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Home My WebLink About20171607.tiffINVENTORY OF ITEMS FOR CONSIDERATION Applicant DCP Operating Company LP Case Number 5MJUSR17-83-542 Submitted or Prepared Prior to Hearing At Hearing 1 E -Mail: Eric Ewing to Tom Parko dated April 24, 2017 at 10:05AM w attachments X 2 Attachment: ECHO — Enforcement and Compliance History Online Facility Summary — DCP Mewbourn Gas Plant (7 pages) X 3 Attachment: Letter to Mr. Ewing from CDPHE, APCD dated April 17, 2017 Current Status of all DCP Mewbourn Gas Plant state air and construction permits (3 pages) X 4 Attachment: CDPHE, APCD Compliance Order of Consent Facility — DCP Mewbourn Gas Plant (22 pages) X 5 Attachment: CDPHE, APCD Field Inspection Report dated July 23, 2017 Facility — DCP Mewbourn Gas Plant (52 pages) X 6 E -Mail: Torn Parko to Eric Ewing dated April 24, 2017 at 11:39 AM X 7 E -Mail: Eric Ewing to Tom Parko dated April 24, 2017 at 12:22 PM X 8 Letter dated July 16, 2017 from CDPHE, APCD Warning letter to DCP Midstream LP related to compliance issues (3 pages) X 9 E-mail: Phillip Brewer to Jennifer Maddox dated April 24, 2017 12:56 PM Request for information re: Warning Letter to DCP Midstream LP regarding non-compliance at Mewbourn Natural Gas Plant, AIRS No. 123-0090 X 10 E -Mail: Tom Parko to Eric Ewing dated April 25, 2017 at 8:39 AM X 11 E-mail: Phillip Brewer to Kim Ogle, Michelle Martin dated April 26, 2017 10:44 AM. Jennifer Maddox Response to inquiry re: Warning Letter to DCP Midstream LP regarding non-compliance at Mewbourn Natural Gas Plant, AIRS No. 123-0090 x 12 Telephone call to Troy Swain, Local Government Designee from SPO Dennis Nagel with concerns of dust generated from use of Section Line Road X 13 Letter of Concern, SPO Don and Terri Dechant dated May 8, 2017 X 14 Letter from Gerald Johnson on behalf of neighborhood SPOs in opposition dated May 15, 2017 X 14A SPO Petition associated with Gerald John Letter dated May 15, 2017 X 15 Photographic images of Dechant Property and residence, no date X 16 Eight (8) Articles from Internet, media reports and CRS Title 34 excerpt provided by Mr. Eric Ewing, multiple dates X I hereby certify that the items identified herein were submitted to the Department of Planning Services at or prior to the sbheduled Planning Commissioners hearing. Kim EOaleI ❑ Planner From: Eric Ewing [mailto:ewinghr@yahoo.com] Sent: Monday, April 24, 2017 10:05 AM To: Tom Parko Jr. <tparko@co.weld.co.us> Cc: Kim Ogle <kogle@co.weld.co.us> Subject: URGENT: Requesting a Stay of Proceedings for 5MJUSR17-83-542f Dear Mr. Parko, I am requesting that proceedings for DCP Midstream's plans to expand the Mewbourn Gas Processing Plant as proposed in 5MJUSR17-83-542 be delayed until the plant is in compliance, all information regarding plant compliance is made available, and enough time is afforded to adequately prepare for comment. DCP Midstream is Non -compliant for Significant Reasons DCP Midstream is still non -compliant regarding air pollution regulations and Development Standards that are significant. The EPA website indicates that the DCP Midstream Mewbourn plant is still in Significant Non -Compliance (SNC) as a High Priority Violator (HPV) for exceeding emissions regulated at the Federal, State, and Weld County levels. Important Information Not Available - Ongoing Investigation Important information that allows me to speak from a fully informed position to the Planning Commission is not available. The information is being withheld by the State of Colorado, because the DCP Midstream Mewbourn plant is currently under investigation. This causes me to be disadvantaged and not able to adequately address the Planning Commissions regarding my interests. Inadequate Time to Prepare for Comment The Planning Commission hearing is scheduled for Tuesday, May 16, 2017 and is less than 30 days from today. Based on my recent conversations with yourself, Mr. Swain, and Mr. Brewer, I do not believe we know enough about the facts to move forward with approving Development Standards for 5MJUSR17-83-542. With working full-time, raising a family, and having no formal training in this area, it seems reasonable that I would be afforded at least 30 days to prepare for comment after all relevant information is made available to me. Documents Supporting Request: 1. State of Colorado's response to my recent Information Request stating the records are "subject to an investigatory hold". (Page 4 of the attached document titled Ewing Response 4.17.2017) 2. EPA Echo website showing that DCP Midstream is in non-compliance as of Saturday, April 22, 2017. (Page 4 of attached document titled DCP MIDSTREAM NONCOMPLIANT WITH AIR POLLUTION REGULATIONS AS OF APRIL 24 2017) EXHIBIT k frtt C1`xz t3 454.4 1 3. Consent Order from Colorado Department of Public Health & Environment stating that DCP Midstream has violated air pollution regulations for exceeding and continuing to exceed permitted emissions. Prompt Action in Order to Reduce Impacts to DCP Midstream Prompt notification to DCP Midstream of the delay in proceedings will allow them to plan accordingly and reduce economic impacts. Urgency of Staying Proceedings Moving forward with the Planning Commission hearing for May 16, 2017 regarding 5MJUSR17-83-542 and subsequent plant expansion will cause irreparable harm. Please let me know if I need to take further action beyond emailing you regarding this request. Sincerely, Eric Ewing 16974 CR 40 La Salle, CO 80645 970-347-7737 ewinghr@yahoo.com CC: Kim Ogle, Planner Detailed Facility Report I ECHO I US EPA Page 1 of 7 ECH Enforcement and Compliance History Online Detailed Facility Report Facility Summary MEWBOI RN GAS PLANT 18455 WELD COUNTY RD 35, GILCREST, CO 80623 0 FRS (Facility Registry Service) ID: 110010691750 EPA Region: 08 Latitude: 40.266583 Longitude: -104.734944 Locational Data Source: RMP Industry: Oil and Gas Extraction; Pipeline Transportation Indian Country: N Enforcement and Compliance Summary SuWtc CAA CWA RfRA bop (5 Von) i Date e( lit —a 09'23.'7016 Compliance Slate nlpinunt violation No Violation No Violation Compliance) Rif 12) r O CAA CWA RCRA 1 2 -Quarter Violation History Under Development I 2 3 4 5 6 7 8 9 10 Quarters MI No Violation Noncompliance III Significant Violation Unknown 11 lltn io NC 'Non- ljln m Significant Informal Fnforcanaa tunas Famal Silurwnalt Action Violation IS yeas) (5 yens) I7 u u Penalties from Formal Fnforcanan EPA Cases (5 Pmaltia from EPA Cams lawns l55un) Sle? SOO yeas) 15 ;can) Related Reports Q Air Pollutant Report ▪ CWA Pollutant Loading Report © CWA Effluent Charts Regulatory Information Clean Air Act (CAA): Operating Major (CO00000008 1 2300090) Clean Water Act (CWA): Minor, Permit Ettective (COR900 328) Other Regulatory Reports Air Emissions Inventory (EIS): No Information Greenhouse Gas Emissions (eGGRT): 1006131 Toxic Releases (TRI): No Information EXHIBIT 1friubsa rat a I 2 https://echo.epa.gov/detailed-facility-report?fid=OO0000000812300090 Detailed Facility Report I ECHO I US EPA Page 2 of 7 Resource Conservation and Recovery Act (RCRA): Inactive ( ) Other (COD 149181646) Safe Drinking Water Act (SDWA): No Information Facility/System Characteristics Facility/System Characteristics System Shale FRS (ING CAA RMP CAA AIR CAA I(T CW.% Rtlt RCRA Idoaaber I'awaac 11001IY9175, I iaVJ 1I buccl Emitter 1(000007655_ CO0000090112300090 Major Emmons 900? •a CODI49111646 4 9111 6 4 6 Slatur Subject ACTIVE °paalrg Mina General pawn C aaed Faahtg Effective Other Inactive ( Permit Lpnauon Daic Indian Country I abtudc Gataal Stationary Fuel Combustion. Parulc+tnt and Nalwal Gat Sntem, CAA.MACT. CAANSI'S. .U'SI), CA.\SIP. I. \.\M' Storm Water InduW 441 nt.:.0 ?017 I.a5rtudc N 4) 2665X3 •101 `:4944 • 40 !66 i1) •(0471944 • 40 ?67?2? -104 734444 Facility Address System FRS DUG RMP AIR 161 RCS Statute CAA CAA CAA CWA RCRA Idantlia Fru:Oily Nam 110010691750 10061? 1 10000007655'_ C00000000SI 2\00090 COR10032$ COD149111646 I.EWBOURN GAS PLANT AEWBOURN GAS PLANT MEWBOURN GAS PLANT NY MIDSTREAM. LP- fiEWBOLR.N MEI/BOURN GAS RANT ASSOCIATED NAT GAS (KERSEY PLANT( Flediq Addrar 11455 WEIR COUNTY RD 35. DU..6tEST• CO 10623 12455 WELD COUNTY RD 35. GILCREST. CO 10623 IW9S COUNTY ROAD 35, PLATTEVB.IE, CO 8065I NESE SEC 35 TIN R66W. GILCREST 23 MI. SE OF, CO 10615 11455 CR 35, GN,CIEST, CO 00673 11455 W(R 35. GBLCREST, 03 10623 Facility SIC (Standard Industrial Classification) Codes System tilt ICP 'Yb000000SI '_300000 COlt900321 SIC Cods 4922 1121 SIC Iluc aural Gas Itammm urn Natural (3 41 I 'quids Facility Tribe Information Resenauon Suns Tithe Name FPA Titan') No data taauds rammed Distance lo Tribe (mda) Enforcement and Compliance Facility NAICS (North American Industry Classification System) Codes Ionian N\R• I000110076552 00 76 5 5 2 GNG 1006131 111112 ilk 000000000/17300090 4113210 Identifier NAJCS Cie NAICS Dacrrytaun 211111 Nasal Gas liquid E:hactaa Nleral Gera I squid Extraaaa I'tpclmc I untpvtuba or Natural Oa https://echo.epa.gov/detailed-facility-report?fid=OO0000000812300090 4/24/2017 Detailed Fac i 1 ity Report I ECHO I US EPA Page 3 of 7 Compliance Monitoring History (5 years) Slemm Source ID 8yemt lespittiaa bps Lad .Ap c..y Dart C4.4 000003000812300090 AIR Tr.4CCReenptlReren State 01120'101- Mari : No Fadq Reran Denson Fmme1 CAA r00001000411400090 00000041130009O 41R TVACC Rec.g*R tee State 01/30401" CAA CO000000011_300090 AIR FCE O4o-Site Sratc 09123/2016 CAA aManes0417JtUAO AIR Shalt Tea Stale 01/110016 Fwdr..gs Pass Pn:uwwb VOLIflLBORGANIC COMMANDS IMM CAA COOryXRri0811500090 .41R Stack Tnt .State 086/9/8016 Frndr.gs /'as Pnihrawa Cabo. moat NITROORN aWDESN02. IDWflLE ORGANIC CONPOONDS(I'OCSI CAA 100000000817300090 AIR 7V ACC Rat pNt rww Store 02/01/2016 CM COO(00000812300090 AIR 11' ACC RernpbRevw. .Stare 01/31/2016 Risen No FadgRyat Dmator CM C00000t$0812300090 OR Stack Test State I0'16/701J Padgett Per Pala NITROGEN O.AMDES.NO: CAA 00000000021 n00090 AIR FCR Dada Sea. 09123/201S CAA COOwa.001123Wg9J .OR Stack Ten Stage IMO/ .011 Fmdags 1'at Peasant Carbon ontawasek CM COn009W0S113Wfl1 AIR Stack Ti.' Stole 060!0015 Fartngs Pao Po hw.a_- IMAMS IFCIC') CAA 000000GJOS17300090 AIR Stack Tae Stale 06/250015 Fad..gs Pan Pnlhrawa N17ROGEV OYIDMNO2 CL4 000040000a12300090 .410 PCS O.•6nt EPA 06/171201J 01.4 C0000000014123000 70 AIR 27' ACC Receipt/Renew .State 02107122015 C4A 00000000081230(1090 AIR TV ACCRecnptRarw► Stare 02/01/2015 Fabrl .No Fa. dw Report Devwtrrww CAA 000000000911300090 AIR FC! Oo-ste Stale 09/24/2014 CAA C00000090T12JUA9J .OR 77'.4C'CRe .ip.Revn Stare 01/304011 CAA 000000000817100090 AIR Stock Ten State 1024/2013 Fs.drwks Pan Pol:usaea. .A7TROGEV' OXIDES NO2 CIA 030000000012900090 .AIR 711 ACC RecetpNPnww Stan 021110013 Penang Vas Farley Repeat ltevstlrass CIA 000000(O0S17300090 .41R TI' ACC Receipt/Ran :Tate 02040013 CAA C O0000000911300090 .4/R Stark Tett Aso- 11/710011 Faber Pas Psdlusewa Carbon mos.4 CAA CCOPI 00S17J0009O .410 Stack Ten State 11010011 Falange Pau PaOwwa NITROGEN 0.17DES NO2 C.i4 0.10=00001234(1090 .4/R Stack Ten State 1101/2011 Fadivgr Pan P.uhtalsa: IVLAflLSORCIANI('COk/POLNDSIRKS) CAA 000000000812300090 .4/R Stock !'err Stott 11/1/0012 Fadmgr Pan Pa:liaana: NITRIXIEN GUMS NO2 CAA C0000000481230GYA9 AIR Stack Tan Gob 11/11/7012 Farhat* P. at Pdhw.a. Cabo. monad. CA4 000000098/2300090 .AIR Stalk Ten State 11/110017 Fa.dnwgs Pens Pnl/ula.a VOLATILE ORGANIC COMPOUNDS 011709 C4.4 COO(g.0000812300M0 .A1R Sta. k Ten Gate 11114/2012 Fording. Pan P:./liana Condo. ~monk C4.4 C000000008/2300M0 11R .Steak Ten Slate /1/140012 Fishegr Pas Potlsaa a VOLATILE ORGANIC CO.NPOL'MISAVOCS) CIA CO1XAzwt0aR30UY.0 AMR Stack Test State 11/14/212 Fadwgs Pau P.dhrm.a. .4/MOGEV 0.17DESNO7 C.4.4 CO*JPJ0009/)30x90 AIR Stack Test .tote 11/13'2017 Meth T To Pan Pn is waa Carioca momande C4.4 COOVYWXIS/2300090 .110 Slack Test State 11/130012 Saul mg. Pass Pn..vena: I GL4fll11ORGANIC COMPOUNDS/VOCS) CAA C00000000i12300090 .AIR Stack Ten .tab 11/13/2012 Fr.dr.gs Pmt Pollusawo: ADMIXES OXIDES NO2 CAA C00000(00812300090 .110 Steak Tea State 11/12/2017 Fmds.gs Pass P i:wares. R9LITILE ORGANIC COMPOUNDS 12t7C3) r'.1.4 C000000008I2100090 .4/R Stuck Ten State 11/12/2012 Fadagr Pas Toilworn, Carbon mamnde ('.4.4 ('O00000X0123(UIZI .110 .Stuck lett :lute 11/17/2012 Fardregr Yens Ptdl.b.b. .VITROGAN ()AWES .V02 C'4.4 C 0001. 0011230x90 AIR Stack Ten Stan II/082012 Fiedler' Pas PhL.wwa: NITROGEN 0.1.71283 P102 t_C1 C'000000otm/730009t/ 110 Stock Test :late 11/082012 Fladrags Pan Panama Carbon mamma C4.4 0'00000000111300090 .41R Stack Ten State 11/0872011 Pmdsegr. Pas Palhsona VOLI'Ili ORGANIC COMPOUNDS IIVCS) C4.4 C0000tX100812300090 AIR Sit k Ten .taw 11/07/2012 Fadrugs Pm Pollab.b VOLATILE ORC24MCCO.tlPOI D)S IVOCO. C4.4 C00000000/17300090 .410 Stack Teti State 11/07012 Flndsvgr Fad Pot/wank M7ROGEV0.17Df.V02 CIA 0000000008/7300010 AIR Stack Ten Stale 11/070012 Fadrngs Pas Palatines Corbels .ranonh 0:44 C000nna12300090 .4/R .Stack Ten State /1t716CU12 F.athngs Pas P..:hno.b• VOL IILE(ROANICCM/POLNDS!9!X ) CIA COAM009001812300i00 .410 Stock Ter' Stale 116/6/2012 Fadnegs Posher Powdawb: M7ROG5N OXIDESN02 CIA 000000000)12300090 .1/R Stuck Ten :Tate 1111612017 Fmd..gs Pan Polluw.a. NITROGEN 017DESNO2 https://echo.epa.gov/detailed-facil ity-report?fid=CO0000000812300090 4/24/2017 Detailed Facility Report I ECHO I US EPA Page 4 of 7 Slerte Seven ID System Inpccusa Type Lead .Agency Duct Fvedmg CIA C00/X0000512300090 AIR Stark Ten Slate 11/062012 F'mds.gs Pon !Whitton Carbon monoxide CU C00000000812300990 0 0 00008/23 0 0990 .11R Smsk Ten Stole 114762017 Fmdi.gs PenJsng Pollutants Carbon mnmes& CIA CO0000000111100090 AIR Stook Ten State 11/7620/2 Faber ➢c„✓ing Pallutab IDUTIlSORGANIC CO.VP0UVDSImes) C l CO00COO0OSmoot7% .11R Stink Test State 11/02/7012 Ymdtnge Prange Pollutants Toluene Cif CUGO,WMM12340090 .41R Stock Ten San 11402012 F'mdigs Pending Pollutants. Xrl n. CIA C000COQ70g12300O9t1 AIR Stack Test Store 11/02/2012 Fntelogs Pon Pollutants 1/7drogesuullde CIA C000000001/2300090 AIR Stark Tett gore 11/02/2012 Fmds.gs Pending Pathaann: flaunt CIA CO000000W12300090 AIR Stock Ten Store 11/0212012 Fmdnugs Pan Pollwmiu .WT OGEVOA7DRS.V07 CAA C00000O0W2300090 d/R Slot Tett Stole 114212012 1 n.L.gs Pending Pa/ant. F.thylbesrene CIA CO0000000f17300090 AIR Sale Test Sling 11/02/7012 Miaow. Pao Pdlau.ts Carbon monnsiJe CU CO004400t%1234fA/90 AIR Stuck Ten 9ute 11/0212012 Findings Pins )cltwunts- Sul/w da.nde CU CUO020O0t$12300(J9e/ .11R Stock Tett Sale 1142/2012 Finding. Peada.g Pollutants. IUU771RUR0.IN/CIX.WPUUNDS(IUC7'1 CIA CO0(g000OS12300090 AIR Stink Tett Stoic 11/0212012 Fmds.gs Peadrng Palheaats: Senate CAA C00000000111?i00090 AIR SCI: ()aSste Sttic 052412012 Entries in italics are not considered inspections in official counts. Compliance Summary Data Sink CAA CWA Rt11A Source ID truss. SSs'; S,enill.aN 1',20-umpliencc>HPV inlet FFmnn wale ) 000000000511300090 C0R900322 COD149101646 Vca Na Na Domani,e Canon .401 1dduSWe wZV3017 1231/2016 QIn in NC (Nim.Ca abonajt ..—. A 04/7'2017 0 Three Year Compliance Status by Quarter Stance PseeaseeUntaM/Viotoaan Type CAA (Stuco ID: C00100010012300090) QTR I QTR 2 07/01-0910(14 1001-12/31/4 QTR 3 QTR 1 QTR 3 QTR 6 QTR 7 QTR I QTR 9 QTR 10 QTR II QTR 12 01,01- 0101- 07/01- 10(01- 0101- 0401- 07(01- 10101- 0144 Q94 03/3115 06/30/IS 09/30/1S 11/31,15 03(3116 0630'16 0930'16 1131116 03/31117 0430/17 flanks Typo Agee./ Fodky.lwtd IlMoo HPV IIPV HPV HPV IIPV IIPV HPV IIPV IIPV HPV ION IM' HIN HWe.)• Uod6t- nude- triad*. Casino Adds- Adder .AMnt4& - .- Adds.- Addis* MM. Mir State State State Stott Stoic Sane Stan Stale Suit Stole state suit Program Pulhnate CAAMACT, CAANSPS, CA.% F01V CO CAAPSD, CAASIP, CAATVP CAAMACT, CAANSPS. CAA HAV CO CAAPSD, CAASIP, CAATVP CAAMACT, CAANSPS, CA.% IWV CO CAAPSD, CAASIP, CAATVP CAANSPS. CAA UPC CO CAASIP, CAATVP CAAMACT. CAANSPS, CA.% FRY CO CAAPSD, CA ASH,. CAATVP HIstork Vienesiesa CAA CAA MALT (SECTION 6.1 NESHAPS) NSPS VOLATILE ORGANIC COMPOUNDS (VOCS) NITRIRWEN OXIDES NO2 Va.ATtE ORGANIC CQAWuNIIS (VOCS) NITROGEN OXIDES N02 VOLATILE ORGANIC COMPOUNDS (VOCE) 11.05''.011 01.'01.,_313 1010WXII2 09'177000 11/08/2014 V-HPV V-HPV Vie Via V -NW V-IWV Via Via • https://echo.epa.gov/detailed-facility-report?fid=0O0000000812300090 4/24/2017 Detailed Facility Report I ECHO I US EPA Page 5 of 7 titanic CAA CA.\ CA ProgarePollutantNiolaoon Type PST) SIP TITLE. V PERMITS QTR I QTR 2 QTR J QTR 4 QTR S QTR 6 QTR 7 QTR 8 QTR 9 QTR 10 QTR II QTR 12 \'-HPV V.IIPV Me \40 V-HPV Vio V•HPV V-IIPV Vio Vio Shutt I'rortam Pollutant/Violation Type CWA CWA CWA ('WA CW S ,Source ID. COR900328) F. airO-Lerel Palos SNC (Srenlfiunl Nue-tompllance)/RNC (Repnrlsbl. Not- fomplisncel History Ferran Schedule Violations Schedulc Eton sauced Lab but I sported: 14rftnu Compliant P<A Ynlaa c Evaluation QTR I QTR 2 QTR 3 QTR 4 QTR S QTR 6 QTR 7 QTRII QTR 9 QTR IO QTR 11 QTR 12 01101- 04/01. 07/01- 10/01- 01/01-0391115 04/01. 07/01- 10/01. 01/01. 04/01- 07/01- 1001- 0331/14 0630/14 0➢/30/16 12/31/14 06/30/15 0990/.5 123145 0171116. 06/30/16 09/30/16 12/31/16 N. Viol N. VW N. N. 1/101 VW t. VW V (NoraNC V) 03.31.15 No No VW VW 05.29- 15 Schedule Et au rspatd Lac Perform Compliance Performance 05-29- Et al0331.13 15 Schedule Etw onthsa'<d and not reported Paftrm Cnmelias Pafoeaun.x Ftaluatiurs Schedule Etta( unearned bot reported: Perform ('omplunee Performance Evaluate* 03-31.15 03-11• I S 05.29' IS 03.29. IS N. N. N. VIA V1d VW No Na Viol VW QTR I3- 01101-04/21/17 thug Stmt Program Pollutant Vtolmun'type QTR I Q1R2 QTR3 QTR4 QTRS HER.5 (Source IL. ('OD14911416461 07101-09'30/14 1001.121114 0101.03'31'15 04/01.06130115 07(OL09/3Ni5 RCR t FaciWy-Lad Status QTR 6 QTR 7 QTR I QTR 9 QTR 10 QTR II QTR 12 10(01-1.7. 3105 01/01.03/31/16 04/01.06/34116 07101-0030/16 1001.12/31/16 01/0I-03/31/17 0401-0H3W17 Informal Enforcement Actions (5 Years) Statute CAS CAA CAA Swum %IR tIN ttN 11R Sarcc ll l T)ps of Arnim ('17000001108 12300090 ('(700000004/1!300090 (700003000411100090 ('(100000014123W0Y0 Notice o(Vrolataa. Noire of Niobium Vortex of Volume Notts of Violas, lad Wares State "tic Sale Sat Lam 08' 192015 06'21/2013 06121/2013 0921/3H2 Formal Enforcement Actions (5 Years) CAA CAA CAA CAA CAA Source II) Tye< of :taste ,'00000000812300090 C001000001112300190 8 1 23 00 0'90 C001000004 12-'00090 000000000812300090 %Snouuau c (lido tdmmsarahve (hJo tdatmauahvo Order %dm.ruuaotc (lido teal ..Ivlq Star State Sam Stu< Dots 06/21/2016 141271'3115 0427/2013 04/27/2015 Pauli) 556.700 SI 30.800 so SO Pawky Ik.uiplae. ICIS (Integrated Compliance Information System) Case History (5 years) Primary l.aw.Scctou Can No. tame Type load Agency Cat Name ItstwlV'tkd Dare Settlementl),Iu Federal Penalty Sutlau! Pasahy No data records rammed SEP (Supplemental Fav-uunmmtl Pru)oet) Coil Comp .Sctaoo ('oft Environmental Conditions Water Quality https://echo.epa.gov/detailed-facility-report?fid=0O0000000812300090 4/24/2017 Detailed Facility Report I ECHO I US EPA Page 6 of 7 Passe lD C'OR9t10321 Coebied Sawa Speer Number of CSO (Cambiead Sawa Ovatl w) Outtalk I ]-Dips wnn (waieaded Ramdary Dame) Hl'C (RAD (Red Address Daubed)) With IWalaebd Ragtag Dade) Subwatads d Name (RAD (Red :3ddree Daubed)) State Walabody Name (ICIS du g:ra eel Compliance Info.m.tim Spun)) (01900030606 City of Rvase-Sods Woo Riva dead Impend Wean Clan Caro of Impaine d(i0 by Orucp ) Wade Valid. Caul - Akan Reawv Weeded with ESA (Endaaprd Spade .kaHmlod Aquatic Spasm' No llr Waterbody Designated Uses Road Code Warcrbody Name Fxocptrmal Use Recreational Ilse Aquatic life t'de Sbdlfmb Dne Bed Closure Within Lae Ice Reach (lours Within Dart Two 1w. 1019(10V3tVt1560 No No No No No No Air Quality Non-:3Wmmad 4u' 1'a No To No Pdalaml.) Oise Lod Particulate Mahe Sd<t [boxs Pollutants Toxics Release Inventory History of Reported Chemicals Released in Pounds per Year at Site 0 TRI Facald) ID Tw Total As Emotions Salicc Wata Docuarlo Air Pollutant Report Ott'-sdo Tru de' lo POT W. IPS:tidy Owed Trcacmmt Wets) Undapumd ln)wtium Rdsw to Land Total Ca-aieRekase Total Off+Sc Reload No data record. raeaod Toxics Release Inventory Total Releases and Transfers in Pounds by Chemical and Year 0 tisamul Name NO data recede rctancd Demographic Profile Demographic Profile of Surrounding Area (3 Miles) This section provides demographic information regarding the community surrounding the facility. ECHO compliance data alone are not sufficient to determine whether violations at a particular facility had negative impacts on public health or the environment. Statistics are based upon the 2010 US Census and American Community Survey data, and are accurate to the extent that the facility latitude and longitude listed below are correct. The latitude and longitude are obtained from the EPA Locational Reference Table (LRT) when available. Radius of Arca t'cra [atiedc t'de I.oepmdc Tool Peseta ) 40 7665$3 -104.734944 1.587 1 and Area Wee Ara Population Dainty Pacatt Minmdy 0% 56:14 ml 50% Hm.dtold. m 4a Houses tone m Ara Ilocuholdt m Pubbc 3autancc Patad Rebel Await I cvd 532 573 7 537 Kea Raeakdewn Pawn (L) lac Breakdown Peace i'.1 https://echo.epa.gov/detailed-facility-report?fie=C O00000008 12300090 4/24/2017 Detailed Facility Report I ECHO I US EPA Page 7 of 7 Itacc Arcakdoan 11Lrtc Abxan-.%mcn;an Hrpag c 0ngm .4ra.Pacthc Itlauda .Uaaicut Wan. ()thaAtknaial Paton (%) 1.271(11%) 10(1%) 756 (4$%1 7 (0%) 13 (I%) 279 (l1%) 1gc AsulNnan Etcatios Lcvcl (peraata 25 & ohda) (cats than Mh Glade Mh through 1201 Grade Htgh Schrnd Diploma Srmc Culkgc2yi. R A.A. or More: (Ldd 5 van and younger Minor. 17 %cats and young., \data IS vicars and oldcr Scnuu. 65 van and nits Plan...(%1. 120(11.42%) 131(13.13%) 323 (30.73%) 336 01.97%) 134(1275%) In.annc Atcakduarn [ at than 515.000 515.900 - n5.000. $25.000.550900 55(1pu0 - S15.000 Grata than S75.000. Pawns 1%) 96 (6•) 447 (2850 1.140 (72%) 164 (ION Hao.d1o16n(5) 40 (6.99%) 70(1134%) 193 (33.74%) 113 (19.76%) 156 (27.27%) https://echo.epa.gov/detailed-facility-report?fid=0O0000000812300090 4/24/2017 COLORADO Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Eric Ewing 16974 CR 40 La Salle CO 80645 970-347-7737 Via email: ewinghr@yahoo.com 17 April 2017 RE: Request dated 13 April 2017 Dear Mr. Ewing, The Colorado Department of Public Health and Environment, Air Pollution Control Division (Division) is in receipt of your request for: DCP Mewbourn Gas Processing Facility MEWBOURN GAS PLANT 18455 WELD COUNTY RD 35, GILCREST, CO 80623 Source ID: CO0000000812300090 AIRS No: 123/0090 1. Current status regarding compliance with state air and construction permits. 2. If non -compliant, a list of what is left to do to be compliant. 3. History of complaints regarding air pollution, emissions, and releases. 4. Record of releases and emissions including quantity and contents (how much of what pollutant) reported by DCP Midstream between July 2012 to current. 5. Emails and communications between CDPHE, DCP Midstream and/or Weld County regarding compliance of DCP Midstream Mewbourn Gas Plant. Division staff has performed a preliminary review and estimates that it will take approximately 12 hours of staff time to find, retrieve and perform an initial review the requested records associated with this request. The estimated minimum cost associated with fulfilling this portion of the records request is $360.00 ($30 per hour for 12 hours) in accordance with our Department Open Records Act policy. We do have enforcement action reports available on our web site, at this link: https: / /www.colorado.gov/pacific/cdphe/enforcement-action-reports Many records have been digitized and are readily available via our Web Drawer, at this link: http: //environmentalrecords.colorado.gov/ HPRMWebDrawer/ Record I would recommend to search the Record Number, from the drop down menu, and then the first seven of the AIRS ID, xxx-xxxx. Here's an example: 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.cotorado.gov/cdphe John W. Hickenlooper, Governor Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer Cotes: . :c1 l-. . i , ;!\ y ;X: Record Number I23-00C11 Go to the right side of the screen and select the contents button: Contents :4: I'. Y?L (WI If you wish specific records from the facility file, which you do not find via Web Drawer, please identify which ones you would like and I can provide you with an estimate for scanning those. I can create a record by performing a data pull for a list of complaints for this facility. There is an associated $30 data pull fee for this. Also, we do redact citizen information on complaints. It wilt take approximately one hour to perform those redactions, with an estimated cost of $30 ($30 per hour for 1 hour). I cannot release the current inspection report until has been finalized. Also, some of the records you have requested may be subject to an investigatory hold. I would not be able to identify those specific documents until we have gathered the records and performed the review. Once the investigation is complete, the public records would be available. CORA allows an agency to recover some of the costs associated with responding to a request for records. See § 24-72-205, C.R.S. CDPHE Policy 2.17 ("Policy") establishes the costs associated with producing records. See, https://www.colorado.gov/pacific/cdphe/department-policy-2.17 The Policy states, "[i]f researching, retrieving, reviewing and producing records consumes more than one hour of staff time, the Division charges $30 an hour for all staff time associated with locating and producing records for a requester." Department policy states that all records requested are to be reviewed prior to release. The total for this portion of your estimate is $420.00 ($360.00 to find, retrieve and perform initial review; $30.00 data pull; $30.00 time for redactions). If you authorize these charges, please take the following action: 1. Notify me by email at cdphe_apcd_records@state.co.us , and 2. You may pay via credit card (VISA or MasterCard are accepted), or, 3. Remit a check or money order, payable to the Colorado Department of Public Health and Environment and mail to: CO Dept. of Public Health and Environment Attn: APCD Records Manager 4300 Cherry Creek Drive South Denver, CO 80246-1530 Upon receipt of payment, staff will begin compiling the records. It may be that the retrieval and initial review can be accomplished in less than the estimated time; if this is the case, the applicable portion of your deposit will be returned to you. It may be that, upon further review, staff will 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303.692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor ; Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer o^ca\ Sxt t kl. determine that additional document retrieval and/or review time is needed to respond to your request. If that is the case, the Division will notify you prior to performing the work. If, during the review process, it is determined that there are privileged records, the Division wilt notify you. This estimate does not include creation of a Vaughn Index (privilege log) or affidavit. If you wish to receive a Vaughn Index and affidavit, the estimate for creating these documents wilt be based up on the actual costs involved. When the documents are ready, the Division win contact you to make arrangements for their inspection and copying/scanning. If the number of pages exceeds 25, the Division charges $.25 per page for all documents copied/scanned. Responsive records can be burned to a CD, which has an additional cost of $10.00. Or, if the size of records exceeds what can be burned onto a CD, we do have thumb drives available, for which actual costs may exceed $10.00. This estimate does not include potential copying/scanning fees. Records that were identified during the preliminary review will be retained for 30 calendar days after the date of this estimate. If authorization and payment as described above are not received within the 30 -day timeframe, records will be returned to their normal records retention cycles according to Department policy. Please let me know if you have any questions. Feet free to call me at 303-692-3221 or email at margaret.knox-kruschke@state.co.us Sincerely, ? Margaret Knox-Kruschke Records Manager Air Pollution Control Division Colorado Department of Public Health and Environment 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.cotorado.gov/cdphe John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer -Na• a, %Cy\ f; _ Printed from electronic record COLORADO Department of Public Health & Environment AIR POLLUTION CONTROL DIVISION COMPLIANCE ORDER ON CONSENT CASE NO. 2015-073 AIRS NO. 123/0090 IN THE MATTER OF DCP MIDSTREAM, LP The Colorado Department of Public Health and Environment ("CDPHE"), through the Air Pollution Control Division ("Division"), issues this Compliance Order on Consent ("Consent Order"), pursuant to the Division's authority under § 25-7-115(3)(b), C.R.S. of the Colorado Air Pollution and Prevention and Control Act, §§ 25-7-101 to 1309, C.R.S. ("the Act"), and its implementing regulations, 5 C.C.R. § 1001, et seq ("the Regulations") with the express consent of DCP Midstream, LP ("DCP"). The Division and DCP may be referred to collectively as "the Parties." I. STATEMENT OF PURPOSE The mutual objectives of the Parties in entering into this Consent Order are: 1. To establish compliance requirements and criteria for the continued operation of DCP's Mewbourn Natural Gas Processing Plant located in SE 'A Section 35, T4N, R66W in Weld County Colorado ("Facility"); and 2. To resolve the violations of the Act cited herein and in a Compliance Advisory issued to DCP by the Division on August 19, 2015. II. DIVISION'S FINDINGS OF FACT AND DETERMINATION OF VIOLATIONS Based upon the Division's investigation into and review of the compliance issues identified herein, and in accordance with § 25-7-115(3), C.R.S., the Division has made the following determinations regarding violations of regulatory, statutory, and/or permit requirements associated with the Facility. 3. At all times relevant to the violations cited herein, DCP was a foreign limited partnership in good standing and registered to conduct business in the State of Colorado. EXHIBIT Cj Via i1 •n cam. J Printed from electronic record 4. DCP owns and/or operates the Facility. The Facility is subject to the terms and conditions of Colorado Construction Permit Number 09WE1136 Issuance 2 issued to DCP Midstream, LP on June 28, 2012 ("Permit Number 09WE 1136"), Colorado Air Quality Control Statutes, and Colorado Air Quality Control Commission ("AQCC") Regulations. 5. The following equipment is subject to Permit Number 09WE 1136: AIRS Point Facility Equipment ID Point Description 101 C-211 One (1) Caterpillar, G379NA, SN: 72B641, natural gas fired, 4 -stroke, rich - burn, naturally aspirated, reciprocating internal combustion engine, heat input rated at 2.6 MMBTU per hour, output rated at 330 HP, running a natural gas / vapor compressor. Emissions are controlled by AFR and a Non -Selective Catalytic Reduction system. 102 C-167 One (1) Waukesha, L7044GSI, SN: C13852-1, natural gas fired, 4 -stroke, rich - burn, turbocharged, reciprocating internal combustion engine, heat input rated at 12.9 MMBTU per hour, output rated at 1,680 HP, running a natural gas compressor. Emissions are controlled by AFR and a Non -Selective Catalytic Reduction System. 103 C-179 One (1) Waukesha, L7042GSI, SN: 240410, natural gas fired, 4 -stroke, rich - burn, turbocharged, reciprocating internal combustion engine, heat input rated at 11.6 MMBTU per hour, output rated at 1,478 HP, running a natural gas compressor. Emissions are controlled by AFR and a Non -Selective Catalytic Reduction System. 104 C-129 One (1) Waukesha, L7042 GU, SN: 286822, natural gas fired, 4 -stroke, rich - burn, naturally aspirated, reciprocating internal combustion engine, heat input rated at 6.4 MMBTU per hour, output rated at 896 HP, running a natural gas compressor. Emissions are controlled by AFR and a Non -Selective Catalytic Reduction system. 105 C-134 One (1) Waukesha, L7042GU, SN: 285300, natural gas fired, 4 -stroke, rich - burn, naturally aspirated, reciprocating internal combustion engine, heat input rated at 6.4 MMBTU per hour, output rated at 896 HP, running a natural gas compressor. Emissions are controlled by AFR and a Non -Selective Catalytic Reduction system. 106 C-130 One (1) Waukesha, L7042GSI, SN: 339839, natural gas fired, 4 -stroke, rich - burn, turbocharged, reciprocating internal combustion engine, heat input rated at 11.2 MMBTU per hour, output rated at 1,478 HP, running a natural gas compressor. Emissions are controlled by AFR and a Non -Selective Catalytic Reduction system. 107 C-131 One (1) Waukesha, L7042GSI, SN: 397541, natural gas fired, 4 -stroke, rich - burn, turbocharged, reciprocating internal combustion engine, heat input rated at 11.2 MMBTU per hour, output rated at 1,478 HP, running a natural gas compressor. Emissions are controlled by AFR and a Non -Selective Catalytic Reduction system. 108 F017 Facility Equipment Leaks. Emissions minimized by Leak Detection and Repair Program. 109 LO Condensate loadout. Emissions controlled by a combustor. ®COLORADO An Pollution Cannot Division Printed from electronic record AIRS Point Facility Equipment ID Point Description 110 TANKS Four (4) tanks, 400 bbl each, for storage of stabilized natural gas condensate. Emissions controlled by a combustor. 111 C0170 One (1) Solar, Taurus 60, SN: TC 10559, natural gas fired combustion turbine, heat input rated at 50.1 MMBTU per hour. This is equipped with Dry Low NOx combustion system for minimizing emissions of Nitrogen Oxides. This powers a natural gas compressor. Identified as Inlet 1. 112 C0180 One (1) Solar, Taurus 60, SN: TC 10560, natural gas fired combustion turbine, heat input rated at 50.1 MMBTU per hour. This is equipped with Dry Low NOx combustion system for minimizing emissions of Nitrogen Oxides. This powers a natural gas compressor. Identified as Inlet 2. 113 C250 One (1) Caterpillar, G3608TALE, SN: BEN00563, natural gas fired, 4 -stroke, turbo -charged, lean -burn, low emissions design, reciprocating internal combustion engine, heat input rated at 17.9 MMBTU per hour, output rated at 2,370 HP, powering a natural gas compressor. Emissions are controlled by an oxidation catalyst. Identified as Residue 1 114 C251 One (1) Caterpillar, G3608TALE, SN: BEN00565, natural gas fired, 4 -stroke, turbo -charged, lean -burn, low emissions design, reciprocating internal combustion engine, heat input rated at 17.9 MMBTU per hour, output rated at 2,370 HP, powering a natural gas compressor. Emissions are controlled by an oxidation catalyst. Identified as Residue 2. 115 C252 One (1) Caterpillar, G3608TALE, SN: BEN00567, natural gas fired, 4 -stroke, turbo -charged, lean -bum, low emissions design, reciprocating internal combustion engine, heat input rated at 17.9 MMBTU per hour, output rated at 2,370 HP, powering a natural gas compressor. Emissions are controlled by an oxidation catalyst. Identified as Residue 3. 116 C253 One (1) Caterpillar, G3608TALE, SN: BEN00572, natural gas fired, 4 -stroke, turbo -charged, lean -bum, low emissions design, reciprocating internal combustion engine, heat input rated at 17.9 MMBTU per hour, output rated at 2,370 HP, powering a natural gas compressor. Emissions are controlled by an oxidation catalyst. Identified as Residue 4. 117 C254 One (1) Caterpillar, G3608TALE, SN: BEN00571, natural gas fired, 4 -stroke, turbo -charged, lean -bum, low emissions design, reciprocating internal combustion engine, heat input rated at 17.9 MMBTU per hour, output rated at 2,370 HP, powering a natural gas compressor. Emissions are controlled by an oxidation catalyst. Identified as Residue 5. 118 G 1650 One (1) Solar, Taurus 70, SN: TG09548, natural gas fired combustion turbine, heat input rated at 61.6 MMBTU per hour. This is equipped with Dry Low NOx combustion system for minimizing emissions of Nitrogen Oxides. This runs an electric power generator. Identified as Genset 1. 119 G1670 One (1) Solar, Taurus 70, SN: TG09549, natural gas fired combustion turbine, heat input rated at 61.6 MMBTU per hour. This is equipped with Dry Low NOx combustion system for minimizing emissions of Nitrogen Oxides. This runs an electric power generator. Identified as Genset 2. CoCOLORADO O wtr Pollution Control Division Cew^ue' J MRYL b Lbw:mown: Printed from electronic record AIRS Point Facility Equipment ID Point Description 120 AM001 Natural gas sweetening (by removal of Carbon Dioxide and Hydrogen Sulfide) system (Precision Pipe & Vessel, LLC, Model 1502, SN: 2381-9089) using a 30-50% solution of Methyldiethanolamine (MDEA), process feed gas design rated at 160 MMSCF per day, and an amine recirculation rate of 640 gallons per minute. This system consists of: natural gas / amine contactor, amine flash tank, and amine regenerator (heating unit under AIRS PT ID: 123/0090/121). Emissions from the still vent are routed to a regenerative thermal oxidizer (AIRS PT ID: 123/0090/124). Emissions from the flash tank are routed to a vapor recovery unit (VRU) and returned to the plant inlet. 121 H776 One (1) Optimized Process Furnace, Inc., Model 200, SN: J091036, natural gas fired amine regeneration reboiler, heat input design rated at 64.9 MMBTU per hour. This is equipped with Ultra -Low NOx combustion system for minimization of Nitrogen Oxides emissions. - D-931 Natural gas dehydration system using Triethylene glycol (TEG), (Exterran, SN: 8907) process feed design rated at 160 MMSCF per day, and two (2) electric Rotor pumps with design glycol recirculation rate of 25 gallons per minute each (total of 50 gallons per minute). This system consists of: natural gas / glycol contactor, glycol flash tank, glycol regenerator reboiler (heat provided by hot gases from various combustion processes supplemented by a hot oil heater (AIRS Point ID: 123/0090/123). Flash tank off gases are directly routed to a VRU and returned to the plant inlet. Still vent emissions are routed through a condenser, and then to regenerative thermal oxidizer (AIRS PT ID: 123/0090/124). 122 123 H771 Two (2) Devco, HeliFlow, SN: 3431-3, natural gas fired hot oil heaters, heat input design rated at 26.0 MMBTU per hour each. These are equipped with Ultra-Low-NOx combustion systems for minimization of Nitrogen Oxides emissions. Hot oil is used to provide heat to various natural gas processes at the facility including supplemental heat for glycol regeneration reboiler. Only one heater to be operated at a time, the other is to be used as a backup. 124 TO701 One (1) Anguil Environmental Services, Inc., Model 200, SN: 14808, regenerative thermal oxidizer, heat input design rated at 11.0 MMBTU per hour. Natural gas used for startup. This is equipped with Low NOx combustion system for minimization of Nitrogen Oxides emissions. Emissions from various processes at this facility are routed into this thermal oxidizer for thermal destruction. Natural gas is used for startup to raise the temperature to normal operating level. 6. On September 24, 2014, Mr. Tim Taylor, of the Division, conducted an inspection, pursuant to the Division's authority under § 25-7-111(2)(c), C.R.S., at the Facility for the purpose of determining compliance with Permit Number 09WE 1136, the Act and the Regulations for the period commencing August 1, 2012 and ending August 31, 2014. Based on Mr. Taylor's inspection, and a review of records related to the Facility, the Division issued a Compliance Advisory to DCP on August 19, 2015. 7. On October 8, 2015, DCP caused written responses to the issues identified by the Division in the Compliance Advisory to be filed with the Division. On October 28, 2015 and November 17, 2015, the Division and DCP met to discuss the issues identified in the Compliance 4 COLORADO CO Air Pollution Control Division Oronene-i .t Purl •4.11h h L.n+f..n. Printed from electronic record Advisory and DCP's written responses to those issues. On November 16, 2015, December 1, 2015 and December 11, 2015, DCP submitted additional information to the Division in writing relatedto the issues identified in the Compliance Advisory and the discussions concerning those issues between the parties that took place on October 28, 2015 and November 17, 2015. 8. Based upon a review of information including Mr. Taylor's inspection, records related to the Facility, and the information provided by DCP, the Division has determined the following: a. DCP failed to limit emissions of air pollutants to the specified emission limits, provide emissions records, and/or to correctly calculate emissions from each emission unit on a rolling 12 -month total, violating Permit Number 09WE1136, Condition 5. i. AIRS Point 101: DCP failed to correctly calculate March 2014 emissions. DCP submitted corrected calculations to the Division on October 8, 2015. ii. AIRS Point 106: DCP failed to correctly calculate March 2014 emissions. DCP submitted corrected calculations to the Division on October 8, 2015. iii. AIRS Point 107: DCP failed to correctly calculate March 2014 and May 2014 emissions. DCP submitted corrected calculations to the Division on October 8, 2015. iv. AIRS Point 109: DCP failed to provide records of carbon monoxide ("CO") emissions for the combustor controlling the condensate loadout from August 2012 to August 2014. DCP submitted the records to the Division on October 8, 2015. v. AIRS Points 109 and 110: DCP reported the pilot light for the flare controlling the condensate tanks and loadout was not lit during September 2014, August 2014, July 2014, June 2014, May 2014, April 2014, March 2014, and from April 1 — 3, 2013; March 14 — 31, 2013; February 19 — 28, 2013; February 1 — 6, 2013; September 17 — 27, 2012; September 6 — 9, 2012; and September 3, 2012. DCP submitted electronically recorded data to the Division on October 8, 2015 showing the pilot light was lit or partially lit on all but 2 days during the inspection period . On November 17, 2015 the Division requested that DCP recalculate the control efficiency of the flare for the days the pilot light was either not lit or was partially lit. DCP supplied recalculated control efficiencies to the Division on December 1, 2015. *® COLORADO C O AU Pollution Control Mouton 7eoH+.. > 'ia .wm' b 6nviwrr * Printed from electronic record vi. MRS Points 118 and 119: DCP exceeded the annual nitrogen oxides ("NOx") (combined 17.49 tons per year "tpy") and CO (combined 17.76 tpy) emission limits for the Genset Turbines G1650 and G1670 for the rolling 12 -month period ending August 2014 with NOx emissions of 17.67 tpy and CO emissions of 17.96 tPY• vii. AIRS Point 120: DCP failed to provide rolling 12 -month records of hydrogen sulfide ("H2S") emissions for the amine unit from August 2012 to August 2014. DCP submitted the records to the Division on October 8, 2015. viii. AIRS Point 124: DCP failed to provide rolling 12 -month records of sulfur dioxide ("SOx") emissions for the RTO from August 2012 to August 2014. DCP submitted the records to the Division on October 8, 2015. b. DCP failed to comply with the specified process rates and/or to correctly calculate consumption for each unit on a rolling 12 -month total, violating Permit Number 09WE 1136, Condition 11. i. AIRS Point 101: DCP failed to accurately calculate March 2014 fuel use. ii. AIRS Point 103: DCP exceeded the monthly fuel use limit of 8.19 MMscf/month for engine C-179/AIRS Point 103 in May 2014 (8.95 MMscf/month). DCP submitted corrected records to the Division on October 8, 2015. iii. AIRS Point 106: DCP failed to accurately calculate March 2014 fuel use. DCP submitted corrected records to the Division on October 8, 2015. iv. AIRS Point 107: DCP failed to accurately calculate March 2014 and May 2014 fuel use. DCP submitted corrected records to the Division on October 8, 2015. v. AIRS Points 118 and 119: DCP exceeded the combined monthly fuel use limit of 47.36 MMscf/month for the generator turbines G- 1650 and G-1670/AIRS Points 118 and 119 in April 2013 (50.19 MMscf/month). vi. AIRS Point 120: DCP exceeded the monthly feed natural gas limit of 4,960 MMscf/month for the amine unit AM001 /AIRS Point 120 in May 2013 (5,059 MMscf/month). COLORADO Atr Potlutton Control Dtvtafon }esne., 'r Nate e Heft, b Em. tarry," Printed from electronic record vii. AIRS Point 121: DCP exceeded the monthly fuel use limit of 45.986 MMscf/month for the heater H776/AIRS Point 121 in May 2014 (51.95 MMscf/month). DCP submitted corrected records to the Division on October 8, 2015. viii. MRS Point 123: DCP exceeded the monthly fuel use limit of 18.422 MMscf/month for the heater H771/AIRS Point 123 in May 2014 (20.81 MMscf/month) and August 2013 (18.68 MMscf/month). DCP submitted corrected records to the Divison on October 8, 2015. ix. AIRS Point 124: DCP exceeded the monthly waste gas combusted limit of 141 MMscf/month for the RTO TO701/AIRS Point 124 in May 2013 (146.82 MMscf/month), March 2013 (144.34 MMscf/month), November 2012 (153.45 MMscf/month) and October 2012 (155.35 MMscf/month). DCP exceeded the annual waste gas combusted limit of 1655 MMscf/yr for TO701/AIRS Point 124 for the rolling 12 -month periods ending October 2013 (1,671 MMscf/yr), September 2013 (1,686 MMscf/yr), August 2013 (1,666 MMscf/yr) and May 2013 (1,602 MMscf/yr). c. DCP failed to limit the maximum lean amine recirculation pump rate to 640 gallons per minute on the following dates, violating Permit Number 09WE 1136, Condition 12. 4/20/2013 5/21/2013 7/17/2013 9/8/2013 4/21/2013 5/22/2013 7/18/2013 10/3/2013 4/22/2013 5/24/2013 8/1/2013 10/4/2013 4/23/2013 5/26/2013 8/5/2013 10/5/2013 4/24/2013 6/8/2013 8/15/2013 10/6/2013 4/26/2013 6/12/2013 8/16/2013 10/7/2013 4/28/2013 6/16/2013 8/19/2013 10/8/2013 4/29/2013 7/11/2013 8/21/2013 10/9/2013 5/18/2013 7/13/2013 8/22/2013 11/1/2013 5/19/2013 7/14/2013 8/31/2013 2/28/2014 5/20/2013 7/15/2013 9/7/2013 d. DCP failed to record the lean glycol circulation rate for the triethylene glycol (TEG) dehydrator under AIRS Point 022 on the following dates: October 11 — 12, 2013; October 22, 2013; December 1 — 8, 2013; December 14, 2013; December 19 — 31, 2013; January 1 — 7, 2014; . COLORADO C O Au voihtl/on Control Division Printed from electronic record January 16 — 31, 2014; March 25 — 26, 2014; and March 29 — 31, 2014; violating Permit Number 09WE1136, Condition 13. e. The emergency flare exceeded 20% opacity for 24 hours on May 21, 2014, in violation of Permit Number 09WE1136, Condition 15. f. DCP failed to meet the Subpart KKK Delay of Repair requirements for 57 components, including 37 valves, violating Permit Number 09WE1136, Condition 22. As of October 2015, 7 components remain on Delay of Repair. g. DCP failed to control emissions from AIRS Point 122 by 90% on November 27 — 28, 2014 as a result of non -operation of the RTO, violating Permit Number 09WE1136, Conditions 29 and 30. h. DCP failed to follow the O&M Plans and recording keeping formats approved by the Division, violating Permit Number 09WE1136, Condition 33. i. DCP failed to record daily catalyst inlet temperatures for the Reciprocating Internal Combustion Engines ("RICE") as follows: Month Catalyst Inlet Temperatures Not Provided (hours of operation) August 2012 AIRS Point 113/C-250 (438 hours), AIRS Point 114/C-251 (617 hours), AIRS Point 115/C-252 (293 hours), AIRS Point 116/C- 253 (665 hours), AIRS Point 117/C-254 (529 hours) September 2012 AIRS Point 101/C-211 (554 hours; only 4 daily readings — should be at least 23), AIRS Point 104/C-129 (223 hours; only 4 daily readings — should be at least 9) November 2012 AIRS Point 101/C-211 (705 hours; only 4 daily readings — should be at least 30), AIRS Point 104/C-129 (499 hours; only 4 daily readings — should be at least 21), AIRS Point 105/C-134 (296 hours; only 2 daily readings — should be at least 12) December 2012 AIRS Point 101/C-211 (737 hours; only 5 daily readings — should be at least 31) and AIRS Point 104/C-129 (124 hours; only 1 daily reading — should be at least 5) January 2013 AIRS Point 101/C-211 (735 hours; only 4 daily readings — should be at least 31) February 2013 AIRS Point 101/C-211 (654 hours; only 4 daily readings — should be at least 27) and AIRS Point 105/C-134 (9 hours, no readings) March 2013 AIRS Point 101/C-211 (736 hours; only 4 daily readings — should be at least 31), AIRS Point 104/C-129 (147 hours; only 2 daily readings — should be at least 6), AIRS Point 105/C-134 (161 hours; only 2 daily readings — should be at least 7) April 2013 AIRS Point 101/C-211 (684 hours; only 5 daily readings — should be at least 28) May 2013 AIRS Point 101/C-211 (744 hours; only 4 daily readings — should be at least 31) June 2013 AIRS Point 101/C-211 (709 hours; only 4 daily readings — should COLORADO CO O Air nonunion Control Division c . 'm.c v n.e1c .b.Mh a rnwonn.nj Printed from electronic record be at least 30), AIRS Point 103/C-179 (485 hours; only 18 daily readings — should be at least 20), AIRS Point 106/C-130 (75 hours, no readings), AIRS Point 107/C-131 (277 hours; only 8 daily readings — should be at least 11), AIRS Point 113/C-250 (440 hours; only 12 daily readings — should be at least 18), 114/C-251 (565 hours; only 16 daily readings — should be at least 23), AIRS Point 115/C-252 (537 hours; only 14 daily readings — should be at least 17), 116/C-253 (632 hours; only 18 daily readings — should be at least 26), AIRS Point 117/C-254 (694 hours; only 21 daily readings — should be at least 29) July 2013 AIRS Point 101/C-211 (737 hours; only 5 daily readings — should be at least 30) August 2013 AIRS Point 101/C-211 (716 hours; only 4 daily readings — should be at least 31), AIRS Point 102/C-167 (711 hours; only 18 daily readings — should be at least 29), AIRS Point 103/C-179 (612 hours; only 15 daily readings — should be at least 25), AIRS Point 113/C-250 (623 hours; only 15 daily readings - should be at least 26), AIRS Point 114/C-251 (717 hours; only 19 daily readings - should be at least 30), AIRS Point 116/C-253 (214 hours; only 4 daily readings — should be at least 9), AIRS Point 117/C-254 (726 hours; only 19 daily readings — should be at least 30) September 2013 AIRS Point 101/C-211 (703 hours; only 5 daily readings — should be at least 29), AIRS Point 107/C-131 (36 hours) October 2013 AIRS Point 101/C-211 (730 hours; only 3 daily readings — should be at least 30), AIRS Point I 15/C-252 (330 hours; only 7 daily readings — should be at least 14) November 2013 AIRS Point 101/C-211 (690 hours; only 5 daily readings — should be at least 29), AIRS Point 103/C-179 (422 hours; only 8 daily readings — should be at least 13), AIRS Point 115/C-252 (704 hours; only 22 daily readings — should be at least 29), AIRS Point 116/C-253 (636 hours; only 12 daily readings — should be at least 26), AIRS Point 117/C-254 (703 hours; only 22 daily readings — should be at least 29) December 2013 AIRS Point 101/C-211 (729 hours; only 5 daily readings — should be at least 30), AIRS Point 102/C-167 (687 hours; only 17 daily readings — should be at least 28), AIRS Point 103/C-179 (528 hours; only 1 daily reading — should be at least 22), AIRS Point 113/C-250 (660 hours; only 16 daily readings — should be at least 27), 114/C-251 (632 hours; only 17 daily readings — should be at least 26), AIRS Point 115/C-252 (719 hours; only 16 daily readings — should be at least 30), AIRS Point 116/C-253 (658 hours; only 8 daily readings — should be at least 27), AIRS Point 117/C-254 (617 hours; only 17 daily readings — should be at least 26) January 2014 AIRS Point 101/C-211 (742 hours; only 3 daily readings — should be at least 31), AIRS Point 103/C-179 (359 hours; only 9 daily readings — should be at least 15), AIRS Point 114/C-251 (408 hours; only 11 daily readings — should be at least 17), AIRS Point 115/C-252 (697 hours; only 25 daily readings — should be at least 29) February 2014 AIRS Point 101/C-211 (661 hours; only 4 daily readings — should be at least 28) April 2014 AIRS Point 101/C-211 (606 hours; only 3 daily readings — should be at least 25), AIRS Point 1 13/C-250 (617 hours; only 16 daily ®COLORADO Au Pollution Control Division (,n,ru v 01.pC YtYn fi [nnmrr+ Printed from electronic record readings — should be at least 25), AIRS Point 114/C-251 (450 hours; only 4 daily readings — should be at least 19) May 2014 AIRS Point 101/C-211 (200 hours; only 3 daily readings — should be at least 8) June 2014 AIRS Point 101/C-211 (573 hours; only 5 daily readings — should be at least 24), AIRS Point 107/C-131 (691 hours; only 21 daily readings — should be at least 29) July 2014 AIRS Point 101/C-211 (704 hours; only 4 daily readings — should be at least 29), AIRS Point 103/C-179 (604 hours; only 21 daily readings — should be at least 25) August 2014 AIRS Point 101/C-211 (740 hours; only 4 daily readings — should be at least 31) ii. DCP failed to record the AFRC O2 mV reading on a weekly basis for AIRS Point 103/C-179 in December 2013 (66 hours of operation, no reading — should be 1); and AIRS Point 107/C-131 in July 2014 (360 hours of operation; 1 reading — should be 2). iii. DCP failed to record the catalyst differential pressure ("dP") and/or failed to conduct appropriate maintenance or perform a portable analyzer test when the dP was outside the baseline range for the following AIRS Points/RICE: RICE Unit # /AIRS Point Missed Monthly Catalyst dP Readings (with Hours of Operation for that Month) Recorded Catalyst dP Outside Baseline Range Reported Maintenance or Portable Analyzer Test for Catalyst dP Outside Baseline Range C-211/101 None June 2014, May 2014, Jan. 2014, Feb. 2013, Jan. 2013, Nov. 2012 None C-167/102 June 2014 (666), May 2014 (426), April 2014 (707), Jan. 2013 (585) None N/A C-179/103 Dec. 2013 (528) None N/A C-129/104 Apr. 2013 (21) None N/A C-134/105 Apr. 2013 (22), Nov. 2012 (296) None N/A C -130/10b Apr. 2013 (25), Jun. 2013 (75) None N/A C-131/107 July 2014 (434), Mar. 2014 (52), Sept. 2013 (36), June 2013 (277) December 2012 None C250/113 June 2013 (440) None N/A C251/114 Jan. 2014 (408), None N/A COLORADO Air Pollution Control Mutation ner-• u .• n tat N.(intni7 Cn.nnoV.Y Printed from electronic record Dec. 2013 (632), June 2013 (565) C252/115 June 2013 (405) None N/A C253/116 June 2013 (632) May 2014 None C254/117 June 2013 (694) July 2014, July 2013, May 2013, April 2013, March 2013 None iv. DCP failed to monitor and record the thermal oxidizer combustion temperature when the TEG Dehydrator was reported to be in operation on October 14, 2012; October 24, 2012; December 30, 2012; September 11, 2013; September 23, 2013; October 31, 2013; November 21, 2013 — December 8, 2013; December 11, 2013; February 6, 2014; March 1, 2014; March 2, 2014; March 5, 2014; March 6, 2014; March 25, 2014 — March 27, 2014; and April 1, 2014 - April 9, 2014. v. DCP failed to record whether the flare pilot light was lit on the following dates: December 26 — 31, 2013; December 5 — 14, 2013; July 6, 2013; June 21 — 23, 2013; June 17, 2013; June 11 — 12, 2013; May 14, 2013; January 17, 2013; December 30, 2012; December 26 — 27, 2012; November 19, 2012; November 4, 2012; October 31, 2012; October 1, 2012; and September 13, 2012. DCP submitted s electronically recorded data to the Division on October 8, 2015 showing the pilot light was lit or partially lit on all but 8 days during the inspection period. On November 17, 2015 the Division requested that DCP recalculate the control efficiency of the flare for the days the pilot light was not lit or was partially lit. DCP supplied the recalculated control efficiencies to the Division on December 1, 2015. vi. DCP failed to conduct a Method 22 reading of the condensate tanks' flare on the following dates: December 26 — 31, 2013; December 5 — 14, 2013; July 6, 2013; June 21 — 23, 2013; June 17, 2013; June 11 — 12, 2013; May 14, 2013; January 17, 2013; December 30, 2012; December 26 — 27, 2012; November 19, 2012; November 4, 2012; October 31, 2012; October 1, 2012; and September 13, 2012. vii. DCP failed to operate the PRVs on the condensate storage tanks to ensure flashing, working and breathing losses (as applicable) are routed to the control device under normal operating conditions. S, COLORADO co Au Pollution Control Division lorry"Y• d %bc M*' bfnny.e., Printed from electronic record i. The monthly average condenser outlet temperature for the TEG Dehydrator under AIRS Point 122 exceeded the 145° F limit in October 2013 (149.12 °F), September 2013 (160.55 °F), August 2013 (156.77 °F), July 2013 (182.22 °F), June 2013 (180.33 °F), May 2013 (157.47 °F), November 2012 (182.33 °F), October 2012 (148.56 °F), September 2012 (161.59 °F) and August 2012 (177.13 °F), violating Permit Number 09WE 1136, Condition 34. Also, based on information provided by DCP, the Division will no longer pursue enforcement for the issues identified in Paragraphs A.viii, E, I, J.v, L, and M of the Compliance Advisory. 9. The Division and DCP entered into settlement discussions for the violations as determined by the Division. The Parties reached a settlement that is detailed in this Consent Order. III. ORDER and AGREEMENT Based on the foregoing factual and legal determinations, pursuant to its authority under § 25-7-115, C.R.S., and as a result of the violations cited herein, the Division orders DCP to comply with all provisions of this Consent Order, including all requirements set forth below. 10. DCP agrees to the terms and conditions of this Consent Order. DCP agrees that this Consent Order constitutes an order issued pursuant to § 25-7-115, C.R.S., and is an enforceable requirement of Part 1 of the Act. DCP also agrees not to challenge directly or collaterally, in any judicial or administrative proceeding brought by the Division to enforce this Consent Order or by DCP against the Division: a. the issuance of this Consent Order; b. the factual and legal determinations made by the Division herein; and c. the Division's authority to bring, or the court's jurisdiction to hear, any action to enforce the terms of this Consent Order under the Act. 11. Notwithstanding the above, DCP does not admit to any of the factual or legal determinations made by the Division herein, and any action undertaken by DCP pursuant to this Consent Order shall not constitute an admission of liability by DCP with respect to the condition of the Facility. In addition, and without limitation as it relates to other disputed claims, DCP specifically does not concede, admit or agree with the Division's factual determinations in Section II, Paragraphs 8.a.vi, 8.b.i, 8.b.v, 8.b.vi, 8.e, 8.f , 8.g and 8.h.vii. Compliance Requirements 12. Effective immediately, and without limitation, DCP shall comply with the Act and the Regulations in the regulation and control of air pollutants. ®COLORADO Atr Pollution Control Division :k.m...c o 0...r e Printed from electronic record 13. For the seven (7) components remaining on Delay of Repair identified in 8.f above, repair shall be completed no later than the next process unit shutdown before the end of 2016. 14. Within ninety (90) days of the effective date of this Consent Order, DCP shall complete any necessary repairs to ensure the PRVs on the condensate storage tanks are operated to ensure flashing, working and breathing losses (as applicable) are routed to the control device under normal operating conditions as required by the approved O&M Plan per Permit Number 09WE1136, Condition 33. 15. All documents submitted under this Consent Order shall use the same titles as stated in this Consent Order, and shall reference both the case number and the number of the paragraph pursuant to which the document is required. Unless otherwise specifically provided herein, no document submitted for Division approval under this Consent Order may be implemented unless and until written approval is received from the Division. Any approval by the Division of a document submitted under this Consent Order is effective upon receipt by DCP. All approved documents, including all procedures and schedules contained in the documents, are hereby incorporated into this Consent Order, and shall constitute enforceable requirements under the Act. Administrative Penalty Requirements 16. Based upon the factors set forth in § 25-7-122, C.R.S., the Division has determined an administrative penalty in the amount of Fifty -Six Thousand Seven Hundred Dollars ($56,700.00) against DCP is appropriate and consistent with the Division's policies for violations of the Act and the Regulations cited in Section II of this Consent Order. DCP agrees to pay the sum of Fifty -Six Thousand Seven Hundred Dollars ($56,700.00) in administrative penalties. Payment is due within thirty (30) calendar days of the effective date of this Consent Order by certified, corporate or cashier's check drawn to the order of "Colorado Department of Public Health and Environment" and delivered to the attention of the Manager, Compliance, Air Pollution Control Division, 4300 Cherry Creek Drive South, APCD-SS-B1, Denver, Colorado 80246-1530. IV. SCOPE AND EFFECT OF CONSENT ORDER 17. The Parties agree and acknowledge that this Consent Order constitutes a full and final settlement of the violations cited herein. This Consent Order is final agency action. DCP agrees not to challenge the terms and conditions of this Consent Order in any proceeding before any administrative body or any judicial forum, whether by way of direct judicial review or collateral challenge. 18. This Consent Order shall be enforceable by either party in the same manner as if the Division had entered this Consent Order without agreement by DCP. The Parties agree that any violation of the provisions of this Consent Order by DCP concerning the Act, or the Regulations, shall be a violation of a final order of the Division for the purposes of §§ 25-7-115, 121, and 122, C.R.S., and may result in the assessment of civil penalties of up to Fifteen + COLORADO CO w Ponunon Control Division ire . Nei:.. ..w,.,b:c,n ✓....... Printed from electronic record Thousand Dollars ($15,000.00) per day for each day of such violation. 19. The Parties' obligations under this Consent Order are limited to the matters expressly stated herein or in approved submissions required hereunder. All submissions made pursuant to this Consent Order are incorporated into this Consent Order and become enforceable under the terms of this Consent Order as of the date of approval by the Division. 20. The Division's approval of any submission, standard, or action under this Consent Order shall not constitute a defense to, or an excuse for, any prior violation of any requirement under the Act, the Regulations, or any subsequent violation of any requirement of this Consent Order, the Act, or the Regulations. 21. Entering into this settlement shall not constitute an admission of violation of the air quality laws by DCP, nor shall the Division or any third party infer it to be such an admission by DCP in any administrative or judicial proceeding. Notwithstanding the foregoing or anything in this Consent Order to the contrary, the described violation will constitute part of DCP's compliance history for any purpose for which such history is relevant, including considering the violation described above in assessing a penalty for any subsequent violations, in accordance with the provisions of § 25-7-122, C.R.S., against DCP. 22. DCP shall comply with all applicable Federal, State, and/or local laws and regulations and shall obtain all necessary approvals or permits to conduct the investigation and remedial activities required by this Consent Order and perform its obligations required hereunder. The Division makes no representation with respect to approval and permits required by Federal, State, or local laws or regulations other than those specifically referred to herein. 23. Nothing herein shall be construed as prohibiting, altering, or in any way limiting the ability of the Division to seek any other remedies or sanctions available by virtue of DCP's violation of this Consent Order or of the statutes and regulations upon which this Consent Order is based, or for DCP's violation of any applicable provision of law. V. LIMITATION RELEASES AND RESERVATION OF RIGHTS AND LIABILITY 24. Upon the effective date of this Consent Order, and during its term, this Consent Order shall stand in lieu of any other enforcement action by the Division with respect to the violations cited herein. This Consent Order does not grant any release of liability for any violations, regardless of when they occurred, that are not cited in this Consent Order. The Division reserves the right to bring any action it deems necessary to enforce this Consent Order, including actions for penalties and/or injunctive relief 25. Nothing in this Consent Order shall preclude the Division from imposing additional requirements necessary to protect human health or the environment and to effectuate the purposes of this Consent Order. Nor shall anything in this Consent Order preclude the Division from imposing additional requirements in the event that additional information is discovered that indicates such requirements are necessary to protect human health or the COLORADO CO AU Poll'Won Control Division S... .r..• Pumc*rim olr-.rn Printed from electronic record environment. 26. DCP reserves its rights and defenses regarding liability in any proceedings regarding the Facility other than proceedings to enforce this Consent Order. 27. Upon the effective date of this Consent Order, DCP releases and covenants not to sue the State of Colorado as to all common law or statutory claims or counterclaims arising from, or relating to, the violations of the Act or the Regulations specifically addressed herein. 28. DCP shall not seek to hold the State of Colorado or its employees, agents or representatives liable for any injuries or damages to persons or property resulting from acts or omissions of DCP, or those acting for or on behalf of DCP, including its officers, employees, agents, successors, representatives, contractors or consultants in carrying out activities pursuant to this Consent Order. DCP shall not hold out the State of Colorado or its employees, agents or representatives as a party to any contract entered into by DCP in carrying out activities pursuant to this Consent Order. Nothing in this Consent Order shall constitute an express or implied waiver of immunity otherwise applicable to the State of Colorado, its employees, agents, or representatives. 29. The Division reserves the right to bring any action or to seek civil or administrative penalties for any past, present, or future violations of the Act and the Regulations, not specifically addressed herein. Further, the Division has the right to bring any action to enforce this Consent Order and to seek authorized penalties for any violation of this Consent Order. VI. FORCE MAJEURE 30. DCP shall perform the requirements of this Consent Order within the schedules and time limits set forth herein and in any approved plan unless the performance is prevented or delayed by events that constitute a force majeure. A force majeure is defined as any event arising from causes which are not reasonably foreseeable, which are beyond the control of DCP, and which cannot be overcome by due diligence. 31. Unless otherwise provided in the Act or the Regulations, within seventy-two (72) hours of the time that DCP knows or has reason to know of the occurrence of any event which DCP has reason to believe may prevent DCP from timely compliance with any requirement under this Consent Order, DCP shall provide verbal notification to the Division. Within seven (7) calendar days of the time that DCP knows or has reason to know of the occurrence of such event, DCP shall submit to the Division a written description of the event causing the delay, the reasons for and the expected duration of the delay, and actions which will be taken to mitigate the duration of the delay. 32. The burden of proving that any delay was caused by a force majeure shall at all times rest with DCP. If the Division agrees that a force majeure has occurred, the Division will so notify DCP. The Division will also approve or disapprove of DCP's proposed actions for mitigating the delay. If the Division does not agree that a force majeure has occurred, or if the Printed from electronic record Division disapproves of DCP's proposed actions for mitigating the delay, it shall provide a written explanation of its determination to DCP. Pursuant to the Dispute Resolution section, within fifteen (15) calendar days of receipt of the explanation, DCP may file an objection. 33. Delay in the achievement of one requirement shall not necessarily justify or excuse delay in the achievement of subsequent requirements. In the event any performance under this Consent Order is found to have been delayed by a force majeure, DCP shall perform the requirements of this Consent Order that were delayed by the force majeure with all due diligence. VII. DISPUTE RESOLUTION 34. If the Division determines that a violation of this Consent Order has occurred; that a force majeure has not occurred; that the actions taken by DCP to mitigate the delay caused by a force majeure are inadequate, the Division shall provide a written explanation of its determination to DCP. Within fifteen (15) calendar days of receipt of the Division's determination, DCP shall: a. Submit a notice of acceptance of the determination; or b. Submit a notice of dispute of the determination. If DCP fails to submit either of the above notices within the specified time, it will be deemed to have accepted the Division's determination. 35. If DCP files any notice of dispute, the notice shall specify the particular matters in the Division's determination that DCP seeks to dispute, and the basis for the dispute. Matters not identified in the notice of dispute shall be deemed accepted by DCP. The Division and DCP shall have thirty (30) calendar days from the receipt by the Division of the notification of dispute to reach an agreement. If agreement cannot be reached on all issues within this thirty (30) day period, the Division shall confirm or modify its decision within an additional fourteen (14) days, and the confirmed or modified decision shall be deemed effective and subject to appeal in accordance with the Act and the Colorado Administrative Procedure Act, Article 4, Title 24, Colorado Revised Statutes. VIII. NOTICES 36. Unless otherwise specified, any report, notice or other communication required under the Consent Order shall be sent to: For the Division: Enforcement Unit Supervisor Colorado Department of Public Health and Environment APCD-SS-B 1-1400 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 ®COLORADO Air Pollution Control Division Prasn.w.,i & kaalt we01 b it Printed from electronic record For DCP: John Admire, Senior Director, Environment DCP Midstream, LP 370 17th Street, Suite 2500 Denver, Colorado 80202 ®COLORADO Atr Pollution Control Division : - 0. 9601- "nfl'k nrpwww.n Printed from electronic record IX. OBLIGATIONS UNAFFECTED BY BANKRUPTCY 37. The obligations set forth herein are based on the Division's police and regulatory authority. These obligations require specific performance by DCP of corrective actions carefully designed to prevent on -going or future harm to public health or the environment, or both. Enforcement of these obligations is not stayed by a petition in bankruptcy. DCP agrees that the penalties set forth in this Consent Order are not in compensation of actual pecuniary loss. Further, the obligations imposed by this Consent Order are necessary for DCP and the Facility to achieve and maintain compliance with State law. X. MODIFICATIONS 38. This Consent Order may be modified only upon mutual written agreement of the Parties. XI. BINDING EFFECT, AUTHORIZATION TO SIGN AND EFFECTIVE DATE 39. This Consent Order is binding upon the Parties to this Consent Order and their corporate subsidiaries or parents, their officers, directors, agents, attorneys, employees, contractors, successors in interest, affiliates and assigns. The undersigned warrant that they are authorized to bind legally their respective principals to this Consent Order, and that the Parties have the authority to enter into this Consent Order. This Consent Order shall be effective upon the date signed by the last party. In the event that a party does not sign this Consent Order within thirty (30) calendar days of the other party's signature, this Consent Order becomes null and void. This Consent Order may be executed in multiple counterparts, each of which shall be deemed an original, but all of which shall constitute one and the same Consent Order. COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT By: Date: @/y/�/�-Y annon MEMillan Compliance and Enforcement Program Manager Air Pollution Control Division DCP MIDSTREAM, LP By: Date: � Mb/2616 William L. Johnson Vice President, Operations — North Region ®COLORADO Air Pollution Control Division 'y.... •, bl . n.un I 1. e Printed from electronic record cc: Shannon McMillan, APCD Jennie Morse, APCD Tom Roan, Office of Attorney General Adam Eisele, US EPA Scott Patefield, US EPA Jeffrey W. Schwarz, Esq., CSMKF Tim Taylor, APCD Jen Mattox, APCD Heather Wuollet, APCD Michael Stovern, US EPA File • COLORADO Department of Public Health & Environment Air Pollution Control Division Field Inspection Report County Code: 123 _ Source Number: 0090 Date of Inspection: 07/23/2015 _ Date Report Submitted: 11/04/2015 REVISED 7/27/16 Inspector: James Flores Company and Facility Name: DCP Midstream LP — Mewbourn Natural Gas Plant Site Location: SEC35 T4N R66W County: Weld Contact Person: Jill Thornberry Phone Number: 970-515-2110 Permit Number(s): 09WE1136 and 09OPWE062 Time: 10:00 a.m. Company Mailing Address: 3026 4th Ave Greeley, CO 80631 Source Class: Major (CO, VOC, and NOx) Compliance Period: 09/2014-06/2015 Inspection Type: Routine (unannounced) Inspection Level: Full Compliance Evaluation Hours: Inspection: 5 Travel and Prep: 10 Report: 57 Total: 72 Applicable Subparts (NSPS/MACT): NSPS Dc, NSPS KKK, NSPS LLL, NSPS JJJJ, NSPS KKKK, MACT HH (area), and MACT ZZZZ (area). Compliance Status: Out of Compliance Description of Source On July 23, 2015, Mr. James Flores, of the Air Pollution Control Division ("Division"), conducted a full compliance inspection of the Mewbourn Natural Gas Plant ("Mewbourn" or "Facility"), owned and operated by DCP Midstream LP ("company"). Ms. Thornberry provided records to demonstrate compliance with the permit(s) listed above on November 24, 2015, and as supplemented on 12/2/15 and 12/11/5. This compliance inspection evaluated compliance under the permits identified for the period from 09/2014-06/2015 ("Compliance Period"). The Mewbourn Natural Gas Processing Plant ("Mewbourn" or "facility") is an onshore natural gas processing facility designated under Standard Industrial Classification 1321 that is owned and operated by DCP Midstream, LP ("DCP"). The facility is classified as a Major Source for Oxides of Nitrogen (NOx), Carbon Monoxide (CO) and Volatile Organic Compounds (VOC) for Operating Permit purposes and a Synthetic Minor for CO for Prevention of Significant Deterioration (PDS) purposes. Mewbourn is permitted to operate under Colorado's Title V Operating Permit Program, Operating Permit 95OPWE062, which was first issued on June 1, 1999 and renewed on May 1, 2009. On or about August 21, 2009, DCP submitted a permit application for the Mewbourn Modernization Plan ("Mewbourn II"), which included replacing two (2) gas processing skids with a cryogenic turbo -expander for Natural Gas Liquids (NGL) extraction, removing and replacing seven existing reciprocating internal combustion engines (RICE), installing controls on four existing RICE and the condensate tanks and loadout, installing new dehydration and sweetening units also equipped with emission controls, and increasing processing capacity of the plant to 160 MMSCf per day (MMscfd). DCP completed construction of the modernization project in May 2011 and Mewbourn II started up on May 19, 2011 under Construction Permit 09WE1136. With the start up of Mewbourn II, DCP decommissioned the two processing skids and five of the RICE associated with the original Mewbourn ("Mewbourn I"), which was covered under 95OPWE062. This equipment is still on site but the RICE have been blinded off and the processing skids are inactive. For purposes of this inspection, compliance has been evaluated against 09WE1136, which is the most current, up-to-date permit for operations at the facility. DCP submitted modification applications for 95OPWE062 on October 19 and 27, 2010 and a renewal application on May 1, 2013; therefore, a permit shield was granted. The Air Pollution Control Division ("Division") is processing the renewal application; however, DCP requested that the application be placed on hold in a letter received by the Division on November 6, 2014, due to planned requested revisions to 09WE1136 that would result in "certain administrative and technical changes that, ultimately, would need to be incorporated into the revised Title V permit." Mewbourn receives both high and low pressure gas for processing. High pressure gas is received from DCP's Marla Compressor Station at approximately 950 psi via one 12" inlet. The facility receives low pressure gas at approximately 100 psi via two 12" inlets from the gathering field. The low pressure gas enters three (3) inlet scrubbers and any liquids that drop out are hard -piped to two (2) 60,000 -gallon capacity pressurized tanks. The liquids are then sent through a stabilization skid to remove the lighter ends, which are recompressed to the low pressure inlets using a Vapor Recovery Unit (VRU), and the liquids are stored in four (4) 400 -bbl capacity atmospheric storage tanks that are controlled with an enclosed flare. The low l 230090-INSP-2015 EXHIBIT twitn '5'3 rt- COLORADO Department of Public Health b Environment Air Pollution Control Division Field Inspection Report pressure gas undergoes two -stage compression using two (2) Solar turbines and up to six (6) Waukesha RICE, though only two are necessary with the other four RICE acting as back-ups. High pressure gas and the compressed low pressure volumes are co -mingled in a main header after the inlet RICE and turbines and sent to the amine system for removal of carbon dioxide (CO2) and hydrogen sulfide (H2S) if present. The amine flash tank emissions are routed back to the low pressure inlet using a VRU and the still vent emissions are directed to a Regenerative Thermal Oxidizer (RTO) for control. The gas stream then enters a triethylene glycol dehydration (TEG Dehy) unit for removal of water. The TEG Dehy's flash tank emissions are also routed to the low pressure inlet by VRU and the still vent emissions are also controlled by the same RTO. The gas goes through additional moisture removal via molecular sieve dehydration system and is delivered to the cryogenic plant for NGL processing. NGLs drop out from the gas stream using both cryogenic expansion and a JT-skid, and are routed through a de- methanizer and to up to three different pipelines for delivery off -site. The light ends off the de-methanizer are compressed (2 -stage) and delivered to pipeline for sales. At the time of the inspection, Mewbourn was processing at full capacity of 160 MMScfd. Equipment on -site included seven (7) four stroke rich burn (4SRB) RICE equipped with non -selective catalytic reduction (NSCR) for emissions control (Cat 4SRB RICE used to power main VRU; Waukesha 4SRB RICE used for inlet compression), five (5) four stroke lean burn (4SLB) RICE equipped with oxidation catalysts for control (residue compressors), four (4) Solar turbines equipped with Dry Lo-NOx (2 inlet compressors, 2 generators), four (4) 400 -bbl atmospheric condensate storage tanks controlled by an enclosed flare, one (1) condensate loadout controlled by the enclosed flare, one (1) amine unit, one (1) amine reboiler heater, one (1) TEG Dehy, two (2) hot oil heaters, three (3) VRUs (1 primary RICE -powered and 2 electric back-ups), one (1) regenerative thermal oxidizer, one (1) emergency flare (controls turbine and propane compressors' blowdowns and valve blowdowns), and fugitive emissions. For purposes of this inspection, compliance has been evaluated against 09WE 1136, which is the most current, up-to-date permit for operations at the facility. Com I liance Histo • Case No. 2015-073: As a result of an inspection of Mewbourn on 9/24/14, the Division identified several noncompliance issues, including fuel use, processing rates and emissions exceedances, failure to properly record/report operating parameters and calculate emissions, failure to follow the O&M Plan, and failure to comply with NSPS KKK, Regulation No. 7 Section XVII. The Division issued a Compliance Advisory on September 14, 2014. The Division met with DCP on 10/28/15 and 11/17/15 to discuss the com ' liance issues. The case remains o . en as of the date of this ins . ection re. ort. • Case No. 2013-036: As a result of compliance testing conducted on the RTO and Waukesha RICE at Mewbourn in November 2012, the Division determined that testing of the RTO was conducted under conditions not representative of normal operation based on a reduced processing rate for the TEG Dehy and unreported maintenance on the RTO prior to testing; therefore, the test results were not considered valid. DCP also failed to provide requested RTO maintenance records to the Division by no later than December 28, 2012 pursuant to a request made under C.R.S. §25-7-111(2)(c) and (i). It was also determined that the AIRS Point 106 Waukesha RICE was not tested under conditions representative of normal operation because the engine settings were changed the evening before the test; therefore, the test results were not considered valid. Finally, compliance testing of the AIRS Point 104 Waukesha RICE showed the permitted NOx emission limit for the unit was exceeded. The Division issued a Notice of Violation (NOV) to DCP on June 21, 2013 for the identified noncompliance issues (identified through a full compliance inspection performed on 08/24/2012), which also included noncompliance issues from Case No. 2013-035 for Mewbourn (see below). On August 28, 2013, the Division and DCP met to discuss the issues identified in the NOV. DCP provided additional requested information to the Division on January 23, 2014. The Division and DCP met again on July 22, 2014. • Case No. 2013-035: As the result of an inspection of Mewbourn on August 24, 2012, the Division identified several noncompliance issues, including exceeding opacity limits for the emergency flare, not providing accurate GlyCalc runs to demonstrate actual average benzene emissions from the TEG Dehy are under 0.90 megagrams (1,984 pounds) per year for exemption from MACT HH general requirements, failing to demonstrate compliance with the annual and monthly VOC limits for the Amine Unit and TEG Dehy based on an undemonstrated control efficiency from the RTO and non- representative operating parameters for the TEG Dehy, exceeding permitted fuel consumption and NOx and VOC emission limits for the AIRS Point 105 Waukesha RICE, failing to record the lean glycol circulation rate for the TEG Dehy on a 1230090-INSP-2015 Page 2 of 52 COLORADO Department of Public Health b Environment Air Pollution Control Division Field Inspection Report daily basis as required on several dates, failing to provide downtime records for the flare controlling the condensate storage tanks, failing to provide an operating and maintenance (O&M) plan for the Amine Unit and failing to demonstrate compliance with certain requirements of the O&M plan for most of the RICE. The Division issued a Notice of Violation (NOV) to DCP on June 21, 2013 for the identified noncompliance issues (identified through a full compliance inspection performed on 08/24/2012), which also included noncompliance issues from Case No. 2013-036 for Mewbourn (see above). On August 28, 2013, the Division and DCP met to discuss the issues identified in the NOV. DCP provided additional requested information to the Division on January 23, 2014. The Division and DCP met again on July 22, 2014. • Case No. 2012-057: Compliance testing conducted on the RTO and Waukesha and Caterpillar RICE in August — December 2011 failed to demonstrate compliance with the control efficiency for the RTO and permitted emission limits for the RICE. The Division issued a Compliance Advisory (CA) to DCP on May 21, 2012, which also included noncompliance issues for DCP's Roggen and Enterprise facilities (Case Nos. 2012-058 & -062). The Division and DCP met on June 21, 2012 to discuss the issues identified in the CA. On 4/24/15, DCP entered into a Compliance Order on Consent (COC) to resolve the violations identified under Case Nos. 2012-057, 2013-035 & 2013-036. Under this COC, DCP was required to pay a civil penalty of $130,800 to the state within 30 days of the effective date of the COC, and complete a Supplemental Environmental Projects (SEP) by donating $104,640 to the Volunteers for Outdoor Colorado. Additionally, DCP must comply with the following requirements by the date listed below: Requirement Date Due Date Comments Received Submit permit application to modify Permit 09WE1136 Issuance 2 to reduce TEG 7/26/15 was a Sunday, therefore the submittal is not considered late. throughput capacity and remove AIRs 7/26/15 7/27/15 Points 104, 105, & 107 Remove AIRs Points 104, 105, & 107 and submit a cancellation notice to APCD 5/27/15 5/22/15 Cancellations submitted. Conduct compliance tests on Airs Point 106 a. Within 90 days of the effective date of the COCA Protocol submitted 30 days prior to testing as required. Test demonstrated compliance with permitted 7/26/15 6/25/15 emissions limits. Test report submitted 8/9/15, 44 days after test completion. b. Within twelve months of the first test 6/25/16 Engineer, purchase, construct and operate Thermal Oxidizer to control emissions from DEHY (AIRS 122) 7/26/15 was a Sunday, therefore the submittal is not considered late. a. Submit permit application to modify Permit 09WE1136 Issuance 2 to account for the 7/26/15 7/27/15 installation/operation of thermal oxidizer b. Commence operation of the Thermal Oxider at Mewbourn 12/31/15 12/8/15 Commence operation of the Thermal Oxider at Lucerne II 8/31/16 a. Submit permit application to modify Permit 09WE1136 Issuance 7/26/15 6/17/2015 2 to account for the 1230090-INSP-2015 Page 3 of 52 • COLORADO Department of Public Health & Environment Air Pollution Control Division Field Inspection Report installation/operation of thermal oxidizer Thermal Oxidizer Compliance Tests a. Conduct compliance testing on Mewbourn RTO (AIRS 124) 6/5/16 b. Conduct compliance testing on TO at Lucerne II 180 days after startup c. Conduct compliance testing on RTO in accordance with Permit 12WE2024 TBD The case remains open pending the completion of the listed compliance requirements. Case No. 1998-015: As the result of an inspection, the Division identified site from what was permitted leak detection records to the division. A Notice to discuss these and other was signed on 12/24/98-1/8/99, and a Supplemental Environmental several noncompliance issues, including Violations are for having a different engine on fuel usage for engine under 85WE336-1, not having under 84WE429-5, exceeding permit limits for available on site, and inadequate record keeping of Violation was sent and conference was violations at Duke facilities. A Compliance with an administrative penalty of Project valued at $30,000. SEP report and information in VOC monitor reports submitted scheduled. The Division met with DCP on 7/20/98 Order on Consent involving 13 Duke Energy facilities .$50,000, a Non -Compliance Penalty of $4,046.00, dated 8/6/99 received. Case is considered closed. All of the following points are covered under Construction Permit 09WE1136 AIRS ID Facility ID Point Description 123-0090-101 C-2 11 One (1) Caterpillar, G379NA, SN: 72B641, natural gas fired, 4 -stroke, rich -burn, naturally aspirated, reciprocating internal combustion engine, heat input rated at 2.6 MMBTU per hour, output rated at 330 HP, running a natural gas / vapor compressor. Emissions are controlled by AFR and a Non -Selective Catalytic Reduction system. 123-0090-102 C-167 One (1) Waukesha, L7044GSI, SN: C13852-1, natural gas fired, 4 -stroke, rich - burn, turbocharged, reciprocating internal combustion engine, heat input rated at 12.9 MMBTU per hour, output rated at 1,680 HP, running a natural gas compressor. Emissions are controlled by AFR and a Non -Selective Catalytic Reduction System. 123-0090-103 C-179 One (1) Waukesha, L7042GSI, SN: 240410, natural gas fired, 4 -stroke, rich -burn, turbocharged, reciprocating internal combustion engine, heat input rated at 11.6 MMBTU per hour, output rated at 1,478 HP, running a natural gas compressor. Emissions are controlled by AFR and a Non -Selective Catalytic Reduction System. 123-0090-104 C-129 One (1) Waukesha, L7042 GU, SN: 286822, natural gas fired, 4 -stroke, rich -burn, naturally aspirated, reciprocating internal combustion engine, heat input rated at 6.4 MMBTU per hour, output rated at 896 HP, running a natural gas compressor. Emissions are controlled by AFR and a Non -Selective Catalytic Reduction system. Cancellation request submitted 5/22/15 123-0090-105 C-134 One (1) Waukesha, L7042GU, SN: 285300, natural gas fired, 4 -stroke, rich -burn, naturally aspirated, reciprocating internal combustion engine, heat input rated at 6.4 MMBTU per hour, output rated at 896 HP, running a natural gas compressor. Emissions are controlled by AFR and a Non -Selective Catalytic Reduction system. Cancellation request submitted 5/22/15 123-0090-106 C-130 One (1) Waukesha, L7042GSI, SN: 339839, natural gas fired, 4 -stroke, rich -burn, turbocharged, reciprocating internal combustion engine, heat input rated at 11.2 MMBTU per hour, output rated at 1,478 HP, running a natural gas compressor. Emissions are controlled by AFR and a Non -Selective Catalytic Reduction system. 123-0090-107 C-131 One (1) Waukesha, L7042GSI, SN: 397541, natural gas fired, 4 -stroke, rich -burn, turbocharged, reciprocating internal combustion engine, heat input rated at 11.2 1230090-INSP-2015 Page 4 of 52 COLORADO Department of Public Health Fs Environment Air Pollution Control Division Field Inspection Report MMBTU per hour, output rated at 1,478 HP, running a natural gas compressor. Emissions are controlled by AFR and a Non -Selective Catalytic Reduction system. Cancellation request submitted 5/22/15. 123-0090-108 F-017 Facility Equipment Leaks. Emissions minimized by Leak Detection and Repair Program. 123-0090-109 LO Condensate loadout. Emissions controlled by a combustor. 123-0090-110 TANKS Four (4) tanks, 400 bbl each, for storage of stabilized natural gas condensate. Emissions controlled by a combustor. 123-0090-111 C-0170 One (1) Solar, Taurus 60, SN: TC 10559, natural gas fired combustion turbine, heat input rated at 50.1 MMBTU per hour. This is equipped with Dry Low NOx combustion system for minimizing emissions of Nitrogen Oxides. This powers a natural gas compressor. Identified as Inlet 1. 123-0090-112 C-0180 One (1) Solar, Taurus 60, SN: TC 10560, natural gas fired combustion turbine, heat input rated at 50.1 MMBTU per hour. This is equipped with Dry Low NOx combustion system for minimizing emissions of Nitrogen Oxides. This powers a natural gas compressor. Identified as Inlet 2. 123-0090-113 C-250 One (1) Caterpillar, G3608TALE, SN: BEN00563, natural gas fired, 4 -stroke, turbo -charged, lean -burn, low emissions design, reciprocating internal combustion engine, heat input rated at 17.9 MMBTU per hour, output rated at 2,370 HP, powering a natural gas compressor. Emissions are controlled by an oxidation catalyst. Identified as Residue 1 123-0090-114 C-251 One (1) Caterpillar, G3608TALE, SN: BEN00565, natural gas fired, 4 -stroke, turbo -charged, lean -burn, low emissions design, reciprocating internal combustion engine, heat input rated at 17.9 MMBTU per hour, output rated at 2,370 HP, powering a natural gas compressor. Emissions are controlled by an oxidation catalyst. Identified as Residue 2. 123-0090-115 C-252 One (1) Caterpillar, G3608TALE, SN: BEN00567, natural gas fired, turbo -charged, lean -burn, low emissions design, reciprocating internal combustion engine, heat input rated at 17.9 MMBTU per hour, output rated at powering a natural gas compressor. Emissions are controlled by an catalyst. Identified as Residue 3. 4 -stroke, 2,370 HP, oxidation 123-0090-116 C-253 One (1) Caterpillar, G3608TALE, SN: BEN00572, natural gas fired, 4 -stroke, turbo -charged, lean -burn, low emissions design, reciprocating internal combustion engine, heat input rated at 17.9 MMBTU per hour, output rated at 2,370 HP, powering a natural gas compressor. Emissions are controlled by an oxidation catalyst. Identified as Residue 4. 123-0090-117 C-254 One (1) Caterpillar, G3608TALE, SN: BEN00571, natural gas fired, turbo -charged, lean -burn, low emissions design, reciprocating internal combustion engine, heat input rated at 17.9 MMBTU per hour, output rated at powering a natural gas compressor. Emissions are controlled by an catalyst. Identified as Residue 5. 4 -stroke, 2,370 HP, oxidation 123-0090-118 G-1650 One (1) Solar, Taurus 70, SN: TG09548, natural gas fired combustion turbine, input rated at 61.6 MMBTU per hour. This is equipped with Dry combustion system for minimizing emissions of Nitrogen Oxides. This electric power generator. Identified as Genset 1. heat Low NOx runs an 123-0090-119 G-1670 One (1) Solar, Taurus 70, SN: TG09549, natural gas fired combustion turbine, heat input rated at 61.6 MMBTU per hour. This is equipped with Dry Low NOx combustion system for minimizing emissions of Nitrogen Oxides. This runs an electric power generator. Identified as Genset 2. 123-0090-120 AM -001 Natural gas sweetening (by removal of Carbon Dioxide and Hydrogen system (Precision Pipe & Vessel, LLC, Model T502, SN: 2381-9089) 50% solution of Methyldiethanolamine (MDEA), process feed gas design 160 MMSCF per day, and an amine recirculation rate of 640 gallons Sulfide) using a 30- rated at per minute. 1230090 -IN SP -2015 Page 5 of 52 (COLORADO Department of Public Health & Environment Air Pollution Control Division Field Inspection Report This system consists of: natural gas / amine contactor, amine flash tank, and amine regenerator (heating unit under AIRS PT ID: 123/0090/121). Emissions from the still vent are routed to a regenerative thermal oxidizer (AIRS PT ID: 123/0090/124). Emissions from the flash tank are routed to a vapor recovery unit (VRU) and returned to the plant inlet. 123-0090-121 H-776 One (1) Optimized Process Furnace, Inc., Model 200, SN: J091036, natural gas fired amine regeneration reboiler, heat input design rated at 64.9 MMBTU per hour. This is equipped with Ultra -Low NOx combustion system for minimization of Nitrogen Oxides emissions. 123-0090-122 D-931 Natural gas dehydration system using Triethylene glycol (TEG), (Exterran, SN: 8907) process feed design rated at 160 MMSCF per day, and two (2) electric Rotor pumps with design glycol recirculation rate of 25 gallons per minute each (total of 50 gallons per minute). This system consists of: natural gas / glycol contactor, glycol flash tank, glycol regenerator reboiler (heat provided by hot gases from various combustion processes supplemented by a hot oil heater (AIRS Point ID: 123/0090/123). Flash tank off gases are directly routed to a VRU and returned to the plant inlet. Still vent emissions are routed through a condenser, and then to regenerative thermal oxidizer (AIRS PT ID: 123/0090/124). 123 -0090-123 H-771 Two (2) Devco, HeliFlow, SN: 3431-3, natural gas fired hot oil heaters, heat input design rated at 26.0 MMBTU per hour each. These are equipped with Ultra -Low - NOx combustion systems for minimization of Nitrogen Oxides emissions. Hot oil is used to provide heat to various natural gas processes at the facility including supplemental heat for glycol regeneration reboiler. Only one heater to be operated at a time, the other is to be used as a backup. 123-0090-124 TO -701 One (1) Anguil Environmental Services, Inc., Model 200, SN: 14808, regenerative thermal oxidizer, heat input design rated at 11.0 MMBTU per hour. Natural gas used for startup. This is equipped with Low NOx combustion system for minimization of Nitrogen Oxides emissions. Emissions from various processes at this facility are routed into this thermal oxidizer for thermal destruction. Natural gas is used for startup to raise the temperature to normal operating level. Report Submittal Type (NSPS, T5, etc.) Date Due Date Received Notes Annual and Semi-annual Title V Certifications Title V Semi-annual Report (07/01/2014-12/31/2014) 02/01/2015 02/02/2015 Deviations reported (included in Malfunction section of this report. SAR (Semi-annual Report) came in one (1) day late. Since 02/01/2015 was a Sunday, it is likely the report was received by the due date but not processed until 02/02/2015 (Monday). Therefore enforcement is not recommended. Title V Annual Compliance Certification 2014 (01/01/2014-12/31/2014) 02/01/2015 02/02/2015 Deviations reported (included in Malfunction section of this report. Annual Compliance Certification came in one (1) day late. Since 02/01/2015 was a Sunday, it is likely the report was received by the due date but not processed until 02/02/2015 (Monday). Therefore enforcement is not recommended. Title V Semi-annual Report (1/1/2015-6/30/2015) 08/01/2015 08/03/2015 Deviations reported (included in Malfunction section of this reports. SAR came in one (1) day late. Since 08/01/2015 was a Saturday, it is likely the report was received by the due date but not processed until 08/03/2015 (Monday). Therefore enforcement is not recommended. NSPS and MACT Compliance Submittals (Note- DCP mistakenly submitted MACT DDDDD and MACT but later explained in emails dated February 3, 2015 and December thought that the HAP emissions estimates resulting from the ZZZZ (major source) initial notifications on May 31, 2013, 12, 2014 that at the time the notification was made, it was September 17, 2012 updated fugitive emissions component hard 1230090-INSP-2015 Page 6 of 52 40 COLORADO Department of Public Health Et Environment Air Pollution Control Division Field Inspection Report count at Mewbourn plus the 25% buffer added to file the MACT notification. DCP has since Mewbourn have never exceeded 25 tons per year to the component hard count (as a compliance buffer) triggered the obligation confirmed that the actual emissions of hazardous air pollutants (HAP) at or the major source threshold.) MACT HH Initial Notification (area source) 01/03/2008 12/20/2012 For TEG Dehy under AIRS Point 122. Notification required under 40 CFR §63.775(c)(1) & (7) for an area source not located within any urban area (UA) plus offset and urban cluster (UC) boundaries. The determined optimal glycol circulation rate was 15.70 gallons per minute (gpm), but DCP requested an alternate glycol circulation rate, per 63.775(c)(7)(iii), of 34.9 gpm, due to a difference in inlet water content (Ib/MMscf), which is the permitted circulation rate in 09WE1136. Under 63.764(d)(2)(ii), if the TEG Dehy is unable to meet the sales gas specification for moisture content using the determined optimal glycol circulation rate, the owner or operator must calculate an alternate circulation rate using GRI-GLYCalcT"l, Version 3.0 or higher. NSPS KKK Semi-annual Report (07/01/2014-12/31/2014) 02/01/2015 02/02/2015 DCP reported 310 leaks discovered during the compliance period, 12 of which were not repaired within 15 days and placed on the delay of repair (DOR) report due to shutdowns required for repair or replacement. DCP reported that no process unit shut downs occurred during the compliance period. Since 02/01/2015 was a Sunday, it is likely the report was received by the due date but not processed until 02/02/2015 (Monday). Therefore enforcement is not recommended. NSPS KKK Semi-annual Report (01/01/2015-06/30/2015) 08/01/2015 08/03/2015 DCP reported 430 leaks discovered during the compliance period, 38 of which were not repaired within 15 days and placed on the DPR report due to shutdowns required for repair or replacement. DCP reported that no process unit shut downs occurred during the compliance period. Since 08/01/2015 was a Saturday, it is likely the report was received by the due date but not processed until 08/03/2015 (Monday). Therefore enforcement is not recommended. Reported Malfunctions Malfunction, May 24-27, 2015 (RTO) DCP reported a total duration of 72.5 hours (total RTO down time 31.0 hours) for the malfunction and resulting VOC emissions of 1124.4 pounds (0.56 tons), of which 803.7 pounds (0.40 tons) were hazardous air pollutants (BTEX). 5/25/2015 (12 pm) 5/24/2015 (1:00 pm) DCP reported that the Regenerative Thermal Oxidizer (RTO) experienced a malfunction event at approximately 11:00 a.m. on May 24, 2015 due to low combustion chamber temperatures caused a burner air actuator programming malfunction. During this time operations lowered plant throughput to minimize emissions. DCP indicated it contacted the RTO manufacturer regarding the issue. The RTO was brought back online at approximately 11:27 a.m. on May 27, 2015. During the malfunction duration, the RTO was operated approximately 57.2% of the time during the 72.5 hours of this malfunction event. DCP indicated that the RTO manufacturer will continue to review this event and follow up in the second half of 2015 to ensure the malfunction has been corrected. Emissions accounted for in rolling twelve month totals submitted 12/11/15, and did not cause any excess emissions. Malfunction (5/24-27/15) determination: Invalid — malfunction does not meet the requirement for Affirmative pattern from previous malfunctions on May 22 and March 26. of Regulation No. 7, XII.H to control emissions from a dehydrator by no emissions exceedance, and the COC requirements to route Defense, because there is evidence of a recurring While the malfunction resulted in a violation 90%, the 12/11/15 emissions supplement indicated 1230090-INSP-2015 Page 7 of 52 COLORADO Department of Public Health Er Environment Air Pollution Control Division Field Inspection Report DEHY-1 to a dedicated TO (SEE Case Nos. 2012-057 & 2013-075/076), the inspector does not recommend enforcement. Malfunction, May 21-24, 5/23/2015 5/22/2015 DCP reported that the RTO experienced a malfunction event at 2015 (RTO) DCP reported a total duration of 70.6 hours (total RTO down time 38.6 hours) for the malfunction and resulting VOC emissions of 1594.4 pounds (0.80 tons), of which 1143.6 pounds (0.57 tons) were hazardous air pollutants (BTEX). (12 pm) (3:05 pm) approximately 12:23 p.m. on May 21, 2015 due to low combustion chamber temperature caused by a burner air actuator programming malfunction. During this time operations lowered plant throughput to minimize emissions. DCP indicated it contacted the RTO manufacturer regarding the issue. The RTO was brought back online at approximately 11:00 a.m. on May 24, 2015. During the malfunction duration, the RTO was operated approximately 45.3% of the time during the 70.6 hours of this malfunction event. DCP indicated that the RTO manufacturer will continue to review this event and follow up in the second half of 2015 to ensure the malfunction has been corrected. Emissions accounted for in rolling twelve month totals submitted 12/11/15, and did not cause any excess emissions. Malfunction (5/21-24/15) determination: Invalid — malfunction does not meet the requirement for Affirmative Defense, because there is evidence of a recurring pattern from previous malfunction on March 26. While the malfunction resulted in a violation of Regulation No. 7, XII.H to control emissions from a dehydrator by 90%, the 12/11/15 emissions supplement indicated no emissions exceedance, and the COC requirements to route DEHY-1 to a dedicated TO (SEE Case Nos. 2012-057 & 2013-075/076), the inspector does not recommend enforcement. Malfunction, May 10-12 and 5/11/2015 5/11/2015 DCP reported that the RTO experienced a malfunction event at 12-14, 2015 (RTO) DCP reported a total duration of 110.8 hours (total RTO down time 79.8 hours) for the malfunction and resulting VOC emissions of 3326.0 pounds (1.66 tons), of which 2378.9 pounds (1.19 tons) were hazardous air pollutants (BTEX). (12 pm) (8:00 am) approximately 1:51 a.m. on May 10, 2015 due to a loss of combustion chamber temperature caused by a faulty amplifier module and faulty flame scanner. During this time the gas processing capacity rate and dehydration system throughput was reduced to minimize emissions. DCP indicated once the two faulty components were replaced, the RTO went back online temporarily, operating for 1.5% of the first 64.2 hours and 64.2% of the last 46.6 hours. The continued failure of the RTO was caused by the newly installed flame scanner, which was faulty. Once a new flame scanner was installed, the RTO was able to operate without failure at 4:36 p.m. on May 14, 2015. Emissions accounted for in rolling twelve month totals submitted 12/11/15, and did not cause any excess emissions. Malfunction determination: Valid — meets Affirmative Defense criteria. Malfunction does not appear to have resulted from an activity or event that and maintenance practices. could have been reasonably foreseen and avoided, or planned for, by better operation Malfunction, March 25, 2015 3/26/2015 3/26/2015 DCP reported that the RTO experienced a malfunction event at (RTO) DCP reported a total duration of 2.3 hours for the malfunction and resulting VOC emissions of 87.6 pounds (0.04 tons), of which 63.0 pounds (0.03 tons) were (12 pm) (8:30 am) approximately 8:25 p.m. on March 25, 2015 due to an issue associated with combustion chamber temperature. Further investigation determined that the burner air actuator programming malfunctioned which caused the issue in the combustion chamber. During this time operations lowered plant throughput to minimize emissions while the RTO was not functioning. DCP indicated it contacted the RTO manufacturer and was onsite when the problem was resolved, returning the RTO to 1230090 -IN SP -2015 Page 8 of 52 COLORADO Department of Public Health Ft Environment Air Pollution Control Division Field Inspection Report hazardous air pollutants (BTEX). operation at approximately 10:42 p.m. on March 25, 2015. DCP indicated that the RTO manufacturer will continue to review this event and follow up in the second half of 2015 to ensure the malfunction has been corrected. Emissions accounted for in rolling twelve month totals submitted 12/11/15, and did not cause any excess emissions. Malfunction determination: Valid — meets Affirmative Defense criteria. Malfunction does not appear to have resulted from an activity or event that and maintenance practices. could have been reasonably foreseen and avoided, or planned for, by better operation Malfunction, March 7-8, 2015 3/8/2015 3/8/2015 DCP reported that following a power generating turbine failure, (RTO) DCP reported a total duration of 24.6 hours for the malfunction and resulting (12 pm) (11 am) resulting in a shutdown for repair, the RTO experienced a malfunction event when it failed to return to normal operation and would not fully start back up. During this time operations lowered plant throughput to minimize emissions while the RTO was not functioning. VOC emissions of 862.4 pounds (0.43 tons), of which 619.3 pounds (0.31 tons) were hazardous air pollutants (BTEX). DCP indicated that at approximately 1:06 p.m. on March 7, 2015 the RTO experienced a malfunction and could not fully start back up due to a faulty fuel valve after a shutdown. DCP determined the fuel valve which aided in providing the proper air to fuel ratio for the combustion chamber was not properly sealed and began immediate repairs, working overnight, to correct the fuel valve. Once the repairs were completed, the RTO was returned to normal operating conditions at 1:40 p.m. on March 8, 2015. Emissions accounted for in rolling twelve month totals submitted 12/11/15, and did not cause any excess emissions. Malfunction determination: Valid — meets Affirmative Defense criteria. Malfunction does not appear to have resulted from an activity or event that and maintenance practices. could have been reasonably foreseen and avoided, or planned for, by better operation Malfunction, February 11, 2/12/2015 2/12/2015 DCP reported that at approximately 10:00 a.m. the flare that 2015 (Combustor) (12 pm) (11:30 am) controls the condensate tanks and loadout (AIRS 109 & 110) experienced a malfunction and emitted opacity greater than or equal to 30%. DCP personnel immediately investigated the cause of the opacity, removed built up dirt and ash in the burner, and readjusted a louver control malfunction that was causing a lack of air flow. DCP indicated the even lasted only 5 minutes. DCP has set up a maintenance work order to be generated semi-annually to specifically clean burners and check the function of the louver controls. Emissions did not exceed the time duration for an opacity violation, therefore the event did not cause any excess emissions. Malfunction, December 29, 12/30/2014 12/30/2014 DCP reported that the RTO experienced a malfunction event, 2014 — January 1, 2015 (RTO) DCP reported a total duration of 59.0 hours for the malfunction and resulting VOC emissions of 3,0260 (12 pm) (8:00 am) which occurred as a result of a poppet valve failure which subsequently caused the RTO to shutdown. During this time the gas processing capacity rate and dehydration system throughput was reduced to minimize emissions. DCP indicated that at approximately 9:00 p.m. on December 29, 2014 the RTO experienced a malfunction. DCP personnel 1230090-INSP-2015 Page 9 of 52 COLORADO Department of Public Health b Environment Air Pollution Control Division Field Inspection Report pounds (1.51 tons), of which 1,729.7 pounds (0.86 tons) were hazardous air pollutants (BTEX). immediately began investigating the cause of the poppet valve failure and determined the parts needed to be replaced. Once the repairs were completed, the RTO was back online at 8:00 a.m. on January 1, 2015. Emissions accounted for in rolling twelve month totals submitted 12/11/15, and did not cause any excess emissions. Malfunction determination: Valid — meets Affirmative Defense criteria. Malfunction does not appear to have resulted from an activity or event that and maintenance practices. could have been reasonably foreseen and avoided, or planned for, by better operation Malfunction, November 27 — 12/1/14* 12/1/14 DCP reported that the RTO experienced a malfunction, which 28, 2014 (RTO) (12 pm) (11:56 am) occurred as a result of an alarm associated with the poppet valves being activated. The activation of the alarm caused the DCP reported a total duration of 37.7 hours for the malfunction and resulting VOC emissions of 1,434.6 pounds (0.71 tons), of which 815.4 pounds (0.41 tons) were hazardous air pollutants (BTEX). *Note - since 11/28/14 was a Friday, the next business day was Monday, 1211/14 for purposes of the initial reporting deadline. RTO to shutdown. During this time the gas processing capacity rate and dehydration system throughput was reduced to minimize emissions. On December 18, 2014 and January 28, 2015, DCP indicated in "investigated follow up reports that it the cause of the alarm and determined it was caused by a frozen poppet valve actuator. The freezing resulted from exposure of the actuator to cold air found to be escaping by an improperly sealed valve that moves air into the poppet valve chamber. The actuator was thawed and the RTO was put back into service at approximately 6:30 pm on November 28, 2014. Repairs to the valve will be completed during preventative maintenance event scheduled to take place during the 31d or 4th quarter of 2015. The status of the actuator will continue to be monitored by the alarm system." The Inspector does not recommend further enforcement as this compliance issue is addressed under Case No. 2015-073 (see "Compliance History" section). Malfunction (11/27/14 —11/28/14) determination: Invalid — malfunction does not meet the requirement for Affirmative Defense, since it could have reasonably been foreseen and avoided, or planned for, by better operation and maintenance practices through having previously recommended parts in stock to address the issue and completing recommended yearly Preventative Maintenance Evaluations (PME). Malfunction, September 16, 9/17/14 9/17/14 DCP reported the malfunction occurred due to a leaking valve 2014 (Smoking Flare) (12 pm) (8:16 am) on the propane compressor, C-143. C-143 was being blown down to the emergency flare and during this time the compressor discharge block valve was leaking propane and compressor lube oil back into the compressor. This mixture of propane and lube oil was then being blown down to the flare, which caused it to periodically emit opacity greater than 30%. In an attempt to minimize the duration of the malfunction event, DCP personnel began addressing the issue by closing the blowdown valve and addressing the compressor leak appropriately. The malfunction event lasted approximately 75 minutes. Malfunction (9/16/14) determination: Valid — meets Affirmative Defense criteria. Malfunction does not appear to have resulted from an activity or event that could have been reasonably foreseen and avoided, or planned for, by better operation and maintenance practices. 1230090-INSP-2015 Page 10 of 52 COLORADO Department of Public Health 8 Environment Air Pollution Control Division Field Inspection Report Malfunction, September 10 - 9/11/14 9/11/14 DCP reported that at approximately 2:00 pm on September 10, 12, 2014 (RTO) DCP reported a total duration of 54.4 hours for the malfunction and resulting VOC emissions of 1,823.6 pounds (0.91 tons), of which 982.2 pounds (0.50 tons) were hazardous air pollutants (BTEX). 2014, the RTO at Mewbourn was shutdown to safely facilitate the investigation of an inability to maintain desired temperature ranges with the RTO chamber beds. The shutdown was temporary. Once the investigation was completed and the operational issue identified and needed repairs made, the RTO was restarted at 8:24 pm on September 12, 2014. To minimize emissions during the investigation, DCP reduced the gas processing throughput at Mewbourn and the throughput to the TEG dehydration system. Operation at Mewbourn was continued to avoid having to shut-in upstream producers and to thereby minimize and avoid the emissions ramifications associated with such a shut-in. During the inspection, DCP reported that the RTO manufacturer, Anguil, had identified the location of the hot air/gas bypass valve on the RTO as being too close to the combustion chamber as the cause of the problem. As a result, the valve was leaking and not forcing temperature into the chamber beds. In order to address this, the valve had been blinded off as a temporary fix until the parts for a permanent fix could be manufactured by Anguil, which would move the valve further down the bypass line/ductwork from the combustion chamber. During the Performance Maintenance Evaluation (PME) of the Mewbourn RTO conducted by Anguil (RTO manufacturer) on April 29, 2014, operation of the hot gas bypass was verified and the control set point reduced from 1750 to 1700 °F to help better control excess chamber temperature. Malfunction (9/10/14) determination: Valid — meets Affirmative Defense criteria. Malfunction does not appear to have resulted from an activity or event that could have been reasonably foreseen and avoided, or planned for, by better operation and maintenance practices, since the PME did not identify the location of the hot air bypass valve as an issue and the valve was not operating as designed. Compliance Assistance/Source Actions None 40 CFR 60, Subpart Dc, -New Source Performance Standards: Standards of Performance for Small Industrial -Commercial - Institutional Steam Generating Units Is the source subject to Dc: Yes, Heaters H771 (AIRS Pt. 123) and H776 (AIRS Pt. 121) are subject to the reporting requirements of Subpart Dc because the units only use natural gas as fuel. Under 40 CFR §60.48c(g)(1), DCP is required to maintain records of natural gas combusted as fuel to demonstrate compliance with Subpart Dc. DCP meters the fuel use for H771 and H776 on a monthly basis, and confirmed only natural gas is used as fuel for the heaters. Source is in compliance. 40 CFR 63, Subpart HH ,National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities 1230090-INSP-2015 Page 11 of 52 COLORADO Department of Public Health b Environment Air Pollution Control Division Field Inspection Report 5.961s the source subject to HH : Yes, Mewbourn is an HH area source. DCP has taken federally enforceable limits to maintain a synthetic minor source of HAPs. Condition 5 for reported HAP emissions at Mewbourn. On January 3, 2007, the EPA promulgated area source requirements for glycol dehydrators using triethylene glycol (area MACT HH). Pursuant to 40 CFR §63.760, affected sources under the area MACT HH include each triethylene glycol dehydrator at an area source of HAPS. Pursuant to § 63.764(d)(1), owners/operators of an affected source not located in a UA plus offset and UC boundary are required to determine and employ the optimal glycol circulation rate if unable to comply with the actual annual throughput (less than 3.0 MMscf/day) or benzene emission (less than 1.0 ton/year) exemption requirements in § 63.764(e)(1). Actual annual average throughput for the Mewbourn TEG dehydration unit has not been less than 3.0 MMscf/day and controlled benzene emissions from the unit have been greater than 1.0 ton/year; thus, each the Mewbourn TEG dehydration unit must comply with the determined optimal glycol circulation rate for the unit. The determined optimal glycol circulation rate was 15.70 gallons per minute (gpm), but DCP requested an alternate glycol circulation rate, per 63.775(c)(7)(iii), of 34.9 gpm, due to a difference in inlet water content (lb/MMscf), which is the permitted circulation rate in 09WE1136. Under 63.764(d)(2)(ii), if the TEG dehydration unit is unable to meet the sales gas specification for moisture content using the determined optimal glycol circulation rate, the owner or operator must calculate an alternate circulation rate using GRI-GLYCalc'-', Version 3.0 or higher. DCP has not exceeded the alternate glycol circulation rate for the compliance period based on records provided the Inspector. Source is in compliance. 40 CFR 63, Subpart HHH , National Emission Standards for Hazardous Air Pollutants From Natural Gas Transmission and Storage Facilities Is the source subject to HHH: No, Mewbourn does not meet the definition of a Natural Gas Transmission and Storage Facility as defined under HHH. 40 CFR Part 60.630, Subpart JJJJ, New Source Performance Standards: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines Is source subject to JJJJ (Y or N): Yes, but only the five (5) Caterpillar G3608 reciprocating internal combustion engines (RICE) under AIRS Points 113 — 117 (C250 — C254) are subject to JJJJ based on their manufacture dates. All other RICE at Mewbourn, including the permanent replacement units for AIRS Point 104 (C-129) installed in September 2012 and for AIRS Point 101 (C-211) installed in May 2014 under the Alternate Operating Scenario (AOS), were manufactured prior to June 12, 2006 according to the APENs submitted for those units. NSPS JJJJ applies to spark ignition RICE based on horsepower and date of manufacture, as described at 40 CFR Part 60.4230. Owners and operators of spark ignition RICE that commence construction after June 12, 2006 and are manufactured: i. on or after July 1, 2007, for engines ≥500 hp (except for lean burn RICE 500 hp ≤ engine < 1,350 hp); ii. on or after January 1, 2008, for lean burn RICE 500 hp ≤ engine < 1,350 hp; iii. on or after July 1, 2008, for engines < 500 hp; or iv. on or after January 1, 2009, for emergency engines > 25 hp. DCP completed performance testing on the AIRS Point 113 - 117 (C250 - C254) RICE on September 22"d -September 24th 2014 demonstrating compliance with applicable JJJJ emission standards of 2.0 gram per horsepower -hour (g/hp-hr) NOx, 4.0 g/hp-hr CO and 1.0 g/hp-hr VOC. Note that as of the inspection report date, the Division has not yet adopted NSPS JJJJ. Until such time as it does, any RICE subject to JJJJ will be subject only under Federal law; therefore, the reference to these provisions in this report is only for applicability purposes and no compliance determination has been made. 40 CFR Part 60.630, Subpart KKK, New Source Performance Standards: Standards of Performance for Equipment Leaks of VOC from Onshore Natural Gas Processing Plants Is source subject to KKK: Yes, Mewbourn meets the definition of an Onshore Natural Gas Processing Plant under Subpart KKK. Energy Maintenance Services (EMS) is the current Leak Detection and Repair (LDAR) contractor for the facility. Initial Testing Date and Results: 1997 Date of the last component hard count: July 9th 2015 1230090 -IN SP -2015 Page 12 of 52 COLORADO Department of Public Health b Environment Air Pollution Control Division Field Inspection Report Were all detected leaks repaired in the 5 day timeframe, or within the 15day limit? No — see "Report Submittal Type/ MACT & NSPS Reports" section on pages 5 — 6. DCP reported no process unit shutdowns in their KKK semi-annual reports. The discovered leaks placed on DOR are required to be repaired during the next process unit shutdown. Source is in compliance. Was all recordkeeping submitted to the Division? Yes — see "Report Submittal Type/MACT & NSPS Reports" section. 40 CFR Part 60.630, Subpart KKKK, New Source Performance Standards: Standards of Performance for Stationary Combustion Turbines Is source subject to KKKK (Y or N): Yes, See response to Condition 26 of Construction Permit 09WE 1 136 for details. i 40 CFR Part 60, Subpart LLL, New Source Performance Standards: Standards of Performance for Onshore Natural Gas Processing: SO2 Emissions Is source subject to LLL (Y or N): Yes, the amine unit at Mewbourn is an affected source, but according to §60.640(b), affected facilities that have a design capacity less than 2 long tons per day (LT/D) of hydrogen sulfide (H2S) in the acid gas (expressed as sulfur) are required to comply with §60.647(c), but are not required to comply with §60.642 through §60.646. §60.647(c) stipulates that to certify that a source is exempt from the control requirements of LLL, each owner or operator of a facility with a design capacity less than 2 LT/D of H2S in the acid gas (expressed as sulfur) shall keep, for the life of the facility, an analysis demonstrating that the facility's design capacity is less than 2 Long Tons per Day (LT/D) or 2.24 Tons/Day of H2S expressed as sulfur. DCP demonstrated during Title V/Operating Permit modification review (see Technical Review Document for Modification to Operating Permit 95OPWE062, July — August 2012) that Mewbourn meets the requirements for exemption and, therefore, the amine unit is not subject to the SO2 standards of Subpart LLL. See also response to Condition 42 of Construction Permit 09WE 1136. Source is in compliance. 40 CFR Part 60.5360, Subpart OOOO, New Source Performance Standards: Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution Is source subject to OOOO (Y or N): No, the storage vessels and current reciprocating compressors at Mewbourn were not constructed, modified or reconstructed after the effective date of August 23, 2011. In the case of like -kind engine replacements under the Alternate Operating Scenario (AOS), such as what occurred with the permanent replacements of unit C-129/AIRS Point 104 in November 2012, unit C-211/AIRS Point 101 in May 2014, and unit C-179/AIRS Point 103 on September 22, 2014, only the engine is replaced and the compressor package remains unchanged. There are no gas wells, gas -driven pneumatic controllers, or centrifugal compressors at the facility. 40 CFR 63, Subpart ZZZZ, National Emission Standard for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines 1230090-INSP-2015 Page 13 of 52 COLORADO Department of Public Health b Environment Air Pollution Control Division Field Inspection Report Is the source subject to ZZZZ: Yes, Mewbourn is a ZZZZ area source. DCP has taken federally enforceable limits to maintain a synthetic minor source of HAPs. See Condition 5 for reported HAP emissions at Mewbourn. On August 10, 2010, EPA promulgated area source requirements for all existing spark -ignited Reciprocating Internal Combustion Engines (RICE), and existing spark -ignited RICE less than or equal to 500 HP at major sources of HAP. Pursuant to 40 C.F.R. 63.6590(a)(1)(ii)& (iii), defines a stationary RICE located at an area source of HAPs and stationary RICE with a site rating of less than 500 hp at a major source of HAPs as existing if the owner/operator commenced construction before June 12, 2006. The RICE under AIRS Points 101 - 107 at Mewbourn meet the definition of existing stationary spark ignited RICE at an area source of HAP, and DCP must meet applicable requirements for these RICE no later than October 19, 2013. The RICE under AIRS Point 101 is subject to inspection and maintenance requirements every 1,440 hours of operation or annually, whichever comes first, which includes changing the oil and filter, and inspecting spark plugs, belts and hoses and replacing as necessary. According to DCP, the AIRS Points 102 - 107 RICE, which are greater than 500 HP, met the definition of remote RICE under 40 CFR §63.6675 as of October 19, 2013. DCP reported that it conducted an initial evaluation in July 2012 of all its stationary RICE to determine which RICE were "remote" at that time. Annual evaluations are conducted each year during the month of July and results finalized July 31St, with the most recent evaluations completed in July 2014 and July 2013 confirming the remote status of the RICE under AIRS Points 102 - 107. Evaluations are conducted by DCP's GIS Group, which is the same group that conducts all DOT Class Location evaluations for DCP. The GIS Regulatory Analyst gathers data from various sources (e.g., Xmap, ArcMap, PODs) and reviews all pipelines entering or exiting facilities with compressors driven by "remote" stationary RICE. Results are then reviewed with DCP Field Operations to validate structure data, aerial imagery and other determining factors. Thus, per 40 CFR §63.6603(a), DCP must comply with inspection and maintenance requirements for the AIRS Points 102 - 107 RICE every 2,160 hours of operation or annually, whichever comes first, and includes changing the oil and filter, and inspecting spark plugs, belts and hoses and replacing as necessary. DCP will be required to evaluate the remote status of these RICE again by July 2015 (every 12 months). Source is in compliance. 40 CFR 63.7480, Subpart DDDDD, National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters Is the source subject to DDDDD (Y or N): No If no, why not: Mewbourn is not a major source of HAPs as defined under DDDDD. On January 31, 2013, EPA promulgated major source requirements for industrial, commercial, or institutional boilers and process heaters located at major sources. Pursuant to 40 CFR 63.7485, affected sources under MACT DDDDD include any industrial, commercial, or institutional boiler or process heater as defined in §63.7575 that is located at, or is part of, a major source of HAPs. Pursuant to 40 CFR 63.7495, a new or reconstructed boiler or process heater must comply with this subpart by January 31, 2013 while an existing boiler or process heater must comply with this subpart no later than January 31, 2016. An existing source is defined as commencing construction prior to January 31, 2013. 1230090-INSP-2015 Page 14 of 52 COLORADO Department of Public Health b Environment Air Pollution Control Division Field Inspection Report AQCC Regulation No. 7, Control of Ozone via Ozone Precursors and Control of Hydrocarbons via Oil and Gas Emissions Facility Location: Non -Attainment Area Facility Category: Natural gas processing plant Equipment at Facility: Glycol dehydrators Controls installed to comply with Regulation No. 7: Yes AQCC Regulation No. 7, §XII: VOC Emissions from Oil and Gas Operations Mewbourn is located within the Ozone Non -Attainment Area, and is required to comply with the requirements of AQCC Regulation No. 7, Sections XII. G, and H. §XII.G: Gas Processing Plants Section XII.G.1 requires the facility to follow the leak detection and repair (LDAR) program required by NSPS Subpart KKK. Is Source Subject to KKK? YES SEE NSPS KKK discussion, Reporting Section, and Conditions 21 & 22 of Permit 09WE1136. Section XII.G.2 requires atmospheric condensate storage tanks used to store condensate that has not been stabilized and has uncontrolled actual emissions of greater than or equal to two tons per year (tpy) to control emissions by at least 95%. There are four (4) atmospheric tanks at Mewbourn that store stabilized condensate. The tanks are manifolded together and controlled by a John Zink air -assisted enclosed flare as required by Conditions 24 & 25 of Construction Permit 09WE1136. Actual uncontrolled emissions for the tanks for the rolling 12 -month period ending September 2014 were 0.02 tpy and the condensate is stabilized; therefore, the tanks are not subject to Section XII.G.2. Source is in compliance. For the purpose of Regulation No. 7, §XII.G, source is in compliance. §XII.H: Glycol Dehydrators Uncontrolled actual VOC emissions from The Mewbourn triethylene glycol (TEG) dehydrator's (AIRS Point a still vent or flash separator/flash tank on 122) flash tank emissions are controlled by a VRU and, at the time a glycol dehydrator must be reduced by at of the inspection the still vent emissions were controlled by a least 90% through the use of a condenser condenser and RTO, which was capable of achieving 90% control or other air pollution control equipment. of emissions. As of 12/8/15, the TEG is now controlled by a dedicated Thermal Oxidizer; SEE Case Nos. 2012-057 & 2013- 035/036. Note, however, that emissions from the TEG dehydrator were not controlled by 90% from September 10th - 12th 2014, November 27th -28th 2014, December 29th 2014- January 1St 2015, March 7th -8th 2015, March 25th 2015, May 10th -12th 2015, May 21St -24th 2015, and May 24th -27th 2015, as result of non -operation of the RTO due to reported malfunctions by DCP. SEE Malfunction reporting, above. While the malfunctions resulted in a violation of Regulation No. 7, XII.H to control emissions from a dehydrator by 90%, due to the 12/11/15 emissions supplement indicating no emissions exceedance and the COC requirements to route DEHY-1 to a dedicated TO (SEE Case Nos. 2012-057 & 2013-075/076), the inspector does not recommend enforcement. SOURCE IS NOT IN COMPLIANCE. Control Device Type: VRU (flash tank) Condenser/RTO (still vent) through Dec. 8, 2015 Thermal oxidizer after December 8, 2015. For the purpose of Regulation No. 7, §XII.H, SOURCE IS NOT IN COMPLIANCE. 1230090-INSP-2015 Page 15 of 52 • COLORADO Department of Public Health Es Environment Air Pollution Control Division Field Inspection Report AQCC Regulation No. 7, Section XVI: Control of Emissions from Stationary and Portable Engines in the 8 -Hour Ozone Control Area Mewbourn is located within the Ozone Non -Attainment Area, and is consequently required to comply with the requirements of AQCC Regulation No. 7, Section XVI.A. §XVI.A.2: Natural Gas RICE Any natural gas fired engine with a manufacturer's design rate greater than 500 hp must employ air pollution control technology. (XVI.A) All engines at Mewbourn are natural gas fired and greater than 500 HP, except the Caterpillar unit under AIRS Point 101, which is 330 HP. All the Mewbourn engines are equipped with air pollution control technology (oxidation catalysts for lean -burn engines under AIRS Point 113 — 117 and air -fuel ratio control and non -selective catalytic reduction systems for rich -burn engines under AIRS Points 101 - 107), as required under Construction Permit 09WE1136. Rich burn engines shall be equipped with an NSCR and AFR controller. (XVI.B.I) Lean burn engines shall be equipped with an oxidation catalyst. (XVI.B.2) All the Mewbourn engines are equipped with air pollution control technology (oxidation catalysts for lean -burn engines under AIRS Point 113 —117 and air -fuel ratio control and non -selective catalytic reduction systems for rich -burn engines under AIRS Points 101 - 107), as required under Construction Permit 09WE1136. The emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. (XVI.B.3) DCP maintains the catalysts according to the manufacturer specifications. For the purpose of Regulation No. 7, §XVI.A.2, source is in compliance. AQCC Regulation No. 7, Section XVII: Statewide Controls for Oil and Gas Operations and Natural Gas -Fired Reci . rocatin Internal Combustion En ines Mewbourn is required to comply with the requirements of AQCC Regulation No. 7, Sections XVII.C& E. §XVII.B: General Requirements Control Device Type: Enclosed combustor (AIRS Point 110) Date control device installed: Before 5/2/2014 Able to visually observe proper operation and free of visible emissions? (XVII.B.2.b) Yes SEE Conditions 24 & 25 of Permit 09WE1136. Is the combustion device equipped with auto -igniter? (XVII.B.2.d) Yes For the purpose of Regulation No. 7, §XVII.B, source is in compliance. §XVII.D: Glycol Dehydrators Control Device Type: VRU (flash tank) Condenser/RTO (still vent) through Dec. 8, 2015 Thermal oxidizer after December 8, 2015. Beginning 05/01/2008, VOC emissions from still vents and separator or flash tanks on glycol dehydrators located at an oil and gas exploration and production operation, natural gas compressor station, or gas - processing plant with actual uncontrolled VOC emissions of 15 tpy or greater shall be reduce by at least 90% through the use The Mewbourn triethylene glycol (TEG) dehydrator's (AIRS Point 122) flash tank emissions are controlled by a VRU and, at the time of the inspection the still vent emissions were controlled by a condenser and RTO, which was capable of achieving 90% control of emissions. As of 12/8/15, the TEG is now controlled by a dedicated Thermal Oxidizer; SEE Case Nos. 2012-057 & 2013- 035/036. 1230090-INSP-2015 Page 16 of 52 COLORADO Department of Public Health & Environment Air Pollution Control Division Field Inspection Report of a condenser or air pollution control equipment. (XVII.D.1) Beginning 05/01/2015, VOC emissions from still vents and separator or flash tanks on glycol dehydrators located at an oil and gas exploration and production operation, natural gas compressor station, or gas - processing plant with actual uncontrolled VOC emissions of 6 tpy or greater (or 2 tpy or greater if located within 1,320 ft of a building unit or designated outside activity area) shall be reduce by at least 95% through the use of a condenser or air pollution control equipment. (XVII.D.3) Note, however, that emissions from the TEG dehydrator were not controlled by 90% from September 10th - 12th 2014, November 27th -28th 2014, December 29th 2014- January 1st 2015, March 7th -8th 2015, March 25th 2015, May 10th -12th 2015, May 21st -24th 2015, and May 24th -27th 2015, as result of non -operation of the RTO due to reported malfunctions by DCP. SEE Malfunction reporting, above. While the malfunctions resulted in a violation of Regulation No. 7, XII.H to control emissions from a dehydrator by 90%, due to the 12/11/15 emissions supplement indicating no emissions exceedance and the COC requirements to route DEHY-1 to a dedicated TO (SEE Case Nos. 2012-057 & 2013-075/076), the inspector does not recommend enforcement. SOURCE IS NOT IN COMPLIANCE. For the purpose of Regulation No. 7, §XVII.D, SOURCE IS NOT IN COMPLIANCE.. §XVII.E: Natural Gas RICE Pursuant to §XVII.B.5, glycol natural gas dehydrators and internal combustion engines that are subject to an emissions control requirement in an NSPS or MACT standard are not subject to Section XVII, except for the LDAR requirements in §XVII.F. See MACT ZZZZ discussion for compliance demonstration. The five (5) Caterpillar G3608 reciprocating internal combustion engines (RICE) under AIRS Points 113 —117 (C250 — C254) are subject to JJJJ based on their manufacture dates. Owners/operators of new or natural gas The engines at Mewbourn operated in Colorado prior to the dates fired RICE relocated into Colorado after in the table and are considered existing engines not subject to the the dates specified in Table 2 shall meet the emission standards based on the horsepower rating, size, and construction/ relocation rate. (XVII.E.2) emission standards. Owners/operators of natural gas fired All the Mewbourn engines are equipped with air pollution control RICE with a manufacturer's nameplate technology (oxidation catalysts for lean -burn engines under AIRS design rating of greater than 500 hp Point 113 —117 and air -fuel ratio control and non -selective catalytic constructed or modified on or before reduction systems for rich -burn engines under AIRS Points 101 — February 1, 2009, shall install emission controls on or before July 1, 2010, unless an owner/operator can demonstrate that retrofit costs exceed $5,000/ton VOC. The demonstration of retrofit costs was due no later than August 1, 2009. (XVII.E.3) 107), as required under Construction Permit 09WE1136. For the purpose of Regulation No. 7, §XVII.E, source is in compliance. AQCC Regulation No. 7, §XVIII: Natural Gas -Actuated Pneumatic Controllers Associated with Oil & Gas Operations §XVIII: Pneumatics Low -bleed pneumatic controllers used? No No -bleed pneumatic controllers used? Yes High -bleed pneumatic controllers used? No DCP reported that none of the pneumatic controllers at Mewbourn are gas -driven (all are no -bleed or air -powered).] For the purpose of Regulation No. 7, §XVIII, source is in compliance. See conditions 29 and 30 for a more detailed compliance determination of Regulation No. 7 XIIH and XVIID. 1230090-INSP-2015 Page 17 of 52 so COLORADO Department of Public Health & Environment Air Pollution Control Division Field Inspection Report PERMIT CONDITIONS AND COMPLIANCE STATUS FOR Construction Permit # 09WE1136 (facility - wide), Issuance 2 (AIRS ID 123/0090-999), effective June 28, 2012, issued to DCP Midstream, LP REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. Within one hundred and eighty days (180) after issuance of this permit, compliance with the conditions contained on this permit shall be demonstrated to the Division. It is the permittee's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). This permit was issued on June 28, 2012; therefore, permit self -certification was due no later than December 25, 2012. Permit self -certification was submitted on December 24, 2012; however, due to outstanding noncompliance issues (see "Compliance History" section on page 2), final authorization of the permit has not been approved. Source is in compliance. 2. 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 per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) The equipment under this permit was already in operation on the permit's issuance date, as the permit was issued as a modification to thirteen (13) existing emission points at the facility. Source is in compliance. 3. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Reference: Regulation No. 3, Part B, Section III.E.) See responses to Conditions 36 — 41. Source is in compliance. 4. 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. The final authorization letter for this permit has not been issued. Permit self -certification was submitted on December 25, 2012; however, due to outstanding noncompliance issues (see "Compliance History" section on page 2), final authorization of the permit has not been approved. Source is in compliance. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Monthly Limits: Facility Equipment ID AIRS Point Tons per Month Emission Type SO. H2S NO. VOC CO C-211 101 --- --- 0.43 0.27 0.43 Point 1230090-INSP-2015 Page 18 of 52 • COLORADO Department of Public Health Fs Environment Air Pollution Control Division Field Inspection Report C-167 102 --- --- 2.07 1.03 2.07 Point C-179 103 --- --- 1.82 1.21 1.82 Point C-129 104 --- --- --- --- --- Point C-134 105 --- --- --- --- --- Point C-130 106 --- --- --- --- --- Point C-131 107 --- --- 0.61 0.61 1.82 Point F017 108 --- --- --- 2.70 --- Fugitives LO 109 --- --- --- 0.21 0.18 Point TANKS 110 --- --- --- 0.11 --- Point C0170 111 --- --- 1.12 --- 1.13 Point C0180 112 --- --- 1.12 --- 1.13 Point C250 113 --- -- 3.89 5.44 1.49 Point C251 114 Point C252 115 Point C253 116 Point C254 117 Point G1650 118 --- --- 1.49 --- 1.51 Point G1670 119 Point AM001 120 --- 0.04 --- 0.71 --- Point H776 121 --- --- 0.69 0.13 1.94 Point D-931 122 --- --- --- 1.02 --- Point H771 123 --- --- 0.28 --- 0.78 Point TO701 124 2.70 --- 0.07 --- 0.40 Point (Note: Monthly limits are based on a 31 -day month.) The owner or operator shall calculate monthly emissions based on the calendar month. Facility -wide emissions of each individual hazardous air pollutant shall be less than 1,359 lb/month. Facility -wide emissions of total hazardous air pollutants shall be less than 4,011 lb/month. This permit was issued on 06/28/2012. Source was required to comply with monthly emission limits until 06/28/2013. For this compliance period, source was only required to comply with annual (rolling 12 -month emission limits). Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type SO. 112S NO: VOC CO 1230090-INSP-2015 Page 19 of 52 COLORADO Department of Public Health & Environment Air Pollution Control Division Field Inspection Report C-211 101 --- --- 5.10 3.19 5.10 Point C-167 102 --- --- 24.33 12.17 24.33 Point C-179 103 --- --- 21.41 14.27 21.41 Point C-129 104 --- --- 0.73 0.73 2.20 Point C-134 105 --- --- 0.73 0.73 2.20 Point C-130 106 --- --- 3.64 3.64 10.91 Point C-131 107 --- --- 7.14 7.14 21.41 Point F017 108 --- --- --- 31.73 --- Fugitives LO 109 --- --- --- 2.41 2.1 Point TANKS 110 --- --- --- 1.29 --- Point C0170 111 --- --- 13.14 --- 1332 Point C0180 112 --- --- 13.14 --- 1332 Point C250 113 --- --- 45.76 64.08 17.56 Point C251 114 Point C252 115 Point C253 116 Point C254 117 Point G1650 118 --- --- 17.49 --- 17.76 Point G1670 119 Point AM001 120 --- 0.50 --- 8.43 --- Point H776 121 --- --- 8.12 1.49 22.74 Point D-931 122 --- --- --- 12.06 --- Point H771 123 --- --- 3.25 --- 9.11 Point TO701 124 31.73 --- 0.86 --- 4.67 Point See "Notes to Permit Holder #4 for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility -wide emissions of total hazardous air pollutants shall be less than 23.6 tpy. i _ Table 2 — Highest Rolling 12 -Month Emissions 1230090-INSP-2015 Page 20 of 52 COLORADO Department of Public Health & Environment Air Pollution Control Division Field Inspection Report Facility Equipment ID AIRS Point Highest Tons per Year Compliance Status Rollingg 12 -Month SOS H2S NO. VOC CO C-211 101 Sept. 2014 NA NA 4.39 2.74 4.39 In Compliance C-167 102 Apr. 2015 NA NA 22.03 11.01 22.03 In Compliance C-179 103 June 2015 NA NA 17.36 11.58 17.36 In Compliance C-129 104 Did not operate during the compliance period In Compliance C-134 105 Did not operate during the compliance period In Compliance C-130 106 Oct. 2014 NA NA 1.78 1.78 5.33 In Compliance C-131 107 Oct. 2014 NA NA 1.63 1.63 4.89 In Compliance F017 108 Sept. 2014 NA NA NA 42.26 NA Not in Compliance* LO 109 Sept. 2014 NA NA NA 0.04 0.01 In Compliance TANKS 110 Sept. 2014 NA NA NA 0.02 NA In Compliance C0170 111 June 2015 NA NA 12.53 0.43 12.69 In Compliance C0180 112 June 2015 NA NA 12.76 0.44 12.93 In Compliance C250 113 NA NA 40.91 57.45 15.69 In Compliance C251 114 C252 115 Dec. 2014 C253 116 C254 117 G1650 118 NA NA 17.72 0.57 18.01 Not in Compliance** G1670 119 Dec. 2014 AM001 120 Sept. 2014 NA 0.03 NA 7.29 NA Not in Compliance*** H776 121 Oct 2014 NA NA 7.16 1.31 20.05 In Compliance D-931 122 Oct. 2014 NA NA NA 3.26 NA Not in Compliance*** H771 123 Sept. 2014 NA NA 2.96 0.54 8.28 In Compliance TO701 124 Oct. 2014 1.88 NA 0.59 NA 3.22 In Compliance Individual HAP Sept. 2014 3.01 (Benzene) In Compliance Facility -Wide Total HAP Dec. 2014 13.52 In Compliance Compliance with the synthetic minor status of this facility shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling (12) month total. By the end of each month a new 1230090-INSP-2015 Page 21 of 52 • COLORADO Department of Public Health & Environment Air Pollution Control Division Field Inspection Report twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate monthly emissions and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all emission units, requiring an APEN, at this facility. See Table 2 for the highest rolling 12 -month emissions during the compliance review period for each AIRS Point. DCP calculated emissions for each AIRS Point covered by this permit using the emission calculation methodologies/emission factors outlined in the permit. *For F-017/ (AIRS point 108) (Fugitives), DCP exceeded the rolling 12 -month VOC emission limit for the entire compliance period as follows: Rolling 12 ending Reported tpy Sept -14 42.26 Oct -14 42.2 Nov -14 42.13 Dec -14 42.11 Jan -15 42.15 Feb -15 42.19 Mar -15 42.23 Apr -15 42.27 May -15 42.31 Jun -15 42.35 In the 12/11/15 information supplement, DCP explained that "DCP submitted a Title V Operating Permit renewal application for Mewbourn on April 30, 2013 which included an APEN with updated emission calculations for fugitive emissions. As such these emissions are covered by the Title V application shield." The APEN was submitted with a requested limit of 59.11 tpy VOC from VOC emissions. However, pursuant to Regulation No. 3, Part C, I.A.4, a permit shield does not apply to terms and conditions that become applicable to the source subsequent to permit issuance. As this AIRS Point ID is not one of the permits incorporated into Permit 95OPWE062 (SEE Section I, Condition 1.3), the permit shield does not apply, and DCP cannot operate at the requested permit limit until the applicable provisions of Permit 09WE1136 are incorporated into the Title V operating permit. Additionally, the Title V Operating permit application renewal submitted 11/6/14 did not include a specific request, or follow the requirements of submitting minor permit modification, as required under Regulation No. 3, Part c, X & XI. Consequently, these are considered emissions exceedances for this compliance determination. On July 27, 2015, DCP submitted a minor permit modification application to the Division for the fugitive emissions increase, and on July 26, 2016, DCP submitted a revised Title V Operating Permit renewal application for Mewbourn incorporating the fugitive emissions increase into the Title V Operating Permit. **For G1650/G1670 (AIRS points 118/119), DCP exceeded the rolling 12 -month NOx and CO limits in the rolling 12 -month period ending in December 2014. The annual NOx limit is 17.49 tons. DCP reported NOx emissions at 17.72 tons in the rolling 12 -month period ending December 2014. The annual CO limit is 17.76 tons. DCP reported CO emissions at 18.01 tons in the rolling 12 -month period ending December 2014. DCP explained that there was no fuel exceedance due to the emission factor using hours of operation, not a fuel heat basis, and consequently no fuel exceedance is identified. On December 18, 2014, the Division granted enforcement discretion for operation of G1650/G1670 in excess of the annual limit for December 2014 for a period of 135 hours, or approximately 500 lbs of NOx and CO, 1230090-INSP-2015 Page 22 of 52 COLORADO Department of Public Health b Environment Air Pollution Control Division Field Inspection Report respectively. These emissions exceedances are at or below 500 lbs per pollutant, and inspector does not recommend enforcement for this noted exceedance. ***For AM001 (AIRS point 120) (Amine unit) and D-931 (AIRS point 122) (Dehy unit), DCP's Promax runs failed to account for RTO downtime. DCP reported RTO downtime in September 2014, November 2014, December 2014, January 2015, March 2015, and May 2015. DCP incorrectly calculated emissions at AIRS points 120 and 122 for the entire compliance period (September 2014- June 2015). In the information supplement submitted December 11, 2015, DCP explained that "DCP noted some copy/paste errors in the excess emissions tables contained in the follow-up malfunction reports sent to the Division as part of the Mewbourn Title V semi-annual monitoring and deviation report for the 1st semi- annual period in 2015. These errors consisted of the dehy emissions table not being pasted into the documents. DCP has therefore created the attached table, file named MewII_(Malf Events).pdf, which includes the prior -reported emissions for the malfunction events along with the dehy emissions reported individually for each event. This table also includes a column that adds to the 12 -month rolling emissions the malfunction (excess) emissions to the month of the malfunction." The updated emissions records indicated no emissions exceedance for the Amine or Dehy units. SOURCE IS NOT IN COMPLIANCE for failure to calculate emissions on a rolling twelve month basis. Although DCP is using the permitted control efficiencies for the amine unit and TEG dehydration unit emissions (100% flash tank and 96.7% still vent), required testing to demonstrate the control efficiency of the RTO completed on November 2, 2012 was not approved by the Division as valid and is being pursued through a non-compliance action (see "Case No. 2013-036" in Compliance History section on page 2). SOI R('1' IS NOT IN COMM 1 %NC . 6. The owner or operator shall track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility emission limitations as seen below. An inventory of each insignificant activity and associated emission calculations shall be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities shall be defined as any activity or equipment, which emits any amount but does not require an Air Pollutant Emission Notice (APEN). Total emissions from the facility, including permitted emissions and insignificant activities, shall not exceed: • 10 tons per year of a single hazardous air pollutant and/or • 25 tons per year of total hazardous air pollutants (HAP). DCP is tracking and recording emissions from all insignificant activities at Mewbourn, which include various storage tanks (TEG, Lube oil, Methanol, Oily stormwater, Used oil, Produced water, etc.), office furnace and heaters, flare pilot, and compressor blowdowns. DCP reported total HAP emissions from insignificant activities at Mewbourn as 0.13 tons per year (tpy). Source is in compliance. 7 Point 120: Compliance with the emission limits in this permit shall be demonstrated by running the Promax simulation model or Division -approved software on a monthly basis using the most recent amine unit inlet extended sour gas analysis and recorded operational values (including gas throughput, lean amine recirculation rate, VRU downtime, and other operational values as specified in the O&M plan). Recorded operational values, except for gas throughput, shall be averaged on a monthly basis for input into Promax simulation model. For AM001 (AIRS point 120) (Amine unit), DCP's Promax runs failed to account for RTO downtime. DCP reported RTO downtime in September 2014, November 2014, December 2014, January 2015, March 2015, and May 2015. DCP incorrectly calculated emissions at 1230090-INSP-2015 Page 23 of 52 .COLORADO Department of Public Health & Environment Air Pollution Control Division Field Inspection Report AIRS points 120 for the entire compliance period (September 2014- June 2015). Source is not in compliance. 8. Point 120: 100% of emissions that result from the flash tank shall be routed to the VRU to be recycled and recompressed. Emissions from the regenerator still vent shall be collected and controlled by a thermal oxidizer in order to reduce the emissions of volatile organic compounds to the level listed in this section, above. Operating parameters of the VRU and thermal oxidizer are identified in the operation and maintenance plan for this unit. (Reference: Regulation No.3, Part B, Section III.E.) 100% of emissions that result from the Point 120 flash tank are routed to the VRU to be recycled and recompressed, and emissions from the regenerator still vent are collected and controlled by a thermal oxidizer. See response to Condition 33 regarding compliance with the operating parameters of the VRU and thermal oxidizer in the operation and maintenance plan. Source is in compliance. 9. Point 122: Compliance with the emission limits in this permit shall be demonstrated by running the GRI GlyCalc model version 4.0 or higher on a monthly basis using the most recent wet gas analysis and recorded operational values (including gas throughput, lean glycol recirculation rate, VRU downtime, flash tank temperature, flash tank pressure, and other operational values specified in the O&M Plan). Recorded operational values, except for gas throughput, shall be averaged on a monthly basis for input into GRI GlyCalc. For D-931 (AIRS point 122) (Dehy unit), DCP's GlyCalc runs failed to account for RTO downtime. DCP reported RTO downtime In September 2014, November 2014, December 2014, January 2015, March 2015, and May 2015. DCP incorrectly calculated emissions at AIRS points 120 and 122 for the entire compliance period (September 2014- June 2015). Source is not in compliance. 10. Point 122: 100% of emissions that result from the flash tank associated with this dehydrator shall be recycled and recompressed. Emissions from the regenerator still vent shall be collected and controlled by a thermal oxidizer in order to reduce the emissions of volatile organic compounds to the level listed in this section, above. Operating parameters of the VRU and thermal oxidizer are identified in the operation and maintenance plan for this unit. (Reference: Regulation No.3, Part B, Section III.E.) 100% of emissions that result from the Point 122 flash tank are routed to the VRU to be recycled and recompressed, and emissions from the regenerator still vent are collected and controlled by a thermal oxidizer. See response to Condition 33 regarding compliance with the operating parameters of the VRU and thermal oxidizer in the operation and maintenance plan. Source is in compliance. PROCESS LIMITATIONS AND RECORDS 11. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the applicant and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit Monthly Limit (31 days) C-211 101 Consumption of natural gas as a fuel 21.69 MMscf/yr 1.84 MMscf/month 1230090-INSP-2015 Page 24 of 52 COLORADO Department of Public Health & Environment Air Pollution Control Division Field Inspection Report C-167 102 Consumption of natural gas as a fuel 107.21 MMscf/yr 9.11 MMscf/month C-179 103 Consumption of natural gas as a fuel 96.48 MMscf/yr 8.19 MMscf/month C-129 104 Consumption of natural gas as a fuel. Operation: 1,488 hours/year 9.11 MMscf/yr --- C-134 105 Consumption of natural gas as a fuel. Operation: 1,488 hours/year 9.11 MMscf/yr --- C-130 106 Consumption of natural gas as a fuel. Operation: 4,464 hours/year 47.52 MMscf/yr --- C-131 107 Consumption of natural gas as a fuel 93.26 MMscf/yr 7.92 MMscf/month 109 Throughput of stabilized natural gas condensate 476,190 bbl/yr 40,444 bbl/month 110 Throughput of stabilized natural gas condensate 476,190 bbl/yr 40,444 bbl/month C0170 111 Consumption of natural gas as a fuel 417.93 MMscf/yr 35.5 MMscf/month C0180 112 Consumption of natural gas as a fuel 417.93 MMscf/yr 35.5 MMscf/month C250 113 Consumption of natural gas as a fuel for all 5 compressor engines. 35,040 compressor engine -hours per year. 602.47 MMscf/yr total 51.17 MMscf/month total C251 114 C252 115 C253 116 C254 117 G1650 118 Total operation of the 2 generator turbines: 9504 generator turbine -hours per year. Consumption of natural gas as a fuel 557.57 MMscf/yr 47.36 MMscf/month G1670 119 AM001 120 Feed natural gas 58,400 MMscf/yr 4,960 MMscf/month H776 121 Consumption of natural gas as a fuel 541.45 MMscf/yr 45.986 MMscf/month D-931 122 Feed natural gas 58,400 MMscf/yr 4,960 MMscf/month H771 123 Consumption of natural gas as a fuel 216.91 MMscf/yr 18.422 MMscf/month TO701 124 Waste gas (-12 BTU/SCF) combusted 1,655 MMscf/yr 141 MMscf/month Compliance with the yearly consumption 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 monthly consumption of natural gas and keep a compliance record on site or at a local field office with site responsibility, for Division review. This permit was issued on 06/28/2012. DCP was required to comply with monthly limits until 06/28/2013. Since this compliance period takes place entirely outside of that time frame, source is only required to comply with annul limits (on a rolling 12 -month basis). DCP is tracking and recording process/consumption rates for each AIRS Point covered by this permit as required and reported the following rolling 12 -month process/consumption rates for each AIRS Point during the compliance review period): 1230090-INSP-2015 Page 25 of 52 • COLORADO Department of Public Health b Environment Air Pollution Control Division Field Inspection Report Process/Consumption Rates Facility Equipment ID AIRS Point Process Parameter Highest Rolling 12 -Month Compliance Status C-211 101 Consumption of natural gas as a fuel 18.54 MMscf/yr. (Sept. 2014) In Compliance C-167 102 Consumption of natural gas as a fuel 95.23 MMscf/yr. (Apr. 2015) In Compliance C-179 103 Consumption of natural gas as a fuel 76.06 MMscf/yr. (June 2015) In Compliance C-129 104 Did not operate during the compliance period In Compliance C-134 105 Did not operate during the compliance period In Compliance C-130 106 Consumption of natural gas as a fuel. Operation: 4,464 hours/year 7.51 MMscf/yr. (Oct. 2014) In Compliance C-131 107 Consumption of natural gas as a fuel 21.19 MMscf/yr. (Oct. 2014) In Compliance 109 Throughput of stabilized natural gas condensate 8,115 bbl/yr. (Sept. 2014) In Compliance 110 Throughput of stabilized natural gas condensate 8,115 bbl/yr. (Sept. 2014) In Compliance C0170 111 Consumption of natural gas as a fuel 378.44 MMscf/yr. (June 2015) In Compliance C0180 112 Consumption of natural gas as a fuel 385.55 MMscf/yr. (June 2015) In Compliance C250 113 Consumption of natural gas as a 529.23 MMscf/yr. total Dec 2014) In Compliance C251 114 C252 115 fuel for all 5 compressor engines. 35,040 compressor engine -hours C253 116 per year. C254 117 G1650 118 Total operation of the 2 generator turbines: 9504 turbine- 517 MMscf/ r. (Dec 2014) In Compliance G1670 119 generator hours per year. Consumption of natural gas as a fuel AM001 120 Feed natural gas 49,955 MMscf/yr. (Nov 2014) In Compliance H776 121 Consumption of natural gas as a fuel 477.49 MMscf/yr. (Oct 2014) In Compliance D-931 122 Feed natural gas 41,091 MMscf/yr. (April 2015) In Compliance H771 123 Consumption of natural gas as a fuel 197.12 MMscf/yr. (Sept. 2014) In Compliance TO701 124 Waste gas (-12 BTU/SCF) combusted 1,450 MMscf/yr. (Oct. 2014) In Compliance Source is in compliance. 1230090-INSP-2015 Page 26 of 52 COLORADO Department of Public Health & Environment Air Pollution Control Division Field Inspection Report 12. Point 120: This unit shall be limited to the maximum lean amine recirculation pump rate of 640 gallons per minute. The lean amine recirculation rate shall be recorded daily in a log maintained on site and made available to the Division for inspection upon request. (Reference: Regulation No. 3, Part B, II.A.4) DCP tracks the lean amine recirculation pump rate for Point 120 on a continuous basis through its electronic monitoring system (DCS) for the facility and maintains daily records, which were provided to the Inspector. During the inspection, the observed lean amine recirculation pump rate on the DCS was 600.5 gallons per minute (gpm). DCP reported no exceedances of the maximum lean amine recirculation pump rate during the compliance period. Source is in compliance. 13. Point 122: This unit shall be limited to the maximum lean glycol circulation rate 34.9 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. (Reference: Regulation No. 3, Part B, II.A.4) DCP tracks the lean glycol circulation rate for Point 122 on a continuous basis through its electronic monitoring system (DCS) for the facility and provided circulation rate records to the Inspector. During the inspection, the observed lean glycol circulation rate was 18.4 gallons per minute (gpm). The highest reported lean glycol circulation rate was 22.8 gpm on June 12th 201.5. Source is in compliance. STATE AND FEDERAL REGULATORY REQUIREMENTS 14. The permit number and AIRS ID number shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable). The permit number and AIRS ID number were marked on all the subject equipment under this permit. Source is in compliance. 15. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section I1.A.1. & 4.) Mewbourn was in operation at the time of the inspection, but no visible emissions were observed. The following equipment identification and operating parameters were noted: Waukesha Engines Engine AIRS Point / Unit # 102/C-167 103/C-179 104/C-129 105/C-134 106/C-130 107/C-131 Engine Serial Number C13852-1 C10731/1 387242 285300 339839 397541 Engine Operating Hours 49,483 7,077 Not operating Not operating Not operating Not operating Engine RPM 1,097 1,114 Not operating Not operating Not operating Not operating Compressor Suction Pressure 105 psi 105 psi Not operating Not operating Not operating Not operating Compressor Discharge Pressure 890 psi 880 psi Not operating Not operating Not operating Not operating 1230090-INSP-2015 Page 27 of 52 COLORADO Department of Public Health & Environment Air Pollution Control Division Field Inspection Report Catalyst Inlet Temperature ° 1,052 F ° 914 F Not operating Not operating Not operating Not operating Catalyst Differential Pressure (dP) 6.5" 1.5" Not operating Not operating Not operating Not operating Caterpillar Engines Engine AIRS Point / Unit # 101 /C-211 113 /C-250 114 /C-251 115 /C-252 116 /C-253 117 /C-254 Engine Serial Number 72B643 BEN00563 BEN00565 BEN00567 BEN00572 BEN00571 Engine Operating Hours 9,885 26,750 29,526 Not operating 25,834 30,284 960 1000 748 Not operating 1000 753 E i gine RPM Compressor Suction Pressure 27 psi 255 psi 259 psi Not operating 253 psi 255 psi Compressor Discharge Pressure 140 psi 834 psi 834 psi Not operating 834 psi 832 psi Catalyst Inlet Temperature 815°F 777 °F 735 °F Not operating 750°F 727 °F Catalyst Differential Pressure (dP) 2.00" 2.94" 2.73" Not operating 3.23" 2.51" Turbines Turbine AIRS Point / Unit # 111 /C0170 112/C0180 118/G1650 119/G1670 Turbine Serial Number TC10559 (skid); Turbine SN 1979 TC10560 (skid); Turbine SN 1980 TG09548 (skid); Turbine SN 589 TG09549 (skid); Turbine SN 590 Turbine Operating Hours 34,030 34,256 25,138 14,968 Turbine Load 96.8% 97.6% Not operating 100% Compressor Suction Pressure 135 psi 134 psi Not operating NA Compressor Discharge Pressure 879 psi 878 psi Not operating NA Amine Unit and TEG Dehydration Unit AIRS Point / Unit # 120 / AM001 (Amine) 122 / D-931 (Dehy) Contactor Inlet Temperature 100 °F 121 °F Contactor Inlet Pressure 862 psi 863 psi Flash Tank Temperature 146 °F 207 °F Flash Tank Pressure 65 psi 35 psi 1230090-INSP-2015 Page 28 of 52 COLORADO Department of Public Health & Environment Air Pollution Control Division Field Inspection Report Reboiler Temperature 250 °F 374 °F Amine or Glycol Circulation Rate 600.5 gallons/minute 18.4 gallons/minute Condenser Outlet Temperature NA NA RTO Temperature (Chamber 1) 1717°F 1717°F RTO Temperature (Chamber 2) 1686 °F 1686 °F DCP reported opacity greater than or equal to 30% on February 11th 2015 for the flare that controls the condensate tanks and loadout (AIRS 109 & 110). DCP did not take a Method 9 reading during this event, but reported it none the less. There was no evidence present to confirm opacity greater that 30% during the reported malfunction event. In addition, the malfunction was deemed to be valid. DCP reported intermittent opacity greater than 30% on September 176 2014. DCP was able to limit the duration of each opacity event by controlling the blowdown valve periodically while repairs commenced. Source claims that this kept the six (6) minute average below the 30% opacity limit. In addition, this reported malfunction event was deemed to be valid. Source is in compliance. 16. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) Mewbourn was in operation at the time of the inspection, but no odors were noted. One (1) odor complaint for Mewbourn was submitted to the Division on November 7, 2014. A Division investigation of this complaint did not discover a violation of the odor requirements of Regulation No. 2. Source is in compliance. Reciprocating Internal Combustion Engines 17. Points 102, 103, 104, 105, 106 and 107: This equipment is subject to the control requirements for stationary and portable engines in the 8 -hour ozone control area under Regulation No. 7, Section XVI.B.1. For rich burn reciprocating internal combustion engines, a non -selective catalyst reduction system and an air fuel controller shall be required. See "AQCC Regulation No. 7" section on page 14. Source is in compliance. 18. Points 102, 103, 104, 105, 106 and 107: This equipment is subject to the control requirements for natural gas -fired reciprocating internal combustion engines under Regulation No. 7, Section XVII.E.3.a (State only enforceable). All rich burn reciprocating internal combustion engines with a manufacturer's nameplate design rate greater than 500 horsepower shall install and operate both a non -selective catalytic reduction and an air fuel controller by July 1, 2010. See "AQCC Regulation No. 7" section on page 14. Source is in compliance. 19. Points 101-107, 113-117: All new, modified or relocated (into the state) natural gas -fired reciprocating internal combustion engines are subject to the control requirements for natural gas - fired reciprocating internal combustion engines under Regulation No. 7, Section XVI1.E (State only enforceable). The owner or operator of any natural gas -fired reciprocating internal combustion engine that is either constructed or relocated to the state of Colorado from another state 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: Maximum Engine HP Construction or Relocation Date Emission Standard in g/hp-hr NOx CO VOC <100HP Any N/A N/A N/A 1230090-INSP-2015 Page 29 of 52 • COLORADO Department of Public Health Et Environment Air Pollution Control Division Field Inspection Report > 1 00HP and <500HP — January 1, 2008 January 1, 2011 2.0 1.0 4.0 2.0 1.0 0.7 ≥S00HP July 1, 2007 July 1, 2010 2.0 1.0 4.0 2.0 1.0 0.7 See "AQCC Regulation No. 7" section on page 14. Source is in compliance. 20. Points 113, 114, 115, 116 and 117: This equipment is subject to the control requirements for stationary and portable engines in the 8 -hour ozone control area under Regulation No. 7, Section XV1.B.2. For lean burn reciprocating internal combustion engines, an oxidation catalyst shall be required. See "AQCC Regulation No. 7" section on page 14. Source is in compliance. Fugitive Emissions 21. Point 108: This source is subject to Regulation No. 7, Section XII.G.1 (State only enforceable). For fugitive VOC emissions from leaking equipment, the leak detection and repair (LDAR) program as provided at 40 C.F.R. Part 60, Subpart KKK (see Regulation Number 6, Part A, Subpart KKK) shall apply, regardless of the date of construction of the affected facility. The operator shall comply with all applicable requirements of Section XII. See "AQCC Regulation No. 7" section on page 14. Source is in compliance. 22. Point 108: This facility is subject to the New Source Performance Standards requirements of Regulation No. 6, Part A, Subpart KKK, Standards of Performance for Onshore Natural Gas Processing Plants including, but not limited to, the following: • 40 CFR, Part 60, Subpart A — General Provisions • §60.632 Standards o (a) - Each owner or operator subject to the provisions of this subpart shall comply with the requirements of § 60.482-1 (a), (b), and (d) and 60.482-2 through 60.482-10, except as provided in § 60.633, as soon as practicable, but no later than 180 days after initial startup. o (b) - An owner or operator may elect to comply with the requirements of §60.483-1 and §60.483-2. o (d) Each owner or operator subject to the provisions of this subpart shall comply with the provisions of §60.485 except as provided in §60.633(f) of this subpart. o (e) Each owner or operator subject to the provisions of this subpart shall comply with the provisions of §§60.486 and 60.487 except as provided in §§60.633, 60.635, and 60.636 of this subpart. • §60.633 Exceptions o (a) Each owner or operator subject to the provisions of this subpart may comply with the following exceptions to the provisions of subpart VV. o (b)(1) Each pressure relief device in gas/vapor service may be monitored quarterly and within 5 days after each pressure release to detect leaks by the methods specified in §60.485(b) except as provided in §60.632(c), paragraph (b)(4) of this section, and §60.482-4 (a) through (c) of subpart VV. ■ (2) If an instrument reading of 10,000 ppm or greater is measured, a leak is detected. 1230090-INSP-2015 Page 30 of 52 4000LORADO Department of Public Health b Environment Air Pollution Control Division Field Inspection Report • (3)(i) When a leak is detected, it shall be repaired as soon as practicable, but no later than 15 calendar days after it is detected, except as provided in §60.482-9. • (ii) A first attempt at repair shall be made no later than 5 calendar days after each leak is detected. o (c) Sampling connection systems are exempt from the requirements of §60.482-5. • §60.635 Recordkeeping o (a) Each owner or operator subject to the provisions of this subpart shall comply with the requirements of paragraphs (b) and (c) of this section in addition to the requirements of §60.486. o (b) The following recordkeeping requirements shall apply to pressure relief devices subject to the requirements of §60.633(b)(1) of this subpart. • (1) When each leak is detected as specified in §60.633(b)(2), a weatherproof and readily visible identification, marked with the equipment identification number, shall be attached to the leaking equipment. The identification on the pressure relief device may be removed after it has been repaired. • (2) When each leak is detected as specified in §60.633(b)(2), the following information shall be recorded in a log and shall be kept for 2 years in a readily accessible location: • (i) The instrument and operator identification numbers and the equipment identification number. • (ii) The date the leak was detected and the dates of each attempt to repair the leak. • (iii) Repair methods applied in each attempt to repair the leak. • (iv) "Above 10,000 ppm" if the maximum instrument reading measured by the methods specified in paragraph (a) of this section after each repair attempt is 10,000 ppm or greater. • (v) "Repair delayed" and the reason for the delay if a leak is not repaired within 15 calendar days after discovery of the leak. • (vi) The signature of the owner or operator (or designate) whose decision it was that repair could not be effected without a process shutdown. • (vii) The expected date of successful repair of the leak if a leak is not repaired within 15 days. • (viii) Dates of process unit shutdowns that occur while the equipment is unrepaired. • (ix) The date of successful repair of the leak. • (x) A list of identification numbers for equipment that are designated for no detectable emissions under the provisions of §60.482-4(a). The designation of equipment subject to the provisions of §60.482- 4(a) shall be signed by the owner or operator. • §60.636 Reporting Requirements o (a) Each owner or operator subject to the provisions of this subpart shall comply with the requirements of paragraphs (b) and (c) of this section in addition to the requirements of §60.487. o (b) An owner or operator shall include the following information in the initial semiannual report in addition to the information required in §60.487(b) (1)—(4): Number of pressure relief devices subject to the requirements of §60.633(b) except for 1230090-INSP-2015 Page 31 of 52 .COLORADO Air Pollution Control Division Department of Public Health & Environment Field Inspection Report those pressure relief devices designated for no detectable emissions under the provisions of §60.482-4(a) and those pressure relief devices complying with §60.482- 4(c). o (c) An owner or operator shall include the following information in all semiannual reports in addition to the information required in §60.487(c)(2) (i) through (vi): • (1) Number of pressure relief devices for which leaks were detected as required in §60.633(b)(2) and • (2) Number of pressure relief devices for which leaks were not repaired as required in §60.633(b)(3). See Subpart KKK section on page 14. Source is in compliance. Condensate Truck Loadout 23. Point 109: Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III.E) DCP confirmed that condensate loading to truck tanks at Mewbourn is conducted by submerged fill. Source is in compliance. Condensate Storage Tanks 24. Point 110: The condensate storage tanks covered by this permit are subject to Regulation 7, Section XVII emission control requirements. These requirements include, but are not limited to: Section XVII.C. - Emission reduction from condensate storage tanks at oil and gas exploration and production operations, natural gas compressor stations, natural gas drip stations and natural gas processing plants. XVII.C.1. Beginning May 1, 2008, owners or operators of all atmospheric condensate storage tanks with uncontrolled actual emissions of volatile organic compounds equal to or greater than 20 tons per year based on a rolling twelve-month total shall operate air pollution control equipment that has an average control efficiency of at least 95% for VOCs on such tanks. XVII.C.3. Monitoring: The owner or operator of any condensate storage tank that is required to control volatile organic compound emissions pursuant to this section XVII.C. shall visually inspect or monitor the Air Pollution Control Equipment to ensure that it is operating at least as often as condensate is loaded out from the tank, unless a more frequent inspection or monitoring schedule is followed. In addition, if a flare or other combustion device is used, the owner or operator shall visually inspect the device for visible emissions at least as often as condensate is loaded out from the tank. XVII.C.4. Recordkeeping: The owner or operator of each condensate storage tank shall maintain the following records for a period of five years: XVII.C.4.a. Monthly condensate production from the tank. XVII.C.4.b For any condensate storage tank required to be controlled pursuant to this section XVII.C., the date, time and duration of any period where the air pollution control equipment is not operating. The duration of a period of non - operation shall be from the time that the air pollution control equipment was last observed to be operating until the time the equipment recommences operation. 1230090-INSP-2015 Page 32 of 52 COLORADO Department of Public Health & Environment Air Pollution Control Division Field Inspection Report XVII.C.4.c. For tanks where a flare or other combustion device is being used, the date and time of any instances where visible emissions are observed from the device. See "AQCC Regulation No. 7" section on page 14. Based on actual uncontrolled emissions, the Mewbourn tanks are not currently subject to Regulation No. 7, Section XVII.C for the compliance period reviewed. Source is in compliance. 25. Points 110: The flare covered by this permit is subject to Regulation No. 7, Section XVII.B General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed, have no visible emissions during normal operations, and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. The operator shall comply with all applicable requirements of Section XVII. See response to Condition 24 above. The flare controlling the Mewbourn condensate tanks is not currently subject to Regulation No. 7, Section XVII.B for the compliance period reviewed; however, the flare is enclosed, equipped with a sight glass, and was confirmed to be in operation during the inspection with no visible emissions. Source is in compliance. Turbines 26. Points 111, 112, 118 and 119: The combustion turbines are subject to the New Source Performance Standards requirements of Regulation No. 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 100 ppm at 15% O2 or 5.5 lb/MW-hr; See response below to NO. Monitoring. Source is in compliance. • §60.4330 — Sulfur Dioxide Emissions Limits o §60.4330 (a)(I) - 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. DCP provided sulfur monitoring results of the Mewbourn fuel gas using ASTM D5504 from December 30, 2013 and December 2, 2014. The 2013 results showed total grains of sulfur of 0.0542 per 100 scf and total grains of H2S of 0.0792 per 100 scf, and the 2014 results showed total grains of sulfur of .0414 per 100 scf and total grains of H2S of .0246 grains per 100 scf, which meets the requirement of 20 grains of sulfur or less per 100 scf in Subpart KKKK. Source is in compliance. • §60.4340 — NO. Monitoring o §60.4340 (a) - Operator shall perform annual performance tests in accordance with §60.4400 to demonstrate continuous compliance with NOx emissions limits. DCP conducted required performance tests on the Mewbourn turbines under Points 111, 112, 118 and 119 on October 24, 2013, which showed compliance with NOx emission limits in NSPS Subpart KKKK. The test results were reviewed and approved by the Division on January 14, 2014. The results of the tests showed measured NOx emissions at 15% O2 to be 9 ppm for Point 111, 8 ppm for Point 112, 7 ppm for Point 118 and 5 1230090-INSP-2015 Page 33 of 52 COLORADO Department of Public Health 8 Environment Air Pollution Control Division Field Inspection Report ppm for Point 119. Note that because measured NOx emissions were less than 75% of the limit for each turbine, the next KKKK performance tests on the turbines will need to be completed no later than December 24, 2015, per §60.4340 (a), which allows subsequent performance testing no more than 26 calendar months following the previous performance test showing NOx emissions were less than 75% of the limit. Note that DCP is also conducting quarterly portable analyzer tests on the Mewbourn turbines and all test results from the compliance review period showed compliance with permitted emission limits. Source is in compliance. Amine Sweetening Unit 27. Point 120: This amine unit is subject to the New Source Performance Standards requirements of Regulation No. 6, Part A, Subpart LLL, Standards of Performance for Onshore Natural Gas Processing: SO2 Emissions, including, but not limited to, the following: • 40 CFR, Part 60, Subpart A — General Provisions • §60.640 — Applicability and Designation of Affected Facilities o §60.640(b) - Facilities that have a design capacity less than 2 long tons per day (LT/D) of hydrogen sulfide (H2S) in the acid gas (expressed as sulfur) are required to comply with §60.647(c) but are not required to comply with §§60.642 through 60.646. • §60.647 — Record keeping and reporting Requirements o §60.647(c) - To certify that a facility is exempt from the control requirements of these standards, each owner or operator of a facility with a design capacity less that 2 LT/D of H2S in the acid gas (expressed as sulfur) shall keep, for the life of the facility, an analysis demonstrating that the facility's design capacity is less than 2 LT/D of H2S expressed as sulfur. See "Subpart LLL" section. Source is in compliance. TEG Glycol Dehydrator 28. The control device covered by this permit is subject to Regulation No. 7, Section XVII.B General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed, have no visible emissions during normal operations, and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. The operator shall comply with all applicable requirements of Section XVII. The Mewbourn TEG Glycol Dehydrator is controlled by a Regenerative Thermal Oxidizer (RTO), not a flare; therefore this permit condition does not apply. Source is in compliance. 29. Point 122: This equipment is subject to the control requirements for glycol natural gas dehydrators under Regulation No. 7, Section XVII.D (State only enforceable). Beginning May 1, 2008, 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 an average of at least 90 percent through the use of air pollution control equipment. This source shall comply with all applicable general provisions of Regulation 7, Section XVII 1230090-INSP-2015 Page 34 of 52 COLORADO Department of Public Health b Environment Air Pollution Control Division Field Inspection Report See "AQCC Regulation No. 7" section on page 14. Source failed to control emissions from the Mewbourn TEG Glycol Dehydrator by 90% during reported malfunctions of the RTO from September 10th - 12th 2014, November 27th — 28th 2014, December 29th 2014 — January 1" 2015, March 7th — 8th 2015, March 25th 2015, May 10th - 12th 2015, May 21St — May 24th 2015, and May 24th — May 27th 2015 Only the September 10th - 12th 2014 reported malfunction was deemed to be valid. SEE Malfunction reporting, above. While the malfunctions resulted in a violation of Regulation No. 7, XII.H to control emissions from a dehydrator by 90%, due to the 12/11/15 emissions supplement indicating no emissions exceedance and the COC requirements to route DEHY-1 to a dedicated TO (SEE Case Nos. 2012-057 & 2013-075/076), the inspector does not recommend enforcement. `O1 RCT IS NOT IN C'C1l1 PI 11. NC F 30. Point 122: This equipment is subject to the control requirements for glycol natural gas dehydrators under Regulation No. 7, Section XII.H. Beginning May 1, 2005, 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 through the use of air pollution control equipment. This source shall comply with all applicable general provisions of Regulation 7, Section XII. See "AQCC Regulation No. 7" section on page 14. SOURCE IS NOT IN COMPLIANCE (see response to Condition 29 above). 31. Point 122: This source is subject to the TEG dehydrator area source requirements of 40 CFR, Part 63, Subpart HH - National Emission Standards for Hazardous Air Pollutants for Source Categories from Oil and Natural Gas Production Facilities including, but not limited to, the following §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 (O(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 (O(3) through (f)(6) of this section. §63.760 (f)(6) - The owner or operator of an affected area source that is not located in an Urban -1 county, as defined in §63.761, the construction or reconstruction of which commences on or after July 8, 2005, shall achieve compliance with the provisions of this subpart immediately upon initial startup or January 3, 2007, whichever date is later. §63.764 - General Standards §63.764 (d)(2) —Each owner or operator of an area source not located in a UA plus offset and UC boundary (as defined in §63.761) shall comply with the provisions specified in paragraphs (d)(2(i) through (iii) of this section. §63.764 (d)(2)(i) - Determine the optimum glycol circulation rate using the following equation: 1230090-INSP-2015 Page 35 of 52 COLORADO ' Air Pollution Control Division Department of Public Health b Environment Field Inspection Report L -1.15 *3.0 gal TEG * F * (1— O) lb H2O 24hr/day Where: Lon- = Optimal circulation rate, gal/hr. F = Gas flowrate (MMSCF/D) I = Inlet water content (lb/MMSCF) O = Outlet water content (lb/MMSCF) 3.0 = The industry accepted rule of thumb for a TEG-to water ratio (gal TEG/lbH2O) 1.15 = Adjustment factor included for a margin of safety. §63.764 (d)(2)(ii) - Operate the TEG dehydration unit such that the actual glycol circulation rate does not exceed the optimum glycol circulation rate determined in accordance with paragraph (d)(2)(i) of this section. If the TEG dehydration unit is unable to meet the sales gas specification for moisture content using the glycol circulation rate determined in accordance with paragraph (d)(2)(i), the owner or operator must calculate an alternate circulation rate using GRI—GLYCaIcTM, Version 3.0 or higher. The owner or operator must document why the TEG dehydration unit must be operated using the alternate circulation rate and submit this documentation with the initial notification in accordance with §63.775(c)(7). §63.764 (d)(2)(iii) - Maintain a record of the determination specified in paragraph (d)(2)(ii) in accordance with the requirements in §63.774(f) and submit the Initial Notification in accordance with the requirements in §63.775(c)(7). If operating conditions change and a modification to the optimum glycol circulation rate is required, the owner or operator shall prepare a new determination in accordance with paragraph (d)(2)(i) or (ii) of this section and submit the information specified under §63.775(c)(7)(ii) through (v). §63.774 - Recordkeeping Requirements §63.774 (b) - Except as specified in paragraphs (c), (d), and (1) 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. (i) §63.774 (b)(1)(i) — All applicable records shall be maintained in such a manner that they can be readily accessed. (ii) §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. (iii) §63.774 (b)(1)(iii) - The remaining 4 years of records may be retained offsite. (iv) §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 (1) - The owner or operator of an area source not located within a UA plus offset and UC boundary must keep a record of the calculation used to determine the optimum glycol circulation rate in accordance with §63.764(d)(2)(i) or §63.764(d)(2)(ii), as applicable. 1230090-INSP-2015 Page 36 of 52 COLORADO Department of Public Health Et Environment Air Pollution Control Division Field Inspection Report §63.775 — Reporting Requirements §63.775 (c) - Except as provided in paragraph (c)(8), each owner or operator of an area source subject to this subpart shall submit the information listed in paragraph (c)(1) of this section. If the source is located within a UA plus offset and UC boundary, the owner or operator shall also submit the information listed in paragraphs (c)(2) through (6) of this section. If the source is not located within any UA plus offset and UC boundaries, the owner or operator shall also submit the information listed within paragraph (c)(7). §63.775 (c)(1) - The initial notifications required under §63.9(b)(2) not later than January 3, 2008. In addition to submitting your initial notification to the addressees specified under §63.9(a), you must also submit a copy of the initial notification to EPA's Office of Air Quality Planning and Standards. Send your notification via e-mail to CCG—ONG@EPA.GOV or via U.S. mail or other mail delivery service to U.S. EPA, Sector Policies and Programs Division/Coatings and Chemicals Group (E143—01), Attn: Oil and Gas Project Leader, Research Triangle Park, NC 27711. §63.775 (c)(7) - The information listed in paragraphs (c)(I)(i) through (v) of this section. This information shall be submitted with the initial notification. (v) §63.775 (c)(7)(i) - Documentation of the source's location relative to the nearest UA plus offset and UC boundaries. This information shall include the latitude and longitude of the affected source; whether the source is located in an urban cluster with 10,000 people or more; the distance in miles to the nearest urbanized area boundary if the source is not located in an urban cluster with 10,000 people or more; and the names of the nearest urban cluster with 10,000 people or more and nearest urbanized area. (vi) §63.775 (c)(7)(ii) - Calculation of the optimum glycol circulation rate determined in accordance with §63.764(d)(2)(i). (vii) §63.775 (c)(7)(iii) - If applicable, documentation of the alternate glycol circulation rate calculated using GRI-GLYCalcTM, Version 3.0 or higher and documentation stating why the TEG dehydration unit must operate using the alternate glycol circulation rate. (viii) §63.775 (c)(7)(iv) - The name of the manufacturer and the model number of the glycol circulation pump(s) in operation. (ix) §63.775 (c)(7)(v) - Statement by a responsible official, with that official's name, title, and signature, certifying that the facility will always operate the glycol dehydration unit using the optimum circulation rate determined in accordance with §63.764(d)(2)(i) or §63.764(d)(2)(ii), as applicable. §63.775 (f) - Notification of process change. Whenever a process change is made, or a change in any of the information submitted in the Notification of Compliance Status Report, the owner or operator shall submit a report within 180 days after the process change is made or as a part of the next Periodic Report as required under paragraph (e) of this section, whichever is sooner. The report shall include: §63.775 (f)(1) - A brief description of the process change; §63.775 (f)(2) - A description of any modification to standard procedures or quality assurance procedures §63.775 (f)(3) - Revisions to any of the information reported in the original Notification of Compliance Status Report under paragraph (d) of this section; and §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. 1230090-INSP-2015 Page 37 of 52 'COLORADO Department of Public Health Et Environment Air Pollution Control Division Field Inspection Report See Subpart HH section. Source is in compliance. Heaters 32. Points 121 and 123: This source is subject to the New Source Performance Standards requirements of Regulation No. 6, Part A Subpart Dc, Standards of Performance for Small Industrial -Commercial -Institutional Steam Generating Units including, but not limited to, the following: a. The owner or operator of the facility shall record and maintain records of the amount of fuel combusted during each month (40 CFR Part 60.48c(g)). b. Monthly records of fuel combusted required under the previous condition shall be maintained by the owner or operator of the facility for a period of two years following the date of such record (40 CFR Part 60.48c(i)). DCP only uses natural gas as fuel for the heaters and maintains monthly and rolling 12 - month records of fuel use for the units (see table in response to Condition 11 for reported fuel use). Source is in compliance. In addition, the following requirements of Regulation No. 6, Part A, Subpart A, General Provisions, apply. c. At all times, including periods of start-up, shutdown, and malfunction, the facility and control equipment shall, to the extent practicable, be maintained and operated in a manner consistent with good air pollution control practices for minimizing emissions. Determination of whether or not acceptable operating and maintenance procedures are being used will be based on information available to the Division, which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. (Reference: Regulation No. 6, Part A. General Provisions from 40 CFR 60.11 The heaters were operating during the inspection and no visible emissions were observed. DCP is following acceptable operating and maintenance procedures for the heaters. Source is in compliance. d. No article, machine, equipment or process shall be used to conceal an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gases discharged to the atmosphere. (§ 60.12) There was no evidence of concealment found during the inspection of the heaters or in a review of the records for Mewbourn provided by DCP. Source is in compliance. e. Written notification of construction and initial startup dates shall be submitted to the Division as required under § 60.7. DCP submitted a Notice of Startup for the heaters on May 25, 2011. Source is in compliance. f. Records of startups, shutdowns, and malfunctions shall be maintained, as required under § 60.7. DCP is maintaining records of startups, shutdowns, and malfunctions. See pages 5- 10 for reported malfunctions at Mewbourn, none of which were related to the heaters. Source is in compliance. 1230090-INSP-2015 Page 38 of 52 • COLORADO Department of Public Health b Environment g. Air Pollution Control Division Field Inspection Report Excess Emission and Monitoring System Performance Reports shall be submitted as required under § 60.7. The Excess Emission and Monitoring System Performance Reports apply to a continuous monitoring device, which is not required for the Mewbourn heaters. Source is in compliance. h. Performance tests shall be conducted as required under § 60.8. No performance testing of the heaters is required. The only requirement is to maintain fuel use records. Source is in compliance. General notification and reporting requirements under § 60.19. There are no ongoing or periodic reporting requirements for the heaters. Notification of startup was submitted on May 25, 2011. Source is in compliance. OPERATING & MAINTENANCE REQUIREMENTS 33. Upon startup of these points, the applicant shall follow the operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) The approved operating and maintenance (O&M) plans for Mewbourn utilize the Division's O&M Plan Templates (Forms APCD -301, -302, -303, -304, -306). An overview of the O&M Plans' requirements in italics and DCP's actions for each requirement in bold are noted below: Reciprocating Internal Combustion Engines (RICE): • Inlet temperature to the catalyst will be monitored/recorded daily and maintained between 750 °F and 1,250 °F for Rich Burn RICE (AIRS Points 101 - 107) and between 450 °F and 1,350 °F for Lean Burn RICE (AIRS Points 113 - 117); DCP manually records the catalyst inlet temperature for the Mewbourn RICE on a daily basis (not monitored on DCS/electronic monitoring system) and provided monitoring records to the Inspector for the compliance review period. A review of the provided records shows all recorded catalyst inlet temperatures were within the specified range for the particular RICE. Source is in compliance. • Air -Fuel Ratio Controller (AFRC) oxygen (O2) sensor millivolt (mV) reading will be monitored and recorded weekly and during portable analyzer testing for Rich Burn RICE, and the O2 sensor will be replaced per manufacturer's recommended schedule. DCP manually records the AFRC O2 sensor mV reading for each of the Mewbourn Rich Burn RICE on a weekly basis (not monitored on DCS/electronic monitoring system) and during portable analyzer testing, and provided monitoring records to the Inspector for the compliance review period. A review of the provided records indicates all recorded O2 sensor mV readings were within the target voltage and no adjustments were made. DCP is replacing the O2 sensors on the Mewbourn Rich Burn RICE on a regular schedule. The O2 sensors on units C-129, -130, -131 and -134 (AIRS Points 104 - 107) are being replaced quarterly, while the O2 sensors on units C-167, -179 and - 211 (AIRS Points 101 - 103) are being replaced based on hours of operation. 1230090-INSP-2015 Page 39 of 52 COLORADO Department of Public Health b Environment Air Pollution Control Division Field Inspection Report Source is in compliance. • Catalyst Differential Pressure (dP) baseline will be established during each initial compliance and portable analyzer test, and the catalyst dP will be monitored/recorded monthly and maintained within (plus or minus) 2 inches of water column from the baseline. If the pressure is outside this range then the appropriate maintenance shall be performed to bring the pressure back into range. In lieu of maintenance the source may choose to perform a portable analyzer test of the engine to establish a new dP value. If the test demonstrates that the engine is in compliance with its emission limits, the dP value at which the engine is tested shall become the new baseline. DCP provided catalyst dP records for the Mewbourn RICE to the Inspector. A review of the provided records indicates that all catalyst dP readings were within 2" of the water column form the most recently established baseline value (baseline values were established during quarterly portable analyzer testing events). Source is in compliance. • Portable analyzer testing will be performed quarterly (EPA reference method test can be used to replace a portable analyzer test if it takes place during the proper time period); if four consecutive portable analyzer tests show compliance with the permitted emission limits then the testing frequency will decrease to semi-annual (allowance to decrease to semi-annual testing does not apply because Mewbourn is a Major Source); DCP is completing portable analyzer testing of the Mewbourn RICE on a quarterly basis as required and provided test results to the Inspector. RICE C-129 and C-134 (AIRS Points 104 & 105) did not operate during the compliance period. Therefore, they were not tested. The Division's Portable Testing guidelines allows an operator to opt out of testing if an engine operates less than 100 hours in a quarter. All completed tests showed compliance with permitted NOx and CO emission limits. Source is in compliance. • Clean, recondition and replace the catalyst per manufacturer's recommended schedule. For a new, cleaned or reconditioned catalyst on an existing engine, a new dP baseline must be established within the first seven (7) days of engine/catalyst operation and re-established during the next regularly scheduled emission test. DCP reported that catalysts are replaced/reconditioned more frequently than the manufacturer's recommended schedule and that portable testing is always completed within 7 business days to establish a new dP baseline value. There was no evidence (catalyst operating parameters outside of acceptable ranges reported throughout the compliance period) to suggest that regular catalyst maintenance was not occurring. Source is in compliance. TEG Dehydrator: • Daily monitoring and recording of the lean glycol circulation rate using a glycol flow meter (primary) or assume the maximum design pump rate (back-up). See response to Condition 13. Source is in compliance. 1230090-INSP-2015 Page 40 of 52 • COLORADO Department of Public Health & Environment Air Pollution Control Division Field Inspection Report • Weekly monitoring and recording of the wet gas inlet temperature and pressure. DCP is recording the wet gas inlet temperature and pressure for the TEG Dehydrator on a daily basis and maintaining monthly averages. During the inspection, the observed wet gas inlet temperature and pressure was 121 °F and 863 psi, respectively. Source is in compliance. • Monthly monitoring and recording of the volume of gas processed. DCP monitors the volume of gas processed by the TEG Dehydrator. See table in response to Condition 11 for reported gas processing rates. • Weekly monitoring and recording of the condenser outlet temperature. See response to Condition 34. Source is in compliance. • The thermal oxidizer combustion chamber temperature will be monitored and recorded daily to verify it is at least 1400 °F. DCP monitors the Mewbourn thermal oxidizer operating temperature in real time through its facility electronic monitoring system (DCS), which will alarm if the combustion chamber temperature drops below 1400 °F. During the inspection, the observed combustion chamber temperatures were 1717 °F and 1686 °F. DCP provided daily combustion chamber temperature records for the thermal oxidizer and none were below 1400 °F. Source is in compliance. Amine Unit: • Daily monitoring and recording of the lean amine circulation rate using an amine flow meter (primary) or assume the maximum design pump rate (back-up). See response to Condition 12. Source is in compliance. • Weekly monitoring and recording of the gas inlet temperature and pressure. DCP is recording the gas inlet temperature and pressure for the Amine Unit on a daily basis and maintaining monthly averages. During the inspection, the observed wet gas inlet temperature and pressure was 100 °F and 862 psi, respectively. Source is in compliance. • Monthly monitoring and recording of the volume of gas processed DCP monitors the volume of gas processed by the Amine Unit. See table in response to Condition 11 for reported gas processing rates. • The thermal oxidizer combustion chamber temperature will be monitored and recorded daily to verj it is at least 1400 °F. DCP monitors the Mewbourn thermal oxidizer operating temperature in real time through its facility electronic monitoring system (DCS), which will alarm if the combustion chamber temperature drops below 1400 °F. During the inspection, the observed combustion chamber temperatures were 1717 °F and 1686 °F. DCP provided daily combustion chamber temperature records for the thermal oxidizer and none were below 1400 °F. Source is in compliance. Condensate Storage Tanks 1230090-INSP-2015 Page 41 of 52 40 COLORADO Department of Public Health Et Environment Air Pollution Control Division Field Inspection Report • Condensate throughput will be monitored and recorded monthly through sales or haul tickets (primary) or tank level measurements, which take into account all additions and loadout activities (backup). DCP monitors and records throughput for the Mewbourn condensate tanks as required. See table in response to Condition 11 for reported condensate throughput. Source is in compliance. • The temperature and pressure of the separator will be monitored and recorded weekly. DCP reported that it monitors the pre -stabilizer 3 -phase separator temperature through its facility electronic monitoring system (DCS) and manually records the separator pressure. At the time of the inspection, the separator temperature was observed to be 121 °F and the pressure was 35 psi. Source is in compliance. • The presence of the flare pilot light/flame will be monitored and recorded daily through a thermocouple (primary) or visual inspection (backup) or optical sensor (back up). DCP reported it monitors the flare pilot light operation via thermocouple connected to the facility's electronic monitoring system (DCS) and that an alarm sounds if the flame goes out. DCP also performs a manual daily check of the flare pilot to ensure it is operating and provided records of these checks to the Inspector. During the inspection, the flare pilot light was confirmed to be in operation. Source is in compliance. • Method 22 readings for determining visible emissions from the flare will be performed and recorded daily. DCP reported it performs daily Method 22 readings of the condensate tanks' flare and provided records of the readings to the Inspector. DCP reported that no visible emissions were observed from the flare for the entire compliance period. During the inspection, the flare was confirmed to be in operation with no visible emissions. Source is in compliance. • The thief hatch seals shall be inspected for integrity annually and replaced as necessary. Thief hatch covers shall be weighted and properly seated. Pressure relief valves (PRV) shall be inspected annually for proper operation and replaced as necessary. PRVs shall be set to release at a pressure that will ensure flashing, working and breathing losses (as applicable) are routed to the control device under normal operating conditions. Annual inspections shall be documented with an indication of status, a description of any problems found, and their resolution. DCP is performing the required annual inspection of the Mewbourn condensate tanks' thief hatches and PRVs through a third -party vendor (Quadco, Inc.). The most recent inspections were performed on October 3, 9 and 10, 2014. Source is in compliance. 34. Point 122: The condenser outlet temperature shall be recorded as per the frequency required in the approved O&M Plan. This information shall be maintained in a log on site and made available to the Division for inspection upon request. The condenser outlet temperature shall not exceed 145 °F on a monthly average basis. The approved O&M Plan requires weekly recording of the condenser outlet temperature for Point 122. DCP is recording the condenser outlet temperature on a daily basis and maintaining monthly averages. Source is in compliance. 1230090-INSP-2015 Page 42 of 52 COLORADO Department of Public Health b Environment Air Pollution Control Division Field Inspection Report 35. Point 122: The flash tank temperature and pressure shall be recorded on a weekly basis. This information shall be maintained in a log on site and made available to the Division for inspection upon request. DCP is recording the flash tank temperature and pressure for Point 122 on a daily basis and maintaining monthly averages. During the inspection, the observed flash tank temperature and pressure for Point 122 was 207 °F and 35 psi, respectively. Source is in compliance. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 36. Points 101, 102, 103, 104, 105, 106, 107, 111, 112, 113, 114, 115, 116, 117, 118, 119: Source compliance tests shall be conducted to measure the emission rate(s) for the pollutants listed below in order to show compliance with various emission standards, emission limits, and to demonstrate performance of the emission control devices / systems. 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 stack 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 (Reference: Regulation No. 3, Part B., Section III.G.3) Oxides of Nitrogen using EPA approved methods. Volatile Organic Compounds using EPA approved methods. Carbon Monoxide using EPA approved methods. Formaldehyde According to the Division records, compliance testing for each AIRS Point was completed as follows: AIRS ID Date Test Completed Comments 101 August 29-31, 2011 102 and September 1-2, Testing demonstrated compliance with permitted emission limits. 103 2011 104 November 6-8, 12- Testing showed AIRS Point 104 (C-129) exceeded the permitted NOx 105 15 and 21, 2011 emission limit. 106 The Division did not accept testing for AIRS Point 106 (C-130) since 107 engine operating records showed the engine ignition timing was changed the day before the test, and the Division had specifically requested in the October 19, 2012 letter to DCP that it not modify engine operational set -points for a period of six (6) days prior to the test, specifically in order to ensure the test was conducted under conditions representative of normal operations. Testing showed compliance with permitted emission limits for AIRS Points 105 (C-134) and 107 (C-131). SOURCE IS NOT IN COMPLIANCE. The Inspector does not recommend further enforcement as the compliance issues for AIRS Points 104 and 106 are addressed under Case No. 2013-036 (see "Compliance History" section). 111 Testing demonstrated compliance with permitted emission limits. 1230090-INSP-2015 Page 43 of 52 COLORADO Department of Public Health 8 Environment Air Pollution Control Division Field Inspection Report 112 August 29-31, 2011 and September 1-2, 2011 113 November 12-13, 114 2013 115 Testing demonstrated compliance with permitted emission limits. 116 117 118 August 29-31, 2011 119 and September 1-2, Testing demonstrated compliance with permitted emission limits. 2011 SOURCE IS NOT IN COMPLIANCE. The Inspector does not recommend further enforcement as the compliance issues for AIRS Points 104 and 106 are addressed under Case No. 2013-036 (see "Compliance History" section). 37. Point 120: A source initial compliance test shall be conducted on emissions point 120 to measure the emission rate(s) for the pollutants listed below and the control efficiency in order to demonstrate compliance with the emissions limits contained 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 (Reference: Regulation No. 3, Part B., Section III.G.3) Volatile Organic Compounds using EPA approved methods. Benzene, Toluene, Ethylbenzene, Xylenes and n -Hexane using EPA approved methods. Hydrogen Sulfide using EPA approved methods DCP conducted compliance testing on AIRS Point 120 (Amine Unit and Regenerative Thermal Oxidizer/RTO) on November 2, 2012, but the Division determined that testing was not conducted under conditions representative of normal operation (reduced processing rate for AIRS Point 122, which also feeds into the RTO, and unreported maintenance on the RTO prior to testing); therefore, the test results were not considered valid. DCP also failed to provide requested RTO maintenance records to the Division by no later than December 28, 2012 pursuant to a request made under C.R.S. §25-7-111(2)(c) and (i). SOURCE IS NOT IN COMPLIANCE. The Inspector does not recommend further enforcement as this compliance issue is addressed under Case No. 2013-036 (see "Compliance History" section). 38. Point 120: Within one hundred and eighty days (180) after issuance of this permit, the owner or operator shall complete the initial annual extended sour gas analysis testing required by this permit and submit the results to the Division as part of the self -certification process. Results of the sour gas analysis shall be used to calculate emissions of criteria pollutants and hazardous air pollutants per Condition no. 7. DCP conducted the required extended sour gas analysis for AIRS Point 120 from a sample taken on November 27, 2012 and submitted the results with permit self -certification received on December 24, 2012 within 180 days after issuance of this permit. Source is in compliance. 1230090-INSP-2015 Page 44 of 52 e COLORADO Department of Public Health £t Environment Air Pollution Control Division Field Inspection Report 39. Point 120: Within one hundred and eighty days (180) after issuance of this permit, the operator shall complete an initial sample of the inlet gas to the plant to determine the concentration of hydrogen sulfide (H2S) in the gas stream. The sample results shall be submitted to the Division as part of the self -certification process and used to calculate emissions from this unit according to Condition 7. DCP determined the concentration of hydrogen sulfide (H2S) in the inlet gas stream to Mewbourn for AIRS Point 120 via gas chromatograph on November 27, 2012 and submitted the results with permit self -certification received on December 24, 2012 within 180 days after issuance of this permit. Results showed H2S levels of 0.1 ppm mole (ul/L) or 0.0000 pounds per 1,000 standard cubic feet. Source is in compliance. 40. Point 122: A source initial compliance test shall be conducted on emissions point 122 to measure the emission rate(s) for the pollutants listed below and the control efficiency in order to demonstrate compliance with the emissions limits contained 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 (Reference: Regulation No. 3, Part B., Section III.G.3) Volatile Organic Compounds using EPA approved methods. Benzene, Toluene, Ethylbenzene, Xylenes and n -Hexane using EPA approved methods. DCP conducted compliance testing on AIRS Point 122 (TEG Dehydration Unit and Regenerative Thermal Oxidizer/RTO) on November 2, 2012, but the Division determined that testing was not conducted under conditions representative of normal operation (reduced processing rate for AIRS Point 122 and unreported maintenance on the RTO prior to testing); therefore, the test results were not considered valid. DCP also failed to provide requested RTO maintenance records to the Division by no later than December 28, 2012 pursuant to a request made under C.R.S. §25-7-111(2)(c) and (i). SOURCE IS NOT IN COMPLIANCE. The Inspector does not recommend further enforcement as this compliance issue is addressed under Case No. 2013-036 (see "Compliance History" section). 41. Point 124: A source initial compliance test shall be conducted on emissions point 124 to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emissions limits contained 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 (Reference: Regulation No. 3, Part B., Section III.G.3) Oxides of Sulfur using EPA approved methods. Oxides of Nitrogen using EPA approved methods. Carbon Monoxide using EPA approved methods. Hydrogen Sulfide using EPA approved methods. DCP conducted compliance testing on AIRS Point 124 (Regenerative Thermal Oxidizer/RTO) on November 2, 2012, but the Division determined that testing was not 1230090-INSP-2015 Page 45 of 52 'COLORADO Department of Public Health & Environment Air Pollution Control Division Field Inspection Report conducted under conditions representative of normal operation (reduced processing rate for AIRS Point 122, which feeds into the RTO, and unreported maintenance on the RTO prior to testing); therefore, the test results were not considered valid. DCP also failed to provide requested RTO maintenance records to the Division by no later than December 28, 2012 pursuant to a request made under C.R.S. §25-7-111(2)(c) and (i). SOURCE IS NOT IN COMPLIANCE. The Inspector does not recommend further enforcement as this compliance issue is addressed under Case No. 2013-036 (see "Compliance History" section). Periodic Testing Requirements 42. Point 120: The operator shall sample the inlet gas to the plant on an annual basis to determine the concentration of hydrogen sulfide (H2S) in the gas stream. The sample results shall be monitored to demonstrate that this amine unit qualifies for the exemption from the Standards of Performance for Onshore Natural Gas Processing: SO2 Emissions (§60.640(b)). The testing required by Condition 43 may be used for this demonstration. DCP is determining the concentration of hydrogen sulfide (H2S) in the inlet gas stream to Mewbourn for AIRS Point 120 on an annual basis as required. The most recent determination was completed on December 02, 2014 via gas chromatograph (ASTM D5504) and showed H2S levels of .5 ppm mole (ul/L) or 0.0001 pounds per 1000 standard cubic feet (total sulfur and H2S). The results show the amine unit qualifies for the exemption from the Standards of Performance for Onshore Natural Gas Processing: SO2 Emissions (§60.640(b)). Source is in compliance. 43. Point 120: The owner or operator shall complete an extended sour gas analysis prior to the inlet of the amine unit on an annual basis. Results of the sour gas analysis shall be used to calculate emissions of criteria pollutants and hazardous air pollutants this permit. DCP is completing an extended sour gas analysis prior to the inlet of the amine unit on an annual basis. The most recent analyses were completed from samples taken on March 27, 2014 (April 3, 2014 analysis) and December 2, 2015 (Analysis on December 4, 2015). Source is in compliance. 44. Point 120: The owner or operator shall sample the inlet gas to the plant on an annual basis to determine the concentration of hydrogen sulfide (H2S) in the gas stream. The sample results shall be used to calculate emissions from this unit according to Condition 7. See responses to Condition 42 and 43. The extended sour gas analyses include concentration of hydrogen sulfide (H2S) in the gas stream and the sample results are being used to calculate emissions from AIRS Point 120 according to Condition 7. Source is in compliance. 45. Point 122: The owner or operator shall complete an extended wet gas analysis prior to the inlet of the TEG dehydrator on an annual basis. Results of the wet gas analysis shall be used to calculate emissions of criteria pollutants and hazardous air pollutants per this permit. DCP is completing an extended wet gas analyses prior to the inlet of the amine unit on an annual basis. The most recent analyses were completed from samples taken on March 27, 2014 (April 3, 2014 analysis) and December 2, 2015 (analysis on December 4, 2015). Results of the wet gas analysis are being used to calculate emissions of criteria pollutants and hazardous air pollutants per this permit. Source is in compliance. ADDITIONAL REQUIREMENTS 46. All previous versions of this permit are cancelled upon issuance of this permit. 1230090-INSP-2015 Page 46 of 52 COLORADO Department of Public Health b Environment Air Pollution Control Division Field Inspection Report Source is in compliance. 47. This facility is located in an ozone non -attainment or attainment -maintenance area and subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.b., for minimization and / or control of emissions of Volatile Organic Compounds and Nitrogen Oxides. For the requested emissions, compliance with the requirements to minimize and / or control the emissions specified in this permit are determined to be RACT for this facility. Any request/s for modification of this permit for increased allowable emissions shall be accompanied by RACT analyses. DCP is following the requirements for minimization and / or control of emissions of Volatile Organic Compounds and Nitrogen Oxides in this permit. Source is in compliance. 48. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually 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 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. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A or B. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine or turbine, 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 or turbine. The most recent APENs for the emission points under this permit were received on the following dates: AIRS Point Current APEN Received Date 101 05/15/2014 102 05/01/2013 103 10/06/2014 104 04/30/2013 105 02/29/2012 106 107 108 07/27/2015 109 9/30/10 110 111 07/22/2014 112 1230090-INSP-2015 Page 47 of 52 • COLORADO Department of Public Health b Environment Air Pollution Control Division Field Inspection Report 113 02/29/2012 114 115 116 117 118 07/22/2014 119 07/22/2014 120 02/29/2012 122 02/29/2012 123 03/23/2012 124 02/29/2012 Source is in compliance. 49. Minimum stack heights are required for the following points: Facility ID AIRS Point Minimum stack height (ft) 123/0090 101 16.48 102 40.00 103 40.00 104 23.21 105 23.21 106 27.98 107 28.00 111 35.80 112 35.80 113 45.00 114 45.00 115 45.00 116 45.00 117 45.00 118 45.00 119 45.00 121 20.00 123 20.00 124 40.00 Emergency Flare 75.00 DCP confirmed the stack height for each emissions point meets the minimum stack height requirement. Source is in compliance. 50. 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 provisions of this construction permit must be incorporated into the operating permit. The application for the modification to the Operating Permit is due within one year from permit issuance. This permit was issued on June 28, 2012; therefore, the modification to the Mewbourn Operating Permit was due no later than June 28, 2013. DCP submitted the Operating Permit modification/renewal application on May 1, 2013 and an application shield was granted effective May 1, 2013. In an email to Mr. Flores on December 12, 2014, DCP further explained that at the time the notification was made, it was thought that the HAP emissions estimates resulting from the September 17, 2012 updated fugitive emissions component hard count at Mewbourn plus the 1230090-INSP-2015 Page 48 of 52 COLORADO Department of Public Health b Environment Air Pollution Control Division Field Inspection Report 25% buffer added to the component hard count (as a compliance buffer) triggered the obligation to file the MACT notification. DCP has since confirmed that the actual emissions of hazardous air pollutants (HAP) at Mewbourn have never exceeded 25 tons per year or the major source threshold. Source is in compliance. 51. Non -attainment New Source Review requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable NSR threshold will require a full NSR review of the source as though construction had not yet commenced on the source. The source shall not exceed the NSR threshold until a NSR permit is granted. (Regulation No. 3 Part D, V.A.7) See Table 2 in response to Condition 5 for reported facility -wide emissions. No evidence was observed during the inspection or in a review of the records provided by DCP or the Division's records, including reported malfunctions deemed invalid, to indicate relaxation of any permit condition has occurred at Mewbourn during the compliance review period that would trigger Non -attainment New Source Review requirements. Source is in compliance. 52. Prevention of Significant Deterioration (PSD) requirements shall apply to this source for CO at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable PSD threshold will require a full PSD review of the source as though construction had not yet commenced on the source. The source shall not exceed the PSD threshold until a PSD permit is granted. (Regulation No. 3 Part D, VI.B.4) See Table 2 in response to Condition 5 for reported facility -wide emissions. No evidence was observed during the inspection or in a review of the records provided by DCP or the Division's records, including reported malfunctions deemed invalid, to indicate relaxation of any permit condition has occurred at Mewbourn during the compliance review period that would trigger Prevention of Significant Deterioration requirements. Source is in compliance. GENERAL TERMS AND CONDITIONS: 53. 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 No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 54. 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-I 14.5(12)(a) C.R.S. and AQCC Regulation No. 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. 55. This permit is issued in reliance upon the accuracy and completeness of information supplied by the applicant 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 applicant or applicant's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 1230090-INSP-2015 Page 49 of 52 • COLORADO Department of Public Health Et Environment Air Pollution Control Division Field Inspection Report 56. 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. 57. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the applicant, or the Division revokes a permit, the applicant or owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 58. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 59. 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. DCP is in compliance with the General Terms and Conditions of this permit. Inspection Summary and Conclusion Based upon the physical inspection, a review of the records provided, supplemental information, and the Division's and other records, DCP is NOT in compliance with the following: A. Pursuant to AQCC Regulation No. 7, XII.H and XVII.D, an applicable source must control emissions from glycol dehydrators by at least 90%. The Mewbourn triethylene glycol (TEG) dehydrator's (AIRS Point 122) flash tank emissions are controlled by a VRU and the still vent emissions are controlled by a condenser and RTO, which are capable of achieving 90% control of emissions. Note, however, that emissions from the TEG dehydrator were not controlled by 90% from September 10th — 12th 2014, November 27th -28th 2014, December 29th 2014- January 1St 2015, March 7th -8th 2015, March 25th 2015, May 10th -12th 2015, May 21St -24th 2015, and May 24th -27th 2015, as result of non -operation of the RTO due to reported malfunctions by DCP (only the September 10th -12th 2014 malfunction is considered valid), violating AQCC Regulation No. 7 XII H and XVII.D. B. Pursuant to Permit Number 09WE1136, Condition 5, Source was required to limit emissions form all points to the specified levels listed in the condition's emissions table. 1. For F-017/ (AIRS point 108/Fugitives), DCP exceeded the rolling 12 -month VOC emission limit for the entire compliance period as follows: Rolling Reported 12 ending tpy Sept -14 42.26 Oct -14 42.2 Nov -14 42.13 Dec -14 42.11 Jan -15 42.15 1230090-INSP-2015 Page 50 of 52 4DICOLORADO Department of Public Health b Environment Air Pollution Control Division Field Inspection Report Feb -15 42.19 Mar -15 42.23 Apr -15 May -15 42.27 42.31 Jun -I5 42.35 In the 12/11/15 information supplement, DCP explained that "DCP submitted a Title V Operating Permit renewal application for Mewbourn on April 30, 2013 which included an APEN with updated emission calculations for fugitive emissions. As such these emissions are covered by the Title V application shield." The APEN was submitted with a requested limit of 59.11 tpy VOC from VOC emissions. However, pursuant to Regulation No. 3, Part C, I.A.4, a permit shield does not apply to terms and conditions that become applicable to the source subsequent to permit issuance. As this AIRS Point ID is not one of the permits incorporated into Permit 95OPWE062 (SEE Section I, Condition 1.3), the permit shield does not apply, and DCP cannot operate at the requested permit limit until the applicable provisions of Permit 09WE1136 are incorporated into the Title V operating permit. Additionally, the Title V Operating permit application renewal submitted 11/6/14 did not include a specific request, or follow the requirements of submitting minor permit modification, as required under Regulation No. 3, Part c, X & XI. Consequently, these are considered emissions exceedances for this compliance determination, violating Permit Number 09WE1136, Condition 5. On July 27, 2015, DCP submitted a minor permit modification application to the Division for the fugitive emissions increase, and on July 26, 2016, DCP submitted a revised Title V Operating Permit renewal application for Mewbourn incorporating the fugitive emissions increase into the Title V Operating Permit. 2. For AM001 (AIRS point 120) (Amine unit) and D-931 (AIRS point 122) (Dehy unit), DCP's Promax runs failed to account for RTO downtime. DCP reported RTO downtime in September 2014, November 2014, December 2014, January 2015, March 2015, and May 2015. DCP incorrectly calculated emissions at AIRS points 120 and 122 for the entire compliance period (September 2014- June 2015). In the information supplement submitted December 11, 2015, DCP explained that "DCP noted some copy/paste errors in the excess emissions tables contained in the follow-up malfunction reports sent to the Division as part of the Mewbourn Title V semi-annual monitoring and deviation report for the 151 semi-annual period in 2015. These errors consisted of the dehy emissions table not being pasted into the documents. DCP has therefore created the attached table, file named MewIliMalf Events).pdf, which includes the prior -reported emissions for the malfunction events along with the dehy emissions reported individually for each event. This table also includes a column that adds to the 12 -month rolling emissions the malfunction (excess) emissions to the month of the malfunction." The updated emissions records indicated no emissions exceedance for the Amine or Dehy units. DCP failed to calculate emissions for the Amine unit on a rolling twelve month basis, violating Permit Number 09WE1136, Condition 5. C. Pursuant to Permit Number 09WE1136, Condition 7, the source is required to demonstrate compliance with the emission limits listed in condition 5 by running a monthly Promax simulation model using the most recent control device downtime. DCP's Promax runs failed to account for RTO downtime. DCP reported RTO downtime in September 2014, November 2014, December 2014, January 2015, March 2015, and May 2015. DCP incorrectly calculated emissions at AIRS points 120 for the entire compliance period (September 2014- June 2015), violating Permit Number 09WE1136, Condition 7. D. Pursuant to Permit Number 09WE1136, Condition 9, the source was required to demonstrate compliance with the emission limits listed in condition 5 by running a monthly GRI GlyCalc simulation model using the most recent control device downtime. DCP's Promax runs failed to account for RTO downtime. DCP reported RTO downtime In September 2014, November 2014, December 2014, January 2015, March 2015, and May 2015. DCP incorrectly calculated emissions at AIRS points 122 for the entire compliance period (September 2014- June 2015), violating Permit Number 09WE1136, Condition 9. E. Pursuant to Permit Number 09WE1136, Condition 29, the source is required to comply with the Regulation No. 7 XVIID and all applicable general provision of section XVII. DCP failed to control emissions from the TEG glycol dehydrator by 90% during reported malfunctions of the RTO from September 10th -12th 2014, November 27th — 210 1230090-INSP-2015 Page 51 of 52 COLORADO Department of Public Health b Environment Air Pollution Control Division Field Inspection Report 2014, December 29th 2014 — January 1St 2015, March 7th — 8th 2015, March 25th 2015, May 10th - 12th 2015, May 21St —May 24th 2015, and May 24th — 27th 2015 (only the September 10th -12th 2014 reported malfunction was deemed valid). In addition, DCP is not in compliance with the general provisions of Regulation No. 7 XVII.B.1.b and XVII.B.2.a., violating Permit Number 09WE1136, Condition 29. F. Pursuant to Permit Number 09WE1136, Condition 30, the source is required to comply with the Regulation No. 7 XII.H and all applicable general provision of section XII. DCP failed to control emissions from the TEG glycol dehydrator by 90% during reported malfunctions of the RTO from September 10th -12th 2014, November 27th — 28th 2014, December 29th 2014 — January 1St 2015, March 7th — 8th 2015, March 25th 2015, May 10th - 12th 2015, May 21St —May 24th 2015, and May 24th — 27th 2015 (only the September 10th -12th 2014 reported malfunction was deemed valid), violating Permit Number 09WE1136, Condition 30. DCP is also NOT IN COMPLIANCE with Conditions 36, 37, 40 and 41 of Construction Permit #09WE1136, Issuance 2 pertaining to Compliance Testing issues. However, the Inspector does not recommend enforcement as these noncompliance issues have been addressed through Case Nos. 2012-057 & 2013-035/036 (see "Compliance History" section on page 2). The Inspector recommends the issuance of a Warning Letter. 1230090-INSP-2015 Page 52 of 52 On Mon Apr 24 2017 11:39:59 GMT -0600 (Mountain Daylight Time), Tom Parko Jr. <tparko@co.weld.co.us>wrote: Mr. Ewing, Thank you for your email. We will make sure that your email is included in the record. believe Mr. Ogle has reached out to you about the amendment and the hearing dates before the Planning Commission and Board of County Commissioners. At this time, we are going to move forward with the My 16th PC hearing. With that said, the Planning Commission has the ability to continue the hearing or refer the case back to Planning based on testimony given from the public or from staff recommendations / comments. The Planning Commission can also provide a recommendation to approve or deny the request. Sincerely, Tom Parko, M.A. Director of Planning Services Weld County Dept. of Planning Services 1555 N. 17th Avenue Greeley, CO. 80631 Office: 970-400-3572 Mobile: 970-302-5333 Confidentiality Notice: This electronic transmission and any attached documents or other writings are intended only for the person or entity to which it is addressed and may contain information that is privileged, confidential or otherwise protected from disclosure. If you have received this communication in error, please immediately notify sender by return e-mail and destroy the communication. Any disclosure, copying, distribution or the taking of any action concerning the contents of this communication or any attachments by anyone other than the named recipient is strictly prohibited. EXHIBIT ' ly,Tv`fk :sir> 91"- From: Eric Ewing [mailto:ewinghr@yahoo.com] Sent: Monday, April 24, 2017 12:22 PM To: Tom Parko Jr. <tparko@co.weld.co.us> Cc: Kim Ogle <kogle@co.weld.co.us>; Michelle Martin <mmartin@co.weld.co.us>; Phillip Brewer <pbrewer@co.weld.co.us>; Ben Frissell <bfrissell-durley@co.weld.co.us> Subject: Re: RE: URGENT: Requesting a Stay of Proceedings for 5MJUSR17-83-542f Mr. Parko, Thanks for the speedy response. I appreciate the time you are putting into this issue. I'll submit something in writing to address the USR Development Standards to be included for the Planning Commission's review before May 16, 2017. What you received today is inadequate. The email you responded to doesn't address my concerns regarding the 5Am USR details, just the proceedings for May 16, 2017. In addition, I have more information I need from Weld County: 1. Why Development Standard #26 regarding COGCC rules on the 3rdAm was removed and is not present on the 4thAm? 2. A draft of the 5thAm. I also need to request my communications with you be kept as confidential as practical due to previous incidences of retaliation and intimidation by DCP Midstream employees/associates for cooperating with CDPHE. Please let me know how to do that and still have the Planning Commission know my concerns. Thanks, Eric Ewing EXHIBIT 7 COLORADO Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Issued on: July 27, 2016 Ms. Patricia Grajeda De Babb Environmental Specialist DCP Midstream, LP 370 17th Street, Suite 2500 Denver, CO 80202 Re: Warning Letter to DCP Midstream LP regarding non-compliance at Mewbourn Natural Gas Plant, AIRS No: 123-0090 Dear Ms. Patricia Grajeda De Babb, This Warning Letter provides notice to DCP Midstream LP ("DCP") related to compliance issues discovered by the Air Pollution Control Division ("Division"). DCP owns and operates the Mewbourn Natural Gas Plant at SEC35 T4N R66W in Weld County ("Mewbourn"). Mewbourn is subject to the terms and conditions of the Colorado Construction Permit Number 09WE1136 Issuance 2 issued to DCP on June 28, 2012 ("Permit Number 09WE1136"), Colorado Air Quality Control Statutes, and Colorado Air Quality Control Commission ("AQCC") Regulations. On July 23, 3015, Mr. James Flores of the Division inspected Mewbourn. Based on Mr. Flores' inspection and a review of records related to Mewbourn, the Division is issuing this Warning Letter for the following non-compliance issue(s): 1. Pursuant to AQCC Regulation No. 7, XII.H and XVII.D, and Condition 29 of Permit 09WE1136, an applicable source must control emissions from glycol dehydrators by at least 90%. The Mewbourn triethylene glycol (TEG) dehydrator's (AIRS Point 122) flash tank emissions were controlled by a VRU and the still vent emissions are controlled by a condenser and RTO, which are capable of achieving 90% control of emissions. Emissions from the TEG dehydrator were not controlled by 90% from September 10th - 12th 2014, November 27th -28th 2014, December 29th 2014- January 1St 2015, March 7th - 8th 2015, March 25th 2015, May 10th -12th 2015, May 21St -24th 2015, and May 24th -27th 2015, as result of non -operation of the RTO due to reported malfunctions by DCP (only the September 10th -12th 2014 malfunction is considered valid), violating AQCC Regulation No. 7 XII H and XVII.D. An emissions supplement dated 12/11/15 indicated no emissions exceedance, and DCP has complied with Compliance Order on Consent for Case Nos. 2013-036, 2013-035, Et 2012-057, to route the emissions from the TEG's still vent to a dedicated thermal oxidizer in July 2015. 2 Pursuant to Permit Number 09WE1136, Condition 5, Source was required to limit emissions form all points to the specified levels listed in the condition's emissions table. 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer EXHIBIT iffreovsektityv, 43+1- 8 c5 A. For F-017/ (AIRS point 108/Fugitives), DCP exceeded the rolling 12 -month VOC emission limit for the entire compliance period as follows: Rolling 12 ending Reported tpy Sept -14 42.26 Oct -14 42.2 Nov -14 42.13 Dec -14 42.11 Jan -15 42.15 Feb -15 42.19 Mar -15 42.23 Apr -15 42.27 May -15 42.31 Jun -15 42.35 DCP believed the Title V Operating Permit renewal application for Mewbourn on April 30, 2013 which included an APEN with updated emission calculations for fugitive emissions, would be covered by the Title V application shield. The APEN was submitted with a requested limit of 59.11 tpy VOC from VOC emissions. However, pursuant to Regulation No. 3, Part C, I.A.4, a permit shield does not apply to terms and conditions that become applicable to the source subsequent to permit issuance. As this AIRS Point ID was not one of the permits incorporated into Permit 95OPWE062 (SEE Section I, Condition 1.3), the permit shield did not apply. Consequently, these are considered emissions exceedances for this compliance determination, violating Permit Number 09WE1136, Condition 5. On July 27, 2015, DCP submitted a minor permit modification application to the Division for the fugitive emissions increase, and on July 26, 2016, DCP submitted a revised Title V Operating Permit renewal application for Mewbourn incorporating the fugitive emissions increase into the Title V Operating Permit. B. For AM001 (AIRS point 120) (Amine unit) and D-931 (AIRS point 122) (Dehy unit), DCP's Promax runs failed to account for RTO downtime. DCP reported RTO downtime in September 2014, November 2014, December 2014, January 2015, March 2015, and May 2015. DCP incorrectly calculated emissions at AIRS points 120 and 122 for the entire compliance period (September 2014- June 2015). In the information supplement submitted December 11, 2015, DCP explained that "DCP noted some copy/paste errors in the excess emissions tables contained in the follow-up malfunction reports sent to the Division as part of the Mewbourn Title V semi-annual monitoring and deviation report for the 1 S` semi-annual period in 2015. These errors consisted of the dehy emissions table not being pasted into the documents. DCP has therefore created the attached table, file named Mewll_(Malf Events).pdf, which includes the prior -reported emissions for the malfunction events along with the dehy emissions reported individually for each event. This table also includes a column that adds to the 12 -month rolling emissions the malfunction (excess) emissions to the month of the malfunction." The updated emissions records indicated no emissions exceedance for the Amine or Dehy units. DCP failed to calculate emissions for the Amine unit on a rolling twelve month basis, violating Permit Number 09WE1136, Condition 5. 3. Pursuant to Permit Number 09WE1136, Condition 7, the source is required to demonstrate compliance with the emission limits listed in condition 5 by running a 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer monthly Promax simulation model using the most recent control device downtime. DCP's Promax runs failed to account for RTO downtime. DCP reported RTO downtime in September 2014, November 2014, December 2014, January 2015, March 2015, and May 2015. DCP incorrectly calculated emissions at AIRS points 120 for the entire compliance period (September 2014- June 2015), violating Permit Number 09WE1136, Condition 7. In the information supplement submitted December 11, 2015, updated emissions records indicated no emissions exceedance for the Amine or Dehy units and incorporated downtime into the model simulation. 4. Pursuant to Permit Number 09WE1136, Condition 9, the source was required to demonstrate compliance with the emission limits listed in condition 5 by running a monthly GRI GlyCalc simulation model using the most recent control device downtime. DCP's Promax runs failed to account for RTO downtime. DCP reported RTO downtime In September 2014, November 2014, December 2014, January 2015, March 2015, and May 2015. DCP incorrectly calculated emissions at AIRS points 122 for the entire compliance period (September 2014- June 2015), violating Permit Number 09WE1136, Condition 9. In the information supplement submitted December 11, 2015, updated emissions records indicated no emissions exceedance for the Amine or Dehy units and incorporated downtime into the model simulation. This letter constitutes a formal warning that DCP operated in violation of Conditions 5, 7, 9, Et 29 Permit Number 09WE1136, as well as AQCC Regulation No. 7, XII.H and XVII.D. Please be aware that you are responsible for complying with State air pollution regulations and that there are substantial administrative and civil penalties for failing to do so. Section 25-7-122(1)(b), C.R.S., provides that any person failing to comply with an applicable emission control regulation of the Air Quality Control Commission shall be subject to a penalty of not more than Fifteen Thousand Dollars ($15,000.00) per day for each day of such violation. If you have any questions concerning this matter, contact me at 303-692-3144. Sincerely, -1110atiq Jennifer Mattox Enforcement Supervisor, Oil Et Gas Team Stationary Sources Program P 303.692.3144 I F 303.782.0278 4300 Cherry Creek Drive South, Denver, CO 80246-1530 jennifer.mattox@state.co.us cc: Heather Wuollet, APCD Shannon McMillan, APCD Jennifer Morse, APCD Margaret Knox-Kruschke, APCD Christopher Laplante, APCD File 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 From: Phillip Brewer Sent: Monday, April 24, 2017 12:56 PM To: Mattox - CDPHE, Jennifer (jennifer.mattox@state.co.us) <iennifer.mattox@state.co.us> Cc: Lauren Light <Ilight@co.weld.co.us>; Ben Frissell <bfrissell-durley@co.weld.co.us>; Tom Parko Jr. <tparko@co.weld.co.us> Subject: Revisiting 123-0090 Mewbourne-Ewing Complaint Good Morning, Jennifer: This is a set of questions about the 123-0090 Mewbourn Plant that is a continuing problem for us here in Weld County. The original reason for Weld County interest in the compliance of the plant with APCD issued air permits was expressed by a neighbor of the plant whose name is Eric Ewing. The "Actions Report" in CACTIS for 123-0090 show that all previously discovered violations were resolved as of July 1, 2016. This note addresses the: "Warning Letter to DCP Midstream LP regarding non-compliance at Mewbourn Natural Gas Plant, AIRS No.: 123-0090" Dated July 27, 2016. This "Warning Letter" was issued in response to the findings of an inspection that was conducted on July 23, 2015 by James Flores. Questions: 1. How much time is allowed DCP Midstream to resolve the "warnings"? 2. What procedure is followed by the APCD if warnings are not resolved or addressed? 3. Has DCP Midstream as of April 21, 2017 (today) resolved or satisfactorily addresssed the "warnings" that are listed in this letter? 4. Is a letter (written documentation) issued by the Division to DCP-Midstream when all of the "warnings" are resolved? 5. What is the APCD follow-up procedure if the warnings are not resolved? Thanks, again, Jennifer for looking at our questions about this major source here in our area. Phil J. Phillip (Phil) Brewer Environmental Specialist III Weld County Department of Public Health and Environment Environmental Health Services 1555 N 17th Avenue Greeley, CO 80631 EXHIBIT From: Tom Parko Jr. Sent: Tuesday, April 25, 2017 8:39 AM To: Eric Ewing <ewinghr@yahoo.com> Cc: Kim Ogle <kogle@co.weld.co.us>; Michelle Martin <mmartin@co.weld.co.us>; Phillip Brewer <pbrewer@co.weld.co.us>; Ben Frissell <bfrissell-durley@co.weld.co.us> Subject: RE: RE: URGENT: Requesting a Stay of Proceedings for 5MJUSR17-83-542f Eric, Good morning. If you submit your concerns in writing to the Planning Commission or to the Board of County Commissioners please send those to Kim Ogle. Kim will make sure they are part of the record. With respect to your question regarding Development Standard No.26, it was removed because the COGCC (Colorado Oil and Gas Conservation Commission) doesn't have jurisdiction over midstream facilities so it's not applicable. Any communications with me concerning cases can be included as part of the public record. As stated above, if you want your concerns vetted with the Planning Commission and the Board of County Commissioners I recommend that you send a letter and / or attend the hearings and speak during public comment. Sincerely, Tom Parko, M.A. Director of Planning Services Weld County Dept. of Planning Services 1555 N. 17th Avenue Greeley, CO. 80631 Office: 970-400-3572 Mobile: 970-302-5333 Confidentiality Notice: This electronic transmission and any attached documents or other writings are intended only for the person or entity to which it is addressed and may contain information that is privileged, confidential or otherwise protected from disclosure. If you have received this communication in error, please immediately notify sender by return e-mail and destroy the communication. Any disclosure, copying, distribution or the taking of any action concerning the contents of this communication or any attachments by anyone other than the named recipient is strictly prohibited. EXHIBIT pitlT4'94- .0 D 2 10 From: Phillip Brewer Sent: Wednesday, April 26, 2017 10:44 AM To: Kim Ogle <kogle@co.weld.co.us>; Michelle Martin <mmartin@co.weld.co.us> Cc: Ben Frissell <bfrissell-durley@co.weld.co.us> Subject: FW: Revisiting 123-0090 Mewbourne-Ewing Complaint Kim and Michelle: Please see attached response from the APCD re. the warning letter issued to DCP Midstream re. the Mewbourne Plant inspection. My interpretation of the response is: "There are no compliance violations. All discovered compliance violations have been resolved." May we assuredly have this entered into the archived records of this complaint from Mr. Ewing. Contact me if you have further comments or interpretational requirements. Phil J. Phillip (Phil) Brewer Environmental Specialist III Weld County Department of Public Health and Environment Environmental Health Services 1555 N 17th Avenue Greeley, CO 80631 970-356-4000, x 2227 (office & messages) 970-304-6411 (Fax) 970-590-7702 (c, M -F, 8 am - 5pm) pbrewer@co.weld.co.us • PHAB s*inia ..thm... 5* v,,, ,$ Confidentiality Notice: This electronic transmission and any attached documents or other writings are intended only for the person or entity to which it is addressed and may contain information that is privileged, confidential or otherwise protected from disclosure. If you have received this communication in error, please immediately notify sender by return e-mail and destroy the communication. Any disclosure, copying, distribution or the taking of any action concerning the contents of this communication or any attachments by anyone other than the named recipient is strictly prohibited. From: Mattox - CDPHE, Jennifer [mailto:jennifer.mattox@state.co.us] Sent: Wednesday, April 26, 2017 9:54 AM To: Phillip Brewer <pbrewer@co.weld.co.us> Cc: Lauren Light <Ilight@co.weld.co.us>; Ben Frissell <bfrissell-durley@co.weld.co.us>; Tom Parko Jr. <tparko@co.weld.co.us>; shannon.mcmillan@state.co.us; Laplante - CDPHE, Christopher <christopher.laplante@state.co.us> Subject: Re: Revisiting 123-0090 Mewbourne-Ewing Complaint HI Phil, Thanks for your questions about Mewbourn; I apologize for the delay in replying; I've answered your questions in red text below, but please let me know if you have additional questions. I am also copying my Chris Laplante and Shannon McMillan, so they are apprised of the request and my response. Please let me know if I can provide any additional information. Best, J Jennifer Mattox Enforcement Supervisor, Oil & Gas Team Stationary Sources Program COLORADO Air Pollution Control Division Department of Public Health & Environment P 303.692.3144 I F 303.782.0278 4300 Cherry Creek Drive South, Denver, CO 80246-1530 jennifer.mattox@state.co.us I www.colorado.gov/cdphe/apcd 4300 Cherry Creek Drive South, Denver, CO 80246-1530 On Mon, Apr 24, 2017 at 12:56 PM, Phillip Brewer <pbrewer@co.weld.co.us>wrote: Good Morning, Jennifer: This is a set of questions about the 123-0090 Mewbourn Plant that is a continuing problem for us here in Weld County. The original reason for Weld County interest in the compliance of the plant with APCD issued air permits was expressed by a neighbor of the plant whose name is Eric Ewing. The "Actions Report" in CACTIS for 123-0090 show that all previously discovered violations were resolved as of July 1, 2016. This note addresses the: "Warning Letter to DCP Midstream LP regarding non-compliance at Mewbourn Natural Gas Plant, AIRS No.: 123-0090" Dated July 27, 2016. This "Warning Letter" was issued in response to the findings of an inspection that was conducted on July 23, 2015 by James Flores. Questions: 1. How much time is allowed DCP Midstream to resolve the "warnings"? Warning Letters are for violations that companies have already addressed. The Division does not issue a WL for ongoing compliance issues, rather a Warning Letter is a close-out document. If these issues had not been rectified as discussed in the WL, the Division would have evaluated the use of another enforcement mechanism. 2. What procedure is followed by the APCD if warnings are not resolved or addressed? See above. In this instance, each of the violations was addressed, as described in the WL- the solutions included submitting an updated permit application, correctly calculating emissions, and providing information regarding control equipment downtime. 3. Has DCP Midstream as of April 21, 2017 (today) resolved or satisfactorily addresssed the "warnings" that are listed in this letter? For the 2015 full compliance evaluation, these compliance issues were closed with the issuance of the WL, which was a recognition that the noncompliance issues had been addressed. 4. Is a letter (written documentation) issued by the Division to DCP-Midstream when all of the "warnings" are resolved? I'm not sure I understand this question, if you could clarify that would help me... if you're asking whether the WL is issued when all compliance issues are resolved, then yes, the WL is considered to address those issues discovered during an inspection. 5. What is the APCD follow-up procedure if the warnings are not resolved? Warning Letters are issued upon confirmation that any outstanding compliance issues have been addressed, so there is no follow up procedure. Thanks, again, Jennifer for looking at our questions about this major source here in our area. Phil J. Phillip (Phil) Brewer Environmental Specialist Ill Weld County Department of Public Health and Environment Environmental Health Services 1555 N 17th Avenue Greeley, CO 80631 970-356-4000, x 2227 (office & messages) 970-304-6411 (Fax) 970-590-7702 (c, M -F, 8 am - 5pm) pbrewer@co.weld.co.us Confidentiality Notice: This electronic transmission and any attached documents or other writings are intended only for the person or entity to which it is addressed and may contain information that is privileged, confidential or otherwise protected from disclosure. If you have received this communication in error, please immediately notify sender by return e-mail and destroy the communication. Any disclosure, copying, distribution or the taking of any action concerning the contents of this communication or any attachments by anyone other than the named recipient is strictly prohibited. May 11, 2017 Telephone call received by Troy Swain, Local Government Designee from Dennis Nagel who expressed concerns with dust generated from construction vehicles and equipment traveling on County Road 38 Section Line past his residence. Troy suggested he attend the land use hearing. Don & Terri Dechant 18488 WCR 33, LaSalle, CO 80645 970.302.1798 terridechant@yahoo.com 5/8/17 Weld County Department of Planning Services Case #/ Record #: 5MJUSR17-83-542 1555 N 17th AVE, Greeley CO 80631 To Whom It May Concern, PcsEivEco MAY 152 Weld County Oil YPlann csrrce Partm�E nt GREELE As a resident and landowner adjacent to the Natural Gas Processing Facility, my family and I are concerned about the noise pollution that is generated and additional noise pollution that will occur. Along with decreasing the values of our home and property. We propose the following options: Option 1: The Natural Gas Processing Facility pay the cost to: 1. Stucco the exterior of our house. • Justification to reduce noise pollution inside our home. • We can get three quotes for the job, if needed. 2. Put in an additional tree line or wall near our property boundary. • Justification to reduce the site of gas plant along with sound reduction when working outside. Option 2: The Natural Gas Processing Facility to: 1. Buy our home and property. We look forward to working with your project to make the area a continued desirable place to live. Sma Iv, p c-.,C__yroeuu Don & Terri Dechant EXHIBIT AA rim; !Pr yeti '3 To: Weld County Planning Services 1555 N. 17th Ave. Greeley, CO. 80631 Attention: Kim Ogle Planner May 15, 2017 Re. Hearing objections regarding DCP Midstream, LP gas plant expansion Case No. 5MJUSR17-83-542 Dear Kim Ogle, The property owners adjacent to and affected by the DCP Midstream, LP gas plant here -in file formal objections to the proposed amendment to the USR-542 for the expansion of the existing gas plant in what is now an agricultural zone. Reference the attached list of property owners who endorse this letter and area part in filing this formal objection to the current gas plant expansion. This objection per the adjacent and otherwise affected property owners will be on record until and if the county as well as DCP Midstream, LP can fully address and mitigate our concerns as listed below. The list of concerns include first and foremost the safety concerns of such a large gas facility operating with virtually no protection for the surrounding property owners should a catastrophic accident take place. How will the county as well the DCP Midstream, LP assure that there is proper "on -site" containment should and accident occur such that no surrounding property owner suffer the risk of losing life, life stock, agriculture and/or personal property. There is currently no plan that we are aware of to protect surrounding property in case of a catastrophic accident. How does the county as well as DCP Midstream plan on addressing additional nuisances such as noise pollution, fumes, odor levels, and dust control (related to increase truck traffic). The current plant appears to already violate as a minimum the county codes regarding noise levels and fugitive dust do to truck traffic on non -paved county roads. The surrounding property owners only see these nuisances to escalate with further expansion of the existing plant. We the property owners would then look to the county to solve our concerns and assure that any gas plant expansion has mitigated these issues prior to allowing the plant to expand. Increased traffic on county roads 33, 35, 38, 40 and 42 are all a big concern. Since the last gas plant expansion the truck traffic has increase 10 fold (we do not have an actual traffic study as we do not feel it is the surrounding property owners responsibility to perform such a study, however, the truck traffic has increased substantially). This increased traffic has caused the surrounding property owners harm in the following ways: The increased traffic on these county roads causes an unsafe condition when weather hits the non -paved county roads. This is due to the semi -trucks causing mass rutting with small amounts of moisture on the roads. More trucks means more rutting which affects safe passage as well as damage to personal vehicles. Further, the additional truck traffic causes more dust and higher risk of personal injury as most of these vehicles exceed the legal speed limits. It is obvious that more traffic due to the expanded gas facility would only further increase these risks. The surrounding property owners would expect the county to attempt to mitigate our concerns about these increased risks prior to any approval of an expansion. It must be further pointed out that during the last approval of the current USR-542, DCP Midstream, LP stated that this would be indeed the last expansion requested for this facility. However, here we are several years later and DCP Midstream is once again asking for additional expansion of their facility with very little regard to the impact to the surrounding community. We are unsure as to when and if they will ever stop requesting further expansions. These expansions affect not only the increased nuisances of noise, dust, odor, and traffic but also continues to erode surrounding property values. Since a good deal of the surrounding property owners have been living in the area for a long period of time in an agricultural environment, the count must EXHIBIT t 5MTUSR 11-89 -5H' realize the huge impact on the way of life from not only the first major expansion but even more so with the next planned expansion. We, the surrounding property owners on and around County Road 33, 35, 38, 40 and 42 near the current DCP Midstream, LP gas plant, respectfully request that you Weld County would disapprove any granting the amendment to the existing USR-542 and/or further expansion as of the existing DCP Midstream, LP gas plant facility until and if DCP Midstream, LP along with the county properly demonstrate that they have mitigated all our concerns stated here -in. Sincerely, Gerald Johnson Acting Alison for the surrounding property owners 16274 County Road 40 LaSalle, CO. 80645 Attachment: Signed petition by surrounding and affected property owners agreeing to the written objection as stated here -in Xc: file, PZ esquire David Hunt From: Sent: To: Subject: David Hunt Friday, May 12, 2017 10:01 AM David Hunt; geraldjohnson7@netzero.net Gas Plant exspansion To whom it may concern, RE: DCP Midstream, LP gas plant expansion, Case No. 5MJUSR17-83-542 As a landowner, farmer, in the general area of the existing DCP plant, I wanted to comment on the proposed expansion. I believe that landowners should be able to do what they want to with the land they own. Having said that, I understand the challenges a larger commercially operated property brings to an area where Ag and residential properties already exist. The increased traffic, operational noise of the gas plant, and safety concerns are real, especially to land owners and residences directly adjacent to the plant. Imagine your response to a facility being built next to where you live that, at any time, can light up the night like the sun is next door to you with an excess gas discharge being burned off, or the constant low rumbling noise, occasional loud noise, being the norm vs. the quiet setting of the Colorado country side you are used to. L' Some people are understanding, calling it progress, putting up with the changes. Some people are rightly upset. The closer to the plant, the more neighbors there are in the latter category. How to balance the needs of a property owner with the needs of neighbors is something that I'm glad is not my responsibility. „Sounds like an almost impossible job the planners and commissioners are asked to do on a regular basis. I would like to offer a couple of solutions that I think would help us all coexist. A 10 foot tall dirt berm surrounding the facility where possible would go a long way in suppressing the constant noise issue and mitigate some safety concerns in the event of a catastrophic accident. I would further suggest that requiring additional road improvements to roads leading to the facility would mitigate some of the traffic concerns. I think these would be reasonable requests of the facility owners as they continue doing business. I appreciate the opportunity to comment, David Hunt 14460 CR 40 Platteville, Co. 80651 1 We the surrounding and affected property owners of the DCP Midstream, LP gas plant expansion associated with the requested Amendment to USR-542 located North and adjacent to CR38; west of and adjacent to CR 35: have read and agree with the letter written by Gerald Johnson dated May 15, 2017 generally stating our objections to the approval of first the Amendment to USR-542 and of the expansion of the existing gas plant expansion until such time that the Weld County as well DCP Midstream have adequately addressed our concerns. t Afar Signature of Propert Owner Property Address Cee>"((; Signature of Property Ow Signature of Property Owner did/ Signature of Property Owner Signature of Pr/pert G y r `� Cry z/ C! L 5/ C.(C, £O, gO6113 r-i _ -3 .c.- Property Address /075,4 je,d9 Property Address /d 756 w eyo IXs Am rem kite, 3s G 4,4[[f,co rag 75.- remL E/d M Eft lc Property Address L7 lrJ'r7✓ • .. ti -COX c�/ /v -V42. -V42. --- Signature of Property wner gCrUalin Signature of�,foperty Owner t‘\- We•:\4t w.Alk\--Le\14,1\-\\QA Signature of Property Owner e ( cd\s, Signature of Property Owner n Signature of Property Owner 1 ee3(,C ,coo qs /n a it/e 33 -LA cillej(le - Property Address i6a Vy (A)ca 2/0 /ASAI/ECo 30vr Property Address /C392 2 &' 2 33 2 ri S a III <p Property Address Ct �Lt 33 LqSa Property Address gob LIS c (0 g(JLLIS «c PWtteuatfe sdto l Property Address rflog° cvc,a3.; LAsAiiz co 5a6yJ Property Address 9 7G ,moo_ a *zS EXHIBIT c 4 A Property Address We the surrounding and affected property owners of the DCP Midstream, LP gas plant expansion associated with the requested Amendment to USR-542 located North and adjacent to CR38; west of and adjacent to CR 35: have read and agree with the letter written by Gerald Johnson dated May 15, 2017 generally stating our objections to the approval of first the Amendment to USR-542 and of the expansion of the existing gas plant expansion until such time that the Weld County as well DCP Midstream have adequately addressed our concerns. and, el eartind /45-020 td04 t34 ALO esSafte (7c10,61:5 Signature oYPr roperty OwneProperty Address )306 Ck Le() Signature of Property Owner ViM{4 t� p Y Property Address 6� leL 9064/C Signature of Property Owner Signature of Property Owner Signature of Property 0 ner C Property Address nr n ture` Sign Property Owner ner ii9vhs (yLvaicfrA...)- Signature of Property Owner 4/ 1565 coy-- W4 Property Address 194\ CAA) Property Address Afil4), gays LaSeM cooq5' (An W (.p 33 t4leik, Property Address Zca3a G,✓C t ? 3 11 f zf- Signature of Property Owner Signature of Pr Property Address icV-0 117" id(e_53 Ic?//5 per Owner Property Address (305 -"Sr 6 e&? 44,4SA(le_ Signature of Pro• -rt Owner A - Property Address /5 ) 2-3r PL-4-77-0-iatce- r� � eeZ✓' ittrnak\ 1 jc(125- (2._ 31( PA 4/1/4 Sig(ature of Prope wne Signs of Property Owner JA -2.1 Signature of Prope 11935 Cn 33 chLSedLe Co w695 Property Address 16oX7 Cie Yp LOSQI4 CO ?QC wner = L �zrt,x� Signature of Property ner 6-er Property Address e of Property Owner Property Address 1�0�7 wCQ 114° &<J/e,COBo‘sS6ej Property Address /6o/7c2 qU (4Sc I/c: Property Address / AtajA(;/ 1 z? )9-z_ (2_ (-4> LaSedke V.°% Signature of Property Owner g ature r.r•rop- -r Owner ill 74 ig :tur pert frOytiner f Signature of Property Owne Ar. Signature of Property Owner Signature of Property Owner Property Address c ‘4, Property Address 769Cr iiAz 33hIA// (a efdt7 Property Address ,stiyyt)\ SANAOCts /63 C if 3y fear/La.& crei65 i Property Address ze,60e Property Address /ffiti YL— &Site Property Address 1566`? R 3g Pasbc?S 4-00 ock ,St?) z i2 3?),(A--N cr) /k_ cvaV Signature of Property Owner Property Address krt c" -y_-: 33 p ick-H-1)Q, Signature of Property Owner Property Address Occi egg 14/41 /Et (nEalic Signature of Property wner Property Address Signure of Propert Owner Signature of Propel ,iwner Signature of Property Owner 610/1/49-e•a:Nre\e afeneCtst.N.4___. Signature of Property Owner ( toy, fiLk Signature of Property Owner Property Address /c9)4 efr Sj' j? Property Address 20 to L13 cast gow-1 )1 c) ciz. 4-0 Q a &065 Property Address (?Lk\ou'UQ) gt'(62s1 Property Address L'.1? tit F ` Atka uit& 6-si Property Address Signature of Property Owner Property Address Signature of Property Owner Property Address Signature of Property Owner Property Address Colorado Revised Statutes 2016 TITLE 34 MINERAL RESOURCES GEOLOGICAL SURVEY ARTICLE 1 Geological Survey PART 1 COLORADO GEOLOGICAL SURVEY 34-1-100.5 to 34-1-106. (Repealed) PART 2 GEOLOGY 34-1-201 to 34-1-202. (Repealed) PART 3 PRESERVATION OF COMMERCIAL MINERAL DEPOSITS 34-1-301. Legislative declaration. (1) The general assembly hereby declares that: (a) The state's commercial mineral deposits are essential to the state's economy; (b) The populous counties of the state face a critical shortage of such deposits; (c) Such deposits should be extracted according to a rational plan, calculated to avoid waste of such deposits and cause the least practicable disruption of the ecology and quality of life of the citizens of the populous counties of the state. (2) The general assembly further declares that, for the reasons stated in subsection (1) of this Colorado Revised Statutes 2016 1 Uncertified Printout section, the regulation of commercial mineral deposits, the preservation of access to and extraction of such deposits, and the development of a rational plan for extraction of such deposits are matters of concern in the populous counties of the state. It is the intention of the general assembly that the provisions of this part 3 have full force and effect throughout such populous counties, including, but not limited to, the city and county of Denver and any other home rule city or town within each such populous county but shall have no application outside such populous counties. 34-1-302. Definitions. As used in this part 3, unless the context otherwise requires: (1) "Commercial mineral deposit" means a natural mineral deposit of limestone used for construction purposes, coal, sand, gravel, and quarry aggregate, for which extraction by an extractor is or will be commercially feasible and regarding which it can be demonstrated by geologic, mineralogic, or other scientific data that such deposit has significant economic or strategic value to the area, state, or nation. (2) "Extractor" means any individual, partnership, association, or corporation which extracts commercial mineral deposits for use in the business of selling such deposits or for use in another business owned by the extractor or any department or division of federal, state, county, or municipal government which extracts such deposits. (3) "Populous county or populous counties of the state" means any county or city and county having a population of sixty-five thousand inhabitants or more according to the latest federal decennial census. 34-1-303. Geological survey to make study. After July 1, 1973, the Colorado geological survey shall contract for a study of the commercial mineral deposits in the populous counties of the state in order to identify and locate such deposits. Such study shall be of sand, gravel, and quarry aggregate, and shall be completed on or before July 1, 1974, and shall include a map or maps of the state showing such commercial mineral deposits, copies of which may be generally circulated. Any commercial mineral deposits discovered subsequent to July 1, 1974, may be, upon discovery, included in such study. 34-1-304. Master plan for extraction. (1) The county planning commission for unincorporated areas and for cities and towns having no planning commission or the planning commission for each city and county, city, or town, within each populous county of the state, shall, with the aid of the maps from the study conducted pursuant to section 34-1-303, conduct a study of the commercial mineral deposits located within its jurisdiction and develop a master plan for the extraction of such deposits, which plan shall consist of text and maps. In developing the master plan, the planning commission shall consider, among others, the following factors: (a) Any system adopted by the Colorado geological survey grading commercial mineral deposits according to such factors as magnitude of the deposit and time of availability for and feasibility of extraction of a deposit; (b) The potential for effective multiple sequential use which would result in the optimum Colorado Revised Statutes 2016 2 Uncertified Printout Detailed Facility Report I ECHO I US EPA Page 1 of 7 EC 11 Enforcement and Compliance History Online Detailed Facility Report Facility Summary MEWBOE'RN GAS PLANT 18455 WELD COUNTY RD 35, GILCREST, CO 80623 0 FRS (Facility Registry Service) ID: 110010691750 EPA Region: 08 Latitude: 40.266583 Longitude: -104.734944 Locational Data Source: RMP Industry: Oil and Gas Extraction: Pipeline Transportation Indian Country: N Enforcement and Compliance Summary A Statute CAA OVA RCRA Imp (5 Nicoll -an Venn] hr-pedlitm 09232016 Compliance Statue Significant Violation No \'IolaHm No Violation CAA CWA RCRA 12 -Quarter Violation History Under Development 8 9 10 1 2 3 4 5 6 7 Quarters Qtr. m NC (Non- Qtn in Significant Compharw-e) t0(12) Violation 12 12 0 0 11 in No Violation ■ Noncompliance • Significant Violation Unknown Intt•nnal FsJc'acam,d Actions Formal Enforcement Actions 5 revs) (5 yc.n)_ 4 4 Penalties from Formal Fnforve to n A¢una (. Yc). Slr.300 11 EPA Cases (5 Petunia from EPA Cues ycan] t5)v-an) Related Reports • Air Pollutant Report • CWA Pollutant Loadine Report © CWA Effluent Charts Regulatory Information Clean Air Act (CAA): Operating Major (0O0000000812300090) Clean Water Act (CWA): Minor. Permit Effective (COR900 328) Other Regulatory Reports Air Emissions Inventory (EIS): No Information Greenhouse Gas Emissions (eGGRT): 1006131 Toxic Releases (TRI): No Information https://echo.epa.gov/detailed-facility-report?fid=CO0000000812300090 5/16/2017 Detailed Facility Report I ECHO I US EPA Page 2 of 7 Resource Conservation and Recovery Act (RCRA): Inactive ( ) Other (COD149181646) Safe Drinking Water Act (SDWA): No Information Facility/System Characteristics Facility/System Characteristics System Statute Idcnnfie 1'00 me Stwut yrcas FRS 111..0.:.1 -iii RMP CAA 100000076552 ACTIVE WIG CAA lisped 11 Direct Emitter Subject General Stationary Fuel Combustion. Petrokwn and Natural Om Systems AIR CAA C00000000S123WD90 Major Emissions °pasting CAAMACT. CAANSPS. CAAPSD. CAASIP. CAATVP ICP CWA 3 i ip.mol2x Minor. General Penult Covered Faabty Effective Soon Water Industrial RCR RCRA C'OD149181646 GWet Inactive l l - Item* Esplilion Dose Indian Country Latitude Longitude 06/02017 N 40.2665%3 -104.714944 N N 40.266513 -101734944 N N 40.267222 -Iw 714441 N Facility Address Sy•dem Statute ldentifct 1 RS CMG AIR ICP RCR G5A CAA CAA CWA RCRA Facility Name _ _ _ Facility Mn 11 0(1 106917CO MEWIIDLIRN OAS PLANT 100000076552 MEWBOURN OAS PLANT 1006131 %LEV/BOURN OAS PLANT CO0000000&I2100090 DCP MIDSTREAM. U'- MEWBOURN C09900328 MEWBOURN GAS PLANT COD149181646 ASSOCIATED NAT OAS (KP.RSE.Y PLANT) 18455 WELD COUNTY RD 35, OILCREST, CO 80623 18295 COUNTY ROAD 35, PIATTEVI LE CO 80651 18455 WELD COUNTY RD 35, GILCRF_ST, CO 8(623 NESE SEC 35 T4N R66W, 011CRFST 23 MI SE OF, CO 80645 18455 CR 35, OILCREST, CO 10623 18455 WCR 35, OILCREST, CO 80623 Facility SIC (Standard Industrial Classification) Codes Facility NAICS (North American Industry Classification System) Codes Syatesa AIR SIC Code SIC [)cso C00000000EI 2100090 1CP C0R90032R 4921 Natural Gas Transmatsnm 1321 Natural Gas Liquids Facility Tribe Information �Rrerwion Name Tribe Namc EPA Tribal II) noun., i,. Tube (milesI No data records returned Enforcement and Compliance Identifier NAICS Code NAICS Daaiption RS1P 100000076552 211112 Natural Gas Liquid Extraction (,116 1006131 211112 Natural Gas Liquid Extraction AIR CO0000000812300090 4K621ti Pipe lane Trwupottation of Nostril Gar https://echo.epa.gov/detailed-facility-report?fid=CO0000000812300090 5/16/2017 Detailed Facility Report I ECHO I US EPA Page 3 of 7 Compliance Monitoring History (5 years) Statute Source ID i sedan Inspc.tton Tspe I cad \geneet Date I _ F i CAA C0000000912300090 AIR 7'1'ACC Raa:ptRnte. Garr 0220201' Frwiteg: No Farbmkrpan Deviations CAA C00000000812300090 AIR 7Y ACT RecapvRencw Slate 01/30'201' CAA CO0000000It12100090 AIR FCE Ot•Sits State 09[23/2016 CM COOOOOO08/2300090 AIR Stack Tat Stare 0541:2016 Findget Pass Pollutants: VOL1TTLE ORGANIC COAIPOUSDS (TVCS CAA C0000000(MI2300090 AIR Stack Ten State 05/092016 Findrgr Pass Pollutants: Carbon maaaude.NITROGEN DUDE CNO2 I Y)L1771E ORGANIC C'OIIPOUNDS (VOC:O CAA C0000070081210t00➢0 AIR T3' ACC RecaptReceew Slate 02/01/2016 '.'AA 0000000008/2300090 AIR Tl'AC1C Recap1Rene. Slate 01/31/2016 Frwbag: No Facility Report Drmrnau t'AA C00000000812300090 AIR Stack Test Slate 10'13'2013 Pimnngs: Pan Pollutants: wrRocoe DAVITS NO2 CAA CO0000000812200090 AIR FCE On -Site State 0743/2015 CM C00000000812300090 AIR Stack Test State 06.252013 Finding:. Pat PdMsres: IOLITTLE ORGANIC COMPOUNDS (TTX3% CAA 000000000612100090 AIR Stack Tern Stare 06252015 Pindrngs: PasPoCWwtr Conlon monoode CM ['000000008/23000947 AIR Stack Ten State 06252015 Flnebry Peas Pdlsormtr NITROGEN OXIDES NO2 CM C000070001f12300090 AIR PCE On toe bPA 06'/70015 CM CO0000000812300350 .4/k TV ACC Recap$Renew State 02/02120/5 CM C00000000312300090 AIR TT'ACC RemupeReaew State 02/0112015 Plowboy: No Findlay Repa.t Iscoarmn CAA 000000000812300090 AIR FCE On -Site Slate 09/24/2014 CM COQ000000912300OS`0 AIR TI 'ACC Rece,1 Rnser &ate 01'302011 CAA C00000000612300090 AIR Stack Ten Saute 10'21/2013 Anesgr Pau Pdseamut NITROGEN OA7DESNO2 CAA C000tCd.004123000SO AIR T7' ACC Receipt/Renew State 02/252013 Priam: No FacdeyRgwat Denson+ CM C0000000O672300090 AIR TI' ACC kecapoRnre. Slate 02'O1'201) CM C00000000612300000 ./k Stack Ten Gar 112//2012 Frwksgr Pau Pollstsm: NITROGEN 0A7DESNO2 CM 000600000812300090 .4/k Stack Test State 110112012 Flndirgr• Pan Palkoann: VOLATILE ORGANIC COMPOLN'!1S (I'OCSI CM CO0002000612300790 AIR Stack Test State 11/21/2012 Findley Pace Pa /debts: Cask*, monoxide CM C00000000g12300090 AIR Stack Test Gar 11/152012 Enirgr Pea Pollutants: I17L4T7LE ORGANIC COMPOUNDS (TVC& CM C00000000e12300090 AIR Stack Ten Sate 111512012 Flinches: Pau Pasant NITROGEN OAEDESNO2 CM C00000000012300090 AIR Stack Ten State /1•/52012 Finding:. Pau Pollnow: Carbon monoxide CAA CO0260000812300090 AIR Stock Test Gate 111112012 Findings. Pan Pollutant; NITROGEN DUDES NO2 CAA C00000000612300090 AIR Stack Test Sam 11/11/2012 Findings Pas Polliwogs. Carbon monattdc CAA 000000000512300090 AIR Stack Test State 11/11/2012 Andsgc Pau Pollutant: I PLITILE ORGANIC COAIPOLNDS fl'OC3S C'44 000000000 /2300090 AMR Stuck Test Gate 1I/1312012 Fadsge: Pm PPOasaes: VOLATILE ORGANIC CLRIPOUNDS(3t7CSl C'44 000000090512100090 A!R Stack Ten Gate 11'13/2012 Flr+dngr Pose Palbttav: Carbon monoxide CM [000000008/2300090 AIR Stack Test State 11'152012 Fledsga• PetPoldeawe. NIT O FN °A7DESNO2 CAA C000000008123o0090 AIR Slack Test .tare 1112'2012 "sow Pao Pollutant NITROGEN OXIDES NO2 ('M COOO00000F72300S1 AM Stack Test Gate 11'12'1012 Flealigr Pau PaLaanr I t)L1 TILE ORGANIC COMPOUNDS(222CM CM CO0700000R12300090 AIR Stack Tan Gam 111220/2 msrgr Pan Palfats. Carbon monoxide C000(0000812300090 0 011 230 0090 AIR Stack Ten State 11/08.'2012 Ftndsgr Pau Pdseant: NITROGEN OATDESNO2 CM C000000008123000A0 AIR Stack Ten Sane 11/0&2012 Ftndreer Pau Peasant Carbon monamde i.4A C000000008/23000S0 AIR Stack Ten Stair 11/0812012 blisdbur Pau Pa/lataat: 117L177LE ORGANIC COMPOUNDS (T'OCS) CAA 000000000812300090 AIR Stack Test Gate 11'0712012 FLdtgr Fad PdMaet: NITROGEN OXIDES NO2 CM 000000000812300090 AIR Stack Ten State 11'07.2012 FtndsgrPau Pollutants: IOJLATIIEORGANIC COMPOUNDS (OCSI CAA CCNl000C00612300090 AIR Stack Ten Gate 11072012 Flntkrgr Pau Paws*: Carbon montwde CM 00000000008/23000% AIR Stack Test Gate 1/'062012 Fint tgr Pear, Polhennts: NITROGEN OA7DES NO2 CM [000000008/2300)90 AIR Stack Test Gate 11/062012 Frmkrgr Pau Pollrawu: Nlrxu,EV Ol7DESNO2 CAA 000000000812300090 AIR Stock Tess Gate 11/062012 Flm6sgr rowdy Pass: Carbon monoxide https://echo.epa.gov/detailed-facility-report?fid=CO0000000812300090 5/16/2017 Detailed Facility Report I ECHO I US EPA Page 4 of 7 stmne Sono ID Syamm Inspection Type Lad Alien" Dale j — PadnI CAA C00000000812300090 AIR Stack Test State 111062012 Fusty: Pau PoDeam : Carbon monoxide ('44 C00060000812300090 0 0 0 0 0 912300 09 0 AIR Stock Ten Sate 11106'2012 Ftndsgv Pan Poasans: POL47TLE ORGANIC CQtiPOtWDS (4 VCS CAA C00000000012300090 AIR Stack Test Sate 11106'2012 Finny: Penang PaAon:: I VIATILE ORGANIC COMPOfNDSIVOCS1 CAA C00000030812300090 AIR Stack Test State 1110212012 P)naty Pam Pa$aantt: Carbon monavde CAA C00000000312100090 AIR Stack Test Sam 11102/2012 Andngs. Pauly Painu: Hexane CM 000000000812300090 AIR Stack Tea Sam 111002012 flndty: Pass Pollutant. Sulfur dtavde CM C000000G+G812300090 AIR Stack Ten Sate 11/02'2012 &natgr Penang PoAeans: Bet[ene CM C0(M000YXM12300090 AIR Stack Ten State 11102/2012 Finanar hash: Pallsaants: VOLATILE ORGANIC COMPOUNDS (Well CM CO0000000812300090 AIR Stack Test State 11/0212012 Fledter PazPa/Mnts: ll)drgeo sulfide CM C00000000812300090 AIR Sack Test State 11/02/2012 F)nces.• Pm Pennons: NITROGEN OA/DESNO2 CM C0000000G812100090 AIR Stack Teat Sate 11/02/2012 F)nasgr PaSsgPolbtasts: Eskyibenzene CM 0000000008/2300090 AIR Suck Test Dote 11102'2012 Fmdiqx Paeans Pannone:: Xylem COOOOOCG08I2300090 AIR Stack Test Sam 11/02/2012 Ftndngr AmongPolkante Tobin CAA CO0000000812300090 AIR FCE 4rSile Stale 0&'242012 Entries in italics are not considered inspections in official counts. Compliance Summary Data Statute Source ID CAA CWA RCRA 000000000812300090 COR900328 COD149111646 Current SM i S.Snufrant Non-complianceyIIPV Wish Priority Vidalia) Dkscription Omen As Of I Yes Addle -State No No 03+13Z017 12131.4016 0$13/0I7 gellto $c24aaConi.lune•)(901 13 0 Three Year Compliance Status by Quarter Statute _ Program Pollutant Violation Type CAA (Sara Ilk 0'000000009123110090) vmmeoe T, pc Fud lly-I.eM Scans HPV HMary ASa7 trepans CAAMACT, CAANSPS, t t nr-. CO CAAPSD, CAASIP, CAATVP CAAMACT. CAANSPS. t I'\ CO CAAPSD, CAASIP. CAATVP CAAMACT, CAANSPS. C','.\ UPI/ CO CAAPSD. CAASIP, CAATVP CAANSPS, HPV CO CAASIP, CAATVP CAAMACT, CAANSPS. CAA IItCO CAAPSD. CAASIP, CAATVP llttoric Violation. LIACT (SECTION 63 NESIIAPS) NSPS VOLATILE ORGANIC COMPOUNDS ( VOCS) NITROGEN OXIDES NO2 VOLATILE ORGANIC COMPOUNDS (VOCS) NRROOE♦ OXIDES NO2 VOLATILE ORGANIC COMPOUNDS (VOCS) , QTR I Q7R 2 --� M 3 QM 4 QTR s QTR 6 QTR 7 0TR ft QTR 9 RIR 10 QTR I t 4 QTR 12 07,01-09/30/14 10/01-12/31114 0101- 0401- 07ro1, 10 01- 0101. 0401- 07/01- 10/01. 1)L01. 04/01. o3131/Is 061!015 0913015 12.11;11 01 31 16 0610'16 09130)6 123146 0301.17 ' 0690'I7 HPY IIPV• HPV HPV HPV tin tin Hh' HPV IIPV HPV HPN Unsdk. Rant. Vasa- Undo. Addis- Adds- Addis Addis- Adds- Atha. Adis- Mdn- Si to Sere Stem Stun Sae Stele Site State Slaw Stow Side Sumo 11.0512011 ?» 02,01/1013 10014012 0917/2000 11105'2011 V-HPV V-HPV Vio Vio V-HPV V.til'V Vie Vio https://echo.epa.gov/detailed-facility-report?fid=OO00000008123 00090 5/16/2017 Detailed Facility Report I ECHO I US EPA Page 5 of 7 • Statute CAA CAA CAA ProgremPullutant Violation Type PSI) SIP TI71.E V PERMITS QTR 1 QTR 2 QTR 3 V-IIPV V-HPV Vio Vio V-HPV V-HPV Vio Vio V-HPV Vin Vio QTR 5 QTR 6 QTR 7 QTR 8 QTR 9 QTR 10 VTR I 1 VTR 12 Statute Program Pollutant:Violation iolation Type CWA (N A (Soaect ID: COR90032R) Fadllty-Level Statue SN((Significant NeercompllaoceYRN(' (Reportable Ne- ('omp0aace) IItstoat Permit Schedule Violations Schedule Even acheved late but reported: Perform Compliance Pedotmance Evaluation CWA Schedule Eisen reported late Perform Compliance Performance Evalutioo CWA CWA QTR I + Q7R 2 QTR 3 QTR 4 0101- 04001- 07/01. 10 01- 0111(14 0690/14 0910/14 1211 14 N• N. No No Vial VW Vial Viol QTR 5 01 01-03 31 I5 hi Vial V (NooRNCV) 03.31.15 03.31-15 QTR 6 QTR 7 QTR S QTR 9 QTR 10 QTR II QTR 12 04/01• 07/01- 1001• 0101- 04/0)- 0701- 10 01- 0670.'15 09/3015 121115 033116 06/30/16 J 09/30/16 1231 l6 No No No No No No No Viol Vial YW Vial Vial Vld Viol 05-29- 15 05.29- 15 Schedule Evers unachieved and not reported: Perform 03-31.13 03.29• Compliance PMorn aawc EvaluationIS Sluttish Evens =stun ed but repeated: Perform Compliance Perfonunce Evdemon 03.31.15 05.29 - IS QTR 13- 01 01-05 12 17 I 'rd Suring Program Paltutant Violation hp: < QTR 1 QTR 2 QTR 3 QTR 4 QTR 5 j QTR 6 Q7R 7 QTR $ QTR 9 QTR 10 1 Q711 11 QTR 12 RCRA (Sena m: ('OD1491106461 0701.0230'14 1001.1231 14 0101-03/31/13 0401.06/30/13 t 07A1.09r3d13 _ IONI.1291(15 01/01-03/31(16 0401.0690'16 0701.0930'16 10/01-IV3I/16 01/01.03/31/7 0401.06'30.'17 RCRA Facing .Level States --- Informal Enforcement Actions (5 Years) CAA CAA CAA CAA Svvtem AIR AIR AIR AIR Sore ID Action CU1f0000008123000'x0 CO9000000612100090 C00000000112300090 C(70000000112300090 Now. or Violation Notice of Violation Notice of Violation Notes of Violation Lad Agcnn Stilt Stave S'tac Stale Dow 61/191015 0671/1013 06211013 051212012 Formal Enforcement Actions (5 Years) Statute CAA CAA CAA C:\.\ Source ID C00000000812300090 000000000011300090 C00000000812300090 C00000000812300090 fl.oi Action A6airgralira Order Administrative Ord/ Admiaiaaaive order Adrnian mve Onb tit Stns Sire Stine Sale bate 0611/2016 0427/2015 (427/2015 04/27/2015 Penal() 556.700 5130.800 50 so Penalty Description ICIS (Integrated Compliance Information System) Case History (5 years) I"imary Law/SMion Taw No. t Cut Type Lead Agency I Case Nye ImadYilad Date _Seidman Data I Federal Talky hrraA,otal Peaky i SEP ISupplanemal Enunmmemd Propel! Cost Comp Action Cost No data note taunted Environmental Conditions Water Quality https://echo.epa.gov/detailed-facility-report?fid=0O0000000812300090 5/16/2017 Detailed Facility Report I ECHO I US EPA Page 6 of 7 Perms II) COR90031S Combined Sewa System' Number of CSC (Combined Sewn O inflow) Outfalb 12 -Digit Wen (Watershed Bounden Datasal) BCC (RAD (Reach Address Database)) WBD(Watadhed Boundary. Daises) Subwateralted Name (RAD (Reads Address Database)) 101900030606 City of Evens -South Platte Rim State Wnerhody Name (1C1S ttnegrted Compliance Information System)) Plane Valley Canal - Milton Reservoir Impaired Warm Impaired Class Causes of lmpanncn(s) by Group(s) Watershed with ESA (E dagend Species AdI-listed Aquatic Species? No Yea Waterbody Designated Uses I Reach Code 10190003000560 Air Quality _ Watsmbody Name I Exespbiottat the I Knauss d Use I Aquatic Life Use No No No Now :\tlamncnt ShaBfuh Use Beach Closure Within Last Yea No No 14cm'h Closure )Rehm I sit Tun Veen No Pollwanl f I (hove I.eat Particulate Marta Sulfur thoudr Pollutants Toxics Release Inventory History of Reported Chemicals Released in Pounds per Year at Site 0 TRI Fa.dity ID 1 cat Total Aar Emmons Surface Water Dis:turgcs Air Pollutant Report rut -Sac Transl en I„ I bsud realness Worts) l.lndergroutd bycaoma Releaaa to Land Total Oo-aite Italian Tetai OWf sileieLeaw 1 No data scot* rat fined Toxics Release Inventory Total Releases and Transfers in Pounds by Chemical and Year ('lemma) Name No data retMd, reltlmcd Demographic Profile Demographic Profile of Surrounding Area (3 Miles) This section provides demographic information regarding the community surrounding the facility. ECHO compliance data alone are not sufficient to determine whether violations at a particular facility had negative impacts on public health or the environment. Statistics are based upon the 2010 US Census and American Community Survey data, and are accurate to the extent that the facility latitude and longitude listed below are correct. The latitude and longitude are obtained from the EPA Locational Reference Table (LRT) when available. Radios of Ara: Cants Lade: Center longitude: Total Persons: 3 40.266510 -104.734944 1,587 Land Arm. Water Are.: Population Density. Percent Minority: tot'.. 0•. 56 fq mt .`lot• Hou,chokh m Area (lousing !'ruts in Area: Households on Public Assistance. Pesos Below Poverty Level. 531 573 7 537 Raw enslaves Persons I•.1 Agc Breakdown Penaee ("9 https://echo.epa.gov/detailed-facility-report?fid=CO0000000812300090 5/16/2017 Detailed Facility Report I ECHO I US EPA Page 7 of 7 • • Race Haeakdona N7ute . Vn.:an•:4nrn: an Hnpanrc•Ongm Arran Ps.aft. Islander knwncan Indian (*Iles Multuaaak Paanru (•.) 1.278 (81%) 1011.1 756 (48%) 7(0%) 13(1.) 279 (18`.1 Age Breakdown Child S wan and younger: Panora I'. Marton 17 yeas and younger Adults 18 )corn and older Season 65 years and older 96(6%) 447 (28 e) 1.140 (72%) 164(10'.) Eduction Level (Paws. 25 A older) lass than 9th Grade: 9th through 12th Grade: Hills School Diploma: Some College 2•yr B S.:13.A or More: Penum__ fJ Income Brakdow'a Harahalds (%) 120(11.42%) 138 (13.13%) 323(30.73%) 336 (3I.97a%) 134(1175%) I.as then 515.000: 515.000.525.000. 525.000.550.000: 550.000.572000: arega the 575.000: 4046.99%) 70 (1224%) 193 (33.74%) 113 (19.76%) 156 (27.27%) https://echo.epa.gov/detailed-facility-report?fid=0O0000000812300090 5/16/2017 Clean air group gives Weld County an F for ozone, says Denver, Fort Collins amo... Page 1 of 2 Clean air group gives Weld County an F for ozone, says Denver, Fort Collins among most polluted cities in country Staff and wire reports April 19, 2017 DENVER — Ozone pollution has improved in Denver and Fort Collins. but both cities remain among the 15 worst in the nation. the American Lung Association said. Denver had the 11th -worst ozone levels and Fort Collins had the 15th -worst, the association said in its 2017 clean air report released Tuesday. The report, which ranked the 25 most polluted and 25 least polluted cities in the country. did not mention Greeley. The report gave Weld County an F for the number of high ozone days. making Weld one of 10 Colorado counties on the Front Range or in nearby foothills to earn a D or an F. Denver and the northern Front Range have long struggled to meet federal ozone standards. Ozone can be harmful to people with respiratory problems and other vulnerable groups, including children and the elderly. People who are active outdoors can also suffer. The American Lung Association said Colorado's ozone problem has multiple causes. including vehicle exhaust. the oil and gas industry, trees, coal -burning power plants and weather conditions. Some of Colorado's ozone drifts in from out of state. Nationwide. ozone levels and year-round particle pollution have declined since the association's 2016 report, but short-term spikes in particulate pollution increased. Denver's short-term particulate pollution also worsened. the report said. The report also gave Weld a passing grade for high particle pollution days. Colorado officials were reviewing the report and questioned some of the methodology, said Jeremy Neustifter, a spokesman for the Department of Public Health and Environment. http://www.greeleytribune.com/news/local/clean-air-group-gives-weld-county-an-f... 5/16/2017 Clean air group gives Weld County an F for ozone, says Denver, Fort Collins amo... Page 2 of 2 The report gave some counties a failing grade even if they met federal standards, Neustifter said. And the report assumes everyone in a county is exposed to the highest level of ozone recorded, even if most residents don't travel to the site where the worst concentrations were found, he said. The report used data from 2013-15 gathered from federal, tribal, state and county agencies. The association said it was the most recent verified data available. Residents of most U.S. cities can breathe easier than people in some other parts of the world. Last August. Mexico City issued an alert after ozone levels hit more than 150 percent of acceptable levels. In December, Beijing issued a warning when particulate pollution reached more than 15 times the safe level. Last year, Denver was eighth and Fort Collins 10th. Dawn Mullally. director of air quality and transportation for the American Lung Association in Colorado, said Denver has made great strides over several decades. "We've come a long way since the smoggy days of the 1970s," she said. Mullally said regulations under the federal Clean Air Act shouldn't be relaxed. "This is the air we breathe. We must protect it," she said. http://www.greeleytribune.com/news/local/clean-air-group-gives-weld-county-an-f... 5/16/2017 EARTHWORKS I Gas Processing Page 1 of 8 • HomeX • Take Action • Donate Share• Stay Connected • About Us • Issues • Change Corporations • Reform Governments • Serve Communities • Protect the Environment • Take Action • Donate • About Us • Issues • Library • Media • EARTHblog • Voices • Tags Search All Sites Stay Connected email Search Sign Up • Other EARTHWORKS Sites • No Dirty Gold • Recycle My Cell Phone • Oil and Gas Accountability Project • Our Bristol Bay • Stop the Frack Attack https://www.earthworksaction.org/issues/detail/gas_processing 5/16/2017 EARTHWORKS I Gas Processing Page 2 of 8 Gas Processing Bluestone Gas Processing complex, Evans City, PA. Photo: Robert Dorman When first extracted, natural gas is a blend of methane; water; natural gas liquids (NGLs) such as ethane, butane, and propane; and condensate, a light hydrocarbon. Gas processing is the bridge between the extraction of gas and its delivery as a finished product typically composed mostly of methane for use in homes, businesses, and utilities. Gas processing has two steps: 1. Separation of the components of the raw extracted material 2. Creation of new products The steps and technologies used at processing plants depend on the composition of gas, which varies across formations and regions. For example: • "Sour" gas contains the toxic gas hydrogen sulfide, and is extracted from some western and southern states • "Wet" gas has a high NGL content and is found in some parts of the Marcellus and Utica Shale • "Dry" gas has a high proportion of methane As of 2014, there were about 550 natural gas processing plants nationwide. The number has risen in recent years alongside shale gas production, which has yielded more liquids -rich gas. https://www.earthworksaction.org/issues/detail/gasprocessing 5/16/2017 EARTHWORKS I Gas Processing Page 3 of 8 Operators have sought additional processing capacity to satisfy the growing market for NGLs to feed the petrochemical and plastics industries. Air pollution Air pollution is the biggest impact of gas processing. Processors pollute the air when operating because they — • Rely on combustion to operate • Use flares to burn off gases • Often simply vent gas Share• Have a wide range of equipment that can and does leak Air sampling near large gas processing plants in Pennsylvania indicates that such facilities can release a wide variety of chemicals. They are known to release several climate and health - harming pollutants, including: • carbon monoxide (CO) • nitrogen oxides (NOx) • fine and coarse particulate matter (PM2.5 and PM 10) • sulfur dioxides (SOx) • volatile organic compounds (VOCs) • hazardous air pollutants (HAPs) (e.g., formaldehyde, benzene, toluene, and xylene) • greenhouse gases (methane, carbon dioxide, and nitrous oxide) https://www.earthworksaction.org/issues/detail/gas_processing 5/16/2017 EARTHWORKS I Gas Processing Page 4 of 8 Bluestone Processing Plant, Butler County, PA (Sept 2016) ce hare Safety and health Safety and health are key concerns for workers at, and residents near, gas processing plants. Gas and gas liquids can be toxic to breathe, and because they are highly volatile, plants can catch fire or explode. Processing and storing gas that contains hydrogen sulfide is also very risky, since it is a toxic gas with significant health impacts. A recent study concluded that gas development facilities can be noisy enough to pose health risks such as stress, sleep deprivation, and elevated blood pressure. Earthworks measured noise near a large gas processing facility in Pennsylvania, finding that levels were often in the upper 50-70 decibel (dBA) range, which exceeds state and federal standards. Regulation Under the federal Clean Air Act, state regulators review permits and plans for processing plants and determine whether, based on projected pollution levels, they require only a state air permit (for "minor" sources) or also a federal one (for "major" sources). State regulatory agencies provide notice when federal air permits for major sources (known as Title V) are open for public comment. https://www.earthworksaction.org/issues/detail/gasjrocessing 5/16/2017 EARTHWORKS I Gas Processing Page 5 of 8 In 2016, the US Environmental Protection Agency (EPA) issued a new rule to reduce pollution of methane and volatile organic compounds from oil and gas operations, including at gas processing plants. As a result of a legal petition from 19 environmental organizations, EPA proposed a new rule in early 2017 to require gas processing plant operators to report their air pollution to the federal Toxics Release Inventory (TRI). This action was based on the health risks of regulated chemicals and hazardous air pollutants like benzene, formaldehyde, and xylene, that processing plants emit. Currently, the only processing facilities that are subject to TRI reporting requirements are those that remove sulfur from sour gas. Share For more information: • Environmental Integrity Project report on pollution from the expanding natural gas products industry. • US EPA proposed rule to require gas processing plant operators to report toxic chemical pollution. • Energy Information Administration detailed paper on the stages of gas processing. • Pipeline and Hazardous Materials Safety Administration overview of gas processing. • Occupational Safety and Health Administration Hazard Alert for workers at oil and gas production and processing sites. Have information to add? Send us an email at info [at] earthworksaction.org. Tagged with: infrastructure, g 2Share Infrastructure I lub r • >> Pipelines • >> Pipeline Stations https://www.earthworksaction.org/issues/detail/gas _ processing 5/16/2017 EARTHWORKS I Gas Processing Page 6 of 8 • >> Gas Processing • >> Gas Storage • >> Waste Management • >> Community Search Issues rare Follow Earthworks Search • Follow EARTHWORKS on Facebook • Follow EARTHWORKS on Youtube • Follow EARTHWORKS on Twitter • Follow EARTHWORKS on Filch • Follow EARTHWORKS by email • Earthworks RSS Recent News May 10 I Earthworks Senate votes to keep BLM methane rule intact to protect taxpayers and public health May 3 ( Earthworks I SumOfUs Peruvian Supreme Court Acquits Maxima Acuna de Chaupe May 2 I Earthworks Earthworks expands state -based effort to cut oil & gas pollution that harms health and climate From EARTHb1og May 15 I Bonnie Gestring Trump's EPA ignores science, paves the way for Pebble mine May 4 I Nadia Steinzor Court approves seismic testing in Florida panther habitat Apr 24 I Nadia Steinzor Premature pipeline partying https://www.earthworksaction.org/issues/detail/gas _ processing 5/16/2017 EARTHWORKS I Gas Processing Page 7 of 8 On Twitter I just published "Trump's EPA ignores science, paves the way for Pebble mine" medium.com/@Earthworks/tr... @Medium pic.twitter.com/6gFhOzLeL4 Reply Retweet Favorite On Facebook Be the first of your friends to like this • CHANGE CORPORATIONS • REFORM GOVERNMENTS • SERVE COMMUNITIES • PROTECT THE ENVIRONMENT • TAKE ACTION • DONATE • About us • Issues • Library • Media • EARTHblog • Voices • Contact • No Dirty Gold • Oil and Gas Accountability Project • Recycle My Cell Phone • Our Bristol Bay • Mining Reform Campaign • Stop the Frack Attack https://www.earthworksaction.org/issues/detail/gas_processing 5/16/2017 EARTHWORKS I Gas Processing Page 8 of 8 • Earthworks * 1612 K St., NW, Suite 808, Washington, D.C., 20006 USA * 1 202 887 1872 * info(a?earthworksaction.org * Privacy Policy Share https://www.earthworksaction.org/issues/detail/gas _ processing 5/16/2017 EARTHWORKS I Compressor Stations Page 1 of 6 • HomeX • Take Action • Donate • Stay Connected • About Us • Issues • Change Corporations • Reform Governments • Serve Communities • Protect the Environment • Take Action • Donate • About Us • Issues • Library • Media • EARTHb1og • Voices • Tags Search All Sites Stay Connected email i Sign Up Search • Other EARTHWORKS Sites O No Dirty Gold O Recycle My Cell Phone O Oil and Gas Accountability Project O Our Bristol Bay O Stop the Frack Attack https://www.earthworksaction.org/issues/detail/compressor_stations 5/16/2017 EARTHWORKS j Compressor Stations Page 2 of 6 Compressor Stations Hancock Compressor Station, Long Eddy, New York Compressor stations are large industrial facilities that maintain the flow and pressure of natural gas by receiving gas from the pipeline, re -pressurizing it, and sending it back into the pipeline system. (Pump stations do the same thing for oil.) Compressors are generally constructed every 40-100 miles along a pipeline, depending on the terrain and capacity of both the pipeline and the station. While some older stations contain only one or two engines, newer or expanded ones can have six or more engines. Each engine has a stack, which is a key source of air pollution. Engines run on diesel, natural gas, or electricity. Air sampling shows that compressor stations release climate and health -harming pollutants, including: • carbon monoxide (CO); • nitrogen oxides (NOx); • fine and coarse particulate matter (PM2.5 and PM10); • sulfur dioxides (SOx); • volatile organic compounds (VOCs); • hazardous air pollutants (HAPs) (e.g., formaldehyde, benzene, toluene, and xylene); and • greenhouse gases (methane, carbon dioxide, and nitrous oxide). Because they run engines and have a variety of equipment that can leak, compressor stations pollute the air whenever they operate. Pollution can be particularly intense during scheduled or https://www.earthworksaction.org/issues/detail/compressor_stations 5/16/2017 EARTHWORKS I Compressor Stations Page 3 of 6 accidental T blowdown" events, when pressure builds to the point where gas is vented directly into the air in order to prevent explosions. Saturn Compressor Station, Doddridge County, WV Compressor stations and other gas development operations can be noisy enough to pose health risks by causing stress, sleep deprivation, and elevated blood pressure. Earthworks measured noise near compressor and processing facilities in Pennsylvania, finding that levels were often in the upper 50-70 decibel (dBA) range, which exceeds state and federal standards. When the Federal Energy Regulatory Commission (FERC) reviews interstate gas pipeline projects, compressor stations are included in the project plans. Under the federal Clean Air Act, state regulatory agencies also have to review plans for compressor stations and determine whether, based on projected pollution levels, they require just a state air permit or also require a federal one. State regulatory agencies must provide notice of when federal air permits (known as Title V) are open for public comment. For more information: • Southwest Pennsylvania Environmental Health Project compressor stations and health impacts. • Penn State Extension how compressor stations work. https://www.earthworksaction.org/issues/detail/compressor_ stations 5/16/2017 EARTHWORKS I Compressor Stations Page 4 of 6 Tagged with: pipelines, infrastructure, compressor stations 1 Share Infrastructure Hub • >> Pipelines • >> Pipeline Stations • >> Gas Processing • >> Gas Storage • >> Waste Management • >> Community Search Issues Search Follow Earthworks • Follow EARTHWORKS on Facebook • Follow EARTHWORKS on Youtube • Follow EARTHWORKS on Twitter • Follow EARTHWORKS on Flickr • Follow EARTHWORKS by email • Earthworks RSS Recent News May 10 I Earthworks https://www.earthworksaction.org/issues/detail/compressor_ stations 5/16/2017 EARTHWORKS I Compressor Stations Page 5 of 6 Senate votes to keep BLM methane rule intact to protect taxpayers and public health May 3 I Earthworks I SumOfUs Peruvian Supreme Court Acquits Maxima Acura de Chaupe May 2 I Earthworks Earthworks expands state -based effort to cut oil & gas pollution that harms health and climate From EARTHb1og May 15 I Bonnie Gestring Trump's EPA ignores science, paves the way for Pebble mine May 4 I Nadia Steinzor Court approves seismic testing in Florida panther habitat Apr 24 I Nadia Steinzor Premature pipeline partying On Twitter I just published "Trump's EPA ignores science, paves the way for Pebble mine" medium.com/@Earthworks/tr... @Medium pic.twitter.com/6gFh0zLeL4 Reply Retweet Favorite On Facebook Be the first of your friends to like this i • CHANGE CORPORATIONS • REFORM GOVERNMENTS • SERVE COMMUNITIES • PROTECT THE ENVIRONMENT • TAKE ACTION https://www.earthworksaction.org/issues/detail/compressor stations 5/16/2017 EARTHWORKS I Compressor Stations Page 6 of 6 • DONATE • About us • Issues • Library • Media • EARTHb1og • Voices • Contact • No Dirty Gold • Oil and Gas Accountability Project • Recycle My Cell Phone • Our Bristol Bay • Mining Reform Campaign • Stop the Frack Attack • Earthworks * 1612 K St., NW, Suite 808, Washington, D.C., 20006 USA * 1 202 887 1872 * infOiearthworksaction.org * Privacy Policy https://www.earthworksaction.org/issues/detail/compressor_ stations 5/16/2017 DCP Midstream - Operating Safely and Reliably Page 1 of 5 Seguridad Contact Us Midstream_ SAFETY & SUSTAINABILITY > OPERATING SAFELY AND RELIABLY Safety is our core value. We are dedicated to keeping our employees and communities safe and committed to protecting the environment. DCP Midstream establishes principles to protect and advance the corporation's essential interests nationally and to fulfill our commitment to people and the environment. Protecting and responsibly managing natural resources are critical to the quality of life in the areas we serve. the environment, and DCP Midstream's long- term business success. DCP Midstream Pipeline Integrity Management Program Our Pipeline Integrity Management Program ensures our facilities are safe, reliable. and properly maintained to help keep our communities safe. Our Pipeline Integrity practices include monitoring. inspecting, routine testing. risk analysis techniques and other methods as needed to keep our natural gas and liquid transmission pipelines fit for service at all times. All of the nation's pipelines are regulated by the U.S. Department of Transportation's Pipeline and Hazardous Materials Safety Administration (PHMSA). The Pipeline Safety Improvement Act of 2002 requires each transmission pipeline operator to implement an integrity management program. More information on Integrity Management and related subjects can be found at the PHMSA Integrity Management website. If you have questions regarding our Pipeline Integrity Management Program, please contact us at pipeline-integrity@DCPMidstream.com. http://www.dcpmidstream.com/safety-sustainability/operating-safely-and-reliably 5/16/2017 DCP Midstream - Operating Safely and Reliably Page 2 of 5 Products We Transport The products we transport through our pipelines are natural gas, crude oil, condensate and highly volatile liquids (HVLs) as shown below. NATURAL GAS e4• Some natural gas may contain toxic hydrogen -sulfide (H2S). • The vapors are lighter than air and colorless. • There is an extreme fire and/or explosion danger. CRUDE OIL • Some crude oil may contain toxic hydrogen -sulfide (H2S). • Crude oil color can vary from yellow to black. • There is a fire danger. CONDENSATE PRODUCTS • Condensate products vary widely in color. • The vapors are heavier than air. • There may be danger of fire when condensate products are spilled. HIGHLY VOLITILE LIQUIDS (HVLS) 1)4 http://www.dcpmidstream.com/safety-sustainability/operating-safely-and-reliably 5/16/2017 DCP Midstream - Operating Safely and Reliably Page 3 of 5 • Comprised of products such as: ethane, butane. propane, or mixtures of the above. • The vapors are heavier than air. • HVLs burn very readily and may explode. Safety Data Sheets Find more information in our downloadable safety documents below. Butane (Commercial Grade) Butane (Field Grade) Ethane Isobutane Natural Gas Natural Gasoline Natural Gas Condensate Natural Gas Liquids Produced Salt Water Propane Propane (Odorized) Slop Oil Sulfur Liquid IN THE NEWS Air Force pilot from Franktown named FOX31 Hero of the Month READ STORY MIDSTREAM 101 http://www.dcpmidstream.com/safety-sustainability/operating-safely-and-reliably 5/16/2017 it DCP Midstream - Operating Safely and Reliably Page 4 of 5 Learn the industry basics and our role in it. START HERE EXPLORE DCP'S FOOTPRINT View our assets with our interactive map. EXPLORE MAP Safety & Sustainability OPERATING SAFELY AND RELIABLY PIPELINE SAFETY CALL 811 BEFORE YOU DIG http://www.depmidstream.com/safety-sustainability/operating-safely-and-reliably 5/16/2017 DCP Midstream - Operating Safely and Reliably Page 5 of 5 COMMUNITY INVESTMENT SEGURIDAD 1 y in EMPLOYEE LOGIN EMERGENCY CONTACTS 811 PRIVACY POLICY TERMS OF USE © Copyright 2017 DCP Midstream. LLC. All rights reserved. http://www.dcpmidstream.com/safety-sustainability/operating-safely-and-reliably 5/16/2017 Item I. Financial Statements DCP MIDSTREAM, LP CONDENSED CONSOLIDATED BALANCE SHEETS (Unaudited) ASSETS Current assets: Cash and cash equivalents Accounts receivable: Trade, net of allowance for doubtful accounts of $4 million Affiliates Other Inventories Unrealized gains on derivative instruments Other Total current assets Property, plant and equipment, net Goodwill Intangible assets, net Investments in unconsolidated affiliates Unrealized gains on derivative instruments Other long-term assets Total assets LIABILITIES AND EQUITY Current liabilities: Accounts payable: Trade Affiliates Other Current maturities oflong-term debt Unrealized losses on derivative instruments Accrued interest Accrued taxes Accrued wages and benefits Capital spending accrual Other Total current liabilities Long-term debt Unrealized losses on derivative instruments Deferred income taxes Other long-term liabilities Total liabilities Commitments and contingent liabilities Equity: Predecessor equity Limited partners (143,302,328 and 114,749,848 common units issued and outstanding, respectively) General partner Accumulated other comprehensive loss Total partners' equity Noncontrolling interests Total equity Total liabilities and equity See accompanying notes to condensed consolidated financial statements. March 31, 2017 December 31, 2016 S ( \lilliuns) 176 S 1 541 104 6 64 31 58 980 9,047 236 135 2,988 4 189 652 134 6 72 42 87 994 9,069 236 137 2,969 5 201 S 13,579 S 13,611 $ 546 S 677 51 48 14 10 500 500 36 91 57 72 68 49 25 72 20 20 73 84 1,390 4,709 7 28 195 1,623 4,907 1 28 199 6,329 6,758 4,220 7,108 2,591 121 18 (9) (8) 7,220 6,821 30 32 7,250 6,853 S 13,579 $ 13,611 1 PRO Fact Sheet No. 103 Partner Reported Opportunities (PROs) NaturalGaS R for Reducing Methane Emissions EM'°"`�'°" PnveN" Install Electric Compressors f sous Technology/Practice Overview Description Gas -fired engines are often used to run compressors, generators, and pumps. In some operations, part of the produced gas stream is used to power these engines. Methane emissions result from leaks in the gas supply line to the engine, incomplete combustion, or during system upsets. The majority of the gas from a "system upset" comes from compressor blowdown emissions and is the same for both gas engine and electric motor driven compressors. Partners reported that installing electric motors in place of gas -fired units can decrease gas losses. Electric motors reduce the chance of methane leakage by eliminating the need for fuel gas, require less maintenance, and improve operational efficiency. Operating Requirements An electrical power supply is needed to implement this technology. Applicability Remote facilities with an available electrical power source and high maintenance cost may be good candidates for this technology. Methane Emissions Methane emissions savings are based on an emissions factor of 2.11 Mcf per year horsepower.' Partners have reported methane savings ranging from 40 Mcf per year up to 16,000 Mcf per year. Economic and Environmental Benefits Methane Savings Estimated annual methane emission reductions Economic Evaluation 32,800 Helper 5 reciprocating compressors replaced Estimated Gas Price Annual Methane Savings Value of Annual Fuel Gas Savings* Estimated Implementation Cost Incremental Operating Cost Payback (months) $7.00/Mcf $5.00/ Mcf $3.00/Mcf 32,800 Mcf 32,800 Mcf 32,800 Mcf $11,900,000 $8,500,000 $5,100,000 $6,050,000 $6,050,000 $6,050,000 $6,200,000 $6,200,000 $6,200,000 13 Months 32 Months Does not payback Only the value of fuel gas savings were considered, since the avoided methane emissions from the compressor are unburned hydrocarbons and, therefore, are included in the fuel gas savings. Additional Benefits • Reduced fuel gas consumption • Increased operational efficiency and reduced maintenance costs • Faster permitting due to lower noise output and no emissions Compressors/Engines Dehydrators Directed Inspection & Maintenance Pipelines Pneumatics/Controls Tanks Valves Wells Other Applicable Sector(s) Production Processing Transmission Distribution Other Related Documents: Install Electric Motor Starters, PRO No. 105 Convert Gas Driven Chemical Pumps, PRO No. 202 PRO Fact Sheet No. j_Q2 Continued Install Electric Compressors (Cont'd) Economic Analysis Basis for Costs and Emissions Savings Methane emissions reductions of 32,800 Mcf per year apply to the replacement of two 2,650 hp, two 4,684 hp, and one 893 hp reciprocating engines. One partner reported replacing two 2,650 hp, two 4,684 hp, and one 893 hp reciprocating compressors with four 1,750 hp electric compressors. The total cost of replacement was $6,050,000 and includes the cost of the motor and the compressor. Fuel gas savings of 1,700,000 Mcf per year apply to the 5 compressors replaced assuming 20% efficiency, a heat content of 1,020 Btu per scf of gas, and 8,760 hours of operation per year. When estimating the value of gas savings, only the value of fuel gas savings were considered since the avoided methane emissions attributed to the compressor are unburned hydrocarbons and are therefore considered to be included in the fuel gas savings. Incremental operating costs are primarily electricity costs. Reduced maintenance costs would offset some of the electricity costs, and are assumed to be approximately 10% of the capital costs. Assuming 50% efficiency for the four 1,750 hp electric compressors and 8,760 hours of operation per year at a price of $0.075 per kw -hr, electricity costs would be $6,800,000 per year. Discussion Installing an electric motor in place of a gas driven engine will increase operational efficiency, reduce maintenance costs, and yield significant methane savings. The capital costs and the electricity costs, however, are higher for an electric motor compared to those for a gas driven engine. The primary reasons for implementation of this project are fuel gas savings and maintenance savings. An additional benefit is the faster permitting process as a result of lower noise output and no emissions. It should be noted, however, that the economics may vary significantly for transmission companies as a result of contractual agreements and ownership of the gas which would be responsible for the additional revenue included in this economic analysis. 2011 Methane Content of Natural Gas The average methane content of natural gas varies by natural gas industry sector. The Natural Gas STAR Program assumes the following methane content of natural gas when estimating methane savings for Partner Reported Opportunities. Production Processing Transmission and Distribution 79 % 87% 94% 1Emission factor is based on Annex 3 of the Inventory of U.S. Greenhouse Gas Emissions and Sinks 1990-2009. The emission factor is for Compressor Gas Engine Exhaust and is calculated as shown below: 0.24 scf/HPhr x 8,760 hrs / 1000 = 2.1 Mcf CH4/HPyr 2 y m 8 Tr. .61 > u •.c d z o x M E 1 c f l HI " o m tai a To N C ; O to E Y v `o L c ro a_ en V o c 10 G rq o > o e a A X w 2 d MOB to come o v) c E Dx C �j a D ` a w > � C L E y u ro J V � € _Q) ro 4 [ at3t$ N a E XN € ftr ro a I t Um St cg 0 01 M a0 U c a e Eoe g 0 o C E arrg o o • w' A p R ptfi f0 h - a = C N Eg o p o L _ a =:!A „ ''Qc�o vaz" OOo u, 0= em on a E. o G gt N o� CA N - rya EEo e� N co I s ro 3 Z Ol C z ro C z P t ` L a) 7 ft w > N E O 5 ro LL C Gas processing plant opens, provides more capacity to move natural gas I Greeley... Page 1 of 3 (/news/business/) Gas processing plant opens, provides more capacity to move natural gas December 15, 2015 DCP Midstream this year has significantly increased capacity for natural gas processing northeast of Greeley. For many, it couldn't have happened fast enough. Oil and gas exploration company executives have lamented high line pressures in the Wattenberg Field — which lies in the heart of Greeley and Weld County — for a couple years. Natural gas gathering lines are buried throughout Weld. The higher the line pressure, the harder it is to get the oil and gas out of the well and off to market. For years. excess product meant extra flaring. which no producer wants. They might as well be throwing bricks of cash in the fireplace. DCP Midstream's O'Connor Plant. which opened in 2013 south of Kersey, was supposed to be the relief valve, allowing for an additional 110 million cubic feet of natural gas processing capacity per day in an increasingly high -volume field. The plant underwent an almost immediate expansion the following year to allow for another 50 million cubic feet per day processing capacity. That still wasn't enough, but Lucerne II already was being built about 4 miles northeast of Greeley. The $250 million gas processing plant came online in June. "I think you'd hear from a lot of (executives) ... this plant from their perspective was possibly a little late," said Bill Johnson, vice president of North and Permian Business Unit Operations of DCP Midstream. "Our perspective was it was timed right. It's a very large investment, so we have to know the gas will be there and we can recoup some of that investment." The plant opening gave DCP Midstream the capacity to process 800 million cubic feet of natural gas per day out of the Wattenberg Field, and more than 55,000 barrels per day capacity to process natural gas liquids, such as butane and ethane. The plant brought the company's assets to a total of nine processing plants in the Wattenberg, representing an 80 percent increase in the company's gathering and processing capacity in the past two years. http://www.greeleytribune.com/news/business/gas-processing-plant-opens-provides... 5/16/2017 Gas processing plant opens, provides more capacity to move natural gas I Greeley... Page 2 of 3 For many producers, it was an agonizing wait. In a Noble Energy third-quarter earnings release, officials noted the importance of the plant's opening: "Accordingly. line pressures in the northern part of the field, particularly in and around the company's Wells Ranch area. have been reduced by up to 100 psi," the earnings release stated. "... As a result of the reduction in field line pressures, the company's legacy vertical well production averaged nearly 25.000 barrels of oil equivalent per day in the third quarter, which is a high point over the past year and an increase of more than 5,000 barrels of oil equivalent per day versus pre -Lucerne -2 rates." the release stated. Barrels of oil equivalent means all the product that comes out of the well. which includes crude, natural gas and natural gas liquids. The anticipation built as company executives discussed the obstacles in their field in the last year. Scot Woodall. CEO and COO of Bill Barrett Corp.. said in a second-quarter 2015 earnings call, said the Lucerne II plant quickly provided a significant development in his company's production. "Definitely Lucerne II is going to help us. Almost all of our gas flows toward Lucerne II, and since it has had some pretty good run times here of recently. I think we are observing a plus -or -minus 100 psi drop in wellhead pressures because of Lucerne II," Woodall said in an earnings call. DCP Midstream is a must -run business, officials explain, but they don't build processing plants for the sake of building them. They need to know the demand is there and it will stay there to justify the expense and time. The gas processing plants take two years to build. The plants essentially filter the gas and clean it up to certain levels. and they're about to come up on a busy season with the typical cold temperatures in the winter. "The gas that comes out of the ground isn't suitable to be sent straight into houses to be burned as natural gas," Johnson said. "It has water, contaminants, other things. We basically take the liquids out, the water out, process it so it meets a standard so in everyone's house, it burns the same. If we just took what came out of the ground, some would burn hot. some wouldn't burn well at all, and it would be a mess. We clean it up and standardize it and sell it." Most of the gas that comes out of the ground in Weld is consumed locally, but it does get shipped to the greater markets. http://www.greeleytribune.com/news/business/gas-processing-plant-opens-provides... 5/16/2017 Gas processing plant opens, provides more capacity to move natural gas I Greeley... Page 3 of 3 Demand continues to grow, even in an industrywide downturn. That demand has allowed DCP Midstream to broaden its reach, officials say, that will keep flows moving. even in the case of system hiccups. The company has strategically located its plants in and around Greeley, all connected and at the ready. "One of the cool things about our system and the service we offer, you'll see all bigger. newer plants are connected by these lines, which allows us to move gas from gathering and process it at almost any one of those plants," Johnson said. A map of DCP's service area a year ago showed a growing issue with high line pressures, on the western or more urban fringes of the Wattenberg Field. "Producers were getting a little frustrated with us for not having lower pressures," Johnson said. The additional processing capacity at Lucerne II has reduced line pressures to the point that operators could bring online even old legacy wells that were shut in for some time, said Lucerne II Plant Manager Tauna Rignall. "Some of our customers have been able to restore some of their old wells," she said. While the company contemplates a 10th plant, it's also in the process of building a pipeline that will help producers on the fringes. Even today. officials contemplate a potential 10th processing plant in the Wattenberg Field — a permit to build already is on the books. The big question will be demand. Certainly, this recently slowdown will be a big player in that decision. DCP earlier this year cut its ranks by 20 percent. "We have an idea out there and a permit filed to build a Mountain View plant, but you can see we don't have a date," Johnson said. "It's really based on the needs of our customers and their timelines. We kind of stand ready to be able to build that plant, permitted and it will depend on the activity in the basin and the needs of the customers." http://www.greeleytribune.com/news/business/gas-processing-plant-opens-provides... 5/16/2017 Hello