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Home My WebLink About20142690.tiff STATE OF COLORADO John W.Hickenlooper,Governor - - Larry Wolk,MD,MSPH :4YCot. Executive Director and Chief Medical Officer �9$ Dedicated to protecting and improving the health and environment of the people of Colorado I n 2)1 4300 Cherry Creek Dr.S. Laboratory Services Division ; ra?e/ 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/cdphe and Environment Weld County-Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 August 26,2014 Dear Sir or Madam: On August 29, 2014,the Air Pollution Control Division will publish a public notice for DCP Midstream LP— Bernhardt Compressor Station, in the The Greeley 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 I 4300 Cherry Creek Drive South Denver,Colorado 80246-1530 Attention: Clara Gonzales Regards, 71 r RECEIVED Clara Gonzales Public Notice Coordinator AUG 2 9 2014 Stationary Sources Program WELD COUNTY Air Pollution Control Division COMMISSIONERS Enclosure -RUbt,C, lUHRuD CC:'HL,/?LJPUf 2014-2690 q-S- ti 8/z9 r - - STATE OF COLORADO John W.Hickenlooper,Governor Larry Wolk,MD,MSPH .04 cozoR'Gp� v Executive Director and Chief Medical Officer r.T; , P;, Dedicated to protecting and improving the health and environment of the people of Colorado * * 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/cdphe and Environment Website Title: DCP Midstream LP—Bernhardt Compressor Station—Weld County Released To: The Greeley Tribune On: August 26,2014 Published: August 29, 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: Bernhardt Compressor Station Natural gas compression facility SEC31,T5N, R66W Weld County The proposed project or activity is as follows: The applicant proposes to modify their permit to account for increased fugitive emissions. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section IILC due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B,Section IILC.La (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 WE1480 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such comment must be submitted in writing to the following addressee: Stuart Siffring Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South,APCD-SS-B1 Denver,Colorado 80246-1530 cdphe.commentsapcd@state.co.us STATE OF COLORADO pF'cozott COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT yo AIR POLLUTION CONTROL DIVISION TELEPHONE: (303)692-3150 .1876• CONSTRUCTION PERMIT • PERMIT NO: 11WE1480 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 Bernhardt Compressor Station, located in Section 31, Township 5N, Range 66W, 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 L7044GSI, Serial Number TBD, natural gas-fired, turbo-charged, 4SRB reciprocating internal C-191 001 combustion engine, site rated at 1680 horsepower at 1200 RPM. This engine shall be equipped with non-selective catalytic reduction (NSCR) system and air-fuel ratio control. This emission unit is used for natural gas compression. One (1) Waukesha, Model L7044GSI, Serial Number TBD, natural gas-fired, turbo-charged, 4SRB reciprocating internal C-182 002 combustion engine, site rated at 1680 horsepower at 1200 RPM. This engine shall be equipped with non-selective catalytic reduction (NSCR) system and air-fuel ratio control. This emission unit is used for natural gas compression. One (1)Waukesha, Model L7044GSI, Serial Number TBD, natural gas-fired, turbo-charged, 4SRB reciprocating internal C-183 003 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: 123/9011 Page 1 of 24 NGEngine Version 2009-1 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 Facility AIRS Description Equipment ID Point One (1)Waukesha, Model L7044GSI, Serial Number TBD, natural gas-fired, turbo-charged, 4SRB reciprocating internal C-184 004 combustion engine, site rated at 1680 horsepower at 1200 RPM. This engine shall be equipped with non-selective catalytic reduction (NSCR) system and air-fuel ratio control. This emission unit is used for natural gas compression. One(1)Triethylene glycol (TEG) natural gas dehydration unit(make, model, serial number: QB Johnson, 630712A) with a design capacity of 50 MMscf per day. This emissions unit is equipped with one(1) electric pump (make, model: D 1 005 TBD)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 a condenser and then to an enclosed combustor. 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. The engines addressed under AIRS Points 001 through 004 may be replaced with another engine in accordance with the temporary engine replacement provision or with another Waukesha L7044GSI engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. 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. This construction permit represents final permit approval and authority to operate this emissions source. Therefore, it is not necessary to self-certify. (Regulation 3, Part B, Section III.G.5). EMISSION LIMITATIONS AND RECORDS 2. 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 Equipment ID Point NO, VOC CO Emission Type C-191 001 1,378 1,929 2,756 Point C-182 002 1,378 1,929 2,756 Point AIRS ID: 123/9011 Page 2 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 C-183 003 1,378 1,929 2,756 Point C-184 004 1,378 1,929 2,756 Point D-1 005 2,842 340 Point FUG 006 9,686 Fugitive 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-191 001 8.1 11.4 16.2 Point C-182 002 8.1 11.4 16.2 Point C-183 003 8.1 11.4 16.2 Point C-184 004 8.1 11.4 16.2 Point D-1 005 16.7 2.0 Point FUG 006 57.0 Fugitive See "Notes to Permit Holder #4 for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 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. PROCESS LIMITATIONS AND RECORDS 3. 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) AIRS ID: 123/9011 Page 3 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 Process/Consumption Limits Facility AIRS Annual Monthly Limit Equipment Point Process Parameter Limit (31 days) ID 1289 C-191 001 Consumption of natural gas as a fuel cf8 m MMscfscflr MMsN /month 10.9 C-182 002 Consumption of natural gas as a fuel Mscf/ cf/m MMscftyr MMscF/month 128.8 C-183 003 Consumption of natural gas as a fuel MMsd/yr MMsdcf/m/month C-184 004 Consumption of natural gas as a fuel 10.9 MMsdscftyr MMsd/month 550 D-1 005 Natural gas throughput scf/ 1,f MMscf/ m yr MMscf/month FUG 006 Not applicable 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 4. 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). 5. 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.) 6. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) Waukesha Engines (AIRS Points 001 through 0041 7. 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 2, above. Operating parameters of the control equipment are identified in the operation and maintenance plan. (Reference: Regulation No.3, Part B, Section III.E.) 8. This equipment is subject to the control requirements for stationary andportable 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. AIRS ID: 123/9011 Page 4 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 9. 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 z100HP and January 1, 2008 2.0 4.0 1.0 <500HP January 1, 2011 1.0 2.0 0.7 2500HP 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 Deily (AIRS Point 0051 10. 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. 11. 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 enclosed combustor. The control system shall reduce uncontrolled emissions of VOC from the TEG dehydration unit to the emission levels listed in Condition 2, above. Operating parameters of the control equipment are identified in the operation and maintenance plan. (Reference: Regulation No.3, Part B, Section III.E.) 12. 100% of emissions that result from the flash tank associated with this dehydrator shall be recycled to the compressor station inlet and recompressed. 13. 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. AIRS ID: 123/9011 Page 5 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 14. 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. 15. The enclosed combustor covered by this permit is subject to Regulation No. 7, Section XVII.B General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed, have no visible emissions during normal operations, and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. The operator shall comply with all applicable requirements of Section XVII. 16. 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. 17. This source is subject to the TEG dehydrator area source requirements of 40 CFR, Part 63, Subpart HH - National Emission Standards for Hazardous Air Pollutants for Source Categories from Oil and Natural Gas Production Facilities including, but not limited to, the following: • §63.760—Applicability and designation of affected source 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 (t)(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 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. AIRS ID: 123/9011 Page 6 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 • §63.764 (d)(2)(i) — Determine the optimum glycol circulation rate using the following equation: Lo„ =1.15*3.0 gal TEG* F*(/—O) IbH2O 24hr/day Where: LoPT = 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— GLYCalcTM, Version 3.0 or higher. The owner or operator must document why the TEG dehydration unit must be operated using the alternate circulation rate and submit this documentation with the initial notification in accordance with §63.775(c)(7). • §63.764 (d)(2)(iii) — Maintain a record of the determination specified in paragraph (d)(2)(ii) in accordance with the requirements in §63.774(f) and submit the Initial Notification in accordance with the requirements in §63.775(c)(7). If operating conditions change and a modification to the optimum glycol circulation rate is required, the owner or operator shall prepare a new determination in accordance with paragraph (d)(2)(i) or (ii) of this section and submit the information specified under§63.775(c)(7)(ii) through (v). • §63.774- 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 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. AIRS ID: 123/9011 Page 7 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 • §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. • §63.776—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 (cx7) - The information listed in paragraphs (c)(1)(i) through (v) of this section. This information shall be submitted with the initial notification. • §63.775 (cX7)(i) - Documentation of the source's location relative to the nearest UA plus offset and UC boundaries. This information shall include the latitude and longitude of the affected source; whether the source is located in an urban cluster with 10,000 people or more; the distance in miles to the nearest urbanized area boundary if the source is not located in an urban cluster with 10,000 people or more; and the names of the nearest urban cluster with 10,000 people or more and nearest urbanized area. AIRS ID: 123/9011 Page 8 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 • §63.775 (c)(7)(ii) - Calculation of the optimum glycol circulation rate determined in accordance with §63.764(d)(2)(i). • §63.775 (c)(7)(iii) - If applicable, documentation of the alternate glycol circulation rate calculated using GRI- GLYCalcTM, Version 3.0 or higher and documentation stating why the 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 (0(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 18. 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. 19. 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 for the pollutants for which the area is 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 20, shall satisfy the requirement to apply RACT. AIRS ID: 123/9011 Page 9 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11 WE1480 Air Pollution Control Division Issuance 2 20. 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 semi- annual 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. 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, AIRS ID: 123/9011 Page 10 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 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 21. 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 Periodic Testing Requirements 22. AIRS Points 001 through 004: 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. 23. 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. 24. 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 25. 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: AIRS ID: 123/9011 Page 11 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5)tons per year or more, above the level reported on the last APEN; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A. 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. 26. Federal regulatory program requirements (i.e. PSD, NANSR)shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D).) 27. 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) 28. MACT Subpart 7777 - 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: 29. 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. AIRS ID: 123/9011 Page 12 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 30. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation 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. 31. 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. 32. 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. 33. 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. 34. 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. 35. 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: AIRS ID: 123/9011 Page 13 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 Stuart Siffring Permit Engineer Permit History Issuance Date Description Issuance 2 This Issuance Modification to increase permit limits for point 006 to reflect as built condition. Change control device for still vent of point 005 from reboiler to combustor. Issuance 1 11/21/2011 Issued to DCP Midstream, LP AIRS ID: 123/9011 Page 14 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 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: http://www.cdphe.state.co.us/regulations/airreas/100102aocccommonprovisionsrea.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) Formaldehyde 5000 A 1622 Yes 389 Methanol 67561 C 355 Yes 177 Acetaldehyde 75070 A 323 Yes 162 001 Acrolein 107028 A 305 Yes 152 Benzene 71432 A 183 No 92 1,3-Butadiene 106990 A 77 No 38 Toluene 108883 C 65 No 32 Formaldehyde 5000 A 1622 Yes 389 Methanol 67561 C 355 Yes 177 Acetaldehyde 75070 A 323 Yes 162 002 Acrolein 107028 A 305 Yes 152 Benzene 71432 A 183 No 92 1,3-Butadiene 106990 A 77 No 38 Toluene 108883 C 65 No 32 Formaldehyde 5000 A 1622 Yes 389 003 Methanol 67561 C 355 Yes 177 AIRS ID: 123/9011 Page 15 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 Acetaldehyde 75070 A 323 Yes 162 Acrolein 107028 A 305 Yes 152 Benzene 71432 A 183 No 92 1,3-Butadiene 106990 A 77 No 38 Toluene 108883 C 65 No 32 Formaldehyde 5000 A 1622 Yes 389 Methanol 67561 C 355 Yes 177 Acetaldehyde 75070 A 323 Yes 162 004 Acrolein 107028 A 305 Yes 152 Benzene 71432 A 183 No 92 1,3-Butadiene 106990 A 77 No 38 Toluene 108883 C 65 No 32 Benzene 71432 A 114,889 YES 6,108 Toluene 108883 C 141,530 YES 7,605 005 Ethylbenzene 100414 C 6,136 YES 332 Xylenes 1330207 C 70,959 YES 3,863 n-Hexane 110543 C 63,874 YES 1,908 Benzene 71432 A 153 No NA Toluene 108883 C 87 No NA 006 Xylenes 1330207 C 7 No NA n-Hexane 110543 C 2501 Yes NA 5) The emission levels contained in this permit are based on the following emission factors: Points 001 through 004: Emission Factors- Emission Factors— Uncontrolled Controlled CAS Pollutant Ib/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. AIRS ID: 123/9011 Page 16 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer's specifications Manufacturer's specifications CO Manufacturers specifications Manufacturer's specifications VOC Manufacturers specifications Manufacturer's specifications 5000 Formaldehyde Manufacturers 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 Ib/MMscf; and O =6.7 lb/MMscf. Point 006: Component Gas Service Heavy Oil Light Oil ervic S Water/Oil Service Connectors 725 0 3144 0 Flanges 300 0 809 0 Open-ended Lines 0 0 0 0 Pump Seals 0 0 9 0 Valves 319 0 1019 0 Other* 26 0 25 0 VOC Content(wt%) 31.84% 100% 100% 100% *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump amens, hatches, instrument meters, polish rods and vents TOC Emission Factors (kg/hr-component): Component Gas Service Heavy Oil Light Oil ervi S Water/Oil Service Connectors 2.0E-04 7.5E-06 2.1E-04 1.1E-04 Flanges 3.9E-04 3.9E-07 1.1E-04 2.9E-06 Open-ended Lines 2.0E-03 1.4E-04 1.4E-03 2.5E-04 Pump Seals 2.4E-03 NA 1.3E-02 2.4E-05 Valves 4.5E-03 8.4E-06 2.5E-03 9.8E-05 Other 8.8E-03 3.2E-05 7.5E-03 1.4E-02 AIRS ID: 123/9011 Page 17 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 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. 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 tens 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) AIRS Points 001 through 004: Each engine is subject to 40 CFR, Part 60, Subpart JJJJ— Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal Register posting —effective March 18, 2008). This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA website at: htto://www.epa.aov/ttn/atw/area/fr18ia08.odf 8) AIRS Points 001 through 004: 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: htto://www.epa.00v/ttn/atw/area/fr18ia08.odf Additional information regarding area source standards can be found on the EPA website at: htto://www.eoa.aov/ttn/atw/area/arearules.html 9) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Major Source VOC, CO, NOx, HAPs PSD Synthetic Minor Source CO NANSR Synthetic Minor Source VOC, NOx MACT HH Area Source Requirements MACT 7777 Area Source Requirements 10) 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 AIRS ID: 123/9011 Page 18 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart 777Z—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX 11) 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: http://www.cdphe.state.co.us/ap/oilgaspermitting.html AIRS ID: 123/9011 Page 19 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 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 intemal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility-Altemative 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: 123/9011 Page 20 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 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/CDPHE-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: 123/9011 Page 21 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 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 SO2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr. For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating intemal combustion engines: VOC:The emission limitations in NSPS JJJJ CO:The emission limitations in NSPS JJJJ NOX:The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (§60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State- Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified below: • Rich bum 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: 123/9011 Page 22 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 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 NOx 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, § LB (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 7777 AIRS ID: 123/9011 Page 23 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 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 7777. 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: 123/9011 Page 24 of 24 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: DCP Midstream, LP Permit Number 11WE1480 Source Location: Bernhardt Compressor Station Section 31, T5N, R66W Equipment Description: Natural Gas Compression Facility AIRS ID: 123/9011/001 through 006 Date: 07/31/2014 Review Engineer: Stuart Siffring Control Engineer: Stefanie Rucker Section 2—Action Completed Grandfathered X Modification APEN Required/Permit Exempt X CP2 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? 7/7/2014 Section 4—Source Description AIRS Point Equipment Description One (1)Waukesha, Model L7044GSI, Serial Number TBD, natural gas-fired, turbo-charged, 4SRB reciprocating internal combustion engine, site rated at 1680 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 L7044GSI, Serial Number TBD, natural gas-fired, turbo-charged, 4SRB reciprocating internal combustion engine, site rated at 1680 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. Page 1 One(1)Waukesha, Model L7044GSI, Serial Number TBD, natural gas-fired, turbo-charged, 4SRB reciprocating internal combustion engine, site rated at 1680 003 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 TBD, natural gas-fired, turbo-charged,4SRB reciprocating internal combustion engine, site rated at 1680 004 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)Triethylene glycol (TEG) natural gas dehydration unit(QB Johnson, 630712A)with a design capacity of 50 MMscf per day. This emissions unit is equipped with one(1) electric pump(Make: Best Pump Works)with a design 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 a condenser and thn to an enclosed combustor. Emissions from the flash tank are routed to a vapor recovery unit(VRU)which returns vapors back to the inlet of the compressor station. 006 Equipment leaks (fugitive VOCs)from a natural gas compression facility. 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 any criteria pollutant? Yes X No If"yes",for what pollutant? (Note: These pollutants are subject to minor source PM10 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 001 Manufacturer's specifications 002 Manufacturer's specifications 003 Manufacturer's specifications 004 Manufacturer's specifications 005 GRI Gly-Calc v4.0(Refer to Section 14 for calculations) 006 EPA-453/R-95-017, Table 2-4 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 001 128.8 MMscf per year, 1680 hp 002 128.8 MMscf per year, 1680 hp Page 2 003 128.8 MMscf per year, 1680 hp 004 128.8 MMscf per year, 1680 hp 005 18,250 MMSCF per year, 24 gallons per minute glycol circulation rate Equipment Type Gas Heavy Oil(or Light Oil (or Water/Oil Heavy Liquid) Light Liquid) Connectors 725 3144 006 Flanges 300 809 Open-Ended Lines 0 0 Pump Seals 0 9 Valves 319 1019 Other 26 25 Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory). AIRS Point Process Consumption/Throughput/Production Data Year 005 and 006 Same as Above 2014 Basis for Permitted Emissions(Permit Limitsl AIRS Point Process Consumption/Throughput/Production 001 128.8 MMscf per year, 1680 hp 002 128.8 MMscf per year, 1680 hp 003 128.8 MMscf per year, 1680 hp 004 128.8 MMscf per year, 1680 hp 005 18,250 MMSCF per year, 24 gallons per minute glycol circulation rate Equipment Type Gas Heavy Oil (or Light Oil (or Water/Oil. Heavy Liquid) Light Liquid) Connectors 725 3144 006 Flanges 300 809 Open-Ended Lines 0 0 Pump Seals 0 9 Valves 319 1019 Other 26 25 Does this source use a control device? X Yes No % Reduction AIRS Point Process Control Device Description Pollutant Granted NOx 96.2% VOC 53.3% 001 through of NSCR and air fuel ratio controller CO 91.5% 004 HCHO 76% Other HAPs 50% 005 01 VRU for flash tank. Condenser and Combustor VOC 95% for Still Vent 006 01 None NA Section 6—Emission Summary(tons per year) Point TSP NO, VOC CO Single HAP Total HAP Facility,PTE Before 0.81 Emissions 001 1.1 212.5 24.3 189.8 1.5 formaldehyde Controls/Limits: 002 1.1 212.5 24.3 189.8 0.81 1.5 formaldehyde 003 1.1 212.5 24.3 189.8 0.81 1.5 formaldehyde Page 3 004 1.1 212.5 24.3 189.8 0.81 1.5 formaldehyde . _ 005 0.4 534.3 2.0 70.8 198.7 toluene 1.25 006° 57.0 n-hexane70.9 1.4 Total° 4.5 851.1 633.5 762.4 toluene 205.0 Point TSP NO, VOC CO Single HAP Total HAP Controlled point 0.2 source emission 001 1.1 8.1 11.4 16.2 formaldehyde 0.5 rate: 0.2 002 1.1 8.1 11.4 16.2 formaldehyde0.2 0.5 003 1.1 8.1 11.4 16.2 formaldehyde0.2 0.5 004 1.1 8.1 11.4 16.2 formaldehyde3.8 0.5 005 0.4 16.7 2.0 toluene1.25 9.9 006" 57.0 n-hexane3.9 1.4 Total° 4.5 33.5 64.3 68.0 toluene 12.4 Total permitted plant-wide 32.8 70.3 66.8 3.9 12.3 emissions`: toluene A: These emissions are fugitive sources so they are not included in the total for PTE. B: The total PTE values in this line also include emissions for insignificant activities. The facility's insignificant activities include one 2.86 MMBtu/hr dehy reboiler, pressurized condensate loadout, compressor blowdowns,two 100 bbl produced water tanks, one 1000 gallon methanol tank, 200 gallon lube oil tank, 1000 gallon glycol tanks and 80 bbl drain tank. Emission rates for insignificant activities are based on emission estimates provided with this package. 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 ere me emissions Controlled Emission AIRS ID Pollutant CAS# BIN Emission Rate reportable? Rate(lblyr) (Ib/yr) Formaldehyde 5000 A 1622 Yes 389 Methanol 67561 C 355 No 177 Acetaldehyde 75070 A 323 Yes 162 001 Acrolein 107028 A 305 Yes 152 Benzene 71432 A 183 Yes 92 1,3-Butadiene 106990 A 77 Yes 38 Toluene 108883 C 65 No 32 Formaldehyde 5000 A 1622 Yes 389 Methanol 67561 C 355 No 177 Acetaldehyde 75070 A 323 Yes 162 002 Acrolein 107028 A 305 Yes 152 Benzene 71432 A 183 Yes 92 1,3-Butadiene 106990 A 77 Yes 38 Page 4 Toluene 108883 C 65 No 32 Formaldehyde 5000 A 1622 Yes 389 Methanol 67561 C 355 No 177 Acetaldehyde 75070 A 323 Yes 162 003 Acrolein 107028 A 305 Yes 152 Benzene 71432 A 183 Yes 92 1,3-Butadiene 106990 A 77 Yes 38 Toluene 108883 C 65 No 32 Formaldehyde 5000 A 1622 Yes 389 Methanol 67561 C 355 No 177 Acetaldehyde 75070 A 323 Yes 162 004 Acrolein 107028 A 305 Yes 152 Benzene 71432 A 183 Yes 92 1,3-Butadiene 106990 A 77 Yes 38 Toluene 108883 C 65 No 32 Benzene 71432 A 114,889 YES 6,108 Toluene 108883 C 141,530 YES 7,605 005 Ethylbenzene 100414 C 6,136 YES 332 Xylenes 1330207 C 70,959 YES 3,863 n-Hexane 110543 C 63,874 YES 1,908 006 n-Hexane 110543 C 2500 Yes NA 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 NOx, CO, 001-004 01 VOC, Regulation No. 3, Part B., Section III.G.3 Stack Test , HAPS Section 9—Source Classification I Is this a new previously un-permitted source? Yes X No What is this point classification? True X Synthetic Major Minor Minor What is this facility classification? True X Synthetic 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 If"yes"what kind of modification? Minor X Synthetic Major Minor Page 5 Section 10—Public Comment Does this permit require public comment per CAQCC Regulation 3? X Yes No If'yes',for which pollutants?Why? VOC 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 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? Controlled NOx emissions<40 tpy. Controlled CO emissions< 100 tpy. AIRS Point Section 12—Regulatory Review RegulMion 1-Partiattde. 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-APENa.Construction Permits. Ooeratin4 Permits. PSI) Part A-APEN Requirements Applicant is required to tile 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 001-004 NSPS JJJ: Not currently adopted in Colorado regulations. Listed in"Notes to permit holder.° Page 6 Regulation 7—Volatile Organic Compounds Section XVI.B Applicant is located in NAA and thus required to install NSCR on rich burn engine rated greater than 500 hp. 001-004 Section XVII.E. Engines are subject to emission standards unless NSPS JJJJ and MACT 7777 requirements ultimately are applicable. 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. 005 Section XVII.D(State only enforceable). Applicant is required to reduce V0C emissions from this dehydrator by at least 90% since uncontrolled VOC emissions are greater than the 15.0 TPY threshold. Section XII.G.1. 006 Applicant is located in NAA but since it is not a gas processing facility, the requirements are not applicable. Regulation 8—Hazardous Air Pollutants 001-004 MACT ZZZZ: Area source requirements are not currently adopted in Colorado regulations. Listed in "Notes to permit holder." MACT HH: This facility is an area source of HAP and MACT HH area source requirements 005 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 practice standard in HH. 006 MACT HH: This facility is an area source of HAPs. No fugitive requirements for area sources. Section 13—Aerometric Information Retrieval System Coding Information Point Process Process Throughput Emission Pollutant/ Fugitive Emission Control Description limit Factor CAS# (Y/N) Factor Source (%) "See separate table for AIRS Coding for Points 001 through 004. 58.55 V0C No GlyCalc 4.0 97 lbs/mmscf 0.068 N0x No AP-42 — Ib/mmbtu 0.37 CO No AP-42 — lb/mmbtu 6.30 Benzene/ 18, Glycol Ibs/mmscf 71432 MSCF 005 01 Dehydrator per year 7.76 Toluene/ No GlyCalc 4.0 95 Ibs/mmscf 108883 0.34 Ethylbenzene No GlyCalc 4.0 95 Ibs/mmscf /100414 3.89 Xylenes/ No GlyCalc 4.0 95 lbs/mmscf 1330207 3.50 n-Hexane/ No GlyCalc 4.0 97 lbs/mmscf 110543 SCC 31000227: Glycol Dehydrator: reboiler still stack Fugitive 006 01 V0C NA NA V0C Yes EPA-453/R-95- NA Equipment 017,Table 2-4 Leaks Section 14—Miscellaneous Application Notes AIRS Point 005 TEG Dehydrator Modification to change still vent control device from reboiler(as reboiler fuel gas)to an enclosed combustor. Add NOx and CO emission factors from flare. Page 7 AIRS Point 006 Fugitive Emissions from Equipment Leaks Modification to correct fugitive counts based on as built condition. Facility Wide Comments This modification only changes points 006 and 005. Page 8 STATE OF COLORADO op corn COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT "` AIR POLLUTION CONTROL DIVISION * TELEPHONE: (303)692-3150 .1876•* CONSTRUCTION PERMIT PERMIT NO: 13WE1108 1 08 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 Troudt Compressor Station, located in the SENW of Section 27, Township 6N, Range 66W, 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 L7044GSI, Serial Number TBD, natural gas-fired, turbo-charged, 4SRB reciprocating internal C-306 001 combustion engine, site rated at 1680 horsepower at 1200 RPM. This engine shall be equipped with non-selective catalytic reduction (NSCR) system and air-fuel ratio control. This emission unit is used for natural gas compression. One (1)Waukesha, Model L7044GSI, Serial Number TBD, natural gas-fired, turbo-charged, 4SRB reciprocating internal C-307 002 combustion engine, site rated at 1680 horsepower at 1200 RPM. This engine shall be equipped with non-selective catalytic reduction (NSCR) system and air-fuel ratio control. This emission unit is used for natural gas compression. One (1)Waukesha, Model L7044GSI, Serial Number TBD, natural gas-fired, turbo-charged, 4SRB reciprocating internal C-308 003 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: 123/9ACB Page 1 of 26 NGEngine Version 2009-1 Colorado Department of Public Health and Environment Air Pollution Control Division Facility AIRS Description Equipment ID Point One(1)Waukesha, Model L7044GSI, Serial Number TBD, natural gas-fired, turbo-charged,4SRB reciprocating internal C-309 004 combustion engine, site rated at 1680 horsepower at 1200 RPM. This engine shall be equipped with non-selective catalytic reduction (NSCR) system and air-fuel ratio control. This emission unit is used for natural gas compression. One(1)Waukesha, Model L7044GSI, Serial Number TBD, natural gas-fired, turbo-charged, 4SRB reciprocating internal C-310 005 combustion engine, site rated at 1680 horsepower at 1200 RPM. This engine shall be equipped with non-selective catalytic reduction (NSCR) system and air-fuel ratio control. This emission unit is used for natural gas compression. One (1)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) plus one D 1 006 backup pump with a design capacity of 24 gallons per minute each. This unit is equipped with a flash tank, reboiler and still vent. Emissions from the still vent are routed to the enclosed combustor. Emissions from the flash tank are routed toa vapor recovery unit (VRU)which returns vapors back to the inlet of the compressor station. The VRU is permitted 1% annual downtime. FUG 007 Equipment leaks(fugitive VOCs)from a natural gas compression facility. The engines addressed under AIRS Points 001 through 005 may be replaced with another engine in accordance with the temporary engine replacement provision or with another Waukesha L7044GSI engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. 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 sect), 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/a0/downloadforms.html. Failure to notify the APCD of startup of 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. AIRS ID: 123/9ACB Page 2 of 26 Colorado Department of Public Health and Environment Air Pollution Control Division 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 x C-306 001 1,376 1,934 2,756 Point C-307 002 1,376 1,934 2,756 Point C-308 003 1,376 1,934 2,756 Point C-309 004 1,376 1,934 2,756 Point C-310 005 1,376 1,934 2,756 Point D-1 006 204 4,806 1122 Point FUG 007 -- 9,346 -- Fugitive Facility AIRS Pounds per Month' Emission Type VOC CO Equipment ID Points NO, AIRS ID: 123/9ACB Page 3 of 26 Colorado Department of Public Health and Environment Air Pollution Control Division O-306 001 Point O407 002 Point O408 003 5,504 7,746 11,024 Point C-309 004 Point O410 005 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 O-306 001 8.1 11.4 16.2 Point C-307 002 8.1 11.4 16.2 Point O408 003 8.1 11.4 16.2 Point O409 004 8.1 11.4 16.2 Point O410 005 8.1 11.4 16.2 Point D-1 006 1.2 28.3 6.6 Point FUG 007 — 55.0 — Fugitive Facility AIRS Tons per Year' Equipment ID Point NO VOC CO Emission Type x O-306 001 Point O-307 002 Point O-308 003 32.4 45.6 64.8 Point O409 004 Point O410 005 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. 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. AIRS ID: 123/9ACB Page 4 of 26 Colorado Department of Public Health and Environment Air Pollution Control Division 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 C306 001 Non-selective catalytic reduction system and air/fuel NOx,VOC, and CO ratio controller C 307 002 Non-selective catalytic reduction system and air/fuel NOx, VOC, and CO ratio controller C-308 003 Non-selective catalytic reduction system and air/fuel NOx, VOC, and CO ratio controller C-309 004 Non-selective catalytic reduction system and air/fuel NOR,VOC, and CO ratio controller C-310 005 Non-selective catalytic reduction system and air/fuel NOx, VOC, and CO ratio controller D-1 006 Vapor recovery unit and Combustion device VOC (detailed in condition 17) 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 115.91 C-306 001 Consumption of natural gas as fuel MMscf/yr 9.84 MMscf/month 115.91 C-307 002 Consumption of natural gas as fuel MMscf/yr 9.84 MMscf/month C-308 003 Consumption of natural gas as fuel 115.91 9.84 MMscf/yr MMscf/month C-309 004 Consumption of natural gas as fuel 115.91 9.84 MMscf/yr MMscf/month AIRS ID: 123/9ACB Page 5 of 26 Colorado Department of Public Health and Environment Air Pollution Control Division C-310 005 Consumption of natural gas as fuel 115.91 9.84 MMscf/yr MMscf/month__ 50 D-1 006 Natural gas throughput f m MMscf/yr 250 1,MMsc/month FUG 007 Not applicable Facility AIRS Annual Monthly Limit Equipment Process parameter Point Limit' (31 days)2 ID Consumption of natural gas as fuel for 463.64 39.4 C-306-C- 001- all 5 compressor engines. Total run MMscf/yr MMscf/month 310 005 time shall not exceed 35,040 compressor engine-hours per year. total total 2 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) Waukesha Engines (AIRS Points 001 through 0051 13. 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 intemal combustion engines, a non-selective catalyst reduction system and an air fuel controller shall be required. 14. 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 AIRS ID: 123/9ACB Page 6 of 26 Colorado Department of Public Health and Environment Air Pollution Control Division 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 z500HP 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 Dehv(AIRS Point 0061 15. 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. 16. The flare covered by this permit is subject to Regulation No. 7, Section XVII.B General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed, have no visible emissions during normal operations, and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. The operator shall comply with all applicable requirements of Section XVII. 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 an enclosed combustor. The control system shall reduce uncontrolled emissions of VOC and HAPS from the TEG dehydration unit 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.) 18. 99% of emissions that result from the flash tank associated with this dehydrator shall be recycled to the compressor station inlet and recompressed. 1% downtime of the VRU is allowed and during that time, the flash tank emissions shall be controlled by an enclosed combustor. 19. This unit shall be limited to the maximum lean glycol circulation rate of 24 gallons per minute. The lean glycol recirculation rate shall be recorded weekly in a log maintained on site and made available to the Division for inspection upon request. (Reference: Regulation No. 3, Part B, II.A.4) AIRS ID: 123/9ACB Page 7 of 26 Colorado Department of Public Health and Environment Air Pollution Control Division 20. This source is subject to the TEG dehydrator area source requirements of 40 CFR, Part 63, Subpart HH - National Emission Standards for Hazardous Air Pollutants for Source Categories from Oil and Natural Gas Production Facilities including, but not limited to, the following: • §63.760—Applicability and designation of affected source o §63.760 (0 -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 ofan affected area source shall achieve compliance with the provisions of this subpart by the dates specified in paragraphs (f)(3) through (f)(6) of this section. • §63.760 (0(6) - The owner or operator of an affected area source that is not located in an Urban-1 county, as defined in §63.761, the construction or reconstruction of which commences on or after July 8, 2005, shall achieve compliance with the provisions of this subpart immediately upon initial startup or January 3, 2007, whichever date is later. • §63.762—Startups, Shutdowns, and Malfunctions o The affected source shall comply with the startup, shutdown and malfunction provisions per§63.762. • §63.764-General Standards o §63.764(a) - Table 2 of this subpart specifies the provisions of subpart A (General Provisions) of this part that apply and those that do not apply to owners and operators of affected sources subject to this subpart. o §63.764(b) - All reports required under this subpart shall be sent to the Administrator at the appropriate address listed in §63.13. Reports may be submitted on electronic media. o §63.764(d)(1) — Each owner or operator of an area source located within an UA plus offset and UC boundary shall comply with the requirements specified in paragraphs (d)(1)(i)through (iii) of this section. • §63.764(d)(1)(i) —The owner or operator shall comply with the control requirements for glycol dehydration unit process vents specified in §63.765; • §63.764(d)(1)(ii) — The owner or operator shall comply with the monitoring requirements specified in §63.773; and • §63.764(d)(1)(iii) — The owner or operator shall comply with the recordkeeping and reporting requirements specified in §§63.774 and 63.775. o §63.764(l) - In all cases where the provisions of this subpart require an owner or operator to repair leaks by a specified time after the leak is detected, it is a violation of this standard to fail to take action to repair the leak(s) within the specified time. If action is taken to repair the leak(s) within the specified time, failure of that action to successfully repair the leak(s) is not a violation of this AIRS ID: 123/9ACB Page 8 of 26 Colorado Department of Public Health and Environment Air Pollution Control Division standard. However, if the repairs are unsuccessful, a leak is detected and the owner or operator shall take further action as required by the applicable provisions of this subpart. • §63.765 - Glycol Dehydration Unit Process Vent Standards o §63.765(b)(1) — For each glycol dehydration unit process vent, the owner or operator shall control air emissions by either paragraph (b)(1)(i) or (b)(1)(ii) of this section. • §63.765(b)(1)(i) — The owner or operator shall connect the process vent to a control device or a combination of control devices through a closed-vent system. The closed-vent system shall be designed and operated in accordance with the requirements of §63.771(c). The control device(s) shall be designed and operated in accordance with the requirements of§63.771(d). o §63.765(b)(2) — One or more safety devices that vent directly to the atmosphere may be used on the air emission control equipment installed to comply with §63.765(b)(1). • §63.771 —Control Equipment Requirements o §63.771(c) - The closed-vent system routing HAP emissions from the affected unit to a control device must meet the requirements of 63.771(c). o §63.771(d) - The control device used to reduce HAP emissions in accordance with the standards of this subpart must meet the requirements of §63.771 (d). • §63.772 - Test methods, compliance procedures, and compliance demonstrations o §63.772(c) - The source shall comply with the no detectable emissions test procedure per§63.772(c). o §63.772(e) - Per §63.772(e)(1)(i), a flare that is designed and operated in accordance with §63.11(b) is exempt from the requirements to conduct performance tests and design analyses under §63.772(e) except as specified in §63.772(e)(2): ▪ §63.772(e)(2) - An owner or operator shall design and operate each flare in accordance with the requirements specified in §63.11(b) and in paragraphs (e)(2)(i) and (e)(2)(ii) of this section. • §63.772(e)(2)(i) - The compliance determination shall be conducted using Method 22 of 40 CFR part 60, appendix A, to determine visible emissions. • §63.772(e)(2)(ii) - An owner or operator is not required to conduct a performance test to determine percent emission reduction or outlet organic HAP or TOC concentration when a flare is used. • §63.773—Inspection and Monitoring Requirements AIRS ID: 123/9ACB Page 9 of 26 Colorado Department of Public Health and Environment Air Pollution Control Division o §63.773(c) - For each closed-vent system required to comply with this section, the owner or operator shall comply with the requirements of §63.773(c). o §63.773(d) - For each control device, the owner or operator shall install and operate a continuous parameter monitoring system in accordance with the requirements of §63.773(d). Per §63.773(d)(3)(i)(C), the continuous monitoring system for a flare shall be a heat sensing monitoring device equipped with a continuous recorder that indicates the continuous ignition of the pilot flame. Owners or operators that install and operate a flare in accordance with §63.771(d)(1)(iii) are exempt from the requirements of §63.773 (d)(4) and §63.773(d)(5). • §63.774- Recordkeeping Requirements o §63.774(b) - Each owner or operator of a facility subject to this subpart shall maintain the records specified in §63.774(b). o §63.774(e) - When using a flare to comply with §63.771(d), the records required under§63.774(e) must be maintained. • §63.775—Reporting Requirements o §63.775(c) - Each owner or operator of an area source located within a UA plus offset and UC boundary shall submit the information listed in §63.775(c)(1)through (6). o §63.775(d) - Each owner or operator of a source subject to this subpart shall submit a Notification of Compliance Status Report as required under §63.9(h) within 180 days after the compliance date specified in §63.760(f). In addition to the information required under §63.9(h), the Notification of Compliance Status Report shall include the information specified in §63.775(d). o §63.775(e) -An owner or operator of an area source located inside a UA plus offset and UC boundary shall prepare Periodic Reports in accordance with paragraph §63.775(e)(3) and submit them to the Administrator. o §63.775(f) - Whenever a process change is made, or a change in any of the information submitted in the Notification of Compliance Status Report, the owner or operator shall submit a report within 180 days after the process change is made or as a part of the next Periodic Report as required under §63.775(e), whichever is sooner. The report shall include the information specified in §63.775(f). Fugitive Emissions (MRS Point 007) 21. 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. 22. The reciprocating compressors grouped with the fugitive emissions addressed by AIRS ID 007 are subject to the New Source Performance Standards requirements of Regulation No. 6, Part A, Subpart OOOO, Standards of Performance for Crude Oil and AIRS ID: 123/9ACB Page 10 of 26 Colorado Department of Public Health and Environment Air Pollution Control Division Natural Gas Production, Transmission and Distribution including, but not limited to, the following: • §60.5385(a) — Owner or operator must replace the reciprocating compressor rod packing according to either paragraph §60.5385(a)(1) or(2). (1) §60.5385(a)(1) - Before the compressor has operated for 26,000 hours. The number of hours of operation must be continuously monitored beginning upon initial startup of your reciprocating compressor affected facility, or October 15, 2012, or the date of the most recent reciprocating compressor rod packing replacement, whichever is later. (2) §60.5385(a)(2) - Prior to 36 months from the date of the most recent rod packing replacement, or 36 months from the date of startup for a new reciprocating compressor for which the rod packing has not yet been replaced. • §60.5410 — Owner or operator must demonstrate initial compliance with the standards as detailed in §60.5410(c). • §60.5415 —Owner or operator must demonstrate continuous compliance with the standards as detailed in §60.5415(c). • §60.5420 - Owner or operator must comply with the notification, reporting, and recordkeeping requirements as specified in §60.5420(a), §60.5420(b)(1), §60.5420(b)(4), and §60.5420(c)(3). 23. 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 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 24, shall satisfy the requirement to apply RACT. 24. 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 semi- annual 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 60.180)O). • The operator shall comply with the daily instrument checks in 40 CFR 60.180)(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: AIRS ID: 123/9ACB Page 11 of 26 Colorado Department of Public Health and Environment Air.Pollution Control Division 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 A, 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. 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 A, 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 25. AIRS Points 001-006: 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 AIRS ID: 123/9ACB Page 12 of 26 Colorado Department of Public Health and Environment Air Pollution Control Division 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 26. AIRS Points 001 through 005: A source initial compliance test shall be conducted on emissions point 001, 002, 003, 004 and 005 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 27. AIRS Point 006: A source initial compliance test shall be conducted on emissions point 006 to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emission limits in this permit. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time (Reference: Regulation No. 3, Part B., Section III.G.3) Volatile Organic Compounds using EPA approved methods. 28. AIRS Point 006: 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: The owner or operator shall demonstrate compliance with Condition 16, using EPA Method 22 to measure opacity from the flare. Periodic Testing Requirements 30. AIRS Points 001 through 005: 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 006: 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 AIRS ID: 123/9ACB Page 13 of 26 Colorado Department of Public Health and Environment Air Pollution Control Division analysis shall be used to calculate emissions of criteria pollutants and hazardous air pollutants per this permit. 32. AIRS Point 007: 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. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5)tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO,J in ozone nonattainment areas emitting less than 100.tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. 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. AIRS Points 001-005: 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 altemative-operating scenario and is installing a permanent replacement engine. 34. 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 AIRS ID: 123/9ACB Page 14 of 26 Colorado Department of Public Health and Environment Air Pollution Control Division not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). 35. 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: 37. 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. 38. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation 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. 39. 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. 40. 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. 41. 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 AIRS ID: 123/9ACB Page 15 of 26 Colorado Department of Public Health and Environment Air Pollution Control 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. 42. 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. 43. 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: Stuart Si (ring Permit Engineer Permit History Issuance Date Description Issuance 2 This Issuance Modification to point 007 (fugitives) for the actual hard count performed. Also update point 006 to allow for minor design changes for the dehydrator control device. Updated permit to reflect self-certification documents already submitted. Issuance 1 11/23/2013 Issued to DCP Midstream, LP. Newly permitted compressor station with (5) engines, (1)TEG dehydrator and combustor and associated fugitives. Synthetic minor facility. AIRS ID: 123/9ACB Page 16 of 26 Colorado Department of Public Health and Environment Air Pollution Control Division 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: http://www.cdphe.state.co.us/regulations/airreqs/100102acicccommonprovisionsreq.odf. 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) 6488 (1622 for 1556 (389 for Formaldehyde 50000 A each individ. Yes each individ. running running engine) engine) 1420 (355 for 708 (177 for Methanol 67561 C each individ. Yes each individ. running running engine) engine) 1292 (323 for 648 (162 for Acetaldehyde 75070 A each individ. Yes each individ. running running engine) engine) 001- 1220 (305 for 608 (152 for 005 Acrolein 107028 A each individ. Yes each individ. each running running engine) engine) 732 (183 for 368 (92 for each individ. each individ. Benzene 71432 A running Yes running engine) engine) 308(77 for 152 (38 for 1,3-Butadiene 106990 A each individ. each individ. Yes running running engine) engine) 260 (65 for 128(32 for Toluene 108883 C each individ. Yes each individ. running running engine) engine) AIRS ID: 123/9ACB Page 17 of 26 Colorado Department of Public Health and Environment Air Pollution Control Division Benzene 71432 A 158,460 Yes 9,179 Toluene 108883 C 198,589 Yes 11,634 006 Ethylbenzene 100414 C 8,581 Yes 508 Xylenes 1330207 C 96,959 Yes 5,757 n-Hexane 110543 C 87,160 Yes 3,053 Benzene 71432 A 159 No NA Toluene 108883 C 69 No NA 007 Xylenes 1330207 C 8 No NA n-Hexane 110543 C 2588 Yes NA Note: DCP shall be running four (4) engines at a from the five (5) engines onsite, therefore, combining HAP emissions between four engines. 5) The emission levels contained in this permit are based on the following emission factors: Points 001 through 005: Emission Factors- Emission Factors— Uncontrolled Controlled CAS Pollutant Ib/MMBtu g/bhp-hr Ib/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 1000 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer's specifications Manufacturer's specifications CO Manufacturer's specifications Manufacturer's specifications VOC Manufacturer's specifications Manufacturer's specifications 50000 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 AIRS ID: 123/9ACB Page 18 of 26 Colorado Department of Public Health and Environment Air Pollution Control Division CAS Pollutant Uncontrolled EFSource Controlled EF Source Natural Gas Point 006: 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; = 121.8 lb/MMscf; and O = 1.88 lb/MMscf. CAS Pollutant Ib/MMBtu Source NOx 0.068 AP-42, Table 13.5-1 CO 0.370 AP-42, Table 13.5-1 Point 007: Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 1689 0 1895 0 Flanges 321 0 802 0 Open-ended Lines 0 0 0 0 Pump Seals 0 0 10 0 Valves 389 0 970 0 Other* 24 0 34 0 VOC Content(wt%) 31.84% 100% 100% 100% *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms, hatches, instrument meters, polish rods and vents TOC Emission Factors (kg/hr-component): Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 2.0E-04 7.5E-06 2.1E-04 1.1E-04 Flanges 3.9E-04 3.9E-07 1.1E-04 2.9E-06 Open-ended Lines 2.0E-03 1.4E-04 1.4E-03 2.5E-04 Pump Seals 2.4E-03 NA 1.3E-02 2.4E-05 Valves 4.5E-03 8.4E-06 2.5E-03 9.8E-05 Other 8.8E-03 3.2E-05 7.5E-03 1.4E-02 Source: EPA-453/R95-017 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. AIRS ID: 123/9ACB Page 19 of 26 Colorado Department of Public Health and Environment Air Pollution Control Division 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 005: Each engine is subject to 40 CFR, Part 60, Subpart JJJJ— Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal Register posting —effective March 18, 2008). This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA website at: http://www.epa.gov/ttn/atw/area/fr18ia08.pdf 9) AIRS Points 001 through 005: Each engine is subject to 40 CFR, Part 63, Subpart 7777-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: htto://www.eoa.00v/ttn/atw/area/fr18ia08.Ddf Additional information regarding area source standards can be found on the EPA website at: http://www.epa.pov/ttn/atw/area/arearules.html 10) This facility is classified as follows: Applicable Status Requirement Minor Source:VOC Operating Permit Synthetic Minor Source CO, NOx, benzene,toluene, xylenes, n-hexane,total HAPs PSD Synthetic Minor Source CO NANSR Synthetic Minor Source VOC, NOx MACT HH Area Source Requirements MACT 7777 Area Source Requirements AIRS ID: 123/9ACB Page 20 of 26 Colorado Department of Public Health and Environment Air Pollution Control Division 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 SubpartA—SubpartKKKK 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 QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXX)O( 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: http://www.cdphe.state.co.us/ap/oilgaspermitting.html AIRS ID: 123/9ACB Page 21 of 26 Colorado Department of Public Health and Environment Air Pollution Control Division ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES October 12,2012 2.Alternative Operating Scenarios The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating intemal 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: 123/9ACB Page 22 of 26 Colorado Department of Public Health and Environment Air Pollution Control Division 2.1.2 The owner or operator may permanently replace the existing compressor engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. 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/CDPHE-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: 123/9ACB Page 23 of 26 Colorado Department of Public Health and Environment Air Pollution Control Division For comparison with a short-term limit that is either input based (Ib/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine will be subject to,the results of the test shall be converted to the appropriate units as described in the above-mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline. 2.3 Applicable Regulations for Permanent Engine Replacements 2.3.1 Reasonably Available Control Technology(RACT): Reg 3, Part B§II.D.2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and to NOX and SO2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr. For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating intemal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOX: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (§60.331) and 40 CFR Part 72 (§72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State- Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified below: Rich bum engines with a manufacturer's design rate greater than 500 hp shall use a non- selective catalyst and air fuel controller to reduce emission. Lean bum engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. AIRS ID: 123/9ACB Page 24 of 26 • Colorado Department of Public Health and Environment Air Pollution Control Division The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. Emission Standards: Section XVII.E—State-only requirements Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Construction or Emission Standards in G/hp-hr Max Engine HP Relocation Date NOx 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, them will be an additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, § I.B (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. 2.3.4 Reciprocating internal combustion engine(RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting AIRS ID: 123/9ACB Page 25 of 26 Colorado Department of Public Health and Environment Air Pollution Control Division 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: 123/9ACB Page 26 of 26 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information • Company Name: DCP Midstream, LP Permit Number: 13WE1108 Source Location: Troudt Compressor Station SENW Section 27,T6N, R66W Point 001: 4SRB RICE Point 002: 4SRB RICE Point 003: 4SRB RICE Equipment Description: Point 004: 4SRB RICE Point 005: 4SRB RICE Point 006: TEG glycol dehydrator Point 007: Fugitive emissions (See 13WE1108.CP2.Point 007 for emissions information) AIRS ID: 123/9ACB Date: 8/15/2014 Review Engineer: Stuart Siffring Control Engineer: Stefanie Rucker Section 2—Action Completed Grandfathered X Modification APEN Required/Permit Exempt X CP2 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? 8/1/2014 Section 4—Source Description AIRS Point Equipment Description One(1)Waukesha, Model L7044GSI, Serial Number TBD, natural gas-fired, turbo- charged, 4SRB reciprocating internal combustion engine, site rated at 1680 horsepower 001 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. Page 1 I — One(1)Waukesha, Model L7044GSI, Serial Number TBD, natural gas-fired, turbo- charged, 4SRB reciprocating internal combustion engine, site rated at 1680 horsepower 002 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 TBD, natural gas-fired, turbo- charged, 4SRB reciprocating internal combustion engine, site rated at 1680 horsepower 003 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 TBD, natural gas-fired, turbo- charged, 4SRB reciprocating internal combustion engine, site rated at 1680 horsepower 004 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 TBD, natural gas-fired, turbo- charged, 4SRB reciprocating internal combustion engine, site rated at 1680 horsepower 005 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)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) plus one backup pump with a design capacity of 24 gallons per minute 006 each. This unit is equipped with a flash tank, reboiler and still vent. Emissions from the still vent are routed to an enclosed combustor. Emissions from the flash tank are routed to a vapor recovery unit(VRU)which returns vapors back to the inlet of the compressor station. During VRU downtime, the flash tank vapors are routed to an enclosed combustor. 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? PMro 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 PM10 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 001 Manufacturer's specifications 002 Manufacturer's specifications 003 Manufacturer's specifications 004 Manufacturer's specifications 005 Manufacturer's specifications Page 2 006 GRI Gly-Calc v4.0 (Refer to Section 14 for calculations) 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 001 115.9 MMscf per year, 1680 hp 002 115.9 MMscf per year, 1680 hp 003 115.9 MMscf per year, 1680 hp 004 115.9 MMscf per year, 1680 hp 005 115.9 MMscf per year, 1680 hp 006 18,250 MMSCF per year, 24 gallons per minute glycol circulation rate 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 001 115.9 MMscf per year, 1680 hp 002 115.9 MMscf per year, 1680 hp 003 115.9 MMscf per year, 1680 hp 004 115.9 MMscf per year, 1680 hp 005 115.9 MMscf per year, 1680 hp 006 18,250 MMSCF per year, 24 gallons per minute glycol circulation rate Does this source use a control device? X Yes No '% Reduction AIRS Point Process Control Device Description Pollutant Granted NOx 96.2% VOC 53.3% 001 through Di NSCR and air fuel ratio controller CO 91.5% 005 HCHO 76% Other HAPs 50% VRU for flash tank and an enclosed combustor —97% (based 006 01 for Still Vent VOC on Glycalc) Section 6—Emission Summary(tons per year) Point TSP NO, VOC CO Single HAP Total HAP 001 002 3.2 Facility,PTE Before 003 4.4 850.0 97.2 759.2 formaldehyde 6.0 Emissions 004 Controls/Limits: 006 006 --- --- 731.58 -- 99.29 270.3 toluene Point TSP NO, VOC CO Single HAP Total HAP Page 3 001 002 0.8 003 4.4 32.4 45.6 64.8 formaldehyde 2.0 Controlled point 004 source emission rate: 005 006 — — 28.28 — 5.82 15.0 toluene Insig. 0.1 0.6 2.0 1.1 0.02 0.02 n-hexane Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled Melts emissions Controlled Emission ID Pollutant CAS# BIN Emission Rate reportable? Rate(Ibyr) (Ibyr) 6488(1622 for 1556(389 for Formaldehyde 50000 A each individ. Yes each individ. running engine) running engine) 1420(355 for 708(177 for each Methanol 67561 C each individ. No individ. running running engine) engine) 1292 (323 for 648(162 for each Acetaldehyde 75070 A each individ. Yes individ. running running engine) engine) 1220(305 for 608(152 for each 001-005 Acrolein 107028 A each individ. Yes individ. running each running engine) engine) 732 (183 for 368 (92 for each Benzene 71432 A each individ. Yes individ. running running engine) engine) 308 (77 for 152 (38 for each 1,3-Butadiene 106990 A each individ. Yes individ. running running engine) engine) 260 (65 for 128(32 for each Toluene 108883 C each individ. No individ. running running engine) engine) Benzene 71432 A 158,460 YES 9179 Toluene 108883 C 198,589 YES 11634 006 Ethylbenzene 100414 C 8,581 YES 508 Xylenes 1330207 C 96,959 YES 5757 n-Hexane 110543 C 87,160 YES 3053 Note: Regulation 3, Part A, Section ll.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? Page 4 If"yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method NOx, CO, 001-005 01 VOC, Regulation No. 3, Part B., Section III.G.3 Stack Test HAPS 006 01 VOC, Regulation No. 3, Part B, Section III.E. Extended gas HAPS analysis 006 01 VOC, State Only Requirement Method 22 HAPS Section 9—Source Classification Is this a new previously un-permitted source? Yes X No What is this facility classification? True X Synthetic 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 If"yes"what kind of modification? Minor X Synthetic 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? NOx,CO,VOC and, HAP 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 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? Controlled NOx emissions <40 tpy. Controlled CO emissions < 100 tpy. 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, Operating 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. (Req. 3, Part B, Section II.D.2) Regulation 6-New Source Performance Standards Page 5 001-005 NSPS JJJ: Not currently adopted in Colorado regulations. Listed in °Notes to permit holder." 006 None Regulation 7- Comskitinik Section XVI.B Applicant is located in NAA and thus required to install NSCR on rich bum engine rated greater than 500 hp. 001-005 Section XVII.E. Engines are subject to emission standards unless NSPS JJJJ and MACT 7777 requirements ultimately are applicable. Is this source subject to the control requirements of MACT HH? (Regulation 8-Hazardous Air Pollutants review). Yes 006 This source is subject to the more stringent Federal rules of MACT HH and, therefore, not subject to Regulation 7 controls requirements. Section XII.H: Is this source located in the non-attainment area? Yes 006 This source is not subject to this regulation since it is subject to the control requirements of MACT HH. Section XVII.D(State only enforceable). 006 Applicant is not subject to this regulation since it is subject to the control requirements of MACT HH. 'rReoulaf x 8—Hazardous Airtolifitards ', ,r 001-005 MACT=: Area source requirements are not currently adopted in Colorado regulations. Listed in "Notes to permit holder." MACT HH: If facility is MAJOR source for HAP (summation of HAPS of dehydrators and fugitives greater than 25 TPY total or 10 TPY single HAP),then all glycol dehydrators at this facility are subject to MACT HH. If facility is an area source of HAP,only TEG dehydrators are subject to MACT HH. 1.ls facility a production field facility per 63.761 (Refer to Section 14 for definition)?Yes 2.If facility is defined as a production facility, then is it a major source of HAPS when 006 summing up dehydrator and flash tank emissions?No 3.Is this facility considered MAJOR for HAPS? No 4.Is this source subject to MACT HH?No 5.WHY? This facility is an area source of HAP and MACT HH area source requirements apply to this TEG dehydrator. This dehydrator is located within an urban cluster or within two miles of an urban area, and is subject to the emission control requirements in HH. Section 13—Aerometric Information Retrieval System Coding Information Point Process Process Throughput Emission Pollutant/ Fugitive Emission Control Description limit Factor CAS# (Y/N) Factor Source (%) 13.1 gI1 p NOx No Manufacturer 96.2 hr 11.7 g/hp CO No Manufacturer 53.3 hr 001- 01 4SRB 115.9 1.5 g/hp-hr VOC No Manufacturer 91.5 005 RICE MMscf/yr 0.05 g/hp- Formaldehyde/ No Manufacturer 76 hr 50000 3.06 e-3 Methanol/ AP-42, Table Ib/MMbtu 67561 N° 3.2-3 50 2.79e-3 Acetaldehyde AP-42,Table lb/MMbtu /75070 No 3.2-3 50 Page 6 2.63e-3 Acrolein/ AP-42, Table lb/MMbtu 107028 No 3.2-3 50 1.58-3 Benzene/ AP-42, Table Ib/MMbtu 71432 No 3.2-3 50 6.63e_3 gutadiene/ No AP-42, Table 50 lb/MMbtu 106990 3.2-3 5.58 e-4 Toluene/ AP-42,Table lb/MMbtu 108883 No 3.2-3 50 SCC 20200253: 4-cycle rich burn 80.17 VOC No GIyCaIc 4.0 97 Ibs/mmscf 8.68 Benzene/ No GIyCaIc 4.0 95 Ibs/mmscf 71432 1088 Toluene/ 1825O 01 Glycol MMSCF Ibs/mmsc108883 006 Dehydrator per year 0.47 Ethylbenzene No GIyCaIc 4.0 97 lbs/mmscf /100414 5.31 Xylenes/ No GIyCaIc 4.0 97 Ibs/mmscf 1330207 4.78 n-Hexane/ No GIyCaIc 4.0 97 Ibs/mmscf 110543 SCC 31000227: Glycol Dehydrator: reboiler still stack Section 14—Miscellaneous Application Notes AIRS Point 001-005 Waukesha Engines, 1680 hp each A permit will be issued because the uncontrolled VOC emissions are greater than 5 TPY CO(permit threshold). The 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 7777 and NSPS JJJJ requirements. Page 7 AIRS Point 006 TEG Dehydrator This modification covers the TEG Dehydrator.The changes include removing the condenser as a control device,allowing 1%VRU downtime,and using dry stripping gas. 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 an enclosed combustor. The flash tank emissions are routed back to the plant inlet via a vapor recovery unit(VRU). The reboiler is rated at 2.86 MMbtulhr. In order to determine emissions,the operator used GRI GlyCALC 4.0. The source assumed an inlet gas temperature of 100°F and pressure of 900 psig and I confirmed these values were used in the GlyCALC report. The permitted glycol recirculation rate of 24.0 gallons per minute is also used in the GlyCALC report. Since the facility is a proposed, new facility, a site-specific gas analysis was not available for emission calculations. The source stated that they compiled various gas samples from the area which they felt to be representative of the gas for the facility. This method is appropriate for a new facility. An extended gas analysis will be required as part of the self-certification process to confirm emissions. Gly-Calk-Uncontrolled Emission factors VOC= ((382.3927+262.9553)'2000)/(50'365)=70.72 lb/mmscf(matches APEN) Benzene=((76.2803+2.7629)'2000)/(50'365)=8.66 Ib/mmscf(matches APEN) Toluene=((96.7547+2.3678)'2000)/(50'365)= 10.86 lb/mmsd(matches APEN) Ethylbenzene=((4.2218+0.0626)'2000)/(50'365)=0.47 Ib/mmscf(matches APEN) Xylenes=((47.9212+0.5126)'2000)/(50'365)=5.31 lb/mmsd(matches APEN) N-hexane=((21.0763+18.3240)'2000)/(50'365)=4.32 Ib/mmsd(matches APEN) MACT HH includes requirements for both major and area sources of HAPs. The definition of major source for MACT HH (63.761)states: (3) For facilities that are production field facilities, only HAP emissions from glycol dehydration units and storage vessels with the potential for flash emissions shall be aggregated for a major source determination. For facilities that are not production field facilities, HAP emissions from all HAP emission units shall be aggregated for a major source determination. The following definitions from 63.761 are also needed to determine major source applicability: Production field facilities means those facilities located prior to the point of custody transfer Custody transfer means the transfer of hydrocarbon liquids or natural gas: after processing and/or treatment in the producing operations, or from storage vessels or automatic transfer facilities or other such equipment, including product loading racks,to pipelines or any other forms of transportation. For the purposes of this subpart,the point at which such liquids or natural gas enters a natural gas processing plant is a point of custody transfer. Natural gas processing plant(gas plant) means any processing site engaged in the extraction of natural gas liquids from field gas, or the fractionation of mixed NGL to natural gas products,or a combination of both. Based on the definitions above,this source qualifies as a production field facility since it is prior to entering a natural gas processing plant. For a production field facility,only HAP emissions from dehys and storage tanks with flash emissions are included for determining major source status. The facility's storage tanks are pressurized bullet tanks and there is only one dehy. Using the requested throughput limit of 50 MMscfd and glycol recirculation rate of 24 gpm, uncontrolled VOC emissions from the dehy are 645.35 tpy VOC, uncontrolled total HAP emissions are 270.3 tpy,and uncontrolled toluene emissions are 99.1 tpy. Controlled total HAP emissions from the dehy are 11.3 tpy and controlled toluene emissions are 4.4 tpy. Controlled emissions are based on 100%of flash tank emissions being recycled and 95%control of still vent emissions. 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. Page 8 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 lb/yr in 63.764(e)(ii) because controlled benzene emissions are estimated at 8180 lb/yr. Based on the location information provided in the application, the source is not within an UA Plus Offset but is within 2 miles of a UC boundary. Thus, as an area source inside of a UC boundary, it is eligible for the control requirements in MACT HH. The dehydrator is controlled by an enclosed combustor. These requirements will be listed in the permit. Regulation 7 control requirements will not be included in the permit since it meets the more stringernt rules of MACT HH. I emailed the operator on 3/14/13 to let them know that this facility will be subject to MACT HH control requirements for the TEG. The unit is equipped 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). Criteria pollutant emission levels for this unit are based on factors from AP-42, Chapter 1.4, Small Boilers< 100 MMBtu/hr (7/1998). Insignificant Activities The source provided emission estimates for several insignificant activities at the facility. Since APENs were not submitted for these insignificant activities, emissions and regulatory applicability were not evaluated for these activities/points. Emissions listed in the application were included in the history file to understand total facility emissions but otherwise not reviewed as part of this permit action. The facility's insignificant activities include one 2.86 MMBtu/hr dehy reboiler, two 30,000 gallon pressurized condensate storage tanks, pressurized condensate loadout, compressor blowdowns,two 100 bbl produced water tanks, one 1000 gallon methanol tank, 200 gallon lube oil tank, 1000 gallon glycol tanks and 80 bbl drain tank. Facility Wide Comments This modification also covers the removal of the ECD-1 (Point 008)as a control device. The emissions are now accounted for in the dehy point 006. Page 9 STATE OF COLORADO „c C `k. (b•, COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION 6• .1.9 , 1 TELEPHONE: (303)692-3150 'Ian« CONSTRUCTION PERMIT PERMIT NO: 12WE3179 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 SLW Compressor Station, located in the NWNW of Section 7, Township 5N, Range 63W, 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 L7044GSI, Serial Number TBD, natural gas-fired, turbo-charged, 4SRB reciprocating internal C-301 001 combustion engine, site rated at 1680 horsepower at 1200 RPM. This engine shall be equipped with non-selective catalytic reduction (NSCR) system and air-fuel ratio control. This emission unit is used for natural gas compression. One (1) Waukesha, Model L7044GSI, Serial Number TBD, natural gas-fired, turbo-charged, 4SRB reciprocating internal C-302 002 combustion engine, site rated at 1680 horsepower at 1200 RPM. This engine shall be equipped with non-selective catalytic reduction (NSCR) system and air-fuel ratio control. This emission unit is used for natural gas compression. One (1)Waukesha, Model L7044GSI, Serial Number TBD, natural gas-fired, turbo-charged, 4SRB reciprocating internal C-303 003 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: 12319A95 Page 1 of 27 NGEngine Version 2009-1 • Colorado Department of Public Health and Environment Air Pollution Control Division Facility AIRS Description Equipment ID Point One (1)Waukesha, Model L7044GSI, Serial Number TBD, natural gas-fired, turbo-charged, 4SRB reciprocating internal C-304 004 combustion engine, site rated at 1680 horsepower at 1200 RPM. This engine shall be equipped with non-selective catalytic reduction (NSCR) system and air-fuel ratio control. This emission unit is used for natural gas compression. One(1)Waukesha, Model L7044GSI, Serial Number TBD, natural gas-fired, turbo-charged, 4SRB reciprocating internal C-305 005 combustion engine, site rated at 1680 horsepower at 1200 RPM. This engine shall be equipped with non-selective catalytic reduction (NSCR) system and air-fuel ratio control. This emission unit is used for natural gas compression. One (1) 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) plus one D-1 006 backup pump with a design capacity of 24 gallons per minute each. This unit is equipped with a flash tank, reboiler and still vent. Emissions from the still vent are routed to the enclosed combustor. Emissions from the flash tank are routed to a vapor recovery unit (VRU)which returns vapors back to the inlet of the compressor station. The VRU is permitted 1% annual downtime. FUG 007 Equipment leaks(fugitive VOCs)from a natural gas compression facility. The engines addressed under AIRS Points 001 through 005 may be replaced with another engine in accordance with the temporary engine replacement provision or with another Waukesha L7044GSI engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. 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 sea), 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/downloadforms.html. Failure to notify the APCD of startup of 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. AIRS ID: 123/9A95 Page 2 of 27 Colorado Department of Public Health and Environment Air Pollution Control Division 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; (Hi) 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 VOC CO Equipment ID Point NO, C-301 001 1,376 1,934 2,756 Point C-302 002 1,376 1,934 2,756 Point C-303 003 1,376 1,934 2,756 Point C-304 004 1,376 1,934 2,756 Point C-305 005 1,376 1,934 2,756 Point D-1 006 204 4,806 1122 Point FUG 007 --- 9,346 --- Fugitive Facility AIRS Pounds per Month' Emission Type Equipment ID Points NO VOC CO AIRS ID: 123/9A95 Page 3 of 27 Colorado Department of Public Health and Environment Air Pollution Control Division C-301 001 Point C-302 002 Point C-303 003 5,504 7,746 11,024 Point C-304 004 Point C-305 005 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-301 001 8.1 11.4 16.2 Point C-302 002 8.1 11.4 16.2 Point C-303 • 003 8.1 11.4 16.2 Point C-304 004 8.1 11.4 16.2 Point C405 005 8.1 11.4 16.2 Point D-1 006 1.2 28.3 6.6 Point FUG 007 — 55.0 — Fugitive ECD-1 008 — — 3.0 Point Facility AIRS Tons per Year' Equipment ID Point NO, VOC CO Emission Type C-301 001 Point C-302 002 Point C-303 003 32.4 45.6 64.8 Point C-304 004 Point C-305 005 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 am 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. 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. AIRS ID: 12319A95 Page 4 of 27 Colorado Department of Public Health and Environment Air Pollution Control Division 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 301 001 Non-selective catalytic reduction system and air/fuel NOR,VOC, and CO ratio controller C-302 002 Non-selective catalytic reduction system and air/fuel NOx,VOC, and CO ratio controller C-303 003 Non-selective catalytic reduction system and air/fuel NOR, VOC, and CO ratio controller C-304 004 Non-selective catalytic reduction system and air/fuel NOx, VOC, and CO ratio controller C-305 005 Non-selective catalytic reduction system and air/fuel NOx, VOC, and CO ratio controller D-1 006 Vapor recovery unit and Combustion device VOC (detailed in condition 17) 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 C-301 001 Consumption of natural gas as fuel 115.91 9.84 MMscf/yr MMscf/month C-302 002 Consumption of natural gas as fuel 115.91 9.84 MMscf/yr MMscf/month C-303 003 Consumption of natural gas as fuel 115.91 9.84 MMscf/yr MMscf/month AIRS ID: 123/9A95 Page 5 of 27 Colorado Department of Public Health and Environment Air Pollution Control Division C-304 004 Consumption of natural gas as fuel 115.91 9.84 MMscf/yr MMscf/month C-305 005 Consumption of natural gas as fuel 115.91 9.84 MMscf/yr MMscf/month D-1 006 Natural gas throughput 18,250 1,550 MMscf/yr MMscf/month FUG 007 Not applicable Facility AIRS Annual Monthly Limit Equipment Point Process Parameter Limit (31 days)Z ID C-301 001 C402 002 Consumption of natural gas as fuel for C-303 003 all 5 compressor engines.Total run MMscf/yr cf m time shall not exceed 35,040 MMscftyr MMscf/month C404 004 compressor engine-hours per year. total total C-305 005 2 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 am 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) Waukesha Engines (AIRS Points 001 through 0051 13. 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 intemal combustion engines, a non-selective catalyst reduction system and an air fuel controller shall be required. AIRS ID: 12319A95 Page 6 of 27 Colorado Department of Public Health and Environment Air Pollution Control Division 14. 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 z500HP 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 0061 15. 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. 16. The flare covered by this permit is subject to Regulation No. 7, Section XVII.B General Provisions (State only enforceable). If a flare or other combustion device is used to. control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed, have no visible emissions during normal operations, and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. The operator shall comply with all applicable requirements of Section XVII. 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 an enclosed combustor. The control system shall reduce uncontrolled emissions of VOC and HAPS from the TEG dehydration unit 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.) 18. 99% of emissions that result from the flash tank associated with this dehydrator shall be recycled to the compressor station inlet and recompressed. 1% downtime of the VRU is allowed and during that time, the flash tank emissions shall be controlled by an enclosed combustor. AIRS ID: 123/9A95 Page 7 of 27 Colorado Department of Public Health and Environment Air Pollution Control Division 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) or is deemed exempt under §63.764 (e)(1), then maximum recirculation rate shall not exceed 24.0 gallons per minute. The owner or operator shall maintain weekly 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 HH - National Emission Standards for Hazardous Air Pollutants for Source Categories from Oil and Natural Gas Production Facilities including, but not limited to, the following: • §63.760—Applicability and designation of affected source 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 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: AIRS ID: 123/9A95 Page 8 of 27 Colorado Department of Public Health and Environment Air Pollution Control Division L =1.15*3.0 gal TEG* F*(I—O) lbH2O �24hr/day Where: LoPT = Optimal circulation rate, gal/hr. p F = Gas flowrate (MMSCF/D) I = Inlet water content (lb/MMSCF) O = Outlet water content (Ib/MMSCF) 3.0 = The industry accepted rule of thumb for a TEG-to water ratio (gal TEG/IbHZO) 1.15 = Adjustment factor included for a margin of safety. • §63.764 (d)(2)(ii) — Operate the TEG dehydration unit such that the actual glycol circulation rate does not exceed the optimum glycol circulation rate determined in accordance with paragraph (d)(2)(i) of this section. If the TEG dehydration unit is unable to meet the sales gas specification for moisture content using the glycol circulation rate determined in accordance with paragraph (d)(2)(i), the owner or operator must calculate an alternate circulation rate using GRI— GLYCalcTM, Version 3.0 or higher. The owner or operator must document why the TEG dehydration unit must be operated using the alternate circulation rate and submit this documentation with the initial notification in accordance with §63.775(c)(7). • §63.764 (d)(2)(iii) — Maintain a record of the determination specified in paragraph (d)(2)(ii) in accordance with the requirements in §63.774(f) and submit the Initial Notification in accordance with the requirements in §63.775(c)(7). If operating conditions change and a modification to the optimum glycol circulation rate is required, the owner or operator shall prepare a new determination in accordance with paragraph (d)(2)(i) or (ii) of this section and submit the information specified under§63.775(c)(7)(ii) through (v). • §63.774 - 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 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 AIRS ID: 123/9A95 Page 9 of 27 Colorado Department of Public Health and Environment Air Pollution Control Division 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 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). AIRS ID: 123/9A95 Page 10 of 27 Colorado Department of Public Health and Environment Air Pollution Control Division • §63.775 (c)(7)(iii) - If applicable, documentation of the alternate glycol circulation rate calculated using GRI- GLYCalcTM, Version 3.0 or higher and documentation stating why the TEG dehydration unit must operate using the alternate glycol circulation rate. • §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 007) 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. The reciprocating compressors grouped with the fugitive emissions addressed by AIRS point 007 are subject to the New Source Performance Standards requirements of Regulation No. 6, Part A, Subpart OOOO, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution including, but not limited to, the following: • §60.5385(a) — Owner or operator must replace the reciprocating compressor rod packing according to either paragraph §60.5385(a)(1) or(2). (1) §60.5385(a)(1) - Before the compressor has operated for 26,000 hours. The number of hours of operation must be continuously monitored beginning upon initial startup of your reciprocating compressor affected facility, or AIRS ID: 123/9A95 Page 11 of 27 Colorado Department of Public Health and Environment Air Pollution Control Division October 15, 2012, or the date of the most recent reciprocating compressor rod packing replacement, whichever is later. (2) §60.5385(a)(2) - Prior to 36 months from the date of the most recent rod packing replacement, or 36 months from the date of startup for a new reciprocating compressor for which the rod packing has not yet been replaced. • §60.5410 — Owner or operator must demonstrate initial compliance with the standards as detailed in §60.5410(c). • §60.5415—Owner or operator must demonstrate continuous compliance with the standards as detailed in §60.5415(c). • §60.5420 - Owner or operator must comply with the notification, reporting, and recordkeeping requirements as specified in §60.5420(a), §60.5420(b)(1), §60.5420(b)(4), and §60.5420(c)(3). 25. 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 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 26, shall satisfy the requirement to apply RACT. 26. 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 semi- annual 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. AIRS ID: 123/9A95 Page 12 of 27 Colorado Department of Public Health and Environment Air Pollution Control Division 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 A, 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 five 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. 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 27. AIRS Points 001-006: 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 AIRS ID: 123/9A95 Page 13 of 27 Colorado Department of Public Health and Environment Air Pollution Control Division 28. AIRS Points 001 through 005: A source initial compliance test shall be conducted on emissions point 001, 002, 003, 004 and 005 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 29. AIRS Point 006: 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.) 30. AIRS Point 006: The owner or operator shall demonstrate compliance with Condition 16, using EPA Method 22 to measure opacity from the flare. Periodic Testing Requirements 31. AIRS Points 001 through 005: 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. 32. AIRS Point 006: 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. 33. AIRS Point 007: 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 34. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30'"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 AIRS ID: 12319A95 Page 14 of 27 Colorado Department of Public Health and Environment Air Pollution Control Division For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. 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. 1. AIRS Points 001-005: 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. 35. 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). 36. 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) 37. MACT Subpart 7777 - 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: AIRS ID: 12319A95 Page 15 of 27 Colorado Department of Public Health and Environment Air Pollution Control Division 38. 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 f ee. 39. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation 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. 40. 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. 41. 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. 42. 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. 43. 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. 44. 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. AIRS ID: 12319A95 Page 16 of 27 Colorado Department of Public Health and Environment Air Pollution Control Division By: r . + ,l&'P. n Stuart Siffring Permit Engineer Permit History Issuance Date Description Issuance 2 This Issuance Modification to point 007 (fugitives) for the actual hard count performed. Also update point 006 to allow for minor design changes for the dehydrator control device. Updated permit to reflect self-certification documents already submitted. Issuance 1 11/7/2013 Issued to DCP Midstream, LP. Newly permitted compressor station with (5) engines, (1) TEG dehydrator and combustor and associated fugitives. Synthetic minor facility. AIRS ID: 123/9A95 Page 17 of 27 Colorado Department of Public Health and Environment Air Pollution Control Division 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/regulations/airregs/100102aocccommonprovisionsreo.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 (lb/yr) reportable? Rate(lb/yr) 6488 (1622 for 1556(389 for Formaldehyde 50000 A each individ. Yes each individ. running running engine) engine) 1420 (355 for 708 (177 for each individ. each individ. Methanol 67561 C running Yes running engine) engine) 1292(323 for 648(162 for Acetaldehyde 75070 A each individ. Yes each individ. running running engine) engine) 001- 1220(305 for 608 (152 for 005 Acrolein 107028 A each individ. Yes each individ. each running running engine) engine) 732(183 for 368(92 for each individ. each individ. Benzene 71432 A running Yes running engine) engine) 308(77 for 152 (38 for each individ. each individ. 1,3-Butadiene 106990 A running Yes running engine) engine) 260(65 for 128(32 for Toluene 108883 C each individ. Yes each individ. running running engine) engine) AIRS ID: 123/9A95 Page 18 of 27 • Colorado Department of Public Health and Environment Air Pollution Control Division Benzene 71432 A 158,460 Yes 9,179 Toluene 108883 C 198,589 Yes 11,634 006 Ethylbenzene 100414 C 8,581 Yes 508 Xylenes 1330207 C 96,959 Yes 5,757 n-Hexane 110543 C 87,160 Yes 3,053 Benzene 71432 A 159 No NA Toluene 108883 C 69 No NA 007 Xylenes 1330207 C 8 No NA n-Hexane 110543 C 2588 Yes NA Note: DCP shall be running four (4) engines from out of the five (5) engines onsite, therefore, combining HAP emissions between four engines. 5) The emission levels contained in this permit are based on the following emission factors: Points 001 through 005: 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 1000 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer's specifications Manufacturer's specifications CO Manufacturer's specifications Manufacturer's specifications VOC Manufacturer's specifications Manufacturer's specifications 50000 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 AIRS ID: 123/9A95 Page 19 of 27 Colorado Department of Public Health and Environment Air Pollution Control Division CAS Pollutant Uncontrolled EFSource Controlled EF Source Natural Gas Point 006: 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= 1.88 lb/MMscf. CAS Pollutant IbIMMBtu Source NOx 0.068 AP-42,Table 13.5-1 CO 0.370 AP-42,Table 13.5-1 Point 007: Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 1689 0 1895 0 Flanges 321 0 802 0 Open-ended Lines 0 0 0 0 Pump Seals 0 0 10 0 Valves 389 0 970 0 _Other 24 0 34 0 VOC Content(wt%) 31.84% 100% 100% 100% '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 Service Connectors 2.0E-04 7.5E-06 2.1E-04 1.1E-04 Flanges 3.9E-04 3.9E-07 1.1E-04 2.9E-06 Open-ended Lines 2.0E-03 1.4E-04 1.4E-03 2.5E-04 Pump Seals 2.4E-03 NA 1.3E-02 2.4E-05 Valves 4.5E-03 8.4E-06 2.5E-03 9.8E-05 Other 8.8E-03 3.2E-05 7.5E-03 1.4E-02 Source: EPA-453/R95.017 Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors listed in the table above with representative component counts, multiplied by the VOC content from the most recent gas analysis. Point 008: CAS Pollutant IbIMMBtu Source NOx 0.068 AP-42,Table 13.5-1 CO 0.370 AP-42,Table 13.5-1 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 AIRS ID: 123/9A95 Page 20 of 27 Colorado Department of Public Health and Environment Air Pollution Control Division 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 005: 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.qov/ttn/atw/area/fr18ia08.odf 9) AIRS Points 001 through 005: Each engine is subject to 40 CFR, Part 63, Subpart 7777 -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.qov/ttn/atw/area/fr18ia08.pdf Additional information regarding area source standards can be found on the EPA website at: http://www.eoa.cov/ttn/atw/area/arearules.html 10) This facility is classified as follows: Applicable Status Requirement Minor Source:VOC Operating Permit Synthetic Minor Source CO, NOx, benzene, toluene, xylenes, n-hexane, total 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/ AIRS ID: 123/9A95 Page 21 of 27 Colorado Department of Public Health and Environment Air Pollution Control Division Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60,Appendixes Appendix A—Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart 7777-Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXX( 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: http:/thww.cdphe.state.co.uslap/oilgaspermitting.html AIRS ID: 12319A95 Page 22 of 27 Colorado Department of Public Health and Environment. Air Pollution Control Division ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES October 12, 2012 2. Alternative Operating Scenarios The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility-Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS, and the owner or operator shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with a compressor engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month period. "Permanent" is defined as in the same service for more than 90 operating days in any 12 month period. The 90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90 day total. The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit. All replacement engines are subject to all federally applicable and state-only requirements set forth in this permit(including monitoring and record keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5)years and made available to the Division upon request. The owner or operator shall maintain a log on-site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make them available to the Division upon request. 2.1.1 The owner or operator may temporarily replace an existing compressor engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other requirements applicable to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. AIRS ID: 123/9A95 Page 23 of 27 Colorado Department of Public Health and Environment Air Pollution Control Division 2.1.2 The owner or operator may permanently replace the existing compressor engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. 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/CD P H 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: 123/9A95 Page 24 of 27 Colorado Department of Public Health and Environment Air Pollution Control Division 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 PM,o attainment/maintenance area, RACT applies to PM10 at any level of emissions and to NOx and SO2, as precursors to PM10, if the potential to emit of NOx or SO2 exceeds 40 tons/yr. For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating internal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOx: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (§60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State- Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified below: Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non- selective catalyst and air fuel controller to reduce emission. Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. AIRS ID: 123/9A95 Page 25 of 27 Colorado Department of Public Health and Environment Air Pollution Control Division The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. Emission Standards: Section XVILE—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 NOx 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 intemal 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 bum 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, § LB (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 7777 A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart 7777. An analysis of the applicable monitoring, recordkeeping, and reporting AIRS ID: 123/9A95 Page 26 of 27 Colorado Department of Public Health and Environment Air Pollution Control Division 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: 123/9A95 Page 27 of 27 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: DCP Midstream, LP Permit Number 13WE1108 Source Location: Troudt Compressor Station SENW Section 27, T6N, R66W Point 001: 4SRB RICE Point 002: 4SRB RICE Point 003: 4SRB RICE Equipment Description: Point 004: 4SRB RICE Point 005: 4SRB RICE Point 006: TEG glycol dehydrator Point 007: Fugitive emissions (See 13WE1108.CP2.Point 007 for emissions information) AIRS ID: 123/9ACB Date: 8/15/2014 Review Engineer: Stuart Siffring Control Engineer: Stefanie Rucker Section 2—Action Completed Grandfathered X Modification APEN Required/Permit Exempt X CP2 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? 8/1/2014 Section 4—Source Description AIRS Point Equipment Description One(1)Waukesha, Model L7044GSI, Serial Number TBD, natural gas-fired, turbo- charged, 4SRB reciprocating internal combustion engine, site rated at 1680 horsepower 001 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. Page 1 One(1)Waukesha, Model L7044GSI, Serial Number TBD, natural gas-fired,turbo- charged,4SRB reciprocating internal combustion engine, site rated at 1680 horsepower 002 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 TBD, natural gas-fired,turbo- charged,4SRB reciprocating internal combustion engine, site rated at 1680 horsepower 003 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 combustion engine, site rated at 1680 horsepower 004 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 TBD, natural gas-fired,turbo- charged, 4SRB reciprocating internal combustion engine, site rated at 1680 horsepower 005 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)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) plus one backup pump with a design capacity of 24 gallons per minute 006 each. This unit is equipped with a flash tank, reboiler and still vent. Emissions from the still vent are routed to an enclosed combustor. Emissions from the flash tank are routed to a vapor recovery unit(VRU)which retums vapors back to the inlet of the compressor station. During VRU downtime,the flash tank vapors are routed to an enclosed combustor. Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria X Yes No pollutant? If"ye&,for what pollutant? PM,o 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 PM10 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 001 Manufacturer's specifications 002 Manufacturer's specifications 003 Manufacturer's specifications 004 Manufacturer's specifications 005 Manufacturer's specifications Page 2 006 GRI Gly-Calc v4.0(Refer to Section 14 for calculations) 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 001 115.9 MMscf per year, 1680 hp 002 115.9 MMscf per year, 1680 hp 003 115.9 MMscf per year, 1680 hp • 004 115.9 MMscf per year, 1680 hp 005 115.9 MMscf per year, 1680 hp 006 18,250 MMSCF per year, 24 gallons per minute glycol circulation rate 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 001 115.9 MMscf per year, 1680 hp 002 115.9 MMscf per year, 1680 hp 003 115.9 MMscf per year, 1680 hp 004 115.9 MMscf per year, 1680 hp 005 115.9 MMscf per year, 1680 hp 006 18,250 MMSCF per year, 24 gallons per minute glycol circulation rate Does this source use a control device? X Yes No AIRS Point Process Control Device Description Pollutant % Reduction Granted NOx 96.2% VOC 53.3% 001 through 01 NSCR and air fuel ratio controller CO 91.5% 005 HCHO 76% Other HAPs 50% • VRU for flash tank and an enclosed combustor —97% (based 006 01 for Still Vent VOC on Glycalc) Section 6—Emission Summary(tons per year _ Point TSP NO. VOC CO Single HAP Total HAP 001 002 3.2 Facility,PTE Before 003 4.4 850.0 97.2 759.2 formaldehyde 6.0 Emissions 004 Controls/Limits: 005 006 - - 731.58 -- 99.29 270.3 toluene Point TSP NO, VOC CO Single HAP Total HAP Page 3 001 002 0.8 003 4.4 32.4 45.6 64.8 formaldehyde 2.0 Controlled point 004 source emission rate: 005 006 — — 28.28 _ 5.82 15.0 toluene Insig. 0.1 0.6 2.0 1.1 0.02 0.02 n-hexane Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled MUM omissions Controlled Emission AIRS ID Pollutant CAS# BIN Emission Rate reportable? Rate(lam (Iblyry 6488(1622 for 1556(389 for Formaldehyde 50000 A each individ. Yes each individ. running running engine) engine) 1420(355 for 708(177 for each Methanol 67561 C each individ. No individ. running running engine) engine) 1292(323 for 648(162 for each Acetaldehyde 75070 A each individ. Yes individ. running running engine) engine) 1220(305 for 608(152 for each 001-005 each individ. each Acrolein 107028 A running Yes individ. running engine) engine) 732(183 for 368(92 for each Benzene 71432 A each individ. Yes individ. running running engine) engine) 308(77 for 152(38 for each 1,3-Butadiene 106990 A each individ. Yes individ. running running engine) engine) 260(65 for 128(32 for each each individ. Toluene 108883 C No individ. running running engine) engine) Benzene 71432 A 158,460 YES 9179 Toluene 108883 C 198,589 YES 11634 006 Ethylbenzene 100414 C 8,581 YES 508 Xylenes 1330207 C 96,959 YES 5757 n-Hexane 110543 C 87,160 YES 3053 Note: Regulation 3, Part A, Section 11113.0 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? Page 4 • If"yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method NOx, CO, 001-005 01 VOC, Regulation No. 3, Part B., Section III.G.3 Stack Test HAPS 006 01 VOC, Regulation No. 3, Part B, Section III.E. Extended gas HAPS analysis 006 01 VOC, State Only Requirement Method 22 HAPS Section 9—Source Classification Is this a new previously un-permitted source? Yes X No What is this facility classification? True X Synthetic 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 If"yes"what kind of modification? Minor X Synthetic 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? NOx,CO,VOC and, HAP 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 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? Controlled NOx emissions <40 tpy. Controlled CO emissions < 100 tpy. 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 Operating 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 Page 5 • 001-005 NSPS JJJ: Not currently adopted in Colorado regulations. Listed in"Notes to permit holder.° 006 None Regulation'?—Vow Orggnii'Comonuhds Section XVI.B Applicant is located in NAA and thus required to install NSCR on rich burn engine rated greater than 500 hp. 001-005 Section XVII.E. Engines are subject to emission standards unless NSPS JJJJ and MACT 7777 requirements ultimately are applicable. Is this source subject to the control requirements of MACT HH? (Regulation 8-Hazardous Air Pollutants review). Yes 006 This source is subject to the more stringent Federal rules of MACT HH and, therefore, not subject to Regulation 7 controls requirements. Section XII.H: Is this source located in the non-attainment area? Yes 006 This source is not subject to this regulation since it is subject to the control requirements of MACT HH. Section XVII.D(State only enforceable). 006 Applicant is not subject to this regulation since it is subject to the control requirements of MACT HH. ttn 8—Hazardous Air P._.' 001-005 MACT 7ZZZ: Area source requirements are not currently adopted in Colorado regulations. Listed in "Notes to permit holder.° MACT HH: If facility is MAJOR source for HAP(summation of HAPS of dehydrators and fugitives greater than 25 TPY total or 10 TPY single HAP),then all glycol dehydrators at this facility are subject to MACT HH. If facility is an area source of HAP,only TEG dehydrators are subject to MACT HH. 1.ls facility a production field facility per 63.761 (Refer to Section 14 for definition)?Yes 2.If facility is defined as a production facility, then is it a major source of HAPS when 006 summing up dehydrator and flash tank emissions? No 3.Is this facility considered MAJOR for HAPS? No 4.Is this source subject to MACT HH?No 5.WHY? This facility is an area source of HAP and MACT HH area source requirements apply to this TEG dehydrator. This dehydrator is located within an urban cluster or within two miles of an urban area, and is subject to the emission control requirements in HH. Section 13—Aerometric Information Retrieval System Coding Information Point Process Process Throughput Emission Pollutant/ Fugitive Emission Control Description limit Factor CAS# (Y/N) Factor Source (%) 13.1 g/hp- NOx No Manufacturer 96.2 hr 11.7 g/hp- CO No Manufacturer 53.3 hr 001- 01 4SRB 115.9 1.5 g/hp-hr VOC No Manufacturer 91.5 005 RICE MMscf/yr 0.0 hg/hp- F idehyde/ No Manufacturer 76 r 50000 3.06 e-3 Methanol/ AP-42, Table Ib/MMbtu 67561 No 3.2-3 50 2.79e-3 Acetaldehyde AP-42,Table lb/MMbtu /75070 No 3.2-3 50 Page 6 2.63e-3 Acrolein/ AP-42, Table lb/MMbtu 107028 No 3.2-3 50 1.58-3 Benzene/ No AP-42, Table 50 lb/MMbtu 71432 3.2-3 6.63e-4 Butadiene/ No AP-42, Table 50 lb/MMbtu 106990 3.2-3 5.58 e-4 Toluene/ AP-42, Table lb/MMbtu 108883 No 3.2-3 50 SCC 20200253: 4-cycle rich burn 80.17 VOC No GlyCalc 4.0 97 lbs/mmscf 8.68 Benzene/ No GlyCalc 4.0 95 ' lbs/mmscf 71432 10.88 Toluene/ 18, Glycol lbs/mmscf 108883 01 MMSCF 006 Dehydrator per year 0.47 Ethylbenzene No GlyCalc 4.0 97 lbs/mmscf /100414 5.31 Xylenes/ No GlyCalc 4.0 97 Ibs/mmscf 1330207 4.78 n-Hexane/ No GlyCalc 4.0 97 lbs/mmscf 110543 SCC 31000227: Glycol Dehydrator: reboiler still stack Section 14—Miscellaneous Application Notes AIRS Point 001-005 Waukesha Engines, 1680 hp each A permit will be issued because the uncontrolled VOC emissions are greater than 5 TPY CO (permit threshold). The 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. Page 7 AIRS Point 006 TEG Dehydrator This modification covers the TEG Dehydrator.The changes include removing the condenser as a control device, allowing 1%VRU downtime,and using dry stripping gas. 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 an enclosed combustor. 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. In order to determine emissions,the operator used GRI GlyCALC 4.0. The source assumed an inlet gas temperature of 100°F and pressure of 900 psig and I confirmed these values were used in the GlyCALC report. The permitted glycol recirculation rate of 24.0 gallons per minute is also used in the GlyCALC report. Since the facility is a proposed, new facility,a site-specific gas analysis was not available for emission calculations. The source stated that they compiled various gas samples from the area which they felt to be representative of the gas for the facility. This method is appropriate for a new facility. An extended gas analysis will be required as part of the self-certification process to confirm emissions. Gly-Calc-Uncontrolled Emission factors VOC= ((382.3927+262.9553)*2000)/(50*365) =70.72 lb/mmscf(matches APEN) Benzene=((76.2803+2.7629)*2000)/(50*365)=8.66 lb/mmscf(matches APEN) Toluene=((96.7547+2.3678)*2000)/(50*365)= 10.86 lb/mmscf(matches APEN) Ethylbenzene=((4.2218+0.0626)*2000)/(50*365) =0.47 lb/mmscf(matches APEN) Xylenes= ((47.9212+0.5126)*2000)/(50*365)= 5.31 lb/mmscf(matches APEN) N-hexane=((21.0763+18.3240)*2000)/(50*365)=4.32 lb/mmscf(matches APEN) MACT HH includes requirements for both major and area sources of HAPs. The definition of major source for MACT HH (63.761)states: (3) For facilities that are production field facilities, only HAP emissions from glycol dehydration units and storage vessels with the potential for flash emissions shall be aggregated for a major source determination. For facilities that are not production field facilities, HAP emissions from all HAP emission units shall be aggregated for a major source determination. The following definitions from 63.761 are also needed to determine major source applicability: Production field facilities means those facilities located prior to the point of custody transfer Custody transfer means the transfer of hydrocarbon liquids or natural gas: after processing and/or treatment in the producing operations, or from storage vessels or automatic transfer facilities or other such equipment, including product loading racks, to pipelines or any other forms of transportation. For the purposes of this subpart,the point at which such liquids or natural gas enters a natural gas processing plant is a point of custody transfer. Natural gas processing plant(gas plant) means any processing site engaged in the extraction of natural gas liquids from field gas, or the fractionation of mixed NGL to natural gas products, or a combination of both. Based on the definitions above,this source qualifies as a production field facility since it is prior to entering a natural gas processing plant. For a production field facility, only HAP emissions from dehys and storage tanks with flash emissions are included for determining major source status. The facility's storage tanks are pressurized bullet tanks and there is only one dehy. Using the requested throughput limit of 50 MMscfd and glycol recirculation rate of 24 gpm, uncontrolled VOC emissions from the dehy are 645.35 tpy VOC, uncontrolled total I-lAP emissions are 270.3 tpy, and uncontrolled toluene emissions are 99.1 tpy. Controlled total HAP emissions from the dehy are 11.3 tpy and controlled toluene emissions are 4.4 tpy. Controlled emissions are based on 100%of flash tank emissions being recycled and 95%control of still vent emissions. 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. Page 8 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 lb/yr in 63.764(e)(ii) because controlled benzene emissions are estimated at 8180 lb/yr. Based on the location information provided in the application, the source is not within an UA Plus Offset but is within 2 miles of a UC boundary. Thus, as an area source inside of a UC boundary, it is eligible for the control requirements in MACT HH. The dehydrator is controlled by an enclosed combustor. These requirements will be listed in the permit. Regulation 7 control requirements will not be included in the permit since it meets the more stringernt rules of MACT HH. I emailed the operator on 3/14/13 to let them know that this facility will be subject to MACT HH control requirements for the TEG. The unit is equipped 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). Criteria pollutant emission levels for this unit are based on factors from AP-42, Chapter 1.4, Small Boilers < 100 MMBtu/hr (7/1998). Insignificant Activities The source provided emission estimates for several insignificant activities at the facility. Since APENs were not submitted for these insignificant activities, emissions and regulatory applicability were not evaluated for these activities/points. Emissions listed in the application were included in the history file to understand total facility emissions but otherwise not reviewed as part of this permit action. The facility's insignificant activities include one 2.86 MMBtu/hr dehy reboiler, two 30,000 gallon pressurized condensate storage tanks, pressurized condensate loadout, compressor blowdowns, two 100 bbl produced water tanks, one 1000 gallon methanol tank, 200 gallon lube oil tank, 1000 gallon glycol tanks and 80 bbl drain tank. Facility Wide Comments This modification also covers the removal of the ECD-1 (Point 008)as a control device. The emissions are now accounted for in the dehy point 006. Page 9 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: DCP Midstream, LP Permit Number: 12WE3179 Source Location: SLW Compressor Station NWNW Section 7, T5N, R63W Point 001: 4SRB RICE Point 002: 4SRB RICE Point 003: 4SRB RICE Equipment Description: Point 004: 4SRB RICE Point 005: 4SRB RICE Point 006: TEG glycol dehydrator AIRS ID: 123/9A95 Date: 8/15/2014 Review Engineer: Stuart Siffring Control Engineer: Stefanie Rucker Section 2—Action Completed Grandfathered X Modification APEN Required/Permit Exempt X CP2 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? 8/1/2014 Section 4—Source Description AIRS Point Equipment Description One (1)Waukesha, Model L7044GSI, Serial Number TBD, natural gas-fired,turbo- charged, 4SRB reciprocating internal combustion engine, site rated at 1680 horsepower 001 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. Page 1 One(1)Waukesha, Model L7044GSI, Serial Number TBD, natural gas-fired, turbo- charged,4SRB reciprocating internal combustion engine, site rated at 1680 horsepower 002 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 TBD, natural gas-fired,turbo- charged, 4SRB reciprocating internal combustion engine, site rated at 1680 horsepower 003 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 TBD, natural gas-fired,turbo- charged,4SRB reciprocating internal combustion engine, site rated at 1680 horsepower 004 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 TBD, natural gas-fired,turbo- charged, 4SRB reciprocating internal combustion engine, site rated at 1680 horsepower 005 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)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)plus one backup pump with a design capacity of 24 gallons per minute 006 each. This unit is equipped with a flash tank, reboiler and still vent. Emissions from the still vent are routed to an enclosed combustor. Emissions from the flash tank are routed to a vapor recovery unit(VRU)which returns vapors back to the inlet of the compressor station. During VRU downtime,the flash tank vapors are routed to an enclosed combustor. 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? PM1p 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 PM10 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 001 Manufacturer's specifications 002 Manufacturer's specifications 003 Manufacturer's specifications 004 Manufacturer's specifications 005 Manufacturer's specifications Page 2 006 GRI Gly-Calc v4.0 (Refer to Section 14 for calculations) 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 001 115.9 MMscf per year, 1680 hp 002 115.9 MMscf per year, 1680 hp 003 115.9 MMscf per year, 1680 hp 004 115.9 MMscf per year, 1680 hp 005 115.9 MMscf per year, 1680 hp 006 18,250 MMSCF per year, 24 gallons per minute glycol circulation rate 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 001 115.9 MMscf per year, 1680 hp 002 115.9 MMscf per year, 1680 hp 003 115.9 MMscf per year, 1680 hp 004 115.9 MMscf per year, 1680 hp 005 115.9 MMscf per year, 1680 hp 006 18,250 MMSCF per year, 24 gallons per minute glycol circulation rate Does this source use a control device? X Yes No % Reduction AIRS Point Process Control Device Description Pollutant Granted NOx 96.2% VOC 53.3% 001 through pt NSCR and air fuel ratio controller CO 91.5% 005 HCHO 76% Other HAPs 50% 006 01 VRU for flash tank and an enclosed combustor VOC -97% (based for Still Vent on Glycalc) Section 6—Emission Summary(tons per year) Point TSP NO, VOC CO Single HAP Total HAP Each engine 0.8 Each 1.1 212.5 24.3 189.8 1.5 (Points 001-005) formaldehyde 001 002 3.2 Facility,PTE Before 003 4.4 850.0 97.2 759.2 formaldehyde 6.0 Emissions • 004 Controls/Limits: 005 006 - --- 731.58 -- 99.29 270.3 toluene Page 3 Each engine Each 1.1 8.1 11.4 16.2 0'2 0.5 (Points 001-005) formaldehyde 001 002 0.8 ,Controlled point 003 44 32.4 45.6 64.8 2.0 formaldehyde source emission 004 rate: 005 006 — — 28.28 — 5.82 15.0 • toluene Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled Anise emissions Controlled Emission AIRS ID Pollutant CAS# BIN Emission Rate mortal'? Rate ob/Yri (IbNr) 6488(1622 for 1556(389 for Formaldehyde 50000 A each individ. Yes each individ. running running engine) engine) 1420(355 for 708(177 for each Methanol 67561 C each individ. No individ. running running engine) engine) 1292(323 for 648 (162 for each Acetaldehyde 75070 A each individ. Yes individ. running running engine) engine) 1220(305 for 608(152 for each 001-005 each individ. Acrolein 107028 A Yes individ. running each running engine) engine) 732(183 for 368 (92 for each Benzene 71432 A each individ. Yes individ. running running engine) engine) 308(77 for 152(38 for each 1,3-Butadiene 106990 A each individ. Yes individ. running running engine) engine) 260(65 for 128(32 for each Toluene 108883 C each individ. No individ. running running engine) engine) Benzene 71432 A 158,460 YES 9179 Toluene 108883 C 198,589 YES 11634 006 Ethylbenzene 100414 C 8,581 YES 508 Xylenes 1330207 C 96,959 YES 5757 n-Hexane 110543 C 87,160 YES 3053 Note: Regulation 3, Part A, Section ll.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? Page 4 If"yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method NOx, CO, 001-005 01 VOC, Regulation No. 3, Part B., Section III.G.3 Stack Test HAPS 006 01 VOC, Regulation No. 3, Part B, Section III.E. Extended gas HAPS analysis 006 01 RAPS State Only Requirement Method 22 Section 9—Source Classification Is this a new previously un-permitted source? Yes X No What is this facility classification? True X Synthetic Major Mina 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 If"yes"what kind of modification? Minor X Synthetic 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? NOx,CO,VOC and, HAP 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 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)? Controlled NOx emissions<40 tpy. Controlled CO emissions< If°yes",for which pollutants?Why? 100 tpy. 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, Operating 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 Page 5 001-005 NSPS JJJ: Not currently adopted in Colorado regulations. Listed in'Notes to permit holder.' 006 None Regulation 7-Volatile Organic Compounds Section XVI.B Applicant,is located in NAA and thus required to install NSCR on rich bum engine rated greater than 500 hp. 001-005 Section XVII.E. Engines are subject to emission standards unless NSPS JJJJ and MACT 7777 requirements ultimately are applicable. Is this source subject to the control requirements of MACT HH? (Regulation 8-Hazardous Air Pollutants review). No 006 Is this source subject to the exemptions under MACT HH (i.e. throughput exemption less than 3 MMSCFD or benzene exemption of less than 1984 lb/yr)? No This source is subject to review for the Regulation 7 control requirements. Section XII.H: Is this source located in the non-attainment area? Yes 006 This source is subject to Regulation 7, Section XII.H. 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. Section XVII.D(State only enforceable). 006 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. y$ffiulation 8—Hazardous Air Pollutants • 001-005 MACT=: Area source requirements are not currently adopted in Colorado regulations. Listed in'Notes to permit holder.' MACT HH: If facility is MAJOR source for HAP(summation of HAPS of dehydrators and fugitives greater than 25 TPY total or 10 TPY single HAP),then all glycol dehydrators at this facility are subject to MACT HH. If facility is an area source of HAP,only TEG dehydrators are subject to MACT HH. 1.Is facility a production field facility per 63.761 (Refer to Section 14 for definition)?Yes 2.If facility is defined as a production facility, then is it a major source of HAPS when summing up dehydrator and flash tank emissions?No 006 3.ls this facility considered MAJOR for HAPS? No 4.Is this source subject to MACT HH?No 5.WHY? 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 practice standard in HH. Section 13—Aerometric Information Retrieval System Coding Information Point ProcessProcess Throughput Emission Pollutant/ Fugitive Emission Control Description limit Factor CM# (Y/N) Factor Source (%) 13.1 g/hp NOx No Manufacturer 96.2 hr 11'7 g/hp CO No Manufacturer 53.3 001- 01 4SRB 115.9 hr 005 RICE MMscf/yr 1.5 g/hp-hr VOC No ,Manufacturer 91.5 0.05 glhp- Formaldehyde/ No Manufacturer 76 hr 50000 Page 6 3.06 e-3 Methanol/ AP-42, Table lb/MMbtu 67561 No 3.2-3 50 2.79e-3 Acetaldehyde AP-42, Table lb/MMbtu /75070 No 3.2-3 50 2.63e-3 Acrolein/ AP-42, Table lb/MMbtu 107028 No 3.2-3 50 1.58-3 Benzene/ AP-42, Table lb/MMbtu 71432 No 3.2-3 50 6.63e-4 Butadiene/ No AP-42, Table 50 lb/MMbtu 106990 3.2-3 5.58 e-4 Toluene/ AP-42, Table lb/MMbtu 108883 No 3.2-3 50 SCC 20200253: 4-cycle rich burn 80.17 VOC No GlyCalc 4.0 97 lbs/mmscf 8.68 Benzene/ No GlyCalc 4.0 95 lbs/mmscf 71432 10.88 Toluene/ 18, 01 Glycol MMSCF lbs/mmscf 108883 006 Dehydrator per year 0.47 Ethylbenzene No GlyCalc 4.0 97 lbs/mmscf /100414 5.31 Xylenes/ No GlyCalc 4.0 97 lbs/mmscf 1330207 4.78 n-Hexane/ No GlyCalc 4.0 97 lbs/mmscf 110543 SCC 31000227: Glycol Dehydrator reboiler still stack Section 14—Miscellaneous Application Notes AIRS Point 001-005 Waukesha Engines, 1680 hp each A permit will be issued because the uncontrolled VOC emissions are greater than 5 TPY CO(permit threshold). The 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 7777 and NSPS JJJJ requirements. AIRS Point 006 TEG Dehydrator This modification covers the TEG Dehydrator.The changes include removing the condenser as a control device, allowing 1% VRU downtime, and using dry stripping gas. Insignificant Activities The source provided emission estimates for several insignificant activities at the facility. Since APENs were not submitted for these insignificant activities,emissions and regulatory applicability were not evaluated for these activities/points. Emissions listed in the application were included in the history file to understand total facility emissions but otherwise not reviewed as part of this permit action. The facility's insignificant activities include one 2.86 MMBtu/hr dehy reboiler,two 30,000 gallon pressurized condensate storage tanks, pressurized condensate loadout,compressor blowdowns,two 100 bbl produced water tanks,one 1000 gallon methanol tank, 200 gallon lube oil tank, 1000 gallon glycol tanks and 80 bbl drain tank. Facility Wide Comments This modification also covers the removal of the ECD-1 (Point 008)as a control device. The emissions are now accounted for in the dehy point 006. Page 7 STATE OF COLORADO „of cam COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT dyad AIR POLLUTION CONTROL DIVISION ' TELEPHONE: (303)692-3150 •;876. CONSTRUCTION PERMIT PERMIT NO: 11WE1480 WE1 480 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 Bernhardt Compressor Station, located in Section 31, Township 5N, Range 66W, 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 L7044GSI, Serial Number TBD, natural gas-fired, turbo-charged, 4SRB reciprocating internal C-191 001 combustion engine, site rated at 1680 horsepower at 1200 RPM. This engine shall be equipped with non-selective catalytic reduction (NSCR) system and air-fuel ratio control. This emission unit is used for natural gas compression. One (1)Waukesha, Model L7044GSI, Serial Number TBD, natural gas-fired, turbo-charged, 4SRB reciprocating internal C-182 002 combustion engine, site rated at 1680 horsepower at 1200 RPM. This engine shall be equipped with non-selective catalytic reduction (NSCR) system and air-fuel ratio control. This emission unit is used for natural gas compression. One (1) Waukesha, Model L7044GSI, Serial Number TBD, natural gas-fired, turbo-charged, 4SRB reciprocating internal C-183 003 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: 123/9011 Page 1 of 24 NGEngine Version 2009-1 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 Facility AIRS Description Equipment ID Point One(1)Waukesha, Model L7044GSI, Serial Number TBD, natural gas-fired, turbo-charged, 4SRB reciprocating internal C-184 004 combustion engine, site rated at 1680 horsepower at 1200 RPM. This engine shall be equipped with non-selective catalytic reduction (NSCR) system and air-fuel ratio control. This emission unit is used for natural gas compression. One (1)Triethylene glycol (TEG) natural gas dehydration unit(make, model, serial number: QB Johnson, 630712A) with a design capacity of 50 MMscf per day. This emissions unit is equipped with one (1) electric pump(make, model: D-1 005 TBD)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 a condenser and then to an enclosed combustor. 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. The engines addressed under AIRS Points 001 through 004 may be replaced with another engine in accordance with the temporary engine replacement provision or with another Waukesha L7044GSI engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. 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. This construction permit represents final permit approval and authority to operate this emissions source. Therefore, it is not necessary to self-certify. (Regulation 3, Part B, Section III.G.5). EMISSION LIMITATIONS AND RECORDS 2. 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 Equipment ID Point NO, Emission Type VOC CO C-191 001 1,378 1,929 2,756 Point C-182 002 1,378 1,929 2,756 Point AIRS ID: 123/9011 Page 2 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 C-183 003 1,378 1,929 2,756 Point C-184 004 1,378 1,929 2,756 Point D-1 005 2,842 340 Point FUG 006 9,686 Fugitive 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 Emission Type Equipment ID Point NO VOC CO C-191 001 8.1 11.4 16.2 Point C-182 002 8.1 11.4 16.2 Point C-183 003 8.1 11.4 16.2 Point C-184 004 8.1 11.4 16.2 Point 0-1 005 16.7 2.0 Point FUG 006 57.0 Fugitive See "Notes to Permit Holder #4 for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 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. PROCESS LIMITATIONS AND RECORDS 3. 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) AIRS ID: 123/9011 Page 3 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 Process/Consumption Limits Facility AIRS Annual Monthly Limit Equipment Point Process Parameter Limit (31 days) ID 128.8 10.9 C-191 001 Consumption of natural gas as a fuel MMscf/yr MMscf/month 8 10.9 C-182 002 Consumption of natural gas as a fuel cf MMscf/yr m MMs /month C-183 003 Consumption of natural gas as a fuel 128.8 10.9 MMscf/yr MMscf/month 128.8 10.9 C-184 004 Consumption of natural gas as a fuel MMscf/yr MMscf/month D-1 005 Natural gas throughput 18,250 1,550 MMscf/yr MMscf/month FUG 006 Not applicable 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 4. 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). 5. 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.) 6. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) Waukesha Engines (AIRS Points 001 through 0041 7. 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 2, above. Operating parameters of the control equipment are identified in the operation and maintenance plan. (Reference: Regulation No.3, Part B, Section III.E.) 8. 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. AIRS ID: 123/9011 Page 4 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 9. 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 XVI1.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 Dehv (AIRS Point 005) 10. 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. 11. 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 enclosed combustor. The control system shall reduce uncontrolled emissions of VOC from the TEG dehydration unit to the emission levels listed in Condition 2, above. Operating parameters of the control equipment are identified in the operation and maintenance plan. (Reference: Regulation No.3, Part B, Section III.E.) 12. 100% of emissions that result from the flash tank associated with this dehydrator shall be recycled to the compressor station inlet and recompressed. 13. 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. AIRS ID: 123/9011 Page 5 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 14. 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. 15. The enclosed combustor covered by this permit is subject to Regulation No. 7, Section XVII.B General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed, have no visible emissions during normal operations, and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. The operator shall comply with all applicable requirements of Section XVII. 16. 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), tf 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. 17. This source is subject to the TEG dehydrator area source requirements of 40 CFR, Part 63, Subpart HH - National Emission Standards for Hazardous Air Pollutants for Source Categories from Oil and Natural Gas Production Facilities including, but not limited to, the following: • §63.760—Applicability and designation of affected source 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 (0(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 ()(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 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. AIRS ID: 123/9011 Page 6 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 • §63.764 (d)(2)(i) — Determine the optimum glycol circulation rate using the following equation: L0, =1.15*3.0gal TEG*('F*(I—O)) IbH2O 24hr/day Where: LoPT = 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 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. AIRS ID: 123/9011 Page 7 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 • §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 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. AIRS ID: 123/9011 Page 8 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 • §63.775 (c)(7)(ii) - Calculation of the optimum glycol circulation rate determined in accordance with §63.764(d)(2)(i). • §63.775 (c)(7)(iii) - If applicable, documentation of the alternate glycol circulation rate calculated using GRI- GLYCalcTM, Version 3.0 or higher and documentation stating why the 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 (0(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 006) 18. 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. 19. 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 for the pollutants for which the area is 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 20, shall satisfy the requirement to apply RACT. AIRS ID: 123/9011 Page 9 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 20. 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 semi- annual 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. 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, AIRS ID: 123/9011 Page 10 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 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 21. 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 Periodic Testing Requirements 22. AIRS Points 001 through 004: 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. 23. 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. 24. 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 25. 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: AIRS ID: 123/9011 Page 11 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5)tons per year or more, above the level reported on the last APEN; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A. 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. 26. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D).) 27. 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) 28. MACT Subpart 7777 - 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: 29. 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. AIRS ID: 123/9011 Page 12 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 30. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation 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. 31. 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. 32. 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. 33. 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. 34. 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. 35. 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: s` r t � . f.te« AIRS ID: 123/9011 Page 13 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 Stuart Siffring Permit Engineer Permit History Issuance Date Description Issuance 2 This Issuance Modification to increase permit limits for point 006 to reflect as built condition. Change control device for still vent of point 005 from reboiler to combustor. Issuance 1 11/21/2011 Issued to DCP Midstream, LP AIRS ID: 123/9011 Page 14 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 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: http://www.cdphe.state.co.us/regulations/airreqs/100102aacccommonprovisionsreq.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) Formaldehyde 5000 A 1622 Yes 389 Methanol 67561 C 355 Yes 177 Acetaldehyde 75070 A 323 Yes 162 001 Acrolein 107028 A 305 Yes 152 Benzene 71432 A 183 No 92 1,3-Butadiene 106990 A 77 No 38 Toluene 108883 C 65 No 32 Formaldehyde 5000 A 1622 Yes 389 Methanol 67561 C 355 Yes 177 Acetaldehyde 75070 A 323 Yes 162 002 Acrolein 107028 A 305 Yes 152 Benzene 71432 A 183 No 92 1,3-Butadiene 106990 A 77 No 38 Toluene 108883 C 65 No 32 Formaldehyde 5000 A 1622 Yes 389 003 Methanol 67561 C 355 Yes 177 AIRS ID: 123/9011 Page 15 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 Acetaldehyde 75070 A 323 Yes 162 Acrolein 107028 A 305 Yes 152 Benzene 71432 A 183 No 92 1,3-Butadiene 106990 A 77 No 38 Toluene 108883 C 65 No 32 Formaldehyde 5000 A 1622 Yes 389 Methanol 67561 C 355 Yes 177 Acetaldehyde 75070 A 323 Yes 162 004 Acrolein 107028 A 305 Yes 152 Benzene 71432 A 183 No 92 1,3-Butadiene 106990 A 77 No 38 Toluene 108883 C 65 No 32 Benzene 71432 A 114,889 YES 6,108 Toluene 108883 C 141,530 YES 7,605 005 Ethylbenzene 100414 C 6,136 YES 332 I Xylenes 1330207 C 70,959 YES 3,863 n-Hexane 110543 C 63,874 YES 1,908 Benzene 71432 A 153 No NA Toluene 108883 C 67 No NA 006 Xylenes 1330207 C 7 No NA n-Hexane 110543 C 2501 Yes NA 5) The emission levels contained in this permit are based on the following emission factors: Points 001 through 004: Emission Factors- Emission Factors— Uncontrolled Controlled CAS Pollutant Ib/MMBtu g/bhp-hr Ib/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. AIRS ID: 123/9011 Page 16 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer's specifications Manufacturer's specifications CO Manufacturer's specifications Manufacturer's specifications VOC Manufacturer's specifications Manufacturer's specifications 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: Water/Oil Component Gas Service Heavy Oil Light Oil Service Connectors 725 0 3144 0 Flanges 300 0 809 0 Open-ended Lines 0 0 0 0 Pump Seals 0 0 9 0 Valves 319 0 1019 0 Other* 26 0 25 0 VOC Content(wt%) 31.84% 100% 100% 100% *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): Water/Oil Component Gas Service Heavy Oil Light Oil Service Connectors 2.0E-04 7.5E-06 2.1E-04 1.1E-04 Flanges 3.9E-04 3.9E-07 1.1E-04 2.9E-06 Open-ended Lines 2.0E-03 1.4E-04 1.4E-03 2.5E-04 Pump Seals 2.4E-03 NA 1.3E-02 2.4E-05 Valves 4.5E-03 8.4E-06 2.5E-03 9.8E-05 Other 8.8E-03 3.2E-05 7.5E-03 1.4E-02 AIRS ID: 123/9011 Page 17 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 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. 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) AIRS Points 001 through 004: Each engine is subject to 40 CFR, Part 60, Subpart JJJJ— Standards of Performance for Stationary Spark ignition Internal Combustion Engines (See January 18, 2008 Federal Register posting —effective March 18, 2008). This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA website at: http://www.epa.00v/ttn/atw/area/fr18ia08.odf 8) AIRS Points 001 through 004: Each engine is subject to 40 CFR, Part 63, Subpart 7777-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 r 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.aov/ttn/atw/area/fr18ia08.odf Additional information regarding area source standards can be found on the EPA website at: http://www.eoa.gov/ttn/atw/area/arearules.html 9) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Major Source VOC, CO, NOx, RAPS PSD Synthetic Minor Source CO NANSR Synthetic Minor Source VOC, NOx MACT HH Area Source Requirements MACT 7777 Area Source Requirements 10) 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 AIRS ID: 123/9011 Page 18 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart 777Z—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX 11) 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: http://www.cdphe.state.co.us/ap/oilgaspermitting.html AIRS ID: 123/9011 Page 19 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 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-Atemative 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: 123/9011 Page 20 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 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/CD PHE-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: 123/9011 Page 21 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 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 intemal combustion engines: VOC: The emission limitations in NSPS JJJJ CO:The emission limitations in NSPS JJJJ NOX:The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (§60.331) and 40 CFR Part 72 (§72.2), natural gas contains ' 20.0 grains or less of total sulfur per 100 standard cubic feet. 2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State- Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified below: Rich bum 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: 123/9011 Page 22 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 Air Pollution Control Division Issuance 2 Lean bum 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 NOx 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: 123/9011 Page 23 of 24 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 11WE1480 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 7777. 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 ansite engine has to go through the appropriate Construction/Operating permitting process prior to installation. AIRS ID: 123/9011 Page 24 of 24 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: DCP Midstream, LP Permit Number: 12WE2039 Source Name: Wells Ranch Compressor Station Source Location: NWNW Section 27,T6N, R63W Point 001 -One(1) Reciprocating Internal Combustion Engine for Natural gas compression Point 002-One(1) Reciprocating Internal Combustion Engine for Natural gas compression Point 003 -One(1) Reciprocating Internal Combustion Engine for Equipment Description: Natural gas compression Point 004-One(1) Reciprocating Internal Combustion Engine for Natural gas compression Point 005-One(1) 50 MMSCFD TEG Dehydrator Point 007 -One (1) Reciprocating Internal Combustion Engine for Natural gas compression AIRS ID: 123/9950/001-007 Date: 8/15/2014 Review Engineer: Stuart Siffring Control Engineer: Stefanie Rucker Section 2—Action Completed Grandfathered X Modification APEN Required/Permit Exempt X CP2 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? 8/1/2014 Section 4—Source Description AIRS Point Equipment Description One(1)Waukesha, Model L7044GSI, Serial Number TBD, natural gas-fired, turbo- charged, 4SRB reciprocating internal combustion engine, site rated at 1680 horsepower 001 at 1200 RPM. This engine shall be equipped with a non-selective catalytic reduction (NSCR) system and air-fuel ratio control (AFRC). This emission unit will be used for natural gas compression. Page 1 One(1)Waukesha, Model L7044GSI, Serial Number TBD, natural gas-fired, turbo- charged, 4SRB reciprocating internal combustion engine, site rated at 1680 horsepower 002 at 1200 RPM. This engine shall be equipped with a non-selective catalytic reduction (NSCR)system and air-fuel ratio control(AFRC). This emission unit will be used for natural gas compression. One(1)Waukesha, Model L7044GSI, Serial Number TBD, natural gas-fired, turbo- charged, 4SRB reciprocating internal combustion engine, site rated at 1680 horsepower 003 at 1200 RPM. This engine shall be equipped with a non-selective catalytic reduction (NSCR) system and air-fuel ratio control (AFRC). This emission unit will be used for natural gas compression. One(1)Waukesha, Model L7044GSI, Serial Number TBD, natural gas-fired, turbo- charged, 4SRB reciprocating internal combustion engine, site rated at 1680 horsepower 004 at 1200 RPM. This engine shall be equipped with a non-selective catalytic reduction (NSCR) system and air-fuel ratio control(AFRC). This emission unit will be used for natural gas compression. 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) plus one backup pump with a design capacity of 24 gallons per minute 005 each. This unit is equipped with a flash tank, reboiler and still vent. Emissions from the still vent are routed to an enclosed combustor. Emissions from the flash tank are routed to a vapor recovery unit(VRU)which retums vapors back to the inlet of the compressor station. During VRU downtime, the flash tank vapors are routed to an enclosed combustor. One(1)Waukesha, Model L7044GSI, Serial Number TBD, natural gas-fired, turbo- charged,4SRB reciprocating internal combustion engine, site rated at 1680 horsepower at 1200 RPM. This engine shall be equipped with non-selective catalytic reduction 007 (NSCR) system and air-fuel ratio control(AFRC). This emission unit will be used for natural gas compression. This engine will function as a backup to the four main engines (points 001-004).All five engines will be permitted, but only four engines will be running at any given time. 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? PM1p 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 PM10 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 001 Manufacturer's specifications/AP-42 002 Manufacturer's specifications/AP-42 003 Manufacturer's specifications/AP-42 004 Manufacturer's specifications/AP-42 005 GRI Gly-Calc v4.0(Refer to Section 14 for calculations) Page 2 007 Manufacturer's specifications/AP-42 Did the applicant provide actual process data for the emission inventory? Yes X No Basis for Potential to Emit(PIE) AIRS Point Process Consumption/Throughput/Production 001-004, 115.9 MMscf per year; 7876 Btu/HP-hr; 1680 hp; 1000 Btu/scf(for each engine) 007 005 18,250 MMSCF per year, 24 gallons per minute glycol circulation rate Basis for Permitted Emissions(Permit Limits) AIRS Point Process Consumption/Throughput/Production 001-004, 115.9 MMscf per year; 7876 Btu/HP-hr; 1680 hp; 1000 Btu/scf(for each of the four main 007 engines) 005 18,250 MMSCF per year, 24 gallons per minute glycol circulation rate Does this source use a control device? X Yes No AIRS Point Process Control Device Description Pollutant % Reduction Granted NOx 96.2% VOC 53.3% 001-004, of NSCR and Air-Fuel ratio controller CO 91.5% 007 HCHO 76% Other HAPs 50% VRU for flash tank and an enclosed combustor —97% (based 005 01 for Still Vent VOC on Glycalc) Section 6—Emission Summary(tons per year) Point TSP NO, VOC CO Single HAP Total HAP 001 002 Facility PTE Before 003 4.4 850.0 97.2 759.2 3'24 5.8 (Formaldehyde) Emissions Controls/Limits: 004 007 005A --- --- 731.58 toluene 270.3 Point TSP NO, VOC CO Single HAP Total HAP 001 002 0.8 Controlled point 003 4.4 32.4 45.6 64.8 (Formaldehyde) 2.0 source emission 004 rate: 007 5.82 005A --- 1.2 28.28 6.6 toluene 15.0 Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled Are the Controlled Emission AIRS ID Pollutant CAS# BIN Emission Rate emissions Rate(IEmi (Iblyr) reportable? 001 Formaldehyde 5000 A 1622 Yes 389 Page 3 Methanol 67561 C 355 No 177 Acetaldehyde 75070 A 323 Yes 162 Acrolein 107028 A 305 Yes 152 Benzene 71432 A 183 Yes 92 1,3-Butadiene 106990 A 77 Yes 38 Toluene 108883 C 65 No 32 Formaldehyde 5000 A 1622 Yes 389 Methanol 67561 C 355 No 177 Acetaldehyde 75070 A 323 Yes 162 002 Acrolein 107028 A 305 Yes 152 Benzene 71432 A 183 Yes 92 1,3-Butadiene 106990 A 77 Yes 38 Toluene 108883 C 65 No 32 Formaldehyde 5000 A 1622 Yes 389 Methanol 67561 C 355 No 177 Acetaldehyde 75070 A 323 Yes 162 003 Acrolein 107028 A 305 Yes 152 Benzene 71432 A 183 Yes 92 1,3-Butadiene 106990 A 77 Yes 38 Toluene 108883 C 65 No 32 Formaldehyde 5000 A 1622 Yes 389 Methanol 67561 C 355 No 177 Acetaldehyde 75070 A 323 Yes 162 004 Acrolein 107028 A 305 Yes 152 Benzene 71432 A 183 Yes 92 1,3-Butadiene 106990 A 77 Yes 38 Toluene 108883 C 65 No 32 Benzene 71432 A 158,460 YES 9179 Toluene 108883 C 198,589 YES 11634 005 Ethylbenzene 100414 C 8,581 YES 508 Xylenes 1330207 C 96,959 YES 5757 n-Hexane 110543 C 87,160 YES 3053 Benzene 71432 A 33 No NA Toluene 108883 C 33 No NA 006 Xylenes 1330207 C 9 No NA n-Hexane 110543 C 568 No NA 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. Page 4 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 001-004, NOx, CO, 007 01 VOC, Regulation No. 3, Part B., Section III.G.3 Stack Test RAPS Section 9—Source Classification Is this a new previously un-permitted source? Yes X No What is this point classification*? True X Synthetic Major Minor Minor What is this facility classification? True X Synthetic 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 If"yes"what kind of modification? Minor X Synthetic Major Minor *This point refers to the combination of all points covered under this permit.Actually,with the exception of point 006,each of the points covered under this permit is by itself a Synthetic Minor source. Section 10—Public Comment Does this permit require public comment per CAQCC Regulation 3? X Yes No If"yes", for which pollutants?Why? NOx,CO,VOC and, HAP 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 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? Controlled NOx emissions <40 tpy. Controlled CO emissions < 100 tpy. 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. Page 5 Regulation 3-APENs.Construction Permits: Operating 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 P'erformance:Standards, = 001-004, NSPS JJJ: All four engines are subject to this subpart; however, NSPS JJJJ is not 007 currently adopted in Colorado regulations. Applicable NSPS JJJJ requirements are listed in the`Notes to permit holder section of the permit. Regulation 7 -VOW Organic Compounds Section XVI.B Applicant is located in a non-attainment area and thus required to install NSCR on rich 001-004, burn engine rated greater than 500 hp. 007 Section XVII.E. Engines are subject to emission standards unless NSPS JJJJ and MACT 7777 requirements ultimately are applicable. Section XII.H. This source is located in a non-attainment area and uncontrolled VOC emissions are greater than the 15.0 TPY threshold. Therefore, the dehydration unit at this source is 005 subject to requirements under Section XII.H. 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. Regulation 8—Hazar'dous Ain Polutants ,'> 001-004, MACT ZZZZ: All four engines are subject to this subpart; however, MACT 7777 is not 007 currently adopted in Colorado regulations. Applicable MACT 7777 requirements are listed in the"Notes to permit holder section of the permit. MACT HH: This facility is an area source of HAP and MACT HH area source requirements 005 apply to this TEG dehydrator. This Dehydrator is not located within a UA plus offset or UC boundary; it will only be required to comply with the optimal circulation rate standard in this subpart. Section 13—Aerometric Information Retrieval System Coding Information Point Process Process Throughput Emission Pollutant/ Fugitive Emission Control Description limit Factor CAS# (YIN) Factor Source (%) `See separate table for AIRS Coding for Points 001 through 004. 70'72 VOC No GLYCalc 4.0 97.3 lbs/MMscf 8.66 Benzene/ No GLYCalc 4.0 94.8 lbs/MMscf 71432 10.86 Toluene/ 18,25O No GLYCalc 4.O 95.5 01 Glycol MMSCF lbs/MMscf 108883 005 Dehydrator per year 0.47 Ethylbenzene No GLYCalc 4.0 96.7 lbs/MMscf /100414 5.31 Xylenes/ No GLYCalc 4.0 96.9 lbs/MMscf 1330207 4.32 n-Hexane/ No GLYCalc 4.0 97.0 Ibs/MMscf 110543 SCC 31000227: Glycol Dehydrator reboiler still stack Page 6 Section 14—Miscellaneous Application Notes AIRS Point 000O704' Waukesha Engines, 1680 hp each A permit will be issued because the uncontrolled VOC emissions are greater than 5 TPY CO (permit threshold). The 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. AIRS Point 005 TEG Dehydrator This modification covers the TEG Dehydrator.The changes include removing the condenser as a control device, allowing 1%VRU downtime, and using dry stripping gas. Insignificant Activities The source provided emission estimates for several insignificant sources at the facility. Since APENs were not submitted for these insignificant sources, emissions and regulatory applicability were not evaluated for these points/activities. Total emissions from these sources is included in the history file to understand total facility emissions but otherwise not reviewed as part of this permit action. Facility Wide Comments This modification also covers the removal of the ECD-1 (Point 008)as a control device. The emissions are now accounted for in the dehy point 006. • Page 7 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: DCP Midstream, LP Permit Number 11WE1480 Source Location: Bernhardt Compressor Station Section 31, T5N, R66W Equipment Description: Natural Gas Compression Facility AIRS ID: 123/9011/001 through 006 Date: 07/31/2014 Review Engineer: Stuart Siffring Control Engineer: Stefanie Rucker Section 2—Action Completed Grandfathered X Modification APEN Required/Permit Exempt X CP2 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? 7/7/2014 Section 4—Source Description AIRS Point Equipment Description One (1)Waukesha, Model L7044GSI, Serial Number TBD, natural gas-fired, turbo-charged, 4SRB reciprocating internal combustion engine, site rated at 1680 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 L7044GSI, Serial Number TBD, natural gas-fired, turbo-charged, 4SRB reciprocating internal combustion engine, site rated at 1680 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. Page 1 One (1)Waukesha, Model L7044GSI, Serial Number TBD, natural gas-fired, turbo-charged, 4SRB reciprocating internal combustion engine, site rated at 1680 003 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 TBD, natural gas-fired, turbo-charged, 4SRB reciprocating internal combustion engine, site rated at 1680 004 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)Triethylene glycol (TEG) natural gas dehydration unit(QB Johnson, 630712A) with a design capacity of 50 MMscf per day. This emissions unit is equipped with one (1)electric pump (Make: Best Pump Works) with a design 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 a condenser and thn to an enclosed combustor. Emissions from the flash tank are routed to a vapor recovery unit(VRU)which returns vapors back to the inlet of the compressor station. 006 Equipment leaks(fugitive VOCs) from a natural gas compression facility. 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? PM,a 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 FMK) 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 001 Manufacturer's specifications 002 Manufacturer's specifications 003 Manufacturer's specifications 004 Manufacturer's specifications 005 GRI Gly-Calc v4.0(Refer to Section 14 for calculations) 006 EPA-453/R-95-017,Table 2-4 Did the applicant provide actual process data for the emission inventory? Yes X No Basis for PotentiaIto Emit EPEEt AIRS Point Process Consumption/Throughput/Production 001 128.8 MMscf per year, 1680 hp 002 128.8 MMscf per year, 1680 hp Page 2 003 128.8 MMscf per year, 1680 hp 004 128.8 MMscf per year, 1680 hp 005 18,250 MMSCF per year, 24 gallons per minute glycol circulation rate Equipment Type Gas Heavy Oil(or Light Oil (or Water/Oil Heavy Liquid) Light Liquid) Connectors 725 3144 006 Flanges 300 809 Open-Ended Lines 0 0 Pump Seals 0 9 Valves 319 1019 Other 26 25 Basis for Actual Emissions Reported During this APEN Filing(Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 005 and 006 Same as Above 2014 Basis for Permitted Emissions(Permit Limits' AIRS Point Process Consumption/Throughput/Production 001 128.8 MMscf per year, 1680 hp 002 128.8 MMscf per year, 1680 hp 003 128.8 MMscf per year, 1680 hp 004 128.8 MMscf per year, 1680 hp 005 18,250 MMSCF per year, 24 gallons per minute glycol circulation rate Equipment Type Gas Heavy Oil (or Light Oil (or Water/Oil Heavy Liquid) Light Liquid) Connectors 725 3144 006 Flanges 300 809 Open-Ended Lines 0 0 Pump Seals 0 9 Valves 319 1019 Other 26 25 Does this source use a control device? X Yes No AIRS Point Process Control Device Description Pollutant % Reduction Granted NOx 96.2% 001 through VOC 53.3% 004 of NSCR and air fuel ratio controller CO 91.5%HCHO 76% Other HAPs 50% 005 01 VRU for flash tank. Condenser and Combustor VOC r 95% for Still Vent 006 01 None NA Section 6—Emission Summary (tons per year) Point TSP NO, VOC CO Single HAP Total HAP Facility,PTE Before 0.81 Emissions 001 1.1 212.5 24.3 189.8 formaldehyde 1.5 Controls/Limits: y 002 1.1 212.5 24.3 189.8 0.81 1.5 formaldehyde 003 1.1 212.5 24.3 189.8 0.81 1.5 formaldehyde Page 3 004 1.1 212.5 24.3 189.8 0.81 1.5 formaldehyde 005 0.4 534.3 2.0 70.8 198.7 toluene 1.25 006" 57.0 n-hexane70.9 1.4 TotalB 4.5 851.1 633.5 762.4 toluene 205.0 Point TSP NO, VOC CO Single HAP Total HAP Controlled point 0.2 source emission 001 1.1 8.1 11.4 16.2 formaldehyde 0.5 rate: 0.2 002 1.1 8.1 11.4 16.2 ��formaldehyde 0.5 0.2 003 1.1 8.1 11.4 16.2 formaldehyde0.2 0.5 004 1.1 8.1 11.4 16.2 formaldehyde3.8 0.5 005 0.4 16.7 2.0 toluene1.25 9.9 006A 57.0 1.4 n-hexane3.9 Total° 4.5 33.5 64.3 68.0 toluene 12.4 Total permitted plant-wide 32.8 70.3 66.8 3.9 12.3 emissions c: toluene A: These emissions are fugitive sources so they are not included in the total for PTE. B: The total PTE values in this line also include emissions for insignificant activities. The facility's insignificant activities include one 2.86 MMBtu/hr dehy reboiler, pressurized condensate loadout, compressor blowdowns,two 100 bbl produced water tanks, one 1000 gallon methanol tank,200 gallon lube oil tank, 1000 gallon glycol tanks and 80 bbl drain tank. Emission rates for insignificant activities are based on emission estimates provided with this package. 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 �n er.mr.bN Controlled Emission AIRS ID Pollutant CAS# BIN Emission Rate reportable? Rate(1W) (Ib/yr) Formaldehyde 5000 A 1622 Yes 389 Methanol 67561 C 355 No 177 Acetaldehyde 75070 A 323 Yes 162 001 Acrolein 107028 A 305 Yes 152 Benzene 71432 A 183 Yes 92 1,3-Butadiene 106990 A 77 Yes 38 Toluene 108883 C 65 No 32 Formaldehyde 5000 A 1622 Yes 389 Methanol 67561 C 355 No 177 Acetaldehyde 75070 A 323 Yes 162 002 Acrolein 107028 A 305 Yes 152 Benzene 71432 A 183 Yes 92 1,3-Butadiene 106990 A 77 Yes 38 Page 4 Toluene 108883 C 65 No 32 Formaldehyde 5000 A 1622 Yes 389 Methanol 67561 C 355 No 177 Acetaldehyde 75070 A 323 Yes 162 003 Acrolein 107028 A 305 Yes 152 Benzene 71432 A 183 Yes 92 1,3-Butadiene 106990 A 77 Yes 38 Toluene 108883 C 65 No 32 Formaldehyde 5000 A 1622 Yes 389 Methanol 67561 C 355 No 177 Acetaldehyde 75070 A 323 Yes 162 004 Acrolein 107028 A 305 Yes 152 Benzene 71432 A 183 Yes 92 1,3-Butadiene 106990 A 77 Yes 38 Toluene 108883 C 65 No 32 Benzene 71432 A 114,889 YES 6,108 Toluene 108883 C 141,530 YES 7,605 005 Ethylbenzene 100414 C 6,136 YES 332 Xylenes 1330207 C 70,959 YES 3,863 n-Hexane 110543 C 63,874 YES 1,908 006 n-Hexane 110543 C 2500 Yes NA Note: Regulation 3, Part A, Section ll.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 NOx, CO, 001-004 01 VOC, Regulation No. 3, Part B., Section III.G.3 Stack Test HAPS Section 9—Source Classification Is this a new previously un-permitted source? Yes X No What is this point classification? True X Synthetic Major Minor Minor What is this facility classification? True X Synthetic 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 If"yes"what kind of modification? Minor X Synthetic Major Minor Page 5 Section 10—Public Comment Does this permit require public comment per CAQCC Regulation 3? X Yes No If'yes", for which pollutants?Why? VOC 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 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? Controlled NOx emissions<40 tpy. Controlled CO emissions< 100 tpy. AIRS Point Section 12—Regulatory Review Reautatlon 1 -P ' Smoke.Carbon Monoxide`andtStrftur'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. Reoutatiort 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. Requtatlo a 3-ARMS;Coftstruction Permits.amanita 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 ILD.2) Regulation 6-Nevi%2Source'Perfomrance:Stendarcts = 001-004 NSPS JJJ: Not currently adopted in Colorado regulations. Listed in"Notes to permit holder." Page 6 Regulation 7—Volatile Organic Compounds Section XVI.B Applicant is located in NAA and thus required to install NSCR on rich burn engine rated greater than 500 hp. 001-004 Section XVII.E. Engines are subject to emission standards unless NSPS JJJJ and MACT ZZZZ requirements ultimately are applicable. 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. 005 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 XII.G.1. 006 Applicant is located in NAA but since it is not a gas processing facility, the requirements are not applicable. Regulation 8—Hazardous Air Pollutants 001-004 MACT ZZZZ: Area source requirements are not currently adopted in Colorado regulations. Listed in "Notes to permit holder." MACT HH: This facility is an area source of HAP and MACT HH area source requirements 005 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 practice standard in HH. 006 MACT HH: This facility is an area source of HAPs. No fugitive requirements for area sources. Section 13—Aerometric Information Retrieval System Coding Information Point Process Process Throughput Emission Pollutant/ Fugitive Emission Control Description limit Factor CAS# (Y/N) Factor Source (%) *See separate table for AIRS Coding for Points 001 through 004. 58.55 VOC No GlyCalc 4.0 97 Ibs/mmscf 0.068 NOx No AP-42 — lb/mmbtu 0.37 CO No AP-42 — lb/mmbtu 6.30 Benzene/ 18, 01 Glycol MMSCF lbs/mmscf 71432 005 Dehydrator per year 7.76 Toluene/ No GlyCalc 4.0 95 Ibs/mmscf 108883 0.34 Ethylbenzene No GlyCalc 4.0 95 Ibs/mmscf /100414 3.89 Xylenes/ No GlyCalc 4.0 95 Ibs/mmscf 1330207 3.50 n-Hexane/ No GlyCalc 4.0 97 Ibs/mmscf 110543 SCC 31000227: Glycol Dehydrator: reboiler still stack Fugitive 006 01 VOC NA NA VOC Yes EPA-453/R-95- NA Equipment 017, Table 2-4 Leaks Section 14—Miscellaneous Application Notes AIRS Point 005 TEG Dehydrator Modification to change still vent control device from reboiler(as reboiler fuel gas)to an enclosed combustor. 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