HomeMy WebLinkAbout20091481.tiffSTATE OF COLORADO
Bill Ritter, Jr., Governor
James B. Martin, Executive Director
Dedicated to protecting and improving the health and environment of the people of Colorado
4300 Cherry Creek Dr. S.
Denver, Colorado 80246-1530
Phone (303) 692-2000
TDD Line (303) 691-7700
Located in Glendale, Colorado
http://www.cdphe.state.co.us
June 16, 2009
Mr. Steve Moreno
Weld County Clerk
1402 N. 17th Ave.
Greeley, CO 80631
Dear Mr. Moreno:
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
(303) 692-3090
Colorado Department
of Public Health
and Environment
The Air Pollution Control Division will publish a public notice for the Kerr-McGee Gathering, LLC.
This public notice will be published in the Fort Lupton Press on June 20, 2009.
Thank you for assisting the Division by making the enclosed package (includes public notice,
preliminary analysis, Air Pollutant Emission Notice(s) and draft permit(s)) available for public review
and comment. It must be available for public inspection for a period of thirty (30) days from the date
the public notice is published.
Please forward any comment regarding this public notice to the address below.
Colorado Department of Public Health and Environment
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Attention: Jacquie Barela
ds,
eh
aljuel ni e1V. Barela
Public Notice Coordinator
Stationary Sources Program Air Pollution Control Division
iaI IC F -L
(1)(‘'/ 0
2009-1481
NOTICE OF REQUEST FOR SYNTHETIC MINOR
FOR
Kerr-McGee Gathering, LLC
PERMIT NOs. 09WE0284, 03WE0061, & 94WE760-1
TABLE OF CONTENTS
1. PUBLIC NOTICE
2. PRELIMINARY ANALYSIS
3. DRAFT PERMIT
Prepared by
Matthew S. Burgett, P.E.
Colorado Department of Public Health and Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
STATE OF COLORADO
Bill Ritter, Jr., Governor
James B. Martin, Executive Director
Dedicated to protecting and improving the health and environment of the people of Colorado
4300 Cherry Creek Dr. S.
Denver, Colorado 80246-1530
Phone (303) 692-2000
TDD Line (303) 691-7700
Located in Glendale, Colorado
http://www.cdphe.state.co.us
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
(303) 692-3090
Released to: Fort Lupton Press on June 16, 2009; published June 20, 2009
PUBLIC NOTICE OF A PROPOSED PROJECT
OR ACTIVITY WARRANTING PUBLIC COMMENT
Colorado Department
of Public Health
and Environment
The Colorado Air Pollution Control Division has declared that 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 an application to the Division has been received for an emission permit on the following
proposed project and activity:
Kerr-McGee Gathering, LLC has applied for cancellation of a Title V Operating Permit, requiring re -issuance of
three construction permits for the Dougan Compressor Station located at 16280 Weld County Road 10, Fort
Lupton, Weld County, Colorado. Public comment is sought for these permits due to the following reasons:
• Source is attempting to obtain federally enforceable limit on the potential to emit to avoid Title V
Operating Permit requirements.
The Division hereby solicits and requests submission of public comment concerning the aforesaid proposed
project and activity for a period of thirty (30) days from and after the date of this publication. Any such comment
must be in writing and be submitted to the following addressee:
Matthew S. Burgett, P.E.
Colorado Department of Public Health and Environment
APCD-SS-B I
4300 Cherry Creek Drive South
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
permit. 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 application for the emission permit, the Preliminary Analysis of said application, 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, Glendale,
Colorado.
PRELIMINARY ANALYSIS
Applicant
Kerr-McGee Gathering, LLC
Permit No(s).
09WE0284, 03WE0061. 94WE760-1
Facility Location
Dougan Compressor Station
16280 Weld County Road 10
Fort Lupton, Weld County, Colorado
Source No.
123/0185
Review Engineer
Matthew S. Burgett, P.E.
Date
June 16, 2009
Control Engineer
Roland Hea, P.E.
Project Description
Kerr-McGee Gathering, LLC has proposed issuance of the following construction permits
at the Dougan Compressor Station in order to cancel the Title V Operating Permit:
All Permits:
• Facility -wide Hazardous Air Pollutant (HAP) limits have been added to the permits
in order to consider this a synthetic minor facility. Potential emissions for the
facility exceed the thresholds for the following Major Source MACT requirements.
With the issuance of the proposed federally enforceable permits to limit the
potential to emit below major source thresholds as determined under each MACT
requirement, the source will be classified as a Synthetic Minor (Area) Source for
MACT applicability:
o MACT HH requirements (National Emissions Standards for Hazardous Air
Pollutants for Oil & Natural Gas Production)
94WE760-1 —Glycol Dehydration Unit:
• This construction permit is being re -issued as Initial Approval.
• The permit requires submittal of a current operating & maintenance plan.
• The area source MACT HH requirements have been added to the permit.
03WE0061 — Condensate Tank Battery:
• The permit requires submittal of a current operating & maintenance plan.
• Site specific testing is required prior to Final Approval to verify emissions.
09WE0284 — Fugitive Equipment Leaks:
• This construction permit is being issued as Final Approval.
• A new construction permit number has been assigned since this unit was
previously considered "grandfathered" from construction permitting.
Requested
Emissions - facility
Pollutant
Controlled
Emissions (tpy)
Potential
Emissions (tpy)
Oxides of Nitrogen
1.6
-
Volatile Organic Compounds
50.2
500.6
Carbon Monoxide
2.9
-
Total HAPs
6.6
131.1
Regulatory Status
Synthetic Minor Source for Operating Permit Applicability: Upon the issuance of
these permits, emissions will be limited below major source levels.
Area Source for MACT HH Applicability: With the issuance of federally enforceable
permits, actual emissions of HAPs from the above listed sources will be limited to less 8
tons per year, and total HAPs will be limited to less than 20 tons per year, and the source
will be classified as a Synthetic Minor Source.
Ambient Impact
No ambient impact analysis is required at this time since no significant emissions
Analysis
increases are requested and the level of emissions of NOx and CO do not warrant
modeling.
Public Comment
Requirement
Public comment is required for sources wishing to obtain federally enforceable emission
limits to avoid major source status (by limiting potential to emit) through a construction
permit. By limiting the potential to emit, this source will not be subject to the requirements
of the Title V Operating Permit Program requirements, or major source MACT NH
requirements (National Emissions Standards for Hazardous Air Pollutants from Oil and
Natural Gas Production Facilities)
DRAFT
PERMIT
PERMIT NO: 09WE0284
DATE ISSUED:
ISSUED TO: Kerr-McGee Gathering, LLC
FINAL APPROVAL
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Natural gas transmission facility, known as the Dougan Compressor Station, located at
16280 Weld County Road 10, Fort Lupton, Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
F001
005
Equipment leaks (fugitive VOCs) from a natural gas
compression/processing facility.
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:
1. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission Type
VOC
F001
005
25.02
Fugitive
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.
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
123/0185/005
ver. 2/00
Kerr-McGee Gathering, LLC
Permit No. 09WE0284
Final Approval
Page 2
Colorado Department of Public Heal DRAFT
Air Poll
PERMIT
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.
Emissions shall be based on the most recent extended gas analysis. 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.
STATE REGULATORY REQUIREMENTS
2. 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.)
3. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable)
COMPLIANCE TESTING AND SAMPLING
4. The permittee shall complete an extended gas analysis on a semiannual basis of gas
samples that are representative of gas that may be released as fugitive emissions.
ADDITIONAL REQUIREMENTS
5. 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.
6. 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 equal 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.
7. Prevention of Significant Deterioration (PSD) requirements shall apply to this source at any
such time that this source becomes major solely by virtue of a relaxation in any permit
condition. Any relaxation that increases the potential to emit above the applicable PSD
threshold will require a full PSD review of the source as though construction had not yet
123/0185/005 ver. 2/00
Kerr-McGee Gathering, LLC
Permit No. 09WE0284
Final Approval
Page 3
Colorado Department of Public Heal DRAFT
Air Poll
PERMIT
commenced on the source. The source shall not exceed the PSD threshold until a PSD
permit is granted. (Regulation No. 3 Part D, VI.B.4)
8. 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)
Matthew S. Burgett, P.E.
Enviromental Engineer
Permit History
Issuance
Date
Description
Final Approval
This Issuance
This Construction Permit is being issued to
replace the permit conditions previously found in
the Operating Permit. The source intends to
cancel the Title V Operating Permit.
Notes to Permit Holder:
1) The production or raw material processing limits and emission limits contained in this permit are based on
the consumption rates requested in the permit application. These limits may be revised upon request of
the permittee providing there is no exceedance of any specific emission control regulation or any ambient
air quality standard. A revised air pollution emission notice (APEN) and application form must be
submitted with a request for a permit revision.
2) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The permittee shall notify the Division of any
malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon
as possible, but no later than noon of the next working day, followed by written notice to the Division
addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See:
http://www. cd phe.state. co. u s/requ lations/airregs/ 100102agcccom mon provisionsreq. pdf.
3) The emission levels contained in this permit are based on the following emission factors:
Emission Factors (kg/hr-component):
Component
Gas Service
Water/Oil Service
Light Oil
Heavy Oil
Valves
4.5E-03
9.8E-05
2.5E-03
8.4E-06
Connectors
2.0E-04
1.1E-04
2.1E-04
7.5E-06
123/0185/005
ver. 2/00
Kerr-McGee Gathering, LLC
Permit No. 09WE0284
Final Approval
Page 4
Colorado Department of Public Heal DRAFT
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PERMIT
Flanges
3.9E-04
2.9E-06
1.1E-04
3.9E-07
Seals
2.4E-03
2.4E-05
1.3E-02
NA
Other
8.8E-03
1.4E-02
7.5E-03
3.2E-05
Source: EPA -453/R95-017
4) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor
PSD
Synthetic Minor
NA NSR
Synthetic Minor
MACT HH
Synthetic Minor
123/0185/005 ver. 2/00
Kerr-McGee Gathering, LLC
Permit No. 09WE0284
Final Approval
Page 5
Colorado Department of Public Heal DRAFT
Air Poll
PERMIT
GENERAL TERMS AND CONDITIONS: (IMPORTANT! READ ITEMS 5,6,7 AND 8)
1. 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.
2. 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.
3. 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 final approval 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.
4. This permit and any required attachments must be retained and made available for inspection upon request
at the location set forth herein. With respect to a portable source that is moved to a new location, a copy of the
Relocation Notice (required by law to be submitted to the APCD whenever a portable source is relocated)
should be attached to this permit. 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.
5. Issuance (initial approval) of an emission permit does not provide "final" authority for this activity or
operation of this source. Final approval 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
approval 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. If the APCD so determines, it will provide written
documentation of such final approval, which does constitute "final" authority to operate. Compliance with the
permit conditions must be demonstrated within 180 days after commencement of operation.
6. THIS PERMIT AUTOMATICALLY EXPIRES IF you (1) do not commence construction or operation within
18 months after either the date of issuance of this permit or the date on which such construction or activity was
scheduled to commence as set forth in the permit, whichever is later; (2) discontinue construction for a period of
18 months or more; or (3) do not complete construction within a reasonable time of the estimated completion
date. Extensions of the expiration date may be granted by the APCD upon a showing of good cause by the
permittee prior to the expiration date.
7. YOU MUST notify the APCD no later than thirty days after commencement of the permitted operation
or activity by submitting a Notice of Startup (NOS) form to the APCD. The Notice of Startup
(NOS) form may be downloaded online atwww.cdphe.state.co.us/ap/downloadforms.html. Failure to
do so is a violation of Section 25-7-114.5(12)(a), C.R.S. and AQCC Regulation No. 3, Part B, Section III.G.1.,
and can result in the revocation of the permit. You must demonstrate compliance with the permit conditions
within 180 days after commencement of operation as stated in condition 5.
8. 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. Ifa 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.
9. 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.
123/0185/005 ver. 2/00
s
DRAFT
PERMIT
PERMIT NO:
DATE ISSUED:
ISSUED TO:
03WE0061
Kerr-McGee Gathering LLC
INITIAL APPROVAL
Modification No. 1
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Natural gas transmission facility, known as the Dougan Compressor Station, located at
16280 Weld County Road 10, Fort Lupton, Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE
FOLLOWING:
AIRS Point
Equipment Description
006
Four 225 -bbl, one 200 -bbl, and one 300 -bbl tank manifolded together and
used for the storage of condensate. An Air -Assisted Flare is used to
control emissions from the condensate storage tank battery vent.
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 Obtain a Final Approval Permit
1. Within one hundred and eighty days (180) after commencement of operation, compliance with the
conditions contained on this permit shall be demonstrated to the Division. It is the permittee's
responsibility to self certify compliance with the conditions. Failure to demonstrate compliance
within 180 days may result in revocation of the permit. (Information on how to certify compliance
was mailed with the permit.)
2. The operator shall complete site specific testing as required by this permit.
3. The operator shall implement Operating and Maintenance Plan requirements as required by this
permit.
Emissions and Condensate Production Limits and Recordkeepinq Requirements
4. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). Compliance with the annual limits shall be determined on a rolling
AIRS ID: 123/0185/006 Page 1 of 7
E
Kerr-McGee Gathering LLC
Permit Number 03WE0061
Initial Approval
Colorado Department of Public Heath and Environment
Air Pollution Control Division
(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 for Division review. (Reference: Regulation No. 3, Part B, Section
I I.A.4)
Volatile Organic Compounds: 14.0 tons per year.
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.
5. This source shall be limited to a maximum condensate throughput rate as listed below and all
other activities, operational rates and numbers of equipment as stated in the application. Monthly
records of the actual production rate shall be maintained by the applicant and made available to
the Division for inspection upon request. (Reference: Regulation No. 3, Part B, Section II.A.4.)
Throughput of condensate shall not exceed 22,000 barrels per year.
Compliance with the yearly production limits shall be determined on a rolling twelve (12) month
total.
Operating and Maintenance Plan Requirements
6. Prior to final approval being issued, the applicant shall submit to the Division for approval an
operating and maintenance plan for all control equipment and control practices, and a proposed
record keeping format that will outline how the applicant will maintain compliance on an ongoing
basis with the requirements of this permit. The operating and maintenance plan shall commence
at startup. (Reference: Regulation No. 3, Part B, Section III.G.7.)
Testing Requirements
7. Prior to final approval being issued, the applicant shall complete site specific sampling including a
compositional analysis of the pre -flash pressurized condensate routed to these storage tanks and
a sales oil analysis to determine RVP and API gravity. Testing shall be in accordance with the
guidance contained in PS Memo 05-01. Results of testing shall be used to determine a site -
specific emissions factor using Division approved methods. Results of site -specific sampling
shall be used to demonstrate compliance with the emissions factors chosen for this emissions
point.
Colorado State Standards
8. The condensate storage tanks covered by this permit are subject to Regulation 7, Section XVII
emission control requirements. These requirements include, but are not limited to:
Section XVII.B — General Provisions
Section XVII.B.1.c. - 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 than 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.
AIRS ID: 123/0185/006 Page 2 of 7
Kerr-McGee Gathering LLC
Permit Number 03WE0061
Initial Approval
Colorado Department of Public Heath and Environment
Air Pollution Control Division
Section XVII.C. - Emission reduction from condensate storage tanks at oil and gas exploration
and production operations, natural gas compressor stations, natural gas drip stations
and natural gas processing plants.
XVII.C.1. Beginning May 1, 2008, owners or operators of all atmospheric condensate storage
tanks with uncontrolled actual emissions of volatile organic compounds equal to or
greater than 20 tons per year based on a rolling twelve-month total shall operate air
pollution control equipment that has an average control efficiency of at least 95% for
VOCs on such tanks.
XVII.C.3. Monitoring: The owner or operator of any condensate storage tank that is required
to control volatile organic compound emissions pursuant to this section XVII.C. shall
visually inspect or monitor the Air Pollution Control Equipment to ensure that it is
operating at least as often as condensate is loaded out from the tank, unless a more
frequent inspection or monitoring schedule is followed. In addition, if a flare or other
combustion device is used, the owner or operator shall visually inspect the device for
visible emissions at least as often as condensate is loaded out from the tank.
XVII.C.4. Recordkeeping: The owner or operator of each condensate storage tank shall
maintain the following records for a period of five years:
XVII.C.4.a. Monthly condensate production from the tank.
XVII.C.4.b For any condensate storage tank required to be controlled pursuant to this
section XVII.C., the date, time and duration of any period where the air
pollution control equipment is not operating. The duration of a period of non -
operation shall be from the time that the air pollution control equipment was
last observed to be operating until the time the equipment recommences
operation.
XVII.C.4.c. For tanks where a flare or other combustion device is being used, the date
and time of any instances where visible emissions are observed from the device.
9. This source is subject to the recordkeeping, monitoring, reporting, and emission control
requirements of Regulation 7, Section XII VOLATILE ORGANIC COMPOUND EMISSIONS
FROM OIL AND GAS OPERATIONS. The operator shall comply with all applicable requirements
of Section XII.
Additional Requirements
10. Visible emissions shall not exceed zero percent (0%) opacity during normal operation of the
source (Regulation 7, Section XVII.B.1.c). 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. EPA Method 9 shall be used to measure opacity.
(Reference: Regulation No. 1, Section II.A.1. & 4.)
11. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable)
12. The permit number shall be marked on the subject equipment for ease of identification.
(Reference: Regulation No. 3, Part B, III.E.) (State only enforceable)
13. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part
A, II.C)
a. Annually whenever a significant increase in emissions occurs as follows:
AIRS ID: 123/0185/006 Page 3 of 7
t
Kerr-McGee Gathering LLC
Permit Number 03WE0061
Initial Approval
Colorado Department of Public Heath and Environment
Air Pollution Control Division
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, new storage tanks installed, existing
storage tanks replaced, a new well is drilled and added to the battery, or whenever a
different type of control equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
14. 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 equal 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.
15. Prevention of Significant Deterioration (PSD) requirements shall apply to this source at any such
time that this source becomes major for PSD solely by virtue of a relaxation in any permit
condition. Any relaxation that increases the potential to emit above the applicable PSD threshold
will require a full PSD review of the source as though construction had not yet commenced on the
source. The source shall not exceed the PSD threshold until a PSD permit is granted.
(Reference: Regulation No.3, Part D, Section VI.B.4.)
16. Major stationary source requirements for non -attainment areas shall apply at 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 major stationary source threshold will result
in this source being subject to Major Stationary Source requirements of Regulation No. 3, Part D,
Section V. This source shall not exceed the major stationary source threshold until compliance
with Regulation No. 3., Part D, Section V. has been achieved.
By
Matthew S. Burgett, P.E.
Environmental Engineer
Action
Date Issued
Notes
IA Modification No. 1
This Issuance
Facility intends to drop out of Title V permitting
and requires a Construction Permit.
Title V Operating Permit
June 25, 2007
Production = 22,000 bbl/yr. Issued to Kerr-
McGee Gathering LLC.
Title V Operating Permit
December 1, 2004
Condensate tank requirements incorporated
directly into Operating Permit 95OPWE033.
AIRS ID: 123/0185/006
Page 4 of 7
Kerr-McGee Gathering LLC
Permit Number 03WE0061
Initial Approval
Colorado Department of Public Heath and Environment
Air Pollution Control Division
Production = 11,000 bbl/yr. Issued to Kerr-
McGee Rocky Mountain Corp.
AIRS ID: 123/0185/006 Page 5 of 7
Kerr-McGee Gathering LLC
Permit Number 03WE0061
Initial Approval
Colorado Department of Public Heath and Environment
Air Pollution Control Division
Notes to Permit Holder:
1) 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.
2) The throughput limits and emission limits contained in this permit are based on the throughput rates
requested in the permit application. These limits may be revised upon request of the permittee
providing there is no exceedance of any specific emission control regulation or any ambient air quality
standard. A revised air pollution emission notice (APEN) and application form must be submitted with
a request for a permit revision.
3) The following emissions of non -criteria reportable air pollutants are estimated based upon the
requested condensate throughput contained in your application and the E&P Tanks report dated
02/05/2007. This information is listed to inform the operator of the Division's analysis of the specific
compounds. This information is listed on the Division's emission inventory system.
UNCONTROLLED CONTROLLED
C.A.S. # SUBSTANCE EMISSIONS (LB/YR) REPORTABLE? EMISSIONS (LB/YR)
71-43-2 Benzene
108-88-3 Toluene
1330-20-7 Xylenes
110-54-3 n -Hexane
1800
1404
136
10484
YES
YES
NO
YES
90
70
6
524
4) The emission levels contained in this permit are based on the following uncontrolled emission factors
from API's E&P Tanks:
Volatile Organic Compounds:
Benzene
Toluene
n -Hexane
* flare controls emissions by 95%.
Flare Combustion emissions are APEN Exempt
25.1336 pounds per barrel.
0.0818 pounds per barrel.
0.0638 pounds per barrel.
0.4763 pounds per barrel.
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 May 2, 2012. A
revised APEN shall be submitted no later than 30 days before the five-year term expires.
6) This emission unit is classified as a: Synthetic Minor Source. This facility is classified as follows:
Applicable Requirement
Status
Operating Permit
Synthetic Minor
PSD
Synthetic Minor
NA NSR
Synthetic Minor
MACT HH
Synthetic Minor
AIRS ID: 123/0185/006
Page 6 of 7
Kerr-McGee Gathering LLC
Permit Number 03WE0061
Initial Approval
Colorado Department of Public Heath and Environment
Air Pollution Control Division
GENERAL TERMS AND CONDITIONS: (IMPORTANT! READ ITEMS 5,6,7 AND 8)
1. 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.
2. 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.
3. 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 final approval 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.
4. This permit and any required attachments must be retained and made available for inspection upon request
at the location set forth herein. With respect to a portable source that is moved to a new location, a copy of
the Relocation Notice (required by law to be submitted to the APCD whenever a portable source is
relocated) should be attached to this permit. 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.
5. Issuance (initial approval) of an emission permit does not provide "final" authority for this activity or operation
of this source. Final approval 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 approval
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. If the APCD so determines, it will provide written
documentation of such final approval, which does constitute "final" authority to operate. Compliance with
the permit conditions must be demonstrated within 180 days after commencement of operation.
6. THIS PERMIT AUTOMATICALLY EXPIRES IF you (1) do not commence construction or operation within
18 months after either the date of issuance of this permit or the date on which such construction or activity
was scheduled to commence as set forth in the permit, whichever is later; (2) discontinue construction for a
period of 18 months or more; or (3) do not complete construction within a reasonable time of the estimated
completion date. Extensions of the expiration date may be granted by the APCD upon a showing of good
cause by the permittee prior to the expiration date.
7. YOU MUST notify the APCD no later than thirty days after commencement of the permitted operation
or activity. Failure to do so is a violation of Section 25-7-114.5(12)(a), C.R.S. and AQCC Regulation No. 3,
Part B, Section III.G.1., and can result in the revocation of the permit. You must demonstrate compliance
with the permit conditions within 180 days after commencement of operation as stated in condition 5.
8. 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.
9. 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: 123/0185/006 Page 7 of 7
DRAFT
PERMIT
PERMIT NO: 94WE760-1
INITIAL APPROVAL
DATE ISSUED: Modification No. 1
ISSUED TO: Kerr-McGee Gathering, LLC
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Natural gas transmission facility, known as the Dougan Compressor Station, located at
16280 Weld County Road 10, Fort Lupton, Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
One (1) Custom Triethylene Glycol Dehydrator, s/n: GDUD01W, rated at 80.0 MMscf/day, natural
gas fired reboiler, equipped with an electric glycol pump, flash tank and associated still vent. This
emission unit uses an air -assisted flare, or reboiler, as the VOC control system.
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 Obtain a Final Approval Permit
1. Within one hundred and eighty days (180) after commencement of operation, compliance with the
conditions contained on this permit shall be demonstrated to the Division. It is the permittee's
responsibility to self certify compliance with the conditions. Failure to demonstrate compliance
within 180 days may result in revocation of the permit. (Information on how to certify compliance
was mailed with the permit.)
2. 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)
3. The operator shall implement Operating and Maintenance Plan requirements as required by this
permit.
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INITIAL APPROVAL
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Colorado Department of Public Hey
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PERMIT
Emissions & Process Limits, and Recordkeepinq Requirements
4. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Annual Limits:
Facility Equipment
ID
AIRS
Point
Tons per Year
NOx
VOC
CO
D-01
001
0.5
11.0
2.7
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.
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.
5. 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 extended 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.
6. This unit shall be configured such that the flash tank vapors are routed to the flare, or reboiler
burner (for use as fuel), and still vent vapors are routed to the flare. The flare and reboiler burner
shall be capable of reducing uncontrolled emissions of VOC from the TEG dehydration unit to the
emission levels listed in Condition 4, above. The reboiler burner shall be firing at all times that
flash tank vapors are routed to it. Operating parameters of the control equipment shall be
identified in the operation and maintenance plan. (Reference: Regulation No.3, Part B, Section
III.E.)
7. This source shall be limited to a maximum processing and/or consumption rate as listed below
and all other activities, operational rates and numbers of equipment as stated in the application.
Monthly records of the actual consumption rate shall be maintained by the applicant and made
available to the Division for inspection upon request. (Reference: Regulation 3, Part B,III.A.4)
Dehydration of natural gas shall not exceed 14,600 million scf per year.
Compliance with the yearly consumption limits shall be determined on a rolling twelve (12) month
total.
8. This unit shall be limited to the maximum lean glycol circulation rate of 5.0 gpm. The lean glycol
recirculation rate shall be recorded weekly in a log maintained on site and made available to the
Division for inspection upon request. (Reference: Regulation No. 3, Part B, II.A.4)
A
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PERMIT
Operating and Maintenance Plan Requirements
9. Prior to final approval being issued, the applicant shall submit to the Division for approval an
operating and maintenance plan for all control equipment and control practices, and a proposed
record keeping format that will outline how the applicant will maintain compliance on an ongoing
basis with the requirements of this permit. The operating and maintenance plan shall commence
at startup. (Reference: Regulation No. 3, Part B, Section III.G.7.)
State and Federal Requirements
10. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the
source. During periods of startup, process modification, or adjustment of control equipment
visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive
minutes. (Reference: Regulation No. 1, Section II.A.1. & 4.)
11. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable)
12. This equipment is subject to the control requirements for glycol natural gas dehydrators under
Regulation No. 7, Section XII.C. 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.
13. 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.
14. 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
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 TM ,
Version 3.0 or higher, and the procedures presented in the
associated GRI-GLYCaIc TM Technical Reference Manual. Inputs to
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Colorado Department of Public He2 DRAFT
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the model shall be representative of actual operating conditions of
the glycol dehydration unit and may be determined using the
procedures documented in the Gas Research Institute (GRI) report
entitled "Atmospheric Rich/Lean Method for Determining Glycol
Dehydrator Emissions" (GRI-95/0368.1); or
§63.772(b)(2)(ii) - The owner or operator shall determine an average
mass rate of benzene emissions in kilograms per hour through direct
measurement using the methods in §63.772(a)(1)(i) or (ii), or an
alternative method according to §63.7(f). Annual emissions in
kilograms per year shall be determined by multiplying the mass rate
by the number of hours the unit is operated per year. This result shall
be converted to megagrams per year.
• §63.774 - Recordkeeping Requirements
o §63.774 (d)(1) - An owner or operator of a glycol dehydration unit that meets the
exemption criteria in §63.764(e)(1)(i) or §63.764(e)(1)(ii) shall maintain the records
specified in paragraph (d)(1)(i) or paragraph (d)(1)(ii) of this section, as appropriate,
for that glycol dehydration unit.
• §63.774 (d)(1)(ii) - The actual average benzene emissions (in terms of
benzene emissions per year) as determined in accordance with
§63.772(b)(2).
15. 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)
Monitoring and Testing Requirements
16. The inlet gas temperature and inlet gas pressure shall be measured and recorded monthly.
17. 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 Condition no. 4.
Additional Requirements
18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Reg.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 there is an 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.
19. All previous versions of this permit are cancelled upon issuance of this permit.
20. 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
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Colorado Department of Public Hee DRAFT
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to emit equal 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.
21. Prevention of Significant Deterioration (PSD) requirements shall apply to this source at any such
time that this source becomes major for PSD solely by virtue of a relaxation in any permit
condition. Any relaxation that increases the potential to emit above the applicable PSD threshold
will require a full PSD review of the source as though construction had not yet commenced on the
source. The source shall not exceed the PSD threshold until a PSD permit is granted.
(Reference: Regulation No.3, Part D, Section VI.B.4.)
22. Major stationary source requirements for non -attainment areas shall apply at 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 major stationary source threshold will result
in this source being subject to Major Stationary Source requirements of Regulation No. 3, Part D,
Section V. This source shall not exceed the major stationary source threshold until compliance
with Regulation No. 3., Part D, Section V. has been achieved.
By:
Matthew S. Burgett, P.E.
Permit Engineer
Permit History
Issuance
Date
Description
IA Modification No. 1
This Issuance
Issued to Kerr-McGee Gathering, LLC. Facility
intends to drop out of Title V permitting.
Title V Operating
Permit 95OPWE033
March 27, 2006
Issued to Kerr-McGee Gathering LLC.
Title V Operating
Permit 95OPWE033
May 10, 2002
Issued to Kerr-McGee Rocky Mountain Corp.
Requirements modified via the Title V permit.
Addition of flare. Natural gas throughput limit =
14,600 MMscf, VOC limit = 11 ton/yr.
Title V Operating
Permit 95OPWE033
April 3, 2000
Issued to HS Resources, Inc.
Title V Operating
Permit 95OPWE033
March 11, 1999
Requirements modified via the Title V permit.
Natural gas throughput limit = 14,600 MMscf,
VOC limit = 197 ton/yr.
Title V Operating
Permit 95OPWE033
November 1, 1997
Requirements modified via the Title V permit.
Natural gas throughput limit = 14,600 MMscf,
VOC limit = 168 ton/yr.
Initial Approval
December 16, 1996
Issued to KN Wattenberg Transmission Limited
Liability. Natural gas throughput limit = 29,200
MMscf, VOC limit = 165.2 ton/yr.
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Colorado Department of Public Hee Air Polk DRAFT
PERMIT
Notes to Permit Holder:
1) The production or raw material processing limits and emission limits contained in this permit are
based on the production/processing rates requested in the permit application. These limits may be
revised upon request of the permittee providing there is no exceedence 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/100102agcccommonprovisionsreg.pdf.
3) The following emissions of non -criteria reportable air pollutants are based upon the emissions as
reported in the most recent APEN submittal. This information is listed to inform the operator of the
Division's analysis of the specific compounds. This information is listed on the Division's emission
inventory system.
C.A.S. # SUBSTANCE EMISSIONS fLB/YRj
71-43-2 Benzene 459
4) The emission levels contained in this permit are based on information provided in the application and
the GRI GlyCalc model. Combustion emission factors from AP -42 Table 13.5-1 (1/95).
NOx = 0.068 lb/106 Btu
CO = 0.37 lb/106 Btu
5) This emission unit is classified as a: Synthetic Minor Source. This facility is classified as follows:
Applicable Requirement
Status
Operating Permit
Synthetic Minor
PSD
Synthetic Minor
NA NSR
Synthetic Minor
MACT HH
Synthetic Minor
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PERMIT
GENERAL TERMS AND CONDITIONS: (IMPORTANT! READ ITEMS 5,6,7 AND 8)
1. 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.
2. 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.
3. 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 final approval 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.
4. This permit and any required attachments must be retained and made available for inspection upon
request at the location set forth herein. With respect to a portable source that is moved to a new
location, a copy of the Relocation Notice (required by law to be submitted to the APCD whenever a
portable source is relocated) should be attached to this permit. 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.
5. Issuance (initial approval) of an emission permit does not provide "final" authority for this activity or
operation of this source. Final approval 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 approval 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. If the APCD so
determines, it will provide written documentation of such final approval, which does constitute "final"
authority to operate. Compliance with the permit conditions must be demonstrated within 180
days after commencement of operation.
6. THIS PERMIT AUTOMATICALLY EXPIRES IF you (1) do not commence construction or operation
within 18 months after either the date of issuance of this permit or the date on which such construction
or activity was scheduled to commence as set forth in the permit, whichever is later; (2) discontinue
construction for a period of 18 months or more; or (3) do not complete construction within a reasonable
time of the estimated completion date. Extensions of the expiration date may be granted by the APCD
upon a showing of good cause by the permittee prior to the expiration date.
7. YOU MUST notify the APCD no later than thirty days after commencement of the permitted
operation or activity by submitting a Notice of Startup (NOS) form to the APCD. The
Notice of Startup (NOS) form may be downloaded online at
www.cdphe.state.co.us/ap/downloadforms.html. Failure to do so is a violation of Section 25-7-
114.5(12)(a), C.R.S. and AQCC Regulation No. 3, Part B, Section III.G.1., and can result in the
revocation of the permit. You must demonstrate compliance with the permit conditions within 180 days
after commencement of operation as stated in condition 5.
8. 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.
9. 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.
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