Loading...
HomeMy WebLinkAbout20191656'k)tvc- ‘)1),Y‘edki.) COLORADO Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 April 24, 2019 Dear Sir or Madam: RECEIVED APR 2 9 2019 WELD COUNTY COMMISSIONERS On May 2, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for DCP Operating Company, LP - Troudt Compressor Station. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer cc:PLC-co), i44.3-0 PvicavoitimicA 2019-1656 5/(0/ Ig y129/►q Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: DCP Operating Company, LP - Troudt Compressor Station - Weld County Notice Period Begins: May 2, 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: Troudt Compressor Station Natural Gas Compressor Station SENW of Section 27, Township 6N, Range 66W Weld County The proposed project or activity is as follows: The operator is requesting to modify existing sources and add new sources to an existing natural gas compressor station located in the ozone non -attainment area. The operator is requesting to modify an existing 64 MMSCFD TEG natural gas dehydration unit and add an engine currently covered under a GP02 to the existing facility wide permit. The operator is also requesting to add the following sources to the facility: (i) One (1) Solar Taurus Turbine, (ii) One (1) 88 MMSCFD TEG dehydration unit, (iii) Fugitive component leaks and (iv) Pressurized hydrocarbon loadout. The facility is now classified as a major source for VOC and CO. 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 13WE1108 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: Harrison Slaughter Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 COLORADO 1 I n� Pt' K4S�NWEtW'�IYdniYMs6 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Harrison Slaughter `. Package #: 381853 Received Date: 5/18/2018 Review Start Date: 8/2/2018 Section 01 - Facility Information Company Name: DCP Operating Company, LP County AIRS ID: 123 Plant AIRS ID: 9ACB Facility Name: Troudt Compressor Station Physical Address/Location: County: Type of Facility: Natural Gas Compressor Station What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? ❑ Carbon Monoxide (CO) ❑ Particulate Matter (PM) E✓ Ozone (NOx & VOC) SENW quadrant of Section 27, Township 6M, Range 66W Weld County Quadrant Section Township Range SENW 27 6N 66 Section 02 - Emissions Units In Permit Application AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 .` Natural Gas RICE C-306 Yes 13WE1108 4... No No Action Requested 002 ! : Natural Gas RICE -.' C-307 Yes 13WE1108 4 No No Action "Requested 003 Natural Gas RICE C-308 - Yes 13WE1108 4 No No Action Requested 004 Natural Gas RICE C-309 ' Yes 13WE1108 4 No No Action Requested 005 Natural Gas RICE C-310 Cancelled on 10/06/16. Removed from permit in CP3. 006 Dehydrator D-1 Yes 13WE1108 4 Yes -Permit Modification 007 Fugitive Component Leaks FUG - Cancelled on 08/14/15 008 Process Flare ". ECD-1 Cancelled on 08/04/14. 009 Natural Gas RICE C-311 Yes 13WE1108 4 - Yes =Permit Modification Cancel GP02 and add to individual 010 Turbine TURB-1 No 13WE1108 4 Yes Permit Modification New Source. 011 Dehydrator. D-2 Yes 13WE1108 4 Yes Permit Modification New Source 012 Fugitive Component Leaks FUG No 13WE1108 4 Yes Permit Modification New Source 013 : Liquid Loading L-1 - No 13WE1108 4 Yes Permit Modification New Source - Pressurized Loadout 014 Produced Water Tank PW No - 18WE0588 1 No APEN Required /Permit Section 03 - Description of Project DCP Operating Company, LP (DCP) submitted an application to modify an existing compressor station located in the ozone non -attainment area. As part of this modification, DCP is requesting the modification of existing sources and the addition of new sources. Details of the requests in the application are as follow: 1. DCP is requesting to modify the following existing points: (a) TEG Dehydrator (Point 006) - The operator is requesting to remove the requested annual downtime of the enclosed combustor. Sources subject to control requ irements 1 in MACT HH are required to have the control device operating at all times. Additionally,the permitted emissions are being updated based on a current GlyCalc simulation. Waste gas and assist/pilot light gas combustion process limits were added to the permit. Finally, the assist gas calculation for the enclosed combustor was updated. (b) Compressor Engine (Point 009) - The operator is requesting to cancel the current GP02 coverage for this source and add this engine to the facility wide permit for this facility. This facility no longer qualifies to have engines covered using a GPO2 because permitted VOC and CO emissions are greater than 90 tpy. 2. The operator is requesting to add the following new sources to this facility as part of this permit modification: (a) One (1) Solar Taurus 70-10802S compression turbine rated at 69.83 MM Btu/hr, (b) One (1) 88 MMscf/day TEG dehydration unit, Colorado Air Permitting Project icirugitive equipment [eves (d) Pressurized loadout of condensate from a pressurized storage vessel to pressurized tank trucks, and (e) Three (3) 2401 barrel fixed roof produced water storage vessels. The produced water storage vessels are addressed under permit #18WE0588. Public comment will be required for this permit modification because the operator is requesting new synthetic minor limits toavoid other requirements. Additionally, this modification results in the facility being classified as a new major source of VOC (Title V & NANSR) and CO (Title V). As a result, the operator will be required to submit an application to obtain an operating permit within one year of commencement of operation of any piece of equipment covered by this permit. This permit will also be issued as initial approval because new sources have been added to the facility and new requirementshave been added to the existing sources that 1. were modified with this project. Since the change in VOC emissions associated with this project are less than 100 tpy, the facility is not subject to NANSR review. However, the facility is classified as a major source of VOC with regards to NANSR going forward. As a result, future modifications will need to be evaluated with regards m the major modification thresholds. Additionally, the change in CO emissions are less than 250 tpy. As a result, the facility is not subject to PSD review. As shown below, the facility is still classified as synthetic minor for PSD. Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Yet SO2 NOx CO VOC PM2.5 PM10 TSP HAPs J J Is this stationary source a major source? yes? If yes, explain what programs and which pollutants here SO2 Nox CO VOC Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) R ❑ ❑J PM2.5 PM10 TSP HAPs ❑ ❑ Glycol Dehydrator Emissions Inventory trenrarator 'Facility Alas ID: Merlon Equipment Description Meta. oahydram,Typ= ation Design Capacity: PeurriecorPrenVe PumpType Design/Ma. Necucmation Rate. DomdratorEwlpmant Flash Tank Stripling Gat Dehydrator Equipment DescrIstion One (31 Tdahytenogiyuor MG) noeualsas denyamtibn unit (Mum: comemn, Modeb TDT, serial xamber. Mo2o59T3%(351552esignepacley of m MM.afpm does near yutppods,khz(Ma.PMe,Mo4s2035 Plunger Pumpalelecticdduenpywl pampwhh ade,iscopacltyof 5appibrn parmin 052 Taeedenydmxanu01 eq p. rnhsstiase.,nash,anw and ebo3erMimeo emssions air-cooledcondenses Mary Deea . Mitsmnslrom the 1355,33252 routed 2' 2ITtoahpvap.Socomy Emission Control Devia.escnpbom nit(VMDlfasa secondary contr. deveco, So. to. ...eons aro n,uroeto tho Ennoeoa Mom. Motion 03 ProessIos 05201 formatlonfnr Emisslnn30stfrartes Sem, Emissions. Dehydrator Stillventand Flashranxlif present Pa 'p;.625ar ;300.0 :re wed per year Requested Mon.lyThroughput= Potentalm Emit(PIE(Thro2gnput= x3,352 AM, per year sewn ry Ernlssions-combustion Device[a] torar. Pollution control Still Vam Control CoMenserem6sion eduction clefined Prill141,01.31 device: Primary control ratlon. socondanmontrol dead.: Secondary Vol device operation: Vent Gas Heating Value: StIll Vent Waste GasVent Pate: Plaslotonkrtontrol Prim .idol Primary control device operation: Secondary control dove.: Secondary control device operation: Flash...as Heating Value FleshTankWane Gas vent gat.. Enclosed Flare Mot fuel rate; HeatContent %diceOSEmiecnns M.o.& Motnadolaeies 5230 oegree31 q od To amp".; "ti�,a"y..yk"i Degree30 onanmro3 edpbmrl Controlled pntr. Controlled(l3/hr) qec SOS 5.99705 3 raelli 5005'eneyn: *0=:::30330» ..4,793 0 Toluene Toluene 3.47,g:3 3 EthybeMrenesnaene xrTIMatma552, :;s 3.5,4333 0 gyknee 'ra.'tl4" . 0.139955 0 n-Nenne 0553dir,5°??"r '.5i a'• x. v ono%6lS 0 , gika G,";.t'.ibn34i.i1V10:. oomsss 3 Matra McWanol '�ti:1�d.613513r�,'-"�� O.O3oE%ii 3 MASH TANS Poirot nt VOL Uncontrolled 'ISM, Control Menai° Controlled OM Secondary Controlled Ilb//s Toluene Ethylhenzene Mlenes nrelesene 0.004025 ecte Methanol ceslbmuMIPut; Sall vent primary Control: 532'30,0 MMtcf/yr sill vent Mcon Wal sall', s tyr Combusts. Stil(Ventprlmary Contra: 3.n MM312/2, Stlllvent Secondary. Contral: 3n SANIscf/y1 Dry Goa 11; ro hour: Fla.ATankP,m.y Control: Tra,M2.0 MMSMAT Ilashr33533mndery Control: 1.130.11 M scf/yr WasteFlash TenkprlmaryControl as robust taleascf/yr Flash -tank Seconderyanwk OM/ MMscf/yr fuel/Pcsist Gas Combust. Pilot,. 0.23B 5f/year Assist Fuel 47.2M4 NINI.Myear Total. ST.Taa 055555/yea v,9aa.0 Marisa/month 0.3 MMfd/manta I.Nv(6w.. Worm TOM neeroane icoMatena Mao MITA M. 42. Yrosart yrc a OW Imirria es MOMS 0.0762 tre arraMit 7145. MONA ISM ToYmor COIMI x, .ism Pe, clan m, r. der Glycol Dehydrator Emissions Inventory re Ore operalor segues. Ree.sred Puffer(.: buffer? criteria powanb Potential to Emit Uncontrol(../.i`)a Actual EnlIsions UncontrolledControlled Imnsheaal Pequested Permit Uni. d Controlled ItonsNeag{vnsryeer) Peon.. M.N... lled le/�nul PMLS SOx 0.04 P.M 0.06 OM OM 6.00 0.6o PM 0.00 MOO Hazardous Pollutants Uncontrolled a Ubs/marl Actual EmIsstons Uncontrolled Ills/yea,) Requested Pennit Limit Uncontrolled O./marl Requested mit PermitControlled (Ws/year) (ton...) Toluene FtxVraene Tl lore 64916.66 .54,96 .66.64 4606.. 46.. PM. .26. 13476 -Methanol 1.16 0.07 1.66 1..66 692 19.4.05 6.02 0.10 .0035 Section 06, lato Pummel Anal sls Regulation 7. Section Xl. Regulation Past E. MAcrocvvxx Ikea) Peg... s, PertE, MACS Subpart Hx (Maori Peguletkm, Part E. MAREubpartxxx (sue rap latoryappdrabmtvwar.hoot for detailed analysis) Source requires a oorrntt Dehydrat Thecont. ...for Psis dehydrator is notaubiert to Fagvt.tian],Eoction NVli9?A Dohydratorissubia.-sto Dom Issubloc So area sours. MAcixx-Control re..em.msin53.aFF por53.is51a1111 You hau.mmoted..thl,m v o`....e to MAC( xxx. 0.107 4756 125,14,9 0tuf act 15.19,57.9,25 Mend 6.6761 ssePlane 1184 OsPosne 3761, .16.74 0.552 6.767 4.1.16 7741 3761.9 147.1 oxs..) L. 1151, 5. 1,1,04 1c4r.1r OHS Fltofterli.ng Vzlue of Gas 160,21571 DIEth.:1 Sow 3e: GPM Enginoeling......4. page Glycol Dehydrator Emissions Inventory Section 07-Inelel and PerteitcSarnpline and Testing ments Was the extended wet, mp used mm v m/aBwreceSs model sltespecitea amuecteaw.mI/a year of °t uncon. pornitwultomama/ Innfal p1 �t ag v mantmaem//.time mp �w¢n emfamnumb Does teeeornpany requesta cont'ol tlevice eft idency greater than 9556 fOr flare areal -Mete,. deeke? If yeethe panne Wel vantage and itetial compliance tett condition to demonstrate the destruction efficieneyof the combustion device based on int. and outlet concentra o Ong If the tompany has requested a Iter ben use to achieve IttI N/ ley,the h permit will contama r/nan, control device Minima cemr;mnrenuamba�mpeaturefor. sar.ie,azer lithe company using a thermal oxi.et AND requeseng minfrnunetembettion chamber an MOO degrees 33 If y , permit will contain ea fmml pn testte/9 , meat af, permit n pea ngn minimum c/mbB,tmnchambertempeatuaforthethomwlor,mso C; e y gih lea rmitea 1 / so- omtae ycacmo hd Peati her the permanorthe0.41plaette requ cimum outlet., med nN Ne C ERFi1, /sf Qo R /fia pa w t No a jra h 1 ref [sdep depot other resBfai/fv Bin waa eeiamfneam «ne[/mpNti/ n ea:e«iee� mzsl pprovrdt anioae / Z981:;,' uneoneolled IlathenkV03a /S m the operator c f o " / Ava d the A subject to the 9 $ oI tl/q ¢spL s 7vumm req r o o V 6 f ▪ '!ktby 1 1 bge(9.e thm [,/r/xe sa eyo.monr s[ arp(vs s).Ne s./ ) [ ev lI td 1. to m.o.,. toattoe ',bested, contro,doccodomno iron n t :) x ap } rp ig BNam ti..}� b are bnawm etFaen aatnneer,nlaaoewaetea:en.aa,Fe ppeamr .Bea e[ewa:..sae rcp,�me., ftnf,,..„, ,e 3,6,t3 a: submit -Lod .y e m /brreb s / t tRxirelBs pe /1/rBIVRB/ otk. PEi. ills { b i tl b/ U b cf/5 g ,.eue ztjorcb for,.o ,. b ▪ b d e a��sh eo/ns,�n wao• ga�a Beare 1 ea n�,ep :r cc/n eWecaf � xo.ga a,�nme h Iay aaftofnwe IY a ddlio leas a re1B p se eupaa n:} arery,dl • sae h agty and Bang mdemone tbG h hae d asirr,,,,nitlalenmplette.1, was S/ingp l p by /In/a/pta tl s XI m a yoor, ,oilO, Iced to estioistoorofsdio,,,Cxns m.1,6.o the ern h te.e casnbustionprocesies lna r/ each Gcikar ,.. the st,Ihronoa,-,,i OW, tank \o,stogas.strearos ,O11,Iho Lal,Idted on a monthly hasisond coed along,. rhe oolodatod Cow rate and mondoradOours °tope:atm to deterrnice n assist Ms was � � operator Nog to the OW plan, the OmodurinowM1.01eVoUh iankekssiord istovindlt be tr,sked aaa yl?. .The cie,hydraeon unit it equipped wile. l l d rfiem e gprol xmNng meapW a ma.lhetc.3hr i,. F m wrot/n wmr ant, gaseompoetion.3he ,on, p/o�eTh are mn m/ maa , aeen,e / parameter, era cfri.',.-fiOnteir-,',,ervior.sIgn azaa.ltth p m![,s+ eropu[ I' anobc e b ,. € B,p ea /n, , , ,. u d F mole "Aya a mans s?S/f/ t l atoenm I v and/thee aae iedrarc d p eafne 7. pub}rc n`dou< Int c6 code Suction 09 - Inventory SCC Coding and Ern6slons Factors 31010 0.004 Pollutant omissions factor contr.% unks 6/MMscf b/MMtef b/MMuf NOx b/MMuf VII 95 97.0 b/Mtestf b/MMuf eentene 4.161 95.1 b/MMuf Toluene , 3.979 95.0 /MMscf ENylbenzene b/MMscf Xylene 1.153 g9.0 b/MMscf nelextine. 0.625 96.0 b/MMscf 224 7013 0.005 b/MMscf MBMan/I 10os 96.4 b/MMscf Dehydrator Regulatory Analysis Worksheet Colored° HeOatim 6 Pam n and 3 -AP1N end Pormlt Rapuiamams Source Is in tHe Non•Attainment Area .311,1,1143111 1 Pre Uncontrolled actin, emissions from any crlterla pollutantfrom Mls IndMl2ual source greater Nan 2TPYIftealatlon 3, Partn,3.311.0.1.01 2 Pre toOll facility uncontrolled VOCemiss ons greeter Man 5311.1103 greater Men 10TPYor COemisslons arearer than 10131 (Regulation 3. Part 6,58622311.D317 'You haveIndicated Out sour. iolnth2N2-Attainment Area 1. Pre uncontrolled ons from any allele polluranbfrom this Individual s°ur6e greaterthan1TPV (Regulation 3, Par, EeVmnIID.1IV 2 Are total uncon trolled VOC amkslons greater Man 2663,1103 greater than 5 UV orCO(VIsslons greater than 10631(Reg2atlons ParIO,Seqaon 11.0.211 Colorado Regulation T,5enionxl,H • M163yml natural aehyera mentimamteramearea(3eg7,3861133PlHlane211 • MBgrymi dehydrator baled at n og.ne aas m.�aeo anti pmdor6o2 operation',aturalagas6 pressor starwr, law. gas erp rte lomweg73mden sage aenyaatororgroup 017.1mamrsataslnyesrodn.3606r1.616.mar greaterN station yf�s7slns m"an x3H3.W a NH amid uncontrolled emIsslons olvOC from the Inellvklual glycol namaleaaaehwamremal to or greater than 1ay(Reg7,3m8o3le.H32lV 1O3,16a103,16atoris subject to RomUrtion 7.33alon13111 Section12011—EMssan RNumons from glycol 362.11 gas dehydramrs MAR MalV515 1. Is tiled...x..61a and natural production is elMn of the follows. aria: a. Meaty Mat processes, Upgrades orsmres hydrocarbon owds'163.3601a)(11)1OR fnlRry Matprocesses, upgrades or stores natural gas prlor%Me pointae which naeuralga1 enters the natural gastransmbsfo0 and storage source category or a delivered to a nnal b. end use/ 111.73011113113 2 enytllO ff031 .1x018111311111(111133 12317.mrrre Man HHapPllmhRhy 40 CF. Part 63, subpa n Conn RH, 06 and Gas Production Faagtiae ArwSourmRarwwmems • 461010 abiethy16 egtm 1E210313218131111111.76IXb112n1 ur mptiom 23. Is Me actual annual age Ibwrata of nom raj gas to the glycol dehydatlon unItless Mn 33.66¢747M Msm 03 22. Pre amalannual average ...Mons of benzene par day 35311611e31110Me glycol aehyeatta n unit process vent to Me ab3rephne less Ma n 1234.1lb/vr (63.76410111417 3. Is the unlIlocatetl Inside ora plus offsetand UV:loom., area, IDehv ssubiedto areas,«° MAR HH-7ontra recubamanl21161.76566163.164121111 .7per 663.764111,x6112 463.7666-Emisslons Control Smclards 463.773- Monitoring Standards 463.,4-.con:keep,. 463.725-Reportlng AkalorSourcoRequuan+ Does the miry have a fauAry.wae actual annual average natural gas Mrooahpuelessthn 0.65MMsc3/day AND a facniry-weexual annual average hyaroarbn Houk, Mroughpuc less Man 1. 243.121631 (63.760(e)12))2 Smell or Deily oetemlnnin 2e. the actual annual average te of natural gas Oa1Me gyca dehydration unit less 12a33.0011436331561 280111arday163261, Yo. Are small Bain Requirements al erage embsbns or bemne hole Me.co1 aehMn don unit p Cocas vent m Me atmosphere less than1.984.21013r ib/m 16306113 3. nofMasneli glycol dehydration unmm ence on or before 33635123,201.1163.76012)11113(3)and (C16 4. For Ms small 61102.1661102.16 a coMml day. required m mea1Me Rraemgslon ltmle given bymeapplbble equation, �vae Continue -You have Mice., theatt6inmentstatus on the ProlectSummaryMeet ConHnue - me facility type on Mee ProlectSumrar. Sheer.. 01137 r&degto2ega1aa2nzsecm3 wl.H karalnua •Sourcesubiecch MCI HH regulemen1.1111ave Indira. the sou roe category= Mevrolecl1ummary11830 o t3 Mnn III Area s ourre apple. batty 132033 Ira IDe tlnue-You have indicated Medw,valrartype 0381eavaamrbuenmrvsneel 'You haw indicated Mat MN lasilltv Isnot vohleatannaiarSourceroguiren,1111313,13MHH. per 463.764161 Tablet 466.761-3mgsbns control standards 663.773-Monimdng 633.714-Recordkeeping 463.776-3eportlng 40631136n 61,3326.341130 H H 14 Natural 6as &ansmission and storage fadihles laciurvcode x36a1annual average natural gas Mreugrpm less Man 1.9194051MMx1/day and glycol dehydrators Meanly cos emission sour, 163.121011111 Small or Largo Daily lox nation 18. Is Me achol ann. average Howrate of Amur-03as to Me.. 2111713 °n unit less Man 3224051MM.per clay 114811,241261 71. cage emissions of benzene fmmtne glycol debycaa3n unit prmessvenem Me amtmpnere less denlyg4.11btyr1633.70311R117 Small 0623 Requ(m lmnb al mall glycol dehydration unit Commence on or before nugrata,2011163.1n0(b)W ad 13117 a FarMissn3. Hid lli del, Is a control device reoulred m meetme 0733 emission limit lstmtlam7lgNn by me appflcahlx eouavom • 'You sublaate MnersHH. 3631Subpart Abe 14111one per. 563.1274 b1Tabte2 123 -Em1s na Control standards 463.1731.cno-°I 17210761118122142 466.1x61- Inspect. and Monitoring 463.16.9¢-Record.eping 463.1235 -Record. Cobra. Regwatin7.50Nan WILD L is Me tl1Mramr 2,38.[31 an emission control relulrementunder MAC! HH or HHH IRegulxen7,5ectlonx33.051, Mb aehyeramr d ac a eammissin/smrcgefadlty, i4. Was tills glycol natural gEedydra16Ie nsmicm+ before May t,aasslRReg71ectlon ln.4.41V reswrsrm'norgarpmcessrnggang3eg7,sectlonxvlla3R H sln6egyml namalgmeenyeamrequalmorgrorerman 61636 Pery®r V.666 631VOCHme 43. dehydrator l000tedwdtIn 1331 feet GrabuMInm naitm°riI Inmate oublde,Why area Meg,. Section.3.13.4.211 Ifcombu led on or after May 1, 2015.are ummneollee aural en2ssnnoroma single glycol natural gas dellyeratorequtl m orgres[b ar, my VOClRegub2on 7...on x111.0.4.1, DallvslustorlSetion1Vl - sl -General tor ulslo1s3I33Pollution 0030111 Equipmens Band Prevention ofEmisimu -EmIsslons Reduction Alternative 8113onsComml fo lonalS6etlonl 6 1this glycol natural pas dehvaamr controlled hva hxk-un113131111 cnmbuseon dnbe l3.e., notMepdmary control 4.11011211 notenelo,m 391111 Irho carttrei .6. for 013 claNdravar la not subioce 3363.ion1.6«trnxy11.63. Section 33113.2.a - Marna. em3slons control equlpment Disclaimer Comm.. TNS Wcuman,',sofa rule or regulation. and u»analysts'icanfainarr®yn3laPPHm a PanbularsiWarbn bamirspon i3te m2 var(0(4 evenc10770tces Pas document does not change or subs../¢any law. reguatbn,orany other k5/H8lentiip repubemas, SW is raj legally enforceable. In the nt of any tonne bei.een gle langiagebfIris ll [banyan, alp Me language of Usa Goan7..Act, ifsimplementasa regulations. and Air Qualify Control Comm..3141 regulations, the anp7111aft. 2171270ute asnasa21071 to.. 726 use at ndl.nuMsayangaaega such as5ewmrerp.'"may.287772'and WIC mlenda7lo 775447 SPCA hbnrela/N�s andx7nananda(ronc Mandalay termhpksgy such as'mus•atl'requ0ed'ore,sMansnd be311721eca11440 requvamenis unde•ure terms NMa Claan Air Actarp ArOuahly Control Comm/mix, regulations, bath's dement Wes not esta . r�alH binGigregwremenis in and of es Ho 16 Me nexIquestion tte Iuestion le unit h sugxtm cone°, repuiremanu In 33.765 per 633601311 Source mbuntm peg 7.286233 x311- Youlave previously lekat66 Main Me MdCTsectlon Conti...Fe-Yoe have previously 130latea MI5 In l#153101321700371071801113 Conwue Yo. kn. preiouslylnn1ed this In Ma Rag 7. eon Xll deter.. In RICE Emissions Inventory 'Facility AIRS ID: v R3, 9ACB ₹ County Plant Section 02 -Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested NOx Control Efficiency%: Requested VOL Control Efficiency Ns Requested CO Control _.. Efficiency 5: Requested HCHO Control Efficiency 0: Requested Other HAP Control Efficiency%: PCrnE 009 bra=n) Waukesha Model. L7044051 SN 528325433 na heciprocating internal combustion ergs, sit s91 catalytic re/.HO. system(NSCR) endtali used fornatuml gas compression Engine Manufacture§ Date: ?pa r x2/3'/2015,Q, Manufacturer: Amwshitewalge Model Number. L7U44G51" ."un€ Serial Number: `e2: 508204603iti: Engine Function ° aerating Mfg's Max. Rated Horsepower @ sea level: x.1610 Horsepower used for calc tl ≥s'.s,-1`690"w..r,.l BSCF @ 100% Load (btu/hp-M0 N.. 0102751§3J„vN;„ li Site- Rated B5CF @ 100% load (bt3/hp-hr): 7876 Other Parameters Engine Type Aspratmn t Elam calG nera or Max Site Rating(kw) Requested Hours of Operation �,�.:'0 . 487011 PTE Hours of Operation a87 0 Actual Hours of Op 1 ,, X14119 Section 03-Promssin&Rate Information for Emissions Estimates Fuel Use Rate @ 100% Load 14701.86667 scf/hr ACTUAL Annual Fuel Consumption : 5032 MMscf/yr MAX POTENTIAL Annual Fuel Consumption 128.788 MMscf/yr REQUESTED Annual Fuel Consumption 128.788 MMscf/yr Requested Fuel Heating Value q,+.u;O,;A,M„ry;iw,pr•.,: !s`45a;.".300. btu/scf Actual Fuel Heating Value 42 e88 .x5Ht'fi8t'otIilAP °u 100311 btu/scf Section 04 -Emissions Factors & Methodologies ME= ZE Pollutant 8 03300 0.500 SI RICE Engine MIEMIEIMMIMM EEMZIVECEMEM Source 0.500 0.700 !ZIDEEE=IMAiir Formaldehyde 00E-0 =NE ®' Rn'f _ .2 ®®' t MMMXIM3.000[-03 I I..+Ti Y`I 1, WOMEN7.9 4 ..7 ESEMZIIIIMEIIM _ 5300E-03 90E-04 1.950E-0 0.000E+00 0 000E+00 0.000E+00 0.000Ere0 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) (tans/yearl - Nes CO HOC PM, PMsu 502 215.76 101.45 3.81 715.70 8.113 18930 89.25 7.63 183.80 16.23 29.33 11.44 5.34 24.33 1136 1.12 0.53 0.53 1.12 1.12 1.12 0.53 0.53 1.12 1.12 003 0.02 0.02 0.03 0.03 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/yearl (Ibs/yeah) Requested Permit Limits Uncontrolled Controlled Ilbs/yearl (Ibs/year) Formaldehyde Acetaldehyde Acrolefn Methanol Benzene Toluene Ethylbereene Xylene n -Hexane 2,2,4-TMP 1,3 -Butadiene 1122 763 183 1622.25 38934 323 152 76 323.39 161.69 305 143 72 304.84 152.42 355 167 83 354.68 17734 183 86 43 183.14 91.57 65 30 15 64.68 32.34 3 1 1 287 1.44 23 11 5 22.60 11,30 0 0 0 0.00 0.00 0 0 0 000 0.00 77 36 18 76.85 38.42 Emission Factors Units 3.722885475 0.135980494 lb/MMBtu 3.275010553 0280014172 Ib/MMBtu 0.419874302 0.195955337 Ib/MMBtu 6.934E-02 fl/hp-hr 6.934E-02 9/11P -hr 2.101E-03 glhphr 1.400E-02 3.359E-03 I6/MMBtu 9.967E-03 4.984E-03 g/hp-hr 9.396E-03 4.698E-03 g/hp-hr 1.093E-02 5.466E-03 glhp-hr 5.645E-03 2.822E-03 g/hp-hr 1.993E-03 9.967E-04 g/hp-hr 9.860E-05 4.430E-05 g/hp-hr 6.966E-04 3.483E-04 g/hp-hr 0.000E+00 0.000E+00 g/hp-hr 0.000E+00 0.000E+00 glhp-hr 2.369E-03 1.184E-03 g/hp-hr 13WE1108.CP4 RICE Emissions Inventory Section 06 -Regulatory Analysis Regulatory Requirements Regulatlonl Section II.A.1- Except as provided in paragraphs 2through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opadity. This standard is based on 24 consecutive opacity readings taken at 15 -second Intervals for six min utes.The approved reference test method for visible emissions measurement is EPA Method 9 (AO CFR, Part 60, Appendix A Rely, 19921) in all subsections of Section II. A and B of this regulation. Regulation 2 Section I.A- No person, wherever located, shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odorswhich are measured In excel of the following limits: For areas used predominantly for residential or commercial purposes it is a violation R odors are detected afterthe odorous air has been diluted with seven (7) or more volumes of odor free air. Regulao'an3 Part A-APEN Requirements Criteria Pollutants: For criteria pollutants, Air Pollatant Emission Notices are required for: each individual emission point In en attainment area with uncontrolled actual emissions of two ton per year or more of any individual criteria pollutant (pollutants are not summed). Applicant is required to file an APEN since emlssrens exceed 1 ton per year VOC and NOx. Part B —Construction Permit Exemptions Applicant Is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 2TPY threshold (Regulation Number3, Part 0, Section IL0.3.a) Regulation ] Section XVI.B: This engine has a design rate greater than SOOHP (reported as 1,6aOHP) and is located in the ozone non - attainment area. As a result, the engine is subjectxo the air pollution control technology requirements of Section XVI.B.1 for rich burn engines.The APES submitted Indicates the engine is equippedwhh an Air/fuel ratio controller and a non -selective catalytic reduction system to control emissions. As such, the engine is complying with this part of the regulation. Section %VILE: According to Regulation 7 Section XVII.8.5: "Internal combustion engines that are subject to en missions control requirement in a federal maximum achievable control technology ("MACE") standard under40 CFR Part 63, a Best Available Control Technology ("BAR") limit, or a New Source Performance Standard ("NSW) under 40 CFR Part 60 are not subject to Section XVII., except for the leak detection and repair. requirements in Section XVILF." This engine Is subject to emission control requirements in NSPS LA. As a result, it Is not subjectto the requirements of Regulation ]Sedan XVII.E. MALI.IIa This engine Is subject to MALT E22. The facility Ilan area source of HAPs, so the engine is not subject to major source requirements. Since this engine is located at an area source of HAP emissions and commenced construction after to June 12, 2006, it is classified w a "New Stationary Rice." According to §63.659tyo): "Stationary RICE subject to Regulations under 40 CFR Part 60. An affected source that meets any of the criteria I, paragraphs (c)(1) through (7) of this section must meet the requirements of this part by meeting the requirements cf40 CFR part 60 subpart 1111, for compression ignition engines or40 CFR part 60 subpart 1111, for spark ignition engine. No further requirements apply for such engines under this part." The engine mews the criteria listed in §63.6690(cX1): "A new or reconstructed stationary RICE located at an area source." As a result, no further requirements apply for this engine in MACIZZZL NSPS flit Is this engine subject to NSPS000 I I This engine commenced construction after June 12, 2C06, and it was manufactured after Jul 1, 2007 (Roe,aa30(a)(4)(1)). Asa result, the engine is subject to the standards in NSPS JW. According to §60.4233(e) "Owners and operators of stationary Sl ICE with a maximum engine power greater than or equal to 75 XW (100 HP) (except gasoline and rich burn engines that use LPG) must comply with the emission sandards In Table Ito this subpart for their stationary SI ICE." Since this engine was mamufactured after 07/01/2010,the emission standards in Table 1 of this subpart are as fallow: (I) 500=1.0 g/hp-hr, (R) C0= CO g/hp-hr, (iii) VOC= 0.7 g/hp-hr. The controlled emission factors represented in the application meettheseemisslon standards. 13WE110S.CP4 RICE Emissions Inventory Section 0] -Technical Analysis Notes 1.Anint al timpilancetestferth s engine Will, be{ q fretl forthefoll wmg easons ()Th nglne lasso- oral device and n me-ptaWratingg atenhan 50;0 HO and(IThe fa'. Il ty syn[heilcihin rinr^'p NOx maim -for yOC and co.ThisInitial complancet'consistent witlit e requirementsn ihegerreral permit 02for naturalgas fired reciprocating internal comb ion eng nee'.: [should also be noted 2. According to the notice of start.up submIttedforihissource,thesource began operation on 06/21/2017 AS a result, nronthiylm0s are not included in the pennt beaesethis engine has been operating for morethan oeyear Based on P5 Memo 97-03, ''After the first year of operation the monthly limdswill no longer be ineffect and onlytherolling l2 -month limits will remain." Since the engine has been operating for rnorethen one year, the operatorwI have sufficient data to maintain rolling nomonth totals. 3. In the: regulatory applicability s sect,on, it was deterrmned that this en6neis not sublet to Regulation] Section XVII.0. bat the engine is subject to control standardsunder NSPS1111. See the regulatory applicability section (Section 06) above for eddmonat details th adding the atg t the facilitywide permit fortheTraadtcom. 6. The ermssion factor used for th 1/01 representnth non methane hyd arbon amts ion fattorfmrcith catalyst data she emissionfactor that includes ethane in the emission iate results ma conservative estimateofu0C emsi�w,s. Haaraeott, [he,' atiod. 7. The operator provided both a manufa cturer specification sheet and catalyst data sheet fortno engine. The moo conservatveemisson factors and brake specrItc fuel consumption from each data shee was used for permitting purposes. 8.Snceemission factors are represented in lb/MMBtu in the permit, the perator is requiredto sample heat content of the felgas combusted in order to calculate actual emissions. 9. The operator was provided with a draft permit and APEN redlnej00 review prior to publccomment.The operator agreed with rte APEN redlines and provided thee comments on the draft permit The commentsand p provided follows: () Comment: Condition B Please roundtl t for AIRS 009 {C-311) to match the other4identical onsteg f y )II Response: While understand the d f sist cy t6 urpoloyt dth sup toe decimal point. In this Instance, NO and CO t d t8lt tpy d1623tpy ptvely. If were to round these dOWn to 8.1,PYand 162 tpy, you would be q dY ply witha limit of810 and: 1620 tpy. This ooUid automatically ptY out of compl Wth the eml pi %'G limits fyou operate t8760hours/year because tharequested ssl b these levels. As a result,the limits Ith p { it for, NOx andC0 will remain at82 ipY and163toy l the permit. {g}Comment: Notes to Permit Holder g4 Pleasenpdata the HAP emissions fort -31120 ma[chtliose PorYhe other nel compressor pressorengines orris: facility, foroonsstency. (Iv)Responsa. Th s'3 change has bee mde as requested (0)Comment: CondTions42 and 43: OCP suggests that initial compliance testing on the 5th compressor unt included tribe revised Otaft permd(AIR5009) shouldn't be required. This unit is not a new as d was previously Permitted nder General. Permit 02 This engine s already tested tonally under Sf50 Ell requirements when Owes initially permitted back n' source, was 2016 (0)Response: While I understand this is an existing engine that has been tested initially under NIPS JO), this engine should have also been tested perthe GP02 that was originally issued. Per section VA. of the GP. .If the stationery source Is synthetic minorfor NOx or CO aninitial complancetest for outlet concentrations of NOx and CO is required. Initial compliance test requirements only apply to engines equipped with a catalytic emission control device that are nameplate -rated greaterthan or equal to 509 hp." Since the engine meets bth requirements, a test protorefshould have been submitted' to the Division m orderto conduct the Initial GP02sack test Based on myreview of records, the engine was never tested per the GP02 and thus ever demonstrated compliance with the general permit testing requirements. As a result, the testing that should have been conducted per the GP02.s now included in this permft.The operator reviewed the responses provided and expressed they had no further Section'08 SCC Coding and Emissions Factors AIRS Point g 009 Process d 01 SCC Code b3 sferxi CoinhUsti EhFLtes Nadi Uncontrolled Emissions Pollutant Factor Control% 000 PM10 0.019 0.005 b/MMBN PM2.5 0019 0.00% b/MMBtu Nex 3.7229E+00 96.24% b/MMBtu VOC 0420 53.33% /MMBtu CO 3.2]5 91.4S% b/MMBtu 502 5.88E-09 0.00% b/MMBtu Formaldehyde 1.40E-02 76.00% /MMBtu Acetaldehyde 2.79E-03 50.00'% blMMBtu Acrolein 2.63E-03 50.00% 1100BN Methanol 3.06E-03 50.00% /MMEitu Benzene 1.58E-03 50.00% b/MM. Toluene 5.58E-04 50.00% /MMBtu Ethyl benzene 248E-05 50.00% b/MMBtu Xylene 1.95E-04 50.00% b/MMBtu n -Hexane 0.00E+00 50.00% /MMBtu 2,2,4-TMP 000f000 50.00% b/MMBN 1,3 -Butadiene 6.63E-04 50.00% /MM0tu 13WE11a8.CP4 Turbine Emissions Inventory Sealon 05 .4misslons Inventory odtede Polluants Potential (c Emit Uncontrolled (tons/year)N(tonrhear) Actual Emlsslw Rona/year) Requested Permit Wolfs Itore/eerl (tomNear) PM10 Pl42.5 CO 202 0.00 0.00 2.0136 2.0184 2.02 0.00 0.00 2.010 10186 18.59 Hazardous Nr Pollutants Potential to.. Uncontrolled (tin igeerl Actual relsslons Uncontrolled Controlled U mhead (to.6,1 lmre/r Requested Pemlttlmlts l Itm4Nearl (tons/yar1 Requested Permitting. ...lled ed 11:/yearl1 hiss/curl Formaldehde 2.172E-01 0.000E. 0000E+00 2.172E-01 4172E-01 4343247 4341147 Acetaldehyde 1.2.23E-02 Ogg.. 0.000.0 1.223,02 1.723E-02 24:1654 whin 1.957E-03 60000+00 0.000E+00 1.937E-03 1.937E-03 3.9149 3.3149 Emus. 3.670E-03 0.000E. 0.000E+00 3.670.3 3.670.03 7.340S 73405 1,3-Butadione 1310-04 0400E. 0.000E+00 1415E. 1315,04 0.2630 0.2630 F1rHbo 903JF-0 19.5747 Teluene 3.976042 0.000 °Aloof.° 4976E-02 3.936,02 79.5224 745224 PAH 6729.4 6060.0 0.000E+00 6.729E-04 6.729,04 43438 3450 Xylone 1..0-02 6000E. 0.000E+00 1.957E-02 1457042 39.1495 03.1495 cdmrla Pollutants VOC Uncontrolled Potential to Emit (tonsryean) 043 0.02 inIsslons Uncontrolled Controlled 105/year) ImtnNearl 0.00 0.00 0.00 Requested Permit umlls Uncontrolled 100Nearl (mm/year) 0.43 602 2.11 0.43 402 2.11 600 Prea.ss03, er.inesbutdvwdere. OF.. Polluans Potential to Emit Isms/Pear) Actual Emissive (tom/year) 1tons/7001 Requested Permit UmIts Controlled Itom/yearl (00/7.6rl x CO0.02 0.19 0.19 0.00 0.00 0.02 602 1.49 B,Bg g.aB 1.49 1.45 Section 06 • Re ulato Su are Analysis 8arvbtionl Sertion IL0.1-Exast as provIded In paragraphs 2rtuwgh 6 below, no owner or opermor of a sours shall allow or cause Me emistln into the abnosphere of any. pollutant which Is In excess a 20%opo0ty. Tide standard Is based on 24 rmssadve osedty read hats taken at 13 - second forsx minutes. The approved reference rest metkd Mr visible emissions measurement Is EPA McMd 9 (40 GP. Part 60, Appendix Apwy,19921)In all subsettbrs of Section ILA and Bo,Min regulation. Section 104 No owner or operator shall cause or permit robe emitted Into Me atmosphere from arch be Ib timing equlpmer:g pa Ncul ate maher the floe ....II exceeds the following: fuel burningequipmentent with designed hmt 09In. puts greater than 1x10°001 par hour, but less Manor equal tos00x10o ON per honsthe following equation will be used to determine Me allowable particulate emission Ilmlratlon. PE.0.51Fig... Where: E PaN Pounds per million BN heat Input. Fl Fuel Input In Million per hour. The todesign h MF./hr.w a result, the turbine Is subject to this portion oldie regWatlen. Using Nov above equation, the allowable particulate om'esie^Omiredan Is0.16616/MMeu.The AP -42 embsbn factor cxlasb/MM6m used nth. akuletIenabev.b halo... particulate embsusoressola. Section VI.64. New of sulfur dl to ole slid t emit mouse to be emlwd sulfur dioxide In excessof Me following pmd e asespec Ilmita n(Heat input m�zhall be the manufacturer's guammeed maximum Mat Input arse) q.e(q. Combustion Turbines with a Mat Input al less than 250 millin an per hour, 04 pounds of sulfur dioxide per million BTU of haat input. The turbine covered under point 010 hesa dark^ heat Input rate of 69.09 MMmu/hr. As a result, the turbine is subject to this portion ol the regulation. The AP -42 edssion fetter of 3.4x0 s1b/MM. used in Ma calculations above le below this sulfur dioxide emission threshold. p.m;e'2 - located, Mall cause or allow tMwissl^nof odorous air contaminants from any snipe snve such 0. limits: Far erns used predominantly. residential wmmmerriel resit lnddeteoobpewodors which are measured Me.. odorous yumases It is a violation it odors are detected ater the abets air has been dil:rted MM.. pl cr more sod times of dm !main. Regulation 3 Part APEN P.aquinmems Criteria Polluter. For criteria pollutants urPollutant EMiw;m, Notices are requitedtor: each Individual emlsslonpaintln a mnattebm=t area with uncontrolled oval emissions of one ton per year or more of any idlmat criteria pollutant (pollutants are mot suramedlfor which Me area is non-atteinment. Applicant is required to file an APENsint emissions exceed l ton per year NOa Part 0 -Construction Permit Ficaroptions Applicant is required to ok alpermit sin. uncontrolled Non emissions from thlsfaclllty are greeter then the 10 TPT thtnshold(eeg , Part B,section 00.2a1 ...le.n6 Part 8Section II. Standards of Pedamnce br New Fuel Miming Equipment ISC Standard for Plaice,. Marton On and r the te on which pertormance test s completed, no owner cresator subj.atorle prmsdmn of MIs regulatln may a5mar00ra ca1seMedscharge Into.au0544810lof any Pergal ...ere... 11.C2. Far fuel burning equipment gat: ¢mdse greater Nan one million but less Mari 250 million Stu per hour heat input. Me Milo.. equation will bewail to dotemine the allowable paNnda te emission limitation: PEM35[ry Were: PE able partied.. emission In pads per million Btu heat input Fsb is the fuel input In million 0tu per hour. If [wear more units connect to any opening, the maximum allowable mid.. ate shall ion Ma sum of the Individual emistonfates. 1603. Greater than 20 percent oPertry. 100 Stendaf4 for Sulfur 010800810 hichrlw required performance rest is completed, no owrer or operatwaub1eet ayddls1M1arge or cause Me discharge Into the atmosphere sulfur dlorlde In execs.!: 11.0,3.a. Sources win a heat Input of less than 250 million 0W per hour: Marys. 302/millin MU Ifio turbine tad under point010 M1ue design inn input rate of 69.83 MMF./,9 and will be constructed .40.01/30/79.4Po resuksh, [whine Is subjectto this potion oftbe rervkibn 01143 the .hove equation. 11.02., the allowable pavkuh45.mhabn limhetion is 0.1666/MATOW. The AP -42 omission factor of 6.6310 itiPM/MM9W used nth@mkuletbns above is bebwM4 babes particulateb584!, the AP -42 emusbnfawrof3.440' b6OWMMBW used Intimcaln:lrtbrs above, sulfur cll.., emission threshold of08890WMMazu. N.PS GO: The provisions of Mb subpart are applicable to the following airy., faclll[Ies: NI...onary8,...n.... heat Input a[ our, based on the lower he [ng wealthe 50 aid. oak load emalto or greater Man 10.7 pge]oulea(10 rel. Btu) per 5 The beat input at peals Mad for. turbine (Plot 0201b68.9MM8W/I:rwhl.hbmat.rib.n SSMMMS/h, As 08. .WAna mould be subject ow OM isee 0p1ablety discussion below]. Ac0Ningto NSP3 MN% §60.43051.15[ combustion turbine regulated under subpart are exempt hem the requirernerde of subpart SG of this pert. Neat recovery Amen generetan and duct burners regulated underthb subpart are exemptedfrom Ma requiremams of subparts ,adsdMathis part. As a tesuh,NSP5GG does not apply to poimal0. a at Input at peak load equal to or greater n 10J Nsps5MIX: If you are the owner ce operate,- of a iaum varynbus's.WMw1Mheat than ¢¢ 353.10.(108.0.1 ar hour, based= the d= liryser heating value of the fuel, which commend consomti.0 modghcadortcc rmxetmmn after February 14 2005, your nab Ise Is subject to. subpart As 2,014546KK.ppDI.O.M.es to this turbine. The applicable I.O.M.by after This turbine (Paha 0101 ha 8 ht input at peak load of 69.03 MMatu/hr 1010MMatu/kand commence construction February 18, 2005. a 409 n perm. been the b. geguktlon7 Section XV 406. Combustion Atlfustmant ApplkabAhy. Except es pmelded In Section %18,0.2., As of January 1,201], this Section %18.0.6. applies to boilers, duct bunters, Amass heaters, ttetionary combustion turbines, end atatbnbry 06000 wing Internal combustion engines with uncontrolled actual emissions of No q to0,m...en ...en Rye (5l tons pry er that oxtad at majors^urces of NOx as of Juno 16. The turbine cowered under paint 010 b not located at an existing major sour. of NOs Asa rest'', this turbine b not subject to thk portion of Me regulation. MACT u are osubject to this subpert Flyouoa proper. o50.404,. combustion turbnabated at a major sauce of HAP This WM. (Point 010) Is not subject to MALT Mg bemuse 6 is located et an area source of HAPembsbn. 110722 5:\PA\20ll\13WE1108ID4 Turbine Emissions Inventory vb'nep d ate stt )IL) e presa�zth urelgzsr 12 fmgrs,e,d0n20%cOhe uei ss arf HG / to tz sib/hi hr/sgaz gtu)[}e boom) as der'an e Voe n de terminncitobe z Foy wrc em _. e nme n sll p retes{a re's rwlro er n add the anufacW ucns ...express than the Vot em n "� m°Ale mar¢n cw L(1 2 ht - td.. Y d / H fI p ce p d 6 fo 6 CAP -42(o e 4 l P £ J 6 C . d an "n fats rsf M p Vu n o f P42 za< p[ .d ) 1 n oC(maximum) . i, 2' in ternv OfPM e'rOss s,5elarA E1}2zu h6useo'tner 5"b/MM -e t,I0-onnor, to fntnzrenAass than geceryv a"..dcusiorcer source . dl,' shown chatAMPO( rs,)fo natunni odi are,an 11,,ladd In _ ddr fytdhouldb:notzd thatone Dividon". for the t p e ate narfap. u ,e,,, ..0, -e0 t,, onto,.. for P1411.0 and pMz5 , r o n-Pz d o sure ehe , rw, An non. wincnn,av a condnInnto nvb,ne be tracked hasnd on the 'Oetionn long Btu(q.2 0,03g5210/MO40.).0 usuhs 2/0 d dnd mannfacvdrerspncifientl,n021,,,ondedp tvpoet,on000nwarearon for ppmvalues, e evadable 'aro-nano Ovv.01,310, den, n[he rut M iyhlgnermanthe n/hry d n ,conditron that equresta rod.,bopem d Ina way that tile SononiOn mode is engaged dmesduring noon,opera., prevlonsaypll a renardoonntoNOxrnade o not provided m the p r tarty ou , they rn thee ncpe.e o b ion Onn information h fever, r mthsbait/One dec to athertthemmntnunus m >00 top/Pt,rso sw.aeterso,o nnstporv.too,,ver Osong 0.0 ts conducted ona gwrte.y bass. te, testing for NOx and CO has been rIsusnsa marmfactorerapeneed emission f actor tor ad ore lOtial tenting ontdremento 0000,25,1f/a rnitsion factor used to ododatn CC nrongonn o lry, 0 only he OS s 250 oxygen mt lmis are based orunanuhc1 2 von, renuned by NSPS 2000 o1, 012 ( nperanngv NOx levels. 15 Form °E crygen the stack tog h p ra wind dl e a v5 d, the operator' may demnztatewmpwrvn nISPS KRKK bnvonod,-t nlydam trtecoro m IM the parole - - - [uparm: sbualowoeventzhaaeMeer emisceon os compared roomedy state opera tronvfssa not., icpL n m -d unetor elevated em these psi mtledmnura-tuerdan6Wen events a. in4dsted,to,pnonida lor e �clty,ne manor sourer provided data included at x, COahm 4 'n basedonmnntaetaanpsam bomnm,07ulantu.0441handy em.zonameeaat ana zbumo =- now n i sf rNox t oleldroca todownIold b}brand b/nr,ineop luesare significantly er than c es dutinguaa up and s�nutdow ifr'ss need tae rem ss orzd hood vn no � on n. • eft o d co t. Fort A 1 n e PCw oua Theo_ borer, needed to be an T tl,e'virlOniemi,storfc61cMor.Osedatheruse;V, ad fx oo nupivi o,cfficati8OsheettliatO dared Ilant content. trt b nerchnice rh'eogeraror was expressed use,) on10 4 00re avived dnn2 sh ae(0tl.v) sI e 7 Theo odd ' n't urrzhr 'm(b/MMen),(M00^sscp,m ao ¢a ho,M5 .ea ' . "lu[ e facet vbem [oboe ,Y c/NM sson so I' .- 5. The O prnvidndpne comment.the drag p 0.1 is Once - � me turbine start,and mu'.rn,y van, no Impann on dvarolln-rOssion,niculatinnstor ap= f d_r)4 eased urvorrond, and prevInnsapplicanorn submitted: e ba up/shtdo ! lattonz'ir 02,00 and Yong s nttyc q rack the ergh orehertart2up/2,0[donw+.Thbdaddonwam ate because basis -ap/doom me 34m Ibinventemlsann lectors now.. ; m f /M1 ofthe e ode nn kthatm 020000,7/021120t0002/002110070002804190025020327 Inn/shutdown cmN'slr /eat 08271 ,sec d uprsn saw, ,does not vary k7f esdron nnOno thn oodef esthete n 2Mer d the need tovark event. The operator re•en.oe'd d ed Ne.lovr g nhe !prorlded ,factors f n, In Other .SUS. ism to[het ds ter soma rd opera e,hen caialote /v yr(in e mrrzld a n 70D !, o SLIM Ew these nednm h < Fa Mt Iwdzo o (a az.5 ) edanto is smlu Hsu .zed'If WYaup[meiortM sta de lsn 1,e0YOs b/eventtectors no on zsVI, mo0< n ery tv -,m a ofemssonm vn. dre sedwrine12 peon hedwThM a(DCPIm :deceive-redder:aria,.evelca A f zh Word:, f "' dby. N , fa ec rsComore'd nd ut, 0 4 p p k n w 3 ,tor e a b/ev• wn 9eiad operator hey dwed heep og alelom Imo nti'iekerm ' Section 08 -Inventory SCC Coding and Emissions factors 010 Protons, SCC Code Uncontrolled Emissions Pollutant Factor Control', 72011) 0.60E-07b/MMetu Input PM25 6.60E-03b/MMBtu Input NOx 569.50OMatt, VOC Z.10503b/MMetu Input CO 6.05502b/MMetu Input 930 /1,415712 Input Formaldehyde b/MMetu Input Acetaldehyde - Inpto bMA.Inp21ut b/M5Stu Input 15-Edlene 5606.47 IWNIIVBtu Input Ethylie 3.334--05 b/MMetu Input Toilene 1.30504 NM. Input b/MM9tu Input 55ene 6.40E -n5 0/00041010420 VOC NOx 100 VOC 6.00 150 6500 Martrup event rt-up event drta pent /shutdown event /shutdown even[ /shutdown even 120122 N:Pa\2023\rwE2105.CP4 Glycol Dehydrator Emissions Inventory cal Dehm010 'Facility 016010: Plant 600 911 Polnt Section 02 -Equipment .ptlm['Gelb DehydratorInformation DehyaramrTypm serlaINunMen Deslan Calamity: Recirculation Pump omutlan Number°, Pumps PurnOTYPn Ceslgn/Mat00100 06on gate Dehydrator Equipment Flesh Tank Pelsaer Burnes Stripping Gaz Dehydrator EpuipmentOeseipdon MMsc0day plIons/m0ute flash.* and reboller burner One (g110 001006 glycol (TEel n.tural pas dah142610n unit(xm TOO with d0i¢n cap01 0 60 20 2 11400 Tnle aims un0ts equipped with % SMnl,a:Tae.Moeel: TM) els:rmadaengiymlpump with aaeg�®pedtyorolgmlo, per inure The dehydration unilsanui0060lBh osslllwnt.flash lank, and reboller human. ErnIssionsfrom the EMI sant am routed to an air.00lad conderser, and Man tot., Enclosed Emission Can.! cevice Descdpdan. Un0(VRUiAfa ry =Imo: devna,fwsh 00006,,1000 are routedmme Enclosed Pere. em�n,em nam.Iwna,nnnkammGxao y m p Recovery sectIan m - Promaire Pate Information Io r Emissbm Estimates Primary Em6aara-Dehpm1000111/ant and Flash Tank lll present] PesuestedPermitUr.Throusimu, 12,12110,5, SNOW WY., Potentialm Em¢(PTE)Throeghput 5 35,110 00127000 r Secondary Errisdons-C, hustfon Devrtgq Mr Mr Pcllutian control Sall Vent Control Condenses Condenser ernisslon rvyommldei reduction claimed. MmaSemndarycontrol device: Flash tankControl PrlmeryrnGrol dog.: Primary control device opeatmn: Secondary enrol device: Secondary eel device operation: Plash ',rite's eating value FlashTankwaste Gas Vent Pata: Ermlosed Flare u,&tgasam: Heat content 240acr/hr 9 scf/hr adm- Bm/gcr Section..-Em6siam Factors 8. MGhada'oGas Requested 00601220106607100 2,720 MhIssf per mon. ested condenser Ou,GTemperature: _.,.i e, -260 Degrees %z. Central mn.enw x SecluestedTO . DegreesCanttol EST Flash Tankremp: Flash Tank Pressure: Dry Gas water Content Pollutant UncontrolledllbSul ConSolled1lM. Con lee 0/.1 VOC 06.025 ,5. 433701 Toluene ii:OSBiyn:x. 090665 0 Emylbenaene '4 .69539.4,5,, 0917665 0 Xylenes 09 0.175155 0 n4ielane ..,2L636.:x'ru� ".'. 0.0363 0 n6TMP ,.,A.y:.:0Af36t„'ti'I" 0.00069 0 Methanol , .': UA30S2C.'t�"+ D.msOtsy D RASSTANX Pollutant VOC Benzene Toluene Sthylbeinene xyle*e Uncanoolled 76701) Control Renee Pdmary Coneml21m702 Secondary Controlled 11670,1 SIG/c+: 0.107 0.00539 0.000615 0.358 0.0007.0 Methanol Dry Gas Control: � Mill Vent Primary MSG/yf Rh Vent Secandary 0140011 MMscf/yr Wastrknan ConwecnComb...Mscf/yr sollventseran ry nto, 00 HIMscf/yr rvGesThravithos0 Flash Tank Prfmary Control, 30,514. Fanscf/yr FlashTankxmr0aryCon0ol: 1,6064 MINscf/yr Waste Gas urban FlashTank Prfrnary Condo, 0.0 71142/20 Hash Tanksetentl ryControl: 020 MMscf/yr PIIG fuel/Asset Gas Gambian,. P00106611 040 M0,/yeer MsIstruel: 47904 M /ydr Teta, 41.70 MM,Gnear Lean Glycol Water Con.nt x wLxg7.0 2,706.0 400542/month 0.89 MMscf/month 5555.4 46.5 ,5 3962 5512 0.45 S76,6 itM 675,E COM,. 6740 SOW 656S 5.4.45,54 4,42t 045,ABM S222 52.13 Glycol Dehydrator Emissions Inventory slon Factor Suction 05 Enqsslons Old operator reques al't bu f!wanton, buffer? Requested Buffer (96): Pollutant Ethvlbenzene NOx CO Pollutant Pollutant SOX NOP Pollutant Unco rolled Co rolled pb/MM,70 4!! IDgGa rnmogbputI .52555725 0-9771.6 0.00576 '(44054'tlllb 4 MI 'k Still Vent sewndaryconero5oeY® Uncontrolled Uncontrolled (Il/MMGtu( (Ib/n+Manl Iwa (Waste combusted) Combust.) 1.g. OP 1 00319427 0.00,2002. 0 WOO Flash Tank Primary Control Device Uncontrolled Uncontrolled 1110577774) ste Heat aste Gas ma steel Combusted) usted) 00.0 0.00 Y8t: 4MIN UP.ti"Jcryfi 4.474! flesh semMery 447ral Device Uncontnalerl ro/Mla0l401 (14/MMsi Ie) (wastexeat(wane ea edl ) u0oro ut/assist Gas combustion Uncontrolled Uncontrolled (I4/MMgtul (0(575071 Mugu Heat (weft Gas b ned Combos.) m u 1 pm'is., ,taw9.5686 aa asses Emission Factor Source Cate. Pollutants UncontrPolled (mm/Ymae)d t m Emissions (tons/year)(070,,tro9 (montrolledControlled r. Uncontrollexl m (mn00 Requested Monthly Controlled ug(00/moms) PM10 'MC 0.07 0.07 0.07 0.07 11.2S 7.,9.21 724.89 72439 3670.77 xazaraauzurpobutant u0lbetyezr)a uncontrolled (40/751led 51) Uncontrolled Uts/Vaarr(Its/7051) (070/740,d (mm/yea,) Toluene mhylbanzone 44105o n.Hezane 226 TMP Methanol 1106a5.24 116.3, 116005, 3427.53 342753 170.S 3427.53 270,5 1.71 0.0, 43970.32 28.874.29 1661. 246.74.3. 1.105 16.26 0.84 2917730 281,50 1009.09 281,59. 1009,9 14.09 0.50 165.01 185.01 0.69 135.01 0.69 0.09 P003 MAAS 284.86 1020 299.66 30.2.03 0.1 0.005 Section 06. Pegulato SUrnma Anal is PegulatIon, Parts A, B Regulation 7,5ection Regulation 7.5ection Regulation Part, MALT subpartHH(Area) Regulation 8. Part E. MAR Subpart NH (Major) Pe4uration E. Part E. Mncl Subpart HHH (sot regulatory applicability wor4beot for detailed enatysl9 Dehydrator of sub. to10541, 53001io1341343 Control440113401047141! 445 (4,4)!r '0 n34544454(405444177!4054!)4704I144 4 Dehydrator Dairy. subj.= to area source MAR HI - Control requirementsn 53.765 per...7541O11 You have indicuted that tiefaeiliry is not subiaa Ntaioi.3murce remsireraents a MACT141.1. You hare ',Id...lied that thin. facilit, is not subject to MAC,' XXX. .316 LoWn,-.H.10n9 Value pf Gas 410/,_t 45..115.E Gtwatr .3V lotu/.c! .b. 2t_/zl 002 SGS isobuiPne 3.2 .083 37,1.5 417,7 0,74.7 7143 ar Hmher HeW np Value of Gas 1.56-6.94735 Pluieof Sr:µ_:!:- .5 4'334P� J4 Bg-+_3= Glycol Dehydrator Emissions Inventory ream 0]-.lel and Pee., emoting and..tineg..moms as the extended wet, sans* used In the crycalc model/Process mod...sped, and cplicted within a year of epplicaion submittal, If Rost. permltwmcnnte.aelnnial[0,U ..testing mqurrementm aemonstrme compiance with emission omit 0se eer,,ency greater than 95% for are or combustfon device? If valet., permit,. rammaln and initalteplanet on condition toaemodmtreta tlwaos troabn efficincyw the mmbnni..,eeicel.e.eed on inletananmlet concentrtie^ .rePlinFt nee company eas requested a control deuece oleidency greater than 55%, Isermaloxelizerorregenerative thermal macaws Iseing used to achieve'', Is the corns's,' using a thermal osIdeer MO segues., minInsurn combust...or temperature lower Sean 1,400,e4ree, ,yos, tea parr. Mil =melts an sl,tlal Compliances tasting requIrornont AN0 pormit condition spot, eine the minlmum consIsuelion cearnbortomporatureforthethorma,oxidaor. !:I., Tee mfss,sn's (rotes t6e still ,,,sard'reltfed -so.aeoesienses.pdoi to Lierngseletoseee'tee enclosed 'Sere. eoperelsrIenottatei seed, for anyc cendenser. Thls Is demonstrated to t y mode t,caEsseees iseconse, emissions a,s1 use, a 95„nt.r,lassoda,,,t1-, see Rare to cat.ai control!. es,ssre,,,s 'are. 2 .ou efors. condenser n[.mmbton ., orated earv.-ae the pemldwill mpe+a operatorused Ne Seendenseras,sontrol tlevIce,She eye cif she eeeventstrearn,,o salculatesselle,,,,nbustion ernes,. is seseptabl e as iris 1.1, ..TTerrupre'sen,zn Of L.,,,i missions, ille co-hgr oplion ro,calEulabngskIll iient.:',' , is,ornbustion emissions Mel have bee ethers Weans, I / 6rn ively thence :ilsesSficesiee shang, or ether reeuleterrequesenien, As ,,M1, trzs.etarmmd ese see ofthe cosnesssItionand novirste a ssecamo wth me Condon WO, a,spIst,lx for astimaSnOtaventr,rnbu5Son s-,S,,,Semperatire an, pressure, Use ialetsver gas sees., in ese simuleseser do neSsnatse wise. reseporeesre sod 13,551,r, On the rel,,,,,,..e sarrOe Prned,,,,,,,,....0..03d re.,,d teS,G1,,, S.... • I.I;As.riln . rase: xstisit.sa131 tSe operator, 1-Inwever,Ille operator aded a I.O.X.bsfier to the, emiss,xx estimate to account for vorMor, in.the gas onalysfs ost other act,. „,e,” ,e,eceeervesieechan else s Gyc..csmoalon As ar r,*b can a.o efor pmrgp %Her at. onIn. " ebwat glv efe9. tsepecoad bynme I2CH,Ie of Iect e'regoe.met Foe .specs ecPopk/a p4na.are,.a (ode ,ougy/'O / Jnae saeafbok b f ) rft 1 7 x R'/" W N_. (Id im N I f d/ n Pe rarwn,ta oedaa,tt.y "ontrold p..',O'er( ,4e37a, and 1Nnerarcp may ventmaa etaacan dt,1e'seeto PMwe -r nt was no.. theruie requested c'ontroi device ' ISlisisernent an,uscle,6Me deviceeownp os i.e.,. oSf eSp Tt incormstly allowed((1,101ntime aflhaSsod,ring WES ers,s,onswou be route e,sperato,r,XX4Yressar teateate rrohowmeters for fhoXesh tookorsslixextv.71exasstrxen,Thesperato16xpressedtteII 01 1 1(40 71 tanks dlcrm n.drtom Ne 11]i H II Ic by aenMrara em ere. ocn isoon a s gas throuelsout is enIt .ago /hrree'o1er since thxreoder hes ad gta/hr, E xmnetp Colorado 'onl ol_k paeorfnd'cet to gh:txxl and aaxktf [ ed by xhecombustorMw etasppsanerate andarefiereforznatmeee edbnacons3 p scf/hr ands k46r.i tocdld n Nog€d p faeftow 1 icOt eIS Xfor tlptrt, Xli He assist foesdpie,e van though tM1eseratea`areipnxmnCai m'sonassscgasandvi ptfue Include, e= rbecauseateonsribrttes ea M eraltmemfsalw limit an rvo<an nedmsee Inaea d evofJmeor ed nonm yara,bron "oredu'naa o..etrat lheov�orthodeeye-adononrt.w ,maps net¢ 'pe rot nedx "dry gas I'Mo ins larglage accurataIr re.c.ifie voluErre of gas the opemtur la directly ronasuring at the facility and ocatrae compliance bthe p .wMe,. 'die dry"ges now raw, Sethe Input value toe dee GlyCalcsimulation tee aPeretoe uses to elernonstrete someesnee 'v. tee emission emits,' see perm, „ dad m Mee, en,,tvcale stmeasion ie else spec...uses, sees ,ehyarator fs fr, end. to be p8rtof a new separate corn,sdan tr., at the facHry.,8 result the ps conlosakil ' :; Mee -:per w r., t a etea q .. e Sample teas svill bee ernes,. are..., e conservative. .• s :11.-0.,cOrding tosheope,sthr; the S.S.,1,o,sent of 1.14 Seas, gas streams /Rase Sank ands. Velln023, gas) seine calculaSetl based on the en creel., elyea team. By ca.,. egress., val. ng tees inio a es(sasstank control. by sec, ads eIex/o (Ss .)ra I tar Hile odtventandftsM1 spsXwasse sax xtrsanix viill Se CaSulatid xn a rxxxSIly Ss. st. useil alaxgxiSS Ole calculated flew rate and ertenitared hours °toper.. es deternsese tee corneustionertessions. ales eep se, sset for ttt.endoe ee:o.e reethannaentmr,Se pressed wet gas Issreneree during wester sionthsi. - - - o ,orrregardfss the So* tronsmitter that. be used to track V.I.clown.e xs intl ie.,. in tee 0,,,ere ,ne tio, transmitter indicates the orxsencx oruvs,o, sox, est nets ' ,_. i a+ei He flowerans Its ntlicamifmgv routed (1 fN s axre mosue ti.on MIS to Brea .cet hyl" es:, osee re ca,- rens fneliceeed a,,ej to s seltelese seed. Vets dosentrrtse ern... reeeeos dell," , ,' ,' • , - ' • . :"10. Tea dels,,satfon us,. epurppern [wolfelecIrled6ven Mr, P h uanonrete o130ngo the assEcaUss. only one sums Is ea V € 0 Thesaood Nrcol peme ly p vas bken more o wll be ressrea too.. a xits spec!,eetvest petodemo am initio cam w me parmtredm iee op.eratorid ca t used n< wi',leen glycol and areas vestersenseet ere eee,osoe g eees e,,,,,,,,,,,,,,,,,,,,,,,, ,ss, p ,s, rm q Ne pe for so nmh nor these inFele". de IhM ksp.fled in the Y 1 4s0ai h IseetheGIKals sem:I...are then multi,. by ...of tie:In...I, nsole.,onsentrstiesn ss,e ieletn.He.ne mole% uses-ed.:ion, m ry ul used e ma i detesselne emission, Hoseaver,the rnole % values pros. a conservative esslrnate temssro IaIng s s dtpesN to etM1aoc 'ssbns teeen iee,Sarbtetyleoeneliesssrmulatonto de s• Sect., - Inventory scc Coding aiel Emissions Factors 011 Co Proer uncontrosoe Pollutant [mivaon Factor Control P010 0.000 b/MMscf 4/1xlmse sox 0200 0.0 b/INNISef le04 0.150 00b/MM VOC 05.1 97.0 b/MMscf CO 0102 0/003.B75 95.157f 701174 95.0b/MMaaf Ebaaf �xyien/MM e b/MAW n.elosasse 007 95.4b/MMaaf /MM.df Methanol o.oce rs.a /Mt, Dehydrator Regulatory Malysis Worksheet Cobreao Re...Ion 3 Parts a an a a -APEN end PemlltRequirements [Source Is to the Nn -Attainment Area 1. Are emIsstons from any rr (Regulation 3, part,, Section 6.0.1.2), z Are. rad./uc n2trolled VOCemis=r g sbnegreateMan 5TPv 0. greater Man1611,orr2tertuan CD emissions greater man 101.6, (Rewladn 3, PartR,5ecaon 11.0.3,7 IYouhobslnaimted that source is inthe Non-Atteinnwn1Area 1. Are uncontrolled sanal source greater man ITPY 10224 gon 3, Partlx ,5donit.o.l.a1? z Are to cillty uncontrolledtrolled VOCemissbnsfrom the greater than 5Try oral emissions greater than 1011, 3, Part R, Section Ilan, I= urea lieuolses an ura Requiresa APEN Gob the nextquestbn Colorado Peculation Is ea esdehydrator located In the 6.hr ozone control area orany ozone non-atobmentarea or attaInment/maIntenance area IPeg az), Pro)at Sheet. Is glycol dehydrator loaatl scan oil and gas eaploradon and prod.,. operation', natural gas compressor atation,namral gas Ldp stet. ortgaspraessing plant lReg]Eecaon ou have lndiaad mefality tyre on Me Prolee5ummary Sheet. 3. Is. sum of 0121uncontrolled emissions ofVOC horn any single dabyaramror group of dehydrators eta singlestationarysdurcerequal b or greater manl5my(Reg], SeeaSeeder,xll.H3.b1? Go mmen enquesdon eual Area trolled em,s,ons ofVGC from. individual glycol natural gas El...prawn,...eater maul tw(Ree.Sedion xtl.x.3.a1?_ Dehydrator lsaublect to Regulaaon',Suction xll.H to Regulation, Section MLR Section Mal—EMssbn Reductions from glycol natural gas dehydrators MAR Malvsls 1. Is Me dehydrator I«atmacan ell and natural gas production (adllMmacmeea elmenfthe fellowingniterla: a 1611'026procoses, upgrades crsto,. hydrocarbonnquids' 0,66(a11z1);O6 facility thatprocesses, upgradesorsbres naval gas prior. Me polntatwbtch natural gas enters me natural gas transmission and storage source category or Is delivered. a final b, end user'. (63.760(a3)}7 z Isms enyarmm may xx Aaagl�ry m=7'rentsamon =err.. ncucrxx eopu,ahalty 40CFR,Parta3,subparl 6,6H , ell and Gas Production Eaellttles I. ,the dehydrator amemvleneblvc0l(rtGlaehvarabanunit(63.rso(a(o11? .mina 20. Is the a6tval annual average CoWiate of natural gas 10me glycol dehydrzaon W.I.,man 3..274' CANIscf per aay163.'64(elalm, 20. Pre aCtUal annual average emissions ofbercene from. glycol dehydration unit num. Vent.. amosphere less than 1ss4.mbhr fsaae4le{(1lln1? 3. Is the unItlocated ola plusolfserand VC boundary area? Ioeissubiecbto urea source MAR H11. Cont. requirementsin 63765 ner00310mfu Subpart A,Generalprovlslons per 080.)6412)000182 463.'65-Emisslons Control Standards 663373- Monimring5tandards 663.774- tordbeepbg 463.7'6 -Reporting MajorsPeculremeMs mefamy haves acNtywtae acme, annual average natural gas throughputless man 0.�MMscf/dayAND a faclllty-wide aebal annual average hydrotarbo q ...ugh,. Ie.man 1. 37 bblid (6376ge1(y), mall ortarge Leby oeterminatlon 2a. Is theadual annual average. tlawrate or .al gas to the givcol dehydado n unit., than 3..1]4] M NW, per day 163.051,7 Ob. Me actual annual ave rage emissions of benzene from the glycol dehydration unit process vent tothe atmosphere less man 1.su.210/yr 165.]611? Smell Doh, Reoulmments 3. Ofd construction ofine small glycol dehydration unhcommente on or beforenugustz3,2011163.]6o(b11111RIg1 and 1C1, A Frthlssmall deb,Is a control device required to wet. ECU erasion,IMt given by. aoplkable equation, Continue source Is subject. MAR NH requirement.0eu have122lczte2 the source category. me Prolectsummary sheet w. MAC, HH Area soma appllabilih section Iyes I0ondne-You have Ind.,. Ibe dehydrator rope thedehvdrator bvn.,y4hee0 lye or Scum, rnulamem4010001Hx. Subpart A, General provislone per 463.]64121 Table z 463765 • Em,sbns Control Standards 463773 -Monitoring 463.714-Pecordepbg pans -Reporting 40 aR,pert 63,subwrt MAR HHH, 220tualGasTransmlalon and Stooge Facilities I Is Ole facIllty woe actu al age n atural gas m roughp u t less Man 0.3336651 MMsa/226 262 yvcol aehva amrs me omv xgg misstn n source 1631zz0(n V Similar ,4 actual 08. .on reMe actua l anDetenual average Mwrate of natural gas to Me glycol dehydration unll04s Man 30340x1 MM r per de, (63.1a0(b)(zl l 20. Are null average embsians ofbenaenefromme g0,10410060n 1016 process vent. atmosthe 0phere less Man 1364.z1b/yr 163.12'0@1(21)? teenygw0 00120te 3. Did all glycol dehydration nit commence on or befereAugust23, zm1(63.1agb)(21 and 1311, 4. For., small del,. Is a control aevlcerequlretl.meettheSTExemisslon Rm¢&anaara?l given bvme applicable epuabn, Irn indiuntotltbutIthIsbaclibt nut *Ian to Hut. her 463.12]4 Ia1 Tads 2 6630275 -Melons Control Standards 463.1'01 tonal EquInme0t5and ads 463.1283-InspeNon and Moni.dng 463.1284-Recordbeepfng 463.1235-Repoting manx4R.0 tlebydam 01424 11001ntunder NUR Hx or HHH (Rego lawn7,0mon x011.0.5)? Is thIs ter located at a transmIssloNsmage rni6ry, 2. Is this dehydrator located., an ell and gas exploration and production operation, natural gas compressor atatlonor gas processing plant Oleg', Section 0VIl.0.3)i 4. wasm15 gynalnaturalgas.hydratorconstructed before 1.11,201500607 Seclionn11.0.40 If dprIoFe, May1, 2o15, are uncontrolled actual emlss0ns from a sl gleglycol natural gas dehydrator equal tour greater man 6t0t dehydrator's tons per year 2tpy VOL If the located wlmin1,320 Nebo, a bungling unit or designated ouctdeact. realReg].setnonxMl.o.abli 5. If constructed on crafter May 1, 2015,araunconcolled actual emIssions frame sin gleglvcol natural gas dehydrator equal t0 orgreater than 2 tpv Voc Ciegaation].section xvlt0.4a? IOeSection xvb,0. 03 Sect. MX eralPI...Ions. Al, Pollution... Equipment and Prevention of Emismons Section%VII.D3 Emisslons Reduction Prev,lons 6. Is thisxlyco, natural Ras dehydrator controlledb0ab =e1te.. notme mime, control devlal Claris notencl0404? Irn n ', Caution 001.9,7,e 5 61400411.024—Pltemaave emissions control equ1pment Disclaimer Cannnission s.Thisdc171008 1.7 note rvkorreg54111n, andtheana7sisit contains maynotapplyfo a particular situation based upon ihe irM0404l0hczs andcaumstances. This document sloes not change a -substitute for anykw, regal.,, or any other kgally binding requirement and /s not legally enforceable. In Ne event of any nom". between are language &this documentalM the languageof the Clean /Wed,. Xs implementing regulation, and Air QuaGy Control Commission mgulalbns the ylellle°,the stamaorregu08onwRIc00011 The use alit 40140abloy language such ae'reconnlend• 04242244010anc Yana is mended le describe APCD inleryrelaaiens and mzmmendatbns Maudateytemvnobgysuoh as 'me and000 Ynaluire0are inlended b describe co ,04148 requirements under,. farms of the Clean AlrAcf and AirQualify Control Commission rcgulab'ons, but In's dceameni does rafesfannsh ingenr binding rcquirerrents mama., go to Me nextpuestIon neutpuestion The unitiss electba compel requirements, 63]65 per63.]64(d1W Source is vmecr. Reg 7, 8240 401 -you have prevlAualy indicaracols Inure MAcrse4a4n ^You have previously Indicated mjs In me beginning of,. MAO" .sectlo n Continue -You have prevbusWIndicated Ws In Ole Rea Suction xndetermmauon Fugitive Emissions Inventory itional RecuI It Conetde all Section 01-Admtnstrattve Information Facility AIRS ID: 323,;" • "+: 1ACB 022 County Plant Point Section 02- Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: mpov tI lee Trtiin$ eRp Igas damp Section 03 - Pmcessine Pate Information for Emissions Estimates ' 71s1 ;ectt n7x not applicable to fugitives. Section 04 -Emissions Factors & Methodologies Regulation 7 Information Operating Hours: ,. Emission Factor Source Control Efficiency Source: Calculations Service Component Type Countsource) Emission Factor (kg/hr- Table2-4 Table2-6 Control (%) Pollutant Mass Fraction uncontrolled Emissions (tpy) Controlled Emissions (toy) Connectors 650 2.00E-04 1.00E-05 0.0% VOC. 0287 0.048351401 0.048355401 Flanges fie 3.90E-04 5.70E-06 0.0% Ben 'p..00050851 = 8.55853E-06 8.55863E-05 Gas Open -Ended Lines Pump Seals 0 - 1 "!.( 2.00E-03 2.40E-03 150E-05 3.50E-04 D.0% 0.0% 'Toluene 5 00 0 38651 „ lethAenze e.0,90p„Q09¢j;'°1 6.49613606 1.68532E-06 6.49813E-05 1.58532E-06 Valves 2(3 ' 450E-03 250E-05 0.0% J(yle 8:00007100 1.1975E-06 1.1976E-05 Other alt 8.80E-03 1.20E-04 0.0% L r' -H O,55$8219X Fy 0.000660729 0.000664729 Relief Valves S ': 8.80E-03 1.20E-04 0.0% 5.2,4TMis ,oib000365 • 6.1627606 6,1627E-08 Connectors ' 750E-06 750E-06 0.0% VOC Flanges `-'.. 3.90E-07 3.90E-07 0.0% Benzene Open -Ended Lines 1.40E-04 7.20E-05 0.0% Toluene 0 Heavy Oil Pump Seals 0.00E400 0.001400 0.0% Ethylbemene 0 ' Valves 8.40E-06 640E-06 0.0% Xylenes Other 3.20E-05 3.20E-05 0.0% n -Hexane E-.5):: �:„. �. '.- Relief Valves -- — — Connectors 1.7966. 2.10E-04 9.70E-05 0.0% VOC "/ 'i T 1.309628167 1.300520167 Flanges ' 1176 1.10E-04 2.40E-05 0.0% Ben :'5,81177079 '- 0.002318699 0.002314899 Open -Ended Lines 0 1.40E-03 1.40E-05 0.0% Toluene 040134449'' 0.001760648 0.001766648 Light Oil Pump Seals 15 1.30E-02 5.10E-04 0.0% Ethylbe 4.29394E -06 4.29392E-05 Valves 2397 2.50E-03OE-03 1.90E-05 0.0% Xylenes 0.Q,040�9t27,9- 0.000egT76 0,00032446949 OA0p324-0d9 Other 72 7.50E-03 1.10E-04 0.0% n -H '0013fi7' „ 0.01790125 0.01790125 Relief Valves 0 7.5-01-03 1.10E-04 0.0% 2,2,4-TMP . 0,20040065 n 0.000167004 0.000167054 Connectors — 1.10E-04 1.00E-05 0.0% VOC Ranges 2.90E-06 2.90E-06 0.0% Benzene 0 Open -Ended Lines 250E-04 350E-06 0.0% Toluene 0 " ' Water/Oil Pump Seals - = 2.40E-05 2.40E-05 0.0% EOhylbenzene 0 Valves 9.80E-05 9.70E-06 0.0% Xyleres 0 Other ,,. 1.40E-02 5.90E-05 0.0% n -Hexane 5 Relief Valves — . — — 60,h0umtyear Section 05- Emissions Inventors Did operator request a buffer! Requested Buffer (%): Pollutant Uncontrolled Emissions Convened Emissions Source VOC 2.04 toy 2.04 toy Screening EFs-EPA-453/R-95-017 Table 2-e Benzene 7.21 lb/yr 7.21 Ib/yr Screening EFs - EPA.453/R-95-017 Table 2-8 Toluene 5.48 lb/yr 5.48 INyr Screening EFs -EPA-053/R-05-017 Table 2-8 Ethylber¢ene 0.131b'yr 0.131Nyr Screening EFs -EPA-453/R-tS-017 Table 2-O Xylenes 1.01 Ib/yr 1.01 IWyr Screening EFs-EPA-053/R-95-017 Tablet -8 n -Henna 55.69 lb/yr 55.591NN Screening EFs-EPA-053R-95-017 Table2-8 2,2,4-7MP 0.52 lb/yr 0.521dyr Screening EFs -EPA-453/R-95-017 Table 2-e Section 06 Re I to Summ Review Regulation 3, Fart B. Section III.D.2 to determine h RACT is required? Review 40 CFR, Pert 60. Subpart KKK to determine If applicable to this source? Review 40 CFR, Part 60, Subpart 0000 to determine it 60.5380 andlcr 50.5385 is applicable? low Section 1MI.F to determine is LDAR is applicable? Regulation 1 Section II.A.1- Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any a4 pollutnrt which is in excess of 20%°molly. This standard h based en 24 consecutive opacity readngs taken at 15 -second intenralsfor sic minutes. The approved reference test method for visible emissions measurement's EPA Method 9 (40 CFR, Part 60, Appendbt A (July,19021) in all subsections of Section II. A and B of this reguktion. Regulation 2 Section LA- No person, wherever located, shall cause or allow the emission of odorous air conbminanb from any single source such as to result In detacthbla odors which are measured la excess of the following limit: For areas used predominantly for residential or commercial purposes it b a v-mletion if odors are detected after the odorous air has been diluted with seven (7) or more volumes of odor freeair. Regulation Part A-APEN Requirements Criteria Pollutants: For criteria pollutant, Air Pollutant Emission Notices are required ton each individual emission point in a nona0a/nment area with uncontrolled actual emissions of one ton per year or more of any ndMclual order's pollutant (pollutants are not summed) for which the area Is non -attainment. Applicant is required to file an APEN since emissions exceed t ton per yearVOC Part B— Construction Permit Exemptions Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 2.0 TPY threshold (Reg. 3, Pad B, Section 1152.5) Is this source located in an ozone non -attainment area or attainment maintenance area? Yes. if yes is this source subject to leak detection and repair (LOAR) requirements per Regulation 7, Section XVI F orXI0.G or 40 CFR. Part 50, Subparts KKK 0000, or 0000a?Yes Part 5,1110.2. RACT requirements for new or modified minor sources This section of Regulation 3 requires RACT for new or modified minor sources located in nonattainment or attatnmentlmainterance areas. This source is located in the 8 -hour ozone nonattainment area. The date of interest for determining whether the source is new or modified is therefore November 20, 2007 (the date of the 8 -hour ozone NA area designation). Since the fugitives will be in service after the date above, this source is considered "newer modified." This facility is subject to Regulation 7 Section XII, WI and MOPS 00005. Fallowing the leak detection and repair programs specified in these regulations satisiffes the RACTreq/iremens of Regulation 3. The permit will contain a condition reflecting this determination. Regulation Is this source at en onshore "natural gas processing plant" as defined in 40 CFR, Part 60.8317 Did this source commences construction, reconstruction, or modfiatbn after January 20, 1984, end on or before August 23,2011? . NIA This source is not subject to NSPS KKK because the facility does not meet the definition of a"natural gas processing plan." Did this source commences construction, reconstruction, or molt/ ation afterAugust 23, 2011 and on or before September 18, 2015? 28.7 0.050801 0.038571 0.000941 0.007108 0.39219 0.003658 Ina 0.177079 0.134440 0.003279 0.024775 1.367 0.012753 TPY 0.00360673 0.0036067 0.00273844 0.0027384 6.6187E -OS 6.619E-05 0.00050464 0.0005046 0.02704297 0.027843 0.00025975 0.0002508 Fugitive Emissions Inventory The engines covered under points 001-004 end OH (compression tram l) commenced construction between August 23, 2011 and September18,2015. These engines drive reciprocating compressors. Based on this Information, the reciprocating compressors are subject to the requirements in NSPS 0000 §60.5365. It should be further notedthat the fugitive requirements' in NSPS 0000 only apply to onshore natural gas processing plants. This facility does not meet the definition of natural gas processing plant and therefore is not subject to the fugitive requirements of NSPS 0000. Regulation 7 Is this source located in an ozone non -attainment area or attainment maintenance area? Is this source at en onshore ntural gas processing plant' as defined in 40CFR, Part 60.031? classified as a natural gas processing plant. Therefore, this source is subject to Regulation Facility. Section ] Section XII.G. Is the facility classified as a well production facility.- natural gas compresses station? Since this facility is classified as a natural gas compressor station, it is subject to Regulation? Section XII.L. and =LP. g rye, N Regulation 8 Is the source at a"natural gas processing plant" as defined In 40 CFR, Part 65.751? Is this facility considered a" major source of HAP as specifically defined in 40 CFR, Part 0.761 for k that arenot prodccton field facilities? If you repond "yes" to both questions above, Earther review h the provisions of 40 CFR, Part 63.769 "Equipment Leak Standards" apply'? Source is not subject to MALT HH because the facility is classified as a synthetic minor source of HAPs. Additionally, this source does not meet the definition of a"natural gas processing plant." NSPS 0000a Did this source commence construction, reconstruction, or modification after September 18, 2015? Is this source at a well she compressor stet on or onshore "natural gas processing plant as defined n 40 CFR Part 60.5430e? This facility meets the definition of a compressor station as defined by 40 CFR Part 60.5430a. Therefore, the fugitive emissions at this facility are subject to NSPS 0000a. See note 6 in section 07 for additional information. 'e Yes es Section 07 - Technical Analysis Notes Z,Addetional Note;: r �Ni V id'J itt . el Theu6C and HAP % -Weight usedtoestifehte'e nsfrmn thee e o obanedfrom a sdespecrfnlet gas enalysietakennroarthe TEA Weber the' r rrcudt fatlity on IIr04/2o16,Te f ch tad rerempv infirm hydroge, rbon doxae, rdl ogen,"enrootargon, and alcebolsTI'x was dor% ih order" ethe entire sample is composed afrryrirenerbenblnsimlar a(iplicntioar,ibeeperator expressed the cdculaton was done h e theernions factors:nthe EPA i protocol for Equipment leek Emb%on EPmatesanefor total Organic compound enrissionbates(see note a under to We 28). This calculation resoltsn a consenrative hsin@te-' Of HOC and HAP weght% calve s h 0',0 on rypically accepts the VOC d HAP values repeated directly on 1,0 sample analysis. As a result, thesevalues were deemed. 2cceptablefor calculation purposes"A ample of, the i (Had ed to determine the VOL eght%i(as fellows." ttishotildb iotn d h f rheinthihyd b bntjancrbrenents exdadinkH -H" Cot, NO, O2[Argon d alcohols) ih 'y l harnple was determined be f»567%. Using this valuenaiong wrrle the VOC (ell cornhonentbxeludingmethane, ethane, Hex o,OO2,N2,O21Argem and alcohols}wereht Ye ofz7.4s% the correOd Vol -(o.ight%-w as dere ed as follows HOC wi%(cacrectedjm27,45/95.67.100-78,69%.This calculation wale(so conducted for the HAPweght%values. ₹, 2.The VOCand HAPweght%values used to nor,maree ro m encfthe lght %pid seroice obtanedfrymh amp site 00 0,1, 01cr gas analysis sample taken from tiniren010 In elan rH Toudn frclijrygn 11/oo/201& in Ills inMereCe.tfirtrtoe,Mice furtheYfcrr'ededthevalues'ro remeYelhethane and ethane: As a result, he operatoc is P;aSSerhing ROI:MO.0e semple0 COtnpoeed ofVOC. Here again,this0ethddologyleads to'0ponoeruatNeestimate of V00 and HAPweght percent values and thereforewas (.,::deemed aceenteble for penaitting'burpeses.01 example ofthe dalculatoo medtrtrteteminellien Hexane weight 'Poises follows: In thisensta dee,0010100M be notedth tthe V00 content ofthe streamihat orreefedto assume 100% lydrocarbcnlg28.c%( Iculatonin' hole I). 000510le vale, I g thth-econected n -v 00010011% of0:39219"ettix ctedroHm n weight%forth" iquidstream wad Tedaefell "n-Hexwt%(corrected) 0.39219/28.695000 1.367Y,This calculation evae else.cooducted f01the omen ng MAR weight %values: . " H3 Sncetheemse sfromthrspdint aced using an ertended gas seemeMehalsisrnoretban one year old and hevnequipment willbe-addedt tletaclty,ini(ial %C%rnolnancetsang will require tfzt'a rtespec fnextended gas/vaporsample he obtained to denhonstratenompliancewnh the em son Ism-ticonta dh OM permit An ', atended hqurdan less wll'not be re used as partbfthe initial compliance because thebneranor lg assumng100%v0Crn light cqudstream, which is the most `- 4: eased do the epelicetion,shMhomponent cants 0b 3arn? con, actual cohnt of existiogegipment(conducteden OR)P/2018j and an estmate of new components that 'uullba added as resole,ofthenewcompeszonfrainThe estimates basd on an actual count conducted eta smleriacfty-Since a portion ofthe co poneniceunt is l-mitimated, the tierenit willcOntain en initiarcomPlianeeteit requrringthat " actualhardtnunt of components be completed upon commencement of p ra not thenew' a b,5..The emissionoal Ikons frttithis point include a 50% buffer to account f'hltorechenges in equipment and gas cemposhion. The use of this beffe< is acceptablefor pe 'Itingsin et he'estirnatdifPee t may be na to base don theffn01 st Uionoftheiaolity.- - ' Accnrdngto NSPSOc00a§60.53 5 'Youenesulel cttp ineeppiNable"provisiotisafrhusubpart dycu arethe oeinefier operatotiofoneormere f theens hore affected'- facit'res'Mee inp ragraphs ja)through Hj f he eaction fee whch you manininciconqreeetionemedificationeor recOnsiructiort after September 18, 2615." This facility is • listed under §60.5365a(jjwli Hh includes The collection of fugtve erelesibn,s components at icompresSorstatimMiesdefined,M5605430", is en affected ffocility."This section is goes oq to further state that For purposes of§60.5397a modification Pipressor tation occuMwhem(lhAn-i'ddRianalc p installed ompres sttion." Aspart of this modification, ttie operator Needing a new compression turbneto thelecilityfor the neuvcompresson tranAu a result.ihefacirtys rnnsdered 'eSmodified for thepurposes of, §605397 8 ed onthis,alitheequipmentaiOis Reality issubjeo to thefug0ive reghiremenis frtedn§6053975.;;' ',SA: The leak donention and repair progiam for natural gax 'compeemor,Stations rs detalnd peReguletion 7Secten XVIIF Regblalol.7 he unuNLF:3,d. totes For Purposes of - eeSedt on XVll.F3., fugitive emssions0, et be calci4ared0 h onP ofTable 2-4ofthe 1995 EPA Prertoc lfct Equpment Leak Emsfon Eel e3-(Oodu t mene 3 EPA-0s3(RoS'017j or other Orvs On apprcoed method U gTable2-0wrth th gceold50%buffer, ftlg6 VOC l,nsipns calculated at 059 tpy- Usng MN -" formatrpnalongwhcb hnable3n Secton XVllF3. It wasdeterminedthempeonfrequencyforth. facvmtyismcihly ' `-8, 6ncethiefa`cibty siocated intbe&h r00One ContrlA a (01aenomettainMeni 00001,areab,Ibis,HHijacbbaina,i6pIrdebncriari end repair program detailed In Regulation? 5ectranjtlldeIhepermit will contain a son,drtion referencing the requrmenoe the seetioo of the regulation;., -• -- - 9. Acou1dingto tit PPnrat on,thee g m eredunder,poiM5001-004 and 009 drive recipr c i gco prey. rs These engines/comer svrsvom cod construction betvyeeh August232011and5epiernbr to, 2015'-and'ir enor loon madf • d or reconnVURd cetheirrorsh run.Additionally, 110compressor., - .orated betwee • the wellhead and point of 'nested,' tie f the netoralg iansmbsiort and is a0es00met As a 001/h, rhos p s subject to the requirements1,0ede NSPsn ,6000 060.%485, It shpufdeefunher noted thattltecedpocatdghlnpresorsertsubjectll the requremenist Colorado Regulation7 Seale n X114,25'ee the 10pocoting, pessorcomponent counts are accounted for in thefg v-othon"oenegory,"the nopb0000and Regulation 7$0011n XIIJ.0. (Hoe frementsfer reciprocating 00. According to the application, the new cornDreaeihnt bn drives a centrifugal compressiersSInM this turbine libe,c rted after 09/18/1015, the cen'rfugal Rompressom is potentially art'apecredf dryunden5010 V000 However, the peretoPladiestedth"e centrifiegM Compeassorwilluse dry seals. NSPS 0000a only ldentrhes .Eathcentrfugaldompreseor afigctedfaclty, which iS erS%centr'dugalw peilobcsmgwtealsa naffe d tit ny a tuer 4605865a(u). gncetn(e ePann%nel cornpres'sorusesHrysears,¢ is not an affected facility underu5P50000a. it should be furtheM 0tedthat the requirements nColorado Regulation 7 Sechbn 1111.10.0lso only app,,,to eentrrfuga pressors with wet seals. As .. result, the centrfu€e( CreopressOcet,t4si )Ityu not subjecttuMe requirements ofnegulalon '.10. Theoperator w0s provided with a draft permit and ',PENmp'ne re p.orto:publlc mene The op expressedtheyagreed with theredines and provided one ft ent0nihe draft comment and response provded Perkin,1 follows. (?)Coin ti condition 33 gitfvesat Tree& anesuoject tusubpalto000z requirements, rather than 0000requ;remettsThs'shased on the prevous 2016 modification witch the 5N^ cimpresSoi was added tothe facility.(')Rsponee.eased on' ethe infOrrnatiomProvided in the apolkation, the" reciprocating compressors at this-facilitycori ednonsemerip po 00/16/,e5 and nave not been modified or Meonstniced,sincethat date Ths'a supported by the commenceconstruction date of02/11/20151istedonthodphhlor point 009 Whla the reciprocating tompress0rsare :grpod with the fugitives for per dngp'uip0s.,fire and re separa a0 nshore00led fabihties within NSPS 0000/o000a. eased on the cornmence onsiructon datede the reqprocating compressors, they are subject t0 NSPS 0060, Ho' e ey the fugitive emissiomare,sul,jectn Ihe'requi mentsS in NSPS 0000e based on the ridition of the newcampr sor gncn Colorado has not adopted NSPS 0000a, the rehhirementscot d the notes. permit holderas condition 9 NSPS 0000a I lired lyf d let dad !Hied as,RACT„foithebagrtives in 25 Finally,NonditiOnS3ulodel The reciprocatingg compressars grouped N the Hrgitinb eraissions addressed byvllS IN 010012Nare,subjecto NSPS OCC,O, This condition waswritten n this ma finer to further clarify that lyhe recitirecating compressors tireS'hbject to NSPS 0600whllethefugitive ereiseioNs aNMeublect•th NSPS 0600a. The Operattir qreviewed therespoaseand expressed they agreed whhthe way the - , t is rm n written In the pch.The p ""pressed they had oo Father comment?, , - Sec0On 05 - Inventory SCC Coding and Emissions Factors AIRS Paint if 012 Process SCC Cod 01 Uncontrolled Pollutant Emissions Factor Control% Source Varies by Varies by VOC c emponenitype component type Screening EFs-EPA-453/8-95-017Table2-8 Varies by Varies by Benzene component type component type Screening EFs-EPA-4530-95-017 Table 2-8 Varies by Varies by Toluene component type component tme Screening hFs-Era-4s3/n-95-012 Table2-8 Varies by Varies by Ethylbenzene component type component type Screening EFs-EPA-458/1.95.O17 Table 2-8 Varies by Varies by Xylene component type component type Screening EFs-EPA-453/8-95-017 Table 2-8 Varies ley Varies by n -Hexane component type component type Screening EFs - EPA -453/8-95-017 Table 2-8 Velem try Varies by 224 TMP component type cnmponerh type Screening EFs-EPA-453/8-95-017 Table 2-8 Hydrocarbon Loadout Emissions Inventory Section al -Administrative Information Facility AIRS ID: 123 County 9AC8 Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Is this loadout controlled? essurized loadout of condensate from a pressurized bullet tanks td pros ource are not controlled. Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Truck Loadout Capacity Condensate Production Loadouts/month Loadouts/year Secondary Emissions - Combustion Device(s) gallons/load 2 377n009? gallons/month 622,823.71 bbl/year 311.01 loadout/month 3,732 14 loadout/year Section 04 - Emissions Factors & Methodologies Loadout Hose Parameters Liquid Hose Diameter 66666667 feet Vapor Hose Diameter : 0.166666067 feet Liquid Hose Length* `�-f:.'.d feet Vapor Hose Lenth* feet Liquid Hose Volume 0.021816616 cubic feet Vapor Hose Volume 0.021816616 cubic feet Tank and Truck Pressure Tank and truck pressure :-_'..?:.97 psig 109.2 psia iced tank trucks. 0.00 MMBTU per year MMBTU per year MMBTU per year Notes: *Length accountsfor length of isolation valve on pressurized hose. ) There are two hoses connected to each truck during loadout. PV=nRT. Where: P = pressure in hose at time of disconnect =storage tank pressure (psia) V= volume of hoses (cubic feet) n =number of lb -moles of product in hoses R = Universal gas constant =10.73 ft^3 * psi / Ibmole / degR T =average loadout temperature = 60 °F = 519.67R Vapor Density n 0.000427251 Ibmol n/V 0.019583724 Ibmol/ft^3 MW 1f.49 lb/Ibmol Vapor Density 2.281387958 Ib/ft^3 Liquid Density SG 0.7396 Density of Water - 6.33 lb/gallon Liquid Density 6.160868 lb/gallon 46.08329264 Ib/ft^3 I Notes: 1. All liquid lines contain liquid products at individual specific gravity. 2. All vapor return lines contain products that behave as ideal gases at 607 and storage tank pressure. • VOC Emissions: Vapor Emissions 185.75 lb/year 0.09 tpy Liquid Emissions 3,752.23 lb/year 1.88 tpy Total Emissions 1.96899 tpy Component Mass Fraction Source Benzene Representative5ample (See Section 08 for notes) Representative5ample (See Section Rotor notes) Representative -Sample (See Section 08 Oar notes) Representative Sample (See Sectmn` OS For notes) ;. Representative Sample (See Section 08 for notes) Representative Sample (See Section. OS far notes) Toluene 0-02 Ethylbenzene c2.770 -03;a. Xylene 1.74E-02 n -Hexane 6.60E-02 224 TMP 5.77E-03 19 of 22 K:\PA\2013\13WE1108.CP4 Hydrocarbon Loadout Emissions Inventory Pollutant ®' MNI2=11!MMEE3KIM 6.96E-02 Hydrocarbon Loadout Uncontrolled Controlled (lb/loadout event) (lb/loadout event) (Volume Loaded) 1.05,52E+00 (Volume Loaded) 1.06E+00 9.01E-03 Pollutant 6.09E-03 6.09E-0 Control Device Uncontrolled (Ib/MMBtu) Uncontrolled (lb/bbl) (Volume Loaded) 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 (waste heat combusted) Section 05 - Emissions Inventory Emission Factor Source Emission Factor Source Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) PM10 . PM2.5 SOx NOx VOC CO 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 D.00 0.00 0.00 0.00 0.00 D.00 0.00 0,00 0.00 0.00 0.00 0.00 1.97 1.97 1.97 1.97 1.97 0.00 0.00 0.00 0.00 0.00 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled fibs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (Ito/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 33.61 33.61 33.61 33.61 33.61 91.64 91.64 91.64 91.64 91.64 10.90 10.90 10.90 10.90 10.90 68.52 68.52 68,52 68.52 68.52 259.71 259.71 259.71 259.71 259.71 22.71 22.71 22.71 22.71 22.71 Section 06- Regulatory Summary Analysis • Regulation 3, Parts A, B Source requires a permit RACT- Regulation 3, Part B, Section III.D.2.a (See regulatory applicability worksheet for detailed analysis) The loadout operation must satisfy RACT. Section 07 - Initial and Periodic Sampling and Testing Requirements You have indicated above the source is not controlled. The following question does not require an ans Section 08 - Technical Analysis Notes 1. Based on the information provided in the application, emissions only ocarfrom apressurized loadout operation when the hoses used to transfer fluids -are disconnected and exposed to the atmosphere. In order to : ' calculate emissions, the operator has assumed both the liquid hose and vapor return hose are completely filled with emissions at the time of disconnection and the entirety of these emissionsare vented to the € atmosphere. As such, the volume of each hose was calculated and: used in the emission estimate. Further, the calculation assum es all the liquid in the liquid hose isconverted toe gas and vented to the atmosphere. It is t also assumed that the liquid'. and vapor are 100% VOC.These two assumptions likely result in a conservative estimate of ernissi ons. 3. Themolecular weight of the gas, density of the liquid and mass fractions of HAPs used to estimate the HAP emissions were obtained from a representative sample taken from the SLW Compressor Station on .09/24/2014. While the sample is not site specific and more than one year old, it was determined an initial compliance test re quiring a site -specific sample he obtained was not required forthe following reasons: (I) As discussed in 41 above, the operator assumed both the liquid and vapor hoses are completely filled with liquid/gas at t he time of disconnection and the entirety of these emissions are vented to the atmosphere. According to the operator, this is a conservative estimate of emissions since any remaining liquid in the liquid hose is routed back to a storage vessel and not he allowed to evaporate. (ii) Also discussed above, the operator assumes the liquidand. vapor are 100% VOC.This is themost conservative estimate for ',./(1)C content. (iii) In most cases oil will have a specific gravity less than that efwater. .As a result, the mostconservative estimate of specific gravity for o -I 31 ( e water has a specific gravity of 1) Using this value results in total !: overall VOC emissions of 2.63 tpy. This is the most conservative estimate for theliquid portion of emissions and does not re suit in, change a-Ity status or addtional'requirements for the.loadout operaton. rce would not have significant impact on the permit of 4. This is a new source (came into service after 11/20/07) located in the ozone non-attammentarea. Asa result, this source i5 su bject to RACT. Based on information provided, the Ioadout operation transfers fluid from pressurized storage vessels to pressurized tank trucks. As the loadout operation is conducted, the vapors displaced from the pressor zed trucks are routed bookie the pressurized storage vessels. As a result, emissions only occur when the Squid and vapor hoses are disconnected after completion of the loadout operation. Based on this inform. ion, the operator is using vapor balance with pressurized vessels, This method of j operations satisfies RACT. 5. The operator was provided with a draft permit to review 20 of 22 K:\PA\2013\13WE1108.CP4 Hydrocarbon Loadout Emissions Inventory Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point It 013 Process It 01 SCC Code Uncontrolled Emissions Pollutant Factor . Control % Units PM10 0.00E+00 0 . 10/1,000 gallons transferred PM2.5 0.00E+00 0 lb/1,000 gallons transferred SOx 0.00E+00 0 10/1,000 gallons transferred NOx 0.00E+00 0 lb/1,000 gallons transferred VOC 1.51E-01 0 lb/1,000 gallons transferred CO 0.00E+00 0 lb/1,000 gallons transferred Benzene 1.29E-03 0 lb/1,000 gallons transferred Toluene 3.51E-03 0 lb/1,000 gallons transferred Ethylbenzene 4.17E-04 0 lb/1,000 gallons transferred Xylene 2.62E-03 0 lb/1,000 gallons transferred n -Hexane 9.94E-03 0 lb/1,000 gallons transferred 224 TMP 8.69E-04 0 lb/1,000 gallons transferred 21 of 22 K:\PA\2013\13WEll08.CP4 Hydrocarbon Loadout Regulatory Analysis Worksheet Colorado Re ulation 3 Parts A and B - APEN and Permit Requirements ISource 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. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 11.5.1.1)? 3. Is the loadout operation loading less than 10,000 gallons (238 BBts) 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.8.3)? 'Not enough information NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 11.8.1.1)? 3. Is the loadout operation loading less than 10,000 gallons (238 BB{s) 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 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section II.D.2)? 'Source requires a permit 7. RACT - Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section III.D.2.a)? The loadout operation must satisfy RACY. Disclaimer This document assists operators with determining opposability 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" 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. NA NA Yes Go to next question. Go to question 6 The loadout requires a permit 'NOLOIN The loadout operation must satisfy RACT. Permit number: Date issued: Issued to: of Division h 8 Environment CONSTRUCTION PERMIT 13WE1108 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 4 DCP Operating Company, LP Troudt Compressor Station 123/9ACB SENW SEC 27 T6N R66W Weld County Natural Gas Compressor Station Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description C-306 001 One (1) Waukesha, Model L7044G51, Serial Number 5283704055, natural gas -fired, turbo- charged, 4SRB reciprocating internal combustion engine, site rated at 1680 horsepower at 1200 RPM. This emission unit is used for natural gas compression. Non -selective catalytic reduction (NSCR) system and air -fuel ratio control C-307 002 One (1) Waukesha, Model L7044GSI, Serial Number 5283704066, natural gas -fired, turbo- charged, 4SRB reciprocating internal combustion engine, site rated at 1680 horsepower at 1200 RPM. This emission unit is used for natural gas compression. Non -selective catalytic reduction (NSCR) system and air -fuel ratio control C-308 003 One (1) Waukesha, Model L7044GSI, Serial Number 5283704049, natural gas -fired, turbo- charged, 4SRB reciprocating internal combustion engine, site rated at 1680 horsepower at 1200 RPM. This emission unit is used for natural gas compression. Non -selective catalytic reduction (NSCR) system and air -fuel ratio control C-309 004 One (1) Waukesha, Model L7044GSI, Serial Number 5283704080, natural gas -fired, turbo- charged, 4SRB reciprocating internal combustion Non -selective catalytic reduction (NSCR) CDPHE E COLORADO Air Pollution Control Division I Department of Public Hearth Er Environment Page 1 of 58 engine si rated x,80 horspower at 1200 RPM. issio m is use •°l or natural gas com. -ssio system and air -fuel ratio control D-1 006 One (1) Triethylene glycol (TEG) natural gas dehydration unit (Make: Cameron, Model: 208, Serial Number: NI120297190) with a design capacity of 64 MMscf per day. This emissions unit is equipped with two (2) (Make: FMC, Model: M06 Plunger Pumps) electric driven glycol pumps each with a design capacity of 18 gallons per minute. Only one glycol pump will be operated at any given time. The second glycol pump serves as a back-up only. This dehydration unit is equipped with a still vent, flash tank, and reboiler burner. Emissions from the still vent are routed to an air-cooled condenser, and then to the enclosed combustor. Emissions from the flash tank are routed directly to a vapor recovery unit (VRU) that recycles emissions back to the compressor station inlet. During VRU downtime, flash tank emissions are routed to the enclosed combustor. The VRU has a maximum of 5% annual downtime. C-311 009 One (1) Waukesha Model: L7044 GSI SN: 5283704513 natural gas fired, turbocharged, 4SRB reciprocating internal combustion engine, site rated at 1,680 HP. This emission unit is used for natural gas compression. Non selective catalytic reduction (NSCR) system and air -fuel ratio control TURB-1 010 One (1) Solar Taurus 70-108025, Serial Number: TBD, natural gas fired turbine rated at 69.83 MMBtu/hr (LHV) heat input at 40°F ambient temperature and 9,439 horsepower at 11,763 RPM. This turbine is used for natural gas compression. This source is equipped with SoLoNOx technology for minizing emissions of Nitrogen Oxides. None D-2 011 One (1) Triethylene glycol (TEG) natural gas dehydration unit (Make: TBD, Model: TBD, Serial Number: TBD) with a design capacity of 88 MMscf per day. This emissions unit is equipped with two (2) (Make: TBD, Model: TBD) electric driven glycol pumps each with a design capacity of 30 gallons per minute. Only one glycol pump will be operated at any given time. The second glycol pump serves as a back-up only. This dehydration unit is equipped with a still vent, flash tank, and reboiler burner. Emissions from the still vent are routed to an air-cooled condenser, and then to the enclosed combustor. Emissions from the flash tank are routed directly to a vapor recovery unit (VRU) that recycles emissions back to the compressor station inlet. During VRU downtime, flash tank emissions are routed to the enclosed combustor. The VRU has COLORADO Air Pollution Control Division Department °f Public. Health & Environment Page 2 of 58 a maximum of 5% annual downtime. e e '•n u ponent .s from a natura gas compressor station. None L-1 013 Loadout of condensate from pressurized storage vessels to pressurized tank trucks using vapor balance. None Points 001-004 &e 009: These engines may be replaced with another engine in accordance with the temporary engine replacement provision or with another Waukesha L7044GS1 engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. Point 006 ft 011: The glycol pump may be replaced with another pump of the same design capacity in accordance with the provisions of the Alternate Operating Scenario (AOS) included in this permit. Point 010: This turbine may be replaced with another Solar Taurus 70-10802S turbine rated at 9,439 HP in accordance with the temporary turbine replacement provision or with another Solar Taurus 70-10802S turbine rated at 9,439 HP in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment B. 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. Points 010-013: YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air- permitting-notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self- certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) COLORADO Air Pollution Control Division Department of Public Health Er Dwirompertt Page 3 of 58 5. a•oint ': .wing l ration �be pro _led to the Division within fifteen (15) days of e of this permit. • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Regulation Number 3, Part B, III.E.) 6. Point 011: 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. (Regulation Number 3, Part B, III.E.) 7. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 8. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Monthly Limits: Facility Equipment lD AIRS Point Process Pounds per Month Emission yP Type PM2.5 PM10 NO,� VOC CO TURB-1 010 01 344 344 3,125 119 3,159 Point D-2 011 01 --- --- 420 3,680 1,915 Point FUG 012 01 --- --- --- 357 --- Fugitive L-1 013 01 --- --- --- 340 --- Point Note: • Monthly limits are based on a 31 -day month. • For Point 010 the following process designation applies: o (01) Steady-state turbine emissions The owner or operator shalt calculate monthly emissions based on the calendar month. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 1,359 pounds per month. Facility -wide emissions of total hazardous air pollutants shall not exceed 3,398 pounds per month. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Annual Limits: COLORADO Air Pollution Control Division Department of Pubic Health & Enrronrnent Page 4 of 58 ` Equi e I i � AIRS • ` Pr• s Tons per Year Emission Type PM PM10 NO. VOC CO C-30 ` - 1 1.2 8.1 11.4 16.2 Point C-307 002 01 1.2 1.2 8.1 11.4 16.2 Point C-308 003 01 1.2 1.2 8.1 11.4 16.2 Point C-309 004 01 1.2 1.2 8.1 11.4 16.2 Point D-1 006 01 --- --- 2.3 14.9 10.4 Point C-311 009 01 1.2 1.2 8.2 11.4 16.3 Point TURB-1 010 01 2.1 2.1 18.4 0.7 18.6 Point 02 --- --- 0.1 0.5 2.2 03 --- --- 0.1 0.2 1.5 D-2 011 01 --- --- 2.5 21.7 11.3 Point FUG 012 01 --- --- --- 2.1 --- Fugitive L-1 013 01 --- --- --- 2.0 --- Point Note: • See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. • For Point 010 the following process designations apply: o (01) Steady-state Turbine Emissions o (02) Start-up Turbine Emissions o (03) Shutdown Turbine Emissions Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Points 010-013: During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits, for criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. CDPHE COLORADO Air Pollution Control Division Department cH Pubic Health 8 Environment Page 5 of 58 9. 'oint �1 ��iRi ompli ith t isslon _ its in this permit shall be demonstrated by r on a monthly basis using the most recent is a nal values, including: dry gas throughput of the tor), lean , col recirculation rate, vapor recovery unit down inine, con.enser ou e emperature, as tank temperature and pressure, wet gas inlet temperature, and wet gas inlet pressure. Recorded operational values, except for dry gas throughput and VRU downtime, shall be averaged on a monthly basis for input into the model and be provided to the Division upon request. 10. Point 006 Et 011: On a weekly basis, the owner or operator shall monitor and record operational values including: flash tank temperature and pressure, wet gas inlet temperature and pressure and condenser outlet temperature. These records shall be maintained for a period of five years. 11. Point 012: The owner or operator shall calculate actual emissions from this emissions point based on representative component counts for the facility with the most recent extended gas analysis, as required in the Compliance Testing and Sampling section of this permit. The operator shall maintain records of the results of component counts and sampling events used to calculate actual emissions and the dates that these counts and events were completed. These records shall be provided to the Division upon request. 12. The owner or operator shall operate and maintain the emission points in the table below with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. The owner or operator shall operate this dehydration unit so as to prevent any emissions directly to the atmosphere. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled C-306 001 Non -selective catalytic reduction (NSCR) system and air -fuel ratio control NOx, VOC, CO and HAP C-307 002 Non -selective catalytic reduction (NSCR) system and air -fuel ratio control NOx, VOC, CO and HAP C-308 003 Non -selective catalytic reduction (NSCR) system and air -fuel ratio control NOx, VOC, CO and HAP C-309 004 Non -selective catalytic reduction (NSCR) system and air -fuel ratio control NOx, VOC, CO and HAP D-1 006 Still Vent: Enclosed Combustor VOC and HAP Flash Tank: Enclosed Combustor (during VRU downtime - up to 5% downtime annually) C-311 009 Non -selective catalytic reduction (NSCR) system and air -fuel ratio control NOx, VOc, CO and HAP D-2 011 Still Vent: Enclosed Combustor VOC and HAP Flash Tank: Enclosed Combustor (during VRU downtime - up to 5% downtime annually) 13. The owner or operator shall operate and maintain the emission points in the table below as a closed loop system and shall recycle 100% of emissions as described in the table below. (Regulation Number 3, Part B, Section III.E.) COLORADO Air Pollution Control Division I Public Health & Environment Page 6 of 58 D-2 011 ycling Description Pollutants Recovered Flash Tank: Recycled to Plant Inlet with a VRU (except during VRU downtime - up to 5% downtime annually) Flash Tank: Recycled to Plant Inlet with a VRU (except during VRU downtime - up to 5% downtime annually) VOC and HAP VOC and HAP PROCESS LIMITATIONS AND RECORDS 14. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4.) ) Process Limits Facility Equipment ID AIRS Point Process Process Parameter Annual Limit Monthly Limit (31 days) C-306 001 01 Consumption of natural gas as fuel 115.91 MMSCF --- C-307 002 01 Consumption of natural gas as fuel 115.91 MMSCF --- C-308 003 01 Consumption of natural gas as fuel 115.91 MMSCF --- C-309 004 01 Consumption of natural gas as fuel 115.91 MMSCF --- D-1 006 01 Total Dry Gas Throughput 23,360 MMSCF --- 02 Flash tank waste gas routed to and combusted by the ECD 0.6 MMSCF --- 03 Still vent waste gas routed to and combusted by the ECD 7.0 MMSCF --- 04 Combustion of assist gas and pilot fuel by the enclosed combustor 47.8 MMSCF --- C-311 009 01 Consumption of natural gas as fuel 128.8 MMSCF --- TURB-1 010 01 Consumption of natural gas as fuel 673.6 MMSCF 57.21 MMSCF 02 Ten minute turbine start-up event 48 --- 03 Ten minute turbine shutdown event 48 --- D-2 011 01 Total Dry Gas Throughput 32,120 MMSCF 2,728 MMSCF 02 Flash tank waste gas routed to and 0.9 MMSCF --- COLORADO Air Pollution Control Division Page 7 of 58 04 mbust 9 by the E Still vent aste gas route • =•and combus e• .y the ECD 10.52 MMSCF 0.89 MMSCF Combustion of assist gas and pilot fuel by the enclosed combustor 47.8 MMSCF 4.06 MMSCF L-1 013 01 Pressurized loadout events 3,733 loadouts 317 loadouts The owner or operator shall monitor monthly process rates based on the calendar month. Points 010-013: 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. 15. Points 001-004 Ft 009: The owner or operator shall continuously monitor and record the volumetric flow rate of natural gas combusted as fuel for each engine using an operational continuous flow meter at the inlet of each engine. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. 16. Point 006 & 011: The volume of dry gas throughput shall be measured by gas meter at the outlet of the dehydrator. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. 17. Point 006: This unit shall be limited to the maximum lean glycol circulation rate of 18 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. (Regulation Number 3, Part B, Section II.A.4) 18. Points 006 Et 011: The owner or operator shall monitor and record flash tank vapor recovery unit (VRU) downtime on a daily basis. Flash tank VRU downtime shall be defined as times when the waste gas vented from the dehydrator flash tank is routed to the enclosed combustor rather than the VRU. The total hours of flash tank VRU downtime, total flash tank waste gas volume, and total volume of flash tank waste gas routed to the ECD shall be recorded on a monthly basis. The owner or operator shall use monthly VRU downtime records, monthly gas volume records and the calculation methods established in the Notes to Permit Holder to demonstrate compliance with the process and emission limits specified in this permit. 19. Point 010: The owner or operator shall continuously monitor and record the volumetric flow rate of natural gas combusted as fuel for the turbine using an operational continuous flow meter at the inlet of the turbine. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. COLORADO Air Pollution Control Division Department of Public. Health e Environment Page 8 of 58 20. onths' dat all and r _. rde based on t or operator s a l us- rion hly recors o demons ra calculate emissions as described in this permit. r shall monitor and record the total number of each month, the total number of startup hall be calculated, and a new twelve month revious twelve months' data. The owner e compliance with the process limits and to 21. Point 011: This unit shall be limited to the maximum lean glycol circulation rate of 30 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 (LLpt) provisions under MACT HH. (Regulation Number 3, Part B, Section II.A.4) STATE AND FEDERAL REGULATORY REQUIREMENTS 22. Points 001-004, 006, 009-011 Et 013: The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 23. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 24. Points 001-004, 009, 010 Et 012-013: Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.1. & II.A.1.4.) 25. Points 001-004, 006 Et 009-013: These sources are located in the ozone non -attainment or attainment -maintenance area and are subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, Section III.D.2.a. The following requirements were determined to be RACT for these sources: Facility Equipment ID AIRS Point RACT Pollutants C-306 001 Non -selective catalytic reduction (NSCR) system and air -fuel ratio control NOx, VOC C-307 002 Non -selective catalytic reduction (NSCR) system and air -fuel ratio control NOx, VOC C-308 003 Non -selective catalytic reduction (NSCR) system and air -fuel ratio control NOx, VOC C-309 004 Non -selective catalytic reduction (NSCR) system and air -fuel ratio control NOx, VOC D-1 006 Still Vent: Enclosed Combustor VOC Flash Tank: Recycled to plant inlet via VRU. Routed to enclosed combustor during 5% VRU downtime. C-311 009 Non -selective catalytic reduction (NSCR) system and air -fuel ratio control NOx, VOC TURB-1 010 Natural gas as fuel, low NOx burners, good combustion practices NOx, VOC D-2 011 Still Vent: Enclosed Combustor VOC COLORADO Air Pollution Control. Division Department of Public Health L Envirorgnerq Page 9 of 58 FUG 012 led to plant inlet via nclosed combustor RU downtime. rovid olorado Regulation 7 Sections XII it XVII and 40 CFR Part 60 Subpart 0000a V0C L-1 013 Condensate loading to tank trucks shall be conducted by loading from pressurized storage vessels to pressurized tank trucks using a vapor balance system. V0C Waukesha Engines (Points 001-004 Et 009) 26. Points 001-004 Et 009: This equipment is subject to the control requirements for stationary and portable engines in the 8 -hour ozone control area under Regulation Number 7, Section XVI.B.1. For rich burn reciprocating internal combustion engines, a non -selective catalyst reduction system and an air fuel controller shall be required. TEG Dehydration Units (Points 006 Et 011) 27. Points 006 Et 011: 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. (Regulation Number 1, Section II.A.5.) 28. Points 006 Et 011: This source is subject to Regulation Number 7, Section XII.H. The operator shall comply with all applicable requirements of Section XII and, specifically, shall: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for glycol natural gas dehydrators; and • Ensure uncontrolled actual emissions of volatile organic compounds from the still vent and vent from any gas -condensate -glycol (GCG) separator (flash separator or flash tank), if present, shall be reduced by at least 90 percent on a rolling twelve-month basis through the use of a condenser or air pollution control equipment. (Regulation Number 7, Section XII.H.1.) 29. Points 006 a 01l: 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 including, but not limited to the following: (Regulation Number 8, Part E, Subpart A and HH) MACT HH Applicable Requirements Area Source Within UA/UC boundary §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. §63.762 - Affirmative defense for violations §63.762(a) - The provisions set forth in this subpart shall apply at all times. COLORADO Air Pollution Control Division Depa, men1 nt Pui[ c Health 5 En:^rrnmem Page 10 of 58 of a 'ssion n duri malf fi ti §63.764 - General Standards 64(a Tabl of this su art specifies the provisions of subpart A eral Pr isio of this par . hat apply and those that do not apply to san...- :' : of affe - ources subjectto this subpart. §63.764(b) - All reports required under this subpart shall be sent to the Administrator at the appropriate address listed in §63.13. Reports may be submitted on electronic media. §63.764(d)(1) - Each owner or operator of an area source located within an UA plus offset and UC boundary shall comply with the requirements specified in paragraphs (d)(1)(i) through (iii) of this section. §63.764(d)(1)(i) - The owner or operator shall comply with the control requirements for glycol dehydration unit process vents specified in §63.765; §63.764(d)(1)(ii) - The owner or operator shall comply with the monitoring requirements specified in §63.773; and §63.764(d)(1)(iii) - The owner or operator shall comply with the recordkeeping and reporting requirements specified in §563.774 and 63.775. §63.764(i) - In all cases where the provisions of this subpart require an owner or operator to repair leaks by a specified time after the leak is detected, it is a violation of this standard to fail to take action to repair the leak(s) within the specified time. If action is taken to repair the leak(s) within the specified time, failure of that action to successfully repair the leak(s) is not a violation of this standard. However, if the repairs are unsuccessful, a leak is detected and the owner or operator shall take further action as required by the applicable provisions of this subpart. §63.764(j) - At all times the owner or operator must operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. 563.765(b)(1) - For each glycol dehydration unit process vent, the owner or operator shall control air emissions by either paragraph (b)(1)(i), (ii), or (iii) of this section. §63.765 - Glycol Dehydration Unit Process Vent Standards §63.765(b)(1)(i) - The owner or operator of a large glycol dehydration unit, as defined in §63.761, shall connect the process vent to a control device or a combination of control devices through a closed -vent system. The closed - vent system shall be designed and operated in accordance with the requirements of §63.771(c). The control device(s) shall be designed and operated in accordance with the requirements of §63.771(d). 563.765(b)(2) - One or more safety devices that vent directly to the atmosphere may be used on the air emission control equipment installed to comply with §63.765(b)(1). COLORADO Air Pollution Control Division I Peparmen[ of Ribiic Hea?!h 5 Em. *onrrn.*.nr Page 11 of 58 $63.771 - Control Equipment Requirements ed-ve ystem shall route all gases, vapors, and mater: in an emissions unit to a control device rements s• cified in paragraph (d) of this section. 1(' losed-v tern shall be designed and operated with no detectable emissions. 563.771(c)(3) - If the closed -vent system contains one or more bypass devices that could be used to divert all or a portion of the gases, vapors, or fumes from entering the control device, the owner or operator shall meet the requirements specified in paragraphs (c)(3)(i) and (c)(3)(ii) of this section. $63.771(c)(3)(i) - For each bypass device, except as provided for in paragraph (c)(3)(ii) of this section, the owner or operator shall either: §63.771(c)(3)(i)(A) - At the inlet to the bypass device that could divert the stream away from the control device to the atmosphere, properly install, calibrate, maintain, and operate a flow indicator that is capable of taking periodic readings and sounding an alarm when the bypass device is open such that the stream is being, or could be, diverted away from the control device to the atmosphere; or §63.771(c)(3)(i)(B) - Secure the bypass device valve installed at the inlet to the bypass device in the non -diverting position using a car -seal or a lock - and -key type configuration. §63.771(d) - Control device requirements for sources except small glycol dehydration units. §63.771(d)(1) - The control device used to reduce HAP emissions in accordance with the standards of this subpart shall be one of the control devices specified in paragraphs (d)(1)(i) through (iii) of this section. $63.771(d)(1)(i) - An enclosed combustion device (e.g., thermal vapor incinerator, catalytic vapor incinerator, boiler, or process heater) that is designed and operated in accordance with one of the following performance requirements: §63.771(d)(1)(i)(A) - Reduces the mass content of either T0C or total HAP in the gases vented to the device by 95.0 percent by weight or greater as determined in accordance with the requirements of 563.772(e) $63.771(d)(3) - The owner or operator shall demonstrate that a control device achieves the performance requirements of paragraph (d)(1) of this section as specified in §63.772(e). $63.771(d)(4) - The owner or operator shall operate each control device in accordance with the requirements specified in paragraphs (d)(4)(i) and (ii) of this section. $63.771(d)(4)(i) - Each control device used to comply with this subpart shall be operating at all times when gases, vapors, and fumes are vented from the HAP emissions unit or units through the closed -vent system to the control device, as required under §63.765, §63.766, and §63.769. An owner or operator may vent more than one unit to a control device used to comply with this subpart. COLORADO Air Pollution Control Division Department of Public Health S Environment Page 12 of 58 §63.772 - Test Methods, Compliance Procedures and Compliance Demonstration rol device monitored in accordance with he owner or operator shall demonstrate irements of §63.772(f) or (g), as • . 2( ' o dete :: emissions test procedure shall be conducted in accordance with Method 21, 40 CFR part 60, appendix A. §63.772(c)(2) - The detection instrument shall meet the performance criteria of Method 21, 40 CFR part 60, appendix A, except that the instrument response factor criteria in section 3.1.2(a) of Method 21 shall be for the average composition of the fluid and not for each individual organic compound in the stream. §63.772(c)(3) - The detection instrument shall be calibrated before use on each day of its use by the procedures specified in Method 21, 40 CFR part 60, appendix A. §63.772(c)(4) - Calibration gases shall be as follows: §63.772(c)(4)(i) - Zero air (less than 10 parts per million by volume hydrocarbon in air); and $63.772(c)(4)(ii) - A mixture of methane in air at a concentration less than 10,000 parts per million by volume. §63.772(c)(5) - An owner or operator may choose to adjust or not adjust the detection instrument readings to account for the background organic concentration level. If an owner or operator chooses to adjust the instrument readings for the background level, the background level value must be determined according to the procedures in Method 21 of 40 CFR part 60, appendix A. §63.772(c)(6)(i) - Except as provided in paragraph (c)(6)(ii) of this section, the detection instrument shall meet the performance criteria of Method 21 of 40 CFR part 60, appendix A, except the instrument response factor criteria in section 3.1.2(a) of Method 21 shall be for the average composition of the process fluid, not each individual volatile organic compound in the stream. For process streams that contain nitrogen, air, or other inert gases that are not organic hazardous air pollutants or volatile organic compounds, the average stream response factor shall be calculated on an inert -free basis. §63.772(c)(6)(ii) - If no instrument is available at the facility that will meet the performance criteria specified in paragraph (c)(6)(i) of this section, the instrument readings may be adjusted by multiplying by the average response factor of the process fluid, calculated on an inert -free basis as described in paragraph (c)(6)(i) of this section. §63.772(c)(7) - An owner or operator must determine if a potential leak interface operates with no detectable emissions using the applicable procedure specified in paragraph (c)(7)(i) or (c)(7)(ii) of this section. $63.772(c)(7)(i) - If an owner or operator chooses not to adjust the detection instrument readings for the background organic concentration level, then the maximum organic concentration value measured by the detection instrument is compared directly to the applicable value for the potential leak interface as specified in paragraph (c)(8) of this section. COLORADO Air Pollution Control Division ibiic HE&th S EnviFonmer:l Page 13 of 58 owner operator chooses to adjust the detection the ba•round organic concentration level, the tic differe =' e between the maximum organic measured the instrument and the background value . am -rmined in paragraph (c)(5) of this section is compared with the applicable value for the potential leak interface as specified in paragraph (c)(8) of this section. $63.772(c)(8) - A potential leak interface is determined to operate with no detectable organic emissions if the organic concentration value determined in paragraph (c)(7) of this section, is less than 500 parts per million by volume. §63.772(e) - Control device performance test procedures. This paragraph applies to the performance testing of control devices. The owners or operators shall demonstrate that a control device achieves the performance requirements of §63.771(d)(1), (e)(3)(ii) or (f)(1) using a performance test as specified in paragraph (e)(3) of this section. $63.772(e)(3) - For a performance test conducted to demonstrate that a control device meets the requirements of §63.771(d)(1), (e)(3)(ii) or (f)(1), the owner or operator shall use the test methods and procedures specified in paragraphs (e)(3)(i) through (v) of this section. The initial and periodic performance tests shall be conducted according to the schedule specified in paragraph (e)(3)(vi) of this section. $63.772(e)(3)(i) - Method 1 or 1A, 40 CFR part 60, appendix A, as appropriate, shall be used for selection of the sampling sites in paragraphs (e)(3)(i)(A) and (B) of this section. Any references to particulate mentioned in Methods 1 and 1A do not apply to this section. §63.772(e)(3)(i)(A) - To determine compliance with the control device percent reduction requirement specified in §63.771(d)(1)(i)(A), (d)(1)(ii) or (e)(3)(ii), sampling sites shall be located at the inlet of the first control device, and at the outlet of the final control device. §63.772(e)(3)(ii) - The gas volumetric flowrate shall be determined using Method 2, 2A, 2C, or 2D, 40 CFR part 60, appendix A, as appropriate. §63.772(e)(3)(iii) - To determine compliance with the control device percent reduction performance requirement in §63.771(d)(1)(i)(A), (d)(1)(ii), and (e)(3)(ii), the owner or operator shall use one of the following methods: Method 18, 40 CFR part 60, appendix A; Method 25A, 40 CFR part 60, appendix A; ASTM D6420-99 (2004), as specified in §63.772(a)(1)(ii); or any other method or data that have been validated according to the applicable procedures in Method 301, 40 CFR part 63, appendix A. The following procedures shall be used to calculate percent reduction efficiency: §63.772(e)(3)(iii)(A) - The minimum sampling time for each run shall be 1 hour in which either an integrated sample or a minimum of four grab samples shall be taken. If grab sampling is used, then the samples shall be taken at approximately equal intervals in time, such as 15 -minute intervals during the run. §63.772(e)(3)(iii)(B) - The mass rate of either T0C (minus methane and ethane) or total HAP (E;, E0) shall be computed using the equations and procedures specified in paragraphs (e)(3)(iii)(B)(1) through (3) of this COLORADO j Air Pollution Control Division Department of Public. Health & Environment Page 14 of 58 section. As an alternative, the mass rate of either TOC (minus methane and ethane) or total HAP at the inlet of the control device (E;) may be calculated using the procedures specified in paragraph (e)(3)(iii)(B)(4) of this section. $63.772(e)(3)(iii)(B)(1) - The following equations shall be used: n Ei = K2 1 CiJMij Qi j=1 n E0=K2(�_0jM0i )Q0 j=1 Where: C;;, Co; = Concentration of sample component j of the gas stream at the inlet and outlet of the control device, respectively, dry basis, parts per million by volume. E. = Mass rate of TOC (minus methane and ethane) or total HAP at the inlet and outlet of the control device, respectively, dry basis, kilogram per hour. M;;, M.; = Molecular weight of sample component j of the gas stream at the inlet and outlet of the control device, respectively, gram/gram- mole. Qp = Flowrate of gas stream at the inlet and outlet of the control device, respectively, dry standard cubic meter per minute. K2 = Constant, 2.494 x 10-6 (parts per million) (gram -mole per standard cubic meter) (kilogram/gram) (minute/hour), where standard temperature (gram -mole per standard cubic meter) is 20 °C. n = Number of components in sample. $63.772(e)(3)(iii)(B)(2) - When the TOC mass rate is calculated, all organic compounds (minus methane and ethane) measured by Method 18, 40 CFR part 60, appendix A, or Method 25A, 40 CFR part 60, appendix A, or ASTM D6420-99 (2004) as specified in §63.772(a)(1)(ii), shall be summed using the equations in paragraph (e)(3)(iii)(B)(1) of this section. §63.772(e)(3)(iii)(B)(3) - When the total HAP mass rate is calculated, only HAP chemicals listed in Table 1 of this subpart shall be summed using the equations in paragraph (e)(3)(iii)(B)(1) of this section. §63.772(e)(3)(iii)(B)(4) - As an alternative to the procedures for calculating E; specified in paragraph (e)(3)(iii)(B)(1) of this section, the owner or operator may use the model GRI-GLYCalcTM, Version 3.0 or higher, and the procedures presented in the associated GRI-GLYCalcTM Technical Reference Manual. Inputs to the model shall be representative of actual operating conditions of the glycol dehydration unit and shall be determined using the procedures documented in the Gas Research Institute (GRI) report entitled "Atmospheric Rich/Lean Method for Determining Glycol Dehydrator Emissions" (GRI-95/0368.1). When the TOC mass rate is calculated for glycol dehydration units using the model GRI-GLYCalcTM, all organic compounds COLORADO Air Pollution Control Division imeri;.o Pubtir. He.:' ttn P cnvPccrner Page 15 of 58 (minus methane and ethane) measured by Method 18, 40 CFR part 60, appendix A, or Method 25A, 40 CFR part 60, appendix A, shall be summed. When the total HAP mass rate is calculated for glycol dehydration units using the model GRI-GLYCalcTM, only HAP chemicals listed in Table 1 of this subpart shall be summed. $63.772(e)(3)(iii)(C) - The percent reduction in TOC (minus methane and ethane) or total HAP shall be calculated as follows: Rcd = E1 —E0 x 100% Where: Et Rcd = Control efficiency of control device, percent. E; = Mass rate of TOC (minus methane and ethane) or total HAP at the inlet to the control device as calculated under paragraph (e)(3)(iii)(B) of this section, kilograms TOC per hour or kilograms HAP per hour. E. = Mass rate of TOC (minus methane and ethane) or total HAP at the outlet of the control device, as calculated under paragraph (e)(3)(iii)(B) of this section, kilograms TOC per hour or kilograms HAP per hour. §63.772(e)(3)(vi) - The owner or operator shall conduct performance tests according to the schedule specified in paragraphs (e)(3)(vi)(A) and (B) of this section. $63.772(e)(3)(vi)(A) - An initial performance test shall be conducted within 180 days after the compliance date that is specified for each affected source in §63.760(f)(7) through (8), except that the initial performance test for existing combustion control devices (i.e., control devices installed on or before August 23, 2011) at major sources shall be conducted no later than October 15, 2015. If the owner or operator of an existing combustion control device at a major source chooses to replace such device with a control device whose model is tested under §63.772(h), then the newly installed device shall comply with all provisions of this subpart no later than October 15, 2015. The performance test results shall be submitted in the Notification of Compliance Status Report as required in §63.775(d)(1)(ii). §63.772(e)(3)(vi)(B) - Periodic performance tests shall be conducted for all control devices required to conduct initial performance tests except as specified in paragraphs (e)(3)(vi)(B)(1) and (2) of this section. The first periodic performance test shall be conducted no later than 60 months after the initial performance test required in paragraph (e)(3)(vi)(A) of this section. Subsequent periodic performance tests shall be conducted at intervals no longer than 60 months following the previous periodic performance test or whenever a source desires to establish a new operating limit. The periodic performance test results must be submitted in the next Periodic Report as specified in §63.775(e)(2)(xi). Combustion control devices meeting the criteria in either paragraph (e)(3)(vi)(B)(1) or (2) of this section are not required to conduct periodic performance tests. §63.772(f) - Compliance demonstration for control device performance requirements. This paragraph applies to the demonstration of compliance COLORADO Air Pollution Control Division nt blie Nca;'.h b Fn;vnr„mer Page 16 of 58 with the control device performance requirements specified in §63.771(d)(1)(i), (e)(3), and (f)(1). Compliance shall be demonstrated using the requirements in paragraphs (f)(1) through (3) of this section. As an alternative, an owner or operator that installs a condenser as the control device to achieve the requirements specified in §63.771(d)(1)(ii), (e)(3), or (f)(1) may demonstrate compliance according to paragraph (g) of this section. An owner or operator may switch between compliance with paragraph (f) of this section and compliance with paragraph (g) of this section only after at least 1 year of operation in compliance with the selected approach. Notification of such a change in the compliance method shall be reported in the next Periodic Report, as required in §63.775(e), following the change. $63.772(f)(1) - The owner or operator shall establish a site specific maximum or minimum monitoring parameter value (as appropriate) according to the requirements of §63.773(d)(5)(i). §63.772(f)(2) - The owner or operator shall calculate the daily average of the applicable monitored parameter in accordance with §63.773(d)(4) except that the inlet gas flowrate to the control device shall not be averaged. §63.772(f)(3) - Compliance with the operating parameter limit is achieved when the daily average of the monitoring parameter value calculated under paragraph (f)(2) of this section is either equal to or greater than the minimum or equal to or less than the maximum monitoring value established under paragraph (f)(1) of this section. For inlet gas flowrate, compliance with the operating parameter limit is achieved when the value is equal to or less than the value established under 563.772(h) or under the performance test conducted under §63.772(e), as applicable. $63.772(f)(4) - Except for periods of monitoring system malfunctions, repairs associated with monitoring system malfunctions, and required monitoring system quality assurance or quality control activities (including, as applicable, system accuracy audits and required zero and span adjustments), the CMS required in §63.773(d) must be operated at all times the affected source is operating. A monitoring system malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring system to provide valid data. Monitoring system failures that are caused in part by poor maintenance or careless operation are not malfunctions. Monitoring system repairs are required to be completed in response to monitoring system malfunctions and to return the monitoring system to operation as expeditiously as practicable. §63.772(f)(5) - Data recorded during monitoring system malfunctions, repairs associated with monitoring system malfunctions, or required monitoring system quality assurance or control activities may not be used in calculations used to report emissions or operating levels. All the data collected during all other required data collection periods must be used in assessing the operation of the control device and associated control system. $63.772(f)(6) - Except for periods of monitoring system malfunctions, repairs associated with monitoring system malfunctions, and required quality monitoring system quality assurance or quality control activities (including, as applicable, system accuracy audits and required zero and span adjustments), failure to collect required data is a deviation of the monitoring requirements. CDPHE on 'COLORADO Air Pollution Control Division Department of Pubic Health. & Environment Page 17 of 58 §63.773 - Inspection and Monitoring Requirements §63.7m£ ( 1) - For each closed -vent system or cover required to comply with this section, the owner or operator shalt comply with the requirements of paragraphs (c) (2) through (7) of this section. . 3( Except as provided in paragraphs (c)(5) and (6) of this section, each closed -vent system shall be inspected according to the procedures and schedule specified in paragraphs (c)(2)(i) and (ii) of this section, each cover shall be inspected according to the procedures and schedule specified in paragraph (c)(2)(iii) of this section, and each bypass device shall be inspected according to the procedures of paragraph (c)(2)(iv) of this section. §63.773(c)(2)(i) - For each closed -vent system joints, seams, or other connections that are permanently or semi -permanently sealed (e.g., a welded joint between two sections of hard piping or a bolted and gasketed ducting flange), the owner or operator shall: §63.773(c)(2)(i)(A) - Conduct an initial inspection according to the procedures specified in §63.772(c) to demonstrate that the closed -vent system operates with no detectable emissions. Inspection results shall be submitted with the Notification of Compliance Status Report as specified in §63.775(d)(1) or (2). §63.773(c)(2)(i)(B) - Conduct annual visual inspections for defects that could result in air emissions. Defects include, but are not limited to, visible cracks, holes, or gaps in piping; loose connections; or broken or missing caps or other closure devices. The owner or operator shall monitor a component or connection using the procedures in §63.772(c) to demonstrate that it operates with no detectable emissions following any time the component is repaired or replaced or the connection is unsealed. Inspection results shall be submitted in the Periodic Report as specified in §63.775(e)(2)(iii). $63.773(c)(2)(ii) - For closed -vent system components other than those specified in paragraph (c)(2)(i) of this section, the owner or operator shall: §63.773(c)(2)(ii)(A) - Conduct an initial inspection according to the procedures specified in §63.772(c) to demonstrate that the closed -vent system operates with no detectable emissions. Inspection results shall be submitted with the Notification of Compliance Status Report as specified in §63.775(d)(1) or (2). §63.773(c)(2)(ii)(B) - Conduct annual inspections according to the procedures specified in 563.772(c) to demonstrate that the components or connections operate with no detectable emissions. Inspection results shall be submitted in the Periodic Report as specified in §63.775(e)(2)(iii). §63.773(c)(2)(ii)(C) - Conduct annual visual inspections for defects that could result in air emissions. Defects include, but are not limited to, visible cracks, holes, or gaps in ductwork; loose connections; or broken or missing caps or other closure devices. Inspection results shall be submitted in the Periodic Report as specified in §63.775(e)(2)(iii). $63.773(c)(2)(iv) - For each bypass device, except as provided for in §63.771(c)(3)(ii), the owner or operator shall either: $63.773(c)(2)(iv)(A) - At the inlet to the bypass device that could divert the steam away from the control device to the atmosphere, set the flow indicator to take a reading at least once every 15 minutes; or COLORADO Air Pollution Control Division 1 Deparment 0 Public Health 5 Environment Page 18 of 58 §63 ` )(iv) - If the bypass device valve installed at the inlet to the bypass device is secured in the non -diverting position using a car -seal or a lock -and -key type configuration, visually inspect the seal or closure mechanism at least once every month to verify that the valve is maintained in the non -diverting position and the vent stream is not diverted through the bypass device. §63.773(c)(3) - In the event that a leak or defect is detected, the owner or operator shall repair the leak or defect as soon as practicable, except as provided in paragraph (c)(4) of this section. §63.773(c)(3)(i) - A first attempt at repair shall be made no later than 5 calendar days after the leak is detected. §63.773(c)(3)(ii) - Repair shall be completed no later than 15 calendar days after the leak is detected. §63.773(c)(4) - Delay of repair of a closed -vent system or cover for which leaks or defects have been detected is allowed if the repair is technically infeasible without a shutdown, as defined in 563.761, or if the owner or operator determines that emissions resulting from immediate repair would be greater than the fugitive emissions likely to result from delay of repair. Repair of such equipment shall be complete by the end of the next shutdown. §63.773(c)(5) - Any parts of the closed -vent system or cover that are designated, as described in paragraphs (c)(5) (i) and (ii) of this section, as unsafe to inspect are exempt from the inspection requirements of paragraphs (c)(2)(i), (ii), and (iii) of this section if: §63.773(c)(5)(i) - The owner or operator determines that the equipment is unsafe to inspect because inspecting personnel would be exposed to an imminent or potential danger as a consequence of complying with paragraphs (c)(2)(i), (ii), or (iii) of this section; and §63.773(c)(5)(ii) - The owner or operator has a written plan that requires inspection of the equipment as frequently as practicable during safe -to - inspect times. 563.773(c)(6) - Any parts of the closed -vent system or cover that are designated; as described in paragraphs (c)(6) (i) and (ii) of this section, as difficult to inspect are exempt from the inspection requirements of paragraphs (c)(2)(i), (ii), and (iii) of this section if: §63.773(c)(6)(i) - The owner or operator determines that the equipment cannot be inspected without elevating the inspecting personnel more than 2 meters above a support surface; and §63.773(c)(6)(ii) - The owner or operator has a written plan that requires inspection of the equipment at least once every 5 years. §63.773(c)(7) - Records shall be maintained as specified in §63.774(b)(5) through (8). §63.773(d)(1) - For each control device, except as provided for in paragraph (d)(2) of this section, the owner or operator shall install and operate a continuous parameter monitoring system in accordance with the COLORADO Air Pollution Control Division Departmer t of Public Hea1;h 8'cnrironrnetr Page 19 of 58 requirements of paragraphs (d)(3) through (7) of this section. Owners or operators that install and operate a flare in accordance with §63.771(d)(1)(iii) or (f)(1)(iii) are exempt from the requirements of paragraphs (d)(4) and (5) of this section. The continuous monitoring system shall be designed and operated so that a determination can be made on whether the control device is achieving the applicable performance requirements of §63.771(d), (e)(3), or (f)(1). Each continuous parameter monitoring system shall meet the following specifications and requirements: $63.773(d)(1)(i) - Each continuous parameter monitoring system shall measure data values at least once every hour and record either: $63.773(d)(1)(i)(A) - Each measured data value; or §63.773(d)(1)(i)(B) - Each block average value for each 1 -hour period or shorter periods calculated from all measured data values during each period. If values are measured more frequently than once per minute, a single value for each minute may be used to calculate the hourly (or shorter period) block average instead of all measured values. §63.773(d)(1)(ii) - A site -specific monitoring plan must be prepared that addresses the monitoring system design, data collection, and the quality assurance and quality control elements outlined in paragraph (d) of this section and in §63.8(d). Each CPMS must be installed, calibrated, operated, and maintained in accordance with the procedures in your approved site - specific monitoring plan. Using the process described in §63.8(f)(4), you may request approval of monitoring system quality assurance and quality control procedures alternative to those specified in paragraphs (d)(1)(ii)(A) through (E) of this section in your site -specific monitoring plan. §63.773(d)(1)(ii)(A) - The performance criteria and design specifications for the monitoring system equipment, including the sample interface, detector signal analyzer, and data acquisition and calculations; $63.773(d)(1)(ii)(B) - Sampling interface (e.g., thermocouple) location such that the monitoring system will provide representative measurements; §63.773(d)(1)(ii)(C) - Equipment performance checks, system accuracy audits, or other audit procedures; $63.773(d)(1)(ii)(D) - Ongoing operation and maintenance procedures in accordance with provisions in §63.8(c)(1) and (3); and §63.773(d)(1)(ii)(E) - Ongoing reporting and recordkeeping procedures in accordance with provisions in §63.10(c), (e)(1), and (e)(2)(i). $63.773(d)(1)(iii) - The owner or operator must conduct the CPMS equipment performance checks, system accuracy audits, or other audit procedures specified in the site -specific monitoring plan at least once every 12 months. §63.773(d)(1)(iv) - The owner or operator must conduct a performance evaluation of each CPMS in accordance with the site -specific monitoring plan. §63.773(d)(3) - The owner or operator shall install, calibrate, operate, and maintain a device equipped with a continuous recorder to measure the !COLORADO Air Pollution Control Division 1 Department of Public: Health h `crniror:n«r. Page 20 of 58 values of operating parameters appropriate for the control device as specified in either paragraph (d)(3)(i), (d)(3)(ii), or (d)(3)(iii) of this section. §63 73(d) (i) - continuous monitoring system that measures the following operating parameters as applicable: $63.773(d)(3)(i)(A) - For a thermal vapor incinerator that demonstrates during the performance test conducted under §63.772(e) that the combustion zone temperature is an accurate indicator of performance, a temperature monitoring device equipped with a continuous recorder. The monitoring device shall have a minimum accuracy of ±2 percent of the temperature being monitored in °C, or ±2.5 °C, whichever value is greater. The temperature sensor shall be installed at a location representative of the combustion zone temperature. §63.773(d)(4) - Using the data recorded by the monitoring system, except for inlet gas flowrate, the owner or operator must calculate the daily average value for each monitored operating parameter for each operating day. If the emissions unit operation is continuous, the operating day is a 24 - hour period. If the emissions unit operation is not continuous, the operating day is the total number of hours of control device operation per 24 -hour period. Valid data points must be available for 75 percent of the operating hours in an operating day to compute the daily average. §63.773(d)(5) - For each operating parameter monitor installed in accordance with the requirements of paragraph (d)(3) of this section, the owner or operator shall comply with paragraph (d)(5)(i) of this section for all control devices, and when condensers are installed, the owner or operator shall also comply with paragraph (d)(5)(ii) of this section. §63.773(d)(5)(i) - The owner or operator shall establish a minimum operating parameter value or a maximum operating parameter value, as appropriate for the control device, to define the conditions at which the control device must be operated to continuously achieve the applicable performance requirements of §63.771(d)(1), (e)(3)(ii), or (f)(1). Each minimum or maximum operating parameter value shall be established as follows: $63.773(d)(5)(i)(A) - If the owner or operator conducts performance tests in accordance with the requirements of §63.772(e)(3) to demonstrate that the control device achieves the applicable performance requirements specified in §63.771(d)(1), (e)(3)(ii) or (f)(1), then the minimum operating parameter value or the maximum operating parameter value shall be established based on values measured during the performance test and supplemented, as necessary, by a condenser design analysis or control device manufacturer recommendations or a combination of both. §63.773(d)(6) - An excursion for a given control device is determined to have occurred when the monitoring data or lack of monitoring data result in any one of the criteria specified in paragraphs (d)(6)(i) through (vi) of this section being met. When multiple operating parameters are monitored for the same control device and during the same operating day and more than one of these operating parameters meets an excursion criterion specified in paragraphs (d)(6)(i) through (vi) of this section, then a single excursion is determined to have occurred for the control device for that operating day. §63.773(d)(6)(i) - An excursion occurs when the daily average value of a monitored operating parameter is less than the minimum operating COLORADO Air Pollution Control Division Deparrnent of Public Heath & Environment Page 21 of 58 parameter limit (or, if applicable, greater than the maximum operating parameter limit) established for the operating parameter in accordance with the requirements of paragraph (d)(5)(i) of this section. • } 3( •"' ' An excursion occurs when the monitoring data are not available for at least 75 percent of the operating hours in a day. $63.773(d)(6)(v) - If the closed -vent system contains one or more bypass devices that could be used to divert all or a portion of the gases, vapors, or fumes from entering the control device, an excursion occurs when: $63.773(d)(6)(v)(A) - For each bypass line subject to §63.771(c)(3)(i)(A) the flow indicator indicates that flow has been detected and that the stream has been diverted away from the control device to the atmosphere. §63.773(d)(6)(v)(B) - For each bypass tine subject to §63.771(c)(3)(i)(B), if the seal or closure mechanism has been broken, the bypass line valve position has changed, the key for the lock -and -key type lock has been checked out, or the car -seal has broken §63.773(d)(7) - For each excursion, the owner or operator shall be deemed to have failed to have applied control in a manner that achieves the required operating parameter limits. Failure to achieve the required operating parameter limits is a violation of this standard. 863.774 - Recordkeeping 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) - 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 be maintained in such a manner that they can be readily accessed. §63.774(b)(1)(ii) - The most recent 12 months of records shall be retained on site or shall be accessible from a central location by computer or other means that provides access within 2 hours after a request. §63.774(b)(1)(iii) - The remaining 4 years of records may be retained offsite. $63.774(b)(1)(iv) - Records may be maintained in hard copy or computer - readable form including, but not limited to, on paper, microfilm, computer, floppy disk, magnetic tape, or microfiche. §63.774(b)(2) - Records specified in §63.10(b)(2); §63.774(b)(3) - Records specified in §63.10(c) for each monitoring system operated by the owner or operator in accordance with the requirements of §63.773(d). Notwithstanding the requirements of §63.10(c), monitoring data recorded during periods identified in paragraphs (b)(3)(i) through (iv) of this section shall not be included in any average or percent leak rate computed under this subpart. Records shall be kept of the times and durations of all such periods and any other periods during process or control device CDPHE ;COLORADO Air Pollution Control Division Department of Public Health , 'c.^..^iconmen; Page 22 of 58 operation when monitors are not operating or failed to collect required data. $63 f 74(b) .. (i)-Monitoring system breakdowns, repairs, calibration checks, and zero (low-level) and high-level adjustments; §63.774(b)(3)(iii) - Periods of non -operation resulting in cessation of the emissions to which the monitoring applies; and §63.774(b)(3)(iv) - Excursions due to invalid data as defined in §63.773(d)(6)(iv). §63.774(b)(4) - Each owner or operator using a control device to comply with §63.764 of this subpart shall keep the following records up-to-date and readily accessible: $63.774(b)(4)(i) - Continuous records of the equipment operating parameters specified to be monitored under §63.773(d) or specified by the Administrator in accordance with §63.773(d)(3)(iii). §63.774(b)(4)(ii) - Records of the daily average value of each continuously monitored parameter for each operating day determined according to the procedures specified in §63.773(d)(4) of this subpart, except as specified in paragraphs (b)(4)(ii)(A) through (C) of this section. $63.774(b)(4)(iii) - Hourly records of the times and durations of all periods when the vent stream is diverted from the control device or the device is not operating. - $63.774(b)(4)(iv) - Where a seal or closure mechanism is used to comply with §63.771(c)(3)(i)(B), hourly records of flow are not required. In such cases, the owner or operator shall record that the monthly visual inspection of the seals or closure mechanism has been done, and shall record the duration of all periods when the seal mechanism is broken, the bypass line valve position has changed, or the key for a lock -and -key type lock has been checked out, and records of any car -seal that has broken. 563.774(b)(5) - Records identifying all parts of the cover or closed -vent system that are designated as unsafe to inspect in accordance with §63.773(c)(5), an explanation of why the equipment is unsafe to inspect, and the plan for inspecting the equipment. §63.774(b)(6) - Records identifying all parts of the cover or closed -vent system that are designated as difficult to inspect in accordance with §63.773(c)(6), an explanation of why the equipment is difficult to inspect, and the plan for inspecting the equipment. §63.774(b)(7) - For each inspection conducted in accordance with 563.773(c), during which a leak or defect is detected, a record of the information specified in paragraphs (b)(7)(i) through (b)(7)(viii) of this section. §63.774(b)(7)(i) - The instrument identification numbers, operator name or initials, and identification of the equipment. $63.774(b)(7)(ii) - The date the leak or defect was detected and the date of the first attempt to repair the leak or defect. COLORADO Air Pollution Control Division Department of Public. Health & Emiranmer:! Page 23 of 58 $63.714( (7)(iii) Maximum instrument reading measured by the method specified in §63.772(c) after the leak or defect is successfully repaired or determined to be nonrepairable. • 4(•= �4rg "Repair delayed" and the reason for the delay if a leak or defect is not repaired within 15 calendar days after discovery of the leak or defect. §63.774(b)(7)(v) - The name, initials, or other form of identification of the owner or operator (or designee) whose decision it was that repair could not be effected without a shutdown. §63.774(b)(7)(vi) - The expected date of successful repair of the leak or defect if a leak or defect is not repaired within 15 calendar days. §63.774(b)(7)(vii) - Dates of shutdowns that occur while the equipment is unrepaired. §63.774(b)(7)(viii) - The date of successful repair of the leak or defect. §63.774(b)(8) - For each inspection conducted in accordance with §63.773(c) during which no leaks or defects are detected, a record that the inspection was performed, the date of the inspection, and a statement that no leaks or defects were detected. §63.774(b)(9) - Records identifying ancillary equipment and compressors that are subject to and controlled under the provisions of 40 CFR part 60, subpart KKK; 40 CFR part 61, subpart V; or 40 CFR part 63, subpart H. §63.774(g) - The owner or operator of an affected source subject to this subpart shall maintain records of the occurrence and duration of each malfunction of operation (i.e., process equipment) or the air pollution control equipment and monitoring equipment. The owner or operator shall maintain records of actions taken during periods of malfunction to minimize emissions in accordance with §63.764(j), including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation. §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. §63.775 - Reporting Requirements $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 the EPA's Office of Air Quality Planning and Standards. Send your notification via email to Oil and Gas Sector@epa.govorvia U.S. mail or other mail delivery service to U.S. EPA, Sector Policies and Programs Division/Fuels and Incineration Group (E143-01), Attn: Oil and Gas Project Leader, Research Triangle Park, NC 27711. §63.775(c)(2) - The date of the performance evaluation as specified in §63.8(e)(2) if an owner or operator is required by the Administrator to conduct a performance evaluation for a continuous monitoring system. 563.775(c)(3) - The planned date of a performance test at least 60 days before the test in accordance with §63.7(b). Unless requested by the COLORADO Air Pollution Control Division Department of Public Health & Enraanment Page 24 of 58 Administrator, a site -specific test plan is not required by this subpart. If requested by the Administrator, the owner or operator must submit the site - specific test plan required by 563.7(c) with the notification of the performance test. A separate notification of the performance test is not required if it is included in the initial notification submitted in accordance with paragraph (c)(1) of this section. §63.775(c)(4) - A Notification of Compliance Status as described in paragraph (d) of this section; §63.775(c)(5) - Periodic reports as described in paragraph (e)(3) of this section; and $63.775(c)(6) - If there was a malfunction during the reporting period, the Periodic Report specified in paragraph (e) of this section shall include the number, duration, and a brief description for each type of malfunction which occurred during the reporting period and which caused or may have caused any applicable emission limitation to be exceeded. The report must also include a description of actions taken by an owner or operator during a malfunction of an affected source to minimize emissions in accordance with §63.764(j), including actions taken to correct a malfunction. §63.775(d) - Each owner or operator of a source subject to this subpart shall submit a Notification of Compliance Status Report as required under 563.9(h) within 180 days after the compliance date specified in 563.760(f). In addition to the information required under §63.9(h), the Notification of Compliance Status Report shall include the information specified in paragraphs (d)(1) through (12) of this section. This information may be submitted in an operating permit application, in an amendment to an operating permit application, in a separate submittal, or in any combination of the three. If all of the information required under this paragraph has been submitted at any time prior to 180 days after the applicable compliance dates specified in §63.760(f), a separate Notification of Compliance Status Report is not required. If an owner or operator submits the information specified in paragraphs (d)(1) through (12) of this section at different times, and/or different submittals, subsequent submittals may refer to previous submittals instead of duplicating and resubmitting the previously submitted information. $63.775(d)(1) - If a closed -vent system and a control device other than a flare are used to comply with §63.764, the owner or operator shall submit the information in paragraph (d)(1)(iii) of this section and the information in either paragraph (d)(1)(i) or (ii) of this section. 663.775(d)(1)(ii) - If the owner or operator is required to conduct a performance test, the performance test results including the information specified in paragraphs (d)(1)(ii)(A) and (B) of this section. Results of a performance test conducted prior to the compliance date of this subpart can be used provided that the test was conducted using the methods specified in §63.772(e)(3) and that the test conditions are representative of current operating conditions. If the owner or operator operates a combustion control device model tested under §63.772(h), an electronic copy of the performance test results shall be submitted via email to Oil_and_Gas_PT@EPA.GOV unless the test results for that model of combustion control device are posted at the following Web site: epa.gov/airquality/oilandgas/. COLORADO Air Pollution Control Division Deparimeery of Public Health & En,:ironment. Page 25 of 58 $63.7 ( (1)(11)( - The percent reduction of HAP or TOC, or the outlet concentration of HAP or TOC (parts per million by volume on a dry basis), determined as specified in §63.772(e)(3) of this subpart; and 5(•` i" - The value of the monitored parameters specified in §773(d) of this subpart, or a site -specific parameter approved by the permitting agency, averaged over the full period of the performance test. $63.775(d)(1)(iii) - The results of the closed -vent system initial inspections performed according to the requirements in §63.773(c)(2)(i) and (ii). §63.775(d)(4) - The owner or operator shall submit one complete test report for each test method used for a particular source. $63.775(d)(4)(i) - For additional tests performed using the same test method, the results specified in paragraph (d)(1)(ii) of this section shall be submitted, but a complete test report is not required. §63.775(d)(4)(ii) - A complete test report shalt include a sampling site description, description of sampling and analysis procedures and any modifications to standard procedures, quality assurance procedures, record of operating conditions during the test, record of preparation of standards, record of calibrations, raw data sheets for field sampling, raw data sheets for field and laboratory analyses, documentation of calculations, and any other information required by the test method. $63.775(d)(5) - For each control device other than a flare used to meet the requirements of §63.764, the owner or operator shall submit the information specified in paragraphs (d)(5) (i) through (iii) of this section for each operating parameter required to be monitored in accordance with the requirements of §63.773(d). $63.775(d)(5)(i) - The minimum operating parameter value or maximum operating parameter value, as appropriate for the control device, established by the owner or operator to define the conditions at which the control device must be operated to continuously achieve the applicable performance requirements of §63.771(d)(1) or (e)(3)(ii) $63.775(d)(5)(ii) - An explanation of the rationale for why the owner or operator selected each of the operating parameter values established in §63.773(d)(5). This explanation shall include any data and calculations used to develop the value and a description of why the chosen value indicates that the control device is operating in accordance with the applicable requirements of §63.771(d)(1), (e)(3)(ii) or (f)(1). $63.775(d)(5)(iii) - A definition of the source's operating day for purposes of determining daily average values of monitored parameters. The definition shall specify the times at which an operating day begins and ends. $63.775(d)(6) - Results of any continuous monitoring system performance evaluations shall be included in the Notification of Compliance Status Report. $63.775(d)(9) -The owner or operator shall submit the analysis performed under §63.760(a)(1). §63.775(d)(10) -The owner or operator shall submit a statement as to whether the source has complied with the requirements of this subpart. COLORADO Air Pollution Control Division Department of RibMic Health & Emirarmeni Page 26 of 58 §63. - An owner or operator of an area source shall prepare Periodic Reports in accordance with paragraph (e)(3) of this section and submit them to the Administrator. §63.775(e)(3) - An owner or operator of an area source located inside a UA plus offset and UC boundary shall prepare and submit Periodic Reports in accordance with paragraphs (e)(3)(i) through (iii) of this section. $63.775(e)(3)(i) - Periodic reports must be submitted on an annual basis. The first reporting period shall cover the period beginning on the date the Notification of Compliance Status Report is due and ending on December 31. The report shall be submitted within 30 days after the end of the reporting period. $63.775(e)(3)(ii) - Subsequent reporting periods begin every January 1 and end on December 31. Subsequent reports shall be submitted within 30 days following the end of the reporting period. $63.775(e)(3)(iii) - The periodic reports must contain the information included in paragraph (e)(2) of this section. §63.775(f) - 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 $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. §63.775(g)(1) - Within 60 days after the date of completing each performance test (defined in §63.2) as required by this subpart you must submit the results of the performance tests required by this subpart to EPA's WebFIRE database by using the Compliance and Emissions Data Reporting Interface (CEDRI) that is accessed through EPA's Central Data Exchange (CDX) (www.epa.gov/cdx). Performance test data must be submitted in the file format generated through use of EPA's Electronic Reporting Tool (ERT) (see http://www.epa.gov/ttn/chief/ert/index.htmi). Only data collected using test methods on the ERT Web site are subject to this requirement for submitting reports electronically to WebFIRE. Owners or operators who claim that some of the information being submitted for performance tests is confidential business information (CBI) must submit a complete ERT file including information claimed to be CBI on a compact disk or other commonly used electronic storage media (including, but not limited to, flash drives) to EPA. The electronic media must be clearly marked as CBI and mailed to U.S. EPA/OAPQS/CORE CBI Office, Attention: WebFIRE Administrator, MD C404-02, 4930 Old Page Rd., Durham, NC 27703. The ;COLORADO Air Pollution Control Division i Department of Public Heim& Environment Page 27 of 58 same ERT file with the CBI omitted must be submitted to EPA via CDX as described earlier in this paragraph. At the discretion of the delegated authority, you must also submit these reports, including the confidential business information, to the delegated authority in the format specified by the delegated authority. 563.775(g)(2) - All reports required by this subpart not subject to the requirements in paragraph (g)(1) of this section must be sent to the Administrator at the appropriate address listed in §63.13. The Administrator or the delegated authority may request a report in any form suitable for the specific case (e.g., by commonly used electronic media such as Excel spreadsheet, on CD or hard copy). The Administrator retains the right to require submittal of reports subject to paragraph (g)(1) of this section in paper format. Turbine (Point 010) 30. Point 010: This source is subject to the Particulate Matter and Sulfur Dioxide Emission Regulations of Regulation 1 including, but not limited to, the following (Regulation Number 1, Section III.A.1. Et VI.B.): a. No owner or operator shall cause or permit to be emitted into the atmosphere from any fuel -burning equipment, particulate matter in the flue gases which exceeds the following (Regulation 1, Section III.A.1.): (i) For fuel burning equipment with designed heat inputs greater than 1x106 BTU per hour, but less than or equal to 500x106 BTU per hour, the following equation will be used to determine the allowable particulate emission limitation. PE=0.5(FI)-0.26 Where: PE = Particulate Emission in Pounds per million BTU heat input. Fl = Fuel Input in Million BTU per hour. b. Emissions of sulfur dioxide shall not emit sulfur dioxide in excess of the following combustion turbine limitations. (Heat input rates shall be the manufacturer's guaranteed maximum heat input rates). (i) Combustion Turbines with a heat input of less than 250 Million BTU per hour: 0.8 pounds of sulfur dioxide per million BTU of heat input. (Regulation 1, Section VI. B.4.c. (i).) ) 31. Point 010: This source is subject to the New Source Performance Standards requirements of Regulation 6, Part B including, but not limited to, the following (Regulation 6, Part B, Section II): a. Standard for Particulate Matter - On and after the date on which the required performance test is completed, no owner or operator subject to the provisions of this regulation may discharge, or cause the discharge into the atmosphere of any particulate matter which is: (i) For fuel burning equipment generating greater than one million but less than 250 million Btu per hour heat input, the following equation will be used to determine the allowable particulate emission limitation: PE=0.5(FI )-0.26 Where: PE is the allowable particulate emission in pounds per million Btu heat input. Fl is the fuel input in million Btu per hour. COLORADO Air Pollution Control Division Deaarmerxt of Public Heath 8 En:ironn?r:. Page 28 of 58 opening, the maximum allowable emission al emission rates. opacity. Stan.ard for "u ur Dioxi`.e -�n and after e date on which the required performance test is competed, no owner or operator subject to the provisions of this regulation may discharge, or cause the discharge into the atmosphere sulfur dioxide in excess of: (i) Sources with a heat input of less than 250 million Btu per hour: 0.8 lbs. 5O2/million Btu. 32. Point 010: The combustion turbines are subject to the New Source Performance Standards requirements of Regulation Number 6, Part A, Subpart KKKK, Standards of Performance for Stationary Combustion Turbines including, but not limited to, the following: • 40 CFR, Part 60, Subpart A - General Provisions • §60.4320 - Nitrogen Oxide Emissions Limits o §60.4320 (a) - NOX emissions shall not exceed 25 ppm at 15% O2 or 1.2 lb/MW-hr; • §60.4330 - Sulfur Dioxide Emissions Limits o §60.4330 (a)(1) - SO2 emissions shall not exceed 0.9 lb/MW-hr gross output; or o §60.4330 (a)(2) - Operator shall not burn any fuel that contains total potential sulfur emissions in excess of 0.060 lb SO2/MMBtu heat input. • §60.4333 - General Requirements o §60.4333 (a) - Operator must operate and maintain your stationary combustion turbine, air pollution control equipment, and monitoring equipment in a manner consistent with good air pollution control practices for minimizing emissions at all times including during startup, shutdown and malfunction. • §60.4340 - NOX Monitoring o §60.4340 (a) - Operator shalt perform annual performance tests in accordance with §60.4400 to demonstrate continuous compliance with NOX emissions limits. If the NOX emission result from the performance test is less than or equal to 75 percent of the NOX emission limit for the turbine, you may reduce the frequency of subsequent performance tests to once every 2 years (no more than 26 calendar months following the previous performance test). If the results of any subsequent performance test exceed 75 percent of the NOX emission limit for the turbine, you must resume annual performance tests. • §60.4365 (or §S60.4360 and 60.4370) - SO2 Monitoring o The operator shall comply with §60.4365 or with both §§60.4360 and 60.4370 to demonstrate compliance with SO2 emissions limits. • §60.4375 - Reporting o §60.4375 (b) - For each affected unit that performs annual performance tests in accordance with §60.4340(a), you must submit a written report of the results of each performance test before the close of business on the 60th day following the completion of the performance test. • §S60.4400 and 60.4415 - Performance Tests o Annual tests must be conducted in accordance with §60.4400(a) and (b). o Unless operator chooses to comply with §60.4365 for exemption of monitoring the total sulfur content of the fuel, then initial and subsequent performance tests for sulfur shall be conducted according to §60.4415. COLORADO I Air Pollution Control Division I Department of Public Health b Environment Page 29 of 58 Fu "ti 33. r' oint -' proc • pre y rs a roupeith the fugitive emissions addressed by AIRS rformance andards requirements of Regulation Number A, r. rt Staerform for Crude Oil and Natural Gas Production, Transmission and Distribution including, but not limited to, the following: • §60.5385(a) - Owner or operator must replace the reciprocating compressor rod packing according to either paragraph §60.5385(a)(1) or (2). (i) §60.5385(a)(1) - Before the compressor has operated for 26,000 hours. The number of hours of operation must be continuously monitored beginning upon initial startup of your reciprocating compressor affected facility, or October 15, 2012, or the date of the most recent reciprocating compressor rod packing replacement, whichever is later. (ii) §60.5385(a)(2) - Prior to 36 months from the date of the most recent rod packing replacement, or 36 months from the date of startup for a new reciprocating compressor for which the rod packing has not yet been replaced. • §60.5410 - Owner or operator must demonstrate initial compliance with the standards as detailed in §60.5410(c). • §60.5415 - Owner or operator must demonstrate continuous compliance with the standards as detailed in §60.5415(c). • §60.5420 - Owner or operator must comply with the notification, reporting, and recordkeeping requirements as specified in §60.5420(a), §60.5420(b)(1), §60.5420(b)(4), and §60.5420(c)(3). 34. Point 012: The reciprocating compressors grouped with the fugitive emissions addressed by AIRS ID 012 are subject to the requirements in Regulation 7 Section XII.J. In addition, the operator shall comply with the General Provisions contained in Regulation 7, Section XII.C.1. 35. Point 012: Fugitive component leaks at this natural gas compressor station are subject to the Leak Detection and Repair (LDAR) program requirements, including but not limited to: monitoring, repair, re -monitoring, recordkeeping and reporting contained in Regulation 7, Section XII.L. In addition, the operator shall comply with the General Provisions contained in Regulation 7, Section XII.C.1. 36. Point 012: Fugitive component leaks at this natural gas compressor station are subject to the Leak Detection and Repair (LDAR) program requirements, including but not limited to: monitoring, repair, re -monitoring, recordkeeping and reporting contained in Regulation 7, Section XVII.F. In addition, the operator shall comply with the General Provisions contained in Regulation 7, Section XVII.B.1. Pressurized Loadout (Point 013) 37. Point 013: 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. (Regulation Number 3, Part B, Section III.E.) 38. Point 013: The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Regulation Number 3, Part B, Section III.E.): a. 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 loss during loading and unloading. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. b. 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. COLORADO Air Pollution Control Division Department n! Public. Health & Environmerlz Page 30 of 58 ith an indication of status, a description of Inst �,, an. .er=e the :.or collection return equipment to collect vapors during loa•ingof an c mpar men s o outbounransport trucks. e. Include devices to prevent the release of vapor from vapor recovery hoses not in use. f. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. g. Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. OPERATING a MAINTENANCE REQUIREMENTS 39. Points 001-004, 006, 009 Et 011: Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&tM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the 0&tM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) 40. Point 010: At all times during normal operation, the owner or operator shall operate the turbine in SoLoNOx mode. On a daily basis, the owner or operator shall monitor and record the status of the SoLoNOx mode, including records of when the unit is not operating in SoLoNOx mode. These records shall be made available to the Division upon request. Normal operation shall be defined as all periods of operation except for startup, shutdown, or malfunction events. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 41. Points 006 a oil: Each TEG dehydration unit is subject to the initial testing requirements of 40 C.F.R. Part 63, Subpart HH, as referenced in this permit. 42. Point 009: A source initial compliance test shall be conducted to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emission limits in this permit. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time (Regulation Number 3, Part B., Section III.G.3) Oxides of Nitrogen using EPA approved methods. Carbon Monoxide using EPA approved methods. Volatile Organic Compounds using EPA approved methods. Formaldehyde Hazardous Air Pollutants using EPA approved methods. 43. Point 009: The owner or operator shall complete the initial sampling for gross heating value of the fuel used in the engine as required by this permit and submit the results to the Division as part of the self -certification process to demonstrate compliance with emissions limits. (Regulation Number 3, Part B, Section III.E.) 44. Point 010: This turbine is subject to the initial testing requirements of 40 C.F.R. Part 60, Subpart KKKK, as referenced in this permit. COLORADO Air Pollution Control Division Department or Public Health 5 Environment Page 31 of 58 45. st shal se conducted on the combustion turbine to 1 Ste y -state Turbine Emissions for the pollutants compliant with the emissions limits contained in this The accordancwith the requirements of the Air Pollution n rol Division Cop'lance sY anua and sha •e submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time (Regulation Number 3, Part B., Section III.G.3) Oxides of Nitrogen using EPA approved methods. Carbon Monoxide approved methods. This test may be conducted concurrently with the initial testing required by 40 C.F.R. Part 60, Subpart KKKK. 46. Point 010: The owner or operator shall complete the initial sampling for net heating value of the fuel used in the turbine as required by this permit and submit the results to the Division as part of the self -certification process to demonstrate compliance with emissions limits. (Regulation Number 3, Part B, Section III.E.) 47. Point 011: The owner or operator shall complete the initial extended wet gas analysis prior to the inlet of the TEG dehydration unit within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit. The wet gas analysis shall be analyzed for total VOC, benzene, toluene, ethylbenzene, xylene, n -Hexane, 2,2,4-trimethylpentane and methanol content. 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. (Regulation Number 3, Part B, Section III.E.) 48. Point 011: The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 9, 40 C.F.R. Part 60, Appendix A, to measure opacity from the flare for one continuous hour. (Regulation Number 1, Section II.A.5) 49. Point 012: Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, the owner or operator shall complete the initial extended gas analysis of gas samples that are representative of volatile organic compound (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas analysis shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. The operator shall submit the results of the extended gas analysis and emission calculations to the Division as part of the self -certification process to ensure compliance with emissions limits. 50. Point 012: Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, the operator shall complete a hard count of components at the source and establish the number of components that are operated in "heavy liquid service", "light liquid service", "water/oil service" and "gas service". The operator shall submit the results to the Division as part of the self -certification process to ensure compliance with emissions limits. Periodic Testing Requirements 51. Points 001-004 Et 009: Each engine is subject to the periodic testing requirements as specified in the operating and maintenance (OEM) plan as approved by the Division. Revisions to your 0£tM plan are subject to Division approval. Replacements of this unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A. COLORADO Air Pollution Control Division Department of Pubic Henkh b Environment Page 32 of 58 52. ='oints 1 u Z ' 09: T ass head .• value o uhe fuel used in the engines shall be sampled months with consecutive samples taken at s. If sampling is performed more often, the all be used in the emission calculations. 53. Point 006 £t 011: The owner or operator shall complete an extended wet gas analysis prior to the inlet of each TEG dehydration unit on an annual basis. The wet gas analysis shalt be analyzed for total VOC, benzene, toluene, ethylbenzene, xylene, n -Hexane, 2,2,4-trimethylpentane and methanol content. Results of the wet gas analysis shall be used to calculate emissions of criteria pollutants and hazardous air pollutants per this permit and be provided to the Division upon request. 54. Points 006 a oil: Each TEG dehydration unit is subject to the periodic testing requirements of 40 C.F.R. Part 63, Subpart HH, as referenced in this permit. 55. Point 010: The turbine is subject to the periodic testing requirements of 40 C.F.R. Part 60, Subpart KKKK, as referenced in this permit. 56. Point 010: Replacements of this unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment B. 57. Point 010: The owner or operator shall conduct, at a minimum, quarterly portable analyzer monitoring of the turbine exhaust outlet emissions of nitrogen oxides (NOX) and carbon monoxide (CO) to monitor compliance with the emissions limits for Process 01 - Steady-state Turbine emissions. The source may perform a stack test per the following condition in lieu of portable analyzer testing. Results of all tests conducted shall be kept on site and made available to the Division upon request. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time. 58. Point 010: The owner or operator shall measure the emission rate(s) from the turbine for Process 01 - Steady-state Turbine Emissions for the pollutants listed below at least once every 12 months in order to demonstrate compliance with the emissions limits contained in this permit. Periodic testing shall be conducted within 12 months of the prior test with a minimum period of at least one hundred and eighty (180) days apart. In the event it is not feasible to conduct a test at a minimum of at least one hundred and eighty (180) days apart, a written explanation shall be submitted with the test protocol describing the reasons the testing could not be conducted one hundred and eighty (180) days apart. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time (Regulation Number 3, Part B., Section III.G.3) Oxides of Nitrogen using EPA approved methods Carbon Monoxide using EPA approved methods. 59. Point 010: The net heating value of the fuel used in the turbine shall be sampled and analyzed, at a minimum, once per every three months with consecutive samples taken at least two months apart using EPA approved methods. If sampling is performed more often, the quarterly average results of all valid fuel analyses shall be used in the emission calculations. 60. Point 012: On an annual basis, the owner or operator shall complete an extended gas analysis of gas samples that are representative of volatile organic compounds (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas analysis shall be COLORADO Air Pollution Control Division Deaaemera of Public Health 6 En,Ararrnenr Page 33 of 58 i the Emission Limits and Records section of 61. ont 006 1 ` 1: e e ectric g yco pumps may •e 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. The maximum glycol recirculation rate of a replacement pump shall not exceed the glycol recirculation rate as authorized in this permit. 62. Point 006 £t 011: 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. 63. Point 006 Et 011: 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 64. All previous versions of this permit are cancelled upon issuance of this permit. 65. This permit replaces the following permits and/or points, which are cancelled upon issuance of this permit. Existing Permit Number Existing Emission Point New Emission Point GP02 123/9ACB/009 123/9ACB/009 66. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or 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 For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or (COLORADO Air Pollution Control Division Deaarment of Public Health 6 Environment Page 34 of 58 sting x}; EN expires. 4 lendar4-ys of commencing operation of a permanent epl em��� engi ne unn r th alternativ operating scenario outlined in this permit as At includ specific manufacturer, model and serial number and horsepower of the permanent replacement engine, the appropriate APEN filing fee and a cover letter explaining that the permittee is exercising an alternative - operating scenario and is installing a permanent replacement engine. • Point 010: Within 14 calendar days of commencing operation of a permanent replacement turbine under the alternative operating scenario outlined in this permit as Attachment B. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement turbine, the appropriate APEN filing fee and a cover letter explaining that the owner or operator is exercising an alternative -operating scenario and is installing a permanent replacement turbine. Submittal of an updated APEN is also required for replacement of components if such replacement results in a change of serial number. 67. This source is subject to the provisions of Regulation Number 3, Part C, Operating Permits (Title V of the 1990 Federal Clean Air Act Amendments). The application for the Operating Permit is due within one year of the earliest commencement of operation of any piece of equipment covered by this permit. 68. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, VI.B.4/V.A.7.B). 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 P Pollutant Emissions - tons per year Threshold (tPY) current permit limit (tPY) TURB-1 010 Solar Taurus 70-10802S Turbine VOC 100 1.4 D-2 011 88 MMSCFD TEG Dehydrator 21.7 L-1 013 Pressurized Loadout 2.0 PW* 014 Produced water storage vessels 2.2 ___* ___ APEN Exempt Sources 9.73 Notes: COLORADO Air Pollution Control Division Department of Ribiic Hesilth ,=mirC,nme 4 Page 35 of 58 The produced water storage vessels (permit exempt source) and APEN exempt sources do not have permit limits. However, the PTE of these sources is still considered in the project increase when evaluating PSD and NANSR. Fugitives are not included in this evaluation because this facility is not a listed source. 69. Points 001-004 Et 009: MACT Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of that Subpart on the date as stated in the rule as published in the Federal Register. (Regulation Number 8, Part E) 70. Points 006 and 011: MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities major stationary source requirements shall apply to this stationary source at any such time that this stationary source becomes major solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of Subpart HH. (Regulation Number 8, Part E) 71. Point 010: MACT Subpart YYYY - National Emission Standards for Hazardous Air Pollutants for Stationary Combustion Turbines requirements shall apply to this source at any such time that this source becomes a major source of hazardous air pollutants (HAP) solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of that Subpart on the date as stated in the rule as published in the Federal Register. (Regulation Number 8, Part E) GENERAL TERMS AND CONDITIONS 72. 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. 73. 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. 74. 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. 75. 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. 76. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of COLORADO Air Pollution Control Division Departmert of Public Hean & Environment Page 36 of 58 condi . ns imposed upon a permit are contested by kes a • mit, the owner or operator of a source may eview of t - Division's action. 77.hat all es required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 78. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Harrison Slaughter Permit Engineer Permit History Issuance Date Description Issuance 1 November 25, 2013 Issued to DCP Midstream, LP. Newly permitted compressor station with (5) engines, (1) TEG dehydrator and combustor and associated fugitives. Synthetic minor facility. Issuance 2 October 7, 2014 Modification to increase the emission limit on point 007 (fugitives). Also update point 006 to allow for design changes for the dehydrator control device. Issuance 3 February 7, 2017 Removed Point 005: compression engine (C-310). Point was cancelled by DCP Midstream, LP on 10/06/2016. Point 006: Increased annual natural gas throughput limit from 18,250 MMscf to 23,360 MMscf. Updated various operating parameters and recalculated emissions using GLYCaIc. Updated emission limits based on new modeling results. Increased annual VRU downtime from 1% to 5%. Added allowance for 3% downtime of ECD. Removed Point 007: Fugitives. Cancellation request received 05/01/2015; emissions are below APEN thresholds. Issuance 4 This Issuance Issued to DCP Operating Company, LP • Point 006: Remove ECD downtime/venting to atmosphere. Update emission limits using GlyCalc. Update MACT HH requirements. Include waste gas combustion process limits. • Add Waukesha engine covered under point 009 to facility wide permit. Cancel GP02 COLORADO Air Pollution Control Division Department of Public Heath Er Environment Page 37 of 58 coverage. Add one (1) Solar Taurus 70-108025 natural gas fired compression turbine to the facility (point 010). • Add one (1) 88 MMscf/day TEG dehydration unit (point 011). • Add fugitive emissions (point 012) to the permit. • Add pressurized hydrocarbon loadout (point 013) to the permit. Facility is now classified as a major source. COLORADO Air Pollution Control Division Department of Public I { zdth. b Environment Page 38 of 58 Notes 1) Th proc Bing time for this permit. An invoice for these fe��will • ssu of the,�ermi �� issu"�. The per t holder shall pay the invoice within 30 days of nv ilurhe invwill result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (Ib/yr) Controlled Emissions (lb/yr) C-306 001 Formaldehyde 50000 1622 389 Methanol 67561 355 177 Acetaldehyde 75070 323 162 Acrolein 107028 305 152 Benzene 71432 183 92 1,3 -Butadiene 106990 77 38 Toluene 108883 65 32 C-307 002 Formaldehyde 50000 1622 389 Methanol 67561 355 177 Acetaldehyde 75070 323 162 Acrolein 107028 305 152 Benzene 71432 183 92 1,3 -Butadiene 106990 77 38 Toluene 108883 65 32 C-308 • 003 Formaldehyde 50000 1622 389 Methanol 67561 355 177 Acetaldehyde 75070 323 162 Acrolein 107028 305 152 COLORADO Air Pollution Control Division Department .at Public Heath & Zn an; cent Page 39 of 58 enze 432 183 92 1 Buta ene 1 x:6990 77 38 s; , 83 65 32 C-309 004 Formaldehyde 50000 1622 389 Methanol 67561 355 177 Acetaldehyde 75070 323 162 Acrolein 107028 305 152 Benzene 71432 183 92 1,3 -Butadiene 106990 77 38 Toluene 108883 65 32 D-1 006 Benzene 71432 97,204 4,793 Toluene 108883 92,949 4,607 Ethylbenzene 100414 2,729 136 Xylenes 1330207 27,070 1,349 n -Hexane 110543 19,275 686 2,2,4- Trimethylpentane 540841 125 5 Methanol 67561 195 7 C-311 009 Formaldehyde 50000 1,622 389 Methanol 67561 355 177 Acetaldehyde 75070 323 162 Acrolein 107028 305 152 Benzene 71432 183 92 1,3 -Butadiene 106990 77 38 Ethylbenzene 100414 3 1 Toluene 108883 65 32 Xylene 1330207 23 11 TURB-1 010 Formaldehyde 50000 435 435 Acetaldehyde 75070 25 25 Acrolein 107028 4 4 Benzene 71432 8 8 1,3 -Butadiene 106990 1 1 Ethylbenzene 100414 20 20 Toluene 108883 80 80 Xylene 1330207 40 40 COLORADO Air Pollution Control Division of Public. Health h Enr:•onr,nt Page 40 of 58 Xylenes D-2 011 E e 124,465 6,140 116,606 5,781 14 3,428 171 1330207 33,875 1,688 n -Hexane 110543 28,178 1,010 2,2,4- Trimethylpentane 540841 185 7 Methanol 67561 285 11 FUG 012 Benzene 71432 8 8 Toluene 108883 6 6 Ethylbenzene 100414 1 1 Xylenes 1330207 1 1 n -Hexane 110543 56 56 2,2,4- Trimethylpentane 540841 1 1 L-1 013 Benzene 71432 34 34 Toluene 108883 92 92 Ethylbenzene 100414 11 11 Xylenes 1330207 69 69 n -Hexane 110543 260 260 2,2,4- Trimethylpentane 540841 23 23 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in the permit are based on the following emission factors: Points 001-004: CAS Pollutant Emission Uncontrolled lb/MMBtu Factors - g/bhp-hr Emission Factors Ib/MMBtu - Controlled g/bhp-hr N0x 3.6669 13.1000 0.1400 0.5000 CO 3.2750 11.7000 0.2799 1.0000 V0C 0.4199 1.5000 0.1959 0.7000 PM2 5 1.941x10-2 6.93x10-2 1.941x10-2 6.93x10-2 PM10 1.941x10-2 6.93x10-2 1.941x10-2 6.93x10-2 50000 Formaldehyde 0.0140 0.0500 0.0034 0.0120 67561 Methanol 0.0031 0.0109 0.0015 0.0055 75070 Acetaldehyde 0.0028 0.0100 0.0014 0.0050 107028 Acrolein 0.0026 0.0094 0.0013 0.0047 71432 Benzene 0.0016 0.0056 0.0008 0.0028 106990 1,3 -Butadiene 0.0007 0.0024 0.0003 0.0012 108883 Toluene 0.0006 0.0020 0.0003 0.0010 ;COLORADO Air Pollution Control Division Department of Public Health o 'cn+ renment Page 41 of 58 based a:rake-S 0, and eat va sumption Factor of 7,876 Btu/hp-hr, a site -rated scf. AS ant ncontr EF Source Controlled EF Source NOx Manufacturer's specifications Manufacturer's specifications CO Manufacturer's specifications Manufacturer's specifications VOC Manufacturer's specifications Manufacturer's specifications PM2.5 AP -42 Chapter 3 Table 3.2-3 AP -42 Chapter 3 Table 3.2-3 PM10 AP -42 Chapter 3 Table 3.2-3 AP -42 Chapter 3 Table 3.2-3 50000 Formaldehyde Manufacturer's specifications Manufacturer's specifications 67561 Methanol AP -42; Table 3.2-3 (7/2000); Natural Gas Manufacturer's specifications 75070 Acetaldehyde AP -42; Table 3.2-3 (7/2000); Natural Gas Manufacturer's specifications 107028 Acrolein AP -42; Table 3.2-3 (7/2000); Natural Gas Manufacturer's specifications 71432 Benzene AP -42; Table 3.2-3 (7/2000); Natural Gas Manufacturer's specifications 106990 1,3 -Butadiene AP -42; Table 3.2-3 (7/2000); Natural Gas Manufacturer's specifications 108883 Toluene AP -42; Table 3.2-3 (7/2000); Natural Gas Manufacturer's specifications Point 006: The VOC and HAP emission levels contained in this permit are based on information provided in the application and the GRI GlyCalc 4.0 model. Actual controlled VOC and HAP flash tank emissions are based on 100% control efficiency when emissions are routed to the VRU and 95% control efficiency when emissions are routed to the ECD during VRU downtime. The VRU has a maximum of 5% annual downtime. To determine actual flash tank emissions during VRU downtime, the operator will multiply the lb/hr emission rates from the "Flash Tank Off Gas" stream in the GlyCalc model (based on total actual gas throughput during the month) by the total hours of VRU downtime. A 95% control efficiency is applied to this calculation based on the destruction efficiency of the ECD. Actual controlled VOC and HAP still vent emissions are based on a 95% ECD control efficiency. To determine actual still vent emissions, the operator will multiply the lb/hr emission rates from the "Uncontrolled Regenerator Emissions" stream in the GlyCalc model by the total hours of operation. A 95% control efficiency is applied to this calculation based on the destruction efficiency of the ECD. The following table summarizes the control efficiency for each scenario: Control Scenario VOC Control Efficiency Still vent emissions routed to the ECD. 95% Flash tank emissions routed to the VRU and recycled to the plant inlet. 100% Flash tank emissions routed to the ECD during VRU downtime. 95% COLORADO Air Pollution Control Division Departmenk of Public. Hza!th 5 cnrironmert Page 42 of 58 Me anol e t ssle� this s� are b a n a ma = balance. The methanol/alcohol mole % from th �aerlodl `nle� : as ana �z;E speci ith the Hexane mole % in the GlyCalc Wet Gas input strm U�ntr�=le. = tual eth.k�l em.ion rates , - calculated by multiplying the sum of the n - he led Regen ator Emissions" and "Flash Tank Off Gas" s reams in the "y' alc moe .y t e ratio o the me anol/alcohol mole % in the inlet gas to the n - Hexane mole % in the inlet gas. Actual controlled methanol emissions are calculated using the methodologies described above for VOC and HAP. Uncontrolled Methanol (lb) [( Flash Tank n — Hexane rate, lb) Still Vent n — Hexane rate, l6), (m ethanol mole% — + ( * ) hr hr hr n — Hexane mole Combustion Emissions: Total actual NOx and CO emissions are based on the sum of the emissions for the still vent and flash tank controlled by the ECD and the combustion of ECD pilot and assist fuel. Actual volume of waste gas combusted shall be based on the monthly GlyCalc report streams described in the notes beneath each table. Actual heat content of the waste gas stream shall be calculated monthly based on the GlyCalc report streams described in the notes beneath each table. Total combustion emissions are based on the following emission factors: Still Vent Controlled by the ECD: CAS # Pollutant Uncontrolled Emission Factors lb/MMBtu Source NOx 0.068 AP -42 Chapter 13.5 Industrial Flares CO 0.31 Note: The permitted combustion emissions are based on a still vent waste gas heating value of 1,607.4 Btu/scf. Actual emissions are calculated based on the heat content and waste gas flow rate from the "Condenser Vent Stream" in the most recent monthly GlyCalc report and the hours per month the still vent waste gas is routed to the ECD. The heat content is calculated on a monthly basis using the composition of the "Condenser Vent Stream" in the most recent monthly GlyCalc report and the higher heating value of each component. Flash Tank Controlled by the ECD: CAS # Pollutant Uncontrolled Emission Factors lb/MMBtu Source NOx 0.068 AP -42 Chapter 13.5 Industrial Flares CO 0.31 Note: The permitted combustion emissions are based on a flash tank waste gas heating value of 1,529 Btu/scf. Actual emissions are calculated based on the heat content and waste gas flow rate from the "Flash Tank Off Gas Stream" in the most recent monthly GlyCalc report and the hours per month the flash tank waste gas is routed to the ECD. The heat content is calculated on a monthly basis using the composition of the "Flash Tank Off Gas Stream" in the most recent monthly GlyCalc report and the higher heating value of each component. Combustion of ECD Pilot/Assist Fuel: CAS # Pollutant Uncontrolled Emission Factors lb/MMscf Source NOx 78.2 AP -42 Chapter 13.5 Industrial Flares CO 356.5 Note: The permitted combustion emissions are based on a heating value of 1,150 Btu/scf. The pilot fuel and assist gas flow rates are constant. Actual emissions are calculated by multiplying the emissions factors in the table above by the total fuel flow of the pilot gas and assist gas routed to the ECD. Permitted emissions are based on a constant pilot fuel flow rate of 50 scf/hr and a constant assist fuel flow rate of 5,400 scf/hr. Point 009: COLORADO Air Pollution Control Division Department: of Public Health i- Environment Page 43 of 58 S Emi , on Mme, U ontrolled Po utan A lb/MMBt Factors - g/bhp-hr Emission Factors lb/MMBtu - Controlled g/bhp-hr Ox 3.72 13.3 1.4x10-1 0.5 O 3.2: 11.7 2.8x10-1 1.0 VOC 4.2x10-1 1.5 1.96x10-1 0.7 PM2.5 1.941x10-2 6.93x10-2 1.941x10-2 6.93x10-2 PM10 1.941x10-2 6.93x10-2 1.941x10-2 6.93x10-2 50000 Formaldehyde 1.4x10-2 5.0x10-2 3.36x1O3 1.2x10-2 67561 Methanol 3.06x10-3 1.093x10-2 1.53x10-3 5.47x10-3 75070 Acetaldehyde 2.79x10-3 9.97x10-3 1.395x10-3 4.98x103 107028 Acrolein 2.63x10-3 9.396x10-3 1.315x10-3 4.698x10-3 Note: Emission factors are based on a Brake -Specific Fuel Consumption Factor of 7,876 Btu/hp-hr, a site -rated horsepower value of 1,680, and a fuel heat value of 900 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EF Source Controlled EF Source NOx Manufacturer Manufacturer CO Manufacturer Manufacturer VOC Manufacturer Manufacturer PM2.5 AP -42 Chapter 3 Table 3.2-3 AP -42 Chapter 3 Table 3.2-3 PM10 AP -42 Chapter 3 Table 3.2-3 AP -42 Chapter 3 Table 3.2-3 50000 Formaldehyde Manufacturer Manufacturer 67561 Methanol AP -42 Chapter 3 Table 3.2-3 AP -42 Chapter 3 Table 3.2-3 75070 Acetaldehyde AP -42 Chapter 3 Table 3.2-3 AP -42 Chapter 3 Table 3.2-3 107028 Acrolein AP -42 Chapter 3 Table 3.2-3 AP -42 Chapter 3 Table 3.2-3 Point 010: Process 01: Turbine emissions during steady state operations: CAS Pollutant Emission Factors - Uncontrolled Source lb/MMBtu PPM at 15% 02 PM2.5 6.6x10-3 --- AP -42 Chapter 3 Table 3.1-2a PM10 6.6x1O3 --- AP -42 Chapter 3 Table 3.1-2a NOx 5.99x10-2 15 Manufacturer CO 6.08x10-2 25 Manufacturer VOC 2.1x10-3 --- AP -42 Chapter 3 Table 3.1-2a 50000 Formaldehyde 7.1x10-4 --- AP -42 Chapter 3 Table 3.1-3 Note: Emission factors are based on a heat input rate of 69.83 MMBtu/hr, a lower fuel heat value of 908.2 Btu/scf and 8,760 hours of operation a year. Actual emissions shall be calculated by multiplying the lb/MMBtu emission factors in the table above by the actual net (lower) heat value from the most recent quarterly heat content sample and the most recent monthly metered fuel gas volume. Process 02: Turbine start-up emissions CAS Pollutant Emission Factors - Uncontrolled Source lb/event NOx 1.0 Manufacturer CO 88.0 Manufacturer VOC 18.0 Manufacturer (COLORADO Air Pollution Control Division Department of Public Hnal:h & Environment Page 44 of 58 rer pro - emissi ions sh lcula urbin-tart- even a ors for multip rbine start-ups are based on 10 minute start-up ng the emission factor in the table above by the CAS Pollutant Emission Factors - Uncontrolled Source lb/event NOx 1.0 Manufacturer CO 62.0 Manufacturer VOC 8.0 Manufacturer Note: The manufacturer provided emission factors for turbine shutdowns are based on 10 minute shutdown events. Actual emissions shall be calculated by multiplying the emission factor in the table above by the recorded number of turbine shutdown events. Point 011: The VOC and HAP emission levels contained in this permit are based on information provided in the application and the GRI GlyCalc 4.0 model. Actual controlled VOC and HAP flash tank emissions are based on 100% control efficiency when emissions are routed to the VRU and 95% control efficiency when emissions are routed to the ECD during VRU downtime. The VRU has a maximum of 5% annual downtime. To determine actual flash tank emissions during VRU downtime, the operator will multiply the lb/hr emission rates from the "Flash Tank Off Gas" stream in the GlyCalc model (based on total actual gas throughput during the month) by the total hours of VRU downtime. A 95% control efficiency is applied to this calculation based on the destruction efficiency of the ECD. Actual controlled VOC and HAP still vent emissions are based on a 95% ECD control efficiency. To determine actual still vent emissions, the operator will multiply the lb/hr emission rates from the "Uncontrolled Regenerator Emissions" stream in the GlyCalc model by the total hours of operation. A 95% control efficiency is applied to this calculation based on the destruction efficiency of the ECD. The following table summarizes the control efficiency for each scenario: Control Scenario VOC Control Efficiency Still vent emissions routed to the ECD. 95% Flash tank emissions routed to the VRU and recycled to the plant inlet. 100% Flash tank emissions routed to the ECD during VRU downtime. 95% Methanol emissions from this source are based on a mass balance. The methanol/alcohol mole % from the periodic inlet wet gas analysis is specified with the n -Hexane mole % in the GlyCalc Wet Gas input stream. Uncontrolled actual methanol emission rates are calculated by multiplying the sum of the n - hexane lb/hour rate from the "Uncontrolled Regenerator Emissions" and "Flash Tank Off Gas" streams in the GlyCalc model by the ratio of the methanol/alcohol mole % in the inlet gas to the n - Hexane mole % in the inlet gas. Actual controlled methanol emissions are calculated using the methodologies described above for VOC and HAP. lb Flash Tank n — Hexane rate, lb) Still Vent n — Hexane rate, lb)] ( methanol mole% Uncontrolled Methanol ( ) _ [(Flash ( hr hr hr n — Hexane mole ) Combustion Emissions: Total actual NOx and CO emissions are based on the sum of the emissions for the still vent and flash tank controlled by the ECD and the combustion of ECD pilot and assist fuel. Actual volume of waste gas combusted shall be based on the monthly GlyCalc report streams described in the notes beneath each table. Actual heat content of the waste gas stream shall be calculated monthly based on the GlyCalc CDPHE COLORADO Air Pollution Control Division Department of Public: Heath & Environment Page 45 of 58 le. Total combustion emissions are based on the CAS # Pollutant — ncontrolle Emission Factors lb/MMBtu Source NOx 0.068 AP -42 Chapter 13.5 Industrial Flares CO 0.31 Note: The permitted combustion emissions are based on a still vent waste gas heating value of 1,566 Btu/scf. Actual emissions are calculated based on the heat content and waste gas flow rate from the "Condenser Vent Stream" in the most recent monthly GlyCalc report and the hours per month the still vent waste gas is routed to the ECD. The heat content is calculated on a monthly basis using the composition of the "Condenser Vent Stream" in the most recent monthly GlyCalc report and the higher heating value of each component. Flash Tank Controlled by the ECD: CAS # Pollutant Uncontrolled Emission Factors lb/MMBtu Source NOx 0.068 AP -42 Chapter 13.5 Industrial Flares CO 0.31 Note: The permitted combustion emissions are based on a flash tank waste gas heating value of 1,522.1 Btu/scf. Actual emissions are calculated based on the heat content and waste gas flow rate from the "Flash Tank Off Gas Stream" in the most recent monthly GlyCalc report and the hours per month the flash tank waste gas is routed to the ECD. The heat content is calculated on a monthly basis using the composition of the "Flash Tank Off Gas Stream" in the most recent monthly GlyCalc report and the higher heating value of each component. Combustion of ECD Pilot/Assist Fuel: CAS # Pollutant Uncontrolled Emission Factors lb/MMscf Source NOx 78.2 AP -42 Chapter 13.5 Industrial Flares , CO 356.5 Note: The permitted combustion emissions are based on a heating value of 1,150 Btu/scf. The pilot fuel and assist gas flow rates are constant. Actual emissions are calculated by multiplying the emissions factors in the table above by the total fuel flow of the pilot gas and assist gas routed to the ECD. Permitted emissions are based on a constant pilot fuel flow rate of 50 scf/hr and a constant assist fuel flow rate of 5,400 scf/hr. Point 012: Component Gas Service Heavy Oil Light Oil SWater/Oil ervi Service Connectors 650 --- 7,390 --- Flanges 153 --- 1,175 --- Open-ended Lines 0 --- 0 --- Pump Seals 1 --- 15 --- Valves 293 --- 2,397 - 0ther* 20 --- 72 --- VOC Content (wt. %) 28.7 --- 100 --- Benzene Content (wt. %) 0.0508 --- 0.177 -- Toluene Content (wt. %) 0.0386 --- 0.134 --- Ethylbenzene (wt. %) 0.000941 --- 0.00328 --- Xylenes Content (wt. %) 0.00711 --- 0.0248 --- n-hexane Content (wt. %) 0.392 --- 1.367 --- 2,2,4-Trimethylpentane Content (wt. %) 0.00366 0.0128 COLORADO Air Pollution Control Division Department cI Public Health & Enrroninenr Page 46 of 58 ludes essors, t meteh rods valves, relief valves, diaphragms, drains, dump omponent as ervice Heavy I1 Light Oil Water/Oil Service Connectors 1.0E-05 7.5E-06 9.7E-06 1.0E-05 Flanges 5.7E-06 3.9E-07 2.4E-06 2.9E-06 Open-ended Lines 1.5E-05 7.2E-06 1.4E-05 3.5E-06 Pump Seals 3.5E=04 NA 5.1E-04 2.4E-05 Valves 2.5E-05 8.4E-06 1.9E-05 9.7E-06 Other 1.2E-04 3.2E-05 1.1E-04 5.9E-05 Source: EPA -453/R95-017 Table 2-8 Note that the emission limits included in this permit are derived by multiplying the equipment counts in the table above by a factor of 1.5 to accommodate other minor changes to the facility and to provide a conservative estimate of facility -wide emissions. Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors listed in the table above with representative component counts, multiplied by the VOC content from the most recent gas analysis. Point 013: CAS # Pollutant Uncontrolled Emission Factors lb/loadout Source VOC 1.0552 Engineering Calculation 110543 n -Hexane 6.96x10 -z Engineering Calculation Note: Emission factors are based on liquid and vapor line volumes of 0.0218 ft3/loadout venting directly to atmosphere. Actual emissions shall be calculated by multiplying the number of loadout events by the emission factors in the table above. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692- 3150. 7) Points 001-004 & 009: Each engine is subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal Register posting - effective March 18, 2008). This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA website at: http://www.epa.gov/ttn/atw/area/fr18ja08.pdf 8) Points 001-004 a 009: Each engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January 18, 2008 Federal Register posting - effective March 18, 2008). The January 18, 2008 amendments to include requirements for area sources and engines < 500 hp located at major sources have not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 8. A copy of the complete subpart is available on the EPA website at: http://www.epa.gov/ttn/atw/area/fr18ja08.pdf Additional information regarding area source standards can be found on the EPA website at: http://www.epa.gov/ttn/atw/area/arearules.html COLORADO Air Pollution Control Division Department; nt Public Heath E Environment Page 47 of 58 9) Po Cr Co 2 _' his s subj 40 C Pert 60, d l Gash Dies f ich C aft ` Se « -mbe18, A# 5 (S June 3, 21 orated in part 0000a - Standards of Performance for struction, Modification, or Reconstruction Federal Register posting - effective August Colorado Air Quality Control Commission's e• u a ion Num ier' 6. copy o e comp ete supar" is available at the Office of the Federal Register website at: https://www.federalregister.gov/documents/2016/06/03/2016-11971 /oil -and - natural -gas -sector -emission -standards -for -new -reconstructed -and -modified -sources 10) This permit fulfills the requirement to hold a valid permit reflecting the glycol dehydration unit and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(B) when applicable. 11) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: NOx, benzene, toluene, xylene, n -Hexane a Total HAPs Major Source of: VOC a CO NANSR Synthetic Minor Source of: NOx Major Source of: VOC PSD Synthetic Minor Source of: VOC, NOx and CO MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Applicable MACT HHH Not applicable MACT ZZZZ Major Source Requirements: Not Applicable Area Source Requirements: Applicable MACT YYYY Not applicable NSPS GG Not applicable NSPS KKKK Applicable to point 010 NSPS KKK Not applicable NSPS JJJJ Applicable to points 001-004 a 009 NSPS OOOO Applicable to point 012 (reciprocating compressors) NSPS 0000a Applicable to point 012 12) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ COLOR ADO Air Pollution Control Division Deportment of Pubic himith & Erwirunoteol Page 48 of 58 60 -En 0, xes Sub :rt A - Sub rt KKKK ix A - . `'{ dix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division Department of Public Health& Env ronmont Page 49 of 58 MEN A. PERATI G SCENARIOS IN AL a BUSTION ENGINES October 12, 2012 2. Alternative Operating Scenarios The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility -Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS, and the owner or operator shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with an engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month period. "Permanent" is defined as in the same service for more than 90 operating days in any 12 month period. The 90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90 day total. The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit. All replacement engines are subject to all federally applicable and state -only requirements set forth in this permit (including monitoring and record keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5) years and made available to the Division upon request. The owner or operator shalt maintain a log on -site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make them available to the Division upon request. 2.1.1 The owner or operator may temporarily replace an existing engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other requirements applicable to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. ;COLORADO Air Pollution Control Division Department of Ribtic Heatin & Environment Page 50 of 58 2.1 .2 xisting engine with another engine with the same ::nufac l er "e el, an. =,b powe engines w out modifying this permit so long as the perma a nt rep,k4`ce �._nt •ine•mpl with permit itations and other requirements applicable to the :-xi ' a en a ;:we as a ne a • plicable equirements for the replacement engine. Measurement of emissions .m e permanen replacemen engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found at https://www.colorado.gov/pacific/cdphe/alternate-operating-scenario-aos- reporting-forms. This submittal shall be accompanied by a certification from the Responsible Official indicating that "based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at: https://www.colorado.gov/pacific/sites/default/files/AP Portable -Analyzer -Monitoring -Protocol. pdf Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever applies. COLORADO Air Pollution Control Division Department of Pubiic Health & Environmen.[. Page 51 of 58 For co conce engine in the ith ed .je ntio -term vd ® 1 to, e re ,iy Its o d Pabl Anal hat is r inpu that t isting he t shall be c r Mop toring Pro ased (lb/mmBtu), output based (g/hp-hr) or t is currently subject to or the replacement verted to the appropriate units as described of document. If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline. 2.3 Applicable Regulations for Permanent Engine Replacements 2.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B § II.D.2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and to NOX and SO2, as precursors to PM10, if the potential to emit of NOX or 5O2 exceeds 40 tons/yr. For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating internal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOX: The emission limitations in NSPS JJJJ 5O2: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (5 60.331) and 40 CFR Part 72 (S 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State - Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified below: Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non -selective catalyst and air fuel controller to reduce emission. Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. ;COLORADO Air Pollution Control Division Department of Public Health b Environment Page 52 of 58 y sized for the engine and shall be operated The sources all su:`mi copies'o he re'evanpplicabi iAy'eports required under Condition 2.1.2. Emission Standards: Section XVII.E - State -only requirements Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Max Engine HP Construction or Relocation Date Emission Standards in G/hp-hr NOx CO VOC January 1, 2008 2.0 4.0 1.0 100<Hp<500 January 1, 2011 1.0 2.0 0.7 500≤Hp July 1, 2007 July 1, 2010 2.0 1.0 4.0 2.0 1.0 0.7 The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. 2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ requirements). However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part 8, § 1.8 (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. 2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting (COLORADO Air Pollution Control Division Department cif Public Health b Environment Page 53 of 58 requir requir AOS. N Condit time arse specifie 2.4 Additional Sources e re' ing r y th the - ent s uldbyt CT can s 'vision, pr ll be included in the Applicability Reports MACT is in addition to that required by this e as the testing required by this AOS under ided that such test is conducted within the The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site; an engine that is being installed as an entirely new emission point and not as part of an AOS- approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. !COLORADO Air Pollution Control Division Department of Public Health & Environment Page 54 of 58 August 16, 2011 MEN W B: P RATI SCENARIOS 2_s 0 caq NUOa4, ISSIONS MONITORING 1. Routine Turbine Component Replacements The following physical or operational changes to the turbines in this permit are not considered a modification for purposes of NSPS GG, major stationary source NSR/PSD, or Regulation No. 3, Part B. Note that the component replacement provisions apply ONLY to those turbines subject to NSPS 6G. Neither pre-GG turbines nor post GG turbines (i.e. KKKK turbines) can use those provisions. 1) Replacement of stator blades, turbine nozzles, turbine buckets, fuel nozzles, combustion chambers, seals, and shaft packings, provided that they are of the same design as the original. 2) Changes in the type or grade of fuel used, if the original gas turbine installation, fuel nozzles, etc. were designed for its use. 3) An increase in the hours of operation (unless limited by a permit condition) 4) Variations in operating loads within the engine design specification. 5) Any physical change constituting routine maintenance, repair, or replacement. Turbines undergoing any of the above changes are subject to all federally applicable and state only requirements set forth in this permit (including monitoring and record keeping). If replacement of any of the components listed in (1) or (5) above results in a change in serial number for the turbine, a letter explaining the action as well as a revised APEN and appropriate filing fee shall be submitted to the Division within 30 days of the replacement. Note that the repair or replacement of components must be of genuinely the same design. Except in accordance with the Alternate Operating Scenario set forth below, the Division does not consider that this allows for the entire replacement (or reconstruction) of an existing turbine with an identical new one or one similar in design or function. Rather, the Division considers the repair or replacements to encompass the repair or replacement of components at a turbine with the same (or functionally similar) components. 2. Alternative Operating Scenarios The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of combustion turbines and turbine components has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility- Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any turbine or turbine component replacement performed in accordance with this AOS, and the owner or operator shall be allowed to perform such turbine or turbine component replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Turbine Replacement The following AOS is incorporated into this permit in order to deal with a turbine breakdown or periodic routine maintenance and repair of an existing onsite turbine that requires the use of a temporary replacement turbine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month period. "Permanent" is defined as in the same service for more than 90 operating days in any 12 month period. The 90 days is the total number of days that the turbine is in operation. If the turbine operates only part of a day, that day shall count as a single day towards the 90 -day total. The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit. 'COLORADO Air Pollution Control Division Department of Public bleabh Er Environment Page 55 of 58 suit in the replacement turbine being considered e subject to all applicable requirements of that mance Testing. All replacement turbines are subject to all federally applicable and state -only requirements set forth in this permit (including monitoring and record keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with the NSPS requirements. Results of all tests shall be kept on site for five (5) years and made available to the Division upon request. The owner or operator shall maintain a log on -site and contemporaneously record the start and stop date of any turbine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the turbine (s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement turbine. 2.1.1 The owner or operator may temporarily replace an existing turbine that is covered by this permit with a turbine that is the exact same make and model as the existing turbine without modifying this permit, so long as the temporary replacement turbine complies with the emission limitations for the existing permitted turbine and other requirements applicable to the original turbine. Measurement of emissions from the temporary replacement turbine shall be made as set forth in section 2.2. 2.1.2 The owner or operator may permanently replace the existing turbine that is covered by this permit with a turbine that is the exact same make and model as the existing turbine without modifying this permit so long as the permanent replacement turbine complies with the emission limitations and other requirements applicable to the original turbine as well as any new applicable requirements for the replacement turbine. Measurement of emissions from the temporary replacement turbine shall be made as set forth in section 2.2. 2.1.3 An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement turbine shall be filed with the Division for the permanent replacement turbine within 14 calendar days of commencing operation of the replacement turbine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement turbine. This AOS cannot be used for permanent turbine replacement of a grandfathered or permit exempt turbine or a turbine that is not subject to emission limits. The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent turbine replacement. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement turbine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement turbine. COLORADO Air Pollution Control Division Department of Poetic Health 5 6rnnronrner, Page 56 of 58 shall • conducted using the most current version of the found the Division's website. Results of the portable is ce stat of this unit. Ft� ison ons rt ter nit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever applies. For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement turbine will be subject to, the results of the test shall be converted to the appropriate units as described in the above - mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the turbine is in compliance with both the NOX and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the turbine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or until the turbine is taken offline. 2.3 Applicable Regulations for Permanent Turbine Replacements 2.3.1 NSPS for Stationary Gas Turbines: 40 CFR 60, Subpart GG §60.330 Applicability and designation of affected facility. (a) The provisions of this subpart are applicable to the following affected facilities: Alt stationary gas turbines with a heat input at peak load equal to or greater than 10.7 gigajoules (10 million Btu) per hour, based on the lower heating value of the fuel fired. (b) Any facility under paragraph (a) of this section which commences construction, modification, or reconstruction after October 3, 1977, is subject to the requirements of this part except as provided in paragraphs (e) and (j) of §60.332. A Subpart GG applicability determination as well as an analysis of applicable Subpart GG monitoring, recordkeeping, and reporting requirements for the permanent turbine replacement shall be included in any request for a permanent turbine replacement Note that under the provisions of Regulation No. 6. Part B, Section I.B. that Relocation of a source from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the commence construction date for purposes of determining the applicability of NSPS GG requirements). 2.3.2 NSPS for Stationary Combustion Turbines: 40 CFR 60, Subpart KKKK §60.4305 Does this subpart apply to my stationary combustion turbine? (a) If you are the owner or operator of a stationary combustion turbine with a heat input at peak load equal to or greater than 10.7 gigajoules (10 MMBtu) per hour, based on the higher heating value of the fuel, which commenced construction, modification, or reconstruction after February 18, 2005, your turbine is subject to this subpart. Only heat input to the combustion turbine should be included when determining whether or not this subpart is applicable to your turbine. Any additional heat input to associated heat recovery steam generators (HRSG) or duct burners should not be included when determining your peak heat input. However, this subpart does apply to emissions from any associated HRSG and duct burners. COLORADO Air Pollution Control Division Department of Public Health b En•rrorraent Page 57 of 58 under is subpart are exempt from the requirements of genera rs and duct burners regulated under this subpart ubparts Da, ., and Dc of this part. par ap p h ' th y d as well : : nalysis of applicable Subpart KKKK monitoring, recordkeeping, and reporting requirements for the permanent turbine replacement shall be included in any request for a permanent turbine replacement Note that under the provisions of Regulation No. 6. Part B, Section I.B. that Relocation of a source from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the commence construction date for purposes of determining the applicability of NSPS KKKK requirements). 2.4 Additional Sources The replacement of an existing turbine with a new turbine is viewed by the Division as the installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site; a turbine that is being installed as an entirely new emission point and not as part of an AOS-approved replacement of an existing onsite turbine has to go through the appropriate Construction/Operating permitting process prior to installation. COLORADO Air Pollution Control Division Deparcmsr of Public Health 6 cnvnronTnenr Page 58 of 58 Glycol Dehydration Unit APEN - Form Alt -D -S2 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for Glycol Dehydration (Dehy) Units only. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 -days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 13WE1108 AIRS ID Number: 123 / 9ACB / 006 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification: D-1 [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': DCP Operating Company, LP Site Name: Troudt Compressor Station Site Location: SENW Sec. 27, T6N, R66W Mailing Address: 370 17th Street, Suite 2500 (Include Zip Code) Denver, CO 80202 E -Mail Address2: RShankaran@DCPMidstream.com Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Roshini Shankaran Phone Number: 303-605-2039 1Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 22 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-202 - Glycol Dehydration Unit APEN - Revision 02/2017 381847 1 I �'COLORADO Hr�i.h6 F�ifvl�anm N Permit Number: 13WE1108 AIRS ID Number: 123 / 9ACH 006 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action O NEW permit OR newly -reported emission source -OR - O MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment ❑ Change company name ❑ Add point to existing permit ❑� Change permit Limit O Transfer of ownership3 ❑ Other (describe below) OR- ❑ APEN submittal for update only (Please note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ID Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info & Notes: IRcw\OU Enclosed Combustor (ECD) downtime. Adjusted GLYCaIc Run. 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. ����,twL •?c J`k0..C1;-A calck)k.a t9IA-S. 0312-4 l"\ Section 3 - General Information General description of equipment and purpose: TEG dehydration unit for water removal Facility equipment Identification: For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: D-1 - TEG Dehydration Unit 4 / 27 /2015 / / ❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day days/week weeks/year Will this equipment be operated in any NAAQS nonattainment 0 Yes ❑ No area Is this unit located at a stationary source that is considered a ❑ Yes 0 No Major Source of (HAP) Emissions Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 �{ COLORADO 2 I VGVii pcpuoecmdl,m.n HYvh 6 Encwnm��u Permit Number: 13WE1108 AIRS ID Number: 123 I 9ACff 006 ? 0\-15.0 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Dehydration Unit Equipment Information Manufacturer: Dehydrator Serial • Number: Glycol Used: Oxlean r r' (o"\ Model Number: LO$ Ethylene Glycol (EG) Reboiler Rating: 2.86 MMBTU /hr DiEthylene Glycol (DEG) Glycol Pump Drive: Electric ❑ Gas If Gas, injection pump ratio: Pump Make and Model: 1 primary, 1 backup Glycol Recirculation rate (gal/min): Lean Glycol Water Content: 1.0 Max: 18.0 . Wt.% • TriEthylene Glycol (TEG ) # of pumps: Requested: 18.0 . Acfm/gpm 2 Dehydrator Gas Throughput: Design Capacity: 64.0 MMSCF/day • Requested: 23,360 MMSCF/year. Actual: 17,783.14 MMSCF/year Inlet Gas: Pressure: 950 . Water Content: Wet Gas: Flash Tank: Pressure: 60 • Cold Separator: Pressure: Stripping Gas: (check one) ❑ None ❑ Flash Gas Flow Rate: psig lb/MMSCF psig psig O Dry Gas ❑ Nitrogen scfm Temperature: 100 • Saturated Dry gas: Temperature: Temperature: 120 ' °F 5.0 • lb/MMSCF °F O NA °F❑ NA Additional Required Information: El Attach a Process Flow Diagram ❑✓ Attach GRI-GLYCaIc 4.0 Input Report Et Aggregate Report (or equivalent simulation report/test results) ❑✓ Attach the extended gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 ©© COLORADO 3 I L-1 ' d Hulls 6 Eev4enm•N Permit Number: 13WE1108 AIRS ID Number: 123 /9ACii 006 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information eograpficalCoordinates LatitudelLong rude or U_TM)_ 40.461 / -104.766 -: eperator St C D11b D�schar�. e� h - ove Ground e e _ Feet f ; ,.ter �T�p �� �� a, Velocity (ft7sec Flow Rate ACFM) D-1 30.0 Indicate the direction of the stack outlet: (check one) ❑ Downward ❑ Other (describe): ❑✓ Upward ❑ Horizontal Indicate the stack opening and size: (check one) ❑ Upward with obstructing raincap ✓❑ Circular Interior stack diameter (inches): 40.0 ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 4 I COLORADO o.p+.wualdtacuk Fu1N 6 EnvFvnme.0 Permit Number: 13WE1108 AIRS ID Number: 123 /9ACei 006 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information ❑ Condenser: Used for control of: Type: Make/Model: Maximum Temp Average Temp Requested Control Efficiency ❑✓ VRU: Used for control of: Flash Tank Vapors Size: Make/Model: Requested Control Efficiency 1 00.0 % VRU Downtime or Bypassed 5.0 ❑ Combustion Device: * Used for control of: Still Vent Stream Rating: MMBtu/hr Type: Enclosed Combustor Make/Model: John Zink / FBF ZTOF040X30PF Requested Control Efficiency: 95.0 % Manufacturer Guaranteed Control Efficiency 98.0 % Minimum Temperature: Waste Gas Heat Content 1k.0d-1,\ Btu/scf Constant Pilot Light: 0 Yes ❑ No Pilot burner Rating 0.06 MMBtu/hr Closed ❑ Loop System: Used for control of: Description: System Downtime 0 p Other: Used for control of: Flash Tank Vapors during VRU downtime (5.0%) Description: ECD Combustion Device Control Efficiency of Requested 95.0 0 Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 -. NOS 6I28111 �� COLORADO 5 �� HUW 6EnamnmW Permit Number: 13WE1108 AIRS ID Number: 123 / 9ACii 006 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions?' ❑✓ Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency (% reduction): PM verallRegluested Confrol SO, NO, CO VOC HAPs Other: Vapor Recovery Unit / Enclosed Combustor Vapor Recovery Unit / Enclosed Combustor lcoyo/ 95% aft] 95% From what year is the following reported actual annual emissions data? 2017 Use the following table to report the criteria pollutant emissions from source: Pollutant .. Uncontrolled Emission Factor - _ _ Emission Factor Units _ Emts5on Factor Source (Ap-42 ", Mfg etch. ' '�� c ua nn a Emissions �` Requested(al Permit �� trig" d " E IssionLimit(s) Uncontrolled - _. (Tons/year) _• Controlled5 (Tonslyear) Uncontrolled = (Tgns/yearf. Controlled:" (Tons/year) . PM SO,, NO, 0.068 • lb/MMBtu AP -42 0.23 0.23 2.28 , 2.28' CO 0.31 - Ib/MMBtu AP -42 1.08 1.08 10.38 , 10.38 ' VOC 41.85. Ib/MMscf GLYCaIc., 125.16 3.70 488.82 • pin Benzene 4.16 • lb/MMscf GLYCaIc 11.14 0.55 48.60 • Z.y Toluene 3.98 • lb/MMscf GLYCaIc 10.10 0.50 46.47- Z•3 Ethylbenzene 0.12 • lb/MMscf GLYCaIc 0.28 0.01 1.36 . O.O1- Xylenes 1.16 - lb/MMscf GLYCaIc 2.96 0.15 13.53 • 0.0( n -Hexane 0.83- lb/MMscf GLYCaIc 2.28 0.09 9.64 • 0,'Sq 2,2,4- Trimethylpentane 0.005 • lb/MMscf GLYCaIc -- -- 0.06 I o.cdZ Other: Wit- o\ 0.00?› btMr‘sc.c 1%,..°'5kt,_,Acc 0.1 0.014 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 5Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 JpdtCkz 8, C-9.Cco1aa S, COLORADO 6 I ��ii acpa.�v�d forma H•lLI16 Fmtimnm. Permit Number: 13WE1108 AIRS ID Number: 123 /9ACE' 006 [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/i J2Of Signature of Legally Authorized Person (not a vendor or consultant) Roshini Shankaran Date Senior Environmental Engineti Name (please print) Title Check the appropriate box to request a copy of the: Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) Send this form along with $152.90 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 7I COLORADO dP & Hut 6 Envlmnmnnt Reciprocating Internal Combustion Engine APEN - Form APCD-201 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of thjs APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for reciprocating internal combustion engines (RICE). If your engine is a diesel compression ignition engine or your emission unit does not fall into the RICE category, there may be a more specific APEN for your source (e.g. diesel compression ignition engine, mining operations, asphalt plant, crusher, screen, 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: 13WE1108 F ECEIV l:l) MAY t a 2018 APCD Stations s AIRS ID Number: 123 /9AC%/009 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Site Name: DCP Operating Company, LP Troudt Compressor Station Site Location: SENW Sec. 27, T6N, R66W Mailing Address: (Include zip code) 370 17th Street Suite 2500 Portable Source Home Base: Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Phone Number: E -Mail Address2: Roshini Shankaran 303.-605-2039 . 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 APCD via e-mail to the address provided. Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 3slos COLORADO 1 l .. H..nnsa.menm.a Permit Number: 13WE 1108 AIRS ID Number: 123 /9ACg/ 009 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source (check one below) ❑ STATIONARY source ❑ PORTABLE source ❑ Request coverage under a Construction Permit ❑ Request coverage under General Permit GP023 (Natural Gas Only) If General Permit coverage is requested, the General Permit registration fee of $1,500.00 must be submitted along with the APEN Filing fee. -OR - Q MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ✓❑ Add point to existing permit O Change permit limit ❑ Transfer of ownership' ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ APEN submittal for permit-exempt/grandfathered source O Notification of Alternate Operating Scenario (AOS) permanent replacements Additional Info a Notes: Remove engine C-311 from GP02 coverage, add to individual permit 3 Only one engine may be reported per APEN for GP02 coverage. Coverage under GP02 is voluntary. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. 5 This does not apply to General Permit GP02, as it does not contain a provision for AOS permanent replacements. Section 3 - General Information Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3, etc)? Yes If yes, provide the Company Equipment Identification No. C-311 General description of equipment and purpose: natural gas compression For existing sources, operation began on: 6/21/2017 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? (http: / /www.colorado. gov/cdphe/attainment) Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year r❑ Yes ❑ No Seasonal use percentage: Dec -Feb: 25% Mar -May: 25% June -Aug: 25% Sept -Nov: 25% Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 COLORADO 2 I AY ` n.vmmemr�u� FuhF 6 FnNronm�M Permit Number: 13WE 1108 AIRS ID Number: 123 /9ACiii/ 009 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Engine Information Engine Function: ❑ Primary and/or Peaking ❑ Pump ❑ Water Pump ❑ Emergency Back-up ❑ Other: 0 Compression What is the maximum number of hours this engine will be used for emergency back-up power? hours/year Engine Make: Waukesha Engine Model: L7044 GSI Serial Number': 5283704513 What is the maximum designed horsepower rating? 1,680 hp What is the engine displacement? 9.58 l/cyl What is the maximum manufacturer's site -rating? 1,680 hp kW What is the engine Brake Specific Fuel Consumption at 100% Load? 7,876 BTU/hp-hr Engine Features: Cycle Type:. ❑ 2 -Stroke 0 4 -Stroke Combustion: ❑ Lean Burn 0 Rich Burn Ignition Source: 0 Spark O Compression Aspiration: ❑ Natural 0 Turbocharged Is this engine equipped with an Air/Fuel ratio controller (AFRC)? 0 Yes O No If yes, what type of AFRC is in use? 0 Oz Sensor (mV) ONOx Sensor (ppm) Is this engine equipped with a Low-NOx design? ❑ Yes 0 No Engine Dates: What is the manufactured date of this engine? 02/2015 O Other: What date was this engine ordered? 02/11/2015 What is the date this engine was first located to Colorado? 6/21/2017 What is the date this engine was first placed in service/operation? 6/21/2017 What is the date this engine commenced construction? 02/11/2015 What is the date this engine was last reconstructed or modified? Is this APEN reporting an AOS replacement engine? O Yes 0 No If yes, provide the make, model, and serial number of the old engine below: Engine Make: Engine Model: Serial Number: 6 The serial number must be submitted if coverage under GP02 is requested. Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 3�� Departmcotaltahtic COLORADO Matt. TryIron... Permit Number: 13WE1108 AIRS ID Number: 123 /9ACg/ 009 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information `ograph cal Cooi dada (Latrtudel oneitude'orUT 40.461 / -104.766 N- -`# operato at ® mi.s�.,.:.,r-." -..r 'ifrt�?' a �" r Disc at e4NeAt Above G oinnd Leve F 'tcF :"'-'-m_ `YF^ k, a"u. -$ �� 7e p � -�+'3';v .Y�".,. l -rr . per`." �4 FLo�v/ Rate (�clt e_. C-311 45.0 1,152 8,995 140 Indicate the direction of the Stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular 0 Square/Rectangle ❑ Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap 14.0 Interior stack diameter (inches): Interior stack depth (inches): Section 6 - Fuel Data and Throughput Information Fuel Use Rate @1 OO% -oa , tCF//hour AetuaCArinuaLFue Us k LMMSCF eat< ,- Requested Annual Pur it LUmtt1 - M ScF year 14,702.2 50.32 128.8 From what year is the actual annual amount? 2017 Indicate the type of fuel used$: ❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf) ❑ Field Natural Gas Heating value: BTU/scf 0 Propane (assumed fuel heating value of 2,300 BTU/scf) ❑ Landfill Gas Heating Value: BTU/scf p Other (describe): Residue Gas Heating Value (give units): c\cx} BTU/scf 7 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 8 If fuel heating value is different than the listed assumed value, provide this information in the "Other" field. Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 COLORADO 4 I /Mr > 6.:► AUIW 6FnNtenmN Permit Number: 13WE1108 AIRS ID Number: 123 /9AC/009 [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. The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission calculations. Is any emission control equipment or practice used to reduce emissions? ❑r Yes ❑ No If yes, describe the control equipment AND state the overall control efficiency (% reduction): _ _._:-- ' Pollutant::: -: ..�.- •: •.:. - - -•.::. :- _::::=__:-::,.;.-._,:>-:-�Y. _-.--- .:.-..:•...:._:-_ :.:. =::.=_:::: Prima Control Equipment Description:::_ �, .. - ; , ;; - . _ •,::--::-0vera l Re4nested Gohtro _ :.-= fficienc ` _ -- (9K ieductf n in emissions TSP (PM) PM10 PM2.5 SOX NO NSCR 96% VOC NSCR 53% CO NSCR 91% Other: NSCR Formaldehyde - 76%, Other HAPs - 50% Use the following tables to report criteria and non -criteria pollutant emissions from source: (Use the data reported in Section 6 to calculate these emissions.) From what year is the following reported actual annual emissions data? 2017 riteria: Pollutant; Emissions nventoryi TSP (PM) 0.53 . 1.94E-02- lb/MMBtu AP -42 ctualAnnual Emissions �ontoiled ='== Emissions Tonslyear) 1.12 , 1.12 - uested`;Annual,:Perri mission Limit(s)7 0.53 . PM10 PM2.5 1.94E-02 - lb/MMBtu AP -42 0.53 0.53 . 1.12 - 1.12 • 1.94E-02 - lb/MMBtu AP -42 0.53 • 0.53 • 1.12 - 1.12 • SOX NOx VOC 5.88E-04 • lb/MMBtu AP -42 0.02 . 0.02 0.03 0.03 49ht`.`S 1.5 gThp-hr g/hp-hr Mfg. Mfg. 99,85 t�l.S 11.43 . 3.81 5.34 • -242:52 Lt c.2, 24.33 ' 8.11 11.36 • CO 11.7 - g/hp-hr Mfg. . 89.18 . 7.62 189.80 • 16.22 • Does the emissions source have any uncontrolled actual emissions of non -criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? If yes, please use the following table to report the non -criteria pollutant (HAP) emissions from source: ElYes No Formaldehyde 50000 lb/MM Btu NoneGntena,Repo able Pellui:an-tEmissions Inventory _ missionfactor-= '__-Source="- Mfg:etc): - "= ActuaLAonuaLEmissions=- 762.43 ` 182.98 . 0.014 Mfg. Acetaldehyde 75070 107028 Acrolein Benzene 71432 Other: u,...t-s rt.," e vl^-eu \ • 7 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 441 9 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 COLORADO 5 I Av n.pummorrwuc HwIN bEnWa,uruN Permit Number: 13WE1108 AIRS ID Number: 123 /9AC6/ 009 [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 GP02, I further certify that this source is and will be operated in full compliance with each condition of general permit GP02. 5lolzoig Signature of Legally Authorized Person (not a vendor or consultant) Date Roshini Shankaran Senior Environmental Engineer Name (please print) Title Check the appropriate box to request a copy of the: El 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 $152.90 and the General Permit registration fee of $1,500, 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 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: Make check payable to: https://www.colorado.gov/cdphe/apcd Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 LI COLORADO 6 I o.p..ttd,�� N..iur, [,.m.m k�Y1 7'`f�7, General APEN - Form APCD-2 13'0„/-) 9 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. There may be a more specific APEN for your source (e.g. paint booths, mining operations, engines, etc.). A list of specialty APENs is available on the Air Pollution Control Division (APCD) website at: www.colorado.Rov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 13WE1108 AIRS ID Number: 123 /9ACB/ / 010 [Leave blank unless APCD has already assigned a permit # and AIRSID] Section 1 - Administrative Information Company Name': Site Name: DCP Operating Company, LP Troudt Compressor Station Site Location: SENW Sec. 27, T6N, R66W Mailing Address: (Include Zip code) 370 17th Street, Suite 2500 Portable Source Home Base: Denver, CO 80202 Site Location Weld County: NAICS or SIC Code: 1311 Permit Contact: 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 APCD via e-mail to the address provided. 381845 Form APCD-200 - General APEN - Revision 1/2017 1 AV COLORADO DepameeetdhSlic H.al,hB EnvlmemvM Permit Number: 13WE1108 1 1 08 AIRS ID Number: 123 / 9ACB / o to [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action ❑r NEW permit OR newly -reported emission source (check one below) D STATIONARY source El PORTABLE source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) El Change fuel or equipment ❑ Change company name 0 Add point to existing permit 0 Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) ❑ APEN submittal for permit exempt/grandfathered source Additional Info a Notes: 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Natural Gas Compression Turbine Manufacturer: Solar Model No.: Taurus 70 Serial No.: TBD Company equipment Identification No. (optional): TURB-1 For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: TBD 0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day days/week weeks/year Seasonal use percentage: Dec -Feb: Mar -May: Jun -Aug: Sep -Nov: Form APCD-200 - General APEN - Revision 1/2017 2 I AV Dcpartreent of COLORADO lth 6 ' En+rtmmmo Naam Permit Number: 1 3WE 1108 AIRS ID Number: 123 / 9AC i O\ O [Leave blank unless APCD has already assigned a permit ti and AIRS ID] Section 4 - Processing/Manufacturing Information a Material Use Check box if this information is not applicable to source or process From what year is the actual annual amount? Actual Anriu Amount: (Specify Units) equested Annual Permit Limit_ Specify Units) 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Section 5 - Stack Information epgraphical Coordinates (Latitude/Longitude or•UTM)• 40.461 / -104.766 ❑ Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. = Discharge Height. Above. Gr un Leve . T.thh „ - 4. . Temp It F[ow Rat (A[FM eioc�ty (ft"/se Operator. Stack ID No TURB-1 47.0 Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Upward with obstructing raincap ❑ Circular Interior stack diameter (inches): 54.19 ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): Form APCD-200 - General APEN - Revision 1/2017 3 I hi_ Public COLORADO Permit Number: 13WE 1 108 AIRS ID Number: 123 /9A4( © to TSP (PM) [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Combustion Equipment Et Fuel Consumption Information ❑ Check box if this information is not applicable to the source (e.g. there is no fuel -burning equipment associated with this emission source) sq From what year is the actual annual fuel use data? Indicate the type of fuel useds: ❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/SCF) ❑ Field Natural Gas Heating value: BTU/SCF ❑ Ultra Low Sulfur Diesel (assumed fuel heating value of 138,000 BTU/gallon) ❑ Propane (assumed fuel heating value of 2,300 BTU/SCF) ❑ Coal Heating value: BTU/lb Ash Content: Sulfur Content: ❑� Other (describe): Pipeline Natural Gas Heating value (give units): qo ? Btu/scf 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 5 If fuel heating value is different than the listed assumed value, provide this information in the "Other" field. Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ❑ Yes ❑✓ No If yes, describe the control equipment AND state the overall control efficiency (% reduction): -1 0 -i(o 5 C l 1 verall ,Coritrol Efficieri %reduction in emissions PM10 PM2.s SOX NO), CO VOC Other: Form APCD-200 - General APEN - Revision 1/2017 4I COLORADO IIcpvmcntd %htik • H..unu5„w„nnm.n, TSP (PM) Permit Number: 13WE 1108 AIRS ID Number: 123 / 9ACB/ O11z) [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 (continued) From what year is the following reported actual annual emissions data? Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Uncontrolled Emission 7.Factor (Spec fy Units) AP -42 ncontrolle !Ions/year; Z. vZ 6.6E-03 Ib/MMBtu PM10 6.6E-03 Ib/MMBtu• AP -42 PM2.s 6.6E -OS Ib/MMBtu AP -42 Z.oz 2 -.o7- -SOX 3.4E-03 Ib/MMBtu • AP -42 l.o`1 • NO, 5.614 6i,tIb/MMBtu. Mfg. Co (a.051.I o1-Ib/MM Btu , Mfg. voc 2.1E-03 Ib/MMBtu - AP -42 ul Other: 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. ?ro c\ c! 0.00, Co, o. c} /OC, i-cWck- ad ,`bov‘a.\ C,uvvn o"\ Ly"-.:StOvS ,^ Sto-/E.-u�. o r c1� $A_ut.emu att-W S, Pl - Ste Lalwtct±ia✓vS ;h e�i ccJ c- ( cote- `ykw l c.Ax-tssioK Cti•Eov-S Section 8 - Non -Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non -criteria pollutants (e.g. HAP- hazardous air pollutant) emissions equal to or greater than 250 lbs/year? ❑✓ Yes ❑ No If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source: CAS Number$=' Formaldehyde Overall Control Efficiency Uncontrolled Emission Factor: (specify units) Emission Factor Source AP -42, Mfg. etc) Uncontrolled Actual. Emissions abs/year) ontrolled Actual Emission' (lbs/year, 50-00-0 0.0% 7.1E-04 Ib/MMBtu, AP -42 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. 51 lg COLORADO uld Pnm.c Hue 1lM1 b E.mlmnmem O.-ltos (-LoV\ Form APCD-200 - General APEN - Revision 1 /2017 Permit Number: 1 3WE1108 AIRS ID Number: 123 / 9ACB/ c o [Leave blank unless APCD has already assigned a permit it 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. 5/0-lzo►g Signature of Legally Authorized Person (not a vendor or consultant) Date Roshini Shankaran Senior Environmental Engineer Name (print) Title Check the appropriate box to request a copy of the: ❑� Draft permit prior to issuance E✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) 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 $152.90 to: For more information or assistance call: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: Make check payable to: https://www.colorado.gov/cdphe/apcd Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Form APCD-200 - General APEN - Revision 1/2017 COLORADO 6 1 --. = Glycol Dehydration Unit APEN - Form APCD-202 Air Pollutant Emission Notice (APEN) and Application for Construction Permit i All sections of this APEN and application must be completed for both new and existing facilities, including APE.NCET\ D updates. An application with missing information may be determined incomplete and may be returned or r r t ,. longer application processing times. You may be charged an additional APEN fee if the APEN is filled out t 2O)a incorrectly or is missing information and requires re -submittal. APCD Stai; ; Wars This APEN is to be used for Glycol Dehydration (Dehy) Units only. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is - available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 13WE 1108 AIRS ID Number: 123 / 9ACB / 0/1 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification: D-2 [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': DCP Operating Company, LP Site Name: Troudt Compressor Station Site Location: SENW Sec. 27, T6N, R66W Mailing Address: (Include Zip Code) 370 17th Street, Suite 2500 Denver, CO 80202 E -Mail Address2: RShankaran@DCPMidstream.com Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Roshini Shankaran Phone Number: 303-605-2039 ' Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-202 - Glycol Dehydration Unit APEN Revision 02/2017 381-846 COLORADO 1 18m._...-..�,�� Naimacnh.e�m.a Permit Number: 13WE1108 AIRS ID Number: 123 /9ACa' bit [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action • NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Please note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: TEG dehydration unit for water removal Facility equipment Identification: For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: D-2 - TEG Dehydration Unit / / TBD / / El Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area Is this unit located at a stationary source that is considered a Major Source of (HAP) Emissions Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 days/week Yes Yes El weeks/year No No ��L$ COLORADO 2 /4MiiVi 6 EMd d� HULA 'ItMIMN Permit Number: 13WE 1108 AIRS ID Number: 123 / 9ACii [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Dehydration Unit Equipment Information Manufacturer: Dehydrator Serial Number: Glycol Used: TBD TBD Ethylene Glycol (EG) Model Number: TBD Reboiler Rating: 4.0 ❑ DiEthylene Glycol (DEG) Glycol Pump Drive: ✓❑ Electric ❑ Gas If Gas, injection pump ratio: Pump Make and Model: TBD - 1 primary, 1 backup MMBTU/hr ❑ TriEthylene Glycol s (TEG) # of pumps: Glycol Recirculation rate (gal/min): Lean Glycol Water Content: Max: 30.0 • 1.0 - Wt.% Requested: 30.0 Acfm/gpm 2 Dehydrator Gas Throughput: Design Capacity: 88 . MMSCF/day Requested: 32,120 MMSCF/year Actual: MMSCF/year Inlet Gas: Pressure: 950. Water Content: Wet Gas: psig Temperature: 120- °F lb/MMSCF ❑✓ ' Saturated Dry gas: 5.0 lb/MMSCF Flash Tank: Pressure: 60 - psig Temperature: 120 °F ❑ NA Cold Separator: Pressure: psig Temperature: °F 0 NA Stripping Gas: (check one) ✓❑ None ❑ Flash Gas ❑ Dry Gas 0 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) Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 �V,COLORADO xuun 6 r.,�w°m..0 Permit Number: 13WE1108 AIRS ID Number: 123 /9ACa ®t k [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information 40.461 / -104.766 T-€ d%.ti� '^ i'L:_a.' _ doom or tac 41D' . o �, ,` * .,,- -£^�` = Y _- emp 's ? Flo t ACF,9 'T�v �— e ocrty. �' sec Discharge. 1eight b boveeGround Leye Feet) D-2 30.0 Indicate the direction of the stack outlet: (check one) O Upward ❑ Horizontal ❑ Downward 0 Other (describe): ❑ Upward with obstructing raincap Indicate the stack opening and size: (check one) 0 Circular Interior stack diameter (inches): 40.0 ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): 0 Other (describe): Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 �[ COLORADO 4 1 �SS??yy du� Permit Number: 13WE1108 AIRS ID Number: 123 /9ACei 011 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information Used for control of: D Condenser: Type: Make/Model: Maximum Temp Average Temp Requested Control Efficiency % ❑� VRU: Used for control of: Flash Tank Vapors Size: Make/Model: Requested Control Efficiency 1 00.0 VRU Downtime or Bypassed 5.0 ❑ Combustion Device: * Used for control of: Still Vent Stream Rating: Type: MMBtu/hr Enclosed Combustor Make/Model: John Zink / FBF ZTOF040X30PF 95.0 % Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: 98.0 % Waste Gas Heat Content fvA0 Btu/scf Constant Pilot Light: ❑� Yes ❑ No Pilot burner Rating 0.06 MMBtu/hr Closed ❑ Loop System: Used for control of: Description: System Downtime 0/0 O Other: Used for control of: Flash Tank Vapors during VRU downtime (5.0%) Description: Control Efficiency Requested ECD Combustion Device 95.0 % IN(u.ppl; cc i v' His D31Z 1 Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 5 1 LTV COLORADO Gepuwmtd MAIc ..h 6 Envinnm.d PM Permit Number: 13WE1108 AIRS ID Number: 123 / 9ACej ®'1 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Criteria .Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? 2 Yes ❑ Nb If' yes, please describe the control equipment AND state the overall control efficiency (% reduction): PM VetaliReguested Contra( cienc 7eduction`in'emssions Sox NOx CO VOC Vapor Recovery Unit / Enclosed Combustor 100% / 95% HAPs Vapor Recovery Unit / Enclosed Combustor 100%/95%a Other: From what year is the following reported actual annual emissions data? Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Uncontrolled Emission Factor. Emission Factor Units Emission; Factor Source (AP -42 Mfg :etc)_, Controlleds- (Tons/year).. Uncontrolled (Tons/year) ?; Controlled (Tons%year)-. Uncontrolled (Tons/year) SOX NOx 0.068 - lb/MMBtu AP -42 2.47 ' 2.47' CO 0.31 - lb/MMBtu AP -42 11.27 11.27 . VOC 45.14. Ib/MMscf GLYCalc 724.89 . Benzene 3.87 Ib/MMscf GLYCalc 62.23 Toluene 3.63 . lb/MMscf GLYCalc 58.30 ' Ethylbenzene 0.11- Ib/MMscf GLYCalc 1.71' Xylenes 1.05 • Ib/MMscf GLYCalc 16.94 • o n -Hexane 0.88 - Ib/MMscf GLYCalc 14.09 ' 0.50 2,2,4- Trimethylpentane 0.006 Ib/MMscf GLYCaIc 0.09 • ca. ooh Other: mckiey nol o. 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 5Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. O. DA t. 005 - Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 �cr��tK-cS Thci Cssl\C,5. A COLORADO H.allh 6 Env1mnM.n1 OyJl,+1 Permit Number: 13WE 1108 AIRS ID Number: 123 /9ACH of [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/(-9 rZoi s Signature of Legally Authorized Person (not a vendor or consultant) Date Roshini Shankaran Senior Environmental Engined Name (please print) Title Check the appropriate box to request a copy of the: C Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) Send this form along with $152.90 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 7 I COLORADO w nnuc wuun uu t.�o�mw Fugitive Component Leak Emissions APEN - Form APCD- Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for fugitive component leak emissions. If your emission source does not fall into this category, there may be a different specialty APEN available for your operation (e.g. natural gas venting, condensate tanks, paint booths, etc.). In addition, the General APEN (Form APCD- 200) is available if the specialty APEN options do not meet your reporting needs. A list of specialty APENs is available 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: 13WE 1108 AIRS ID Number: 123 to 203/1/'C'D /9ACB/ 012 — [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: DCP Operating Company, LP Troudt Compressor Station Site Location: SENW Sec. 27, T6N, R66W Mailing Address: 3/0 17th Street, Suite 2500 (Include Zip Code) Denver, CO 80202 Permit Contact: Roshini Shankaran E -Mail Address2: RShankaran@DCPMidstream.com Site Location Weld County: NAICS or SIC Code: 1311 Phone Number: 303-605-2039 I Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2017 381849 �I COLORADO 1 I VV pepam.rnt d Pubtic k�e���N Permit Number: 13WE1108 MRS ID Number: 123 /9ACB/ O` -L [Leave blank unless APCD has already assigned a permit ft and AIRS ID] Section 2- Requested Action ❑✓ NEW permit OR newly -reported emission source (check one below) -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change process or equipment 0 Change company name ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership3 0 Other (describe below) - OR • APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ▪ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information For existing sources, operation began on: 4/27/2015 For new or reconstructed sources, the projected start-up date is: ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source hours/day days/week Operation: Facility Type: ❑ Well Production Facility' 0 Natural Gas Compressor Station4 ❑ Natural Gas Processing Plant4 ❑ Other (describe): weeks/year 4 When selecting the facility type, refer to definitions in Colorado Regulation No. 7, Section XVII. Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2017 2i�V COLORADO Department al Dunn benwenineN Permit Number: 13\JVE 1108 AIRS ID Number: 123 / 9ACB/ olZ [Leave blank unless APCD has already assigned a permit It and AIRS ID] Section 4 - Regulatory Information What is the date that the equipment commenced construction? Will this equipment be operated in any NAAQS nonattainment area?5 Will this equipment be located at a stationary source that is considered a Major Source of Hazardous Air Pollutant (HAP) emissions? Are there wet seal centrifugal compressors or reciprocating compressors located at this facility? Is this equipment subject to 40 CFR Part 60, Subpart KKK? Is this equipment subject to 40 CFR Part 60, Subpart 0000? Is this equipment subject to 40 CFR Part 60, Subpart 0000a? Is this equipment subject to 40 CFR Part 63, Subpart HH? Is this equipment subject to Colorado Regulation No. 7, Section XII.G? Is this equipment subject to Colorado Regulation No. 7, Section XVII.F? Is this equipment subject to Colorado Regulation No. 7, Section XVII.B.3? 11/25/2013 O Yes ❑ Yes 0 Yes ❑ Yes ❑ Yes 0 Yes ❑ Yes ❑ Yes ❑✓ Yes 0 Yes ❑ No ❑✓ No ❑ No O No 0 No ❑ No O No 0 No ❑ No ❑ No 5 See http://www.colorado.gov/cdphe/state-implementation-plans-sips for which areas are designated as attainment/non- attainment. Section 5 - Stream Constituents 0 The required representative gas and liquid extended analysis (including BTEX) to support the data below has been attached to this APEN form. Use the following table to report the VOC and HAP weight % content of each applicable stream. - Stream V0C (wt %) Benzene (wt %) : , Toluene (wt %) : , Ethylbenzene (wt %) ' Xylene (wt %) : ! — n -Hexane (wt %) — 2 2 4 .. __, ' ' Trimethylpentane (wt %) Gas 28.70- 0.051 • 0.039- 0.001- o.ox\- 0.392' 0.004. Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) 100 0.177- 0.134. 0.003- °''''-'- \ -3-P4 0.013 . Water/Oil Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2017 LalWlotid�S. oc f t °� 3I AV COLORADO IieLLp b Enw.Ne.N Permit Number: 13WE 1108 AIRS ID Number: 123 /9ACB/ 017 - [Leave blank unless APCD has already assigned a aermit # and AIRS ID] Section 6 - Geographical Information Geographical Coordinates (Latitude/Longitude or UTM) 40.461 / -104.766 Attach a topographic site map showing location Section 7 - Leak Detection and Repair (LDAR) and Control Information Check the appropriate boxes to identify the LDAR program conducted at this site: ❑ LDAR per 40 CFR Part 60, Subpart KKK 0 Monthly Monitoring - Control: 88% gas valve, 76% light liquid valve, 68% light liquid pump ❑ Quarterly Monitoring - Control: 70% gas valve, 61% light liquid valve, 45% light liquid pump ❑� LDAR per 40 CFR Part 60, Subpart 0000/0000a ❑ Monthly Monitoring - Control: 96% gas valve, 95% light liquid valve, 88% light liquid pump, 81% connectors ▪ LDAR per Colorado Regulation No. 7, Section XVII.F ❑ Other6: 0 No LDAR Program 6 Attach other supplemental plan to APEN form if needed. Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2017 4 AV COLORADO Dp al Paid= IhJSth LE,. .om, N Count8 Permit Number: 1 3WE 1108 AIRS ID Number: 123 / 9ACB / 017 — [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emission Factor Information Select which emission factors were used to estimate emissions below. If none apply, use the table below to identify the emission factors used to estimate emissions. Include the units related to the emission factor. ❑ Table 2-4 was used to estimate emissions7. ❑✓ Table 2-8 (< 10,000ppmv) was used to estimate emissions7. Use the following table to report the component count used to calculate emissions. The component counts listed in the following table are representative of: ❑r Estimated Component Count ❑ Actual Component Count conducted on the following date: Equipment Type Connectors Flanges Open -Ended`" Lines . Pump Seals 293- 20 ' 650 153 1 Emission Factor 2.21E-05 • 1.26E-05 • 5.51E-05 • 2.65E-04 • Units lb/hr/source lb/hr/source lb/hr/source lb/hr/source lb/hr/source Heavy Oil(or Heavy Liquid) Counts Emission Factor Units Light Oil (or Light Liquid) Counts 7390• 1175. 15 • 2397 • 72 Emission Factor 2.14E-05 • 5.29E-06 - 1.12E-03 • 4.19E-05 • 2.43E-04 • Units lb/hr/source lb/hr/source lb/hr/source lb/hr/source lb/hr/source Water/Oil Count8 Emission Factor Units 7 Table 2-4 and Table 2-8 are found in U.S. EPA's 1995 Protocol for Equipment Leak Emission Estimates (Document EPA -453/R- 95-017). 8 The count shall be the actual ora:stimated number of components in each type of service that is used to calculate the "Actual Calendar Year Emissions" below. 9 The Other equipment type should be applied for any equipment other than connectors, flanges, open-ended lines, pump seals, or valves. Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2017 ,; &udt c fo\U lati o S. 1+�S Oy l o ki 51 AVICOLORADO ilWq b FnwmuuN Permit Number: 13WE 1108 AIRS ID Number: 123 /9ACB/ OIL [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Criteria and Non -Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. 2017 From what year is the following reportedactualannual emissions data? Use 'the following table to report the criteria pollutant emissions and non -criteria pollutant (HAP) emissions from source: (Use the data reported in Section 8 to calculate these emissions.) Chemical Name CAS Number _:,_ Actual Annual Emissions Requested Annual Permit Emission Limit(s) Uncontrolled (tons/year) Controlled10 tr "' _ (tons/year) Uncontrolled ' ' `" (Eons/year) ' Controlled,.? _ - "' (Eons/year) voc 0.77 0.77 2.1 • 2.1 . Does the emissions source have any actual emissions of individual non -criteria pollutants (e.g. HAP- hazardous air pollutant) emissions equal to or greater than 250 lbs/year? If yes, use the following table Chemical Name` Number to report the non -criteria pollutant Actual Annual Emissions ❑ Yes (HAP) emissions from source: ® No Requested Annual Permit Emission Limit(s) Uncontrolled (lbs/year) _ ontrolled - (lbs/year) Uncontrolled, (lbs/year) Controlled10' (lbs/year) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 2,2,4 Trimethylpentane Other: 540841 10 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. 11 Requested values will become permit limitations. Requested limit(s) should consider future process growth, component count variability, and gas composition variability. Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2017 6 I4677 Dcpartmera COLORADO pub& Kea. 6 EnuUaMrN Permit Number: 1 3WE1 108 AIRS ID Number: 123 / 9Aca / O12_ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 10 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. 5/11/201% Signature of Legally Authorized Person (not a vendor or consultant) Date Roshini Shankaran Senior Environmental Engineer Name (print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance �✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 to: For more information or assistance call: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2017 ierCOLORA DO 1iylN b Fnwe.wvN Hydrocarbon Liquid Loading APEN - Form APCD. 2D8 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for Hydrocarbon Liquid Loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 13WE1108 AIRS ID Number: 123 /9ACB / O /3 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification: L-1 - Pressurized liquid loading [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': DCP Operating Company, LP Site Name: Troudt Compressor Station Site Location: SENW Sec. 27, T6N, R66W Mailing Address: (Include Zip Code) 370 17th Street, Suite 2500 Denver, CO 80202 E -Mail Address2: RShankaran@DCPMidstream.com Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Roshini Shankaran Phone Number: 303-605-2039 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. Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Rev 02/2017 381850 COLORADO 1 I AV HLl[h6EnnlvnnuU Permit Number: 13WE 1108 AIRS ID Number: 123 /9ACIfk 013 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action O NEW permit OR newly -reported emission source 0 Request coverage under construction permit ❑ Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN Filing fee. -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below) - OR • APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Pressurized truck load out of condensate For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 4/ 27 / 2015 / / Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Does this source load gasoline into transport vehicles? Is this source located at an oil and gas exploration and production site? If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Does thissource splash fill less than 6750 BBL of condensate per year? Does this source submerge fill less than 16308 BBL of condensate per year? ❑✓ Yes ❑ No ❑ Yes ❑r No ❑ Yes 0 No ❑ Yes 2 No ❑ Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 COLORADO 2i ly t ., Hullh6EnNmmm�u Permit Number: 13WE1108 AIRS ID Number: 123 /9ACB/ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information Product Loaded: ❑✓ Condensate ❑ Crude Oil ❑ Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded4: Bbl/yr Actual Volume Loaded: Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth This product is loaded from tanks at this facility into: (eg, "rail tank cars" or "tank trucks") If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: Average temperature of bulk liquid loading: °F True Vapor Pressure Psia @ 60 °F Molecular weight of displaced vapors Lb/lb mol If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: 622,024. Bbl/yr a Actual Volume Loaded: 43,822 Bbl/yr b 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth Product Density: 46.08 • Lb/ft3 Load Line Volume: 0.0218 ' ft3/truckload Vapor Recovery Line Volume 0.0218 ft3/truckload a 3,733 loads/yr . . b 263 loads/yr Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 3 I COLORADO pepvwmtd p Jk HYiUh B F..TNm111MN Permit Number: 13WE 1108 AIRS ID Number: 123 /9AC' Ot [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Geographical Information Gaphal Cates' (Laeogrtitude/Loicngitude oroordinUTM) 40.461 / -104.766 F Operator St c ID 0 _ Discharge Hei hl Above Ground Le el , N x Tern F _ • IoW Rate XCCEM e oci t sec) L-1 Indicate the direction of the stack outlet: (check one) ❑ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter (inches): ❑ Other (describe): ❑ Upward with obstructing raincap Section 6 - Control Device Information Loading occurs using a vapor balance system: Requested Control Efficiency 100 % ❑ Combustion Device: Pollutants Controlled: Rating: Type: Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: MMBtu/hr Make/Model: Waste Gas Heat Content Constant Pilot Light: ❑ Yes ❑ No Pilot burner Rating Btu/scf MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested 0/0 Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 /fiCOLORADO 4 �/Ryyr RM.,herdo,P16u. Hul[h 6 FivLpgmvrtl PM Permit Number: 13VVE1108 AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] 123 /9AC� 012) Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ❑ Yes ❑✓ No If yes, describe the control equipment AND state the overall control efficiency (% reduction): PM verall Requested Control i Efficiency % reduction in emissions) _ SOX NO„ CO VOC HAPs Other: ❑ Using State Emission Factors (Required for GP07) VOC ❑ Condensate 0.236 Lbs/BBL ❑ Crude 0.104 Lbs/BBL Benzene n -Hexane 0.00041 Lbs/BBL 0.0036 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? 2017 Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Uncontrolled Emission Factor; Emission Factor ?Units Emission__ Factor Source Mfg etc) Controlled5 (Tons/year) nested Annua1Permit mssron Limit Uncontrolled (Tons/year) Uncontrolled; (Tons/year) `_ Controlled (Tons/year) '; SOX NO„ VOC 1.055 lb/load Eng. Est. 0.12 0.12 2.0 • 2.0 • CO Benzene Toluene Ethylbenzene Xylenes n -Hexane 0.070 lb/load Eng. Est. neg. neg. 0.13 0.13 2,2,4- Trimethylpentane Other: 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 5Annual emission, fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 CO *I I w1LL� B &`Lwovnen Ht Permit Number: 13 WE 1108 AIRS ID Number: [Leave blank unless APCD has already assigned a permit ti and AIRS ID] 123 /9ACR/ pA3 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 the applicable General Permit: Signature of Legally Authorized Person (not a vendor or consultant) Date Roshini Shankaran Senior Environmental Engineer Name (print) Title Check the appropriate box to request a copy of the: E✓ 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 $152.90 and the General Permit registration fee of $250 as 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 Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 6 I A® COLORADO cm„a,md wuc Huub b Enwoamm% Hello