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Home My WebLink About20141071.tiff STATE OF COLORADO John W.Hickenlooper,Governor - Larry Wolk,MD,MSPH /(Dv oo�0, .8 Executive Director and Chief Medical Officer e a r,7 0', Dedicated to protecting and improving the health and environment of the people of Colorado VN.r(—• : , 4300 Cherry Creek Dr.S. Laboratory Services Division ' ,�"""A/ Denver,Colorado 80246-1530 8100 Lowry Blvd. eie Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department Located in Glendale,Colorado (303)692-3090 of Public Health www.colorado.gov/cdphe and Environment Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 RECEIVED March 31, 2014 APR 0 3 2014 Dear Sir or Madam: COMMISSIONERS On April 3, 2014, the Air Pollution Control Division will publish a public notice for DCP Midstream LP— Sullivan Compressor Station, in the 1 he Grccle>. Tribune. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the date the public notice is published. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health & Environment APCD-SS-B 1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards. 1 Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure • ?i�.bL LI I�eu C�' �{ W(E.�, G.a+ �.M, D•D) 2014-1071 ! 11 YLL .1•&) ttt (P•e)) ,1 I / STATE OF COLORADO John W.Hickenlooper,Governor Larry Walk,MD, MSPH ,oF cozoq Executive Director and Chief Medical Officer Fe Dedicated to protecting and improving the health and environment of the people of Colorado . 7.rn e3. 011 • 4300 Cherry Creek Dr.S. Laboratory Services Division .1876 Denver,Colorado 80246-1530 8100 Lowry Blvd. Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department Located in Glendale,Colorado (303)692-3090 of Public Health www.colorado.gov/Ldphe and Environment Website Title: DCP Midstream LP— Sullivan Compressor Station — Weld County Released To: The Greeley Tribune On: March 31,2014 Published: April 3, 2014 PUBLIC NOTICE OF A PROPOSED PROJECT OR ACTIVITY WARRANTING PUBLIC COMMENT Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: DCP Midstream LP Facility: Sullivan Compressor Station Natural gas compressor station SWSE Sec 17, T7N, R62W Weld County The proposed project or activity is as follows: The source proposes to modify an existing 50 MMSCF per day natural gas compression station. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B. Section III.C.I.a (25 tpy in a non-attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis,and a draft of Construction Permit 11 WE1478 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at www.colorado.gov/cdphe/AirPublicNotices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such comment must be submitted in writing to the following addressee: Carissa Money Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B 1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303)692.3150 . *� CONSTRUCTION PERMIT PERMIT NO: 11WE1478 WE1 478 Issuance 2 DATE ISSUED: ISSUED TO: DCP Midstream, LP THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural gas compression facility, known as the Sullivan Compressor Station, located in SWSE Section 17, Township 7N, Range 62W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Description Equipment ID Point One (1)Waukesha, Model L7044GS1, Serial Number C- 17064/1, natural gas-fired, turbo-charged, 4SRB reciprocating internal combustion engine, site rated at 1680 C-189 001 horsepower at 1200 RPM. This engine shall be equipped with non-selective catalytic reduction (NSCR) system and air-fuel ratio control. This emission unit is used for natural gas compression. One (1)Waukesha, Model L7044GS1, Serial Number C12870/2, natural gas-fired, turbo-charged, 4SRB reciprocating internal combustion engine, site rated at 1680 C-190 002 horsepower at 1200 RPM. This engine shall be equipped with non-selective catalytic reduction (NSCR) system and air-fuel ratio control. This emission unit is used for natural gas compression. One (1)Waukesha, Model L7044GS1, Serial Number TBD, natural gas-fired, turbo-charged, 4SRB reciprocating internal C-198 003 combustion engine, site rated at 1680 horsepower at 1200 RPM. This engine shall be equipped with non-selective catalytic reduction (NSCR) system and air-fuel ratio control. This emission unit is used for natural gas compression. AIRS ID: 123/9009 Page 1 of 27 NGEngins Version 2009-1 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1478 Air Pollution Control Division Issuance 2 Facility AIRS Description Equipment ID Point One (1)Triethylene glycol (TEG) natural gas dehydration unit(make, model, serial number: not submitted)with a design capacity of 50 MMscf per day. This emissions unit is equipped with either one (1)electric pump or one (1)gas injection pump (make, model: not submitted) with a design D-1 005 capacity of 24 gallons per minute. This unit is equipped with a flash tank, reboiler and still vent. Emissions from the still vent are routed to a condenser and then to the fuel gas line of the reboiler. Emissions from the flash tank are routed to a vapor recovery unit (VRU)which returns vapors back to the inlet of the compressor station. FUG 006 Equipment leaks (fugitive VOCs) from a natural gas compression facility. One (1)Waukesha, Model L7044GS1, Serial Number to be determined, natural gas-fired, turbo-charged, 4SRB reciprocating internal combustion engine, site rated at 1680 C-199 008 horsepower at 1200 RPM. This engine shall be equipped with non-selective catalytic reduction (NSCR) system and air-fuel ratio control. This emission unit is used for natural gas compression. One (1)Waukesha, Model L7044GS1, Serial Number C- 16762/1, natural gas-fired, turbo-charged, 4SRB reciprocating internal combustion engine, site rated at 1680 27TEMP 009 horsepower at 1200 RPM. This engine shall be equipped with non-selective catalytic reduction (NSCR) system and air-fuel ratio control. This emission unit is used for natural gas compression. The engines addressed under AIRS Points 001 through 003, 008 and 009 may be replaced with another engine in accordance with the temporary engine replacement provision or with another Waukesha L7044GS1 engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. 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. YOU MUST notify the APCD no later than fifteen days after commencement of the permitted operation or activity by submitting a Notice of Startup (NOS) form to the APCD. The Notice of Startup (NOS) form may be downloaded online at www.cdphe.state.co.us/ap/downioadtorms-htmi. Failure to notify the APCD of startup of AIRS ID: 123/9009 Page 2 of 27 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1478 Air Pollution Control Division Issuance 2 the permitted source is a violation of AQCC Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) after commencement of operation, compliance with the conditions contained on this permit shall be demonstrated to the Division. It is the permittee's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). 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 No. 3, Part B, Section III.E.) 5. The manufacturer, model number, and serial number of the subject equipment shall be provided to the Division within fifteen days (15) after commencement of operation. This information shall be included on the Notice of Startup (NOS) submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Monthly Limits: Facility AIRS Pounds per Month Emission Type Equipment ID Point NO, VOC CO C-189 001 1,378 1,929 2,756 Point C-190 002 1,378 1,929 2,756 Point C-198 003 1,378 1,929 2,756 Point D-1 005 2,842 Point FUG 006 5,266 Fugitive C-199 008 1,378 1,929 2,756 Point 27TEMP 009 1,378 1,929 2,756 Point AIRS ID: 123/9009 Page 3 of 27 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1478 Air Pollution Control Division Issuance 2 Facility AIRS Pounds per Month' Emission Type Equipment ID Points NO, VOC CO C-189 001 Point C-190 002 Point C-198 003 5,512 7,716 11,024 Point C-199 008 Point 27TEMP 009 Point Monthly limits are based on a 31-day month. Facility-wide emissions of each individual hazardous air pollutant shall be less than 1,358.9 lb/month. Facility-wide emissions of total hazardous air pollutants shall be less than 3,397.3 lb/month. Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO VOC CO Emission Type C-189 001 8.1 11.4 16.2 Point C-190 002 8.1 11.4 16.2 Point C-198 003 8.1 11.4 16.2 Point D-1 005 16.7 Point FUG 006 31.0 Fugitive C-199 008 8.1 11.4 16.2 Point 27TEMP 009 8.1 11.4 16.2 Point Facility AIRS Tons per Year' Emission Type Equipment ID Point NO, VOC CO C-189 001 Point C-190 002 Point C-198 003 32.4 45.6 64.8 Point C-199 008 Point 27TEMP 009 Point 'The monthly and annual emissions limits contained in these tables represent the combined allowable emissions for all five emissions points combined. DCP's emissions for these five points are limited to the equivalent of four engines operating at 100%annual capacity. See "Notes to Permit Holder #4 for information on emission factors and methods used to calculate limits. AIRS ID: 123/9009 Page 4 of 27 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1478 Air Pollution Control Division Issuance 2 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 20.0 tpy. During the first twelve (12) months of operation, compliance with both the monthly and yearly emission limitations shall be required. After the first twelve (12) months of operation, compliance with only the yearly limitation shall be required. Compliance with the synthetic minor status of this facility shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)from each emission unit, on a rolling (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate monthly emissions and keep a compliance record on site, or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all emission units, requiring an APEN, at this facility. 8. 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 No.3, Part B, Section III.E.) • Facility AIRS Pollutants Equipment Point Control Device Controlled ID C-189 001 Non-selective catalytic reduction system and air/fuel NON, VOC, and CO ratio controller C-190 002 Non-selective catalytic reduction system and air/fuel NON, VOC, and CO ratio controller C-198 003 Non-selective catalytic reduction system and air/fuel NON,VOC, and CO ratio controller Vapor recovery unit, Condenser, and Combustion D-1 005 VOC device (detailed in condition 17) FUG 006 RACT LDAR VOC C-199 008 Non-selective catalytic reduction system and air/fuel NON,VOC, and CO ratio controller 27TEMP 009 Non-selective catalytic reduction system and air/fuel NON,VOC, and CO ratio controller PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the applicant and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Annual Monthly Limit Equipment Point Process Parameter Limit (31 days) ID 128.8 10.9 C-189 001 Consumption of natural gas as a fuel MMscf/yr MMscf/month AIRS ID: 123/9009 Page 5 of 27 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1478 E1478 Air Pollution Control Division Issuance 2 C-190 002 Consumption of natural gas as a fuel 128.8 10.9 MMscf/yr MMscf/month 8 10.9 C-198 003 Consumption of natural gas as a fuel cf MMscf/ m scf/yr MMs /month D-1 005 Natural gas throughput 18,250 1,550 MMscf/yr MMscf/month FUG 006 Not applicable C-199 008 Consumption of natural gas as a fuel 128'8 10.9 MMscf/yr MMscf/month 27TEMP 009 Consumption of natural gas as a fuel 128.8 10.9 MMscf/yr MMscf/month Facility AIRS Annual Monthly Limit Equipment Point Process Parameter Limit2 (31 days)2 ID C-189 001 C-190 002 Consumption of natural gas as fuel for 515.2 43.8 all 5 compressor engines. Total run C-198 003 MMscf/yr MMscf/month time shall not exceed 35,040 total total C-199 008 compressor engine-hours per year. 27TEMP 009 The monthly and annual process limits contained in these tables represent the combined allowable emissions for all five emissions points combined. DCP's fuel consumption and hours of operation for these five points are limited to the equivalent of four engines operating at 100% annual capacity. During the first twelve (12) months of operation, compliance with both the monthly and yearly consumption limitations shall be required. After the first twelve (12) months of operation, compliance with only the yearly limitation shall be 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. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. 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). 11. Visible emissions shall not exceed twenty percent(20%)opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.1. &4.) 12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) AIRS ID: 123/9009 Page 6 of 27 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1478 Air Pollution Control Division Issuance 2 Waukesha Engines (AIRS Points 001 through 003, 008 and 009) 13. Each engine shall be equipped with non-selective catalytic reduction (NSCR) system and air-fuel ratio control. The control system shall reduce uncontrolled emissions of NOx, VOC and CO from each engine to the emission levels listed in Condition 7, above. Operating parameters of the control equipment are identified in the operation and maintenance plan. (Reference: Regulation No.3, Part B, Section III.E.) 14. 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. 15. This equipment is subject to the control requirements for natural gas-fired reciprocating internal combustion engines under Regulation No. 7, Section XVII.E (State only enforceable). The owner or operator of any natural gas-fired reciprocating internal combustion engine that is either constructed or relocated to the state of Colorado from another state after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Maximum Engine Construction or Emission Standard in g/hp-hr HP Relocation Date NOx CO VOC <100HP Any N/A N/A N/A ≥100HP and January 1, 2008 2.0 4.0 1.0 <500HP January 1, 2011 1.0 2.0 0.7 ≥500HP July 1, 2007 2.0 4.0 1.0 July 1, 2010 1.0 2.0 0.7 Note: Per Regulation No. 7, Section XVII.B.4, internal combustion engines that are subject to an emissions control requirement in a federal maximum achievable control technology ("MACT") standard under 40 CFR Part 63, a Best Available Control Technology ("BACT") limit, or a New Source Performance Standard under 40 CFR Part 60 are not subject to this Section XVII. TEG Dehy(AIRS Point 0051 16. Compliance with the emission limits in this permit shall be demonstrated by running the GRI GlyCalc model version 4.0 or higher on a monthly basis using the most recent wet gas analysis and recorded operational values (including gas throughput, lean glycol recirculation rate, VRU downtime and other operational values specified in the O&M Plan). Recorded operational values, except for gas throughput, shall be averaged on a monthly basis for input into GRI GlyCalc. 17. This unit shall be configured such that the flash tank vapors are routed to the VRU to be recycled to the compressor station inlet and still vent vapors are routed to the fuel gas line of the reboiler. The control system shall reduce uncontrolled emissions of VOC from the TEG dehydration unit to the emission levels listed in Condition 7, above. Operating AIRS ID: 123/9009 Page 7 of 27 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1478 Air Pollution Control Division Issuance 2 parameters of the control equipment are identified in the operation and maintenance plan. (Reference: Regulation No.3, Part B, Section III.E.) 18. 100% of emissions that result from the flash tank associated with this dehydrator shall be recycled to the compressor station inlet and recompressed. 19. This source shall be limited to a maximum lean glycol recirculation pump rate as calculated per 40 CFR, Part 63, Subpart HH, §63.764 (d)(2)(i). If the owner or operator requests an alternate circulation rate per §63.764(d)(2)(ii), then maximum recirculation rate shall not exceed 24.0 gallons per minute. The owner or operator shall maintain monthly records of the actual lean glycol recirculation rate and make them available to the Division for inspection upon request. 20. This equipment is subject to the control requirements for glycol natural gas dehydrators under Regulation No. 7, Section XII.H. Beginning May 1, 2005, uncontrolled actual emissions of volatile organic compounds from the still vent and vent from any gas- condensate-glycol (GCG) separator (flash separator or flash tank), if present, shall be reduced by at least 90 percent through the use of air pollution control equipment. This source shall comply with all applicable general provisions of Regulation 7, Section XII. 21. This equipment is subject to the control requirements for glycol natural gas dehydrators under Regulation No. 7, Section XVII.D (State only enforceable). Beginning May 1, 2008, uncontrolled actual emissions of volatile organic compounds from the still vent and vent from any gas-condensate-glycol (GCG) separator (flash separator or flash tank), if present, shall be reduced by an average of at least 90 percent through the use of air pollution control equipment. This source shall comply with all applicable general provisions of Regulation 7, Section XVII. 22. This source is subject to the TEG dehydrator area source requirements of 40 CFR, Part 63, Subpart NH - National Emission Standards for Hazardous Air Pollutants for Source Categories from Oil and Natural Gas Production Facilities including, but not limited to, the following: • §63.760—Applicability and designation of affected source o §63.760 (f) -The owner or operator of an affected major source shall achieve compliance with the provisions of this subpart by the dates specified in paragraphs (f)(1) and (f)(2) of this section. The owner or operator of an affected area source shall achieve compliance with the provisions of this subpart by the dates specified in paragraphs (f)(3) through (f)(6) of this section. • §63.760 (f)(6) -The owner or operator of an affected area source that is not located in an Urban-1 county, as defined in §63.761, the construction or reconstruction of which commences on or after July 8, 2005, shall achieve compliance with the provisions of this subpart immediately upon initial startup or January 3, 2007, whichever date is later. • §63.764-General Standards AIRS ID: 123/9009 Page 8 of 27 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1478 Air Pollution Control Division Issuance 2 o §63.764 (d)(2) —Each owner or operator of an area source not located in a UA plus offset and UC boundary(as defined in §63.761) shall comply with the provisions specified in paragraphs (d)(2(i) through (iii)of this section. • §63.764 (d)(2)(i) — Determine the optimum glycol circulation rate using the following equation: L„„ =LIS*3.0 gal TEG*'F*(! 0)) IbH,o v24hr/day Where: LOFT = Optimal circulation rate, gal/hr. F = Gas flowrate (MMSCF/D) I = Inlet water content (lb/MMSCF) O = Outlet water content (lb/MMSCF) 3.0 = The industry accepted rule of thumb for a TEG-to water ratio (gal TEG/IbH2O) 1.15 =Adjustment factor included for a margin of safety. • §63.764 (d)(2)(ii) — Operate the TEG dehydration unit such that the actual glycol circulation rate does not exceed the optimum glycol circulation rate determined in accordance with paragraph (d)(2)(i) of this section. If the TEG dehydration unit is unable to meet the sales gas specification for moisture content using the glycol circulation rate determined in accordance with paragraph (d)(2)(i), the owner or operator must calculate an alternate circulation rate using GRI— GLYCaIcTM, Version 3.0 or higher. The owner or operator must document why the TEG dehydration unit must be operated using the alternate circulation rate and submit this documentation with the initial notification in accordance with §63.775(c)(7). • §63.764 (d)(2)(iii) — Maintain a record of the determination specified in paragraph (d)(2)(ii) in accordance with the requirements in §63.774(f) and submit the Initial Notification in accordance with the requirements in §63.775(c)(7). If operating conditions change and a modification to the optimum glycol circulation rate is required, the owner or operator shall prepare a new determination in accordance with paragraph (d)(2)(i) or (ii) of this section and submit the information specified under§63.775(c)(7)(ii) through (v). • §63.774 - Recordkeeping Requirements o §63.774 (b) - Except as specified in paragraphs (c), (d), and (f) of this section, each owner or operator of a facility subject to this subpart shall maintain the records specified in paragraphs (b)(1) through (11) of this section: • §63.774 (b)(1) - The owner or operator of an affected source subject to the provisions of this subpart shall maintain files of all information (including all reports and notifications) required by this subpart. The files shall be retained for at least 5 years following the date of each AIRS ID: 123/9009 Page 9 of 27 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1478 Air Pollution Control Division Issuance 2 occurrence, measurement, maintenance, corrective action, report or period. • §63.774 (b)(1)(i) — All applicable records shall be maintained in such a manner that they can be readily accessed. • §63.774 (b)(1)(ii) — The most recent 12 months of records shall be retained on site or shall be accessible from a central location by computer or other means that provides access within 2 hours after a request. • §63.774 (b)(1)(iii) — The remaining 4 years of records may be retained offsite. • §63.774 (b)(1)(iv) — Records may be maintained in hard copy or computer-readable form including, but not limited to, on paper, microfilm, computer, floppy disk, magnetic tape, or microfiche. o §63.774(f) -The owner or operator of an area source not located within a UA plus offset and UC boundary must keep a record of the calculation used to determine the optimum glycol circulation rate in accordance with §63.764(d)(2)(i)or§63.764(d)(2)(ii), as applicable. • §63.775—Reporting Requirements o §63.775 (c) - Except as provided in paragraph (c)(8), each owner or operator of an area source subject to this subpart shall submit the information listed in paragraph (c)(1) of this section. If the source is located within a UA plus offset and UC boundary, the owner or operator shall also submit the information listed in paragraphs (c)(2) through (6) of this section. If the source is not located within any UA plus offset and UC boundaries, the owner or operator shall also submit the information listed within paragraph (c)(7). • §63.775 (c)(1) - The initial notifications required under §63.9(b)(2) not later than January 3, 2008. In addition to submitting your initial notification to the addressees specified under §63.9(a), you must also submit a copy of the initial notification to EPA's Office of Air Quality Planning and Standards. Send your notification via e-mail to CCG— ONG@EPA.GOV or via U.S. mail or other mail delivery service to U.S. EPA, Sector Policies and Programs Division/Coatings and Chemicals Group (E143—01), Attn: Oil and Gas Project Leader, Research Triangle Park, NC 27711. • §63.775 (c)(7) - The information listed in paragraphs (c)(1)(i) through (v) of this section. This information shall be submitted with the initial notification. • §63.775 (c)(7)(i) - Documentation of the source's location relative to the nearest UA plus offset and UC boundaries. This information shall include the latitude and longitude of the affected source; whether the source is located in an urban cluster with 10,000 people or more; the distance in miles to the nearest urbanized area boundary if the source is not located in AIRS ID: 123/9009 Page 10 of 27 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1478 Air Pollution Control Division Issuance 2 an urban cluster with 10,000 people or more; and the names of the nearest urban cluster with 10,000 people or more and nearest urbanized area. • §63.775 (c)(7)(ii) - Calculation of the optimum glycol circulation rate determined in accordance with §63.764(d)(2)(i). • §63.775 (c)(7)(iii) - If applicable, documentation of the alternate glycol circulation rate calculated using GRI- GLYCaIcTM, Version 3.0 or higher and documentation stating why the TEG dehydration unit must operate using the alternate glycol circulation rate. • §63.775 (c)(7)(iv) - The name of the manufacturer and the model number of the glycol circulation pump(s) in operation. • §63.775 (c)(7)(v) - Statement by a responsible official, with that official's name, title, and signature, certifying that the facility will always operate the glycol dehydration unit using the optimum circulation rate determined in accordance with §63.764(d)(2)(i)or§63.764(d)(2)(ii), as applicable. o §63.775 (f) - Notification of process change. Whenever a process change is made, or a change in any of the information submitted in the Notification of Compliance Status Report, the owner or operator shall submit a report within 180 days after the process change is made or as a part of the next Periodic Report as required under paragraph (e) of this section, whichever is sooner. The report shall include: • §63.775(f)(1) -A brief description of the process change; • §63.775 (f)(2) - A description of any modification to standard procedures or quality assurance procedures • §63.775 (f)(3) — Revisions to any of the information reported in the original Notification of Compliance Status Report under paragraph (d) of this section; and • §63.775 (f)(4) - Information required by the Notification of Compliance Status Report under paragraph (d) of this section for changes involving the addition of processes or equipment. Fugitive Emissions (AIRS Point 0061 23. The operator shall calculate actual emissions from this emissions point based on representative component counts for the facility with the most recent 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. 24. Minor sources in designated nonattainment or attainment/maintenance areas that are otherwise not exempt pursuant to Section II.D. of Regulation No. 3, Part B, shall apply Reasonably Available Control Technology (RACT)for the pollutants for which the area is AIRS ID: 123/9009 Page 11 of 27 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1478 Air Pollution Control Division Issuance 2 nonattainment or attainment/maintenance (Reference: Regulation No. 3, Part B, III.D.2.a). Compliance with the requirements of an inspection and repair program, as required by Condition 25, shall satisfy the requirement to apply RACT. 25. The operator shall use optical gas imaging (i.e. IR camera) to screen all pumps, valves, connectors, and pressure relief devices that contain or contact a process stream that is at least 10 percent VOC by weight. The operator shall perform screening on a monthly basis. The IR camera shall be maintained per the manufacturer's recommendations. In addition, the source shall follow procedures for implementing an alternative work practice for monitoring equipment for leaks as specified below: • Any emissions imaged by the optical gas instrument (i.e. IR camera) at the required detection sensitivity level qualify as a leak. Additionally, any indications of liquids dripping shall qualify as a leak. • The detection sensitivity level shall be 60 grams per hour which correlates to the least frequent monitoring schedule listed in Table 1 of 40 CFR 60 Subpart A. • The operator shall comply with the instrument specifications in 40 CFR 60.18(i)(1). • The operator shall comply with the daily instrument checks in 40 CFR 60.18(i)(2). • The operator shall perform screening in accordance with 40 CFR 60.18 (i)(3). • The operator shall tag all leaking components with date of leak detected, date of repair and date of rescreening to confirm repair. Once a leak is repaired, the leaker tag may be removed. • Component leaks detected shall be repaired as set forth below: o The leak will be repaired within 15 days. Repaired components shall be re- screened within five days of repair to determine if the leak is repaired. If the rescreening shows a leak, then the leak shall be repaired as soon as practicable, but no later than 15 days after the rescreening. Repeat the process until the rescreening shows no leak. o As an alternative to using the IR camera, re-screening may be performed in accordance with the Alternative Screening Procedure as specified in 40 CFR 60 Appendix 7, Method 21, Section 8.3.3. o If a leak is detected but it is technically infeasible to make the repair without a process unit shutdown, repair of this equipment shall occur before the end of the next process unit shutdown. Facility records shall be maintained documenting the rationale for placing a leaking component on the Delay of Repair list, identifying the repair methods applied in each attempt to repair the leak, identifying the leaking component ID number, and listing an estimated date for repairing the component. Monitoring to verify the repair must occur within 15 days after startup of the process unit. • The following records shall be maintained and kept onsite for two years and shall be made available to the Division upon request: o A video record must be used to document leak survey results. The video record must include a time and date stamp for each monitoring event. AIRS ID: 123/9009 Page 12 of 27 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1478 Air Pollution Control Division Issuance 2 o A video record must be used to document leaks that are found and to confirm repairs showing the date/time of screening for each event. The video record must include a time and date stamp for each monitoring event. If the Alternative Screening Procedure per 40 CFR 60 Appendix 7, Method 21, Section 8.3.3 is used for re-screening, then records of re-screening dates, re-screening method, and re-screening results must be maintained in lieu of a video record. o List of components screened and associated dates. o List of currently leaking components. o List of repaired components along with the repair method and associated repair dates. o List of successful repairs, repair delays, and post-repair screenings and associated dates. o Records of daily instrument check including the distance and flow meter reading at which the leak was imaged. Keep a video record of the daily instrument check for each configuration of the optical gas imaging instrument used during the leak survey (for example, the daily instrument check must be conducted for each lens used). The video record must include a time and date stamp for each daily instrument check. The video record must be kept for two years. OPERATING & MAINTENANCE REQUIREMENTS 26. Upon startup of these points, the applicant shall follow the operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 27. AIRS Points 002, 003, 008 and 009: A source initial compliance test shall be conducted on emissions point 002, 003, 008 and 009 to measure the emission rate(s)for the pollutants listed below in order to demonstrate compliance with the emissions limits contained in this permit. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time (Reference: Regulation No. 3, Part B., Section III.G.3) Oxides of Nitrogen Carbon Monoxide Volatile Organic Compounds Formaldehyde AIRS ID: 123/9009 Page 13 of 27 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1478 Air Pollution Control Division Issuance 2 28. AIRS Point 005: The owner or operator shall complete the initial annual extended wet gas analysis testing required by this permit and submit the results to the Division as part of the self-certification process to ensure compliance with emissions limits. (Reference: Regulation No. 3, Part B, Section III.E.) 29. AIRS Point 006: Within one hundred and eighty days (180) after commencement of operation, 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 30. AIRS Points 001 through 003, 008 and 009: Each engine is subject to the periodic testing requirements as specified in the operating and maintenance (O&M) plan as approved by the Division. Revisions to your O&M plan are subject to Division approval. Replacements of this unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A. 31. AIRS Point 005: 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. 32. AIRS Point 006: On an annual basis, the permittee shall complete an extended gas analysis of gas samples that are representative of VOC and 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. ADDITIONAL REQUIREMENTS 33. All previous versions of this permit are cancelled upon issuance of this permit. 34. This permit replaces the following permits, which are cancelled upon issuance of this permit. Emission Point Existing Permit No. New Permit No. 123/9009/008 GP02 -APEN Document#284515 11WE1478 123/9009/009 GP02—APEN Document#300735 11WE1478 35. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5)tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO,) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per AIRS ID: 123/9009 Page 14 of 27 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1478 Air Pollution Control Division Issuance 2 year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine, the appropriate APEN filing fee and a cover letter explaining that the permittee is exercising an alternative-operating scenario and is installing a permanent replacement engine. 36. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). 37. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities major stationary source requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of Subpart HH. (Reference: Regulation No. 8, Part E) 36. MACT Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of that Subpart on the date as stated in the rule as published in the Federal Register. (Reference: Regulation No. 8, Part E) GENERAL TERMS AND CONDITIONS: 39. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 40. 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 AIRS ID: 123/9009 Page 15 of 27 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1478 Air Pollution Control Division Issuance 2 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 No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self- Certify for Final Authorization section of this permit. 41. This permit is issued in reliance upon the accuracy and completeness of information supplied by the applicant and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the applicant or applicant's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 42. 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. 43. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the applicant, or the Division revokes a permit, the applicant or owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 44. 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. 45. 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: Carissa Money Permit Engineer AIRS ID: 123/9009 Page 16 of 27 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1478 Air Pollution Control Division Issuance 2 Permit History Issuance Date Description Issuance 2 This Issuance Modified description of TEG Dehy (AIRS ID 005) to allow electric pump or gas injection pump. No change in requested emission and process limits. Increased fugitive equipment leak (AIRS ID 006) emission limit from 8 tpy to 31.0 tpy. Removed all references to AIRS ID 004 (request to cancel received 2/2/2012). Converted AIRS ID 008 and 009 from GP02 coverage to be covered by this permit. Issuance 1 11/21/2011 Issued to DCP Midstream, LP AIRS ID: 123/9009 Page 17 of 27 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1478 Air Pollution Control Division Issuance 2 Notes to Permit Holder: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 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 permittee 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 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 permittee 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: htto.//www.cdphe.state.co.us/requlations/airregs/100102aocccommonprowsionsreq.pdf. 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. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Point Pollutant CAS# BIN (Ib/yr) reportable? Rate (Ib/yr) 389 (total allowable Formaldehyde 5000 A 1622 Yes from all five engines is 1,556 Ib/yr) 177 (total allowable Methanol 67561 C 355 Yes from all five engines is 708 lb/yr) 001, 002, 162 (total allowable 003, 008, Acetaldehyde 75070 A 323 Yes from all five 009 engines is EACHA 648 Ib/yr) 152 (total allowable Acrolein 107028 A 305 Yes from all five engines is 608 Ib/yr) 92 (total allowable Benzene 71432 A 183 No from all five engines is 368 Ib/yr) AIRS ID: 123/9009 Page 18 of 27 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1478 Air Pollution Control Division Issuance 2 38 (total allowable 1,3-Butadiene 106990 A 77 No from all five engines is 152 Ib/yr) 32 (total allowable Toluene 108883 C 65 No from all five engines is 128 Ib/yr) Benzene 71432 A 117,519 YES 6,108 Toluene 108883 C 144,132 YES 7,605 005B Ethylbenzene 100414 C 6,232 YES 332 Xylenes 1330207 C 71,816 YES 3,863 n-Hexane 110543 C 109,618 YES 1,908 Benzene 71432 A 179 No 69 Toluene 108883 C 79 No 31 006 Ethylbenzene 100414 C 9 No 3 Xylenes 1330207 C 9 No 3 n-Hexane 110543 C 2,931 YES 1,136 A: DCP shall be running four(4)engines from out of the five(5) engines onsite, therefore, there is a combined HAP emissions based on maximum of four engines operating. B: The values listed in the table for AIRS Point 005 are based on worst-case emissions from two possible equipment set-ups. 5) The emission levels contained in this permit are based on the following emission factors: Points 001 through 003, 008 and 009: Emission Factors- Emission Factors— Uncontrolled Controlled CAS Pollutant lb/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr NOx 3.6669 13.1000 0.1400 0.5000 CO 3.2750 11.7000 0.2799 1.0000 VOC 0.4199 1.5000 ___ 0.1959 0.7000 5000 Formaldehyde 0.0140 0.0500 0.0034 0.0120 67561 Methanol 0.0031 0.0109 0.0015 0.0055 75070 Acetaldehyde 0.0028 0.0100 0.0014 0.0050 107028 Acrolein 0.0026 0.0094 0.0013 0.0047 71432 Benzene 0.0016 0.0056 0.0008 0.0028 106990 1,3-Butadiene 0.0007 0.0024 0.0003 0.0012 108883 Toluene 0.0006 0.0020 0.0003 0.0010 Emission factors are based on a Brake-Specific Fuel Consumption Factor of 7876 Btu/hp-hr, a site-rated horsepower value of 1680,and a fuel heat value of 900 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer's specifications Manufacturer's specifications AIRS ID: 123/9009 Page 19 of 27 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1478 Air Pollution Control Division Issuance 2 CAS Pollutant Uncontrolled EFSource Controlled EF Source CO Manufacturer's specifications Manufacturer's specifications VOC Manufacturer's specifications Manufacturer's specifications 5000 Formaldehyde Manufacturer's specifications Manufacturer's specifications 67561 Methanol AP-42; Table 3.2-3 (7/2000); Manufacturer's specifications Natural Gas 75070 Acetaldehyde AP-42; Table 3.2-3 (7/2000); Manufacturer's specifications Natural Gas 107028 Acrolein AP-42; Table 3.2-3 (7/2000); Manufacturer's specifications Natural Gas 71432 Benzene AP-42; Table 3.2-3 (7/2000); Manufacturer's specifications Natural Gas 106990 1,3-Butadiene AP-42; Table 3.2-3 (7/2000); Manufacturer's specifications Natural Gas 108883 Toluene AP-42; Table 3.2-3 (7/2000); Manufacturer's specifications Natural Gas Point 005: The emission levels contained in this permit are based on information provided in the application and the GRI GlyCalc 4.0 model. Controlled emissions are based on 100% recycle of the flash tank emissions and 95% control of the still vent vapors. Optimal recirculation rate per MACT HH (63.74(d)(2)(i)) is based on the following information submitted with the application: F = 50MMscfd; I = 121.8 lb/MMscf; and O=6.7 lb/MMscf. Point 006: Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 935 0 5470 0 Flanges 0 0 0 0 Open-ended Lines 0 0 0 0 Pump Seals 0 0 30 0 Valves 320 0 2115 0 Other' 10 0 70 0 VOC Content(wt%) 31.8% 100% 100% 100% Benzene Content(wt%) 0.102% 0.102% Toluene Content(wt%) 0.045% 0.045% EthylBenzene Content 0.005% 0.005% (wt%) Xylene Content(wt%) 0.005% 0.005% n-Hexane Content(wt%) 1.674% 1.674% *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 AIRS ID: 123/9009 Page 20 of 27 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1478 Air Pollution Control Division Issuance 2 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 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 and then applying 88% control for gas valves, 76% control for light liquid valves and 68%for light liquid pump seals for monthly RACT LDAR program. 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) The following equipment is currently exempt from construction permitting requirements and/or APEN reporting requirements based on information provided by the operator for the Division's analysis: AIRS ID Facility ID Description Notes NA TEG TEG Dehy unit reboiler, This unit is exempt from APEN reporting Reboiler rated at 2.86 MMBtu/hr requirements because the design rate is less than 5 MMBtu/hr (Regulation No. 3, Part A, II.D.1.k), and is therefore also exempt from construction permitting requirements (Regulation no. 3, Part B, II.D.1.a). Criteria pollutant emission levels for this unit are based on factors from AP-42, Chapter 1.4, Small Boilers < 100 MMBtu/hr(7/1998). 8) AIRS Points 001 through 003, 008, and 009: Each engine is subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal Register posting — effective March 18, 2008). This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA website at: http://www.epa.00v/ttn/atw/area/fr18ia08.pdf 9) AIRS Points 001 through 003, 008 and 009: Each engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January 18, 2008 Federal Register posting - effective March 18, 2008). The January 18, 2008 amendments to include requirements for area sources and engines < 500 hp located at major sources have not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 8. A copy of the complete subpart is available on the EPA website at: http://www.epa.gov/ttn/atw/area/fr18ia08.odf Additional information regarding area source standards can be found on the EPA website at: http://www.epa.qov/ttn/atw/area/arearules.html 10) This facility is classified as follows: Applicable Status Requirement AIRS ID: 123/9009 Page 21 of 27 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1478 Air Pollution Control Division Issuance 2 Operating Permit Synthetic Minor Source CO, VOC, NOx, HAPs PSD Synthetic Minor Source CO NANSR Synthetic Minor Source VOC, NOx MACT HH Area Source Requirements MACT ZZZZ Area Source Requirements 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/ 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 OQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX 12) An Oil and Gas Industry Construction Permit Self-Certification Form is included with this permit packet. Please use this form to complete the self-certification requirements as specified in the permit conditions. Further guidance on self-certification can be found on our website at: • AIRS ID: 123/9009 Page 22 of 27 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1478 Air Pollution Control Division Issuance 2 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: 123/9009 Page 23 of 27 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1478 Air Pollution Control Division Issuance 2 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. 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. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable • analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The owner or operator shall measure nitrogen oxide (NOX)and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven(7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer)as found on the Division's web site at: http://www.colorado.qov/cs/Satellite/C D PH E-AP/CBON/1251596520270. Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year)or short term (lbs/unit of time)emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year(whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year(8760),whichever applies. AIRS ID: 123/9009 Page 24 of 27 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1478 Air Pollution Control Division Issuance 2 For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine will be subject to, the results of the test shall be converted to the appropriate units as described in the above-mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline. 2.3 Applicable Regulations for Permanent Engine Replacements 2.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B§ II.D.2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and to NOX and 5O2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr. For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating internal combustion engines: VOC:The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOX:The emission limitations in NSPS JJJJ 5O2: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (§60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State- Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified below: Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non- selective catalyst and air fuel controller to reduce emission. AIRS ID: 123/9009 Page 25 of 27 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1478 Air Pollution Control Division Issuance 2 Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. Emission Standards: Section XVII.E—State-only requirements Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Construction or Emission Standards in G/hp-hr Max Engine HP Relocation Date x NO CO VOC January 1, 2008 2.0 4.0 1.0 100<Hp<500 January 1, 2011 1.0 2.0 0.7 July 1, 2007 2.0 4.0 1.0 500<Hp July 1, 2010 1.0 2.0 0.7 The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. 2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ requirements). However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, § 1.8 (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. 2.3.4 Reciprocating internal combustion engine(RICE) MACT: 40 CFR Part 63, Subpart ZZZZ AIRS ID: 123/9009 Page 26 of 27 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1478 Air Pollution Control Division Issuance 2 A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. 2.4 Additional Sources The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site; an engine that is being installed as an entirely new emission point and not as part of an AOS- approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. AIRS ID: 123/9009 Page 27 of 27 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: DCP Midstream, LP Permit Number: 11WE1478.CP2 E 1478.CP2 Sullivan Compressor Station Source Location: SWSE Section 17, T7N, R62W Equipment Description: Natural Gas Compression Facility AIRS ID: 123/9009/005,006,008 and 009 Date: February 13, 2014 Review Engineer: Carissa Money Section 2—Action Completed Modification— Grandfathered X For Points 005 and 006 APEN Required/Permit Exempt (mod)and 008 and 009 (convert from GP02) CP1 Transfer of Ownership APEN Exempt/Permit Exempt Section 3—Applicant Completeness Review Was the correct APEN submitted for this source type? X Yes No Is the APEN signed with an original signature? X Yes No Was the APEN filled out completely? X Yes No Did the applicant submit all required paperwork? X Yes No Did the applicant provide ample information to determine emission rates? X Yes No If you answered "no"to any of the above, when did you mail an Information Request letter to the source? On what date was this application complete? March 11, 2014 Section 4—Source Description AIRS Point Equipment Description One (1)Triethylene glycol (TEG) natural gas dehydration unit (make, model, serial number: not submitted)with a design capacity of 50 MMscf per day. This emissions unit is equipped with either one (1) electric pump or one (1)gas 005 injection pump (make, model: not submitted) with a design capacity of 24 gallons per minute. This unit is equipped with a flash tank, reboiler and still vent. Emissions from the still vent are routed to the fuel gas line of the reboiler. Emissions from the flash tank are routed to a vapor recovery unit(VRU) which returns vapors back to the inlet of the plant. 006 Equipment leaks (fugitive VOCs)from a natural gas compression facility. Page 1 One (1)Waukesha, Model L7044GSI, Serial Number to be determined, natural gas-fired, turbo-charged, 4SRB reciprocating internal combustion engine, site 008 rated at 1680 horsepower at 1200 RPM. This engine shall be equipped with non- selective catalytic reduction (NSCR) system and air-fuel ratio control. This emission unit is used for natural gas compression. One (1)Waukesha, Model L7044GSI, Serial Number to be determined, natural gas-fired, turbo-charged, 4SRB reciprocating internal combustion engine, site 009 rated at 1680 horsepower at 1200 RPM. This engine shall be equipped with non- selective catalytic reduction (NSCR) system and air-fuel ratio control. This emission unit is used for natural gas compression. Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria X Yes No pollutant? If"yes", for what pollutant? PM10 CO X Ozone Is this location in an attainment maintenance area for Yes X No any criteria pollutant? If"yes", for what pollutant? (Note: These pollutants are subject to minor source PM,o CO Ozone RACT per Regulation 3, Part B, Section III.D.2) Is this source located in the 8-hour ozone non- attainment region?(Note: If"yes"the provisions of X Yes No Regulation 7,Sections XII and XVII.C may apply) Section 5—Emission Estimate Information • AIRS Point Emission Factor Source 005 GRI Gly-Calc v4.0 (Refer to Section 14 for calculations) 006 EPA-453/R-95-017, Table 2-4 008 Manufacturer for NOx, CO and VOC. AP-42 for all others. 009 Manufacturer for NOx, CO and VOC.AP-42 for all others. Did the applicant provide actual process data for the emission inventory? Yes X No Basis for Potential to Emit(PTE) AIRS Point Process Consumption/Throughput/Production 005 18,250 MMSCF per year, 24 gallons per minute glycol circulation rate 008 128.8 MMscf per year, 1680 hp 009 128.8 MMscf per year, 1680 hp Basis for Actual Emissions Reported During this APEN Filing(Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year Did not report actual-new facility Basis for Permitted Emissions(Permit Limits) AIRS Point Process Consumption/Throughput/Production 005 18,250 MMSCF per year, 24 gallons per minute glycol circulation rate 008 128.8 MMscf per year, 1680 hp 009 128.8 MMscf per year, 1680 hp Does this source use a control device? X Yes No Page 2 Reduction AIRS Point Process Control Device Description Pollutant Granted 005 0t VRU for flash tank and Reboiler Fuel Gas VOC 98% System for Still Vent 006 01 Monthly RACT LDAR program VOC 59% NOx 96.2% CO 91.5 008 and 009 01 NSCR VOC 30 Formaldehyde 76 HAPs 50 Section 6-Emission Summary(tons per year) Point TSP NO, VOC CO Single HAP Total HAP Facility,PTE Before 72.1 Emissions 005 1,005.3 toluene 224.7 Controls/Limits: 1.5 006 76.2 1.6 n-hexane0.8 008 1.1 212.5 24.3 189.8 1.5 formaldehyde0.8 009 1.1 212.5 24.3 189.8 formaldehyde 1.5 Facilit 72.3 y 5.6 1063.2 1,128.86 950.2 toluene 233.7 Total" • Point TSP NO, VOC CO Single HAP Total HAP Controlled point 3.8 source emission 005 16.7 toluene 9.9 rate: 0.6 006 31.0 0.6 n-hexane0.2 008 1.1 8.1 11.4 16.2 0.5 Formaldehyde0.2 009 1.1 8.1 11.4 16.2 0.5 Formaldehyde Total permitted plant-wide 32.4 93.3 64.8 3.9 12.6 emissionsc: toluene A: Refer to history file for details B: These emissions only include point sources and do not include fugitives. C: These emissions do not include insignificant activities but do include fugitives that qualify as permitted emission sources. Section 7— Non-Criteria/Hazardous Air Pollutants Uncontrolled Are me emissions Controlled Emission AIRS ID Pollutant CAS# BIN Emission Rate reportable? Rate(Ib/yr) (Ib/yr) *See 11WE1478,E1478, Issuance 2, Notes to Permit Holder#4 for NCRP values. Note: Regulation 3, Part A, Section II.B.3.b APEN emission reporting requirements for non-criteria air pollutants are based on potential emissions without credit for reductions achieved by control devices used by the operator. Section 8—Testing Requirements Will testing be required to show compliance with any emission rate or regulatory X Yes No standard? If"yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method Page 3 008, 009 01 NOx, CO, Reg3 Part B, Section III.G.3 Stack test VOC, HCHO Section 9—Source Classification Is this a new previously un-permitted source? Yes X No True Synthetic What is this point classification? X Major Minor Minor True Synthetic What is this facility classification? X Major Minor Minor Classification relates to what programs? X Title V X PSD X NA NSR X MACT Is this a modification to an existing permit? X Yes No Synthetic If"yes"what kind of modification? Minor X Major Minor Section 10—Public Comment Does this permit require public comment per CAQCC Regulation 3? X Yes No If"yes",for which pollutants?Why? For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)? X Yes No For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)? Yes X No For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? X Yes No Section 11 —Modeling Is modeling required to demonstrate compliance with National Ambient Yes X No Air Quality Standards (NAAQS)? If"yes",for which pollutants?Why? AIRS Point Section 12—Regulatory Review _Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide Section II.A.1 -Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15-second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60,Appendix A(July, 1992))in all subsections of Section II.A and B of this regulation. Regulation 2—Odor Section I.A- No person, wherever located, shall cause or allow the emission of odorous air • contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7)or more volumes of odor free air. Regulation 3-APENs. Construction Permits.Ooeratina Permits. PSD Part A-APEN Requirements Applicant is required to file an APEN since emissions exceed applicable thresholds. Part B—Construction Permit Exemptions Applicant is required to obtain a permit since emissions exceed applicable thresholds. (Reg. 3, Part B, Section II.D.2) Regulation 6- New Source Performance Standards 008 and NSPS JJJ: Not currently adopted in Colorado regulations. Listed in "Notes to permit 009 holder." Page 4 Regulation 7—Volatile Orq nic Compounds Section XII.G Since this site is a compressor station, it is not subject to these requirements. Section XII.H. Applicant is located in NAA and uncontrolled VOC emissions are greater than the 15.0 TPY threshold. Thus source is subject to requirements under Section XII.H. Section XVI.B 005, 006, Applicant is located in NAA and thus required to install NSCR on rich burn engine rated 008, 009 greater than 500 hp. Section XVII.D (State only enforceable). Applicant is required to reduce VOC emissions from this dehydrator by at least 90% since uncontrolled VOC emissions are greater than the 15.0 TPY threshold. Section XVII.E. Engines are subject to emission standards unless NSPS JJJJ and MACT ZZZZ requirements ultimately are applicable. Regulation 8—Hazardous Air Pollutants MACT HH: This facility is an area source of HAP and MACT HH area source requirements apply to this TEG dehydrator. This dehydrator is not located within an urban cluster or within two miles of an urban area, and is subject to the optimal circulation rate work 005, 006 practice standard in HH. Since it is an area source and a compressor station, fugitive equipment leak requirements of MACT HH are not applicable. 008, 009 MACT 7777: Area source requirements are not currently adopted in Colorado regulations. Listed in "Notes to permit holder." Section 13—Aerometric Information Retrieval System Coding Information Process Throughput Emission Pollutant/ Fugitive Emission Control Point Process Description limit Factor CAS# (Y/N) Factor Source Ws) 110.17 VOC No GlyCalc 4.0 98 lbs/mmscf 6.44 Benzene/ No GlyCalc 4.0 95 lbs/mmscf 71432 7.90 Toluene/ 18, Glycol lbs/mmscf 108883 01 MDehydrator per year year CF 005 0.34 Ethylbenzene No GlyCalc 4.0 95 lbs/mmscf 1100414 3.94 Xylenes/ No GlyCalc 4.0 95 lbs/mmscf 1330207 6.01 n-Hexane/ No GlyCalc 4.0 98 Ibs/mmscf 110543 SCC 31000227: Glycol Dehydrator: reboiler still stack Fugitive 76.2 ton per EPA-453/R-95- 01 equipment NA year VOC Yes 017,Table 2-4 59 006 leaks SCC 31000220:All Equip. Leak Fugitives(Valves,flanges,connections,seals,drains) 008 and 009—See separate spreadsheet for emission factors and SCC Page 5 Section 14-Miscellaneous Application Notes AIRS Point 005 TEG Dehydrator This emissions point covers emissions from one triethylene glycol (TEG)dehydrator that treats field gas prior to sending the gas on for additional processing at a gas plant. The TEG dehydrator will have a maximum capacity of 50 MMscfd based on the APEN. The pump specifications are not yet known but the requested glycol recirculation rate is 24.0 gallons per minute. The still vent will be routed to a condenser and then to the reboiler firebox. The flash tank emissions are routed back to the plant inlet via a vapor recovery unit (VRU). The reboiler is rated at 2.86 MMbtu/hr. For this modification, the source requested to change the equipment description so that they could install either an electric pump or a gas injection pump. The first issuance of the permit was based on an electric pump and the operator stated that using a gas injection pump would result in lower emissions. Thus, the source was requesting to modify the equipment description but not make any emission or throughput changes. When I reviewed the GlyCalc reports,the uncontrolled emissions using a gas injection pump were substantially higher(1005 tpy vs 534 tpy)than the model for the electric pump. The flash tank emissions are substantially higher when using a gas injection pump and the still vent emissions are slightly lower. The GlyCalc Handbook states that both pumps are equivalent from an air emissions standpoint. It is not clear to me why the emissions are higher. I confirmed that the GlyCalc report for the electric pump was identical to the report provided in the original application so the differences are not due to a different model for the electric pump. For this situation, ultimately, controlled emissions are less when using the gas injection pump because the flash tank emissions are 100% recycled to the plant inlet and the uncontrolled still vent emissions are slightly lower. The fact that the uncontrolled flash tank emissions are substantially higher does not impact the controlled emissions due to recycling. If the flash tank emissions were not recycled, then the controlled emissions would be higher for the model using a gas injection pump. I created a GlyCalc model to see if I could better understand the differences. Both models were based on GRI GlyCALC 4.0, inlet gas temperature of 125F, in let gas pressure of 920 psig and glycol recirculation rate of 24.0 gallons per minute. The wet gas composition is the same as for the original submittal. (The basis for wet gas composition is a compilation of various gas samples from the area which is appropriate for a new facility. An extended gas analysis will be required as part of the self-certification process to confirm emissions.) As was done with the original submittal,the"wet gas water content"was marked as subsaturated for the simulation, and I confirmed by running the models using defaults that this option had little change in the estimated emissions (very slightly decreased). Additionally, as was done for the original submittal, the source specified a dry gas water content of 6.7 lbs H2O/MMscf and lean glycol water content of 1.0 wt% instead of using the default values of 7.0 lbs H2O/MMscf and 1.5 wt%. I confirmed that using these values, in lieu of defaults, slightly increased emissions. I generated the same emissions as provided in the application and cannot understand the reason for the substantially higher uncontrolled emissions when using a gas injection pump. To address the discrepancy, uncontrolled emissions are based on the GlyCalc results when using gas injection pump and controlled values are based on Glycalc results when using an electric pump. Thus, the emission limit in the permit was not adjusted but uncontrolled HAP values in Notes to Permit Holder were increased to agree with the updated Glycalc report for gas injection pump. Emission factors listed in Section 13 of this analysis are based on the sum of flash tank and still vent emissions from the GlyCALC report when using a gas injection pump. Regulatory applicability remains the same as detailed in the PA for the original permit issuance. The facility is an area source for MACT HH. As specified in 63.760(b)(2), the only affected sources for area sources are TEG dehydrators. The source cannot meet the processing exemption limit in 63.764(e)(i) because the proposed process limit is 50 MMscfd which exceeds the exemption limit of 3.002 MMscfd. The source cannot meet the benzene exemption limit of 1,984 Ib/yr in 63.764(e)(ii) because controlled benzene emissions are estimated at 6,107 lb/yr. The source will be located at least 15 miles from an Urban Cluster(Greeley)so it is not within an UA Plus Offset or within a UC boundary. Thus, as an area source outside of a UC boundary, it is eligible for the optimal circulation rate work practice standard in 63.764(d)(2). These requirements will be listed in the permit. Page 6 Regulation 7, Section XVII.D requires emission control standards for dehydrators with uncontrolled emissions of VOC greater than 15 tons per year from all the dehydrators on site. As discussed above, uncontrolled VOC emissions are 1,005 tpy. Section XVII,B.4 states that dehydrators subject to an emission control requirement in a federal MACT standard are not subject to requirements under Section XVII. This dehy is subject to a work practice standard under MACT HH, not an emission control requirement;thus,the dehy is still subject to the requirements of Section XVII.D. Further, since the source will be located in a non-attainment area,the dehy is also subject to the requirements of Regulation 7, Section XII.H. While the requirements of Section XII and XVII appear duplicative, both Regulation 7 requirements will be listed in the permit since they are both applicable. The unit is equipped with a reboiler rated at 2.86 MMbtu/hr. Since the reboiler burner has a design rate less than 5 mmbtu/hr, then it is APEN-exempt(Regulation No. 3, Part A, II.D.1.k), and is therefore also exempt from construction permitting requirements(Regulation no. 3, Part B, II.D.1.a). AIRS Point 006 Fugitive Equipment leaks The source requested to increase the emission limit for fugitive equipment leaks from 8 tpy to 76.2 tpy based on actual hard count from a partial build-out of the site. Emissions are based on an inlet gas analysis collected 4/5/2013. Initial sampling will not be required since the most recent sample was collected at the site and within a year of the application date. However, an initial hard count will still be required so that a final count is completed when the site is completely built. Regulatory applicability for MACT HH, NSPS KKK and Reg 7 Section XII remains the same as the previous permit issuance since the site still qualifies as a compressor station and not a natural gas processing plant. Previously for minor source RACT, the source was required to conduct semi-annual IR camera inspections since fugitive emissions were at 8 tpy. Now that the uncontrolled fugitive emissions are at 76.2 tpy, the RACT requirement will be changed to require monthly IR camera monitoring. This frequency is consistent with current permitting policy as well as with the Regulation 7 changes that were accepted by the AQCC on 2/23/2014. Since IR monitoring will now occur monthly, the source can utilize control percentages developed by EPA for monthly LDAR program which is 88%for valves in gas service, 76% for valves in light liquid service and 68%for pump seals in light liquid service. AIRS Point 008 and 009 Waukesha Engines, 1680 hp each The source requested to convert the engines covered by GP02 to this facility-wide permit. The source also requested to establish a maximum group emission limit for all engines at the site since one of the engines will operate as back-up. The maximum permitted emissions allow for only four engines to operate 8760 hours per year. Each engine will have an individual emission limit to ensure each engine can monitor compliance for federal and state emission limits as well as stack testing. However,the group emission limit will allow the site to obtain federally enforceable emission limits based on expected operations. The GP02 coverage for both engines will be cancelled when this permit modification is issued. The originally submitted APEN included slightly different values for VOC and formaldehyde than the engines permitted under AIRS ID 001 through 003. I emailed the source on 3/6/2014 asking for clarification. The source modified the APEN so that VOC and formaldehyde for all the engines are based on manufacturer specifications. Some engines have not yet been ordered so exact dates are not yet known for establishing regulatory applicability. The engines will most likely be subject to area source requirements under MACT ZZZZ and NSPS JJJJ requirements. Also, the source requested to cancel the engine covered under AIRS ID 004 on 2/2/2012. Thus, with this modification, all requirements associated with AIRS ID 004 have been removed from the permit. Page 7 Facility Wide Comments DCP is proposing to modify a natural gas compression facility with a capacity of 50 MMscfd. This stationary source is located in Weld County which is currently considered a non-attainment area for ozone. The facility will install emissions controls in order to be considered a synthetic minor source for Non-attainment New Source Review(NANSR)requirements that would have otherwise been triggered due to emissions of nitrogen oxides (NOx)and volatile organic compounds (VOC)in excess of 100 tons per year. The facility will also be considered synthetic minor source for Prevention of Significant Deterioration (PSD) requirements that would have otherwise been triggered due to emissions of carbon monoxide(CO)in excess of 250 tons per year. The source will be a synthetic minor source of criteria pollutants and HAP emissions for Title V Operating Permit program. DCP is a"midstream" natural gas company and thus does not own, operate, or control any oil or natural gas leases, production wells or production lease sites(E&P sites).Additionally, DCP stated that no DCP compressor stations are currently located, or will be located, within a quarter mile of the Sullivan compressor station. DCP also stated that no DCP compressor stations or gas plants that are greater than a quarter mile from the Sullivan compressor station will be wholly dependent with Sullivan. Page 8 K G 5 "t Sd y ° E `o ' c O a c • c u voice=i 0 < -. .c ❑ '0_ 5 i 'S c m „ • � N M N c, Er U N N N c;c _ r, ot e v. Pr: - < y 4, yr i. y. O x2 a O T V L. V O C O O 0 l.`_. e= .� = c G s a 3 "g17, - i .- Z Z Z � c = eb c.1 L �?- O ` $ ` g o — a v S ,, n•P can' r,4 .... c .v N e 'r. . 'C° N - g ° s `.D - O fr. G, `? 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