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Home My WebLink About20121299.tiff STATE OF COLORADO ,I1+_L D COUN Y John W.Hickenlooper,Governor COMMISSIONERS Fco Christopher D.Urbina,and Chief MPH �� Executive Director Medical Officer 9n��t) Ne 'Cyo‘ Dedicated to protecting and improving the health and environment of the peppe(of, ibr22 P 12: 4b 0 4300 Cherry Creek Dr.S. Laboratory Services Division ;,. rage Denver,Colorado 80246-1530 8100 Lowry Blvd. [� _/'� /c Phone(303)692-2000 Denver,Colorado 80230-6928 R E C E I V E D Colorado Department Located in Glendale,Colorado (303)692-3090 of Public Health http://www.cdphe.state.co.us and Environment May 15, 2012 Mr. Steve Moreno Weld County Clerk 1402 N. 17th Ave. Greeley, CO 80631 Dear Mr. Moreno: The Air Pollution Control Division will publish a public notice for Kerr-McGee Gathering, LLC. This public notice will be published in the Greeley Tribune on May 19, 2012. Thank you for assisting the Division by making the enclosed package (includes public notice, preliminary analysis, Air Pollutant Emission Notice(s) and draft permit(s)) available for public review and comment. It must be available for public inspection for a period of thirty (30) days from the date the public notice is published. Please forward any comment regarding this public notice to the address below. Colorado Department of Public Health and Environment APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Attention: Ellen Evans Regards, Ellen Evans Public Notice Coordinator Stationary Sources Program Air Pollution Control Division C R kA;ttw'' CF \AL PL- n . 'x'-la a≥: a 2012-1299 NOTICE OF REQUEST FOR SYNTHETIC MINOR PERMIT FOR NATURAL GAS COMPRESSION FACILITY BY Kerr-McGee Gathering, LLC CONTENTS 1 . PUBLIC NOTICE 2. PRELIMINARY ANALYSIS 3. AIR POLLUTANT EMISSION NOTICES 4. DRAFT PERMIT PREPARED BY: JACOB SEBESTA COLORADO DEPARTMENT OF PUBLIC HEALTH & ENVIRONMENT 4300 CHERRY CREEK DRIVE SOUTH, APCD-SS-B1 DENVER, CO 80246-1530 STATE OF COLORADO John W. Hickenlooper,Governor Christopher E. Urbina,MD,MPH �.OF.Cot0 Executive Director and Chief Medical Officer NQ % Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr.S. Laboratory Services Division , 87s 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 http://www.cdphe.state.co.us and Environment Released to: The Greeley Tribune on May 15, 2012, published May 19, 2012 PUBLIC NOTICE OF A PROPOSED PROJECT OR ACTIVITY WARRANTING PUBLIC COMMENT The Colorado Air Pollution Control Division declares the following proposed construction activity warrants public comment. Therefore, the Air Pollution Control Division of the Colorado Department of Public Health and Environment hereby gives NOTICE, pursuant to Section 25-7-114.5(5), C.R.S. of the Colorado Air Quality Control Act that the Division received an application for an:air pollution emission permit on the following proposed project and activity: Kerr-McGee Gathering, LLC proposes to modify an existing natural gas compression facility known as the Frederick Compressor Station. This source will add six (6) 1,775 horsepower compressor engines and one glycol dehydrator rated at 30 MMscf per day. Condensate production will also increase. This source is located at 3899 Weld County Road 19 near Frederick in Weld County. The modification to this source would be considered a major modification subject to Non-attainment New Source Review (NANSR) if the operator did not install emissions controls, reduce natural gas consumption for an existing natural gas compressor engine and accept Federally enforceable emissions limits in the proposed permit. Since the operator will accept emissions limits that prevent this modification from increasing emissions of NOX and VOC by more than 40 tons per year, this modification will be considered a synthetic minor modification not subject to NANSR review. The facility is considered a major source subject to Title V Operating Permit requirements and Maximum Achievable Control Technology (MACT). As such, this permit is subject to public comment per Regulation 3, Part B, Section III.C.I.d. Copies of the draft permit and preliminary analysis are available for review in the public comment package. The Division has determined that the proposed source will comply with all applicable regulations and standards of the Colorado Air Quality Control Commission and has made a preliminary determination of approval of the application. The Division hereby solicits and requests submission of public comment from any interested person concerning the aforesaid proposed project and activities to comply with the applicable standards and regulations of the Commission for a period of thirty (30) days from the date of this publication. Any such comment must be submitted in writing to the following addressee: Jacob Sebesta Colorado Department of Public Health arid Environment 4300 Cherry Creek Drive South, APCD-SS-Bl Denver, Colorado 80246-1530 Within thirty (30)days following the said thirty(30)-day period for public comment, the Division shall consider comments and, pursuant to Section 25-7-114.5(7)(a), either grant, deny, or grant with conditions,the emission permits. Said public comment is solicited to enable consideration of approval of and objections to the proposed construction of the subject project and activity by affected persons. A copy of the applications for the emission permits,the preliminary analysis of said applications, and accompanying data concerning the proposed project and activity are available for inspection at the office of the Clerk and Recorder of Weld County during regular business hours and at the office of the Air Pollution Control Division, Colorado Department of Public Health and Environment, 4300 Cherry Creek Drive South, Denver, Colorado. Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Kerr-McGee Gathering, LLC 12WE804(modification) \v03WE0064(modification), 08WE0823 (modification) , 10WE1049 • Permit Number: 10WE1050 ,11WE1961 11 WE1962 11WE1y63 N11WE1964 11WE1965 E1965 Source Name: Frederick Compressor Station Source Location: 3988 WCR 19, Frederick Unchanged Emission Units at This Facility One (1) 80 MMscf/d Glycol Dehydrator One(1) Caterpillar 3608 2,104 hp engine New and Modified Points Equipment Description: Two(2) Cooper Bessemer 12Q155HC 4,670 hp compressor engines (12WE804) Condensate tank battery (03WE0064) Condensate truck loadout(08WE0823) New: Six(6) Caterpillar G3606LE 1,775 hp compressor engines (10WE1049, 10WE1050, 11WE1961-11WE1964) New: One (1)30 MMscf/d TEG Dehydrator(11WE1965) AIRS ID: 123/0184 Date: 05/15/12 Review Engineer: Jacob Sebesta Control Engineer Chris Laplante Section 2—Action Completed Grandfathered X Modification APEN Required/Permit Exempt X CP1 Transfer of Ownership APEN Exempt/Permit Exempt Section 3—Applicant Completeness Review Was the correct APEN submitted for this source type? X Yes No Is the APEN signed with an original signature? X Yes No Was the APEN filled out completely? X Yes No Did the applicant submit all required paperwork? X Yes No Did the applicant provide ample information to determine emission rates? X Yes No If you answered "no"to any of the above, when did you mail ian . Revi&ed APENs and O&M plans Information Request letter to the source? received 3/6/2012 On what date was this application complete? March 6, 2012 Page 1 Section 4-Source Description AIRS Point Equipment Description Two (2) Cooper Bessemer, Model 12Q155HC, Serial Numbers 48715 &48799, natural gas-fired, turbo-charged, 2SLB reciprocating internal combustion engines, site rated at 004 4300 horsepower each at 425 RPM. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control. This emission unit is used for natural gas compression. One unit is operated as back-up to the other. These emission units were previously covered under separate AIRS points 004 and 005. 008• Seven (7) 225-bbl and one (1) 200-bbl condensate storage tanks. Emissions are routed to a compressor and recycled to the plant inlet. 010 Condensate truck loadout. Emissions from this source are routed to an open flame flare (Make: Flare King, Model: FKAVP-H25-R8S-EPT, Serial Number: 6111). Six (6) Caterpillar,'Model G3606LE, Serial Number To Be Determined, natural gas-fired, 011-016 turbo-charged,4S B.reciprocating internal combustion engines, site rated at 1775 horsepower each at 1000 RPM. Each engine shall be equipped with an oxidation catalyst and air-fuel ratio coritrol. These emission units are used for natural gas compression. One (1) Methylene glycol (TEG)natural gas dehydration unit(make, model, serial number: not submitted)with a design capacity of 30 MMscf per day. This emissions unit 017 is equipped with two (2) electric glycol pumps with a total design capacity of 5 gallons per minute (make and model not submitted). 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 a thermal oxidizer. Flash tank off gas is recycled to the plant inlet. Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria X Yes No pollutant? If"yes", for what pollutant? PM10 CO X Ozone Is this location in an attainment maintenance area for Yes X No any criteria pollutant? If"yes", for what pollutant? (Note: These pollutants are subject to minor source 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 004 NOX and CO: EPA Consent Decree Requirement, VOC: Previous permit, HAP: AP-42, Table 3.2-1 008 E&P Tank v2.0, 12/17/2010 slug catcher condensate analysis from Frederick CS 010 AP-42: Chapter 5.2, Equation 1 Uncontrolled 011-016 NOX, CO, VOC, HCHO: Manufacturer Data, Other HAP: AP-42, Table 3.2-2 Controlled CO, VOC, HCHO: Engineering judgment 017 GRI Gly-Calc v4.0, 4/11/11 gas analysis from Frederick CS 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 004 572.2 MMscf/yr natural gas combusted 008 360,000 BBL condensate throughput per year 010 360,000 BBL condensate throughput per year Page 2 011-016 119.42 MMscf natural gas combusted per year per engine 017 10,950 MMSCF per year, 5 gallons per minute glycol circulation rate Basis for Permitted Emissions (Permit Limits) AIRS Point Process Consumption/Throughput/Production 004 286.1 MMscf/yr natural gas combusted 008 300,000 BBL condensate throughput per year 010 300,000 BBL condensate throughput per year 011-016 119.42 MMscf natural gas combusted per year per engine 017 10,950 MMSCF per year, 5 gallons per minute glycol circulation rate Does this source use a control device? X Yes No AIRS Point Process Control Device Description % Reduction Granted (i) new or remanufactured turbochargers; (ii) pre-combustion 004 001 chambers; (iii) after-coolers with auxiliary water cooling, as NOX: 63.6% needed; (iv) high-pressure fuel injection; and (v) oxidation CO: 58% catalysts. 008 01 Emissions recycled to plant inlet 100% 010 01 Open flame flare 95% CO: 90% 011-016 01 Oxidation catalysts VOC: 35% HCHO: 76% 01 Condenser(maximum outlet temp. = 160°F) 42% 017 02 Thermal oxidizer(minimum operating temper. = 1500'F) 98% Total 98.4% Page 3 Section 6— Emission Summary (tons per year) Uncontrolled Emissions . Point Permit Description PM10 NOx VOC Fug CO Reportable Total VOC HAPs HAPs Cooper 004 95OPWE035 compressor 6.4 228.0 50.1 116.1 9.7 10.4 engine 006 95OPWE035 Glycol 2.6 1,000.0 5.3 718.3 718.3 dehydrator Fugitive 007 95OPWE035 equipment 38.6 0.0 0.0 leaks 008 03WE0064 Condensate 722.0 43.1 44.0 Tank Battery 009 95OPWE035 Caterpillar •, -14.2 30.9 50.8 0.0 8.0 3608,2104 hp 010 08WE0823 truckioadout - 0.4 16.8 2.1 0.1 0.7 011 10WE1049 Caterpillar 0.53 12.3 15.8 43.9 7.6 7.8 3606. 1775hp 012 10WE1050 Caterpillar 0.53 12.3 15.8 43.9 7.6 7.8 3606, 1775hp 013 11WE1961 Caterpillar 0.53 12.3 15.8 43.9 7.6 7.8 3606, 1775hp 014 11WE1962 Caterpillar 0.53 ' 12.3 15.8 43.9 7.6 7.8 3606, 1775hp 015 11WE1963 Caterpillar 0.53 12.3 15.8 43.9 7.6 7.8 3606, 1775hp 016 11WE1964 Caterpillar 0.53 12.3 15.8 43.9 7.6 7.8 3606, 1775hp 30 MMscf/d 017 11WE1965 TEG 3.3 122.7 6.6 78.9 78.9 dehydrator 018 98WE0452.FA2 Wauk L7042G ' 3.3 122.7 6.6 78.9 78.9 896 HP 019 98WE0453.FA3 Wauk L7042G 83.3 8.7 140.3 1.0 1.2 1000 HP w/NSCR 020 09WE0798.GF Condensate 75.3 0.3 115.9 1.3 1.3 Tank Battery 021 09WE0799 Fugitives 9.6 0.0 0.0 TOTAL 9.6 ' 481.0 2,056.1 43.5 700.6 897.9 910.3 (TPY) Page 4 I Point Permit Description PM10 NOx VOC Fug ,CO Reportable Total VOC HAPs HAPs Cooper 004 95OPWE035 compressor 6.4 83.1 50.1 48.7 9.7 10.4 engine 006 95OPWE035 Glycol 2.6 10.0 . 5.3 7.2 7.2 dehydrator Fugitive 007 95OPWE035 equipment 38.6 4: 0.0 0.0 leaks 008 03WE0064 Condensate ,.,1103 ;IV 10.0 0.0 Tank Battery 009 95OPWE035 Caterpillar - 14.3 ' 15:5 10.2 0.0 1.6 3608, 2104 hp 010 08WE0823 truck loadout 0.4 0.8 2.1 0.0 0.0 011 10WE1049 Caterpillar 0.5 12.3 10.3 4.4 2.4 2.6 3606, 1775hp 012 10WE1050 Caterpillar 0.5 12.3 10.3 4.4 2.4 2.6 3606, 1775hp 013 11WE1961 Caterpillar 0.5 12.3 10,3 4.4 2.4 2.6 3606, 1775hp 014 11WE1962 Caterpillar 0.5 12.3 10.3 4.4 2.4 2.6 3606, 1775hp 015 11WE1963 Caterpillar 0.5 12.3 10.3 4.4 2.4 2.6 3606, 1775hp 016 11WE1964 Caterpillar 0.5 12.3 10.3 4.4 2.4 2.6 3606, 1775hp 30 MMscf/d 017 11WE1965 TEG 3.3 2.0 6.6 0.6 0.6 dehydrator 018 98WE0452.FA2 Wauk L7042G 17.3 8.6 17.3 0.8 0.8 896 HP 019 98WE0453.FA3 Wauk L7042G 25.1 2.0 31.4 1.3 1.3 1000 HP w/NSCR 020 09WE0798.GF Condensate 9.6 0.0 0.0 Tank Battery 021 09WE0799 Fugitives 0.5 TOTAL 9.6 219.9 .160.4 43.5 148.0 33.8 38.2 (TPY) • Controlled Emissions Section 7—Non-Criteria / Hazardous Air Pollutants See attached "history file." 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 011-016 01 NOX, CO, MACT7777& Regulation No. 3, Part B., Stack Test HCHO Section III.G.3 Page 5 017 01 VOC, Regulation No. 3„Part B.,Section III.G.3 Stack Test HAPS . 11 Section 9—Source Classification ' Is this a new previously un-permitted source? X Yes No What is this facility classification? True Synthetic Major Minor Minor X Title V PSD X NA NSR X MACT Classification relates to what programs? (This facility is also a synthetic minor source of CO for PSD.) Is this a modification to an existing facility? X Yes . No If"yes" what kind of modification?' Minor X Synthetic Major Minor Nonattainment New Source Review Applicability This facility is an existing major source of NOX and VOC for nonattainment New Source Review (NANSR). The Potential-to-Emit of new equipment will exceed the major modification thresholds for NOX and VOC. However, this source completed a netting analysis to avoid a LAER review for this modification. Based on APCD records of permit actions and actual emissions reported in APCD inspection reports no changes at this facility prior to this project are considered contemporaneous creditable increases or decreases. Reductions • Kerr-McGee requested to.reduce the fuel use limit and emission limits for two existing Cooper compressor engines so that'the fuel.use limit is based on 8760 hours per year of operation (at 100% load)total for the tIR90 enginesrrattier.than 17,520 hours per year(8,760*2). These engines were previously permitted'under separate AIRS IDs 004 and 005, but will now be grouped under point 004. Based on past actual emissions, this reduces emissions by 65.8 tpy NOX and 39.7 tpy VOC. • Emissions from the condensate tank battery will be recycled to the plant inlet rather than continuing to be routed to an open flame flare as in the past. Based on past actual emissions, and all tank emissions being captured and recycled going forward, this reduces emissions by 5.3 tpy VOC. • Condensate truck loadout emissions will be routed to the open flame flare rather than vented to atmosphere. Past actual emissions exceeded the permit limit of 1.2 tpy VOC. However, emissions above permit limits cannot be included in netting analyses. The new permit limit of 0.8 tpy VOC indicates a reduction of 0.4 tpy VOC from condensate truck loadout. Increases This project will add six (6) Caterpillar 3606 compressor engines (1,775 hp each) and one 30 MMscf/d TEG dehydrator to the Frederick Compressor Station. In addition, condensate throughput limits for the tahk battery and truck loadout activity increase to 300,000 BBL per year. These limits were each previously 35,000 BBL per year. The change from past actual emissions to potential emissions under the new permits is summarized below(including only the emission sources that are new, modified, or removed). POINT PERMIT Description I NOx I VOC I CO New and modified (emission increases) Units'_ 008 03WE0064 Condensate Tank'Battery 0.0 010 08WE0823 truck loadout . 0.4 0.8 2.1 011 10WE1049 Caterpillar 3606, 1775hp 12.3 10.3 4.4 012 10WE1050 Caterpillar 3606, 1775hp 12.3 10.3 4.4 013 11WE1961 Caterpillar 3606, 1775hp 12.3 10.3 4.4 014 11WE1962 Caterpillar 3606, 1775hp 12.3 10.3 4.4 015 11WE1963 Caterpillar 3606, 1775hp 12.3 10.3 4.4 016 11WE1964 Caterpillar 3606, 1775hp 12.3 10.3 4.4 Page 6 017 11WE1965 30 MMscf/d TEG 3.3 2.0 6.6 dehydrator Total Increase 77.5 64.6 35.1 Past actual emissions for modified or removed units 004 95OPWE035 Cooper compressor engine 65.8 39.7 38.7 005 95OPWE035 Cooper compressor engine 66.8* 40.0* 39.3* 008 03WE0064 Condensate Tank Battery 5.3 010 08WE0823 truck loadout . Al" 1.2 Change in emissions(actual to PTE) 11.7 18.4 -3.6 *: The netting analysis only subtracted the actual emissions from the lower emitting of the two Cooper compressor engines. Past actual emissions in the table above are the average annual emissions for the period of July 2009 through June 2011 excluding emissions that exceeded permit limits. Actual emissions from condensate truck loadout exceeded the limits in permit 08WE0823. Therefore, the emissions from loadout activity reflect the allowable emissions under that permit. Issuance 2 of permit 08WE0823 increased allowable emissions from the loadout to 2.0 tpy. Kerr-McGee purchased a nearby facility from Encana (also known as the Frederick Compressor Station, AIRS ID 123-0151) in 2011. The Division determined that the facility previously owned by Encana should be considered part of the same stationary source as the Kerr-McGee Frederick Compressor Station following that transfer of ownership. This transfer of ownership was not considered to be a modification or creditable contemporaneous emission increase to this facility because it was not a physical change or change in the method of operation that caused an emission increase. The Encana facility did not undergo any modifications in the contemporaneous period Since the net emissions change at this facility is less than 40 tpy for both NOX and VOC, KMG has successfully"netted"this project out of NA NSR applicability; and the affected equipment is not subject to a LAER review or emissions offsets. Section 10— Public Comment Does this permit require public comment,per CAQCC F egulation 3? I X Yes No If"yes", for which pollutants?Why? NOx,VOC, and HAP' For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)? Yes No For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)? X 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? AIRS Point Section 12— Regulatory Review Re.ulation 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 All Points 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.9i(40.CFR, Part60, Appendix A(July, 1992)) in all subsections of Section II: A and' of this regulation. Re.ulation 2—Odor • • Page 7 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 All Points 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: agulation 3-APENs, Construction Permits, Operating Permits, PSD Part A-APEN Requirements All Points Applicant is required to file an APEN since emissions exceed 1 ton per year VOC in a nonattainment area for ozone. Part B—Construction Permit Exemptions All Points Applicant is required to obtain apertnit since uncontrolled VOC emissions from this facility are greater than'thei2:0 TPY in a nonattainment area. (Reg. 3, Part B, Section II.D.3.a) Part B, III.D.2- RACT requirements for new or modified minor sources This section of Regulation 3 requires RACT for new or modified minor sources located in nonattainment or attainment/maintenance areas. This source is located in the 8-hour ozone nonattainment area, but not the 1-hour ozone area. The date of interest for determining whether the source is new or modified is November 20, 010 2007 (the date of the 8-hour ozone NA area designation). The tank battery from which loadout is occurring has been in service since before the date above. However, this source is considered "modified" based on the dramatic increase in throughput anticipated with this permit modification. The RACT requirements of Section III.D.2 are satisfied by completing loading operations by submerged fill of truck tanks. Regulation 6 -New Source Performance Standards 008 NSPS Kb does not apply because each tank has a capacity less than 471 BBL. 010, 017 None Regulation 7—Volatile Or.anic Compounds Section XVI Each of the engines covered by this engine is a lean burn engine greater than 500 hp located in an 8-hour ozone nonattainment area and each is required by the Section XVI to 004 be operated with an oxidation catalyst: Section XVII Each of these engines was constructed prior to 2009 and each is rated at greater than 500hp. Each of these engines are therefore considered existing engines for Section XVII and are required by this section to be operated with an oxidation catalyst. Section XII This source is subject to the system-wide condensate tank emission reduction requirements of Section XII because this natural gas compressor station stores condensate 008 within the 8-hour ozone nonattainment area. Section XVII This source is required by Section XVII to reduce emissions of VOC by at least 95% because it is a condensate storage tank battery with uncontrolled actual VOC emissions greater than 20 tpy. 010 No sections apply. This facility is neither a terminal, nor a bulk plant per definitions in Reg 7, Section VI.C. Section XVI Each of these points is a lean burn engine greater than 500 hp located in an 8-hour ozone nonattainment area and each is required by the Section XVI to be operated with an 011-016 oxidation catalyst. Section XVII Each of these engines is subject to MACT ZZZZ emission control requirements as adopted in AQCC Regulation 8 and each is therefore not subject to Section XVII. Section XII.H 017 This source is required to reduce VOC emissions from each glycol dehydrator at this facility by at least 90% because the total Uncontrolled VOC emissions from all glycol dehydrators at this facility are greater than the'15.0 TPY. Regulation 8-Hazardous Air Pollutants Page 8 • MACT 7777 004 These engines are"existing two-stroke lean-burn engines rated at over 500 hp located at a major source of HAP."According to 40 CFR 63.6590(b)(3)(i), these engines are not subject to Subpart 777Z. MACT HH This condensate tank battery is not considered a"storage vessel with the potential for flash emissions" because it has an average throughput less than 79,500 liters/day (500 008 BBL/day) and is not part of the affected facility. MACT EEEE This source is not subject to MACT EEEE tiecausg'it is locate at a"production field facility" as defined in 40 CFR 63.761 (located''upstream of tiA'e'natural gas processing plant). MACT EEEE 010 This source is not subject to Subpart EEEE because it is located at a production field facility and thus exempt per 40CFR 63.2334(c)(1). MACT ZZZZ 011-016 This facility is a production field facility as defined in this subpart. This facility is a major source of HAP for MACT ZZZZ applicability and each of these engines is subject to emission control requirements of this subpart. MACT HH This facility is a synthetic minor facility for MACT HH because it is a production field facility as defined in 63.761 and the total HAP emissions from glycol dehydrators and storage vessels with the potential for flash emissions are less than 10 tpy for each individual HAP 017 and less than 25 tpy for all HAP species. This source will have benzene emissions less than 1984 lb/yr (0.9 Mg/yr) when taking into account federally enforceable emission controls. This source is therefore only subject to recordkeeping requirements under MACT HH. ' Section 13—Aerometric Information Retrieval System Ceding Information Process Throughput Emission Pollutant/ Fugitive Emission Control Point Process Description limit Factor , . CAS# (Y/N) Factor Source (%) 114.6041 ' " ' lb/1000 gal ' ' VQE ,+No E&P Tank 100 0.8983 Benzene/ No E&P Tank 100 lb/1000 gal 71432 0.7050 Toluene/ No E&P Tank 100 01 Condensate 12,600,000 lb/1000 gal 108883 008 Tank Battery gal/yr 0.1208 Xylenes/ No E&P Tank 100 . lb/1000 gal 1330207 5.0563 n-Hexane/ No E&P Tank 100 lb/1000 gal 110543 0.1797 2,2,4-TMP/ No E&P Tank 100 lb/1000 qal 540841 SCC 40400311 —Fixed Roof Tank, Condensate, working+breathing+flashing losses 0.3396 CO No AP-42 0 lb/1000 gal 2.6702 VOC No AP-42 95 01 Condensate 12,600,000 lb/1000 qal 010 loadout gal/yr 0.01490 Benzene/ No AP-42 95 lb/1000 gal 71432 0.0839 n-Hexane/ No AP-42 95 lb/1000 gal 110543 SCC 40600132: Crude Oil: Submerged Loading (Normal Service) 20.3717 VOC No GIyCalc 4.0 98.4 10,950 lbs/mmscf 017 01 Glycol MMSCFper 5.1397 Bsenzene/ M1No GlyCalc4.0 98.2 Dehydrator year Ibs/mmscf ' 71432 6.1184 Toluene/ No GlyCalc 4.0 98.4 lbs/mmscf 108883 Page 9 • 0.2070 Ethylbenzene No GlyCalc 4.0 98.8 Ibs/mmscf /100414 2.6039 Xylenes/ No GlyCalc 4.0 98.8 lbs/mmscf 1330207 0.3345 n-Hexane/ No GlyCalc 4.0 98.1 lbs/mmscf 110543 SCC 31000227: Glycol Dehydrator: reboiler still stack Section 14—Miscellaneous Application Notes AIRS Point 010 Condensate Truck Loadout Parameter Value Units Basis for value used S 0.6 Submerged loading: dedicated normal service P 4.6 Psia RVP = 7.0 based on site specific analysis. Value converted to vapor pressure using API nomograph (API 2518) for crude oils. M 41.23 Lb/lb-mole Total emissions gas molecular weight predicted in E&P Tank model used to develop the site specific emission factor for the condensate tank battery. T 531 Deq R L 2.66 Lb VOC/1000 gal 0.112 Lb VOC/bbl NOx and CO emissions associated with the combustion of emissions from this source in a flare were estimated using the AP-42, Table 13.5-1 emission factors and a flare heat input from loadout activity of 0.44 MMBtu/hr(based on 2314 Btu/scf) and pilot gas heat rate of 0.74 MMBtu/hr(each of these numbers were buffered up by 10% to calculate emissions so that the total was 1.3MMBtu/hr). AIRS Point 017 TEG Dehydrator Kerr-McGee originally requested to permit the dehydrator based on a thermal oxidizer control efficiency of 99% at a minimum operating temperature of 1400T. The Division expressed concerns about the viability of meeting that control efficiency at that temperature based on existing stack test data and minimum operating temperature requirements in MACT HH and the pharmaceutical MACT. The Division recommended that KMG initially permit the dehydrator at 1500°F and 98%. KMG will have the option to modify the permit to reflect the temperature and control efficiency determined in any Division-approved stack testing. Page 10 N 'V .. 0 p0 �+ Qr a u ° b . aC" h � � F g � " g _>, « Al C 9 'yv � rn en rn .i �' o • W 0 °+ m- N N a ° 2 a I Q d p I. t L ¢ A tip(1, y b b O^` v 0 ° a .H oNI. o o e �.' m q q ,� « Y o Men ko .4 O CO a 8 a et o W V� > v o 0 0 0 3 C a ti W '0p e ° « � m as -+ r+ C .. 0 0 04r v � 9 .7 c ■ e ° mg R 0 vg a N U N 44 u o p 8 w m •g .� '�!a CO y `'— 6 al v°i � a o' o u El w Al « a. 0 0 v o-g b a .-I' ti u N. ti 6 v •d Q r °'I. 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O ct o a ri $ 00 P. d u 0 UR X >w 0 ' m C J d d > w > d •.. m U v —' ' w di0. d ° d ° CI o z p dp,, fi c ]rN Vca 00 .e x U d 0 c O1 X O O T ° 0 ✓ NUeS r� ? O O p J d y O mZ G U FF w' `na p z > U g o 'n >" ) o o y� O� Q Ca CI W v ® ❑ i ❑ W F W c •u i STATE OF COLORADO OF COLO 0 8 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT „��o AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 \18176/ CONSTRUCTION PERMIT PERMIT NO: 12WE804 Issuance 1 DATE ISSUED: ISSUED TO: Kerr-McGee Gathering, LLC THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural gas compression facility, known as the Frederick Compressor Station, located in 3988 Weld County Rd. 19, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Description Equipment ID Point One (1) Cooper Bessemer, Model 12Q155HC, Serial Number 48715, natural gas-fired, turbo-charged, 2SLB EU-41 reciprocating internal combustion engine, site rated at 4300 horsepower at 425 RPM. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control. This emission unit is used for natural gas compression. 004 One (1) Cooper Bessemer, Model 12Q155HC, Serial Number 48799, natural gas-fired, turbo-charged, 2SLB EU-42 reciprocating internal combustion engine, site rated at 4300 horsepower at 425 RPM. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control. This emission unit is used for natural gas compression. 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 AIRS ID: 123/0184/004 Page 1 of 10 NGEngine Version 2009-1 • Kerr-McGee Gathering sl Col xdo D p eit,1 of Public Health and Environment Permit Na. 12WE804 -I ' 7, Air Pollution Control Division Issuance 1 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 Tons per Month Emission Equipment ID Point NO, VOC CO PM10 PM2.5 TSP Type EU-41 & EU-42 004 7.1 4.3 4.1 0.5 0.5 0.5 Point Monthly limits are based on a 31-day month. Annual Limits: Facility AIRS Tons per Year Emission Equipment ID Point NO, VOC CO PM10 PM2.5 TSP Type EU-41 & EU-42 004 83.1 50.1 48.7 6.4 • 6.4 6.4 Point See "Notes to Permit Holder #4 for information on emission factors and methods used to calculate limits. During the first twelve (12) months of operation after issuance of this permit, compliance with both the monthly and yearly emission limitations shall be required. After the first twelve (12) months of operation after issuance of this permit, 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, 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. 3. Each engine covered by this permit shall be equipped with emission control equipment consiting of (i) new or remanufactured turbochargers; (ii) pre-combustion chambers; (iii) after-coolers with auxiliary water cooling, as needed; (iv) high-pressure fuel injection; and (v) oxidation catalysts. This control equipment shall reduce uncontrolled emissions of NOx and CO from the 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: Civil Action No. 07-CV-01034-WDM-MJW, DOJ Case #90-5-2-1-08656, paragraph 30.) PROCESS LIMITATIONS AND RECORDS 4. 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 Equipment Process Parameter Annual Monthly Limit ID Point Limit (31 days) EU-41 & 004 Consumption of natural gas as a fuel 286.10 24.30 AIRS ID: 123/0184/004 Page 2 of 10 Kerr-McGee Gathering Col do D p men: o'Public Health and Environment Permit No. 12WE804 Air Pollution Control Division Issuance 1 EU-42 MMscf/yr MMscf/month During the first twelve (12) months of operation after issuance of this permit, compliance with both the monthly and yearly consumption limitations shall be required. After the first twelve (12) months of operation after issuance of this permit, 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 5. 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). 6. 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.) 7. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 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.2. For lean burn reciprocating internal combustion engines, an oxidation catalyst shall be required. 9. This equipment is subject to the control requirements for natural gas-fired reciprocating internal combustion engines under Regulation No. 7, Section XVII.E.3.b (State only enforceable). All lean burn reciprocating internal combustion engines with a manufacturer's nameplate design rate greater than 500 horsepower shall install and operate an oxidation catalyst by July 1, 2010. 10. The operator of this source is subject to the requirements of the Consent Decree between EPA, the State of Colorado, Kerr-McGee (Civil Action No. 07-CV-01034-WDM- MJW) including, but not limited to, the following: a. Install emission control equipment consisting of: (i) new or remanufactured turbochargers; (ii) pre-combustion chambers; (Hi) after-coolers with auxiliary water cooling, as needed; (iv) high-pressure fuel injection; and (v) oxidation catalysts. (Paragraph 30) b. This emissions control equipment "shall meet the following control requirement for NOx: 2.0 grams/hp-hr., or an equivalent lbs./MMBTU limit, when the RICE is operating at a 90% load or higher." (Paragraph 32) c. This emissions control equipment "shall have a control requirement of 58% destruction efficiency for CO when the RICE is operating at a 90% load or higher." (Paragraph 33) AIRS ID: 123/0184/004 Page 3 of 10 • Kerr-McGee Gathering, ₹ ; Col do p e or Public Health and Environment Permit No. 12WE804 ? t t Air Pollution Control Division Issuance 1 d. "All emission control equipment shall be appropriately sized for each existing 2SLB RICE. Immediately following installation of each emission control device, Kerr-McGee shall operate and maintain each existing 2SLB RICE and associated emission control and related equipment according to all manufacturer's written instructions or procedures necessary to achieve the emission reductions listed in Paragraphs 32 and/or 33. Oxidation catalysts shall be operated in accordance with Regulation No. 7, Section XVI." (Paragraph 34) e. "Kerr-McGee shall maintain records and information adequate to demonstrate its compliance with the requirements of [Section IV.C. of the Consent Decree], and any applicable regulatory requirements, and shall report the status of its compliance with these requirements in its Annual Reports, submitted pursuant to Section XII (Reporting Requirements)." (Paragraph 39) OPERATING & MAINTENANCE REQUIREMENTS 11. Upon startup of this point, 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 12. This 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. ADDITIONAL REQUIREMENTS 13. All previous versions of this permit are cancelled upon issuance of this permit. 14. This permit replaces the following permits and/or points, which are canceled upon issuance of this permit: Permit No. AIRS ID Notes AIRS Points 004 and 005 and permit numbers 12WE804 and 13WE199 were combined under 13WE199 123/0184/005 AIRS Point 004 and permit 12WE804 in order to permit two engines under one emission limit and one process limit. 15. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or AIRS ID: 123/0184/004 Page 4 of 10 Kerr-McGee Gathering, k,' Col Ado p rt e or Public Health and Environment Permit No. 12WE804 Air Pollution Control Division Issuance 1 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. 16. This source is subject to the provisions of Regulation Number 3, Part C, Operating Permits (Title V of the 1990 Federal Clean Air Act Amendments). The provisions of this construction permit must be incorporated into the operating permit. The application for the modification to the Operating Permit is due within one year of commencement of operation of the equipment or modification covered by this permit. 17. Prevention of Significant Deterioration (PSD) requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable PSD threshold will require a full PSD review of the source as though construction had not yet commenced on the source. The source shall not exceed the PSD threshold until a PSD permit is granted. (Regulation No. 3 Part D, VI.B.4) 18. Emission reductions associated with reducing the fuel use limits for the two (2) engines covered by this permit were relied on in a netting analysis that allowed the construction of equipment covered in permits 10WE1049, 10WE1050, 11WE1961, 11WE1962, 11WE1963, 11WE1964, and 11WE1965 as a minor modification. Non-attainment New Source Review requirements shall apply to the sources covered by the permits listed above at any such time that this project becomes a major modification solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable NSR threshold will require a full NSR review of the source as though construction had not yet commenced on the source. The source shall not exceed the NSR threshold until a NSR permit is granted. (Regulation No. 3 Part D, V.A.7) GENERAL TERMS AND CONDITIONS: 19. 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. 20. 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 AIRS ID: 123/0184/004 Page 5 of 10 Kerr-McGee Gathering, 4.4_C ' Col do � pr� e o Public Health and Environment Permit No. 12WE804 '° Air Pollution Control Division Issuance 1 P f rFm 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. 21. 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. 22. 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. 23. 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. 24. 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. 25. 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: Jacob Sebesta Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Modification to combine points 004 and 005 under point 004 and reduce total processing and emission rates by half. AIRS ID: 123/0184/004 Page 6 of 10 Kerr-McGee Gathering, t� Col xdo p nme o Public Health and Environment Permit No. 12WE804 _ Air Pollution Control Division Issuance 1 �- Incorporated Consent Decree emission limits. Modification 2 1995 TRANSFER OF OWNERSHIP INCREASE IN EMISSION LIMITS FOR VOC, CO, PM AND PM-10. INCREASE IN EMISSIONS IS NOT DUE TO INCREASED OPERATION, BUT A RESULT OF AN EMISSION AUDIT BY THE OPERATOR. IN VIEW OF THESE SIGNIFICANT CHANGES AN INITIAL APPROVAL IS BEING ISSUED. Final Approval FEBRUARY 19, Final Approval Issued. 1986 Modification 1 JULY 2, 1981 ISSUED AS PERMIT NO. C-12,804 INITIAL MARCH 20, ISSUED TO PANHANDLE EASTERN PIPELINE APPROVAL 1980 COMPANY ISSUED AS PERMIT NO. C-12,804 AIRS ID: 123/0184/004 Page 7 of 10 Kerr-McGee Gathering, ' r ' ti Col do I ',p ekt. o Public Health and Environment - Permit No. 12WE804 Air Pollution Control Division Issuance 1 3 Notes to Permit Holder: 1) 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. 2) 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/requlations/airregs/100102agcccommonprovisionsreq.pdf. 3) 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) Formaldehyde 5000 A 14561 Yes 14561 Acrolein 107028 A 2052 Yes 2052 004 Acetaldehyde 75070 A 2047 Yes 2047 Methanol 67561 C 654 No 654 Benzene 71432 A 512 Yes 512 4) The emission levels contained in this permit are based on the following emission factors: Emission Factors - Emission Factors— Uncontrolled Controlled CAS Pollutant Ib/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr NOx 1.7291 5.4900 0.6299 2.0000 CO 0.8800 2.7941 0.3696 1.1735 VOC 0.3800 1.2066 0.3800 1.2066 PM10/PM2.5/ TSP 0.0483 0.1534 0.0483 0.1534 5000 Formaldehyde 0.0552 0.1753 0.0552 0.1753 107028 Acrolein 0.0078 0.0247 0.0078 0.0247 75070 Acetaldehyde 0.0078 0.0246 0.0078 0.0246 67561 Methanol 0.0025 0.0079 0.0025 0.0079 71432 Benzene 0.0019 0.0062 0.0019 0.0062 Emission factors are based on a Brake-Specific Fuel Consumption Factor of 7000 Btu/hp-hr, a site-rated horsepower value of 4300, and a fuel heat value of 922 Btu/scf. Emission Factor Sources: CAS I Pollutant I Uncontrolled EFSource I Controlled EF Source AIRS ID: 123/0184/004 Page 8 of 10 Kerr-McGee Gathering, 7 t Coati do p e o' Public Health and Environment Permit No. 12WE804 Air Pollution Control Division Issuance 1 CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Previous permit Consent Decree Requirement CO Previous permit Consent Decree Requirement VOC Previous permit No control claimed. PM10/PM2.5/ AP-42; Table 3.2-1 (7/2000); No Control TSP Natural Gas 5000 Formaldehyde AP-42; Table 3.2-1 (7/2000); No control claimed. Natural Gas 107028 Acrolein AP-42; Table 3.2-1 (7/2000); No Control Natural Gas 75070 Acetaldehyde AP-42; Table 3.2-1 (7/2000); No Control Natural Gas 67561 Methanol AP-42; Table 3.2-1 (7/2000); No Control Natural Gas 71432 Benzene AP-42; Table 3.2-1 (7/2000); No Control Natural Gas 5) In accordance with C.R.S. 25-7-114.1, the Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years. The five-year term for this APEN expires on October 31, 2016. A revised APEN shall be submitted no later than 30 days before the five-year term expires. 6) This facility is classified as follows: Applicable Status Requirement Operating Permit Major Source of NOx, VOC, CO and HAP PSD Synthetic Minor Source of CO NANSR Major Source of NOx and VOC Major Source Requirements: Not Applicable (no requirements under Subpart MACT ZZZZ ZZZZ for existing 2SLB RICE > 500HP located at a major source of HAP) Area Source Requirements: Not Applicable 7) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A— Subpart KKKK NSPS Part 60, Appendixes Appendix A—Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A— Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DOD MACT 63.1200-63.1439 Subpart EEE — Subpart PPP MACT 63.1440-63.6175 Subpart QQQ — Subpart YYYY AIRS ID: 123/0184/004 Page 9 of 10 • Kerr-McGee Gathering, C P ColAdo D p eE o Public Health and Environment • Permit No. 12WE804 Air Pollution Control Division Issuance 1 MACT 63.6580-63.8830 Subpart ZZZZ— Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX AIRS ID: 123/0184/004 Page 10 of 10 STATE OF COLORADO Id gat :1 r: �r w `oto COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT418 AIR POLLUTION CONTROL DIVISION TELEPHONE: (303)692-3150 *r ♦1876 CONSTRUCTION PERMIT PERMIT NO: 03WE0064 Issuance 1 DATE ISSUED: ISSUED TO: Kerr-McGee Gathering LLC THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural gas compression facility, known as the Frederick Compressor Station, located at 3988 Weld County Rd. 19, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Seven (7) 225 BBL and one (1) 200 BBL fixed roof storage tanks T001 008 used to store condensate. Emissions from these tanks are recycled to the plant inlet. 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. Within one hundred and eighty days (180) after issuance of this permit compliance with the conditions contained on this permit shall be demonstrated to the Division. It is the permittee's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, II.G.2). 2. 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 3. 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. AIRS ID: 123/0184/008 Page 1 of 9 Condensate Tank Version 2009-1 Kerr-McGee Gathering ` olor .f P Depa en' ..li 'Health and Environment Permit No. 03WE00644, it Pollution Control Division Issuance 1 T001 008 -- 0.0 -- Point Monthly limits are based on a 31-day month. The owner or operator shall calculate monthly emissions based on the calendar month. Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO, VOC CO Emission Type T001 008 -- 0.0 -- Point See "Notes to Permit Holder for information on emission factors and methods used to calculate limits. During the first twelve (12) months of operation after issuance of this permit, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation after issuance of this permit, compliance with only the annual limitation is 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. 4. The emission points in the table below shall be maintained and operated with the control equipment as listed in order to reduce emissions below the limits established in this permit. Operating parameters of the control equipment shall be identified in the operating and maintenance plan. (Reference: Regulation No.3, Part B, Section III.E.) Facility AIRS Equipment Control Device Pollutants • ID Point Controlled T001 008 Closed loop system (emissions compressed and VOC recycled to plant inlet) 5. Truck loadout of condensate from this storage tank battery shall be conducted using a vapor recovery system that sends all truck tank vapors to a flare for combustion. This system shall capture and control all flash emissions in the truck tank (this condensate storage tank battery is typically held above atmospheric pressure). (Reference: Regulation No.3, Part B, Section III.E.) PROCESS LIMITATIONS AND RECORDS 6. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates 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: 123/0184/008 Page 2 of 9 Kerr-McGee Gathering olor-F -..Depa en' •f P ell Health and Environment Permit No. 03WE0064e •it Pollution Control Division Issuance 1 . • Process/Consumption Limits Facility AIRS Monthly Limit Equipment Point Process Parameter Annual Limit (31 days) ID T001 008 Condensate throughput 300,000 25,479 BBLJyr BBL/month The owner or operator shall calculate monthly process rates based on the calendar month. During the first twelve (12) months of operation after issuance of this permit, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation after issuance of this permit, compliance with only the annual limitation is required. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate monthly condensate throughput and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 7. 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) 8. 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.) 9. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 10. This source is subject to the recordkeeping, monitoring, reporting and emission control requirements of Regulation 7, Section XII. The operator shall comply with all applicable requirements of Section XII. 11. The condensate storage tanks covered by this permit are subject to Regulation 7, Section XVII emission control requirements. These requirements include, but are not limited to: Section XVII.C. - Emission reduction from condensate storage tanks at oil and gas exploration and production operations, natural gas compressor stations, natural gas drip stations and natural gas processing plants. XVII.C.1. Beginning May 1, 2008, owners or operators of all atmospheric condensate storage tanks with uncontrolled actual emissions of volatile organic compounds equal to or greater than 20 tons per year based on a rolling twelve-month total shall operate air pollution control equipment that has an average control efficiency of at least 95% for VOCs on such tanks. XVII.C.3. Monitoring: The owner or operator of any condensate storage tank that is required to control volatile organic compound emissions pursuant to this AIRS ID: 123/0184/008 Page 3 of 9 Kerr-McGee Gathering , 1:1 olor Depa enI +f P{•li `Health and Environment Permit No. 03WE0064 r it Pollution Control Division Issuance 1 section XVII.C. shall visually inspect or monitor the Air Pollution Control Equipment to ensure that it is operating at least as often as condensate is loaded out from the tank, unless a more frequent inspection or monitoring schedule is followed. In addition, if a flare or other combustion device is used, the owner or operator shall visually inspect the device for visible emissions at least as often as condensate is loaded out from the tank. XVII.C.4. Recordkeeping: The owner or operator of each condensate storage tank shall maintain the following records for a period of five years: XVII.C.4.a. Monthly condensate production from the tank. XVII.C.4.b For any condensate storage tank required to be controlled pursuant to this section XVII.C., the date, time and duration of any period where the air pollution control equipment is not operating, The duration of a period of non-operation shall be from the time that the air pollution control equipment was last observed to be operating until the time the equipment recommences operation. XVII.C.4.c. For tanks where a flare or other combustion device is being used, the date and time of any instances where visible emissions are observed from the device. OPERATING & MAINTENANCE REQUIREMENTS 12. 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.) ADDITIONAL REQUIREMENTS 13. All previous versions of this permit are cancelled upon issuance of this permit. 14, A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NQ) in ozone nonattainment areas emitting less than one hundred tons of VOC or NOx 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 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. AIRS ID: 123/0184/008 Page 4 of 9 Kerr-McGee Gathering, olor- Depa en' 4 P .li Health and Environment Permit No. 03WE0064 f; it Pollution Control Division Issuance 1 • 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. 15. This source is subject to the provisions of Regulation No. 3, Part C, Operating Permits (Title V of the 1990 Federal Clean Air Act Amendments). The provisions of this construction permit must be incorporated into the operating permit. The application for the modification to the Operating Permit is due within one year of the issuance of this permit. 16. Prevention of Significant Deterioration (PSD) requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable PSD threshold will require a full PSD review of the source as though construction had not yet commenced on the source. The source shall not exceed the PSD threshold until a PSD permit is granted. (Regulation No. 3 Part D, VI.B.4) 17. Non-attainment New Source Review requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable NSR threshold will require a full NSR review of the source as though construction had not yet commenced on the source. The source shall not exceed the NSR threshold until a NSR permit is granted. (Regulation No. 3 Part D, V.A.7) GENERAL TERMS AND CONDITIONS 18. 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. 19. . 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. 20. 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. AIRS ID: 123/0184/008 Page 5 of 9 Kerr-McGee Gathering : olor r Depa ent +f P '•li 'Health and Environment Permit No. 03WE0064 '•it Pollution Control Division Issuance 1 21. 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. 22. 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. 23. 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. 24. 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: Jacob Sebesta Permit Engineer Air Pollution Control Division Permit History Issuance Date Description Issuance 1 This Issuance Increased throughput limit to 300,000 BBL per year. Changed control device from flare to vapor recovery and recycle. Operating Permit January 1, 2007 Tank battery incorporated into Operating Permit. 95OPWE035 Throughput limit increased to 35,000 BBL. Issued to Kerr-McGee Gathering, LLC. Initial Approval — September 17, Added one (1) 200 BBL tank. Mod. 1 2004 Initial Approval July 24, 2003 Issued to Kerr-McGee Rocky Mountain Corporation with throughput limit at 27,000 BBL AIRS ID: 123/0184/008 Page 6 of 9 • Kerr-McGee Gathering olor- Depa en' .f P .li Health and Environment Permit No. 03WE0064 it Pollution Control Division Issuance 1 per year. AIRS ID: 123/0184/008 Page 7 of 9 # { Kerr-McGee Gathering;" •t olor Depa en .f P c.h £`Health and Environment - Permit No. 03WE0064 -_ : it Pollution Control Division Issuance 1 Notes to Permit Holder: 1) 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. 2) 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/requlations/airregs/100102agcccommonprovisionsreq.pdf. 3) 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 Controlled Emission Are the Emission AIRS Rate emissions Rate Point Pollutant CAS# BIN (lb/yr) reportable? (Ib/yr) Benzene 71432 A 11,319 YES 0 Toluene 108883 C 8,884 YES 0 n-Hexane 110543 C 63,710 YES 0 008 Ethylbenzene 100414 C 202 NO 0 Xylenes 1330207 C 1,522 YES 0 2,2,4- 540841 C 2,264 YES 0 Trimethylpentane 4) The emission levels contained in this permit are based on the following emission factors: Emission Factors Emission Factors Uncontrolled Controlled CAS # Pollutant lb/BBL lb/BBL Source Condensate Condensate Throughput Throughput MCC 4.8134 0.0 E&P Tank 4.0.9d 110543 n-Hexane 0.2124 0.0 E&P Tank 4.0.9d 71432 Benzene 3.7730 x 10-` 0.0 E&P Tank 4.0.9d 108883 Toluene 2.9612 x 10-2 0.0 E&P Tank 4.0.9d 100414 Ethylbenzene 6.747 x 10-4 0.0 E&P Tank 4.0.9d 1330207 Xylenes 5.0747 x 10-' 0.0 E&P Tank 4.0.9d 540841 2,2,4-TMP 7.5460 x 10-3 0.0 E&P Tank 4.0.9d Note: The controlled emissions factors for this point are based on the vapor recovery recycle control efficiency of 100%. 5) In accordance with C.R.S. 25-7-114.1, the Air Pollutant Emission Notices (APENs) associated with this permit are valid for a term of five years. As of the issuance of this permit, the five-year term for AIRS ID: 123/0184/008 Page 8 of 9 • Kerr-McGee Gathering olor Depa en f P iii '"Health and Environment Permit No. 03WE0064 • it Pollution Control Division Issuance 1 lar ` these APENs expires per the table below. A revised APEN shall be submitted no later than 30 days before the five-year term expires. AIRS Point Date of Expiration 008 March 5, 2017 6) This facility is classified as follows: Applicable Status Requirement Operating Permit Major Source of NOX, VOC, CO, Formaldehyde and Total HAP PSD Synthetic Minor Source of CO NANSR Major Source of NOX and VOC (This permit is issued as part of a Synthetic Minor Modification) Major Source Requirements: Not Applicable to Storage Vessels with MACT HH throughputs less than 500 BBL/day (182500 BBL/year) Area Source Requirements: Not Applicable to Storage Vessels 7) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A— Subpart KKKK NSPS Part 60, Appendixes Appendix A—Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ —Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN — Subpart XXXXXX 8) 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: 123/0184/008 Page 9 of 9 STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION .�� TELEPHONE: (303) 692-3150 •, ,,:y. }1876/ CONSTRUCTION PERMIT PERMIT NO: 08WE0823 Issuance 2 DATE ISSUED: ISSUED TO: Kerr-McGee Gathering LLC THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural gas compression facility, known as the Frederick Compressor Station, located at 3988 Weld County Road 19, Frederick, Section 15, Township 1 North, Range 67 West, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: AIRS Description Point 010 Truck loadout of condensate. Emissions from this source are routed to a flare. 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. Within one hundred and eighty days (180) after issuance of this permit, compliance with the conditions contained on this permit shall be demonstrated to the Division. It is the permittee's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, II.G.2). 2. 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 3. 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: AIRS ID: 123/0184/010 Page 1 of 8 Condensate Loadout Version 2008-1 Kerr-McGee Gathering ColA do B p e ' o' Public Health and Environment Permit No. 08WE0823 r Air Pollution Control Division Issuance 1 • AIRS Pounds per Month Point Emission Type V0C CO 010 142 363 Point Monthly limits are based on a 31-day month. Annual Limits: AIRS Tons per Year Point Emission Type V0C CO 010 0.8 2.1 Point See "Notes to Permit Holder #3" for information on emission factors and methods used to calculate limits. During the first twelve (12) months of operation after issuance of this permit, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation after issuance of this permit, compliance with only the annual limitation is required. Compliance with the annual limits shall be determined 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. 4. Condensate truck loadout emissions shall be routed to a flare that reduces uncontrolled emissions of VOC to the emission levels listed in Condition 3, above. Operating parameters of the control equipment are identified in the operation and maintenance plan. (Reference: Regulation No.3, Part B, Section III.E.) PROCESS LIMITATIONS AND RECORDS 5. 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 AIRS Process Parameter Annual Limit Monthly Limit Point (31 days) 010 Condensate Loading 300,000 BBUyr 25,479 BBL/month During the first twelve (12) months of operation, compliance with both the monthly and yearly loading limitations shall be required. After the first twelve (12) months of operation, compliance with only the yearly limitation shall be required. Compliance with the annual loading 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 the amount of AIRS ID: 123/0184/010 Page 2 of 8 Kerr-McGee Gathering ._. Cola do I p rt e w o Public Health and Environment Permit No. 08WE0823 Air Pollution Control Division Issuance 1 condensate loaded each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 6. 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) 7. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.5.) 8. This source is located in an ozone non-attainment or attainment-maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. The requirements of condition number 9 below were determined to be RACT for this source. 9. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III.E) 10. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) OPERATING & MAINTENANCE REQUIREMENTS 11. 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.) ADDITIONAL REQUIREMENTS 12. All previous versions of this permit are cancelled upon issuance of this permit. 13. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in ozone nonattainment areas emitting less than one hundred tons of VOC or NOx per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or AIRS ID: 123/0184/010 Page 3 of 8 Kerr-McGee Gathering ` Cola do • p.- e o Public Health and Environment Permit No. 08WE0823 Air Pollution Control Division Issuance 1 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. 14. This source is subject to the provisions of Regulation Number 3, Part C, Operating Permits (Title V of the 1990 Federal Clean Air Act Amendments). The provisions of this construction permit must be incorporated into the operating permit. The application for the modification to the Operating Permit is due within one year of commencement of operation of the equipment or modification covered by this permit. 15. Non-attainment New Source Review requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable NSR threshold will require a full NSR review of the source as though construction had not yet commenced on the source. The source shall not exceed the NSR threshold until a NSR permit is granted. (Regulation No. 3 Part D, V.A.7) GENERAL TERMS AND CONDITIONS: 16. 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. 17. 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. 18. 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. AIRS ID: 123/0184/010 Page 4 of 8 Kerr-McGee Gathering Cola do p me i o Public Health and Environment Permit No. 08WE0823 Air Pollution Control Division Issuance 1 19. 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. 20. 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. 21. 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. 22. 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. 23. All previous versions of this permit are cancelled upon issuance of this permit. By: Jacob Sebesta Permit Engineer Permit History Issuance Date Description Issuance 2 This Issuance Increased throughput from 35,000 BBUyr. Added flare as emission control. Issuance 1 September 7, 2011 Modification: increase in throughput and emission limits. Initial Approval November 4, 2008 Issued to Kerr-McGee Oil and Gas Onshore LP AIRS ID: 123/0184/010 Page 5 of 8 Kerr-McGee Gathering = Colk do p ;p a o Public Health and Environment Permit No. 08WE0823 Air Pollution Control Division Issuance 1 Notes to Permit Holder 1) 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. 2) 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/100102agcccommonprovisionsreq.odf. 3) 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 Controlled Emission Are the Emission AIRS Rate emissions Rate Point Pollutant CAS# BIN (Ib/yr) reportable? (Ib/yr) Benzene 71432 A 188 YES 9 010 Hexane 110543 C 1,057 YES 53 4) The emission levels contained in this permit are based on the following emission factors: Emission Factors - Emission Factors - Uncontrolled Controlled CAS Pollutant lb/BBL loaded Source lb/BBL loaded Source CO 0.0143 AP-42 N/A N/A VOC 0.1121 AP-42 0.0056 95% flare 71432 Benzene 6.257 x 10-° AP-42 3.129 x 10-5 control 110543 n-Hexane 3.522 x 10-3 AP-42 1.761 x 10' efficiency The uncontrolled VOC emission factor was calculated using AP-42, Chapter 5.2, Equation 1 (version 1/95) using the following values: S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 4.6 psia M (vapor molecular weight) = 41.23 Ib/Ib-mol T(temperature of liquid loaded) = 531 °R The uncontrolled non-criteria reportable air pollutant (NCRP) emission factors were calculated using the mole fraction of each NCRP predicted for the total losses in the E&P Tank model run used to calculate condensate tank emissions from this facility (for permit 03WE0064.CP1). AIRS ID: 123/0184/010 Page 6 of 8 Kerr-McGee Gathering .` do pPublic Health and Environment Permit No. 08WE0823 : e o Air Pollution Control Division Issuance 1 VOC emission rate [p] lb * 0.002945(benzene mole fraction) * 78.11 f (benzene MW) 41.23 [!b/lbmol] (total loss MW) llbmol Ib = benzene emission rate [—] Yr VOC emission rate [yb] [yr lb * 0.015024(hexane mole fraction) * 86.18[Ibmo d ] (hexane MW) lb 41.23 [lbmol] (total loss MW) lb = hexane emission rate [—] yr 5) In accordance with C.R.S. 25-7-114.1, the Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years. The five-year term for this APEN expires on July 11, 2016. A revised APEN shall be submitted no later than 30 days before the five-year term expires. 6) This facility is classified as follows: Applicable Status Requirement Operating Permit Major Source of NOX, VOC, CO, Formaldehyde and Total HAP PSD Synthetic Minor Source of CO NANSR Major Source of NOX and VOC (This permit is issued as part of a Synthetic Minor Modification) 7) 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 XXXXXX 8) An Oil and Gas Industry Construction Permit Self-Certification Form is included with this permit packet. Please use this form to complete the self-certification requirements as specified in the permit conditions. Further guidance on self-certification can be found on our website at: AIRS ID: 123/0184/010 Page 7 of 8 Kerr-McGee Gathering sr Cola do I 'p. er : o Public Health and Environment Permit No. 08WE0823 Air Pollution Control Division Issuance 1 http.//www.cdphe.state.co us/ap/oilqaspermittinci.html AIRS ID: 123/0184/010 Page 8 of 8 Kerr-McGee/Anadarko •7 • c. m '`•rati olor ep ment of Public Health and Environment Permit No. 10WE1049 Air Pollution Control Division Issuance 1 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, 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. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control that reduces uncontrolled emissions of CO and VOC from the 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.) 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 EU-44 011 Consumption of natural gas as a fuel 119.42 10.14 MMscf/yr MMscf/month 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.) AIRS ID: 123/0184/011 Page 3 of 18 MI Kerr-McGee/Anadarko ` trol m•'►mr?'•ratiA, olor p ment of Public Health and Environment Permit No. 10WE1049 •= • Air Pollution Control Division Issuance 1 S. Periodic Testing Requirements 17. This engine is subject to the periodic testing requirements of 40 C.F.R Part 63, Subpart ZZZZ. 18. This 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. ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine or turbine, the appropriate APEN filing fee and a cover letter explaining that the permittee is exercising an alternative-operating scenario and is installing a permanent replacement engine. 20. This source is subject to the provisions of Regulation Number 3, Part C, Operating Permits (Title V of the 199O Federal Clean Air Act Amendments). The provisions of this construction permit must be incorporated into the operating permit. The application for the modification to the Operating Permit is due within one year of commencement of operation of the equipment or modification covered by this permit. 21. Prevention of Significant Deterioration (PSD) requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable PSD threshold will require a full PSD review of the source as though construction had AIRS ID: 123/0184/011 Page 8 of 18 Kerr-McGee/Anadarko *$trol.R m o 'i .rati olor ep ment of Public Health and Environment Permit No. 10WE1049 '' Air Pollution Control Division Issuance 1 Notes to Permit Holder 1) 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. 2) 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. 3) 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 (lb/yr) Formaldehyde 5000 A 9134 Yes 2192 Acetaldehyde 75070 A 903 Yes 903 Acrolein 107028 A 555 Yes 555 011 Methanol 67561 C 270 No 270 n-Hexane 110543 C 120 No 120 Benzene 71432 A 48 No 48 Toluene 108883 C 44 No 44 4) The emission levels contained in this permit are based on the following emission factors: Emission Factors - Emission Factors— Uncontrolled Controlled CAS Pollutant lb/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr NOx 0.2276 0.7000 0.2276 0.7000 CO 0.8128 2.5000 0.0813 0.2500 VOC 0.2931 0.9015 0.1905 0.5860 5000 Formaldehyde 0.0845 0.2600 0.0203 0.0624 75070 Acetaldehyde 0.0084 0.0257 0.0084 0.0257 107028 Acrolein 0.0051 0.0158 0.0051 0.0158 67561 Methanol 0.0025 0.0077 0.0025 0.0077 110543 n-Hexane 0.0011 0.0034 0.0011 0.0034 71432 Benzene 0.0004 0.0014 0.0004 0.0014 108883 Toluene 0.0004 0.0013 0.0004 0.0013 Emission factors are based on a Brake-Specific Fuel Consumption Factor of 6781 Btu/hp-hr, a site-rated horsepower value of 1775, and a fuel heat value of 905 Btu/scf. AIRS ID: 123/0184/011 Page 11 of 18 RAF pI m STATE OF COLORADO :cc.coz COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT Fe AIR POLLUTION CONTROL DIVISION �`y „`i TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 1 OWE1 049 Issuance 1 DATE ISSUED: ISSUED TO: Kerr-McGee Gathering, LLC THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural gas compression facility, known as the Frederick Compressor Station, located in 3988 Weld County Rd. 19, Frederick in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Description Equipment ID Point One (1)Caterpillar, Model G3606LE, Serial Number To Be Determined, natural gas-fired, turbo-charged, 4SLB reciprocating internal combustion engine, site rated at 1775 EU-44 011 horsepower at 1000 RPM. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control. This emission unit is used for natural gas compression. This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Caterpillar G3606LE engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the APCD no later than fifteen days after commencement of the permitted operation or activity by submitting a Notice of Startup (NOS) form to the APCD. The Notice of Startup (NOS) form may be downloaded online at www.cdphe.state.co.usiap/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: 123/0184/011 Page 1 of 18 NGEngine Version 2009-1 Kerr-McGee/Anadarko orate/ olor di p ent of Public Health and Environment Permit No. 10WE1049 . Air Pollution Control Division Issuance 1 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; (H) 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, I I I.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 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 Equipment ID Point NO, VOC CO Emission Type EU-44 011 2089 1748 746 Point Monthly limits are based on a 31-day month. Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO, VOC CO Emission Type EU-44 011 12.3 10.3 4.4 Point See "Notes to Permit Holder #4 for information on emission factors and methods used to calculate limits. AIRS ID: 123/0184/011 Page 2 of 18 Kerr-McGee/Anadarko.trot. m o rati r''olor p invent of Public Health and Environment Permit No. 10WE1049 Air Pollution Control Division Issuance 1w 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, 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. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control that reduces uncontrolled emissions of CO and VOC from the 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.) 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 119.42 10.14 EU-44 011 Consumption of natural gas as a fuel MMscf/yr MMscf/month 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.) AIRS ID: 123/0184/011 Page 3 of 18 Kerr-McGee/Anadarko trot m aa .rativ. olor pf ment of Public Health and Environment Permit No. 10WE1049 I - , Air Pollution Control Division Issuance 1 12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 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.2. For lean burn reciprocating internal combustion engines, an oxidation catalyst shall be required. 14. This source is subject to the requirements of: • Regulation No. 8, Part E , Subpart III.FFFF: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (RICE) of 40 C.F.R. Part 63, Subpart ZZZZ, and • Regulation No. 8, Part E, Subpart IA, National Emission Standards for Hazardous Air Pollutants for Source Categories: General Provisions, 40 CFR Part 63 including, but not limited to, the following: • Emission and Operating Limitations o 63.6600(b) - If you own or operate a new or reconstructed 4SLB stationary RICE with a site rating of more than 500 brake HP located at major source of HAP emissions you must comply with the following emission limitations (Table 2a, Subpart ZZZZ to Part 63): • reduce CO emissions by 93 percent or more; or • limit concentration of formaldehyde in the stationary RICE exhaust to 14 ppmvd or less at 15 percent O2. o 63.6600(b) - If you own or operate a new or reconstructed 4SLB stationary RICE with a site rating of more than 500 brake HP located at major source of HAP emissions you must comply with the following operating limitations (Table 2b, Subpart ZZZZ to Part 63): • maintain your catalyst so that the pressure drop across the catalyst does not change by more than 2 inches of water at 100 percent load plus or minus 10 percent from the pressure drop across the catalyst that was measured during the initial performance test; and • maintain the temperature of your stationary RICE exhaust so that the catalyst inlet temperature is greater than or equal to 450 °F and less than or equal to 1350 °F. • General Compliance Requirements o §63.6605(a) - You must be in compliance with the emission limitations and operating limitations in this subpart that apply to you at all times, except during periods of startup, shutdown, and malfunction. o §63.6605(b) - If you must comply with emission limitations and operating limitations, you must operate and maintain your stationary RICE, including air pollution control and monitoring equipment, in a manner consistent with good air pollution control practices for minimizing emissions at all times, including during startup, shutdown, and malfunction. AIRS ID: 123/0184/011 Page 4 of 18 Kerr-McGee/Anadarko trolm o rati olor' • -p ment of Public Health and Environment Permit No. 10WE1049 Air Pollution Control Division Issuance 1 • Testing and Initial Compliance Requirements o §63.6610(a) - You must conduct the initial performance test or other initial compliance demonstrations in Table 4 to Subpart ZZZZ of Part 63 that apply to you within 180 days after the compliance date that is specified for your stationary RICE in §63.6595 and according to the provisions in §63.7(a)(2). o §63.6615 - If you must comply with the emission limitations and operating limitations, you must conduct subsequent performance tests semiannually(as per Table 3 of Subpart ZZZZ to Part 63). After you have demonstrated compliance for two consecutive tests, you may reduce the frequency of subsequent performance tests to annually. If the results of any subsequent annual performance test indicate the stationary RICE is not in compliance with the CO or formaldehyde emission limitation, or you deviate from any of your operating limitations, you must resume semiannual performance tests. o §63.6625(a) - If you elect to install a GEMS as specified in Table 5 of this subpart, you must install, operate, and maintain a CEMS to monitor CO and either oxygen or CO2 at both the inlet and the outlet of the control device according to the requirements in paragraphs 63.6625(a)(1) through 63.6625(4) of Subpart ZZZZ to Part 63. o §63.6625(b) - If you are required to install a continuous parameter monitoring system (CPMS) as specified in Table 5 of this subpart, you must install, operate, and maintain each CPMS according to the requirements in §63.8. o §63.6630(a) - You must demonstrate initial compliance with each emission and operating limitation that applies to you according to Table 5 of Subpart ZZZZ to Part 63. o §63.6630(b) - During the initial performance test, you must establish each operating limitation in Tables lb and 2b of Subpart ZZZZ to Part 63 that applies to you. o §63.6630(c) - You must submit the Notification of Compliance Status containing the results of the initial compliance demonstration according to the requirements in §63.6645. • Continuous Compliance Requirements o §63.6635(b) - Except for monitor malfunctions, associated repairs, and required quality assurance or control activities (including, as applicable, calibration checks and required zero and span adjustments), you must monitor continuously at all times that the stationary RICE is operating. o §63.6635(c) - You may not use data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities in data averages and calculations used to report emission or operating levels. You must, however, use all the valid data collected during all other periods. o §63.6640(a) - You must demonstrate continuous compliance with each emission limitation and operating limitation in Tables la and 1b and Tables 2a and 2b of subpart ZZZZ of Part 63 that apply to you according to methods specified in Table 6 of Subpart ZZZZ of Part 63. AIRS ID: 123/0184/011 Page 5 of 18 Kerr-McGee/Anadarko •1,.trol.,wmm ``•rati olor p ment of Public Health and Environment Permit No. 10WE1049 Air Pollution Control Division Issuance 1 o §63.6640(b) -You must report each instance in which you did not meet each emission limitation or operating limitation in Tables la and lb and Tables 2a and 2b of Subpart ZZZZ of Part 63 that apply to you. These instances are deviations from the emission and operating limitations in this subpart. These deviations must be reported according to the requirements in §63.6650. If you change your catalyst, you must reestablish the values of the operating parameters measured during the initial performance test. When you reestablish the values of your operating parameters, you must also conduct a performance test to demonstrate that you are meeting the required emission limitation applicable to your stationary RICE. o §63.6640(d) - Consistent with §§63.6(e) and 63.7(e)(1), deviations from the emission or operating limitations that occur during a period of startup, shutdown, or malfunction are not violations if you demonstrate to the Administrator's satisfaction that you were operating in accordance with §63.6(e)(1). For new, reconstructed, and rebuilt stationary RICE, deviations from the emission or operating limitations that occur during the first 200 hours of operation from engine startup (engine burn-in period) are not violations. o §63.6640(e) - You must also report each instance in which you did not meet the requirements in Table 8 of Subpart ZZZZ to Part 63 that apply to you. • Notifications, Reports and Records o §63.6645(a) - If you own or operate a stationary RICE with a site rating of more than 500 brake HP located at a major source of HAP emissions you must submit all of the notifications in §§63.7(b) and (c), 63.8(e), (f)(4) and (f)(6), 63.9(b) through (e), and (g) and (h) that apply to you by the dates specified. o §63.6645(g) - If you are required to conduct a performance test, you must submit a Notification of Intent to conduct a performance test at least 60 days before the performance test is scheduled to begin as required in §63.7(b)(1). o §63.6645(h) - If you are required to conduct a performance test or other initial compliance demonstration as specified in Tables 4 and 5 of Subpart ZZZZ to Part 63, you must submit a Notification of Compliance Status according to §63.9(h)(2)(ii). • §63.6645(h)(1) - For each initial compliance demonstration required in Table 5 of Subpart ZZZZ to Part 63 that does not include a performance test, you must submit the Notification of Compliance Status before the close of business on the 30th day following the completion of the initial compliance demonstration. • §63.6645(h)(2) - For each initial compliance demonstration required in Table 5 of Subpart ZZZZ to Part 63 that includes a performance test conducted according to the requirements in Table 3 to this subpart, you must submit the Notification of Compliance Status, including the performance test results, before the close of business on the 60th day following the completion of the performance test according to §63.10(d)(2). AIRS ID: 123/0184/011 Page 6 of 18 Kerr-McGee/Anadarko trot m . -orati olor bp ent of Public Health and Environment Permit No. 10WE1049 a' Air Pollution Control Division Issuance 1 o §63.6650(a) - You must submit each report in Table 7 of Subpart ZZZZ to Part 63 that applies to you. o §63.6655(a) - If you must comply with the emission and operating limitations, you must keep the records described in §63.6655(a)(1) through (a)(3), §63.6655 (b)(1)through (b)(3) and §63.6655 (c). o §63.6655(d) - You must keep the records required in Table 6 of Subpart ZZZZ of Part 63 to show continuous compliance with each emission or operating limitation that applies to you. o §63.6660(a) - Your records must be in a form suitable and readily available for expeditious review according to§63.10(b)(1). o §63.6660(b) - As specified in §63.10(b)(1), you must keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. o §63.6660(c) - You must keep each record readily accessible in hard copy or electronic form on-site for at least 2 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record, according to §63.10(b)(1). You can keep the records off-site for the remaining 3 years. • Other Requirements and Information o §63.6665 - Table 8 to this subpart shows which parts of the General Provisions in §§63.1 through 63.15 apply to you. OPERATING & MAINTENANCE REQUIREMENTS 15. Upon startup of this point, 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 16. A source initial compliance test shall be conducted on emissions point 011 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 Formaldehyde AIRS ID: 123/0184/011 Page 7 of 18 Kerr-McGee/Anadarko Itrol m... o .rati olor� •* p vment of Public Health and Environment Permit No. 10WE1049 Air Pollution Control Division Issuance 1 " ` . Periodic Testing Requirements 17. This engine is subject to the periodic testing requirements of 40 C.F.R Part 63, Subpart ZZZZ. 18. This 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. ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5)tons per year or more, above the level reported on the last APEN; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A or B. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine or turbine, the appropriate APEN filing fee and a cover letter explaining that the permittee is exercising an alternative-operating scenario and is installing a permanent replacement engine or turbine. 20. This source is subject to the provisions of Regulation Number 3, Part C, Operating Permits (Title V of the 1990 Federal Clean Air Act Amendments). The provisions of this construction permit must be incorporated into the operating permit. The application for the modification to the Operating Permit is due within one year of commencement of operation of the equipment or modification covered by this permit. 21. Prevention of Significant Deterioration (PSD) requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable PSD threshold will require a full PSD review of the source as though construction had AIRS ID: 123/0184/011 Page 8 of 18 Kerr-McGee/Anadarko trot m o rati =r "olor p ment of Public Health and Environment Permit No. 10WE1049 Air Pollution Control Division Issuance 1 not yet commenced on the source. The source shall not exceed the PSD threshold until a PSD permit is granted. (Regulation No. 3 Part D, VI.B.4) 22. Non-attainment New Source Review requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable NSR threshold will require a full NSR review of the source as though construction had not yet commenced on the source. The source shall not exceed the NSR threshold until a NSR permit is granted. (Regulation No. 3 Part D, V.A.7) GENERAL TERMS AND CONDITIONS: 23. 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. 24. 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. 25. 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. 26. 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. 27. 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. 28. 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 AIRS ID: 123/0184/011 Page 9 of 18 Kerr-McGee/Anadarko trot m o rate olor 4!Jep ent of Public Health and Environment Permit No. 10WE1049 Air Pollution Control Division Issuance 1 R . Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 29. 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: Jacob Sebesta Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued as part of a synthetic minor modification project for NANSR. AIRS ID: 123/0184/011 Page 10 of 18 Kerr-McGee/Anadarko • trot- m . .rats `" olor p ent of Public Health and Environment Permit No. 10WE1049 Air Pollution Control Division Issuance 1 Notes to Permit Holder: 1) 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. 2) 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/requlations/airregs/100102agcccommonprovisionsreq.pdf. 3) 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(lb/yr) Formaldehyde 5000 A 9134 Yes 2192 Acetaldehyde 75070 A 903 Yes 903 Acrolein 107028 A 555 Yes 555 011 Methanol 67561 C 270 No 270 n-Hexane 110543 C 120 No 120 Benzene 71432 A 48 No 48 Toluene 108883 C 44 No 44 4) The emission levels contained in this permit are based on the following emission factors: Emission Factors - Emission Factors— Uncontrolled Controlled CAS Pollutant lb/MMBtu g/bhp-hr Ib/MMBtu g/bhp-hr NOx 0.2276 0.7000 0.2276 0.7000 CO 0.8128 2.5000 0.0813 0.2500 VOC 0.2931 0.9015 0.1905 0.5860 5000 Formaldehyde 0.0845 0.2600 0.0203 0.0624 75070 Acetaldehyde 0.0084 0.0257 0.0084 0.0257 107028 Acrolein 0.0051 0.0158 0.0051 0.0158 67561 Methanol 0.0025 0.0077 0.0025 0.0077 110543 n-Hexane 0.0011 0.0034 0.0011 0.0034 71432 Benzene 0.0004 0.0014 0.0004 0.0014 108883 Toluene 0.0004 0.0013 0.0004 0.0013 Emission factors are based on a Brake-Specific Fuel Consumption Factor of 6781 Btu/hp-hr, a site-rated horsepower value of 1775, and a fuel heat value of 905 Btu/scf. AIRS ID: 123/0184/011 Page 11 of 18 Kerr-McGee/Anadarko « . vfrrn or rata olorJ D p, ent of Public Health and Environment Permit No. 10WE1049 a Air Pollution Control Division Issuance 1 Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer Data No control. CO Manufacturer Data Eng. Judgement VOC Manufacturer Data Eng. Judgement 5000 Formaldehyde Manufacturer Data Enq. Judgement 75070 Acetaldehyde AP-42;Table 3.2-2 (7/2000); No Control Natural Gas 107028 Acrolein AP-42; Table 3.2-2 (7/2000); No Control Natural Gas 67561 Methanol AP-42; Table 3.2-2 (7/2000); No Control Natural Gas 110543 n-Hexane AP-42; Table 3.2-2 (7/2000); No Control Natural Gas 71432 Benzene AP-42; Table 3.2-2 (7/2000); No Control Natural Gas 108883 Toluene AP-42; Table 3.2-2 (7/2000); No Control Natural Gas Note: The uncontrolled VOC emission factor was calculated by adding the non-methane, non- ethane hydrocarbon (NMNEHC) and formaldehyde emission factors provided by the manufacturer and the acetaldehyde and acrolein emission factors from AP-42. This calculation was necessary because the manufacturer's NMNEHC factor did not include emissions of aldehyde compounds. 5) In accordance with C.R.S. 25-7-114.1, the Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years. The five-year term for this APEN expires on July 11, 2016. A revised APEN shall be submitted no later than 30 days before the five-year term expires. 6) This 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 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Major Source of NOx, VOC, CO and HAP PSD Synthetic Minor Source of CO NANSR Major Source of NOx and VOC MACT Z777 Major Source Requirements: Applicable Area Source Requirements: Not Applicable 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.g poaccess.gov/ AIRS ID: 123/0184/011 Page 12 of 18 Kerr-McGee/Anadarko 4trol am • ,orati olor p ent of Public Health and Environment Permit No. 10WE1049 / Air Pollution Control Division Issuance 1 s,m 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 ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX 9) 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: 123/0184/011 Page 13 of 18 t ' Kerr-McGee/Anadarko trot m o rati olor p:ytment of Public Health and Environment Permit No. 10WE1049 4 Air Pollution Control Division rOt Issuance 1 a ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES October 1, 2011 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 permittee 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 permittee 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 permittee 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 permittee 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: 123/0184/011 Page 14 of 18 Kerr-McGee/Anadarko FittrolerArn oratir4tolor p ment of Public Health and Environment Permit No. 10WE1049 •y Air Pollution Control Division Issuance 1 �r_..s 2.1.2 The permittee may permanently replace the existing compressor engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. The AOS cannot be used for the permanent replacement of an entire engine at any source that is currently a major stationary source for purposes of Prevention of Significant Deterioration or Non- Attainment Area New Source Review("PSD/NANSR")unless the existing engine has emission limits that are below the significance levels in Reg 3, Part D, II.A.42. An Air Pollutant Emissions Notice(APEN)that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the permittee 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 permittee shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. Nothing in this AOS shall preclude the Division from taking an action, based on any permanent engine replacement(s),for circumvention of any state or federal PSD/NANSR requirement.Additionally, in the event that any permanent engine replacement(s)constitute(s)a circumvention of applicable PSD/NANSR requirements, nothing in this AOS shall excuse the permittee from complying with PSD/NANSR and applicable permitting requirements. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The permittee 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 permittee shall measure nitrogen oxide(NOX)and carbon monoxide(CO)emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven(7) calendar days of commencing operation of the replacement engine. AIRS ID: 123/0184/011 Page 15 of 18 Kerr-McGee/Anadarko ktrol m . .rati olor p Ant of Public Health and Environment Permit No. 10WE1049 - r Air Pollution Control Division Issuance 1 + All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer). Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year)or short term (lbs/unit of time)emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year(whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year(8760), whichever applies. For comparison with a short-term limit that is either input based (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 naturalgas 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). AIRS ID: 123/0184/011 Page 16 of 18 Kerr-McGee/Anadarko trot m .rata olor ep ent of Public Health and Environment Permit No. 10WE1049 Air Pollution Control Division Issuance 1 e 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. 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 AIRS ID: 123/0184/011 Page 17 of 18 Kerr-McGee/Anadarko PrItrol or;orate olor o jlep*tme tmnt of Public Health and Environment Permit No. 10WE1049 Air Pollution Control Division Issuance 1 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, §l.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 777Z.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: 123/0184/011 Page 18 of 18 STATE OF COLORADO 04'c„ COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION • TELEPHONE: (303) 692-3150 x 1876 CONSTRUCTION PERMIT PERMIT NO: 1 OWE1 050 Issuance 1 DATE ISSUED: ISSUED TO: Kerr-McGee Gathering, LLC THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural gas compression facility, known as the Frederick Compressor Station, located in 3988 Weld County Rd. 19, Frederick in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Description Equipment ID Point One (1) Caterpillar, Model G3606LE, Serial Number To Be Determined, natural gas-fired, turbo-charged, 4SLB EU-45 012 reciprocating internal combustion engine, site rated at 1775 horsepower at 1000 RPM. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control. This emission unit is used for natural gas compression. This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Caterpillar G3606LE engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the APCD no later than fifteen days after commencement of the permitted operation or activity by submitting a Notice of Startup (NOS) form to the APCD. The Notice of Startup (NOS) form may be downloaded online at www.cdphe.state.co.us/ap/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: 123/0184/012 Page 1 of 18 NGEngine Version 2009-1 Kerr-McGee/Anadarko ` Irak. ,m. •ratik olor ep ment of Public Health and Environment Permit No. 10WE1050 Air Pollution Control Division Issuance 1 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, I I I.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 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, V0C CO EU-45 012 2089 1748 746 Point Monthly limits are based on a 31-day month. Annual Limits: Facility AIRS Tons per Year Emission Type Equipment ID Point NO: V0C CO EU-45 012 12.3 10.3 4.4 Point See "Notes to Permit Holder #4 for information on emission factors and methods used to calculate limits. AIRS ID: 123/0184/012 Page 2 of 18 Kerr-McGee/Anadarko ' • m .r'•rata olor ep ment of Public Health and Environment Permit No. 10WE1050 Air Pollution Control Division Issuance 1 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, 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. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control that reduces uncontrolled emissions of CO and VOC from the 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.) 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 119.42 10.14 EU-45 012 Consumption of natural gas as a fuel MMscf/yr MMscf/month 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.) AIRS ID: 123/0184/012 Page 3 of 18 Kerr-McGee/Anadarko • • m ' o •rati j olor ep ment of Public Health and Environment Permit No. 10WE1050 Air Pollution Control Division Issuance 1 12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 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.2. For lean burn reciprocating internal combustion engines, an oxidation catalyst shall be required. 14. This source is subject to the requirements of: • Regulation No. 8, Pad E , Subpart III.FFFF: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (RICE) of 40 C.F.R. Part 63, Subpart ZZZZ, and • Regulation No. 8, Part E, Subpart I.A, National Emission Standards for Hazardous Air Pollutants for Source Categories: General Provisions, 40 CFR Part 63 including, but not limited to, the following: • Emission and Operating Limitations o 63.6600(b) - If you own or operate a new or reconstructed 4SLB stationary RICE with a site rating of more than 500 brake HP located at major source of HAP emissions you must comply with the following emission limitations (Table 2a, Subpart ZZZZ to Part 63): • reduce CO emissions by 93 percent or more; or • limit concentration of formaldehyde in the stationary RICE exhaust to 14 ppmvd or less at 15 percent O2. o 63.6600(b) - If you own or operate a new or reconstructed 4SLB stationary RICE with a site rating of more than 500 brake HP located at major source of HAP emissions you must comply with the following operating limitations (Table 2b, Subpart ZZZZ to Part 63): • maintain your catalyst so that the pressure drop across the catalyst does not change by more than 2 inches of water at 100 percent load plus or minus 10 percent from the pressure drop across the catalyst that was measured during the initial performance test; and • maintain the temperature of your stationary RICE exhaust so that the catalyst inlet temperature is greater than or equal to 450 °F and less than or equal to 1350 °F. • General Compliance Requirements o §63.6605(a) - You must be in compliance with the emission limitations and operating limitations in this subpart that apply to you at all times, except during periods of startup, shutdown, and malfunction. o §63.6605(b) - If you must comply with emission limitations and operating limitations, you must operate and maintain your stationary RICE, including air pollution control and monitoring equipment, in a manner consistent with good air pollution control practices for minimizing emissions at all times, including during startup, shutdown, and malfunction. AIRS ID: 123/0184/012 Page 4 of 18 Kerr-McGee/Anadarko • . :m 5��.ratil olor ep ment of Public Health and Environment Permit No. 10WE1050 Air Pollution Control Division Issuance 1 • Testing and Initial Compliance Requirements o §63.6610(a) - You must conduct the initial performance test or other initial compliance demonstrations in Table 4 to Subpart ZZZZ of Part 63 that apply to you within 180 days after the compliance date that is specified for your stationary RICE in §63.6595 and according to the provisions in §63.7(a)(2). o §63.6615 - If you must comply with the emission limitations and operating limitations, you must conduct subsequent performance tests semiannually (as per Table 3 of Subpart ZZZZ to Part 63). After you have demonstrated compliance for two consecutive tests, you may reduce the frequency of subsequent performance tests to annually. If the results of any subsequent annual performance test indicate the stationary RICE is not in compliance with the CO or formaldehyde emission limitation, or you deviate from any of your operating limitations, you must resume semiannual performance tests. o §63.6625(a) - If you elect to install a CEMS as specified in Table 5 of this subpart, you must install, operate, and maintain a GEMS to monitor CO and either oxygen or CO2 at both the inlet and the outlet of the control device according to the requirements in paragraphs 63.6625(a)(1) through 63.6625(4) of Subpart ZZZZ to Part 63. o §63.6625(b) - If you are required to install a continuous parameter monitoring system (CPMS) as specified in Table 5 of this subpart, you must install, operate, and maintain each CPMS according to the requirements in §63.8. o §63.6630(a) - You must demonstrate initial compliance with each emission and operating limitation that applies to you according to Table 5 of Subpart ZZZZ to Part 63. o §63.6630(b) - During the initial performance test, you must establish each operating limitation in Tables lb and 2b of Subpart ZZZZ to Part 63 that applies to you. o §63.6630(c) - You must submit the Notification of Compliance Status containing the results of the initial compliance demonstration according to the requirements in §63.6645. • Continuous Compliance Requirements o §63.6635(b) - Except for monitor malfunctions, associated repairs, and required quality assurance or control activities (including, as applicable, calibration checks and required zero and span adjustments), you must monitor continuously at all times that the stationary RICE is operating. o §63.6635(c) - You may not use data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities in data averages and calculations used to report emission or operating levels. You must, however, use all the valid data collected during all other periods. o §63.6640(a) - You must demonstrate continuous compliance with each emission limitation and operating limitation in Tables 1a and lb and Tables 2a and 2b of subpart ZZZZ of Part 63 that apply to you according to methods specified in Table 6 of Subpart ZZZZ of Part 63. AIRS ID: 123/0184/012 Page 5 of 18 Kerr-McGee/Anadarko rt\trolw-imil►• •ratio :,, olor .. I-p ment of Public Health and Environment Permit No. 10WE1050 - Air Pollution Control Division Issuance 1 o §63.6640(b) - You must report each instance in which you did not meet each emission limitation or operating limitation in Tables la and lb and Tables 2a and 2b of Subpart ZZZZ of Part 63 that apply to you. These instances are deviations from the emission and operating limitations in this subpart. These deviations must be reported according to the requirements in §63.6650. If you change your catalyst, you must reestablish the values of the operating parameters measured during the initial performance test. When you reestablish the values of your operating parameters, you must also conduct a performance test to demonstrate that you are meeting the required emission limitation applicable to your stationary RICE. o §63.6640(d) - Consistent with §§63.6(e) and 63.7(e)(1), deviations from the emission or operating limitations that occur during a period of startup, shutdown, or malfunction are not violations if you demonstrate to the Administrator's satisfaction that you were operating in accordance with §63.6(e)(1). For new, reconstructed, and rebuilt stationary RICE, deviations from the emission or operating limitations that occur during the first 200 hours of operation from engine startup (engine burn-in period) are not violations. o §63.6640(e) - You must also report each instance in which you did not meet the requirements in Table 8 of Subpart ZZZZ to Part 63 that apply to you. • Notifications, Reports and Records o §63.6645(a) - If you own or operate a stationary RICE with a site rating of more than 500 brake HP located at a major source of HAP emissions you must submit all of the notifications in §§63.7(b) and (c), 63.8(e), (f)(4) and (f)(6), 63.9(b) through (e), and (g) and (h) that apply to you by the dates specified. o §63.6645(g) - If you are required to conduct a performance test, you must submit a Notification of Intent to conduct a performance test at least 60 days before the performance test is scheduled to begin as required in §63.7(b)(1). o §63.6645(h) - If you are required to conduct a performance test or other initial compliance demonstration as specified in Tables 4 and 5 of Subpart ZZZZ to Part 63, you must submit a Notification of Compliance Status according to §63.9(h)(2)(ii). • §63.6645(h)(1) - For each initial compliance demonstration required in Table 5 of Subpart ZZZZ to Part 63 that does not include a performance test, you must submit the Notification of Compliance Status before the close of business on the 30th day following the completion of the initial compliance demonstration. • §63.6645(h)(2) - For each initial compliance demonstration required in Table 5 of Subpart ZZZZ to Part 63 that includes a performance test conducted according to the requirements in Table 3 to this subpart, you must submit the Notification of Compliance Status, including the performance test results, before the close of business on the 60th day following the completion of the performance test according to §63.10(d)(2). AIRS ID: 123/0184/012 Page 6 of 18 Kerr-McGee/Anadarko `';trola,-m =•rati olor p ment of Public Health and Environment Permit No. 10WE1050 Air Pollution Control Division Issuance 1 o §63.6650(a) - You must submit each report in Table 7 of Subpart ZZZZ to Part 63 that applies to you. o §63.6655(a) - If you must comply with the emission and operating limitations, you must keep the records described in §63.6655(2)(1) through (a)(3), §63.6655 (b)(1) through (b)(3) and §63.6655 (c). o §63.6655(d) - You must keep the records required in Table 6 of Subpart ZZZZ of Part 63 to show continuous compliance with each emission or operating limitation that applies to you. o §63.6660(a) - Your records must be in a form suitable and readily available for expeditious review according to §63.10(b)(1). o §63.6660(b) - As specified in §63.10(b)(1), you must keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. o §63.6660(c) - You must keep each record readily accessible in hard copy or electronic form on-site for at least 2 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record, according to §63.10(b)(1). You can keep the records off-site for the remaining 3 years. • Other Requirements and Information o §63.6665 - Table 8 to this subpart shows which parts of the General Provisions in §§63.1 through 63.15 apply to you. OPERATING & MAINTENANCE REQUIREMENTS 15. Upon startup of this point, 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 16. A source initial compliance test shall be conducted on emissions point 012 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 Formaldehyde AIRS ID: 123/0184/012 Page 7 of 18 • Kerr-McGee/Anadarko k trot, m ►. erati A olor Sep.' ment of Public Health and Environment Permit No. 10WE1050 . Air Pollution Control Division Issuance 1 Periodic Testing Requirements 17. This engine is subject to the periodic testing requirements of 40 C.F.R Part 63, Subpart ZZZZ. 18. This 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. ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A or B. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine or turbine, the appropriate APEN filing fee and a cover letter explaining that the permittee is exercising an alternative-operating scenario and is installing a permanent replacement engine or turbine. 20. This source is subject to the provisions of Regulation Number 3, Part C, Operating Permits (Title V of the 1990 Federal Clean Air Act Amendments). The provisions of this construction permit must be incorporated into the operating permit. The application for the modification to the Operating Permit is due within one year of commencement of operation of the equipment or modification covered by this permit. 21. Prevention of Significant Deterioration (PSD) requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable PSD threshold will require a full PSD review of the source as though construction had AIRS ID: 123/0184/012 Page 8 of 18 Kerr-McGee/Anadarko m ' r. .ratit olor ep ment of Public Health and Environment Permit No. 10WE1050 Air Pollution Control Division Issuance 1 not yet commenced on the source. The source shall not exceed the PSD threshold until a PSD permit is granted. (Regulation No. 3 Part D, VI.B.4) 22. Non-attainment New Source Review requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable NSR threshold will require a full NSR review of the source as though construction had not yet commenced on the source. The source shall not exceed the NSR threshold until a NSR permit is granted. (Regulation No. 3 Part D, V.A.7) GENERAL TERMS AND CONDITIONS: 23. 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. 24. 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. 25. 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. 26. 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. 27. 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 86 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. 28. 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 AIRS ID: 123/0184/012 Page 9 of 18 • Kerr-McGee/Anadarko t trop:-m . .ratit , olor .. •ep., rent of Public Health and Environment Permit No. 10WE1050 Y Air Pollution Control Division Issuance 1 Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 29. 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: Jacob Sebesta Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued as part of a synthetic minor modification project for NANSR. AIRS ID: 123/0184/012 Page 10 of 18 Kerr-McGee/Anadarko ' trol=•' m .'` .rati A olor p ment of Public Health and Environment Permit No. 10WE1050 Air Pollution Control Division Issuance 1 Notes to Permit Holder: 1) 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. 2) 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/requlations/airregs/100102aacccommonprovisionsreq.pdf. 3) 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 (Ib/yr) Formaldehyde 5000 A 9134 Yes 2192 Acetaldehyde 75070 A 903 Yes 903 Acrolein 107028 A 555 Yes 555 012 Methanol 67561 C 270 No 270 n-Hexane 110543 C 120 No 120 Benzene 71432 A 48 No 48 Toluene 108883 C 44 No 44 4) The emission levels contained in this permit are based on the following emission factors: Emission Factors - Emission Factors— Uncontrolled Controlled CAS Pollutant lb/MMBtu g/bhp-hr Ib/MMBtu g/bhp-hr NOx 0.2276 0.7000 0.2276 0.7000 CO 0.8128 2.5000 0.0813 0.2500 VOC • 0.2931 0.9015 0.1905 0.5860 5000 Formaldehyde 0.0845 0.2600 0.0203 0.0624 75070 Acetaldehyde 0.0084 0.0257 0.0084 0.0257 107028 Acrolein 0.0051 0.0158 0.0051 0.0158 67561 Methanol ' 0.0025 0.0077 0.0025 0.0077 110543 n-Hexane 0.0011 0.0034 0.0011 0.0034 71432 Benzene 0.0004 0.0014 0.0004 0.0014 108883 Toluene 0.0004 0.0013 0.0004 0.0013 Emission factors are based on a Brake-Specific Fuel Consumption Factor of 6781 Btu/hp-hr, a site-rated horsepower value of 1775, and a fuel heat value of 905 Btu/scf. AIRS ID: 123/0184/012 Page 11 of 18 • Kerr-McGee/Anadarko olor ep ment of Public Health and Environment Permit No. 10WE1050 • �` Air Pollution Control Division Issuance 1 Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer Data No control. CO Manufacturer Data Eng. Judgement VOC Manufacturer Data Eng. Judgement 5000 Formaldehyde Manufacturer Data Eng. Judgement 75070 Acetaldehyde AP-42; Table 3.2-2 (7/2000); No Control Natural Gas 107028 Acrolein AP-42; Table 3.2-2 (7/2000); No Control Natural Gas 67561 Methanol AP-42; Table 3.2-2 (7/2000); No Control Natural Gas 110543 n-Hexane AP-42; Table 3.2-2 (7/2000); No Control Natural Gas 71432 Benzene AP-42; Table 3.2-2 (7/2000); No Control Natural Gas 108883 Toluene AP-42; Table 3.2-2 (7/2000); No Control Natural Gas Note: The uncontrolled VOC emission factor was calculated by adding the non-methane, non- ethane hydrocarbon (NMNEHC) and formaldehyde emission factors provided by the manufacturer and the acetaldehyde and acrolein emission factors from AP-42. This calculation was necessary because the manufacturer's NMNEHC factor did not include emissions of aldehyde compounds. 5) In accordance with C.R.S. 25-7-114.1, the Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years. The five-year term for this APEN expires on July 11, 2016. A revised APEN shall be submitted no later than 30 days before the five-year term expires. 6) This 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 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Major Source of NOR, VOC, CO and HAP PSD Synthetic Minor Source of CO NANSR Major Source of NOx and VOC MACT ZZZZ Major Source Requirements: Applicable Area Source Requirements: Not Applicable 8) 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: 123/0184/012 Page 12 of 18 • Kerr-McGee/Anadarko trolz,m 51_•.ratiY olor p ment of Public Health and Environment _ Permit No. 10WE1050 Air Pollution Control Division Issuance 1 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 PA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN —Subpart XXXXXX 9) 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: 123/0184/O12 Page 13 of 18 • Kerr-McGee/Anadarko trot=,.m :-•rati , olor ep ment of Public Health and Environment Permit No. 10WE1050 • Air Pollution Control Division • Issuance 1 ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES October 1, 2011 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 permittee 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 permittee 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 permittee 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 permittee 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: 123/0184/012 Page 14 of 18 Kerr-McGee/Anadarko • troll =m .r i•rati olor .• ■ep ment of Public Health and Environment Permit No. 10WE1050 . Air Pollution Control Division Issuance 1 2.1.2 The permittee may permanently replace the existing compressor engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. The AOS cannot be used for the permanent replacement of an entire engine at any source that is currently a major stationary source for purposes of Prevention of Significant Deterioration or Non- Attainment Area New Source Review ("PSD/NANSR") unless the existing engine has emission limits that are below the significance levels in Reg 3, Part D, II.A.42. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the permittee 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 permittee shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. Nothing in this AOS shall preclude the Division from taking an action, based on any permanent engine replacement(s), for circumvention of any state or federal PSD/NANSR requirement. Additionally, in the event that any permanent engine replacement(s) constitute(s) a circumvention of applicable PSD/NANSR requirements, nothing in this AOS shall excuse the permittee from complying with PSD/NANSR and applicable permitting requirements. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The permittee 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 permittee shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. AIRS ID: 123/0184/012 Page 15 of 18 Kerr-McGee/Anadarko n'e • m •r't'•ratiay olor ep ment of Public Health and Environment Permit No. 10WE1050 Air Pollution Control Division Issuance 1 All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer). Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year(whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year(8760), whichever applies. For comparison with a short-term limit that is either input based (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 naturalgas 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). AIRS ID: 123/0184/012 Page 16 of 18 Kerr-McGee/Anadarko alirn . l.ratiA olor p ment of Public Health and Environment Permit No. 10WE1050 Air Pollution Control Division Issuance 1 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. 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 AIRS ID: 123/0184/012 Page 17 of 18 Kerr-McGee/Anadarko ` trol:., m 'I •rati A olor • Pep: ment of Public Health and Environment Permit No. 10WE1050 . Air Pollution Control Division Issuance 1 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, § 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 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: 123/0184/012 Page 18 of 18 STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT Ooi AIR POLLUTION CONTROL DIVISION .; TELEPHONE: (303) 692-3150 `.,eve. ' CONSTRUCTION PERMIT PERMIT NO: 11WE1961 WE1 961 Issuance 1 DATE ISSUED: ISSUED TO: Kerr-McGee Gathering, LLC THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural gas compression facility, known as the Frederick Compressor Station, located in 3988 Weld County Rd. 19, Frederick in Weld County, Colorado, THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Description Equipment ID Point One (1) Caterpillar, Model G3606LE, Serial Number To Be Determined, natural gas-fired, turbo-charged, 4SLB EU-46 013 reciprocating internal combustion engine, site rated at 1775 horsepower at 1000 RPM. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control. This emission unit is used for natural gas compression. This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Caterpillar G3606LE engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the APCD no later than fifteen days after commencement of the permitted operation or activity by submitting a Notice of Startup (NOS) form to the APCD. The Notice of Startup (NOS) form may be downloaded online at www.cdphe.state.co.us/ap/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: 123/0184/013 Page 1 of 18 NGEngine Version 2009-1 Kerr-McGee/Anadarko • m .rs•ratiY olor ep ment of Public Health and Environment Permit No. 11WE1961 Air Pollution Control Division Issuance 1 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 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 Equipment ID Point NO, VOC CO Emission Type EU-46 013 2089 1748 746 Point Monthly limits are based on a 31-day month. Annual Limits: Facility AIRS Tons per Year Emission Type VOC CO Equipment ID Point NO, EU-46 013 12.3 10.3 4.4 Point See "Notes to Permit Holder #4 for information on emission factors and methods used to calculate limits. AIRS ID: 123/0184/013 Page 2 of 18 Kerr-McGee/Anadarko trot= •m o :'.rati olor p ment of Public Health and Environment Permit No. 11WE1961 Air Pollution Control Division • Issuance 1 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, 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. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control that reduces uncontrolled emissions of CO and VOC from the 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.) 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 EU-46 013 Consumption of natural gas as a fuel 119.42 10.14 MMscf/yr MMscf/month 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.) AIRS ID: 123/0184/013 Page 3 of 18 Kerr-McGee/Anadarko ` itrol==m ` o ? •ratiY, olor ep,?i ment of Public Health and Environment Permit No. 11WE1961 Air Pollution Control Division Issuance 1 12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 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.2. For lean burn reciprocating internal combustion engines, an oxidation catalyst shall be required. 14. This source is subject to the requirements of: • Regulation No. 8, Part E , Subpart III.FFFF: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (RICE) of 40 C.F.R. Part 63, Subpart ZZZZ, and • Regulation No. 8, Part E, Subpart I.A, National Emission Standards for Hazardous Air Pollutants for Source Categories: General Provisions, 40 CFR Part 63 including, but not limited to, the following: • Emission and Operating Limitations o 63.6600(b) - If you own or operate a new or reconstructed 4SLB stationary RICE with a site rating of more than 500 brake HP located at major source of HAP emissions you must comply with the following emission limitations (Table 2a, Subpart ZZZZ to Part 63): • reduce CO emissions by 93 percent or more; or • limit concentration of formaldehyde in the stationary RICE exhaust to 14 ppmvd or less at 15 percent O2. o 63.6600(b) - If you own or operate a new or reconstructed 4SLB stationary RICE with a site rating of more than 500 brake HP located at major source of HAP emissions you must comply with the following operating limitations (Table 2b, Subpart ZZZZ to Part 63): • maintain your catalyst so that the pressure drop across the catalyst does not change by more than 2 inches of water at 100 percent load plus or minus 10 percent from the pressure drop across the catalyst that was measured during the initial performance test; and • maintain the temperature of your stationary RICE exhaust so that the catalyst inlet temperature is greater than or equal to 450 °F and less than or equal to 1350 °F. • General Compliance Requirements o §63.6605(a) - You must be in compliance with the emission limitations and operating limitations in this subpart that apply to you at all times, except during periods of startup, shutdown, and malfunction. o §63.6605(b) - If you must comply with emission limitations and operating limitations, you must operate and maintain your stationary RICE, including air pollution control and monitoring equipment, in a manner consistent with good air pollution control practices for minimizing emissions at all times, including during startup, shutdown, and malfunction. AIRS ID: 123/0184/013 Page 4 of 18 Kerr-McGee/Anadarko ` • - m ri •rati, olor ep ment of Public Health and Environment Permit No. 11WE1961 �'; Air Pollution Control Division Issuance 1 • Testing and Initial Compliance Requirements o §63.6610(a) - You must conduct the initial performance test or other initial compliance demonstrations in Table 4 to Subpart ZZZZ of Part 63 that apply to you within 180 days after the compliance date that is specified for your stationary RICE in §63.6595 and according to the provisions in §63.7(a)(2). o §63.6615 - If you must comply with the emission limitations and operating limitations, you must conduct subsequent performance tests semiannually (as per Table 3 of Subpart ZZZZ to Part 63). After you have demonstrated compliance for two consecutive tests, you may reduce the frequency of subsequent performance tests to annually. If the results of any subsequent annual performance test indicate the stationary RICE is not in compliance with the CO or formaldehyde emission limitation, or you deviate from any of your operating limitations, you must resume semiannual performance tests. o §63.6625(a) - If you elect to install a GEMS as specified in Table 5 of this subpart, you must install, operate, and maintain a GEMS to monitor CO and either oxygen or CO2 at both the inlet and the outlet of the control device according to the requirements in paragraphs 63.6625(a)(1) through 63.6625(4) of Subpart ZZZZ to Part 63. o §63.6625(b) - If you are required to install a continuous parameter monitoring system (CPMS) as specified in Table 5 of this subpart, you must install, operate, and maintain each CPMS according to the requirements in §63.8. o §63.6630(a) - You must demonstrate initial compliance with each emission and operating limitation that applies to you according to Table 5 of Subpart ZZZZ to Part 63. o §63.6630(b) - During the initial performance test, you must establish each operating limitation in Tables lb and 2b of Subpart ZZZZ to Part 63 that applies to you. o §63.6630(c) - You must submit the Notification of Compliance Status containing the results of the initial compliance demonstration according to the requirements in §63.6645. • Continuous Compliance Requirements o §63.6635(b) - Except for monitor malfunctions, associated repairs, and required quality assurance or control activities (including, as applicable, calibration checks and required zero and span adjustments), you must monitor continuously at all times that the stationary RICE is operating. o §63.6635(c) - You may not use data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities in data averages and calculations used to report emission or operating levels. You must, however, use all the valid data collected during all other periods. o §63.6640(a) - You must demonstrate continuous compliance with each emission limitation and operating limitation in Tables la and 1b and Tables 2a and 2b of subpart ZZZZ of Part 63 that apply to you according to methods specified in Table 6 of Subpart ZZZZ of Part 63. AIRS ID: 123/0184/013 Page 5 of 18 Kerr-McGee/Anadarko trolssm . `'•rati olor ep ment of Public Health and Environment Permit No. 11 WE1961 `' Air Pollution Control Division Issuance 1 o §63.6640(b) - You must report each instance in which you did not meet each emission limitation or operating limitation in Tables la and 1b and Tables 2a and 2b of Subpart ZZZZ of Part 63 that apply to you. These instances are deviations from the emission and operating limitations in this subpart. These deviations must be reported according to the requirements in §63.6650. If you change your catalyst, you must reestablish the values of the operating parameters measured during the initial performance test. When you reestablish the values of your operating parameters, you must also conduct a performance test to demonstrate that you are meeting the required emission limitation applicable to your stationary RICE. o §63.6640(d) - Consistent with §§63.6(e) and 63.7(e)(1), deviations from the emission or operating limitations that occur during a period of startup, shutdown, or malfunction are not violations if you demonstrate to the Administrator's satisfaction that you were operating in accordance with §63.6(e)(1). For new, reconstructed, and rebuilt stationary RICE, deviations from the emission or operating limitations that occur during the first 200 hours of operation from engine startup (engine burn-in period) are not violations. o §63.6640(e) - You must also report each instance in which you did not meet the requirements in Table 8 of Subpart ZZZZ to Part 63 that apply to you. • Notifications, Reports and Records o §63.6645(a) - If you own or operate a stationary RICE with a site rating of more than 500 brake HP located at a major source of HAP emissions you must submit all of the notifications in §§63.7(b) and (c), 63.8(e), (f)(4) and (f)(6), 63.9(b) through (e), and (g) and (h) that apply to you by the dates specified. o §63.6645(g) - If you are required to conduct a performance test, you must submit a Notification of Intent to conduct a performance test at least 60 days before the performance test is scheduled to begin as required in §63.7(b)(1). o §63.6645(h) - If you are required to conduct a performance test or other initial compliance demonstration as specified in Tables 4 and 5 of Subpart ZZZZ to Part 63, you must submit a Notification of Compliance Status according to §63.9(h)(2)(ii). • §63.6645(h)(1) - For each initial compliance demonstration required in Table 5 of Subpart ZZZZ to Part 63 that does not include a performance test, you must submit the Notification of Compliance Status before the close of business on the 30th day following the completion of the initial compliance demonstration. • §63.6645(h)(2) - For each initial compliance demonstration required in Table 5 of Subpart ZZZZ to Part 63 that includes a performance test conducted according to the requirements in Table 3 to this subpart, you must submit the Notification of Compliance Status, including the performance test results, before the close of business on the 60th day following the completion of the performance test according to §63.10(d)(2). AIRS ID: 123/0184/013 Page 6 of 18 Kerr-McGee/Anadarko • m o •rati< olor ep ment of Public Health and Environment Permit No. 11WE1961 • Air Pollution Control Division Issuance 1 o §63.6650(a) - You must submit each report in Table 7 of Subpart Z777 to Part 63 that applies to you. o §63.6655(a) - If you must comply with the emission and operating limitations, you must keep the records described in §63.6655(a)(1) through (a)(3), §63.6655 (b)(1) through (b)(3) and §63.6655 (c). o §63.6655(d) - You must keep the records required in Table 6 of Subpart ZZZZ of Part 63 to show continuous compliance with each emission or operating limitation that applies to you. o §63.6660(a) - Your records must be in a form suitable and readily available for expeditious review according to §63.10(b)(1). o §63.6660(b) - As specified in §63.10(b)(1), you must keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. o §63.6660(c) - You must keep each record readily accessible in hard copy or electronic form on-site for at least 2 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record, according to §63.10(b)(1). You can keep the records off-site for the remaining 3 years. • Other Requirements and Information o §63.6665 - Table 8 to this subpart shows which parts of the General Provisions in §§63.1 through 63.15 apply to you. OPERATING & MAINTENANCE REQUIREMENTS 15. Upon startup of this point, 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 16. A source initial compliance test shall be conducted on emissions point 013 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 Formaldehyde AIRS ID: 123/0184/013 Page 7 of 18 Kerr-McGee/Anadarko trot- m d •r •rata „ olor •• Pep; ment of Public Health and Environment Permit No. 11WE1961 Air Pollution Control Division Issuance 1 Periodic Testing Requirements 17. This engine is subject to the periodic testing requirements of 40 C.F.R Part 63, Subpart ZZZZ. 18. This 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. ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A or B. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine or turbine, the appropriate APEN filing fee and a cover letter explaining that the permittee is exercising an alternative-operating scenario and is installing a permanent replacement engine or turbine. 20. This source is subject to the provisions of Regulation Number 3, Part C, Operating Permits (Title V of the 1990 Federal Clean Air Act Amendments). The provisions of this construction permit must be incorporated into the operating permit. The application for the modification to the Operating Permit is due within one year of commencement of operation of the equipment or modification covered by this permit. 21. Prevention of Significant Deterioration (PSD) requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable PSD threshold will require a full PSD review of the source as though construction had AIRS ID: 123/0184/013 Page 8 of 18 • Kerr-McGee/Anadarko ' • >+ m ►�. <%•rat A, olor •,. to-p ment of Public Health and Environment Permit No. 11WE1961 Air Pollution Control Division Issuance 1 not yet commenced on the source. The source shall not exceed the PSD threshold until a PSD permit is granted. (Regulation No. 3 Part D, VI.B.4) 22. Non-attainment New Source Review requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable NSR threshold will require a full NSR review of the source as though construction had not yet commenced on the source. The source shall not exceed the NSR threshold until a NSR permit is granted. (Regulation No. 3 Part D, V.A.7) GENERAL TERMS AND CONDITIONS: 23. 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. 24. 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. 25. 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. 26. 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. 27. 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. 28. 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 AIRS ID: 123/0184/013 Page 9 of 18 Kerr-McGee/Anadarko trot= m o ".ratiY olor ep ment of Public Health and Environment Permit No. 11WE1961 Air Pollution Control Division Issuance 1 Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 29. 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: Jacob Sebesta Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued as part of a synthetic minor modification project for NANSR. AIRS ID: 123/0184/013 Page 10 of 18 Kerr-McGee/Anadarko . - tm '.ratio . olor ep ment of Public Health and Environment Permit No. 11WE1961 ` Air Pollution Control Division • Issuance 1 Notes to Permit Holder: 1) 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. 2) 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/requlations/airreqs/100102agcccommonprovisionsreq.pdf. 3) 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 (Ib/yr) Formaldehyde 5000 A 9135 Yes 2193 Acetaldehyde 75070 A 903 Yes 903 Acrolein 107028 A 555 Yes 555 013 Methanol 67561 C 270 No 270 n-Hexane 110543 C 120 No 120 Benzene 71432 A 48 No 48 Toluene 108883 C 44 No 44 4) The emission levels contained in this permit are based on the following emission factors: Emission Factors - Emission Factors— Uncontrolled Controlled CAS Pollutant Ib/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr NOx 0.2276 0.7000 0.2276 0.7000 CO 0.8128 2.5000 0.0813 0.2500 VOC 0.2931 0.9015 0.1905 0.5860 5000 Formaldehyde 0.0845 0.2600 0.0203 0.0624 75070 Acetaldehyde 0.0084 0.0257 0.0084 0.0257 107028 Acrolein 0.0051 0.0158 0.0051 0.0158 67561 Methanol 0.0025 0.0077 0.0025 0.0077 110543 n-Hexane 0.0011 0.0034 0.0011 0.0034 71432 Benzene 0.0004 0.0014 0.0004 0.0014 108883 Toluene 0.0004 0.0013 0.0004 0.0013 Emission factors are based on a Brake-Specific Fuel Consumption Factor of 6781 Btu/hp-hr, a site-rated horsepower value of 1775, and a fuel heat value of 905 Btu/scf. AIRS ID: 123/0184/013 Page 11 of 18 Kerr-McGee/Anadarko trolsmaY'.rati . olor gi7ep ment of Public Health and Environment Permit No. 11WE1961 , "i Air Pollution Control Division Issuance 1 Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer Data No control. CO Manufacturer Data Eng. Judgement VOC Manufacturer Data Eng. Judgement 5000 Formaldehyde Manufacturer Data Eng. Judgement 75070 Acetaldehyde AP-42; Table 3.2-2 (7/2000); No Control Natural Gas 107028 Acrolein AP-42; Table 3.2-2 (7/2000); No Control Natural Gas 67561 Methanol AP-42; Table 3.2-2 (7/2000); No Control Natural Gas 110543 n-Hexane AP-42; Table 3.2-2 (7/2000); No Control Natural Gas 71432 Benzene AP-42; Table 3.2-2 (7/2000); No Control Natural Gas 108883 Toluene AP-42; Table 3.2-2 (7/2000); No Control Natural Gas Note: The uncontrolled VOC emission factor was calculated by adding the non-methane, non- ethane hydrocarbon (NMNEHC) and formaldehyde emission factors provided by the manufacturer and the acetaldehyde and acrolein emission factors from AP-42. This calculation was necessary because the manufacturer's NMNEHC factor did not include emissions of aldehyde compounds. 5) In accordance with C.R.S. 25-7-114.1, the Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years. The five-year term for this APEN expires on July 11, 2016. A revised APEN shall be submitted no later than 30 days before the five-year term expires. 6) This 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/fr181a08.pdf 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Major Source of NOx, VOC, CO and HAP PSD Synthetic Minor Source of CO NANSR Major Source of NOx and VOC MACT ZZZZ Major Source Requirements: Applicable Area Source Requirements: Not Applicable 8) 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: 123/0184/013 Page 12 of 18 Kerr-McGee/Anadarko -trot: m " . .ratiA. olor ep ment of Public Health and Environment Permit No. 11WE1961 Air Pollution Control Division Issuance 1 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 SubpartA—SubpartZ MACT 63.600-63.1199 Subpart AA— Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ —Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN — Subpart XXXXXX 9) 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: 123/0184/013 Page 13 of 18 Kerr-McGee/Anadarko • trol=. m .r`•ratiA olor ep ment of Public Health and Environment Permit No. 11WE1961 Air Pollution Control Division Issuance 1 • ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES October 1, 2011 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 permittee 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 permittee 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 permittee 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 permittee 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: 123/0184/013 Page 14 of 18 Kerr-McGee/Anadarko trot , m o •.rati, olor ep ment of Public Health and Environment Permit No. 11WE1961 •: " Air Pollution Control Division Issuance 1 • 2.1.2 The permittee may permanently replace the existing compressor engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. The AOS cannot be used for the permanent replacement of an entire engine at any source that is currently a major stationary source for purposes of Prevention of Significant Deterioration or Non- Attainment Area New Source Review ("PSD/NANSR") unless the existing engine has emission limits that are below the significance levels in Reg 3, Part D, II.A.42. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the permittee 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 permittee shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. Nothing in this AOS shall preclude the Division from taking an action, based on any permanent engine replacement(s), for circumvention of any state or federal PSD/NANSR requirement. Additionally, in the event that any permanent engine replacement(s) constitute(s) a circumvention of applicable PSD/NANSR requirements, nothing in this AOS shall excuse the permittee from complying with PSD/NANSR and applicable permitting requirements. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The permittee 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 permittee shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. AIRS ID: 123/0184/013 Page 15 of 18 • Kerr-McGee/Anadarko ` trol-,-m o ?•rati olor p ment of Public Health and Environment Permit No. 11WE1961 Air Pollution Control Division Issuance 1 All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer). Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year(whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever applies. For comparison with a short-term limit that is either input based (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 naturalgas 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). AIRS ID: 123/0184/013 Page 16 of 18 • Kerr-McGee/Anadarko . - •m ►. .ratiY olor p ment of Public Health and Environment Permit No. 11WE1961 Air Pollution Control Division • Issuance 1 • 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. 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 AIRS ID: 123/0184/013 Page 17 of 18 Kerr-McGee/Anadarko ` . . sm o `.rati+ r . olor ep ment of Public Health and Environment Permit No. 11WE1961 Air Pollution Control Division Issuance 1 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, § 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 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: 123/0184/013 Page 18 of 18 A . STATE OF COLORADO ��p4 CO�O4, Ts COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION *O* TELEPHONE: (303) 692-3150 }•Ian* CONSTRUCTION PERMIT PERMIT NO: 11WE1962 962 Issuance 1 DATE ISSUED: ISSUED TO: Kerr-McGee Gathering, LLC THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural gas compression facility, known as the Frederick Compressor Station, located in 3988 Weld County Rd. 19, Frederick in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Description Equipment ID Point One (1) Caterpillar, Model G3606LE, Serial Number To Be Determined, natural gas-fired, turbo-charged, 4SLB reciprocating internal combustion engine, site rated at 1775 EU-47 014 horsepower at 1000 RPM. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control. This emission unit is used for natural gas compression. This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Caterpillar G3606LE engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the APCD no later than fifteen days after commencement of the permitted operation or activity by submitting a Notice of Startup (NOS) form to the APCD. The Notice of Startup (NOS) form may be downloaded online at vww.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: 123/0184/014 Page 1 of 18 NGEngine Version 2009-1 Kerr-McGee/Anadarko m •1 r=•ratiE" olor •• eep::Invent of Public Health and Environment Permit No. 11WE1962 � ' Y: Air Pollution Control Division Issuance 1 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 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 EU-47 014 2089 1748 746 Point Monthly limits are based on a 31-day month. Annual Limits: Facility AIRS Tons per Year Emission Type VOC CO Equipment ID Point NO, EU-47 014 12.3 10.3 4.4 Point See "Notes to Permit Holder #4 for information on emission factors and methods used to calculate limits. AIRS ID: 123/0184/014 Page 2 of 18 Kerr-McGee/Anadarko " trol s, � m-. .'°'•rata olor • •ep., ment of Public Health and Environment Permit No. 11WE1962 Air Pollution Control Division Issuance 1 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, 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. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control that reduces uncontrolled emissions of CO and VOC from the 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.) 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 119.42 10.14 EU-47 014 Consumption of natural gas as a fuel MMscf/yr MMscf/month 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.) AIRS ID: 123/0184/014 Page 3 of 18 Kerr-McGee/Anadarko ` \trol::m , .fr.orati olor '•• rep ment of Public Health and Environment Permit No. 11WE1962 Air Pollution Control Division Issuance 1 12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 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.2. For lean burn reciprocating internal combustion engines, an oxidation catalyst shall be required. 14. This source is subject to the requirements of: • Regulation No. 8, Part E , Subpart III.FFFF: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (RICE) of 40 C.F.R. Part 63, Subpart ZZZZ, and • Regulation No. 8, Part E, Subpart I.A, National Emission Standards for Hazardous Air Pollutants for Source Categories: General Provisions, 40 CFR Part 63 including, but not limited to, the following: • Emission and Operating Limitations o 63.6600(b) - If you own or operate a new or reconstructed 4SLB stationary RICE with a site rating of more than 500 brake HP located at major source of HAP emissions you must comply with the following emission limitations (Table 2a, Subpart ZZZZ to Part 63): • reduce CO emissions by 93 percent or more; or • limit concentration of formaldehyde in the stationary RICE exhaust to 14 ppmvd or less at 15 percent O2. o 63.6600(b) - If you own or operate a new or reconstructed 4SLB stationary RICE with a site rating of more than 500 brake HP located at major source of HAP emissions you must comply with the following operating limitations (Table 2b, Subpart ZZZZ to Part 63): • maintain your catalyst so that the pressure drop across the catalyst does not change by more than 2 inches of water at 100 percent load plus or minus 10 percent from the pressure drop across the catalyst that was measured during the initial performance test; and • maintain the temperature of your stationary RICE exhaust so that the catalyst inlet temperature is greater than or equal to 450 °F and less than or equal to 1350 °F. • General Compliance Requirements o §63.6605(a) - You must be in compliance with the emission limitations and operating limitations in this subpart that apply to you at all times, except during periods of startup, shutdown, and malfunction. o §63.6605(b) - If you must comply with emission limitations and operating limitations, you must operate and maintain your stationary RICE, including air pollution control and monitoring equipment, in a manner consistent with good air pollution control practices for minimizing emissions at all times, including during startup, shutdown, and malfunction. AIRS ID: 123/0184/014 Page 4 of 18 Kerr-McGee/Anadarko trot )m .rati olor p ment of Public Health and Environment Permit No. 11WE1962 a.. Air Pollution Control Division Issuance 1 • Testing and Initial Compliance Requirements o §63.6610(a) - You must conduct the initial performance test or other initial compliance demonstrations in Table 4 to Subpart ZZZZ of Part 63 that apply to you within 180 days after the compliance date that is specified for your stationary RICE in §63.6595 and according to the provisions in §63.7(a)(2). o §63.6615 - If you must comply with the emission limitations and operating limitations, you must conduct subsequent performance tests semiannually (as per Table 3 of Subpart ZZZZ to Part 63). After you have demonstrated compliance for two consecutive tests, you may reduce the frequency of subsequent performance tests to annually. If the results of any subsequent annual performance test indicate the stationary RICE is not in compliance with the CO or formaldehyde emission limitation, or you deviate from any of your operating limitations, you must resume semiannual performance tests. o §63.6625(a) - If you elect to install a GEMS as specified in Table 5 of this subpart, you must install, operate, and maintain a GEMS to monitor CO and either oxygen or CO2 at both the inlet and the outlet of the control device according to the requirements in paragraphs 63.6625(a)(1) through 63.6625(4) of Subpart ZZZZ to Part 63. o §63.6625(b) - If you are required to install a continuous parameter monitoring system (CPMS) as specified in Table 5 of this subpart, you must install, operate, and maintain each CPMS according to the requirements in §63.8. o §63.6630(a) - You must demonstrate initial compliance with each emission and operating limitation that applies to you according to Table 5 of Subpart ZZZZ to Part 63. o §63.6630(b) - During the initial performance test, you must establish each operating limitation in Tables lb and 2b of Subpart ZZZZ to Part 63 that applies to you. o §63.6630(c) - You must submit the Notification of Compliance Status containing the results of the initial compliance demonstration according to the requirements in §63.6645. • Continuous Compliance Requirements o §63.6635(b) - Except for monitor malfunctions, associated repairs, and required quality assurance or control activities (including, as applicable, calibration checks and required zero and span adjustments), you must monitor continuously at all times that the stationary RICE is operating. o §63.6635(c) - You may not use data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities in data averages and calculations used to report emission or operating levels. You must, however, use all the valid data collected during all other periods. o §63.6640(a) - You must demonstrate continuous compliance with each emission limitation and operating limitation in Tables 1a and 1b and Tables 2a and 2b of subpart ZZZZ of Part 63 that apply to you according to methods specified in Table 6 of Subpart ZZZZ of Part 63. AIRS ID: 123/0184/014 Page 5 of 18 • Kerr-McGee/Anadarko 4 trolx m r�. •ratio olor ,., "repf.moment of Public Health and Environment Permit No. 11WE1962 ? Air Pollution Control Division Issuance 1 o §63.6640(b) - You must report each instance in which you did not meet each emission limitation or operating limitation in Tables la and lb and Tables 2a and 2b of Subpart ZZZZ of Part 63 that apply to you. These instances are deviations from the emission and operating limitations in this subpart. These deviations must be reported according to the requirements in §63.6650. If you change your catalyst, you must reestablish the values of the operating parameters measured during the initial performance test. When you reestablish the values of your operating parameters, you must also conduct a performance test to demonstrate that you are meeting the required emission limitation applicable to your stationary RICE. o §63.6640(d) - Consistent with §§63.6(e) and 63.7(e)(1), deviations from the emission or operating limitations that occur during a period of startup, shutdown, or malfunction are not violations if you demonstrate to the Administrator's satisfaction that you were operating in accordance with §63.6(e)(1). For new, reconstructed, and rebuilt stationary RICE, deviations from the emission or operating limitations that occur during the first 200 hours of operation from engine startup (engine burn-in period) are not violations. o §63.6640(e) - You must also report each instance in which you did not meet the requirements in Table 8 of Subpart ZZZZ to Part 63 that apply to you. • Notifications, Reports and Records o §63.6645(a) - If you own or operate a stationary RICE with a site rating of more than 500 brake HP located at a major source of HAP emissions you must submit all of the notifications in §§63.7(b) and (c), 63.8(e), (f)(4) and (f)(6), 63.9(b) through (e), and (g) and (h) that apply to you by the dates specified. o §63.6645(g) - If you are required to conduct a performance test, you must submit a Notification of Intent to conduct a performance test at least 60 days before the performance test is scheduled to begin as required in §63.7(b)(1). o §63.6645(h) - If you are required to conduct a performance test or other initial compliance demonstration as specified in Tables 4 and 5 of Subpart ZZZZ to Part 63, you must submit a Notification of Compliance Status according to §63.9(h)(2)(ii). • §63.6645(h)(1) - For each initial compliance demonstration required in Table 5 of Subpart ZZZZ to Part 63 that does not include a performance test, you must submit the Notification of Compliance Status before the close of business on the 30th day following the completion of the initial compliance demonstration. • §63.6645(h)(2) - For each initial compliance demonstration required in Table 5 of Subpart ZZZZ to Part 63 that includes a performance test conducted according to the requirements in Table 3 to this subpart, you must submit the Notification of Compliance Status, including the performance test results, before the close of business on the 60th day following the completion of the performance test according to §63.10(d)(2). AIRS ID: 123/0184/014 Page 6 of 18 Kerr-McGee/Anadarko ` • - =m .r '+rater olor • yep ment of Public Health and Environment Permit No. 11WE1962 ' Air Pollution Control Division Issuance 1 o §63.6650(a) - You must submit each report in Table 7 of Subpart ZZZZ to Part 63 that applies to you. o §63.6655(a) - If you must comply with the emission and operating limitations, you must keep the records described in §63.6655(a)(1) through (a)(3), §63.6655 (b)(1) through (b)(3) and §63.6655 (c). o §63.6655(d) - You must keep the records required in Table 6 of Subpart ZZZZ of Part 63 to show continuous compliance with each emission or operating limitation that applies to you. o §63.6660(a) - Your records must be in a form suitable and readily available for expeditious review according to §63.10(b)(1). o §63.6660(b) - As specified in §63.10(b)(1), you must keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. o §63.6660(c) - You must keep each record readily accessible in hard copy or electronic form on-site for at least 2 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record, according to §63.10(b)(1). You can keep the records off-site for the remaining 3 years. • Other Requirements and Information o §63.6665 - Table 8 to this subpart shows which parts of the General Provisions in §§63.1 through 63.15 apply to you. OPERATING & MAINTENANCE REQUIREMENTS 15. Upon startup of this point, 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 16. A source initial compliance test shall be conducted on emissions point 014 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 Formaldehyde AIRS ID: 123/0184/014 Page 7 of 18 Kerr-McGee/Anadarko • trol tem . :'.rate olor .. rep ' ment of Public Health and Environment Permit No. 11WE1962 Air Pollution Control Division Issuance 1 • Periodic Testing Requirements 17. This engine is subject to the periodic testing requirements of 40 C.F.R Part 63, Subpart ZZZZ. 18. This 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. ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A or B. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine or turbine, the appropriate APEN filing fee and a cover letter explaining that the permittee is exercising an alternative-operating scenario and is installing a permanent replacement engine or turbine. 20. This source is subject to the provisions of Regulation Number 3, Part C, Operating Permits (Title V of the 1990 Federal Clean Air Act Amendments). The provisions of this construction permit must be incorporated into the operating permit. The application for the modification to the Operating Permit is due within one year of commencement of operation of the equipment or modification covered by this permit. 21. Prevention of Significant Deterioration (PSD) requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable PSD threshold will require a full PSD review of the source as though construction had AIRS ID: 123/0184/014 Page 8 of 18 Kerr-McGee/Anadarko : trop;mF . `orati]� olor iep ment of Public Health and Environment Permit No. 11WE1962 • "`° Air Pollution Control Division Issuance 1 not yet commenced on the source. The source shall not exceed the PSD threshold until a PSD permit is granted. (Regulation No. 3 Part D, VI.B.4) 22. Non-attainment New Source Review requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable NSR threshold will require a full NSR review of the source as though construction had not yet commenced on the source. The source shall not exceed the NSR threshold until a NSR permit is granted. (Regulation No. 3 Part D, V.A.7) GENERAL TERMS AND CONDITIONS: 23. 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. 24. 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. 25. 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. 26. 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. 27. 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. 28. 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 AIRS ID: 123/0184/014 Page 9 of 18 Kerr-McGee/Anadarko a,",trol=l;m i . .rati, olor p ment of Public Health and Environment Permit No. 11WE1962 Air Pollution Control Division Issuance 1 Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 29. 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: Jacob Sebesta Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued as part of a synthetic minor modification project for NANSR. AIRS ID: 123/0184/014 Page 10 of 18 Kerr-McGee/Anadarko '~ • -' m b •ratiA olor ep ment of Public Health and Environment Permit No. 11WE1962 Air Pollution Control Division Issuance 1 Notes to Permit Holder: 1) 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. 2) 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/airregs/100102aacccommonprovisionsreq.pdf. 3) 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 (Ib/yr) Formaldehyde 5000 A 9135 Yes 2193 Acetaldehyde 75070 A 903 Yes 903 Acrolein 107028 A 555 Yes 555 014 Methanol 67561 C 270 No 270 n-Hexane 110543 C 120 No 120 Benzene 71432 A 48 No 48 Toluene 108883 C 44 No 44 4) The emission levels contained in this permit are based on the following emission factors: Emission Factors - Emission Factors— Uncontrolled Controlled CAS Pollutant Ib/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr NOx 0.2276 0.7000 0.2276 0.7000 CO 0.8128 2.5000 0.0813 0.2500 VOC 0.2931 0.9015 0.1905 0.5860 5000 Formaldehyde 0.0845 0.2600 0.0203 0.0624 75070 Acetaldehyde 0.0084 0.0257 0.0084 0.0257 107028 Acrolein 0.0051 0.0158 0.0051 0.0158 67561 Methanol 0.0025 0.0077 0.0025 0.0077 110543 n-Hexane 0.0011 0.0034 0.0011 0.0034 71432 Benzene 0.0004 0.0014 0.0004 0.0014 108883 Toluene 0.0004 0.0013 0.0004 0.0013 Emission factors are based on a Brake-Specific Fuel Consumption Factor of 6781 Btu/hp-hr, a site-rated horsepower value of 1775, and a fuel heat value of 905 Btu/scf. AIRS ID: 123/0184/014 Page 11 of 18 Kerr-McGee/Anadarko trop=.m •rata olor •. Pep ment of Public Health and Environment Permit No. 11WE1962 r ' 1 Air Pollution Control Division Issuance 1 Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer Data No control. CO Manufacturer Data Eng. Judgement VOC Manufacturer Data Eng. Judgement 5000 Formaldehyde Manufacturer Data Eng. Judgement 75070 Acetaldehyde AP-42; Table 3.2-2 (7/2000); No Control Natural Gas 107028 Acrolein AP-42; Table 3.2-2 (7/2000); No Control Natural Gas 67561 Methanol AP-42; Table 3.2-2 (7/2000); No Control Natural Gas 110543 n-Hexane AP-42; Table 3.2-2 (7/2000); No Control Natural Gas 71432 Benzene AP-42; Table 3.2-2 (7/2000); No Control Natural Gas 108883 Toluene AP-42; Table 3.2-2 (7/2000); No Control Natural Gas Note: The uncontrolled VOC emission factor was calculated by adding the non-methane, non- ethane hydrocarbon (NMNEHC) and formaldehyde emission factors provided by the manufacturer and the acetaldehyde and acrolein emission factors from AP-42. This calculation was necessary because the manufacturer's NMNEHC factor did not include emissions of aldehyde compounds. 5) In accordance with C.R.S. 25-7-114.1, the Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years. The five-year term for this APEN expires on July 11, 2016. A revised APEN shall be submitted no later than 30 days before the five-year term expires. 6) This 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 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Major Source of NOR, VOC, CO and HAP PSD Synthetic Minor Source of CO NANSR Major Source of NOx and VOC MACT ZZZZ Major Source Requirements: Applicable Area Source Requirements: Not Applicable 8) 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: 123/0184/014 Page 12 of 18 Kerr-McGee/Anadarko trot =m • `•rati ` . olor •• eep.; ment of Public Health and Environment Permit No. 11WE1962 ` Air Pollution Control Division • Issuance 1 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 M—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN — Subpart XXXXXX 9) 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 cd phe.state.co.us/ap/oilgaspermitting html AIRS ID: 123/0184/014 Page 13 of 18 Kerr-McGee/Anadarko " trol ;,:ma''-•rati olor ep ment of Public Health and Environment Permit No. 11WE1982 `' Air Pollution Control Division Issuance 1 ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES October 1, 2011 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 permittee 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 permittee 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 permittee 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 permittee 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: 123/0184/014 Page 14 of 18 Kerr-McGee/Anadarko , _trol-• m •rati olor ep : ment of Public Health and Environment Permit No. 11WE1962 Air Pollution Control Division Issuance 1 2.1.2 The permittee may permanently replace the existing compressor engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. The AOS cannot be used for the permanent replacement of an entire engine at any source that is currently a major stationary source for purposes of Prevention of Significant Deterioration or Non- Attainment Area New Source Review ("PSD/NANSR") unless the existing engine has emission limits that are below the significance levels in Reg 3, Part D, II.A.42. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the permittee 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 permittee shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. Nothing in this AOS shall preclude the Division from taking an action, based on any permanent engine replacement(s), for circumvention of any state or federal PSD/NANSR requirement. Additionally, in the event that any permanent engine replacement(s) constitute(s) a circumvention of applicable PSD/NANSR requirements, nothing in this AOS shall excuse the permittee from complying with PSD/NANSR and applicable permitting requirements. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The permittee 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 permittee shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. AIRS ID: 123/0184/014 Page 15 of 18 Kerr-McGee/Anadarko trola tm ►. , .ratik olor '.. Pep ment of Public Health and Environment Permit No. 11WE1962 • Air Pollution Control Division Issuance 1 All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer). Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year(whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year(8760), whichever applies. For comparison with a short-term limit that is either input based (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 naturalgas 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). AIRS ID: 123/0184/014 Page 16 of 18 Kerr-McGee/Anadarko m ►.r'•ratik. olor .•s step ment of Public Health and Environment Permit No. 11WE1962 Air Pollution Control Division Issuance 1 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. 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 AIRS ID: 123/0184/014 Page 17 of 18 Kerr-McGee/Anadarko , trol -m -prat olor •., rep ment of Public Health and Environment Permit No. 11WE1962 Air Pollution Control Division Issuance 1 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 8, § 1.8 (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. 2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required 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: 123/0184/014 Page 18 of 18 FTSTATS OF COLORADO.0 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT 'F` col AIR POLLUTION CONTROL DIVISION * * TELEPHONE: (303) 692-3150 *ra,a+i CONSTRUCTION PERMIT PERMIT NO: 11WE1963 Issuance 1 DATE ISSUED: ISSUED TO: Kerr-McGee Gathering, LLC THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural gas compression facility, known as the Frederick Compressor Station, located in 3988 Weld County Rd. 19, Frederick in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Description Equipment ID Point One (1) Caterpillar, Model G3606LE, Serial Number To Be Determined, natural gas-fired, turbo-charged, 4SLB EU-48 015 reciprocating internal combustion engine, site rated at 1775 horsepower at 1000 RPM. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control. This emission unit is used for natural gas compression. This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Caterpillar G3606LE engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the APCD no later than fifteen days after commencement of the permitted operation or activity by submitting a Notice of Startup (NOS) form to the APCD. The Notice of Startup (NOS) form may be downloaded online at www.cdphe.state.co.us/ap/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: 123/0184/015 Page 1 of 18 NGEngine Version 2009-1 Kerr-McGee/Anadarko t trole..m .e'•rate ': olor ■ep ment of Public Health and Environment Permit No. 11WE1963 Air Pollution Control Division Issuance 1 • 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 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, V0C CO EU-48 015 2089 1748 746 Point Monthly limits are based on a 31-day month. Annual Limits: Facility AIRS Tons per Year Emission Type Equipment ID Point NO, V0C CO EU-48 015 12.3 10.3 4.4 Point See "Notes to Permit Holder #4 for information on emission factors and methods used to calculate limits. AIRS ID: 123/0184/015 Page 2 of 18 Kerr-McGee/Anadarko . - m tk•ratiA olor .• rept ' ment of Public Health and Environment Permit No. 11WE1963 Air Pollution Control Division Issuance 1 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, 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. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control that reduces uncontrolled emissions of CO and VOC from the 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.) 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 EU-48 015 Consumption of natural gas as a fuel 119.42 10.14 MMscf/yr MMscf/month 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.) AIRS ID: 123/0184/015 Page 3 of 18 Kerr-McGee/Anadarko • • �.m �. ` .ratio ; olor • •ep: m'ent of Public Health and Environment Permit No. 11WE1963 Air Pollution Control Division Issuance 1 12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 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.2. For lean burn reciprocating internal combustion engines, an oxidation catalyst shall be required. 14. This source is subject to the requirements of: • Regulation No. 8, Part E , Subpart III.FFFF: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (RICE) of 40 C.F.R. Part 63, Subpart ZZZZ, and • Regulation No. 8, Part E, Subpart I.A, National Emission Standards for Hazardous Air Pollutants for Source Categories: General Provisions, 40 CFR Part 63 including, but not limited to, the following: • Emission and Operating Limitations o 63.6600(b) - If you own or operate a new or reconstructed 4SLB stationary RICE with a site rating of more than 500 brake HP located at major source of HAP emissions you must comply with the following emission limitations (Table 2a, Subpart ZZZZ to Part 63): • reduce CO emissions by 93 percent or more; or • limit concentration of formaldehyde in the stationary RICE exhaust to 14 ppmvd or less at 15 percent O2. o 63.6600(b) - If you own or operate a new or reconstructed 4SLB stationary RICE with a site rating of more than 500 brake HP located at major source of HAP emissions you must comply with the following operating limitations (Table 2b, Subpart ZZZZ to Part 63): • maintain your catalyst so that the pressure drop across the catalyst does not change by more than 2 inches of water at 100 percent load plus or minus 10 percent from the pressure drop across the catalyst that was measured during the initial performance test; and • maintain the temperature of your stationary RICE exhaust so that the catalyst inlet temperature is greater than or equal to 450 °F and less than or equal to 1350 °F. • General Compliance Requirements o §63.6605(a) - You must be in compliance with the emission limitations and operating limitations in this subpart that apply to you at all times, except during periods of startup, shutdown, and malfunction. o §63.6605(b) - If you must comply with emission limitations and operating limitations, you must operate and maintain your stationary RICE, including air pollution control and monitoring equipment, in a manner consistent with good air pollution control practices for minimizing emissions at all times, including during startup, shutdown, and malfunction. AIRS ID: 123/0184/015 Page 4 of 18 Kerr-McGee/Anadarko • trol ':ma.r°•rata olor •• ■ept• ent of Public Health and Environment Permit No. 11WE1963 .. • Air Pollution Control Division Issuance 1 • Testing and Initial Compliance Requirements o §63.6610(a) - You must conduct the initial performance test or other initial compliance demonstrations in Table 4 to Subpart ZZZZ of Part 63 that apply to you within 180 days after the compliance date that is specified for your stationary RICE in §63.6595 and according to the provisions in §63.7(a)(2). o §63.6615 - If you must comply with the emission limitations and operating limitations, you must conduct subsequent performance tests semiannually (as per Table 3 of Subpart ZZZZ to Part 63). After you have demonstrated compliance for two consecutive tests, you may reduce the frequency of subsequent performance tests to annually. If the results of any subsequent annual performance test indicate the stationary RICE is not in compliance with the CO or formaldehyde emission limitation, or you deviate from any of your operating limitations, you must resume semiannual performance tests. o §63.6625(a) - If you elect to install a GEMS as specified in Table 5 of this subpart, you must install, operate, and maintain a CEMS to monitor CO and either oxygen or CO2 at both the inlet and the outlet of the control device according to the requirements in paragraphs 63.6625(a)(1) through 63.6625(4) of Subpart ZZZZ to Part 63. o §63.6625(b) - If you are required to install a continuous parameter monitoring system (CPMS) as specified in Table 5 of this subpart, you must install, operate, and maintain each CPMS according to the requirements in §63.8. o §63.6630(a) - You must demonstrate initial compliance with each emission and operating limitation that applies to you according to Table 5 of Subpart ZZZZ to Part 63. o §63.6630(b) - During the initial performance test, you must establish each operating limitation in Tables lb and 2b of Subpart ZZZZ to Part 63 that applies to you. o §63.6630(c) - You must submit the Notification of Compliance Status containing the results of the initial compliance demonstration according to the requirements in §63.6645. • Continuous Compliance Requirements o §63.6635(b) - Except for monitor malfunctions, associated repairs, and required quality assurance or control activities (including, as applicable, calibration checks and required zero and span adjustments), you must monitor continuously at all times that the stationary RICE is operating. o §63.6635(c) - You may not use data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities in data averages and calculations used to report emission or operating levels. You must, however, use all the valid data collected during all other periods. o §63.6640(a) - You must demonstrate continuous compliance with each emission limitation and operating limitation in Tables la and lb and Tables 2a and 2b of subpart ZZZZ of Part 63 that apply to you according to methods specified in Table 6 of Subpart ZZZZ of Part 63. AIRS ID: 123/0184/015 Page 5 of 18 Kerr-McGee/Anadarko ititrol ratii olor ., rep- ment of Public Health and Environment Permit No. 11WE1963 _. Air Pollution Control Division Issuance 1 o §63.6640(b) - You must report each instance in which you did not meet each emission limitation or operating limitation in Tables la and 1b and Tables 2a and 2b of Subpart ZZZZ of Part 63 that apply to you. These instances are deviations from the emission and operating limitations in this subpart. These deviations must be reported according to the requirements in §63.6650. If you change your catalyst, you must reestablish the values of the operating parameters measured during the initial performance test. When you reestablish the values of your operating parameters, you must also conduct a performance test to demonstrate that you are meeting the required emission limitation applicable to your stationary RICE. o §63.6640(d) - Consistent with §§63.6(e) and 63.7(e)(1), deviations from the emission or operating limitations that occur during a period of startup, shutdown, or malfunction are not violations if you demonstrate to the Administrator's satisfaction that you were operating in accordance with §63.6(e)(1). For new, reconstructed, and rebuilt stationary RICE, deviations from the emission or operating limitations that occur during the first 200 hours of operation from engine startup (engine burn-in period) are not violations. o §63.6640(e) - You must also report each instance in which you did not meet the requirements in Table 8 of Subpart ZZZZ to Part 63 that apply to you. • Notifications, Reports and Records o §63.6645(a) - If you own or operate a stationary RICE with a site rating of more than 500 brake HP located at a major source of HAP emissions you must submit all of the notifications in §§63.7(b) and (c), 63.8(e), (f)(4) and (f)(6), 63.9(b) through (e), and (g) and (h) that apply to you by the dates specified. o §63.6645(g) - If you are required to conduct a performance test, you must submit a Notification of Intent to conduct a performance test at least 60 days before the performance test is scheduled to begin as required in §63.7(b)(1). o §63.6645(h) - If you are required to conduct a performance test or other initial compliance demonstration as specified in Tables 4 and 5 of Subpart ZZZZ to Part 63, you must submit a Notification of Compliance Status according to §63.9(h)(2)(ii). • §63.6645(h)(1) - For each initial compliance demonstration required in Table 5 of Subpart ZZZZ to Part 63 that does not include a performance test, you must submit the Notification of Compliance Status before the close of business on the 30th day following the completion of the initial compliance demonstration. • §63.6645(h)(2) - For each initial compliance demonstration required in Table 5 of Subpart ZZZZ to Part 63 that includes a performance test conducted according to the requirements in Table 3 to this subpart, you must submit the Notification of Compliance Status, including the performance test results, before the close of business on the 60th day following the completion of the performance test according to §63.10(d)(2). AIRS ID: 123/0184/015 Page 6 of 18 Kerr-McGee/Anadarko *trolz,.m r• •rate'` olor .. •ep. ment of Public Health and Environment Permit No. 11WE1963 Air Pollution Control Division Issuance 1 o §63.6650(a) - You must submit each report in Table 7 of Subpart ZZZZ to Part 63 that applies to you. o §63.6655(a) - If you must comply with the emission and operating limitations, you must keep the records described in §63.6655(a)(1) through (a)(3), §63.6655 (b)(1) through (b)(3) and §63.6655 (c). o §63.6655(d) - You must keep the records required in Table 6 of Subpart ZZZZ of Part 63 to show continuous compliance with each emission or operating limitation that applies to you. o §63.6660(a) - Your records must be in a form suitable and readily available for expeditious review according to §63.10(b)(1). o §63.6660(b) - As specified in §63.10(b)(1), you must keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. o §63.6660(c) - You must keep each record readily accessible in hard copy or electronic form on-site for at least 2 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record, according to §63.10(b)(1). You can keep the records off-site for the remaining 3 years. • Other Requirements and Information o §63.6665 - Table 8 to this subpart shows which parts of the General Provisions in §§63.1 through 63.15 apply to you. OPERATING & MAINTENANCE REQUIREMENTS 15. Upon startup of this point, 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 16. A source initial compliance test shall be conducted on emissions point 015 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 Formaldehyde AIRS ID: 123/0184/015 Page 7 of 18 Kerr-McGee/Anadarko 7trol-,m .ratio, olor ep ment of Public Health and Environment Permit No. 11WE1963 Air Pollution Control Division Issuance 1 Periodic Testing Requirements 17. This engine is subject to the periodic testing requirements of 40 C.F.R Part 63, Subpart ZZZZ. 18. This 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. ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A or B. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine or turbine, the appropriate APEN filing fee and a cover letter explaining that the permittee is exercising an alternative-operating scenario and is installing a permanent replacement engine or turbine. 20. This source is subject to the provisions of Regulation Number 3, Part C, Operating Permits (Title V of the 1990 Federal Clean Air Act Amendments). The provisions of this construction permit must be incorporated into the operating permit. The application for the modification to the Operating Permit is due within one year of commencement of operation of the equipment or modification covered by this permit. 21. Prevention of Significant Deterioration (PSD) requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any • permit condition. Any relaxation that increases the potential to emit above the applicable PSD threshold will require a full PSD review of the source as though construction had AIRS ID: 123/0184/015 Page 8 of 18 Kerr-McGee/Anadarko •:trol.:m •r`•rati' . olor .• Pep ment of Public Health and Environment Permit No. 11WE1963 Y' Air Pollution Control Division Issuance 1 not yet commenced on the source. The source shall not exceed the PSD threshold until a PSD permit is granted. (Regulation No. 3 Part D, VI.B.4) 22. Non-attainment New Source Review requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable NSR threshold will require a full NSR review of the source as though construction had not yet commenced on the source. The source shall not exceed the NSR threshold until a NSR permit is granted. (Regulation No. 3 Part D, V.A.7) GENERAL TERMS AND CONDITIONS: 23. 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. 24. 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. 25. 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. 26. 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. 27. 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. 28. 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 AIRS ID: 123/0184/015 Page 9 of 18 Kerr-McGee/Anadarko 4 trol..pm u orate i olor •• rep. rent of Public Health and Environment Permit No. 11WE1963 - Air Pollution Control Division Issuance 1 Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 29. 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: Jacob Sebesta Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued as part of a synthetic minor modification project for NANSR. AIRS ID: 123/0184/015 Page 10 of 18 Kerr-McGee/Anadarko trot-',m .ir`•rati olor;.. Pep ment of Public Health and Environment Permit No. 11WE1963 Air Pollution Control Division Issuance 1 . Notes to Permit Holder 1) 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. 2) 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/requlations/airreqs/100102agcccommonprovisionsreq.pdf. 3) 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 9135 Yes 2193 Acetaldehyde 75070 A 903 Yes 903 Acrolein 107028 A 555 Yes 555 015 Methanol 67561 C 270 No 270 n-Hexane 110543 C 120 No 120 Benzene 71432 A 48 No 48 Toluene 108883 C 44 No 44 4) The emission levels contained in this permit are based on the following emission factors: Emission Factors - Emission Factors— Uncontrolled Controlled CAS Pollutant Ib/MMBtu g/bhp-hr Ib/MMBtu g/bhp-hr NOx 0.2276 0.7000 0.2276 0.7000 CO 0.8128 2.5000 0.0813 0.2500 VOC 0.2931 0.9015 0.1905 0.5860 5000 Formaldehyde 0.0845 0.2600 0.0203 0.0624 75070 Acetaldehyde 0.0084 0.0257 0.0084 0.0257 107028 Acrolein 0.0051 0.0158 0.0051 0.0158 67561 Methanol 0.0025 0.0077 0.0025 0.0077 110543 n-Hexane 0.0011 0.0034 0.0011 0.0034 71432 Benzene 0.0004 0.0014 0.0004 0.0014 108883 Toluene 0.0004 0.0013 0.0004 0.0013 Emission factors are based on a Brake-Specific Fuel Consumption Factor of 6781 Btu/hp-hr, a site-rated horsepower value of 1775, and a fuel heat value of 905 Btu/scf. AIRS ID: 123/0184/015 Page 11 of 18 Kerr-McGee/Anadarko trol '1 m $=.rati ` olor p ment of Public Health and Environment Permit No. 11WE1963 Air Pollution Control Division Issuance 1 Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer Data No control. CO Manufacturer Data Eng. Judgement VOC Manufacturer Data Eng. Judgement 5000 Formaldehyde Manufacturer Data Eng. Judgement 75070 Acetaldehyde AP-42; Table 3.2-2 (7/2000); No Control Natural Gas 107028 Acrolein AP-42; Table 3.2-2 (7/2000); No Control Natural Gas 67561 Methanol AP-42; Table 3.2-2 (7/2000); No Control Natural Gas 110543 n-Hexane AP-42; Table 3.2-2 (7/2000); No Control Natural Gas 71432 Benzene AP-42; Table 3.2-2 (7/2000); No Control Natural Gas 108883 Toluene AP-42; Table 3.2-2 (7/2000); No Control Natural Gas Note: The uncontrolled VOC emission factor was calculated by adding the non-methane, non- ethane hydrocarbon (NMNEHC) and formaldehyde emission factors provided by the manufacturer and the acetaldehyde and acrolein emission factors from AP-42. This calculation was necessary because the manufacturer's NMNEHC factor did not include emissions of aldehyde compounds. 5) In accordance with C.R.S. 25-7-114.1, the Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years. The five-year term for this APEN expires on July 11, 2016. A revised APEN shall be submitted no later than 30 days before the five-year term expires. 6) This 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/fr18ja08.pdf 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Major Source of NOx, VOC, CO and HAP PSD Synthetic Minor Source of CO NANSR Major Source of NOx and VOC MACT ZZZZ Major Source Requirements: Applicable Area Source Requirements: Not Applicable 8) 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: 123/0184/015 Page 12 of 18 Kerr-McGee/Anadarko F trot rm >`.ratic 4. (Dior— rep.q ment of Public Health and Environment Permit No. 11WE1963 Air Pollution Control Division Issuance 1 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 ZZZZ— Subpart MMMMM MACT 63.8980-End Subpart NNNNN —Subpart XXXXXX 9) 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: 123/0184/015 Page 13 of 18 Kerr-McGee/Anadarko • . m .r. •rati olor ep ment of Public Health and Environment Permit No. 11WE1963 Air Pollution Control Division Issuance 1 ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES October 1, 2011 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 permittee 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 permittee 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 permittee 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 permittee 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: 123/0184/015 Page 14 of 18 Kerr-McGee/Anadarko trot ':m .' .rati olor • •ep m'ent of Public Health and Environment Permit No. 11WE1963 - Air Pollution Control Division Issuance 1 2.1.2 The permittee may permanently replace the existing compressor engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. The AOS cannot be used for the permanent replacement of an entire engine at any source that is currently a major stationary source for purposes of Prevention of Significant Deterioration or Non- Attainment Area New Source Review("PSD/NANSR") unless the existing engine has emission limits that are below the significance levels in Reg 3, Part D, II.A.42. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the permittee 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 permittee shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. Nothing in this AOS shall preclude the Division from taking an action, based on any permanent engine replacement(s), for circumvention of any state or federal PSD/NANSR requirement. Additionally, in the event that any permanent engine replacement(s) constitute(s) a circumvention of applicable PSD/NANSR requirements, nothing in this AOS shall excuse the permittee from complying with PSD/NANSR and applicable permitting requirements. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The permittee 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 permittee shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. AIRS ID: 123/0184/015 Page 15 of 18 Kerr-McGee/Anadarko ' • • ~.m ►5r. oratiA olor ep,1 mint of Public Health and Environment Permit No. 11WE1963 Air Pollution Control Division Issuance 1 All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer). Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year(whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year(8760), whichever applies. For comparison with a short-term limit that is either input based (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 naturalgas 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). AIRS ID: 123/0184/015 Page 16 of 18 Kerr-McGee/Anadarko ` , m • orate olor ++ rep.; mint of Public Health and Environment Permit No. 11WE1963 Air Pollution Control Division Issuance 1 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. 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 AIRS ID: 123/0184/015 Page 17 of 18 Kerr-McGee/Anadarko . m .rata olor iep-' ment of Public Health and Environment Permit No. 11WE1963 �: Air Pollution Control Division Issuance 1 equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ requirements). However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, § 1.8 (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. 2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required 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: 123/0184/015 Page 18 of 18 • • STATE OF COLORADO Sv Coto COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT k �o AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 r 1876' CONSTRUCTION PERMIT PERMIT NO: 11 WE1964 Issuance 1 DATE ISSUED: ISSUED TO: Kerr-McGee Gathering, LLC THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural gas compression facility, known as the Frederick Compressor Station, located in 3988 Weld County Rd. 19, Frederick in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Description Equipment ID Point One (1) Caterpillar, Model G3606LE, Serial Number To Be Determined, natural gas-fired, turbo-charged, 4SLB EU-49 016 reciprocating internal combustion engine, site rated at 1775 horsepower at 1000 RPM. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control. This emission unit is used for natural gas compression. This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Caterpillar G3606LE engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the APCD no later than fifteen days after commencement of the permitted operation or activity by submitting a Notice of Startup (NOS) form to the APCD. The Notice of Startup (NOS) form may be downloaded online at www.cdphe.state.co.us/ap/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: 123/0184/016 Page 1 of 18 NGEngine Version 2009-1 Kerr-McGee/Anadarko '—trolt..m ti.ratis, olor°... aep ment of Public Health and Environment Permit No. 11WE1964 Air Pollution Control Division Issuance 1 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 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 EU-49 016 2089 1748 746 Point Monthly limits are based on a 31-day month. Annual Limits: Facility AIRS Tons per Year Emission Type VOC CO Equipment ID Point NO, EU-49 016 12.3 10.3 4.4 Point See "Notes to Permit Holder #4 for information on emission factors and methods used to calculate limits. AIRS ID: 123/0184/016 Page 2 of 18 Kerr-McGee/Anadarko , trolu*m,.. .e#•ratR' i olonlia• Pep ment of Public Health and Environment Permit No. 11WE1964 a.. Air Pollution Control Division Issuance 1 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, 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. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control that reduces uncontrolled emissions of CO and VOC from the 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.) 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 119.42 EU-49 016 Consumption of natural gas as a fuel f/yr 1 MMscf/ 10 MMscf/month 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.) AIRS ID: 123/0184/016 Page 3 of 18 Kerr-McGee/Anadarko ' m ►.r' •rati+] olor Ts rep ment of Public Health and Environment Permit No. 11WE1964 Air Pollution Control Division Issuance 1 12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 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.2. For lean burn reciprocating internal combustion engines, an oxidation catalyst shall be required. 14. This source is subject to the requirements of: • Regulation No. 8, Part E , Subpart III.FFFF: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (RICE) of 40 C.F.R. Part 63, Subpart ZZZZ, and • Regulation No. 8, Part E, Subpart LA, National Emission Standards for Hazardous Air Pollutants for Source Categories: General Provisions, 40 CFR Part 63 including, but not limited to, the following: • Emission and Operating Limitations o 63.6600(b) - If you own or operate a new or reconstructed 4SLB stationary RICE with a site rating of more than 500 brake HP located at major source of HAP emissions you must comply with the following emission limitations (Table 2a, Subpart ZZZZ to Part 63): • reduce CO emissions by 93 percent or more; or • limit concentration of formaldehyde in the stationary RICE exhaust to 14 ppmvd or less at 15 percent O2. o 63.6600(b) - If you own or operate a new or reconstructed 4SL6 stationary RICE with a site rating of more than 500 brake HP located at major source of HAP emissions you must comply with the following operating limitations (Table 2b, Subpart ZZZZ to Part 63): • maintain your catalyst so that the pressure drop across the catalyst does not change by more than 2 inches of water at 100 percent load plus or minus 10 percent from the pressure drop across the catalyst that was measured during the initial performance test; and • maintain the temperature of your stationary RICE exhaust so that the catalyst inlet temperature is greater than or equal to 450 °F and less than or equal to 1350 °F. • General Compliance Requirements o §63.6605(a) - You must be in compliance with the emission limitations and operating limitations in this subpart that apply to you at all times, except during periods of startup, shutdown, and malfunction. o §63.6605(b) - If you must comply with emission limitations and operating limitations, you must operate and maintain your stationary RICE, including air pollution control and monitoring equipment, in a manner consistent with good air pollution control practices for minimizing emissions at all times, including during startup, shutdown, and malfunction. AIRS ID: 123/0184/016 Page 4 of 18 Kerr-McGee/Anadarko - m .i 'oratir olor .• ■ep ment of Public Health and Environment Permit No. 11WE1964 Air Pollution Control Division Issuance 1 • Testing and Initial Compliance Requirements o §63.6610(a) - You must conduct the initial performance test or other initial compliance demonstrations in Table 4 to Subpart ZZZZ of Part 63 that apply to you within 180 days after the compliance date that is specified for your stationary RICE in §63.6595 and according to the provisions in §63.7(a)(2). o §63.6615 - If you must comply with the emission limitations and operating limitations, you must conduct subsequent performance tests semiannually (as per Table 3 of Subpart ZZZZ to Part 63). After you have demonstrated compliance for two consecutive tests, you may reduce the frequency of subsequent performance tests to annually. If the results of any subsequent annual performance test indicate the stationary RICE is not in compliance with the CO or formaldehyde emission limitation, or you deviate from any of your operating limitations, you must resume semiannual performance tests. o §63.6625(a) - If you elect to install a CEMS as specified in Table 5 of this subpart, you must install, operate, and maintain a CEMS to monitor CO and either oxygen or CO2 at both the inlet and the outlet of the control device according to the requirements in paragraphs 63.6625(a)(1) through 63.6625(4) of Subpart ZZZZ to Part 63. o §63.6625(b) - If you are required to install a continuous parameter monitoring system (CPMS) as specified in Table 5 of this subpart, you must install, operate, and maintain each CPMS according to the requirements in §63.8. o §63.6630(a) - You must demonstrate initial compliance with each emission and operating limitation that applies to you according to Table 5 of Subpart ZZZZ to Part 63. o §63.6630(b) - During the initial performance test, you must establish each operating limitation in Tables lb and 2b of Subpart ZZZZ to Part 63 that applies to you. o §63.6630(c) - You must submit the Notification of Compliance Status containing the results of the initial compliance demonstration according to the requirements in §63.6645. • Continuous Compliance Requirements o §63.6635(b) - Except for monitor malfunctions, associated repairs, and required quality assurance or control activities (including, as applicable, calibration checks and required zero and span adjustments), you must monitor continuously at all times that the stationary RICE is operating. o §63.6635(c) - You may not use data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities in data averages and calculations used to report emission or operating levels. You must, however, use all the valid data collected during all other periods. o §63.6640(a) - You must demonstrate continuous compliance with each emission limitation and operating limitation in Tables la and lb and Tables 2a and 2b of subpart ZZZZ of Part 63 that apply to you according to methods specified in Table 6 of Subpart ZZZZ of Part 63. AIRS ID: 123/0184/016 Page 5 of 18 Kerr-McGee/Anadarko . • x,m etr`'•ratiY olor .. •-p ' ment of Public Health and Environment Permit No. 11WE1964 Air Pollution Control Division Issuance 1 o §63.6640(b) - You must report each instance in which you did not meet each emission limitation or operating limitation in Tables 1a and 1b and Tables 2a and 2b of Subpart ZZZZ of Part 63 that apply to you. These instances are deviations from the emission and operating limitations in this subpart. These deviations must be reported according to the requirements in §63.6650. If you change your catalyst, you must reestablish the values of the operating parameters measured during the initial performance test. When you reestablish the values of your operating parameters, you must also conduct a performance test to demonstrate that you are meeting the required emission limitation applicable to your stationary RICE. o §63.6640(d) - Consistent with §§63.6(e) and 63.7(e)(1), deviations from the emission or operating limitations that occur during a period of startup, shutdown, or malfunction are not violations if you demonstrate to the Administrator's satisfaction that you were operating in accordance with §63.6(e)(1). For new, reconstructed, and rebuilt stationary RICE, deviations from the emission or operating limitations that occur during the first 200 hours of operation from engine startup (engine burn-in period) are not violations. o §63.6640(e) - You must also report each instance in which you did not meet the requirements in Table 8 of Subpart ZZZZ to Part 63 that apply to you. • Notifications, Reports and Records o §63.6645(a) - If you own or operate a stationary RICE with a site rating of more than 500 brake HP located at a major source of HAP emissions you must submit all of the notifications in §§63.7(b) and (c), 63.8(e), (f)(4) and (f)(6), 63.9(b) through (e), and (g) and (h) that apply to you by the dates specified. o §63.6645(g) - If you are required to conduct a performance test, you must submit a Notification of Intent to conduct a performance test at least 60 days before the performance test is scheduled to begin as required in §63.7(b)(1). o §63.6645(h) - If you are required to conduct a performance test or other initial compliance demonstration as specified in Tables 4 and 5 of Subpart ZZZZ to Part 63, you must submit a Notification of Compliance Status according to §63.9(h)(2)(ii). • §63.6645(h)(1) - For each initial compliance demonstration required in Table 5 of Subpart ZZZZ to Part 63 that does not include a performance test, you must submit the Notification of Compliance Status before the close of business on the 30th day following the completion of the initial compliance demonstration. • §63.6645(h)(2) - For each initial compliance demonstration required in Table 5 of Subpart ZZZZ to Part 63 that includes a performance test conducted according to the requirements in Table 3 to this subpart, you must submit the Notification of Compliance Status, including the performance test results, before the close of business on the 60th day following the completion of the performance test according to §63.10(d)(2). AIRS ID: 123/0184/016 Page 6 of 18 Kerr-McGee/Anadarko .•m i• •rati olor ep ment of Public Health and Environment Permit No. 11WE1964 Air Pollution Control Division Issuance 1 o §63.6650(a) - You must submit each report in Table 7 of Subpart ZZZZ to Part 63 that applies to you. o §63.6655(a) - If you must comply with the emission and operating limitations, you must keep the records described in §63.6655(a)(1) through (a)(3), §63.6655 (b)(1) through (b)(3) and §63.6655 (c). o §63.6655(d) - You must keep the records required in Table 6 of Subpart ZZZZ of Part 63 to show continuous compliance with each emission or operating limitation that applies to you. o §63.6660(a) - Your records must be in a form suitable and readily available for expeditious review according to §63.10(b)(1). o §63.6660(b) - As specified in §63.10(b)(1), you must keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. o §63.6660(c) - You must keep each record readily accessible in hard copy or electronic form on-site for at least 2 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record, according to §63.10(b)(1). You can keep the records off-site for the remaining 3 years. • Other Requirements and Information o §63.6665 - Table 8 to this subpart shows which parts of the General Provisions in §§63.1 through 63.15 apply to you. OPERATING & MAINTENANCE REQUIREMENTS 15. Upon startup of this point, 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 16. A source initial compliance test shall be conducted on emissions point 016 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 Formaldehyde AIRS ID: 123/0184/016 Page 7 of 18 Kerr-McGee/Anadarko trot: m ."'•ratiy olor ep ment of Public Health and Environment Permit No. 11WE1964 Air Pollution Control Division Issuance 1 Periodic Testing Requirements 17. This engine is subject to the periodic testing requirements of 40 C.F.R Part 63, Subpart ZZZZ. 18. This 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. ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A or B. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine or turbine, the appropriate APEN filing fee and a cover letter explaining that the permittee is exercising an alternative-operating scenario and is installing a permanent replacement engine or turbine. 20. This source is subject to the provisions of Regulation Number 3, Part C, Operating Permits (Title V of the 1990 Federal Clean Air Act Amendments). The provisions of this construction permit must be incorporated into the operating permit. The application for the modification to the Operating Permit is due within one year of commencement of operation of the equipment or modification covered by this permit. 21. Prevention of Significant Deterioration (PSD) requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable PSD threshold will require a full PSD review of the source as though construction had AIRS ID: 123/0184/016 Page 8 of 18 Kerr-McGee/Anadarko ^ trol=j,m ^•rata A., olor i s •ep. rrient of Public Health and Environment Permit No. 11WE1964 Air Pollution Control Division Issuance 1 not yet commenced on the source. The source shall not exceed the PSD threshold until a PSD permit is granted. (Regulation No. 3 Part D, VI.B.4) 22. Non-attainment New Source Review requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable NSR threshold will require a full NSR review of the source as though construction had not,yet commenced on the source. The source shall not exceed the NSR threshold until a NSR permit is granted. (Regulation No. 3 Part D, V.A.7) GENERAL TERMS AND CONDITIONS: 23. 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. 24. 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. 25. 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. 26. 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. 27. 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. 28. 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 AIRS ID: 123/0184/016 Page 9 of 18 Kerr-McGee/Anadarko m ;'•ratiA olor •• sept' ment of Public Health and Environment Permit No. 11WE1964 . Air Pollution Control Division Issuance 1 Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 29. 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: Jacob Sebesta Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued as part of a synthetic minor modification project for NANSR. AIRS ID: 123/0184/016 Page 10 of 18 Kerr-McGee/Anadarko -trol:-m •� r•raU . olor ep ment of Public Health and Environment Permit No. 11WE1964 Air Pollution Control Division Issuance 1 Notes to Permit Holder: 1) 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. 2) 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/requlations/airregs/100102agcccommonprovisionsreq.pdf. 3) 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(Ib/yr) Formaldehyde 5000 A 9135 Yes 2193 Acetaldehyde 75070 A 903 Yes 903 Acrolein 107028 A 555 Yes 555 016 Methanol 67561 C 270 No 270 n-Hexane 110543 C 120 No 120 Benzene 71432 A 48 No 48 Toluene 108883 C 44 No 44 4) The emission levels contained in this permit are based on the following emission factors: Emission Factors - Emission Factors— Uncontrolled Controlled CAS Pollutant Ib/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr NOx 0.2276 0.7000 0.2276 0.7000 CO 0.8128 2.5000 0.0813 0.2500 . VOC 0.2931 0.9015 0.1905 0.5860 5000 Formaldehyde 0.0845 0.2600 0.0203 0.0624 75070 Acetaldehyde 0.0084 0.0257 0.0084 0.0257 107028 Acrolein 0.0051 0.0158 0.0051 0.0158 67561 Methanol 0.0025 0.0077 0.0025 0.0077 110543 n-Hexane 0.0011 0.0034 0.0011 0.0034 71432 Benzene 0.0004 0.0014 0.0004 0.0014 108883 Toluene 0.0004 0.0013 0.0004 0.0013 Emission factors are based on a Brake-Specific Fuel Consumption Factor of 6781 Btu/hp-hr, a site-rated horsepower value of 1775, and a fuel heat value of 905 Btu/scf. AIRS ID: 123/0184/016 Page 11 of 18 Kerr-McGee/Anadarko •* troll ccsmi•ratir t olor iepF ment of Public Health and Environment Permit No. 11WE1964 Air Pollution Control Division Issuance 1 • Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer Data No control. CO Manufacturer Data Eng. Judgement VOC Manufacturer Data Eng. Judgement 5000 Formaldehyde Manufacturer Data Eng. Judgement 75070 Acetaldehyde AP-42; Table 3.2-2 (7/2000); No Control Natural Gas 107028 Acrolein AP-42; Table 3.2-2 (7/2000); No Control Natural Gas 67561 Methanol AP-42; Table 3.2-2 (7/2000); No Control Natural Gas 110543 n-Hexane AP-42; Table 3.2-2 (7/2000); No Control Natural Gas 71432 Benzene AP-42; Table 3.2-2 (7/2000); No Control Natural Gas 108883 Toluene AP-42; Table 3.2-2 (7/2000); No Control Natural Gas Note: The uncontrolled VOC emission factor was calculated by adding the non-methane, non- ethane hydrocarbon (NMNEHC) and formaldehyde emission factors provided by the manufacturer and the acetaldehyde and acrolein emission factors from AP-42. This calculation was necessary because the manufacturer's NMNEHC factor did not include emissions of aldehyde compounds. 5) In accordance with C.R.S. 25-7-114.1, the Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years. The five-year term for this APEN expires on July 11, 2016. A revised APEN shall be submitted no later than 30 days before the five-year term expires. 6) This 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 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Major Source of NOx, VOC, CO and HAP PSD Synthetic Minor Source of CO NANSR Major Source of NOx and VOC MACT ZZZZ Major Source Requirements: Applicable Area Source Requirements: Not Applicable 8) 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: 123/0184/016 Page 12 of 18 Kerr-McGee/Anadarko trol ';m . � _=`•ratiy; olor ep ment of Public Health and Environment Permit No. 11WE1964 -_ Air Pollution Control Division Issuance 1 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 ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN —Subpart XXXXXX 9) 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: 123/0184/016 Page 13 of 18 Kerr-McGee/Anadarko ` m ►• •rati olor +• eep,; ment of Public Health and Environment Permit No. 11WE1964 � Air Pollution Control Division Issuance 1 ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES October 1, 2011 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 permittee 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 permittee 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 permittee 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 permittee 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: 123/0184/016 Page 14 of 18 Kerr-McGee/Anadarko . ;;.m r` .rati�.'= olor ep ment of Public Health and Environment Permit No. 11WE1964 Air Pollution Control Division Issuance 1 2.1.2 The permittee may permanently replace the existing compressor engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. The AOS cannot be used for the permanent replacement of an entire engine at any source that is currently a major stationary source for purposes of Prevention of Significant Deterioration or Non- Attainment Area New Source Review ("PSD/NANSR") unless the existing engine has emission limits that are below the significance levels in Reg 3, Part D, II.A.42. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the permittee 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 permittee shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. Nothing in this AOS shall preclude the Division from taking an action, based on any permanent engine replacement(s), for circumvention of any state or federal PSD/NANSR requirement. Additionally, in the event that any permanent engine replacement(s) constitute(s) a circumvention of applicable PSD/NANSR requirements, nothing in this AOS shall excuse the permittee from complying with PSD/NANSR and applicable permitting requirements. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The permittee 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 permittee shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. AIRS ID: 123/0184/016 Page 15 of 18 Kerr-McGee/Anadarko trot *m . .r'•ratiA olor ep ; tent of Public Health and Environment Permit No. 11WE1964 Air Pollution Control Division Issuance 1 All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer). Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year(whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year(8760), whichever applies. For comparison with a short-term limit that is either input based (Ib/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine will be subject to, the results of the test shall be converted to the appropriate units as described in the above-mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline. 2.3 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 naturalgas 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). AIRS ID: 123/0184/016 Page 16 of 18 Kerr-McGee/Anadarko "--trot-,m., ilr``•rata . olor ep ment of Public Health and Environment Permit No. 11WE1964 Air Pollution Control Division Issuance 1 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. 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 AIRS ID: 123/0184/016 Page 17 of 18 Kerr-McGee/Anadarko •.ttrol7Lm ,+.rati olor:.. •-p, ment of Public Health and Environment Permit No. 11WE1964 Air Pollution Control Division Issuance 1 ,. 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, § 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 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: 123/0184/016 Page 18 of 18 FT STATE OF COLORADO of cod. COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT 4?� I AIR POLLUTION CONTROL DIVISION ° TELEPHONE: (303) 692-3150 . *. x Ian Y% CONSTRUCTION PERMIT PERMIT NO: 11 WE1 965 Issuance 1 DATE ISSUED: ISSUED TO: Kerr-McGee Gathering, LLC THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural gas compression facility, known as the Frederick Compressor Station, located at 3988 Weld County Road 19, Frederick, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID One (1) Triethylene glycol (TEG) natural gas dehydration unit (make, model, serial number: not submitted) with a design capacity of 30 MMscf per day. This emissions unit is equipped D-42 017 with two (2) electric glycol pumps with a total design capacity of 5 gallons per minute (make and model not submitted). 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 a thermal oxidizer. Flash tank off gas is recycled to the plant inlet. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S.(25-7-101 et seq),TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the APCD no later than fifteen days after commencement of the permitted operation or activity by submitting a Notice of Startup (NOS) form to the APCD. The Notice of Startup (NOS) form may be downloaded online at www.cdphe.state.co.us/ap/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. 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 AIRS ID: 123/0184/017 Page 1 of 11 Dehy Version 2009-1 Kerr-McGee Gathering ,' Co ^ do p e o Public Health and Environment Permit No. 11WE1965 Air Pollution Control Division Issuance 1 demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, II.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 and model number of the glycol circulation pumps and thermal oxidizer 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 D-42 017 565 337 1128 Point Monthly limits are based on a 31-day month. Facility-wide emissions of each individual hazardous air pollutant emitted from a glycol dehydrator or storage vessel with the potential for flash emissions as defined in 40 CFR 63.761 shall be less than 1,358.9 lb/month. Facility-wide emissions of total hazardous air pollutants emitted from a glycol dehydrator or storage vessel with the potential for flash emissions as defined in 40 CFR 63.761 shall be less than 3,397.3 lb/month. Annual Limits: Facility AIRS Tons per Year Emission Type Equipment ID Point NO, VOC CO D-42 017 3.3 2.0 6.6 Point See "Notes to Permit Holder#4"for information on emission factors and methods used to calculate limits. AIRS ID: 123/0184/017 Page 2 of 11 Kerr-McGee Gathering, $> Cot,do p e 6 Public Health and Environment Permit No. 11WE1965 Air Pollution Control Division Issuance 1 Facility-wide emissions of each individual hazardous air pollutant emitted from a glycol dehydrator or storage vessel with the potential for flash emissions as defined in 40 CFR 63.761 shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants emitted from a glycol dehydrator or storage vessel with the potential for flash emissions as defined in 40 CFR 63.761 shall be less than 20.0 tpy. During the first twelve(12) months of operation,compliance with both the monthly and yearly emission limitations shall be required. After the first twelve (12) months of operation, compliance with only the yearly limitation shall be required. Compliance with the synthetic minor status of this facility shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate monthly emissions and keep a compliance record on site, or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all emission units, requiring an APEN, at this facility. 8. 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, 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. 9. All flash tank off gas from this unit shall be recycled to the plant inlet. Still vent emissions from this unit shall be routed to a condenser and the vapor from the condenser shall be routed to a thermal oxidizer. This emissions control system shall reduce uncontrolled emissions of VOC 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.) PROCESS LIMITATIONS AND RECORDS 10. 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 D-42 017 Natural gas throughput 10,950 930 MMscf/yr MMscf/month During the first twelve(12) months of operation, compliance with both the monthly and yearly natural gas throughput 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 natural gas throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate monthly AIRS ID: 123/0184/017 Page 3 of 11 Kerr-McGee Gathering, 11 Co do p e o Public Health and Environment Permit No. 11WE1965 .� � Air Pollution Control Division Issuance 1 natural gas throughput and keep a compliance record on site or at a local field office with site responsibility, for Division review. 11. This unit shall be limited to the maximum lean glycol circulation rate 5.0 gallons per minute. The lean glycol recirculation rate shall be recorded daily in a log maintained on site and made available to the Division for inspection upon request. (Reference: Regulation No. 3, Part B, I I.A.4) STATE AND FEDERAL REGULATORY REQUIREMENTS 12. The permit number or 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) 13. 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.) 14. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 15. The thermal oxidizer 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. The operating temperature of the thermal oxidizer used to control emissions from this dehydration unit shall be greater than 1500 °F, or the temperature established during the most recent stack test of the equipment that was approved by the Division, at all times that any dehydration unit still vent emissions are routed to the thermal oxidizer in order to meet the emission limits in this permit. 17. The condenser and thermal oxidizer covered by this permit is subject to Regulation No. 7, Section XII.C General Provisions including, but not limited to the following: XII.C.1.a. All air pollution control equipment used to demonstrate compliance with this Section XII shall be operated and maintained consistent with manufacturer specifications and good engineering and maintenance practices. The owner or operator shall keep manufacturer specifications on file. In addition, all such air pollution control equipment shall be adequately designed and sized to achieve the control efficiency rates required by this Section XII and to handle reasonably foreseeable fluctuations in emissions of volatile organic compounds. 18. 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. 19. 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, AIRS ID: 123/0184/017 Page 4 of 11 Kerr-McGee Gathering, I, CoI =do p e o Public Health and Environment Permit No. 11WE1965 Air Pollution Control Division Issuance 1 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. 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: • §63.764 - General Standards o §63.764 (e)(1) -The owner or operator is exempt from the requirements of paragraph (c)(1) and (d) of this section if the criteria listed in paragraph (e)(1)(i) or (ii) of this section are met, except that the records of the determination of these criteria must be maintained as required in §63.774(d)(1). • §63.764 (e)(1)(i)—The actual annual average flowrate of natural gas to the glycol dehydration unit is less than 85 thousand standard cubic meters per day (3.0 MMSCF/day), as determined by the procedures specified in §63.772(b)(1) of this subpart; or • §63.764 (e)(1)(ii) —The actual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere are less than 0.90 megagram per year, as determined by the procedures specified in §63.772(b)(2) of this subpart. • §63.772-Test Methods, Compliance Procedures and Compliance Demonstration o §63.772(b) - Determination of glycol dehydration unit flowrate or benzene emissions. The procedures of this paragraph shall be used by an owner or operator to determine glycol dehydration unit natural gas flowrate or benzene emissions to meet the criteria for an exemption from control requirements under §63.764(e)(1). • §63.772(b)(1) - The determination of actual flowrate of natural gas to a glycol dehydration unit shall be made using the procedures of either paragraph (b)(1)(i) or (b)(1)(ii) of this section. • §63.772(b)(1)(i)—The owner or operator shall install and operate a monitoring instrument that directly measures natural gas flowrate to the glycol dehydration unit with an accuracy of plus or minus 2 percent or better. The owner or operator shall convert annual natural gas flowrate to a daily average by dividing the annual flowrate by the number of days per year the glycol dehydration unit processed natural gas. • §63.772(b)(1)(ii) -The owner or operator shall document, to the Administrator's satisfaction, that the actual annual average natural gas flowrate to the glycol dehydration unit is less than 85 thousand standard cubic meters per day. • §63.772(b)(2) -The determination of actual average benzene emissions from a glycol dehydration unit shall be made using the procedures of AIRS ID: 123/0184/017 Page 5 of 11 Kerr-McGee Gathering, D` Co do p e o Public Health and Environment Permit No. 11WE1965 . Air Pollution Control Division Issuance 1 • either paragraph (b)(2)(i) or (b)(2)(ii) of this section. Emissions shall be determined either uncontrolled, or with federally enforceable controls in place. • §63.772(b)(2)(i)—The owner or operator shall determine actual average benzene emissions using the model GRI-GLYCaIc TM Version 3.0 or higher, and the procedures presented in the associated GRI-GLYCaIcTM Technical Reference Manual. Inputs to the model shall be representative of actual operating conditions of the glycol dehydration unit and may be determined using the procedures documented in the Gas Research Institute (GRI) report entitled "Atmospheric Rich/Lean Method for Determining Glycol Dehydrator Emissions" (GRI-95/0368.1); or • §63.772(b)(2)(ii) - The owner or operator shall determine an average mass rate of benzene emissions in kilograms per hour through direct measurement using the methods in §63.772(a)(1)(i) or (ii), or an alternative method according to §63.7(f). Annual emissions in kilograms per year shall be determined by multiplying the mass rate by the number of hours the unit is operated per year. This result shall be converted to megagrams per year. • §63.774 - Recordkeeping Requirements o §63.774(d)(1)-An owner or operator of a glycol dehydration unit that meets the exemption criteria in §63.764(e)(1)(i) or §63.764(e)(1)(ii) shall maintain the records specified in paragraph (d)(1)(i) or paragraph (d)(1)(ii) of this section, as appropriate, for that glycol dehydration unit. • §63.774(d)(1)(i)—The actual annual average natural gas throughput(in terms of natural gas flowrate to the glycol dehydration unit per day) as determined in accordance with §63.772(b)(1), or • §63.774 (d)(1)(ii) - The actual average benzene emissions (in terms of benzene emissions per year) as determined in accordance with §63.772(b)(2). OPERATING & MAINTENANCE REQUIREMENTS 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.) 22. The condenser outlet temperature shall be recorded as per the frequency required in the O&M Plan. This information shall be maintained in a log on site and made available to the Division for inspection upon request. The condenser outlet temperature shall not exceed 160 °F on a monthly average basis. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements AIRS ID: 123/0184/017 Page 6 of 11 Kerr-McGee Gathering, . Co A. p do e o Public Health and Environment Permit No. 11WE1965 Air Pollution Control Division Issuance 1 ' 23. 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.) 24. A source initial compliance test shall be conducted on emissions point 017 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 operator shall also demonstrate the thermal oxidizer achieves a minimum destruction efficiency of 98.0% for VOC. The operator shall measure, using EPA approved methods, and record both the post-condenser still vent exhaust and the thermal oxidizer exhaust to determine the destruction efficiency of the thermal oxidizer(process models shall not be used to determine the flowrate or composition of the waste gas sent to the thermal oxidizer for the purposes of this test). The dehydration unit must be operating at its natural gas throughput and lean glycol circulation rate capacity as stated in this permit plus or minus 10% for the duration of the test. The condenser outlet temperature shall be 160°F plus or minus 10% for the duration of the test. The natural gas throughput, lean glycol circulation rate, condenser outlet temperature, and flash tank temperature and pressure shall be monitored and recorded during this test. 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. Periodic Testing Requirements 25. 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. ADDITIONAL REQUIREMENTS 26. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or AIRS ID: 123/0184/017 Page 7 of 11 Kerr-McGee Gathering, C Co do p e o Public Health and Environment Permit No. 11WE1965 Air Pollution Control Division Issuance 1 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. 27. This source is subject to the provisions of Regulation Number 3, Part C, Operating Permits (Title V of the 1990 Federal Clean Air Act Amendments). The provisions of this construction permit must be incorporated into the operating permit. The application for the modification to the Operating Permit is due within one year of commencement of operation of the equipment or modification covered by this permit. 28. Non-attainment New Source Review requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable NSR threshold will require a full NSR review of the source as though construction had not yet commenced on the source. The source shall not exceed the NSR threshold until a NSR permit is granted. (Regulation No. 3 Part D, V.A.7) 29. 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) GENERAL TERMS AND CONDITIONS: 30. 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. 31. 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. 32. 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 applicants agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 33. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. AIRS ID: 123/0184/017 Page 8 of 11 Kerr-McGee Gathering, '.- Co 11 do p me o Public Health and Environment Permit No. 11WE1965 Air Pollution Control Division Issuance 1 34. 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. 35. 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. 36. 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: Jacob Sebesta Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued as part of a synthetic minor modification project for NANSR. AIRS ID: 123/0184/017 Page 9 of 11 • Kerr-McGee Gathering, 11 ..• Co +1 ado e, p e; o' Public Health and Environment Permit No. 11WE1965 : , Air Pollution Control Division Issuance 1 Notes to Permit Holder: 1) 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. 2) 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.cd phe.state.co.us/req u lation s/airreq s/100102agcccommon provisionsreq.pdf. 3) 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(Ib/yr) Benzene 71432 A 56,281 Yes 1,032 Toluene 108883 C 66,996 Yes 1,088 017 Ethylbenzene 100414 C 2,266 Yes 28 Xylenes 1330207 C 28,513 Yes 335 n-Hexane 110543 C 3,663 Yes 70 4) 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 a condenser control efficiency calculated in GlyCalc and a thermal oxidizer control efficiency of 98%. Thermal oxidizer combustion emissions were calculated based on a burner heat rating of 4.60 MMBtu per hour plus the heat input contribution from the still vent emissions(post-condenser). The post-condenser still vent emissions were estimated at 0.4 MMBtu/hr(based on 228 scf/hr and 1765 Btu/scf as estimated in the GlyCalc run used to estimate VOC emissions for this permit). The emission limits for NOX and CO in this permit were buffered by 10% above what was calculated using the values discussed above. Emission Factors CAS # Pollutant lb/MMBtu gas combusted in Source thermal oxidizer NOx 0.138 TCEQ CO 0.2755 TCEQ 5) In accordance with C.R.S. 25-7-114.1, the Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years. The five-year term for this APEN expires on July 11, 2016. A revised APEN shall be submitted no later than 30 days before the five-year term expires. 6) This facility is classified as follows: Applicable Status AIRS ID: 123/0184/017 Page 10 of 11 Kerr-McGee Gathering, t $. Co j.=do p med o Public Health and Environment Permit No. 11WE1965 •�; Air Pollution Control Division Issuance 1 Requirement Operating Permit Major Source of NOR, VOC, CO and HAP PSD Synthetic Minor Source of CO NANSR Major Source of NOR and VOC Major Source Requirements: Not Applicable (Synthetic Minor Source of HAP MACT HH under Subpart HH) Area Source Requirements: Applicable 7) 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 PA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN —Subpart XXXXXX 8) 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/oilqaspermittinq.html AIRS ID: 123/0184/017 Page 11 of 11 Hello