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Home My WebLink About20171608.tiffEXHIBIT INVENTORY CONTROL SHEET Case 5MJUSR17-83-542 - DCP OPERATING COMPANY, LP Exhibit Submitted By Description A. Planning Commission Resolution of Recommendation B. Planning Commission Summary of Hearing (Minutes dated 5/16/2017) C. Planning Services PowerPoint Presentation D. Terry Dechant Decibel Readings 5/31/2017 E. Eric Ewing Packet of Information re Air Pollution 5/31/2017 Handout re Oil & Gas Noise Reduction Barriers F. Unknown (submitted 5/31/2017) G. Applicant Community Meeting Information (submitted 6/8/2017) H. Shirley Johnson Letter of Opposition (dated 7/7/2017) I. Applicant Community Meeting Letter (dated 6/12/2017) J. Rochell Sherman Letter of Objection (dated 7/12/2017) K. Rockelle Rissler Letter of Objection (dated 7/13/2017) Randy and Cindy L. Clement Letter of Objection (dated 7/13/2017) M. Fred Krumpeck Letter of Objection (dated 7/13/2017) N . Jill Lafferty Letter of Objection (dated 7/13/2017) O. Eric Ewing Letter of Objection/Packet (dated 7/13/2017) Letter/Objection to Community Meeting (dated P. Jill Lafferty 7/13/2017) Q. Jill Lafferty Documentation of Flare Events (7/13/2017) R. Scott Sherman Info re Compressors and Sound (7/13/2017) S . Scott Sherman Audio Files of Community Meeting (7/13/2017) T. Juanita Stockwell -Carlson Letter of Opposition (dated 7/14/2017) U . Applicant Presentation from Community Meeting (7/14/2017) V. Applicant CDPHE Construction Permit (Air Emissions) W. Neil Ray Letter of Support from Vital For Colorado 2017-1608 X. Eric Ewing Handouts from DCP Y. Scott Sherman Pictures of "T -Wall" example Z. Chad Calvert Letter of Support from Noble Energy AA. County Attorney Revisions AB. Applicant Correspondence with SPO re next meeting 2017-1608 rile:\ td r . /,` l' / 7 ✓ t J' ngs concerning this property wi ounty Planning Commission and • HYYtv of County Commissioner. Ent %-, hearing ., . <, ...., . WELD COUNTY ADMI STRATTON BUILDIN 1150 "Q" Street • Greeley. -.00 80631 4i CM�P, , .Lee A Site Specific Development Plan and 5th Amended Use by Special Review Permit No. USR- 542 for Mineral Resource Development Facilities, Oil and Gas Support and Service. (Natural Gas Processing facility, the addition of gas processing equipment and one (1) up to one hundred (100) feet in height secure communications tower in the A (Agricultural) Zone District. (DCP Operating Company, LP — Mewbourn Gas Plant) u.-•• a'it Y .w• •:- Y••'•�.r : rtd - f-4, . ' �.«��. -a. -al i_vra,.t ricit.111-57-21Z•!_ 'i 4, !a-� .. sr,. r • Y • — a..? $ . 9)..... �� ,„ sortairrr 1. F ■Fr 'EOrr,. . - i flyer SR ' t r _as." 4 - ■ J - to • F ° ":' r a • al' 4 OA. r r srl• d rIvr e , A�♦ • yAr irle N r - ! r� '•"n' joOlieC is. . ° — -' N am . ' a y . _ F r atscar ..C;b1"!. :14;41#1.6irra_t: ram.: - JECti • ra...Hrit: I « Sf -Jr i r_ a- 4 i i • a.. •-1 4 ft ma • • A • 4 i i r • 4 EB t',e ' N r • _s J N ilt 144-1...... • •9 • l Mewbburn Plant Offices, southwest of Main Gate a • is 4 s w 1R A.. -z.. a'•�FL.e- ti 4 Y "El •• s 'MIL . 4- -10.; : vas t r w ' Pitt it a - s - a -R It 4"-i, • • • ir• # i View from County Road 38 looking northeast, SPO a J + 1 Y r • • r s I' at • a_S-Do. t �', i• S a. . r "L „is N�. � - k - r 22, I. I I. I p i -r di 3 '' a. J< I • I I ♦ r !!% r..'r.- t 4 a I r I • Sid 1 I II • ■ ■ a f r ,.--a . r : — sit-. f. =i aarrar • TT s� - a a I 1 to -East on County Road 38, SPCA on ridge taw lif4rtira ailt lb, al. ita ,+ _ R ..� ��!1��, al r u - A.a' b, inleajak • it Pa' • `5 n. r r s. a 1. .a:_ View to west across land associated with the proposed Mewbourn Gas Plant View North from County Road 36 and County Road 35 r I • A it 1, I • acet v- isissitat a -* 40-a4V ir•` I- LA"kir 2 u 4_ .' at 1 • • 4 is tis ____ SEISE- --� • n.. South toMewbourn • u t. • Don and Terri Dechant 18488 WCR 33, LaSalle, CO 80645 970.302.1798 terridechant@yahoo.com 5/30/17 Weld County Department of Planning Services Case tt/ Record U: 5MJUSR17-83-542 1555 N 17`h AVE, Greeley CO 80631 To Whom It May Concern, As a resident and landowner adjacent to DCP's Natural Gas Processing Facility, my family and I are concerned about the noise pollution that is generated and additional noise pollution that will occur. Along witPS decreasing the values of our home and property. Inadequately controlled noise presents a growing danger to the health and welfare of the neighbors to DCP. The major sources of noise coming from DCP Plant is running " (07 to `17 decibels. NOTE: The average of 85 decibels or greater require PPE. Per the Code of Federal regulations §1910.95, if levels of noise exposure risk is present then personal protective equipment (PPE) shall be provided for employees working in the area. This standard should be true for neighbors in the area as well. We look forward to working with your project to make the area a continued desirable place to live. Sincerely, Don and Terri Dechant EXHIBIT s 5i suSK -EIS-sill Eric Ewing 16974 CR 40 La Salle, CO 80645 May 31, 2017 Regarding: DCP Midstream Mewbourn Gas Plant 18455 Co Rd 35, Platteville, CO 80651 SE 1/4, Section 35, Township 4 North, Range 66 West of the 6th P.M. Dear Weld County Commissioners, I am here today because I am directly impacted by noise and air pollution from this facility. I am requesting that Weld County take significant action against DCP Midstream's Mewbourn Gas Plant at 18455 CR 35, Platteville, CO 806451 for a pattern of non-compliance with Federal Title V of the Clean Air Act (CAA), State of Colorado Air Quality Control Commission Regulations 1 and Regulation 7; and a myriad of Weld County Development Standards and County Codes. DCP's pattern of non-compliance and excessive emissions were preventable.. DCP knew or should have known that operating a gas processing facility out of compliance would negatively impact nearby uses of property. DCP has had many chances to become compliant with regulations and has failed repeatedly. The pattern of non-compliance with regulations as significant as those outlined above interferes with the designed, arranged, intended, and maintained use' of my tract of land and also indicates that the facility is not compatible with other similarly situated surrounding land uses. Anadarko/Kerr McGee has a large compressor station to the east that is currently compliant with air pollution regulations. An attached EPA ECHO Report' for the Hambert facility showing current and historical compliance indicating that compliance is achievable with these types of facilities. Weld County has the legal right to proceed with action as stated in: 1. Sec. 23-2-270 - Development standards.' allows for the Weld County Code, Sec. 23-1-90. - Definitions (not attached) ECHO, Detailed Facility Report, Kerr McGee Gathering - Hambert C.S. 3 Sec. 23-2-270. - Development standards. 1 of 5 a. "revocation or suspension of the special review permit" b. "Civil penalties" c. `Other remedies which are available for noncompliance with the development standards." 2. Development Standard #35: The property owner or operator shall be responsible for complying with all of the foregoing Development Standards. Noncompliance with any of the foregoing Development Standards may be reason for revocation of the Permit by the Board of County Commissioners. Action that should be considered is: 1. Revocation of permit to operate. 2. Denial of permit to expand. If continued operation and/or expansion must be approved, it should be under the following addition of civil penalties and other remedies: 1. Change "may" to "shall" in Development Standard #35. 2. Add Civil penalties for non-compliance retroactive to August 1, 2016. Reasonable proof provided by citizens (noise meters, videos, etc.) and/or third parties including the COGCC shall be actionable. 3. Change Development Standard #14: Reduce noise pollution allowance to 50 db. 7 a.m. to 4 p.m. Monday - Friday and 45 db. evenings, weekends, and holidays. 4. Add a development standard regarding low frequency (C scale) noise to be no more than 60 db. The ongoing and pattern of non-compliance with regulations can be confirmed by the attached documents in reverse chronological order: 1. Environment Protection Agency, Enforcement Compliance History Online, Detailed Facility Report for DCP Mewbourn showing current status as "Significant Violation". Page 1. Highlighted row titled "CAA" showing the text "Significant Violation" under the column header titled "Compliance Status". Page 4. Highlighted rows titled "CAA" showing the text "Yes" under the column headed "Current SNC (Significant Non-Compliance/HPV (High Priority Violation) and the date "05/27/2017" under the column headed "Current As Of. 2. Colorado Department of Public Health & Environment, Air Pollution Control Division, Compliance Order on Consent, Case No. 2015-073; AIRS No. 123/0090 2of5 Particularly concerning text from the referenced document: Page 5. 8.a. "DCP failed to limit emissions of air pollutants to the specified emission limits." Page 6. 8. a. vi. "DCP exceeded the annual nitrogen oxides emission limits..." Page 6. 8.b.v. "DCP exceeded the combined monthly fuel use limit..." Page 6. 8.b.vi. -DCP exceeded the monthly feed natural gas limit... Page 7. 8.b.ix. "DCP exceeded the monthly waste gas combusted limits..." and "DCP exceeded the annual waste gas combusted limit..." Page 7. 8.c. "DCP failed to limit the maximum lean amine recirculation pump rate..." Page 8. 8.e. "The emergency flare exceeded 20% opacity for 24 hours..." Page 8 8.g. "DCP failed to control emissions..." Page 11 8. h. vii "DCP failed to operate the PRVs on the condensate storage tanks to ensure flashing. working and breathing losses (as applicable) are routed to the control device under normal operating standards." 3. Colorado Department of Public Health and Environment, Air Pollution Control Division, Stationary Sources Program, Notice of Violation, Case No. 2013-035 and 2013-036 Particularly concerning text from the referenced document: Page 4. 5.A. "DCP failed to prevent emissions from the emergency flare i in excess of 30% opacity..." Page 5. 5.A.ii. "DCP reported NOx and VOC emissions that exceeded the rolling twelve emission limits..." Page 7. 5.F. "DCP failed to limit Mewbourn Waukesha 105 to maximum annual fuel consumption rate..during three months..." Page 9. L. "DCP has failed to limit the emission rate of NOx... Page 10. M "Because the engine settings were changed the evening before the test, testing was not conducted under conditions representative of normal operation. 4. State of Colorado, Compliance Advisory, Case No: 2021-057, 2012-058, 2012-062, AIRS Nos: 123/0090, 123/0049, 123/0277 Particularly concerning text from the referenced document: Page 4. A. "DCP aborted the testing due to preliminary results indicating emissions were exceeding permitted levels. The December 16, 2011 compliance 3of5 testing was not a representative demonstration of compliance under normal operating conditions due to the processing rate being reduced from approximately 147 MMscf/day prior to testing, to 130 MMscf/day immediately prior to commencing the test." Page 5. B.i. "..DCP aborted the testing due to preliminary results indicating emissions were exceeding permitted levels." Patterns of non-compliance with air pollution regulations causes the facility to be non -compliant with the following Weld County Codes and DEVELOPMENT STANDARDS: 1. Violation of Weld County Code 25-2-250 - Operation Standards'. Requires the "operation of the uses shall comply with the air quality regulations promulgated by the Colorado Air Quality Control Commission." 2. Violation of Weld County Code 23-2-270 - Development Standards' Requires "an applicant for Special Review Permit shall demonstrate conformance with and shall continue to meet any DEVELOPMENT STANDARDS approved and adopted by the County" 3. Violation of Weld County Code 23-2-280. - Changes to a Special Review Permit`' Requires that "major changes from the approved Special Review Plan Map or DEVELOPMENT STANDARDS for the Special Review Permit shall require the review of an amendment to the permit...'' 4. Violation of Weld County DEVELOPMENT STANDARDS contained in 3rdAMUSR - 542- #1. A Site Specific Development Plan and 4th Amended Use by Special Review Permit No. USR-542 for Mineral Resource Development Facilities, oil and gas support and service, Natural Gas Processing facility...subject to the Development Standards stated hereon. #15. The operation shall comply will all applicable rules and regulations of state and federal agencies and the Weld County Code. ' Weld County Code, Sec. 23-2-250. - Operation Standards. 'Weld County Code, Sec. 23-2-270. - Development standards. 6 Weld County Code, Sec. 23-2-280. - Changes to a Special Review Permit. ' Site Specific Development Plan. Use By Special Review Permit, Development Standards, 3rdAMUSR-542 4 of 5 #33. The property owner or operator shall be responsible for complying with the Operation Standards of Section 23-2-250, Weld County Code. #36. The property owner or operator shall be responsible for complying with all the foregoing Development Standards. 5. Violation of Weld County DEVELOPMENT STANDARDS contained in 4thAmUSR - 5428. #1. A Site Specific Development Plan and 4th Amended Use by Special Review Permit No. USR-542 for Mineral Resource Development Facilities, oil and gas support and service. Natural Gas Processing facility...subject to the Development Standards stated hereon. #9. Uses on the property should comply with the Colorado Air Quality Commission's air quality regulations. #18. The operation shall comply will all applicable rules and regulations of state and federal agencies and the Weld County Code. #32. The property owner or operator shall be responsible for complying with the Operation Standards of Section 23-2-250. Weld County Code. #35. The property owner or operator shall be responsible for complying with all the foregoing Development Standards. DCP needs tighter boundaries. Patterns of non-compliance of this nature requires significant action by Weld County such as revocation of permit, denial of expansion, and other remedies such as civil penalties and tighter regulations. Eric Ewing 'Site Specific Development Plan. Use By Special Review Permit, Development Standards, 4M U S R 16-83-542 5of5 Detailed Facility Report I ECHO I US EPA Page 1 of 5 Enforcement and Compliance History Online Detailed Facility Report Facility Summary KERR-MCGEE GATHERING - HAMBERT C.S. 18450 COUNTY ROAD 35, GILCREST 2.8 MI. E OF, CO 80645 FRS (Facility Registry Service) ID: 110001973062 EPA Region: 08 Latitude: 40.270882 Longitude: -104.721923 Locational Data Source: RMP Industry: Oil and Gas Extraction Indian Country: N Enforcement and Compliance Summary Statute Insp (5 Years) CAA 2 Date of Last Inspection 09P03/2014 Compliance Status Qtrs in NC (Non- Qtrs in Stgmficant Campionoc)(at 12) Violation Actions (5 years) Actions (5 years) 0 0 conpvtx"k CAA 1 12 -Quarter Violation History Under Development 2 3 4 5 6 7 8 9 10 11 12 Quarters MI No Violation Noncompliance El Significant Violation Unknown Informal Enforcement Formal Enforcement Penalues from Formal Enforcement EPA Cases (5 Penalties from EPA Actions (5 years) years) Cases (5 years) 517,850 Related Reports Air Pollutant Report Regulatory Information Clean Air Act (CAA): Operating Synthetic Minor (CO0000000812300059) Clean Water Act (CWA): No Information Resource Conservation and Recovery Act (RCRA): No Information Safe Drinking Water Act (SDWA): No Information Other Regulatory Reports Air Emissions Inventory (EIS): No Information Greenhouse Gas Emissions (eGGRT): 1011533 Toxic Releases (TM): No Information https://echo.epa.gov/detailed-facility-report?fid=110001973062&view=f 5/29/2017 Detailed Facility Report I ECHO I US EPA Page 2 of 5 Facility/System Characteristics Facility/System Characteristics System Statute FRS G17G CAA AIR CAA RMP CAA identlrcz Universe 110001973062 1011533 Direct Emitter CO00000008I2300059 Synthetic Munn Emissions 100000172617 Status Subject Operatmg ACTIVE Areas Permit Expiration Date Indian County latitude N 40 270882 General Stationary Fuel Combustion N CAASIP N N Longitude -104.721923 Facility Address System Statute FRS GHG CAA AIR CAA RMP CM Identifies 110001973062 1011533 C00000000812300059 100000172617 Facility Nerve KERR-MCGEE GATHERING - HAMBERT C S Hambctt Compressor Station KERR-MCGEE GATHERING - HAMBERT C S HAMBERT COMPRESSOR STATION Facility Address 18450 COUNTY ROAD 35, GILCREST 2.8 MI. E OF, CO 80645 18450 Weld County Road 35, Gilaest, CO 80623 18450 COUNTY ROAD 35, GILCREST 2.8 NO E OF, CO 90645 18450 WELD COUNTY ROAD 35, GILCREST, CO 80623 Facility SIC (Standard Industrial Classification) Codes Facility NAICS (North American Industry Classification System) Codes System AIR ldmut er C003000008I2300059 SIC Code SIC Desc 1311 Crude Pcuolcum And Natwal (Ms Facility Tribe Information Reservation Manic Tnbc N.anc f PA Tnhnl ID No data rcc nis re!urrc.: Distance to Tithe milts) Enforcement and Compliance Compliance Monitoring History (5 years) Statute Sow= ID System Inspection Type Lead Agency Date CAA CO0000000812300059 AIR Stack Test State 12/08/201.5 CAA 000000000812300059 AIR FCE On -Site State 09103/2014 CAA CO0000000812300059 AIR Stock Test State 09/10/7013 CM C00000000812300059 AIR StotkTest State 09/10/2013 CM CO0000000812300059 AIR Stark Test State 09/101013 CAA CO0000000812300059 .UR Stack Test State 09/10/2013 CM C00000000812300059 AIR Stack Tut State 0146/2013 System RMP RIO OHO AIR 100000172617 100000172617 1011533 C00000000812300059 Identifier NAICS Code 42291 NAICS Description 48621 211111 Crude Petroleum And Natural Gas Exiracuon 211111 Crude Petroleum And Natural Gas Extraction Fudmg Findings. Pass Pollutants Carbon monande. NITROGEN OXIDESM7J. VOLITIIEORGANIC COMPOUNDS (VOCCS) Findings Pass Pollutants: t'OLfl71E ORGANIC COMPOUNDS (➢OCS1 Findings• Pass Pollutants: Formaldehyde Findings: Pau Pollutant NITROGEN OXIDES NO2 Pa p: Pan Pollutants Carbon monoxide Findings: Pass Pollutants • Carbon monatuk https://echo.epa.gov/detailed-facility-report?fid=110001973062&view=f 5/29/2017 Detailed Facility Report I ECHO I US EPA Page 3 of 5 Statute Source ID System inspection Type Lad Agency Date Fimmi CAA C000000008/2300059 AIR Stack Test Stare 0146/2013 Findings: Pau Pollutants: Farmaldehtds CM C00000000812300059 AIR Sack Tesr Sate 01/1612013 Findings: Pan Pollutant,. NITROGEN °AWES 14/O2 CM C00000000S123000S9 AIR SloctTest State 01/16O013 Readings: Pea' Pollutants VOLATILE ORGANIC COINPOUNDS(W)CS) CAA 000000000812300039 AIR Stack Test State 01/15O013 Finery: Pass Polhaaw Carbon mawddr CAA 000000000812300059 AIR Stack Test State 01/15/2013 Findings:: Pass Pollutants: Farnteldehude CM C00000000812300059 AIR Stack Test Stole 01/15/2013 Findings: Pass Pollutants NITROGEN OXIDES NO2 CM CO0(100000812300059 AIR Stack Test State 01/15/2013 Findings: Pass Pollutants: VOLATILE ORGANIC COMPOUNDS (VOCS) CM C00000000812300059 AIR Stack Tut State 11/20/2012 Findbws: Pan Pollutants: Carbon monoxide CM C00000000812300059 AIR Stack Test State 11/20/2012 Findings PanPdlutanw: IVOLITILEORGANIC COMPOUNDS (VOCS) CM C000000008I2300059 AIR Sac* Test Store 11./20/2012 Fudiugs: Pass Pollutants: NITROGEN OXIDES NO2 CM C00000000812300059 AIR Sot* Test State 11/1912012 Findings- Pass Pollutants. Catbanmown* CM 000000000812300059 AIR Stock Test Slats 11/19/2012 Findings: Pass Pollutants: VOLATILE ORGANK'COMPOUNDS (VOCS) CM C00000000812300059 AIR Sock Test Sate 11/19/2012 Findings: Pass Polhaants NITROGEN OXIDES P.O2 CAA C00000000812300059 AIR FCE On -Site Suite 08/28/2012 Entries in italics are not considered inspections in official counts. Compliance Summary Data Statute Some ID Current SNC (Significant Non-canpisance)/HPV (High Priority Violation) Description Curet As Of Qtn in NC (Non -Compliance) (of 12) CAA C00000000812300059 No 05/27/2017 0 Three Year Compliance Status by Quarter Statute Progratn/PolltrtantNtolstwn Type CAA (Source ID: C00000000812300059) Faculty -Level Status HPV History Violation Type Historic Violations CAA CAA Arc, Programs Pollutants SIP TTI1-E V PERMITS QTR I QTR 2 QTR 3 QTR 4 QTR 5 QTR 6 QTR 7 QTR 8 QTR 9 QTR 10 QTR II QTR 12 07.01-09/3N14 10/01-I2/31/14 01/01- 04/01- 07/01- 10/01- 01/01- 04/01- 07/01- 10831- 01/01- 04/01- 03/31/15 06/30/15 09/30/15 12/31/15 03/31/16 06/30/16 09/30/16 12/31/16 03/31/17 06/30/17 No Viol No Viol S -Non- S-Non- HPV HPV S -Non- S-Non- HPV HPV Informal Enforcement Actions (5 Years) Statute Ss stein CAA AIR Source ID Type or Action CO0030000812300059 Nonce of Violation Lead Agency Date Slate 12/12/2012 Formal Enforcement Actions (5 Years) Statute Source ID CAA 000000000812303059 Type of Action I A Arks Admuustrattve ()Set State Date Penalty 03)06'2013 517.850 Pal* DeFlPtion IC1S (Integrated Compliance Information System) Case History (5 years) Primary Law/Section Case No. Case Type Lead Agency Case Name Issued/Filial Date Settlement Date Federal Penalty State/Local Penalty SEP (Supplemental Environmental Project) Cost Comp Action Cost No data records returned https://echo.epa.gov/detailed-facility-report?fid=110001973062&view=f 5/29/2017 Detailed Facility Report I ECHO I US EPA Environmental Conditions Water Quality Penn Combined ID Sesser System° Number of CSC) (Combined Sewer Cnerflosa) (Walls 12 -Digit WBD (Watershed Bounden WAD (Watershed BaaaLn Dataset) Dataset) HUC (RAD (Reach Address Subwatershed Name (RAD (Reach Database)) Address Datatase)) No data records returned State Waterbody Name (ICIS (Integrated Compliance Information System)) Impaired Impaired Waters Class Causes of Impairments) b) Group(sI Page 4 of 5 Watershed with FSA (Endangered Species Au}I)sted Aquatic Species, Waterbody Designated Uses Rauh Code Waterbods Name Exceptional Use Recreational Use Aquatic Life Use Shellfish Use Beach Closure Within Last Year Beach Closure Within Last 'I's v Years No data reaxds returned Air Quality Non -Attainment Area" Polltuan(s) Ye, No Ycc No Ozone 1 sec: Panic elate Matter Sulfur Dioxide Pollutants Toxics Release Inventory History of Reported Chemicals Released in Pounds per Year at Site 0 Air Pollutant Report TR1 Facility IL) Year Total Au Emissions Surface Water Discharges Off -Site Transfers to POTWs (Publicly (.Tared Treatment Works) Underground In)ections Releases to Land Total On -site Releases Total Off -site Releases No data records returned Toxics Release Inventory Total Releases and Transfers in Pounds hy Chemical and Year 0 Chan teal Name No data records returned Demographic Profile Demographic Profile of Surrounding Area (3 Miles) https://echo.epa.gov/detailed-facility-report?fid=110001973062&viev=f 5/29/2017 Detailed Facility Report I ECHO I US EPA Page 5 of 5 This section provides demographic information regarding the community surrounding the facility. ECHO compliance data alone are not sufficient to determine whether violations at a particular facility had negative impacts on public health or the environment. Statistics are based upon the 2010 US Census and American Community Survey data, and are accurate to the extent that the facility latitude and longitude listed below are correct. The latitude and longitude are obtained from the EPA Locational Reference Table (LRT) when available. Radtta o(Arca Center Latitude Center Longitude Total Persons 3 40.2696 -104.724297 1,014 Race Breakdown White Afncan-Amencan Hispanic -Origin Asian/Pacific Islander American Indian Other/Multiracial Land Area Water Area IN initiation Iknsity Percent Mnxmty Pawns (%) 832 (82%) 9(1%) 377 (37%) 4 (0%) I1 (I%) 158 (16%) 0% 361sq.ma 40% Age Breakdown Child 5 years and younger Minors 17 yean and younger Adults 18 years and older Seniors 65 years and older Education Level (Persons 25 & older) Less than 9th Grade 9th through 12th Grade High School Diploma. Some College/2-yr. 13 S /B A or More: Persons (%) 69 (9.72%) ft5 (11 97%) 186 (26.2%) 259 ( 36 48%) III (15.63%) Households in Area Housing Units in Area Households on Public Assistance Persons Below Poverty Level Income Breakdown Less than 515.000 515.000 - S25,030 525.000 - S50.000 sso.o00 - S5.000 Greater than $75,000 352 381 7 385 Pomoon (19 57 (6%) 274 (27%) 739 (73%) 105(10%) Hotuehtolds (%) 30 (7.63%) 63 (16.03%) Ill (2824%) 65 (16.54%) 124 (31.55%) https://echo.epa.gov/detailed-facility-report?fid=110001973062&view=f 5/29/2017 Weld County, CO Charter and County Code Page 1 of 1 Sec. 23-2-270. - Development standards. An applicant for a Special Review Permit shall demonstrate conformance with and shall continue to meet any DEVELOPMENT STANDARDS approved and adopted by the County. The DEVELOPMENT STANDARDS shall be placed on the Special Review Permit Plan Map prior to recording. Noncompliance with any of the approved DEVELOPMENT STANDARDS may be reason for revocation or suspension of the special review permit: by the Board of County Commissioners. Civil penalties in lieu of a suspension may also be imposed with the express prior agreement of the applicant. The availability of these remedies in no way limits the Board of County Commissioners from seeking or applying any other remedies which are available for noncompliance with the development standards.? (Weld County Codification Ordinance 2000-1; Weld County Code Ordinance 2001-8) 5/30/2017 Detailed Facility Report I ECHO I US EPA Page 1 of 7 Enforcement and Compliance History Online Detailed Facility Report Facility Summary MEWBOURN GAS PLANT 18455 WELD COUNTY RD 35, GILCREST, CO 80623 0 FRS (Facility Registry Service) ID: 110010691750 EPA Region: 08 Latitude: 40.266583 Longitude: -104.734944 Locational Data Source: RMP Industry: Oil and Gas Extraction; Pipeline Transportation Indian Country: N Enforcement and Compliance Summary Statute CAA CWA RCRA tnsp (5 Date of Last Years) Inspection 4 09/2.1/2016 Compliance Status Significant Violation No Violation No Violation :1 CAA CWA RCRA 12 -Quarter Violation History Under Development 1 2 3 4 5 6 7 8 9 10 11 12 Quarters I. No Violation Noncompliance Significant Violation I Unknown Qtrs in NC (Non• Qtrs m Significant Compliance) (of 12) Violation 12 12 u Informal Enforcement Formal Enforcement Actions (5 years) Actions (5 years) 3 4 0 — 0 — Penalties from Formal Enforcement EPA Cases (5 Penalties from EPA Actions (5 years) years) Cases (5 years) SI R7,50(t I Related Reports Air Pollutant Report ® CWA Pollutant Loading Report © CWA Effluent Charts Regulatory Information Clean Air Act (CAA): Operating Major (CO0000000812300090) Clean Water Act (CWA): Minor, Permit Effective (COR900328) Resource Conservation and Recovery Act Other Regulatory Reports Air Emissions Inventory (EIS): No Information Greenhouse Gas Emissions (eGGRT): 1006131 Toxic Releases (TRI): No Information https://echo.epa.gov/detailed-facility-report?fid=CO0000000812300090 5/28/2017 Detailed Facility Report I ECHO I US EPA Page 2 of 7 (RCRA): Inactive ( ) Other (COD 149181646) Safe Drinking Water Act (SDWA): No Information Facility/System Characteristics Facilitv/System Characteristics Systan Statute FRS RMP CAA AIR CM GHG CAA ICP CWA RCR RCRA Identifier 110010691750 100000076552 CO0000300812300090 1006131 COR900328 COO149181646 Univalve Staun Major Emissions Direct Emitter Minor General Pirmt Covacd Facility Other ACTIVE °Paging Subject Effective Inactive O Areas CAAMACT, CAANSPS. CAAPSD, CMSIP, CMTVP General Stationary Fuel Combustion, Petroleum and Neural Gas Systems Storm Water Industrial Pamtt Expiration Indian Date Latitude N 40.266583 N N N 4O266583 06/30/2017 N 40.267222 N Longitude •104.734944 -104734944 -104.734444 Facility Address System FRS RMP AIR OHG ICP RCR CAA CAA CAA CWA RCRA Identifier 1100106917% 100000076552 OO0000000812300090 1006131 COR900328 CUD149181646 Facility Name MEWBOURN GAS PLANT MEWBOURN GAS PLANT DCP NCDSTREAM, LP- MEWBOURN MEWBOURN GAS PLANT MEWBOURN GAS PLANT ASSOCIATED NAT GAS (KERSEY PLANT) Facility Address 18455 WELD COUNTY RD 35, GILCREST, CO 80623 18295 COUNTY ROAD 35, PLATTEVILL.E, CO 80651 NESE SEC 35 T4N R66W, GILCREST 2.3 Ml. SE OF, CO 80645 18455 WELD COUNTY RD 35, GILCREST, CO 80623 18455 CR 35, GILCREST, CO 80623 18455 WCR 35, GILCREST, CO 80623 Facility SIC (Standard Industrial Classification) Codes Facility NAICS (North American Industry Classification System) Codes System AIR ICP Identifier CO0000000812300090 COR900328 SIC Code SIC Desc 4922 Natural Gas Transmission 1321 Natural Gas Liquids Facility Tribe Information Raavenon Name Tribe Name EPA Tribal ID No data records returned DMITIOC to Tribe (males) Enforcement and Compliance System Identifier RMP 100000076552 GHG AIR CO0000000812300090 NAILS C«tc 211112 Natural Gas Liqud Extracuon NAILS Description 1006131 211112 Natural Gas Liquid Extraction 486210 Pipeline I-ransportatwnof Natural Gas https://echo.epa.gov/detailed-facility-report?fid=0O00000008123 00090 5/28/2017 Detailed Facility Report I ECHO I US EPA Page 3 of 7 Compliance Monitoring History (5 years) Statute Sarre ED System Inspection T,pe Lead Asencv Date CM CO000(l000812300090 AIR 71'.4CC Receipt,Review State 02/21/2017 Fading So Factl yRepart Deviations Finding CM 0'00000000812300090 All? 13'ACCleceip/ wew State 01/30/2017 CAA CO000CC00812300090 AIR FCE On -Site State 09/23/2016 000000000812300090 AIR Stack Test State 05/11/2016 Findings. Pass Pollutants. -(1' VOLATILE ORGANIC COMPOUNDS OC'S) CM CO0000000812300090 AIR Stack Test Slate (/3 09/2016 Findings Pass Pollutants: Carbon manonde, NITROGEN O,UDES NO2, VOLATILE ORGANIC COMPOUNDS (MKS) CM C00000000812300090 All? T7' ACC Receipt/Renew State 024)1'2016 CM CO00D0000812300090 All? 71'.4CC Receipt Ret,ew State 0!/310016 Finding. No Facility Report Deviations CM 000000000812300090 .UR Stack Test State 10/13/2015 Findings Pass Pollutants: NITROGEN OWES...02 CAA CO0000000812300090 AIR FCE On -Site State 07/23/2015 CM C'O00W000812300090 AIR Stack Test Slam 062$'2015 Findings Pass Pollutants: NITROGEN O,VDES NO2 CM C O00li000081:300090 .414) Stack Test Stale 06:5/2013 Findings Pass Pollutants: VOLATILE ORGANIC COMPOUNDS (VOCS) CM 000000000812300090 .41R Stack Test Stale 06/25/2015 Findings Pass Pollutants: Carbon monoxide CM ('00000000812300090 AIR PCEOn-Site EPA 0617/70/3 CM CO0000000811300090 AIR TV ACCRecetpeRenn. State 024)220/3 CM 000000000812300090 AIR TV ACCReceiptReview Slate 02471/2013 Findtng-NoFacility Report Dena:tons CAA CO00000008I2300090 AIR FCE On -Site State 09/24/2014 CM 000000000812300090 .411? TV .4CC Receipt' nvrew State 01/30/2014 CM C00000000812300090 .U/? Slack Test State 10/712013 Findings Pals Pollutants. NITROGEN 0.12DESN02 CM C0000000680300090 AIR 71'ACC Reeetpt/Rsnew State 02/23/2013 Finding: No Facility &pad Devionant CM CO0000000812300090 All? TV ACC Receipt/Renew Slate 02/04/2013 CM CC8?000000812300CA0 .UH Stock Test Starr f !?1'2012 Findings Pass Pollutants: VOLATILE ORGANIC COMPOUNDS (VOCS) CM C00000000412300090 AIR .Slack Tess Slate 11/:1/2012 Findings Pals Pollutants: NITROGEN 0A7DESNO2 CAA 000000000812300090 .41R Stack Test State 11/21/2012 Findings Pass Pollutants: Carbon manmade CM C00000000812300090 AIR Stack Test State 11115/2017 Findings Pass Pollutants: VOLATILE ORGANIC COMPOUNDS ors) CAA 000000000812300090 AIR Slack Test State 11/15/2012 Findings Pass Pollutants: NITROGEN 0,17DESNO2 CM 000000000812300090 All? Slack Test Starr 11/15/2012 Findings Pass Pollutants: Carbon maroadr CM 0'001100000812300090 All? Slack Test State 11 14/20/2 Findings Pan Pollutants: NITROGEN 0A7DES MX CM C00000000812:100090 AIR Stack Test State 1111412012 Findings Pan Pollutants.' Carbon mosoode CM C000 0000812300090 AIR Stock Test State 11/14/2012 Findings Pass Pollutants: VOLATILE ORG.4.'t7C' COMPOUNDS (VOCS) CAA (000000008/2300090 AIR Stack Test Stare 11/13/2017 Findings. Pass Pollutants: Nl7''ROGE.N 0A7DES NO2 CM 0000000008/2300090 .4/R Stack Test State 11/13/2012 Findings Pan Pollutants: VOLiTlLEORCiANK COMPOUNDS (VOCS) CM CO0000000812300090 AIR Slack Tess State 11/132012 Findings Pass Pollutants.- Carbon monoxide CM 000000000812300090 AIR Stack Test State 11/124012 Findings Pass Pollutants Carbon maenad/ CM C00000000812300090 .41R Stack Test State 11/1]/]011 Findings. Pali Pollutants ,VITW)GEN OXIDES 7102 CAA 000000000812300090 .41R Stack Test Slate 11/12/2012 Fudrngs Pass Pollutants: VOLATILE ORGANIC COM'POUNDS4VCS) CM C00000000812300090 .41R Stack Test State 114)//2012 Findings Pass Pollutants Nt1 XVt,EN 0A7DFS 8.02 CM C00000000812300(190 All? Stack Test State 1 //08/2012 Findings Pass Pollutants: Carbon ma sonde CM 000000009812300090 AIR Slack Test State 11/08/2012 Findings Pass Pollutants: VOLATILE ORGANIC COMPOUNDS (VOCS) CM 000000000812300090 AIR Slack Tell Slate 114)7/201] Findings Pass Pollutants: Carbon monoxide CM 000000000812300090 AIR Stack Test State 11/07/2012 Findings Fail Pollutants.' NITROGEN OXIDES NO2 CM C 000000($812300090 AIR Stack Test State 11/07/2012 Feedings Pan Pollutants; VOLATILE OlAG.4N!C COMPOUNDS(VOCS) CM C00000000812300090 AIR Slack Test State 11/06/2012 Findings Pending Pollutants VOLATILE ORGAN.C COMPOUNDS (VOCS) CM C00000000812300090 AIR Stack Test State 114)62012 Findings Pall Pollutants. VOLATILE ORGANIC COMPOUNDS (VOCS) CM C00000090812300090 .4/1? Slack Ter State 11/06'2012 Findings Pass Pollutants: Carbon monoxide https://echo.epa.gov/detailed-facility-report?fid=CO0000000812300090 5/28/2017 Detailed Facility Report I ECHO I US EPA Page 4 of 7 Statute Source ID System Inspection Type Lead Agency Date CAA C00000000812300090 AIR Stack Test State 11/06/2012 Findings: Pending Pollutants: Carbon monoxide CM C00000000812300090 AIR Stack Test State 11/06/2012 Findings: Pass Pollutants: NITROGEN OXIDES 1102 CM C00000000812300090 AIR Stack Test State /1/062012 Findings: Pending Pollutants: NiTROGEN OXIDES 1102 CM C00000000812300090 AIR Stack Test Slate 11/02/2012 Findings: Pass Pollutants: Hydrogen sulfide CM 000000000812300090 AIR Stack Test Slate 11/02/2012 Findings: Pending Pollutants: Toluene CM C00000000812300090 AIR Stack Test State 11/02/7012 Findings: Pending Pollutants: Xylene CM C00000000812300090 AIR Shack Tut State 11/02/2012 Findings: Pending Pollutants: Hexane CM C00000000812300090 AIR Stack Test State 11/02/2012 Findings: Pending Pollutants: Ethylbensene CM CO0000000812300090 AIR Stack Test State 11/02/2012 Findings: Pass Pollutants: Carbon monoxide CM C00000000812300090 AIR Stack Test State 11/0212012 Findings: Pass Pollutants: NITROGEN OXIDES 1102 CM C00000000812300090 AIR Stack Test State 11/02/2012 Findings: Pass Pollutants: Sullitr dioxide CM C00000000812300090 AIR Stack Test State 11/02/2012 Findings: Pending Pollutants: VOLATILE ORGANIC COMPOUNDS (VOCS) CM C00000000812300090 AIR Stack Test State 11/02/2012 Findings: Pending Pollutants: Benzene CAA 000000000812300090 AIR FCE On Site State 08/24/2012 Entries in italics are not considered inspections in official counts. Compliance Summary Data Statute Source ID Current SNC (Significant Non-compliance)/HPV (High Priority Violation) CAA CO0030000812300090 Yea CWA COR900328 No RCRA COD149181646 No Descnption Current As Of Qtrs in NC (Non -Compliance) (of 12) Addrs-Salo OS/27/2017 12 12/31/2016 1 05/27/2017 0 Three Year Compliance Status by Quarter Statute Program/Pollutant/Violation Type CAA (Source ID: C00000000812300090) Violation Type Facility -Level Status HPV History Agency Programs Pollutants CAAMACT, CAANSPS, CAA I-IPV CO CAAPSD, CAASIP, CAATVP CAAMACT, CAANSPS, CAA HPV CO CAAPSD, CAASIP, CAATVP CAAMACT, CAANSPS, CAA HPV CO CAAPSD, CAASIP, CAATVP CAANSPS, CAA HPV CO CAASIP, CAATVP CAAMACT, CAANSPS, CAA FRV CO CAAPSD, CAASIP, CAATVP Historic Violations CAA CAA MACT (SECTION 63 NESHAPS) NSPS VOLATILE ORGANIC COMPOUNDS (VOCS) NITROGEN OXIDES NO2 VOLATILE ORGANIC COMPOUNDS (VOCS) NITROGEN OXIDES NO2 VOLATILE ORGANIC COMPOUNDS (VOCS) QTR I QTR 2 QTR 3 QTR 4 QTR 5 QTR 6 _QTR 7 QTR 8 QTR9 (LIR 10 _QTR 11 QTR 07/01-09/30/14 10/01-12/31/14 01/01- 04/01- 07/01- 10/01- 01/01- 04/01- 07/01- 10/01- 01/01- 04/01 03/31/15 06/30/15 09/30/15 12/31/15 03/31/16 06/30/16 09/30/16 12/31/16 03/31/17 06/30/ HPV HPV HPV HPV HPV HPV HPV HPV HPV HPV HPV HPS Unaddr- Unaddr- Unaddr- Unaddr- Adder Adds- Addrs- Addrs- Addrs- Adder Addrs- Addn State State State State State State State State State State State Stet( 11/05/2011 »> >» >» »> »> »> »> »> >» »> »> 02/01/2013 »> >» »> »> »> »> »> »> »> »> »> 10/0812012 09/17/2000 >>> >>> 11/08/2014 V-HPV V-HPV Vio Vio V-HPV V-HPV Vio Vio »> >>> >>> >>> >>> >>> >>> »> »> >>> >>> >>> >>> >>> >>> >>> >>> >>> >>> >>> f https://echo.epa.gov/detailed-facility-report?fid=CO0000000812300090 5/28/2017 Detailed Facility Report I ECHO I US EPA Page 5 of 7 Statute CAA CAA CAA Progrant/PollutantNiolation Type PSD SIP 1111.E V PERMITS QTR I QTR 2 QTR 3 QTR 4 QTR 5 QTR 6 QTR 7 QTR 8 QTR 9 QTR 10 QTR I 1 QTR V-HPV V-HPV Vio Vio V-HPV V.HPV Vto Vio V-HPV V-}IPV Vie Vio Statute CWA CWA CWA CWA Progrnn/PollutanVViolation Type CWA (Source ID: COR900328) Fadltty-Level Status SNC (Significant Nontompllance)/RNC (Reportable Non -Compliance) History Permit Schedule Violations QTR I QTR 2 QTR 3 QTR 4 QTR S QTR 6 QTR 7 QTR B QTR 9 QTR 10 QTR 11 QTR 12 01101- 04/01- 07/01- 10/01- 03/31/14 06/30/14 09/30/14 12/31/14 No No No No Viol Viol Viol Viol 01/01-03/31/15 In Viol V (NoOORNC V 1 04/01- 07/01- 10/01- 01/01- 04/01- 07/01- 10/01- 06/30/15 09/30/15 12/31/15 03/31/16 06/30/16 09/30/16 12/31/16 No No No No No No No Viol Viol Viol Viol Viol Viol Viol Schedule Event achieved late but reported: Perform 03-31-15 05- Compliance Performance Evaluation 29.15 Schedule Even reported late. Perform Compliance 03.31.15 05- Performance Evaluation 29.15 Schedule Event unachieved and not reported: 03-31-1 S 05- Perform Compliance Performance Evaluation 29.15 Schedule Evan unachieved but reported: Perform 03.31.15 05- Compliance Performance Evaluation 29-15 QTR 13+ 01/01-05/26/17 Und Statute Program/Pollutam/Violation Type QTR I QTR 2 QTR 3 QTR 4 QTR 5 QTR 6 QTR 7 QTR 8 QTR 9 QTR 10 QTR II QTR 12 RCRA (Source ID: COD149l81646) 07/01-09/30/14 10/01-12/31/14 01/01-03/31/15 04/0I-06/30/15.07/01.09/30/15 10/01-12/31/15;01/01-03/31/16 04/01-06/30/16 07/01-09/30/16 10/01-12/31/16 01101-03/31/17 04/01.06130/17 RCRA Facility -Level Status Informal Enforcement Actions (5 Years) Statute CAA CAA CAA System AIR AIR AIR Source ID Type of Action CO0000000812300090 CO0000000812300090 CO0000000812300090 Notice of Violation Notice of Violation Notice of Violation Lead Agency State State State Date_ 08/19/2015 06/21/2013 06/21/2013 Formal Enforcement Actions (5 Years) Statute CAA CAA CAA CAA Source ID CO0000000812300090 CO0000000812300090 CO0000000812300090 CO0000000812300090 Type of Action Admunstrative Order Administrative Order Administrative Order Administrative Order Lead Agency State State Slate State Date 06/21/2016 04/27/2015 04/27/2015 04/27/2015 Penalty $56,700 SO 6130,800 SO Penalty Desaipuon ICIS (Integrated Compliance Information System) Case History (5 years) Pnmary Law/Section Case No. Case Type Lead Agency Case Name Issued/Filed Date Settlement Date Federal Penalty State/Local Penalty SEP (Supplemental Environmental Project) Cost Comp Action Cost No data records returned Environmental Conditions Water Quality Permit ID Combined Number of CSO Sewer System?(Combined Sewer Overflow) Outfalls 12 -Digit WBD (Watershed Boundary WBD (Watershed Boundary Dataset) State Waterbody Name /CIS Dataset) HUC (RAD (Reach Address Subwatershed Name (RAD (Reach (Integrated Compliance Database)) Address Database)) Information System)) Impaired Impaired Causes of Watershed with ESA Class lmpaument(s) by (Endangered Species Act)- Waters Group(s) listed Aquatic Species? https://echo.epa.gov/detailed-facility-report?fid=CO0000000812300090 5/28/2017 Detailed Facility Report I ECHO I US EPA Page 6 of 7 Permit 1D COR900328 CombinedNumber of CSO Sewer Systtm? (Combined Sewer Overflow) Outfalls 12 -Digit WBD (Watershed Boundary Dataset) HUC (RAD (Reach Address Database)) 101900030606 WBD (Watershed Boundary Dataset) Subwatershed Name (RAD (Reach Address Database)) City of Evans -South Plane River State Waterbody Name (ICIS (Integrated Compliance Information System)) Platte Valley Canal - Milton Rescrvou Impaired Impaired Waters Class Causes of Impairments) by Group(s) Watershed with ESA (Endangered Species Act) - listed Aquatic Species? No Yes Waterbody Designated Uses Reach Code 10190003000560 Watabody Name Exceptional Use Recreational Use No No Aquatic Life Use No Shellfish Use Beach Closure Within Last Year No No Beach Closure Within Last Two Years Air Quality Non-AttainmentArea? Yes No Yes No Pollutant(s) Ozone Lad Particulate Matter Sulfur Dioxide Pollutants Toxics Release Inventory History of Reported Chemicals Released in Pounds per Year at Site 0 Air Pollutant Report TRI Facility ID Year Total All Emissions Surface Water Discharges Off -Sue Transfers to POTWs (Publicly_ Owned Treatment Works) Undergrotmd Injections Releases to Land Total On -site Releases Total Off -site Releases No data records returned Toxics Release Inventory Total Releases and Transfers in Pounds by Chemical and Year 0 Chemical Name No data records returned Demographic Profile Demographic Profile of Surrounding Area (3 Miles) This section provides demographic information regarding the community surrounding the facility. ECHO compliance data alone ire not sufficient to determine whether violations at a particular facility had negative impacts on public health or the environment. Statistics are based upon the 2010 US Census and American Community Survey data, and are accurate to the extent that the facility latitude and longitude listed below are correct. The latitude and longitude are obtained from the EPA Locational Reference Table (LRT) when available. Radius of Area. Center Latitude: Center Longitude: Total Persons: 3 40.266583 -104.734944 1.587 Land Area Water Area Population Density Percent Mtnonty Race Breakdown Persons (%) Households in Area. Housing Units in Area: Households on Public Assistance: Persons Below Poverty Level 532 573 7 537 Age Breakdown Persons (%) https://echo.epa.gov/detailed-facility-report?fid=CO0000000812300090 5/28/2017 Detailed Facility Report I ECHO I US EPA Page 7 of 7 Race Breakdown White. African -American: Hispanic-Origm: Asian/Pacific Islander American Indian: Other/Multiracial: Persons (%) 1,278(81%) 10(1%) 756 (48%) 7 (0%) 13 (I%) 279 (18%) Age Breakdown Child 5 years and younger. Minors 17 years and younger Adults 18 years and older Seniors 65 years and older Education Level (Persons 25 & older) Less than 9th Grade: 9th through 12th Grade: High School Diploma. Some College/2-yr. B.S./B.A. or More: Persons (%) 120 (11.42%) 138 (13.13%) 323 (30.73%) 336 (31.97%) 134 (12 75%) Income Breakdown Leas than 515,000. S15,000 - S25,000: S25,000 - S50,000: 550,000 - 575,000: Greater than 575,000: Persons (95-) 96 (6%) 447 (28%) 1,140 (72%) 164 (10%) Households(%) 40 (6.99%) 70 (12.24%) 193 (33.74%) 113 (19.76%) 156(2717%) https://echo.epa.gov/detailed-facility-report?fid=CO0000000812300090 5/28/2017 COLORADO Department of Public Health & Environment AIR POLLUTION CONTROL DIVISION COMPLIANCE ORDER ON CONSENT CASE NO. 2015-073 AIRS NO. 123/0090 IN THE MATTER OF DCP MIDSTREAM, LP The Colorado Department of Public Health and Environment ("CDPHE"), through the Air Pollution Control Division ("Division"), issues this Compliance Order on Consent ("Consent Order"), pursuant to the Division's authority under § 25-7-115(3)(b), C.R.S. of the Colorado Air Pollution and Prevention and Control Act, §§ 25-7-101 to 1309, C.R.S. ("the Act"), and its implementing regulations, 5 C.C.R. § 1001, et seq ("the Regulations") with the express consent of DCP Midstream, LP ("DCP"). The Division and DCP may be referred to collectively as "the Parties." I. STATEMENT OF PURPOSE The mutual objectives of the Parties in entering into this Consent Order are: 1. To establish compliance requirements and criteria for the continued operation of DCP's Mewbourn Natural Gas Processing Plant located in SE 'A Section 35, T4N, R66W in Weld County Colorado ("Facility"); and 2. To resolve the violations of the Act cited herein and in a Compliance Advisory issued to DCP by the Division on August 19, 2015. II. DIVISION'S FINDINGS OF FACT AND DETERMINATION OF VIOLATIONS Based upon the Division's investigation into and review of the compliance issues identified herein, and in accordance with § 25-7-115(3), C.R.S., the Division has made the following determinations regarding violations of regulatory, statutory, and/or permit requirements associated with the Facility. 3. At all times relevant to the violations cited herein, DCP was a foreign limited partnership in good standing and registered to conduct business in the State of Colorado. 41/4 COLORADO CO Atr pollution Control Division omnnwa• • A.Oli! Hslth v En.vormen 4. DCP owns and/or operates the Facility. The Facility is subject to the terms and conditions of Colorado Construction Permit Number 09WE1136 Issuance 2 issued to DCP Midstream, LP on June 28, 2012 ("Permit Number 09WE1136"), Colorado Air Quality Control Statutes, and Colorado Air Quality Control Commission ("AQCC") Regulations. 5. The following equipment is subject to Permit Number 09WE1136: AIRS Point Facility Equipment ID Point Description 101 C-211 One (1) Caterpillar, G379NA, SN: 72B641, natural gas fired, 4 -stroke, rich - burn, naturally aspirated, reciprocating internal combustion engine, heat input rated at 2.6 MMBTU per hour, output rated at 330 HP, running a natural gas / vapor compressor. Emissions are controlled by AFR and a Non -Selective Catalytic Reduction system. 102 C-167 One (1) Waukesha, L7044GSI, SN: C13852-1, natural gas fired, 4 -stroke, rich - burn, turbocharged, reciprocating internal combustion engine, heat input rated at 12.9 MMBTU per hour. output rated at 1,680 HP, running a natural gas compressor. Emissions are controlled by AFR and a Non -Selective Catalytic Reduction System. 103 C-179 One (1) Waukesha. L7042GSI, SN: 240410, natural gas fired, 4 -stroke, rich - burn, turbocharged, reciprocating internal combustion engine, heat input rated at 11.6 MMBTU per hour, output rated at 1,478 HP, running a natural gas compressor. Emissions are controlled by AFR and a Non -Selective Catalytic Reduction System. 104 C-129 One (1) Waukesha, L7042 GU, SN: 286822, natural gas fired, 4 -stroke, rich - burn, naturally aspirated, reciprocating internal combustion engine, heat input rated at 6.4 MMBTU per hour, output rated at 896 HP, running a natural gas compressor. Emissions are controlled by AFR and a Non -Selective Catalytic Reduction system. 105 C-134 One (1) Waukesha, L7042GU, SN: 285300, natural gas fired, 4 -stroke, rich - burn, naturally aspirated, reciprocating internal combustion engine, heat input rated at 6.4 MMBTU per hour, output rated at 896 HP, running a natural gas compressor. Emissions are controlled by AFR and a Non -Selective Catalytic Reduction system. 106 C-130 One (1) Waukesha, L7042GSI, SN: 339839, natural gas fired, 4 -stroke, rich - burn, turbocharged, reciprocating internal combustion engine, heat input rated at 11.2 MMBTU per hour, output rated at 1,478 HP, running a natural gas compressor. Emissions are controlled by AFR and a Non -Selective Catalytic Reduction system. 107 C-131 One (1) Waukesha, L7042GSI, SN: 397541, natural gas fired, 4 -stroke, rich - burn, turbocharged, reciprocating internal combustion engine, heat input rated at 11.2 MMBTU per hour, output rated at 1,478 HP, running a natural gas compressor. Emissions are controlled by AFR and a Non -Selective Catalytic Reduction system. 108 F017 Facility Equipment Leaks. Emissions minimized by Leak Detection and Repair Program. 109 LO Condensate loadout. Emissions controlled by a combustor. COLORADO Air Pollution Control Divizion Mf dnwn a Pubic hgY.h 6 En..Omn. c AIRS Point Facility Equipment ID Point Description 110 TANKS Four (4) tanks, 400 bbl each, for storage of stabilized natural gas condensate. Emissions controlled by a combustor. 111 C0170 One (1) Solar, Taurus 60, SN: TC10559, natural gas fired combustion turbine, heat input rated at 50.1 MMBTU per hour. This is equipped with Dry Low NOx combustion system for minimizing emissions of Nitrogen Oxides. This powers a natural gas compressor. Identified as Inlet 1. 112 O0180 One (1) Solar, Taurus 60, SN: TC10560, natural gas fired combustion turbine, heat input rated at 50.1 MMBTU per hour. This is equipped with Dry Low NOx combustion system for minimizing emissions of Nitrogen Oxides. This powers a natural gas compressor. Identified as Inlet 2. 113 C250 One (1) Caterpillar, G3608TALE, SN: BEN00563, natural gas fired, 4 -stroke, turbo -charged, lean -burn, low emissions design, reciprocating internal combustion engine, heat input rated at 17.9 MMBTU per hour, output rated at 2,370 HP, powering a natural gas compressor. Emissions are controlled by an oxidation catalyst. Identified as Residue 1 114 C251 One (1) Caterpillar, G3608TALE, SN: BEN00565, natural gas fired, 4 -stroke, turbo -charged, lean -burn, low emissions design, reciprocating internal combustion engine, heat input rated at 17.9 MMBTU per hour, output rated at 2,370 HP, powering a natural gas compressor. Emissions are controlled by an oxidation catalyst. Identified as Residue 2. 115 C252 One (1) Caterpillar, G3608TALE, SN: BEN00567, natural gas fired, 4 -stroke, turbo -charged, lean -burn, low emissions design, reciprocating internal combustion engine, heat input rated at 1 7.9 MMBTU per hour, output rated at 2,370 HP, powering a natural gas compressor. Emissions are controlled by an oxidation catalyst. Identified as Residue 3. 116 C253 One (1) Caterpillar, G3608TALE, SN: BEN00572, natural gas fired, 4 -stroke, turbo -charged, lean -burn, low emissions design, reciprocating internal combustion engine, heat input rated at 17.9 MMBTU per hour, output rated at 2,370 HP, powering a natural gas compressor. Emissions are controlled by an oxidation catalyst. Identified as Residue 4. 117 C254 One (1) Caterpillar, G3608TALE, SN: BEN00571, natural gas fired, 4 -stroke, turbo -charged, lean -burn, low emissions design, reciprocating internal combustion engine, heat input rated at 17.9 MMBTU per hour, output rated at 2,370 HP, powering a natural gas compressor. Emissions are controlled by an oxidation catalyst. Identified as Residue 5. 118 G1650 One (1) Solar, Taurus 70, SN: TG09548, natural gas fired combustion turbine, heat input rated at 61.6 MMBTU per hour. This is equipped with Dry Low NOx combustion system for minimizing emissions of Nitrogen Oxides. This runs an electric power generator. Identified as Genset 1. 119 G1670 One (1) Solar, Taurus 70, SN: TG09549, natural gas fired combustion turbine, heat input rated at 61.6 MMBTU per hour. This is equipped with Dry Low NOx combustion system for minimizing emissions of Nitrogen Oxides. This runs an electric power generator. Identified as Genset 2. COLORADO Air Pollution Control Division D.isiner .n d amoc 1-e.+MN k tnaonrwn AIRS Point Facility Equipment ID Point Description 120 AM001 Natural gas sweetening (by removal of Carbon Dioxide and Hydrogen Sulfide) system (Precision Pipe & Vessel, LLC, Model T502, SN: 2381-9089) using a 30-50% solution of Methyldiethanolamine (MDEA), process feed gas design rated at 160 MMSCF per day, and an amine recirculation rate of 640 gallons per minute. This system consists of: natural gas / amine contactor, amine flash tank, and amine regenerator (heating unit under AIRS PT ID: 123/0090/121). Emissions from the still vent are routed to a regenerative thermal oxidizer (AIRS PT ID: 123/0090/124). Emissions from the flash tank are routed to a vapor recovery unit (VRU) and returned to the plant inlet. 121 H776 One (1) Optimized Process Furnace, Inc., Model 200, SN: J091036, natural gas fired amine regeneration reboiler, heat input design rated at 64.9 MMBTU per hour. This is equipped with Ultra -Low NOx combustion system for minimization of Nitrogen Oxides emissions. 122 D-931 Natural gas dehydration system using Triethylene glycol (TEG), (Exterran, SN: 8907) process feed design rated at 160 MMSCF per day, and two (2) electric Rotor pumps with design glycol recirculation rate of 25 gallons per minute each (total of 50 gallons per minute). This system consists of: natural gas / glycol contactor, glycol flash tank, glycol regenerator reboiler (beat provided by hot gases from various combustion processes supplemented by a hot oil heater (AIRS Point ID: 123/0090/123). Flash tank off gases are directly routed to a VRU and returned to the plant inlet. Still vent emissions are routed through a condenser, and then to regenerative thermal oxidizer (AIRS PT ID: 123/0090/124). 123 H771 Two (2) Devco, HeliFlow, SN: 3431-3, natural gas fired hot oil heaters, heat input design rated at 26.0 MMBTU per hour each. These are equipped with Ultra-Low-NOx combustion systems for minimization of Nitrogen Oxides emissions. Hot oil is used to provide heat to various natural gas processes at the facility including supplemental heat for glycol regeneration reboiler. Only one heater to be operated at a time, the other is to be used as a backup. 124 TO701 One (1) Anguil Environmental Services, Inc., Model 200, SN: 14808, regenerative thermal oxidizer, heat input design rated at 11.0 MMBTU per hour. Natural gas used for startup. This is equipped with Low NOx combustion system for minimization of Nitrogen Oxides emissions. Emissions from various processes at this facility are routed into this thermal oxidizer for thermal destruction. Natural gas is used for startup to raise the temperature to normal operating level. 6. On September 24, 2014, Mr. Tim Taylor, of the Division, conducted an inspection, pursuant to the Division's authority under § 25-7-111(2)(c), C.R.S., at the Facility for the purpose of determining compliance with Permit Number 09WE 1136, the Act and the Regulations for the period commencing August 1, 2012 and ending August 31, 2014. Based on Mr. Taylor's inspection, and a review of records related to the Facility, the Division issued a Compliance Advisory to DCP on August 19, 2015. 7. On October 8, 2015, DCP caused written responses to the issues identified by the Division in the Compliance Advisory to be filed with the Division. On October 28, 2015 and November 17, 2015, the Division and DCP met to discuss the issues identified in the Compliance COLORADO Air Pollution Control Division j*D..11.wv N ;Allllit '1tU9 F En, wor rIM1' Advisory and DCP's written responses to those issues. On November 16, 2015, December 1, 2015 and December 11, 2015, DCP submitted additional information to the Division in writing relatedto the issues identified in the Compliance Advisory and the discussions concerning those issues between the parties that took place on October 28, 2015 and November 17, 2015. 8. Based upon a review of information including Mr. Taylor's inspection, records related to the Facility, and the information provided by DCP, the Division has determined the following: a. ;DCP failed to limit emissions of air pollutants to the: specified emission _ limits, provide emissions records, and/or to correctly calculate emissions from each emission unit on a rolling 12 -month total, violating Permit Number 09WE 1136, Condition 5. i. AIRS Point 101: DCP failed to correctly calculate March 2014 emissions. DCP submitted corrected calculations to the Division on October 8, 2015. ii. AIRS Point 106: DCP failed to correctly calculate March 2014 emissions. DCP submitted corrected calculations to the Division on October 8, 2015. iii. AIRS Point 107: DCP failed to correctly calculate March 2014 and May 2014 emissions. DCP submitted corrected calculations to the Division on October 8, 2015. iv. AIRS Point 109: DCP failed to provide records of carbon monoxide ("CO") emissions for the combustor controlling the condensate loadout from August 2012 to August 2014. DCP submitted the records to the Division on October 8, 2015. v. AIRS Points 109 and 110: DCP reported the pilot light for the flare controlling the condensate tanks and loadout was not lit during September 2014, August 2014, July 2014, June 2014, May 2014, April 2014, March 2014, and from April 1 — 3, 2013; March 14 — 31, 2013; February 19 — 28, 2013; February 1 — 6, 2013; September 17 — 27, 2012; September 6 — 9, 2012; and September 3, 2012. DCP submitted electronically recorded data to the Division on October 8, 2015 showing the pilot light was lit or partially lit on all but 2 days during the inspection period . On November 17, 2015 the Division requested that DCP recalculate the control efficiency of the flare for the days the pilot light was either not lit or was partially lit. DCP supplied recalculated control efficiencies to the Division on December 1, 2015. COLORADO Air Pollution Control Division roarmen: c' n.UK Fa tli fimnax.r: vi. AIRS Points 118 and 119: DCP exceeded the annual nitrogen oxides ("NOx") (combined 17.49 tons per year "tpy") and CO (combined 17.76 tpy) emission limits for the Genset Turbines G1650 and G1670 for the rolling 12 -month period ending August 2014 with NOx emissions of 17.67 tpy and CO emissions of 17.96 tPY• vii. AIRS Point 120: DCP failed to provide rolling 12 -month records of hydrogen sulfide ("H2S") emissions for the amine unit from August 2012 to August 2014. DCP submitted the records to the Division on October 8, 2015. viii. AIRS Point 124: DCP failed to provide rolling 12 -month records of sulfur dioxide ("SOx") emissions for the RTO from August 2012 to August 2014. DCP submitted the records to the Division on October 8, 2015. b. DCP failed to comply with the specified process rates and/or to correctly calculate consumption for each unit on a rolling 12 -month total, violating Permit Number 09WE1136, Condition 11. i. AIRS Point 101: DCP failed to accurately calculate March 2014 fuel use. ii. AIRS Point 103: DCP exceeded the monthly fuel use limit of 8.19 NIMscf/month for engine C-179/AIRS Point 103 in May 2014 (8.95 MMscf/month). DCP submitted corrected records to the Division on October 8, 2015. iii. AIRS Point 106: DCP failed to accurately calculate March 2014 fuel use. DCP submitted corrected records to the Division on October 8, 2015. iv. AIRS Point 107: DCP failed to accurately calculate March 2014 and May 2014 fuel use. DCP submitted corrected records to the Division on October 8, 2015. v. AIRS Points 118 and 119: pCP exceeded the combined monthly fuel use linittof 47.36 MMscf/month for the generator turbines G- 1650 and G-1670/AIRS Points 118 and 119 in April 2013 (50.19 MMscf/month). vi. AIRS Point 120: DCP exceeded the monthly feed natural gas limit of 4,960 MMscf/month for the amine unit AM001 /AIRS Point 120 in May 2013 (5,059 MMscf/month). COLORADO Air Pollution Control Division Depen.ne ni.n Pulls Heaah tr in N'nr vii. AIRS Point 121: DCP exceeded the monthly fuel use limit of 45.986 MMscf/month for the heater H776/AIRS Point 121 in May 2014 (51.95 MMscf/month). DCP submitted corrected records to the Division on October 8, 2015. viii. AIRS Point 123: DCP exceeded the monthly fuel use limit of 18.422 MMscf/month for the heater H771/AIRS Point 123 in May 2014 (20.81 MMscf/month) and August 2013 (18.68 MMscf/month). DCP submitted corrected records to the Divison on October 8, 2015. ix. AIRS Point 124: DCP exceeded the monthly waste gas combusted limit of 141 MMscf/month for the RTO TO701/AIRS Point 124 in May 2013 (146.82 MMscf/month), March 2013 (144.34 MMscf/month), November 2012 (153.45 MMscf/month) and October 2012 (155.35 MMscf/month). DCP exceeded the annual waste gas combusted limit of 1655 MMscf/yr for TO701/AIRS Point 124 for the rolling 12 -month periods ending October 2013 (1,671 MMscf/yr), September 2013 (1,686 MMscf/yr), August 2013 (1,666 MMscf/yr) and May 2013 (1,602 MMscf/yr). c. DCP failed to limit the maximum lean amine recirculation pump rate,to 640 gallons per minute on the following dates, violating Permit Number 09WE 1136, Condition 12. 4/20/2013 5/21/2013 7/17/2013 9/8/2013 4/21/2013 5/22/2013 7/18/2013 10/3/2013 4/22/2013 5/24/2013 8/1/2013 10/4/2013 4/23/2013 5/26/2013 8/5/2013 10/5/2013 4/24/2013 6/8/2013 8/15/2013 10/6/2013 4/26/2013 6/12/2013 8/16/2013 10/7/2013 4/28/2013 6/16/2013 8/19/2013 10/8/2013 4/29/2013 7/11/2013 8/21/2013 10/9/2013 5/18/2013 7/13/2013 8/22/2013 11/1/2013 5/19/2013 7/14/2013 8/31/2013 2/28/2014 5/20/2013 7/15/2013 9/7/2013 d. DCP failed to record the lean glycol circulation rate for the triethylene glycol (TEG) dehydrator under AIRS Point 022 on the following dates: October 11 — 12, 2013; October 22, 2013; December 1 — 8, 2013; December 14, 2013; December 19 — 31, 2013; January 1 — 7, 2014; COLORADO Air Pollution Control Division ocr»vn d WtM Moon b Fin+a-mw.• January 16 — 31, 2014; March 25 — 26, 2014; and March 29 — 31, 2014; violating Permit Number 09WE1136, Condition 13. e. The emergency flare exceeded 20% opacitfor 24 hours. on May 21, 2014, in violation of Permit Number 09WE1136, Condition 15. f. DCP failed to meet the Subpart KICK Delay of Repair requirements for 57 components, including 37 valves, violating Permit Number 09WE1136, Condition 22. As of October 2015, 7 components remain on Delay of Repair. g. DCP failed to control emissions from AIRS Point 122 by 90% on November 27 — 28, 2014 as a result of non -operation of the RTO, violating Permit Number 09WE1136, Conditions 29 and 30. h. DCP failed to follow the O&M Plans and recording keeping formats approved by the Division, violating Permit Number 09WE1136, Condition 33. i. DCP failed to record daily catalyst inlet temperatures for the Reciprocating Internal Combustion Engines ("RICE") as follows: Month Catalyst Inlet Temperatures Not Provided (hours of operation) August 2012 AIRS Point 113/C-250 (438 hours), AIRS Point 114/C-251 (617 hours), AIRS Point 115/C-252 (293 hours), AIRS Point 116/C- 253 (665 hours), AIRS Point 117/C-254 (529 hours) September 2012 AIRS Point 101/C-211 (554 hours; only 4 daily readings — should be at least 23), AIRS Point 104/C-129 (223 hours; only 4 daily readings — should be at least 9) November 2012 AIRS Point 101/C-211 (705 hours; only 4 daily readings — should be at least 30), AIRS Point 104/C-129 (499 hours; only 4 daily readings — should be at least 21), AIRS Point 105/C-134 (296 hours; only 2 daily readings — should be at least 12) December 2012 AIRS Point 101/C-211 (737 hours; only 5 daily readings — should be at least 31) and AIRS Point 104/C-129 (124 hours; only 1 daily reading — should be at least 5) January 2013 AIRS Point 101/C-211 (735 hours; only 4 daily readings — should be at least 31) February 2013 AIRS Point 101/C-21 1 (654 hours; only 4 daily readings — should be at least 27) and AIRS Point 105/C-134 (9 hours, no readings) March 2013 AIRS Point 101/C-211 (736 hours; only 4 daily readings — should be at least 31), AIRS Point 104/C-129 (147 hours; only 2 daily readings — should be at least 6), AIRS Point 105/C-134 (161 hours; only 2 daily readings — should be at least 7) April 2013 AIRS Point 101/C-211 (684 hours; only 5 daily readings — should be at least 28) May 2013 AIRS Point 101/C-211 (744 hours; only 4 daily readings — should be at least 31) June 2013 AIRS Point 101/C-211 (709 hours; only 4 daily readings — should COLORADO Au Pollution Control Division Dtunnvn J PUDIC IIcU(V1 b trtnonm.o be at least 30), AIRS Point 103/C-179 (485 hours; only 18 daily readings — should be at least 20), AIRS Point 106/C-130 (75 hours, no readings), AIRS Point 107/C-131 (277 hours; only 8 daily readings — should be at least 11), AIRS Point 113/C-250 (440 hours; only 12 daily readings — should be at least 18), 114/C-251 (565 hours; only 16 daily readings — should be at least 23), AIRS Point 115/C-252 (537 hours; only 14 daily readings — should be at least 17), 116/C-253 (632 hours; only 18 daily readings — should be at least 26), AIRS Point 117/C-254 (694 hours; only 21 daily readings — should be at least 29) July 2013 AIRS Point 101/C-211 (737 hours; only 5 daily readings — should be at least 30) August 2013 AIRS Point 101/C-211 (716 hours; only 4 daily readings — should be at least 31), AIRS Point 102/C-167 (711 hours; only 18 daily readings — should be at least 29), AIRS Point 103/C-179 (612 hours; only 15 daily readings — should be at least 25), AIRS Point 113/C-250 (623 hours; only 15 daily readings — should be at least 26), AIRS Point 114/C-251 (717 hours; only 19 daily readings — should be at least 30), AIRS Point 116/C-253 (214 hours; only 4 daily readings — should be at least 9), AIRS Point 117/C-254 (726 hours; only 19 daily readings — should be at least 30) September 2013 AIRS Point 101/C-211 (703 hours; only 5 daily readings — should be at least 29), AIRS Point 107/C-131 (36 hours) October 2013 AIRS Point 101/C-211 (730 hours; only 3 daily readings — should be at least 30), AIRS Point 115/C-252 (330 hours; only 7 daily readings — should be at least 14) November 2013 AIRS Point 101/C-211 (690 hours; only 5 daily readings — should be at least 29), AIRS Point 103/C-179 (422 hours; only 8 daily readings — should be at least 13), AIRS Point 115/C-252 (704 hours; only 22 daily readings — should be at least 29), AIRS Point 116/C-253 (636 hours; only 12 daily readings — should be at least 26), AIRS Point 117/C-254 (703 hours; only 22 daily readings — should be at least 29) December 2013 AIRS Point 101/C-211 (729 hours; only 5 daily readings — should be at least 30), AIRS Point 102/C-167 (687 hours; only 17 daily readings - should be at least 28), AIRS Point 103/C-179 (528 hours; only 1 daily reading — should be at least 22), AIRS Point 113/C-250 (660 hours; only 16 daily readings — should be at least 27), 114/C-251 (632 hours; only 17 daily readings — should be at least 26), AIRS Point 115/C-252 (719 hours; only 16 daily readings — should be at least 30), AIRS Point 116/C-253 (658 hours; only 8 daily readings — should be at least 27), AIRS Point 117/C-254 (617 hours; only 17 daily readings — should be at least 26) January 2014 AIRS Point 101/C-211 (742 hours; only 3 daily readings — should be at least 31), AIRS Point 103/C-179 (359 hours; only 9 daily readings — should be at least 15), AIRS Point 114/C-251 (408 hours; only 11 daily readings — should be at least 17), AIRS Point 115/C-252 (697 hours; only 25 daily readings — should be at least 29) February 2014 AIRS Point 101/C-211 (661 hours; only 4 daily readings — should be at least 28) April 2014 AIRS Point 101/C-211 (606 hours; only 3 daily readings — should be at least 25), AIRS Point 113/C-250 (617 hours; only 16 daily COLORADO his Pollution Control Division c.nrb.WUU 01 WOK NOM' b readings — should be at least 25), AIRS Point 114/C-251 (450 hours; only 4 daily readings — should be at least 19) May 2014 AIRS Point 101/C-211 (200 hours; only 3 daily readings — should be at least 8) June 2014 AIRS Point 101/C-211 (573 hours; only 5 daily readings — should be at least 24), AIRS Point 107/C -I31 (691 hours; only 21 daily readings — should be at least 29) July 2014 AIRS Point 101/C-211 (704 hours; only 4 daily readings — should be at least 29), AIRS Point 103/C-179 (604 hours; only 21 daily readings — should be at least 25) August 2014 AIRS Point 101/C-211 (740 hours; only 4 daily readings — should be at least 31) ii. DCP failed to record the AFRC O2 mV reading on a weekly basis for AIRS Point 103/C-179 in December 2013 (66 hours of operation, no reading — should be 1); and AIRS Point 107/C-131 in July 2014 (360 hours of operation; 1 reading — should be 2). iii. DCP failed to record the catalyst differential pressure ("dP") and/or failed to conduct appropriate maintenance or perform a portable analyzer test when the dP was outside the baseline range for the following AIRS Points/RICE: RICE Unit # /AIRS Point Missed Monthly Catalyst dP Readings (with Hours of Operation for that Month) Recorded Catalyst dP Outside Baseline Range Reported Maintenance or Portable Analyzer Test for Catalyst dP Outside Baseline Range C -21I/101 None June 2014, May 2014, Jan. 2014, Feb. 2013, Jan. 2013, Nov. 2012 None C-167/102 June 2014 (666), May 2014 (426), April 2014 (707), Jan. 2013 (585) None N/A C-179/103 Dec. 2013 (528) None N/A C-129/104 Apr. 2013 (21) None N/A C-134/ 105 Apr. 2013 (22), Nov. 2012 (296) None N/A C-130/106 Apr. 2013 (25), Jun. 2013 (75) None N/A C-131/107 July 2014 (434), Mar. 2014 (52), Sept. 2013 (36), June 2013 (277) December 2012 None C250/113 June 2013 (440) None N/A C251/114 Jan. 2014 (408), None N/A COLORADO Air Pollution Control Division tarry men, a WOK I.,atfh h rn.^on.r• Dec. 2013 (632), June 2013 (565) C252/115 June 2013 (405) None N/A C253/116 June 2013 (632) May 2014 None C254/117 June 2013 (694) July 2014, July 2013, May 2013, April 2013, March 2013 None iv. DCP failed to monitor and record the thermal oxidizer combustion temperature when the TEG Dehydrator was reported to be in operation on October 14, 2012; October 24, 2012; December 30, 2012; September 11, 2013; September 23, 2013; October 31, 2013; November 21, 2013 — December 8, 2013; December 11, 2013; February 6, 2014; March 1, 2014; March 2, 2014; March 5, 2014; March 6, 2014; March 25, 2014 — March 27, 2014; and April 1, 2014 - April 9, 2014. v. DCP failed to record whether the flare pilot light was lit on the following dates: December 26 — 31, 2013; December 5 — 14, 2013; July 6, 2013; June 21 — 23, 2013; June 17, 2013; June 11 — 12, 2013; May 14, 2013; January 17, 2013; December 30, 2012; December 26 — 27, 2012; November 19, 2012; November 4, 2012; October 31, 2012; October 1, 2012; and September 13, 2012. DCP submitted s electronically recorded data to the Division on October 8, 2015 showing the pilot light was lit or partially lit on all but 8 days during the inspection period. On November 17, 2015 the Division requested that DCP recalculate the control efficiency of the flare for the days the pilot light was not lit or was partially lit. DCP supplied the recalculated control efficiencies to the Division on December 1, 2015. vi. DCP failed to conduct a Method 22 reading of the condensate tanks' flare on the following dates: December 26 — 31, 2013; December 5 — 14, 2013; July 6, 2013; June 21 — 23, 2013; June 17, 2013; June 11 — 12, 2013; May 14, 2013; January 17, 2013; December 30, 2012; December 26 — 27, 2012; November 19, 2012; November 4, 2012; October 31, 2012; October 1, 2012; and September 13, 2012. vii. DCP failed to operate the PRVs on the condensate storage tanks to ensure flashing, working and breathing losses (as applicable) arc routed to the control device under normal operating conditions. COLORADO Air Pollution Control Division _l.-}tvv.! et %bSK Wn ltb F. ne.on-r i. The monthly average condenser outlet temperature for the TEG Dehydrator under AIRS Point 122 exceeded the 145° F limit in October 2013 (149.12 °F), September 2013 (160.55 °F), August 2013 (156.77 °F), July 2013 (182.22 °F), June 2013 (180.33 °F), May 2013 (157.47 °F), November 2012 (182.33 °F), October 2012 (148.56 °F), September 2012 (161.59 °F) and August 2012 (177.13 °F), violating Permit Number 09WE 1136, Condition 34. Also, based on information provided by DCP, the Division will no longer pursue enforcement for the issues identified in Paragraphs A.viii, E, I, J.v, L, and M of the Compliance Advisory. 9. The Division and DCP entered into settlement discussions for the violations as determined by the Division. The Parties reached a settlement that is detailed in this Consent Order. III. ORDER and AGREEMENT Based on the foregoing factual and legal determinations, pursuant to its authority under § 25-7-115, C.R.S., and as a result of the violations cited herein, the Division orders DCP to comply with all provisions of this Consent Order, including all requirements set forth below. 10. DCP agrees to the terms and conditions of this Consent Order. DCP agrees that this Consent Order constitutes an order issued pursuant to § 25-7-115, C.R.S., and is an enforceable requirement of Part 1 of the Act. DCP also agrees not to challenge directly or collaterally, in any judicial or administrative proceeding brought by the Division to enforce this Consent Order or by DCP against the Division: a. the issuance of this Consent Order; b. the factual and legal determinations made by the Division herein; and c. the Division's authority to bring, or the court's jurisdiction to hear, any action to enforce the terms of this Consent Order under the Act. 11. Notwithstanding the above, DCP does not admit to any of the factual or legal determinations made by the Division herein, and any action undertaken by DCP pursuant to this Consent Order shall not constitute an admission of liability by DCP with respect to the condition of the Facility. In addition, and without limitation as it relates to other disputed claims, DCP specifically does not concede, admit or agree with the Division's factual determinations in Section II, Paragraphs 8.a.vi, 8.b.i, 8.b.v, 8.b.vi, 8.e, 8.f , 8.g and 8.h.vii. Compliance Requirements 12. Effective immediately, and without limitation, DCP shall comply with the Act and the Regulations in the regulation and control of air pollutants. COLORADO Ass Pollution Control Diviston Drtvr:m.rn d hake Heath t. 1.c.vre 13. For the seven (7) components remaining on Delay of Repair identified in 8.f above, repair shall be completed no later than the next process unit shutdown before the end of 2016. 14. Within ninety (90) days of the effective date of this Consent Order, DCP shall complete any necessary repairs to ensure the PRVs on the condensate storage tanks are operated to ensure flashing, working and breathing losses (as applicable) are routed to the control device under normal operating conditions as required by the approved O&M Plan per Permit Number 09WE1136, Condition 33. 15. All documents submitted under this Consent Order shall use the same titles as stated in this Consent Order, and shall reference both the case number and the number of the paragraph pursuant to which the document is required. Unless otherwise specifically provided herein, no document submitted for Division approval under this Consent Order may be implemented unless and until written approval is received from the Division. Any approval by the Division of a document submitted under this Consent Order is effective upon receipt by DCP. All approved documents, including all procedures and schedules contained in the documents, are hereby incorporated into this Consent Order, and shall constitute enforceable requirements under the Act. Administrative Penalty Requirements 16. Based upon the factors set forth in § 25-7-122, C.R.S., the Division has determined an administrative penalty in the amount of Fifty -Six Thousand Seven Hundred Dollars ($56,700.00) against DCP is appropriate and consistent with the Division's policies for violations of the Act and the Regulations cited in Section II of this Consent Order. DCP agrees to pay the sum of Fifty -Six Thousand Seven Hundred Dollars ($56,700.00) in administrative penalties. Payment is due within thirty (30) calendar days of the effective date of this Consent Order by certified, corporate or cashier's check drawn to the order of "Colorado Department of Public Health and Environment" and delivered to the attention of the Manager, Compliance, Air Pollution Control Division, 4300 Cherry Creek Drive South, APCD-SS-B 1, Denver, Colorado 80246-1530. IV. SCOPE AND EFFECT OF CONSENT ORDER 17. The Parties agree and acknowledge that this Consent Order constitutes a full and final settlement of the violations cited herein. This Consent Order is final agency action. DCP agrees not to challenge the terms and conditions of this Consent Order in any proceeding before any administrative body or any judicial forum, whether by way of direct judicial review or collateral challenge. 18. This Consent Order shall be enforceable by either party in the same manner as if the Division had entered this Consent Order without agreement by DCP. The Parties agree that any violation of the provisions of this Consent Order by DCP concerning the Act, or the Regulations, shall be a violation of a final order of the Division for the purposes of §§ 25-7-115, 121, and 122, C.R.S., and may result in the assessment of civil penalties of up to Fifteen COLORADO Au Pollution Control Division wmlvxm Cl Platt- ••' it b ! nwc lr.n Thousand Dollars ($15,000.00) per day for each day of such violation. 19. The Parties' obligations under this Consent Order are limited to the matters expressly stated herein or in approved submissions required hereunder. All submissions made pursuant to this Consent Order are incorporated into this Consent Order and become enforceable under the terms of this Consent Order as of the date of approval by the Division. 20. The Division's approval of any submission, standard, or action under this Consent Order shall not constitute a defense to, or an excuse for, any prior violation of any requirement under the Act, the Regulations, or any subsequent violation of any requirement of this Consent Order, the Act, or the Regulations. 21. Entering into this settlement shall not constitute an admission of violation of the air quality laws by DCP, nor shall the Division or any third party infer it to be such an admission by DCP in any administrative or judicial proceeding. Notwithstanding the foregoing or anything in this Consent Order to the contrary, the described violation will constitute part of DCP's compliance history for any purpose for which such history is relevant, including considering the violation described above in assessing a penalty for any subsequent violations, in accordance with the provisions of § 25-7-122, C.R.S., against DCP. 22. DCP shall comply with all applicable Federal, State, and/or local laws and regulations and shall obtain all necessary approvals or permits to conduct the investigation and remedial activities required by this Consent Order and perform its obligations required hereunder. The Division makes no representation with respect to approval and permits required by Federal, State, or local laws or regulations other than those specifically referred to herein. 23. Nothing herein shall be construed as prohibiting, altering, or in any way limiting the ability of the Division to seek any other remedies or sanctions available by virtue of DCP's violation of this Consent Order or of the statutes and regulations upon which this Consent Order is based, or for DCP's violation of any applicable provision of law. V. LIMITATION RELEASES AND RESERVATION OF RIGHTS AND LIABILITY 24. Upon the effective date of this Consent Order, and during its term, this Consent Order shall stand in lieu of any other enforcement action by the Division with respect to the violations cited herein. This Consent Order does not grant any release of liability for any violations, regardless of when they occurred, that are not cited in this Consent Order. The Division reserves the right to bring any action it deems necessary to enforce this Consent Order, including actions for penalties and/or injunctive relief 25. Nothing in this Consent Order shall preclude the Division from imposing additional requirements necessary to protect human health or the environment and to effectuate the purposes of this Consent Order. Nor shall anything in this Consent Order preclude the Division from imposing additional requirements in the event that additional information is discovered that indicates such requirements are necessary to protect human health or the COLORADO Alr Pollution Control Dwuion rK..n.ne .: r/ Put*...IIft b in. .ew. n environment. 26. DCP reserves its rights and defenses regarding liability in any proceedings regarding the Facility other than proceedings to enforce this Consent Order. 27. Upon the effective date of this Consent Order, DCP releases and covenants not to sue the State of Colorado as to all common law or statutory claims or counterclaims arising from, or relating to, the violations of the Act or the Regulations specifically addressed herein. 28. DCP shall not seek to hold the State of Colorado or its employees, agents or representatives liable for any injuries or damages to persons or property resulting from acts or omissions of DCP, or those acting for or on behalf of DCP, including its officers, employees, agents, successors, representatives, contractors or consultants in carrying out activities pursuant to this Consent Order. DCP shall not hold out the State of Colorado or its employees, agents or representatives as a party to any contract entered into by DCP in carrying out activities pursuant to this Consent Order. Nothing in this Consent Order shall constitute an express or implied waiver of immunity otherwise applicable to the State of Colorado, its employees, agents, or representatives. 29. The Division reserves the right to bring any action or to seek civil or administrative penalties for any past, present, or future violations of the Act and the Regulations, not specifically addressed herein. Further, the Division has the right to bring any action to enforce this Consent Order and to seek authorized penalties for any violation of this Consent Order. VI. FORCE MAJEURE 30. DCP shall perform the requirements of this Consent Order within the schedules and time limits set forth herein and in any approved plan unless the performance is prevented or delayed by events that constitute a force majeure. A force majeure is defined as any event arising from causes which are not reasonably foreseeable, which are beyond the control of DCP, and which cannot be overcome by due diligence. 31. Unless otherwise provided in the Act or the Regulations, within seventy-two (72) hours of the time that DCP knows or has reason to know of the occurrence of any event which DCP has reason to believe may prevent DCP from timely compliance with any requirement under this Consent Order, DCP shall provide verbal notification to the Division. Within seven (7) calendar days of the time that DCP knows or has reason to know of the occurrence of such event, DCP shall submit to the Division a written description of the event causing the delay. the reasons for and the expected duration of the delay, and actions which will be taken to mitigate the duration of the delay. 32. The burden of proving that any delay was caused by a force majeure shall at all times rest with DCP. If the Division agrees that a force majeure has occurred, the Division will so notify DCP. The Division will also approve or disapprove of DCP's proposed actions for mitigating the delay. If the Division does not agree that a force majeure has occurred, or if the COLORADO Division disapproves of DCP's proposed actions for mitigating the delay, it shall provide a written explanation of its determination to DCP. Pursuant to the Dispute Resolution section, within fifteen (15) calendar days of receipt of the explanation, DCP may file an objection. 33. Delay in the achievement of one requirement shall not necessarily justify or excuse delay in the achievement of subsequent requirements. In the event any performance under this Consent Order is found to have been delayed by a force majeure, DCP shall perform the requirements of this Consent Order that were delayed by the force majeure with all due diligence. VII. DISPUTE RESOLUTION 34. If the Division determines that a violation of this Consent Order has occurred; that a force majeure has not occurred; that the actions taken by DCP to mitigate the delay caused by a force majeure are inadequate, the Division shall provide a written explanation of its determination to DCP. Within fifteen (15) calendar days of receipt of the Division's determination, DCP shall: a. Submit a notice of acceptance of the determination; or b. Submit a notice of dispute of the determination. If DCP fails to submit either of the above notices within the specified time, it will be deemed to have accepted the Division's determination. 35. If DCP files any notice of dispute, the notice shall specify the particular matters in the Division's determination that DCP seeks to dispute, and the basis for the dispute. Matters not identified in the notice of dispute shall be deemed accepted by DCP. The Division and DCP shall have thirty (30) calendar days from the receipt by the Division of the notification of dispute to reach an agreement. If agreement cannot be reached on all issues within this thirty (30) day period, the Division shall confirm or modify its decision within an additional fourteen (14) days, and the confirmed or modified decision shall be deemed effective and subject to appeal in accordance with the Act and the Colorado Administrative Procedure Act, Article 4, Title 24, Colorado Revised Statutes. VIII. NOTICES 36. Unless otherwise specified, any report, notice or other communication required under the Consent Order shall be sent to: For the Division: Enforcement Unit Supervisor Colorado Department of Public Health and Environment APCD-SS-B 1-1400 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 ®COLORADO An Pollution COMIS Division For DCP: John Admire, Senior Director, Environment DCP Midstream, LP 370 17`h Street, Suite 2500 Denver, Colorado 80202 COLORADO Aa Pollution Control Division _rc.mnr, 0 uok ✓ Ann b FSLLrnnnn> IX. OBLIGATIONS UNAFFECTED BY BANKRUPTCY 37. The obligations set forth herein are based on the Division's police and regulatory authority. These obligations require specific performance by DCP of corrective actions carefully designed to prevent on -going or future harm to public health or the environment, or both. Enforcement of these obligations is not stayed by a petition in bankruptcy. DCP agrees that the penalties set forth in this Consent Order are not in compensation of actual pecuniary loss. Further, the obligations imposed by this Consent Order are necessary for DCP and the Facility to achieve and maintain compliance with State law. X. MODIFICATIONS Parties. 38. This Consent Order may be modified only upon mutual written agreement of the XI. BINDING EFFECT, AUTHORIZATION TO SIGN AND EFFECTIVE DATE 39. This Consent Order is binding upon the Parties to this Consent Order and their corporate subsidiaries or parents, their officers, directors, agents, attorneys, employees, contractors, successors in interest, affiliates and assigns. The undersigned warrant that they are authorized to bind legally their respective principals to this Consent Order, and that the Parties have the authority to enter into this Consent Order. This Consent Order shall be effective upon the date signed by the last party. In the event that a party does not sign this Consent Order within thirty (30) calendar days of the other party's signature, this Consent Order becomes null and void. This Consent Order may be executed in multiple counterparts, each of which shall be deemed an original, but all of which shall constitute one and the same Consent Order. COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT By: Date: 11 C annon M ` illan Compliance and Enforcement Program Manager Air Pollution Control Division DCP MIDSTREAM, LP By: 641er-Date: u /n/zaV William L. Johnson Vice President, Operations — North Region COLORADO Atr Pollution Control Division cc: Shannon McMillan, APCD Jennie Morse, APCD Tom Roan, Office of Attorney General Adam Eisele, US EPA Scott Patefield, US EPA Jeffrey W. Schwarz, Esq.. CSMKF Tim Taylor, APCD Jen Mattox, APCD Heather Wuollet, APCD Michael Stovern, US EPA File CERTIFIED MAIL: 7011 2000 0001 3463 8864 DATE OF MAILING: June 21, 2013 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION STATIONARY SOURCES PROGRAM NOTICE OF VIOLATION Case No. 2013-035 and 2013-036 In the Matter of DCP Midstream, LP The Colorado Department of Public Health and Environment ("CDPHE"), through the Air Pollution Control Division ("Division"), issues this Notice of Violation to DCP Midstream, LP ("DCP") pursuant to the Division's authority under § 25-7-115(2), C.R.S. I. ALLEGED FINDINGS OF FACT AND PROVISIONS OF LAW ALLEGED TO HAVE BEEN VIOLATED 1. The Division issues this Notice of Violation following an investigation of DCP's Mewboum Natural Gas Processing Plant ("Mewbourn"), located in SE 'A Section 35, Township 4 North, Range 66 West. Mewbourn is subject to statutes and regulations including, but not limited to, the terms and conditions of Colorado Construction Permit Number 09WE1136, Issuance 2, issued to DCP on June 28, 2012 ("Permit Number 09WE1136 Issuance 2"), Colorado Air Quality Control Statutes, and Colorado Air Quality Control Commission ("AQCC") Regulations. Mewbourn was previously subject to Permit Number 09WE1136, Issuance 1, issued to DCP on June 21, 2011 ("Permit Number 09WE1136 Issuance 1"). 2. Equipment subject to Permit Number 09WE1136 Issuances 1 and 2 includes: Facility Equipment ID AIRS Point Description C-129 104 One 4 -stroke, combustion output Emissions Catalytic (collectively Waukesha (1) Waukesha, L7042 GU, SN: 286822, natural gas fired, rich -burn, naturally aspirated, reciprocating internal engine, heat input rated at 6.4 MMBTU per hour, rated at 896 HP, running a natural gas compressor. are controlled by AFR and a Non -Selective Reduction system. ("Mewbourn Waukesha with AIRS Points 105, and 106 "Mewbourn Engines") 104") COMPLIANCE ORDER ON CONSENT En the Matter of DCP Midstream, LP AIRS No: 123/0090 Facility Equipment AIRS Description Point ID C-134 105 One (1) Waukesha, L7042GU, SN: 285300, natural gas fired, 4 -stroke, rich -burn, naturally aspirated, reciprocating internal combustion engine, heat input rated at 6.4 MMBTU per hour, output rated at 896 HP, running a natural gas compressor. Emissions are controlled by AFR and a Non -Selective Catalytic Reduction system. ("Mewbourn Waukesha 105") C-130 106 One (1) Waukesha, L7042GSI, SN: 339839, natural gas 4 -stroke, rich -burn, turbocharged, reciprocating internal combustion engine, heat input rated at 11.2 MMBTU per fired, hour, output rated at 1,478 HP, running a natural gas compressor. Emissions are controlled by AFR and a Non -Selective Catalytic Reduction system. ("Mewboum Waukesha 106") C250 113 One (1) Caterpillar, G3608TALE, SN: BEN00563, natural fired, 4 -stroke, turbo -charged, lean -burn, low emissions reciprocating internal combustion engine, heat input rated 17.9 MMBTU per hour, output rated at 2,370 HP, powering gas design, at a with natural gas compressor. Emissions are controlled by an oxidation catalyst. Identified as Residue 1. (collectively AIRS Points 114, 115, 116, and 117 "Mewbourn Caterpillar Engines") AM001 120 Natural gas sweetening (by removal of Carbon Dioxide Hydrogen Sulfide) system (Precision Pipe & Vessel, LLC, Model T502, SN: 2381-9089) using a 50% solution of Methyldiethanolamine (MDEA), process feed gas design at 160 MMSCF per day, and an amine recirculation rate gallons per minute. This system consists of: natural gas and rated of 640 / oxidizer tank to the amine contactor, amine flash tank, and amine regenerator (heating unit under AIRS PT ID: 123/0090/121). Emissions from the still vent are routed to a regenerative thermal (AIRS PT ID: 123/0090/124). Emissions from the flash are routed to a vapor recovery unit (VRU) and returned plant inlet. ("Mewbourn Amine Unit") 2 COMPLIANCE ORDER ON CONSENT In the Matter of DCP Midstream, LP MRS No: 123/0090 Facility Equipment ID AIRS Point Description D-931 122 Natural gas (TEG), (Exterran, MMSCF glycol recirculation 50 gallons glycol contactor, (heat provided supplemented 123/0090/123). VRU and routed through oxidizer dehydration per day, per minute). by by Flash returned a condenser, (AIRS PT SN: and two rate glycol hot gases a hot tank to the ID: system using Triethylene 8907) process feed (2) electric Rotor of 25 gallons per This system consists flash tank, glycol from various oil heater (AIRS off gases are plant inlet. Still and then to 123/0090/124). design minute regenerator combustion Point directly vent regenerative ("Mewbourn pumps glycol rated each of: natural ID: routed emissions at 160 with design (total of gas / reboiler processes to a are thermal Dehy") TO701 124 One (1) Anguil Environmental Services, Inc., Model 200, SN: 14808, regenerative thermal oxidizer, heat input design rated at 11.0 MMBTU per hour. Natural gas used for startup. This is equipped with Low NOx combustion system for minimization of Nitrogen Oxides emissions. Emissions from various processes at this facility are routed into this thermal oxidizer for thermal destruction. Natural gas is used for startup to raise the temperature to normal operating level. ("Mewbourn RTO") 3. On August 24, 2012, Ms. Jennifer Mattox, of the Division, inspected Mewbourn. DCP provided supplemental information via electronic mail on August 31, 2012; September 21, 2012; September 24, 2012; September 28, 2012; October 10, 2012; and October 22, 2012. 4. On November 2, 2012, DCP conducted compliance testing on the Mewbourn RTO. Results from the Mewbourn RTO testing were received by the Division on December 3, 2012. From November 6-8, 2012; November 12-15, 2012; and on November 21, 2012; DCP conducted compliance testing on the Mewbourn Waukesha Engines. Results from the testing of the Mewbourn Waukesha Engines were received by the Division on December 18, 2012. Mr. Jeremy Murtaugh, of the Division, was present at Mewbourn on October 29, 2012; November 2, 2012; November 5-8, 2012; November 12-15, 2012; and November 21, 2012 to observe testing and testing preparations. 5. Based upon Ms. Mattox's August 24, 2012 inspection, information provided through DCP's supplemental submissions, and records pertaining to Mewbourn, the Division has identified the following alleged violations: A. Pursuant to AQCC Regulation No. 1, §II.A.5., no owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is 3 COMPLIANCE ORDER ON CONSENT In the Matter of DCP Midstream, LP MRS No: 123/0090 in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. A malfunction event at Mewbourn on August 10, 2011 caused un-stabilized condensate vapors to be sent to the emergency flare, an Air Pollution Emission Notice ("APEN") exempt emissions point at Mewbourn, causing opacity in excess of 30% for approximately 3 hours. Pursuant to AQCC Common Provisions Regulation, §II.E.2, the owner or operator of the facility experiencing excess emissions during a malfunction shall notify the Division verbally as soon as possible, but no later than noon of the Division's next working day, and shall submit written notification following the initial occurrence of the excess emissions by the end of the source's next reporting period. DCP verbally notified the Division of the opacity event on August 10, 2011, but DCP did not submit a written notification by the end of the source's next reporting period, February 1, 2012, and this violation does not qualify for an affirmative defense under AQCC Common Provisions Regulation, §II.E.2. DCP failed to prevent emissions from the emergency flare in excess of 30% opacity for approximately three hours on August 10, 2011, violating AQCC Regulation No. 1, §II.A.5. B. Pursuant to 40 C.F.R. 60 §63.774(d)(1) and Permit Number 09WE1136 Issuance 1, Condition 31, DCP may demonstrate the Mewbourn Dehy is exempt from the Area MACT HH general requirements by maintaining records of the actual average benzene emissions in accordance with §63.772(b)(2), as evidence that actual annual benzene emissions from the dehydration unit process vent are under 0.90 megragrams per year, 1,984 pounds per year. To date DCP has failed to provide accurate G1yCalc runs to demonstrate actual average annual benzene emissions under 0.90 megagrams, in accordance with §63.772(b)(2), and thereby qualify for the Area MACT HH exemption for the Mewbourn Dehy, violating 40 C.F.R. 60 §63.774(d)(1)and Permit Number 09WE 1136 Issuance 1, Condition 31. C. Pursuant to Permit Number 09 WE 1136 Issuance 1, Condition 5, DCP was required to limit pollutant emissions to the following Nitrogen Oxide ("NOr"), Volatile Organic Compound ("VOC"), and Carbon Monoxide ("CO") limits: Annual Limits in Tons Per Year ("tov" Emissions Point NO„ VOC CO Mewbourn Amine Unit 1.84 Mewbourn Dehy 3.80 Mewbourn Waukesha 105 0.73 0.44 1.47 4 COMPLIANCE ORDER ON CONSENT In the Matter of DCP Midstream, LP AIRS No: 123/0090 Monthly Limits in Tons Per Month ("tam" Emissions Point NO,, VOC CO Mewbourn Amine Unit 0.16 Mewbourn Dehy 0.32 DCP calculated annual and monthly VOC emissions for the Mewbourn Amine Unit and Mewbourn Dehy and provided them to the Division. However, these calculations attributed 99% control to the Mewbourn RTO and that control efficiency has not been demonstrated by compliance testing conducted under representative conditions, as required by AQCC Common Provisions Regulation §II.C.3., therefore, DCP failed to demonstrate compliance with the annual and monthly VOC limits for the Mewbourn Amine Unit and Mewbourn Dehy from June 2011 through June 2012, violating Permit Number 09WE1136 Issuance 1, Condition 5. ii. DCP calculated the following annual pollutant emissions from the Mewbourn Waukesha 105 for the rolling twelve month period from July 2011 to June 2012: NO„ VOC CO 0.99 tpy 1.98 tpy 0.59 DCP reported NO„ and VOC emissions that exceeded the rolling twelve month emission limits for the period from July 2011 to June 2012, violating Permit Number 09WE1136 Issuance 1, Condition 5. D. Pursuant to Permit Number 09WE1136 Issuance 1, Condition 7, compliance with the emission limits for the Mewbourn Amine Unit shall be demonstrated by running the Promax simulation model or Division - approved software on a monthly basis using the most recent amine unit inlet extended sour gas analysis and recorded operational values (including gas throughput, lean amine recirculation rate, VRU downtime, and other operational values as specified in the O&M plan). DCP is using the most recent sour gas analysis, monthly avenges of operational parameters and running a Promax simulation on a monthly basis. The resulting lb/hr is multiplied by the hours in the month, and 100% control is applied to the flash tank vapors that are•routed to the Facility's low pressure VRU, and 99% control is attributed to the still vent emissions routed to the RTO. Using the emission methodology permitted under Permit Number 09WE1136 Issuance 1, DCP did not report any monthly emission exceedances. However, DCP's calculations attributed 99% control to the Mewbourn RTO and that control efficiency has not been 5 COMPLIANCE ORDER ON CONSENT In the Matter of DCP Midstream, LP AIRS No: 123/0090 demonstrated by compliance testing conducted under representative conditions, as required by AQCC Common Provisions Regulation §II.C.3.. DCP failed to demonstrate compliance with the emission limits from the Mewbourn Amine Unit from June 2011 through June 2012, violating Permit Number 09WE1136 Issuance 1, Condition 7. E. Pursuant to Permit Number 09WE 1136 Issuance 1, Condition 9, compliance with the emission limits for the Mewbourn Dehy shall be demonstrated by running the GRI GlyCalc model version 4.0 or higher on a monthly basis using the most recent wet gas analysis and recorded operational values (including gas throughput, lean glycol recirculation rate, VRU downtime, flash tank temperature, flash tank pressure, and other operational values specified in the O&M Plan). In review of the emissions simulations from the GlyCalc runs, the Division identified several non -representative inputs in the provided GlyCalc runs. DCP provided updated GlyCalc runs on October 22, 2012, but failed to rectify the following discrepancies: a. For the June 2011 GlyCalc run, DCP input a glycol circulation rate of 11.1 gallons/minute ("gpm") with a recorded rate of 16.0 gpm. The updated October 22, 2012 GlyCalc run used a rate of 17.0 gpm, and the supplement October 22, 2012 records indicated a rate of 18.36 gpm. b. For the March 2012 GlyCalc run, DCP input a glycol circulation rate value of 9.17 gpm, with a recorded rate of 19.9 gpm. The updated October 22, 2012 GlyCalc run input a rate of 10.6 gpm. c. For the May 2012 GlyCalc run, DCP input a glycol circulation rate of 14.4 gpm, with a recorded rate of 25.14 gpm. The updated October 22, 2012 GlyCalc run input a rate of 12.6 gpm, and the supplement October 22, 2012 records indicated a rate of 25.46 gpm. DCP's calculations also attributed 99% control to the Mewbourn RTO and that control efficiency has not been demonstrated by compliance testing conducted under representative conditions, as required by AQCC Common Provisions Regulation §II.C.3. Based on the testing results and the deficiencies in the GlyCalc runs, as described above, DCP has failed to demonstrate compliance with permitted emission limits for the Mewbourn Dehy from June 2011 through June 2012, violating Permit Number 09WE 1136 Issuance 1, Condition 9. 6 COMPLIANCE ORDER ON CONSENT In the Matter of DCP Midstream, LP AIRS No: 123/0090 F. Pursuant to Permit Number 09WE1136 Issuance 1, Condition 11, DCP is required to limit Mewbourn Waukesha 105 to a maximum annual fuel consumption rate of 9.11 MMscf/yr. DCP reported the following fuel consumption exceedances for C-134: Rolling 12 ending Reported (MMScf/yr) 13.22 June 2012 May 2012 12.36 April 2012 12.28 DCP failed to limit Mewbourn Waukesha 105 to a maximum annual fuel consumption rate of 9.11 MMscf/yr during three months in 2012, violating Permit Number 09WE1136 Issuance 1, Condition 11. G. Pursuant to Permit Number 09WE1136 Issuance 1, Condition 13, DCP is required to limit the Mewbourn Dehy to a maximum lean glycol circulation rate of 34.9 gpm. The lean glycol recirculation rate is required to be recorded in a daily log maintained on site and made available to the Division for inspection upon request. DCP failed to record TEG circulation rate on June 8, 2011; July 22-23, 2011; August 1, 2011; August 9, 2011; October 25-27, 2011; and December 19, 2011. DCP failed to demonstrate compliance with the Mewbourn Dehy's maximum lean glycol circulation rate limit on nine days in 2011, violating Permit Number 09WE1136 Issuance 1, Condition 13. H. Pursuant to Permit Number 09WE1136 Issuance 1, Condition 24, for any condensate storage tank required to be controlled pursuant to AQCC Regulation No. 7, §XVII.C, DCP is required to record the date, time and duration of any period where the air pollution control equipment is not operating. The Division has requested for DCP to provide downtime information for the flare controlling the Mewbourn Tanks, but, to date, no downtime records to demonstrate downtime have been received, violating Permit Number 09WE1136 Issuance 1, Condition 24. Pursuant to Permit Number 09WE1136 Issuance 1, Condition 33, upon startup of the Mewbourn's emission points, DCP is required to follow the operating and maintenance plan ("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. i. Upon request, DCP was unable to provide an O&M Plan for the Amine Unit, violating Permit Number 09WE1136 Issuance 1, Condition 33. 7 COMPLIANCE ORDER ON CONSENT In the Matter of DCP Midstream, LP AIRS No: 123/0090 ii. For the Mewbourn Reciprocating Internal Combustion Engines ("RICE"), DCP is required under the approved O&M Plan to track changes in differential pressure on a monthly basis to verify that the water column stayed within two inches of the baseline and conduct quarterly portable testing. The Division observed the following deficiencies regarding the RICE: RICE Delta P Portable testing 101 Not recorded ' Jan/Feb/May/June 2012. Completed quarterly, all summaries report 102 Not recorded in Jan 2012 compliance with 103 Recorded monthly. NOx/CO emission limits. Not recorded May 2011 -June No portable testing 104 2012 from 3rd Quarter 2011- 2°d Quarter 2012 Not recorded Jan/Feb 2012, 3rd Q. 2012 failed to 105 June -11 demonstrate compliance with NOx annual emission limits 106 Not recorded Feb- May 2012 No portable testing in 1"&2"Q2012 Not recorded January and Completed quarterly, all 107 March 2012 June 2012 reading of 7", summaries report compliance with baseline reported at 4.4" NOx/CO emission limits. 113 Recorded monthly. 114 115 Not recorded Nov -11 116 June 2012 reading of 2.9", baseline reported at 0.7" 117 Recorded monthly. DCP failed to demonstrate compliance with the O&M Plan for the Mewbourn RICE, due to the deficiencies noted in the table above, violating Permit Number 09WE1136 Issuance 1, Condition 33. iii. For the Mewbourn Dehy, DCP was required to record the glycol circulation rates on a daily basis, which they failed to do on nine occasions as cited in the alleged violation contained in Paragraph 5(G) above, violating Permit Number 09WE1136 Issuance 1, Condition 33. 8 COMPLIANCE ORDER ON CONSENT In the Matter of DCP Midstream, LP AIRS No: 123/0090 Based on Mr. Murtaugh's testing and testing preparation observations on October 29, 2012; November 2, 2012; November 5-8, 2012; November 12-15, 2012; and November 21, 2012; a review of the testing results received on December 3, 2012 and December 18, 2012; and a review of records pertaining to Mewbourn, the Division has identified the following alleged violations: Mewbourn RTO J. Pursuant to Permit Number 09WE1136 Issuance 2, Conditions 1, 37, 40 and 41, DCP was required to conduct compliance testing on the Mewbourn Amine Unit, Mewbourn Dehy, and Mewbourn RTO to demonstrate compliance with permitted emissions limits within one 180 days after permit issuance. Compliance testing must be conducted while equipment is operating within 90% of rated capacity, and under conditions representative of normal operation, as stated in Paragraph 8 of the Division's Compliance Test Manual (Revision 2 from June 2006). DCP conducted testing on November 2, 2012, but the Mewbourn Dehy was operating at 110 MMscf/day, 69% of its permitted rated capacity of 160 MMscf/day. In addition, DCP performed unreported maintenance on the RTO, prior to compliance testing. As a result of operating the Mewbourn Dehy at reduced processing rates during the test and performing unreported maintenance on the RTO, the Division cannot verify that this testing was conducted during conditions representative of normal operation. DCP was issued Permit Number 09WE1136 on June 28, 2012 and successful compliance testing was due by December 25, 2012. To date DCP has not successfully completed compliance testing to show compliance with emission standards and emission limits, violating Permit Number 09WE1136 Issuance 2, Conditions 1, 37, 40 and 41. K. Pursuant to C.R.S. §25-7-111(2)(c) and (i), and the Division's request made pursuant to this statutory provision by a December 18, 2012 electronic mail transmission to Jill Thornberry and Stephen Ondak of DCP, DCP was required to provide all Mewbourn RTO maintenance records, both routine and non -routine, from November 1, 2011 to the present day, by no later than December 28, 2012. To date DCP has not provided the records requested, violating C.R.S. §25-7-111(2)(c) and (i). Mewbourn RICE L. Pursuant to Permit Number 09WE1136 Issuance 2, Condition 5, DCP is required to limit NO„ emissions from Mewbourn Waukesha 104 to 0.73 tpy. DCP performed compliance testing on Mewbourn Waukesha 104 on November 7, 2012, which demonstrated a NO,, emission rate of 0.76 tons per year. DCP has failed to limit the emission rate of NOX to 0.73 tons per year, violating Permit 09WE1136 Issuance 2, Condition 5. 9 COMPLIANCE ORDER ON CONSENT In the Matter of DCP Midstream, LP MRS No: 123/0090 The last successful compliance test on Mewbourn Waukesha 104, prior to November 7, 2012, was in May 1999, so compliance testing has not been successfully conducted since the plant expansion permitted by Construction Permit Number 09WE1136 Issuance 1, which was issued June 21, 2011. The duration of time between compliance tests was from June 21, 2011 through November 21, 2012, when DCP successfully retested Mewbourn Waukesha 104 after replacing the catalyst housing with larger diameter housing and installing two new NSCR catalyst elements. M. Pursuant to Permit Number 09WE1136 Issuance 2, Conditions 1 and 36, DCP is required to conduct compliance testing on Mewbourn Waukesha 106 to demonstrate compliance with various emission standards contained in the permit. Testing was required to be conducted within 180 days of the June 28, 2012 permit issuance; therefore, the successful testing should have been conducted by December 25, 2012. AQCC Common Provisions Regulation, §II.C. specifies that compliance testing shall be conducted under such conditions as the Division shall specify to the plant operator based on representative performance of the affected facility. Because the engine settings were changed the evening before the test, testing was not conducted under conditions representative of normal operation. To date, DCP has not conducted compliance testing to successfully demonstrate compliance with the emission standards and emission limits contained in the permit, violating of Permit Number 09WE1136 Issuance 2, Conditions 1 and 36. H. STANDARD PENALTY PROVISION AND ADDITIONAL RELIEF FOR THE VIOLATIONS AS ALLEGED 1. Sections 25-7-115(3)(b) and 25-7-122(1)(b), C.R.S., provide that any person who violates any requirement of a construction permit or a regulation of the Commission shall be subject to a civil penalty of not more than $15,000.00 per day for each day of such violation. 2. Section 25-7-111(2)(i), C.R.S. empowers the Division to obtain from the district or county court for the district or county in which the source is located a subpoena to compel production of information relating to emissions of the source or to any investigation authorized by Article 7 (Air Quality Control) of C.R.S. Title 25, as reasonably required by the Division under 25-7-111(2)(i), C.R.S. 3. Section 25-7-115(5), C.R.S., requires the Division to determine if a noncompliance penalty is applicable. If the Division finds a noncompliance penalty is applicable, the Division may assess the penalty for any period of violation from the date that non-compliance began until the date on which the emission source is brought into compliance. The Division will review, and have the opportunity to independently verify, any noncompliance penalty calculations submitted in accordance with the provisions of § 25-7-115(5)(b), C.R.S. 10 COMPLIANCE ORDER ON CONSENT In the Matter of DCP Midstream, LP AIRS No: 123/0090 III. CONFERENCE REGARDING THE ALLEGED VIOLATIONS 1. In accordance with the requirements of § 25-7-115(3), C.R.S., the Division has scheduled a conference regarding the violations described above at 10:00 AM on July 17, 2013, in Room CI C at the Air Pollution Control Division offices, located at 4300 Cherry Creek Drive South, Denver, Colorado 80246. This conference will provide DCP an opportunity to submit data, views, and arguments concerning the alleged violations and whether assessment of civil and noncompliance penalties is appropriate. The conference is an informal proceeding; however, you may have legal counsel attend with you. Following the conference and upon completion of our investigation, the Division will determine whether a Compliance Order should be issued and whether a civil penalty and noncompliance penalty must be assessed. The Division may provide further opportunity for you to respond after the conference if circumstances warrant. 2. If the scheduled conference date and time is not convenient for you, please contact Ms. Shannon McMillan, at 303-692-3259, to reschedule the conference. If you have any other questions concerning the conference or other matters prior to the scheduled conference, contact Megan Lowe at 303-692-3123. IV. ADDITIONAL ACTION BY THE DIVISION If DCP fails to attend the conference, the Division will issue a Compliance Order and possibly assess penalties against DCP. Subsequent violation of the Compliance Order may subject DCP to further enforcement action under § 25-7-121, C.R.S. (court injunction) and § 25- 7-122, C.R.S. (civil penalties up to $15,000.00 per day of violation). V. ISSUE DATE OF NOTICE This Notice of Violation shall be considered issued upon mailing in accordance with § 25-7-103(15), C.R.S. 11 COMPLIANCE ORDER ON CONSENT In the Matter of DCP Midstream, LP AIRS No: 123/0090 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT on c i an Field Services Program Manger Stationary Sources Program Air Pollution Control Division tri Je f r ttox Fie d Enforcement Supervisor Stationary Sources Program Air Pollution Control Division cc: Shannon McMillan, APCD Mark McMillan, APCD Paul Carr, APCD Tom Roan, Office of Attorney General Cindy Beeler, US EPA Jennifer Mattox, APCD Jeremy Murtaugh, APCD Megan Garvey, APCD Adam Eisele, US EPA STATE OF OLOFADO John W. Hickenlooper, Governor Christopher E. Urbina, MD, MPH Executive Director and Chief Medical Officer Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr. S. Denver, Colorado 80246-1530 Phone (303) 692-2000 Located in Glendale, Colorado http://www.cdphe.state.co.us Laboratory Services Division 8100 Lowry Blvd. Denver, Colorado 80230-6928 (303) 692-3090 Colorado Department of Public Health and Environment COMPLIANCE ADVISORY Issued By: Air Pollution Control Division 4300 Cherry Creek Drive South MS: APCD-BI-SS Denver, Colorado 80246-1530 Telephone: 303-692-3150 Case No: 2012-057, 2012-058, 2012-062 Issued To: DCP Midstream, LP 370 17th St., Ste. 2500 Denver, CO 80202 Contacts: Paul Park and Stephen Ondak U.S. Certified Mail No. 7011 0470 0000 8929 5182 AIRS Nos: 123/0090, 123/0049, 123/0277 Mailing Date: May 21, 2012 Stack Test Dates: August 29, 2011 through August 31, 2011; September 1, 2011 through September 2, 2011; September 20, 2011; November 29, 2011; December 5, 2011 through December 7, 2011; December 12, 2011 through December 13, 2011; December 16, 2011; and December 20, 2011 Inspection Date: October 25, 2011 This Compliance Advisory provides notice, pursuant to § 25-7-115(2), C.R.S., regarding information gained during the Air Pollution Control Division's ("Division's") inspection and/or review of records related to DCP Midstream, LP's Mewbourn Gas Plant, Roggen Gas Plant and Enterprise Compressor Station Facilities located in Weld County, Colorado. The Division believes that the compliance issues identified below may constitute violations of the Colorado Air Pollution Prevention and Control Act ("the Act") and its implementing regulations. Please be aware that you are responsible for complying with applicable State air pollution requirements and that there are substantial administrative and civil penalties for failing to do so. C.R.S. §25-7-115 provides that any person who violates the Act, its implementing regulations or any permit issued thereunder may be subject to an administrative penalty of up to $15,000 per day of such violation. The issuance of this Compliance Advisory does not in any way limit or preclude the Division from pursuing its additional enforcement options concerning this inspection/review, including issuance of a Compliance Order and assessment of penalties. Also, this Compliance Advisory does not constitute a bar to enforcement action for conditions not addressed in this Compliance Advisory. Failure to respond to this Compliance Advisory by the date indicated at the end of this Compliance Advisory may be considered by the Division in the subsequent enforcement action and the assessment of penalties. Furthermore, the Division's enforcement process contemplates a full and final resolution of the compliance issues herein addressed, and those COMPLIANCE ADVISORY Issued to DCP Midstream, LP AIRS No: 123/0090 (2012-057), 123/0049 (2012-058), 123/0277 (2012-062) that may result from further review, in a timely manner. If at any time throughout the process of reaching such a resolution the Division determines that the Parties cannot agree to the dispositive facts, compliance requirements and/or penalty assessments (if any) associated with this Compliance Advisory, or a resultant enforcement action, the Division may exercise its full enforcement authority allowed under the law. DCP Midstream, LP (hereinafter "DCP") owns and operates the Mewbourn Natural Gas Processing Plant ("Mewbourn"), located in SE'/ Section 35, Township 4 North, Range 66 West; the Roggen Natural Gas Processing Plant ("Roggen"), located in Section 24, Township 2N, Range 63W; and the Enterprise Compressor Station ("Enterprise"), located in SW '/ of SW 'A, Section 30, T2N, R63W, all in Weld County, Colorado (collectively "Facilities"). Mewboum is subject to the terms and conditions of Colorado Construction Permit Number 09WE1136 Issuance 1 issued to DCP on June 21, 2011 ("Permit Number 09WE1136"), Colorado Air Quality Control Statutes, and Colorado Air Quality Control Commission ("AQCC") Regulations. Equipment subject to Permit Number 09WE1136 includes: Facility Equipment ID AIRS Point Description C-129 104 One (1) Waukesha, L7042 GU, SN: 286822, natural gas fired, 4 -stroke, rich -burn, naturally aspirated, reciprocating internal combustion engine, heat input rated at 6.4 MMBTU per hour, output rated at 896 HP, running a natural gas compressor. Emissions are controlled by AFR and a Non - Selective Catalytic Reduction system. (collectively with AIRS Points 105, 106, and 107 "Mewbourn Waukesha Engines") C-1 -1)4 105 One (1) Waukesha, L7042GU, SN: 285300, natural gas fired, 4 -stroke, rich -burn, naturally aspirated, reciprocating internal combustion engine, heat input rated at 6.4 MMBTU per hour, output rated at 896 HP, running a natural gas compressor. Emissions are controlled by AFR and a Non - Selective Catalytic Reduction system. C-130 106 One (1) Waukesha, L7042GSI, SN: 339839, natural gas fired, 4 -stroke, rich -burn, turbocharged, reciprocating internal combustion engine, heat input rated at 11.2 MMBTU per hour, output rated at 1,478 HP, running a natural gas compressor. Emissions are controlled by AFR and a Non - Selective Catalytic Reduction system. C-131 107 One (1) Waukesha, L7042GSI, SN: 397541, natural gas fired, 4 -stroke, rich -burn, turbocharged, reciprocating internal combustion engine, heat input rated at 11.2 MMBTU per hour, output rated at 1,478 HP, running a natural gas compressor. Emissions are controlled by AFR and a Non - Selective Catalytic Reduction system. C250 113 One (1) Caterpillar, G3608TALE, SN: BEN00563, natural gas fired, 4 - stroke, turbo -charged, lean -burn, low emissions design, reciprocating internal combustion engine, heat input rated at 17.9 MMBTU per hour, output rated at 2,370 HP, powering a natural gas compressor. Emissions are controlled by an oxidation catalyst. Identified as Residue 1. (collectively with AIRS Points 114, 115, 116, and 117 "Mewboum Caterpillar Engines") C251 5 1 114 One (1) Caterpillar, G3608TALE, SN: BEN00565, natural gas fired, 4 - stroke, turbo -charged, lean -burn, low emissions design, reciprocating internal combustion engine, heat input rated at 17.9 MMBTU per hour, output rated at 2,370 HP, powering a natural gas compressor. Emissions are controlled by an oxidation catalyst. Identified as Residue 2. 2 COMPLIANCE ADVISORY Issued to DCP Midstream, LP AIRS No: 123/0090 (2012-057L123/0049 (2012-058), 123/0277 (2012-062 Facility Equipment ID AIRS Point Description C252 115 One (1) Caterpillar, G3608TALE, SN: BEN00567, natural gas fired, 4 - stroke, turbo -charged, lean -burn, low emissions design, reciprocating internal combustion engine, heat input rated at 17.9 MMBTU per hour, output rated at 2,370 HP, powering a natural gas compressor. Emissions are controlled by an oxidation catalyst. Identified as Residue 3. C253 116 One (1) Caterpillar, G3608TALE, SN: BEN00572, natural gas fired, 4 - stroke, turbo -charged, lean -burn, low emissions design, reciprocating internal combustion engine, heat input rated at 17.9 MMBTU per hour, output rated at 2,370 HP, powering a natural gas compressor. Emissions are controlled by an oxidation catalyst. Identified as Residue 4. C254 1 117 One (1) Caterpillar, G3608TALE, SN: BEN00571, natural gas fired, 4 - stroke, turbo -charged, lean -burn, low emissions design, reciprocating internal combustion engine, heat input rated at 17.9 MMBTU per hour, output rated at 2,370 HP, powering a natural gas compressor. Emissions are controlled by an oxidation catalyst. Identified as Residue 5. AM001 120 Natural gas sweetening (by removal of Carbon Dioxide and Hydrogen Sulfide) system (Precision Pipe & Vessel, LLC, Model T502, SN: 2381- 9089) using a 50% solution of Methyldiethanolamine (MDEA), process feed gas design rated at 160 MMSCF per day, and an amine recirculation rate of 640 gallons per minute. This system consists of: natural gas / amine contactor, amine flash tank, and amine regenerator (heating unit under AIRS PT ID: 123/0090/121). Emissions from the still vent are routed to a regenerative thermal oxidizer (AIRS PT ID: 123/0090/124). Emissions from the flash tank are routed to a vapor recovery unit (VRU) and returned to the plant inlet. ("Mewbourn Amine Unit") D-931 122 Natural gas dehydration system using Triethyleneglycol (TEG), (Exterran, SN: 8907) process feed design rated at 160 MMSCF per day, and two (2) electric Rotor pumps with design glycol recirculation rate of 25 gallons per minute each (total of 50 gallons per minute). This system consists of: natural gas / glycol contactor, glycol flash tank, glycol regenerator reboiler (heat provided by hot gases from various combustion processes supplemented by a hot oil heater (AIRS Point ID: 123/0090/123). Flash tank off gases are directly routed to a VRU and returned to the plant inlet. Still vent emissions are routed through a condenser, and then to regenerative thermal oxidizer (AIRS PT ID: 123/0090/124). ("Mewboum Dehy") TO701 124 One (1) Anguil Environmental Services, Inc., Model 200, SN: 14808, regenerative thermal oxidizer, heat input design rated at 11.0 MMBTU per hour. Natural gas used for startup. This is equipped with Low NOx combustion system for minimization of Nitrogen Oxides emissions. Emissions from various processes at this facility are routed into this thermal oxidizer for thermal destruction. Natural gas is used for startup to raise the temperature to normal operating level. ("Mewbourn RTO") Roggen is subject to the terms and conditions of Colorado Construction Permit Number l OWE 1659 Issuance 2 issued to DCP on November 22, 2011 ("Permit Number 10WE1659"), Colorado Construction Permit Number 07WE0988 Initial Approval issued to DCP on August 26, 2008 ("Permit Number 07WE0988"), Colorado Air Quality Control Statutes, and Colorado Air Quality Control Commission ("AQCC") Regulations. Equipment subject to Permit Number I 0WE1659 includes: 3 COMPLIANCE ADVISORY Issued to DCP Midstream, LP AIRS No: 123/0090 (2012-057), 123/0049 (2012-058), 123/0277 (2012-062) One (1) Triethylene glycol (TEG) natural gas dehydration unit with a design capacity of 85 MMscf per day ("Roggen Dehy"). This unit is equipped with a flash tank, reboiler and still vent. Emissions from the still vent are routed to a regenerative thermal oxidizer with a minimum control efficiency of 99% ("Roggen RTO"). One (1) Methyldiethanolamine (MDEA)-based natural gas sweetening system for acid gas removal with a design capacity of 85 MMscf/day ("Roggen Amine Unit"). This system includes a natural gas/amine contactor and still vent and reboiler. Still vent emissions shall be routed to the Roggen RTO. Equipment subject to Permit Number 07WE0988 includes: One (1) Waukesha L7042, rated at 1,478 horsepower @ 1,200 rpm, turbo -charged four-cycle standard rich bum, natural gas fired, internal reciprocating combustion engine designated as stack ID C-181 ("Roggen RICE"). This engine is used for Residue Gas Compression. This engine is equipped with air -fuel ration control and NSCR. Enterprise is subject to the terms and conditions of Colorado Operating Permit Number 95OPWE 103, Renewal Issued to DCP on December 1, 2007 ("Permit Number 95OPWE103"), Colorado Air Quality Control Statutes, and Colorado Air Quality Control Commission ("AQCC") Regulations. Equipment subject to Permit Number 95OPWE103 includes a combustion device for still vent control from the triethylene glycol dehydration unit ("Enterprise Flare"), AIRS Point 123/0277/068. Mewbourn On September 20, 2011, compliance testing was conducted on the Mewbourn RTO. No results from this compliance testing event were received by the Division. Because no compliance testing results were submitted for the September 20, 2011 testing event at Mewbourn and based on subsequent correspondence with DCP indicating that emissions from preliminary test results exceeded permitted limits, the Division has identified the following compliance issue: A. Pursuant to Permit Number 09WE1136 Condition 6, through operation of the Mewbourn RTO, DCP was required to achieve 99% overall control efficiency of emissions routed from Mewbourn Dehy and the Mewbourn Amine Unit. Pursuant to Permit Number 09WE1136 Condition 5, the Mewbourn Dehy, Mewbourn Amine Unit, and Mewboum RTO were subject to the following annual, tons per year ("tpy"), and monthly, tons per month ("tpm"), limits: Equipment SOx (tpm/tpy) NOx (tpm/tpy) VOC (tpm/tpy) CO (tpm/tpy) Mewbourn Dehy - - 0.32/3.8 - Mewbourn Amine Unit - - 0.16/1.84 - Mewbourn RTO 1.73/20.4 0.06/0.73 0.34/3.96 DCP commenced compliance testing on the Mewbourn RTO on September 20, 2011 to demonstrate compliance with the limits contained in the table above, but, as DCP notified the Division in an el conic mail message received by Mr._Reinhardt on September 21, 2011, DCP aborted the testing due to preliminary results indicating emissions were exceeding permitted limits_ . As stated in Paragraph 9 of the Division's Compliance Test Manual (Revision 2 from June 2006): If a facility stops a test solely to avoid failing the test, this may be used as credible evidence to show that the source was out of compliance with its emission limitations. DCP conducted further compliance testing on the Mewbourn RTO on December 16, 2011 in an attempt to demonstrate compliance with Permit Number 09WE1136 Condition 6. Mr. Scott Patefield, of the Division, was present to observe the testing and the Division received the test results on January 30, 2012. The December 16, 2011 compliance testing Was -not a representative demonstration of4 compliance under normal operating conditions due to the processing rate being reduced from approximately 147 MMscf/day prior to testing, to 130 MMscf/day immediately prior to commencing the test. COMPLIANCE ADVISORY Issued to DCP Midstream, LP AIRS No: 123/0090 (2012-057), 123/0049 (2012-058), 123/0277 (2012-062) On August 29, 2011 through August 31, 2011 and September 1, 2011 through September 2, 2011, compliance testing was conducted on the Mewbourn Compressor Engines and Mewbourn Caterpillar Engines. The testing on September 1, 2011 and September 2, 2011 was observed by Mr. Jeremy Murtaugh of the Division. Compliance testing results were received by the Division on November 14, 2011. Based on a review of the compliance testing results and records related to the Facility, the Division has identified the following compliance issues: B. Pursuant to Permit Number 09WE1136 Condition 5, DCP was required to limit emissions from Mewbourn Waukesha Engines and Mewbourn Caterpillar Engines to thresholds described below: i. DCP was required to limit emissions from four Mewbourn Waukesha Engines to the following limits: AIRS Point NOx (tpm/tpy) VOC (tpm/tpy) CO (tpm/tpy) 104 0.07/0.73 0.04/0.44 0.13/1.47 105 0.07/0.73 0.04/0.44 0.13/1.47 106 0.31/3.46 0.19/2.18 0.62/7.27 107 0.61/7.14 0.36/4.28 1.21/14.27 DCP commenced compliance testing on the Mewbourn Waukesha Engines on August 31, 2011 and September 1, 2011 to demonstrate compliance with the limits contained in the table above, but DCP aborted the testing due to preliminary results indicating emissions were exceeding permitted limit. As stated in Paragraph 9 of the Division's Compliance Test Manual (Revision 2 from June 2006): If a facility stops a test solely to avoid failing the test, this may be used as credible evidence to show that the source was out of compliance with its emission limitations. DCP failed to demonstrate compliance with annual and monthly NOx, VOC, and CO emission limits for the Mewbourn Waukesha Engines, violating Permit Number 09WE1136 Condition. DCP conducted further compliance testing on three of the Mewbourn Waukesha Engines, AIRS Points 105, 106, and 107, on November 29, 2011 and December 5, 2011 through December 7, 2011, in an attempt to demonstrate compliance with Permit Number 09WE1136 Condition 5. Test results were received by the Division on January 30, 2012. Significant tuning was required, some with the aid of real-time continuous emissions data, for the Mewbourn Waukesha Engines at AIRS Points 106 and 107 to demonstrate compliance with Permit Number 09WE1136 Condition 5, and the Division does not consider this to be a representative demonstration of compliance under normal operating conditions. Testing of the Mewbourn Waukesha Engine at AIRS Point 105 demonstrated monthly NOx emissions of 0.15 tpm and 0.16 tpm and CO emissions of 0.39 tpm and 0.25 tpm during two high load tests, which is in excess of the 0.07 tpm N0x limit and the 0.13 tpm CO limit. ii. Also pursuant to Permit Number 09WE1136 Condition 5, DCP was required to limit combined VOC emissions from the Mewbourn Caterpillar Engines located at AIRS Points 113, 114, 115, 116, and 117 to 2.41 tpm and 28.28 tpy. Compliance test results from testing on August 29, 2011; August 31, 2011; September 1, 2011; and September 2, 2011 on the Mewbourn Caterpillar Engines demonstrated exceedances of the monthly and annual VOC limits as follows: 5 COMPLIANCE ADVISORY Issued to DCP Midstream, LP AIRS No: 123/0090 (2012-057), 123/0049 (2012-058), 123/0277 (2012-062) Engine Cat G3608 Cat G3608 Cat G3608 Cat G3608 Cat G3608 Engine ID C-250 C251* C-252* C-253* C-254* Total Emissions 5 En_'nes High Load Low Load Permit Limits AIRS ID 113 114 115 116 117 High Load Low Load1 High Low High Low 1{igh Low High Low VOCs (twill) 0.59 0.62 0.55 - 0.62* 0.73 0.62* 0.6 0.62* 0.81 0.62* 3.28 3.12 2.41 VOCs (tpy) 7.12 7.49 6.56 7.49* 8.7 7.49* 7.2 7.49* 9.75 7.49* E 32.772 1129.9622 1 28.28 *Only one 30 -minute run was conducted on these engines. Per the APCD Compliance Test Manual, when conducting abbreviated testing, the emissions values from the full length (three -30 minute runs) test shall be used to demonstrate compliance. 1) Monthly mass emission are calculated using the lb/hr emission factor for each engine, and 730 operating hours for each engine (Permit does not restrict monthly operation). 2) Annual emissions are calculated using the lb/hr emission factor for each engine, and 35,040 total annual operating hours, allocated as follows: 8,760 hours for engines C-250, 252, 253 and 254 and 0 operating hours for C-251. The permit does not limit any individual engine's operating hours. For VOC emissions, since the permit allows the engines with the highest emissions to operate 8,760 hours per year, the 4 engines with the highest emissions were used to calculate emissions. DCP failed to limit VOC emissions from the Mewbourn Caterpillar Engines to annual andmonthly limits. violating Permit Number 09WE1136 Condition 5. DCP conducted further compliance testing on the Mewbourn Caterpillar Engines on December 12, 2011 and December 13, 2011, in an attempt to demonstrate compliance with Permit Number 09WE1136 Condition 5. Mr. Paul Buck, of the Division, was present to observe the testing on December 12, 2011 and the Division received the test results on April 23, 2012. Significant tuning was required, some with the aid of real-time continuous emissions data, for the Mewbourn Caterpillar Engines to demonstrate compliance with Permit Number 09WE1136 Condition 5, and the Division does not consider this to be a representative demonstration of compliance under normal operating conditions. C. Pursuant to Permit Number 09WE1136 Conditions 1, 3, 35, 36, 40, and 41, DCP was required to complete compliance testing demonstrations and self -certify compliance with the conditions and emissions limits contained in Permit Number 09WE1136 within one hundred and eighty days (180) after the permit's June 21, 2011 issuance, by December 18, 2011. DCP attempted to demonstrate compliance through compliance testing on the Mewbourn RTO, the Mewbourn Waukesha Engines, and the Mewbourn Caterpillar Engines, but failed to do so as outlined in Paragraphs A and B above. DCP failed to timely demonstrate compliance with the conditions and emissions limits contained in Permit Number 09WE1136 and failed to submit self -certification by December 18, 2011, violating Permit Number 09WE1136 Conditions 1, 3, 35, 36, 40, and 41. Roggen On October 25, 2011, Ms. Jen Mattox, of the Division inspected Roggen. On December 20, 2011, Ms. Mattox observed compliance testing at Roggen. Results from the compliance testing were received by the Division on February 7, 2012. Based on Ms. Mattox's inspection, a review of the compliance testing results, and records related to Roggen, the Division has identified the following compliance issues: D. Pursuant to Permit Number 07WE0988 Condition 3, DCP is required to calculate the rolling 12 -month emission totals of individual and combined Hazardous Air Pollutants ("HAPs") to demonstrate compliance with annual limits, and have those compliance records readily available to provide to the Division for review. In the original records reviewed by Ms. Mattox either during or immediately after her October 25, 2011 inspection of Roggen, DCP failed to calculate both individual and combined HAPs emissions. DCP failed to calculate the rolling 12 -month emission totals of individual and combined Hazardous Air Pollutants ("HAPs") to demonstrate compliance with annual limits, Permit Number 07WE0988 Condition 3. 6 COMPLIANCE ADVISORY Issued to DCP Midstream, LP AIRS No: 123/0090 (2012-057), 123/0049 (2012-058), 123/0277 (2012-062) DCP provided an information supplement to the Division on January 12, 2012, which provided HAPs emissions calculations, but the calculations were done incorrectly, as the most current APEN reported emission factors were not used. E. F. Pursuant to Permit Number 10WE1659 Conditions 11 and 14, through operation of the Roggen RTO, DCP was required to achieve 99% overall control efficiency of emissions routed from the Roggen Dehy and the Roggen Amine Unit. DCP conducted compliance testing on the Roggen RTO on December 20, 2011, and test results demonstrate only 95.4% overall control efficiency. DCP failed to achieve 99% overall control efficiency through operation of the Roggen RTO, violating Permit Number 10WE1659 Conditions 11 and 14. Pursuant to Permit Number 10WE1659 Conditions 2 and 38, DCP was required to demonstrate, and self -certify, compliance with the conditions and destruction efficiency requirements contained in Permit Number l OWE 1659 within one hundred and eighty days (180) after its July 1, 2011 startup, by December 28, 2011. DCP attempted to demonstrate compliance through the December 20, 2011 compliance testing, but failed to demonstrate compliance, as stated in Paragraph E above. DCP timely submitted self -certification on or about December 28, 2011 but failed to demonstrate compliance with the conditions and requirements contained in Permit Number 10WE1659, violating Permit Number 10WE1659 Conditions 2 and 38. G. Pursuant to Permit Number 10WE1659 Condition 16, DCP was required to limit the Roggen Dehy's maximum lean glycol circulation rate to 20 gallons per minute ("gpm"). DCP provided records demonstrating the Roggen Dehy's glycol circulation rate exceeded 20 gallons per minute in both July 2011, with a monthly average of 20.9 gpm reported, and August 2011, with a monthly average of 21.6 gpm reported. On or about October 17, 2011, DCP contacted the Division to notify them that DCP had continued to exceed the maximum lean glycol circulation rate beyond August 2011. Later, DCP notified the Division that on November 4, 2011 the pumps were repaired and the pumps were returned to compliance with the maximum lean glycol circulation rate. DCP failed to limit the Roggen Dehy's maximum lean glycol circulation rate to 20 gallons per minute from July 2011 to November 4, 2011, violating Permit Number l 0WE1659 Condition 16. H. Pursuant to Permit Number I0WE1659 Condition 34, DCP was required to complete a hard count of components at Roggen and establish the number of components that are operated in "heavy liquid service", "light liquid service", "water/oil service" and "gas service" within one hundred eighty (180) days after operation of the Roggen Amine Unit and Roggen Dehy commenced on July 1, 2011, by December 28, 2011. DCP was required to provide this information to the Division as part of the self - certification submission, but when DCP submitted the self -certification on or about December 28, 2011 a hard count of components at Roggen was not included. DCP failed to timely submit a hard count of components at Roggen, violating Permit Number l OWE 1659 Condition 34. DCP provided a hard component count to the Division or about March 2, 2012. Enterprise On October 25, 2011, Ms. Jen Mattox, of the Division inspected Enterprise. Based on Ms. Mattox's inspection and records related to Enterprise, the Division has identified the following compliance issues: I. Pursuant to Permit Number 95OPWE103 Condition 3.1.3, DCP was required to perform an extended gas analysis to collect, sample and analyze inlet gas to determine concentrations of Benzene, Toluene, Ethyl Benzene, and Xylene ("BTEX"). If any of these BTEX constituents concentrations exceed values provided in Condition 3.1.3, including 10.0 ppm of Ethyl Benzene, the frequency of the extended gas analysis is increased to a quarterly basis. DCP conducted an extended gas analysis in October 2009 that demonstrated an analyzed concentration of 14 ppm Ethyl Benzene. DCP failed to provide quarterly extended gas analysis reporting to the Division following the October 2009 results, violating Permit Number 95OPWE103 Condition 3.1.3. 7 COMPLIANCE ADVISORY Issued to DCP Midstream, LP AIRS No: 123/0090 (2012-057), 123/0049 (2012-058), 123/0277 (2012-062) J. Pursuant to Permit Number 95OPWE103 Condition 3.11.1.3, if a flare or other combustion device is used to control emissions of volatile organic compounds, it shall be enclosed and have no visible emissions. During her October 25, 2011 inspection, Ms. Mattox observed visible emissions between 5- 10% opacity over three -to five minutes of observation "puffing" from the flare. DCP provided the Division with an information supplement on December 13, 2011 stating that DCP conducted maintenance on the Enterprise Flare including tuning the level controls and flash tank pressure control. DCP had a third party Method 9 certified tester conduct a visible emissions evaluation EPA Method 22 on December 8, 2011, and the tester observed sporadic opacity emissions of less than 5% opacity from the flare for a total of 4 minutes and 55 seconds for the two hour period. On or about March 13, 2012, DCP submitted an EPA Reference Method 9 opacity reading completed on the Enterprise Flare on or about March 9, 2012 indicating a six minute average opacity of 7.3%. DCP failed to prevent visible emissions from the Enterprise Flare on October 25, 2011, December 8, 2011, and March 9, 2012, violating Permit Number 95OPWE103 Condition 3.11.1.3. The Division notes that it is important to resolve the above -referenced issues as soon as possible. Therefore, the Division encourages DCP to immediately identify those compliance issues that are not in dispute and to rectify those issues before the upcoming Compliance Advisory meeting. The Division also requests that DCP provide the Division with a brief written response to the alleged violations ("Source Response"). The Source Response should identify the undisputed compliance issues and, if an alleged violation is disputed, the basis for the dispute. The Division requests that DCP provide the Source Response, to the attention of Ms. Jen Mattox, no later than ten business days before the Compliance Advisory meeting. At the upcoming meeting, the Division will confirm the actions taken to rectify the undisputed compliance issues and proceed with unresolved matters as outlined below. If you have any questions regarding this Compliance Advisory, the Division's enforcement processes, or any related issues, please refer to the APCD Enforcement Manual located at www.cdphe.state.co.us/ap/down/Enforcement Guide.pdf and/or contact the Division personnel identified below. To close out this Compliance Advisory, DCP is requested to contact the Division and schedule a meeting to: ➢ Discuss the disputed Compliance Advisory issues and answer any remaining questions you may have; > Submit information necessary to successfully show that the deficiencies and noncompliance issues (or any portion of them) are not violations of Colorado's air pollution laws; and Establish a mutually acceptable schedule and guidelines for the full and final resolution of any remaining deficiencies and noncompliance issues in a timely manner. Please contact one of the compliance officers identified below by no later than May 29, 2012 to schedule a meeting with the Division to discuss the Compliance Advisory. The Division currently anticipates that the meeting will take place during the week of June 18_ Shannon McMillan, Field Enforcement Program Manager (303-692-3259) Jen Mattox, Field Enforcement Inspector (303-692-3144) The Division considers the Source Response to be subject to the C.R.E. Rule 408 settlement communication privilege. 8 COMPLIANCE ADVISORY Issued to DCP Midstream, LP AIRS No: 123/0090 (2012-057), 123/0049 (2012-058), cc: Shannon McMillan, APCD Chris Reinhardt, APCD Paul Carr, APCD Mark McMillan, APCD Scott Patefield, APCD Tom Roan, Attorney General's Office Cindy Beeler, EPA (Region VIII) 123/0277 (2012-062) Jeremy Murtaugh, APCD Jen Mattox, APCD Arch Crouse, APCD Marley Bain, APCD Albion Carlson, EPA (Region VIII) File Sec. 23-2-250. - Operation standards. An applicant for a Special Review Permit shall demonstrate conformance with the following operation standards in the Special Review Permit application to the extent that the standards affect location, layout and design of the Use by Special Review prior to construction and operation. Once operational, the operation of the USES permitted shall conform to these standards. A. The operation of the USES shall comply with the noise standards enumerated in Section 25-12-101, C.R.S. B. The operation of the USES shall comply with the air quality regulations promulgated by the Colorado Air Quality Control Commission. C. The operation of the USES shall comply with the water quality regulations promulgated by the Colorado Water Quality Control Commission. D. The USES shall comply with the following lighting standards: 1. Sources of light, including light from high -temperature processes such as combustion or welding, shall be shielded so that light rays will not shine directly onto ADJACENT properties where such would cause a nuisance or interfere with the USE on the ADJACENT properties; and 2. Neither direct nor reflected light from any light source may create a traffic hazard to operators of motor vehicles on PUBLIC or private STREETS and no colored lights may be used which may be confused with or construed as traffic control devices. E. The USES shall not emit heat so as to raise the temperature of the air more than five degrees (5°) Fahrenheit at or beyond the LOT line. F. Property shall be maintained in such a manner that grasses and weeds are not permitted to grow taller than twelve (12) inches. In no event shall the property owner allow the growth of NOXIOUS WEEDS. G. Any off -site and on -site Improvements Agreement shall be made in conformance with the County policy on collateral for improvements, as well as in conformance with Section 12- 5-10 et seq., and the Engineering and Construction Standards in Appendix 12-A. (Weld County Codification Ordinance 2000-1; Weld County Code Ordinance 2007-1; Weld County Code Ordinance 2016-5 ) Weld County, CO Charter and County Code Page 1 of 1 Sec. 23-2-270. - Development standards. An applicant for a Special Review Permit shall demonstrate conformance with and shall continue to meet any DEVELOPMENT STANDARDS approved and adopted by the County. The DEVELOPMENT STANDARDS shall be placed on the Special Review Permit Plan Map prior to recording. Noncompliance with any of the approved DEVELOPMENT STANDARDS may be reason for revocation or suspension of the special review permit by the Board of County Commissioners. Civil penalties in lieu of a suspension may also be imposed with the express prior agreement of the applicant. The availability of these remedies in no way limits the Board of County Commissioners from seeking or applying any other remedies which are available for noncompliance with the development standards. (Weld County Codification Ordinance 2000-1; Weld County Code Ordinance 2001-8) about:blank 5/8/2017 Weld County, CO Charter and County Code Page 1 of 2 Sec. 23-2-280. - Changes to a Special Review Permit. A. Any approved Special Review Permit shall be limited to the items shown on the Special Review plan map and governed by the DEVELOPMENT STANDARDS. Major changes from the approved Special Review Plan Map or DEVELOPMENT STANDARDS for the Special Review Permit shall require the review of an amendment to the permit by the Planning Commission and approval by the Board of County Commissioners before such changes from the plan map or DEVELOPMENT STANDARDS are permitted. The Department of Planning Services is responsible for determining whether a major change exists. Any other changes shall be filed with the Department of Planning Services with the approved Special Review Permit. B. Any decrease in the land mass occupied by a Use by Special Review Permit shall qualify the landowner to be able to request a partial vacation of the Use by Special Review from the Board of County Commissioners, permitting the following: 1. The subject property under consideration for a partial vacation of the Use by Special Review has received permission to release the property from the permit from applicable County and State agencies. An example would be the release of a portion of a gravel mining operation from the Colorado Division of Mining Reclamation and Safety at the completion of the reclamation activities on the subject property. Evidence of such release shall be provided to the Department of Planning Services with the request to vacate such portion of the property. 2. The partial vacation process defined herein does not create separate parcels. 3. To obtain a partial vacation of the Use by Special Review permit, the applicant shall: a. Submit a letter to the Department of Planning Services requesting the partial vacation. b. about:blank 5/8/2017 Weld County, CO Charter and County Code Page 2 of 2 Submit a revised Use by Special Review plat to the Department of Planning Services illustrating the vacated portion of the property and the existing permit. The revised plat shall include a note stating that the partial vacation does not create separate parcels. 4. Upon determination of compliance with the original Use by Special Review permit and all applicable applications, this Chapter and Chapter 29 of this Code, by the Department of Planning Services, the applicant shall be granted a partial vacation of the Use by Special Review permit. 5. Once approved, the applicant must submit a plat conforming to Subsection 23-2-260.D of this Code. This plat shall illustrate the vacated portions of the property/operation. The plat shall contain two (2) vicinity maps. The first shall illustrate the use boundary prior to the partial vacation. The second shall illustrate the use boundary after the partial vacation. (Weld County Codification Ordinance 2000-1; Weld County Code Ordinance 2009-8 ; Weld County Code Ordinance 2011-3 ) about:blank 5/8/2017 10 II 12 13 14 17 18 22 31 32 v- U- T- 5- R - Or 0- N eel dr G - r.. 0 - C e_ A DCP Midstream 3rdAmUSR-542 LEGAL DESCRIPTION SE 1/4, Section 35. Township 4 North, Range 66 West of the 6th P.M. w St -41 0 -tor FCEND e PROPERTY CORNER • SECTION CORNER A ACCESS POINT NOTES t ALL Plitt ReOti1 W WAY ARE ADJACENT TO CORRY ROADS 2. net ARE NO N,pRpORAPtIC FEATURES DOE Art NO ADJACOFT INICATION DITCHES 3 TIE PROPERTY SLOPES GRADUALLY TO 'C NORM Wet ARE NO Spl6w nn TOPOGRAPHICAL CHANGES. t A 6' OWN DIE ma DEMOS DC PWOE7.tY KING mom= M on USA. 5. MO OTHER LANDSCAPING IS PROPOSED. I DOE IS 1 ACCESS POINT ON DE EAST 90E OF Delft* AND 1 CONECIMO TM no PLANTS era M U.Sr 7 NMI ARE NO n00p OR 00 LOGIC HAZARDS: DENS ARE NO MINERAL was. e. one ARE NO MISTY EASEMENTS i _ 1/ Of7 .E _1osg.?7 QE 000U 3rd Am USR-542 t30UNDARY II x II %rQ Jl' or w %tor (UW p01ACARY Left) EAST IAE SE 1/4 SEC 3n 4458 �72 1 \l 4 33rd 12 U 3 33 35 7 4 72 �� e 3� 73 70 69 A47 toll SURVEY 3rd Am USR-542 BOUNDARY M Xt_Wi t_at at_-_ I IIII MIMIlagild] Mill I8aVII1111 sets ISM et.w Weld Ccasr. CO 111 1 R TAI OILS an Moreno ant I n.oeder e w 33, gel LaoED II CLOSED N 00' 21' 10'w 771N' . .. .. .]4.Rh7 r sAY- j 477 eW ) 47 35 \/ T e r . 447:7 0000 ann MIMI ss s net 7= === RAJ. IOU 511001.N5Y4r la_ N SOL WX11Alt 9uLLOW DfGVATOOSS 0SIZMOOSLNOS *1110UT SAWS O WTI BAWLS 4 LL Ca.ea L SUILOP IS SVE FARM LNC $t 5TWIIATED) Yee W C TAINT A11500001100. NROS 47 airy LM iS.My Sir Slight Sight lye/ 11104 7a Wall Sad 'Lamy Son Sight Spit Wiest. lir NO 72 Von. ltd 955Th Spit Sigt Sys Mr Ye. a go 1e6p Nix 3,1,0 eras rutted! Linda Faob-J sag owe a dA•erel land sod of narty. Era It alter Lama Fairy Dal ore all aimed lgn at. ass ad uarthua4 or play. ty TULL LEGAL DESCRIPTION OF USR BOUNDARY A Iran of 108 Seward Owner (SE 1/4) Of Swan 35. Terry 4 Stn. Rana N Pat ef the Sigh (6) Prneps us. , Wad Canty. Sate .f Snide. So bap a pates or 1081 arum panel deeot.d In the Remand Eea,paa Nor 1007-36-4-fr-not roams et Raaptkn No. 21tMfl et 108 Ind County Sled N the O.t end Reorder. de.oaed a fda.a COSIOIC N am tag Oh. -Conan (E 1/4) crier of odd area apt Nara S 02' 3Y M' IL a alas.. el /0N.3• pet toe pant et the laaeed one d the 1Mueaan 1 pats naerad W pea 1077 el R.cwear M. 02017304 ens ere POET OF MESS lance S 00 3•' or W demo O. led Ryhl-of-Ooy of the aW Canty ROW 35 (N loot Rq 4 -of -Way). o des t of 10110 fed trooper Wm daces So, Ssdhead corms d .•lE Sake 35 Ms. S 02' IT yr E. • alum.. d 55411 Met Thence N r 24 00' R • rear d SMOG fiat to • point Deco N 07 SF 00' E. • disbar el 1050.00 feet t • pent Thee S IV 24' 00' E. • Stan* el 4700000 ea/ tee peat MOS a Ud .at batedery lbw Of .ME Shan t awes S 00 35' arts the saw oat Mladey M. Ada* of 430 Mn IS • peel! located N the Sera.ai owner el sod N•.1 t k Thence S K 24' 00' C den the south baedey the ere end ninon l • Serena. er 3500 I.M le tot POINT OF IKONS CalaMkg • reteloted ono or 553.451 square MN or 11552 ores. PLANNING COMMISSION CERTIFICATION This N to certify that the Weld County Planning Commission has certified and does hereby recommend to the Board of County Commissioners, Weld County, Cdorodo, for its confirmation, approve and adoption of this Site Specific Development Plan and Use by Specie Review as a1L...nand_ deserted F-thereon this _a_doy of FyffA.n M•i . 201. Chair, Weld FCounty Planning Commission BOARD OF COUNTY COIaOS90tERS C(RTIF1CATION This le to certify that the Board of County Commissioners, Weed County . Colorado. does hereby confirm and adopt this SIN Specific Devrapnnet Plan and Use by specie Review and anted. as shown and deserted hereon this ay of *94010 air 2(127 Chair, Boar ATTEST! Weld County Clerk to BY: Depu y Clerk to the : '' d` PROPERTY OWNERS CERTIFICATE The undersigned major property owner does hereby agree to the Site Specific Development Pion and Use by Speed Review Development Standards os described hereon this 4B_day of Sentare.- . 2DQ9 2 `a Ruch. 1 Vice President, DCP Midstream Development Standards ^s Sit. tc.tt Orrapsen3 Plan ad Tat Lnfded Us by Sps,i Ian erne /Se, . fur *Wire Rearm Cer.cen'ad reelltilibikellsg .r a and Gee &wart end Sera unity (a .rd Des woesem/ Foray) a the A (.Bata) Za. District. N • t e)tct to the D.wleemoµ Staset elated traew I Appron of tae plan may coots a veiled properly nem pascal In Section 73-a-Io M the Weld County Cos. 3 Al Itala and need vendee in denied In the Sol.a Motto. D.,po.o ]rte. ad Feria Act. Sedtlon 30-20-300.5. CRS. Std be .toed and removed tar Mad armed n a morns' that pretest egos. aurae end e'aadwete aantedatlln . Ire pewwrart deer el wade end be penn.itd et We St.. Mb Is net nail le .Mid• eras emotes eeenal•y envied inn the demitlnn ere sore ens .n Use SS Ste. Seed Ms end reeler Ail 30--20-1005- CR I fate a.erlda Inn M Para- stored. and Seen M Y eneweiter Sat. rasa bAAN. Ml RoNhe plYdele .,as -s, mewing ICS. ad saw pausal wawa orare. • 1W. eppeaat did .ponds h orordonc..,a the oppror.d aide Hader, Me 7 r.r.. *at M 'jr- path -onto rears rat be contrd.d a Ode Ws Ter les/ty red be aware n ...,.,.note Nor M a uroved Dos! "bonnet Pion at d lames_ n the fenny did .0k. s to the maevm-r :err-atere nose ewes atoned n a s I (Nepal)bale detect ) bale Oct a dslbN .•d le Satre 14-5-30 of IM VW; County Conn S. Adeseeta grammes hand sating and tan 4OCRtk, end te prodded for arptey..11 and petrels of lbe MceRy. to My spark ayelern located en en property most <onply etch d prw/daee of the add Cary Cede, pertaining to MOMS Slap tescil Salina 11. Pa.pNe tat hare (Portable tdets) she De provided during the canetructan of the locsly. 12. The l.dity dla Sze the salting public wore supply. (Centro, add County Water Dblrkt) 13. Al potwnlldy hotadwm chemicals molt be "toted and hunded in a sale manner. In octoroonce with product toning. ' and n a motor that minimizes the release of hazardous of pdutants and ratatio organic compound. 14 If asdroN , the appeoaa Isar aka a Storm Nectar,* eermn horn the Cdvo0e Dgrrimert of PUS -0 IJledrh W ( w wort. Voter *roily Central Dane � 13' The genies stet serer WS / aPrere are sae reidal .. ae.o. ere tale alw^.f^ M:r. w Carr Coto It A Mang pant epelloeltan not be canpl.t.d. on two to'WNte NO' of pans. rd'.e.g eeld"ee'od lardotlon plea ally a ON Sr of a Cara. reg4tes adWlecl or ergo.e. moll N a,b.tted Tor rotes A teepee rikel termed.• ,*at. performed by o Carodo regbterd aol.aion l .gilt.r. root be rewired. 17. A Pat Nave ad le aprored and a era must be bead pr+a to sat of cor.tn.ltot 1L Stoat ate idlest ~ea oat o ddwrerned by the we cant y Cod. IS. vi_ ad panes te the reddr meet. of the 2006 ntamutrend Damp lit dsntl d. a. take, rue, Gee. and .0 flew Ca... a... OSSe► M 2008 Nehomd &.ante Coe. arid Chests 73 of the add Cant, Code 2s. AS/ Or M Peiltedi -Qad1 Fire Protection Dbbtct a reposed prla lc att.n IS of pion to non 21. Waiy height ad ad awe" protecoot and butabore and ..euta' of trainee of mead eraaetry de♦-ONl.ne die be In acco0o,ee .an the Baldng Cade Setboct and offset dslaect. Goa be 4.4,.. .4 by Chard 23 al the One Canty Code Offnt and setback. deletion are reaped Sam the Mites proalicn tram the bease'g a The eft-Orst p.jYnp arm inducing the ocean dean tot be me fand with ryan or the tall rdant. Ord ad M Ivied to paint drainage problems. 23. The emir el the prepafty ai pay lee the motwtas and the cost of eeldalwn for new rood ooeen onsets .n.n•nr the hildiellee of a culvert b mode necessary by the creation of a ne. access from prisole papery -d le • Csay red, by any Stearn el the noturd flow of sole scene prhon property by the owner. orb/any OIIre Milan e•Ned by any Dow of private property lb. naval else .a be determined In accordance enh e tdldpN MRplwi.t.g pristine. 1a property owns ad be r..perble he cleaning the borrow ditch to the intent HMS t sea.w.sd,te the rood aeon real and lading proper range 24. The hktsted Sew pollenm and runoff amounts war be mankind on the sale n such a mover that It we -t r.sanaly pr.•erte the natural character of the arse and prevent property do'roge of the type generally olbtbated le art fete and Mary Hammes. amnia cancenbolbn ova/n. anpbrns coral of .torn' ^nett 25. the .pee -eel le need to comply Nth o Cenral* baetm.nt of 'wow. end Environment. Water Oddity Control Seen r.5Mtla. re.l*p Plamenter dead preodtay ad pseecta M orselnan M... a.le Sd,orga .A 74 Abe a. le e•M•e le esrep/y r a Ceara O Cue se CCaea•..aa Cdneewr (COCCC) Mo it eM rep/•aa. e.IAeAr SW pee a eincw. trearew craft ad rearview 27. 'M epprca4 snare contact the tftly Coadieator b The aid Canty Deportment of Pubic wale. at (570) 304 -pea. rot 3750. Ir a aght-of-way awned far ay were tr'at may be ,sawed in the fir d soy an Canty Roods 35 are a A special trarreaet permit .e be rsoted b any onneed at awrerget vehicles .hide may access 0e site. 2s. EM.cthe Jitney I. 2003. b.J*'g pent bead an the lot ire s reams to oO.r to the In "trvchre of the Canty -w10. And Impact Fee Program 29. Emecth. Avast I. 2005. ee•A"g parrs Wad on Use .mitt site N be rafted to nasem to ta fee W arr of Its. CaPtld (wanton assoct Fee and the Stora.soter/Dranoge m.oct ra Propan 30the haft we Caneply with the approved Magri Pen and Socha 23-3-2500 I (.100y Standards) M the Wad Canty Cede. 31. Should maws aide not on the property. or aeeene eoloaaed a 0 rests of the proposed development. the GeeroarlSendowner des be response for cantreebp the nealoo egad& p.c,an1 la Section 15-1-150. C.R.S. 32 IM property owner a operator end be r•oon.bla for oonri g wIth the Design Slandad. of Section 23-2-240 of the Meld Cary Cede, V u t -S ,-P rN We. peyptr4,aeeer a open emit Pe mersomiteseer w.ryeg an W Ol.Ns Sean of Saar 73e2 -)gar el la add Cams; Cave 34 TAW Crrty Cennnsa porn sad be granted oaten onto the properly at any rnea.Me Urns in ceder to inane the eclmlen cored out an the properly comply with the Devdapn'ent Standards elated herein and all oppkdp. Wed County winked SS TA. Thin Aresrdd Un by Shedd Renee ad dud be angled to the prone Own herein and govard by the w.golng standards an all Oppi able USE Canty reg:Aotlor.. Setetantbe cAa. ere ban the pions a D.,Sc as vt Slondad. a .born ce dated drop eept. the approval of en amdbnent of the Peron by to wda Cavity Town of Canty Ccrsn,4 home, belie such deasgn from one don. a De,deprne't Sta.ad, ere 0ernat.d My other then" shall be Weda ea anla of the Dartnent et Meng Sean Jr Teer_ pnpsry w es can a stop be e.apos.i' 'a caneryisa es de* re anew S.vrw—aea Seaar& v__,.iaeae eM en el the for leper Orear- t Stem a e., le rend' Ice ASS et M Pear by as teas d Cray Casa. sae. -J N -G -( IDr S Mal - Sea O OS - cdcpr Midstream_ In tete Pat 110116111. as 7d to wlh6O =DO it, POO L1e5 M SO KS KIS 9111St OOAI SOS at Far Will t t Mr MP O t t at/02/01 65/27/01 we War w Q WELD COUNTY, COLORADO MEWBOURN PLANT Ii 3rdNnUBR-842 SITE SPECIFIC DEVnOPS®IT PLAN-SHT. I DRAFTED MTE a/t•/N rtWPItO*I. BY: we CHECKED BY: POP SCAL NOM DIRE: w/u/rn I 01/81/01 al/1•/Df lee OAE eT • SSR en ISSUE . 1 I - DWG NO. D -03303-01-004A i I 2 3 4 5 • 7 • s la i1 11 13 — . r ' —t 14 IS Is /7 Io l9 . r 20 23 22 23 24 25 25 27 21 b 30 11.01 MTV ISSUE F 0 -C B A 31 32 33 ACRD ralNAIE: SITE SPECIFIC DEVELOPMENT PLAN USE BY SPECIAL REVIEW PERMIT DEVELOPMENT STANDARDS 4MUSR16-83-542 1. A Site Specific Development Plan and 4th Amended Use by Special Review Permit No. USR-542 for Mineral Resource Development Facilities, oil and gas support and service, Natural Gas Processing facility, and the addition of one Lease Automatic Custody Transfer (LACT) unit which includes 2 pumps, a filter, and one meter housed inside a pre -fabricated CDOH approved building in the A (Agricultural) Zone District. (DCP Midstream, LP — Mewbourn Gas Plant), subject to the Development Standards stated hereon. 2. Approval of this plan may create a vested property right pursuant to Section 23-8-10 of the Weld County Code. (Department of Planning Services) 3. The hours of operation are 24 hours a day, seven days a week, as stated by the applicant(s). (Department of Planning Services) 4 The number of employees is ten (10) as stated by the applicant(s). (Department of Planning Services) 5. All liquid and solid wastes (as defined in the Solid Wastes Disposal Sites and Facilities Act; 30-20-100.5, C.R.S., as amended) shall be stored and removed for final disposal in a manner that protects against surface and groundwater contamination. (Department of Public Health and Environment) 6. No permanent disposal of wastes shall be permitted at this site. This is not meant to include those wastes specifically excluded from the definition of a solid waste in the Solid Wastes Disposal Sites and Facilities Act, 30-20-100.5, C.R.S., as amended. (Department of Public Health and Environment) 7. Waste materials shall be handled, stored, and disposed of in a manner that controls fugitive dust, fugitive particulate emissions, blowing debris, and other potential nuisance conditions. The applicant shall operate in accordance with Chapter 14, Article 1 of the Weld County Code. (Department of Public Health and Environment) 8. The applicant shall operate in accordance with the approved Waste Handling Plan. (Department of Public Health and Environment) 9. Fugitive dust and fugitive particulate emissions should attempt to be confined on the property. Uses on the property should comply with the Colorado Air Quality Commission's air quality regulations. The facility shall be operated in accordance with the approved Dust Abatement Plan at all times. (Department of Public Health and Environment) 10. The facility shall adhere to the maximum permissible noise levels allowed in the I (Industrial) Zone District, as delineated in Section 14-9-30 of the Weld County Code. (Department of Public Health and Environment) 11. Adequate drinking, hand washing and toilet facilities shall be provided for employees and patrons of the facility, at all times. (Department of Public Health and Environment) 12. Any septic system located on the property must comply with all provisions of the Weld County Code pertaining to On -site Wastewater Treatment Systems (0WTS). (Department of Public Health and Environment) 13. Adequate toilet facilities (Portable toilets) shal be provided during the construction of the facility (Department of Public Health and Environment) 4MUSR16-83-542— DCP Midstream, LP Mewbourn Gas Plant Page 6 14. The facility shall utilize the existing public water supply. (Central Weld Water District). (Department of Public Health and Environment) 15. All potentially hazardous chemicals must be handled in a safe manner in accordance with product labeling. All chemicals must be stored secure, on an impervious surface, and in accordance with manufacturer's recommendations. (Department of Public Health and Environment) 16. If applicable, the applicant shall obtain a Storm Discharge Permit from the Colorado Department of Public Health and Environment, Water Quality Control Division. (Department of Public Health and Environment) 17 The applicant shall submit an Air Pollution Emission Notice (A.P.E.N.) and Emissions Permit Application and obtain a permit from the Air Pollution Control Division, Colorado Department of Public Health and Environment, as applicable. (Department of Public Health and Environment) 18 The operation shall comply with all applicable rules and regulations of State and Federal agencies and the Weld County Code. (Department of Public Health and Environment) 19. The property owner or operator shall provide written evidence of an approved Emergency Action and Safety Plan on or before March 15th of any given year signed by representatives for the Fire District and the Weld County Office of Emergency Management to the Department of Planning Services. (Department of Planning Services) 20 Sources of light shall be shielded so that light rays will not shine directly onto adjacent properties where such would cause a nuisance or interfere with the use on the adjacent properties in accordance with the plan. Neither the direct, nor reflected, light from any light source may create a traffic hazard to operators of motor vehicles on public or private streets. No colored lights may be used which may be confused with, or construed as, traffic control devices. (Department of Planning Services) 21. All signs shall adhere to Chapter 23, Article IV, Division 2 and Appendices 23-C, 23-D and 23-E of the Weld County Code. (Department of Planning Services) 22. The historical flow patterns and runoff amounts on the site will be maintained. (Department of Planning Services -Engineer) 23. Weld County is not responsible for the maintenance of onsite drainage features. (Department of Planning Services -Engineer) 24. The property owner shall control noxious weeds on the site. (Department of Public Works) 25. The access on the site shall be maintained to mitigate any impacts to the public road including damages and/or offsite tracking. (Department of Public Works) 26. There shall be no parking or staging of vehicles on public roads. On -site parking shall be utilized. (Department of Public Works) 27. The existing point on County Road 35 approximately 2400 feet North of County Road 38 shall be gated and locked at all times except for seasonal maintenance. (Department of Public Works) 28. Building permits may be required, per Section 29-3-10 of the Weld County Code. Currently, the following have been adopted by Weld County: 2012 International Codes. 2006 International Energy Code, and 2014 National Electrical Code. A Building Permit Application must be completed and two (2) complete sets of engineered plans bearing the wet stamp of a Colorado registered architect or engineer must be submitted for review. A Geotechnical Engineering Report 4MUSR16-83-542— DCP Midstream, LP Mewbourn Gas Plant Page 7 performed by a Colorado registered engineer shall be required or an Open Hole Inspection. (Department of Building Inspection) 29. Building Permits issued on the proposed lots will be required to adhere to the fee structure of the Weld County Road Impact Program. (Department of Planning) 30. Building Permits issued on the proposed lots, will be required to adhere to the fee structure of the County Facility Fee and Drainage Impact Fee (Department of Planning) 31. The property owner or operator shall be responsible for complying with the Design Standards of Section 23-2-240, Weld County Code. (Department of Planning Services) 32. The property owner or operator shall be responsible for complying with the Operation Standards of Section 23-2-250, Weld County Code. (Department of Planning Services) 33. Necessary personnel from the Weld County Departments of Planning Services, Public Works, and Public Health and Environment shall be granted access onto the property at any reasonable time in order to ensure the activities carried out on the property comply with the Conditions of Approval and Development Standards stated herein and all applicable Weld County regulations. (Department of Planning Services) 34. The Special Review area shall be limited to the plans shown hereon and governed by the foregoing standards and all applicable Weld County regulations. Substantial changes from the plans or Development Standards as shown or stated shall require the approval of an amendment of the Permit by the Weld County Board of County Commissioners before such changes from the plans or Development Standards are permitted. Any other changes shall be filed in the office of the Department of Planning Services. (Department of Planning Services) 35. The property owner or operator shall be responsible for complying with all of the foregoing Development Standards. Noncompliance with any of the foregoing Development Standards may be reason for revocation of the Permit by the Board of County Commissioners. (Department of Planning Services) 36. RIGHT TO EXTRACT MINERAL RESOURCES STATEMENT Weld County has some of the most abundant mineral resources, including, but not limited to, sand and gravel, oil. natural gas, and coal. Under title 34 of the Colorado Revised Statutes, minerals are vital resources because (a) the state's commercial mineral deposits are essential to the state's economy; (b) the populous counties of the state face a critical shortage of such deposits; and (c) such deposits should be extracted according to a rational plan, calculated to avoid waste of such deposits and cause the least practicable disruption of the ecology and quality of life of the citizens of the populous counties of the state. Mineral resource locations are widespread throughout the County and person moving into these areas must recognize the various impacts associated with this development. Often times mineral resource sites are fixed to their geographical and geophysical locations. Moreover, these resources are protected property rights and mineral owners should be afforded the opportunity to extract the mineral resource. 37. WELD COUNTY'S RIGHT TO FARM: Weld County is one of the most productive agricultural counties in the United States, typically ranking in the top ten counties in the country in total market value of agricultural products sold. The rural areas of Weld County may be open and spacious, but they are intensively used for agriculture. Persons moving into a rural area must recognize and accept there are drawbacks, including conflicts with long-standing agricuiturai practices and a lower level of services than in town. Along with the drawbacks come the incentives which attract urban dwellers to relocate to rural areas: open views, spaciousness, wildlife, lack of city noise and congestion, and the rural atmosphere and way of life. Without neighboring farms, those features which attract urban dwellers to rural Weld County would quickly be gone forever. 4MUSR16-83-542— DCP Midstream, LP Mewbourn Gas Plant Page 8 Agricultural users of the land should not be expected to change their long-established agricultural practices to accommodate the intrusions of urban users into a rural area. Well -run agricultural activities will generate off -site impacts, including noise from tractors and equipment; slow -moving farm vehicles on rural roads; dust from animal pens, field work, harvest and gravel roads; odor from animal confinement, silage and manure; smoke from ditch burning; flies and mosquitoes; hunting and trapping activities; shooting sports, legal hazing of nuisance wildlife; and the use of pesticides and fertilizers in the fields, including the use of aerial spraying. It is common practice for agricultural producers to utilize an accumulation of agricultural machinery and supplies to assist in their agricultural operations. A concentration of miscellaneous agricultural materials often produces a visual disparity between rural and urban areas of the County. Section 35-3.5-102, C.R.S., provides that an agricultural operation shall not be found to be a public or private nuisance if the agricultural operation alleged to be a nuisance employs methods or practices that are commonly or reasonably associated with agricultural production. Water has been, and continues to be, the lifeline for the agricultural community. It is unrealistic to assume that ditches and reservoirs may simply be moved "out of the way" of residential development. When moving to the County, property owners and residents must realize they cannot take water from irrigation ditches, lakes, or other structures, unless they have an adjudicated right to the water. Weld County covers a land area of approximately four thousand (4,000) square miles in size (twice the size of the State of Delaware) with more than three thousand seven hundred (3,700) miles of state and County roads outside of municipalities. The sheer magnitude of the area to be served stretches available resources. Law enforcement is based on responses to complaints more than on patrols of the County, and the distances which must be traveled may delay all emergency responses, including law enforcement, ambulance, and fire. Fire protection is usually provided by volunteers who must leave their jobs and families to respond to emergencies. County gravel roads, no matter how often they are bladed, will not provide the same kind of surface expected from a paved road. Snow removal priorities mean that roads from subdivisions to arterials may not be cleared for several days after a major snowstorm. Services in rural areas, in many cases, will not be equivalent to municipal services. Rural dwellers must, by necessity, be more self-sufficient than urban dwellers. People are exposed to different hazards in the County than in an urban or suburban setting. Farm equipment and oil field equipment, ponds and irrigation ditches, electrical power for pumps and l is _ _ - high J traffic, _ J L..... L..-. . a L..�-s 4ae. aI i.--wry dogs ..�..eJ L.:el ite' pivot operations, Mgr 11 speed sand uui a, puncture dints, territorial: iwr ia' farm dugs ai d livestock, and open burning present real threats. Controlling children's activities is important, not only for their safety, but also for the protection of the farmer's livelihood. 4MUSR16-83-542- DCP Midstream, LP Mewbourn Gas Plant Page 9 Oil & Gas Noise Elimination I Noise Reduction Walls 11 Page 1 of 5 f8+intor �b 888-823-5131 REQUEST A QUOTE SOUND -ABSORPTION SCIENCE BLOG CONTACT US OIL a GAS NOISE REDUCTION WALL BARRIERS An expanding global demand and expanding domestic energy reserves have fueled renewed interest in America's oil & gas business. With a growing distaste for our dependence on foreign sources of oil, companies both large and small are scrambling to find domestic reserves in commercial quantities. This aggressive approach has led companies to search for and produce oil and natural gas, hydrocarbons, in locations previously considered too close to residential and commercial development. And while exploration companies generally go the extra mile to accommodate and appease affected landowners, one issue has proven more challenging than most: Noise. N 4! D J EXHIBIT 571,3uSRFT 93-5 https://noisebarrierwalls.com/oil-gas-noise-reduction-wall-barriers/ 5/30/2017 Oil & Gas Noise Elimination I Noise Reduction Walls Page 2 of 5 How Do Production Companies Reduce Compressor Noise? There are two primary noise attenuation techniques widely used for compressor systems. One involves a fully -enclosed, sound -attenuated building. The other involves a high-performance, sound -absorptive peripheral noise barrier. Both designs are extremely effective at mitigating noise, but there are significant differences between the two. 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QUICK LINKS • HOME » SOUND -ABSORPTION » SCIENCE » BLOG » CONTACT US https://noisebarrierwal l s.com/oil-gas-noise-reduction-wall-barriers/ 5/30/2017 Letterhead June 12, 2017 Dear xxxxx, RECEIVED JUN 0 8 2017 WELD COUNTY COMMISSIONERS As a neighbor of our Mewbourn plant, I wanted to invite you to join me on Monday, June 19 at 6 p.m. at the Meadows Event Center is Platteville. In my role, I manage our DCP operations in Weld County and I want to thoroughly understand your views related to our Mewbourn expansion project. I would like to spend our time together listening to your concerns. I would also like to respond to questions you may have about the Mewbourn plant and the expansion project, but it is important that our team has an understanding of your concerns so that we can explore solutions for mitigation. After this opportunity to listen, we would like to organize a second session so we can return and share our ideas for potential mitigation solutions and have further discussion. Your input will be helpful in developing those solutions. We are reaching out directly to all property owners in the nearby vicinity of our Mewbourn plant. I hope you will join us. There is no need to respond if you are able to attend. We look forward to hearing your thoughts and comments. Sincerely, David Jost DCP Midstream Operations dmjost@dcpmidstream.com Meadows Event Center 14016 County Road 32 (at the intersection of CR 29 & CR 32) Platteville, CO 80651 • • • • Mewbourn III neighbors on petition, page 1 of 4 Wayne Haagenstad 16495 CR 40 LaSalle, CO 80645 Rick Margheim 18481 CR 35 Platteville, CO 80651 Lorene Webber 15156 CR 38 Platteville, CO 80651 Michael Buck 18952 CR 35 LaSalle, CO 80645 Leila Berig 16730 CR 40 LaSalle, CO 80645 Shirley Johnson 18628 CR 33 LaSalle, CO 80645 Gerald Johnson 16274 CR 40 LaSalle, CO 80645 Casey Bodkin 18397 CR 33 LaSalle, CO 80645 Don and Terri Dechant 18488 CR 33 LaSalle, CO 80645 Brandon and Nicole Schmidt 16505 CR 36 Platteville, CO 80651 Richard Ferge 15426 CR 33 Platteville, CO 80651 • • • Mewbourn III neighbors on petition, page 2 of 4 Randy and Cindy Clement 18520 CR 33 LaSalle, CO 80645 Grant and Janel Greiman 15301 CR 40 Platteville, CO 80651 Lori Linderman 19382 CR 33 LaSalle, CO 80645 Sheri Hannah -Rub 18874 CR 33 LaSalle, CO 80645 Pamela Hoffman 15645 CR 40 Platteville, CO 80651 Mary Ulrich 19401 CR 33 LaSalle, CO 80645 Rita Blatter 19906 CR 33 LaSalle, CO 80645 David Amerine 20030 CR 33 LaSalle, CO 80645 Kathy Hardin 20118 CR 33 LaSalle, CO 80645 Douglas Graham 20595 CR 33 LaSalle, CO 80645 Elmer, Audrey, and Ben Kitzman 15925 CR 38 Platteville, CO 80651 • • • Mewbourn Ill neighbors on petition, page 3 of 4 Jill Lafferty 18435 CR 33 LaSalle, CO 80645 Patricia and Richard Stahl 16087 CR 40 LaSalle, CO 80645 Timothy Cooley 16019 CR 40 LaSalle, CO 80645 Jeff Carlson and Juanita Stockwell -Carlson 16782 CR 40 LaSalle, CO 80645 Eric Ewing 16974 CR 40 LaSalle, CO 80645 Douglas Tschudy 16955 CR 33 Platteville, CO 80651 Dennis Nagel 16311 CR 38 Platteville, CO 80651 Terry Martinson 17353 CR 42 LaSalle, CO 80645 Kevin Schmidt 16924 CR 42 LaSalle, CO 80645 Jim Shutt 15669 CR 38 Platteville, CO 80651 1 • Mewbourn III neighbors on petition, page 4 of 4 Deborah and Richard Miller 18026 CR 33 Platteville, CO 80651 Gerald and Lynette Kilpatrick 20487 CR 33 LaSalle, CO 80645 Irene Peppler 15945 CR 42 LaSalle, CO 80645 Richard and Marlaena Hartness 15716 CR 40 Platteville, CO 80651 Tami Webb 15948 CR 38 Platteville, CO 80651 • • • Mewbourn III neighbors within 500 feet, but not on petition, page 1 of 1 Anadarko E & P Company LP C/O Travis Holland -Property Tax PO Box 173779 Denver, CO 80217 David Ludwig 18010 CR 38 Platteville, CO 80651 Michael Phelan 10314 CR 23 Fort Lupton, CO 80621 Linda Feola-Jung 18230 CR 35 Platteville, CO 80651 -;‘ talit-07n. b(171- 6-71 .7 'le 1 17 PFCEIVED JUL 112017 Weld County Planning impartment GREELEY OFFICE ‘D- rt, AA-2,_erend.c, s ite'----tvelw-r-k4-J &A -flat aft lezteAtag-, &.tee ire j t . g_ersurni dt-777-7-7,,c,b_dec6-72 44-tel--&& &Pe ./0 ana asiez. -1;62. x.A.d 4 r P oft- • do AO dela € z-eca Oaa Atai r,z4A6-Ad • ,,Z4‘;:l arrw iet-eci€ttLe.- ,eo-zi-trae .;to Xze_adtd (le -e -v& ei--n6e,ea Ltne,c,e-aa d_ef 4:eare- /14 a S 772 4, aje, st V a -"nem ,-}-‘• en �d,-,Afrtl-tae WIZfrItx.t. -1 • P f,,:ce, A/nit) %7,,tv„... `ter rivo z .e-t•b 4n • 4(e-A2:c-z-tz-e-r 'ftifealti dairfroarr-' /84, nfJzI,e_ 33 d p Midstream June 12, 2017 Dear Kim Ogle, DCP MIDSTREAM 3026 4th Ave Greeley, CO 80631 970-356-9700 As a neighbor of our Mewbourn plant, I wanted to invite you to join me on Monday, June 19 at 6 p.m. at the Meadows Event Center is Platteville. In my role, I manage our DCP operations in Weld County and I want to thoroughly understand your views related to our Mewbourn expansion project. I would like to spend our time together listening to your concerns. I would also like to respond to questions you may have about the Mewbourn plant and the expansion project, but it is important that our team has an understanding of your concerns so that we can explore solutions for mitigation. After this opportunity to listen, we would like to organize a second session so we can return and share our ideas for potential mitigation solutions and have further discussion. Your input will be helpful in developing those solutions. We are reaching out directly to all property owners in the nearby vicinity of our Mewbourn plant. I hope you will join us. There is no need to respond if you are able to attend. We look forward to hearing your thoughts and comments. Sincerely, David Jost DCP Midstream Operations dmiost@dcpmidstream.com Meadows Event Center 14u16 County Road 32 (at the intersection of CR 29 & CR 32) Platteville, CO 80651 www.dcpmidstream.com Tisa Juanicorena From: Sent: To: Subject: Attachments: Kim Ogle Wednesday, July 12, 2017 6:23 AM Esther Gesick; Tisa Juanicorena; Karla Ford 5MJUSR17-83-542 ADDITION TO FILE NOTICE OF COMMUNITY MEETING DCP OPERATING MEWBOURN PLANT EXPANSION RECED 6.12.2017.pdf Esther Tisa and Karla Attached is the letter sent out to the SPOs and interested persons concerning the first neighborhood meeting between DCP Midstream and SPOs and interested persons. Please make this document a part of the record. Thank you Kim I dcp Midstream June 12, 2017 Dear Kim Ogle, DCP MIDSTREAM 3026 4th Ave Greeley, CO 80631 970-356-9700 As a neighbor of our Mewbourn plant, I wanted to invite you to join me on Monday, June 19 at 6 p.m. at the Meadows Event Center is Platteville. In my role, I manage our DCP operations in Weld County and I want to thoroughly understand your views related to our Mewbourn expansion project. I would like to spend our time together listening to your concerns. I would also like to respond to questions you may have about the Mewbourn plant and the expansion project, but it is important that our team has an understanding of your concerns so that we can explore solutions for mitigation. After this opportunity to listen, we would like to organize a second session so we can return and share our ideas for potential mitigation solutions and have further discussion. Your input will be helpful in developing those solutions. We are reaching out directly to all property owners in the nearby vicinity of our Mewbourn plant. I hope you will join us. There is no need to respond if you are able to attend. We look forward to hearing your thoughts and comments. Sincerely, David Jost DCP Midstream Operations dmjost@dcpmidstream.com Meadows Event Center 14016 County Road 32 (at the intersection of CR 29 & CR 32) Platteville, CO 80651 www.dcpmidstream corn Esther Gesick From: Sent: To: Subject: Please add to the record. Julie Cozad Wednesday, July 12, 2017 11:32 AM Tom Parko Jr.; Esther Gesick FW: DCP Mewbourn SMJUSR17-83-542 hearing 7/17/2017 Julie Cozad Weld County Commissioner, District 2 1150 O Street P.O. Box 758 Greeley, CO 80632 Office: 970-336-7204 Cell: 970-515-2424 Fax: 970-336-7233 icozad@weldgov.com Confidentiality Notice: This electronic transmission and any attached documents or other writings are intended only for the person or entity to which it is addressed and may contain information that is privileged, confidential or otherwise protected from disclosure. If you have received this communication in error, please immediately notify sender by return e-mail and destroy the communication. Any disclosure, copying, distribution or the taking of any action concerning the contents of this communication or any attachments by anyone other than the named recipient is strictly prohibited. From: Rochell [mailto:msrochell44@yahoo.com] Sent: Wednesday, July 12, 2017 10:53 AM To: Barbara Kirkmeyer <bkirkmeyer@weldgov.com>; Steve Moreno <smoreno@weldgov.com>; Julie Cozad <jcozad@weldgov.com>; Sean Conway <sconway@weldgov.com>; Mike Freeman <mfreeman@weldgov.com>; Kim Ogle <kogle@weldgov.com>; Tom Parko Jr. <tparko@weldgov.com>; Troy Swain <tswain@weldgov.com> Subject: DCP Mewbourn SMJUSR17-83-542 hearing 7/17/2017 Weld County Commissioners and Planning, I am very concerned about another expansion of the DCP Mewbourn plant on the corner of WCR35 and WCR38. This plant has a long history of non-compliance and I cannot fathom that Weld County would allow an expansion of a facility that has so many current violations. The constant roar of this processing plant has greatly affected our quality of life since the Mewbourn II expansion. It is much, much louder than before and the noise and flaring increases at night. Our whole house shakes and it makes it very difficult to sleep which is affecting my performance at work. Our peacock cries all night alerting us to danger from the noise. DCP assures us that the noise never exceeds 70 decibels, which is very high considering the proximity to residents. However, we have measured readings of 85 and higher coming from a compressor on the east side of the 1 plant on many occasions. We have taken readings with several devices at the same time and they all read the same levels. DCP had an independent noise study done two weeks ago, but none of the microphones were staged near this area. Again, their study concluded that decibels under 70 were recorded. The light pollution is tremendous. Our whole property is lit up all night long as if it was daytime. I am not able to use a telescope, and I am an avid stargazer I have had to purchase blackout curtains, which are very expensive, to keep the plant from lighting up the whole inside of our house. We are also noticing increased black smoke billowing from the stacks when there is a flare. On Friday 7/7/17 at 9:00am there was a major flare with an extreme amount of smoke coming from the stacks. A neighbor contacted me to report that she had black soot all over her porch after this event. The plant manager informed me that the facility was shut down and evacuated. however none of the neighbors were alerted to the fact that there were hazards. Several of our neighbors are very ill and are suspecting that these emissions have something to do with their decline in health. Also. we notice burning of our eyes and throats during flares. Approximately two years ago, we were inside the house an smelled a strong gas odor. We ran outside to safety where the smell was much stronger. We called the neighbor to see if there was a problem at their house. and concluded that it was coming from the Mewbourn plant. This gas was sinking and stayed on the ground for a long time. We also smelled it in our basement. When Mewbourn was contacted, the said "Oh, sorry. We had a mishap over here." When I review air quality studies such as the FRAPPE experiment conducted by NASA and NCAR from aircraft and the PAO Platteville Atmospheric Observatory, I am very concerned about the amount of Benzine, Toulene, VOCs, and other ozone contributors that are raining down on us. The study can be found here: http://onlinelibrary.wiley.corn/doi/10.1002/2016JD025327/full. I hesitate to hold family functions at my house in fear of my guests being exposed to these hazards I am also extremely concerned about Homeland Security and the access to this plant. When you drive up to the gate, it opens automatically and anyone can enter. Sometimes the gate is wide open for hours at a time. We feel that this plant is a major target for terrorism and much greater security needs to be implemented with a tall solid fence and and armed g uard Please consider denying the expansion of the Mewbourn Plant and please consider shutting this plant down completely given the long history of violations. If this plant is allowed to continue operating, the neighbors and I feel that they should be expected to operate under "Dark Skies" and "Residential Noise" levels so we can regain our quality of life in Weld County. We are continuing supporters of the Weld County Commission and trust that you will protect the voters interests. Sincerely, Rochell Sherman 17375 WCR 38 Platteville, CO 80651 720-985-4893 msrochell44cyahoo.com 2 Tisa Juanicorena From: Sent: To: Subject: Esther Gesick Thursday, July 13, 2017 2:10 PM Tisa Juanicorena FW: Mewbourn Plant From: Julie Cozad Sent: Thursday, July 13, 2017 11:17 AM To: Esther Gesick <egesick@weldgov.com> Subject: FW: Mewbourn Plant Please add to the public record. Julie Cozad Weld County Commissioner, District 2 1150 O Street P O Box 758 Greeley, CO 80632 Office: 970-336-7204 Cell 970-515-2424 Fax 970-336-7233 jcozadcweldgov.com EXHIBIT relit_ 211- $ --L(2 Confidentiality Notice: This electronic transmission and any attached documents or other writings are intended only for the person or entity to which it is addressed and may contain information that is privileged, confidential or otherwise protected from disclosure. If you have received this communication in error, please immediately notify sender by return e-mail and destroy the communication. Any disclosure, copying, distribution or the taking of any action concerning the contents of this communication or any attachments by anyone other than the named recipient is strictly prohibited. From: rockyrissler@gmail.com[mailto:rockyrissler@gmail.com] Sent: Thursday, July 13, 2017 11:15 AM To: Julie Cozad <jcozad@weldgov.com>; Barbara Kirkmeyer <bkirkmeyer@weldgov.com>; Steve Moreno <smoreno@weldgov.com>; sconway@weldgov.co <sconway@weldgov.co>; Mike Freeman <mfreeman@weldgov.com>; Kim Ogle <kogle@weldgov.com>; Tom Parko Jr. <tparko@weldgov.com>; Troy Swain <tswain@weldgov.com> Subject: Mewbourn Plant Good morning Commissioners, My name is Rockelle Rissler and I am a neighbor effected by the Mewbourn Plant currently and am greatly concerned about the proposed expansion. Like most of my neighbors, I moved here to get away from the noise of 'city life' and enjoy the great outdoors that Weld County is famous for. Sadly, the plant currently creates so much noise it is worse than most areas in industrial settings. I 1 am worried that if the plant is allowed to expand and double production, the noise level is only going to get worse. I realize that DCP has plans to mitigate the noise by replacing some equipment and housing some of the new equipment if the expansion is allowed to go forward. However, if the expansion is not approved DCP does not plan to make these improvements to the current plant. I do not understand why the expansion would be approved for more problems when DCP is unable to solve the current problems. The second issue I have with the current plant is the light pollution. My husband and I are avid star gazers, another reason we moved here. The light pollution coming from the plant makes it impossible to use the telescope thereby ruining another reason for being here. We have spoken with DCP representatives who assure us that they are committed to changing the lighting setup and going dark at night. Yeah! BUT, they will only commit to this change if the plant expansion is approved. The technology is out there and truly so simple most homes are using more technology to run lights, garage doors, etc. Again, I do not understand why the expansion would be approved for more problems when DCP is unable to solve the current problems. The third issue I have with the current plant is air pollution and what is being vented into my breathing air. DCP has not provided us with any information about what they are venting and how bad for us it is. We have asked repeatedly for reports of what and how much is being released and DCP continues to take the stand that although they are venting particulates we should just trust them that these compounds are not bad for us. Once again, I do not understand why the expansion would be approved for more problems when DCP is unable to solve the current problems. I think all of my concerns can be summed up as enjoyment of my property and the safety of myself, family, neighbors, and even my animals. I own and operate a small cattle ranch and worry about what pollutants are being absorbed by my cattle and how that will effect their health, their meat, and their ability to reproduce. There are many studies that show that long term exposure to low level consistent noise is detrimental to their health as well as to human health. Along with the safety issues, I am concerned about what goes on over there and what happens to us when there is a problem. On 7/7/17 there was a serious event at the plant that required the plant to be evacuated. Because I live so close to the plant I am able to hear the sirens which is the only reason we were aware of any problem. DCP tried to dance around the issue and to be honest, I think they admitted the evacuation by mistake. We are supposed to be committed to honest and open communication and I do not believe that is what we are getting. We feel like we are communicating better as neighbors with DCP, but we feel like we need more opportunities to continue our dialogue. My request is that the expansion be denied until the current problems can be addressed and fixed. I would like to see actual measurable numbers for noise, light, and air pollution. Noise level should be set for residential since that is what this area is. We are not an industrial area and should not be expected to live with industrial level noise. The technology is out there. I believe you have been provided with a cut sheet for building and insulating structures that reduce the noise to residential levels. We know DCP is capable to this since it is currently being utilized at the Crossroads Station. Thank you for your time and consideration. I have faith that each of you will give this matter the attention it deserves. Sincerely, Rockelle Rissler 17313CR38 Platteville, CO 80651 970 518 4784 Sent from Mail for Windows 10 2 Tisa Juanicorena From: Sent: To: Subject: Esther Gesick Thursday, July 13, 2017 1:19 PM Tisa Juanicorena FW: Mark Mewbourne DCP expansion From: Julie Cozad Sent: Thursday, July 13, 2017 10:12 AM To: Esther Gesick <egesick@weldgov.com> Subject: FW: Mark Mewbourne DCP expansion We got several emails from folks, so I am sending them to you to add to the record. If you already got them, then just disregard. Please add the correspondence below to the record. Thanks, Julie Julie Cozad Weld County Commissioner, District 2 1150 O Street P.O. Box 758 Greeley, CO 80632 Office: 970-336-7204 Cell: 970-515-2424 Fax: 970-336-7233 jcozad(a�weldgov.com EXHIBIT 1 S 5i ,ts(11-fl - SH Confidentiality Notice: This electronic transmission and any attached documents or other writings are intended only for the person or entity to which it is addressed and may contain information that is privileged, confidential or otherwise protected from disclosure. If you have received this communication in error, please immediately notify sender by return e-mail and destroy the communication. Any disclosure, copying, distribution or the taking of any action concerning the contents of this communication or any attachments by anyone other than the named recipient is strictly prohibited. From: Randy Clement [mailto:clem970@aol.com] Sent: Wednesday, July 12, 2017 10:50 PM To: Julie Cozad <icozad@weldgov.com> Subject: Mark Mewbourne DCP expansion To: Weld County Commissioners From: Randy and Cindy Clement 18520 Weld County Road 33 La Salle, Colorado We are writing to you concerning the expansion of the DCP plant located on County Road 35. We have lived within 1 one mile of this plant since it's beginnings. We fought its very existence with no success. We realize that these plants are necessary. but at what cost to the neighboring community? The level of noise that exists on a daily basis is extremely high for our so called country living. We have opened our home to the neighbors of our community who are also worried about what this expansion means for us in the future. Our group has met several times and is growing. We have met twice with DCP to discuss what can be done to make this plant fit into our community in a safer and quieter manner. They offered some proposals to their plant. however we have found that these changes were proposed in Dec. of 2016. We submitted some ideas to DCP that would help make living near them more tolerable. Most of our proposals were not acceptable to them. We feel that more time is needed to try and reach a compromise. because DCP failed to reach out to us immediately following the first commissioner meeting. ( Approximately 4 weeks passed until our first meeting.) We feel that DCP has room for improvement. and hopefully you will too. We strongly believe this plant should not be rated at an industrial noise level with the amount of people surrounding it. We would also like to see a couple rows of trees around the perimeter of the plant which would reduce not only the noise but the appearance. With the amount of noise that exists at the current plant, we can not imagine what doubling in size will be. Please consider our requests! Our community needs your ear and your help! Thank -you, Randy and Cindy Clement 2 Tisa Juanicorena From: Sent: To: Subject: Esther Gesick Thursday, July 13, 2017 1:21 PM Tisa Juanicorena FW: Mewborn III plant expansion concerns From: Julie Cozad Sent: Thursday, July 13, 2017 10:12 AM To: Esther Gesick <egesick@weldgov.com> Subject: FW: Mewborn III plant expansion concerns Julie Cozad Weld County Commissioner, District 2 1150 O Street P.O. Box 758 Greeley. CO 80632 Office. 970-336-7204 Cell: 970-515-2424 Fax: 970-336-7233 jcozad(a�weldgov. corn Confidentiality Notice: This electronic transmission and any attached documents or other writings are intended only for the person or entity to which it is addressed and may contain information that is privileged, confidential or otherwise protected from disclosure. If you have received this communication in error, please immediately notify sender by return e-mail and destroy the communication. Any disclosure, copying, distribution or the taking of any action concerning the contents of this communication or any attachments by anyone other than the named recipient is strictly prohibited. From: Rick Krumpeck [mailto:fkrumpeck@peakrc.com] Sent: Thursday, July 13, 2017 7:42 AM To: Mike Freeman <mfreeman@weldgov.com>; Julie Cozad <"cozad@weldgov.com>; Sean Conway <sconway@weldgov.com>; Barbara Kirkmeyer <bkirkmeyer@weldgov.com>; Steve Moreno <smoreno@weldgov.com> Subject: Mewborn III plant expansion concerns My name is Fred Krumpeck. I live due east of the proposed Mewborn plant expansion. I have several concerns with this expansion, even after meeting with DCP officials during community meetings. While there are some worthwhile discussions /negotiations taking place It was brought to my attention that a powerpoint was produced especially for a neighborhood meeting. This powerpoint stated what DCP was willing to do to placate the neighborhood concerns. After listening to this presentation for several hours of questions and answers. I have come to realize the DCP has not offered to make any changes to their business plans as I have found an (amended permit application from DCP dated 2016) stating their intent to expand their existing plant that what DCP has offered to concede to the neighborhood was already in their plans. There seems to be a lack of good faith discussion. I feel that we are being ramrodded into accepting the expansion. Please take some time to listen to the recordings of the meetings that are being delivered to you today. Why / how could you possibly let DCP expand on a facility that has been out of compliance for numerous years without requiring them to make repairs/corrections prior to another expansion. Their intent is to basically double the output of the existing plant in this expansion. While removing some equipment and retrofitting other the plant personnel will not give us and quantitive decible values of the proposed noise we can expect upon completion. It is already too loud, perhaps you folks could require them to adhere to a higher standard residential, light commercial? There is a plan to reduce some outdoor lighting levels, however DCP stated that they do not have the personnel to accomplish this with current staffing. The conversations and meeting that we are having with DCP are good and need to continue before a ruling should be made. Put yourselves in our shoes for a day. We live in the country for the ability to have a quality of life that has less stress, less noise, less traffic. As our elected officials I hope that you can make a decision based on your constituents needs and not just the might tax dollar. Please consider granting a continuance for the neighborhood to come up with an equitable agreement with DCP. Respectively Fred Krumpeck 2 Esther Gesick From: Sent: To: Cc: Subject: Barbara Kirkmeyer Thursday, July 13, 2017 S:55 AM JILL LAFFERTY; Esther Gesick Kim Ogle; Julie Cozad; Steve Moreno; Sean Conway; Mike Freeman; Tom Parko Jr.; Troy Swain Re: Letter to Weld County Commissioners for Official Record Esther Please make this email part of the public record. Thanks Barb Have a great day On Jul 13, 2017, at 2:38 AM, JILL LAFFERTY <heavenlvhavens u,msn.com> wrote: Dear Weld County Commissioners, I am writing to you as a fourth generation Coloradoan regarding my concerns about the proposed expansion to the DCP Midstream Mewbourn Plant. I have serious concerns about allowing DCP to expand their Mewbourn site at this time. DCP is the largest company of their kind in the United States with as much as 460 million in cash assets. DCP should be on the forefront of innovation for setting the highest industry standards with the most efficient, safe, compliant, and quiet plants in the nation. DCP could go above and beyond "Best Practices" as evidenced by the agreement between Encana and the city of Erie for how Encana is going to exceed the industry's Best Practices in 18 different areas. DCP seems to operate at a much lower standard than others in the industry. DCP could, if they chose to do so, find and implement ways of being the least disruptive to their surrounding neighbors. However, this has not been my experience with DCP. They continually operate at the highest levels of their USR's industrial noise standards, and the site is very bright at night. I am very concerned about their safety with the continued flaring of gases, (sometimes with a black smoke being emitted), and their recent evacuation during an unplanned event on Friday July 7 to which their safety was of great concern to them. However, they didn't take into consideration our safety, nor did they notify us of an event that required the evacuation of their personnel for safety reasons. They have had our email addresses since June 19 and they could have given us notification of the serious situation requiring an evacuation, (which is highly unusual and speaks to the severity of the event), on July 7, so that we could have taken measures to protect our families and livestock if required. We were not given that opportunity and it showed a lack of concern for us, their neighbors. EXHIBIT 3 9Z.\ -1a , 1 • Noise levels. The Mewbourn site continually runs at the highest noise levels according to the decibel readings that I have taken using an iphone app that is within a plus or minus 2 dBA level of the certified decibel reading equipment. I have taken readings during the day and night and consistently over the last 6 weeks. Daytime levels range from 77-83 dBA and night time levels range from 72-77 dBA. Mewbourn runs at the highest allowed levels of their current USR Industrial Noise Level Standard of 80 decibels during the day and 75 at night. I am requesting that in order for an approval for their expansion at the Mewbourn site, that they operate with a noise level of 60 decibels and their USR be amended to reflect this reduction in decibel level. As property owners, we have asked numerous times in meetings with DCP, for DCP to put into writing what their decibel level/s will be after the installation of their proposed new equipment and after their proposed mitigation of noise levels through insulated buildings, the shutting down of certain pieces of equipment, and the addition of newer more efficient equipment. DCP will not commit to any noise level number for the Mewbourn site expansion, however, they have committed to a 60 decibel level for their site known as "Crossroads Compressor Site" off of CR 44 and CR 49. I know it is doable, it is currently being done elsewhere at Anandarko sites along the northern front range (as have taken readings at five different sites and they are approximately 20 decibels lower than Mewbourn's) and DCP has agreed to a 60 decibel level for another of their sites just east of us. I want a decibel level that is measurable so that it is enforceable and I am agreeable to a 60 decibel level, as are the rest of my neighbors. DCP has engaged Wave Engineering for noise studies, yet they are unable to commit to any decibel levels below their current levels even though they continue to state that with the expansion, the new equipment will reduce their noise levels. With Wave Engineering's studies, they should be able to tell us what their expected level is going to be. • I have been concerned about Mewbourn's gas emissions. The Mewbourn site is considered a "major plant" and as such can have catastrophic events, not to mention the fact that in their air permit they are allowed to emit several tons of gases in a year and an expansion of their site will increase some of their emissions by almost 30% by their estimates. They currently operate at 160 million cubic feet per day of gas being processed at the Mewbourn site and their proposed expansion would give them another 200 million cubic feet per day for a total of 360 million cubic feet per day of gas being processed. During the July 10 meeting, Craig their plant manager, admitted that the plant had to be evacuated on Friday July 7 after an unplanned event. This admission was after I had presented evidence of a black ash that had coated my daughter on Friday July 7 as well as on Sat July 8. I also told DCP I had video of a gas flare during that same week that was emitting a black smoke. I was astonished, as were the other property owners, that Craig, the plant manager, would admit to having evacuated the plant on Friday morning. This is an unusual, serious, and significant event! It occurred to me that DCP had our email contact information from the June 19 meeting and if they thought it was important enough to evacuate their people from the site for safety reasons, they did not show the same concern for their neighbors! We weren't notified about the evacuation and it was only during a slip of the tongue that Craig admitted to the evacuation. As recent events of explosions at other sites along the front range have been in the news, this admission of an evacuation really upset me as well as the other neighbors attending the July 10 meeting. I am seriously concerned about the continued flaring which is considered an unwanted and negative event and to which Craig said can occur during the early morning hours (after midnight and which I and other family 2 members have observed on several occasions) because that is when they have scheduled their maintenance and this is also when flaring can occur. He did say that they can change their maintenance schedule so that flares occur during the day, however, I'd rather they solve the issues of why the plant is flaring so much in the first place. • Mr. David Jost was asked at the July 10 meeting, " if the expansion was not approved, would DCP still mitigate the issues surrounding their noise levels and dim their lights?" was very concerned with his answer, (paraphrasing), he stated that he would not have the money to mitigate the noise, lighting, etc. that the money to correct the problems currently at the Mewbourn plant were tied up in the funding for the expansion of the plant. If we didn't agree to their expansion, we basically would not be getting anything concerning the mitigation of their current noise levels or of their bright lights. His statement, in my opinion, seemed like a "quid pro quo". If you don't approve our expansion, well, too bad for you, I can't do a thing about solving your current complaints. I may be able to do a little here or there, but I really don't think I can do much. He said it wasn't his decision regarding the funding for mitigation of the current issues, the money is not available unless the expansion is approved. This made a lot of the neighbors, including myself, uneasy and some neighbors addressed him using strong language to voice our serious concerns related to his statement of either it gets approved or you don't get much. • I would like to see DCP address their current problems of continually operating with high noise levels, bright lighting, gas emissions (flares and unplanned events requiring an evacuation) and show us that they can operate a safe, quiet, compliant plant that is minimally disruptive to their neighbors for a set period of time before being allowed to expand, more than doubling their processing capacity. Mr. Jost has admitted that mistakes were made in the past, he was brought in 16 months ago to address the problems at the Mewbourn site and that he still considers himself "new" and needs more time to correct the problems. I would suggest that DCP and Mr. Jost be given exactly that, more time to fix their current problems at the Mewbourn site. With the recent incident requiring the evacuation of the plant's personnel, and the blatant disregard for us by not giving us any notification in order to protect ourselves, I think this speaks volumes as to how DCP operates at this site and why they should be denied an approval to expand at this time. Sincerely, Jill Lafferty 18435 WCR 33 LaSalle, CO 80645 970-590-4156 3 Tisa Juanicorena From: Sent: To: Subject: Attachments: Esther Gesick Thursday, July 13, 2017 2:16 PM Tisa Juanicorena FW: Letter Regarding DCP Midstream SMJUSR17-83-542 Ewing DCP Letter To BOCC July 13 2017.pdf From: Julie Cozad Sent: Thursday, July 13, 2017 12:30 PM To: Esther Gesick <egesick@weldgov.com> Subject: Fwd: Letter Regarding DCP Midstream SMJUSR17-83-542 Please add to public record. Sent from my Verizon, Samsung Galaxy smartphonc Original message From: Eric Ewing <ewinghr@yahoo.com> Date: 7/13/17 11:45 AM (GMT -07:00) To: Barbara Kirkmeyer <bkirkmeyer@weldgov.com>, Mike Freeman <mfreeman@weldgov.com>, Julie Cozad <jcozad@weldgov.com>, Sean Conway <sconway@weldgov.com>, Steve Moreno <smoreno@weldgov.com> Cc: Kim Ogle <kogle@weldgov.com>, "Tom Parko Jr." <tparko@weldgov.com> Subject: Letter Regarding DCP Midstream 5MJUSR17-83-542 Dear Commissioners, Please see attached letter regarding DCP Midstream Mewbourn. Sincerely, Eric Ewing 16974 C R 40 La Salle, CO 80645 970-347-7737 Eric Ewing 16974CR40 La Salle, CO 80645 July 13, 2017 Board of County Commissioners Weld County Re: DCP Midstream Mewbourn Gas Processing Facility Dear Commissioners, The purpose of this letter is to inform you of the efforts I have made to work with DCP Midstream since the Land Use Hearing on May 31, 2017 and to request revisions to the USR permit. Working Directly with DCP Midstream I designed mitigation that could be implemented on my property to help mitigate odor, air pollution, lights, noise, and traffic impacts on my property. (Attachment A) I had to call David Jost of DCP Midstream to ask him if he received the proposal as I received no response. I asked DCP Midstream if they would pay for the mitigation? (Attachment B). I have received no response from DCP Midstream regarding my proposal as of writing this letter. SPO Meetings The results of those meetings always ended with SPO's wanting measurable and enforceable development standards such as: • 55 decibel residential noise limit • Dark Skies lighting regulation • Real time air pollution monitoring DCP Midstream Meetings The results of those meetings seem to have left SPOs wanting quantifiable and measurable improvement to the development standards such as: • 55 decibel residential noise limit • Dark Skies lighting regulation • Real time air pollution monitoring The SPOs asked DCP Midstream to sign the attached operator agreement to which DCP Midstream refused. (Attachment C) Page 1 of 2 Other Similar Facilities Mitigate Noise Better Than DCP I visited the Fort Lupton gas processing facilities on CR 22 and took noise measurements that were below the DCP Mewbourn facility. I visited an AKA Energy gas processing facility on CR 40 east of Gilcrest and the facility's noise level was considerably less than DCP Mewbourn. A third party provided the SPO's with a summary of a noise study that had the same results I outline above. The crossroads compressor station that DCP Midstream is proposing in USR-17-003 (CR 49 & CR 44) is being proposed with a noise limit of 60 db. The AKA Energy compressor station proposed in 3MUSR17-84-625 (CR 55 & CR 54) is being proposed with a noise limit of 55 db. Although a gas processing facility is different than just a compressor station, the same types of technology and mitigation can be implemented and those operators are willing to be held to a measurable noise limit. Non -Compliance with COGCC and CDPHE Regulations The COGCC identified the DCP Mewbourn facility in violation with noise regulations on May 28, 2014. (Attachment D) The facility is currently and has a history of non-compliance with air pollution regulations as I presented in the previous hearing. The State of Colorado's Air Pollution Control Division is currently investigating the facility for air pollution violations based on SPO provided information and reasonable proof. (Attachment E) Recommended Action for Board of County Commissioners Revise the USR permit as follows: • 55 db. residential noise limit • Immediate and sustained compliance with all laws and regulations Sincerely, Eric Ewing Attachments Page 2 of 2 Eric Ewing 16974 CR 40 La Salle, CO 80645 ewinghr(a�yahoo.com 970-347-7737 July 2, 2017 Mr. Jost DCP Midstream Greeley. CO DMJostradcpmidstrea m. com Re. DCP Midstream Mewbourn Gas Plant Dear Mr. Jost, Hope you are doing well. The following are things we could do to my property to help mitigate noise. lights, odors. air pollution. and traffic from the gas plant. Trees, bushes, mulch, drip -line - $25,923 39 Privacy Fence - $15,000 Removal of existing Split Rail fence - $1.000 Replacement Windows - $4,316 Stucco work for window replacement - $1,000 Grand Total: $47,239.39 Attached is a drawing of the property with the treeline and fences, estimates for modifications and pictures of the gas plant I would also be open to considering previous solutions presented by Mr. Groom and Ms. Barry Please contact me at your convenience if you would like to discuss further Sincerely, Eric Ewing CC: Mr. Groom Showroom Located 2108 35 "D' Ave Greeley. CO Office 8 Warehouse 2723 9th Ave., Greeley. CO 80631 associates guni-design. corn June 30, 2017 email: Eric Ewing 16974 CR 40 LaSalle, CO 80645 970-347-7737 (970) 356-1398 (970) 669-7943 (970) 495-0445 (970) 356-1399 (FAX) (Work and Material Description: 1 This proposal is to install 4 new Sunrise Single Hung and Casement windows in the color white. All windows will come with Latitude Glass with Summit Technology. Laminate Glass and half screens The windows will be installed with a nail fin with silicone behind the fin and window tape over the fin. This will keep air infiltration from coming in around the window frame and is the standard install in new construction and meets building codes The stucco will need to be removed before we install the windows by the homowners stucco contractor Stucco contractor will caulk the exterior. t0" Cost Discount Dining Room - 47 1/4 x 47 1/4 Single Slider: S 1.306.00 $ 1 188.00 Kitchen - 35 1/4 x 35 1,4 Awning: S 1.170.00 $ 1.064 00 Bedroom - 35 1/4 x 53 1/2 Single Hung: S 1.146.00 S 1.042 00 Master Bath - 35 1/2 x 35 1/2 Single Hung wi Rain Glass: S 1.124.00 $ 1 022 00 Estimated Total S 4.316.00 All work will be carried out in a workmanlike manner. UNI provides all jobsite Liability and Workman's Compensation Insurance. i Revised 6 30,2017 ARBORLAND NURSERY 16 White Swamp Oak 2 - 21/2" 565 00/ea S9040.00 64 Sea Green Juniper #5 46 00/ea 2944,Q0 Subtotal S11.984.00 Installation (plantina & delivery) 7790.00 total S19,744.00 tax 347 5a TOTAL PLANTS & PLANTING Red Cedar Mulch 400 ft X 8 ft X 3" deep 30 yards @ 75 00/yd S2250.00 Installation 2250.00 Tax 65 25 TOTAL MULCH Drip Irrigation system 352 2 GPH emitters 800 Ft 3M inch drip line Netaftm 120 mesh filter Parts S506.64 Labor 759.96 TOTAL DRIP SYSTEM TOTAL PROJECT $25,923.39 22485 STATE HIGHWAY 60 MILUKEN, COLORADO 80543 PHONE (970) 587.2258 S20 091.54 $4565.25 S1266.60 ARBORLAND NURSERY Ila tt:' tuft Swan? ay.; b: . Green, )c,cnper 5 Arliire--rtemm der_ ?246S S1ATE HIGHWAY 60 MILLIKEN. COLORADO 80543 PHONE (970) 587-2258 Bonnell Fencing Services, Inc PO Box 337442 Greeley. CO 80633 Name / Address Eric Esnug 169-4 County Rd 40 LaSalle. CO S0635 Ph 970-353-1819 Fax 970-353-1988 E -m... paul©bonnellfencing.com Description Proposal / Contract Date Proposal tt 5.5, 2017 I53'':; Ship To Eric [sting 169`4 County Rd 40 LaSalle. CO 80645 Oty 6' Tall Aliitc Vinyl Privacy Fence Extra posts (with concrete. rails. and caps) for short sections of fence Labor to install fence Labor to install extra posts °does not include any winos al of existutg fence 20S I 20S I Thank you for the oppornmtry to meet your femme needs' 1 Terms 50°° down. balance at completion Total 15.85 3.296.S0T 32.00 32.00T 8.00 1.664.00 4S.00 4S 00 Cost Subtotal S5.040.S0 All material is guaranteed to be as specified. and the ebony work is to be performed ill accordance with the drawings and specifications subnutted for above work and completed in a timely woikinanitke nLatwer. Any alterations or deviation front proposed work involving additional costs will be billed accordingly. ••• 50°° Jowu with balance due in hill upon completion unless stated specific* otherwise. Signature Sales Tax (2.9%) $96.54 Total 55.137.34 Eric Ewing 16974 CR 40 La Salle, CO 80645 ewinghrc yahoo.com 970-347-7737 July 5, 2017 Mr Jost DCP Midstream Greeley. CO DMJost(a dcpmidstream corn Re. Design Change #1; Ewing DCP Mewbourn Mitigation Dear Mr Jost, Hope you are doing well_ Design for the mitigation is progressing and we've discovered there may be some additional minor work that needs to be done to incorporate the tree and shrub screening. The existing chain link fence for the backyard and the adjacent dog run will need to be moved in 10 - 20 feet as well as a propane tank that will need to be relocated to the north west about 50' There is also a lawn irrigation system watering the backyard lawn The sprinkler heads that line the south west edge of the lawn will need to be moved in or eliminated The good news is that we can use the sprinkler lines and or zones off the controller to control watering the trees and shrubs if we don't need them for the reduced lawn area. I've added $7,500 to the project to cover those additional costs This is a Rough Order of Magnitude and hopefully actual costs would come down with reusing the materials the best we can. Below is updated project costs and attached is the additional drawing showing the need for the change Here is a the updated project costs: Trees, bushes, mulch, drip -line - $25.923.39 Privacy Fence - $15,000 Removal of existing Split Rail fence - $1,000 Replacement Windows - S4,316 Stucco work for window replacement - $1.000 Change #1 Relocating fencing, propane tank, irrigation system - $7,500 Grand Total S17,239.39 S54 739 39 Please let me know if you have questions. I can be contacted anytime for more discussion Sincerely. A Eric Ewing CC: Mr. Groom 7/10/2017 Print Window Subject RE: Updated Design and Costs for Ewing DCP Mewbourn Mitigation 8 X From: ewinghr@yahoo.com To: DMJost@dcpmidstream.com Cc pgroorn@wobilawcom Date: Saturday, July 8, 2017, 10:53:24 AM MDT Mr Jost, Thanks for getting back to me The drawing shows a fence all the way around my properly, but I don't plan on putting it wnere the tree row will go since space is a premium there. That's why it's only 515k for the fence since it will just be along the roads to help with the DCP traffic. Is DCP going to pay for the costs of the mitigation I've proposed') I'd also like to request reimbursement for my legal costs for the previous round of trying to get DCP to mitigate impacts That's maybe a little over S5k if I remember correctly Let me know what I should do next to get action from DCP on these items Thanks, Eric On Fri, Jul 7.2017 at 5:08 AM, Jost, David M <OMJost@dcpmsdstream.com> wrote. Eric, Just wanted to acknowledge that I received your two emails with attachments. David From: Enc Ewing [mailto.ewinghr@yahoo.com] Sent: Wednesday, July 05. 2017 9:18 AM To: Jost, David M <DMJost@dcpmidstream.corn> Cc: Patrick Groom <pgroom@wobjlaw.com> Subject: Updated Design and Costs for Ewing DCP Mewbourn Mitigation Mr. Jost, Hope you had a great holiday. Please see attached letter regarding change #1 for the mitigation project. If you have questions, please let me know. Thanks, Eric On Fri. Jul 7, 2017 at 5 08 AM Jost. David M <DMJost@dcpmidstream corn> wrote Eric, Just wanted to acknowledge that I received your two emails with attachments David From: Eric Ewing [mailto:ewinghr@yahoo.com] Sent: Wednesday, July 05, 2017 9.18 AM To: Jost, David M <DMJost@dcpmidstream.com> Cc: Patrick Groom <pgroom@wobjlaw.com> Subject: Updated Design and Costs for Ewing DCP Mewbourn Mitigation Mr. Jost, 1/2 7/10/2017 Print Window Hope you had a great holiday. Please see attached letter regarding change #1 for the mitigation project. If you have questions, please let me know. Thanks, Eric 2/2 Specific agenda prepared by the property owners for the neighborhood meeting on July 10`x', 2017 with DCP Midstream and the property owners regarding the Mewbourn Plant current operation and future expansion. The purpose of this agenda is to reach a Memorandum of Understanding by conclusion of the evening meeting such that this written document would be a part of the approval of the current requested amended USR by DCP Midstream. Herein are the items the surrounding property owners expect to get established and into writing via the memorandum of understanding: • Noise: Reduce the noise levels to a residential level at the property line of the Mewbourn plant with design criteria meeting these standards being approved in the operations standards prior to construction permit being granted by the County. • Air Emissions: DCP must meet all current city, county, state, and federal air quality regulations/standards, and this needs to be a part of their operating standards. ■ Require a "Dispersion Study" for when there are flares as to what types of gases are being emitted, the concentration of those gases, the flow rate at the stack, temperature, pressure, etc., so that the surrounding property owners know what we are being exposed to, when, and at what concentrations and at what distances. • If the concentration of gases are high enough, within 1,000 feet of a property owner, require permanent monitoring of gas emissions at the plant site. • Lighting: The neighbors are requesting that Mewbourn operate with the "Dark Skies" standards that have been adapted throughout the United States • Appearance: Make the plant visually appealing, screened from neighbor's views • Notifications: Real time reporting of pressure releases, flares, accidents, informing property owners through mass alerts (text messaging, emails, phone calls, etc.,) so that we can take actions to limit our exposure to the gas emissions with these incidents • Security: Secure the site by other means other than chain link fencing • Construction: • Limit construction hours to 7am to 7pm Monday through Friday being a "good neighbor" • Dust management by having a water truck constantly watering the construction route • Establish haul route, currently the neighbors are agreeable to using CR 32 from the south up CR 35 to the plant site. The neighbors do not want any construction traffic on CR 33, CR 38, or CR 40. The neighbors do not want the use of Mag Chloride or Brine on the road • Chip seal CR 35, or pave • Trash abatement at least once a week, more frequently if needed • Establish a complaint line for the surrounding neighbors for addressing their issues regarding the construction and construction traffic Inspector Name: LEONARD, MIKE FORM INSP Oil and State Gas Cons of Colorado ervation Commission13 # DNR DE OE ES Rev 05/11 1120 Lincoln Street, Suite 801, Denver, Colorado 80203 Phone: (303) 894-2100 Fax: CO Inspection Date: (303) 894-2109 05/28/2014 to HELD INSPECTION FORM Document Number Location Facility 668204773 ID Loc ID Inspector Name: On Inspection -Site Identifier 412248 LEONARD, MIKE 2A Doc Num: Overall Inspection: Operator VIOLATION Information: OGCC Operator Number: 4680 THIS IS A FOLLOW UP INSPECTION Name of Operator: DCP MIDSTREAM LP jx FOLLOW UP INSPECTION REQUIRED NO FOLLOW UP INSPECTION Address: 370 17TH STREET - SUITE 2500 REQUIRED City: DENVER State: CO Zip: 80202 INSPECTOR REQUESTS FORM 42 WHEN CORRECTIVE ACTIONS ARE COMPLETED Contact Information; Contact Name Phone Email Comment Park, Paul (970) 378-6372 PDPark@dcpmidstream.com All Plant Inspections Compliance Summary: QtrQtr Sec: Twp: Range. Insp. Date Doc Num Insp. Type Insp Status Satisfactory PA Pas/Fail /Action Required P/F/I (P/F) Violation (Y/N) 05/17/2014 668200760 AC AC SATISFACTOR No Y 05/06/2014 668200767 AC AC SATISFACTOR No Y 04/29/2014 668200765 AC AC SATISFACTOR No Y 04/23/2014 668200764 AC AC SATISFACTOR No Y 04/22/2014 668200762 AC AC SATISFACTOR No Y inspector Comment: Within ten days submit plan for mitigation to bring to compliant noise levels Related Facilities: Facility ID Type Status Status Date Well Class API Num Facility Name Insp Status 412248 GAS AC 04/20/1998 - MEWBOURN GAS AC PROCESSIN PLANT 412248 G PLANT rg Equipment; Location InventQry Location Emergency Contact Number (S/A/V): Corrective Date: Comment Corrective Action: Spills: - - flats) Q..n• CflQflfl4A Ilan INCCn9nn7791 Page 1 of 5 7/13/2017 Print Window X Subject Re: DCP Midstream Mewbourn Gas Plant Air Spills From: jennifer mattox@state.co.us To: ewinghr@yahoo.com Date: Wednesday, July 12, 2017, 4:51:37 PM MDT Mr Ewing, Thank you for sending these to the Division. Please allow the Division time to investigate, and we will get back to you as soon as possible. Are you comfortable with the Division sharing these video links w/DCP7 Thanks, Jennifer Mattox Enforcement Supervisor, Oil Et Gas Team Stationary Sources Program COLORADO Au Pollution Control Division tacpanmerd d Public Health b Enwonmrni P 303.692.3144 I F 303.782.0278 4300 Cherry Creek Drive South, Denver. CO 80246.1530 jennifer,mattox@state.co.uf I www,colorado.rtov/cdohe/aocd 4300 Cherry Creek Drive South, Denver, CO 80246.1530 "Are you curious about ground -level ozone in Colorado" Visit our ozone weboage to learn more On Wed, Jul 12, 2017 at 1216 PM, Eric Ewing <ewinphra}yahoo.com> wrote Ms. Mattox, Attached is a PDF document listing potential air spills from the facility Setting YouTube to highest definition setting will help with clarity. Please let me know if you see any possible violations of air pollution regulations Thanks, Eric Ewing 16974 CR 40 La Salle, CO 80645 970-347-7737 1/1 AThink Green - Not every email needs to be printed Tisa Juanicorena From: Sent: To: Cc: Subject: Attachments: Kim Ogle Thursday, July 13, 2017 12:07 PM Tisa Juanicorena Esther Gesick FW: Documents to be admitted to the Record concerning the application for Expansion of DCP's Mewbourn site DCP meeting minutes.pdf; DCP Amendment 7.6.17.pdf; DCP Agenda.pdf; Mewbourn Plant Neighbor Meeting - 071017 (1).pdf Please add to case number 5MJUSR17-83-542, hearing scheduled for 7.17.2017 at 10 o'clock Thank you Kim Ogle Planner Department of Planning 1555 North 17th Avenue Greeley, Colorado 80631 Direct: 970.400.3549 Office: 970.353.6100 x 3540 Facsimile: 970.304.6498 Confidentiality Notice: This electronic transmission and any attached documents or other writings are intended only for the person or entity to which it is addressed and may contain information that is privileged, confidential or otherwise protected from disclosure. If you have received this communication in error, please immediately notify sender by return e-mail and destroy the communication. Any disclosure, copying, distribution or the taking of any action concerning the contents of this communication or any attachments by anyone other than the named recipient is strictly prohibited. From: JILL LAFFERTY [mailto:heavenlyhavens@msn.com] Sent: Thursday, July 13, 2017 9:40 AM To: Kim Ogle <kogle@weldgov.com> Cc: Julie Cozad <jcozad@weldgov.com>; Barbara Kirkmeyer <bkirkmeyer@weldgov.com>; Steve Moreno <smoreno@weldgov.com>; Sean Conway <sconway@weldgov.com>; Mike Freeman <mfreeman@weldgov.com>; Tom Parko Jr. <tparko@weldgov.com>; Troy Swain <tswain@weldgov.com> Subject: Re: Documents to be admitted to the Record concerning the application for Expansion of DCP's Mewbourn site 1 From: JILL LAFFERTY <heavenlyhavens@msn.com> Sent: Wednesday, July 12, 2017 11:35 PM To: JILL LAFFERTY; ICE. Ed Lafferty Subject: Documents to be admitted to the Official Record concerning the Application for Expansion of DCP's Mewbourn site Dear Commissioners and County Planners, Attached you will find the four documents that we would like to have entered into the official record for DCP's USR amendment application for expansion to the Mewbourn site. • Meeting Minutes provided by DCP concerning the first meeting between DCP and the surrounding property owners which took place on June 19, 2017 • An amendment to the DCP Meeting Minutes to clarify items left out or needing further expansion to the DCP Meeting Minutes from June 19, 2017 that were generated and provided by DCP from the surrounding property owners • An agenda written by the surrounding property owners for the July 10, 2017 meeting with DCP, our second and final meeting • Power Point document generated and provided by DCP as to what they are proposing to do for the surrounding property owners concerning the Mewbourn site currently and during an expansion DCP representatives, during the second community meeting on July 10, 2017, presented their Power Point presentation as to what they are willing to provide (and include in their amended USR permit) to the surrounding property owners in an attempt to mitigate noise, air emissions, lighting, security, real time notifications and constructions concerns. As surrounding property owners, we are still not satisfied with their mitigation of the noise levels. DCP was asked on multiple occasions during the meeting, "what noise levels are you willing to put into writing that you will not exceed after installing the new equipment?", "what will be the decibel level at the plant after the installation of the new equipment?" DCP was unwilling to state a decibel level. As surrounding property owners, we want a measurable and enforceable level not to exceed 60 decibels (which is a commercial noise level). The neighbors are willing to concede from a 55 decibel (residential) level to a 60 decibel level. This should be something DCP can commit to especially should all their new noise mitigation plans be actually implemented. DCP has already committed to a 60 decibel level at their "Crossroads Compressor" site at CR 44 and CR 49. We know DCP can operate at a 60 decibel level, they have agreed to do it for another DCP site but were unwilling to commit to a 60 decibel level for their Mewbourn site during our second meeting. We want a decibel level of 60 or less to be included as part of their amended USR. We have also brought up on several occasions, that as property owners, we would like for DCP to commit to no future expansions at the Mewbourn site as this site is already a very large facility and any further expansion would dramatically affect all the surrounding property owners. We would like for you to consider, should you approve this current permit for expansion, that DCP not be allowed to expand at the Mewbourn site again in the future. Sincerely, 2 Jill Lafferty 18435 WCR 33 LaSalle, CO 80645 970-590-4156 3 Meeting Minutes On June 19, 2017, DCP Midstream ("DCP") hosted an open house at 6:00 pm to discuss with neighbors around the Mewbourn plant DCP's plans to expand the facility. David Jost, Vice President of Northern Operations, for DCP facilitated the meeting. Approximately 35 area residents attended the meeting. The meeting lasted until approximately 9:30 pm. Mr. Jost opened the meeting by outlining the purpose of the meeting which was to listen to the concerns of neighbors with respect to the Mewbourn expansion project. He acknowledged that DCP had not done a good job of communicating with neighbors about the project or its regular operations. A number of attendees stated that they did not know who to contact at DCP, or would leave messages but get no response. Several people made suggestions, including a phone hotline for local residents to use for complaints or concerns, and more meetings during and after construction of the new facility. Mr. Jost committed to advising Mewbourn neighbors who the proper contact at DCP would be, to improving communication with the Mewbourn neighbors in general, and to holding a follow up meeting on July 10, 2017 to discuss the action DCP can take to mitigate concerns expressed at the meeting. Mr. Jost agreed to increase regular communications with the nearby homeowners. At the next meeting, we will discuss some options to provide more information on a regular basis to people living within a certain distance of the plant. In no particular order, the other concerns expressed at the meeting and DCP's plans to respond are as follows: Safety — Mr. Jost opened the meeting addressing some concerns around the safety of the plant. DCP is known as being a safe operator. Mr. Jost emphasized how important safety is to himself and stressed that DCP takes safety very seriously. DCP insists on a culture of safety for all of its employees and contractors. We talk about, we train on it, we work with local first responders in "asset wide drills," we share our Emergency Response Plans with local first responders, and we stress that any employee or contractor working at a DCP facility can stop a job if they feel like something is unsafe. DCP follows regulatory requirements and industry standards for safety evaluation and management. DCP also "over -designs" its facilities to ensure that they are safe by engineering them to handle conditions that are more extreme than actual operating conditions. At the next meeting, DCP will present information on the following issues raised at the June 19 meeting: • What is in the Mewbourn Plant Emergency Response Plan, including how DCP responds to emergencies and security incidents? • A map showing the DCP pipelines around Mewbourn Plant 2. Security - Some of you expressed concerns about the security of the plant, given terrorism or other safety risks, and wanted to know what DCP did about these issues. DCP commented that it restricts access to the plant facilities, using fencing, locking gates, and key cards to access the buildings. In addition, Mr. Jost said that the Emergency Response Plan includes plans for security incidents and threats to the plant, and we coordinate regularly with local first responders like fire and police departments. DCP will provide information at the next meeting about these concerns: • How do we control access to the facility so that unauthorized people can't tamper with it or otherwise cause problems? Can anyone get access? • Do we work with homeland security on terrorism issues affecting plant security? 3. Noise - Multiple homeowners complained that the noise from the current facility was a problem, and several stated that the problem was worse at night. Some identified the flare as a source of problematic noise, or said that they felt or observed noise -related vibrations in their homes. Others stated that the sound measurement data DCP presented at the USR hearing showing noise levels well within the standards for industrial facilities was not accurate, and said they thought the noisier equipment must not have been operating when DCP's consultant took measurements, resulting in lower numbers. Some homeowners have taken their own readings, which have produced higher numbers than DCP's sound measurement data. It was recommended that DCP conduct another sound study, with measurements taken during the day and night, for a longer period. There did not appear to be any consensus from the homeowners on how to address the issue. Several people told the DCP representatives that "you are the experts — you tell us what options are available." Others said that the walls installed on the west side of the plant did not provide noise reduction. Some people thought a high berm on the west side and trees or a wall built on top of the berm would provide noise reduction and mitigate the visual impact of the facility, but others said that this wouldn't help them because of the location of their home relative to the berm location. DCP said it has been working on ideas to reduce noise and will present some mitigation measures at the next meeting. At the next meeting, DCP will provide information about noise to respond to the questions and concerns raised in June: • Is the plant noisier at night or at certain times? DCP will take additional sound measurements during day and night at the same locations, to see whether there are differences caused by equipment operating at different times, and will present this information. • Is the plant out of compliance with the sound standards? • What are the noisier parts of the plant? • What kinds of sound mitigation are most effective in general? Amendment to Meeting Minute Produced by DC P Midstream relating to the neighborhood meeting held on June 19th 2017 This amendment is required to address items left out of the meeting minutes produced and sent out by DCP Midstream on June 23, 2017. The necessity to amend comes as many key points, discussions and action items by DCP were left out of the meeting minutes produced by DCP. This amendment is an attempt to assure that no key detail, action item, statements made by any party at the meeting, goes uncaptured. First, to elaborate on the opening paragraph of the minutes, there additional statements made by Mr. Jost in his opening statement and his subsequent discussion that were inadvertently left out. So after reviewing the actual communication discussion, it is necessary to actually capture some of Mr. Josts actual statements. These are paraphrased here -in: Mr. Jost stated that he is currently the General Manager of DCP Midstream Colorado and that he has only been in charge of the DCP Midstream Colorado area for 16 months. He acknowledged that in the past DCP Midstream had not been a good neighbor (not just a poor communicator as stated in the original minutes) and that he was asking the surrounding property owners "to give him a chance and time" to make things right. He was committed to be a good neighbor going forward and acknowledged they (DCP) had some work to do to earn the property owners trust. He also stated that his word was his bond and that he had the utmost integrity such that if he said he said he would do something it could be counted on being done. He stated it was the objective of this meeting and another meeting scheduled for July 10, 2017 to get through all the concerns expressed at the meeting and address them in an attempt to get an understanding with the property owners of how DCP plans to be a good neighbor while going forward with the plant expansion. It was asked by the property owners if DCP planned to put it in writing any agreements made with the property owners during the next neighborhood meeting on July 10`h, prior to going to the July 17 County Commission Board meeting. Mr. Groom responded (again paraphrased) that it was the intent to get to an understanding prior to going to the board meeting. This is where the property owners asked if there was enough time between now and July 17, 2017 to get a general agreement between DCP and the property owners of how DCP would address their concerns prior to moving forward with the next phased plant expansion. Mr. Jost stated that he would try to add an additional meeting before July 10. This did not get set prior to the meeting being adjourned. Item 3. Noise: DCP meeting minutes did not adequately include all the discussion and concerns addressed by all property owners who spoke regarding the extremely loud and disruptive noise that emanates from the existing plant during the day and night throughout the week including both Saturdays and Sundays. The noise concerns raised by all the property owners who spoke were nothing short of extremely distraught, mad, and upset at how their lives had been drastically changed, for the worse since the plant that is now in operation, has been in existence. For most of the property owners, they actual stated it had dramatically reduced their quality of life, such that they no longer felt they were able to have an enjoyable home environment. Although the property owners did state to DCP "that you are the expert — you tell us what options are available". This came after the proper owners suggested the following items that they considered could mitigate and dramatically reduce the noise level, and in fact the neighbors want Mewbourn to operate with Residential noise levels. 1 These included: - DCP should replace all gas fired compressors converting them to electric and housing them in a building. This include replacing "all" gas fired compressors not just some as proposed by DCP. - Building an earthen berm around the entire site high enough to act as a significant sound barrier. The earthen berm was to be landscaped with trees. It was acknowledged that this might not help a couple of the property owners to the east whose property elevation was higher. - It was suggested that it a sound wall could also be constructed along the entire site to a height that could satisfy all the property owners. A sound wall along with the earthen berm built in conjunction with each other could mitigate both the noise problem and obtain a more visually appeasing plant. It was suggested that other DCP Midstream competitors had achieved much more agreeable neighborhood operating plants by utilizing several of the above construction techniques to dramatically reduce the noise volume. The noise issue kept coming back to the fact that there would be design issues to come up with the best approach to mitigate. At this the property owners stated ""that you are the expert — you tell us what options are available in order to dramatically reduce the noise emitted by the plant". At which time, one of the DCP engineers stated that they have been working on this problem since the property owners sent a letter to the planning commission. The DCP engineer stated that he would come to the July 10, 2017 meeting with ideas to mitigate the noise. The property owners voiced additional concern that how is a plant that is operating at or exceeding its allowable noise limit currently, plan to assure the property owners that not only the existing plant noise could be brought way down but how the new plant now operating at over double the volume would keep the noised level down to a level that would be satisfactory to the property owners. Item 4. Air Emissions: A missing action item was: DCP agreed to provide a summary level spreadsheet, at the July 10 meeting, with the quarterly emissions reported by DCP to the government over the last five years and when they were in violation of the air emission standards. • A question was asked regarding, "What types of gases does Mewbourn plant emit? I have seen where the gases can be of a carcinogenic and a neurotoxic nature, from Benzene, Hexane, Toluene, Benzopyrene, Methane, Ethylbenzene, Nitrous oxide, Hydrogen Sulfide, Carbon Monoxide. When the plant "off gases" or "pressure releases " the gases into the atmosphere, how much is being emitted and what types of gases are being emitted? I am concerned about the health consequences to surrounding neighbors as we can have several emissions a week, flares and pressure releases. Also, with the flares, the burning of gases, what types are being burned off"? The plant manager (who has been on this site for approximately 2-3 months) answered, (paraphrasing), that the flare burns all but 3-5% of heavy gases. Hydrocarbons. One of the engineers stated that with the pressure releases, done without the flare, the gas is light, it's Methane. 2 Item 5. Lighting: An item that was not included in DCP produced minutes was that, not like other plants, DCP would look at converting the DCP Midstream plant into a "dark skies" plant. This would be a totally dark plant with lighting only needed in cases of emergency or maintenance. This was suggested in conjunction with utilizing a lighting system, based on a photometric study that would only have the minimum lighting required, all lighting down cast and facing inward to the plant. Additional Item(s) discussed at the meeting but not making it into the meeting minutes: Future plant expansion: • The property owners point blank asked if DCP would put in writing that should this next plant expansion go through, would they agree not to expand this plant any more in the future. DCP was not prepared to respond to this question at this time. • DCP mentioned that at one time they were trucking the gas and that there were 4 tanks now that were not being utilized at the south end of the property as they no longer truck gas. A question was asked as to if the tanks could be removed and this land could be used instead for the expansion. Additional Items of concern expressed by property owners that were left out of the original meetings minutes: • Air Pollution and Chemical Leaks: • The property owners spoke about their homes filling with hydrocarbons at times and that they have contacted the DCP plant and their staff about the situation. DCP's staff confirmed the releasing of hydrocarbons and expressed their apologies. • The neighbors spoke about their houses filing with chemicals and that the chemicals caused their eyes and throats to burn. • The neighbors spoke about smelling propane, condensate, or some other chemical while on their own property. • The neighbors spoke about being "impacted" by odors and air pollution. • The neighbors spoke about not being able to use their property for planned family events. • Traffic: • The neighbors spoke about their homes being damaged by previous Mewbourn II construction traffic and they had requested DCP to "take care of" the damage. • The neighbors spoke about their not feeling safe on their own property due to Mewbourn II construction traffic. • Noise: • The neighbors spoke about not being able to hear crickets or birds. • The neighbors spoke about their family events being cancelled due to Mewbourn II noise. • The neighbors requested good noise level data from DCP. • 3 • Lights: ■ The neighbors spoke about the "skies being lit up" at night that the plant is too bright at night. • DCP's past record of addressing neighbor concerns: • The neighbors spoke about their being at the mercy of DCP. ■ The neighbors spoke about not being treated by DCP and Mewbourn II. • The neighbors spoke about DCP not taking care of the people (neighbors). • The neighbors spoke about offering to pay Bill Johnson, DCP Executive, for a noise wall, but no wall was ever put up. • The neighbors spoke about the County Commissioners wanting at least 60 days between hearings, but DCP complained it would cost them too much money (time). However, Mr. Jost asked the neighbors at the first June meeting to "please give him more time to resolve the problems" at Mewbourn, that he was still "new" to the situation, mistakes had been made in the past and he hadn't been aware of the neighbor's concerns." • Property Values: • The property owners were concerned about how the expansion of the plant will further negatively impact their property value. DCP stated that they understood the concerns and that hopefully with the many discussed options to mitigate the plants impact on the surrounding properties that this would help address this concern. Other than the above comments, no further additions or deletions are a part of the minutes. Note: Subsequent to the meeting, Mr. Margheim spoke with Mr. Jost and was told personally by Mr. Jost that he would meet Mr. Margheim at his property within the next two weeks to discuss his issues /complaints with the Mewbourn plant and DCP. To date, Mr. Margheim has not heard from Mr. Jost. 4 Specific agenda prepared by the property owners for the neighborhood meeting on July 10th, 2017 with DCP Midstream and the property owners regarding the Mewbourn Plant current operation and future expansion. The purpose of this agenda is to reach a Memorandum of Understanding by conclusion of the evening meeting such that this written document would be a part of the approval of the current requested amended USR by DCP Midstream. Herein are the items the surrounding property owners expect to get established and into writing via the memorandum of understanding: • Noise: Reduce the noise levels to a residential level at the property line of the Mewbourn plant with design criteria meeting these standards being approved in the operations standards prior to construction permit being granted by the County. • Air Emissions: DCP must meet all current city, county, state, and federal air quality regulations/standards, and this needs to be a part of their operating standards. • Require a "Dispersion Study" for when there are flares as to what types of gases are being emitted, the concentration of those gases, the flow rate at the stack, temperature, pressure, etc., so that the surrounding property owners know what we are being exposed to, when, and at what concentrations and at what distances. • If the concentration of gases are high enough, within 1,000 feet of a property owner, require permanent monitoring of gas emissions at the plant site. • Lighting: The neighbors are requesting that Mewbourn operate with the "Dark Skies" standards that have been adapted throughout the United States • Appearance: Make the plant visually appealing, screened from neighbor's views • Notifications: Real time reporting of pressure releases, flares, accidents, informing property owners through mass alerts (text messaging, emails, phone calls, etc.,) so that we can take actions to limit our exposure to the gas emissions with these incidents • Security: Secure the site by other means other than chain link fencing • Construction: • Limit construction hours to 7am to 7pm Monday through Friday being a "good neighbor" • Dust management by having a water truck constantly watering the construction route • Establish haul route, currently the neighbors are agreeable to using CR 32 from the south up CR 35 to the plant site. The neighbors do not want any construction traffic on CR 33, CR 38, or CR 40. The neighbors do not want the use of Mag Chloride or Brine on the road • Chip seal CR 35, or pave • Trash abatement at least once a week, more frequently if needed • Establish a complaint line for the surrounding neighbors for addressing their issues regarding the construction and construction traffic I' t kg 4 ;Ott_ • +=r • - —. 1 ♦i _. r. . s+ an► .b 1 - --IW._ ••,••• tie 1 • I' ly '-i • • --:-- f .4 - • r 4 1 .0 nnit • THE RIGHT TIME MEWBOURN NEIGHBOR MEETING July 10, 2017 M,r_ar.•I ... 7 i` v y 13 iii Tell. ice iC Operational �� Excellence A X RELIABILITY cicri Midstream Tonight's Purpose Existing Mewbourn Plant Mewbourn Plant Expansion i I Emergency Response Procedures 1 Air Quality I Ongoing Communications Processes Current 72 -Hour Noise Data Property Line Locations 1-4 Sound Pressure Level d8A 70 60 50 40 30 20 10 0 Sflf .l naaaaanaaa I i i I I I IIHuIIIIIIiUhiiIIIIIillhiiiU'i'i'N1iilhi am II III 1 hiiiiihnui II 1111111 I' I 1'111111 111 11111i111111111 "11'1111'1111 IIIIIIIIII w inn Inglompippolippommommooliompimpp 1 1 1 IIIIIII" Imil mg Ion � � �� 1�1�� ■�� 1�1 �LocaGonlLeq (dBA) "1111 �� I � � 111111111 ,� ��' III � �� ,� ,� �Location 2 Leq (d BA) �� ,� �� 1�� _Location3Leq�dBA) I11�A�A_ I ANNAA N�� I��INnnl wI�A��'+�,�� ■■ t � Location 4 Leq (d BA) N VI CO p- 8 O O 8 Tuesday Jun. 27 O O W O O O O t°o' ►-+ O O 8 8 8 Wednesday Jun. 28 O O W O W Q1 lD r N O O O N ~ O O O N Oo O O O 8 8 8 8 O O O O 8 8 8 8 Thursday Friday Jun. 29 Jun. 30 W O1 to p.- f.. N V' 8 8 Saturday Jul. 1 Wave Engineering Existing Mewbourn Noise Mitigations CDEnclose compressor building Insulate vessel Shut down compressors cp m • • • Noise Mitigation • Construct building to fully enclose residue compressor • Shut down three gas compressors • Insulate plant inlet tank and associated piping • Turn off alarms tied to flare; use strobe lights to notify operators • Light Mitigation • Lights off at night, except on walkways and when operators are working on equipment • Downcast light • Reduce night time scheduled flaring Mewbourn Plant Expansion • Noise Mitigation • Residue Compressor and Gas Turbine • Fully enclosed building • Insulate residue compressor piping located outside of the building • Electric compressors fully enclosed in building • Light Mitigation • Lights off at night, except on walkways and when operators are working on equipment • Downcast light • Visual Mitigation • Sixteen foot wall on west side of the plant Mewbourn Construction Traffic Mitigation Platteville, CR 32, CR 35, CR 38 idstream Mewbo�r, Emergency Response Procedures Marµxerial C. a. 9 ct 4`:, 9.9 � 4, Operational Cy ik Excellence RELIABILITY 10 Air Quality Questions NnMN`"' U cow a 3 tt 4, Operational �ty Excellence RELIABILITY 11 Mewbourn Plant Emissions Mewbourn Gas Plant Annual Emissions (TPY) NOx CO VOC SO2 Current Permitted Emissions 169.5 175.6 163.6 38.9 Proposed Project Changes* 30.1 33.0 -5.0 -1.0 Proposed Emissions Total Permitted 199.6 208.6 158.6 37.9 12 July 13, 2017 Mr. Kim Ogle Weld County Planning Department 1555 N 17th St Greeley, CO 80631 Re: Flare events at the Mewbourn Plant Dear Mr. Ogle, RECEI\1E1) JUL 13 2017 Weld County Planning Department GREELEY OFFICE I have captured recent flare events and put them on the included zip drive. The first event was on June 27, 2017 after being awakened at 2 am that morning and the flare continued to burn throughout the day. It had periods of emitting black smoke which DCP engineers have stated is not good. The next video is from July 7, 2017 at around 9 am when the flare was quite large and the plant seemed eerily quiet. During our meeting with DCP on Monday night on July 10, 2017 I brought up pictures of my daughter being coated in a black gritty ash on July 7 and July 8 along with the fact that I had previous videos of the flare emitting a black smoke. Craig, the plants manager admitted that on July 7 they had an unplanned event and it required evacuating the plant. The neighbors were not notified at the time of the evacuation and I was actually at the plants perimeter videoing the flare event! I would like to include these two videos into the official record along with the attached letter regarding my documentation of noise levels and flare events over the past 6 weeks. Sincerely, Jill Lafferty 18435 WCR 33 LaSalle, CO 80645 Noise Levels, Flares, and Pressure Releases at Mewbourn Plant as Documented by Jill Lafferty (Neighbor) Note: Using NOISH decibel reader app for iphone, Soundmeter app for iphone (which NIOSH considers to be within a +/- 2dBA difference from certified decibel readers and is appropriate for reading noise levels with an iphone), and Decibel 10th. All three of these apps were used along with a certified decibel reader and they were within the +/- 2 dBA of the certified reader. Also, taking readings at 5 different sites, plus the Mewbourn site, the same phone with the same apps were used to take readings with wind speeds under 5 mph each time. Even if the apps aren't "certified", they are still relative in the fact that they were used at each site with the same equipment and under the same conditions each time. The values are informative even if they aren't certified. I did not try to determine what type of equipment was running at the time as I am not an expert in this area. However, based on the readings at the various sites, it was found that DCP is consistently higher by 20 dBA at the Mewbourn site compared to Anandarko and Excel Energy sites and its another 10-15 dBA higher than their other DCP site. I can't speak as to the number of flares or pressure releases except for the Mewbourn site. May 29, 2017: Flare, 2 pm ongoing The Nagels stated, "they couldn't have family over for a Memorial Day Celebration. The plant was too loud for a conversation." May 30: Flared Loud May 31: Flared starting in the early am. The Clements called about how loud the plant was. Video at 10 pm that night of compressor at midway Mewbourn plant. Readings of 77-84 dBA at the compressor midway on east side of plant. (the .28 second video gives an indication of just how loud 75 plus decibels is!) June 1: 3 AM ! Flared. Woke us up. Continued to flare throughout the day, loud June 3: Pressure Release/off gassing, 9:30-10:45 am in short bursts, very loud June 6: Readings at 9:45 pm, again running at the top levels of 74-78 for nighttime level to not exceed 75. June 11-22. Daily readings range from 77-84 at Mewbourn. Nightly readings range from 74-77. They continually run at the top level of their Industrial Standards of 80 daytime and 75 nighttime! June 22: Frederick Anandarko Plant off of CR 19 and HWY 6. Perimeter has a small rocked berm about 10' high with 10' high pine trees scattered on top. The compressors are housed and the decibel readings are 50-55 which is somewhat quiet. Pictures of this plant. Also a house to the north of this plant and close proximity has a 30-36' dirt berm with hay bales to block noise and view of plant. Mr. Dave Kisker's report has this plant on another date at 60 dBA. Next plant: CR 19 across from the Excel Energy plant (Springcreek?) with the fantastic berm. DCP Spindle Plant. The compressors seemed to be "housed" and there were very large fans facing west. Most of the housed fan units had levels of 60-65 dBA except for one fan toward the north end that was at 70-74 dBA. At 60 decibels it starts getting a what I would consider "loud". (The 75-80 is not acceptable, being an industrial level in our residential neighborhood, it is agitating and considerably loud and is fairly constant). Pictures Excel Energy plant across the street on CR 19 and CR 18 had a 30' grassed berm with various 10-15' tall pine trees and leafy trees. Along the berm were sections of brick work. This plant was very quiet with under 40 decibels. Pictures CR 18 and CR 21 Anandarko Tri Towne Plant. Had a berm that sloped upwards with the terrain. Probably a 10,-15' berm, however, with the slope it was more like a 20'-25' berm and the plant was lower so less visible than most. I noticed 6 black stacks which I believe to be compressors. 45-54 dBA level at their property line. Fairly quiet in my opinion. I wouldn't mind a 50 dBA level at Mewbourn's property line. Pictures June 23: Lucerne 2 Plant off of O Street (CR 64) and east of Hwy 85. Somewhat bermed. It is a DCP plant. Southside 50-53 dBA, Eastside 48-50 dBA at 10:30 am. Actually not too obnoxious. Taken at locations that would be similar to the Dechants distance from Mewbourn. I have had as high as 75 at their property at night during the first week in June. From our property, we are directly west of the compressor that is the most offensive. We can get readings of 55-60 on our front porch. This is not acceptable! Off of Crossroads Blvd going towards Windsor, just before Hwy 257 and just west of the nice homes on the hill there is a plant with 12 stacks. It is bermed with grass also. Noise from Crossroads is 40-45 dBA. I am not sure of this plants name. However, at close proximity to their neighbors, they run 40-45 which I have previously noted is acceptable in my opinion. We know this can and is being done presently. June 24 (Sat): Gerald Johnson called to say the plant was extremely loud. I didn't make a reading as we were leaving out of town. Later in the evening I took readings and at the midsection it was 77-83dBA. June 25 (Sun): Ed Lafferty, my husband and our daughter were awakened at 5 am! from the noise. It was so loud that he had to shut our windows. He then went out on the back porch until 6:30 am and the noise was so loud that he heard it and the porch faces west and is blocked by our home! With this loud of noise, the plant had to be running over 80 dBA for us to hear it on the west side of our home. Plus this was on a Sunday morning starting at 5 am which is not all that unusual as I have previously mentioned that the flaring has woken us up at 2 am and 3 am on different days. At 10 am the reading was 78-81 dBA. Later in the evening, the Clements called to state that the noise was very loud. June 26: 2 am flare woke us up and continued to flare over 24 hours. Took a video of the black smoke coming off of the flare. c3; n 3-7 v'deo 0 i 2� Tune 28: still flaring as but not high g tJ4 71 2o, 7 v 66.0 eVazuct or) I ive. snel - (tuck 4-- +h -e Yhe J 33 (l C1S .1_ Ui as icr1 czewaxe_ aryt- hazi beot) (vas be f r\-3 evwns_cRteci anoL thee v i oti2 O aC he_ [airy c (cure, `S i nitres st-i rl3 i-O an ever* +hot+ ret LLi red a_ Yj €1/41.04A-a:hCn( t&ra loo kS V€3 S i m( l OLr -f-o c) -i- her �-' lekre_ events 0 5O , as nei�Jhbe,-si Wi+flQSSfl3 Q sec t care Ve rSius � cycz eve n -E- rel r rn5 a n e Vankcdri or) � -There's 410 -1' a 1Of ciba L46 7/2 -ii 7 D C? Cal 6 5 3c/5 A/ 74892 Natural Gas Compressors - Controlling Sound Five Things You Should Know EIVED JUL 13 2017 • A natural gas compressor increases • Southwestern Energy (SWN) locates • SWN reduces the sound generated the pressure of the gas so it can be transported through a pipeline and ultimately used by consumers. Depending on the volume and flow of wells within a natural gas producing area, a compressor station may have one or more compressor units. Facts About Compressors and Sound SWN currently operates more than 800 compressor units located on well pads or at large stations away from well pads. We use a variety of methods to control sound levels. In 2011, the Arkansas O1 and Gas Commission (AOGC) passed a new rule, requiring a sound level of 55 dB at all "Noise Sensitive Areas" (NSA) in proximity to natural gas compressors. However, SWN already achieved that level of sound control at many cf our existing stations. Finding the Right Location One of the best ways to reduce sound is distance. SWN works to select sites for compressor stations that are located away from residences and other occupied areas. Certain terrains and cultural features such as parks. historic sites and wetlands are not considered for locations. Conducting the Right Testing SWN conducts sound surveys before and after installation of a compressor statbn. We also take readings at nearby residences to determine sound level. In situations where sound levels exceed the 55 dB design goal, SWN has taken corrective action to reduce Continued on back sound exposure. our compressor units at residential populations as possible. The location of a compressor station depends on the quantity and location of wells in relation to the pipeline system. • Compressor station facility maintenance activity or other variables may cause a short-term increase in sound level. Well -insulated COUNTS compressor facilities through , L$SIONE&Ian design, equipment and sound absorbing systems that lower sound levels. • At minimum, SWN achieves sound • levels below 55 decibels (dB) at the nearest residence, which is slightly quieter than the sound level of an average conversation. The insulation layers used h compressor sto ton buildings provide a solid surface to contain noise and materials to reduce sound energy or "dampen" sound before It can escape. By varying the types of sound-darrp- ening material, sound levels are exponentially decreased because one material can "catch" sound the other material albws to escape. Perforated aluminum panel - holes provide space for sound to travel through and be "caught" In sound -damp eningrnaterial. Roof Ecterior spa. - Well swn Southwestern Energy' wwwswn.com I NYSE: SWN I Last updated Jan. 2014 Controlling Sound (continued) Using the Right Equipment SWN purchases special or non-standard compressor units with extra silencers and the highest level of sound reduction available related to exhaust systems. We have worked to reduce the four main sources of constant sound from our compressor stations. pi Engine exhaust and oh- intake systems are equipped with silencers to reduce sound by 50 and 60 dB. © Natural gas and water-cooling equipment have high efficiency fans to prevent turbulence and reduce sound by 2 to 3 dB. These high efficiency fans have a greater number of blades, which also contributes to producing less noise. le Larger piping than typically used in compressor stations is installed to keep the gas velocity low. This reduces continuous high -frequency (high-pitched) sounds. i0 If sound levels are above 55 dB at a Noise Sensitive Area, SWN constructs buildings over mechanical equipment to reduce sound levels. SWN spends between $145,000 and $200,000 per compressor to enclose them and currently has 42 stations with buildings. Each station contains one or more compressor. OWN CONSTRUCTS BUILDINGS around compressor eSL1iornent to lover sound levers. Many of our large compressor 'stations currently have build`€ngs around than. How Loud is it Realltj? Sound pressure is measured in decibels (de). When SWN takes a reading, we test and report sound In levels of the A scale, which Is the scale associated with human hearing and most regulations. Decibel Level 0 SWN ensures sound levels produced by compressor stations measure 55 de(A) or lower at the nearest residence. 100 110 120 130 140 Sound Comparison Lowest sound audnle to the human ear Crickets, distant frogs, whisper Kitten meowing, songbirds, distant dog bark Refrigerator running, babbling stream Average conversation level Busy restaurant tractor idling, barn cleaner, conveyors, elevators rector at 50 percent load, leaf blower, home air compressor, combine Tractor at 60 percent load, power tools Tractor at full load, bad muffler, old chain saw Gunshot, backfire, dynamite blast oats courte4; of the Texas Cooperative Extension. 'Texas A&M university The Environmental Protection Agency (EPA) recomrfends a maximum 24 -hour continuous sound -level exposure of 70 c13, The Occupational Heath and safety Aomdnisstratlon (OSHA) has mandated a ma dinum limit of 90 ds for eght hours of continuous sound exposure vstithout hearing protection. Doing the Right Thing dent has a concern related to sound level or other issues concerning SWN, residents may contact (866) 322-0801. swn S'owthwestern. Energy' w~<AN.swn.com I NYSE: SWN I Last updated Jan. 2014 Memorex° TRACK NO./NAME TRACK NO./NAME Dcp mrG062417 MS Case- ryJTas.f i7-St3 Sys � feFenN #1 t+�ifh ltirco �yoEivr's 6--z9- 7 cMemvrex TRACK NO./NAME TRACK NO./NAME b 0 gU I I9o7Pc 2, 030 tc << 4 ,-t rt FeffakiaMitlsralla iliMardify214M1ria411111111 MISPNW717.11111111 RECEIVED JUL 132017 COMMISSIONERS COUNTY Original File contains Audio CDs of the DCP Community Meeting from SPO Scott Sherman submitted July 13, 2017 Tisa Juanicorena From: Sent: To: Subject: Esther Gesick Friday, July 14, 2017 8:35 AM Tisa Juanicorena FW: DCP's expansion of Mewbourn Plant Original Message From: Barbara Kirkmeyer Sent: Friday, July 14, 2017 5:54 AM To: Juanita Stockwell <juanitasthoughts@gmail.com>; Esther Gesick <egesick@weldgov.com>; Commissioners <COMMISSIONERS@co.weld.co.us> Subject: Re: DCP's expansion of Mewbourn Plant Thank you for your letter. Will see that it becomes part of the public record. Barb Have a great day I EXHIBIT d 'sr criisgx > On Jul 13, 2017, at 1:19 PM, Juanita Stockwell <juanitasthoughts@gmail.com>wrote: > My name is Juanita Stockwell -Carlson > I am writing regarding the expansion of the Mewbourn gas plant that essentially sets in my back yard as well as many of my neighbors. > We have met as a community with DCP on two occasions about our concerns of the expansion and what it will u ltimately do to our quality of life. > We have addressed our concerns about the impact of sound, air, and light pollution. As well as the visual aesthetics of the plant in it's current state of operation. And the increase of construction traffic and trash and road maintenance. > As a property owner the idea of this expansion is frightful! Considering DCP admitted to a high level plant evacuation on Friday July 7th 2017! > We would like to continue to be a good neibor to DCP, however they have been less than forthcoming with what they are willing to do too keep a good relationship with us. > They have spoken about the removal of some compressors and housing and insulation for those that will remain there. To help with sound. Along with modifications of lighting and some of the daily plant operations schedule. > However a majority of these things were already stated in a document dated December 2016. > An amendment to current industrial sound decibel level needs to be made. Ideally I know my neighbors and I would like to to be set at residential level. However we would be happy with a reduction to commercial levels. > DCP has also stated they can not build a berm of sorts to help visually hide the plant because of the cost to do so isn't allocated in the current expansion budget. Yet other gas companies, such as Anadarko have gone above and beyond to be good neighbors and built them. > DCP is one of the biggest gas processing companies in the United States. Yet when we asked them to fix the current issues with the plant as it is they stated unless they get the approval for the expansion they could not guarantee the removal of compressors or housing them in insolated buildings. Because those things were already stated to be done in the December 2016 document with the expansion budget. > I understand that DCP brings in a substantial amount of revenue for Weld County. But at what cost? > I love my home and where I live but I can not sleep soundly unless I wear ear plugs because of the noise coming from the plant. I also sleep with an eye mask because the light pollution at night even with my shades pulled it's to bright. 1 > I am not completely against DCP my husband works within the oil and gas industry and in he past has made repairs at the Mewbourn plant as a pipeline welder. But as their neibor I would like to see these things addressed and added before they are given final approval. > > *Address current violations with plant *Sound *Light *Environmental > pollution *Berm to make it more visually pleasing *Construction > traffic, road dust > > I will be attending the meeting on Monday with my neighbors and look forward to finding a solution that will benefit everyone. > > > Sincerely, > Juanita Stockwell -Carlson > 16782 County Road 40 > LaSalle, CO 80645 > 970-415-1012 ><IMG_20170713_131742881_HDR.jpg> 2 a E .4 w T I �- Jr' S• C • Ca.. • r in' t c 7i • .T sr THE RIGHT TIME BOARD OF COUNTY COMMISSIONERS - WELD COUNTY 44 July 17, 2017 11.'S, snit CI M sr �nnyi Operational Excellence RELIABILITY cicp Midstream S. DCP Midstream Mewbourn 3 Project talcp Midstream DC P's Footprint in Weld County • Gas Processing Plants - 9 with a capacity of 850 MMcf/d • Over 170 employees • 2016 ad valorem taxes of $19.3 million Project Description • Location: Adjacent to existing Mewbourn 2 Plant (160 MMcfid) site in Weld County � Capacity: 230 MMcf/d • Scope: Deep cut cryogenic gas processing plant servicing production in Weld County � Projected ln-ServiceDate: O42018 � Capital Investment: $175 million • Construction Jobs: 200 over 15 months • Additional ad valorem taxes: $2.3 million • New DCP employees: ~12 Mewbourn 3 project is a significant investment in Weld County that creates jobs and additional tax revenue 2 Weld County Production Profile Expansion of DCP's Gas Processi p Midstream. I I I I I Growth remains robust in the DJ Basin DCP's Weld County gas plants are operating at 100% capacity Additional processing capacity is needed to handle increased volumes of natural gas from our customers Producers have estimated an increase of up to 30% over the next five years Expansion of DCP's processing capacity is required to facilitate continued development of oil and gas resources in Weld County 30 28 26 24 I 2 22 re 20 18 16 Gas Production from Oil Wells (Bcf/d) DJ Basin Gas Production Rest of U.B. DJ Basin Nt` "ti �+ N' NSS 1.2 1.1 1.0 0.9 0.8 0.7 0.6 0.5 0.4 0.3 0.2 v w Go 3,000 2,500 2,000 � 1,500 11,000 500 0 „E‘,Nn) %et .61,ENC3 v‘,N93 %et ,t$ etj <ebv kej er Future Wells Legacy a Rig Count 60 50 40 g 30 a 20 g 10 DCP Weld County system is operating at capacity and incremental processing capacity is re • uired to allow for continued oil and • as develo • ment 3 dcP Midstream. � DCP invited residents in the vicinity of the Mewbourn Plant to a meeting on June 19, 2017 � Approximately 35 area residents attended the meeting which ran from 6:00 p.m. to 9:30 p.m. � DCP asked area residents to raise any concerns and mitigation that DCP should consider as a follow up to the comments made at the BOCC Hearing on May 31, 2017 � DCP also had individual discussions with area residents following both meetings, as well as on separate occasions, in order to address specific questions or concerns � DCP held a second community meeting on July 10, 2017, and presented mitigation measures designed to address concerns expressed at the June 19, 2017 meeting 4 Current Sound Levels at Mewbourn Plant awirmail REJAAELTY clicp Midstream. I In response to area residents request, DCP retained Wave Engineering to conduct a 72 -hour continuous monitoring study to determine sound levels at the Mewbourn Plant under normal operating conditions • Wave used professional sound measurement equipment at four perimeter locations • Wave determined that sound levels at the Mewbourn Plant were lower than the applicable sound standards at all times. Average daily sound levels are shown on the chart and the full report is included in the appendix I Figure 1: 72 -hour test locations near e Mewbourn property line. Date 6/28/201716/29/2017 6/30/2017 Location Leg (dBA) Location Average 1 61 56 55 58 65 65 i 63 64 3 58 58 54 57 62 4 65 56 62 5 72 -Hour Continuous Sound Data (Wave) SIC Midstream 80 70 60 co 50 Sound Pressure Leve 40 30 20 10 0 0 O Tuesday Jun. 27 ioa 8 It I 0 0 Property Line Locations 1-4 a��ay_ a C o 8 8 8 a Wednesday Jun! 28 w C os 0 C _—.►—►-__. - a_w Ime tit Cle Thursday Jun. 29 • IL IS B 0 LO C or C a O tit 0 Location 1 Leq (d BA) — Location 2 Leq (d BA) Location 3 Leg (d BA) —Location 4 Leq (d BA) .. .a a. a. 8 8 8 Friday Jun. 30 0 a 0 w 0 en 0 0 C NJ Saturday Jul. 1 Mitigation of Sound at Mewbourn Plant SIC Midstream � Multiple area residents complained that sound from the Mewbourn Plant is a problem and several stated the problem was worse at night � In order to address these concerns, DCP identified the equipment that generates the highest sound levels and proposed the following mitigation to reduce sound at the source: • Construct building to fully enclose existing residue compressor • Shut down three existing gas compressors • Insulate plant inlet tank and associated piping � Turn off process alarms tied to flare; use strobe lights to notify operators New residue compressor and gas turbine to be located in a fully enclosed building � Insulate residue compressor piping located outside of the building • New electric compressors fully enclosed in building I Mitigation actions ensure sound levels will be below current industrial standards 7 Mitigation at Existing Mewbourn Plant SIC Midstream 0 Enclose compressor building (:::) Insulate vessel OShut down compressors s Lighting Mitigation SIC Midstream � Numerous area residents complained of lighting at the Mewbourn Plant � In order to address these concerns, DCP proposed the following mitigation measures: � Lights off at night, except on walkways and when operators are working on equipment � Downcast lighting on walkways � Modify maintenance schedule to reduce night-time scheduled flaring events � Visual Mitigation - sixteen foot wall on west side of the plant Mitigation actions significantly reduce lighting impacts on area residents 9 Mewbourn Construction Traffic Mitigation as _ANL.= I I I Area residents expressed concern around construction traffic and proposed DCP use CR 32 from the south up to CR 35 to Mewbourn DCP agreed to use that proposed route for daily traffic excluding heavy equipment based on loading requirements DCP also agreed to perform dust suppression if acceptable to the County, trash abatement at least once a week and establish a complaint line for area residents 1-17 IL -� r�1a tell • 2 • G 1 D se 10 -1_ 4 oPir E3 - rgt0 1' 143/4 a r I m HEdAN.TY ity d _ Midstream_ abti iid st retji r-, - Mawboo u r . II d- 4 got is art 9 EI ;>4 S 4. —F 9 N -'p Midstream. � Mewbourn Natural Gas Plant Project Profile I I I I Install necessary piping, cryogenic equipment, vessels, heaters, emergency flares Electrification of certain equipment that would normally burn natural gas (compressors, reboilers, heaters) Removal of three older higher -emitting engines (replaced by new electric compression) Use of ultra -low emitting turbines for electricity production and for compression � With electrification of certain equipment, use of low -emitting turbines, and removal of older existing equipment, this plant project has very low emissions for a plant of this capacity Mewbourn Nat. Gas Plant Annual Permitted Emissions (TPY) NOx CO VOC SO2 Current Permitted Emissions (160mm) 191 42 171 175 Proposed Project Changes (+230mm) 33 -2 -1 7 208 789 41 New Total Permitted Emissions 178 11 dcP Midstream. � Mewbourn 3 project is necessary to meet growth in Weld County � Mewbourn 3 is a state -of -the art facility that will create jobs and increase tax revenue in Weld County • DCP has proposed significant mitigation measures to address area residents concerns at a cost of over $3 million � DCP requests approval of the USR Permit with the mitigation measures proposed in this presentation 12 Sound Monitoring Report WaveEngineering Acoustics, Noise & Vibration July 6, 2017 Mr. Paul Park DCP Midstream 3 026 4th Avenue Greeley, Colorado 80631 Re : DCP Mewbourn — 72 hour sound monitoring report Wave #1658 Dear Paul, We measured sound levels last week at the DCP Mewbourn gas plant. Sound levels were measured at four locations near the Mewbourn property line. The sound monitors ran from Tuesday, June 27, through Saturday, July 1, 2017. The intent of the measurements was to evaluate the variance in sound levels over the course of a day, and from day to day. The measurement locations were selected to represent locations that are in the direction of the closest residential neighbors to the facility. The measured sound levels at the Mewbourn site property lines were within the Weld County, Colorado, permissible limits. Weld County Noise Regulation The Weld County Code, Chapter 14, Article IX limits noise levels generated by the Mewbourn facility. The Industrial limits that apply to the facility are 80 dBA during the daytime and 75 dBA during nighttime hours (9:00 p.m. to next 7:00 a.m.). Since the Mewbourn plant operates continuously day and night, the nighttime limit of 75 dBA must be met. Sound Level Measurements Sound levels were measured at the Mewbourn plant from Tuesday, June 27 to Saturday, July 1, 2017. The intent was to capture three full weekdays (Wednesday, Thursday, and Friday). The test equipment, locations, conditions, and results are described below. F 1100 W. Littleton Blvd. #420 Littleton, CO 80120 720 -446 -WAVE (9283) www.WaveEngineering:co Mr. Paul Park July 6, 2017 Page Measurement Procedures and Locations Four sound meters were set up tocontinuously record a series of 15 -minute duration measurements. The overall -weighted equivalent sound level (average) was measured as well as the minimum, the maximum, and a series of statistical sound levels. The four locations are shown in Figure 1. Figure 1: 72 -hour test locations near the Mewbourn property line 1100 W. Littleton Blvd. #420 Littleton, CO 80120 720 -446 -WAVE (9283) www.WaveEngineering:co Mr. Paul Park July 6, 2017 Page 3 Test Equipment The following test equipment was used. Location 1 Larson Davis Model 870B sound level meter S/N 1375, Type 1 per ANSI S1.4 Larson Davis preamp PRM900C, SiN 0142 Larson Davis 1/2" microphone Model 2541, S/N 7107 Location 2 Larson Davis Model 870B sound level meter SIN 1376, Type 1 per ANSI S1.4 Larson Davis preamp PRM900C, SiN 1443 Larson Davis ',/2" microphone Model 2560, 2077 Location 3 Larson Davis Model 870B sound level meter SA 1540, Type 1 per ANSI S1.4 Larson Davis preamp PRM900C, S/N 0761 Larson Davis '." microphone Model 2560, S/N 2632 Location 4 Larson Davis Model 870B sound level meter SiN 0564, Type 1 per ANSI 51.4 Larson Davis preamp PRM900B, S/N 2561 Larson Davis !/2" microphone Model 2541, S/N 8074 System calibration was checked in the field before and after the measurements with a Larson Davis CA250 acoustic calibrator, SN 2405, acoustic calibrator. Laboratory calibration certificates for the equipment are available upon request. Windscreens and bird spikes were used on all microphones. Weather Conditions Weather and meteorological conditions can influence the transmission of sound outdoors and have a significant effect when sound travels distances greater than about 300 feet. Wind speed and direction, and the presence of a temperature lapse or inversion, have the most influence on sound transmission between distant points. Wind and rain can also have a significant effect on measured sound levels due to the sound from rustling leaves, grass, rainfall, etc. The weather conditions were collected from a meteorological station reporting to the Weather Underground website (www. Wunderground.com). The weather station is located 6.3 miles to the northeast of the Mewbourn plant, as shown in Figure 2. 1100 W. Littleton Blvd. #420 Littleton, CO 80120 720 -446 -WAVE (9283) www.WaveEngineering:co Mr. Paul Park July 6, 2017 Page 4 Forecast for Greeley, CO > 40.355 -104.764 > 4699 ft P S Data PWS W igets Wunder Station PWS viewed 4 times since July 1, 2017 Radar y e bca Gilcrest * icon Weaillg data collection • Mewbourn Figure 2: Weather Underground station location A plot of temperature, wind speed, and wind direction for each day is included in Appendix A. Light rain between the hours of 9:00 p.m. and midnight on June 29. While I was on site, the following weather conditions were observed and recorded. A Kestrel 3000 portable weather meter was used to measure temperature, relative humidity, and wind speed. Table 1: on site weather observations Date Temperature (°F) Relative (% Wind Speed (mph) Wind Direction Time Humidity RH) Tuesday, 6/27/17 8:30 am - 12:30 pm -- -- 0-2 NE Tuesday, 6/27/17 1:05 pm 94 21 5 West Saturday, 7/1/17 3:25 pm 84 15 6 -NE E Measurement Results Sound levels were measured at four locations over a span of five days that included three full weekdays. The sound level meter cannot discriminate betweensound generated by the gas plants ■ 1100 W. Littleton Blvd. #420 Littleton, CO 80120 720 -446 -WAVE (9283) www.WaveEngineering:co Mr. Paul Park July 6, 2017 Page 5 or other sources such as aircraft and traffic. At Location 2, for example, the sound of occasional passing vehicles on WCR 35 impacts the measurements. The sound of Mewbourn equipment was clearly audible at all four locations.. The LEQ values are plotted in Figures 3 through 7. Table 2 shows the daily averages The LEQ (equivalent sound level) is similar to the average sound level. In the figures, each data point represents a 15 -minute measurement. Property Line (North) Location 1 Sound Pressure Level (RA) 7O 60 50 40 30 20 10 0 I 1 __L. — ,J__ _,... L1 1._ t ......___ N N I I p _____ _ i I l - __. ___ _ _ __T._ H ii.i., a r y_Y_p _ I I V ikil I- 1 I I r 1 1 1 1 1 i 1)111,, up C C Tuesday Jun. 27 r Tr Y= ch O o C 0 C 1N NJ g Wednesday Jun. 23 cc soa C 7 i 1 F i weaw•♦ r • 1_1 r r l 1 I, r t J 1L"L74 1 >� r„ y,1 b I I r I r ■p I A i Ii l i _ I I i, I I, I$ $11111 1 1 1 . - 1.? L!1 CO ha 6 6 6 Thursday Jun. 29 Figure 3: Sound Levels at Measurement Location 1 .7 l'7 CO F=• 8 g 8 8 Friday Jun. 3C I _ d g.0 Er, 6 o a C. Location 1 is north of Mewbourn 1, inside the north property line. The sound level at this location varied approximately 18 dBA between the highest and lowest 15 minute average sound levels. S 1100 W. Littleton Blvd. #420 Littleton, CO 80120 720 -446 -WAVE (9283) www.WaveEngineering.co C C Saturday Jul. 1 Mr. Paul Park July 6, 2017 Page 6 Property Line (East) - Location 2 Sound Pressure Level NBA) 89 70 60 50 40 ao 20 10 4 Il — — —._ __ ._—. _:_ _. � Ills-- — --- —— —' -- — —— — --., ._.. __ ._ ._. -. .—— —' -- — ---'-- — -- — - -- — ----.-- -- _ ! 11 . _ �__ r __ __ H : FL H _ _— II 1_ L_.e...... -- 11 t rL — _ L. .__I_. 1 - dT- L, i .-L 4_' .' .. ' -.. _ .1—.-1--L ,_ i — yp ..._1_ L... ......4_ .r - .L ' ' _. _L .- ..-, ._! O it a c r � s s r• n S 8 8 Tuesday Jun. 27 0 O w 6 a 0 d C f.a 8 5-k psh Lri co nr cr: g Wednesday Jun. 28 S 0 0 sa 0 C 1p a N 8 Thursday Jun. 29 Figure 4: Sound Levels at Measurement Location 2 co _ !� P' --- VV _0 o- Ni - - Leg BA) (.ci i!i`"_ ? *ill! I_ iti.lt It i.1 0 3 O .G��yY ,may S S PO 1^ 'sad o r r n y s r. • r Friday Jun. 30 0 0 w 0 Location 2, near the east property line, was the closest measurement location to the center of the plant. We expect this location to vary the least because it should be the least susceptible to atmospheric conditions. Nonetheless, the sound level at this location varies approximately 10 dBA between the highest and lowest 15 minute average sound levels. 1100 W. Littleton Blvd. #420 Littleton, CO 80120 720 -446 -WAVE (9283) www.WaveEngineering:co cc 8 Saturday Jul. 1 Mr. Paul Park July 6, 2017 Page 7 Property Line (Southwest) - Location Sound Pressure Leve so 70 60 50 40 30 20 10 0 r. A sip r sit V• 8 *Nod ISMS P osSO I. INSISS Sim Se SSS — F 0 Q 8 NJ, OD 1l g Tuesday Jun. 27 P L`r at W a 76 a o coo Wednes-d y Jun. 28 cru old Q 0 o 4 I' C C Thursday Jun. 29 Figure 5: Sound Levels at Measurement Location 3 1-0 g C C w al w b o o g Friday Jun. 30 w fr-AY..' a till. 0 0 0' 0' Location 3 is near the west property line, towards the south end of the property. It is southwest of the Mewbourn plant. This location had the lowest average sound level and approximately 25 dBA of variance between the highest and lowest 15 minute average sound levels. 1100 W. Littleton Blvd. #420 Littleton, CO 80120 720446 -WAVE (9283) www.WaveEngineering:co ima VI 8 Saturday Jul. 1 Mr. Paul Park July 6, 2017 Page 8 Property Line (Northwest) - Location 4 Sound pressure Level (dMM) $O 7O 60 SO 40 3O 20 10 a apaaala • _.. L _zi sea men , . y Sa 1 1 ui C ha 1-" V'6 CO o 6 Tuesday J u,n. 27 C rs- —_ , _ I r- L...... a. 1 r a— iIsar a asap. - I Gis i 0 'glen •c c.pc c a Wednesday Jun. 28 ala J o 0 • i w i N VI 1. 1 e Thursday Jun. 29 Figure 6: Sound Levels at Measurement Location 4 �+F t • an. Pa walla — Simla —1 • _,— Met —1 —1 4. Oa o w o o a 0 C. C 1 1 I 1 ima Ina lea rJ V1 GQ Friday Jun. 30 .a:. i -mss 1 -- -_ --» Leg (dBA) - -,- ,a s iki,iiiiiit$ i_..lails.L O 0 C 6 0 Location 4 is northwest of the plant and approximately 1001 inside of the north property line. Similar to Location 3, this location had approximately 26 dBA of variance between the highest and lowest 15 minute average sound levels. 1100 w. Littleton Blvd., #420 Littleton, CO 80120 720 -446 -WAVE (9283) www.WaveEngineering:co a a I--� 1--1 NJ VI Saturday Jul. 1 Mr. Paul Park July 6, 2017 Page 9 Property Line Locations 1-4 Sound Pressure Lever (deA) 70 60 50 40 30 20 10 p Tuesday Jun. 27 4.1 ► UD 4-4 ima ki Ca 8 8 Wednesday Jun. 22 0 C O 0 0 Figure 7: Sound levels at all four locations 8 Thursday Jun. 29 N' 8 t — C Q C Ni4-1 0 - C Friday Jun. 30 Sa 'W 8 ica 8 I _ -L® ��tiare Leg (dB4 Locaticri 2 Leg (d RA) Location o Leg (d ESA) Location 4 Leg (dBA) C 0 Figure 7 shows the sound levels at all four locations overlaid for comparison. If the sound levels at all four locations drop simultaneously, it is most likely because the plant noise has dropped. However, if certain locations rise while others fall, it is more likely due to atmospheric conditions, wind direction, etc. Table 2 below shows the daily average of sound levels for the three complete days at each location. As expected, Location 2 is the most consistent. There are significant variations from day to day at the more distant Locations 1, 3, and 4. 1100 W. Littleton Blvd. #420 Littleton, CO 80120 720446 -WAVE (9283) www.WaveEngineering:co 4xt u NJ S.J' Saturday Jul. 1 Mr. Paul Park July 6, 2017 Page 10 Table 2: Mewbourn daily average sound levels Date 6/28/2017k/29/2017 6/30/2017 Location Leg (dBA)► Locatio i r+er age I 1 61 56 55 58 2 63 65 65 64 3 58 58 54 57 4 U 65 62 56 62 h Conclusions Sound levels were measured at four locations near the Mewbourn property line from June 27 to July 1, 2017. The data show that the sound levels vary significantly. There is no clear trend related to day or night. The measured sound levels at all four locations remained below the Weld County Industrial nighttime limit of 75 dBA for the entire duration. Please let me know if you have any questions or would like to discuss this report. Sincerely, Jeff Kwolkoski Digitally signed by Jeff Kwolkoski DN: cn=Jeff Kwolkoski, o=Wave Engineering, Inc., ou, email jefI@WaveEngineering.co, c=US Date: 2017.07.06 08:39:11 -06'00' Jeff Kwolkoski, I IE6 INCE Bd. Cert. President Encl: Appendix A — Weather Data 1100 W. Littleton Blvd. #420 Littleton, CO 80120 720 -446 -WAVE (9283) www.WaveEngineering.co Appendix A Weather Data Appendix A Weather Data Weather History Graph June 27, 2017 12Aht -.00 20 16- 1U 5 360` 2 r1.1- 130` r1Qt - • • • 100 0.50 0.00 3AM 6AM 9Ahvt 12PM 3P1•1 6PM 9PM ' 2AM Temperature (`F) - Dew Point (°F) • • i t • • S. • • • • • • • • • • • • • •! • • • U.S • • • • • • • •• •• • • • • • • • • • • r Wind Spccd (mph) =I 'Mid Gus: (mph) • • • • • • • • • • • • • • • • N Wind Direction Weather History Graph June 2852017 40 71) 15. 10 5 0 Jsti St. SEX I 121`.1 3PM -e, Precip Acrtim Total (in) MI Prerip Rate (in) 6Prvt 3PM Temperature (°F) - Dew Point (°F) A A lv-liNA A A A f f 1__1 V i ic 1_l 270° leo, Lcs• • 0° 1 D 0.5U 0.00 • • • • • • ■ • • • • ■ • • ■ a • It • ■ • • • • • • • S. • ■ • • • • • • • • n Li Wind Speec (mph) - Wind Gust (mph) • • e • • • • • • ■ • • gu • • • • • • N MI Wind Direction Page 2of4 -Precip. Accunl. Total (in, S Precip. Rate (in) S Appendix A— Weather Data Weather History Graph June 29, 2017 ID ail 360' 270' 1€in° n' • on 0.25 020 0 15 0 u0 05 0 in 3AM SAM • • • • • • • • DAM • • • 12PM 3PM c3rM 9,PM IN Temperature rF) - Dew Point (`F) • Wind Speed (mph) I. Wind Gust (,mph) N • • • a a • • a • . • • • ' • a • • • • • • • • • • • • • • • ■ • • • • • ■ • • ' a • • • • • • • • • • a • • • • • • • 5 • • • • ■ a • Weather History Graph June 30, 2017 70 0 10 6 2 S Wind Speed (mph) 30y. ■ 270c 18Vc. got 0° 4.1I}2 0.31 0.}0 • • • • • • 3AM • • • • • • • • •. ■ EMI 9AM • • • • • a • • i • • • • • • • • • • • 1 • N Wind Direction Nrecip. Accum. IDtal ( n) Nrecip. Kate (In) 12PM 33M 6PM • • • • ■ • • • • • ■ 4 • • ■ • • • • • • a • • IS ternperature (1F) - Dew Point • Wind GLst (mphi N v • • F Wind Direction Page 3of4 Precip. Accum. Tctal (in) ® Precip. Rate (in) Appendix A— Weather Data Weather History Graph July 1, 2017 30 30 70 h0 30 4U 6 5 4 3 2 1 0 360° ° 2/0" 3AM EAM 9AM 12 P,.'1 3PM 6PM 9PM Temperature (°F,' - Dew Point (°F) i\A 18U 9a°i .. • • • • • • • . . . • . r 1J V 1.30 030 • • . I • • • • • . • • . • .• • • F • • • • I • .• • • I 1 . • . • • • • • • • Wind Speed (mph) -'wind Gust (mpg) • • 1Vlitid Diiectiori Page 4 of 4 Precip. Accum_ Total (in) - Precip. Rate (ii) N S DCP Midstream Meeting Minutes Meeting Minutes o n June 19/ 2017/ DCP Midstream ("DCP") hosted an open house at 6:00 pm to discuss with neighbors around the Mewbourn plant DCP's plans to expand the facility. David Jost, Vice President of Northern O perations, for DCP facilitated the meeting. Approximately 35 area residents attended the meeting. The meeting lasted until approximately 9:30 pm. Mr. Jost opened the meeting by outlining the purpose of the meeting which was to listen to the concerns of neighbors with respect to the Mewbourn expansion project. He acknowledged that DCP had not done a good job of communicating with neighbors about the project or its regular operations. A number of attendees stated that they did not know who to contact at DCP, or would leave messages but get no response. Several people made suggestions, including a phone hotline for local residents to use for complaints or concerns, and more meetings during and after construction of the new facility. Mr. Jost committed to advising Mewbourn neighbors who the proper contact at DCP would be, to improving communication with the Mewbourn neighbors in general, and to holding a follow up meeting on July 10, 2017 to discuss the action DCP can take to mitigate concerns expressed at the meeting. Mr. Jost agreed to increase regular communications with the nearby homeowners. At the next meeting, we will discuss some options to provide more information on a regular basis to people living within a certain distance of the plant. In no particular order, the other concerns expressed at the meeting and DCP's plans to respond are as follows: 1. Safety — Mr. Jost opened the meeting addressing some concerns around the safety of the plant. DCP is known as being a safe operator. Mr. Jost emphasized how important safety is to himself and stressed that DCP takes safety very seriously. DCP insists on a culture of safety for all of its employees and contractors. We talk about, we train on it, we work with local first responders in "asset wide drills," we share our Emergency Response Plans with local first responders, and we stress that any employee or contractor working at a DCP facility can stop a job if they feel like something is unsafe. DCP follows regulatory requirements and industry standards for safety evaluation and management. DCP also "over -designs" its facilities to ensure that they are safe by engineering them to handle conditions that are more extreme than actual operating conditions. At the next meeting, DCP will present information on the following issues raised at the June 19 meeting: • What is in the Mewbourn Plant Emergency Response Plan, including how DCP responds to emergencies and security incidents? • A map showing the DCP pipelines around Mewbourn Plant 2. Security — Some of you expressed concerns about the security of the plant, given terrorism or other safety risks, and wanted to know what DCP did a bout these issues. DCP commented that it restricts access to the plant facilities, using fencing/ locking gates, and key cards to access the buildings. In addition, Mr. Jost said that the Emergency Response Plan includes plans for security incidents and threats to the plant, and we coordinate regularly with local first responders like fire and police departments. DCP will provide information at the next meeting about these concerns: • How do we control access to the facility so that unauthorized people can't tamper with it or otherwise cause problems? Can anyone get access? • Do we work with homeland security on terrorism issues affecting plant security? 3. Noise - Multiple homeowners complained that the noise from the current facility was a problem, and several stated that the problem was worse at night. Some identified the flare as a source of problematic noise, or said that they felt or observed noise -related vibrations in their homes. Others stated that the sound measurement data DCP presented at the USR hearing showing noise levels well within the standards for industrial facilities was not accurate, and said they thought the noisier equipment must not have been operating when DCP's consultant took measurements, resulting in lower numbers. Some homeowners have taken their own readings, which have produced higher numbers than DCP's sound measurement data. It was recommended that DCP conduct another sound study, with measurements taken during the day and night, for a longer period. There did not appear to be any consensus from the homeowners on how to address the issue. Several people told the DCP representatives that "you are the experts —you tell us what options are available." Others said that the walls installed on the west side of the plant did not provide noise reduction. Some people thought a high berm on the west side and trees or a wall built on top of the berm would provide noise reduction and mitigate the visual impact of the facility, but others said that this wouldn't help them because of the location of their home relative to the berm location. DCP said it has been working on ideas to reduce noise and will present some mitigation measures at the next meeting. At the next meeting, DCP will provide information about noise to respond to the questions and concerns raised in June: • Is the plant noisier at night or at certain times? DCP will take additional sound measurements during day and night at the same locations, to see whether there are differences caused by equipment operating at different times, and will present this information. Is the plant out of compliance with the sound standards? +� What are the noisier parts of the plant? What kinds of sound mitigation are most effective in general? What does DCP do to control noise now, and what additional noise mitigation measures are DCP proposing to implement at Mewbourn? 4. Air Emissions - There were a lot of questions about compliance with air quality standards, and with the effect of emissions from the plant on the health of nearby residents. One person said that there was a venting event of some kind right before the meeting, and wanted to know what it was. Some people wanted to know what kind of air permit violations had been identified by the CDPHE, and what DCP has done and will do to address those issues. Mr. Jost stated that DCP is in compliance with its air permits and the CDPHE sets air standards in permits at levels designed to protect health, safety and environment. There was extended questioning regarding the gas and organic compounds being vented into the air during flaring or venting events, including what amounts were ok or not ok. Someone noted occasional odors coming from the plant, and Mr. Jost said that an odor didn't necessarily indicate an air quality problem. DCP will have a representative at the next meeting who can address air emissions from the plant, the applicable standards, and DCP's compliance with its CDPHE permit, including:. • What are the sources of air emissions at the plant? How does DCP control emissions? What are the limits in DCP's air permit? Are those limits protective? • Has DCP exceeded those limits? Is DCP in compliance with the permit now? +� What kind of air quality permit violations at Mewbourn are shown in EPA's ECHO database? Lighting - Numerous homeowners complained about the lighting at the plant. Mr. Bricco, one of DCP's engineers, and Mr. Jost suggested that there are options that DCP will consider adding to the plan, including new downcast LED lighting and/or motion sensors that would reduce light when it is not needed. At the next meeting, DCP will provide information about how DCP can reduce light from the plant at night. 6. Traffic - Concerns were raised regarding construction traffic. The homeowners as a group would prefer that DCP designate specific traffic routes to and from the plant. One homeowner suggested diverting traffic south on CR 35 to CR 32, which apparently would avoid most of the homeowners. DCP is evaluating ways to manage construction traffic to reduce impact on the local community. At the next meeting, DCP will present information about how DCP can reduce construction traffic impacts on the nearby residents. 7. Flare — Many homeowners said the flare caused disturbances, either because of noise or light, or that the flaring created concerns about the safety of the facility. Some raised issues with the frequency of flaring events. Mr. Jost said that this equipment is part of the normal operation of the plant, and did not mean there was a safety problem. He said DCP would evaluate the recent flaring events, and determine if there were ways to reduce frequency, especially at night, or if there were ways to reduce related activities at night to reduce the flare's overall impact. At the next meeting, DCP will provide some more information about how the flare is operated, whether the frequency of flaring is related to safety, and what DCP can do to manage this part of its operation to reduce impacts on nearby residents. Landowner amendment received 07/06/17 Amendment to Meeting Minute Produced by DC P Midstream relating to the neighborhood meeting held on June 19th 2017 This amendment is required to address items left out of the meeting minutes produced and sent out by DCP Midstream on June 23, 2017. The necessity to amend comes as many key points, discussions and action items by DCP were left out of the meeting minutes produced by DCP. This amendment is an attempt to assure that no key detail, action item, statements made by any party at the meeting, goes uncaptured. First, to elaborate on the opening paragraph of the minutes, there additional statements made by Mr. Jost in his opening statement and his subsequent discussion that were inadvertently left out. So after reviewing the actual communication discussion, it is necessary to actually capture some of Mr. Josts actual statements. These are paraphrased here -in: Mr. Jost stated that he is currently the General Manager of DCP Midstream Colorado and that he has only been in charge of the DCP Midstream Colorado area for 16 months. He acknowledged that in the past DCP Midstream had not been a good neighbor (not just a poor communicator as stated in the original minutes) and that he was asking the surrounding property owners "to give him a chance and time" to make things right. He wascommitted to be a good neighbor going forward and acknowledged they (DCP) had some work to do to earn the property owners trust. He also stated that his word was his bond and that he had the utmost integrity such that if he said he said he would do something it could be counted on being done. He stated it was the objective of this meeting and another meeting scheduled for July 10, 2017 to get through all the concerns expressed at the meeting and address them in an attempt to get an understanding with the property owners of how DCP plans to be a good neighbor while going forward with the plant expansion. It was asked by the property owners if DCP planned to put it in writing any agreements made with the property owners during the next neighborhood meeting on July 10th, prior to going to the July 17 County Commission Board meeting. Mr. Groom responded (again paraphrased) that it was the intent to get to an understanding prior to going to the board meeting. This is where the property owners asked if there was enough time between now and July 17, 2017 to get a general agreement between DCP and the property owners of how DCP would address their concerns prior to moving forward with the next phased plant expansion. Mr. Jost stated that he would try to add an additional meeting before July 10. This did not get set prior to the meeting being adjourned. Item 3. Noise: DCP meeting minutes did not adequately include all the discussion and concerns addressed by all property owners who spoke regarding the extremely loud and disruptive noise that emanates from the existing plant during the day and night throughout the week including both Saturdays and Sundays. The noise concerns raised by all the property owners who spoke were nothing short of extremely distraught, mad, and upset at how their lives had been drastically changed, for the worse since the plant that is now in operation, has been in existence. For most of the property owners, they actual stated it had dramatically reduced their quality of life, such that they no longer felt they were able to have an enjoyable home environment. Although the property owners did state to DCP "that you are the expert you tell us what options are available". This came after the proper owners suggested the following items that they considered could mitigate and dramatically reduce the noise level, and in fact the neighbors want Mewbourn to operate with Residential noise levels. 1 These included: - DCP should replace all gas fired compressors converting them to electric and housing them in a building. This include replacing "all" gas fired compressors not just some as proposed by DCP. Building an earthen berm around the entire site high enough to act as a significant sound barrier. The earthen berm was to be landscaped with trees. It was acknowledged that this might not help a couple of the property owners to the east whose property elevation was higher. - It was suggested that it a sound wall could also be constructed along the entire site to a height that could satisfy all the property owners. A sound wall along with the earthen berm built in conjunction with each other could mitigate both the noise problem and obtain a more visually appeasing plant. It was suggested that other DCP Midstream competitors had achieved much more agreeable neighborhood operating plants by utilizing several of the above construction techniques to dramatically reduce the noise volume. The noise issue kept coming back to the fact that there would be design issues to come up with the best approach to mitigate. At this the property owners stated ""that you are the expert — you tell us what options are available in order to dramatically reduce the noise emitted by the plant". At which time, one of the DCP engineers stated that they have been working on this problem since the property owners sent a letter to the planning commission. The DCP engineer stated that he would come to the July 10, 2017 meeting with ideas to mitigate the noise. The property owners voiced additional concern that how is a plant that is operating at or exceeding its allowable noise limit currently, plan to assure the property owners that not only the existing plant noise could be brought way down but how the new plant now operating at over double the volume would keep the noised level down to a level that would be satisfactory to the property owners. Item 4. Air Emissions: A missing action item was: DCP agreed to provide a summary level spreadsheet, at the July 10 meeting, with the quarterly emissions reported by DCP to the government over the last five years and when they were in violation of the air emission standards. • A question was asked regarding, "What types of gases does Mewbourn plant emit? I have seen where the gases can be of a carcinogenic and a neurotoxic nature, from Benzene, Hexane, Toluene, Benzopyrene, Methane, Ethylbenzene, Nitrous oxide, Hydrogen Sulfide, Carbon Monoxide. When the plant "off gases" or "pressure releases " the gases into the atmosphere, how much is being emitted and what types of gases are being emitted? I am concerned about the health consequences to surrounding neighbors as we can have several emissions a week, flares and pressure releases. Also, with the flares, the burning of gases, what types are being burned off"? The plant manager (who has been on this site for approximately 2-3 months) answered, (paraphrasing), that the flare burns all but 3-5% of heavy gases. Hydrocarbons. One of the engineers stated that with the pressure releases, done without the flare, the gas is fight, it's Methane. 2 Item 5. Lighting: An item that was not included in DCP produced minutes was that, not like other plants, DCP would look at converting the DCP Midstream plant into a "dark skies" plant. This would be a totally dark plant with lighting only needed in cases of emergency or maintenance. This was suggested in conjunction with utilizing a lighting system, based on a photometric study that would only have the minimum lighting required, all lighting down cast and facing inward to the plant. Additional Item(s) discussed at the meeting but not making it into themeeting minutes: Future plant expansion: • The property owners point blank asked if DCP would put in writing that should this next plant expansion go through, would they agree not to expand this plant any more in the future. DCP was not prepared to respond to this question at this time. • DCP mentioned that at one time they were trucking the gas and that there were 4 tanks now that were not being utilized at the south end of the property as they no longer truck gas. A question was asked as to if the tanks could be removed and this land could be used instead for the expansion. Additional Items of concern expressed by property owners that were left out of the original meetings minutes: • Air Pollution and Chemical Leaks: • The property owners spoke about their homes filling with hydrocarbons at times and that they have contacted the DCP plant and their staff about the situation. DCP's staff confirmed the releasing of hydrocarbons and expressed their apologies. ■ The neighbors spoke about their houses filing with chemicals and that the chemicals caused their eyes and throats to burn. ■ The neighbors spoke about smelling propane, condensate, or some other chemical while on their own property. ■ The neighbors spoke about being "impacted" by odors and air pollution. • The neighbors spoke about not being able to use their property for planned family events. Traffic: ■ The neighbors spoke about their homes being damaged by previous Mewbourn II construction traffic and they had requested DCP to "take care of" the damage. ■ The neighbors spoke about their not feeling safe on their own property due to Mewbourn II construction traffic. • Noise: • The neighbors spoke about not being able to hear crickets or birds. ■ The neighbors spoke about their family events being cancelled due to Mewbourn II noise, ■ The neighbors requested good noise level data from DCP. • 3 • Lights. The neighbors spoke about the "skies being lit up" at night that the plant is too bright at night. • [PCP's past record of addressing neighbor concerns: • The neighbors spoke about their being at the mercy of DCP. ■ The neighbors spoke about not being treated by DCP and Mewbourn II. ■ The neighbors spoke about DCP not taking care of the people (neighbors). • The neighbors spoke about offering to pay Bill Johnson, DCP Executive, for a noise wall, but no wait was ever put up. The neighbors spoke about the County Commissioners wanting at least 60 days between hearings, but DCP complained it would cost them too much money (time). However, Mr. Jost asked the neighbors at the first June meeting to "please give him more time to resolve the problems" at Mewbourn, that he was still "new" to the situation, mistakes had been made in the past and he hadn't been aware of the neighbor's concerns." • Property Values: • The property owners were concerned about how the expansion of the plant will further negatively impact their property value. DCP stated that they understood the concerns and that hopefully with the many discussed options to mitigate the plants impact on the surrounding properties that this would help address this concern. Other than the above comments, no further additions or deletions are a part of the minutes. Note: Subsequent to the meeting, Mr. Margheim spoke with Mr. Jost and was told personally by Mr. Jost that he would meet Mr. Margheim at his property within the next two weeks to discuss his issues /complaints with the Mewbourn plant and DCP. To date, Mr. Margheim has not heard from Mr. Jost. 4 Landowner agenda received 07/06/17 Specific agenda prepared by the property owners for the neighborhood meeting on July 10th, 2017 with DCP Midstream and the property owners regarding the Mewbourn Plant current operation and future expansion. The purpose of this agenda is to reach a Memorandum of Understanding by conclusion of the evening meeting such that this written document would be a part of the approval of the current requested amended USR by DCP Midstream. Herein are the items the surrounding property owners expect to get established and into writing via the memorandum of understanding: • Noise: Reduce the noise levels to a residential level at the property line of the Mewbourn plant with design criteria meeting these standards being approved in the operations standards prior to construction permit being granted by the County. • Air Emissions: DCP must meet all current city, county, state, and federal air quality regulations/standards, and this needs to be a part of their operating standards. ■ Require a "Dispersion Study" for when there are flares as to what types of gases are being emitted, the concentration of those gases, the flow rate at the stack, temperature, pressure, etc,, so that the surrounding property owners know what we are being exposed to, when, and at what concentrations and at what distances. ■ If the concentration of gases are high enough, within 1,000 feet of a property owner, require permanent monitoring of gas emissions at the plant site. • Lighting: The neighbors are requesting that Mewbourn operate with the "Dark Skies" standards that have been adapted throughout the United States • Appearance: Make the plant visually appealing, screened from neighbor's views • Notifications: Real time reporting of pressure releases, flares, accidents, informing property owners through mass alerts (text messaging, emails, phone calls, etc.,) so that we can take actions to limit our exposure to the gas emissions with these incidents • Security: Secure the site by other means other than chain link fencing • Construction: • Limit construction hours to 7am to 7pm Monday through Friday being a "good neighbor" • Dust management by having a water truck constantly watering the construction route Establish haul route, currently the neighbors are agreeable to using CR 32 from the south up CR 35 to the plant site. The neighbors do not want any construction traffic on CR 33, CR 38, or CR 40. The neighbors do not want the use of Mag Chloride or Brine on the road ■ Chip seal CR 35, or pave • Trash abatement at least once a week, more frequently if needed • Establish a complaint line for the surrounding neighbors for addressing their issues regarding the construction and construction traffic Landowner comments received after 07/10/17 meeting From: JILL LAFFERTY [mailto:heavenlyhavens@msn.com] Sent: Monday, July 10, 201710:18 PM To: Jost, David M <DMJost@dcpmidstream.com> Subject: July 10 meeting Dear David, Thank you for addressing all of my concerns in a satisfactory manner tonight. I was very impressed with the answers that were given and what you are proposing to do for us. On another note, I was genuinely concerned about the black gritty ash that had covered my daughter this weekend. After observing a flare with black smoke recently, I was concerned that the black gritty ash was related to the plant's flaring of gases. One daughter was coated in suntan oil, and the other wasn't. It was the first time I had ever seen such a particulate accumulate on our skin so I assumed that if we weren't coated in oil, the ash typically fell off of us and we were not aware that it could be of a more frequent occurrence. I could tell your e ngineers were honestly perplexed as to what the source of the ash might be. When Jeff stated that, "the gases are the same that are burned in your homes" and that the gases burn "clean", thought yes, that makes sense to me. After I asked the question and showed the photo of the gritty black ash to John, rumors started swirling around the room that the ash was from a neighbor burning tires for three days straight! I understand that he lives quite some distance from me, hence the fact that I hadn't seen anything burning in my area except for the flare. Once I was made aware of this potential source for the ash, it all made sense as to the timeline and the type of "ash" that coated my daughter. When I pinched it between my fingers, it left very little ashy residue but remained hard and gritty. You might want to let your e ngineers know the source as they really were perplexed and they'd be happy with the e xplanation. Sincerely, Jill Lafferty STATE CAF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: DATE ISSUED: ISSUED TO: 09WE1136 July 14, 2017 DCP Operating Company, LP Issuance 4 THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural gas processing facility, known as the Mewbourn Natural Gas Processing Plant, located in SE1/4 Section 35, Township 4 North, Range 66 West, in Weld County. Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description C-211 101 One (1) Caterpillar, G379NA, SN: 72B643, natural gas fired, 4 - stroke, rich -burn, naturally aspirated. reciprocating internal combustion engine, heat input rated at 2.6 MMBTU per hour, output rated at 330 HP, running a natural gas / vapor compressor. Emissions are controlled by AFR and a Non - Selective Catalytic Reduction system. C-167 102 One (1) Waukesha, L7044GS1, SN: C14610-1, natural gas fired, 4 -stroke, rich -burn, turbocharged. reciprocating internal combustion engine, heat input rated at 12.9 MMBTU per hour, output rated at 1,680 HP, running a natural gas compressor. Emissions are controlled by AFR and a Non -Selective Catalytic Reduction System. C-179 103 One (1) Waukesha, L7042GS1, SN: C-10731-1, natural gas fired, 4 -stroke, rich -burn, turbocharged, reciprocating internal combustion engine, heat input rated at 11.6 MMBTU per hour, output rated at 1,478 HP, running a natural gas compressor. Emissions are controlled by AFR and a Non -Selective Catalytic Reduction System. AIRS ID: 123/0090 Page 1 of 72 NGEngine Version 2009-1 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division Facility Equipment ID AIRS Point Description C-130 106 One (1) Waukesha, L7042GS1, SN: 339839, natural gas fired, 4 -stroke, rich -burn, turbocharged, reciprocating internal combustion engine, heat input rated at 11.2 MMBTU per hour, output rated at 1,478 HP, running a natural gas compressor. Emissions are controlled by AFR and a Non -Selective Catalytic Reduction system. F017 108 Facility Equipment Leaks. Emissions minimized by Leak Detection and Repair Program. LO 109 Stabilized natural gas condensate loadout to tank trucks. Emissions from this source are controlled by an enclosed combustor (John Zink, ZCT-1-4-35-X-1/3). TANKS 110 Four (4) 400 barrel fixed roof stabilized natural gas condensate storage vessels connected via liquid manifold. Emissions from this source are controlled by an enclosed combustor (John Zink, ZCT-1-4-35-X-1/3). C0170 111 One (1) Solar, Taurus 60, SN: OHH 15-T9606, natural gas fired combustion turbine, heat input rated at 50.1 MMBTU per hour. This is equipped with Dry Low NOx combustion system for minimizing emissions of Nitrogen Oxides. This powers a natural gas compressor. Identified as Inlet 1. C0180 112 One (1) Solar, Taurus 60, SN: OHE17-T9134, natural gas fired combustion turbine, heat input rated at 50.1 MMBTU per hour. This is equipped with Dry Low NOx combustion system for minimizing emissions of Nitrogen Oxides. This powers a natural gas compressor. Identified as Inlet 2. C250 113 One (1) Caterpillar, G3608TALE, SN: BEN00563, natural gas fired, 4 -stroke, turbo -charged, lean -burn, low emissions design, reciprocating internal combustion engine, heat input rated at 17.9 MMBTU per hour, output rated at 2,370 HP, powering a natural gas compressor. Emissions are controlled by an oxidation catalyst. Identified as Residue 1 C251 114 One (1) Caterpillar, G3608TALE, SN: BEN00565, natural gas fired, 4 -stroke, turbo -charged, lean -burn, low emissions design, reciprocating internal combustion engine, heat input rated at 17.9 MMBTU per hour, output rated at 2,370 HP, powering a natural gas compressor. Emissions are controlled by an oxidation catalyst. Identified as Residue 2. AIRS ID: 123/0090 Page 2 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division Facility Equipment ID AIRS Point Description C252 115 One (1) Caterpillar, G3608TALE, SN: BEN00567, natural gas fired, 4 -stroke, turbo -charged, lean -burn, low emissions design, reciprocating internal combustion engine, heat input rated at 17.9 MMBTU per hour, output rated at 2,370 HP, powering a natural gas compressor. Emissions are controlled by an oxidation catalyst. Identified as Residue 3. C253 116 One (1) Caterpillar, G3608TALE, SN: BEN00572, natural gas fired, 4 -stroke, turbo -charged, lean -burn, low emissions design, reciprocating internal combustion engine, heat input rated at 17.9 MMBTU per hour, output rated at 2,370 HP, powering a natural gas compressor. Emissions are controlled by an oxidation catalyst. Identified as Residue 4. C254 117 One (1) Caterpillar, G3608TALE, SN: BEN00571, natural gas fired, 4 -stroke, turbo -charged, lean -burn, low emissions design, reciprocating internal combustion engine, heat input rated at 17.9 MMBTU per hour, output rated at 2,370 HP, powering a natural gas compressor. Emissions are controlled by an oxidation catalyst. Identified as Residue 5. G1650 118 One (1) Solar, Taurus 70, natural gas fired combustion turbine (SN: TG09548), rated at 61.6 MMBTU per hour heat input and 8,046 horsepower (HP). This is equipped with Dry Low NOx combustion system for minimizing emissions of Nitrogen Oxides. This runs an electric power generator. Identified as Genset 1 G1670 119 One (1) Solar, Taurus 70, natural gas fired combustion turbine (SN: TG09549), rated at 61.6 MMBTU per hour heat input and 8,046 horsepower (HP). This is equipped with Dry Low NOx combustion system for minimizing emissions of Nitrogen Oxides. This runs an electric power generator. Identified as Genset 2 AIRS ID: 123/0090 Page 3 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division Facility Equipment ID AIRS Point Description AM001 120 One (1) methyldiethanolamine (MDEA) natural gas sweetening unit (Make: Precision Pipe and Vessel, Model: T- 501, Serial Number: 1830) for acid gas removal with a design capacity of 160 MMscf per day. This emission unit is equipped with three (3) (Make: Schlumberger RedaHP, Model: J350N) electric driven amine recirculation pumps with a total limited capacity of 640 gallons per minute of lean amine. Only two (2) amine recirculation pumps will be operated at any given time. The third amine recirculation pump serves as a back-up only. This amine unit is equipped with a natural gas/amine contactor, reflux condenser, flash tank, still vent and amine regeneration reboiler covered under point 123/0090/121. Emissions from the flash tank are routed directly to the vapor recovery unit (VRU) that recycles the emissions back to the plant inlet. The VRU has a maximum of 5% annual downtime. During VRU downtime, flash tank emissions are routed to the plant flare covered under point 123/0090/125 with a 95% destruction efficiency. The acid gas stream from the still vent is routed to reflux condenser and then to a thermal oxidizer (TO) (Make: Anguil, Model: 632, Serial Number: TBD) with fuel gas limited at 18 MMBtu/hr. The destruction efficiency for the TO is 96.7%. During TO downtime, emissions from the still vent are routed to an acid gas flare covered under point 123/0090/136 with a destruction efficiency of 95%. The TO has a maximum downtime of 13 days per year (312 hrs/year). H776 121 One (1) Optimized Process Furnace, Inc., Model 200, SN: J091036, natural gas fired amine regeneration reboiler, heat input design rated at 64.9 MMBTU per hour. This is equipped with Ultra -Low NOx combustion system for minimization of Nitrogen Oxides emissions. AIRS ID: 123/0090 Page 4 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division Facility Equipment ID AIRS Description Point D-931 122 One (1) Triethylene glycol (TEG) natural gas dehydration unit (Make: Precision Pipe & Vessel LLC, Model: T-531, Serial Number: CL09-144) with a design capacity of 125 MMSCF per day. This emissions unit is equipped with two (2) (Make: Rotor Tech, Model: GS -3308) electric driven glycol pumps with a limited total combined capacity of 28 gallons per minute. This dehydration unit is equipped with a still vent, glycol flash tank, and reboiler burner (heat provided by hot gases from various combustion processes supplemented by a hot oil heater) covered under AIRS Point ID: 123/0090/123. Emissions from the still vent are routed to an air-cooled condenser, and then to a vapor recovery unit (VRU) that recycles the emissions back to the plant inlet. Emissions from the flash tank are routed directly to the vapor recovery unit (VRU) that recycles the emissions back to the plant inlet. The VRU that recycles the still vent and flash tank emissions has a maximum 2% annual downtime. During VRU downtime, still vent and flash tank emissions are routed to the open flare covered under AIRS Point ID: 123/0090/125. H771 123 Two (2) Devco, HeliFlow, SN: 3431-3, natural gas fired hot oil heaters, heat input design rated at 26.0 MMBTU per hour each. These are equipped with Ultra-Low-NOx combustion systems for minimization of Nitrogen Oxides emissions. Hot oil is used to provide heat to various natural gas processes at the facility including supplemental heat for glycol regeneration reboiler. Only one heater to be operated at a time, the other is to be used as a backup. F-1 Backup TO TURB-1 TURB-2 125 127 129 130 Plant flare (John Zink, KMI-12-8-WB, SN: 912554) used for blowdowns, amine flash during VRU downtime and dehydrator flash and still vent (point 122) during VRU downtime. Backup thermal oxidizer for amine unit (Point 120) and primary thermal oxidizer glycol dehydrator (Point 122). Emissions from amine still vent are routed to the backup TO when RTO is down and acid gas is not venting for a maximum of 55 days. One (1) Solar, Taurus 70, natural gas fired combustion turbine (SN: TBD), rated at 72.7 MMBTU per hour heat input and 9,055 horsepower (HP). This is equipped with Dry Low NOx combustion system for minimizing emissions of Nitrogen Oxides. This source is used for natural gas compression. One (1) Solar, Taurus 70, natural gas fired combustion turbine (SN: TBD), rated at 72.7 MMBTU per hour heat input and 9,055 horsepower (HP). This is equipped with Dry Low NOx combustion system for minimizing emissions of Nitrogen Oxides. This source is used for natural gas compression. AIRS ID: 123/0090 Page 5 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division Facility Equipment ID AIRS Point Description D-2 131 One (1) Triethylene glycol (TEG) natural gas dehydration unit (Make: TBD, Model: TBD, Serial Number: TBD) with a design capacity of 230 MMscf per day. This emissions unit is equipped with two (2) (Make: TBD. Model: TBD) electric driven glycol pumps each with a design capacity of 40 gallons per minute. Only one glycol pump will be operated at any given time. The second glycol pump serves as a back-up only. This dehydration unit is equipped with a still vent, flash tank, and and electric reboiler burner. Emissions from the still vent are routed to an air-cooled condenser, and then to a vapor recovery unit (VRU) that recycles the emissions back to the plant inlet. Emissions from the flash tank are routed directly to the vapor recovery unit (VRU) that recycles the emissions back to the plant inlet. The VRU that recycles the still vent and flash tank emissions has a maximum 2% annual downtime. During VRU downtime, still vent and flash tank emissions are routed to the open flare covered under AIRS Point ID: 123/0090/137. HT -01 132 One (1) Optimized Process Furnaces Inc. (OPF) (Model: TBD, SN: TBD) natural gas fired regeneration heater. The heater is design rated at 9.6 MMBtu/hr. This heater is equipped with a low NOx combustion system for minimizing emissions of Nitrogen Oxides. The heater provides heat for mole sieve regeneration. HT -02 133 One (1) Optimized Process Furnaces Inc. (OPF) (Model: TBD, SN: TBD) natural gas fired hot oil heater. The heater is design rated at 40.8 MMBtu/hr. The heater is equipped with a low NOx combustion system for minimizing emissions of Nitrogen Oxides. The heater provides heat for the condensate stabilizer and demethanizer trim reboiling. TANKS -2 134 Two (2) 755 barrel fixed roof stabilized natural gas condensate storage vessels connected via liquid manifold. Emissions from this source are controlled by an enclosed combustor (John Zink, ZCT-1-4-35-X-1/3). FUG -02 135 Fugitive emission component leaks from a natural gas processing plant associated with the Mewbourn III expansion project. F-2 136 One (1) acid gas flare (Make: Zeeco, Model: HSLF, SN: TBD) used to control the amine unit still vent emissions during thermal oxidizer downtime. F-3 137 One (1) open flare (Make: Zeeco, Model: HSLF, SN: TBD) used for maintenance purposes. This open flare also controls emissions from the TEG dehydration unit covered under point 131 during VRU downtime. Point 101 may be replaced with another engine in accordance with the temporary engine replacement provision or with another Caterpillar G379NA engine in accordance with the AIRS ID: 123/0090 Page 6 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. Point 102 may be 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. Points 103 & 106 may be replaced with another engine in accordance with the temporary engine replacement provision or with another Waukesha L7042GSl engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. Points 111 & 112 may be replaced with another turbine in accordance with the temporary turbine replacement provision or with another Solar Taurus 60 turbine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment B. Points 113, 114, 115, 116 & 117 may be replaced with another engine in accordance with the temporary engine replacement provision or with another Caterpillar G3608TALE engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. Point 118 & 119 may be replaced with another Solar Taurus 70 turbine rated at 8,046 HP in accordance with the temporary turbine replacement provision or with another Solar Taurus 70 turbine rated at 8,046 HP in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment B. Point 129 & 130 may be replaced with another Solar Taurus 70 turbine rated at 9,055 HP in accordance with the temporary turbine replacement provision or with another Solar Taurus 70 turbine rated at 9,055 HP in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment B. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. Points 129-137: 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 - AIRS ID: 123/0090 Page 7 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division certify compliance as required by this permit may be obtained online at www.colorado.qov/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 per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, 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. (Reference: Regulation Number 3, Part B, Section III.E.) 5. Points 129, 130, 132, & 133: 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. • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation Number 3, Part B, III.E.) 6. Point 131: The following information shall be provided to the Division within fifteen (15) days of the latter of commencement of operation or issuance of this permit. • The dehydrator manufacturer name, model number and serial number • The glycol circulation pump manufacturer name and model number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation Number 3, Part B, III.E.) 7 The operator shall retain the permit final authorization letter issued by the Division after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 8. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation Number 3, Part B, Section II.A.4) Monthly Limits: Facility Equipment ID AIRS Point Process Pounds per Month Emission Type pM2.s PMio SO„ H2S NO. VOC CO AIRS ID: 123/0090 Page 8 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division TURB-1 129 01 357 357 --- --- 2,552 --- 2,992 Point TURB-2 130 01 357 357 --- --- 2,552 --- 2,992 Point D-2 131 02 --- --- --- --- --- 172 --- Point HT -01 132 01 --- --- --- --- 340 --- 571 Point HT -02 133 01 219 219 --- --- 1,446 --- 2,429 Point TANKS -2 134 01 --- --- --- --- --- 313 --- Point FUG -02 135 01 --- --- --- --- --- 4,573 --- Fugitive Note: Monthly limits are based on a 31 -day month. The owner or operator shall calculate monthly emissions based on the calendar month. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 1,359 pounds per month. Facility -wide emissions of total hazardous air pollutants shall not exceed 3,431 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 Point Process Tons per Year Emission Type PM2.5 PM10 SOX H2S NO. VOC CO C-211 101 01 --- --- --- --- 5.10 3.19 5.10 Point C-167 102 01 --- --- --- --- 24.33 12.17 24.33 Point C-179 103 01 --- --- --- --- 21.41 14.27 21.41 Point C-130 106 01 --- --- --- --- 3.64 3.64 10.91 Point F017 108 01 --- --- --- --- --- 50.79 --- Fugitives LO 109 01 --- --- --- --- 1.0 4.62 3.96 Point TANKS 110 01 --- --- --- --- --- 1.89 --- Point C0170 111 01 --- --- --- --- 13.14 --- 13.32 Point C0180 112 01 --- --- --- --- 13.14 --- 13.32 Point C250 113 01 --- --- --- --- 45.76 64.08 17.56 Point C251 114 01 --- --- Point C252 115 01 --- --- Point C253 116 01 --- --- Point AIRS ID: 123/0090 Page 9 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division C254 117 01 --- --- Point G1650 118 01 1.78 1.78 --- --- 16.12 --- 16.38 Point G1670 119 01 1.78 1.78 --- --- 16.12 --- 16.38 Point AM001 120 01 --- --- 33.72 0.57 --- 8.44 --- Point 02 --- --- 0.05 --- 12.54 0.41 28.16 03 --- --- --- --- 0.13 --- 0.61 H776 121 01 --- --- --- 8.12 1.49 22.74 Point D-931 122 02 --- --- --- --- 0.57 --- Point H771 123 01 --- --- --- --- 3.25 --- 9.11 Point F-1 125 01 --- --- --- --- --- 1.8 1.2 Point Backup TO 127 01 --- --- 5.1 --- 3.0 3.0 4.8 Point TURB-1 129 01 2.10 2.10 --- --- 15.02 --- 17.61 Point TURB-2 130 01 2.10 2.10 --- --- 15.02 --- 17.61 Point D-2 131 02 --- --- --- --- 1.01 --- Point HT -01 132 01 --- --- --- --- 2.00 --- 3.36 Point HT -02 133 01 1.29 1.29 --- --- 8.51 --- 14.30 Point TANKS -2 134 01 --- --- --- --- --- 1.84 - Point FUG -02 135 01 --- --- --- --- 26.92 --- Fugitive F-2 136 Point 02 --- --- 0.01 --- 0.73 1.55 3.10 F-3 137 01 --- --- --- --- 0.68 1.97 2.80 Point Notes: 1. See "Notes to Permit Holder" #4 for information on emission factors and methods used to calculate limits. 2. Process 01, 02 and 03 for point 120 are as follow: a. Process 01: Natural gas processed by the amine unit b. Process 02: Combustion of still vent waste gas, supplemental fuel and pilot fuel by the thermal oxidizer. c. Process 03: Combustion of flash tank waste gas by the plant flare (point 125). 3. Process 01 and 02 for point 136 are as follow: a. Process 01: Natural gas processed by the amine unit during thermal oxidizer downtime. b. Process 02: Combustion of still vent waste gas. purge gas, assist gas and pilot fuel by the flare. Facility -wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility -wide emissions of total hazardous air pollutants shall be less than 20.2 tpy. AIRS ID: 123/0090 Page 10 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Points 129-137: During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 9. The owner or operator shall track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility emission limitations as seen below. An inventory of each insignificant activity and associated emission calculations shall be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities shall be defined as any activity or equipment, which emits any amount but does not require an Air Pollutant Emission Notice (APEN) or is permit exempt. (Reference: Regulation 3, Part C.II.E.) Total emissions from the facility, including permitted emissions and insignificant activities, shall not exceed: • 25 tons per year of total hazardous air pollutants (HAP). 10. Point 120 & 136: Compliance with the emission limits in this permit shall be demonstrated by running the Promax simulation model or Division -approved software on a monthly basis using the most recent amine unit inlet extended sour gas analysis and recorded operational values including: gas throughput, lean amine recirculation rate, vapor recovery unit (VRU) downtime, thermal oxidizer (TO) downtime, flash tank temperature and pressure, sour gas inlet temperature and sour gas inlet pressure. Recorded operational values, except for gas throughput, shall be averaged on a monthly basis for input into Promax simulation model. 11. Point 122 & 131: Compliance with the emission limits in this permit shall be demonstrated by running the GRI GlyCalc model version 4.0 or higher on a monthly basis using the most recent extended wet gas analysis and recorded operational values, including: total actual gas throughput, lean glycol recirculation rate, vapor recovery unit (VRU) downtime, flash tank temperature and pressure, wet gas inlet temperature, and wet gas inlet pressure. Recorded operational values, except for total actual gas throughput, shall be averaged on a monthly basis for input into the model and be provided to the Division upon request. 12. Point 135: The operator shall calculate actual emissions from this emissions point based on representative component counts for the facility with the most recent extended gas analysis, as required in the Compliance Testing and Sampling section of this permit. The operator shall maintain records of the results of component counts and sampling events used to calculate actual emissions and the dates that these counts and events were completed. These records shall be provided to the Division upon request. AIRS ID: 123/0090 Page 11 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division 13. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation Number 3, Pad B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled C-211 101 Air -Fuel Ratio Controller and NSCR NOx, VOC, CO, & HAP C-167 102 Air -Fuel Ratio Controller and NSCR NOx, VOC, CO, & HAP C-179 103 Air -Fuel Ratio Controller and NSCR NOx, VOC, CO, & HAP C-130 106 Air -Fuel Ratio Controller and NSCR NOx, VOC, CO, & HAP LO 109 Enclosed Combustor VOC & HAP TANKS 110 Enclosed Combustor VOC & HAP C250 113 Oxidation Catalyst CO, VOC, & HAP C251 114 Oxidation Catalyst CO, VOC, & HAP C252 115 Oxidation Catalyst CO, VOC, & HAP C253 116 Oxidation Catalyst CO. VOC, & HAP C254 117 Oxidation Catalyst CO, VOC, & HAP AM001 120 Still Vent: Routed to thermal oxidizer (TO). Routed to acid gas flare covered under point 123/0090/136 during TO downtime. VOC & HAP Flash Tank: Recycled to plant inlet via VRU. Routed to open flare covered under point 123/0090/125 during 5% VRU downtime. D-931 122 Still Vent: Recycled to plant inlet via VRU. Routed to open flare covered under point 123/0090/125 during 2% VRU downtime. VOC & HAP Flash Tank: Recycled to plant inlet via VRU. Routed to open flare covered under point 123/0090/125 during 2% VRU downtime. D-2 131 Still Vent: Recycled to plant inlet via VRU. Routed to open flare covered under point 123/0090/137 during 2% VRU downtime. VOC & HAP Flash Tank: Recycled to plant inlet via VRU. Routed to open flare covered under point 123/0090/137 during 2% VRU downtime. TANKS -2 134 Enclosed Combustor VOC & HAP AIRS ID: 123/0090 Page 12 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division PROCESS LIMITATIONS AND RECORDS 14. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the applicant and made available to the Division for inspection upon request. (Reference: Regulation Number 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Process Parameter Annual Limit Monthly Limit (31 days) C-211 101 01 Consumption of natural gas as a fuel 21.69 MMSCF --- C-167 102 01 Consumption of natural gas as a fuel 107.21 MMSCF --- C-179 103 01 Consumption of natural gas as a fuel 96.48 MMSCF --- C-130 106 01 Consumption of natural gas as a fuel. Operation: 4,464 hours/year 47.52 MMSCF --- LO 109 01 Throughput of stabilized natural gas condensate 912,500 barrels --- TANKS 110 01 Throughput of stabilized natural gas condensate 912,500 barrels --- C0170 111 01 Consumption of natural gas as a fuel 417.93 MMSCF --- C0180 112 01 Consumption of natural gas as a fuel 417.93 MMSCF --- C250 113 01 Consumption of natural gas as a fuel for all 5 compressor engines. 35,040 compressor engine- hours per year. 602.47 MMSCF total --- C251 114 01 --- C252 115 01 --- C253 116 01 --- C254 117 01 --- G1650 118 01 Consumption of natural gas as a fuel 513.75 MMSCF --- G1670 119 01 Consumption of natural gas as a fuel 513.75 MMSCF --- AM001 120 01 Natural Gas Throughput 58,400 MMSCF --- 02 Combustion of still vent waste gas routed to the thermal oxidizer. 1,688.44 MMSCF ' --- Combustion of supplemental fuel and pilot fuel at the thermal oxidizer. 150.67 MMSCF ---- AIRS ID: 123/0090 Page 13 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division 03 Combustion of flash tank waste gas routed to the plant flare (point 125) 3.21 MMSCF H776 121 01 Consumption of natural gas as a fuel 541.45 MMSCF --- D-931 122 01 Total Natural Gas Throughput 45,625 MMSCF 02 Natural Gas Throughput During VRU Downtime 912.5 MMSCF H771 123 01 Consumption of natural gas as a fuel 216.91 MMSCF F-1 125 01 Natural gas flaring 9.09 MMSCF --- Backup TO 127 01 Waste gas combusted during RTO downtime 252.4 MMSCF - TURB-1 129 01 Consumption of natural gas as a fuel 606.79 MMSCF 51.53 MMSCF TURB-2 130 01 Consumption of natural gas as a fuel 606.79 MMSCF 51.53 MMSCF D-2 131 01 Total Natural Gas Throughput 83,950 MMSCF 7,130 MMSCF 02 Natural Gas Throughput During VRU Downtime 1,679 MMSCF 142.6 MMSCF HT -01 132 01 Consumption of natural gas as a fuel 80.09 MMSCF 6.80 MMSCF HT -02 133 01 Consumption of natural gas as a fuel 340.39 MMSCF 28.91 MMSCF TANKS -2 134 01 Throughput of natural gas condensate 912,500 barrels 77,500 barrels F-2 136 01 Natural Gas Processed by the amine unit during TO downtime 2,080 MMSCF - 02 Combustion of Still Vent Waste Gas 65.37 MMSCF Combustion of assist fuel and purge gas 17.21 MMSCF --- Combustion of pilot light fuel. 1.18 MMSCF --- F-3 137 01 Combustion of maintenance gas and purge gas 15.63 MMSCF --- 02 Combustion of pilot light fuel 1.71 MMSCF - Notes: 1) Point 137: The open flare covered under point 137 will handle gas (inlet and residue) routed to the flare during standard operational process/normal operation of equipment (i.e. AIRS ID: 123/0090 Page 14 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division maintenance and blowdown activities). The process limit does not include gas routed to the flare during malfunction events or startup and shutdown events per the Colorado Common Provisions Regulation Section II.E and II.J. The process limit also does not include waste gas associated with the dehydrator (Point 131) still vent and flash tank routed to this flare during VRU downtime. The owner or operator shall monitor monthly process rates based on the calendar month. Point 120 & 136: The volume of gas processed shall be measured by gas meter or by assuming the maximum design rate of the amine unit of 160 MMscf/day. Point 122: The volume of gas processed shall be measured by gas meter or by assuming the maximum design rate of the dehydrator unit of 125 MMscf/day. Point 131: The volume of gas processed shall be measured by gas meter or by assuming the maximum design rate of the dehydrator unit of 230 MMscf/day. 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 yearly consumption limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate monthly consumption of natural gas and keep a compliance record on site or at a local field office with site responsibility, for Division review. 15. Point 120: This unit shall be limited to the maximum lean amine recirculation pump rate of 640 gallons per minute. The lean amine recirculation rate shall be recorded daily in a log maintained on site and made available to the Division for inspection upon request. Amine recirculation rate shall be monitored by one of the following methods: assuming maximum design pump rate, using amine flow meter(s), or recording strokes per minute and converting to circulation rate. (Reference: Regulation Number 3, Part B, II.A.4) 16. Point 120: On a weekly basis, the owner or operator shall monitor and record operational values including: flash tank temperature and pressure and sour gas inlet temperature and pressure. These records shall be maintained for a period of five years. 17. Point 120: The owner or operator shall monitor and record VRU downtime for this emission point on a daily basis. VRU downtime shall be defined as times when the waste gas vented from the amine unit flash tank is routed to the open flare (point 125) rather than the VRU. The total hours of VRU downtime, total volume of gas vented from the amine unit flash tank and total volume of gas vented from the amine unit flash tank during VRU downtime shall be recorded on a monthly basis. The owner or operator must use monthly VRU downtime records, monthly records of gas vented from the amine unit flash tank, and the emission factors established in the Notes to Permit Holder to demonstrate compliance with the process and emission limits specified in this permit. 18. Point 120 & 136: The owner or operator shall monitor and record thermal oxidizer (TO) downtime for this emission point on a daily basis. TO downtime shall be defined as times when the waste gas vented from the amine unit still vent is routed to the acid gas flare (point 136) rather than the TO. The total hours of downtime and volume of gas processed during TO downtime shall be recorded on a monthly basis. The operator AIRS ID: 123/0090 Page 15 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division shall demonstrate natural gas processed by the amine unit does not exceed 2,080 MMSCF/year while emissions from the amine unit still vent are routed to the acid gas flare (point 136) during TO downtime on a rolling 12 month total basis. 19. Point 120 & 136: The owner or operator shall continuously monitor and record the volumetric flow rate of waste gas vented from the amine unit still vent using a flow meter. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. 20. Point 120: The owner or operator shall continuously monitor and record the volumetric flow rate of supplemental fuel combusted by the thermal oxidizer using a flow meter. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. 21. Point 122: This unit shall be limited to the maximum lean glycol circulation rate of 28 gallons per minute. The lean glycol recirculation rate shall be recorded daily in a log maintained on site and made available to the Division for inspection upon request. Glycol recirculation rate shall be monitored by one of the following methods: assuming maximum design pump rate, using glycol flow meter(s), or recording strokes per minute and converting to circulation rate. This maximum glycol circulation rate does not preclude compliance with the optimal glycol circulation rate (Lop,;) provisions under MACT HH. (Reference: Regulation Number 3, Part B, II.A.4) 22. Point 122 & 131: 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. 23. Points 122 & 131: The owner or operator shall monitor and record VRU downtime for each emission point on a daily basis. VRU downtime shall be defined as times when the waste gas vented from the glycol dehydrator flash tank and/or still vent is routed to the open flare rather than the VRU. The total hours of VRU downtime, total volume of gas processed and total volume of gas processed during VRU downtime shall be recorded on a monthly basis. The owner or operator must use monthly VRU downtime records, monthly gas processing records, and the calculation methods established in the Notes to Permit Holder to demonstrate compliance with the process and emission limits specified in this permit. 24. Points 129 & 130: The owner or operator shall continuously monitor and record the volumetric flow rate of natural gas combusted as fuel for each turbine using an operational continuous flow meter at the inlet. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. 25. Point 131: This unit shall be limited to the maximum lean glycol circulation rate of 40 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 AIRS ID: 123/0090 Page 16 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division maximum design pump rate, using glycol flow meter(s), or recording strokes per minute and converting to circulation rate. This maximum glycol circulation rate does not preclude compliance with the optimal glycol circulation rate (Lops) provisions under MACT HH. (Reference: Regulation Number 3, Part B, II.A.4) 26. Points 132 & 133: The owner or operator shall continuously monitor and record the volumetric flow rate of natural gas combusted as fuel for each heater using an operational continuous flow meter at the inlet. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. 27. Point 136: The owner or operator shall continuously monitor and record the volumetric flow rate of assist gas routed to the flare using a flow meter. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. 28. Point 137: The owner or operator shall continuously monitor and record the volumetric flow rate of process and purge gas routed to the flare using a flow meter. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 29. The permit number and AIRS ID number shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable). 30. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation Number 1, Section II.A.1. & 4.) 31. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) Reciprocating Internal Combustion Engines 32. Points 102, 103, & 106: This equipment is subject to the control requirements for stationary and portable engines in the 8 -hour ozone control area under Regulation No. 7, Section XVI.B.1. For rich burn reciprocating internal combustion engines, a non -selective catalyst reduction system and an air fuel controller shall be required. 33. Points 102, 103 & 106: This equipment is subject to the control requirements for natural gas -fired reciprocating internal combustion engines under Regulation No. 7, Section XVII.E.3.a (State only enforceable). All rich burn reciprocating internal combustion engines with a manufacturer's nameplate design rate greater than 500 horsepower shall install and operate both a non -selective catalytic reduction and an air fuel controller by July 1, 2010. 34. Points 101, 102, 103, 106, 113-117: All new, modified or relocated (into the state) natural gas -fired reciprocating internal combustion engines are subject to the control requirements for natural gas -fired reciprocating internal combustion engines under Regulation No. 7, AIRS ID: 123/0090 Page 17 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division 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 g/hp-hr NOx CO VOC <100HP Any N/A N/A N/A ≥100HP and <500HP January 1, 2008 January 1, 2011 2.0 1.0 4.0 2.0 1.0 0.7 >500HP July 1, 2007 July 1,2010 2.0 1.0 4.0 2.0 1.0 0.7 35. Points 113, 114, 115, 116 & 117: This equipment is subject to the control requirements for stationary and portable engines in the 8 -hour ozone control area under Regulation No. 7, Section XVI.B.2. For lean burn reciprocating internal combustion engines, an oxidation catalyst shall be required. Fugitive Emissions 36. Point 108 & 135: This source is subject to Regulation No. 7. Section XII.G.1 (State only enforceable). For fugitive VOC emissions from leaking equipment, the leak detection and repair (LDAR) program as provided at 40 CFR Part 60, Subpart KKK (July 1, 2016) shall apply, regardless of the date of construction of the affected facility, unless subject to applicable LDAR program as provided at 40 CFR Part 60, Subparts OOOO or 0000a (July 1, 2016).The operator shall comply with all applicable requirements of Section XII. 37. Point 108: This facility is subject to the New Source Performance Standards requirements of Regulation No. 6, Part A, Subpart KKK, Standards of Performance for Onshore Natural Gas Processing Plants including, but not limited to, the following: • 40 CFR, Part 60, Subpart A — General Provisions • §60.632 Standards (a) - Each owner or operator subject to the provisions of this subpart shall comply with the requirements of § 60.482-1 (a), (b), and (d) and 60.482-2 through 60.482-10, except as provided in § 60.633, as soon as practicable, but no later than 180 days after initial startup. (b) - An owner or operator may elect to comply with the requirements of §60.483-1 and §60.483-2. (d) Each owner or operator subject to the provisions of this subpart shall comply with the provisions of §60.485 except as provided in §60.633(f) of this subpart. 0 0 AIRS ID: 123/0090 Page 18 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division o (e) Each owner or operator subject to the provisions of this subpart shall comply with the provisions of §§60.486 and 60.487 except as provided in §§60.633, 60.635, and 60.636 of this subpart. • §60.633 Exceptions o (a) Each owner or operator subject to the provisions of this subpart may comply with the following exceptions to the provisions of subpart VV. o (b)(1) Each pressure relief device in gas/vapor service may be monitored quarterly and within 5 days after each pressure release to detect leaks by the methods specified in §60.485(b) except as provided in §60.632(c), paragraph (b)(4) of this section, and §60.482-4 (a) through (c) of subpart VV. • (2) If an instrument reading of 10,000 ppm or greater is measured, a leak is detected. • (3)(i) When a leak is detected, it shall be repaired as soon as practicable, but no later than 15 calendar days after it is detected, except as provided in §60.482-9. • (ii) A first attempt at repair shall be made no later than 5 calendar days after each leak is detected. o (c) Sampling connection systems are exempt from the requirements of §60.482-5. • §60.635 Recordkeeping o (a) Each owner or operator subject to the provisions of this subpart shall comply with the requirements of paragraphs (b) and (c) of this section in addition to the requirements of §60.486. o (b) The following recordkeeping requirements shall apply to pressure relief devices subject to the requirements of §60.633(b)(1) of this subpart. • (1) When each leak is detected as specified in §60.633(b)(2), a weatherproof and readily visible identification, marked with the equipment identification number, shall be attached to the leaking equipment. The identification on the pressure relief device may be removed after it has been repaired. • (2) When each leak is detected as specified in §60.633(b)(2), the following information shall be recorded in a log and shall be kept for 2 years in a readily accessible location: • (i) The instrument and operator identification numbers and the equipment identification number. • (ii) The date the leak was detected and the dates of each attempt to repair the leak. • (iii) Repair methods applied in each attempt to repair the leak. • (iv) "Above 10,000 ppm" if the maximum instrument reading measured by the methods specified in paragraph (a) of this section after each repair attempt is 10,000 ppm or greater. • (v) "Repair delayed" and the reason for the delay if a leak is not repaired within 15 calendar days after discovery of the leak. AIRS ID: 123/0090 Page 19 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division • (vi) The signature of the owner or operator (or designate) whose decision it was that repair could not be effected without a process shutdown. • (vii) The expected date of successful repair of the leak if a leak is not repaired within 15 days. • (viii) Dates of process unit shutdowns that occur while the equipment is unrepaired. • (ix) The date of successful repair of the leak. • (x) A list of identification numbers for equipment that are designated for no detectable emissions under the provisions of §60.482-4(a). The designation of equipment subject to the provisions of §60.482-4(a) shall be signed by the owner or operator. • §60.636 Reporting Requirements :> (a) Each owner or operator subject to the provisions of this subpart shall comply with the requirements of paragraphs (b) and (c) of this section in addition to the requirements of §60.487. (b) An owner or operator shall include the following information in the initial semiannual report in addition to the information required in §60.487(b) (1)— (4): Number of pressure relief devices subject to the requirements of §60.633(b) except for those pressure relief devices designated for no detectable emissions under the provisions of §60.482-4(a) and those pressure relief devices complying with §60.482-4(c). (c) An owner or operator shall include the following information in all semiannual reports in addition to the information required in §60.487(c)(2) (i) through (vi): ■ (1) Number of pressure relief devices for which leaks were detected as required in §60.633(b)(2) and ■ (2) Number of pressure relief devices for which leaks were not repaired as required in §60.633(b)(3). Condensate Truck Loadout 38. Point 109: This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III.E) 39. Point 109: The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation Number 3, Part B, III.D.2): a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. AIRS ID: 123/0090 Page 20 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division b. All compartment hatches at the facility (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. The owner or operator shall inspect loading equipment and operations onsite at the time of inspections to monitor compliance with above conditions. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. 40. Point 109: All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. Condensate Storage Tanks 41. Points 110 & 134: 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: • 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. 42. Points 110 & 134: The storage tanks covered by this permit are subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 43. Points 110 & 134: The storage tanks covered under this permit are subject to the recordkeeping requirements in Regulation Number 7, Section XVII.C.3. The owner or operator of each storage tank subject to Sections XII.D. or XVII.C. must maintain records of STEM, if applicable, including the plan, any updates, and the certification, and make them available to the Division upon request. In addition, for a period of two (2) years, the owner or operator must maintain records of any required monitoring and make them available to the Division upon request, including: AIRS ID: 123/0090 Page 21 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division • XVII.C.3.a. The AIRS ID for the storage tank • XVII.C.3.b. The date and duration of any period where the thief hatch, pressure relief device, or other access point are found to be venting hydrocarbon emissions, except for venting that is reasonably required for maintenance, gauging, or safety of personnel and equipment. • XVII.C.3.c. The date and duration of any period where the air pollution control equipment is not operating. • XVII.C.3.d. Where a combustion device is being used, the date and result of any EPA Method 22 test or investigation pursuant to Section XVII.C.1.d.(v). • XVII.C.3.e. The timing of and efforts made to eliminate venting, restore operation of air pollution control equipment, and mitigate visible emissions. • XVII.C.3.f. A list of equipment associated with the storage tank that is designated as unsafe, difficult, or inaccessible to monitor, as described in Section XVII.C.1.e., an explanation stating why the equipment is so designated, and the plan for monitoring such equipment. 44. Point 134: This source is subject to the New Source Performance Standards requirements of Regulation Number 6, Part A, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels for which construction, reconstruction or modification commenced after July 23, 1984, including, but not limited to, the following: • 40 CFR, Part 60, Subpart A — General Provisions • §60.112b - Standard for volatile organic compounds (VOC) o §60.112b(a) The owner or operator of each storage vessel with a....design capacity greater than or equal to 75 m3 but less than 151 m3 containing a VOL that, as stored, has a maximum true vapor pressure equal to or greater than 27.6 kPa but less than 76.6 kPa, shall equip each storage vessel with one of the following: ■ §60.112b(a)(3) A closed vent system and control device meeting the following specifications: • §60.112b(a)(3)(i) The closed vent system shall be designed to collect all VOC vapors and gases discharged from the storage vessel and operated with no detectable emissions as indicated by an instrument reading of less than 500 ppm above background and visual inspections, as determined in part 60, subpart VV, §60.485(b). • §60.112b(a)(3)(ii) The control device shall be designed and operated to reduce inlet VOC emissions by 95 percent or greater. If a flare is used as the control device, it shall meet the specifications described in the general control device requirements (§60.18) of the General Provisions. §60.113b — Testing and procedures AIRS ID: 123/0090 Page 22 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division • The owner or operator of each storage vessel as specified in §60.112b(a) shall meet the requirements of paragraph (a), (b), or (c) of this section. The applicable paragraph for a particular storage vessel depends on the control equipment installed to meet the requirements of §60.112b. • §60.113b(d) The owner or operator of each source that is equipped with a closed vent system and a flare to meet the requirements in §60.112b (a)(3) or (b)(2) shall meet the requirements as specified in the general control device requirements, §60.18 (e) and (f). a §60.115b — Reporting and recordkeeping requirements • §60.115b(d) After installing a closed vent system and flare to comply with §60.112b, the owner or operator shall meet the following requirements. • §60.115b(d)(1) A report containing the measurements required by §60.18(f) (1), (2), (3), (4), (5), and (6) shall be furnished to the Administrator as required by §60.8 of the General Provisions. This report shall be submitted within 6 months of the initial start-up date. • §60.115b(d)(2) Records shall be kept of all periods of operation during which the flare pilot flame is absent. • §60.115b(d)(3) Semiannual reports of all periods recorded under §60.115b(d)(2) in which the pilot flame was absent shall be furnished to the Administrator. o §60.116b — Monitoring of operations • §60.116b(a) The owner or operator shall keep copies of all records required by this section, except for the record required by paragraph (b) of this section, for at least 2 years. The record required by paragraph (b) of this section will be kept for the life of the source. • §60.116b(b) The owner or operator of each storage vessel as specified in §60.110b(a) shall keep readily accessible records showing the dimension of the storage vessel and an analysis showing the capacity of the storage vessel. • §60.116b(g) The owner or operator of each vessel equipped with a closed vent system and control device meeting the specification of §60.112b or with emissions reductions equipment as specified in 40 CFR 65.42(b)(4), (b)(5), (b)(6), or (c) is exempt from the requirements of paragraphs (c) and (d) of this section. Turbines 45. Points 111, 112, 118, 119, 129 & 130: The combustion turbines are subject to the New Source Performance Standards requirements of Regulation Number 6, Part A, Subpart KKKK, Standards of Performance for Stationary Combustion Turbines including, but not limited to, the following: • 40 CFR, Part 60, Subpart A — General Provisions • §60.4320 — Nitrogen Oxide Emissions Limits AIRS ID: 123/0090 Page 23 of 72 DCP Midstream, LP Permit No. 09WE1136 1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division §60.4320 (a) - NO;., emissions shall not exceed 25 ppm at 15% O2 or 1.2 lb/MW- hr: • §60.4330 - Sulfur Dioxide Emissions Limits §60.4330 (a)(1) - SO2 emissions shall not exceed 0.9 lb/MW-hr gross output; or §60.4330 (a)(2) - Operator shall not burn any fuel that contains total potential sulfur emissions in excess of 0.060 lb SO2/MMBtu heat input. • §60.4333 — General Requirements §60.4333 (a) Operator must operate and maintain your stationary combustion turbine, air pollution control equipment, and monitoring equipment in a manner consistent with good air pollution control practices for minimizing emissions at all times including during startup, shutdown and malfunction. • §60.4340 - NOx Monitoring §60.4340 (a) Operator shall perform annual performance tests in accordance with §60.4400 to demonstrate continuous compliance with NOx emissions limits. If the NOx emission result from the performance test is less than or equal to 75 percent of the NOx emission limit for the turbine, you may reduce the frequency of subsequent performance tests to once every 2 years (no more than 26 calendar months following the previous performance test). If the results of any subsequent performance test exceed 75 percent of the NOx emission limit for the turbine, you must resume annual performance tests. • §60.4365 (or §§60.4360 and 60.4370) - SO2 Monitoring The operator shall comply with §60.4365 or with both §§60.4360 and 60.4370 to demonstrate compliance with SO2 emissions limits. • §60.4375 — Reporting §60.4375 (b) - For each affected unit that performs annual performance tests in accordance with §60.4340(a), you must submit a written report of the results of each performance test before the close of business on the 60th day following the completion of the performance test. • §§60.4400 and 60.4415 — Performance Tests o Annual tests must be conducted in accordance with §60.4400(a) and (b). o Unless operator chooses to comply with §60.4365 for exemption of monitoring the total sulfur content of the fuel, then initial and subsequent performance tests for sulfur shall be conducted according to §60.4415. Amine Sweetening Unit 46. Point 120: This amine unit is subject to the New Source Performance Standards requirements of Regulation Number 6, Part A, Subpart LLL, Standards of Performance for Onshore Natural Gas Processing: SO2 Emissions, including, but not limited to, the following: • 40 CFR, Part 60, Subpart A — General Provisions AIRS ID: 123/0090 Page 24 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division • §60.640 — Applicability and Designation of Affected Facilities o §60.640(b) - Facilities that have a design capacity less than 2 long tons per day (LT/D) of hydrogen sulfide (H2S) in the acid gas (expressed as sulfur) are required to comply with §60.647(c) but are not required to comply with §§60.642 through 60.646. • §60.647 — Record keeping and reporting Requirements §60.647(c) - To certify that a facility is exempt from the control requirements of these standards, each owner or operator of a facility with a design capacity less that 2 LT/D of H2S in the acid gas (expressed as sulfur) shall keep, for the life of the facility, an analysis demonstrating that the facility's design capacity is less than 2 LT/D of H2S expressed as sulfur. TEG Glycol Dehydrators 47. Point 122 & 131: These sources are 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.) 48. Points 122, 131, 125, & 137: The open flares covered by under Points 125 and 137 have been approved as an alternative emissions control devices under Regulation Number 7, Section XVII.B.2.e. provided the following conditions are maintained: • The open flare will not be the primary destination for emissions from the still vent or flash tank. • The open flares must 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 open flare, or by other convenient means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Section XVII.B.2.b.) • The open flare will be equipped with an operational auto -igniter upon installation of the combustion device (Regulation 7, Section XVII.B.2.d(i)). 49. Point 122 & 131: This equipment is subject to the control requirements for glycol natural gas dehydrators under Regulation Number 7, Section XVII.D. (State only enforceable). These requirements include, but are not limited to: 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 AIRS ID: 123/0090 Page 25 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division uncontrolled actual emissions of hydrocarbons by at least 95 percent on a rolling twelve-month basis through the use of a condenser or air pollution control equipment. If a combustion device is used, it shall have a design destruction efficiency of at least 98% for hydrocarbons. XVII.D.4. The control requirement in Section XVII.D.3. shall apply where: XVII.D.4.a. Uncontrolled actual emissions of VOCs from a glycol natural gas dehydrator constructed on or after May 1, 2015, are equal to or greater than two (2) tons per year. Such glycol natural gas dehydrators must be in compliance with Section XVII.D.3. by the date that the glycol natural gas dehydrator commences operation. XVII.D.4.b. Uncontrolled actual emissions of VOCs from a single glycol natural gas dehydrator constructed before May 1, 2015, are equal to or greater than six (6) tons per year, or two (2) tons per year if the glycol natural gas dehydrator is located within 1,320 feet of a building unit or designated outside activity area. 50. Point 122 & 131: The glycol dehydration unit at this facility is subject to National Emissions Standards for Hazardous Air Pollutants for Source Categories from Oil and Natural Gas Production Facilities, Subpart HH. This facility shall be subject to applicable area source provisions of this regulation, as stated in 40 C.F.R Part 63, Subpart A and HH including but not limited to the following: (Regulation Number 8, Part E, Subpart A and HH) MACT HH Applicable Requirements Area Source Benzene emissions exemption §63.764 - General Standards §63.764 requirements paragraph records of as required §63.764 the glycol than 0.90 specified (e)(1) - The owner or operator is exempt from the of paragraph (d) of this section if the criteria listed in (e)(1)(i) or (ii) of this section are met, except that the the determination of these criteria must be maintained in §63.774(d)(1). (e)(1)(ii) — The actual average emissions of benzene from dehydration unit process vent to the atmosphere are less megagram per year, as determined by the procedures in §63.772(b);2, of this subpart. AIRS ID: 123/0090 Page 26 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division §63.772 - Test Methods, Compliance Procedures and Compliance Demonstration §63.774 - Recordkeeping Requirements §63.772(b) - Determination of glycol dehydration unit flowrate, benzene emissions, or BTEX emissions. The procedures of this paragraph shall be used by an owner or operator to determine glycol dehydration unit natural gas flowrate, benzene emissions, or BTEX emissions. §63.772(b)(2) - The determination of actual average benzene emissions from a glycol dehydration unit shall be made using the procedures of either paragraph (b)(2)(i) or (b)(2)(ii) of this section. Emissions shall be determined either uncontrolled, or with federally enforceable controls in place. §63.772(b)(2)(i) — The owner or operator shall determine actual average benzene emissions using the model GRI-GLYCalc TM Version 3.0 or higher, and the procedures presented in the associated GRI-GLYCalc 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 the procedures documented in the Gas Research Institute (GRI) report entitled "Atmospheric Rich/Lean Method for Determining Glycol Dehydrator Emissions" (GRI-95/0368.1); or §63.772(b)(2)(ii) - The owner or operator shall determine an average mass rate of benzene emissions in kilograms per hour through direct measurement using the methods in §63.772(a)(1)(i) or (ii), or an alternative method according to §63.7(f). Annual emissions in kilograms per year shall be determined by multiplying the mass rate by the number of hours the unit is operated per year. This result shall be converted to megagrams per year. §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). Heaters 51. Points 121, 123 & 133: These sources are subject to the New Source Performance Standards requirements of Regulation Number 6, Part A Subpart Dc, Standards of Performance for Small Industrial -Commercial -Institutional Steam Generating Units including, but not limited to, the following: AIRS ID: 123/0090 Page 27 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division a. The owner or operator of the facility shall record and maintain records of the amount of fuel combusted during each month (40 CFR Part 60.48c(g)). b. Monthly records of fuel combusted required under the previous condition shall be maintained by the owner or operator of the facility for a period of two years following the date of such record (40 CFR Part 60.48c(i)). Acid Gas Flare 52. Point 136: No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Reference: Regulation Number 1, Section I I .A.5. ) Requirements Covering Multiple Sources 53. Points 118-119, 121, 123, 129-130 & 132-133: These sources are subject to the Particulate Matter and Sulfur Dioxide Emission Regulations of Regulation 1 including, but not limited to, the following (Regulation 1, Section II I.A.1): a No owner or operator shall cause or permit to be emitted into the atmosphere from any fuel -burning equipment, particulate matter in the flue gases which exceeds the following (Regulation 1, Section III.A.1): (1) For fuel burning equipment with designed heat inputs greater than 1x106 BTU per hour, but less than or equal to 500x106 BTU per hour, the following equation will be used to determine the allowable particulate emission limitation. PE=0.5(FI)-°26 Where: PE = Particulate Emission in Pounds per million BTU heat input. Fl = Fuel Input in Million BTU per hour. b. Emissions of sulfur dioxide shall not emit sulfur dioxide in excess of the following combustion turbine limitations. (Heat input rates shall be the manufacturer's guaranteed maximum heat input rates). (1) Points 118-119 & 129-130: Combustion Turbines with a heat input of less than 250 Million BTU per hour: 0.8 pounds of sulfur dioxide per million BTU of heat input. (Regulation 1 Section VI.B.4.c) (2) Points 121, 123, 132, & 133: Limit emissions to not more than two (2) tons per day of sulfur dioxide. (Regulation 1 Section VI.B.5.a.) 54. 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.b. The following requirements were determined to be RACT for this source: AIRS ID: 123/0090 Page 28 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division Facility Equipment ID AIRS Point RACT Pollutants C-211 101 Air -Fuel Ratio Controller and NSCR NOx, VOC C-167 102 Air -Fuel Ratio Controller and NSCR NOx, VOC C-179 103 Air -Fuel Ratio Controller and NSCR NOx, VOC C-130 106 Air -Fuel Ratio Controller and NSCR NOx, VOC F017 108 LDAR as provided at 40 CFR Part 60 Subpart KKK VOC LO 109 Submerged fill, Enclosed Combustor VOC TANKS 110 Enclosed Combustor VOC C0170 111 Natural gas as fuel, low NOx burners, good combustion practices NOx, VOC C0180 112 Natural gas as fuel, low NOx burners, good combustion practices NOx, VOC C250 113 Oxidation Catalyst VOC C251 114 Oxidation Catalyst VOC C252 115 Oxidation Catalyst VOC C253 116 Oxidation Catalyst VOC C254 117 Oxidation Catalyst VOC G1650 118 Natural gas as fuel, low NOx burners, good combustion practices NOx, VOC G1670 119 Natural gas as fuel, low NOx burners, good combustion practices NOx, VOC AM001 120 Still Vent: Thermal Oxidizer (TO). Routed to acid gas flare covered under point 123/0090/136 during TO downtime. VOC Flash Tank: Recycled to plant inlet via VRU. Routed to open flare covered under point 123/0090/125 during 5% VRU downtime. H776 121 Natural gas as fuel, low NOx burners, good combustion practices NOx, VOC D-931 122 Still Vent: Recycled to plant inlet via VRU. Routed to plant flare covered under point 123/0090/125 during 2% VRU downtime. VOC Flash Tank: Recycled to plant inlet via VRU. Routed to plant flare covered under point 123/0090/125 during 2% VRU downtime. H771 123 Natural gas as fuel, low NOx burners, good combustion practices NOx, VOC AIRS ID: 123/0090 Page 29 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division TURB-1 129 Natural gas as fuel, low NOx burners, good combustion practices NOx, VOC TURB-2 130 Natural gas as fuel, low NOx burners, good combustion practices NOx, VOC D-2 131 Still Vent: Recycled to plant inlet via VRU. Routed to plant flare covered under point 123/0090/137 during 2% VRU downtime. VOC Flash Tank: Recycled to plant inlet via VRU. Routed to plant flare covered under point 123/0090/137 during 2% VRU downtime. HT -01 132 Natural gas as fuel, ultra low NOx burners, good combustion practices NOx, VOC HT -02 133 Natural gas as fuel, ultra low NOx burners, good combustion practices NOx, VOC TANKS -2 134 Enclosed Combustor VOC FUG -02 135 LDAR as provided at 40 CFR Part 60 Subpart 0000a VOC 55. Points 118-119, 121, 123, 129-130 & 132-133: These sources are subject to the New Source Performance Standards requirements of Regulation 6, Part B including, but not limited to, the following (Regulation 6, Part B, Section II): a. Standard for Particulate Matter — On and after the date on which the required performance test is completed, no owner or operator subject to the provisions of this regulation may discharge, or cause the discharge into the atmosphere of any particulate matter which is: (1) For fuel burning equipment generating greater than one million but less than 250 million Btu per hour heat input, the following equation will be used to determine the allowable particulate emission limitation: PE=0.5(FI)-°26 Where: PE is the allowable particulate emission in pounds per million Btu heat input. Fl is the fuel input in million Btu per hour. If two or more units connect to any opening, the maximum allowable emission rate shall be the sum of the individual emission rates. (2) Greater than 20 percent opacity. b. Standard for Sulfur Dioxide — On and after the date on which the required performance test is competed, no owner or operator subject to the provisions of this regulation may discharge, or cause the discharge into the atmosphere sulfur dioxide in excess of: (1) Points 118-119 & 129-130: Sources with a heat input of less than 250 million Btu per hour: 0.8 lbs. SO2/million Btu. 56. Points 108, 111, 112, 118, 119, 120, 121, 123, 125, 129, 130, & 133-137: These sources are subject to the requirements of Regulation Number 6. Part A, Subpart A, General Provisions, including, but not limited to, the following: AIRS ID: 123/0090 Page 30 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division a. At all times, including periods of start-up, shutdown, and malfunction, the facility and control equipment shall, to the extent practicable, be maintained and operated in a manner consistent with good air pollution control practices for minimizing emissions. Determination of whether or not acceptable operating and maintenance procedures are being used will be based on information available to the Division, which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. (Reference: Regulation 6, Part A. General Provisions from 40 CFR 60.11(d)) b. No article, machine, equipment or process shall be used to conceal an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gases discharged to the atmosphere. (§60.12) c. Written notification of construction and initial startup dates shall be submitted to the Division as required under §60.7. d. Records of startups, shutdowns, and malfunctions shall be maintained, as required under §60.7. e. Written notification of opacity observation or monitor demonstrations shall be submitted to the Division as required under § 60.7. f. Excess Emission and Monitoring System Performance Reports shall be submitted as required under § 60.7. g. Performance tests shall be conducted as required under §60.8. h. Compliance with opacity standards shall be demonstrated according to § 60.11. i. The flare shall be designed and operated, and records and reports shall be furnished, as required under § 60.18. 57. Points 101-103, 106, 111-119, 121, 129, 130, & 133: This source is subject to Regulation Number 7, Section XVI.D. The operator shall comply with all applicable requirements of Section XVI including but not limited to: • XVI.D.1. As of January 1, 2017, this Section XVI.D. applies to the following combustion equipment with uncontrolled actual emissions of NOx equal to or greater than five (5) tons per year, and that are located at existing major sources of NOx, as listed in Section XIX.A. • XVI.D.2. Combustion process adjustment o XVI.D.2.a. When burning the fuel that provides the majority of the heat input since the last combustion process adjustment and when operating at a firing rate typical of normal operation, the owner or operator must conduct the AIRS ID: 123/0090 Page 31 of 72 DCP Midstream, LP Permit No. 09W E 1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division following inspections and adjustments of boilers and process heaters, as applicable: • XVI.D.2.a.(i) Inspect the burner and combustion controls and clean or replace components as necessary. • XVI.D.2.a.(ii) Inspect the flame pattern and adjust the burner or combustion controls as necessary to optimize the flame pattern. • XVI.D.2.a.(iii) Inspect the system controlling the air -to -fuel ratio and ensure that it is correctly calibrated and functioning properly. • XVI.D.2.a.(iv) Measure the concentration in the effluent stream of carbon monoxide and nitrogen oxide in ppm, by volume, before and after the adjustments in Sections XVI.D.2.a.(i)-(iii). Measurements may be taken using a portable analyzer. XVI.D.2.c. The owner or operator of a stationary combustion turbine must conduct the following inspections and adjustments, as applicable: • XVI.D.2.c.(i) Inspect turbine inlet systems and align, repair, or replace components as necessary. • XVI.D.2.c.(ii) Inspect the combustion chamber components, combustion liners, transition pieces, and fuel nozzle assemblies and clean, repair, or replace components as necessary. • XVI.D.2.c.(iii) When burning the fuel that provides the majority of the heat input since the last combustion process adjustment and when operating at a firing rate typical of normal operation, confirm proper setting and calibration of the combustion controls. XVI.D.2.d. The owner or operator of a stationary internal combustion engine must conduct the following inspections and adjustments, as applicable: ■ XVI.D.2.d.(i) Change oil and filters as necessary. • XVI.D.2.d.(ii) Inspect air cleaners, fuel filters, hoses, and belts and clean or replace as necessary. ■ XVI.D.2.d.(iii) Inspect spark plugs and replace as necessary. XVI.D.2.e. The owner or operator must operate and maintain the boiler, duct burner, process heater, stationary combustion turbine, or stationary internal combustion engine consistent with manufacturer's specifications, if available. or good engineering and maintenance practices. XVI.D.2.f. Frequency AIRS ID: 123/0090 Page 32 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division • XVI.D.2.f.(i) The owner or operator must conduct the initial combustion process adjustment by April 1, 2017. An owner or operator may rely on a combustion process adjustment conducted in accordance with applicable requirements and schedule of a New Source Performance Standard in 40 CFR Part 60 or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 to satisfy the requirement to conduct an initial combustion process adjustment by April 1, 2017. • XVI.D.2.f.(ii) The owner or operator must conduct subsequent combustion process adjustments at least once every twelve (12) months after the initial combustion adjustment, or on the applicable schedule according to Sections XVI.D.4.a. or XVI.D.4.b. • XVI.D.3. Recordkeeping o XVI.D.3.a. The owner or operator must create a report once every calendar year identifying the combustion equipment at the facility subject to Section XVI.D. and including for each combustion equipment: O ■ XVI.D.3.a.(i) The date of the adjustment; • XVI.D.3.a.(ii) Whether the combustion process adjustment under Sections XVI.D.2.a.-e. was followed, and what procedures were performed; • XVI.D.3.a.(iii) Whether a combustion process adjustment under XVI.D.4.a.-b.. was followed, what procedures were performed, and what New Source Performance Standard or National Emission Standard for Hazardous Air Pollutants applied, if any; and ■ XVI.D.3.a.(iv) A description of any corrective action taken. • XVI.D.3.a.(v) If the owner or operator conducts the combustion process adjustment according to the manufacturer recommended procedures and schedule and the manufacturer specifies a combustion process adjustment on an operation time schedule, the hours of operation. • XVI.D.3.a.(vi) If multiple fuels are used, the type of fuel burned and heat input provided by each fuel. XVI.D.3.b. The owner or operator must retain manufacturer recommended procedures, specifications, and maintenance schedule if utilized under Section XVI.D.4.a. for the life of the equipment, and make available to the Division upon request. o XVI.D.3.c. The owner or operator must retain annual reports for at least 5 years, and make available to the Division upon request. AIRS ID: 123/0090 Page 33 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division • XVI.D.4. As an alternative to the requirements described in Sections XVI.D.2.a.-e. and XVI.D.3.a.: XVI.D.4.a. The owner or operator may conduct the combustion process adjustment according to the manufacturer recommended procedures and schedule; or XVI.D.4.b. The owner or operator of combustion equipment that is subject to and required to conduct a period tune-up or combustion adjustment by the applicable requirements of a New Source Performance Standard in 40 CFR Part 60 or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 may conduct tune-ups or adjustments according to the schedule and procedures of the applicable requirements of 40 CFR Part 60 or 40 CFR Part 63. XVI.D.4.c. The owner or operator may comply with applicable recordkeeping requirements related to combustion process adjustments conducted according to a New Source Performance Standard in 40 CFR Part 60 or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63. 58. This source is subject to Regulation Number 7 Section XIX. The operator shall comply with all applicable requirements of Section XIX including but not limited to: • XIX.C. Stationary combustion turbines at the following major sources must comply with the applicable NOx emission limits and associated monitoring, recordkeeping, and reporting requirements in either 40 CFR Part 60, Subpart GG (July 1, 2016) or 40 CFR Part 60, Subpart KKKK (July 1, 2016) as expeditiously as practicable, but no later than January 1, 2017: XIX.C.1. DCP Midstream, Kersey/Mewbourn (123-0090) — turbines (pt 111, 112, 118). • XIX.D. Stationary internal combustion engines at the following major sources must comply with applicable NOx emission limits and associated monitoring, recordkeeping, and reporting requirements in 40 CFR Part 60, Subpart 1111 (July 1, 2016), 40 CFR Part 60, Subpart JJJJ (July 1, 2016), and/or 40 CFR Part 63, Subpart ZZZZ (July 1, 2016) as expeditiously as practicable, but no later than January 1, 2017: XIX.D.4. DCP Midstream. Kersey/Mewbourn (123-0090) — engine (pt 101). OPERATING & MAINTENANCE REQUIREMENTS 59. Points 101-103, 106, 109, 110, 113-117, 120, 122, 131, & 134: Upon startup of these points, the applicant shall follow the operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation Number 3, Part B, Section III.G.7.) AIRS ID: 123/0090 Page 34 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division 60. Point 109: The owner or operator of a loadout at which an enclosed combustor is used to control emissions shall: a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks and route these vapors to the enclosed flare. b. Include devices to prevent the release of vapor from vapor recovery hoses not in use. c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. d. Operate all recovery and disposal equipment at a back pressure less than the pressure relief valve setting of transport vehicles. e. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers shall be weighted and properly seated. f. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs shall be set to release at a pressure that will ensure flashing, working and breathing losses are routed to the control device under normal operating conditions. 9. Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 61. Point 120: Within one hundred and eighty days (180) of the latter of commencement of operation of the thermal oxidizer as the primary control device or issuance of this permit, the owner or operator shall complete the initial annual extended sour gas analysis testing required by this permit. The owner or operator shall use this sour gas analysis to calculate actual emissions, as prescribed in the Emission Limitations and Records section of this permit, to verify initial compliance with the emission limits. The owner or operator shall submit the analysis and the emission calculation results to the Division as part of the self - certification process. 62. Point 120: Within one hundred and eighty days (180) of the latter of commencement of operation of the thermal oxidizer as the primary control device or issuance of this permit, the operator shall complete an initial sample of the inlet gas to the plant to determine the concentration of hydrogen sulfide (H2S) in the gas stream. The owner or operator shall use the sample results to calculate actual emissions, as prescribed in the Emission Limitations and Records section of this permit, to verify initial compliance with the emission limits. The sample results shall also be monitored to demonstrate that this amine unit qualifies for the exemption from the Standards of Performance for Onshore Natural Gas Processing: SO2 Emissions (§60.640(b)). The owner or operator shall submit the analysis and the emission calculation results to the Division as part of the self -certification process. AIRS ID: 123/0090 Page 35 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division 63. Point 120: Upon commencement of operation of the thermal oxidizer as the primary control device for the amine unit still vent a source initial compliance test shall be conducted on this emissions point to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emissions limits in this permit. The operator shall also demonstrate the thermal oxidizer achieves a minimum destruction efficiency of 96.7% for VOC. The operator shall measure and record, using EPA approved methods, VOC mass emission rates at the thermal oxidizer inlet and outlet to determine the destruction and removal efficiency of the thermal oxidizer (process models shall not be used to determine the flow rate or composition of waste gas (acid gas stream from the still vent) sent to the thermal oxidizer for the purposes of this test). The natural gas throughput, lean amine recirculation rate, MDEA concentration, sulfur content of the sour gas entering the amine unit, and thermal oxidizer combustion chamber temperature shall be monitored and recorded during this test. This test shall be run with the thermal oxidizer operating at the minimum combustion chamber temperature of 1,400°F as indicated in the O&M plan for this point. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time (Reference: Regulation Number 3, Part B., Section III.G.3) Sulfur Dioxide using EPA approved methods. Oxides of Nitrogen using EPA approved methods. Volatile Organic Compounds using EPA approved methods. Carbon Monoxide using EPA approved methods. 64. Points 129 & 130: These turbines are subject to the initial testing requirements of 40 C.F.R. Part 60, Subpart KKKK, as referenced in this permit. 65. Points 129 & 130: A source initial compliance test shall be conducted on each of the combustion turbines to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emissions limits contained in this permit. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time (Reference: Regulation Number 3, Part B., Section III.G.3) Carbon Monoxide using EPA approved methods. This test may be conducted concurrently with the initial testing required by 40 C.F.R. Part 60, Subpart KKKK. 66. Point 131: The owner or operator shall complete the initial extended wet gas analysis within one hundred and eighty days (180) of the latter of commencement of operation or AIRS ID: 123/0090 Page 36 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division issuance of this permit. The owner or operator shall use this analysis to calculate actual emissions, as prescribed in the Emission Limitation and Records section of this permit, to verify initial compliance with the emission limits. The owner or operator shall submit the analysis and the emission calculation results to the Division as part of the self -certification process. (Reference: Regulation Number 3, Part B, Section III.E.) 67. Point 133: A source initial compliance test shall be conducted on this heater to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emissions limits contained in this permit. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time (Reference: Regulation Number 3, Part B., Section III.G.3) Oxides of Nitrogen using EPA approved methods. Carbon Monoxide using EPA approved methods. 68. Point 135: Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, the owner or operator shall complete the initial extended gas analysis of gas samples that are representative of volatile organic compound (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas analysis shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. The operator shall submit the results of the extended gas analysis and emission calculations to the Division as part of the self -certification process to ensure compliance with emissions limits. 69. Point 135: Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, the operator shall complete a hard count of components at the source and establish the number of components that are operated in "heavy liquid service", "light liquid service", "water/oil service" and "gas service". The operator shall submit the results to the Division as part of the self -certification process to ensure compliance with emissions limits. Periodic Testing Requirements 70. Point 108 & 135: On an annual basis, the owner or operator shall complete an extended gas analysis of gas samples that are representative of volatile organic compounds (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas analysis shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. 71. Point 111, 112, 118, 119, 129 & 130: These turbines are subject to the periodic testing requirements of 40 C.F.R. Part 60, Subpart KKKK, as referenced in this permit. 72. Point 111, 112, 118, 119, 129 & 130: The operator shall conduct, at a minimum, quarterly portable analyzer monitoring of the turbine exhaust outlet emissions of nitrogen oxides (NOX) and carbon monoxide (CO) to monitor compliance with the emissions AIRS ID: 123/0090 Page 37 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division limits. Results of all tests conducted shall be kept on site and made available to the Division upon request. 73. Point 120 & 136: The operator shall sample the inlet gas to the plant on an annual basis to determine the concentration of hydrogen sulfide (H2S) in the gas stream. The sample results shall be monitored to demonstrate that this amine unit qualifies for the exemption from the Standards of Performance for Onshore Natural Gas Processing: SO2 Emissions (§60.640(b)). The testing required by Condition 74 may be used for this demonstration. 74. Point 120 &136: The owner or operator shall complete an extended sour gas analysis prior to the inlet of the amine unit on an annual basis. Results of the sour gas analysis shall be used to calculate emissions of criteria pollutants and hazardous air pollutants as prescribed in the Emission Limitation and Records section of this permit. 75. Point 122 & 131: The owner or operator shall complete an extended wet gas analysis prior to the inlet of the TEG dehydrator on an annual basis. Results of the wet gas analysis shall be used to calculate emissions of criteria pollutants and hazardous air pollutants per this permit. 76. Point 125: On an annual basis, the operator shall complete a site specific extended gas analysis of the natural gas routed to this emissions unit in order to verify the VOC content (weight fraction) of this emission stream and using volume from the flare meter along with a 95% DRE to demonstrate compliance with emission limits. Results of testing shall be used to calculate site -specific emission factors for the pollutants referenced above (in units of TPY permit limit) using Division approved methods. Emission factors established through this periodic testing shall be less than or equal to, the emissions factors established in the permit application and `Notes to Permit Holder- for this emissions point. If the site specific emissions factor developed through this sampling and analysis is greater than the emissions factor established in the permit application and "Notes to Permit Holder" the operator shall submit to the Division within 60 days, a request for permit modification to update emissions factors and emissions limits specified in this permit. The owner or operator shall continue to use the emissions factors established in the permit application and "Notes to Permit Holder- to calculate actual emissions and demonstrate compliance with the emissions limits specified in this permit unless a modification is submitted to the Division. Records of site -specific sampling and emissions factor analysis shall be recorded and maintained by the operator and made available to the Division for inspection upon request. 77. Point 136: On an annual basis, the owner/operator shall complete a site specific extended gas analysis ("Analysis") of the assist gas and purge gas routed to this emission unit order to verify the VOC and n -Hexane content (weight fraction) of this emission stream. Results of the Analysis shall be used to calculate site -specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF) using Division approved methods. Results of the Analysis shall be submitted to the Division as part of the self - certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the AIRS ID: 123/0090 Page 38 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). ADDITIONAL REQUIREMENTS 78. All previous versions of this permit are cancelled upon issuance of this permit except as provided by condition 80 in this permit. 79. The operator shall have 15 days after commencement of operation of the associated natural gas processing train to cancel the following points and permanently remove them from service. Removal of this equipment is required to maintain synthetic minor modification status per Regulation 3 Part D: Existing Permit Number Existing Emission Point New Emission Point 09WE1136 123/0090/102 Engine is cancelled upon startup of new Mewbourn III Natural Gas Processing Train 09WE1136 123/0090/103 Engine is cancelled upon startup of new Mewbourn III Natural Gas Processing Train 09WE1136 123/0090/106 Engine is cancelled upon startup of new Mewbourn III Natural Gas Processing Train 80. The owner or operator shall operate AIRS Points 120, 122 and 127 as authorized by permit 09WE1136 Issuance 3 (dated October 21, 2016) until the startup of the two (2) electric powered vapor recovery units (VRUs) that will be utilized to recycle the still vent emissions from AIRS point 122 and the flare covered under point 136 (As authorized by this issuance of permit 09WE1136, Issuance 4) that will be used to control amine unit still vent emissions during thermal oxidizer (TO) downtime. The startup of the electric powered vapor recovery units and flare (point 136) shall occur no later than 365 days after issuance of this permit. The owner or operator shall submit a cancellation notice for AIRS Point 127 within 15 days of startup of the electric powered vapor recovery units and flare (point 136). 81. The owner or operator shall not operate the turbine covered under AIRS Point 119 as authorized by permit 09WE1136 Issuance 4 (this Issuance) until the startup of the Mewbourn III natural gas processing train. 82. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: 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 reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in ozone nonattainment areas emitting less than 100 tons of VOC or NO„ per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or AIRS ID: 123/0090 Page 39 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine or turbine under the alternative operating scenario outlined in this permit as Attachment A or B. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine or turbine, the appropriate APEN filing fee and a cover letter explaining that the owner or operator is exercising an alternative -operating scenario and is installing a permanent replacement engine or turbine. Submittal of an updated APEN is also required for replacement of components if such replacement results in a change of serial number. 83. Minimum stack heights are required for the following points: Facility ID AIRS Point Minimum stack height (ft) 123/0090 101 16.48 102 40.00 103 40.00 106 27.98 111 35.80 112 35.80 113 45.00 114 45.00 115 45.00 116 45.00 117 45.00 118 45.00 121 20.00 123 20.00 Emergency Flare 75.00 84. This source is subject to the provisions of Regulation Number 3, Part C, Operating Permits (Title V of the 1990 Federal Clean Air Act Amendments). The provisions of this construction permit must be incorporated into the operating permit. The application for the modification to the Operating Permit is due within one year from permit issuance. AIRS ID: 123/0090 Page 40 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division 85. Points 118, 119, 129 & 130: MACT Subpart YYYY - National Emission Standards for Hazardous Air Pollutants for Stationary Combustion Turbines requirements shall apply to this source at any such time that this source becomes a major source of hazardous air pollutants (HAP) solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of that Subpart on the date as stated in the rule as published in the Federal Register. (Reference: Regulation Number 8, Part E) 86. Point 122, 131, & 135: MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities major stationary source requirements shall apply to this stationary source at any such time that this stationary source becomes major solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of Subpart HH. (Reference: Regulation Number 8, Part E) 87. Points 121, 123, 132 & 133: MACT Subpart DDDDD - National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters requirements shall apply to this source at any such time that this source becomes a major source of hazardous air pollutants (HAP) solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of that Subpart on the date as stated in the rule as published in the Federal Register. (Reference: Regulation Number 8, Part E) 88. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, VI.B.4/V.A.7.B). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels. Increases in permit limits for any of these emissions units will require evaluation of the original project net emissions increase to ensure the significant modification thresholds are not exceeded: Facility Equipment ID AIRS Point Equipment Description Pollutant Emissions - tons per year Threshold Current Limit LO 109 Condensate Loadout NOx VOC 40 40 30.2 23.39 TANKS 110 Condensate Tank G1650 118 Combustion Turbines G1670 119 AM001 120 Amine Unit AIRS ID: 123/0090 Page 41 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division D-931 122 TEG Dehydrator TURB-1 129 Combustion Turbines TURB-2 130 D-2 131 TEG Dehydrator HT -01 132 Regeneration Heater HT -02 133 Hot Oil Heater TANKS -2 134 Condensate Tank F-2 136 Acid Gas Flare F-3 137 Open Flare GENERAL TERMS AND CONDITIONS: 89. 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. 90. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 91. 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. 92. 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. AIRS ID: 123/0090 Page 42 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division 93. Each and every condition of this permit is a material pad hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 94. 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. 95. 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 Histor Issuance Date Description Issuance 4 This Issue to DCP Operating Company, LP Issuance Company name change application was received by the Division on May 25, 2017. Cancel points 102, 103, 106 upon startup of new Mewbourn III Natural Gas Processing Train. Point 109: Increase permitted throughput from 476,190 bbl/year to 912,500 bbl/year. Point 110: Increase permitted throughput from 476,190 bbl/year to 912,500 bbl/year. Update emissions factors. Point 118: Split two turbines covered under this point into two separate points. Include separate process and emission limits for points 118 and 119. Point 119: Increase operating hours to 8,760 hours per year. Point 120: Change control scenario for still vent. Still vent is now controlled primarily by a thermal oxidizer (TO). During TO downtime still vent emissions are routed to a flare (point 136). Still AIRS ID: 123/0090 Page 43 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division vent emissions are no longer vented to atmosphere. Point 122: Utilize GlyCalc to estimate emissions. Update control scenario so both flash tank and still vent emissions are recycled to the plant inlet by a VRU or controlled by an open flare (point 125) during VRU downtime (max 2% annually). Addition of points 129-137 for Mewbourn III expansion project. Issuance 3 October 21, 2016 Removal of Points 104, 105 and 107. Combining Points 118 and 119 under one AIRS ID (Point 118). Point 108: Increase permit limits from 31.7 TPY to 50.8 TPY. Point 120: Additional process to equipment downtime for RTO. The RTO to control Point 120 only. Point 122: Addition of its own control device (Point 125). No change in emissions. Addition of points 125 and 127. Removing Point 124 from permit because emissions from this point have been distributed among individual emission sources. Issuance 2 June 28, 2012 Modification to 13 points: 104-107: Increase permit limits to reflect 0.5g/hp-hr VOC and 1.5g/hp-hr CO. 113-117: Increase permit limits to reflect 0.7g/hp-hr VOC default factor from Regulation 7. 120: update emissions to reflect change in destruction efficiency of Thermal Oxidizer from 99% to 96.7%. Add H2S limit. 122: update emissions to reflect change in destruction efficiency of Thermal Oxidizer from 99% to 96.7% 123: update to allow a second/backup heater to be used during downtime. 124: update destruction efficiency to 96.7% from 99%. Increase SOx limit. Issuance 1 June 21, 2011 Modification to 5 source points: Point 109 (condensate loadout): decrease in permit limit and change of control device from a condenser to a combustor with 95% control efficiency; Point 110 (condensate tank battery): decrease in permit limit and change of control device from a condenser to a combustor with 95% control efficiency; Point 120 (amine sweetening unit): increase processing rate from 125 mmscfd to 160 mmscfd and increase amine recirculation rate gpm 540 gpm to 640 gpm; Point 122 (TEG dehydrator): increasing the lean glycol recirculation rate from 26.8 gpm to 34.9 gpm, re-routing the flash tank from the RTO to the existing VRU unit, and raising the flash tank temperature from 110°F to 190rF; and Point 124 (thermal oxidizer): increase in NOx and CO permit limits and adding SOx emissions. Initial Approval December 29, 2009 Initial Approval. Synthetic Minor Modification of a Major Source. Public comment conducted to render the permit and permit conditions federally enforceable. Issued to DCP Midstream, LP. AIRS ID: 123/0090 Page 44 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division Upon startup under this permit, all previously issued permits for this facility will be canceled. AIRS ID: 123/0090 Page 45 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 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://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emission Rate (Ib/yr) Are the emissions reportable? Controlled Emission Rate (lb/yr) 101 Formaldehyde 50000 467 Yes 112 Acetaldehyde 75070 64 No 32 Acrolein 107028 60 No 30 Ethylbenzene 100414 1 No 0 Xylenes 1330207 4 No 2 Benzene 71432 36 No 18 Toluene 108883 13 No 6 102 Formaldehyde 50000 2,308 Yes 553 Acetaldehyde 75070 314 Yes 157 Acrolein 107028 296 Yes 148 Ethylbenzene 100414 3 No 1 Xylenes 1330207 22 No 11 Benzene 71432 178 No 89 Toluene 108883 63 No 31 103 Formaldehyde 50000 2,077 Yes 498 Acetaldehyde 75070 283 Yes 141 AIRS ID: 123/0090 Page 46 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division Acrolein 107028 266 Yes 133 Ethylbenzene 100414 3 No 1 Xylenes 1330207 20 No 10 Benzene 71432 160 No 80 Toluene 108883 57 No 28 106 Formaldehyde 50000 1,023 Yes 143 Acetaldehyde 75070 139 No 70 Acrolein 107028 131 No 66 Ethylbenzene 100414 1 No 0 Xylenes 1330207 10 No 5 Benzene 71432 79 No 39 Toluene 108883 28 No 14 108 Benzene 71432 786 Yes 248 Toluene 108883 616 Yes 194 Ethylbenzene 100414 14 No 5 Xylenes 1330207 108 No 34 n -hexane 110543 3,498 Yes 1,102 109 Benzene 71432 2,454 Yes 123 Toluene 108883 6,800 Yes 340 Ethylbenzene 100414 507 Yes 26 Xylenes 1330207 5,140 Yes 257 n -Hexane 110543 13,203 Yes 661 2,2,4-TMP 540841 10 No 1 110 Benzene 71432 1,005 Yes 51 Toulene 108883 2,784 Yes 140 Ethylbenzene 100414 208 No 11 Xylenes 1330207 2,105 Yes 106 n -Hexane 110543 5,406 Yes 271 2,2,4-TMP 540841 4 No 1 111 and 112 each Formaldehyde 50000 312 Yes 312 Acetaldehyde 75070 18 No 18 Acrolein 107028 3 No 3 AIRS ID: 123/0090 Page 47 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division Benzene 71432 5 No 5 Toulene 108883 57 No 57 Ethylbenzene 100414 18 No 18 Xylenes 1330207 28 No 28 113- 117 total ' Formaldehyde 50000 73,200 Yes 7,360 Acetaldehyde 75070 5,200 Yes 2,600 Acrolein 107028 3,200 Yes 1,600 Benzene 71432 240 No 120 118 Formaldehyde 50000 383 Yes 383 Acetaldehyde 75070 22 No 22 Acrolein 107028 4 No 4 Benzene 71432 7 No 7 1,3 -Butadiene 106990 1 No 1 Ethylbenzene 100414 18 No 18 Toluene 108883 71 No 71 Xylenes 1330207 35 No 35 119 Formaldehyde 50000 383 Yes 383 Acetaldehyde 75070 22 No 22 Acrolein 107028 4 No 4 Benzene 71432 7 No 7 1,3 -Butadiene 106990 1 No 1 Ethylbenzene 100414 18 No 18 Toluene 108883 71 No 71 Xylenes 1330207 35 No 35 120 Benzene 71432 164,641 Yes 5,201 Toluene 108883 127,227 Yes 4,051 Ethylbenzene 100414 2,451 Yes 78 Xylenes 1330207 25,859 Yes 832 n -Hexane 110543 4,406 Yes 29 2,2.4-TMP 540841 19 No 1 Hydrogen Sulfide 7783064 34,591 Yes 1,139 Methanol 67561 25,733 Yes 849 AIRS ID: 123/0090 Page 48 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division Methyl Mercaptan (MeSH) 74931 1,820 Yes 53 121 Benzene 71432 1 No 1 Toulene 108883 2 No 2 Formaldehyde 50000 41 No 41 n -Hexane 110543 975 Yes 975 122 Benzene 71432 136,415 Yes 137 Toluene 108883 129,275 Yes 130 Ethylbenzene 100414 2,475 Yes 3 Xylenes 1330207 43,242 Yes 44 n -Hexane 110543 17,785 Yes 18 2,2,4-TMP 540841 32 No 1 Hydrogen Sulfide 7783064 361 Yes 1 123 Benzene 71432 1 No 1 Toulene 108883 1 No 1 Formaldehyde 50000 16 No 16 n -Hexane 110543 390 Yes 390 125 Benzene 71432 152 No 8 Toulene 108883 119 No 7 Ethylbenzene 100414 3 No 0 Xylenes 1330207 21 No 1 n -Hexane 110543 677 Yes 42 127 Benzene 71432 43,633 Yes 1,362 Toulene 108883 40,097 Yes 1,276 Ethylbenzene 100414 721 Yes 23 Xylenes 1330207 9,083 Yes 293 n -Hexane 110543 5,706 Yes 100 Methanol 67561 29,389 Yes 947 Formaldehyde 50000 453 Yes 453 129 Acetaldehyde 75070 26 No 26 Acrolein 107028 4 No 4 Benzene 71432 8 No 8 AIRS ID: 123/0090 Page 49 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division 1,3 -Butadiene 106990 1 No 1 Ethylbenzene 100414 21 No 21 Toluene 108883 83 No 83 Xylenes 1330207 41 No 41 130 Formaldehyde 50000 453 Yes 453 Acetaldehyde 75070 26 No 26 Acrolein 107028 4 No 4 Benzene 71432 8 No 8 1,3 -Butadiene 106990 1 No 1 Ethylbenzene 100414 21 No 21 Toluene 108883 83 No 83 Xylenes 1330207 41 No 41 131 Benzene 71432 6,011 Yes 301 Toluene 108883 5,745 Yes 288 n -Hexane 110543 2,232 Yes 112 Hydrogen Sulfide 7783064 2 No 1 132 Formaldehyde 50000 6 No 6 Benzene 71432 1 No 1 Toluene 108883 1 No 1 n -Hexane 110543 145 No 145 133 Formaldehyde 50000 26 No 26 Benzene 71432 1 No 1 Toluene 108883 2 No 2 n -Hexane 110543 613 Yes 613 134 Benzene 71432 978 Yes 49 Toluene 108883 2,709 Yes 136 Ethylbenzene 100414 202 No 10 Xylene 1330207 2,047 Yes 103 n -Hexane 110543 5,259 Yes 263 2,2,4-TMP 540841 4 No 1 135 Benzene 71432 785 Yes 126 Toluene 108883 1,117 Yes 178 AIRS ID: 123/0090 Page 50 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division Ethylbenzene 100414 124 No 20 Xylene 1330207 369 Yes 59 n -Hexane 110543 17,080 Yes 2,725 2,2,4-TMP 540841 755 Yes 121 136 Benzene 71432 5,592 Yes 280 Toluene 108883 4,359 Yes 218 Ethylbenzene 100414 84 No 5 Xylenes 1330207 896 Yes 45 n -Hexane 110543 1,939 Yes 99 Hydrogen Sulfide 7783064 1,229 Yes 62 Methanol 67561 916 Yes 46 Methyl Mercaptan (MeSH) 74931 57 No 3 137 Benzene 71432 77 No 4 Toluene 108883 60 No 3 Ethylbenzene 100414 2 No 0 Xylenes 1330207 11 No 1 n -Hexane 110543 1,806 Yes 94 2,2,4-TMP 540841 4 No 1 Hydrogen Sulfide 7783064 2 No 0 Methanol 67561 1 No 0 Methyl Mercaptan (MeSH) 74931 2 No 0 5) The emission levels contained in this permit are based on the following emission factors: Point 101: Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer Manufacturer + AFR and NSCR CO Manufacturer Manufacturer + AFR and NSCR VOC Manufacturer Manufacturer + AFR and NSCR 50000 Formaldehyde 21.525 lb/mmscf (APEN) APEN + AFR and NSCR 75070 Acetaldehyde 2.9295 lb/mmscf (APEN) APEN + AFR and NSCR 107028 Acrolein 2.7615 lb/mmscf (APEN) APEN + AFR and NSCR 71432 Benzene 1.6590 lb/mmscf (APEN) APEN + AFR and NSCR AIRS ID: 123/0090 Page 51 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division Point 102: CAS Pollutant Emission Factors - Uncontrolled Uncontrolled EF Source Emission Factors — Controlled Controlled EF Source NOx 1.6 g/hp-hr Manufacturer 0.16 g/hp-hr Manufacturer + 90% control CO 1.6 g/hp-hr Manufacturer 0.32 g/hp-hr Manufacturer + 80% control VOC 1.0 g/hp-hr Manufacturer 0.5 g/hp-hr Manufacturer + 50% control 50000 Formaldehyde 0.0205 Ib/mmbtu AP -42 0.0103 Ib/mmbtu AP -42 + 50% control 75070 Acetaldehyde 0.0028 Ib/mmbtu AP -42 0.0014 Ib/mmbtu AP -42 + 50% control 107028 Acrolein 0.0026 Ib/mmbtu AP -42 0.0013 Ib/mmbtu AP -42 + 50% control 71432 Benzene 0.0016 Ib/mmbtu AP -42 0.0008 Ib/mmbtu AP -42 + 50% control Emission factors are based on manufacturer specifications and AP -42. Point 103: CAS Pollutant Emission Factors - Uncontrolled Uncontrolled EF Source Emission Factors — Controlled Controlled EF Source NOx 11.0 g/hp-hr Manufacturer 1.496 g/hp-hr Manufacturer + 86.4% control CO 8.0 g/hp-hr Manufacturer 1.504 g/hp-hr Manufacturer + 81.2% control VOC 1.5 g/hp-hr Manufacturer 0.4995 g/hp-hr Manufacturer + 66.7% control 50000 Formaldehyde 0.0205 Ib/mmbtu AP -42 0.0049 Ib/mmbtu AP -42 + 76% control 75070 Acetaldehyde 0.0028 Ib/mmbtu AP -42 0.0014 lb/mmbtu AP -42 + 50% control 107028 Acrolein 0.0026 Ib/mmbtu AP -42 0.0013 lb/mmbtu AP -42 + 50% control 71432 Benzene 0.0016 Ib/mmbtu AP 42 0.0008 lb/mmbtu AP -42 + 50% control Emission factors are based on manufacturer specifications and AP -42. Point 106: CAS Pollutant Emission Factors - Uncontrolled Uncontrolled EF Source Emission Factors — Controlled Controlled EF Source NOx 11.0 g/hp-hr Manufacturer 0.5 g/hp-hr Manufacturer + 95.5% control CO 8.0 g/hp-hr Manufacturer 1.5 g/hp-hr Manufacturer + 81.25% control VOC 1.5 g/hp-hr Manufacturer 0.5 g/hp-hr Manufacturer + 66% control 50000 0.0205 Ib/mmbtu AP -42 0.0029 Ib/mmbtu AP -42 + 86% control Formaldehyde AIRS ID: 123/0090 Page 52 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division CAS Pollutant Emission Factors - Uncontrolled Uncontrolled EF Source Emission Factors — Controlled Controlled EF Source 75070 Acetaldehyde 0.0028 lb/mmbtu AP -42 0.0014 Ib/mmbtu AP -42 + 50% control 107028 Acrolein 0.0026 lb/mmbtu AP -42 0.0013 lb/mmbtu AP -42 + 50% control 71432 Benzene 0.0016 lb/mmbtu AP -42 0.0008 lb/mmbtu AP -42 + 50% control Emission factors are based on manufacturer specifications and AP -42. Point 108: Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 7912 --- 5971 --- Flanges 3890 --- 2133 --- Open-ended Lines 2 --- 0 --- Pump Seals 21 --- 41 --- Valves 4017 --- 2861 --- Other* 166 --- 108 --- VOC Content 'wt /) 21.504 --- 100 --- Benzene Content (wt%, 0.052 --- 0.2438 --- Toluene Content (wt%) 0.041 --- 0.1911 - - Ethylbenzene Content (%) 0.001 --- 0.0044 --- Xylenes Content (%) 0.007 --- 0.0334 --- n -hexane Content (%) 0.233 --- 1.0849 --- *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms, hatches, instrument meters, polish rods and vents TOC Emission Factors (kg/hr-component): Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 2.0E-04 7.5E-06 2.1E-04 1.1E-04 Flanges 3.9E-04 3.9E-07 1.1E-04 2.9E-06 Open-ended Lines 2.0E-03 1.4E-04 1.4E-03 2.5E-04 Pump Seals 2.4E-03 NA 1.3E-02 2.4E-05 Valves 4.5E-03 8.4E-06 2.5E-03 9.8E-05 Other 8.8E-03 3.2E-05 7.5E-03 1.4E-02 Source: EPA -453/R95-017 AIRS ID: 123/0090 Page 53 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division Note that the emission limits included in this permit are derived by multiplying the equipment counts in the table above by a factor of 1.1 to accommodate other minor changes to the facility and to provide a conservative estimate of facility -wide emissions. Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors listed in the table above with representative component counts, multiplied by the VOC content from the most recent gas analysis. Point 109: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 2.18x10-3 2.18x10-3 TNRCC CO 8.68x10-3 8.68x10-3 TNRCC VOC 2.023x10-1 1.011x10-2 AP -42 71432 Benzene 2.689x10-3 1.34x10-4 Mass Balance 108883 Toluene 7.45x10-3 3.72x10-4 Mass Balance 100414 Ethylbenzene 5.55x104 2.77x1O5 Mass Balance 1330207 Xylene 5.63x10-3 2.81x10-4 Mass Balance 110543 n -Hexane 1.446x10-2 7.23x10-4 Mass Balance Note: The uncontrolled VOC emission factor was calculated using AP -42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L = 12.46*S*P*M/T S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 5.0032 psia M (vapor molecular weight) = 66 lb/lb-mol T (temperature of liquid loaded) = 512.45 °R The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor. The mass fractions of each NCRP were obtained from the Mewbourn extended natural gas liquid analysis obtained on March 11, 2009. Controlled emission factors are based on an enclosed combustor efficiency of 95%. The NOx and CO emissions factors (EF) in the table above are based on the TNRCC Technical Supplement 4 emissions factors of 0.138 lb/MMBtu and 0.5496 lb/MMBtu respectively. The emissions factors from TNRCC were converted to units of lbs/bbl using a waste gas heating value of 3,397 Btu/scf and a gas -to -oil ratio (GOR) of 4.65 scf/bbl. An example of this calculation is as follows: lb \I / 0.138 lb\ / 3397 MMBtu 1 MMsc \I / k.65 scf \I _ 0.00218 lb NOx EFNOx bbl/ \MMBtu/ * \ MMscf / * �1,000,000scf/ * \ bbl / bbl Point 110: CAS # Pollutant Emission Factors Uncontrolled lb/BBL Condensate Throughput Emission Factors Controlled lb/BBL Condensate Throughput Source VOC 8.28x10-2 4.14x10-3 Tanks 4.0.9d AIRS ID: 123/0090 Page 54 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division CAS # Pollutant Emission Factors Uncontrolled lb/BBL Condensate Throughput Emission Factors Controlled lb/BBL Condensate Throughput Source 71432 Benzene 1.1x10-3 5.5x10-5 Mass Balance 108883 Toluene 3.05x10-3 1.52x10-4 Mass Balance 1330207 Xylenes 2.3x10-3 1.15x1O° Mass Balance 110543 n -Hexane 5.92x1O3 2.96x10-4 Mass Balance Note: The controlled emissions factors for point 110 are based on the enclosed combustor control efficiency of 95%. The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor. The mass fractions of each NCRP were obtained from the Mewbourn extended natural gas liquid analysis obtained on March 11, 2009. Points 111, 112: CAS Pollutant Emission Factors — Uncontrolled Uncontrolled EF Source NOx 15 ppmvd Manufacturer CO 25 ppmvd Manufacturer VOC 0.0021 lb/mm btu AP -42 Points 113, 114, 115, 116 and 117: CAS Pollutant Emission Factors - Uncontrolled Uncontrolled EF Source Emission Factors — Controlled Controlled EF Source NOx 0.5 g/hp-hr Manufacturer 0.5 g/hp-hr NA CO 2.74 g/hp-hr Manufacturer 0.1918 g/hp-hr Manufacturer + 93% control VOC 1.03 g/hp-hr Manufacturer 0.7 g/hp-hr CDPHE Reg 7 default 50000 Formaldehyde 0.40 g/hp-hr Manufacturer 0.04 g/hp-hr Manufacturer + 90% control 75070 Acetaldehyde 0.0084 lb/mmbtu AP -42 0.0014 lb/mmbtu AP -42 + 50% control 107028 Acrolein 0.0051 lb/mmbtu AP -42 0.0013 Ib/mmbtu AP -42 + 50% control 71432 Benzene 0.0004 lb/mmbtu AP -42 0.0008 lb/mmbtu AP -42 + 50% control Point 118 and 119: CAS Pollutant Emission lb/MMBtu Factors PPM - Uncontrolled Source PMio 6.6x1O3 ___ AP -42 Chapter 3 Table 3.1-2a AIRS ID: 123/0090 Page 55 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division CAS Pollutant Emission lb/MMBtu Factors PPM - Uncontrolled Source PM25 6.6x10-3 ___ AP -42 Chapter 3 Table 3.1-2a NOx 5.97x1O2 15 Manufacturer CO 6.07x10-2 25 Manufacturer 50000 Formaldehyde 7.1x10-4 _-_ AP -42 Chapter 3 Table 3.1-3 Note: Emission factors are based on a rated heat input of 61.58 MMBtu/hr, a higher heating value of 1,050 Btu/scf and 8,760 hours of operation a year. Point '120: Process 01: The emission levels contained in this permit are based on the ProMax simulation model using the extended sour gas analysis representative of the natural gas processed by this unit submitted with the permit application. Controlled emissions are based on 100% control efficiency when the flash tank is routed to the VRU, 96.7% control efficiency when the still vent is routed to the thermal oxidizer (TO), and 95% control efficiency when the flash tank is routed to the flare (point 125) during VRU downtime (max 5% annually). SO2 emissions resulting from the combustion of H2S and methyl mercaptan (MeSH) in the waste gas (including flash tank stream during VRU downtime and acid gas stream from the still vent) are based on a mass balance assuming 64.06 lb SO2/Ib-mol, 34.08 lb H2S/lb-mol, and 48.1 lb MeSH/lb-mol. The following calculation demonstrates the mass balance: so2(tpy) = HZS tons) (64.06 lb 502) lb — mot ) I [(MESH tons) (64.06 lb ( lb — mol I `11 year 1 lb — mol 1 * 34.08 lb 1-125 + year * \ lb — mol SO2)1 * \48.1 lb MeSH)] Combustion emissions associated with the still vent routed to the thermal oxidizer, flash tank routed to the plant flare (point 125) and combustion of supplemental fuel and pilot fuel at the thermal oxidizer are based on the following emissions factors: Process 02: Still Vent Controlled by the Thermal Oxidizer: CAS # Pollutant Uncontrolled Emission Factors lb/MMscf Waste Gas Combusted Source NOx 1.94 TCEQ CO 4.36 AP -42 Chapter 13.5 Note: The combustion emission factors are based on a heating value of 14.085 Btu/scf. Actual emissions are calculated by multiplying the emission factors in the table above by the total waste gas flow routed from the amine unit still vent to the thermal oxidizer as measured by flow meter. Combustion of Supplemental Fuel and Pilot Fuel at the TO: CAS # Pollutant Uncontrolled Emission Factors lb/MMscf fuel Gas Combusted Source SOx 0.6 AP -42 Table 1.4-2 NOx 144.9 TCEQ CO 325.5 AP -42 Chapter 13.5 AIRS I D : 123/0090 Page 56 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division CAS # Pollutant Uncontrolled Emission Factors lb/MMscf fuel Gas Combusted Source VOC 5.5 AP -42 Table 1.4-2 Note: The combustion emission factors are based on a heating value of 1,050 Btu/scf. Actual emissions are calculated by multiplying the emission factors in the table above by the supplemental fuel volume for the TO (as measured by flow meter) plus the fuel volume to the TO pilot (constant at 95.2 scf/hr). Process 03: Flash Tank Controlled by the Plant Flare (Point 125): CAS # Pollutant Uncontrolled Emission Factors lb/MMscf Waste Gas Combusted Source NOx 83.48 AP -42 Chapter 13.5 CO 380.59 AP -42 Chapter 13.5 Note: The combustion emission factors are based on a heating value of 1,227.72 Btu/scf. Actual emissions are calculated by multiplying the emission factors in the table above by the total waste gas flow routed from the amine unit flash tank to the plant flare (point 125) as calculated using ProMax and VRU downtime records. Points 121 and 123: CAS Pollutant Emission Factors — Uncontrolled Uncontrolled EF Source NOx 30 lb/mmscf Manufacturer CO 84 lb/mmscf AP -42 VOC 5.5 lb/mmscf AP -42 Point 122: The emission levels contained in this permit are based on information provided in the application and the GRI GlyCalc 4.0 model. Actual controlled emissions are based on a 100% control efficiency when emissions are routed to the VRU and a 95% control efficiency when emissions are routed to an open flare during VRU downtime (max 2% annually). To determine actual emissions during VRU downtime, the operator will multiply lb/hr emission results from the monthly GlyCalc model (based on the total actual gas throughput during the month) by the total hours of VRU downtime. A 95% control efficiency will be applied to this calculation based on the destruction efficiency of the flare. The operator will determine the actual monthly gas throughput during VRU downtime using the following equation: Total Gas Throughput, MMscf VRU Downtime, hrs Monthly Hours, hrsGas Throughputniu Downtime —()) (Total ) Month Month t Month Point 125: AIRS ID: 123/0090 Page 57 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division CAS Pollutant Emission Factors — Uncontrolled Uncontrolled EF Source Emission Factors — Controlled Controlled EF Source NOx 179 lbs/mmscf Engineering Calculation --- NA CO 477 lbs/mmscf Engineering Calculation --- NA VOC 14326 lbs/mmscf Engineering Calculation 736 lb/mmscf Engineering Calculation 71432 Benzene 30.712 Ibs/mmscf Engineering Calculation 1.5356 lb/mmscf Engineering Calculation 108883 Toluene 24.071 lbs/mmscf Engineering Calculation 1.2035 lb/mmscf Engineering Calculation 100414 Ethylbenzene 0.5603 lbs/mmscf Engineering Calculation 0.0280 lb/mmscf Engineering Calculation 1330207 Xylenes 4.2020 lbs/mmscf Engineering Calculation 0.2101 lb/mmscf Engineering Calculation 110543 n -Hexane 136.66 lbs/mmscf Engineering Calculation 8.4 lb/mmscf Engineering Calculation Point 127: CAS Pollutant Emission Factors — Uncontrolled Uncontrolled EF Source Emission Factors — Controlled Controlled EF Source NOx 23.6 lb/mmscf Engineering Calculation ___ NA CO 37.8 lb/mmscf AP -42 --- NA VOC 1637.8 lbs/mmscf Promax 54.30474 lb/mmscf Promax + 96.7% control SOx 40.3 lbs/mmscf Mass Balance --- NA 71432 Benzene 172.9 lbs/mmscf Manufacturer Lb/mmscf Promax + 96.7% control 108883 Toluene 158.9 lbs/mmscf Promax 5.2437 lb/mmscf Promax + 96.7% control 100414 Ethylbenzene 2.86 lbs/mmscf Promax 0.0944 lb/mmscf Promax + 96.7% control 1330207 Xylenes 35.99 lbs/mmscf Promax 1.1877 lb/mmscf Promax + 96.7% control 110543 n -Hexane 22.61 lbs/mmscf Promax 0.7461 lb/mmscf Promax + 96.7% control 67561 Methanol 116.4 Ibs/mmscf Promax 3.8412 lb/mmscf Promax + 96.7% control Point 129 and 130: CAS Pollutant Emission lb/MMBtu Factors PPM - Uncontrolled Source PMio 6.6x10-3 ___ AP -42 Chapter 3 Table 3.1-2a PM2.5 6.6x10-3 ___ AP -42 Chapter 3 Table 3.1-2a NOx 4.71x10-2 13 Manufacturer AIRS ID: 123/0090 Page 58 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division CAS Pollutant Emission lb/MMBtu Factors PPM - Uncontrolled Source CO 5.52x10-2 25 Manufacturer VOC 2.1x10-3 ___ AP -42 Chapter 3 Table 3.1-2a 50000 Formaldehyde 7.1x10-4 --- AP -42 Chapter 3 Table 3.1-3 Note: Emission factors are based on a rated heat input of 72.73 MMBtu/hr, a higher heating value of 1,050 Btu/scf and 8,760 hours of operation a year. Point 131: The emission levels contained in this permit are based on information provided in the application and the GRI GlyCalc 4.0 model. Actual controlled emissions are based on a 100% control efficiency when emissions are routed to the VRU and a 95% control efficiency when emissions are routed to an open flare during VRU downtime (max 2% annually). To determine actual emissions during VRU downtime, the operator will multiply lb/hr emission results from the monthly GlyCalc model (based on the total actual gas throughput during the month) by the total hours of VRU downtime. A 95% control efficiency will be applied to this calculation based on the destruction efficiency of the flare. The operator will determine the actual monthly gas throughput during VRU downtime using the following equation: Gas Throughput, MMscf) VRU Downtime, Monthly Hours, hrs)Gas ThroughputVRU Downtime =(Total 1 hrs) (Total Month Month Month Point 132: CAS # Pollutant Emission Factors Uncontrolled lb/MMscf Source NOx 50 AP -42 Chapter 1 Table 1.4-1 CO 84 AP -42 Chapter 1 Table 1.4-1 Note: Emission factors are based on a rated heat input of 9.6 MMBtu/hr, a higher heating value of 1,050 Btu/scf and 8,760 hours of operation a year. Point 133: CAS # Pollutant Emission Factors Uncontrolled lb/MMscf Source PMio 7.6 AP -42 Chapter 1 Table 1.4-2 PM2.5 7.6 AP -42 Chapter 1 Table 1.4-2 NOx 50 AP -42 Chapter 1 Table 1.4-1 CO 84 AP -42 Chapter 1 Table 1.4-1 110543 n -Hexane 1.8 AP -42 Chapter 1 Table 1.4-3 AIRS ID: 123/0090 Page 59 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division Note: Emission factors are based on a rated heat input of 40.8 MMBtu/hr, a higher heating value of 1,050 Btu/scf and 8,760 hours of operation a year. Point 134: CAS # Pollutant Emission Factors Uncontrolled lb/BBL Condensate Throughput Emission Factors Controlled lb/BBL Condensate Throughput Source VOC 8.06x10-2 4.03x10-3 Tanks 4.0.9d 71432 Benzene 1.07x1O3 5.35x10-5 Mass Balance 108883 Toluene 2.96x10-3 1.48x10-4 Mass Balance 1330207 Xylenes 2.24x1O3 1.12x10-4 Mass Balance 110543 n -Hexane 5.76x10-3 2.88x1O4 Mass Balance Note: The controlled emissions factors for point 134 are based on the enclosed combustor control efficiency of 95%. Point 135: Component Gas Service Gas Control % Light Oil Light Liquid Control % Connectors 4,288 30 7,857 30 Flanges 2,885 30 1,786 30 Open-ended Lines 1 75 0 --- Pump Seals 0 --- 50 88 Valves 3,727 95 2,840 95 Other* 155 75 37 75 Relief Valves 49 95 32 95 VOC Content (wt. %) 28.09% --- 100% --- Benzene Content (wt. %) 0.0653% --- 0.2326% --- Toluene Content (wt. %) 0.0929% --- 0.3308% --- Ethylbenzene (wt. %) 0.0103% --- 0.0365% --- Xylenes Content (wt. %) 0.0307% --- 0.1091% --- n-Hexane Content (wt. %) 1.4216% --- 5.0607% --- 2,2,4 -IMP Content (wt. %) 0.0628% --- 0.2236% *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms. drains, dump arms, hatches, instrument meters, polish rods and vents TOC Emission Factors (kg/hr-component): Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 2.0E-04 7.5E-06 2.1E-04 1.1E-04 Flanges 3.9E-04 3.9E-07 1.1E-04 2.9E-06 Open-ended Lines 2.0E-03 1.4E-04 1.4E-03 2.5E-04 Pump Seals 2.4E-03 NA 1.3E-02 2.4E-05 AIRS ID: 123/0090 Page 60 of 72 DCP Midstream, LP Permit No. 09WE1136 1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division Valves 4.5E-03 8.4E-06 2.5E-03 9.8E-05 Other 8.8E-03 3.2E-05 7.5E-03 1.4E-02 Relief Valves 8.8E-03 3.2E-05 7.5E-03 1.4E-02 Source: EPA -453/R95-017 Table 2-4 Note that the emission limits included in this permit are derived by multiplying the emissions resulting from the component counts in the table above by a factor of 1.1 to accommodate other minor changes to the facility and to provide a conservative estimate of facility -wide emissions. Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors listed in the table above with representative component counts, multiplied by the VOC content from the most recent extended gas analysis. Point 136: Process 01: The emission levels contained in this permit are based on the ProMax simulation model using the extended sour gas analysis representative of the natural gas processed by this unit submitted with the permit application. Controlled emissions are based on 95% control efficiency when the amine unit still vent is routed to the acid gas flare (point 136) during thermal oxidizer downtime. SO2 emissions resulting from the combustion of H2S and methyl mercaptan (MeSH) in the still vent waste gas are based on a mass balance assuming 64.06 lb SO2/lb-mol, 34.08 lb H2S/lb-mol, and 48.1 lb McSH/Ib-mol. The following calculation demonstrates the mass balance: H2S tonsl 64.06 lb 502 (34.08 lb — mol 11 ft MeSH tonsl (64.06 lb S021 (lb — mol11S02(tpy) =year ) *( lb — mol ) * lb H2S)] + year ) * ( lb — mol ) * (48.1 lb McSH)I Process 02: Combustion emissions are based on the following emission factors: Still Vent Waste Gas Controlled by the Flare: CAS # Pollutant Uncontrolled Emission Factors lb/MMscf Waste Gas Combusted Source NOx 9.57x10-1 AP-42 Chapter 13.5 CO 4.36 AP -42 Chapter 13.5 Note: The combustion emission factors are based on a heating value of 14.085 Btu/scf. Actual emissions are calculated by multiplying the emission factors in the table above by the total waste gas flow routed from the amine unit still vent to the flare (point 136) as measured by flow meter. AIRS ID: 123/0090 Page 61 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division Combustion of Assist Gas and Purge Gas: CAS # Weight Fraction of Gas (%) Pollutant Emission Factors Uncontrolled lb/MMscf Emission Factors Controlled lb/MMscf Source NOx 74.25 74.25 AP 42 Chapter 13.5 CO 338.52 338.52 AP 42 Chapter 13.5 SO2 0.6 0.6 AP -42 Chapter 1 Table 1.4-2 7.44 VOC 3599.58 179.97 Gas Analysis 110543 0.21 n -Hexane 111.36 5.56 Mass Balance Note: The uncontrolled VOC and HAP emissions were calculated using the March 29, 2017 residue gas analysis obtained from the Mewbourn gas plant. The controlled VOC and HAP emission factors are based on the flare control efficiency of 95%. NOx and CO emission factors are based on a heating value of 1,092 Btu/scf. Actual emissions are calculated by multiplying the emission factors in the table above by the total assist gas and purge gas routed to the flare (point 136). The assist gas routed to the flare is measured using a flow meter. The purge gas is routed to the flare at a constant rate of 115 scf/hr. Combustion of Pilot Light Fuel: CAS # Pollutant Emission Factors Uncontrolled lb/MMscf Source NOx 100 AP -42 Chapter 1 Table 1.4-1 CO 84 AP -42 Chapter 1 Table 1.4-1 SO2 0.6 AP -42 Chapter 1 Table 1.4-2 VOC 5.5 AP -42 Chapter 1 Table 1.4-2 110543 n -Hexane 1.8 AP 42 Chapter 1 Table 1.4-3 Note: Emission factors are based on a higher heating value of 1,050 Btu/scf and 8,760 hours of operation a year. The pilot light fuel has a constant rate of 134.6 scf/hr. Total actual combustion emissions are based on the sum of the emissions calculated for the combustion of still vent waste gas, assist gas and purge gas, and pilot light gas. Point 137: Emissions associated with the open flare result from the combustion of maintenance gas (inlet and residue), purge gas (residue), and pilot light gas. Total actual emissions are based on the sum of the emissions calculated for the combustion of maintenance gas and purge gas (process 01) and the combustion of pilot light gas (process 02). This open flare will handle gas (inlet and residue) routed to the flare during standard operational process/normal operation of equipment (i.e. maintenance and blowdown activities). The process limit does not include gas routed to the flare AIRS ID: 123/0090 Page 62 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division during malfunction events or startup and shutdown events per the Colorado Common Provisions Regulation Section II.E and Ili. The process limit also does not include waste gas associated with the dehydrator (Point 131) still vent and flash tank routed to this flare during VRU downtime. Process 01: Combustion of maintenance (residue and inlet) gas and purge gas CAS # Weight Fraction of (0/0) Gas Pollutant Emission Factors Uncontrolled Ib/MMscf Emission Factors Controlled lb/MMscf Source NOx 76.5 76.5 AP 42 Chapter 13.5 CO 348.78 348.78 AP 42 Chapter 13.5 9.71 VOC 5,032.41 251.62 Gas Analysis 110543 0.23 n -Hexane 115.34 5.76 Mass Balance Note: The uncontrolled VOC and HAP emissions were calculated using a weighted average of a residue gas analysis obtained from the Mewbourn gas plant on March 29, 2017 and an inlet gas sample obtained from the Mewbourn gas plant on December 2, 2014. The weighted average is based on the relative contribution of residue and purge gas volume (84%) and inlet gas volume (16%) to the total volume of gas vented to the flare. The controlled VOC and HAP emission factors are based on the flare control efficiency of 95%. NOx and CO emission factors are based on a heating value of 1,125 Btu/scf. Actual emissions are calculated by multiplying the emission factors in the table above by the total gas flow routed to this flare as measured by flow meter. Process 02: Combustion of pilot light fuel CAS # Pollutant Emission Factors Uncontrolled lb/MMscf Source NOx 100 AP -42 Chapter 1 Table 1.4-1 CO 84 AP -42 Chapter 1 Table 1.4-1 VOC 5.5 AP -42 Chapter 1 Table 1.4-2 110543 n -Hexane 1.8 AP -42 Chapter 1 Table 1.4-3 Note: Emission factors are based on a higher heating value of 1,050 Btu/scf and 8,760 hours of operation a year. The pilot light fuel has a constant rate of 195 scf/hr. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692- 3150. 7) Points 113, 114, 115, 116 and 117: These engines are 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 AIRS ID: 123/0090 Page 63 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA website at: http://www.epa.gov/ttn/atw/area/fr18ia08.pdf 8) Points 113, 114, 115, 116 and 117: These engines are subject to 40 CFR, Part 63. Subpart ZZZZ — National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January 18, 2008 Federal Register posting — effective March 18, 2008). The January 18, 2008 amendments to include requirements for area sources and engines < 500 hp located at major sources have not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 8. A copy of the complete subpart is available on the EPA website at: http://www.epa.gov/ttn/atw/area/fr18ja08.pdf Additional information regarding area source standards can be found on the EPA website at: http://www.epa.gov/ttn/atw/area/arearules.html 9) Point 135: This source is subject to 40 CFR, Part 60, Subpart OOOOa-Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After September 18, 2015 (See June 3, 2016 Federal Register posting — effective August 02, 2016). This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA website at: https://www.qpo.qov/fdsys/pkg/FR-2016-06-03/pdf/2016-11971.pdf 10) This facility is classified as follows: Applicable Requirement Status Operating Permit Major Source: CO, VOC, and NOx Synthetic minor source: HAPS NANSR Major Source: VOC and NOx PSD Synthetic Minor Source: CO MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Applicable MACT ZZZZ Area Source Requirements: Applicable to Points 113, 114, 115, 116 and 117 MACT DDDDD Not applicable NSPS KKK Applicable to point 108 NSPS OOOO Not applicable NSPS 0000a Applicable to point 135 NSPS Kb Applicable to point 134 NSPS KKKK Applicable to points 111, 112, 118, 119, 129 and 130 NSPS Dc Applicable to points 121, 123, and 133 NSPS LLL Recordkeeping requirements only for Point 120 11) 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/ AIRS ID: 123/0090 Page 64 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A — Subpart KKKK NSPS Part 60, Appendixes Appendix A — Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A — Subpart Z MACT 63.600-63.1199 Subpart AA — Subpart DDD MACT 63.1200-63.1439 Subpart EEE — Subpart PPP MACT 63.1440-63.6175 Subpart OOO - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ — Subpart MMMMM MACT 63.8980 -End Subpart NNNNN — Subpart XXXXXX AIRS ID: 123/0090 Page 65 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 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 No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS, and the owner or operator shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with a compressor engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. Temporary" is defined as in the same service for 90 operating days or less in any 12 month period. "Permanent' is defined as in the same service for more than 90 operating days in any 12 month period. The 90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90 day total. The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit. All replacement engines are subject to all federally applicable and state -only requirements set forth in this permit (including monitoring and record keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5) years and made available to the Division upon request. The owner or operator shall maintain a log on -site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make them available to the Division upon request. 2.1.1 The owner or operator may temporarily replace an existing compressor engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other requirements applicable to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. AIRS ID: 123/0090 Page 66 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division 2.1.2 The owner or operator may permanently replace the existing compressor 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. The AOS cannot be used for the permanent replacement of an entire engine at any source that is currently a major stationary source for purposes of Prevention of Significant Deterioration or Non -Attainment Area New Source Review ("PSD/NANSR") unless the existing engine has emission limits that are below the significance levels in Reg 3, Part D, II.A.42. 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 http://www.cdphe.state.co.us/ap/oilgaspermitting.html. 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. Nothing in this AOS shall preclude the Division from taking an action, based on any permanent engine replacement(s), for circumvention of any state or federal PSD/NANSR requirement. Additionally, in the event that any permanent engine replacement(s) constitute(s) a circumvention of applicable PSD/NANSR requirements, nothing in this AOS shall excuse the owner or operator from complying with PSD/NANSR and applicable permitting requirements. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. AIRS ID: 123/0090 Page 67 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at: https://www.colorado.gov/pacific/sites/default/files/AP Portable-Analyzer-Monitorinq-Protocol.pdf Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever applies. For comparison with a short-term limit that is either input based (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. 2.4 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: 123/0090 Page 68 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division ATTACHMENT B ALTERNATIVE OPERATING SCENARIOS COMBUSTION TURBINES Routine Turbine Component Replacements The following physical or operational changes to the turbines in this permit are not considered a modification for purposes of NSPS GG, NSR/PSD, or Regulation No. 3: 1) Replacement of stator blades, turbine nozzles, turbine buckets, fuel nozzles, combustion chambers, seals, and shaft packings, provided that they are of the same design as the original. 2) Changes in the type or grade of fuel used, if the original gas turbine installation, fuel nozzles, etc. were designed for its use. 3) An increase in the hours of operation (unless limited by a permit condition) 4) Variations in operating loads within the engine design specification. 5) Any physical change constituting routine maintenance, repair, or replacement. Turbines undergoing any of the above changes are subject to all federally applicable and state -only requirements set forth in this permit (including monitoring and record keeping). If replacement of any of the components listed in (1) or (5) above results in a change in serial number for the turbine, a letter explaining the action as well as a revised APEN and appropriate filing fee shall be submitted to the Division within 30 days of the replacement. Note that the repair or replacement of components must be of genuinely the same design. Except in accordance with the Alternate Operating Scenario set forth below, the Division does not consider that this allows for the entire replacement (or reconstruction) of an existing turbine with an identical new one or one similar in design or function. Rather, the Division considers the repair or replacements to encompass the repair or replacement of components at a turbine with the same (or functionally similar) components. Alternative Operating Scenarios The following Alternative Operating Scenario (AOS) for temporary and permanent combustion turbine replacement and turbine component replacement has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility -Alternative Operating Scenarios, and Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration and has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any combustion turbine replacement performed in accordance with this AOS, and the permittee shall be allowed to perform such turbine or turbine component replacement without applying for a revision to this permit or obtaining a new Construction Permit. 1. Turbine Replacement The following AOS is incorporated into this permit in order to deal with a turbine breakdown or periodic routine maintenance and repair of an existing onsite turbine that requires the use of a temporary replacement turbine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month period. The 90 days is the total number of days that the turbine is in operation. If the turbine operates only part of a day, that day counts towards the 90 day total. Note that the compliance AIRS ID: 123/0090 Page 69 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division demonstrations made as part of this AOS are in addition to any compliance demonstrations required by this permit. All replacement turbines are subject to all federally applicable and state -only requirements set forth in this permit (including monitoring and record keeping) Results of all tests and the associated calculations pursuant required by this AOS shall be submitted to the Division within 30 calendar days of the test. Results of all tests shall be kept on site for five (5) years and made available to the Division upon request. The permittee shall maintain a log on -site to contemporaneously record the start and stop date of any turbine replacement, the manufacturer, model number, horsepower, and serial number of the turbine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement turbine. Any permanent turbine replacement under this AOS may result in the replacement turbine being considered a new affected facility for purposes of NSPS and shall be subject to all applicable requirements of that Subpart including, but not limited to, any required Performance Testing. at. The permittee may temporarily replace an existing permitted turbine provided such replacement turbines are [e.g. GE LM6000] combustion turbines without modifying this permit, so long as the emissions from the temporary replacement turbine comply with the emission limitations for the existing permitted turbine as determined in Section 2. Measurement of emissions from the temporary replacement turbine shall be made as set forth in Section 2. l�. The permittee may permanently replace the existing permitted combustion turbine provided such replacement turbines are [e.g. GE LM6000] combustion turbines without modifying this permit so long as the emissions from the permanent replacement turbine comply with the emission limitations for the existing permitted turbine as determined in Section 2. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model, and serial number of the permanent replacement turbine shall be filed with the Division for the permanent replacement turbine within 14 calendar days of commencing operation of the replacement turbine. The APEN shall be accompanied by the appropriate APEN filing fee and a cover letter explaining that the permittee is exercising an alternative operating scenario and is installing a permanent replacement turbine. This AOS cannot be used for permanent turbine replacement of a grandfathered turbine or a turbine that is not subject to emission limits. The permittee shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent turbine replacement. 2. Portable Analyzer Testing The permittee shall measure nitrogen oxide (NO.) and carbon monoxide (OO) emissions in the exhaust from the replacement turbine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement 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 website at: http://www.cdphe.state.co.us/ap/down/portanalyzeproto.pdf AIRS ID: 123/0090 Page 70 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual or short term 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. If the portable analyzer results indicate compliance with both the NO. and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the turbine is in compliance with both the NO. 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 NO. or CO emission limitations, the turbine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NO. and CO emission limitations or until the turbine is taken offline. 3. Additional Sources The replacement of an existing turbine with a new turbine is viewed by the Division as the installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site; a turbine that is being installed as an entirely new emission point and not as part of an AOS-approved replacement of an existing onsite turbine must go through the appropriate Construction/Operating permitting process prior to installation. PSD 4.2.8 At its discretion, the Division may require that the permittee apply for and obtain a minor permit modification, in accordance with the provisions of Regulation No. 3, Part C, § X, for any permanent turbine replacement. 4.2.9 Nothing in this AOS shall preclude the Division from taking an action, based on any permanent turbine replacement(s), for circumvention of any state or federal Prevention of Significant Deterioration or Non -Attainment New Source Review ("PSD/NSR") requirement. Additionally, in the event that any permanent turbine replacement(s) constitute(s) a circumvention of applicable PSD/NSR requirements, nothing in this AOS shall excuse the permittee from complying with PSD/NSR and applicable Title V permitting requirements. AIRS ID: 123/0090 Page 71 of 72 DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division ATTACHMENT C INSIGNIFICANT ACTIVITIES Description NOx VOC CO 0.1 MMBtu/hr shop heater 0.04 0.00 0.02 0.1 MMBtu/hr office furnance 0.04 0.00 0.02 0.036 mmbtu/hr office hot water heater 0.01 0.00 0.01 560 gal kerosene tank --- 0.00 --- 2000 gal Norkool tank --- --- --- 6000 gal lube oil tank --- --- --- 2000 gal Norkool tank --- - --- 1000 gal TEG tank --- --- --- 2000 gal Methanol tank --- 0.03 --- 560 gal lube oil tank --- --- --- 988 gal HMO tank --- --- --- 10 bbl dehy water --- --- 300 gal, TEG/oily water tank --- --- --- 300 gal Scavenger tank --- - --- 2000 gal HMO overflow tank --- --- --- 10 bbl oily stormwater tank --- --- --- 80 bbl oily stormwater tank --- --- --- 10 bbl oily stormwater tank --- --- --- 250 gal used oil tank --- --- 65-150 gal each engine and < 40 gal each compressor tube oil tanks --- -- --- 2000 gal Methanol tank --- 0.03 --- 300 gal Methanol tank --- 0.00 --- 60000 gal Pressurized Y -Grade storage tank --- --- --- 60000 gal Pressurized Y -Grade storage tank - --- --- 60000 gal Pressurized condensate surge tank --- --- --- 3000 gal Pressurized Propane storage tank --- --- --- 5000 gal Pressurized Propane storage tank --- --- --- Combustor pilot 0.57 0.05 0.49 Compressor blowdowns for maintenance activities * --- 6.22 --- Pig Launching/Receiving Blowdowns --- 0.5 --- Pressurized raw condensate unloading rack --- 0.98 --- *There is a blowdown vent for each compressor package so each is a separate emission point VOC emissions calculated separately for each vent. AIRS ID: 123/0090 Page 72 of 72 The Honorable Members of the Weld County Commission PO Box 758 Greeley, CO 80631 Dear County Commissioners, Following the energy downturn since late 2014, we're encouraged by the potential renewed opportunities that a robust energy industry fosters for Weld County's overall business community. As leaders of that business community who understand the importance of oil and natural gas development to the overall health of our economy, we aim to keep this progress moving forward. To further that economic health, we encourage your support for the expansion of DCP Midstream's Mewbourn gas processing facility, otherwise known as the company's "Mewbourn 3" project. See Site Specific Development Plan and 5th Amended Use by Special Review Permit No. 5MJUSR17-83-542 (Docket #2017-42 PL0439). On a practical level, this expanded processing capacity is imperative for the fulfillment of the current and future development plans for many of Weld County's most heavily invested oil and gas operators. But on a more societal level, a vote for expansion means preserving current levels of employment and investment for a host of allied service industries and related Weld County employers. Real jobs for real Weld County residents. According to a recent study by SmartAsset, Weld County leads the state in business investments thanks, in part, to the oil and gas industry. DCP's nearly $400 million investment in Mewbourn 3 will unlock even further investment by operators and allied service providers, enabling Weld County to stay at the top of so many leading business indicators. These business investments not only benefit the industry, but also reach into our communities by means of enhanced revenue for the county for schools, infrastructure and public safety. Weld County's 2017 Budget acknowledges that oil and gas development activity, both direct and indirect, represents "the main economic driver in the majority of positive economic activities in Weld County." Current and future investments fostered by Mewbourn 3 can be expected to translate over time into hundreds of millions of ad valorem revenue into the county's general fund. As you decide on this application, we encourage you to consider the economic and financial benefits this project poses to the industry and to the overall economic health of Weld County. Thank you for your consideration and your service to Weld County. Sincerely, Bill Jerke, Executive director -FUEL Tom Haren, CEO-AGPROfessionals Ronnie Van Buskirk att, or ccu y. INCARBON VALLEY •^.: M ¢ )# OL.?flSAe me ! :: •.. r, �\ ..4.r .�1"/ Videle1/4 Vital for Colorado 4950 S Yosemite St. #236 I Greenwood Village, CO 80111 www.vitalforcolorado.com [he Honorable Members of the Weld County Commission PO Box 758 Greeley, CO 80631 Dear County Commissioners. Following the energy downturn since late 2014, we're encouraged by the potential renewed opportunities that a robust energy industry fosters for Weld County's overall business community. As leaders of that business community who understand the importance of oil and natural gas development to the overall health of our economy, we aim to keep this progress moving forward. To further that economic health, we encourage your support for the expansion of DCP Midstream's Mewbourn gas processing facility, otherwise known as the company's "Mewbourn 3" project. See Site Specific Development Plan and 5th Amended Use by Special Review Permit No. 5MJUSR 17-83-542 (Docket #2017-42 PL0439). On a practical level, this expanded processing capacity is imperative for the fulfillment of the current and future development plans for many of Weld County's most heavily invested oil and gas operators. But on a more societal level, a vote for expansion means preserving current levels of employment and investment for a host of allied service industries and related Weld County employers. Real jobs for real Weld County residents. According to a recent study by SmartAsset, Weld County leads the state in business investments thanks, in part, to the oil and gas industry. DCP's nearly $400 million investment in Mewbourn 3 will unlock even further investment by operators and allied service providers, enabling Weld County to stay at the top of so many leading business indicators. These business investments not only benefit the industry, but also reach into our communities by means of enhanced revenue for the county for schools, infrastructure and public safety. Weld County's 2017 Budget acknowledges that oil and gas development activity, both direct and indirect, represents "the main economic driver in the majority of positive economic activities in Weld County." Current and future investments fostered by Mewbourn 3 can be expected to translate over time into hundreds of millions of ad valorem revenue into the county's general fund. As you decide on this application, we encourage you to consider the economic and financial benefits this project poses to the industry and to the overall economic health of Weld County. Thank you for your consideration and your service to Weld County. Sincerely, Bill Jerke, Executive director -FUEL Tom Haren, CEO-AGPROfessionals Ronnie Van Buskirk CARBON VALLEY F1 T?%~vT1nn7r Vital for Colorado 4950 S Yosemite St. #236 I Greenwood Village, CO 80111 www.vitalforcolorado.com Ezicp Midstream... December 5, 2016 DCP Midstream 370 17th Street, Suite 2500 Denver, CO 80202 6 21116 Sent via UPS Tracking Number 1Z F46 915 02 9914 8351 Colorado Department of Public Health and Environment Air Pollution Control Division - Oil & Gas Division 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 RE: DCP Midstream, LP Mewbourn Natural Gas Processing Plant (AIRS ID 123/0090) Construction Permit Number: 09WE1136 - Issuance 3 Permit Modification Application Dear Sir or Madam, DCP Midstream, LLC (DCP) respectfully submits the enclosed permit modification application for the Mewbourn Natural Gas Processing Plant (Mewbourn) located in SE1/4, Section 35, T4N, R66W, Weld County, Colorado. Mewbourn is currently authorized under Colorado Department of Public Health and Environment (CDPHE) Air Pollution Control Division (APCD) (herein referred to as the "Division") Permit No. 09WE1136 (issuance 3) issued on October 21, 2016. DCP is proposing to expand Mewbourn and add a new 230 MMscfd natural gas processing train, called Mewbourn III. As part of this modification, DCP is requesting the removal of existing sources, modifications of existing sources and addition of new sources, as detailed below. Remova of Existing Sources • Waukesha Natura Gas Fired RICE Engine (A RS D 123/0090/102. ID C-1671 DCP is proposing to remove Waukesha L7044GS1, SN: C14610-1, 1,680 hp natural gas fired RICE engine from service. • Waukes is Natura Gas Fired R CE Engine (A RS D 123/0090/103. D G-1791 DCP is proposing to remove Waukesha L7042GS1, SN: C-10731-1, 1,478 hp natural gas fired RICE engine from service. • Waukesha Natura Gas Fired RICE Engine LA RS iD 123/0090/106.1D C-130). DCP is proposing to remove Waukesha L7042GS1, SN: 339839, 1,478 hp natural gas fired RICE engine from service. Modifications to Existing Sources: • Amine Unit (AIRS ID 123/0_ 090/120. ID AM001): o Currently the amine unit is controlled by a regenerative thermal oxidizer (RTO) with backup control supplied by a thermal oxidizer (TO), with a DRE of 96.7%. DCP is proposing to remove the RTO and make the TO the primary control device for the amine unit with a DRE of 96.7%. The plant flare will serve as backup during TO downtime (permitting two weeks per year of backup at 95% DRE). DCP would like to retain the 5 days per year of venting during TO downtime. • TEG Dehydrator (A RS D 123/0090/122. ID D-931): o DCP is proposing to recycle the TEG dehydrator still vent stream back to the plant inlet via a vapor recovery unit (VRU). A redundant VRU is in place for any primary TEG dehydrator VRU downtime. The flash tank stream is also recycled to the plant inlet with a VRU. DCP is requesting to conservatively permit 2% annual VRU downtime during which time the TEG dehydrator still vent and flash streams will be routed to the plant flare with a DRE of 95%. • ,Gensets G1650 and G1670 (AIRS ID 123/0090/118 and AIRS ID 123/0090/119),: c Currently Gensets G1650 and G1670 are represented as one emission point (118) with a combined hours of operation limit. DCP is proposing to separate these gensets into two separate emission points (118 and 119) and increase hours of operation to 8,760 hours per year for both units. • Condensate Storagee Tan ,AIRS ID 123/0090/110. ID TANKS: o DCP is proposing to increase the condensate storage tanks throughput from 476,190 barrels (bbl) per year (yr) to 912,500 bbl/yr. • Condensate Truck Loadout (AIRS ID 123/0090/109. ID LO): o DCP is proposing to increase the annual condensate loadout throughput from 476,190 bbl/yr to 912,500 bbl/yr. • Plant Flare (AIRS ID 123/0090/125, ID F-1): • DCP is permitting amine acid gas stream to the flare during TO downtime (maximum of two weeks per year). o DCP is proposing to route the TEG dehydrator still vent and flash gas streams to the plant flare during VRU annual downtime (2% annually). o DCP would like to increase the waste gas flow to the plant flare by 25% in order to account for the new train. • Various insignificant activity updates. Proposed NEW Sources: • NEW Solar T-70 Turbines (IDs TURB-1. and TU RB-2): o DCP is proposing to install two new Solar T-70 turbines which will serve as residue compressors. • NEW Regeneration Heater (HT -01): o DCP is proposing to install a new 9.6 M MBtu/hr mole sieve regeneration heater. • NEW Hot Oil Heater (HT -021: o DCP is proposing to install a new 40.8 MMBtu/hr hot oil heater. • NEW TEG Dehydrator (JD D-2_• o DCP is proposing to install a new TEG dehydrator and will recycle the still vent stream and flash tank stream of the glycol dehydrator back to the plant inlet via a VRU. A redundant VRU will be in place for any primary TEG dehydrator VRU downtime. DCP is requesting to conservatively permit 2% annual VRU downtime during which time the TEG dehydrator still vent and flash streams will be routed to the plant flare with a DRE of 95%. • NEW Stabilized Condensate Storage Tanks ( D TANKS -2): DCP is proposing to install two new 755 barrel fixed roof stabilized condensate storage tanks. Emissions from the storage tanks will be controlled by the enclosed combustor with a DRE of 95%. DCP is requesting a combined annual throughput of 912,500 bbl/yr for the new condensate tanks. • NEW fugitive components associated with the Mewbourn • Various insignificant activity additions, I expansion ( D FUG -2) As detailed above, DCP is removing and revising the process for several sources as part of this project. Since the reduction in particulates (PM, PM10, and PM2.5), nitrogen oxides (N0x), volatile organic compounds (VOCs) and carbon monoxide (CO) emissions is a substantial amount of emissions, DCP has performed a netting analysis to take credit for these reductions. Potential emissions were assumed for the proposed new equipment per Regulation 3, Part D, Section II.A.1.c. Per CDPHE APCD Regulation 3 Part D, Section I I.A., a netting analysis was completed for PM, PM10, PM2.5, NOx, VOCs and CO. The consecutive twenty four month period for the netting analysis was September 2014 through August 2016 for PM, PM10, PM2.5, and NOx and was October 2011 through November 2013 for VOC and CO. For sources that are "new" (i.e. have operated for less than two years) per Regulation 3, Ii.A.13.a.(i), baseline emissions are based on their permitted potential to emit, per Regulation 3, Part D Ii.A.4.c. As shown in the table below, the proposed project modifications do not result in a significant net emission increase of criteria pollutants and therefore the project is not considered a major modification for criteria pollutants. Table 1: Mewbourn III Project Emission Changes AIRS ID Description Status Pro)osed Changes In Annual Emissions (tpyj a PM PMap PMt; S02 NOx VOC CO 123/0090/102 C167 Waukesha L7044G51 (1.680 hp) 005 REMOVE -0.97 -0.97 -0.97 -- -21.65 -10.04 -20.09 123/0090/103 C179 Waukesha L7042GS1 (1,478 hp) OOS REMOVE -0.88 -0.88 -0.88 -- -19.11 -11.56 -17.34 123/0090/106 C130 Waukesha L7042GSI (1,478 hp) OOS REMOVE -0.04 -0.04 -0.04 -- -0.28 -1.89 -5.76 123/0090/TBD FUG -2 - Mewbourn III Fugitive Emissions • ADD -- - -- -- -- -- -- 123/0090/109 LO - Condensate Tank Loadout UPDATE -- -- -- -- 0.48 2.21 1.89 123/0090/110 TANKS - (4) 400 bbl Condensate Tanks UPDATE -- - -- -- 0.04 0.60 0.13 123/0090/118 G1650 - Genset 1 Solar Taurus -70 Turbine (8046 hp) UPDATE -- -- •- -- -- -- -- 123/0090/119 G1670 - Genset 2 Solar Taunis-70 Turbine (8046 hp) UPDATE 1.4H 1.48 1.48 0.76 13.38 0.47 13.60 123/0090/120 AM001 - Amine Unit to TO UPDATE 0.57 0.57 0.57 0.04 11.41 3.26 24.39 123/0090/122 D-931 • TEG Dehydrator Recyled to Inlet UPDATE -- -- -- 0.46 -8.90 -4.86 -7.07 123/0090/127 Backup TO - Amine Acid Gas and TEG Still Vent OOS REMOVE -- -- -- -- -- 123/0090/125 F-1/Plant Flare UPDATE -- -- -- 1.35 0.68 0.89 2.77 123/0090/TBD TURB-1 - Solar Taurus -70 Turbine (9055 hp) ADD 2.10 2.10 2.10 1.08 15.02 0.67 17.61 123/0090/TBD TURB-2 - Solar Taurus -70 Turbine (9055 hp) ADD 2.10 2.10 2.10 1.08 15.02 0.67 17.61 123/0090/TBD D-2 - TEG Dehydrator Recycled to Inlet ADD -- - -- 0.05 0.08 1.25 0.3S 123/0090/TBD HT -01 -9.6 MMBtu/hr Regen Hot Oil Heater ADD 0.30 0.30 0.30 0.02 2.00 0.22 3.36 123/0090/TBD HT -02 - 40.8 MMBtu/hr Stabilizer Hot Oil Heater ADD 1.29 1.29 1.29 0.10 8.51 0.94 14.30 123/0090/TBD TANKS -2 - (2) 755 bbl Condensate Tanks ADD -- — -- -- 0.20 1.84 0.79 Insignificant Activities UPDATE -- -- -- -- 0.00 10.91 0.00 Total Project Emission Changes from Mewbourn Expansion and Mewbourn ill Train 5.96 5.96 5.96 4.96 16.87 -4.43 46.53 NNSR SER 2 -- - -- - 4^, 40 — Is the project above NNSR SERs? -- — _ -- — NO NO — Sources marked with '•' are fugitive emission sources. ' Emissions shown represent project increases and decreases in permitted emissions and represent the difference between permitted emissions and future potentials. `The project is located in a non -attainment area for ozone but is in an attunment or unclassifiable area for NOx, therefore emissions of NOx are subject to both PSD and NNSR programs. Since VOC is only regulated as a precursor to ozone, only the NNSR program applies for this project As shown in the table above and in the emission calculations included in Attachment C of this submittal, the requested modifications result in a net decrease of VOC. The proposed emissions for all criteria pollutants are below Nonattainment New Source Review NNSR significance thresholds. 'ranted from Electronic Record STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 09WE1136 Issuance 4 DATE ISSUED: July 14, 2017 ISSUED TO: DCP Operating Company, LP THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural gas processing facility, known as the Mewbourn Natural Gas Processing Plant, located in SE1/4 Section 35, Township 4 North, Range 66 West, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description C-211 101 One (1) Caterpillar, stroke, rich -burn. combustion output rated compressor. Selective Catalytic G379NA, naturally engine, heat at 330 HP, Emissions Reduction SN: 72B643, natural aspirated, reciprocating input rated at 2.6 MMBTU running a natural gas / are controlled by AFR system. gas fired, 4 - internal per hour, vapor and a Non - C-167 102 One (1) Waukesha. L7044GSl, SN: C14610-1, natural gas fired. 4 -stroke, rich -burn, turbocharged, reciprocating internal combustion engine, heat input rated at 12.9 MMBTU per hour, output rated at 1.680 HP, running a natural gas compressor. Emissions are controlled by AFR and a Non -Selective Catalytic Reduction System. C-179 103 One (1) Waukesha, L7042GSI, SN: C-10731-1, natural gas fired, 4 -stroke, rich -burn, turbocharged, reciprocating internal combustion engine, heat input rated at 11.6 MMBTU per hour, output rated at 1.478 HP, running a natural gas compressor. Emissions are controlled by AFR and a Non -Selective Catalytic Reduction System. AIRS ID: 123/0090 Page 1 of 72 NGEngine Version 2009-1 Printed from Electronic Record .. DCP Midstream, LP Permit No. 09WE1136 Issuance 4 Colorado Department of Public Health and Environment Air Pollution Control Division Facility Equipment ID AIRS Point Description D-931 122 One (1) Triethylene glycol (TEG) natural gas dehydration unit (Make: Precision Pipe & Vessel LLC, Model: T-531, Serial Number: CL09-144) with a design capacity of 125 MMSCF per day. This emissions unit is equipped with two (2) (Make: Rotor Tech, Model: GS -3308) electric driven glycol pumps with a limited total combined capacity of 28 gallons per minute. This dehydration unit is equipped with a still vent, glycol flash tank, and reboiler burner (heat provided by hot gases from various combustion processes supplemented by a hot oil heater) covered under AIRS Point ID: 123/0090/123. Emissions from the still vent are routed to an air-cooled condenser, and then to a vapor recovery unit (VRU) that recycles the emissions back to the plant inlet. Emissions from the flash tank are routed directly to the vapor recovery unit (VRU) that recycles the emissions back to the plant inlet. The VRU that recycles the still vent and flash tank emissions has a maximum 2% annual downtime. During VRU downtime, still vent and flash tank emissions are routed to the open flare covered under AIRS Point ID: 123/0090/125. H771 123 Two (2) Devco, HeliFlow, SN: 3431-3, natural gas fired hot oil heaters, heat input design rated at 26.0 MMBTU per hour each. These are equipped with Ultra-Low-NOx combustion systems for minimization of Nitrogen Oxides emissions. Hot oil is used to provide heat to various natural gas processes at the facility including supplemental heat for glycol regeneration reboiler. Only one heater to be operated at a time, the other is to be used as a backup. F-1 125 Plant flare (John Zink, KMI-12-8-WB, SN: 912554) used for blowdowns, amine flash during VRU downtime and dehydrator flash and still vent ;point 122) during VRU downtime. Backup TO 127 Backup thermal oxidizer for amine unit (Point 120) and primary thermal oxidizer glycol dehydrator (Point 122). Emissions from amine still vent are routed to the backup TO when RTO is down and acid gas is not venting for a maximum of 55 days. TURB-1 129 One (1) Solar, Taurus 70, natural gas fired combustion turbine (SN: TBD), rated at 72.7 MMBTU per hour heat input and 9.055 horsepower (HP). This is equipped with Dry Low NOx combustion system for minimizing emissions of Nitrogen Oxides. This source is used for natural gas compression. TURB-2 130 One (1) Solar, Taurus 70, natural gas fired combustion turbine (SN: TBD), rated at 72.7 MMBTU per hour heat input and 9,055 horsepower (HP). This is equipped with Dry Low NOx combustion system for minimizing emissions of Nitrogen Oxides. This source is used for natural gas compression. AIRS ID: 123/0090 Page 5 of 72 4 Enforcement and Compliance History Online Detailed Facility Repo Facility Summary MEWBOURN GAS PLANT 18455 WELD COUNTY RD 35, GILCREST, CO 80623 0 G FRS (Facility Registry Service) ID: 110010691750 EPA Region: 08 Latitude: 40.266583 Longitude: -104.734944 Locational Data Source: RMP Industry: Oil and Gas Extraction; Pipeline Transportation Indian Country: N Enforcement and Compliance Summary I Statute CAA (WA ktRA ln.pt5 DatcofI.ast Ycarsi Impccuon 4 003/3116 Compliance Status Wee No Violation No Violation CAA CWA RCRA 12 -Quarter Violation History Under Development 1 2 3 4 5 6 7 8 9 10 11 12 Quarters No Violation Noncompliance MI Significant Violation Unknown Qin in NC lion- Qtr. in Significant Informal Enlacement Formal Eaforccmcnt Penalties nom Formal Compliance • (of 12 • Violation Action. t 5 car.I .\cttona i 5 %car4. I mnr:cmrnt Actto i. 5 scars; i S s can l: 12 4 MUM* ri.SUu EPA C.J.C. Penalties from EPA Case.; 5 scan, 00 Related Reports Regulatory Information Other Regulatory Reports 4 Vs r Ss" Statute S w'cc ID S.,tcm Inspection T>pc I cad Dale Finding Aicno CLI Co0000000Y12300090 .1l!( Stack lest Slate 11 14 :012 bindings Pass Pollutants Carbon nan.ntJe CLI (V00000008 12100090 . Ilk Stack Test Slate 11 13 :012 Finn's Pass Pollutants .VITROGE:Y O.17DES.aO2 (I L I ('O0000000YI2300090 . i /It Stack Test State 11 I) :012 Findings Pass l'.J/stants Carh.m mon..tt& ( IL I ('0000000.11:300090 ilk Stack Test Stale 11 13 201: bindings Pass Pollutants 1Ol-ITII b' OHCa1Ale CO$lPOt NW CLI (1 70000000412)00090 .Ilk Stack Test State 11 1:201: Findings Pass /'oil twos .VITRQ(ILYO.ITDES NO2 C11 ('O000000GY12300090 III( Stack Test State 1112:0/: 1vnJrngs Pass Pollutants Carbonmamsttale (ILI t'00000000Y1a00090 .1/k Stack Test State 11 12 2012 bon.hngs Pass Pollutants IULITILEORCLIX7t'('n1U'()INDStIVCS$ t:LI ('00000000812300090 .Ilk Stack Test State 1lOY:0!2 FrnJengs Pan Pollutants 1nLITILEORG.INK •('0.I/POtMIStITX'SI ( IL I ( i)00o000GY1:300090 ilk Stack Test Drat: 11 ON 2012 ban.httgs /'an 1'ollntants X/TROGE.V OXIDES VO: (:L I ('O00000008I2100090 . ilk Stack lest Slate 11 ON 201: btn.bngs Pass Pollutants ('arh.m moawmd e (:1.I t'Oo0(Mutioas 100090 .1/k Stack Test State 110720/2 bindings Pan Pollutants IOLITILEORGAN A•COMPOUNDS IltI'Ss 0.1.1 (1)00000001,2300090 .11k Slack Test Slate 11 07 20/: Findings b.nl Pollutants VITRO(bNOXIDES NO2 '0000o0U0YI2300090 ilk Stack Test State 11 072012 Findings Pass Pollutants t'arbon munattJe ('0000000GY1:300090 .11k Stack Test Sral: 1106 :01: Findings Pending Pollutants NITROGEN. OXIDES XO2 (: L I ('00000000Y 12100090 ilk Stack Test State l l 06 201: bindings Pending Pollutants l•(71.1711.11. ORU LVR' ('O.11POI NDS O('Sr t:LI ('O000000GS12300090 .I/k Stack Ten State 11062012 bindings 1'avl'allarsanus I'OLITILEOR0LL\7('(O(IPOLNDSt1O('Sa ( :LI ('00000000.',1:3000150 .1/k Stack lest State II 06 201: maws Pass Pollutants Caftan nwnott.k C.1.1 ('00000000',1:300090 .11K Stack Test State 11 04:0I: Findings l'enJuagPollutants ('arhamtn.in.atdk CI ('00000000',12300090 .1/K Stack Test State 11 06 201. bindings Pan Pollutants VITRO( in' OXIDES NO: t:LI t'000000WY12100090 .Ilk Stack Test State 11 02 2012 bindings l'endhngPollutants l:tin/hcn:ene t 'o00(It00GY1230009U .11k Slack Test State 11 02 2012 Findings Pan Pollutants t'arh.n su..n..r,Je ('.LI ('0000000AY/:30009U .Ilk Stack Test State 1102:01: bindings PassPolltants NITR(XMEVO.17DESNO2 (:LI ('o001JO000s12300090 .1/k Slack lest State 11 02 2012 bindings Pending Pollutants !OLIl/LEOKaIkk'('OJ1PO1 DSsI'O(Si t: L I ('051000000112300090 II!t Stack Test State 11 0::01: binJmgs Pars Pollutants Sulfur Jimmie t:Ll (')00000t1GY12300090 .Ilk Stack Test State 1102 2011 F)aa.Sngs Pending Pollutants T.duene CLI ('00000004'1:300090 .111? Stack Test State 1102:0/: bindings !Jesting Pollutants !Inane (tLI ('O000000GY12300090 .Itk Stack Test State 11 02 2012 bindings PendingP.rl/utants ken:ene (al (100000000812300090 . Ilk Stack Test State 11 0:101: b in.hngs Pending Pollutants .!Meng (:LI ('O0U(000GYI:300090 .11k Stack lest Stale 110::u1: bindings Pass Pollutants II;Jrigenndli.k CAA (. XXXXXXE!tI2360040 AIR 1'C'L OI-Sue slate nx 24 2(II: Entries in italics are not considered inspections in official counts. Compliance Summary Data Statute Saut:c II) CAA C'(XMll70(tstati.no ttwo CWA ('UR•MY)t:R RCRA C01)140I$IWu (wreen: SN(' (sspntcm N.nwntpltnnctl IIPVtIh$hMonts %•wlatwnt I)c'cnp( ion ('urrcnt As of t/trs In NC iNon-C'omphanca tot 12) Yes Addis -Stall 01(15/24,17 do Iii :I :u 17 No r1 IS 2('I7 13 u Three Year Compliance Status by Quarter Slatutc Prataan. Pollutant/Vtalalt..n T.1.: CAA (Source ID: C0(00004J08123(N8)90) Facitlh-Lesel Status QTR I QTR 07/01-00 .3014 10111.12_ 11 14 QTR % 44 I 1 Q R S QTR O QTR 7 QTR a QTR o QTR 10 QT 01111_ h.Fnl- 07111. Ittnl. (II III- u.11'I- 07/01- 10/01- 01 of ii IS It. 3u 15 na ;0 15 12 tl IS (rt,:l l() tti.3o,Its /0(30/16 I?!3I/16 (13/ NPV HPV HPV HPV HPV HPV HPV HPV HP%' HAI H r. DCP Midstream Mewbourn Gas Processing Facility Screen Shot of EPA ECHO Website July 16, 2017 Envuonmental Topics Laws & Regulations About EPA ECH Enforcement and Compliance History Online YOU are here Horne • Detailed Facility Report 0 Detailed Facility Report upend A4 — Co.:apse Al. Emplane Facilities Create Maps Search EPA.gov Mdyee Tint Serene ed Toots Resources O He ECHO Gee Login Contact U Report Vrolat.on A Report Data tiro. ' i I DW DKLonery Print O Nttp Facility Summary V Enforcement and Compliance Summary = r Statute Una V Years) a ' tine of Lam crapestom Cke S iS :::ail CWA 5CR+ Compliance Status Carnpbanct 3tata >Kni€crt Voin c- •ie VlolS n 140 Violation gets ++ WC. !of� t MEWBOURN GAS PLANT 18455 WELD COMA' RD 35, GILCREST, CO 80623 r,) FRS to. 110010691750 EPA Region 08 Latitude: 40.266583 Longitude: •104.734941 Locational Crate Source RMP Industry Oil and Gas Extraction, Pipeline Transportation Indian Country. N Qtn in LCn•T•arK Violation anAotrnat tnla.nnrera means Ordeal IPACates a yes, Gonna( aref rcereent A<roO" ,a ,nary 4 ►emdeea from Formal enlorce.nem Am on (Sian) araiyra from EPA Cases !3 years) Displays an indication of the most recent compliance status for each statute under which the facility is regulated. Status codes include: • No Violation — Blue • Noncompliance - Yellow -orange • Significant Violation — Red • No Information/Unknown/Not Available - Gray DCP Midstream Mewbourn Gas Processing Facility Screen Shot of EPA ECHO Website July 17, 2017 Compliance Summary Data StJ'VIP Source ID CWA RCRA C00000000812300090 COD149181646 Current SNCIHPV [k%rq.t�on 1c Acins Sate Current As of 071:...:. 03.31./2011 37; Qtrs In NC (0t 12) Three Year Compliance Status by Quarter Program/Pollutant/Violation Type CM (Source ID: 000000000812300090) Facility Level Status CM CM CM CM CM Agesci TYPe HPV CO HPV CO HPV CO HPV History Prowaes CMMACT, CMNSPS, CAAPSD, CMSIP, CMTVP CANMACT,CAANSPS,CAAPSD, CMSIP, CAMP CMMACT. CMNSPS, CAAP50, CMS1P, CAATVP tIPV CO GAWPS, CMSP, CAMP FRV CO CMIMCT, CMNSPS, CAAPSD, CAASIP, CMTVP PoYtRartb VOLATILE ORGANIC COMPOUNDS (VOCS) QTR 1 07/01- 09/30/14 Unaddr-Stat 11/05/2011 NITROGEN OXIDES NO2 02/01/2013 VOLATILE ORGANIC COMPOUNDS (VOCS) 10/08/2012 NITROGEN COXES NO2 09/17/2100 VOLATILE ORGANIC COMPOUNDS (VOCS) QTR2 10/01- 12/31/14 HPV >ao >0, 11/08/2014 QTR 3 01101- 03/31115 HPV QTR 4 04/01- 06/30/15 HPV XP) ao> SOS QTR 5 07/01- 09/30/15 HPV QTR 6 10/01- 12/31/15 HPV »> auw >>> QTR 7 01/01- 03/31/16 HPV QTR 8 04/01- 06/30/16 HPV QTR 9 07/01- 09/30/16 QTR 10 10/01- 12/31/16 QTR 11 01101 03/31/17 co QTR 12 04/01. 06/30/17 Addrs-State Addrs-State Addrs-State Addrs-State Addrs-State Addrs-State »> a» >>> >e> >>> NiskeicVlobtions CM CM CM MAC1 (SECTION 63 NESHAPS) NSPS PSC CM SIP V HPV Vic V HPV Vie V-HPVVa V+IPVVIo V HPVVro V HPV %/to V-HPV Vro V-HPV Vto The HPV designation is removed for a given source when all federal and state administrative and judicial action against the source is complete, the source has completed all requirements under the consent decree or final order including payment of all penalties and completion of supplemental environmental projects, and the source has been confirmed to be complying with the CAA. The High Priority Violation (HPV) flag is reported in ICIS-Air, as of the last update. A 'Yes' appears in the column to indicate that the facility has HPV status. The status of "Addressed" indicates that a formal enforcement action has been taken against the facility but its violations have not yet been resolved, or that a decision not to take a formal action has been made. For the CAA, violations are not considered resolved until the source is in full physical compliance and all penalties are paid. "Unaddressed" indicates that the facility's violations have not yet been addressed with a formal enforcement action or the decision to do so has not yet been made. EPA ECHO Help Menu & Definitions Compliance Status Displays an indication of the most recent compliance status for each statute under which the facility is regulated. Status codes include: • No Violation — Blue • Noncompliance - Yellow -orange • Significant Violation — Red • No Information/Unknown/Not Available - Gray Significant Non -Compliance Definitions by Statute Air High Priority Violation (HPV) Definition The Air program uses the term HPV. HPV designations are made according to the ssuance of Policy on Timely and Aporopnate Enforcement Response to High Priority Violations The following criteria can trigger HPV status for a violation that occurs at a Title -V major source or a non -Title -V major source subject to a Compliance Monitoring Strategy (CMS) plan: • Failure to obtain a New Source Review (NSR) permit and/or install Best Available Control Technology or Lowest Available Emission Reductions for any new major stationary source or major modifications at a major stationary source. • Exceedance of a major stationary source annual emission threshold, as defined in the NSR regulations, by a synthetic minor stationary source. • Violation of the any emission limitation, emission standard, or operating parameter that has continued for at least seven days, but not necessarily continuous, according to: Title I, Part C or D, of the Clean Air Act and implementing regulations, Standards of Performance for New Sources (NSPS) Part 60, or National Emission Standards for Hazardous Air Pollutants (NESHAP) Parts 61 and 63. • Violations of federally enforceable work practices, testing requirements. monitoring requirements, recordkeeping or reporting that substantially interferes with enforcement or determination of a facility's compliance requirements. • Violations specifically identified and communicated to enforcement agencies by the U.S. EPA Air Enforcement Division Director, or as mutually agreed upon between the enforcement agency and corresponding EPA Region. The HPV designation is removed for a given source when all federal and state administrative and judicial action against the source is complete. the source has completed all requirements under the consent decree or final order including payment of all penalties and completion of supplemental environmental projects. and the source has been confirmed to be complying with the CAA. The High Priority Violation (HPV) flag is reported in ICIS-Air, as of the last update. A 'Yes' appears in the column to indicate that the facility has HPV status. Below is a list of violation codes within ICIS-Air that translate to HPV status. • Addrs-EPA - Addressed, EPA Lead • Addrs-State - Addressed, State Lead • Addrs-Local - Addressed, Local Lead • Unaddr-EPA - Unaddressed, EPA Lead • Unaddr-State - Unaddressed. State Lead • Unaddr-Local - Unaddressed, Local Lead The status of "Addressed" indicates that a formal enforcement action has been taken against the facility but its violations have not yet been resolved, or that a decision not to take a formal action has been made. For the CAA, violations are not considered resolved until the source is in full physical compliance and all penalties are paid. "Unaddressed" indicates that the facility's violations have not yet been addressed with a formal enforcement action or the decision to do so has not yet been made. It1t'2tidy, tip it 11, IUL/ O..•U I11•t t..tSIVIODU It,. '.Vt11)JItcttt-C t 1Ct41%ttta, At1U .111VCIILtI y .3yat.cnl I *a ••••• .. V. . • Enforcement Case Summary Report Without Comm ts Case# Case Description 2012-057 Aborted (failed) stack test Action Achieved EFV2 3/15/2017 Case# Case Description • Penalty AIRS ID Plant/Location 123-0090 DCP MIDSTREAM, LP- MEWBOURN AIRS ID Plant/Location 2013-035 Opacity and emission limit violations 123-0090 DCP MIDSTREAM, LP- MEWBOURN Action Achieved Penalty EFV2 3/15/2017 Case# Case Description 2013-036 Failed stack tests Action Achieved Penalty EFV2 3/15/2017 Case# Case Description 2015-115 Reg. 7 violations MEP Action Achieved Penalty EFV2 2/6/2017 AS 1/27/2017 19,600 Case# Case Description 2016-085 Failed stack test - NOx Action Achieved Penalty EFV2 1/10/2017 Case# Case Description 2016-105 Failed to conduct compliance testing Action Achieved Penalty EFV2 1/11/2017 AS 1/4/2017 15,300 Case# Case Description 2016-106 Testing, monitoring and reporting violations AIRS ID Plant/Location 123-0090 DCP MIDSTREAM, LP- MEWBOURN AIRS ID Plant/Location 031-2105 ENCANA - REG 7 & OOOO REPORTING AIRS ID Plant/Location 113-0015 CCI PARADOX UPSTREAM - ANDY'S MESA CS AIRS ID Plant/Location 777-3427 OLDCASTLE DBA 4 CORNERS - CO CRUSHER #2 AIRS ID Plant/Location 037-0098 OLDCASTLE SW GROUP - 11589 HWY 6 Case Opened Case Closed 4/2/2012 .0 3/15/2017 Case Opened 3/1/2013 Case Closed 3/15/2017 Case Opened Case Closed 3/1/2013 3/15/2017 Case Opened Case Closed 12/23/2015 2/6/2017 Case Opened 4/4/2016 Case Closed 1/10/2017 Case Opened Case Closed 5/16/2016 1/11/2017 Case Opened Case Closed 5/16/2016 1/11/2017 Action Achieved Penalty ea lit 41, ,40* • r I ` • • ~`• afl�, • • •• -'••• 1 r -•��. • ,_�+r + ••r�� • �� " ♦a tale ale Oa •ar- s • • ` MONIS rdp• ... •f•r+. .�1lb IMS , • ear•• ',•,• �• • 4, . , � • • ass op s • OAP Y aale a Oita taliqp •y al l% •.• , a-= �.r - ' . ��.••• !' -ilk ' C - .« 4y . tiats... a. "it�.rr. tfe�„ _ • , " "vh��r�:. • _yam 1•w�►� rtC� * sW♦ 'r tev. �.4.,a,.; t,. tot;so �.. ►1i!!�.� - _.•�Y.. z. .. '� �;, _ •may'.'•c'y � :' i 1625 Broadview Suite 2200 Denver, Colorado80= Tot (303) 228-4000 Fax: (303) 228.4280 n blenmoor July 17, 2017 a?, noble gy Honorable Members of the Weld County Commission PO Box 758 Greeley, CO 80631 Re: Docket #2017-42 PL 0439 Dear Commissioners: Noble Energy offers strong support for the DCP Midstream application for a Use by Special Review permit: DCP Midstream LNG gas facilities in Gilcrest (Docket #2017-42 PL 0439). This permit will allow expansion of the processing plant at Mewbourn, which is a necessary addition to the gas processing capacity in the DJ Basin. Construction will have many important benefits for continuing oil and gas development in Weld County. The 200 Mmcf/day expansion in gas processing capacity will dramatically improve line pressure, which has a twofold beneficial impact. First, lower line pressures are good for safety. High line pressures increase risk. Second, lower line pressures will improve the ability of upstream companies to produce liquids, which benefits investment, employment and tax revenue. The chart referenced below provides an estimate for the amount of associated crude oil that can be brought to sales based on increasing gas processing capacity. The amount of crude oil impacted by the new gas processing capacity depends on the Gas to Oil (GOR) ratio of producers selling into the DCP system. For Noble Energy, our average GOR in the impacted area is roughly 6 mcf per barrel of oil. So in that case, an addition of 200,000 mcf per day of gas processing capacity would have the effect of lifting capacity constraints on 33,333 barrels of oil per day. When the Lucerne 2 plant was completed, Noble Energy experienced an almost instant increase in oil production. Mew 3 Plant Nameplate Capacity Gas (Mcf/d) GOR Associated Crude Oil (Bbld) Notes 200,000 2 200,000 4 200,000 6 200,000 8 200,000 10 200,000 12 200,000 14 200,000 16 100,000 50,000 33,333 25,000 20,000 16,667 14,286 12,500 NBL Mustang Avg With that calculation in mind, a change of 33,333 bbls/day of oil would have an economic impact of nearly $1.5 million per day in economic activity in Weld County, at $45/bbl oil, or $547 million per year. That could equate to increases in local and county ad valorem taxes of between $20-35 million per year, depending on where the production is and the applicable mill v levies in the tax districts. It also provides a significant number of direct, indirect and induced jobs. Thank you for your attention to this matter. Noble Energy, Inc. 1625 Broadway, Suite 2200 Denver, CO 80202 5MJUSRI 7-83-542 Amendments to the Resolution • New COA 1.B. o An Improvements and Road Maintenance Agreement is required for offsite improvements at this location during the period of construction. Road maintenance including, but not limited to dust control, damage repair, specified haul routes and future traffic triggers for improvements will be included. • New COA 1.C o A landscaping/screening plan to mitigate visual impacts shall be submitted to the Department of Planning Services after consultation with the area property owners. "Area property owners" includes all residents within t/2 mile of the property and all persons who request such notification. • New COA 1.D o A lighting plan shall be submitted to the Department of Planning Services, which shall require all lights to be turned off during nighttime hours, except for walkways and as required by emergency maintenance, maintenance requiring plant -wide shutdown, and as other emergencies demand. • New COA 1.E o A Communications Plan, shall be submitted to the Department of Planning Services, after consultation with the area property owners. Such Communication Plan shall require community meetings with the area property owners, as well as an online communication presence. • New COA 1.F o A Noise Mitigation Plan shall be submitted to the Department of Planning Services. • Updated COA 6.A. o New third sentence: The plan shall include notification to area property owners. • Updated D.S. 3 o New second sentence: "Except for maintenance that requires complete plant shutdown, construction and routine maintenance shall occur during daylight hours." • Updated D.S. 4 o The number of employees is limited to twenty (20). • Updated D.S. 5. o "Co -location of other antennas by other service providers shall be allowed in accordance with the Operator's safety requirements." • New D.S. 7 o The Operator shall comply with the approved Communications Plan submitted to the Department of Planning Services. • New D.S. 8 o The Operator shall comply with the approved Landscaping/Screening Plan submitted to the Department of Planning Services. • New D.S. 9 o The Operator shall comply with the approved Lighting Plan submitted to the Department of Planning Services. • Updated D.S. 16 o The facility shall not exceed 65 db(A) as measured in accordance with the Light Industrial standard as set forth in C.R.S. 25-12-103. • New D.S. 17 o The Operator shall comply with the approved Noise Mitigation Plan submitted to the Department of Planning Services. • Update D.S. 23 o Add another sentence: The Operator shall notify the Weld County Department of Public Health and Environment of all Compliance Orders on Consent (COC) or other enforcement actions by the Colorado Department of Public Health and Environment within sixty (60) days. • New D.S. 39 o For any minor amendment to the USR permit, the Operator shall notify all property owners within 500 feet of the property. If more than 30% of such property owners object, the amendment shall be considered a major amendment requiring approval by the Board of County Commissioners. Esther Gesick From: Sent: To: Cc: Subject: Esther, Julie Cozad Wednesday, August 2, 2017 5:35 PM Jost, David M; rockyrissler@gmail.com Barbara Kirkmeyer; Steve Moreno; sconway@weldgov.co; Mike Freeman; Kim Ogle; Tom Parko Jr.; Troy Swain; Esther Gesick RE: Mewbourn Plant Expansion noise and light mitigation Please add this information to the official record. Thanks, Julie Julie Cozad Weld County Commissioner, District 2 1150 O Street P.O. Box 758 Greeley, CO 80632 Office: 970-336-7204 Cell: 970-515-2424 Fax: 970-336-7233 icozad(aweldgov.com Confidentiality Notice: This electronic transmission and any attached documents or other writings are intended only for the person or entity to which it is addressed and may contain information that is privileged, confidential or otherwise protected from disclosure. If you have received this communication in error, please immediately notify sender by return e-mail and destroy the communication. Any disclosure, copying, distribution or the taking of any action concerning the contents of this communication or any attachments by anyone other than the named recipient is strictly prohibited. From: Jost, David M[mailto:DMJost@dcpmidstream.com] Sent: Wednesday, August 02, 2017 5:32 PM To: rockyrissler@gmail.com Cc: Julie Cozad <jcozad@weldgov.com>; Barbara Kirkmeyer <bkirkmeyer@weldgov.com>; Steve Moreno <smoreno@weldgov.com>; sconway@weldgov.co <sconway@weldgov.co>; Mike Freeman <mfreeman@weldgov.com>; Kim Ogle <kogle@weldgov.com>; Tom Parko Jr. <tparko@weldgov.com>; Troy Swain <tswain@weldgov.com> Subject: RE: Mewbourn Plant Expansion noise and light mitigation Rocky, I am just getting back from vacation and working through a lot of emails. I hope to have a date by Friday on our next meeting. We are working on all the current items as required by the County Commissioners. -David 1 From: rockyrissler@gmail.com[mailto:rockyrissler@gmail.com] Sent: Thursday, July 27, 2017 11:52 AM To: Jost, David M <DMJost@dcpmidstream.com> Cc: jcozad@weldgov.com; bkirkmever@weldgov.com <bkirkmeyer@weldgov.com>; smoreno@weldgov.com <smoreno@weldgov.com>; sconwav@weldgov.co <sconwav@weldgov.co>; mfreeman@weldgov.com <mfreeman@weldgov.com>; kogle@weldgov.com <kogle@weldgov.com>; tparko@weldgov.com <tparko@weldgov.com>; tswain@weldgov.com <tswain@weldgov.com> Subject: Mewbourn Plant Expansion noise and light mitigation Good morning David, I am curious about when DCP is planning to meet with the neighborhood group to discuss plans for the berm and plans for a T -Wall on the East side of plant . We also would like a date when the plant will begin "dark skies". I know you are anxious to get the construction under way and I'm fairly sure that is where your energy is being spent currently. As opposed to what you might believe, I too am anxious for the construction to start (so it will end!) and would like to have a definite plan in place. I believe meeting with us again was mandated by the County Commissioners before construction begins. Please let me know a few dates that work for your group and I will check with my group to pick a date and time that works for all of us. We generally meet on Wednesdays at 7 pm if you could make that work on your end. Thank you for your continued efforts working with us. Rocky Rissler 970 518 4784 Sent from Mail for Windows 10 2 Hello