCG-ONG@EPA.GOV or via U.S. mail or other mail delivery service to U.S. EPA, Sector Policies and Programs Division/Coatings and Chemicals Group (E143-01), Attn: Oil and Gas Project Leader, Research Triangle Park, NC 27711. §63.775 (c)(7) - The information listed in paragraphs ;(c)(1)(i) F,n through (v) of this'section. This inf'ormatioshall"be submitted' with the initial notification. §63.775 (c)(7)(i) Documentation;of the source's location relative to the nearest UA plus offset and UC boundaries. This information shall include the latitude andlongitude (lithe affected source; whether the source is located in an urban cluster with 19,000 people or more;`the distance in miles to the nearest urbanized area boundarythe source is not Located in an urban cluster with 10,000 people or more; and the names of the nearest.'urban cluster with 10,000 people or more and nearest urbanized area. §63.775 (c)(7)(ii) - Calculation of the optimum glycol Circulation rate determined in accordance with §63.764(d)(2)(i). §63.775 (c)(7)(iii) - If applicable, documentation of the alternate glycol circulation rate calculated using GRI-GLYCalcTM, Version 3.0 or higher and documentation stating why the TEG dehydration unit must operate using the alternate glycol circulation rate. §63.775 (c)(7)(iv) - The name of the manufacturer and the model number of the glycol circulation pump(s) in operation. §63.775 (c)(7)(v) - Statement by a responsible official, with that official's name, title, and signature, certifying that the facil,ity will always operate the glycol dehydration unit using the optimum circulation rate determined in accordance with §63.764(d)(2)(i) or $63.764(d)(2)(ii), as applicable. Page 12 of 22 COLORADO Air Pollution Control Division I Department of Puel c Health & Emaronree t. Dedicated to protecting and improving the health and environment of the people of Colorado §63.775 (f) - Notification of process change. Whenever a process change is made, or a change in any of the information submitted in the Notification of Compliance Status Report, the owner or operator shall submit a report within 180 days after the process change is made or as a part of the next Periodic Report as required under paragraph (e) of this section, whichever is sooner. The report shall include: §63.775 (f)(1) - A brief description of the process change; §63.775 (f)(2) - A description of any modification to standard procedures or quality assurance procedures §63.775 (f)(3) - Revisions to any of the information reported in the original Notification of Compliance Status Report under paragraph (d) of this section; and wvi §63.775 (f)(4) - Information required by the Notification of Compliance Status Report under paragraph (d) of this section for changes involving the addition of processes or equipment. OPERATING &t MAINTENANCE REQUIREMENTS 36. on startup offthese points, the owner or operatorrshall follow the most recent operating and maintenance (O&tM) plan and record " keeping format' approved by the Division, -'?;n order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to e&tM plan'`are subject to Division approval prior to implementation. (Reference: Regulation llaer 3 .-Part B, Section COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 37. Point 077: 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. (Reference: Regulation Number 7, Sections XVII.B.2. and XVII.A.17) 38. Point 077: 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.) Page13of22 COLORADO Air Pollution Control Division. Department of F tItc Health tt flmbonreent Dedicated to protecting and improving the health and environment of the people of Colorado 39. Point 077: The owner or operator shall complete the initial extended gas analysis of the fuel gas used for assist and pilot gas within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit. The owner or operator shall use this analysis to calculate actual emissions, as prescribed in the Emission Limitation and Records section of this permit, to verify initial compliance with the emission limits. The owner or operator shall submit the analysis and the emission calculation results to the Division as part of the self -certification process. (Reference: Regulation Number 3, Part B, Section III.E.) Periodic Testing Requirements 40. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, on a daily basis 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. (Reference: Operating Permit 95OPWE103 Condition 4.3 and Regulation Number 7, Sections X1 I B.2. and XVII.A.17) if opacityls observed,, the owner or operator shall perform EPA Reference` Method 9, 40 C.F.R. Part 60, Appendix A to measure opacity from the flare for one continuous hour. (Reference: Regulation Number 1, Section II.A.5.) ) 41. Print 077: Thee owner or operator shall complete an extended wet gas analysisrior to the inlet of the dehydrate unit on an annual basis. Results of the wet gas analysisjshall be used to calculate emissions of criteria pollutants and hazardous air, pollutants per this permit and be provided to the Division upon request. 42. Point 077: The owner or operator shall complete an extended gas analysis on the fuel gas used as' assist and pilot gas on an annual basis. Results of the extended gas analysis shalt be used to calculate emissions of criteria pollutants `and hazardous air pollutants per this permit and be provided to the Division upon request. ALTERNATE OPERATING SCENARIOS 43. Point 077: The dehydration unit's electric pumps may be replaced with another electric glycol pump in accordance with the requirements of Regulation 3, Part A, Section IV.A and without applying for a revision to this permit or obtaining a new construction permit. A replacement pump shall operate at the same or lower glycol recirculation rate as authorized in this permit. 44. Point 077: The owner or operator shall maintain a log on -site or at a local field office to contemporaneously record the start and stop dates of any pump replacement, the manufacturer, model number, serial number and capacity of the replacement pump. 45. Point 077: All pump replacements installed and operated per the alternate operating scenarios authorized by this permit must comply with all terms and conditions of this construction permit. ADDITIONAL REQUIREMENTS 46. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation Number 3, Part A, II.C.) Page 14 of 22 COLORADO Air Pollution Control Division t e ,ar4rnent of P' btc Health 6 En -Aram -hem Dedicated to protecting and improving the health and environment of the people of Colorado • 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 NO, 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 r,any non -c. eportable pollutant: If tl emissionsiincrease y 50% or five (5) tons per year, whichever is less, above the level:: reported on the last,APEN submitted to the Division. Whenever ther is a change in the owner or.operator of any facility, process or activity; or Whenever new c ntro equipment is instal or whenever a different t of control equipment replaces an existing type of control equipment; or Whenever a permit limitation must be modified; or No latter than 30 days before the existing APEN.expire 47. ' his source is subject to the provisions of Regulation Number 3 Part C, Operating Permits (Title he 1990 Federal°:Clean Air Act Amendments). TheproViitons of this construction permit must be incorporated into the Operating Permit. The application for the modification to the Operating Permit is due within one year of the issuance of this permit. 48. The requirements of Colorado Regulation No. 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.7.8). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Facility Equipment ID AIRS Point Equipment Description Pollutant Emissions - tons per year Threshold Current Permit Limit Page 15 of 22 ;COLORADO Air pollution Control Division Dedicated to protecting and improving the health and environment of the people of Colorado P013 063 Stabilized Condensate Storage Tanks P016 066 Stabilized Condensate Loadout D-3 077 TEG Dehydration Unit PW 075 Produced Water Storage Tank 'AAMBtu/hr eboi ler VOC 40 1.68 0.94 23.95 2.11 The produced water storage tank (AIRS 075) is',a permit exempt source (18WE08 XP) pursuant to the Colorado egulation No. 3, Part B, Section ll.D.1 m exemption (wastewaters<1,% crude oil). However,; with the addition` of the new, larger,,dehydration unit, throughput o,this tank is expecte,to increase Therefore, the PTE of this source is still considered in the project increase when evaluating NANSR applicability ' The 1 vlMBtu/hr reboiler :associatedE with dehydration unit D-3 is both an APEN and permit exemptIsource pursuant to Colorado Regulation No. 3, Part A, Section II.D.1 k and Part B, Section II.D.1 because this source was installed with 1Y-... as a part of this modification, the PTEsi f this source must considered in thee project ' increase when evaluating NANSR *ability. ' P Y• GENERAL TERMS AND CONDITIONS 49. 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. 50. 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. Page 16 of 22 COLORADO Air Pollution. Control Division ; tunvnt of ` ub tc Health b C• nvLonrnett Dedicated to protecting and improving the health and environment of the people of Colorado 51. 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. 52. 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. 53. 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 erm or condition of the permit. If the Division denies a Permit,, conditionseimpose tupon a permit are,contested by the owner or operator, or the Division revokes a permit, t e owner or operator of a source may request i hearing before the AQCC tor review of the Division's action. 54. Section 25-7-14.7(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 la:cancellation of the permit. ,Upon notification annual fee billing will terminate. 55. Violation of the terms of a permit or of the provisionsof the. Colorado Air Pollutio'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 enalties -122.1 (criminal pena ties C.R.S. By: Elie Schuchardt, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to DCP Operating Company, LP for the construction of a new dehydration unit (D-3) and to permit increased emissions from the stabilized condensate storage tanks (P013) and condensate truck loading (P016). Page 17 of 22 'COLORADO Air Pollution. Control Division ra c t:1,,.71:c HealthEt r. ironnien Dedicated to protecting and improving the health and environment of the people of Colorado 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. (Reference: 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 PartxlI.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of;non-criteria reportable airpollutants 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. AIRS Point 063 Pollutant Benzene CAS # 71432 Incontrolled Emissions' (tb/yr)° Controlled Emissions (lb/yr)', 41 Toluene 108883 3,043 152 Ethylbenzene 100414 203 10 Xylenes 1330207 2,231 112 n -Hexane 110543 6,491 325 066 Benzene 71432 105 5 Toluene 108883 129 6 n -Hexane 110543 734 37 077 Benzene 71432 133,283 7,773 Toluene 108883 199,611 11,751 Ethylbenzene 100414 6,227 369 Xylenes 1330207 45,786 2,725 n -Hexane 110543 26,253 922 Page 18 of 22 ?COLORADO Air Pollution Control Division Department of rP b c Hean & Fr; inar.l Hutt Dedicated to protecting and improving the health and environment of the people of Colorado 2,2,4-Trimethylpentane 540841 18 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) Point 063: The emission levels contained in this permit are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source -- VOC 0.332 0.0166 Mass Balance 71432 Benzene 0.004 0.0002 Mass Balance 108883 Toluene 0.015 0.0008 Mass Balance 1330207 Xylene 0.011 0.0006 Mass Balance 11,054 . n -Hexane ... 0.032 .: 0.00.16 Masi Balance Note The controlled emissions` factors for this point are based°on a control=,e 0. 6) Point066: The emission levels contained in thispermitare based on the following emission factors: Pollutant ncontrolled ission Factors lb/bbl .: Controlled Emission Factors lb/bbi Source VOC 0.186 0.009 x.0003; Mass Balance Mass Balance n -Hexane 110543 0.006 uncontrolled VOC emission factor was calculated using AP -42, Chapter 5. verson.1 /95) using the following values: L = 12.46*S*P*M/T S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 4.65 psia M (vapor molecular weight) = 66 lb/lb-mol T (temperature of liquid loaded) = 520 °R Equation 1 The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor. Controlled emission factors are based on an enclosed combustor efficiency of 95% and a collection efficiency of 100%. Page 19 of 22 COLORADO Air Pollution Control Division n €n£ ct a In Health ft Err onme=:t Dedicated to protecting and improving the health and environment of the people of Colorado 7) Point 077: The emission levels contained in this permit are based on information provided in the application, the emission factors listed below and the GRI GlyCalc 4.0 model. VOC and HAP Emissions: Total actual VOC and HAP emissions for the dehydration unit will be the sum total of the emissions generated by the flash tank, still vent, assist gas and pilot gas. The following summarizes the calculation methodologies for each source of VOC and HAP emissions: • Flash Tank VOC and HAP Emissions: Actual controlled VOC and HAP emissions from the flash tank are based on 100% control efficiency when the emissions are routed to the VRU, and a 95% control efficiency when the emissions are routed to the enclosed combustor during periods of VRU downtime. VRU downtime is not to exceed 5% of total annual dehydration unit operation. To determine actual flash tank emissions, the hourly flowrate of the "Flash Tank Off Gas" stream obtained from the most recent GlyCalc run will be multiplied by the total number of hours during which the VRU was not operating and flash gas emissions were routed to the enclosed' combuustor, to' whichha control efficiency of 95% will'be,applied. Still Vent VOC and HAP Emissions: Actual,controlledVOC and HAP emissions from the still vent are based on a 95% control efficiency when the emissions are routed to the enclosed, combustor, and, +a 0% control efficiency when the emissions are routed to atmosphere during enclosed combustor downtime. Enclosed combustor downtime is not to exceed 1% of total°annual dehydration unit operation."To;deetermine actual still vent emissions, the hourly�`flowrate of the "Uncontrolled' Regenerator Emissions" stream obtained from the most recent GlyCalc run will be multiplied by the total number of hours during which the enclosed combustor was operating and still vent emissions were routed to it, to which a control efficiency of will be applied. Emissions generated during enclosed, combustor downtime will be added to this value, and will be determined by multiplying the hourly -flowrate of the "Uncontrolled Regenerator Emissions" stream obtained from the most recent GlyCalc run by the number of hours during which the enclosed combustor was not operating and emissions were routed to atmosphere. • Assist Gas VOC and HAP Emissions: Actual controlled VOC and HAP emissions from the combustion of assist gas are based on a 95% control efficiency for the enclosed combustor. Note that assist gas is only used when the enclosed combustor is operating; assist gas emissions are not generated during periods of permitted enclosed combustor downtime. To determine actual assist gas emissions, the assist gas flowrate (based on a set value of 3,200 scfh) will be multiplied by the VOC and HAP content indicated by the most recent extended analysis of the fuel gas used as assist gas and the hours of enclosed combustor operation, to which a control efficiency of 95% will be applied. • Pilot Gas VOC and HAP Emissions: Refer to the combustion emissions section below. Combustion Emissions: Total actual NOx and CO emissions for the dehydration unit will be the sum total Qf the emissions generated from flash tank, still vent, assist gas and pilot gas combustion. The following tables and notes set forth the calculation methodologies for each source of combustion emissions: Page 20 of 22 COLORADO Air Pollution Control Division t-Pahl₹c Wealth b Er a onment Dedicated to protecting and improving the health and environment of the people of Colorado Still Vent Primary Control (Enclosed Combustor; permitted 1% annual downtime): CAS # Pollutant Uncontrolled Emission Factors lb/MMbtu Source NOx 0.068 AP -42 Chapter 13.5 Industrial Flares CO 0.31 AP -42 Chapter 13.5 Industrial Flares Note: The combustion emission limits listed in this permit are based on a heating value of 1,549 Btu/scf. Actual emissions are calculated using the emission factors in the table above, the heat content of the "Condenser Vent Stream" obtained from the most recent GlyCalc run, the hourly flowrate of the "Regenerator Overheads Stream" obtained from the most recent GlyCalc run and the hours per month that the still vent was routed to the enclosed combustor. Note that NOx and CO emissions are not produced during periods of permitted downtime, since still vent emissions are routed to atmosphere and not combusted. Flash Tank Secondary Control (Enclosed Combustor; during permitted 5% annual VRU downtime): S # Pollutant Uncontrolled : Emission Factors lb/MMbtu ource NOx „ 0.068 k .. AP -42 Chapter 13.5 Industrial Flares CO 0.31 AP -42 Chapter 13.5 Industrial Flares Note The combustion emission limits listed in this permit are based on a heating value of 1,360 Btu/s;„Actual emissions are calculated using the`emission facto in the table above, the heat content and hourly,flowrate of the "Flash Tank Off yea � Gas" obtained from the°most recent GlyCalc run, and the hours per month that the flash tank gas was routed to the enclosed combustor. Nate that NOx and COemissions are.not produced during periods of VRU operation, Where the flash gas ts`recycled to inlet and not combusted. Assist Gas Combustion (Enclosed Combustor) CA' # ` Pollutant' Uncontrolled Emission' Factors lb/MMbtu Source NOx 0.068 AP -42 Chapter 13.5 Industrial Flares CO 0.31 AP -42 Chapter 13.5 Industrial Flares Note: The combustion emission limits listed in this permit are based on a heating value of 1,020 Btu/scf. Actual emissions are calculated using the emission factors in the table above, the heat content of the fuel gas obtained from the most recent analysis, a constant assist gas flowrate of 3,200 scfh and the hours of enclosed combustor operation. Pilot Gas Combustion (Enclosed Combustor): CAS # Pollutant Uncontrolled Emission Factors lb/MMscf Source NOx 100 AP -42 Chapter 1.4 External Combustion CO 84 AP -42 Chapter 1.4 External Combustion VOC 5.5 AP -42 Chapter 1.4 External Combustion Note: The combustion emission limits listed in this permit are based on a heating value of 1,020 Btu/scf. Actual emissions are calculated using the emission factors in the table above, the heat content of the fuel gas obtained from the most recent analysis, a constant pilot gas flowrate of 50 scfh and the hours of enclosed combustor operation. 8) 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 Page 21 of 22 COLORADO} Air Pollution Control Division Porto Health rr Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 9) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 10) This facility is classified as follows: Applicable Requirement Status Operating, Permit Major Source of: NOx, CO, VOC, HAP PSD v NANSR True Minor Source of: NOx ;'Synthetic,Minor Source of:' VOC, CO Major Source of: NOx MACT HH ,Major Source Requirements Not Applicable AreaSource Requirements: Applicable 11) Full text of the Tltte 40, Protection of Environment Electronic Code of Federal Regulations can be found at the webste listed below: http //ecfr.gpoaccess gov/ Part 60 Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 22 of 22 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package 6: Received Date: Review Start Date: Elie Schuchardt 386033 5/17/2019 5/22/2019,;, _. Section 01- Facility Information Company Name: DCP Operating Company, LP County AIRS ID: 123 Plant AIRS ID: 0277 Facility Name: Enterprise Compressor Station Physical Address/Location: County: Type of Facility: NatunatGas Compressor Station What industry segment?Oil &:"NaturalGas Production & Processing Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? L Carbon Monoxide (CO) SWSW quadrant of Section 30, Township 3N, Range 63W Weld County Section 02 - Emissions. Units In Permit Application Particulate Matter (PM) E Quadrant Section Township Range SWSW Ozone (NOx & VOC) 3N ... 63 AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 063 Condensate Tank P013 -- Yes I9WE0492 CPI No -:. Permit ' Modification Permitted under 95OPWE103 066 ,.. Liquid Loading P016 .. Yes 19W50492 CP1 No '._ ... Permit Modification Permitted under 95OPWE103 077 Dehydrator 0-3 Yes 19WE0492 CP1 yes Permit initial Issuance New defy to replace D-2 Section 03 - Description of Project This modification requests the permitting of a new TEG dehydration unit (AIRS 077) rated at 145 MMSCFD to replace TEG dehydration unit D-2 (AIRS 068) rated at 11r MMSCFD for increased dehydration capacity. Enclosed flare COMB -1 (previously AIRS 074) will no longer be its own point, but will instead be grouped under the new dehydration unit AIRS ID (077), as requested. This modification also permits additional throughput for Stabilized Condensate Storage Tanks (AIRS 063) and Stabilized Condensate Loadout (AIRS 066) as a result of the increased dehydration capacity. Note that an increase in V0C emissions from the permit -exempt produced water storage tanks (AIRS 075,18VUE0877.XP) is also expected with this modification, but as a permit exempt unit, is not addressed in this PA. A project emissions accounting analysis was received with this modification to demonstrate that this project falls below the significance threshold of 40 tons/year VOC for a moderate ozone non -attainment area (Colorado Regulation No. 3, Part D, Section ILA.44). Because the combined potential to emit (PTE) of each of the sources permitted under this modification, the permit exempt produced water tanks and and APEN and permit exempt dehydration unit reboiler cumulatively fall below the40 ton/year significance threshold for VOC in moderate ozone non -attainment areas, the project emissions accounting analysis was not evaluated in detail. Because emissions associated with this project when evaluating each unit at PTE are below the significance threshold for VOC (cumulative potential to emit= 28.72 tons/year (including the permit -exempt produced water tanks)), this modification does not constitute a major modification for the purposes of NANSR. Note that the NOx and CO emission increases from this project are well below their respective significance levels of 40 tons/year and 100 tonslyear as welt. Section 04- Public Comment Requirements Is Public Comment Required? If yes, why? Req€ estingSynthetic Mina r P Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? Ifio If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? No Is this stationary source a synthetic minor? Yes If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration IPSO) Colorado Air Permitting Project Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) LI Li ULU LI U L L L Is this stationary source a major source? If yes, explain what programs and which pollutants herSO2 Prevention of Significant Deterioration (PSD) ❑ Title V Operating Permits (OP) L Non -Attainment New Source Review (NANSR) NOx CO VOC PM2.5 PM10 TSP HAPs ❑ ❑ ❑ O O Li Li L L U L4 L u L Condensate Storage Tank(s) Emissions Inventory 063 Condensate Tank 'Facility AIRs ID: f128$% t county Plan 06 Poi Section 02 - Equipment Description Details Detailed Emissions Unit Fight (8) 300 bbl Fixed Roof Stabilized Condensate Storage Tanks (P013) Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency 56: ,Endosed Flare (mfg: LEED): Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput = IRequested Permit Limit Throughput= Potential to Emit (PTE) Condensate Throughput = Secondary Emissions - Combustion Device(s) MW of Butane MW of Pentane Heat content of Butane Heat content of Pentane Heat content of waste gas= Universal Gas Constant=si'ft3/IbmoCR Atmospheric Pressure = MW of Vapors= °RB lb/Ibmol Temperature= Vented 474188 scf/yr Volume of waste gas emitted per BBL of liquids produced = 2.338 scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = S 1 . 5. Barrels (hall per year 202,8481 Barrels (bbl) per year Barrels (bbl) per year 58.127b/Ibmol 5 Ib/Ibmol iii Btu/scf 9 Btu/scf TBtu/scf Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Actual Condensate Throughput While Emissions Controls Operating= 54,165: Barrels (bbl) per year Requested Monthly Throughput= 17228 Barrels (bbl) per month 430 MMBTU per year .1,5.7.,1. MMBTU per year .1,6.1.1. MMBTU per year Pollutant Uncontrolled Controlled (Ib/bbl) (Ib/bbl) (Condensate Throughput) 0.004 (Condensate Throughput) 0.0166 0.0002 MIIIM112212M =EMI MMIERTEMIIM MIESEEMIIMI11 0.001 0.011 Pollutant mmzEmm 0.00.1::.;.. 0.0001 0,0000 0.0000 Control Device Uncontrolled Uncontrolled (lb/MMBtu) waste heat combusted) (lb/bbl) U3` (Condensate Throughput) 0.0001 0.0001 0.0005 0.0025 Emission Factor Source Emission Factor Source 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) VOC PM10 PM2.5 NOx CO 33.07 8.99 8.45 33.67 .1.68 786 0.01 0.00, 0.00 0.01 0.01 0.00 0.00 0.01 0.01 1 0.05 0.01 0.01 0.05 0.05 9 0.25 0.07 0.07 0.25 0.25 42 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 TMP 811 217 11 811 41 3043 812 41 3043 152 ' 203 54 3 203 10 22:31 546 30 22:3.3, 112 6491 1733 87 6481 325 0 0 0 0 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B 'Source requires a porntit 3 of 16 K:\PA\2019\19 W E0492. C P 1 Condensate Storage Tank(s) Emissions Inventory Regulation 7, Section XII.C, D, E, F Storage Tank is not subject to Regulation 7. Section X€I.C-F; Subject to Section XII.I Regulation 7, Section XII.G, C Storage Tank is not subject to Regulation 7, Section XII,0 Regulation 7, Section XVII. B, C.1, C.3 ' Storage tank is subject to Regulation 7, Section XVI€, B, C.1 & CS Regulation 7, Section XVII.C.2 Storage Tank is subject to Reuglation N. 7, Section XVII.C.2.a Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to P157510, Regulation 6, Part A, NSPS Subpart 0000 Storage Tank is not subject to NSPS 0000 Regulation B, Part E, MACT Subpart H H Storage Took is not subject to MALT NH (See regulatory applicabiliy worksheet for detailed analysis) 4 of 16 K,\PA\2019\19WE0492.CP1 Condensate Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-0 Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then It may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01 Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling 2N/A- site specific EF used Section 08 - Technical Analysis Notes L In operator correspondence received 7/79/2019, it was verified that the correct'condendsate throughput value is 202,840bhl/yr, as listed vs the APEN submitted with the 5/17/2079 applicati in I., This modiflaatien servgsonly su increasethe permitted throughput to these tangs. Note that this increase i n throughput should theere} rally only result in an increase in working losses from these tanks; breathing lasses should remain unchanged. As a conservative approach, the operator elected to ratio the Total working and breathing losses by the throughput to.arrive at the new emissierr limitations, as opposed to ratioing the working losses only. 3, 591 aI samplingwas not included In this permitter the condensate storage n since -these tanksstore only stabilized condensate. Because this condensate is stabilized down to an RVP seciScation, it is not expected that the composition of condensate would vary significaMly, sincethis RVP specification is not changing. Note that ail emission factors listed in this permit were obtained from a site-sper fissamp€e dated 5/26/2011, which was included in a construction permit application received 1/5/2012 (this application was incorporated directly into the 8/1/2012 renewal of opera? rig"-. permit 9SOPWE103), 4. As a conservative approach, the operator assume approximation for the stabilized condensate), ha 00% he hydrocarbon emissions estimated using EPA Tanks 4.0.9d were VOC emissions (notethatRVP 10 gasoline was used as an 5. interpolation between butane and pentane was used to arrive at the heat content of the -super stream from these condensate storage tanks. Since the vapor molecular weightof 66 Ib/lbmol estimated from EPA Tanks4.0.9d falls between butane (MW = 58.12 Ib/Ibmei) and; pentane._ (MIN =72.15), it was assumed that the heat content of the tank vapors should fall between a heat content of 3010.8 Stu/soffor butane and 3'6998t5/scf for pentane. Interpolation between these two values was used to arrive at the heat content of the tank vapor stream of39978tu/scfr Note that the heat contents used for "interpolation are the lower (net) heating values of butane and pentane,: since the AP -47 Chapter 13.5 emission factors are applicable to the lower heatingvalue of the stream combusted, _ .. _.. 6. These condensate storage tanks are not located at pipeline orrailcar injection facility and is therefore not subject to Colorado Regulation No 7, Section Vl.B.2. ZThe EoterpnseCompressor Station is major source of HAP, for the purposes of Title V. However, because it is classified as a production field facility under MACTHH, only HAP emissions produced Ytum dehydration dolts and storage Vessels are aggregated for the purposes of major source determination for this rule (563.761 definition -of major source). Total HAP emissions from The dehydration unit D-3 and condensate storage tanks P013, when taking into account federally enforceable controls,donot produce emissions in excess of the majorsource thresholds. As such, for the purposes of MAC( HH, the Enterprise Compressor Station is considered to bean area source of HAP emissionssubject only tOTE6 dehydration unit requirements.Syothetic minor HAP limits -were introduced into the permitter hese toe emission_ points only to ensure major source MACT H H requirements are not triggered during the permit term. 8. The condensate storage tanks are exempted from the requirements of Colorado Regulation No 7, Section XII.0 Fpursuant to Section 11151. Because air pollution control equipment is installed and operated on these tanks (Section Xlt.t.1),the air polllution control equipment achieves a 95% HOC control efficiency (Section X11.12, note that the SEED combustor is rated to a design destruction efficiency for hydrocarbons of 88% In accordance with the Section XVII.C.1,4requirement), and OCP does not own or operate any exploratiion and production facilities within the B Hour Ozone Control area (Section Xt1,1.3),these condensate stofage tanks are exempted from the system -wide controlrequirements of Section Xl4C F. in accordance with Section XII.ifthese storage tanks are instead subject to Sections Xlf.I.4arid Xll.t3- Note that the engine, fugitive emission and compressor requirements under Section Xil.t.5 are tsi de the scope of this construction permit and were therefore not ". included in the permit, 3 Because thesestorage tanks exclusively hold stabilized condensate, these tanks are not subject }o the STEM plan requirements of Colorado Regulation No. 7, Section XVII.C.Lb However, these tanks are subfectM the capture requirementsset forth in Section XVILC2.a. Compliance with these capture requirements will be achieved in accordance with the same schedule as required for those storage tonics that are regpired to.Hevelap a STEM plan and records shall be kept pursuant to the requirements i Section )0/11,C,S, 50. Method 22 readings to monitor compliance against the no visible emissions reggirements of Colorado Regulation Na 7, Section XVII.82will be condpcc d on a daily basis, pursuant to the .I f₹equencyset forth in the 8/1/2012 Issuance of the operating permit. 11. For the purposes of SOPS regulations, the definition of modification per 40 CFR'part 60.2 isa any physics₹ change in, or change in the method of operation of, an existing farshty,ohicIs increases the amount of any air pollutant (to whidt a standard applies) emitted into the atmosphere by that facility or which results in the emission of any air pollutant (to which a standard applies) into the atmosphere not previously emitted." Note that the operator is requesting to increase condensate. throughput witch increases the VOC emitted Asa result, the storage vessels would be considered modified per the definition above. Since this source will be modified after the applicability date for NSPS 0000 (September IS, 2015) the source would be potentially subject to NSPS 0000a Based on the regulatory analysis, it was determined these storage vessels are not subject to NSPS0000a because the potential VOC _emissions per storagevessel are less than 6tpy Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # Process # SCC Code 063 01 - 5.f,�"-tS. Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 ' 0 lb/1,000 gallons condensate throughput PM2.5 .0.00 0 lb/1,000 gallons condensate throughput NOx 0.01 0 lb/1,000 gallons condensate throughput VOC 7.9 95 lb/1,000 gallons condensate throughput CO 0.06 0 lb/1,000 gallons condensate throughput Benzene 0.10 95 lb/1,000 gallons condensate throughput Toluene 0.36 95 lb/1,000 gallons condensate throughput Ethylhenzene 0.02 95 lb/1,000 gallons condensate throughput Xylene 0.26 95 lb/1,000 gallons condensate throughput n -Hexane - 0.76 95 lb/1,000 gallonscondensate throughput 224 TMP 0.00 95 Ib/1,000 gallons condensate throughput 5 of 16 K:\PA\2019\19 W E0492.CP1 Condensate Tank Regulatory Analysis Worksheet Colorado Regulation Parts A and 8 - APEN and Permit Requirements ounce is in e:,s 4o -Attainment Area ATTAINMENT 1. Are uncontrolled actual emtsions from any criteria pollutants from this individual source greater than 2 TPY(Regulatian 3, Part A, Section ll.D.I.a)? 2. Is the construction date (service date) priorto 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and114 and Section 2 for additional guidance on grandfather applicability(? 3. Are totalfacllhy uncontrolled VOC emissions greater than TPY, NOx greater than lO TPY or CO emssions greater than lO IVY (Regulation 3, Part B, Section 11.0.3)? I'cor.h,Lve:nmc'atod thatsou:oe isistiherce-Attainment Ataa NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this Individual source greater than l TPY (Regulation 3, Part A, Section ll.Dl.e)? 2. Is the canstmdian date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greaterthan 2 TPY, NO4greaterthan 5TPY or CO emissions greaterthan lO Try (Regulation 3, Part B, Indian 11.0.2)? 'Sow -cc reaulres a permit Colorado Regulation 7, Section XILc-F • 1. Is this storage tank looted in Cie 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area) 2. 'stills storagetank located at an oil and gas exploration and production operation`, natural gas compressor station or natural gas drip station? 3. Is this storage tank located upstream of a natural gas Processing Plant? Iurn+age tank is cuir( t to Rcgulatirn i, Section Xii,C.F Section 011.1.1 -General Requirements for Air Pollution Control Equipment- Prevention of Leekags Section XII.C.2-Emission Estimation Procedures Section )(11.0- Emissions Control Requirements section NILE - Monitoring Section XILF-Recordkeeping and Reporting Source Is NOT subject to Xll.C-F see PA notes for condensate tank; subjectta XII.I Colorado Regulation?. Section MI. 1. Is this storage tank lasted in the 8 -hr ozone control area or any axone non -attainment area or attainment/maintenance area) 2. Is this storage tank located at anatural gas processing plant? 3. Does this storage tank eshibtFlash°(e.g. storing nan-stabiliaed liquids) emissions and have uncontrolled actual emissions greaterthan or equal to 2 tons per year %/CC? o g'Lark .;rattublecttr,Reguiatfen7,Snxi::nX0.ti Section 011.0.2- Emissions Control Requirements Section XII.C.1 —General Requirements for Air Pollution Control Equipment —Prevention of Leakagr Section XII.C2—Emission Estimation Procedures Colorado Regulation?. Section WI) 1, Is this tank located at a transmission/storage facility? 2. Is the condensatestaragetank' located at an oil and gas exploration and production operation, well production faciliuf, natural gas compressor station' or natural gas processing plant? 3. Is the condensate storage tank a fried roof storage tank? 4. Are uncontrolled actual emissions of this storage tank equal to or greater than S tons per year VOC? Iat0-aga tares It subject to Neguiaticn 1, Semfon XVii, N. C.L. A C5 Section XVila —General Provisuns for Air Pollution Control Equipment and Prevention of Emission, Section XMI.C1- Emissions Control and Monitoring Provisions Section XVII.t.3 - Remrdkeepilg Requirements Dom the condensate storage tank cancan only "stabllized" liquids? 'Stooge Tanks th,, uisjeet t:: Pygpiatian 7, 9act'inu ( Vd.f.2 section XVII.C2 - Capture and Monitoring for Storage Tanks fined with Air Pollution Control Equipment Storage tanks are subject to capture requirements inflection XVII.C2.e only; STEM does not apply 40 CFR. Part 60. Suboen rib. Standards of Performance for Volatile Organic Liquid Storage Vessels 1. lithe individual storage vessel apathy greaterthan or equal to 75 cubic meters (ma) (-4T2 Bats)? 2. Does the storage vessel meet the following exemption in 60.111b(d)(4)? a. Does the vessel has a design capacity less than or equal to 1589.874 ma 1'"10,000 BBL) used for petroleum' or condensate stored, processed, ortreated prior to custody transfe? as defined in 60.1116? 3. Wasthe condensate storage tank constructed, reconstructed, or modd"ed(see definitions 40 CFR, 60.2) afteruuN 23, 1984? 4. Does the tank meet the definition of 'storage vessel. in 60.1116? 5. Does the storage vessel store a"volatile organic liquid (VOL). as defined in 60.1111? 6. Does the storage vessel meet any one of the following additional exemptions: a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa ("29.7 psij and without emissions to the atmosphere (60.110b(d)(2))?; or b. The design capacity is greaterthan or equal to ]51 ma (550 BBL] and stores a liquid with a maximum true vapor pressure` less than 35 kPa (60.11ob(b)I?; or c. The design capacity is greaterthan or equal to 75 ref (^471 BBL) but less than 151 m3 ('-950 BBL) and stores a liquid with a maximum true vapor pressure° less than 15.0 kPa(60.110b(b))? Yes Na tae lye......,,.. Steepgo Tana is rants subinrita MPS Kb Subpart A, General Provisions 46o.112b - Emissions Control Sttardarat for V0C §601136 -Testing and Procedures §60.1156- Reporting and Recordkeeping Requirement 460.116b - Monitoring of Operations 40 CFR, Part SO, Subpart 0000. Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this condensate storage vesellocated at a facility In the onshore ail and natural gas production segment, natural gas processing segment or natural gas transmission and Adage segment of the industry? 2. Was the condensate storage vessel constructed, reconstructed, or modified( see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? 3. Are potential VOC emissionsirow the Individual storage vessel greaterthan or equalto 6. tons peryear? 4. Does this condensate storage vessel meet the definition of"storage vessel's per 60,5430? 5. Is the storage vessel sub)ed to and controlled In accordance with requirements forstorage vessels in d0 CFR Part 6oSubpart Kb or 40 CFR Part 63 Subpart FM? 'Std gel' 0000 Subpart A. General Provisions per 6605425Table 3 450.5395- Emissions Control Standards far VOC 460.5413 -Testing and Procedures 4605395(g) - Nmifiatlan, Reporting and Recordkeeping Requirements 660.5416(c) -Cover and Closed Vent System Mennodng Requirements 460.541? -Control Device Monitoring Requirements INme: If a storage vessel Is preubusly determined to be subject to NIPS 0000 due to emissions above 6 tons per year VOC on the appllability determination date, It should remain subject to NSPS 0000 per 60.5365(e)(2) even If potential VOL emissions drop below6 tans per year] 40 CFR, Part 63, Subpart MAR NH, Oil and Gas Production Facilities 1. Is the storage tank located at an oil and natural gas praductionfacility that meets either of the following criteria: a. Afadlt that processes, upgrades or stores hydrocarbon liquid? (63.?50(a)(2)); OR b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end use? (63.760(a)(3)l? 2. Is the tank looted at a facility that Is major. for HAP'? 3. Does the tank meet the definitionof"storage vessel• In 63.761? 4. Does the tank meet the definhionof"storage vessel with the potential forflash emissions. per 63.261? 5. Is the tank subject to control requirements under40 CFR Part 50, Subpart lb or Subpart 0000i '6toraga Tank is notsuclect tc MCI Hy Subpart A, General prav''eians per 463.764 (a) Table 2 §63.766 -Emissions Contra) ltandards 463.773 -Monitoring §63274- Recordkeeping - §63.775 -Reporting RACE Review RAC] review Is required If Regulation 7 does not apply AND lithe tank is In the non -attainment area. If the tank meets both criteria, then review RACr requirements. Wsddirnet This document assists operators With determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a role or regulation, and the analysis d contains may net apply to a particular situation based upon the indtuiduel facts and circumstances. This document does not change or substitute for any law, regulation, or any other legallybinding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, end Air Qualify Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as 'recommend," 'may,' ...should," and 'Wan," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and °required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. hone Iran I Hydrocarbon Loadout Emissions Inventory 066 Liquid Loading (Facility AIRS ID: Coun Plan Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Is this loadout controlled? Collection Efficiency: Control Efficiency: 95.00 Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded = Requested Permit Limit Throughput= Potential to Emit (PTE) Volume Loaded = v yposi lee:: Barrels (bbl) per year f VOIN4f1'L,ax$48iBarrels (bbl) per year Requested Monthly Throughput = Actual Volume Loaded While Emissions Controls Operating = G 54,16; Barrels (bbl) per year 17228 Barrels (bbl) per month Secondary Emissions - Combustion Device(s) MW of Butane MW of Pentane Heat content of Butane Heat content of Pentane Heat content of waste gas= Universal Gas Constant= Atmospheric Pressure = Volume of waste gas emitted per year = Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = $- d2;u ,Barrels (bbl) per year 58.12`. Ib/Ibmol 72.15 Ib/Ibmol 3010..8'. Btu/scf 3699 Btu/scf 3397 Btu/scf .0.731psi*ft3/Ibmol'R 2 psia scf/year Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04- Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility being permitted? Loading Loss Equation L = 12.46" S'P•M/1 240 MMBTU per year 900 MMBTU per year 900 MMBTU per year The stabilized hydrocarbon liquid sample is valid for developing site specific emissions factors. Factor Meaning Value Units Source 5 Saturation Factor 0.5 { y yaI4P�42Lhagtta'5.2T i 5ubtt6eged €fldt'Ltng: fid [ate4Ncast a[Secy o(S:0: ,.'""" P True Vapor Pressure 4.65-.::. .,.. psia M Molecular Weight of Vapors 66 Ib/Ib-mol T Liquid Temperature .519.67. Rankine ;Qy L Loading Losses 4.4555055? lb/1000 gallons 0.185433342 lb/bbl Component Mass Fraction Emission Factor Units Source Benzene 0.00270 0.001 lb/bbl Site Specific Sample Toluene 0.003 0.001 lb/bbl Site Specific Sample Ethylbenzene -::0.000 0.000 lb/bbl :Site Specific Sample Xylene 0.001 0.000 Ib/bbl Site Specific Sample n -Hexane 0.020 J 0.004 lb/bbl Site Specific Sample 224TMP :.0.000 0.080 lb/bbl Site Specific Sample Emission Factors Pollutant VOC Benzene Toluene Ethylbenzene Xylene Hydrocarbon Loadout Uncontrolled Controlled (lb/bbl) (Volume Loaded) (lb/bbl) (Volume Loaded) Br4 0.009 00 .0000 n -Hexane 0.0036 224 TMP 5,0000 Pollutant Control Device 0.0000 0.0 0.0000 Uncontrolled Uncontrolled (Ib/MMBtu) (lb/bbl) (waste heat combusted) (Volume Loaded) PM10 0.007 PM2.5 500 NOx 0,0680 CO 0.3100 , 0.0075 i.. 0.0006` E- 3.02E - 4 3.020: 114 E Emission Factor Source Emission Factor Source 7 of 16 K:\PA\2019\19 W E0492.CP1 Hydrocarbon Loadout 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 0.00 0.00 0.00 0.00 0.00 1 PM2.5 0.00 0,00 0.00 0.00 0.00 1 SOx 0,101 0,00 11,00 11,00 0,00 II NOx 0.03 0.01 0.01 0,03 0.03 VOC 10.81 5,02 0.20 18,81 0,94 160 CO 0..14 0,114 0.04 0.14 4,14 24 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 105 28 1 105 5. Toluene 120 34 2 129 6 Ethylbenzene 4 T _ 0 4 0 Xylene 20 5 0 20 1 n -Hexane 734 196 10 734 3'2 224TMP 0 0 0 0 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B bounce requires a permit RACr- Regulation 3, Part B, Section 111.0.2.a (See regulatory applicability worksheet for detailed analysis) The loaduut mast be operated with submerged RIl to satisfy RACr. Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 09 - Inventory 5CC Coding and Emissions Factors AIRS Point# 066 Process# 31 5CC Code 4-06-001-22 Crude Oil: Submerged Loading Normal Service (S-0.6) Uncontrolled Emissions Pollutant - Factor Control % Units PM10 0.00 0 lb/1,000 gallons transferred PM2.5 0.00 0 lb/1,000 gallons transferred 5Ox 11.00 i) lb/1,000 gallons transferred NOx 0.01 0 lb/1,000 gallons transferred' VOC 4.4 95 lb/1,000 gallons transferred CO 0.33 0 lb/1,000 gallons transferred Benzene 0;01 45 lh/1,000 gallons transferred Toluene 0,02 95 lb/1,000 gallons transferred Ethylhenzene 0.00 95 lb/1,000 gallons transferred Xylene 0.00 95 lb/1,000 gallons transferred n -Hexane 0.09 95 lb/1,000 gallons transferred 224TMP 0.00 95 lb/1,000 gallons transferred 8 of 16 lU\PA\2019\19WE0492.CP1 Hydrocarbon Loadout Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.l.a)i 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 11.0.1.1)7 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)' (You have indicated that source is in the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)i 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)' (Source requires a permit 7. RAT - Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section III.D.2.a)i (The loadout must be operated with submerged fill to satisfy RACT. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend,""may,""should," and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as must" and "required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Glycol Dehydrator Emissions Inventory 077 Dehydrator Facility Alto ID: 0}72.... 077.:. County Plant Paint Section 02 -Equipment Description Details Dehydrator Information Dehydrator Type: Make: Model: Serial Number. Design Capacity: Recirculation Pump Irdormation Number of Pumps Pump Type Make: Model: Design/Max Recrculation Rate: Dehydrator Equipment Flash Tank Reboiler Burner Stripping Gas Dehydrator Equipment Description Emission Control Device Description: MMsd/day gallons/minute , flash tank, and reboller burner One (I)Triethyiene glycolfTEG) natural gas dehydration unit (Make: TOD, Modo:TBD, Serial Nonber.'BD)with a desiin capacity of_4SMMecf per day. This cuipped with 2 t1 primary,1 backup) (Make: FMC, Med.: Stip@x) electric driuen giycol pumps with a deign cspacity of 20 gallons per "lint.. 'Chi ctehyd aeon unit Is equipped with a null vent, HasSPank. end mboaor home:.. Emission s from thestll vent are routed to a.4endensar, end then to the fnclotoA Gate. 3niesiens from the flash monk are reisfod directly to the Vapor Recovery Unit ;WW1. Ate encondery control devoe. fresh toot nnni sel.,rn ere ratted to the Enclosed Flare. Section 03-Proeessing Rate Information for Emissions Estimates Primary Emissions Dehydrator Still Vent and Flash Tank (If pent 'Requested Fermi Limit Throughput = ° A2923p :i MMscf per year Requested Monthly Throughput= 5455 MMscf per month Potential to Emit (FM) Throughput= 52,525 MMsct per year Actual Throughput= 0 MMscf neryeen Secondary Emissions -Combustion Device(s)for Alr Pollution Control . Still Vent Control Condenser. Condenser emission reduction claimed: Primary control deulce, 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: Secondary control device: Secondary control device operation: Flash Tank Gas Heating Value Flash Tank Waste Gas Vent Rate: Assist Gas Assist Gas Routing: Assist Gas Operation: Assist Gas Heating Value Assist Gas Rate: Pilot Gas Pilot GasRoudng: Pilot Gas Operation: Pilot Gas Heating Value Pilot Gas Vent Rate: Section 04 -Emissions Factors & Methodologies ,°,1'07n„, nod from the mungui0.§i Control Efficiency % hr/vr Requested TO TemPo,,.°. �e ._. _ t., Control fVlnhennt% Btu/srt iids7:isdh <: :8]60 I,rlVr ii 0073 Btu/sd iii 3203 0Th 26.032 MMsd/yr 0760 hr/yr 2020. Btu/set scfh 0.438 MMsd/yr 0.0572 MMscf/month Control Efficiency % Control Efficiency % Input Parameters Inlet Gas Pressure Inlet Gas Temperature Requested Glycol Recirculate Rate STILL VENT Pollutant VOC Benzene Toluene Ethylbenzene Bylenes n -Hexane 224-TMP Uncontrolled llb/hrl ..:::81.6559 Control Scenario Primary Controlled (lb/hr) 4,t 07n5 0.755495 1.11.1 0.07512 0.253:'OS 0.0TT335 0.(530`03 Secondary Controlled llb/hrl &1.0553 4.7899 22.3302 0.7014 5.1&37 1.5661 0.0:111 34.7699 23382 0.2024 i0 251837 ' 1,5061 I'IDlOin FLASH TANK Pollutant VOC Benzene Toluene Ethylhenzene Xylenes n-Hesane 224-TMP Control Scenario Primary Secondary Uncontrolled llb/hrl tka57,O743' y;.'R; ESAMOIROM Controlled (lb/hr) Controlled lib/hrl 0 0 2.853755 0.022205 0.022423 0.03'0042 0,00215 0.06344.5 3982537 Dry Gas Thmuehout Still Vent Primary Control 52.325.0 MMsct/yr Still Vent Secondary Control: 529.0 MMscf/yr Waste Gas Combusted: Still Vent Primary Control: 0.6 MMscf/ter Still Vent Secondary Control: 0.0 MMscf/yr Dry Gas Throughout Flash Tank Primary Control: 50,270.0 MMsd/yr Flash Tanknecondary Control: 2,546.3 MMscf/yr Waste Gas Combusted: Flash Tank Primary Control: 0.0 MMscf/Yr Flash Tank Secondary Control: 0.5 MMsd/yr 4,435.^ MMscf/month 0.0 MMscf/month Glycol Dehydrator Emissions Inventory Throughput (0) MW 20.052 10.303 MMscf/yr Ibdh-nwl 3200 scf/hr MMscf/d 0,0708 Mol % MW MW Gas Wt% tonnelize far H( VOC Wt% lia/hr lis/yr tpy Helium 0.01 4 0.00 000 — — — — — 0O2 1.18 43.99 0.52 2.83 - - - - - N2 0.38 28.02 0,11 0.58 - - - - - methane 86,85876 16.01 13.91 75.71 78.38 - - - - ethane 9.5372 30.02 2,86 15.59 16.14 - - - - propane 1.5989 4403 0.70 3.83 3.97 3,97 6.15 57035,0: 23.52 isobulane 0.1041 58.04 0.06 0.33 0,36 0.34 0,53 4020,50 2.01 n -butane - 0,2321 58.04 0.13 0,73 0.76 0.76 1.100 10201,00 6.10 isopentane 0.0395 72.05 0.03 0,15 0.16 0.16 0,25 2120.33 149 n -pentane 0,038 72.05 0,03 0.15 0.15 0.15 0.24 2001.52 1.05 cydopemane 0 — — — — — — — — n -Hexane 0.0214 86.18 0,02 0.10 0.10 0.10 0,15 1410.35 0,71 63406 one 0 — — — — — — — — Other hexanes 0 86.06 0.00 0,00 0.00 0.00 4.00 0,00 0,05 heptane 0 — — — — — — - — — methylcyclohexane 0 — — — — — — — — 224-TMP 0 — — — — — — — Benzene 0 78.12 0.00 0.00 0.00 0,00 0,0:0 0,00 9,00 Toluene 0 92.1 0.00 0.00 0,00 0.00 5,00 0.00 0,00 Elhyiberizene 0 106.1 0.00 0.00 0,00 0,00 0,00 0,00 0,00 Xylene6 i 0 106.1 0.00 0.00 0.00 0.00 0,00 0,00 8,00 coe Heavies 0 — — — — — — — — VOC mass fraction: Still Vent P Control Device Uncontrolled Uncontrolled Pollutant P PM2,5 504 NO4 CO Pollutant (Ih/MMBtu) Illa/MMscf) Still Vent Secondary Control Device Uncontrolled Uncontrolled (Ih/MMBtul (Ib/MMscf) (Waste Heat Combusted) (Waste Gas Combusted) 10,363 Emission Factor Source Emission Factor Source PM10 PM2,5 50 NO4 CO :00 0000 Emission Factor Source Pollutant Flash Tank Primary Control Device Uncontrolled Uncontrolled (Ib/MMBtu( (Waste Heat Combusted) (Ih/(40Mscf) (Waste Gas Combusted( PMI0 PM2.5 500 NO4 CO lash Tank Secondary Control Device Pollutant Uncontrolled Uncontrolled (Ib/MMBtul (Ib/M (Waste Heat Combusted) (Waste Gas Combusted( Emission Factor Source Pilaf Ge Pollutant Uncontrolled E.F. Uncontrolled EC. (Ibs/MMBtu waste (lbs/MMscf waste gas heat combusted( volume combusted) Emissions Factor Source Citation PM10 NO Vac SC0 02 ``UVk n Hexane L,kit , Mel Gas ,0061 Pollutant PM10 PM3,5 SO N00 VOC Section OS - Emissions Inventory Old operator request a buffer?' Requested Buffer (°b): Benzene Toluene Ethylbe len n -Hexane 224TMP Emission Factor Source Uncontrolled Uncontrolled (Ih/MMBtul (Ih/MMscf( {Waste Heat Combusted) (ILL/MM 10 20 (Waste Gas Combusted) (Ib/MMscf) S2 5.400 Total VOC (Unoontro0 37,22 I vent emissions routed to atmosphere - nocombostion Flash Tank Primary Control Device 6 330 - no combustion YOVIPM ICBM I Potential to Emit Criteria Pollutants Uncontrolled Actual Emissions Requested Permit Limits equested Monthly Limits Uncontrolled Controlled Uncontrolled Controlled Controlled Glycol Dehydrator Emissions Inventory (cons/year) (sons/year) (tons/year) (tons/year) (tons/year) (lbs/monthl PBL10 PM2.5 004 Noe Co VOC 005 0.1)) 1.00 0.05 0.85 0.00 0,00 045 11,05 . 0.50 0.08 0.80 _. : 8.511 05 2.27 0.20 0.00 2.27 2.37 005 007,80 0.00 0.00 007,04 2„x:838 37.81 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Pe ink Limits Uncontrolled Controlled lbs/year) (lbs/year) Benzene Toluene Ethylbemene Xylene a -Hexane 224 TMP 133203 8)82 2AU 133003 1720 130011 0.005 ^00 ' 188511 17'851 0227 0.00 0,08 027-.7 0tH 35720 0:x 2.00 08701 2725 24840 0.00 0.70 01432 851 ., <,. m.�;c%rr�- 334233424313 Criteria Pollutants Paten tialto Ems Actual Emissions Requested Pe mil Limits Requested Monthly Limits Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/veer) (tons/year) (tors/veer) (sons/year) (lbs/month) PM10 PM2.5 50x NO5 CO VOC 0.11 0.00 0.00 0.10 ±:,1.0 10 0,11 0.00 0.00 0.11 11.11 Y0 0:01 0.00 000 0.01 0,01 8.07 0.00 0.00 0.87 037 165 0..93 0.00 0,00 4.43 Aka 753 32,22 _ 0,00 1 00 37,.22. 1.3E 014 Hazardous Air Pollutants Potential to Emit. Actual Emissions Requested Permit Limits _ Uncontrolled Uncontrolled Controlled Uncontrolled , Controlled (lbs/year) (lbs/year) (lbs/year) (Ibs/Year) , (Ibs/year) Benzene Toluene Etiylbenaene Xylem a -Hexane 224 TMP 0:s? 0.10 - 0,10 048 0.00 000 0.10 ::,20 0,06 8.00 17.89 0.80 0.00 0.00 0.00 0.07 0.00 0,00 000 0.00 1410.53 8.08 000 141033 70.92 ... 0,14 0.00 .. ... Criteria Pollutants Potential to Ems Uncontrolled (tans/year) Actual Emissions Uncontrolled Controlled (toes/year) (tons/year) Requested Pe mit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (Ibs/month) PM10 10012 4.00017 0.001? 04017 0.0.017 0 PM2.5 0.001; 0,0017 0,0017 0.0017 037017 0 502 0.0021 0.0021 0,0081 0.0001 0.8001 NOx 0.0219 71.0210 0.0210 0,021?. 0.0113 4 CO 0.0024 0.0104 0,0304 00104 0,0104 3 000 _ _ 0.0050 7.8800 il.0012 0.0010 0EOO12 0.2 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/yearl (lbs/year) Requested Pe mit Limits Uncontrolled Controlled (lbs/year) (lbs/year) n -Hexane 1 1. 0 0 ((so(((m((�rra(.. " ,,, ,'I . d::.° W> u// , :334 ,,0T ( 3 (7.:...i.\� 2333333,33 , - -: : Criteria Pollutants Potential to Emit Actual Emissions Requested Perms Limits Requested Monthly Limits Uncontrolled Uncontrolled Controlled' Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (Ibs/month) PMSO PMZ.5 505 NO0 CO VOC 7.70 0.00 0.00 810 0.14 07.54 010 8,00 0.28 0._0 0.10 2'1,04 0.01 0.00 000 0.01 101 2,00 1.10 0.02 0.00 0.4e 1.40 05336 5.70 0.02 0.02 5.72 0.72 1141.17 580.£70 0.08 0.00 604.06 23.45. 4067.50 Hazardous Air Pollutants Potential to Emit Uncontrolled (0s/year) Actual Emissions Uncontrolled Controlled (lbs/year) (Ibs/yearl Requested Pe mit Limos Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 303385 073 O.S 183203 '1223 1000::1 0.0) 0. 19051.', S:f761 4227 0.20 COO 5227 350 40103 0.03 0.33 - ?5100 8175 247x33 0.19 O.Ot5 26250 521. ' 10 0.00 Section 06 - Reeul atory Summary Analysis Regulation 3, Parts 4,B Regulation 7, Section XVII.B4O Regulation 7, Section XVII.B.2.e Regulation 7, Section XII.H Regulation 0, Part E, MACr Sub paste30 (Area) Regulation 8, Part y, MALT 5ubpart0H (Major) Regulation 8, Part E, MACE SubparfllHH (See regulatory applicability worksheet for detailed analysis) Source regoffee permit 0elnterater 70 325(£:: to Regulation 7, 52010010x'11, 0, 0.3 The control desitt for :his dei0A-atar is not subtou i to Reosdstion 7, 60121011 X00.0.2.0 Dehydrator is suajac-to Regulation'?, Seetio,=. 80.ti Oehy .suleet 5t, 30euurr4 MEET HN, per the (33,3o,ne,xa t,Rl64lnrool You haw (ndicatad Mat OWfacility is fell suf jece to t a or Source rveuirements of MGCT HH, You have indicated that this facility is not subject to MACY 11110. action 07 - Initialand Periodic Sampling and Testing Requirements Was the etoended wet gas sample used in the 0108410 model/Process model site-spectfic and collected within a year of application If no, the permit will contain an"Initial Compllance" testing requirement to demonstrate compliance with emission limits If the company has requested control device efficiency greaterthen 95%, is a thermal oxidizer or regenerative thermal oxidizer being used to achieve MI No I If yes, the permit will contain a condition specifying the minimum combustion chamber temperature for the thermal oxidizer Is the company using a thermal oxdizerAND requesting amnimum combustion chambertemperature lower than 1,400 degrees Ft kiie,.�"_ It yes, the permit will contain an "Initial Compliance(' testing requirement AND a permit condition specifying the minimum combustion chamber temperature for the thermal oxidizer. Analvs, YEersj'udF,h,. 4 doubt ms. emall{ioi rig '21/ 3oos/year( 7N'e q £Ge 1 d(fare. f3 g e£the p" i tt k g lit far y yep)'a a Is mode Incalrulatd ncaism114VDC end HAP emnsmn dunnga0%ser rogtlett P t tab Imo d I" lEota 00100 0 :fits ns'Ptillecte0 110100 0loded a he wnr aa,100 ti -,,,, xe d Ifth stree ga am"propeYles:resuhlnry "X.eterled the use of the ce PR a d yredd h drfF nu raacebet s P�'d#arperhn gpamas (I /140 4400)41 and wuheut tens. setts in sbghtlti me, A8n1egwhlchstlli'yentem' glohle,)S Glycol Dehydrator Emissions Inventory Lore ertendedgas nneNs @= app,Bva 6 receipttha, t}te o In den rrf=leda dniware3',u h h trovdess IoM&tp lyy rtF dund AhS074'h gnedi Fhed hyd t 9uAIR5Yfi-(k(N567'J,j It 1 ' h Same AP toe PY9YiffIgSC£L Se h,?n def vd tfag - IId fn cta a9.,ems l6a dEh g59 iGfitd��ard'$OW peY M1W telliacakheugh h pit gas dassrstg p doff {gas ih m ceswe dd edsgjj rateh9 HbU�jlq��sswkeaeddyNlaemfs�fdA factcr5iPAP-q"14hayterl4re, exteA+i an6uskfoRs d(gs.Assisi sar; mk snort arni 5,inns<jn ca vllefrotfi E i2r'¢riSe: aaz an Nstasamnleinf EYxain ytp i ,ice nPHAP forthe purp�sesvfirtlr edFv she pmpasas'bf ajar source de€ rretivnfo @(r(grceabiatpntr.is do notPEodv<e mwsk+M jn. dratdration n ent5-Suns thi I (46'a 6 -ess vfYhe ma}e e[k finer HAPI Dehydrator Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Non -Attainment Area ATTAINMENT • 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)? You have indicated that sourceis in the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY (Regulation 3, Part A, Section 11.111.a)? 2., Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.2)? (Source requires a Permit Colorado Regulation 7, Section XII.H 1. Is this glycol natural gas dehydrator located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area (Reg 7, Section XII.H.1 and 2)? 2. Is this glycol natural gas dehydrator located at an oil and gas exploration and productionoperation, natural gas compressor station, natural gas drip stationor gas -processing plant (Reg 7 Section 3. Is the sum of actual uncontrolled emissions of VOC from any single dehydrator or group of dehydrators at a single stationary source equal to or greater than 15 tpy (Reg 7, Section XII.H.3.b)? 4. Are actual uncontrolled emissions of VOC from the individual glycol natural gas dehydrator equal to or greater than 1 tpy (Reg 7, Section XII.H.3.a)? Dehydrator is subject to. Regulation 1, Section Xli.H Section XII.H — Emission Reductions from glycol natural gas dehydrators MACT Analysis 1. Is the dehydrator located at an oil and natural gas production facility that meets either of the following criteria: a. A facility,that processes, upgrades or stores hydrocarbon liquids (63.760(a((2)); OR A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final b. end user' (63.76D(a)(3)(? 2. Is the dehydrator located at a facility that is a major source for HAPs? (Go to MACT NH Area Source Requirement section to determine MACT NH applicability Yes Yes 40 CFR. Part 63. Subpart MACE HH. Oil and Gas Production Facilities Area Source Requirements 1. Is the dehydrator a triethylene glycol (TEG) dehydration unit (63.760(b)(2))? Exemptions 2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 3.001747 MMscf per day (63.764(e)(1)(i)? 2b. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2 lb/yr (63.764(e)(1)(ii)? 3. Is the unit located inside of a UA plus offset and UC boundary area? 'Dehy Is subject to area source MACT Hit per the requirements in 63.764(d((2( Subpart A, General provisions per §63.764 (a) Table 2 §63.765 - Emissions Control Standards Do Not Apply §63.773 - Monitoring Standards Do Not Apply §63.774- Recordkeeping §63.775 - Reporting Malor Source Requirements 1. Does the facility have a facility -wide actual annual average natural gas throughput less than 0.65 MMscf/day AND a facility -wide actual annual average hydrocarbon liquid throughput less than Small or Large Dehv Determination 2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 3.001747 MMscf per day (63.761)? 2b. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2 lb/yr (63.761)? Small Dehv Requirements 3. Did construction of the small glycol dehydration unit commence on or before August 23, 2011 (63.760(b)(1)(I)(B) and (C )? 4. For this small dehy, is a control device required to meet the BTEX emission limit given by the applicable equation? 'You have Indicated that this facility is not subject to Major Source requirements of MACT NH. Subpart A, General provisions per §63.764 (a) Table 2 §63.765 - Emissions Control Standards §63.773 - Monitoring §63.774 - Recordkeeping §63.775 - Reporting 40 CFR, Part 63, Subpart MACT HHH, Natural Gas Transmission and Storage Facilities 1 Is the facility wide actual annual average natural gas throughput less than 0.9994051 MMscf/day and glycol dehydrators the only HAP emission source (63.1270(f))? Small or Large Dehv Determination 2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 9.994051 MMscf per day (63.1270)b))2)(? 2b. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere -less than 1,984.2 lb/yr (63.1270)b)(2))? Small Dehv Requirements 3. Did construction of the small glycol dehydration unit commence on or before August 23, 2011 (63.1270(b)(2) and (3) )? 4. For this small dehy, Is a control device required to meet the BTEX emission limit (standard?) given by the applicable equation? Yes You have Indicated that this facility is not subject to MACT HHH. Subpart A, General provisions per §63.1274 (a) Table 2 §63.1275 - Emissions Control Standards §63.1281 -Control Equipment Standards §63.1283 - Inspection and Monitoring §63.1284 - Record keeping §63.1285 - Reporting Colorado Regulation 7, Section XVII.D 1. Is the dehydrator subject to an emissions control requirement under MACT HH or HHH (Regulation 7, Section XVII.B.5)? 2. Is this dehydrator located at a transmission/storage facility? 3. Is this dehydrator located at an oil and gas exploration and production operation, natural gas compressor station or gas processing plant (Reg 7, Section XVII.D.3)? 4. Was this glycol natural gas dehydrator constructed before May 1, 2015 (Reg 7 Section XVII.D.4.b)? If constructed prior to May 1, 2015, are uncontrolled actual emissionsfrom a single glycol natural gas dehydrator equal to or greater than 6 tons per year VOC or 2 tpy VOC if the 4a. dehydrator Is located within 1,320 feet of a building unit or designated outside activity area (Reg 7, Section XVII.D.4.b)? 5. If constructed on or after May 1, 2015, are uncontrolled actual emissionsfrom a single glycol natural gas dehydrator equal to or greater than 2 tpy VOC (Regulation 7, Section XVII.D.4.a)? (Dehydrator is subject to Regulation 7, Section XVII, B, D.3 Section XVII.B —General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.D.3 - Emissions Reduction Provisions Alternative Emissions Control (Optional Section) 6. Is this glycol natural gas dehydrator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that Is not enclosed? No No The control device for this dehydrator is not subject to Regulation 7, Section XVII,S,2.e Section XVII.B.2.e —Alternative emissions control equipment Disclaimer I his document assists operators withdetermining applicability of certain requirements of the clean Air Act, its implementing regulations, and Air duality Gontrol Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend," may," "should," and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must"and "required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. RECEIVED Condensate Storage Tank(s) APEN Form APCD-205 MAY 7 zoos 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. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.Rov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: lgWE04a2 AP Stationary Bargees AIRS ID Number: 123 / 0277 / 063 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Namei: DCP Operating Company, LP Site Name: Enterprise Compressor Station Site Location: SWSW Section 30, T3N, R63W Mailing Address: (Include Zip Code) 370 17th Street, Suite 2500 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 4922 Contact Person: Roshini Shankaran Phone Number: 303-605-2039 E -Mail Address2: rshankaran@dcpmidstream.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 3966 Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 3/2019 WjCOLORADO A 1 Oe}vl b En l'u. K�altfibEnalronmMl Permit Number: AIRS ID Number: 123 /0277/063 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action O NEW permit OR newly -reported emission source ❑ Request coverage under traditional construction permit O Request coverage under a General Permit ❑ GP01 O GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑/ MODIFICATION to existing permit (check each box below that applies) O Change in equipment O Change company name3 O Change permit limit O Transfer of ownership4 O Other (describe below) OR - ▪ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info & Notes: Increase throughput, no change in emission factors 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: stabilized condensate tanks Company equipment Identification No. (optional): P013 For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day / O Exploration & Production (E&P) site days/week 52 weeks/year 0 Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? O Yes ■ No Are Flash Emissions anticipated from these storage tanks? ■ Yes 19 No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? ■ Yes El No If "yes", identify the stock tank gas -to -oil ratio: m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No • ■ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No • • Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 3/2019 COLORADO 2 I dr xxnttb a [nnromnmI Permit Number: AIRS ID Number: 123 /0277/063 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl /year) Requested Annual Permit Limits (bbl/year) Condensate Throughput: 54,165 202,848 2018 IFreirm what year is the Gaunt amid t3 Average API gravity of sales oil: 65.4 degrees ❑ Internal floating roof Tank design: ❑✓ Fixed roof RVP of sales oil: 10 ❑ External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) P013 8 2,400 1993 1993 Wells Serviced by this Storage Tank or Tank Battery° (MP Sites On y) API Number Name of Well Newly Reported Well ■ - ■ ■ _ ■ ■ 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The EFrP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.191 / -104A877 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) P013 15 Indicate the direction of the stack outlet: (check one) ❑� Upward ❑ Downward ❑ Horizontal ❑ Other (describe): ❑ Upward with obstructing raincap Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 3/2019 3 I COLORADO ucp.ucun:ot Rubin HSaunkcnn,Gnf,tflt Permit Number: AIRS ID Number: 123 /0277/063 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information 0 Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor O Recovery Unit (VRU): Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed (emissions vented): % ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: NA MMBtu/hr Type: Enclosed Combustor Make/Model: LEE D Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: NA Waste Gas Heat Content: Constant Pilot Light: ✓❑ Yes 0 No Pilot Burner Rating: NA NA Btu/scf MMBtu/hr ❑ Closed Loop System Description of the closed loop system: O Other: Pollutants Controlled: Description: Control Efficiency Requested: % Section 7 - Gas/Liquids Separation Technology Information (E&tP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? psig Describe the separation process between the well and the storage tanks: Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 3/2019 4 I iCOIORADO Permit Number: AIRS ID Number: 123 /0277/063 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the Overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC Enclosed Combustor 95% NOx CO HAPs Enclosed Combustor 95% Other: From vw iast year i_s tilte frallloa'4tsg r ti rued Gaud o.um& emissions 2018 Criteria Pollutant Emissions Inventory Pollutant Emission Factor7 Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissionss (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) VOC 0.332 1b/bbl Tanks 4.0.9d 8.99 0.45 33.67 1.68 NOx CO Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor7 Actual Annual Emissions,. Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions8 (pounds/year) Benzene 71432 4.00E-03 Ib/bbl Eng. Est. 217 11 Toluene 108883 1.50E-02 lb/bbl Eng. Est. 812 41 Ethylbenzene 100414 1.00E-03 lb/bbl Eng. Est. 54 3 Xylene 1330207 1.10E-02 lb/bbl Eng. Est. 596 30 n -Hexane 110543 3.20E-02 lb/bbl Eng. Est. 1,733 87 2,2,4- Trimethylpentane 540841 5 Requested values wilt become permit limitations. Requested limit(s) should consider future growth. 7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 3/2019 5 I COLORADO ihf rtmane n[th:Mk vemthsn,nrmnx ETV/1;5=W' Permit Number: AIRS ID Number: 123 /0277/063 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. Signature of Legally Authorized Person (not a vendor or consultant) Marie Cameron yin Dat Senior Environmental Engineer Name (print) Title Check the appropriate box to request a copy of the: O Draft permit prior to issuance ❑r Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.$ov/cdphe/apcd Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 3/2019 Ayl:2:777. 7. NeatIDb ETVI�OnM&4 RECEIVED MAY 1 7 2019 APC Stionery Hydrocarbon Liquid Loading APEN Form APCD-208 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. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit, condensate storage'tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 1A w E 0 +q 2. AIRS ID Number: 123 / 0277 / 066 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name1: DCP Operating Company, LP Site Name: Enterprise Compressor Station Site Location: SWSW Section 30, T3N, R63W Mailing Address: (Include Zip Code) 370 17th Street, Suite 2500 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 4922 Contact Person: Roshini Shankaran Phone Number: 303-605-2039 E -Mail Address2: rshankaran@dcpmidstream.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 3/2019 399627 1I COLORADO x•allhsF.11V11MtlW1, Permit Number: AIRS ID Number: 123 / 0277 / 066 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action' ❑ NEW permit OR newly -reported emission source O Request coverage under construction permit ❑ Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑✓ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment O Change company name3 ✓❑ Change permit limit ❑ Transfer of ownership4 O Other (describe below) - OR • APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Increase throughput, no change in emission factor 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Loadout of stabilized condensate to trucks Company equipment Identification No. (optional): P016 For existing sources, operation began on: 1993 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? Yes No p I Is this equipment located at a stationary source that is considered a Major Source of (HAP)BI emissions? Yes No • Does this source load gasoline into transport vehicles? Yes No ■ A Is this source located at an oil and gas exploration and production site? Yes No • p If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Yes No • ■ Does this source splash fill less than 6750 bbl of condensate per year? Yes No ■ ■ Does this source submerge fill less than 16308 bbl of condensate per year? Yes No ■ ■ Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 3/2019 ICOLORADO 2 I I-...hbEZP"1*Y.* Permit Number: AIRS ID Number: 123 / 0277 / 066 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information Product Loaded: ❑✓ Condensate O Crude Oil O Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 202,848 bbl/year This product is loaded from tanks at this facility into: (e.g. "rail tank cars" or "tank trucks") Actual Volume Loaded: tank trucks 54,165 bbl/year If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: 0.6 Average temperature of bulk liquid loading: 58.16 , F True Vapor Pressure: 4.65 Psia ® 60 °F Molecular weight of displaced vapors: 66.00 lb/lb-mot If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: bbl/year Actual Volume Loaded: bbl/year Product Density: lb/ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume: ft3/truckload 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 3/2019 3 I COLORADO Dean °IPuti t HNMbEnU1MXn1RY.1 Permit Number: AIRS ID Number: 123 / 02771066 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.191 / -104.4877 Operator.- Stack ID No. Discharge Height Above Ground'Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ftlsec) P016 Indicate the direction of the stack outlet: (check one) o Upward ❑ Horizontal O Downward O Other (describe): Indicate the stack opening and size: (check one) o Circular Interior stack diameter (inches): o Other (describe): O Upward with obstructing raincap Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. O Loading occurs using a vapor balance system: Requested Control Efficiency: ▪ Device: Combustion Used for control of: VOC, HAPs Rating: NA Type: Enclosed Combustor MMBtu/hr Make/Model: LEED Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: NA °F Waste Gas Heat Content: NA Btu/scf Constant Pilot Light: 0 Yes O No Pilot Burner Rating: NA MMBtu/hr ❑ Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 3/2019 4 COLORADO flcp_rtm.° :ro4ns i° tCCat�]i5 Ei��li+6l�hitrtl Permit Number: AIRS ID Number: 123 / 0277 / 066 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the erall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SO. NO), CO VOC Enclosed Combustor 95% HAPs Enclosed Combustor 95% Other: o Using State Emission Factors (Required for GP07) VOC Benzene n -Hexane ❑ Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL ❑ Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL Freon what year its the allegaiing emissions. 2018 Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions tons/ eartons/ (tons/year) ) Controlled Emissions6 (tons/year) Uncontrolled Emissions ear ! Y ) Controlled Emissions tons/ year (tons/year) ) PM SOx NO. CO VOC 0.186 lb/bbl AP -42 5.03 0.25 18.83 0.94 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service(CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions° (pounds/year) Benzene 71432 5.16E-04 lb/bbl Eng. Est. 28 1 Toluene 108883 6.34E-04 lb/bbl Eng. Est. 34 2 Ethylbenzene 100414 1.78E-05 lb/bbl Eng. Est. 1 0 Xylene 1330207 9.62E-05 lb/bbl Eng. Est. 5 0 n -Hexane 110543 3.62E-03 lb/bbl Eng. Est. 196 10 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 3/2019 5I COLORADO ngur,�,poi tIU+ H:annsenmrnnmrmi Permit Number: AIRS ID Number: 123 / 0277 / 066 [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. If this is a registration for coverage under General Permit GP07, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP07. Signature of Legally Authorized Person (not a vendor or consultant) Marie Cameron s/i&/tai Date Senior Environmental Engineer Name (print) Title Check the appropriate box to request a copy of the: E✓ Draft permit prior to issuance ❑✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 3/2019 61 IcoioRAuo i! NOWISE= Glycol Dehydration Unit APEN Form APCD-202 Air Pollutant Emission Notice (APEN) and Application for Construction Permit RECEIVED MAY 1 7 2019 APCD Stationary Sources All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for glycol dehydration (dehy) units only. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdohe/aocd. 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: 101weo*12 AIRS ID Number: 123 / 0277 / 611 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': DCP Operating Company, LP Site Name: Enterprise Compressor Station Site Location: SWSW Section 30, T3N, R63W Mailing Address: (Include Zip Code) 370 17th Street, Suite 2500 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 4922 Contact Person: Roshini Shankaran Phone Number: 303-605-2039 E -Mail Address2: rshankaran@dcpmidstream.com ' Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 399625 Form APCD-202 - Glycol Dehydration Unit APEN - Revision 3/2019 1 I COLORADO w+m.atnw—amu Permit Number: AIRS ID Number: 123/.277/ [Leave blank unless APCD has already assigned a permit it and AIRS ID] Section 2 - Requested Action O NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit ❑ Change permit limit 0 Transfer of ownership4 0 Other (describe below) OR ❑ APEN submittal for update only (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 Et Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: TEG Dehydration unit for water removal Company equipment Identification No. (optional): D-3 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: 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? hours/day days/week Form APCD-202 - Glycol Dehydration Unit APEN - Revision 3/2019 0 O Yes Yes weeks/year No No COLORADO Oepaueavrel h1m 2 � H�atiTSEnYitMYUN Permit Number: AIRS ID Number: 123/0277/ [Leave blank unless APCD has already assigned a permit it and AIRS ID] Section 4 - Dehydration Unit Equipment Information Manufacturer: TBD Dehydrator Serial Number: TBD Model Number: TBD Reboiler Rating: 1.5 MMBTU/hr Glycol Used: O Ethylene Glycol (EG) O DiEthylene Glycol (DEG) ❑✓ TriEthylene Glycol (TEG) Glycol Pump Drive: ❑✓ Electric O Gas If Gas, injection pump ratio: Pump Make and Model: FMC Triplex Glycol Recirculation rate (gal/min): Lean Glycol Water Content: Max: 25.0 1.0 Wt.% Requested: 25.0 Acfm/gpm # of pumps: 2 (1P+1 B) Dehydrator Gas Throughput: Design Capacity: 145 MMSCF/day Requested5: 52,925 MMSCF/year Actual: -- MMSCF/year Inlet Gas: Pressure: 1 ,100 psig Temperature: 115 °F Water Content: Wet Gas: lb/MMSCF ❑� Saturated Dry gas: 5.0 lb/MMSCF Flash Tank: Pressure: 50 psig Temperature: 140 °F ❑ NA Cold Separator: Pressure: psig Temperature: °F 0 NA Stripping Gas: (check one) 0 None O Flash Gas ❑ Dry Gas O Nitrogen Flow Rate: scfm Additional Required Information: ❑✓ Attach a Process Flow Diagram ❑✓ Attach GRI-GLYCalc 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) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-202 - Glycol Dehydration Unit APEN - Revision 3/2019 COLORADO ii Exg..� 3 I d wu� Kaalgtb Ehen0 fa Permit Number: AIRS ID Number: 123 /o2n f [Leave blank unless APCD has already assigned a permit fi and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.191 / -104.4877 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) ECD-1 25.0 Indicate the direction of the stack outlet: (check one) 0 Upward O Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) 0 Circular ❑ Square/rectangle ❑ Other (describe): ECDesai, "91V iltS Val O Upward with obstructing raincap Interior stack diameter (inches): 36.0 Interior stack width (inches): Interior stack depth (inches): &whoa a for sal Tent Ito awn- , llneire hltaring crcm't ou to V lr' tall has ai 1.tB ii auroral ICD ad r�i tujnrnj Mimic liar morintionamar eu repahis Section 6 - Control Device Information O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. O Condenser: Used for control of: Type: Maximum Temp: Make/Model: °F Average Temp: Requested Control Efficiency: °F 0 VRU: Used for control of: Flash Tank vent stream Size: NA Make/Model: TBD Requested Control Efficiency: 100 % VRU Downtime or Bypassed: 5 % ❑ Combustion Device: Used for control of: Still Vent stream Rating: NA MMBtu/hr Type: Enclosed Combustor Make/Model: LEED / L30-0018-00 Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 % Minimum Temperature: NA °F Waste Gas Heat Content: 1,500 Btu/scf Constant Pilot Light: 0 Yes El No Pilot Burner Rating: 0.11 MMBtu/hr Closed O Loop System: Used for control of: Description: System Downtime: 0/0 O Other: Used for control of: Flash Tank during 5% annual VRU downtime Description: Enclosed Combustor Requested Control Efficiency: 95 % Form APCD-202 - Glycol Dehydration Unit APEN - Revision 3/2019 algrIcotoRADo 4 l Haan gtZlent Permit Number: AIRS ID Number: 123/0277/ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction ): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SOX NOx CO VOC Vapor Recovery Unit / Enclosed Combustor 100% / 95% HAPs Vapor Recovery Unit / Enclosed Combustor 100% / 95% Other: From what yew is the fa llll mg oe urted ortuat errorernissims NA Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions6 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) PM SOX NOx 0.068 Ib/MMBtu AP -42 — — .•1 L -1.52' 4c1 CO 0.31 lb/MMBtu AP -42 - - 16.711):47, €.74432. VOC 22.96 lb/MMscf GLYCaIc -- -- 22.00 607.61 *HAP Emissions represent P r to ?11 tall to Emit ff•, r this prop (04y. Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions6 (pounds/year) Benzene 71432 2.52 Ib/MMscf GLYCaIc 133,283 7,773 Toluene 108883 3.77 Ib/MMscf GLYCaIc 199,612 11,751 Ethylbenzene 100414 0.12 Ib/MMscf GLYCaIc 6,227 369 Xylene 1330207 0.87 lb/MMscf GLYCaIc 45,786 2,725 n -Hexane 110543 0.47 Ib/MMscf GLYCaIc 21,812 =85.1' q21, 2,2,4-540841 Trimethylpentane 0.0003 lb/MMscf GLYCaIc 74 17 C $ 1 Other: 67561 (Methanol) 0.003 Ib/MMscf Eng. Est. 159 5 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 /annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. 51 iccioRaoro e�p ,tma,,otwnm x..attn»snm,t* 't1 i Form APCD-202 - Glycol Dehydration Unit APEN - Revision 3/2019 Permit Number: AIRS ID Number: 123/°277/ [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. 5/t1Q/t t Signature of Legally Authorized Person (not a vendor or consultant) Date Marie Cameron Senior Environmental Engineer Name (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) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: httos://www.colorado.gov/cdohe/apcd Form APCD-202 - Glycol Dehydration Unit APEN - Revision 3/2019 6I COLORADO xeauh & EnbtronmMl Hello