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Home My WebLink About20174255.tiffCOLORADO Department of Public Health. Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150O St PO Box 758 Greeley, CO 80632 December 11, 2017 Dear Sir or Madam: RECEIVED DEC 1 4 2017 WELD COUNTY COMMISSIONERS On December 14, 2017, the Air Pollution Control Division will begin a 30 -day public notice period for DCP Operating Company, LP - Libsack Compressor Station. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure Pc >bl c Rix e..uJ ca/a'77 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 cc PLCMM/ rP), .-IL.CJTj 4 C/CFI /JM/C►s) Ia�rs�l� 2017-4255 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: DCP Operating Company, LP - Libsack Compressor Station - Weld County Notice Period Begins: December 14, 2017 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: DCP Operating Company, LP Facility: Libsack Compressor Station Natural Gas Compressor Station Section 36, Township 6N, Range 65W Weld County The proposed project or activity is as follows: The operator is requesting to modify the Libsack Compressor Station in order to. add one (1) Waukesha L7044 GSI compression engine and increase the gas processed by the TEG dehydration unit from 50 MMscf/day to 64 MMscf/day. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made,a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 11WE1475 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such comment must be submitted in writing to the following addressee: Harrison Slaughter Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us 1 Colorado Air Permitting Project Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name:.• Physical Address/Location: Type of Facility: What industry segment? Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? D arbon Monoxide (CO) Section 02 - Emissions Units In Permit Application t1CP.I 123: Libsack Co Section 36, Township 6N, Range 65W, in Weld County, Colorado <P` Weld Quadrant Section Township Range [articulate Matter (PM) axone (NOx & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 atural Gas RICE C-185 Yes 12WE3179 3 No No Action Requested . t3 , 3, 002 . Natural Gas RICE C-186 'Yes 12WE3179 3 No No Action Requested 003 Natural Gas RICE C-187 Yes 12WE3179 3 No No Action Requested ..:. 004. t mural Gas RICE ' C=188 i Yes 12WE3179 3 Na No Action Requested y., Dehydrator D 1 Yes 12WE3179 3;r :.:�. Yes n Perm{t Modification �� E 33113133 3 .33�E1 33��j3r31111 J33 3111333 f 3133"3'x• 'S- 006 1 I; � fr,� ,:: � FUG � ➢�q._. _ No 12WE31779 3 a �i No Cancellation Emrssions � '� 3 T� olds_ - `iveComponent Leaks 007 �fl.,... Natural Gas RICE C-167 Yes 111WE1475 3 Yes Permit Modification lV Section 03 - Description of Project °application requestingto modify the existing TEG Dehydration unit and -add a new engine to the Libsack }Sting synthetic mttnorfacilttylocat l t� 0 Q IO n4n fita'urn ea. The operator is requesting the ity wide perm 64 MMscf/day; 1 13 i11 11 E 131 J3 tea` Add"°Sao 3y%R1 td r �t€kn fo�tice ashl3tagik During VRU downtime flashtanleemissions will belr tecj o e enclosed combustor (EEI 3. Add 3 ' 'ddr downtime forth ECtcontrolling the still vent. During downtime, still vent emf wns ...,.he routed to atm osphere: With this modification, DCP is also requesting the addition of a new compressor engine. The engine to he used at this facility currently operates at DCP's Mewbourn Gas Processing Plant. DCP is also requesting the cancellation of the fugitives covered under point 006. The emissions associated with the fugitives point dropped below APEN reporting thresholds due to new WAR requirements.dnder Colorado Regulation 7, Section XVILE and the use of table 2-8 emissions factors. A cancellation request was submitted for this point on 05/ 01/2015. erequuedforth permit modification. Public comm nt witI be required for this permitbecausi 007 (Regulation 3ParL BSection IIIC.1.d.) and the change in NQx emissions is greater than 2 ed a draft permit prior to pul'c'comment and provided thefollawing comments: (1) Conditioi riiaal emissions limits for AIRS G01.through t lR5'004 to match those of AIRS © ,.fncrease from 1,1"to AIRS points in this application, the PM emissions for the first 4 engines are basecton the sarnem e ission factoras and it makes more sense to have consistent emissions limit fury all S engines dates to Permit Holder #4' ii identical, so please adjust the table in Notes to Permit Holder 4, such that' AIRS' 00 through AIRS 004 match the keep the listed emission rates forthese 5 engines consistent wherever possible. etic minor limits are being Regulation 3 Part B Sectio 1.a) Colorado Air Permitting Project Eon s factors for PM1O PM2 5 and HAPs for point:001 0}4 are identical to thee" d n IUI2 S and the HAP values provided m �Notes to Permit Holder condition 4 vd'ee had no: further co 3l "1 y' Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? If yes, for what pollutants? ra If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, explain what programs and which pollutants here: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) SO2 NOx CO VOC PM2.5 PM10 TSP HAPs OOOO ❑ ❑ ❑ 0 O O ❑ ❑ ❑ O O 0 SO2 NOx CO VOC PM2.5 PM10 TSP HAPs ❑ ❑ ❑ ❑ O O • ❑ ❑ ❑ ❑ O O O O O ❑ Glycol Dehydrator Emissions Inventory Section 01 -Administrative Information 'Facility AIRS ID: Plant Polat se000n 02 - Eeuloment Description Details Dehydrator Information Dehydrator Type: Make: Model: Serial Number: Design Capacity: Recirculation Pump Information Number of Pumps Pump Type Make: Model: Design/Max Recirculation Rate: Dehydrator Equipment Flash Tank Reboiler Berner Stopping Gas Dehydrator Equipment Description Emission Control Device Description: MMscf/day gellons/mleate flash tank, and rehoiles burner One (1)Tdethylene glycol ITEGI natural gas dehydration unit (Make: OA Johnson, Model: Glycol Contactor, Serial Number: 642002)witha design capacity o£ 64MMsef per clay. Thisemissions Lira equipped with l( Make: Best Pump Works, Model: N/A) electric driven glycol pump with a design capacity 0(24 gallons per minute. This dehydration unit is equipped with astill vent, flesh tank, and reboller burner. Emissions from the still vent are muted to an alr.coaled condenser, and then to the Enclosed Vane. Emisslons from the (lash tank are routed directly to the Vapor Recovery Unit (VRU), As a secondary control device, flash tank emissions are routed to the Enclosed Flare. Section 03 - preceasine Rate Information for emissions.stlmates Primary Emissions - Dehydeeter Still Vent and Flash Tank (If present) Requested Permit Limit Throughput ,..., �: s,, 2g''K4(;N,MMsd per year Potential to Emit (PTE) Throughput= 23,360 MMsd per year Secondary Emisslons - Combustion Device(s) for Air Pollution Control Still Vent Control Condenser Condenseremissien neductnen calmed: Primary control device: Primary control device operation: Secondary control devke: Secondary control device operation: Still Vent Gas Heating Value: Still Vent Waste Gas Vent Rate: flash tank Control Primary control device: Primary control device operation: Secondary control device: Secondary central device operation: Flash Tank Gas Heating Value Flash Tank Waste Gas Vent Rate: Enclosed Flare Pilot fuel rate: Assist gas rate: Heat Content 1?iily� xP �k„c Control Efflderry% I�r Vin......._... E?p.rbfk control Ef lderry% hr/Yr:::: G!.etu/scf hr/yr Btu/scf scfh scf/hr ad/hr Btu/scf flg1�33 t:3ii7 Control Efficiency% Control Efficiency% Wet Gas Processed: Still Vent Primary Control: 22,65920 MMsef/yr Still Vent Secondary Control: 70010 MMs6/yr ate Gas Combusted: Still Vent Primary Control: 6.6 MMsd/yr Still Vent Secondary Control: OA MMsd/yr Wet Gas Processed: Flash Tank Primary Control: 22,192.0 MMscf/yr Flash Tank Secondary Control: 1,168.0 MMscf/yr Waste Gas Combusted: Flash Tank Primary Control: 0.0 MMsrf/yr Flash Tank Secondary Control: 0.8 MMscf/yr Pilot fuel/Assist Gas Combusted Pilot Fuel: 0.0.98 MMsd/year Assist Fuel: 2628 MMsd/year Total: 26.718 MMsd/year Glycol Dehydrator Emissions Inventory sectton04-Em10aloes Factors 8 Methodologies Input Parameters Inlet Gas Pressure Inlet Gas Temperature Requested Glycol Recirculate Rate STILL VENT Control &ccoedo • Primary Secondary Pollutant - Uncontrolled (lb/hr) Controlled (lb/hr) Controlled (lb/hr) VOC ;,__;, 99.131?" u, 2.656385 53.1277 Benzene :g,M,A-ki-ili:61I-NRI 0'.560395 112079 Toluene ;90.0122 s})'d(;•! 0.44586 8.9172 Ethylbemene `0.1060 <.swl.R 0.00683 0.1366 Xylenes 1]53≥ 3 i,'EI 0.107625 2.1525 n -Hexane a„(31894". -' %} 0.05902 1.1804 224TMP r - �0,W25? , 0.000'125 0.0025 FLASH TANK Co0001Scenado Primary Secondary Pollutant Uncontrolled (lb/hr) Controlled (lb/hr) Controlled (lb/hr) VOC )il/ 1:1YS3ad69il/9) .,' 0 2.662915 Benzene i ISki0)i11�"i¢',, 0 0.01595 Toluene ':' i4lEut .r,"%� � 0 0.00854 Ethylbenzene :'1'0(0015 0 7,SE-05' XYlenes }i„ifyCM.-AA A 0.000835 n -Hexane 0.094705 224-TMP t '9.tK10 -:_a 0 90.00 Secton 05- Emlaslans invent0eo Old operator request a buffer? Requested Buffer (96): still vent Secondary Cordml Device Uncontrolled Uncontrolled (Ib/MMBtu) (Ib/MMscf) Emission Factor Source (Waste Heat (Waste Gas Combusted) Combusted) Criteria. Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Umits Uncontrolled Controlled (tons/year) (tons/year) PM10 PM2.5 NO0 CO VOC 0.13 0.13 0.13 0.13 0.13 0.19 013 013 0.13 0.13 _ 1.20 - 1.20 1.20 1.20 1.20 5,48 5.48 5,48 5.48 5.48 55916 559.15 22.62 559.16 22.6201 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (Ibs/year) Requested Pe mR Limits Uncontrolled Controlled (Ibs/year) (Ibs/year) Benzene Toluene. Ethylbenzene Xylene n -Havana 224 TMP 823.171 321171 4257 121170.77 9257.05 05491 95491 7363 95491.01 7362.79 '1452 1952 113 1451.71 112.76 22803 22803 1777 22802.63 1770.66 21807 21807 990 2130714 997.55 45 95 2 45.20 2.11 6059 4.63 47.75 3.68 0.73 0.06 60 0.89 10,90 0.50 042 0.00 Glycol Dehydrator Emissions Inventory Section 06- Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7. Section XVII.B.D Dehydrator is subject to Regulation 7, Section XVII. B. 03 Regulation 7, Section XVII.B.2.e The control device tartnie dehydraterSe not subject to Regulation 7, Section XVII,B2,e -_ Regulation 1, Section XlI.H Dehydrator Is subject to Regulatian2, Section X0.11 Regulation B, Part E, MAR Subpart HH (Area) Dehy is sublectto area source MALT 191, per the requirements In 63.0641d1(21 Regulation B, Part E, MAR Subpart HH (Mahar) You have indicated that this facility -is not subject to major sdurcerenuiremerrts oft Regulation B, Part E, MAR Subpart HHH You have Indicated that this facllltyn not subject to MACTHHH. (See regulatory appiicabfSty worksheet for detailed analysis) Section 0]- Inttel and Periodic Sampling and Twine Requirements Wasthe extended wet gas sample used in the Gly(alc model/Process modalsitespeciific and collected within year of application submittal? If no, the permit will contain an "Initial Compliance. testing requirement to demonstrate compliance with emission limns See note 4151n Section 08 for additional information. Does the company request a control device efficiency greaterthan 95%for a Clare or combustion device?. If yes, the permit will contain and Initial compliancetest condition to demonstrate the destmction'efciency of the combustion device based on inlet and outlet concentration sampling Section o8 Technical Analysis Notes 1. In the previous 5suanceofthis permit, the gtncaldehydratossidlvent was controlled by: an enclosed Rare, Addhlonaliy, the flaslit ohmic orcowre recycled by. avapor recoveryun (VRU}.Wmtihts appiicatlon,the operator requesting to add 5%VRU downtime durirrgwtnch{l aslrtank emissiansfrum the, flash tankberouted to the enctosedfiare.Additionalht the operator isrequestmgtmaod344amtualdownrmefarthe EC0 controlling thasdlivent. This downtime is roquiredfos maintenance andrepaInn During dow dme,stillventemsslanswill be routed to atec phere_ - - 2. As inclicateclothe regulatory analysis forth,enwurce, lire 4ycot dehydration units subject to Regulutio. 7S trlunXNI,O. This potbonafthe regulation requiresradiiventsoad vents/ anyfosh sepomtor',It h tonk on a giprorrarhral pas dehydrator lacaredat anmiandgosaxptorationand pmductionopemtton, notarargacrompressorstnafoR organ-grocessfnoplanrSebjectta cantrolcnmgrementsparsaanttbcecrpn 011 Da„ Anal -reduce uncordipliedarMoienadxidensafilydnncarbdnatyotleastSSpercenton areW'ngmaive-nwnih basis through Oledse al a condenser drawpollwiantondoterjuipmertt^ Sincethe operator is t request -Into permffi d f tit stir vent prrrnanicontrold i during which enthapna will be mutedto the atmtspiiere(to.iMhmutmlf the p t ll tante la conditions*. limnthe downtlmeotthe VRV Wdsedfl [eta ensurethehetotal IF control efdbythey greater than q tefi%astegaaedbyihe regulaCiomThese Awrrrit eandtionsare rcgmrediathe permR4a ejrstt2aminimum u(BS%irvetall "�t7m event -the total gas processedtry the dehydration unit less than the pe rted limn ilksh id tmaotedthat thecalculated controleff kienciesfor bemee, &Irene ethylberideneandxylene(tops) Is 5ctldn do)are i tit 98411 h veraftcalculated[actoulafftclennicHo 9Cis 99966. oath VOCcd.OFroleffloleneyts greaten han 95%arid HATA area subset of VOC, It aepeem this dehydration unit meets the contrlm,yseement of Colorado 8egutatlon 25eononXV111,3. 3, The actua4 emissions reported on the APEN do not match with the actual emissionsfutedinthetabletrfSection OS abweThls is dueta the fact that the operator is required to?alalan total emissions using simulator, monthly bas lOSE nrhan through the or emissions factors. As a result, r do not have all tke calculatlo nsused to estrmateaclwl emisions.oue to emissions f ihfsso rceshauid be mo a -' u referenced en the most recentAPEN soh milled an 08/19 /17. 4. Theemissors tromthe rtlll vent are routed to: a condenser pdorto being routed t0the enclosed flare.However, Me operator rsnartakingcredn for any control achieved by thecondenset,This is demonstrated in the calculations by using the -uncontrolled regenerator emissions" stream from the GlyCalc model to caloelate uncontrolled erosions and using a95%control assanatedwdh theitaretocalculate controlledemi.slots, th result, neaher she permttmrthe O&M plan wilt require the condenser outletttemperatu ebe monitored or seta maximum outlet mndecsertemperature 5, In order. .calculate still vent combustion mass. s; the operatorusedthe composition and throughput associated wnhthe"C000000eveM5eream" m the GlyCelc sImutation. WO.the0perateris nett eking credit I. for the rnnderaer as a control deice, thence of Me condenser vent stream to calculates -WI vent combustmnemission, is acceptable as- iOlin noh larety a bettor representation of actual emisions. Theother option for calculating stfttie ( combustion ern lesions would have been to use the 'Regep mtorOnerheads-SCteam E this strearti had been used, NOXand CO emissions would have bees calculated_ as 0.35 toy and 159 tpy rmpectwelylmeat Content r. 198,5A, Btu/sill, Flow Rate -5,900 nef/hr).Comparatively, the CnnonserVent Stream properties results oluuend CO.emissions of.0.34 epy andc5Ttp( respecllVely, This miner difference in emssi0ns Ones not result in a facltydaSAipratlan change As such,R was determined the use of the composticn and flow rate associated with the "Condenser VentSfmarrt^vas acceptable for estntOA%'. stiff vent eoniAMion emissions. 6. The temperetur and pressure of Mei.. wet gas sStoic dInmeslmulatmn do not match with Me temperature and pressureon the site -specific sample yroNdedwnhtheappf&at(a2Asa, result a tbYclyfalc simulation was mato assess the results tithe temperature andpres ure fromthe sample we reused 3nthesfmufatton.This test 00ontutioniewitedw amps pn rates that wereslighilytoerernnervathothamu the emhslon rata estheeted by the operate ',However, theoperotoradded a 20% boffin rtes their emssiumatimateto accountior iodation inthegas anab{sus and other esitatparameters_f152o% buffer resulted. mss0n that areool 00000rvetive than the testtyGJcsimulatlon, Asa taut, the operator's est(nmteofemiulons k likely cone Viand therefore acreptabietorpermhtingp rposa. 7 Based on actualbe etene emissions reported on the APEN dated 06/19(201](, theoperator meetsthearea source bemer ¢exempt ion of MALT HH. Mauch, the operator sooratroentyrequiredto calculate and comply wrththeoptimal glycol circulation rate that would be required based on requested emrs ons.Asa result, the permltwill be updated. retfectthe requirements of'MACTHHforthasortraewhen actual emisslOm ofhentene are below 19842lb/year IMACT HH-Benzene Exam pson}andwhen actual emrssi ncfImmere are greater than 1984,2lb/year#Aree: Source OrmidetlA/UC- Optimal glycol circulation rata), TMs updated sOn,?,e will better info nn t1s operator and lnspecter ofthepotential MACr1N requirementsfar-thissource that w0l be based Ont(le recorded Attar aVernebenze0 51150'rmts.._- the event Me operator is required to complywlth theoptimatglycoP circulation rate the optimal -circulation ram In based on the folfewing pares 2 ms fro m thMICatcsimulation submitted with the application,P- "! 84 MMscf/day,1- 100 31 lb/MMscn and O=6.7Ib/htty&ef_vouogthose values and theequauon in Md0TH04E3.7.4(d)(2')(1)thaoptima tgrycef caxdktlnn rate would be calculated.folloiws:Lopto (110)t)70tT86/Ib"r H501.III640101 c€/0 0)0100.91 fb/MMscf- 6.7 lb/MMSeill/(2.8hrlday)1 866,l32gallns/hr"1ht/000110 14aSga0ons/ilpn. 9. The coobustione0 sons calculatedforehestill vent routed to the colas dcambustorare based en8.700hrsfyear ratherthan therequated 3%downtime(262.8hrs/year)-Thiscalwiatioo methadaccuretely estimates emissions from the comtrastorin the eveotthetmnbustor does not have downtime a rdnperatesforthe entire year. Si ocecombstorbrypiculk have some- downthoedudagtheyear,pennlltingthe still vent combustion emissions at8700hrs/year rauftsle aconservative estimate, - :. 9. The opeatoneuuessedthere areooflow meters farthefla0ttank orstilt vent waste gassteeenus"€he Operator expressed the waste gas from the stifverrt and flash tank isdezerminedirom the monthly GlcCalc simulations. 10 The updated Dgm pip submitted by the operator does no snsn5 IX infermatltc an holy the whrnte etg..PrOce.ed WthedehYdrarorsmmrtoned: Asaresuh,thu Info The operator.Pressed that the volume of gas processed by the dehydrator' ismonitored with a meteratOlefacllitydischarge. m_Ths dohydration tint s equipped with a 2 se mm13t /h febo ter. S ince t his rebolier has a design rate lesotha0 3MMRto/IV, it is APEN exempt per Colorado 3egulation 3 This permrtwas issued-sfnal a pp vat with the previous issuance Issuance 2(Hewever,Shs p rmitwlllbe required toga beck ihrpogll selr-Gerufcaaon beoavaeapewangmaioboereadded W this permit Iternew permit commons and imt I In6iequirement. - - e operatorindkatedth0t the pilot light fuel and assstfoel used by the camdrstorfiow at a constants rand are therefore net meteredPermed ensnlors are based oileconstentpgotfuetflaw rateof 50 and a constant assist fuel flow retard 3,000scf/tx Me operator did Mdlcate 'lathe assist fuel flowaray be longed, Wt 6 constaza et the rates. by the operator. Tiseassttfuet8ow ram used in the apphaoan highest expected tate for thispatameter. - - - U. The operator' indicated that the volume of gas processed by Meglycofdehydiator is monitored using the facility discharge meter. The opertor Mdicated thatCho difference inketvalume and auttetvolumele very, mullet based on the volume processed. As a result; they indicated the d charge meter would provide an acou ate measurement ofges processed by the dehydrtor-§should be noted thatths moflnnncgmetbod w. approved with the0&M plan submitted on Fn June 2014. Further,. this 0rinrmgrnegitod is used at other 00O compressor Aatlons and has been approvedfurfhosnfeciliMem Tnfgsupports tke determination that 'thefecigty,discharge meter s art peptablethroughpa rackng mechanism. 19. The sempieysed In the GlrCafesimulation Is sdesper'dic,howevee,tit a sample was obtained nmrethenena year pdor.n the appIIcmon date -Even though thesampl sobneMed mare Mao a year prior to the pp8eatianrltW00 C10terml0ed IA De ems,. blefor esllmannmssro s for the following rns:IA¢ tlfenntomrolied emissions cacuiated by Me:simulation are vex similar to -the values dalcoleted in tie previous dptltatlot,11.previmG apptleAtion used the sampte''Medln the originaI apnkatI n.Thh dernonStrateS SNOW OSGompo5100n does vary onoirthin but the rariatlOA5 MaybuyynuL)v}tThB'operater added a 20% buffertethe etnissimmealculations to accoun ttor varationsn the gas analysis and other parameters.(qi(The operator is required toobtain, wet gas sample prior totheOndeleton,anannual bash,Thh annual sample is Mere used for akulating actual emission, In ummary, thesample used to calorie¢ emtswnmthh appbation Is likely representativeancitherefore acceptableforertimating emissions, 16. ae0000agtdthe oRerator,theheat content of the waste gas streams will be calculated based on the menthiyCyCak run. ey calculating the heat value eathMOnt@athertha stglilding the heat value used for penandngintothe fission factor,the operator will beabretodemrrnine actualembsiors more ammeter,-. Mree separate tables a sso-Aedwith themmbusxion process. Mash taekcentralled by Sne, still vent controlled bytb, &Assht/pilot fuel combustion} are contained in tit a notes to permit holderoo[leaitfy demonstrate the methods used to calculate emissions. ihenotes under tact( taht0cieariy mdicatethe heat. contentafthestittvent andflash tank waste gas streamswill be ralalmed on a monthly bass and usedatongvwhh the calculated flow rate andmoh0ored hoots of operationtodetenomethecomburtloaemssions. eSAraxpressedthe glycoldeculd,OlipurnpoC:' az Wonldedwtth draft permit to review nom, As AIRS Pnlrtk W5 not nave a model number. AS 5t,ek, Only one menttfacturer vA be provided In the equipment M4454,,5100 The operator rev ewedtbe draft permit and expressed they had no commentsregardingthe madgrcatlon mart Processp SCC Code 01 iffeg Section 09- Inventor, SCC Coding end Ernissleea Factors Uncontrolled Pollutant Emissions Factor Control% Units PM10 0,011 0,00. b/MMscf PM25 0.011 0.00 b/MMscf _ 500 0,103 0,00 b/MMscf. VUC 0.874 - 95.95 b/MMscf CO 0,469 0.00 /MMscf Benzene. 5187 9236 b/MMscf Toluene 0.088 92.29 b/MMscf Ethylbemene 0.982 0023 b/MMscf Xylene 0.976 92.21 b/MMscf n -Hexane 0,934 95.43 b/MMscf 224 TMP 0,002 9533 b/MMscf Dehydrator Regulatory Analysis Worksheet Colorado Regulation 3 parts A and B-APEN and PORttlt ROgUlr0ments Yost have indicated that source Isle the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greater than 2TPY (Regulation 3, Part A, Sectionitt.1.a)7 2. Aretotal facility uncontrolled VOC omiooioru greater than 5TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section ll.D.3)? I' you have indicated thatsaurceis in the Nest-Attairhhs1H Ate₹ ]JON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants front this Individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, Non greater than 5 TPY or CO emissions greater'than 5 TPY (Regulation 3, Part B, Section 11.0.2)? ISOurae requires a permit Colorado Regulation 7, Section XII,H 1. Is this glycol natural gas dehydrator located in the B -hr ozone control area or any oznon-attainment area or attainment/maintenance area (Reg 7, Section XII.H.1 and 2)? 2. Is this glycol natural gas dehydrator located at an oll and gas exploration and production operations, natural gas compressor station, natural gas drip station or gas -processing plant (Reg 7 Section 3. Is the sum of actual uncontrolled emissions of VOC from any single dehydrator or group of dehydrators ate single stationary source equal to or greater than 15 tpy (Reg 7, Section XII.H.3.b)7 4. Are actual uncontrolled emissions of VOC from the Individual glycol natural gas dehydrator equal to or greater than My (Reg 7, Section Xll.H.3.a)7 'Dehydrator in subject to Regulation 7, Section ARM Section XILH— Emission peductions from glycol natural gas dehydrators MACT Analysis 1. Is the dehydrator located at an oil and natural gas production facility that meets either of the following criteria: a. A faculty that processes, upgrades or .stores hydrocarbon liquids' (63.760(a)(2)); OR A facility that processes, upgrades or stores natural gas prior to the point et which natural gas enters the natural gas transmission and storage source category or Is delivered to a final end b, user' (63.760(a)(3))7 2. Is the dehydrator located at a facility that is a major source for HAPe? I(30 to MACE HH Area Source Requirement section EA determine REACT HH nppirabi:tty 40 CFR, Part 63. Subpart MAR HA. Oil and Gas Production Fadlltles Area Source Requirements 1. Is the dehydrator a methylene glycol (TEG) dehydration unit (63.760(6)(2))7 Exemotlons 2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 3.001747 MMscf per day (63.764(e((1)(I)7 2b. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2lb/yr (63.764(e)(1)(ii)7 3. Is the unit located Inside of a UA plus offset and UC boundary areal !Deity is subject to area source MACT HH, per the rcqutrnrrivets In 63.764(3)(2) Subpart A, General provisions per 463.764 (a) Table 2 §63.765- Emissions Control Standards Do Not Apply 463.773 - Monitoring Standards Do Not Apply 463.774- Recordkeeping §63.775 - Reporting Major source Requirements 1. Does the facility haunt facility -wide actual annual average natural gas throughput less than 0.65 MMscf/day AND a facility -wide actual annual average hydrocarbon liquid throughput less than 249.7 Small or Large Delp/ Determination , 2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 3.001747 MMscf per day (63.761)7 2b. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2 lb/yr (63.761)7 Small nehy Requirements 3. Did construction of the small glycol dehydration unit commence on or before August 23, 2011 (63.760(b)(1((I)(e) and (C)? 4. For thls small dehy, ka,control device required to meet the BTEX emission limit given by the applicable equation? (YouhalmIndicated that this =adonis nut subject to Major Source quin-mennsofMACTHit Subpart A, General provisions per 463.764 (a) Table 2 463.755 -mission Control Standards §63.773 -Monitoring 463.779-Recordkeeping §63.776- Reporting 40 CFR Part 63. Subpart MACT HHH. Natural Gas Transmission and Storage Facilities 1 Is the facility wide actual annual average natural gas throughput less than 0.9994051 MMccf/day and glycol dehydrators the only HAP emission source (63.1270(f))7 Small or Large Doh,/ Determination 2a. is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 9.994051 MMscf per day (63.1270(b()2))7 2b. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere lessthan 1,984.2 lb/yr (63.1270(6)(2))? Small Dehv Requirements 3. Did construction of the small glycol dehydration unit commence on or before August 23, 2011 (63.1270(b)(2) and (3) )7 4. For this small dehy, is a control device required to meet the era emission limit (standard?) given by the applicable equation? ea have Indicated that this motility is Ace subject to MACT Subpart A, General provisions per 463.1274 (a) Table 2 §63,1275 - Emissions Control Standards §63,1281 -Control Equipment Standards §63.1283 - inspection and Monitoring §63.1284-Recordkeeping 463.1285 -Reporting Colorado Regulation 7. Section XVII.n 1. Is the dehydrator subject to an emissions control requirement under MACTHH or HHH (Regulation 7, Section XVII.BS)? 2. Is this dehydrator located at a transmission/storage facility? 3. Is this dehydrator located at an oil and gas exploration and production operation, natural gas compressor station or gas processing plant (Reg 7, Section XVII.D.3)? 4. Was thisgiycol natural gas dehydrator constructed before May 1, 2015 (Reg 7 Section XVll.D.4.6)? Yes Inn yes Source Requires an APEN. Go to the next question Source Requires a permit Continue -You have indicated the attainment status on the Project Summary Sheet. Continue -You have indicated the facility type on the Project Summary Sheet. Go to the next question Dehydrator is subject to Regulation 7, Section XII.H Continue -Source is subject to MACT HH requirements. You have indicated the source category on the Project Summary Sheet. Go to MACT HH Area source applicability section Continue -You have Indicated the dehydrator type on the dehydrator inventory sheet. ge to the next question go to the next question - The dehy is subject to the Lopt requirements in 63,764(d)(2) DIEM EMI Continue - You have previously indicated this in the MACT section Continue -You have previously indicated this In the beginning of the MACT section Continue - You have previously Indicated this In the Reg 7, Section Xll determination Go to subquestion 4a.' • If constructed prior to May 1,2015, are uncontrolled actual emissions from a single glycol natural gas dehydrator equal to or greater than 6 tons per year VOC or 2 tpy VOC If the 4a. dehydrator IS located wIthin 1,320 feet of a building unit or designated outside activity area (Reg 7, Section XVIL0.4.b)7 S. If constructed on or after May 1, 2015, are uncontrolled actual emissions from a single glycol natural gas dehydrator equal to or greater than 2 tpy VOC (Regulation?, Section XVII,D.4.a(f Dehydrator is subject to Reguiutiun l,. Sactiun ct il, 0, 0.3 Section XVII.5—General Provisions for Alr Pollution Control Equipment and Prevention of Emissions Section XVII.D.3 - Emissions Reduction Provisions Alternative Emissions Control Motional sectlonl 6. Is this glycol natural gas dehydrator controlled by a back-up or alternate combustion device (La.. not the primary control device) that Is not enclosed? IThe tensed device for taxis dehydrator Is not subject to Regulotion;,Saction XViLR.2.e Section XV11.0.2.e—Altemative emissions control equipment Dtsclalmer This document assists operators with determining applicability of certain requirements of the Clean Air Act, ifs implementing regulations, and Air Quality Control Commission regulations. This document is note rule or regulation, and the analysis if contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change orsubstgute for any law, regulation, crony other legally binding requirement end is not legally enforceable. In the event of any conflict between the language of this document end the language of the Clean Air Act„ its implementing regulations, end Air Quality Control Commission regulations, the language of the statute ormguletlon will control. The use of non -mandatory language such as "recommend,""msy,""should,"and "can," is Intended to describe APCD interpretations and recommendations. Mandatory terminology such as 'must" and "required" are intended to describe controlling requirements under the terms of the Clean Air Act and Alr Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Source Is subject RICE Emissions Inventory Section 01- AdminzaaHve Information IFacilityA1Rs 1D: } iiiliiilMlfY..;9tti County Point Section 02- Equipment Description Details Detailed Emissions Un Desorption: Emission Control . Device Descnptlon: Requested NO% Control Efficiency %: Requested VOC Control Efficiency %: Requested CO Control Efficiency %: Requested HCHO Control Efficiency %: Requested Other HAP Control Efficiency%: Engine Manufacture Date: 3 3002 '. Manufacturer ,.1?I?ar i.ilie a°,n Model Number: I3O64'.GSIa Serial Number r19630}.p?,",°'. Engine Function 4GS155:0.14510/1 naturalgas£rednirtioclra rged, z ASRB ne nein , site rated .1,d00 P. Mt: en gl n shay c6 toyt r d INWCRlsyst chip -fu I t onaoi for natural gas mpress*un. 46, Denoting Mfg's Max. Rated Horsepower @ sea level: Horsepower sed for alcuattons: 1680 BSCF @ 100% Load btu/hp h i ',-,4'' 7876 Site - Rated B5CF @ 100% load (btu/hp-hr): 7876 Engine Type f� Other Parameters Aspiration Electrical Generator Max Site Rating (kw) 0. Max his/yr of Operation Section 03- Processing Rate Irdarreatlon for Emissions Estimates Fuel Use Rate @ 100% Load 147301.86667 scf/hr ACTUAL Annual Fuel Cption � ,„I?'1,�1 .....0-MMsd/yr MAX POTENTIAL Annual Fuel Consumption 128.788 MMscf/yr REQUESTED Annual Fuel Consumption 128.788 MMsd/yr Fuel Heating Value "--:: ...m'=:.9U6":btu/sct Section 04 - Emissions Factors re Methedoes Pollutant Uncontrolled Emission Factor NOx CO VOC PM" 1941E -0Z PM,. 1941E-02 SO2 5.880E-04 Formaldehyde Acetaldehyde 2.790E-03 Acmleln 2630E-03 Methanol 3.060E-03 Benzene 1580E-03 Toluene 5.580E-04 Ethylbenzene 2480E-05 Xylene 1950E-04 n -Hexane 0.000E+00 2,2,4-TMP 0.000E+00 1,3 -Butadiene 6.630E-04 Controlled Emission.Factor 1.500 1.500 0.750 his Ise new engine at this facility, so there Is no actual data. Uncontrolled Emissions 212.51 189.80 2433 Controlled Emissions 24.33 24.33 1217 Source g/hp-hr g/hp-hr g/hp-hr tpy tpy spy toy spy toy Nmmrgahcuer} ManWactueer'. 1941E-02 lb/MMBTU 112 tpy 1.12 toy 1941E-02 lb/MMBTU 1.12 toy 1.12 tpy 5.880E-04 lb/MMBTU 0.0a SPY 0.03 Spy 1200E-02 g/hp hr 1622.25 lb/yr 389.34 Ib/yr 1.395E-03 lb/MMBTU 323.39 lb/yr 16169 lb/yr 1.315E-03 lb/MMBTU 304,34 lb/yr 152.42 lb/yr a0 1.530E-03 Ib/MMBTU 354.68 lb/yr 177.34 lb/yr eY 7.900E-04 Ib/MMOTS 183.14 lb/yr 9137 lb/yr 3r 2790E-04 lb/MMBTU 64.68 lb/yr 3234 Ib/yr L2400-05 lb/MMBTU 287 lb/yr 144 lb/yr 303 9.750E-05 lb/MMBTU 22.60 lb/yr 11.30 lb/yr 4 0.000E+00 lb/MMBTU 0.00 lb/yr 0.00 lb/yr 3702 0.000E+00 lb/MMBTU 0.00 Ib/yr 0.00 lb/yr 3.315E-04 lb/MMBTU 76.85 lb/yr 38.42 lb/yr 3.666902235 0.419860306 3.275019553 0.419857507 0.419874302 '0.279937151 6.904E-02 6.934E-02 2101E-03 1.400E-02 3.359E-03 9.967E-03 4.944E-03 3.396E-03 4.698E-03 1.093E-02 . 5.466E-03 5.645E-03 2622E-03 1.933E-03-. 9.967E-04 8.360E-05 4.430E-05 6.906E-04 3.483E-04' 0.000E+00 D.OODEa00 0.000E+00 0.000E+00 2369E-03 1.1.84E-03 laWE1475.CP3xsm RICE Emissions Inventory. Section 05 - Regulatory Anahlsis Regulatory Requirements Regule0001 Section II.A.1- Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission Into the atmosphere of any air pollutant which is in excess of 20% opacity. Thy standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six, minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, AppendixA (July,1992)) in all subsections of Section II. A and B.ofthis regulation. Regulation 2 Section lA- No person, wherever located, shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential -or commercial purposes it is aviolation if odors are detected after the odorous air has been diluted wlh seven (7) or more volumes of odorfreealr. Regulation 3 Part A-APEN Requirements Criteria Pollutants:For criteria pollutants, Air Pollutant Emission Notice are required fon each individual mission point Ina non -attainment area with uncontrolled actual emissions of one ton per year or more of any Individual crteria pollutant (pollutants are not slimmed) for which the area Is non -attainment. Applicant is required. file an APEN since emissions exceed 1 ton per year VOC and NO. Part B —Construction Permit Exemptions • Applicant is required. obtain a permit since uncontrolled VOC and NOxemissions from this facility are greater than the 2.0 TPY threshold (Reg. 3, Part 8, Section I I.D.2.a) Regulakon7 Section )(1/1.8: These engines have a design rate greater than 500HP (reparted as 1380HP) and are located in the ozone non-ettainment area. Asa result, the engines are subject to the air pollution control technology requirements of Section XV1.B.1 for rich burnengines. The APENs submitted Indicate the engines are equipped with an Air/fuel ratio controller and a nonselective catalytic reduction system to control emissions. As such, the engine Is complying with this part of the regulation. Section )(VILE: According to Regulation 7 Section XVII.8.5: "internal combustion engines that are subject to an emissions control requirement Ina federal maximum achievable control technology ("MACT") standard under 40 CFR Part 63, a Bert Available Control Technology ("tACT") limit, ar a Neu/Source Performance Standard ("NSPS") under 40 CFR Part 60 are not subject to Section XVII., except forthe leak detection and repair requirements In Section XVII.E " This engine's not subject to emission comral requirements in MACT22M. As a resuk, it b subject to the requirements of Regulation 7 Section XVII.E. However, according to the operator, this engine was located In Colorado prior to 2002. As such, this engine Is not subject to the emission performance standards of table 2 in Section XVII.E.2.b. The engine is, however, subject to the requirements of Section XVII.E.3a. This section requires the engine to install and operate both a non -selective catalytic reduction system and an air fuel controller. According to the APEN, the engine is equipped with both and therefore meets the requirements of this section of the regulation. MACf2R2 This engine issubject to MALI' 2222. The facility IS an area source of HAP, so engine is notsubject to major source requiremenss. Since this engine Is located at an area source of HAP emissions and commenced construction prior to June 12, 2006, it's classified as an "Existing Stationary Rice." According to §63.6003(a): "If you own or operate an existingstationary RICE located at an area source of HAP emissions, you must comply with the requirements in Table 2.1 to this subpart and the operating limitations in Table 2h to this subpart that apply to you." Table 2b does not contain requirements for existing 45RB engines at area sources. Please see the discussion below In Section 06 for details of requirements for this englne in Table 2d. N5P511I1 Is this engine subject to NSPSJill?I I This engine was manufactured prior. 2002 and has not been modified or reconstructed. Since NIPS JJJI applies to engines that were manufactured after duly 1, 2007 (engines withmaximum power greater than or equal to 500 HP), N5PS JIJJ does not apply. this engine since it was manufactured pile(. that date. 11WE1475.CP3xlsm RICE Emissions Inventory Section 06 -Technical Analysis Notes Additional tas 1 A 160131 comjC cete§l mmur.i9r£Dand Nok TFiis 20092 Inal 10150,00l°°00fi2L. 07Z}CYol ol000hg;in6leMa:t1 tibsocx oso renorelae.M. using,' nafogeration orz ully,whkhey _ di CM 02,F60110Ur59f9P Ftn`9asCCIII ng nun emergenty519. ,LB d4§'R30%010 ec,elfC€witlri eomgligeoodotefor dl„io r+4ae pnrabeni5, 3033,0 oedrzmo nary 00004Fhasr(eset ngofm r fi 0pO011kratedar0i00ti 000004 000f006 n0 yhlfE'.veyi2s. O.imrenoorr6 op CQOR/0600 tanggim r the' J/qm of.Efff ta.4tobondryxlCE, 45R8slnSo_naty R100 _l0 „Itob OrIS aprnCO td«n5v500F 00410 AIRS Point # m fe:5105 hese grace. at0ry, anal. Process # SCC Code 007 01 alrs6 tnceth I'efiirad In MAGI ZZZZ.Accorair�gtotfi4 0561+1+0 orow scondAot&,,, lnlydal.Z, 604 heoe EIHIIif[ da$ of ,th040p og000moolo oTabie2d of MAE L6ll ul5 fop rip b nnuallf whioheyee cometinstiomlrapf d raplacads any Add tfen uy, §63.6603 rep9 £55h folimss IiC CI 1 d 3 a t nIo500 1plo d004es0so mesolHRamo'':st tth d ft `tt f tes[m oty. • erect more 0000nm0Rlc506derttn'ssubperf, Owners doperano'r t shn0000-e xgen0Y:x.., 'b]f10APth Ym OCOie def1hC3I0 gjrema000140mnany, 61010 §C6.eoA$ OfYhsoohpm11 J3of000thob 5 m keeprecord 0th hYief d lne4l fth af000 afth g fi t 6575 ftfi,s.vbpory rhaownerarnperamrmustEomg+ly10th M.16 re0 eelenisforezrsti cgs0€HAP that0000 emo sr nnba0141 6#l+t **iohh of the e0alaairom" - _ edwesm sahle60t MACr'.Z22L These woo pactic�are on 0o I0 trU600009jA a0 el0p476111 %y lUowelllaintleanoepltiSw HUcron coftroiprauticefor'm m gemrsalq p 1l a Ion f rf rm c¢sia'nd IMF 1 r� - m lssP blaaatlSeyi Pollutant PM10 PM2.5 NOx VOC CO Formaldehyde Acetaldehyde Acrolein Methanol Benzene Toluene Ethylbenzene Xylene n -Hexane 2,2,4-TMP 1,3 -Butadiene Uncontrolled Emissions Factor 0.019 0.019 3.66! 0.420 1275 5.00E-02 2.79E-03 253E-03 3.06E-03 1.58E-03 5.58E-04 2.48E-05 LOSE -04 0.00E+00 0.00E+00 6.63E-04 Control % 0.00% 0.00% 0055% 50.00% 87.18% 76.00% 50.00% 50.00% 50.00% 50.00% 50.00% 50.00% 50.00% 50.00% 10.00% 50.00% {tj,Cfiangeofl d ln revs rot 3ndflllf i0000ctoll Units b/MMBtu b/MMBtu b/MMBtu b/MMBtl. b/MMBtu b/MMBtu b/MMBtu b/MMBtu b/MMBtu b/MMBtu b/MMBtu b/MMBtU b/MMBtu b/MMBtu b/MMBtu b/MMBtu Section 09 - Inventory SCC Coding and Emissions Factors UWE147S.CP3.xlsm STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 PERMIT NO: DATE ISSUED: ISSUED TO: 11WE1475 CONSTRUCTION PERMIT DCP Operating Company, LP Issuance 3 THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural gas compression facility, known as the Libsack Compressor Station, located in Section 36, Township 6N, Range 65W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY. SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point C-185 C-187 003 One (1) Waukesha, ModelL7044GSI, Serial Number 5283701797, natural gas red, turbo -charged, 4SRB reciprocating internal combustion engine, site rated at 1680 horsepower at 1200 RPM. This engine shall be equipped with non -selective catalytic reduction (NSCR) system and air -fuel ratio control. This emission unit is used for natural gas. compression. One (1) Waukesha, Model L7044GS1, Serial Number 5283701843, natural gas -fired, turbo -charged, 4SRB reciprocating internal combustion engine, site rated at 1680 horsepower at 1200 RPM. This engine shall be equipped with non -selective catalytic reduction (NSCR) system and air -fuel ratio control. This emission unit is used for natural gas compression. One (1) Waukesha, Model L7044GS1, Serial Number 5283701844, natural gas -fired, turbo -charged, 4SRB reciprocating internal combustion engine, site rated at 1680 horsepower at 1200 RPM. This engine shall be equipped with non -selective catalytic reduction (NSCR) system and air -fuel ratio control. This emission unit is used for natural gas compression. AIRS ID: 123/9008 Page 1 of 29 NGEngine Version 2009-1 Colorado Department of Public- Health and Environment Air Pollution Control Division Facility Equipment ID AIRS Point Description C-188 004 One (1) Waukesha, Model L7044GSI, Serial Number 5283701845, natural gas -fired, turbo -charged, 4SRB reciprocating internal combustion engine, site rated at 1680 horsepower at 1200 RPM. This engine shall be equipped with non -selective catalytic reduction (NSCR) system and air -fuel ratio control. This emission unit is used for natural gas compression. D-1 005 One (1) Triethylene glycol (TE:) natural gas dehydration unit (Make: QB Johnson I oriel Glycol Contactor, Serial Number: 642012) with a ddesign capacity of 64 MMscf per day. This emissions unit is equipped with one (1) electric driven glycol pump (Make: Best Works Pump, Model: N/A) with a design capacity of 24 gallons per minute. This dehydration unit is equipped with a reboiler,''condenser, flash tank, and still vent. Emissions from the still vent are routed to a condenser and then to an enclosed combustor. During enclosed combustor downtime, emissions from the still vent are vented tothe atmosphere. The enclosed combustor has a maximum of 3% annual downtime. Emissions from the flash tank are routed directly to a vapor recovery unit (VRU) that recycles emissions back to the compressor station inlet During VRU downtime, flash ank emissions are routedvto the enclosed combustor. The VRU has a maximum 5% annual downtime. One (1) Waukesha Model: L7044 GSI SN: C-14610/1 natural gas fired, turbocharged, 4SRB reciprocating internal combustion engine, site rated at 1,680 HP. This engine shall be equipped with a non -selective catalytic reduction (NSCR) system and air -fuel ratio control. This emission unit is used for natural gas compression. Points 001-004, and 007: These engines maybe replaced with another engine in accordance with the temporary engine replacement provision or with another Waukesha L7044GSI engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. Point 005: The glycol pump may be replaced with another glycol pump in accordance with the provisions of the Alternate Operating Scenario (AOS) in this permit. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION AIRS ID: 123/9008 Page 2 of 29 Cdiorado Department of Public Health and Environment Air Pollution Control Division 1. Point 007: YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting-notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self - certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E),, 5. Point 007: The following information shall be provided to the Division within fifteen (15) days of the latter of commencement of operation or issuance of this permit. manufacture date construction date order date • . date of relocation into Colorado • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Regulation Number 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source: EMISSION LIMITATIONS AND RECORDS AIRS ID: 123/9008 Page 3 of 29 Colorado Department of Public Health and Environment Air Pollution Control Division 7. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4) Monthly Limits: Facility Equipment ID AIRS Point Pounds per Month Emission Type PM10 PM2.5 NOX VOC CO - C-167 007 204 204 4,145 2,073 4,145 Point Note: Monthly limits are based on a 31 -day month. The owner or operator shall calculate monthly emissions based on the calendar month. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 1,359 pounds per month. Facility -wide emissions of total hazardous air pollutants shall not exceed 3398 pounds per month. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Annual Limits: Facility Equipment ID AIRS Rent.,. Tons per Year Emission Type PM10 : PM , ;- " NO. '. VOC CO C-185 001 '' 1.2 1.2 8.1 11.4 16.2 Point C-18 002 1.2 1.2 8.1 11.4 16.2 Point C-187 003 12 ... 1.2 8.1 11.4 16.2 Point C''-188 'yam 0.04 1.2 1 8.1 11.4 16.2 Point D-1 005 --- --- 1.2 22.7 5.5 Point C-167 007 `' 1.2 1.2 24.4 12.2 24.4 Point See "Notes to Permit Holder #4 for information on emission factors and methods used to calculate limes„ Facility -wide emissionsjof each individual hazardous air pollutant shall be less than 8.0 tpy. Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required Compliance with the annual limits, for criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder AIRS ID: 123/9008 Page 4 of 29 Colorado Department of Public Health and Environment Air Pollution Control Division shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 8. Point 005: 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, vapor recovery unit (VRU) downtime, ECD downtime, flash tank temperature and pressure, wet gas inlet temperature and wet gas inlet pressure. Recorded operational values (except for gas throughput. VRU downtime, and ECD downtime) shall be averaged on a monthly basis for input into GRI GlyCalc. The actual uncontrolled emission rates for the flash tank and regenerator still vent generated from the corresponding month's GRI-GLYCaIc: model shall be converted to lb/MMscf based on the corresponding monthly total gas: throughput. These VOC and HAP emission factors (in Ib/MMscf) shall then be multiplied by the corresponding actual monthly throughput for each operating scenario (i.e. natural gas processed while still vent is routed to ECD, natural gas processed while still vent is routed to the atmosphere, natural gas processed while flash gas is routed to VRU, and natural gas processed while flash gas is routed to ECD) to calculate monthly emissions and to determine compliance with emission limits in this permit. Actual VOC and HAP emissions from the dehydration unit shall be the sum of total flash tank emissions plus total regenerator still vent emissions. Total flash tank emissions shall be the sum of emissions while flash gas is routedto VRU plus emissions while flash gas is routed to ECD. Total emissions from the regenerator still vent shall be the sum of emissions during ECD uptirne plus emissions during'ECD downtime (i.e. period of venting to atmosphere). 9. The owner otToperator shall track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility potential emission limitations as indicated 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 Pollution Emission Notice (APEN) or is permit exempt. (Regulation Number 3, Part C. II.E.) Total potential emissions from the facility, including all permitted emissions and potential to emit from all insignificant activities, shall be less than: • '10O tons per year of CO 10. The owner or operator shall operate and maintain the emission points in the table below with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled C-185 001 Non -selective catalytic reduction system and air/fuel ratio controller NOx, VOC, and CO AIRS ID: 123/9008 Page 5 of 29 Colorado Department of Public Health and Environment Air Pollution Control Division C-186 002 Non -selective catalytic reduction system and air/fuel ratio controller NOx, VOC, and CO C-187 003 Non -selective catalytic reduction system and air/fuel ratio controller NOx, VOC, and CO C-188 004 . > Non -selective catalytic reduction system and air/fuel ratio controller NOx, VOC, and CO D-1 005 Still Vent: Enclosed Combustor VOC and HAP Flash Tank: Recycled to plant inlet via VRU. Routed to enclosed combustor;.d'uring 5% VRU downtime. VOC and HAP C=167 007 Non -selective catalytic reduction system and air/fuel ratio controller NOx, VOC, and CO 11. Point 005: Except during VRU downtime, 100% of emissions that result from the flash tank associated with this dehydrator shall -be recycled to the compressor station inlet and recompressed in a closed loop system. During VRU downtime, 100% of emissions that result from the flash tank associated with this dehydrator shall be routed to an enclosed combustor. PROCESS LIMITATIONS AND RECORDS 12. This source shall be limited to the:following processing rates as listed below. Monthly records of the actual processing rateshall be:maintained by the owner or operator and made available to the Division for ;inspection upon'request. (Regulation Number 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment C-185 C-186 AIRS Point 001 002 Consumption of natural gas as a fuel - Consumption of natural gas as a fuel Consumption of natural gas as a fuel Consumption of natural gas as a fuel Annual Limit 128.8 MMscf 128.8 MMscf Monthly Limit (31 days) C-187 C-189, 003 004 128.8 MMscf 128.8 MMscf D-1 C-167 005 007 Total natural gas processed 23,360 MMscf Natural gas processed while flash tank waste gas is routed to the enclosed combustor. Natural gas processed while still vent waste gas is routed to the atmosphere. Consumption of natural gas as a fuel 1,168 MMscf 700.8 MMscf 128.8 MMscf 10.94 MMscf AIRS ID: 123/9008 Page 6 of 29 Colorado Department of Public Health and Environment Air Pollution Control Division The owner or operator shall monitor monthly process rates based on the calendar month. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. Points 001-004 and 007: Fuel consumption shall be measured by one of the following methods: individual engine fuel meter; facility -wide fuel meter attributed to fuel consumption rating and hours of operation; or manufacturer provided fuel consumption rate. Point 005: The owner or operator shall monitor monthly process rates based on the calendar month. The volume of gas processed shall be measured by gas meter or by assuming the maximum design rate of the dehydrator unit of 64 MMscf/day.: 13. Point 005: This unit shall be limited to the maximum lean`glycol circulation rate of 24 gallons per minute. The lean glycol recirculation rate shall be recorded daily in a log maintained on site and made available to the Division for inspection upon request. Glycol recirculation rate shall be monitored by one Of ,the following methods: assuming maximum design pump rate, using glycol flow meter(s), or recording strokes per minute and converting to circulation rate. This maximum glycol circulation rate does not preclude compliance with the optima glycol circulation. rate (Loft) provisions under MACT HH. (Regulation Number 3, Part B II " `• 14. Point 005: On a weekly basis, the owner or operator shall monitor and record operational values including: flash tank temperature and pressure and wet gas inlet temperature and pressure. These, records shall be maintained for a period of five years. 15. Point 005: The owner or operator shall monitor and record vapor recovery unit (VRU) downtime on a daily basis. VRU downtime shall be defined as times when the waste gas vented from the dehydrator flash tank is routed to the enclosed combustor rather than the VRU. The total hours of VRU downtime and the volume of gas processed during VRU downtime shall be recorded on a monthly basis. The operator shall demonstrate VRU downtime does not exceed five percent (5%) of total volume of gas processed on a rolling twelve (12) month total basis. 16. Point 005:%The owner or operator shall monitor and record enclosed combustor (ECD) downtime on a daily basis. ECD downtime shall be defined as times when the waste gas vented from the dehydrator still vent is routed to the atmosphere rather than the ECD. The total hours of ECD downtime and volume of gas processed during ECD downtime shall be recorded on a monthly basis. The operator shall demonstrate ECD downtime does not exceed three percent (3%) of total volume of gas processed on a rolling twelve (12) month total basis. STATE AND FEDERAL REGULATORY REQUIREMENTS AIRS ID: 123/9008 Page 7 of 29 Colorado Department of Public Health and Environment Air Pollution_Qorltrol Division 17. The permit number and AIRS ID number shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, III.E.) (State only enforceable). 18. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.1. & 4.) 19. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 20. This source 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. The following requirements were determined to be RACT for this source. Facility Equipment ID AIRS Point Pollutant RACT C-185 001 NOR, VOC Air -Fuel Ratio Controller and NSCR C-186 002 NOR, VOC Air -Fuel Ratio Controller and NSCR C-187 003 NOR, VOC . Air -Fuel Ratio Controller and NSCR C-188 004 NOR, VOC Air -Fuel Ratio Controller and NSCR D-1 005'' Still Vent: Enclosed Combustor VOC Flash Tank: Recycled to plant inlet via VRU. Routed to enclosed combustor during 5% VRU downtime. C-167 007 NOR, VOC Air -Fuel Ratio Controller and NSCR Waukesha Engines (Points 001-004 & 007)" 21 This equipment is subject to the control requirements for stationary and portable engines in the 8 -hour ozone, control area under Regulation Number 7, Section XVI.B.1. For rich urn reciprocating internal combustion engines, a non -selective catalyst reduction system and an air fuel controller shall be required. 22. Points' 001-004: This equipment is subject to the control requirements for natural gas - fired reciprocating internal combustion engines under Regulation No. 7, Section XVII.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 gfhp-hr NOx I CO I VOC AIRS ID: 123/9008 Page 8 of 29 Colorado Department of Public Health and Environment Air Pollution Control Division <100HP Any N/A N/A N/A ≥100HP and January 1, 2008 2.0 4.0 1.0 <500HP January 1, 2011 1.0 2.0 0.7 ≥500HP July 1, 2007 July 1,2010 2.0 1.0 4.0 2.0 1.0 0.7 Note: Per Regulation No. 7, Section XVII.B.4, internal combustion engines that are subject to an emissions control requirement in a federal maximum achievable control technology ("MACT") standard under 40 CFR Part 63, a Best Available Control Technology ("BACT") limit, or a New Source Performance Standard under 40 CFR Part 60 are not subject to this Section XVII. 23. Point 007: This equipment is subject to the requirements for natural gas -fired reciprocating internal combustion engines under Regulation Number 7, Section XVII.E.3 (State only enforceable). Any rich burn reciprocating internal combustion engine constructed or modified before February 1, 2009 with a manufacturer's name plate design rate greater than 500 horsepower shall install and operate both a non -selective catalyst reduction and an air fuel controller by Jury 1, 2010 The operator shall operate and maintain the air pollution control equipment to manufacturer specifications or equivalent to the extent practicable and shall keep manufactiker specifications on equivalent on file. Records of maintenance shall be kept on site or at a local field office with site responsibility, for Division review. Please note that replacements of this engine in accordance with the AOS in Attachment A may be subject to this or "other requirements in Regulation 7, Section XVII.E. TEG Dehydrator (AIRS Point 005) 24. This source is'subject to Regulation Number 7, Section XII.H. The operator shall comply with all applicable requirements of Section XII and, specifically, shall: Comply with the recordkeeping, monitoring, reporting and emission control requirements for"glycol natural gas dehydrators; and Ensure uncontrolled actual emissions of volatile organic compounds from the still vent and vent from any gas -condensate -glycol (GCG) separator (flash separator or flash tank), if present, shall be reduced by at least 90 percent on a rolling twelve- month basis through the use of a condenser or air pollution control equipment. (Regulation Number 7, Section XII.H.1.) 25. The combustion. device covered by this permit is subject to Regulation Number 7, Section XVII.B.2 General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: AIRS ID: 123/9008 Page 9 of 29 Colorado Department of Public Health and Environment Air Pollution Control Division • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 26. The glycol dehydration unit covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.D.3. Beginning May 1, 2015, still vents and vents from any flash separator or flash tank on a glycol natural gas dehydrator located at an oil and gas exploration and production operation, natural gas compressor station, or gas -processing plant subject to control requirements pursuant to Section XVII.D.4., shall reduce uncontrolled actual emissions of hydrocarbons by at least 95% on a rolling twelve-month basis through the use of a condenser or air pollution control equipment. 27. 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. If actual average emissions of benzene from the glycol dehydration unit process vent to atmosphere are greater than 0.90 megagram per year, as determined by the procedures specified in §63.772(b)(2) of this subpart, this source is subject to the area source requirements of 40 CFR, Part 63, Subpart HH including, but not limited to, the following; MACT HH Applicable Requirements Area Source Outside UA/UC boundary §63.760 — Applicability and designation of affected source §63.764 - General Standards AIRS ID: 123/9008 §63.760 (f) - The owner or operator of an affected major source shall achieve compliance with the provisions of this subpart by the dates specified in paragraphs (f)(1) and (f)(2) of this section. The owner or operator of an affected area, source shall achieve compliance with the provisions of this subpart by the dates specified in paragraphs (f)(3) through (f)(6) of this section. §63.760 (0(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 (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: gal TEG* F*(I—O)\ L„, =1.15*3.0 1bH2O 24hr/day1 Where: LOFT = Optimal circulation rate, gal/hr. F = Gas flowrate (MMSCF/D) I = Inlet water content (Ib/MMSCF) O = Outlet water content (Ib/MMSCF) 3.0 = The industry accepted rule of thumb for a TEG-to water ratio (gal TEG/IbH2O) Page 10 of 29 Colorado Department of Public Health and Environment Air Pollution Control Division 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—GLYCalcTM, Version 3.0 or higher. The owner or operator must document why the TEG dehydration unit must be operated using the alternate circulation rate and submit this documentation with the initial notification in accordance with §63.775(c}(7}. '` §63.764 (d)(2)(iii) — Maintain a record of the determination specified in paragraph (d)(2)(ii) in accordance with the requirements in §63.774(f) and submit the Initial Notification in accordance with the requirements in §63.775(c)(7). If operating conditions change and a modification to the optimum glycol circulation rate is required, the owner or operator shall prepare a new determination in accordance with paragraph (d)(2)(i) or (ii) of this section and submit the information specified under §63.775(c)(7)(ii) through (v). §63.774 (b) - Except as specified in paragraphs (c), (d), and (f) of this section, each owner or operator of a facility subject to this subpart shall maintain the records specified in paragraphs (b)(1)through (11) of this section: §63.774 (b)(1) - The owner or operator of an affected source subject to the provisions of this subpart shall maintain files of all information (including all reports and notifications) required by this subpart. The files shall be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report or period. §63.774 (b)(1)(i) — All applicable records shall be maintained in such a manner that they can be readily accessed. §63.774 - Recordkeeping §63.774 (b)(1)(ii)— The most recent 12 months of records shall be retained on Requirements site or shall be accessible from a central location by computer or other means that provides access within 2 hours after a request. §63.774 (b)(1)(iii) — The remaining 4 years of records may be retained offsite. §63.774 (b)(1)(iv) — Records may be maintained in hard copy or computer - readable form including, but not limited to, on paper, microfilm, computer, floppy disk, magnetic tape, or microfiche. §63.774 (f) - The owner or operator of an area source not located within a UA plus offset and UC boundary must keep a record of the calculation used to determine the optimum glycol circulation rate in accordance with §63.764(d)(2)(i) or §63.764(d)(2)(ii), as applicable. §63.775 (c) - Except as provided in paragraph (c)(8), each owner or operator of an area source subject to this subpart shall submit the information listed in paragraph (c)(1) of this section. If the source is located within a UA plus offset and UC boundary, the owner or operator shall also submit the information §63.775 — Reporting listed in paragraphs (c)(2) through (6) of this section. If the source is not Requirements 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 AIRS ID: 123/9008 Page 11 of 29 Colorado Department of Public Health and Environment Air Pollution Control Division 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 Oil and Gas Sector@epa.gov or via U.S. mail or other mail delivery service to U.S. EPA, Sector Policies and Programs Division/Coatings and Chemicals Group (E143—01), Attn: Oil and Gas Project Leader, Research Triangle Park, NC 27711. §63.775 (c)(7) - The information listed in paragraphs (c)(1)(i) through (v) of this section. This information shall be submitted with the initial notification. §63.775 (c)(7)(i) - Documentation of the source's location relative to the nearest UA plus offset and UC boundaries. This information shall include the latitude and longitude of the affected source; whether the source is located in an urban cluster with 10,000 people or more; the cistance 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 namesof the nearest urban cluster with 10,000 people or more and nearest urbanized area. §63.775 (c)(7)(ii) - Calculation of the optimum glycol circulation rate determined in accordance with §63.764(d)(2)(i). §63.775 (c)(7)(iii) - If applicable, documentation of the alternate glycol circulation rate calculated using GRI-GLYCalcTM, Version 3.0 or higher and documentation stating why the TEGdehydration unit must operate using the alternate glycol circulation rate. §63.775 (c)(7)(iv) - The name of the manufacturer and the model number of the glycol circulation pump(s), in operation. §63.775 (c)(7)(v) - Statement by a responsible official, with that official's name, title, and signature, certifying that the 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 reportshall 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. 28. 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 AIRS ID: 123/9008 Page 12 of 29 Colorado Department of Public Health and Environment Air Pollution Control Division Categories from Oil and Natural Gas Production Facilities. If actual average emissions of benzene from the glycol dehydration unit process vent to atmosphere are less than 0.90 megagram per year, as determined by the procedures specified in §63.772(b)(2) of this subpart, this source is subject to -the area source requirements of 40 CFR, Part 63, Subpart HH including, but not limited to, the following: MACT HH Applicable Requirements Area Source Benzene emissions exemption §63.764 - General Standards §63.772 - Test Methods, Compliance Procedures and Compliance Demonstration §63.774 - Recordkeeping Requirements §63.764 (e)(1) - The owner or operator is exempt from the requirements of paragraph (d) of this section if the criteria listed in paragraph (e)(1)(i) or (ii) of this section are met, except that the records of the determination of these criteria must be maintained as required in §63.774(d)(1). §63.764 (e)(1)(ii) — The actual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere are less than 0.90 megagram per year, as determined by the procedures specified in §63.772(b)(2) of this subpart. §63.772(b) - Determination of glycol dehydration unit flowrate or benzene emissions. The procedures of this paragraph shall be used by an owner or operator to determine glycoldehydration unit natural gas flowrate or benzene emissions to meet the criteria for an exemption from control requirements under §63.764(e)(1). §63.772(b)(2) -The .determination of actual average benzene emissions from a glycol dehydration unit shall be made using the procedures of either paragraph (b)(2)(i) or (b)(2)(ii) of this section Emissions shall be determined either uncontrolled, or with federally enforceable controls in place. §63.7720)(2)(i) — The owner or operator shall determine actual average benzene emissions using the model GRI-GLYCalc TM , Version 3.0 or higher, and the procedures presented in the associated GRI-GLYCalc TM Technical Reference Manual. Inputs to the model shall be representative of actual operating conditions of the glycol dehydration unit and may be determined using theprocedures documented in the Gas Research Institute (GRI) report entitled 'Atmospheric Rich/Lean Method for Determining Glycol Dehydrator Emissions" (GRI-95/0368.1); or §63.772(b)(2)(ii) - The owner or operator shall determine an average mass rate of benzene emissions in kilograms per hour through direct measurement using the methods in §63.772(a)(1)(i) or (ii), or an alternative method according to §63.7(f). Annual emissions in kilograms per year shall be determined by multiplying the mass rate by the number of hours the unit is operated per year. This result shall be converted to megagrams per year. §63.774 (d)(1) - An owner or operator of a glycol dehydration unit that meets the exemption criteria in §63.764(e)(1)(i) or §63.764(e)(1)(ii) shall maintain the records specified in paragraph (d)(1)(i) or paragraph (d)(1)(ii) of this section, as appropriate, for that glycol dehydration unit. §63.774 (d)(1)(ii) - The actual average benzene emissions (in terms of benzene emissions per year) as determined in accordance with §63.772(b)(2). OPERATING & MAINTENANCE REQUIREMENTS AIRS ID: 123/9008 Page 13 of 29 Colorado Department of Public Health and Environment Air Pollution Control Division 29. Points 001-005 and 007: Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 30. Point 007: A source initial compliance test shall be conducted to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emission limits in this permit. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time (Regulation Number 3, Part B., Section III.G.3) Oxides of Nitrogen using EPA approved methods. Carbon Monoxide using EPA approved methods. Volatile Organic Compounds using EPA approved methods. Periodic Testing Requirements 31. Points 001-004 and 007: ,,Each engine is subject to the periodic testing requirements as specified in the operating and maintenance (O&M) plan as approved by the Division. Revisions to your O&Mplan are subject. to Division approval. Replacements of this unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A. 32. Point 005: The owner or operator shall complete an extended wet gas analysis prior to theinlet 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 and be provided to the Division upon request. ALTERNATE OPERATING SCENARIOS 33. Point 005: The electric glycol pump may be replaced with another electric glycol pump in accordance with the requirements of Regulation 3, Part A, Section IV.A and without applying for a revision to this permit or obtaining a new construction permit. The maximum glycol recirculation rate of a replacement pump shall not exceed the glycol recirculation rate as authorized in this permit. Point 005: The owner or operator shall maintain a log on -site or at a local field office to contemporaneously record the start and stop dates of any pump replacement, the manufacturer, model number, serial number and capacity of the replacement pump. 35. Point 005: All pump replacements installed and operated per the alternate operating scenarios authorized by this permit must comply with all terms and conditions of this construction permit. AIRS ID: 123/9008 Page 14 of 29 Colorado Department of Public Health and Environment Air Pollution Control Division ADDITIONAL REQUIREMENTS 36. All previous versions of this permit are cancelled upon issuance of this permit. 37. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level repotted on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of V0C or NO. per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the fast 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 No later than 30 days before the existing APEN expires. [thin 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A. The ADEN shall include the specific manufacturer, model and serial number and., horsepower of the permanent replacement engine, the appropriate APEN filing fee and a cover letter explaining that the permittee is exercising an alternative -operating scenario and is installing a permanent replacement engine. e. 38. Federal regulatory program requirements (i.e. PSD, NANSR) 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 Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3 Part D). 39. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities major stationary source requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of Subpart HH. (Regulation Number 8, Part E) AIRS ID: 123/9008 Page 15 of 29 Colorado Department of Public Health and Environment Air Pollution Control Division 40. MACT Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of that Subpart on the date as stated in the rule as published in the Federal Register. (Regulation Number 8, Part E) GENERAL TERMS AND CONDITIONS: 41. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 42. If this permit specifically states that final authorization hasbeen 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 operationof this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation > or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has beenreviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operateare located in the Requirements to Self -Certify for Final Authorization section of this permit. 43. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 44. 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. 45. 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 arejection 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 b.y the Air Pollution Control ' Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 46. 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. AIRS ID: 123/9008 Page 16 of 29 Colorado Department of Public Health and Environment Air Pollution Control Division 47. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Harrison Slaughter Permit Engineer Permit History Issuance Date Description Issuance 1 November 21, 2011 Issued to DCP Midstream, LP Issuance 2 August 14, 2014 Issuance 3 AIRS ID: 123/9008 This Issuance Issued to DCP Midstream, LP. Increase in VOC emission limit for Point 006. Change the control device for Point 005 to an enclosed combustor. Issued permit as final. Source at a synthetic minor facility. Issued to DCP Operating Company, LP Point 005: Modification to increase permitted throughput from 18,250 MMscf/year to 23,360 MMtlscf/year. Add 5% annual VRU downtime during which flash tank emissions will be routed to the ECD. Add 3% annual downtime for ECD controlling the still vent. Point 007: Addition of new compression engine. Cancel point 006. Cancellation request received 05/01/15. Page 17 of 29 Colorado Department of Public Health and Environment Air Pollution Control Division Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working"' day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://vvww.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations AIRS Point Pollutant CAS # Uncontrolled mission ERate (Ib/yr) Are the ''; emissions reportable? Controlled Emission Rate (Ib/yr) 001 Formaldehyde 50000 ` 1 63 Yes 390 Methanol 67561 355 ` Yes 178 Acetaldehyde 75070 324 Yes 162 Acrolein 107028 305 Yes 153 Benzene 71432 184 No 92 1,3 -Butadiene 106990 77 No 39 Toluene 108883 65 No 33 Xylenes 1330207 23 No 12 Ethylbenzene 100414 3 No 2 002 Formaldehyde 50000 1,623 Yes 390 Methanol 67561 355 Yes 178 Acetaldehyde 75070 324 Yes 162 Acrolein 107028 305 Yes 153 Benzene 71432 184 No 92 1,3 -Butadiene 106990 77 No 39 Toluene 108883 65 No 33 Xylenes 1330207 23 No 12 Ethylbenzene 100414 3 No 2 AIRS ID: 123/9008 Page 18 of 29 Colorado Department of Public Health and Environment Air Pollution Control Division 003 Formaldehyde 50000 1,623 Yes 390 Methanol 67561 355 Yes 178 Acetaldehyde 75070 324 Yes 162 Acrolein 107028 305 Yes 153 Benzene 71432 184 No 92 1,3 -Butadiene 106990 77 No 39 Toluene 108883 65 N 33 Xylenes 1330207 23 Ni 12 Ethylbenzene 100414 3 0 2 004 Formaldehyde 50000 1,623 Yes 390 Methanol 67561 355 Yes 178 Acetaldehyde 75070 324 Yes 162 Acrolein 107028 05 Yes 153 Benzene 71432 184! No 92 1,3 -Butadiene 106990 77 No 39 Toluene 108883 .; 65 No 33 Xylenes 1330207,, 2 N 12 Ethylbenzene 100414 3 No 2 005 Benzene 71432 121,171 Yes 9,257 Toluene 108883 5,491 Yes 7,363 Ethylbenzene 100414 1,452 Yes 113 Xylenes 1330207 22,803 Yes 1,777 n -Hexane 110543 21,807 Yes 998 007 2,2,4- Trimethylpentane' Formaldehyde 0841 50000 45 1,623 No Yes 2 390 Methanol 67561 355 Yes 178 Acetaldehyde 75070 324 Yes 162 Acrolein 107028 305 Yes 153 Benzene 71432 184 No 92 1,3 -Butadiene 106990 77 No 39 Toluene 108883 65 No 33 Xylenes 1330207 23 No 12 Ethylbenzene 100414 3 No 2 AIRS ID: 123/9008 Page 19 of 29 Colorado Department of Public Health and Environment Air Pollution Control Division 5) The emission levels contained in this permit are based on the following emission factors: Points 001 through 004: CAS Pollutant Emission Uncontrolled lb/MMBtu Factors - g/bhp-hr Emission Controlled lb/MMBtu Factors — g/bhp-hr NOx 3.6669 13.1000 0.1400 0.5000 CO 3.2750 11.7000 i 0.2799 1.0000 VOC 0.4199 1.5000 " 0.1959 0.7000 PM2.5 1.94x10-2 6.93x10-2 1.94x10-2 6`.93x10-2 PM,o_ 1.94x10-2 6.93x10-2 1.94x10-2 6.93x10-2 50000 Formaldehyde 0.0140 0.0500 0.0034 0.0120 67561 Methanol 0.0031 0.0109 0.0015 0.0055 75070 Acetaldehyde 0.0028 0.0100 0.0014 0.0050 107028 Acrolein 0.0026 0.0094 0.0013 0.0047 71432 Benzene 0.0016 0.0056 0.0008 0.0028 106990 1,3 -Butadiene 0.0007 0.0024 0.0003 0.0012 108883 Toluene 0.0006 0.0020 0.0003 0.0010 Emission factors are based on a Brake -Specific Fuel Consumption Factor of 7876 Btu/hp-hr, a site - rated horsepower value of 1680, and a°fuel heat value of 9Q0 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer's specifications Manufacturer's specifications CO Manufacturer's specifications Manufacturer's specifications VOC _ . Manufacturer's specifications Manufacturer's specifications PM2_5 AP -42 Chapter 3 Table 3.2-3 AP -42 Chapter 3 Table 3.2-3 Mho AP -42 Chapter 3 Table 3.2-3 AP -42 Chapter 3 Table 3.2-3 50000 Formaldehyde Manufacturer's specifications Manufacturer's specifications 67561 Methanol AP -42; Table 3.2-3 (7/2000); Natural' Gas Manufacturer's specifications 75070 Acetaldehyde AP -42; Table 3.2-3 (7/2000); Natural Gas Manufacturer's specifications 107028 Acrolein AP -42; Table 3.2-3 (7/2000); Natural Gas Manufacturer's specifications 71432 Benzene AP -42; Table 3.2-3 (7/2000); Natural Gas Manufacturer's specifications 106990 1,3 -Butadiene AP -42; Table 3.2-3 (7/2000); Natural Gas Manufacturer's specifications 108883 Toluene ' AP -42; Table 3.2-3 (7/2000); Natural Gas Manufacturer's specifications Point 005: The emission levels contained in this permit are based on information provided in the application and the GRI GlyCalc 4.0 model. Controlled flash tank emissions are based on 100% control efficiency when emissions are routed to the VRU and 95% control when emissions are routed to the ECD during VRU downtime. The VRU has a maximum of 5% annual downtime. Controlled still vent emissions are based on 95% control efficiency when emissions are routed to the ECD and 0% control when emissions are routed to the atmosphere during ECD downtime. The ECD has a maximum of 3% annual downtime. The following, table summarizes the control efficiency for each scenario: AIRS ID: 123/9008 Page 20 of 29 Colorado Department of Public Health and Environment Air Pollution Control Division Control Scenario VOC Control Efficiency Still vent emissions routed to the ECD 95% Still vent emissions routed to atmosphere during ECD downtime. 0% Flash tank emissions routed to the VRU and recycled to the plant inlet. 100% Flash tank emissions routed to the ECD during VRU downtime. 95% Optimal recirculation rate per MACT HH (63.764(d)(2)(i)) is based on the following information submitted with the application: F = 64 MMscf/d; I = 100:91 lb/MMscf; and O = 6.7 lb/MMscf. Total actual combustion emissions are based on the sum of the emissions for the still vent and flash tank controlled by the ECD and the combustion of ECD pilot and assist fuel. Total combustion emissions are based on the following emissions factors: Still Vent Controlled by the ECD: CAS # Pollutant Uncontrolled Emission Factors lb/MMBtu Source NOx 0.068 AP -42 CO . 0.31 AP -42 Note: The permitted combustiorw.emissions are based on a' still vent waste gas heating value of 1,526 Btu/scf. Actual emissions are calculated based on the heat content and waste gas flow rate from the condenser vent stream in the monthly GlyCalc report and the hours per month the still vent waste gas is routed to the ECD. The heat content is calculated on a monthly basis using the composition of the condenser vent stream in the monthly GlyCalc report and the higher heating value of each component. Flash Tank Controlled by the ECD: CAS # Pollutant Uncontrolled Emission Factors lb/MMBtu Source NOx 0.068 AP -42 CO 0.31 AP -42 . Note: The permitted combustion. emissions are based on a flash tank waste gas heating value of 1,457 Btu/scf. Actual emissions are calculated based on the heat content and waste gas flow rate from the flash tank off gas stream in the monthly GlyCalc report and the hours per month the flash tank waste gas is routed to the ECD. The heat content is calculated on a monthly basis using the composition of the flash tank off gas stream in the monthly GlyCalc report and the higher heating value of each component. Combustion of ECD Pilot/Assist Fuel: CAS # Note: Pollutant Uncontrolled Emission Factors lb/MMBtu Source NOx 0.068 AP -42 CO 0.31 AP -42 The permitted combustion emissions are based on a heatin value of 900 Btu/scf. T g he pilot fuel and assist gas flow rates are constant. Actual emissions are calculated by multip ying the emissions factors in the table above by the heat content of the pilot/assist gas and the total fuel flow of the pilot gas and assist gas routed to the ECD. Permitted emissions are based on a constant pilot fuel flow rate of 50 scf/hr and a constant assist fuel flow rate of 3,000 scf/hr. AIRS ID: 123/9008 Page 21 of 29 Colorado Department of Public Health and Environment Air Pollution Control Division Points 007: CAS Pollutant Emission Uncontrolled Ib/MMBtu Factors - g/bhp-hr Emission Controlled lb/MMBtu Factors — g/bhp-hr NOx 3.67 13.10 0.42 1.50 CO 3.28 11.70 0.42 1.50 VOC 0.42 1.50 0.21 0.75 PM2.5 1.94x10-2 6.93x10-2 1_.94x10-2 6.93x10-2 PMio 1.94x10-2 6.93x10-2 1.94x10-2 6.93x10-2 50000 Formaldehyde 1.40x10-2 0.05 3.36x10-3 1.20x10-2 67561 Methanol 3.06x10-3 1.09x10-2 1.53x10-3 5.47x10-3 75070 Acetaldehyde 2.79x10-3 9.97x10-3 1.40x10-3 4.98x10-3 107028 Acrolein 2.63x10-3 9.40x1O-3 1.32x10-3 4.70x10-3 71432 Benzene 1.58x10-3 5.65x10-3 7.90x1.0-4 2.82x10-3 106990 1,3 -Butadiene 6.63x10-4 2.37x10-3 3.32x1O4 1.18x10-3 108883 Toluene 5.58x10-4 1.99x10-3 2.79x10-4 9.97x10-4 1330207 Xylenes 1.95x10-4 6.97x10-4 9.75x10-5 3.48x10-4 100414 Ethylbenzene 2.48x10-5 8.86x10-5 1.24x10-5 " 4.43x10-5 Emission factors are based on a Brake -Specific Fuel Consumption Factor of 7,876 Btu/hp-hr, a site -rated horsepower value of 1680, and a fuel heat value of 900 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer Manufacturer CO Manufacturer Manufacturer VOC Manufacturer Manufacturer PM2.5 AP -42 Chapter 3 Table 3.2-3 AP -42 Chapter 3 Table 3.2-3 PMio AP -42 Chapter 3 Table 3.2-3 AP -42 Chapter 3 Table 3.2-3 50000 Formaldehyde Manufacturer Manufacturer 67561 Methanol AP -42 Chapter 3 Table 3.2-3 AP -42 Chapter 3 Table 3.2-3 75070 Acetaldehyde AP -42 Chapter 3 Table 3.2-3 AP -42 Chapter 3 Table 3.2-3 107028 Acrolein AP -42 Chapter 3 Table 3.2-3 AP -42 Chapter 3 Table 3.2-3 71432 Benzene AP -42 Chapter 3 Table 3.2-3 AP -42 Chapter 3 Table 3.2-3 106990 1,3 -Butadiene , AP -42 Chapter 3 Table 3.2-3 AP -42 Chapter 3 Table 3.2-3 108883 Toluene AP -42 Chapter 3 Table 3.2-3 AP -42 Chapter 3 Table 3.2-3 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permt is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692- 3150. 7) The following equipment is currently exempt from construction permitting requirements and/or APEN reporting requirements based on information provided by the operator for the Division's analysis: AIRS ID Facility ID Description Notes NA TEG Reboiler TEG Dehy unit reboiler, rated at 2.86 MMBtu/hr This unit is exempt from APEN reporting requirements because the design rate is less than 5 MMBtu/hr (Regulation No. 3, Part A, II,D.1.k), and is therefore also AIRS ID: 123/9008 Page 22 of 29 Colorado Department of Public Health and Environment Air Pollution Control Division exempt from construction permitting requirements (Regulation no. 3, Part B, II.D.1.a). Criteria pollutant emission levels for this unit are based on factors from AP -42, Chapter 1.4, Small Boilers < 100 MMBtu/hr (7/1998). 8) Points 001-004: Each engine is subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal Register posting — effective March 18, 2008). This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA website at: http://www.epa.qovittn/atw/areafir18ra08.pdf 9) Points 001-004: Each engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Jnternal Combustion Engines. (See January 18, 2008 Federal Register posting - effective March 18, 2008). ; The January 18, 2008 amendments to include requirements for area sources and engines < 500 hp, located at major sources have not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 8. A copy of the complete subpart is available on the EPA website at: http://www.epa.gov/ttn/atw/area/fr18ia08.pdf Additional information regarding area source standards can be found on the EPA website at: http://www.epa.aov/ttn/atw/area/arearules.html 10) Point 007: This engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines (See August 20, 2010 Federal Register posting - effective October 19, 2010). The August 20, 2010 amendments to include requirements for existing engines located at area sources and existing engines < 500 hp located at major sources have not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 8. A copy of the complete subpart is available on the EPA website at: http://www.epa.qov/ttn/atw/ricelfr20au10.pdf Additional information regarding area source standards can be found on the EPA website-at: http://w‘ow.epa.qovittn/atriviarea/arearules.html 11) This facility is classified as follows Applicable Requirement Operating Permit Synthetic Minor Source of: CO, VOC, NOx, Benzene, Toluene, Xylene, n -Hexane and Total HAPs NANSR Synthetic Minor Source of: CO Synthetic Minor Source of: VOC, NOx MACT HH., Area Source Requirements MACT ZZZZ Area Source Requirements 12) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A — Subpart KKKK NSPS Part 60, Appendixes Appendix A — Appendix I AIRS ID: 123/9008 Page 23 of 29 Colorado Department of Public Health and Environment Air Pollution Control Division Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A — Subpart Z MACT 63.600-63.1199 Subpart AA — Subpart DDD MACT 63.1200-63.1439 Subpart EEE — Subpart PPP MACT 63.1440-63.6175 Subpart QQQ — Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ — Subpart MMMMM MACT 63.8980 -End Subpart NNNNN — Subpart XXXXXX AIRS ID: 123/9008 Page 24 of 29 Colorado Department of Public Health and Environment Air Pollution Control Division ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS' RECIPROCATING INTERNAL COMBUSTION ENGINES October 12, 2012 2. Alternative Operating Scenarios The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility -Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation Na.. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and itrhas been found to meet all applicable substantive and procedural requirements. This permit incorporates a"nd;shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS, and the owner or operator shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with an engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary' is defined as in the same service for 90 operating days or less in any 12 month period. "Permanent" is defined as in " the""same service for more than 90 operating days in any 12 month period. The 90 days is the total number ofdays that : the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90 day total. The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance, demonstrations or periodic monitoring required by this permit. All replacement engines are subject two all federally applicable and state -only requirements set forth in this permit (including monitoring and recorei keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5) years and made available to the Division upon request. The owner or operator shall maintain a log on -site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that . are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the owner or operator shall maintain !a copy of all Applicability Reports required under section 2.1.2 and make them available to the Division upon request. 2.1.1 The owner or operator may temporarily replace an existing engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifyingthis permit, so long as the temporary replacement engine complies with all permit limitations and other requirements applicable to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. AIRS ID: 123/9008 Page 25 of 29 Colorado Department of Public Health and Environment Air Pollution Control Division 2.1.2 The owner or operator may permanently replace the existing engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found at https://www.colorado.gov/pacific/cdphe/alternate-operating-scenario-aos- reporting-forms. This submittal shall be accompanied by a certification from the Responsible Official indicating that "based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements.' Note that the testing required by this Condition maybe used to satisfy the periodic testing requirements specified by the permit for the relevant time period (ie. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve 'as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at: https://www.colorado.aov/pacific/sites/default/files/AP Portable-Analyzer-Monitoring-Protocol.pdf Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever applies. AIRS ID: 123/9008 Page 26 of 29 Colorado Department of Public Health and Environment Air Pollution Control Division For comparison with a short-term limit that is either input based (Ib/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine will be subject to, the results of the test shall be converted to the appropriate units as described in the above -mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline. 2.3 Applicable Regulations for Permanent Engine Replacements 2.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B § II.D.2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control. Technology (RACT) for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and to NOX and SO2, as precursors, to. PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr. For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating internal combustion engines: VOC: The emission limitations in. NSPS JJJJ CO: The emission limitations in NSPS JJJJ. NOX: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (§ 60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State - Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified below: Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non -selective catalyst and air fuel controller to reduce emission. Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. AIRS ID: 123/9008 Page 27 of 29 Colorado Department of Public Health and Environment Air Pollution Control Division The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. Emission Standards: -Section XVII.E — State -only requirements Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Max Engine HP Construction or Relocation Date Emission Standards in G/hp-hr NOx CO VOC 100<Hp<500 January 1, 2008 January 1, 2011 2.0 1.0 500≤Hp July 1, 2007 July 1,2010 2.0 1.0 4.0 2.0 1.0 0.7 4.0 2.0 The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. 2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean bum enginesgreater than or equal to 500 hp and less. than 1,350 hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required by NSPS' Subpart JJJJ can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2 2 Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ requirements). However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, § 1.8 (which is referenced in Part A),any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. 2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR. Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required AIRS ID: 123/9008 Page 28 of 29 Colorado Department of Public Health and Environment Air Pollution Control Division under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. 2.4 Additional Sources The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site; an engine that is being installed as an entirely new emission point and not as part of an AOS-approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. AIRS ID: 123/9008 Page 29 of 29 RECEIVED 1,92011 Siatioeary Sources Glycol Dehydration Unit APEN - Form APCD- Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for Glycol Dehydration (Dehy) Units only. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if the specialty APEN options wil not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 11 WE 1475 AIRS ID Number: 123 / 9008 / 005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification: D-1 - TEG Dehydration Unit [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': DCP Operating Company, LP Site Name: Libsack Compressor Station Site Location: Section 36, Township 6N, Range 65W Mailing Address: (Include Zip Code) 370 17th Street, Suite 2500 Denver, CO 80202 E -Mail Address2: RShankaran@DCPMidstream.com Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Roshini Shankaran Phone Number: 303-605-2039 Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-202 - Glycol Dehydration Unit APEN - Revision 02/2017 364782 COLORADO 1 I atPhec xewnn 4E WUCp1MYH Permit Number: 11 WE1475 AIRS ID Number: 123 /9008/ 005 [Leave blank unless APCD has already assigned a permit it and AIRS ID] Section 2- Requested Action ❑ NEW permit OR newly -reported emission source -OR- ❑✓ MODIFICATION to existing permit (check each box below that applies) 0 Change fuel or equipment ❑ Change company name 0 Add point to existing permit ❑✓ Change permit limit ❑ Transfer of ownership3 0 Other (describe below) OR - • APEN submittal for update only (Please note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - [I Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: TEG dehydration unit for water removal Facility equipment Identification: For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: D-1 6 /07 /2013 / / ▪ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area Is this unit located at a stationary source that is considered a Major Source of (HAP) Emissions Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 days/week Yes Yes O 0 weeks/year No No ®COLORADO 2 I - r,==, Permit Number: 11 WE 1475 AIRS ID Number: 123 /9008/ 005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Dehydration Unit Equipment Information Manufacturer: Dehydrator Serial Number: Glycol Used: QB Johnson 642012 0 Ethylene Glycol (EG) Model Number: Glycol Contactor Reboiler Rating: 2.86 DiEthylene Glycol (DEG) Glycol Pump Drive: El Electric ❑ Gas If Gas, injection pump ratio: Pump Make and Model: Best Pump Works / SN: 6123355002 Glycol Recirculation rate (gal/min): Max: Lean Glycol Water Content: 1.0 24.0 Wt.% El (TEG) Requested: 24.0 # of pumps: MMBTU/hr TriEthylene Glycol Acfm/gpm 1 Dehydrator Gas Throughput: Design Capacity: 64 MMSCF/day Requested: 23,360 MMSCF/year Actual: 13,184 MMSCF/year Inlet Gas: Water Content: Flash Tank: Pressure: Wet Gas: Pressure: 46 Cold Separator: Pressure: Stripping Gas: (check one) ❑✓ None El Flash Gas 0 Dry Gas ❑ Nitrogen EInsj psig Flow Rate: scfm lb/MMSCF psig psig Temperature: ❑✓ Saturated Temperature: Temperature: 116F Dry gas: b lb/MMSCF 140 °F °F O p NA NA Additional Required Information: ❑✓ Attach a Process Flow Diagram ❑✓ Attach GRI-GLYCalc 4.0 Input Report Et Aggregate Report (or equivalent simulation report/test results) ❑Q Attach the extended gas analysis (including BTEX Et n -Hexane, temperature, and pressure) V,cd1,►.,xs ?cc aokaeka a na+l. Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 41 -DS Illlol�l- ®® .COLORADO 3 I o.Paw�.ndwnu� - HaaW B EmitOelmanl Permit Number: 11 WE1475 AIRS ID Number: 123 /9008/ 005 [Leave blank unless APCD has already assigned a permit /t and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.446123 / -104.604122 r ® rA har "e etg o e G ound Leuel �Feet P ern Fl.w ° ( C ` e y ocit �( 7set 3 D-1 30.0 Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Upward with obstructing raincap ❑✓ Circular Interior stack diameter (inches): 48.0 ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 COLORADO 4 ;�Prnd H<+.i�h B Envirrmmani Permit Number: 11WE1475 AIRS ID Number: 123 /9008/ 005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information ❑ Condenser: Used for control of: Type: Make/Model: Maximum Temp Average Temp Requested Control Efficiency % ❑✓ VRU: Used for control of: Flash Tank Vapors Size: Make/Model: Requested Control Efficiency 95.0 VRU Downtime or Bypassed 5.0 ❑ Combustion Device: Used for control of: Still Vent Stream Rating: MMBtu/hr Type: Enclosed Combustor Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: Make/Model: 95.0 98.0 % Leed Waste Gas Heat Content Btu/scf Constant Pilot Light: ❑✓ Yes O No Pilot burner Rating 0.05 MMBtu/hr Closed ❑ Loop System: Used for control of: Description: System Downtime 0 o' ✓❑ Other: Used for control of: Description: Control Efficiency Requested Flash Tank Vapors during VRU downtime (5.0%) ECD Combustion Device 95.0 * ECD combustion device used for still vent control has a 3.0% annual downtime for maintenance and repairs. Still vent emissions will vent to atmosphere during periods of ECD downtime. Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 COLORADO 5l ®l tf.17wh ', Hw1ch BE�wYumm.n� Permit Number: 11 WE1475 AIRS ID.Number: 123 / 90081 005 PM PM [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency (% reduction): Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) SOX NO„ CO VOC HAPs Other: Vapor Recovery Unit / Enclosed Combustor Vapor Recovery Unit / Enclosed Combustor ICO10 / 95% trek if 95% From what year is the following reported actual annual emissions data? 2016 Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Uncontrolled Emission Factor` Emission Factor Units Emission Factor Source (AP -42, Mfg. etc) nnual Emissio ueste mission Controlled (Tons/year) Uncontrolled (Tons/year) Controlled5 (Tons/year) Uncontrolled (Tons/year) SOX NOx 0.068 • I b/M M Btu AP -42 0.1 0.1 I.� l.z CO 'ems 0.3� Ib/MMBtu AP -42 0.4 0.4 5•K� VOC Ib/MMscf GLYCaIc 101.5 2.4 559. l� 72.(02. Benzene Toluene lb/MMscf Ib/MMscf GLYCaIc GLYCaIc 12.8 10.5 0.6 0.5 bo-5q Ethylbenzene Xylenes 10.2()cloZ °r,1-k.cKi6l Ib/MMscf lb/MMscf GLYCaIc GLYCaIc 0.2 2.7 0.01 0.1 o. ll.y O.Oto 0. n -Hexane 3.1,(14' Ib/MMscf GLYCaIc 1.9 0.04 O 2,2,4- Trimethylpentane Other: 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 5Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 atVCI4ea ewai �. 14 (( c vq 17 — COLORADO 6 H`f,.(I� :uh ,man, Permit Number:. 11 WE1475 AIRS ID Number: 123 /9008/ 005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. 6/16120 Signature of Legally Authorized Person (not a vendor or consultant) Date Roshini Shankaran Environmental Engineer Name (please print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance ❑✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) Send this form along with $152.90 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 A,- COLORADO 7 I H.1th S vh wain Huiah BEnvhanmam Reciprocating Internal Combustion Engine APEN - Form APCD-201 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for reciprocating internal combustion engines (RICE). If your engine is a diesel compression ignition engine or your emission unit does not fall into the RICE category, there may be a more specific APEN for your source (e.g. diesel compression ignition engine, mining operations, asphalt plant, crusher, screen, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 11WE1475 AIRS ID Number: 123 /9008 / 001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': DCP Operating Company, LP Site Name: Libsack Compressor Station Site Location: Section 36, Township 6N, Range 65W Mailing Address: (Include Zip Code) 370 17th Street, Suite 2500 Portable Source Home Base: Denver, CO Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Roshini Shankaran Phone Number: 303-605-2039 E -Mail Address2: RShankaran@DCPMidstream.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 11/2016 364783 �. COLORADO 1 H N T }NI Permit Number: 11 WE1475 AIRS ID Number: 123 /9008 / oo4., [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ✓❑ NEW permit OR newly -reported emission source (check one below) ❑✓ STATIONARY source ❑ PORTABLE source ❑ Request coverage under a Construction Permit ❑ Request coverage under General Permit GP023 (Natural Gas Only) If coverage under General Permit GP02 is requested, an additional fee of $1,500.00 is required in lieu of hourly fees. -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment 0 Change company name 0 Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ APEN submittal for permit-exempt/grandfathered source ❑ Notification of Alternate Operating Scenario (AOS) permanent replacements Additional Info Et Notes: 3 Only one engine may be reported per APEN for GP02 coverage. Coverage under GP02 is voluntary. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. 5 GP02 fee is not required, but APEN filing fee is required. Section 3 - General Information Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3, etc)? If yes, provide the Company Equipment Identification No. C-167 General description of equipment and purpose: RICE for Natural Gas Compression For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? (http: / / www.colorado.gov /cdphe/attainment) TBD ❑✓ Yes ❑ No Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Seasonal use percentage: Dec -Feb: 25% Mar -May: 25% June -Aug: 25% Sept -Nov: 25% 1 Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 11/2016 COLORADO 2 I ' Cpm+mmrt of noh& Permit Number: 11 WE1475 AIRS ID Number: 123 /9008 / 0O-4, [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Engine Information Engine Function: ❑ Primary and/or Peaking ❑ Pump ❑ Water Pump ❑ Emergency Back-up O Other: 0 Compression What is the maximum number of hours this engine will be used for emergency back-up power? hours/year Engine Make: Waukesha Engine Model: L7044 GSI Serial Number6: C-14610/1 What is the maximum designed horsepower rating? 1,680 hp What is the engine displacement? 9.58 l/cyl What is the maximum manufacturer's site -rating? 1,680 hp kW What is the engine Brake Specific Fuel Consumption at 100% Load? 4, 876 BTU/hp-hr Engine Features: "DS I�f Cycle Type: ❑ 2 -Stroke ❑✓ 4 -Stroke Combustion: ❑ Lean Burn El Rich Burn Ignition Source: ❑✓ Spark ❑ Compression Aspiration: ❑ Natural El Turbocharged Is this engine equipped with an Air/Fuel ratio controller (AFRC)? ✓❑ Yes ❑ No If yes, what type of AFRC is in use? ❑✓ O2 Sensor (mV) LINO Sensor (ppm) ❑ Other: Is this engine equipped with a Low-NOX design? ❑ Yes ❑✓ No Engine Dates: What is the manufactured date of this engine? <2002 What date was this engine ordered? <2002 What is the date this engine was first located to Colorado? NA What is the date this engine was first placed in service/operation? NA What is the date this engine commenced construction? <2002 What is the date this engine was last reconstructed or modified? Is this APEN reporting an AOS replacement engine? ❑ Yes ✓❑ No If yes, provide the make, model, and serial number of the old engine below: Engine Make: Engine Model: Serial Number: 6 The serial number must be submitted if coverage under GP02 is requested. Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 11/2016 COLORADO 3 1 AMY =17,=, -5, Permit Number: I1 WE1475 AIRS ID Number: 123 /9008 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.446123 / -104.604122 Operator Stack ID No Discharge Height Above Ground Level (Feet} Temp ( F) Flow Rate (ACFM) velocity t/ (fsec} C-167 40.0 1,152 9,662 205 Indicate the direction of the Stack outlet: (check one) ✓❑ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular ❑ Square/Rectangle ❑ Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap 12.0 Interior stack diameter (inches): Interior stack depth (inches): Section 6 - Fuel Data and Throughput Information Fuel Use Rate @ 1OO% Load SCF/hour) Actual Annual Fuel Use y (MMSCF/year) Requested Annual Permit Limit1 (MMSCF! year 125.1a ,°I5,,% 14;270 `��'$O1. From what year is the actual annual amount? Indicate the type of fuel used: ❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf) ❑✓ Field Natural Gas Heating value: g00 BTU/scf ❑ Propane (assumed fuel heating value of 2,300 BTU/scf) ❑ Landfill Gas Heating Value: BTU/scf ❑ Other (describe): Heating Value (give units): 4 -DS ►11iNpIr� 7 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 8 If fuel heating value is different than the listed assumed value, provide this information in the "Other" field. Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 11/2016 4 COLORADO Department of _AWalic j8?I. Ftvhonmunt na Permit Number: 11WE1475 AIRS ID Number: 123 /9008 / 061 - [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission calculations. Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No If yes, describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Primary Control Equipment Description Overall Requested Control . . Efficiency (% reduction in emissions) TSP (PM) PM10 PM2.5 SOX NOx NSCR 86Va. ':,.,.. VOC NSCR 50% CO NSCR .84 %I. 2. Other: NSCR Formaldehyde - 76%, Other HAPs - 50% Use the following tables to report criteria and non -criteria pollutant emissions from source: (Use the data reported in Section 6 to calculate these emissions.) From what year is the following reported actual annual emissions data? ..... Criteria Pollutant Emissions Inventory .: Pollutant Emission F actor Actual Annual Emissions e Requested Annual Permit EmissionLimy t(s)7 ' Uncontrolled Basis Units , . Source ` • (AP -42; : Mfg. etc). Uncontrolled Emissions , (Tons/year) . Controlled • Emissions (Tonslyear) Uncontrolled "' Emissions . (Tons/year) Controlled : Emissions (Tons/year'),...` TSP (PM) 1.94E-02 lb/MMBtu AP -42 1.17 1.11. PM10 1.94E-02 lb/MMBtu AP -42 1.12. 1.1 2, PM2.5 1.94E-02 Ib/MMBtu AP -42 1.1Z 1.12. SOX 5.88E-04 lb/MMBtu AP -42 0.03 0.03 NOx A.e. ill g/hp-hr Manufacturer 4.7,6.6, iti l5l 24.315 VOC 1.5 g/hp-hr Manufacturer 24.3 12.2 CO e. II`, y. g/hp-hr Manufacturer ,dam tsi.cg 24.33 Does the emissions source have any uncontrolled actual emissions of non -criteria ❑✓ .Yes ❑ No pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? If yes, please use the following table to report the non -criteria pollutant (HAP) emissions from source: Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number . Emission Factor ; Actual Annual Emissions9 Uncontrolled Basis Units 3(hp-hr lb/MMBtu Source (AP, -42 ,. Mfg. etc) Uncontrolled Emissions (Pounds/year) Controlled Emissions (Pounds/year). Formaldehyde 50000 O.uS w1E5. lbZ2•.S 371.3 Acetaldehyde 75070 2.79E-03 AP -42 434.00 3,2,3A 4,,,, 11,91.7• Acrolein 107028 2.63E-03 Ib/MMBtu AP -42 &64 so.t.1 1'484 lea.6'i Benzene 71432 1.56E-03 Ib/MMBtu AP -42 T949K3,144.G ql,`g Other: Methanol 67561 3.06E-03 Ib/MMBtu AP -42 84" 1543 47.2-2 177.1 7 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 9 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. HOS itliko�l Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 11/2016 5 COLORADO iioltb Era itbt,m,n, Permit Number: 11 WE1475 AIRS ID Number: 123 /9008 / U64_ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage under general permit GP02, I further certify that this source is and will be operated in full compliance with each condition of general permit GP02. KI 6/I 6(2or} Signature of Legally Authorized Person (not a vendor or consultant) Date Roshini Shankaran Environmental Engineer Name (please print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 (if applying for GP02 For more information or assistance call: submit with an additional $1500), to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: Make check payable to: https://www.colorado.gov/cdphe/apcd Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 11/2016 AV COLORADO 6 5= NnYh bEwh�onm�nt Hello