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Home My WebLink About20112615 STATE OF COLORADO John W.Hickenlooper,Governor Christopher E.Urbina,MD, MPH oF•cot oR Executive Director and Chief Medical Officer Dedicated to protecting and improving the health and environment of the people of Colorado .- * 4300 Cherry Creek Dr.S. Laboratory Services Division "r , Denver,Colorado 80246-1530 8100 Lowry Blvd. 1876 Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department Located in Glendale,Colorado (303)692-3090 of Public Health http://www.cdphestate.co.us and Environment September 27, 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 September 30, 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-B I 4300 Cherry Creek Drive South Denver, CO 80246-1530 Attention: Ellen Evans Regards, .)_ t Ellen Evans Public Notice Coordinator Stationary Sources Program Air Pollution Control Division e Iu tor l r 2 i0 - d-l/ 011-2615 NOTICE OF REQUEST FOR SYNTHETIC MINOR PERMIT FOR NATURAL GAS COMPRESSOR STATION • BY Kerr-McGee/Anadarko Petroleum Corporation CONTENTS 1 . PUBLIC NOTICE 2. PRELIMINARY ANALYSIS 3. AIR POLLUTANT EMISSION NOTICES 4. DRAFT PERMIT PREPARED BY: STEPHANIE CHAOUSY 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 cod\ P ' Executive Director and Chief Medical Officer fir; r �'b Dedicated to protecting and improving the health and environment of the people of Colorado * . 4300 Cherry Creek Dr.S. Laboratory Services Division , , Denver,Colorado 80246-1530 8100 Lowry Blvd. sve� 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 September 27,2011, published September 30, 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 modify and operate an oil and natural gas compression facility known as the Hambert Compressor Station. The modification includes the removal of two (2) existing 4- stroke rich burn engines, addition of three (3) new 4-stroke rich burn engines and one (1) TEG dehydrator. This source is located at 18450 Weld County Road 35, Hambert, Colorado in Section 36 of Township 4 North, Range 66 West in Weld County. The source would be considered a major source of air pollutants subject to Non- Attainment New Source Review(NANSR)and Maximum Achievable Control Technology(MACT)requirements if the operator did not install emissions controls and accept Federally enforceable emissions limits in the proposed permit. Since the operator will accept emissions limits less than 100 tons per year for each criteria pollutant and less than 10 tons per year any single hazardous air pollutant(HAP) and 25 tons per year total combined HAP,this source will be considered a synthetic minor source not subject to NANSR or MACT review. The source will have permitted emissions less than 100 tons per year for criteria pollutants and will be considered a synthetic minor source subject to Title V Operating Permit requirements. As such, this permit is subject to public comment per Regulation 3, Part B, Section III.C.1.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: Stephanie Chaousy, PE 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 - NG RICE Company Name Kerr-McGee/Anadarko Petroleum Corporation Permit No. 10WE2360 Facility Name Hambert Compressor Station AIRS 123/0059/007 Facility Location 18450 Weld County Road 35, Hambert, CO Review Date 07/26/2011 Facility Equipment ID EU-51 Permit Engineer Stephanie Chaousy,PE Requested Action New permit/newly reported emission, Request MOD- change permit limit Issuance No. 1 Emission Point Description One(1)Caterpillar, Model G3606 LE, Serial Number TBD, natural gas-fired,turbo-charged, 4SLB 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. Natural Gas Consumption Requested (mmscf/yr) 130.34 Requested(mmscf/m) 11.07 Fuel Heat Value(btu/scf) 905 BSCF(Btu/hp-hr) 7586 Emission Factor Sources Uncontrolled Controlled NOx Manufacturer Manufacturer VOC Subpart JJJJ Subpart JJJJ CO Manufacturer Manufacturer _ Formaldehyde Manufacturer Manufacturer 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 AP-42 AP-42 Point Summary of Criteria Emissions (tpy) Uncontrolled Controlled Proposed Control Requested Requested PTE Efficiency NOx 12.0 12.0 12.0 0.0% VOC 12.0 12.0 12.0 0.0% CO 42.8 4.3 42.8 90.0% SOx 0.0 0.0 0.0 0.0% TSP 0.6 0.6 0.6 0.0% PM10 0.6 0.6 0.6 0.0% PM2.5 0.6 0.6 0.6 0.0% Total HAPs* 0.0 0.0 8.0 65.1% "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 13712 3291 13712 76.0% Acetaldehyde 986 986 986 • A0.0% Acrolein 606 606 606 0.0% Methanol * 295 0.0% n-Hexane * * 131 0.0% Benzene 52 52 52 0.0% Toluene * * 48 0.0% *Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minimus Permitting Requirements The Division believes this source will comply with applicable standards and regulations of the Ambient Air Impacts Commission Public Comment Public Comment Required (Facility project totaling 4 new engines and 1 TEG dehydrator) New/Recon 4SLB over 500 HP located at a(n)Area Source MACT ZZZZ Area MACT ZZZZ applies to RICEs that have a manufacturer date new/reconstruction on or after June 12, 2006. The manufacturer date was not provided, but the Operator indicated that this engine is new and it will subject to area source MACT ZZZZ. It is subject to NSPS JJJJ requirements. Reg &XVII.E NOx: 1.0 CO: 2.0 VOC: 0.7 Standards (g/hp-hr) Reg 7 XVI.B(Ozone NAA Yes requirements)applies? Since this source is subject to area source MACT ZZZZ, it will need to be determined if it is subject to NSPS JJJJ NSPS JJJJ. A manufacturer date was not provided on the APEN, but Operator has indicated that this engine is new, and therefore, will be subject to NSPS JJJJ requirements. Comments/Notes APEN to replace previously requested equipment with one (1) new Caterpillar G3606 LE engine. Summary of Preliminary Analysis - NG RICE Company Name Kerr-McGee/Anadarko Petroleum Corporation Permit No. 10WE2361 Facility Name Hambert Compressor Station AIRS 123/0059/008 Facility Location 18450 Weld County Road 35, Hambert, CO Review Date 07/26/2011 Facility Equipment ID EU-52 Permit Engineer Stephanie Chaousy,PE Requested Action New permit/newly reported emission, Request MOD- change permit limit Issuance No. - 1 Emission Point Description One(1) Caterpillar, Model G3606 LE, Serial Number TBD, natural gas-fired, turbo-charged,4SLB 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. Natural Gas Consumption Requested (mmscf/yr) 130.34 Requested(mmscf/m) 11.07 Fuel Heat Value(btu/scf) 905 BSCF (Btu/hp-hr) 7586 Emission Factor Sources Uncontrolled Controlled NOx Manufacturer Manufacturer VOC Subpart JJJJ Subpart JJJJ CO Manufacturer Manufacturer Formaldehyde Manufacturer Manufacturer 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 AP-42 AP-42 Point Summary of Criteria Emissions(tpy) • Uncontrolled Controlled Proposed Control Requested Requested PTE Efficiency NOx 12.0 12.0 12.0 0.0% VOC 12.0 12.0 12.0 0.0% CO 42.8 4.3 42.8 90.0% SOx 0.0 0.0 0.0 0.0% TSP 0.6 0.6 0.6 0.0% PM10 0.6 0.6 0.6 0.0% PM2.5 0.6 0.6 0.6 0.0% Total HAPs* 0.0 0.0 8.0 65.1% *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 13712 3291 13712 76 0% Acetaldehyde 986 986 986 0.0% Acrolein 606 606 606 0.0% Methanol * 295 0.0% n-Hexane * * 131 0.0% Benzene 52 52 52 0.0% Toluene * * 48 0.0% 'Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minimus Permitting Requirements The Division believes this source will comply with applicable standards and regulations of the Ambient Air Impacts Commission Public Comment Public Comment Required (Facility project totaling 4 new engines and 1 TEG dehydrator) New/Recon 4SLB over 500 HP located at a(n) Area Source MACT ZZZZ Area MACT ZZZZ applies to RICEs that have a manufacturer date new/reconstruction on or after June 12, 2006. The manufacturer date was not provided, but the Operator indicated that this engine is new and it will subject to area source MACT ZZZZ. It is subject to NSPS JJJJ requirements. Reg &XVII.E NOx: 1.0 CO: 2.0 VOC: 0.7 Standards (g/hp-hr) Reg 7 XVI.B(Ozone NAA Yes requirements)applies? Since this source is subject to area source MACT ZZZZ, it will need to be determined if it is subject to NSPS JJJJ NSPS JJJJ. A manufacturer date was not provided on the APEN, but Operator has indicated that this engine is new, and therefore, will be subject to NSPS JJJJ requirements. Comments/Notes APEN to replace previously requested equipment with one (1) new Caterpillar G3606 LE engine. Summary of Preliminary Analysis - NG RICE Company Name Kerr-McGee/Anadarko Petroleum Corporation Permit No. 10WE2362 Facility Name Hambert Compressor Station AIRS 123/0059/009 Facility Location 18450 Weld County Road 35, Hambert, CO Review Date 07/26/2011 Facility Equipment ID EU-53 Permit Engineer Stephanie Chaousy, PE Requested Action New permit newly reported emission, Request MOD- change permit limit Issuance No. 1 Emission Point Description One (1) Caterpillar, Model G3606 LE, Serial Number TBD, natural gas-fired, turbo-charged, 4SLB 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. Natural Gas Consumption Requested (mmscf/yr) 130.34 Requested(mmscf/m) 11.07 Fuel Heat Value(btulscf) 905 BSCF (Btu/hp-hr) 7586 Emission Factor Sources Uncontrolled Controlled NOx Manufacturer Manufacturer VOC Subpart JJJJ Subpart JJJJ CO Manufacturer Manufacturer Formaldehyde Manufacturer Manufacturer 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 AP-42 AP-42 Point Summary of Criteria Emissions (tpy) Uncontrolled Controlled Proposed Control Requested Requested PTE Efficiency NOx 12.0 12.0 12.0 0.0% VOC 12.0 12.0 12.0 0.0% CO 42.8 4.3 42.8 90.0% SOx 0.0 0.0 0.0 0.0% TSP 0.6 0.6 0.6 0.0% PM10 0.6 0.6 0.6 0.0% PM2.5 0.6 0.6 0.6 0.0% Total HAPs' 0.0 0.0 8.0 65.1% *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 Controlled • Proposed Control HAP Name Requested Requested PTE Efficiency Formaldehyde 13712 3291 13712 76 0% Acetaldehyde 986 986 986 0.0% Acrolein 606 606 606 0.0% Methanol * * 295 0.0% n-Hexane * 131 0.0% Benzene 52 52 52 0.0% Toluene * 48 0.0% *Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minimus Permitting Requirements The Division believes this source will comply with applicable standards and regulations of the Ambient Air Impacts Commission Public Comment Public Comment Required (Facility project totaling 4 new engines and 1 TEG dehydrator) New/Recon 4SLB over 500 HP located at a(n)Area Source MACT ZZZZ Area MACT ZZZZ applies to RICEs that have a manufacturer date new/reconstruction on or after June 12, 2006. The manufacturer date was not provided, but the Operator indicated that this engine • is new and it will subject to area source MACT ZZZZ. It is subject to NSPS JJJJ requirements. Reg &XVII.E Standards (g/hp-hr) NOx: 1.0 CO: 2.0 VOC: 0.7 Reg 7 XVI.B(Ozone NAA Yes requirements)applies? Since this source is subject to area source MACT ZZZZ, it will need to be determined if it is subject to NSPS JJJJ NSPS JJJJ. A manufacturer date was not provided on the APEN, but Operator has indicated that this engine is new, and therefore, will be subject to NSPS JJJJ requirements. Comments/Notes APEN to replace previously requested equipment with one (1) new Caterpillar G3606 LE engine. Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Kerr-McGee/Anadarko Petroleum Corporation Permit Number: 11WE1189 Source Location: 18450 Weld County Rd 35, Hambert, CO/Section 36, T4N, R66W,Weld County (Non-attainment) Equipment Description: 30 MMSCFD TEG dehydrator with two (2) pumps AIRS ID: 123-0059-011 Date: March 29, 2011; New APEN received: 7/13/11 Review Engineer: Stephanie Chaousy, PE Control Engineer: Chris Laplante Section 2—Action Completed Grandfathered 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? Yes X 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 I emailed Don Anderson on 3/29/11: the above, when did you mail an • The uncontrolled emissions on the APEN are only the Information Request letter to the "uncontrolled regenerator emissions" and I think that the source? uncontrolled emissions are a combination of the"uncontrolled regenerator emissions" and the"flash tank off gas." I emailed Don for clarification. Don emailed me back on 4/4/11 confirming my analysis. I emailed Don Anderson on 4/4/11: • Since he agreed with the uncontrolled emission limits, I emailed him revised emission factors. Did not get a confirmation from Don before he left Kerr-McGee, so I forwarded the email chain to Gliceria Rodriguez-Canessa on 4/26/11. Gliceria confirmed the emission factors on 4/26/11. I emailed Gliceria Rodriguez-Canessa on 4/26/11: • Requested a new inventory form (APCD-102). Gliceria provided a new facility inventory via email on 4/26/11. • The manufacturer specification sheet for the thermal oxidizer was not included with the dehydrator package, and I would like to see it so that I can confirm the minimum combustion chamber temperature on the O&M plan. Kerr-McGee/Anadarko requested to modify their application so that they could be under modeling requirement thresholds. I received a new application on 7/13/11. On what date was this November 12, 2010; New APEN received 7/13/11 application complete? Page 1 Section 4—Source Description _ AIRS Point Equipment Description One (1)Triethylene glycol (TEG) natural gas dehydration unit(manufacturer, model, serial number: to be determined) with a design capacity of 30 MMscf per day. This emissions 011 unit is equipped with two (2) electric-glycol pump with a design capacity of 5.0 gallons per minute. "!This:irht is equipped with a flash tank, reboiler and still vent. Emissicrs from the flash tank are routed back to the plant inlet in a closed-loop system. Emissions from the still vent are routed through a condenser and then to a thermal oxidizer. 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 1II.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 011 GRI Gly-Calc v4.0 (Refer to Section 14 for calculations) Did the applicant provide actual process data for the emission inventory? X Yes No Basis for Potential to Emit (PTE) AIRS Point Process Consumption/Throughput/Production 011 10,950 MMSCF per year, 5.0 gallons per minute glycol circulation rate Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 011 10,950 MMSCF per year, 5.0 gallons per minute glycol circulation rate Basis for Permitted Emissions (Permit Limits) AIRS Point Process Consumption/Throughput/Production 011 10,950 MMSCF per year, 5.0 gallons per minute glycol circulation rate Does this source use a control device? X Yes No AIRS Point Process Control Device Description % Reduction Granted 011 01 Combustor and condenser 99 Section 6- Emission Summa (tons per year) Point NO,, VOC CO Single HAP Total HAP PTE: 011 2.4 141.7 6.5 42.9 (toluene) 96.2 Uncontrolled point 011 2.4 141.7 6.5 42.9 (toluene) 96.2 source emission rate: Controlled point 011 2.4 8.5 6.5 0.2 (benzene) 0.4 source emission rate: Page 2 Section 7—Non-Criteria / Hazardous Air Pollutants Uncontrolled Are the Controlled Emission Pollutant CAS # BIN Emission Rate emissions Ib/ r (Ib/yr) reportable? Rate( y ) Benzene 71432 A 58,439 Yes 340 Toulene 110543 C 85,728 Yes 290 Ethylbenzene 100414 C 2,883 Yes 4 Xylenes 1330207 C 40,706 Yes 52 n-Hexane 110543 C 4,551 Yes 33 Note: Regulation 3, Part A, Section II.B.3.b APEN emission reporting requirements for non-criteria air pollutants are based on potential emissions without credit for reductions achieved by control devices used by the operator. r 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 01 VOC, Regulation No.3, Part B, Section III.E Extended wet gas HAPS analysis Section 9—Source Classification Is this a new previously un-permitted source? X Yes No What is this point classification? True X Synthetic Major Minor Minor What is this facility classification? True X Synthetic Major Minor Minor Classification relates to what programs? X Title V PSD X NA NSR X MACT Is this a modification to an existing permit? Yes X No If"yes"what kind of modification? Minor Synthetic Major Minor Section 10— Public Comment Does this permit require public comment per CAQCC Regulation 3? X Yes No If"yes", for which pollutants?Why? VOC For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)? X Yes No For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)? 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 Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide Page 3 Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15-second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A(July, 011 1992)) in all subsections of Section II. A and B of this regulation. Section II.A.5 -Smokeless Flare or Flares for the Combustion of Waste Gases 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. Regulation 2—Odor Section I.A - No person, wherever located, shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are 011 measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7) or more volumes of odor free air. Regulation 3 APENs, Construction Permits, Operating Permits, PSD Part A-APEN Requirements 011 Applicant is required to file an APEN since emissions exceeds 1 ton per year VOC in a nonattainment area for ozone. Part B—Construction Permit Exemptions 011 Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 2.0 TPY threshold(Reg. 3, Part B, Section II.D.2.a) Regulation 6- New Source Performance Standards 011 None Regulation 7—Volatile Organic Compounds Is this source subject to MACT HH? (Refer to Section 14, Regulation 8-Hazardous Air Pollutants review). No Is this source subject to the exemptions under MACT HH (i.e. throughput exemption less 011 than 3 MMSCFD or benzene exemption of less than 1984 Ib/yr)? Yes Even though this source is subject to some requirements of MACT HH, it is also subject to Regulation 7 control requirements. Section XVII.D (State only enforceable). 011 Applicant is required to reduce VOC emissions from this dehydrator by at least 90% since uncontrolled VOC emissions are greater than the 15.0 TPY threshold. Regulation 8—Hazardous Air Pollutants MACT HH: If facility is MAJOR source for HAP (summation of HAPS of dehydrators and fugitives greater than 25 TPY total or 10 TPY single HAP),then all glycol dehydrators at this facility are subject to MACT NH. If facility is an area source of HAP, only TEG dehydrators are subject to MACT HH. 1.Is facility a production field facility per 63.761 (Refer to Section 14 for definition)? Yes 2.If facility is defined as a production facility, then is it a major source of HAPS when 011 summing up dehydrator and flash tank emissions? No 3.Is this facility considered MAJOR for HAPS? No 4.Is this source subject to MACT HH? No 5.WHY? This facility is an area source of HAP and MACT HH area source requirements apply to this TEG dehydrator. However, since benzene emissions from each unit will be less 1984 Ib/yr, this source is only required to calculate and keep records demonstrating that benzene emissions stay below this level. Section 13—Aerometric Information Retrieval System Coding Information Process Throughput Emission Pollutant/ Fugitive Emission Control Point Process Description limit Factor CAS# (Y/N) Factor Source - (%) 10,950 25.88 V0C No GlyCalc 4.0 99 011 01 Glycol MMSCF per Ibs/mmscf Dehydrator year with a 5.337 Benzene No GlyCalc 4.0 99 recirculation Ibs/mmscf Page 4 rate of 5 7.829 Toulene No GlyCalc 4.0 99 gpm Ibs/mmscf 0.263 Ethylbenzene No GlyCalc 4.0 99 Ibs/mmscf y y 3.717 Xylenes No GlyCalc 4.0 99 Ibs/mmscf 0.416 n-Hexane No GlyCalc 4.0 99 Ibs/mmscf SCC 31000227: Glycol Dehydrator: reboiler still stack Section 14— Miscellaneous Application Notes AIRS Point 011 Glycol Dehydrator Received modified APEN and supporting calculations on 7/13/11: In order to determine emissions, the operator used GRI GlyCALC 4.0. The source assumed the inlet gas temperature of 100°F and pressure of 900 psig. The permitted glycol recirculation rate is 5 gallons per minute. The GlyCalc model was based off of an extended gas analysis dated 12/9/10. The gas analysis was perfomed less than a year of revised submittal. An initial extended gas analysis will be required because operator is claiming 99% control from the thermal oxidizer, and should show compliance. Gly-Calc (Uncontrolled Emission factors) VOC = (128.8111*1.1*2000)/(30*365) = 25.88 lb/mmscf(matches new APEN) Benzene = (26.5631*1.1*2000)/(30*365) = 5.337 lb/mmscf(matches new APEN) Toluene = (38.9671*1.1"2000)/(30*365) = 7.829 lb/mmscf(matches new APEN) Ethylbenzene = (1.3104*1.1*2000)/(30"365) = 0.263 lb/mmscf(matches new APEN) Xylenes = (18.5028*1.1*2000)/(30*365) = 3. 717 lb/mmscf(matches new APEN) N-hexane = (2.0688*1.1*2000)/(30*365) = 0.416 lb/mmscf(matches new APEN) MACT HH includes requirements for both major and area sources of HAPs. The definition of major source for MACT HH (63.761) states: (3) For facilities that are production field facilities, only HAP emissions from glycol dehydration units and storage vessels with the potential for flash emissions shall be aggregated for a major source determination. For facilities that are not production field facilities, HAP emissions from all HAP emission units shall be aggregated for a major source determination. The following definitions from 63.761 are also needed to determine major source applicability: Production field facilities means those facilities located prior to the point of custody transfer Custody transfer means the transfer of hydrocarbon liquids or natural gas: after processing and/or treatment in the producing operations, or from storage vessels or automatic transfer facilities or other such equipment, including product loading racks, to pipelines or any other forms of transportation. For the purposes of this subpart, the point at which such liquids or natural gas enters a natural gas processing plant is a point of custody transfer. Natural gas processing plant(gas plant) means any processing site engaged in the extraction of natural gas liquids from field gas, or the fractionation of mixed NGL to natural gas products, or a combination of both. Based on the definitions above, this source qualifies as production field facility. Does this dehydrator have a reboiler? Yes If Yes, what is the reboiler rated? 0.75 mmbtu/hr Since the source has a design rate less than 5 mmbtu/hr, it is APEN-exempt (Regulation No. 3, Part A, II.D.1.k), and is therefore also exempt from construction permitting requirements (Regulation no. 3, Part B, II.D.1.a). Criteria pollutant emission levels for this unit are based on factors from AP-42, Chapter 1.4, Small Boilers < 100 MMBtu/hr(7/1998). Page 5 Facility-wide Aggregation Issues I emailed Gliceria Rodriguez-Canessa on 4/26/11 asking her questions about aggregation. She responded on 5/19/11. The answers are in italics: Does Kerr-McGee own or operate any production wells that feed into Hambert Compressor Station? If so: 1. Please provide a list of all E&P sites (well pads), compressor stations and gas plants owned or operated by Kerr-McGee that are located within a quarter mile of the Hambert compressor station. For the sites identified please provide the facility name, AIRS ID when available and the distance of the site to the Hambert compressor station. I have enclosed a spreadsheet showing the facilities located within a quarter mile from the Hambert facility. Please note that we are the majority owner in the wells, not the sole owner. I looked at the spreadsheet provided and there are 2 facilities within !4-mile of Hambert. These facilities are not solely dependent on Hambert. 2. Please provide a list of all E&P sites (well pads), compressor stations and gas plants owned or operated by Kerr-McGee that are located greater than a quarter mile of the Hambert compressor station that are dependent on the operation of the Hambert compressor station to be able to maintain the identified site operations. For the sites identified please provide the facility name, AIRS ID when available and the distance of the site to the Hambert compressor station. There are not facilities that are dependent on Hambert operation. For the purpose of this review, since these facilities are APEN-exempt and not solely dependent of Hambert, the Division believes this stationary source is properly defined for Title V and NSR considerations. 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E W W d Il m y o ≤ o O .a d v v o 5 0 o y v ,Z. c.y w o Z o q '`a6 E` 00 o c ° E ... ° `a O a Q `� « N u a O 31. ra 1. in'S C7 C., H _ c `'� U w u a i '_' 5 N 9 i. >1 v O m ,y aLi 0 ai a P4 m o �' • @ V nn Iwl n+ O `0 C 5 0 Q w .. Q,23 a if > Ca A b .5 0 N 1 m y M 0 sr L Y v '�ol o U 0 U ° y u0, o P. " 9 U g v W N C•-. Q O N U e y o m =so. a o O O s. d v ,_ w > v 2 _ N m .. m .E ! v �' $ o •o •o E _ • Q o a. o v i v o °' v cG I w o c O O c n E o• ^j a' c o f `� x U v aCi c 0 0 o v •° o,v,z p i 0 8 o U H [= Pv' > 'v, cr Q o "� a > p (o 7.; y o co • a c Y ," da9S. e a {3d J rwo k aK ry i e STATE OF COLORADO .Oc.pprp s F4 = /_?, COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 ',1876 *+ CONSTRUCTION PERMIT PERMIT NO: 1 UWE2360 Issuance 1 DATE ISSUED: ISSUED TO: Kerr-McGee/Anadarko Petroleum Corp. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural gas compression facility, known as the Hambert Compressor Station, located in 18450 Weld County Road 35, Hambert, CO, 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 G3606 LE, Serial Number TBD, natural gas-fired, turbo-charged, 4SLB reciprocating internal EU-51 007 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 G3606 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 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 AIRS ID: 123/0059/007 Page 1 of 15 NGEngine Version 2009-1 T+a. Kerr-McGee/Anadarko sW°trot .,m?: r;:. Co ` do v>pa =trit of Public Health and Environment Permit No. 10WE2360 r , Air Pollution Control Division Issuance 1 ee s r ro 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-51 007 2038 2038 728 Point Monthly limits are based on a 31-day month. Facility-wide emissions of each individual hazardous air pollutant shall be less than 1,358.9 lb/month. Facility-wide emissions of total hazardous air pollutants shall be less than 3.397.3 lb/month. Annual Limits: Facility AIRS Tons per Year Emission Type VOC CO Equipment ID Point NO. EU-51 007 12.0 12.0 4.3 Point See "Notes to Permit Holder #4 for information on emission factors and methods used to calculate limits. AIRS ID: 123/0059/007 Page 2 of 15 ter.T 71. Kerr-McGee/Anadarko trot m . Co do p rthe t of Public Health and Environment Permit No. 10WE2360 °` Air Pollution Control Division Issuance 1 Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. During the first twelve (12) months of operation, compliance with both the monthly and yearly emission limitations shall be required. After the first twelve (12) months of operation, compliance with only the yearly limitation shall be required. Compliance with the synthetic minor status of this facility shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate monthly emissions and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all emission units, requiring an APEN, at this facility. 8. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control. The oxidation catalyst shall reduce uncontrolled emissions of CO from the unit to the emission levels listed in this section, 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-51 007 Consumption of natural gas as a fuel 130.3 11.1 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). AIRS ID: 123/0059/007 Page 3 of 15 Kerr-McGee/Anadarko ''44trol Co ii:,do t of Public Health and Environment Permit No. 10WE2360 '. r. Air Pollution Control Division • Issuance 1 11. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.1. & 4.) 12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 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. 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 007 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 Periodic Testing Requirements 16. 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 17. The operator shall have 30 days after the start-up of Points 007, 008 and 009 to cancel the following permits: Permit No. AIRS ID Notes 96WE216-1 123/0059/002 Engine: This equipment will be removed and the AIRS ID: 123/0059/007 Page 4 of 15 rtrat Kerr-McGee/Anadarko Petrol im2V o . Coa,'do Cp merit of Public Health and Environment Permit No. 10WE2360 � '"`� ,., Air Pollution Control Division Issuance 1 r.stt, point will be canceled. 96WE216-2 123/0059/003 Engine: This equipment will be removed and the point will be canceled. 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. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A. The APEN shall include the specific manufacturer, model. and serial number and horsepower of the permanent replacement engine, the appropriate APEN filing fee and a cover letter explaining that the permittee is exercising an alternative-operating scenario and is installing a permanent replacement engine. 19. Operating Permit (OP) requirements shall apply to this source at any such time that the facility wide potential to emit equals or exceeds the major source level. Once the facility wide potential to emit equals or exceeds the major source level a Title V operating permit application shall be submitted in accordance with the requirements in Regulation No. 3, Part C. 20. 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) 21. MACT Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in AIRS ID: 123/0059/007 Page 5 of 15 Kerr-McGee/Anadarko trot `` m Col?*do p t of Public Health and Environment Permit No. 10WE2360 - Air Pollution Control Division z Issuance 1 any permit limitation and shall be subject to all appropriate applicable requirements of that Subpart on the date as stated in the rule as published in the Federal Register. (Reference: Regulation No. 8, Part E) GENERAL TERMS AND CONDITIONS: 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 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, AIRS ID: 123/0059/007 Page 6 of 15 Kerr-McGee/Anadarko ;trot m' o 6. Co '"ado L ≥pa m t cif Public Health and Environment Permit No. 10WE2360 n Air Pollution Control Division Issuance 1 M .t" civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Stephanie Chaousy, PE Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance New engines (Points 007, 008 and 009) replacing Points 002 and 003. Decrease in NOx emissions. Source at synthetic minor facility. AIRS ID: 123/0059/007 Page 7 of 15 Kerr-McGee/Anadarko a trot i, m- • 'j. Co to:qdo p m t o Public Health and Environment Permit No. 10WE2360 a^1 Air Pollution Control Division Issuance 1 _ e. 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 50000 A 13,712 Yes 3291 Acetaldehyde 75070 A 986 Yes 986 Acrolein 107028 A 606 Yes 606 007 Methanol 67561 C 295 No 295 n-Hexane 110543 C 131 No 131 Benzene 71432 A 52 Yes 52 Toluene 108883 C 48 No 48 4) The emission levels contained in this permit are based on the following emission factors: Point 007: Emission Factors - Emission Factors— Uncontrolled Controlled CAS Pollutant lb/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr NOx 0.2034 0.70 0.2034 0.70 CO 0.7265 2.5 0.0727 0.25 VOC 0.2034 0.70 0.2034 0.70 50000 Formaldehyde 0.1162 0.40 0.0279 0.096 75070 Acetakehyde 0.0084 0.0288 0.0084 0.0288 107028 Acrolein 0.0051 0.0177 0.0051 0.0177 67561 Methanol 0.0025 0.0086 0.0025 0.0086 110543 n-Hexane 0.0011 0.0038 0.0011 0.0038 71432 Benzene 0.0004 0.0015 0.0004 0.0015 108883 Toluene 0.0004 0.0014 0.0004 0.0014 Emission factors are based on a Brake-Specific Fuel Consumption Factor of 7586 Btu/hp-hr, a site-rated horsepower value of 1775, and a fuel heat value of 905 Btu/scf. AIRS ID: 123/0059/007 Page 8 of 15 K4 Kerr-McGee/Anadarko Ff,trok..m .,, . CoQr do ≥p rn it Of Public Health and Environment Permit No. 10WE2360 Air Pollution Control Division Issuance 1 Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer Manufacturer CO Manufacturer Manufacturer VOC Subpart JJJJ Subpart JJJJ 50000 Formaldehyde Manufacturer Manufacturer 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 7/12/2016. 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 engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January 18, 2008 Federal Register posting - effective March 18, 2008). The January 18, 2008 amendments to include requirements for area sources and engines < 500 hp located at major sources have not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 8. A copy of the complete subpart is available on the EPA website at: http://www.epa.gov/ttn/atw/area/fr18ia08.pdf Additional information regarding area source standards can be found on the EPA website at: http://www.epa.qov/ttn/atw/area/arearules.html 8) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source CO, VOC, Benzene, Toluene, Xylenes, Formaldehyde, Total HAPS NANSR Synthetic Minor Source CO, VOC, Benzene, Toluene, Xylenes, Formaldehyde, Total HAPS MACT HH Area Source Requirements: Applicable (Benzene exemption) MACT ZZZZ Area Source Requirements: Applicable 9) 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 AIRS ID: 123/0059/007 Page 9 of 15 Kerr-McGee/Anadarko F : trol- m r o 2 . Co . do m t o Public Health and Environment Permit No. 10WE2360 Air Pollution Control Division Issuance 1 MACT 63.1200-63.1439 Subpart EEE— Subpart PPP MACT 6.3.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN —Subpart XXXXXX 10) 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: 123/0059/007 Page 10 of 15 Kerr-McGee/Anadarko atrol1 ml) Coivado m 't of Public Health and Environment Permit No. 10WE2360 1= wti\ Air Pollution Control Division Issuance 1 „�- - a, 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: 123/0059/007 Page 11 of 15 Kerr-McGee/Anadarko tttrol ym . Colic do 0 . m;flit of Public Health and Environment Permit No. 10WE2360 M Air Pollution Control Division Issuance 1 existing engine, 2) any permitted short-term emission limitations for the existing permitted engine, and 3) the applicaole 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/oilgaspermittinq.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. 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/oilgaspermittinq.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. 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. 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. AIRS ID: 123/0059/007 Page 12 of 15 Kerr-McGee/Anadarko '7 trot am: . ,. Co do 1pp,, m 't of Public Health and Environment Permit No. 10WE2360 Air Pollution Control Division »c Issuance 1 m3„ 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. 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. 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. AIRS ID: 123/0059/007 Page 13 of 15 AA Kerr-McGee/Anadarko t �trol m , • . Co. kdo t o Public Health and Environment Permit No. 10WE2360 Air Pollution Control Division Issuance 1 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: 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 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 prcivisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ requirements). However, as of 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 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. A.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ AIRS ID: 123/0059/007 Page 14 of 15 'iiHrtivis- ire" Kerr-McGee/Anadarko F trot imyt o Co.t do E}partme¢it of Public Health and Environment kg Permit No. 10WE2360 Air Pollution Control Division Issuance 1 �}fig, , n x 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 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: 123/0059/007 Page 15 of 15 `1 tx 1 �y Ga STATE OF COLORADO OF COO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT y` AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 s 416* CONSTRUCTION PERMIT PERMIT NO: 1 0WE2361 Issuance 1 DATE ISSUED: ISSUED TO: Kerr-McGee/Anadarko Petroleum Corp. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural gas compression facility, known as the Hambert Compressor Station, located in 18450 Weld County Road 35, Hambert, CO, 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 G3606 LE, Serial Number TBD, natural gas-fired, turbo-charged, 4SLB reciprocating internal EU-52 008 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 G3606 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 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.uslap/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: 123/0059/008 Page 1 of 15 NGEngine Version 2009-1 Kerr-McGee/Anadarko *trol 'm 'o . Col do P Nritrfiefft of Public Health and Environment Permit No. 10WE2361 R rt Air Pollution Control Division Issuance 1 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; (H) discontinues construction for a period of eighteen months or more; (Hi) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) , 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The 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 N0x V0C CO EU-52 008 2038 2038 728 Point Monthly limits are based on a 31-day month. Facility-wide emissions of each individual hazardous air pollutant shall be less than 1,358.9 lb/month. Facility-wide emissions of total hazardous air pollutants shall be less than 3,397.3 lb/month. Annual Limits: Facility AIRS Tons per Year Emission Type V0C CO Equipment ID Point N0x EU-52 008 12.0 12.0 4.3 Point See "Notes to Permit Holder #4 for information on emission factors and methods used to calculate limits. AIRS ID: 123/0059/008 Page 2 of 15 r'. . Kerr-McGee/Anadarko�trol +mp,or . Col.�i tdo D,tpertme= of Public Health and Environment Permit No. 10WE2361 'tsM� r s+ Air Pollution Control Division Issuance 1 a1 , . - ..., Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less han 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. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control. The oxidation catalyst shall reduce uncontrolled emissions of CO from the unit to the emission levels listed in this section, 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-52 008 Consumption of natural gas as a fuel 130.3 11.1 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). AIRS ID: 123/0059/008 Page 3 of 15 d"b+PMe. it �,xrx:rs*ss... Kerr-McGee/Anadarko j* trot m o . Cola do ' p e o Public Health and Environment Permit No. 10WE2361 ' , Air Pollution Control Division Issuance 1 ».,.. 11. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.1. & 4.) 12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 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. 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 008 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 Periodic Testing Requirements 16. 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 17. The operator shall have 30 days after the start-up of Points 007, 008 and 009 to cancel the following permits: Permit No. AIRS ID Notes 96WE216-1 123/0059/002 Engine: This equipment will be removed and the AIRS ID: 123/0059/008 Page 4 of 15 Kerr-McGee/Anadarko arol mao J. Col 'do p nme, o Public Health and Environment Permit No. 10WE2361 Air Pollution Control Division Issuance 1 point will be canceled. 96WE216-2 123/0059/003 Engine: This equipment will be removed and the point will be canceled. 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. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine, the appropriate APEN filing fee and a cover letter explaining that the permittee is exercising an alternative-operating scenario and is installing a permanent replacement engine. 19. Operating Permit (OP) requirements shall apply to this source at any such time that the facility wide potential to emit equals or exceeds the major source level. Once the facility wide potential to emit equals or exceeds the major source level a Title V operating permit application shall be submitted in accordance with the requirements in Regulation No. 3, Part C. 20. 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) 21. MACT Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of AIRS ID: 123/0059/008 Page 5 of 15 Kerr-McGee/Anadarko itrol4Ym . Col -do B. p e o Public Health and Environment Permit No. 10WE2361 Air Pollution Control Division Issuance 1 that Subpart on the date as stated in the rule as published in the Federal Register. (Reference: Regulation No. 8, Part E) GENERAL TERMS AND CONDITIONS: 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 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. AIRS ID: 123/0059/008 Page 6 of 15 Kerr-McGee/Anadarko trot Imb . Cori do ; p -trrne (DP Public Health and Environment Permit No. 10WE2361 . -'• y, z Air Pollution Control Division Issuance 1 r r1 By: Stephanie Chaousy, PE Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance New engines (Points 007, 008 and 009) replacing Points 002 and 003. Decrease in NOx emissions. Source at synthetic minor facility. AIRS ID: 123/0059/008 Page 7 of 15 Kerr-McGee/Anadarko `4 trot , 'm 0r". Col do I p� el o'Public Health and Environment Permit No. 10WE2361 , 'y - Air Pollution Control Division Issuance 1 �.. Notes to Permit Holder: 1) The production or raw material processing limits and emission limits contained in this prrr.: ;re 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 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 50000 A 13,712 Yes 3291 Acetaldehyde 75070 A 986 Yes 986 Acrolein 107028 A 606 Yes 606 008 Methanol 67561 C 295 No 295 n-Hexane 110543 C 131 No 131 Benzene 71432 A 52 Yes 52 Toluene 108883 C 48 No 48 4) The emission levels contained in this permit are based on the following emission factors: Point 008: Emission Factors - Emission Factors- Uncontrolled Controlled CAS Pollutant lb/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr NOx 0.2034 0.70 0.2034 0.70 CO 0.7265 2.5 0.0727 0.25 VOC 0.2034 0.70 0.2034 0.70 50000 Formaldehyde 0.1162 0.40 0.0279 0.096 75070 Acetaldehyde 0.0084 0.0288 0.0084 0.0288 107028 _ Acrolein 0.0051 0.0177 0.0051 0.0177 67561 Methanol 0.0025 0.0086 0.0025 0.0086 110543 n-Hexane 0.0011 0.0038 0.0011 0.0038 71432 Benzene 0.0004 0.0015 0.0004 0.0015 108883 Toluene 0.0004 0.0014 0.0004 0.0014 Emission factors are based on a Brake-Specific Fuel Consumption Factor of 7586 Btu/hp-hr, a site-rated horsepower value of 1775, and a fuel heat value of 905 Btu/scf. AIRS ID: 123/0059/008 Page 8 of 15 �n Kerr-McGee/Anadarko .t trop m ,or Col$Pdo Dp rt rei{ oP Public Health and Environment Permit No. 10WE2361 1 ` fa Air Pollution Control Division Issuance 1 :s '� � . Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer Manufacturer CO Manufacturer Manufacturer VOC Subpart JJJJ Subpart JJJJ 50000 Formaldehyde Manufacturer Manufacturer 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 7/12/2016. 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 engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January 18, 2008 Federal Register posting - effective March 18, 2008). The January 18, 2008 amendments to include requirements for area sources and engines < 500 hp located at major sources have not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 8. A copy of the complete subpart is available on the EPA website at: http://www.epa.gov/ttn/atw/area/fr18ia08.0df Additional information regarding area source standards can be found on the EPA website at: htto://www.epa.qov/ttn/atw/area/arearules.html 8) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source CO, VOC, Benzene, Toluene, Xylenes, Formaldehyde, Total HAPS NANSR Synthetic Minor Source CO, VOC, Benzene, Toluene, Xylenes, Formaldehyde, Total HAPS MACT HH Area Source Requirements: Applicable (Benzene exemption) MACT ZZZZ Area Source Requirements: Applicable 9) 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 AIRS ID: 123/0059/008 Page 9 of 15 Kerr-McGee/Anadarko trol m ;' • ;:. Col do pp me o Public Health and Environment Permit No. 10WE2361 Air Pollution Control Division Issuance 1 „a MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.'•40-63.6173 Subpart QQQ— Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN —Subpart XXXXXX 10) 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: 123/0059/008 Page 10 of 15 wrirt Kerr-McGee/Anadarko trot m o . CoIAdo D.up r�errB oar Public Health and Environment Permit No. 10WE2361 Air Pollution Control Division Issuance 1vantith4 TMh 1Y • %'�?Yap 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: 123/0059/008 Page 11 of 15 Kerr-McGee/Anadarko trolt&mialri.l. Colt do I p ' e0; o. Public Health and Environment Permit No. 10WE2361 3 3_ Air Pollution Control Division Issuance 1 ,,. t,..rte. ,..,_°<s� ��) , 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/oilgaspermittinq.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. 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/oilgaspermittinq.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. 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. 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. AIRS ID: 123/0059/008 Page 12 of 15 Kerr-McGee/Anadarko ,trot mfr . Col4ndo Dp rtme o Public Health and Environment Permit No. 10WE2361 9,4 Air Pollution Control Division Issuance 1 . 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. 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. AIRS ID: 123/0059/008 Page 13 of 15 Kerr-McGee/Anadarko trotµ" mj . Col do •gip rt o Public Health and Environment Permit No. 10WE2361 Air Pollution Control Division Issuance 1 t 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: 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 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 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, § 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. A.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ AIRS ID: 123/0059/008 Page 14 of 15 a:t e,,A Kerr-McGee/Anadarko trolE m/ or Cori do D'pirYmet of Public Health and Environment Permit No. 10WE2361 Air Pollution Control Division Issuance 1 14_4 r. c„ a 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 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: 123/0059/008 Page 15 of 15 VP' . .. haa STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT htais AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 ;'., * CONSTRUCTION PERMIT PERMIT NO: 1 UWE2362 Issuance 1 DATE ISSUED: ISSUED TO: Kerr-McGee/Anadarko Petroleum Corp. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural gas compression facility, known as the Hambert Compressor Station, located in 18450 Weld County Road 35, Hambert, CO, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment ID Point Description One (1) Caterpillar, Model G3606 LE, Serial Number TBD, natural gas-fired, turbo-charged, 4SLB reciprocating internal EU-53 009 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 G3606 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 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 AIRS ID: 123/0059/009 Page 1 of 15 NGEngine Version 2009-1 ' . r :k. Kerr-McGee/Anadarko ``.trolSam t"'. Col do a prt a of Public Health and Environment Permit No. 10WE2362 . Air Pollution Control Division Issuance 1 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 NO,,Equipment ID Point V0C CO EU-53 009 2038 2038 728 Point Monthly limits are based on a 31-day month. Facility-wide emissions of each individual hazardous air pollutant shall be less than 1,358.9 lb/month. Facility-wide emissions of total hazardous air pollutants shall be less than 3,397.3 lb/month. Annual Limits: Facility AIRS Tons per Year Emission Type V0C CO Equipment ID Point NO„ EU-53 009 12.0 12.0 4.3 Point See "Notes to Permit Holder #4 for information on emission factors and methods used to calculate limits. AIRS ID: 123/0059/009 Page 2 of 15 r . Kerr-McGee/Anadarko Fac trol�mq o . Colo do D=;partme of Public Health and Environment Permit No. 10WE2362 ,� I Air Pollution Control Division Issuance 1 Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. During the first twelve (12) months of operation, compliance with both the monthly and yearly emission limitations shall be required. After the first twelve (12) months of operation, compliance with only the yearly limitation shall be required. Compliance with the synthetic minor status of this facility shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate monthly emissions and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all emission units, requiring an APEN, at this facility. 8. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control. The oxidation catalyst shall reduce uncontrolled emissions of CO from the unit to the emission levels listed in this section, 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-53 009 Consumption of natural gas as a fuel 130.3 11.1 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). AIRS ID: 123/0059/009 Page 3 of 15 Kerr-McGee/Anadarko • trolM` m( . . Col do • p ?me _ of Public Health and Environment Permit No. 10WE2362 j Air Pollution Control Division Issuance 1 11. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. flur'r.g periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.1. & 4.) 12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 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. 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 009 to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emissions limits contained in this permit. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time (Reference: Regulation No. 3, Part B., Section III.G.3) Oxides of Nitrogen Carbon Monoxide Periodic Testing Requirements 16. 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 17. The operator shall have 30 days after the start-up of Points 007, 008 and 009 to cancel the following permits: Permit No. AIRS ID Notes 96WE216-1 123/0059/002 Engine: This equipment will be removed and the AIRS ID: 123/0059/009 Page 4 of 15 u=icey A '5x � smi Kerr-McGee/Anadarko ,trot m t or . Col ix do D nmei ot` Public Health and Environment Permit No. 10WE2362 _ at, + „1 Air Pollution Control Division Issuance 1 O4 .JL .,. t: point will be canceled. 96WE216-2 123/0059/003 Engine: This equipment will be removed and the point will be canceled. 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. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine, the appropriate APEN filing fee and a cover letter explaining that the permittee is exercising an alternative-operating scenario and is installing a permanent replacement engine. 19. Operating Permit (OP) requirements shall apply to this source at any such time that the facility wide potential to emit equals or exceeds the major source level. Once the facility wide potential to emit equals or exceeds the major source level a Title V operating permit application shall be submitted in accordance with the requirements in Regulation No. 3, Part C. 20. 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) 21. MACT Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of AIRS ID: 123/0059/009 Page 5 of 15 Kerr-McGee/Anadarko '*•trol: 'm . Col do EE ! et o Public Health and Environment Permit No. 10WE2362 € 4 Air Pollution Control Division Issuance 1 that Subpart on the date as stated in the rule as published in the Federal Register. (Reference: Regulation No. 8, Part E) GENERAL TERMS AND CONDITIONS: 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 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. AIRS ID: 123/0059/009 Page 6 of 15 fur,. t"1. fi Y{S is Kerr-McGee/Anadarko F trot mLo . Col do DO rtrhe or Public Health and Environment Permit No. 10WE2362 � Air Pollution Control Division Issuance 1 By: Stephanie Chaousy, PE Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance New engines (Points 007, 008 and 009) replacing Points 002 and 003. Decrease in NOx emissions. Source at synthetic minor facility. AIRS ID: 123/0059/009 Page 7 of 15 Kerr-McGee/Anadarko r troIek,m` Col do p ev 1 Public Health and Environment Permit No. 10WE2362 rr f Air Pollution Control Division Issuance 1 • ,,,, ' ; ,,, a, ' ., 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.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 50000 A 13,712 Yes 3291 Acetaldehyde 75070 A 986 Yes 986 Acrolein 107028 A 606 Yes 606 009 Methanol 67561 C 295 No 295 n-Hexane 110543 C 131 No 131 Benzene 71432 A 52 Yes 52 Toluene 108883 C 48 No 48 4) The emission levels contained in this permit are based on the following emission factors: Point 009: Emission Factors - Emission Factors— Uncontrolled Controlled CAS Pollutant lb/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr NOx 0.2034 0.70 0.2034 0.70 CO 0.7265 2.5 0.0727 0.25 VOC 0.2034 0.70 0.2034 0.70 50000 Formaldehyde 0.1162 0.40 0.0279 0.096 75070 Acetaldehyde 0.0084 0.0288 0.0084 0.0288 107028 Acrolein 0.0051 0.0177 0.0051 0.0177 67561 Methanol 0.0025 0.0086 0.0025 0.0086 110543 n-Hexane 0.0011 0.0038 0.0011 0.0038 71432 Benzene 0.0004 0.0015 0.0004 0.0015 108883 Toluene 0.0004 0.0014 0.0004 0.0014 Emission factors are based on a Brake-Specific Fuel Consumption Factor of 7586 Btu/hp-hr, a site-rated horsepower value of 1775, and a fuel heat value of 905 Btu/scf. AIRS ID: 123/0059/009 Page 8 of 15 Kerr-McGee/Anadarko troletxmj o, Col i- do D�pertrne' otPublic Health and Environment • Permit No. 10WE2362 f ( \ 'i Air Pollution Control Division Issuance 1 Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer Manufacturer CO Manufacturer Manufacturer VOC Subpart JJJJ Subpart JJJJ 50000 Formaldehyde Manufacturer Manufacturer 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 7/12/2016. 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 engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January 18, 2008 Federal Register posting - effective March 18, 2008). The January 18, 2008 amendments to include requirements for area sources and engines < 500 hp located at major sources have not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 8. A copy of the complete subpart is available on the EPA website at: http://www.epa.nov/ttn/atw/area/fr18ia08.pdf Additional information regarding area source standards can be found on the EPA website at: http://www.epa.gov/ttn/atw/area/arearules.html 8) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source CO, VOC, Benzene, Toluene, Xylenes, Formaldehyde, Total HAPS NANSR Synthetic Minor Source CO, VOC, Benzene, Toluene, Xylenes, Formaldehyde, Total HAPS MACT HH Area Source Requirements: Applicable (Benzene exemption) MACT ZZZZ Area Source Requirements: Applicable 9) 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 • AIRS ID: 123/0059/009 Page 9 of 15 Kerr-McGee/Anadarko °%:trolkm J°. Coll,a do Ow p `me of Public Health and Environment Permit No. 10WE2362 Air Pollution Control Division Issuance 1 MACT 63.1200-63.1439 Subpart EEE— Subpart PPP MACT 63.1443 U3.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ— Subpart MMMMM MACT 63.8980-End Subpart NNNNN — Subpart XXXXXX 10) 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: 123/0059/009 Page 10 of 15 9 y .L Kerr-McGee/Anadarko trot m op Coil do p rimer of Public Health and Environment Permit No. 10WE2362 Air Pollution Control Division Issuance 1 nF t 47 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: 123/0059/009 Page 11 of 15 Kerr-McGee/Anadarko i trol4 m 30 . Col do . pq ` e o Public Health and Environment Permit No. 10WE2362 x "" Air Pollution Control Division Issuance 1 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/oilgaspermittinq.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. 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/oilgaspermittinq.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. 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. 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. • AIRS ID: 123/0059/009 Page 12 of 15 • Kerr-McGee/Anadarko • trolm o . Col do D .p nme o Public Health and Environment Permit No. 10WE2362 4 Air Pollution Control Division Issuance 1 \ r,„ , , 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 wll be subject to, the results of the test shall be converted to tho 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 attainmenUmaintenance 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. 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. AIRS ID: 123/0059/009 Page 13 of 15 Kerr-McGee/Anadarko 'otrol ,m -'ors. Col r do pa ' ei4. o Public Health and Environment Permit No. 10WE2362 t. Air Pollution Control Division Issuance 1 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: 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 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 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.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. A.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ AIRS ID: 123/0059/009 Page 14 of 15 "2"- Kerr-McGee/Anadarko trot mn `. Colo do a part e „ of Public Health and Environment Permit No. 10WE2362 41—'2.' Air Pollution Control Division Issuance 1 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 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: 123/0059/009 Page 15 of 15 rte. wricyFTSTATE OF COLORADO pF COO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION " 3i0) TELEPHONE: (303) 692-3150 +•V ++ +1876 CONSTRUCTION PERMIT PERMIT NO: 11WE1189 WE1 1 89 Issuance 1 DATE ISSUED: ISSUED TO: Kerr-McGee/Anadarko Petroleum Corp. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural gas compression station, known as the Hambert Compressor Station, located at 18450 Weld County Road 35, Hambert, Colorado, Section 36, Township 4 North, Range 66 West, 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 (manufacturer, model, serial number: to be determined) with a design capacity of 30 MMscf per day. This emissions unit is equipped with two (2) electric-glycol pump with a design capacity D-51 011 of 5.0 gallons per minute. This unit is equipped with a flash tank, reboiler and still vent. Emissions from the flash tank are routed back to the plant inlet in a closed-loop system. Emissions from the still vent are routed through a condenser and then to a thermal oxidizer. 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.htmi. 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 AIRS ID: 123/0059/011 Page 1 of 10 Dehy Version 2009-1 ..tom Kerr-McGee/Anadarko troli6. m' • ` Co do rp e t o Public Health and Environment Permit No. 11WE1189 v , ‘ ' : Air Pollution Control Division Issuance 1 ,w u 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, III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The manufacturer, model number and serial number of the subject equipment shall be provided to the Division within fifteen days (15) after commencement of operation. This information shall be included on the Notice of Startup (NOS) submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Monthly Limits: Facility AIRS Pounds per Month Equipment ID Point NO„ V0C CO Emission Type EU-01 011 408 119 1105 Point Monthly limits are based on a 31-day month. Facility-wide emissions of each individual hazardous air pollutant shall be less than 1,358.9 lb/month. Facility-wide emissions of total hazardous air pollutants shall be less than 3,397.3 lb/month. Annual Limits: Facility AIRS Tons per Year Emission Type Equipment ID Point NO, V0C CO EU-01 011 2.4 0.7 6.5 Point See "Notes to Permit Holder#4"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. AIRS ID: 123/0059/011 Page 2 of 10 Kerr-McGee/Anadarko R trot ,m _' Coy do p e o Public Health and Environment Permit No. 11WE1189 ' Itt Air Pollution Control Division Issuance 1 c 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. This unit shall be configured such that the flash tank vapors are routed the plant inlet and the still vent vapors are routed to a condenser and then a thermal oxidizer. The thermal oxidizer shall reduce uncontrolled emissions of VOC from the TEG dehydration unit to the emission levels listed in this section, above. Operating parameters of the control equipment are identified in the operation and maintenance plan. (Reference: Regulation No.3, Part B, Section III.E.) 10. 100% of emissions that result from the flash tank associated with this dehydrator shall be recycled to the plant inlet and recompressed. PROCESS LIMITATIONS AND RECORDS 11. 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 10,950 EU-01 011 Natural gas throughput 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 natural gas throughput and keep a compliance record on site or at a local field office with site responsibility, for Division review. 12. 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 weekly in a log maintained on site and AIRS ID: 123/0059/011 Page 3 of 10 Kerr-McGee/Anadarko ' trol ° }m • , Co =do p, 3met o Public Health and Environment Permit No. 11 WE1189 r Air Pollution Control Division -1 Issuance 1 d las iy w made available to the Division for inspection upon request. (Reference: Regulation No. 3, Part B, II.A.4) STATE AND FEDERAL REGULATORY REQUIREMENTS 13. 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) 14. 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.) 15. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 16. The flare covered by this permit is subject to Regulation No. 7, Section XVII.B General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed, have no visible emissions during normal operations, and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. The operator shall comply with all applicable requirements of Section XVII. 17. This 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. 18. This equipment is subject to the control requirements for glycol natural gas dehydrators under Regulation No. 7, Section XVII.D (State only enforceable). Beginning May 1, 2008, uncontrolled actual emissions of volatile organic compounds from the still vent and vent from any gas-condensate-glycol (GCG)separator(flash separator or flash tank), if present, shall be reduced by an average of at least 90 percent through the use of air pollution control equipment. This source shall comply with all applicable general provisions of Regulation 7, Section XVII 19. 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)(ii) — The actual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere are less than 0.90 AIRS ID: 123/0059/011 Page 4 of 10 Kerr-McGee/Anadarko trol mor Co ado p>ar e•it ofi Public Health and Environment Permit No. 11WE1189 lei ry Air Pollution Control Division Issuance 1 • zte �,R „�.t„ , �,. 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)(2) -The determination of actual average benzene emissions from a glycol dehydration unit shall be made using the procedures of either paragraph (b)(2)(i) or (b)(2)(ii) of this section. Emissions shall be determined either uncontrolled, or with federally enforceable controls in place. • §63.772(b)(2)(i) —The owner or operator shall determine actual average benzene emissions using the model GRI-GLYCaIc T" Version 3.0 or higher, and the procedures presented in the associated GRI-GLYCalc TM Technical Reference Manual. Inputs to the model shall be representative of actual operating conditions of the glycol dehydration unit and may be determined using the procedures documented in the Gas Research Institute (GRI) report entitled "Atmospheric Rich/Lean Method for Determining Glycol Dehydrator Emissions" (GRI-95/0368.1); or • §63.772(b)(2)(ii) - The owner or operator shall determine an average mass rate of benzene emissions in kilograms per hour through direct measurement using the methods in §63.772(a)(1)(i) or (ii), or an alternative method according to §63.7(f). Annual emissions in kilograms per year shall be determined by multiplying the mass rate by the number of hours the unit is operated per year. This result shall be converted to megag rams 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)(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 20. 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.) AIRS ID: 123/0059/011 Page 5 of 10 Kerr-McGee/Anadarko ` troldrm; `. Co do epa e o Public Health and Environment Permit No. 11WE1189 ` , 'w t Air Pollution Control Division Issuance 1 21. 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 riot e,reed 160 °F on a monthly average basis. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 22. 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.) Periodic Testing Requirements 23. 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 24. 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. 25. Operating Permit (OP) requirements shall apply to this source at any such time that the facility wide potential to emit equals or exceeds the major source level. Once the facility wide potential to emit equals or exceeds the major source level a Title V operating permit application shall be submitted in accordance with the requirements in Regulation No. 3, Part C. 26. 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) AIRS ID: 123/0059/011 Page 6 of 10 Kerr-McGee/Anadarko Fu trot m ,ror! . Copt`ido aop rtme{t of Public Health and Environment Permit No. 11WE1189 4,, Air Pollution Control Division Issuance 1 4'dx . 41- 27. MACT Subpart HH- National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities major stationary source requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of Subpart HH. (Reference: Regulation No. 8, Part E) GENERAL TERMS AND CONDITIONS: 28. 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. 29. 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. 30. 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. 31. 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. 32. 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. 33. 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. 34. 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 AIRS ID: 123/0059/011 Page 7 of 10 Kerr-McGee/Anadarko ' trol m 45? Cob do pa et o Public Health and Environment Permit No. 11WE1189 w' P, Air Pollution Control Division Issuance 1 enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Stephanie Chaousy, PE Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Addition of a 30 MMSCFD TEG dehydrator. Source located at a synthetic minor facility. AIRS ID: 123/0059/011 Page 8 of 10 Kerr-McGee/Anadarko trol •mr br . Cole ado �p me t o Public Health and Environment Permit No. 11WE1189 Lid Air Pollution Control Division ' Issuance 1 A R 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.u s/req u lations/a i rreq s/100102agcccom mon 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 (Ib/yr) reportable? Rate (Ib/yr) Benzene 71432 A 58,439 Yes 340 Toulene 110543 C 85,728 Yes 290 011 Ethylbenzene 100414 C 2,883 Yes 4 Xylenes 1330207 C 40,706 Yes 52 n-Hexane 110543 C 4,551 Yes 33 4) The emission levels contained in this permit are based on information provided in the application and the GRI GlyCalc 4.0 model. 5) The following equipment is currently exempt from construction permitting requirements and/or APEN reporting requirements based on information provided by the operator for the Division's analysis: AIRS ID Facility ID Description Notes NA Dehydrator Dehy unit reboiler, rated This unit is exempt from APEN reporting reboiler at 0.75 MMBtu/hr requirements because the design rate is less than 5 MMBtu/hr (Regulation No. 3, Part A, II.D.1.k), and is therefore also exempt from construction permitting requirements (Regulation no. 3, Part B, II.D.1.a). Criteria pollutant emission levels for this unit are based on factors from AP-42, Chapter 1.4, Small Boilers < 100 MMBtu/hr (7/1998). 6) 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 12, 2016. A revised APEN shall be submitted no later than 30 days before the five-year term expires. AIRS ID: 123/0059/011 Page 9 of 10 Kerr-McGee/Anadarko '',strol' -m ;or -:. Co t3clo rp e, o₹ Public Health and Environment Permit No. 11WE1189 Air Pollution Control Division Issuance 1 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source CO, VOC, Benzene, Toluene, Xylenes, Formaldehyde, Total HAPS NANSR Synthetic Minor Source CO, VOC, Benzene, Toluene, Xylenes, Formaldehyde, Total HAPS MACT NH Area Source Requirements: Applicable (Benzene exemption) MACT ZZZZ Area 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 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/oilqaspermittinq.html AIRS ID: 123/0059/011 Page 10 of 10 Hello