HomeMy WebLinkAbout20112282.tiff STATE OF COLORADO
John W.Hickenlooper,Governor ��oF co�o�
Christopher E. Urbina, MD, MPH
Executive Director and Chief Medical Officer
•
Dedicated to protecting and improving the health and environment of the people of Colorado +
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4300 Cherry Creek Dr.S. Laboratory Services Division .1876""
Denver,Colorado 80246-1530 8100 Lowry Blvd.
Phone(303)692-2000 Denver,Colorado 80230-6928 - —`Colorado Department
Located in Glendale,Colorado (303)692-3090 of Public Health
http://www.cdphe.state.co.us and Environment
August 16, 2011
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 the Kerr-McGee/Anadarko
Petroleum Corporation. This public notice will be published in the Greeley Tribune on August 20,
2011.
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-B1
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
A// -1- 2011-2282
av-// g
NOTICE OF REQUEST FOR MINOR PERMIT MODIFICATION FOR
NATURAL GAS PRODUCTION PLANT
BY
Kerr-McGee/Anadarko Petroleum Corporation
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 of Coto
Christopher E. Urbina,MD, MPH F, q
Executive Director and Chief Medical Officer y/ o
Dedicated to protecting and improving the health and environment of the people of Colorado *'\ ir.
4300 Cherry Creek Dr.S. Laboratory Services Division .1876•
Denver,Colorado 80246-1530 8100 Lowry Blvd.
Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department
Located in Glendale,Colorado (303)692-3090 of Public Health
http://www.cdphe.state.co.us and Environment
Released to: The Greeley Tribune on August 16, 2011, published August 20, 2011
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/Anadarko Petroleum Corporation proposes to construct and operate one diesel back-up
generator and one compressor engine at an existing natural gas processing plant. This source is
located approximately 7 miles northeast of Ft. Lupton at 16116 Weld County Road 22. This modification
will increase permitted emissions of oxides of nitrogen by more than 25 tons per year in an ozone
nonattainment area. As such, this permit is subject to public comment per Regulation 3, Part B, Section
III.C.1.a. 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 and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
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.
Summary of Preliminary Analysis - Diesel RICE
Company Name Kerr-McGee Gathering, LLC Permit No. 10WE1587
Facility Name Ft. Lupton Gas Plant AIRS 123/0057/029
Facility Location 16116 Weld County Rd 22 Review Date 09/02/2010
Facility Equipment ID GEN2 Permit Engineer Jacob Sebesta
Requested Action New permit/newly reported emission, Request MOD-change company name
Issuance No. 1
Emission Point Description
One (1) Caterpillar, Model C18 DITA, Serial Number EKW01075, diesel-fired,turbo-charged, compression ignition reciprocating
internal combustion engine, site rated at 900 horsepower at 1800 RPM.This unit is not equipped with emission controls. This
emission unit is used to generate emergency back-up power.
Natural Gas Consumption
Requested (gal/yr) 4300.0
Requested(gal/m) 365.21
Fuel Heat Value(btu/gal) 130127.64
BSCF (Btu/hp-hr) 6173.8336
Emission Factor Sources
Uncontrolled Controlled
NOx Manufacturer's Data No control device.
VOC Manufacturer's Data No control device.
CO Manufacturers Data No control device.
Formaldehyde AP-42,Tabl 3.4-3(10/96) No Control
SOx AP-42 Table 3.4-1 No Control
TSP AP-42,Table 3.4-2(10/96) No Control
PM10 AP-42,Table 3.4-2(10/96) No Control
PM2.5 AP-42,Table 3.4-2(10/96) No Control
Other Pollutants AP-42, Tables 3.4-1 through 4 (10/96) No Control
Point Summary of Criteria Emissions (tpy)
Uncontrolled Proposed Control
Requested Controlled Requested PTE Efficiency
NOx 0.6 0.6 0.6 0.0%
VOC 0.0 0.0 0.0 0.0%
CO 0.0 0.0 0.0 0.0%
SOx 0.3 0.3 0.3 0.0%
TSP 0.0 0.0 0.0 0.0%
PM10 0.0 0.0 0.0 0.0%
PM2.5 0.0 0.0 0.0 0.0%
Total HAPs* 0.0 0.0 0.0 0.0%
*Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de
minimus thresholds. PTE includes all HAPs calculated, even those below de minimus.
Point Summary of Hazardous Air Pollutants (lb/yr)
Uncontrolled Proposed Control
HAP Name Requested Controlled Requested PTE Efficiency
Acrolein 0 0.0%
*Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is
greater than de minimus
Permitting Requirements
No NAAQS violations expected (see details of modeling analysis). This project(including emissions
permitted under 10WE1071 and 10WE1587)will result in impacts to ambient air quality below the
Ambient Air Impacts Significant Impact Level for annual NO2 impacts of 1 ttg/m3. The modeling report recommended that the
permit include minimum stack height requirements and requirements to maintain a fenceline that
precludes public access to the site.
Public Comment Public Comment Required: NOx emissions increase> 25 tpy in ozone NAA
MACT ZZZZ New Emergency Limited Use over 500 HP located at a(n) Major Source
NSPS 1111 This engine is considered a new emergency stationary CI internal combustion engine by NSPS 1111 rated
between 50 and 3000 hp, and is subject to the emission standards in 40 CFR 89.112 and 40 CFR 89.113.
Comments/Notes
0
Summary of Preliminary Analysis - NG RICE
Company Name Kerr-McGee Gathering, LLC Permit No. 10WE1071
Facility Name Ft. Lupton Gas Plant AIRS 123/0057/028
Facility Location 16116 Weld County Rd 22 Review Date 09/02/2010
Facility Equipment ID EU-104 Permit Engineer Jacob Sebesta
Requested Action New permit/newly reported emission
Issuance No. 1
Emission Point Description
One (1) Caterpillar, Model G3616 LE, Serial Number BLB00539, natural gas-fired, turbo-charged, 4SLB reciprocating internal
combustion engine, site rated at 4735 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.
Natural Gas Consumption
Requested (mmscf/yr) 278.87
Requested(mmscf/m) 23.68
Fuel Heat Value(btu/scf) 1004
BSCF (Btu/hp-hr) 6750
Emission Factor Sources
Uncontrolled Controlled
NOx Manufacturer's Data Eng.Judgement
VOC Manufacturer's Data Eng.Judgement
CO Manufacturer's Data Eng.Judgement
Formaldehyde Manufacturer's Data Eng.Judgement
SOX AP-42;Table 3.2-2(7/2000);Natural Gas No Control
TSP AP-42;Table 3.2-2(7/2000);Natural Gas No Control
PM10 AP-42;Table 3.2-2(7/2000); Natural Gas No Control
PM2.5 AP-42;Table 3.2-2(7/2000); Natural Gas No Control
Other Pollutants Describe EF sources- HAPs etc. Describe EF sources- HAPs, etc.
Point Summary of Criteria Emissions (tpy)
Uncontrolled Controlled Proposed Control
Requested Requested PTE Efficiency
NOx 32.0 32.0 32.0 0.0%
VOC 27.4 19.2 27.4 30.0%
CO 114.8 8.0 114.8 93.0%
SOx 0.1 0.1 0.1 0.0%
TSP 1.4 1.4 1.4 0.0%
PM10 1.4 1.4 1.4 0.0%
PM2.5 1.4 1.4 1.4 0.0%
Total HAPs* 0.0 0.0 21.0 66.2%
*Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de
minimus thresholds. PTE includes all HAPs calculated, even those below de minimus.
Point Summary of Hazardous Air Pollutants (Ib/yr)
Uncontrolled Controlled Proposed Control
HAP Name Requested Requested PTE Efficiency
Formaldehyde 36578 8779 36578 76.0%
Acetaldehyde 2341 2341 2341 0.0%
Acrolein 1439 1439 1439 0.0%
Methanol * 700 0.0%
n-Hexane * * 311 0.0%
Benzene 123 123 123 0.0%
Toluene * 114 0.0%
*Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED
UNCONTROLLED is greater than de minimus
Permitting Requirements
No NAAQS violations expected (see details of modeling analysis). This project (including emissions
permitted under 10WE1071 and 10WE1587)will result in impacts to ambient air quality below the
Ambient Air Impacts Significant Impact Level for annual NO2 impacts of 1 µgun'. The modeling report recommended that
the permit include minimum stack height requirements and requirements to maintain a fenceline that
precludes public access to the site.
Public Comment Public Comment Required: NOx emissions increase > 25 tpy in ozone NAA
MACT ZZZZ New/Recon 4SLB over 500 HP located at a(n) Major Source
Reg 7 XVII.E Standards
(g/hp-hr) This engine is exempt from Section XVII because it is subject to an emission standard in MACT ZZZZ.
Reg 7 XVI.B(Ozone NAA Yes
requirements)applies?
This engine is subject to NSPS JJJJ based on a manufacture date of 3/13/2009 (note JJJJ
NSPS JJJJ requriements are not currently included as permit conditions while the reg is not yet adopted into Reg
6).
Comments/Notes
0
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STATE OF COLORADO
OF COO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT N` 'l
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150 `,eye
CONSTRUCTION PERMIT
PERMIT NO: 1 0WE1 5587
Issuance 1
DATE ISSUED:
ISSUED TO: Kerr-McGee/Anadarko Petroleum Corporation
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Natural gas processing facility, known as the Ft. Lupton Gas Plant, located in 16116 Weld
County Rd 22, 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 C18 DITA, Serial Number
EIM/01075, diesel-fired, turbo-charged, 4SRB reciprocating
GEN2 029 internal combustion engine, site rated at 900 horsepower at
1800 RPM. This emission unit is used to generate
emergency back-up power.
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 thirty 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 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
AIRS ID: 123/0057/029 Page 1 of 10
•
Kerr-McGee/Anadarko trot: m �.ratiA
Permit No. 10WE1587 C. .io I • rtme / of Public Health and Environment
Issuance 1 Air Pollution Control Division
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 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
6. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). Monthly records of the actual emission rates shall be
maintained by the applicant and made available to the Division for inspection upon
request. (Reference: Regulation No. 3, Part B, Section II.A.4)
Annual Limits:
Facility AIRS Tons per Year
Emission Type
Equipment ID Point NO, VOC CO
GEN2 029 0.6 -- -- Point
See "Notes to Permit Holder #4 for information on emission factors and methods used to
calculate limits.
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.
PROCESS LIMITATIONS AND RECORDS
7. This source shall be limited to the following maximum consumption, processing and/or
operational rates as listed below. Monthly records of the actual consumption 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
AIRSEquipment Point Process Parameter AL mit nnual
ID
Consumption of diesel as a fuel 4300.00
GEN2 029 gallons/yr
Hours of operation 100
hours/yr
AIRS ID: 123/0057/029 Page 2 of 10
Kerr-McGee/Anadarko 4trol m :o orati d"
Permit No. 10WE1587 C o • '• rtme of Public Health and Environment
Issuance 1 .yam �xf Air Pollution Control Division
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
8. 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).
9. 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.)
10. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
11. This source is subject to the New Source Performance Standards requirements of
Regulation No. 6, Part A, Subpart 1111, Standards of Performance for Stationary
Compression Ignition Internal Combustion Engines (CI ICE) including, but not limited to,
the following:
o §60.4205 (b) Owners and operators of 2007 model year and later emergency
stationary CI ICE with a displacement of less than 30 liters per cylinder that are
not fire pump engines must comply with the emission standards for new nonroad
CI engines in §60.4202, for all pollutants, for the same model year and maximum
engine power for their 2007 model year and later emergency stationary CI ICE.
o § 60.4202 (a) Stationary CI internal combustion engine manufacturers must
certify their 2007 model year and later emergency stationary CI ICE with a
maximum engine power less than or equal to 2,237 KW (3,000 HP) and a
displacement of less than 10 liters per cylinder that are not fire pump engines to
the emission standards specified in paragraphs (a)(1) through (2) of this section.
o § 60.4202 (a) (2) For engines with a maximum engine power greater than or
equal to 37 KW (50 HP), the certification emission standards for new nonroad CI
engines for the same model year and maximum engine power in 40 CFR 89.112
and 40 CFR 89.113 for all pollutants beginning in model year 2007.
Table 1.—Emission Standards (g/kW-hr)
Rated Model NMHC
Power(kW) Tier Year NOx HC +NOx CO PM
kW>560 Tier 1 2000 9.2 1.3 - 11.4 0.54
Tier 2 2006 - - 6.4 3.5 0.20
The model years listed indicate the model years for which the specified tier of standards
take effect.
AIRS ID: 123/0057/029 Page 3 of 10
Kerr-McGee/Anadarko trot •m ,•rati�
Permit No. 10WE1587 C• .fo 9* •. rime of Public Health and Environment
Issuance 1 Air Pollution Control Division
40 CFR 89.112(a)
o § 60.4207(b) Beginning October 1, 2010, owners and operators of stationary CI
ICE subject to this subpart with a displacement of less than 30 liters per cylinder
that use diesel fuel must use diesel fuel that meets the requirements of 40 CFR
80.510(b) for nonroad diesel fuel.
• 40 CFR 80.510(b) Beginning June 1, 2010 . Except as otherwise
specifically provided in this subpart, all NR and LM diesel fuel is subject to
the following per-gallon standards:
(1) Sulfur content:
(i) 15 ppm maximum for NR diesel fuel.
(2) Cetane index or aromatic content, as follows:
(i) A minimum cetane index of 40; or
(ii) A maximum aromatic content of 35 volume percent.
Compliance shall be demonstrated by maintaining copies of the fuel
specifications provided by the supplier on-site or in a readily accessible
location and made available to the Division for inspection upon request.
o § 60.4209 (a) If you are an owner or operator of an emergency stationary CI
internal combustion engine, you must install a non-resettable hour meter prior to
startup of the engine.
o § 60.4211(a) If you are an owner or operator and must comply with the emission
standards specified in this subpart, you must operate and maintain the stationary
CI internal combustion engine and control device according to the manufacturer's
written instructions or procedures developed by the owner or operator that are
approved by the engine manufacturer. In addition, owners and operators may
only change those settings that are permitted by the manufacturer. You must
also meet the requirements of 40 CFR parts 89, 94 and/or 1068, as they apply to
you.
o § 60.4211 (e) Emergency stationary ICE may be operated for the purpose of
maintenance checks and readiness testing, provided that the tests are
recommended by Federal, State, or local government, the manufacturer, the
vendor, or the insurance company associated with the engine. Maintenance
checks and readiness testing of such units is limited to 100 hours per year. There
is no time limit on the use of emergency stationary ICE in emergency situations.
Anyone may petition the Administrator for approval of additional hours to be used
for maintenance checks and readiness testing, but a petition is not required if the
owner or operator maintains records indicating that Federal, State, or local
standards require maintenance and testing of emergency ICE beyond 100 hours
per year. For owners and operators of emergency engines meeting standards
under §60.4205 but not §60.4204, any operation other than emergency
operation, and maintenance and testing as permitted in this section, is prohibited.
f. All engines and control devices must be installed, configured, operated, and
maintained according to the specifications and instructions provided by the
engine manufacturer.
AIRS ID: 123/0057/029 Page 4 of 10
Kerr-McGee/Anadarko ,trol m • ".ratig r
Permit No. 10WE1587 C. o • •l rtmef of Public Health and Environment
Issuance 1 Air Pollution Control Division
g. If engine is equipped with a diesel particulate filter, the filter must be installed
with a backpressure monitor that notifies the owner or operator when the high
backpressure limit of the engine is approached. Records shall be kept of any
corrective action taken after the backpressure monitor has notified the owner or
operator that the high backpressure limit is approached.
12. 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:
• What parts of my plant does this subpart cover?
o §63.6590(b) - Stationary RICE subject to limited requirements. (1) An
affected source which meets either of the criteria in paragraphs (b)(1)(i)
through (ii) of this section does not have to meet the requirements of this
subpart and of subpart A of this part except for the initial notification
requirements of§63.6645(f).
• (i) The stationary RICE is a new or reconstructed emergency
stationary RICE with a site rating of more than 500 brake HP located
at a major source of HAP emissions.
• (ii) The stationary RICE is a new or reconstructed limited use
stationary RICE with a site rating of more than 500 brake HP located
at a major source of HAP emissions.
• Notifications, Reports and Records
o §63.6645(f) - If you are required to submit an Initial Notification but are
otherwise not affected by the requirements of this subpart, in accordance with
§63.6590(b), your notification should include the information in §63.9(b)(2)(i)
through (v), and a statement that your stationary RICE has no additional
requirements and explain the basis of the exclusion (for example, that it
operates exclusively as an emergency stationary RICE if it has a site rating of
more than 500 brake HP located at a major source of HAP emissions).
• 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. You do not need to comply
with the requirements in the General Provisions except for the initial
notification requirements.
OPERATING & MAINTENANCE REQUIREMENTS
13. 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
AIRS ID: 123/0057/029 Page 5 of 10
Kerr-McGee/Anadarko 4trol: m
Permit No. 10WE1587 C. ° o • rtme of Public Health and Environment
Issuance 1 Air Pollution Control Division
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
14. The owner or operator shall demonstrate compliance with Condition 9, using EPA
Method 9 to measure opacity from the engine. (Reference: Regulation No. 1, Section
II.A.1 & 4)
ADDITIONAL REQUIREMENTS
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
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. Emissions from this point shall be released from an unobstructed vertical stack with a
minimum height of 14 feet above ground level.
17. This facility shall be completely enclosed by a fence line and posted with no trespassing
signs that preclude public access to this site as described in the modeling analysis for
this facility. This requirement is imposed as a result of the modeled ambient air NOx
impacts that result from the facility operations. (Reference: Regulation No. 3, Part B,
Section II1.B.5)
18. 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.
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.
AIRS ID: 123/0057/029 Page 6 of 10
Kerr-McGee/Anadarko ..2trolz,..m oratik '
Permit No. 10WE1587 Co . *lc) I rtme;:i of Public Health and Environment
Issuance 1 it Air Pollution Control Division
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
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
AIRS ID: 123/0057/029 Page 7 of 10
Kerr-McGee/Anadarko trot; gym •rati,Ak
Permit No. 10WE1587 .„ Co o I . rtme of Public Health and Environment
Issuance 1 Air Pollution Control Division
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Kerr-McGee Gathering for one
emergency back-up power generator.
AIRS ID: 123/0057/029 Page 8 of 10
;f
sy
Kerr-McGee/Anadarko trot ,` m� • � •rati�
Permit No. 10WE1587 C•'= to I . rtme of Public Health and Environment
Issuance 1 ` „ M Air Pollution Control Division
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/100102agcccommonprovisionsreq.pdf.
3) The emission levels contained in this permit are based on the following emission factors:
Point 029:
Emission Factors - Emission Factors—
Uncontrolled Controlled
CAS Pollutant Ib/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr
NOx 2.0854 5.8400 2.0854 5.8400
CO 0.1714 0.4800 0.1714 0.4800
VOC 0.0036 0.0100 0.0036 0.0100
PM10 0.0573 0.1605 0.0573 0.1605
PM2.5 0.0556 0.1557 0.0556 0.1557
TSP 0.0697 0.1952 0.0697 0.1952
Emission factors are based on a Brake-Specific Fuel Consumption Factor of 6174 Btu/hp-hr, a
site-rated horsepower value of 900, and a fuel heat value of 130128 Btu/gal.
Emission Factor Sources:
CAS Pollutant Uncontrolled EFSource Controlled EF Source
NOx Manufacturer's Data No control device.
CO Manufacturer's Data No control device.
VOC Manufacturer's Data No control device.
PM10 AP-42, Table 3.4-1 through 4 (10/1996) No control device.
PM2.5 AP-42, Table 3.4-1 through 4 (10/1996) No control device.
TSP AP-42, Table 3.4-1 through 4 (10/1996) No control device.
4) 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 February 3, 2015.
A revised APEN shall be submitted no later than 30 days before the five-year term expires.
5) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Major Source of NOX, CO, VOC, and HAP
NANSR Major Source of NOX and VOC
PSD Major Source of CO
AIRS ID: 123/0057/029 Page 9 of 10
Kerr-McGee/Anadarko ` .trol m ,`r. •rate1"
Permit No. 10WE1587 • C. to rtme of Public Health and Environment
issuance 1 Air Pollution Control Division
MACT ZZZZ Major Source Requirements: Applicable
6) 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
7) 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: 123/0057/029 Page 10 of 10
STATE OF COLORADO
F�F'_COO
�_ 8
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT ab
AIR POLLUTION CONTROL DIVISION +�
TELEPHONE: (303) 692-3150 .,876.
CONSTRUCTION PERMIT
PERMIT NO: 1 OWE1 071
Issuance 1
DATE ISSUED:
ISSUED TO: Kerr-McGee/Anadarko Petroleum Corporation
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Natural gas processing facility, known as the Ft. Lupton Gas Plant, located in 16116 Weld
County Rd 22, 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 G3616 LE, Serial Number
BLB00539, natural gas-fired, turbo-charged, 4SLB
EU-104 028 reciprocating internal combustion engine, site rated at 4735
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 G3616 LE 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 thirty 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
AIRS ID: 123/0057/028 Page 1 of 18
NGEngine Version 2009-1
Kerr-McGee/Anadarko ` trol= m k o '.ratir
Permit No. 10WE1071 C., o ' .<rtmei of Public Health and Environment
Issuance 1 ,. Air Pollution Control Division
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).
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 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
6. 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)
Annual Limits:
Facility AIRS Tons per Year
Emission Type
Equipment ID Point NOx VOC CO
EU-104 028 32.0 19.2 8.0 Point
See "Notes to Permit Holder #4 for information on emission factors and methods used to
calculate limits.
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.
7. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control. This
emissions control system shall be capable of reducing uncontrolled emissions of volatile
organic compounds and carbon monoxide from the unit to the emission levels listed in
Condition 6, 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
8. This source shall be limited to the following maximum consumption, processing and/or
operational rates as listed below. Monthly records of the actual consumption rate shall
be maintained by the applicant and made available to the Division for inspection upon
request. (Reference: Regulation 3, Part B, II.A.4)
AIRS ID: 123/0057/028 Page 2 of 18
Kerr-McGee/Anadarko •utrol , m* . .rati� fi
Permit No. 10WE1071 C• ao " • rtme x of Public Health and Environment
Issuance 1 Air Pollution Control Division
Process/Consumption Limits
Facility
AIRS Equipment Point Annual
Process Parameter Limit
ID
EU-104 028 Consumption of natural gas as a fuel 278'87
MMscf/yr
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
9. The permit number and AIRS ID number shall be marked on the subject equipment for
ease of identification. (Reference: Regulation Number 3, Part B, !II.E.) (State only
enforceable).
10. 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.)
11. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
12. 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.
13. 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.
AIRS ID: 123/0057/028 Page 3 of 18
Kerr-McGee/Anadarko ` trol= m •ratiou
Permit No. 10WE1071 Cs Aq : o •' • rtme >a of Public Health and Environment
Issuance 1 � Air Pollution Control Division
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.
• 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.
AIRS ID: 123/0057/028 Page 4 of 18
1
Kerr-McGee/Anadarko Fptrol..`.m .rate t
Permit No. 10WE1071 C• ao •- • .rtme' of Public Health and Environment
Issuance 1 -, , ` „r „ y, Air Pollution Control Division
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
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
AIRS ID: 123/0057/028 Page 5 of 18
Kerr-McGee/Anadarko trol =m • ' •ratif
Permit No. 10WE1071 _ C. _,o I •. rtme .; of Public Health and Environment
Issuance 1 „may .. Air Pollution Control Division
(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).
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(c) - If you are operating a new or reconstructed stationary RICE
which fires landfill gas or digester gas equivalent to 10 percent or more of the
gross heat input on an annual basis, you must keep the records of your daily
fuel usage monitors.
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
AIRS ID: 123/0057/028 Page 6 of 18
Kerr-McGee/Anadarko mfr,o orati cat g
Permit No. 10WE1071 C, = ao i •5rtme I of Public Health and Environment
Issuance 1 Air Pollution Control Division
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
14. 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
15. A source initial compliance test shall be conducted on emissions point 028 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
Periodic Testing Requirements
16. This engine is subject to the periodic testing requirements of 40 C.F.R Part 63, Subpart
ZZZZ.
17. 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
18. 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.
AIRS ID: 123/0057/028 Page 7 of 18
xrt mxvy, x. •
Kerr-McGee/Anadarko qrolt. m . . orati,
Permit No. 10WE1071 C. a ao •:• rtme of Public Health and Environment
Issuance 1 Air Pollution Control 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.
19. Emissions from this point shall be released from an unobstructed vertical stack with a
minimum height of 52.8 feet above ground level.
20. This facility shall be completely enclosed by a fence line and posted with no trespassing
signs that preclude public access to this site as described in the modeling analysis for
this facility. This requirement is imposed as a result of the modeled ambient air NOx
impacts that result from the emissions from this source. (Reference: Regulation No. 3,
Part B, Section 111.6.5)
21. 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.
GENERAL TERMS AND CONDITIONS:
22. 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.
23. 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.
24. 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
AIRS ID: 123/0057/028 Page 8 of 18
asti
Kerr-McGee/Anadarko 3trol�) m 'o rate,r;
Permit No. 10WE1071 rtmet of Public Health and Environment
Issuance 1 $ n ' Air Pollution Control Division
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.
25. 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.
26. 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.
27. 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.
28. 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 to Kerr-McGee Gathering, LLC.
AIRS ID: 123/0057/028 Page 9 of 18
m ¢k ' i r
Kerr-McGee/Anadarko `i,,trolt m . *orate l
Permit No. 10WE1071 C• '";.o It • rtme of Public Health and Environment
Issuance 1 r; Air Pollution Control Division
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 36578 Yes 8779
Acetaldehyde 75070 A 2341 Yes 2341
Acrolein 107028 A 1439 Yes 1439
028 Methanol 67561 C 700 No 700
n-Hexane 110543 C 311 No 311
Benzene 71432 A 123 Yes 123
Toluene 108883 C 114 No 114
4) The emission levels contained in this permit are based on the following emission factors:
Point 028:
Emission Factors - Emission Factors —
Uncontrolled Controlled
CAS Pollutant Ib/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr
NOx 0.2286 0.7000 0.2286 0.7000
CO 0.8198 2.5100 0.0574 0.1757
VOC 0.1960 0.6000 0.1372 0.4200
5000 Formaldehyde 0.1306 0.4000 0.0314 0.0960
75070 Acetaldehyde 0.0084 0.0256 0.0084 0.0256
107028 Acrolein 0.0051 0.0157 0.0051 0.0157
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 0.0013 0.0004 0.0013
108883 Toluene 0.0004 0.0012 0.0004 0.0012
Emission factors are based on a Brake-Specific Fuel Consumption Factor of 6750 Btu/hp-hr, a
site-rated horsepower value of 4735, and a fuel heat value of 1004 Btu/scf.
AIRS ID: 123/0057/028 Page 10 of 18
Kerr-McGee/Anadarko ` trol Flm1I•ratis
Permit No. 10WE1071 Co. —,4lo rtme 4 of Public Health and Environment
Issuance 1 ' f«.. Air Pollution Control Division
Emission Factor Sources:
CAS Pollutant Uncontrolled EFSource Controlled EF Source
NOx Manufacturer's Data Eng. Judgement
CO Manufacturer's Data Eng. Judgement
VOC Manufacturer's Data Eng. Judgement
5000 Formaldehyde Manufacturer's 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
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 February 3, 2015.
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, CO, VOC, and HAP
NANSR Major Source of NOX and VOC
PSD Major Source of CO
MACT ZZZZ Major Source Requirements: 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/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A— Subpart KKKK
NSPS Part 60, Appendixes Appendix A—Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
AIRS ID: 123/0057/028 Page 11 of 18
Kerr-McGee/Anadarko ` -trol m •rati
Permit No. 10WE1071 C. . +o rtme of Public Health and Environment
Issuance 1 Air Pollution Control Division
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:ThAnArw.cdphe.state.co.us/ap/oilgaspermitting.html
AIRS ID: 123/0057/028 Page 12 of 18
ANuts
Kerr-McGee/Anadarko trot m prat
Permit No. 10WE1071 . C. o • • rtme of Public Health and Environment
Issuance 1 , k m Air Pollution Control Division
ATTACHMENT A:
ALTERNATIVE OPERATING SCENARIOS
RECIPROCATING INTERNAL COMBUSTION ENGINES
December 10, 2008
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.
A.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 A.1.2 and make them available to
the Division upon request.
A.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 emissions from the temporary replacement engine comply with the emission
limitations for the existing permitted engine as determined in section A.2. Measurement of emissions
from the temporary replacement engine shall be made as set forth in section A.2.
A.1.2 The permittee may permanently replace the existing compressor engine with an engine that is of
the same manufacturer, model and horsepower without modifying this permit so long as the emissions
from the permanent replacement engine comply with 1) the permitted annual emission limitations for the
AIRS ID: 123/0057/028 Page 13 of 18
•Kerr-McGee/Anadarko trol;'=.m .''a.rati
Permit No. 10WE1071 C. �, sao ra • rtme,k.. of Public Health and Environment
Issuance 1 Air Pollution Control Division
existing engine, 2) any permitted short-term emission limitations for the existing permitted engine, and 3)
the applicable emission limitations as set forth in the Applicability Report submitted to the Division with
the Air Pollutant Emissions Notice (APEN) for the replacement engine (see
http://www.cdphe.state.co.us/ap/oilgaspermitting.html for example applicability report formats).
Measurement of emissions from the permanent replacement engine and compliance with the applicable
emission limitations shall be made as set forth in section A.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/oilaaspermittinq.html.
This submittal shall be accompanied by a certification from a person legally authorized to act on behalf of
the source 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.
A.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: 123/0057/028 Page 14 of 18
Kerr-McGee/Anadarko ' trol& m �ratiIt ,
Permit No. 10WE1071 rC, £ ?o '° : rtme of Public Health and Environment
Issuance 1 * y,.,, ` Air Pollution Control Division
All portable analyzer testing required by this permit shall be conducted using the Division's Portable
Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's website at:
http://www.cdphe.state.co.us/ap/down/portanalyzeproto.pdf
Results of the portable analyzer tests shall be used to monitor the compliance status of this unit.
For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the
tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or
year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation
the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever
applies.
For comparison with a short-term limit that is either input based (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.
A.3 Applicable Regulations for Permanent Engine Replacements
A.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B § II.D.2
All permanent replacement engines that are located in an area that is classified as
attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT)
for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC
and NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for
which the area is in attainment/maintenance or nonattainment, except as follows:
In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of
emissions and to NOX and SO2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds
40 tons/yr.
For purposes of this AOS, the following shall be considered RACT for natural-gas fired reciprocating
internal combustion engines:
VOC: The emission limitations in NSPS JJJJ
CO: The emission limitations in NSPS JJJJ
NOX: The emission limitations in NSPS JJJJ
SO2: Use of natural gas as fuel
PM10: Use of natural gas as fuel
As defined in 40 CFR Part 60 Subparts GG (§ 60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains
20.0 grains or less of total sulfur per 100 standard cubic feet.
AIRS ID: 123/0057/028 Page 15 of 18
Kerr-McGee/Anadarko ,trot= m' t•ratili
Permit No. 10WE1071 C4 P •trtme of Public Health and Environment
Issuance 1 Air Pollution Control Division
A.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E
(State-Only conditions).
Control Requirements: Section XVI
Any permanent replacement engine located within the boundaries of an ozone nonattainment area is
subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified
below:
Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non-
selective catalyst and air fuel controller to reduce emission.
Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation
catalyst to reduce emissions.
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 A.1.2.
Emission Standards: Section XVII.E— State-only requirements
Any permanent engine that is either constructed or relocated to the state of Colorado from another state,
after the date listed in the table below shall operate and maintain each engine according to the
manufacturer's written instructions or procedures to the extent practicable and consistent with
technological limitations and good engineering and maintenance practices over the entire life of the
engine so that it achieves the emission standards required in the table below:
Max Engine HP Construction or Emission Standards in G/hp-hr
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
500≤Hp July 1, 2007 2.0 4.0 1.0
July 1, 2010 1.0 2.0 0.7
The source shall submit copies of the relevant Applicability Reports required under Condition A.1.2
A.3.3 NSPS for spark ignition internal combustion engines: 40 CFR 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 40 CFR 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 A.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 A.2, if approved in
advance by the Division, provided that such test is conducted within the time frame specified in Condition
A.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
AIRS ID: 123/0057/028 Page 16 of 18
Kerr-McGee/Anadarko P trol_ tm ` o orati4
Permit No. 10WE1071 " Cr='�'.: o • • rtme of Public Health and Environment
Issuance 1 Air Pollution Control Division
the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes
equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ
requirements).
However, as of November 1, 2008 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.
A.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ
A.3.4.1 Area Source for HAPs
A permanent replacement engine located at an area source that commenced construction or
reconstruction after June 12, 2006 as defined in § 63.2, will meet the requirements of 40 CFR Part 63,
Subpart ZZZZ by meeting the requirements of 40 CFR Part 60, Subpart JJJJ. 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 A.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 A.2, if approved in advance by the Division,
provided that such test is conducted within the time frame specified in Condition A.2.
A.3.4.2 Major source for HAPs
A permanent replacement engine that is located at major source is subject to the requirements in 40 CFR
Part 63 Subpart ZZZZ as follows:
Existing, new or reconstructed spark ignition 4 stroke rich burn engines with a site rating of more
than 500 hp are subject to the requirements in 40 CFR Part 63 Subpart ZZZZ.
New or reconstructed (construction or reconstruction commenced after 12/19/02) 2 stroke and 4
stroke lean burn engines with a site rating of more than 500 hp are subject to the requirements in
40 CFR Part 63 Subpart ZZZZ.
New or reconstructed (construction or reconstruction commenced after 6/12/06) 4 stroke lean
burn engines with a site rating of greater than or equal to 250 but less or equal to 500 hp and
were manufactured on or after 1/1/08 are subject to the requirements in 40 CFR Part 63 Subpart
ZZZZ.
New or reconstructed (construction or reconstruction commenced after 6/12/06) 2 stroke lean
burn or 4 stroke rich burn engines with a site rating of 500 hp or less will meet the requirements of
40 CFR 63, Subpart ZZZZ by meeting the requirements of 40 CFR 60, Subpart JJJJ.
New or reconstructed (construction or reconstruction commenced after 6/12/06) 4 stroke lean
burn engines with a site rating of less than 250 hp will meet the requirements of 40 CFR 63,
Subpart ZZZZ by meeting the requirements of 40 CFR 60, Subpart JJJJ.
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 A.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
AIRS ID: 123/0057/028 Page 17 of 18
Kerr-McGee/Anadarko trop m " • •rata
Permit No. 10WE1071 C. .o • •;rtme ,_ of Public Health and Environment
Issuance 1 Air Pollution Control Division
under Condition A.2, if approved in advance by the Division, provided that such test is conducted
within the time frame specified in Condition A.2.
A.3.5 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: 123/0057/028 Page 18 of 18
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