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Home My WebLink About20083803.tiff 4je:7) Weld County Planning Department GREELEY OFFICE MAR 2 8 ?pm RECE STATE OF COLORADO Bill Ritter,Jr.,Governor James B.Martin,Executive Director pF cow Dedicated to protecting and improving the health and environment of the people of Colorado y- o 4300 Cherry Creek Dr.S. Laboratory Services Division Denver,Colorado 80246-1530 8100 Lowry Blvd. *1876 Phone(303)692-2000 Denver,Colorado 80230-6928 TDD Line(303)691-7700 (303)692-3090 Colorado Department Located in Glendale,Colorado of Public Health http://www.cdphe.state.co.us and Environment March 21, 2008 Mr. Steve Moreno Weld County Clerk 1402 N. 17th Ave. Greeley, CO 80631 Dear Mr. Moreno: The Air Pollution Control Division will publish a public notice for Kerr- McGee Gathering, LLC. This public notice will be published in the Fort Lupton Press on April 2, 2008. 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 Re ds, Jac el' N. Barela Public Notice Coordinator Stationary Sources Program Air Pollution Control Division (--D ?eV/ .."1.4--) PL/ 1/1_ o4 Zoc838o 3 NOTICE OF REQUEST FOR SYNTHETIC MINOR FOR Kerr-McGee Gathering LLC PERMIT NOs. 07WE0798 & 07WE0799 TABLE OF CONTENTS 1. PUBLIC NOTICE 2. PRELIMINARY ANALYSIS 3. PERMIT APPLICATION 4. AIR POLLUTANT EMISSIONS NOTICES 5. DRAFT PERMITS Prepared by Matthew S. Burgett 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 .0V.cozo 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. 4, Phone(303)692-2000 Denver,Colorado 80230-6928 1876 TDD Line(303)691-7700 (303)692-3090 Colorado Department Located in Glendale,Colorado of Public Health http://www.cdphe.state.co.us and Environment Released to: Fort Lupton Press on March 21,2008;published on April 2,2008 PUBLIC NOTICE OF A PROPOSED PROJECT OR ACTIVITY WARRANTING PUBLIC COMMENT 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 two additional construction permits for the Fort Lupton Compressor Station located at 16116 WCR 22, Fort Lupton in Weld County, Colorado. Two new permits are requested for the installation of one new natural gas-fired engine for compression, and one new TEG Dehydration unit, which will replace an existing unit. Public comment is sought for these proposed additions due to the following reasons: • Potential emissions exceed the thresholds for Major Modification under the Prevention of Significant Deterioration (PSD) and nonattainment New Source Review (NSR) rules. With the issuance of the proposed federally enforceable permits to limit the potential to emit to below the Major Modification thresholds,the addition of these units will not be classified as a Major Modification under PSD and NSR. • The engine is subject to Regulation No. 8, Part E, Subpart III.FFFF: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (RICE) of 40 C.F.R. Part 63, Subpart ZZZZ, • Controlled annual emissions of NOx for these units exceeds 25 tons per year in a nonattainment area. 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 1 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). 07WE0798, 07WE0799 Facility Location Fort Lupton Compressor Station Source No. 123/0057 16116 WCR 22, Fort Lupton Review Engineer Matthew S. Burgett, P.E. Date March 21, 2008 Control Engineer Roland Hea, P.E. Project Description Kerr-McGee has proposed the following additions to the Fort LuptonCompressor Station: • Installation of one new Caterpillar G3616, Serial Number to be determined, natural gas-fired, four-cycle standard lean-burn, turbocharged, internal combustion reciprocating engine, site rated at 4262HP (AIRS ID 026). This unit will be equipped with an oxidation catalyst for control of emissions of VOC, CO and Formaldehyde. Facility ID: EU103. • Installation of one new triethylene glycol dehydrator, Make, Model &Serial Number to be determined, rated at 70 mmscf/day(AIRS ID 027). This unit will be equipped with a condenser and thermal oxidizer for control of emissions of VOC, and Hazardous Air Pollutants. This unit will replace an existing unit at the facility. Potential emissions exceed the thresholds for a Major Modification under the Prevention of Significant Deterioration (PSD) and nonattainment New Source Review (NSR) rules. With the issuance of the proposed federally enforceable permits to limit the potential to emit to below the Major Modification thresholds, the addition of these units will not be classified as a Major Modification under PSD and NSR. Emission Sources Engine: Combustion products, including Hazardous Air Pollutants(HAPs). TEG Dehydrator: Regenerator vent emissions and flash tank emissions along with combustion products from the control devices. Requested Pollutant Controlled Potential Emissions from the Emissions (tpy) Emissions (tpy) New Equipment Oxides of Nitrogen 32.5 32.5 Volatile Organic Compounds 23.5 244.9 Carbon Monoxide 13.6 111.2 Formaldehyde 1.6 6.8 Total HAPs 4.8 83.3 Regulatory Status Major Source for Operating Permit Applicability: emissions of NOx,VOC, CO& HAPs at the Fort Lupton Compressor Station exceed the thresholds for operating permits. The engine is subject to Regulation No. 8, Part E, Subpart III.FFFF: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (RICE) of 40 C.F.R. Part 63, Subpart ZZZZ. The TEG Dehydrator is subject to No. 8, Part E, Subpart III.Z: National Emissions Standards for Hazardous Air Pollutants for Source Category: Oil and Natural Gas Production and Natural Gas Transmission and Storage of 40 C.F.R. Part 63, Subpart HH. Ambient Impact Emissions are not expected to have an adverse impact on ambient air and formal Analysis modeling is not required. Public Comment Public comment is required for sources wishing to obtain federally enforceable emission Requirement limits to avoid a major modification under PSD and NSR. " Units subject to a National Emission Standard for Hazardous Air Pollutants are subject to public comment. Sources with projected controlled annual emissions exceeding 25 tons per year in a nonattainment area are subject to public comment. Air Pollution Control Division Construction Permit Application PLEASE READ INSTRUCTIONS ON REVERSE SIDE. 1. Permit to be issued to: Kerr-McGee Gathering LLC 2. Mailing Address: 1099 Eighteenth Street,Suite 1200, Denver,CO 80202 3. General Nature of Business: Natural Gas Compression SIC code(if known) 4922 4. Air Pollution Source Description: 1)Caterpillar G3616,Natural Gas Compressor Engine 2)70 MMscfd Glycol Dehydrator,natural gas fired Reboiler,equipped with an (List permit numbers if existing source, electric glycol pump and associated still vent. Equipped with a condenser and a thermal oxidizer to control VOC emissions. attach additional pages if needed) Is this a Portable Unit? No 5. Source Location Address(Include Location Map) If portable, include the initial location and home base location 16116 Weld County Rd 22 Fort Lupton,CO 80621 6. Reason for Application: (Check all that apply) X New or Previously Unreported Source Administrative Permit Amendments ❑ Modification of Existing Source ❑ Transfer of Ownership(Complete Section 9& 10 below) ❑ Request for Synthetic Minor Permit ❑ Company Name Change(Complete Section 9 below) ❑ Other: ❑ Other: 7. Projected Startup Date: Unknown Signature of Legally Authorized Person of Company listed in Section 1 Date Signed Don Anderson,Environmental&Regulatory Supervisor Phone: 720-929-6356 Type or Print Name and Official Title of Person Signing Above Fax: 8. Check appropriate box if you want: ,•''''''—` X Copy of preliminary analysis conducted by Division / X To review a draft of the permit prior to issuance r'RECEIVE_) These sections are to be completed only if a company name change or transfer of ownership has occurred. 1 1 10,Ng 9. Permit previously issued to: � APCD t 10.Transfer of Ownership Information ``��,,SourceSourres �.-'. Effective Date of Permit Transfer: "'" As responsible party for the emission source(s)listed above,I certify that the business associated with this source has been sold,and e to transf the permit to said party. ems-. 5- 5----07 Signature of Legally Authori d Person of Company listed in Section 9 /, DatSigned �n 1) D ZCe� '` ., 6-it V/ r0 i1 /2/G�.(' Phone: �� <.&3s Type or Print Name and Official Title of Pe son Signing Above S.`tr Fax: Mail completed application,APENs,and filing fee to: Colorado Department of Public Health and Environment http://www.cdphe.state.co.us/ap/stationary.html Air Pollution Control Division Phone: (303)692-3150 4300 Cherry Creek Drive South,APCD-SS-B1 Denver,Colorado 80246-1530 Revised August 2004 00 a) O O u O 0O0 o N C U N E ..O g ta.o E o tpoT � m � a C • .� O E ad al cn N c.") '-',, w U pp 'b .. N C\ w H a. 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" J co w � o o i -o G) o co a) m a U E 0 a) x u_ _ � CO CO Q °�) U 0 > CO J a - CD a 0 •r_ - CO ct � a m Q c1 u c) aa LLI CD N © N o Ce CD >+ N O C L 'O O 1- a) E 'L O O U C 'C Q d W C Z co W o C CD V a) d o >' O N Ce O Y (n O O E a) x NTo �' m o r U C (.Q )s. i .....- o CO) U) U m I )4 C • O —) O Z a) (a L C 6 O E C C La-) O co O O a) U U a O L o Z Z +r li 73 U .L to i a) O J C __ N U Z O O O N (O U (N O \. < Ea) c a 0 co a E, Q � N- c o o co _ � cn O Z ti DRAFT PERMIT PERMIT NO: 07WE0798 Initial Approval DATE ISSUED: ISSUED TO: Kerr-McGee Gathering LLC THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural Gas Compression facility,known as the Fort Lupton Compressor Station,located in the 16116 WCR 22,Fort Lupton,in Weld County,Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: One(1)Caterpillar G3616,Serial No.: TBD,site-rated at 4262 horsepower,@ 1000 rpm,turbo-charged,four- cycle standard lean burn natural gas fired,internal reciprocating combustion engine. This engine is used for Natural Gas Compression. This engine is equipped with air-fuel ratio control and an Oxidation Catalyst for emissions control. This engine may be replaced with another engine in accordance with the temporary engine replacement provision of the Alternate Operating Scenario(AOS), included in this permit as Attachment A. This engine will be incorporated into Operating permit number 95OPWE013 (see Note 5) 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. 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. EPA Method 9 shall be used to measure opacity. (Reference:Regulation No. 1, Section II.A.1.&4.) 2. The permit number shall be marked on the subject equipment for ease of identification.(Reference:Regulation Number 3,Part B,III.E.)(State only enforceable) 3. Emissions of air pollutants shall not exceed the following limitations(as calculated in the Division's preliminary analysis):(Reference:Regulation No.3,Part B,II.A.4) Pollutant Annual Limit(py) Monthly Limit(lb/month) Nitrogen Oxides 29.4 4988.7 Volatile Organic Compounds 18.1 3074.5 Carbon Monoxide 7.4 1257.0 Monthly limits are based on a 31-day month. 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 annual limits shall be determined on a rolling(12)month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate monthly emissions and keep a compliance record on site, or at a local field office with site responsibility for Division review. 4. This source shall be limited to a maximum 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,II.A.4) Consumption of natural gas as fuel shall not exceed 21.69 MMscf per month(31 days)and 255.36 MMscf per year. AIRS ID: 123/0057/026 Page 1 of 12 Kerr-McGee Gathering LLC Colorado Department of Publi ent Permit No.07WE0798 Air DRAFT ion Initial Approval PERMIT 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. 5. A source compliance test shall be conducted to measure the emission rate(s)for the pollutants listed below, using EPA approved methods. Oxygen shall also be measured using approved methods during the source compliance test. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30)days prior to testing. Engine operating parameters will be included in the analysis with emissions reported in parts per million dry volume and grams per actual horsepower-hour(g/BHP-Hr.)or pounds per million BTU (lb/MMBtu). No test shall be conducted without prior approval from the Division. Any stack 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.III.G.3) Oxides of Nitrogen Carbon Monoxide 6. This engine shall be equipped with a(n) Oxidation Catalyst capable of reducing uncontrolled emissions as follows: Pollutant Control Efficiency Carbon Monoxide At least 93.0% Volatile Organic Compounds At least 28.0% Formaldehyde At least 76.0% Operating parameters of the control equipment are identified in the operation and maintenance plan as specified in Attachment B. The identified operating parameters will replace the control efficiency requirement on the final permit. (Reference: Regulation No.3,Part B, IV.E.) AIRS ID: 123/0057/026 Page 2 of 12 Kerr-McGee Gathering LLC Colorado Department of Publi ent Permit No.07WE0798 Air DRAFT ion Initial Approval PERMIT 7. Within one hundred and eighty days(180) after commencement of operation, the applicant shall adopt and follow the operating and maintenance plan and record keeping format as specified in Attachment B,in order to demonstrate compliance on an ongoing basis with the requirements of this permit. (Reference:Regulation No. 3,Part B, Section III.G.7.) 8. Prevention of Significant Deterioration(PSD)requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable PSD threshold will require a full PSD review of the source as though construction had not yet commenced on the source. The source shall not exceed the PSD threshold until a PSD permit is granted. Regulation No.3 Part D,VI.B.4) 9. 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. 10. This source shall be subject to the requirements of Regulation Number 7,Section XVI(Control of emissions from stationary and portable engines in the 8-hour ozone control area). For lean burn reciprocating internal combustion engines,an oxidation catalyst shall be required.A lean burn reciprocating internal combustion engine is one with a normal exhaust oxygen concentration of 2%by volume,or greater. The emission control equipment required by this section XVI.B shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. 11. This source shall be subject to the requirements of Regulation Number 7,Section XVII.E-Control of emissions from new and relocated natural gas fired reciprocating internal combustion engines. 12. This source is subject to the requirements of: • Regulation No. 8, Part E, Subpart III.FFFF: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines(RICE) of 40 C.F.R. Part 63, Subpart ZZZZ, and • Regulation No. 8, Part E, Subpart I.A, National Emission Standards for Hazardous Air Pollutants for Source Categories: General Provisions, 40 CFR Part 63 including,but not limited to,the following: a. General Requirements: i. You must operate and maintain your stationary RICE,including air pollution control and monitoring equipment,in a manner consistent with good air pollution controlpractices for minimizing emissions at all times, including during startup,shutdown, and malfunction(§ 63.6605(b)). b. Emission limitations for new and reconstructed four stroke lean burn(4SLB)stationary RICE at 100 percent load plus or minus 10 percent(§63.6600(b)): i. Except during periods of startup,shutdown and malfunction: 1. Reduce CO emissions by 93 percent or more,or 2. Limit concentration of formaldehyde in the stationary RICE exhaust to 14 ppmvd or less at 15 percent oxygen. c. Operating limitations for new and reconstructed four stroke lean burn(4SLB)stationary RICE:(§ 63.6600(b)): i. Except during periods of startup,shutdown and malfunction: 1. Maintain the catalyst so that the pressure drop across the catalyst does not change by more than two inches of eater at 100 percent load plus or minus 10 percent from the pressure drop across the catalyst that was measured during the initial performance test,and 2. Maintain the temperature of the stationary RICE exhaust so that the catalyst inlet temperature is greater than or equal to 450°F and less than or equal to 1350°F AIRS ID: 123/0057/026 Page 3 of 12 Kerr-McGee Gathering LLC Colorado Department of Publi ent Permit No.07WE0798 Air DRAFT ion Initial Approval PERMIT d. Performance Testing Requirements i. Initial performance tests shall be conducted as required under§§ 63.6610 and 63.6620 and according to the provisions of§63.7. During the initial performance teat,you must demonstrate initial compliance with the emission limitations and operating limitations as required under§ 63.6630,and submit the Notification of Compliance Status according to the requirements of§ 63.6645. ii. Subsequent performance tests shall be conducted semiannually as required under§§ 63.6615 and 63.6620 and according to the provisions of§ 63.7. 1. After you have demonstrated compliance for two consecutive tests,you may reduce the frequency of subsequent performance tests to annually.If tle results of any subsequent annual performance test indicate the stationary RICE is not in compliance with the CO or formaldehyde emission limitation,or you deviate from any of your operating limitations,you must resume semiannual performance tests. e. Installation,Operating and Maintenance,Monitoring and Data Collection Requirements i. Install,operate and maintain each continuous parameter monitoring system(CPMS)as required under§ 63.6625 and according to the provisions of§63.8. ii. Except for monitor malfunctions,associated repairs,and required quality assurance or control activities(including,as applicable,calibration checks and required zero and span adjustments),you must monitor and collect data continuously at all times that the stationary RICE is operating as required under§63.6635(b) iii. You may not use data recorded during monitoring malfunctions,associated repairs,and required quality assurance or control activities in data averages and calculations used to report emission or operating levels.You must,however,use all the valid data collected during all other periods(§ 63.6635(c)). f. Notifications,Reports and Records i. You must report each instance of deviation from applicable emission and operating limitations as required under§63.6640,and according to the requirements of§63.6650. ii. You must also report each instance in which you did not meet the applicable requirements of the General Provisions in accordance with §63.6640(e) iii. You must submit all of the notifications to the Division as reqiired by §63.6645 and in accordance with §§ 63.7,63.8 and 63.9 that apply to you by the dates specified. iv. You must submit each report to the Division as required by § 63.6650 and in accordance with § 63.10 that apply to you by the dates specified. v. You must keep records as required by §§63.6655 and 63.6660,and in accordance with§ 63.10. AIRS ID: 123/0057/026 Page 4 of 12 Kerr-McGee Gathering LLC Colorado Department of Publi ent Permit No.07WE0798 Air DRAFT ion Initial Approval PERMIT 13. A revised Air Pollutant Emission Notice(APEN)shall be filed: (Reference: Regulation No. 3,Part A,II.C) a. Annually whenever a significant increase in emissions occur 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. 14. The serial number of the subject equipment shall be provided to the Division within one hundred and eighty days(180)after commencement of operation. (Reference:Regulation No. 3,Part B,III.E.) 15. Within one hundred and eighty days(180)after commencement of operation,compliance with the conditions contained on this permit shall be demonstrated to the Division.It is the permittee's responsibility to self-certify compliance with the conditions.Failure to demonstrate compliance within 180 days may result in revocation of the permit.(Reference: Regulation No.3,Part B,II.G.2). 16. 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 initial approval 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(See General Condition No.6.,Item 1.).The Division may grant extensions ofthe deadline per Regulation No.3,Part B,III.F.4.b.(Reference:Regulation No. 3,Part B,III.F.4.) By: By: Matthew S.Burgett,P.E. Roland Hea,P.E. Permit Engineer Unit Leader Permit History Issuance Date Description Initial Approval This Issuance Issuance of Initial Approval to Kerr-McGee Gathering LLC. AIRS ID: 123/0057/026 Page 5 of 12 Kerr-McGee Gathering LLC Colorado Department of Publi ent Permit No.07WE0798 Air DRAFT ion Initial Approval 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 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.l.of the Common Provisions Regulation.See: http://www.cdphe.state.co.us/regulations/airregs/100102agcccommonprovisionsreg.pdf. 3) The following emissions of non-criteria air pollutants(NCRPs)are estimated based upon the site-rated horsepower and requested fuel consumption information as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds. CAS Pollutant Uncontrolled Controlled % Control Reporting Reportable Emissions Emissions Threshold ? (lb/yr) (Ib/yr) (Ib/yr) 5000 Formaldehyde 13536.9 3248.9 76.0% 50 Yes 75070 Acetaldehyde 2143.3 2143.3 0.0% 50 Yes 107028 Acrolein 1317.8 1317.8 0.0% 50 Yes 71432 Benzene 112.8 112.8 0.0% 50 Yes 106990 1,3-Butadiene 68.5 68.5 0.0% 50 Yes 67561 Methanol 641.0 641.0 0.0% 1000 I No 110543 n-Hexane 284.6 284.6 0.0% 1000 1 No 4) The emission levels contained in this permit are based on the following emission factors: Emission Factors-Uncontrolled Emission Factors—Controlled CAS Pollutant lb/IVE iBtu g/bhp-hr lbIMMBtu g/bhp-hr NOx 0.2291 0.7000 0.2291 0.7000 CO 0.8182 2.5000 0.0573 0.1750 VOC 0.1958 0.6100 0.1410 0.4392 5000 Formaldehyde 0.0528 0.1645 0.0127 0.0395 75070 Acetaldehyde 0.0084 0.0260 0.0084 0.0260 107028 Acrolein 0.0051 0.0160 0.0051 0.0160 71432 Benzene 0.0004 0.0014 0.0004 0.0014 106990 1,3-Butadiene 0.0003 0.0008 0.0003 0.0008 67561 Methanol 0.0025 0.0078 0.0025 0.0078 110543 n-Hexane 0.0011 0.0035 0.0011 0.0035 Emission factors are based on a Brake-Specific Fuel Consumption Factor of 6867 btu/hp-hr and a site-rated horsepower value of4262. 5) This source is subject to the provisions of Regulation Number 3,Part C, Operating Permits(Title V of the 1990 Federal Clean Air Act Amendments). The provisions of this construction permit must be incorporated into the operating permit. The application for the modification to the Operating Permit is due within one year of commencement of the equipment covered by this permit. 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 subart is available on the EPA website at: http://www.epa.govittn/atw/area/fr18ja08.pdf AIRS ID: 123/0057/026 Page 6 of 12 Kerr-McGee Gathering LLC Colorado Department of Publi ent Permit No.07WE0798 Air DRAFT ion Initial Approval PERMIT 7) In accordance with C.R.S.25-7-114.1,the Air Pollutant Emission Notice(APEN)associated with this permit is valid for a term of five years. The five-year term for this APEN expires on February 28,2013. A revised APEN shall be submitted no later than 30 days before the five-year term expires. 8) This emission unit is classified as a: Synthetic Minor Source This facility is classified as follows: Applicable Requirement Status Operating Permit Major: NOx,VOC,CO,HAPs PSD Major: CO NANSR Major: NOx,VOC MACT ZZZZ Major: Formaldehyde AIRS ID: 123/0057/026 Page 7 of 12 Kerr-McGee Gathering LLC Colorado Department of Publi ent Permit No.07WE0798 Air DRAFT ion Initial Approval PERMIT • GENERAL TERMS AND CONDITIONS: (IMPORTANT! READ ITEMS 5,6,7 AND 8) I. 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 at least thirty days (fifteen days for portable sources) prior to 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: 123/0057/026 Page 8 of 12 Kerr-McGee Gathering LLC Colorado Department of Publi ent Permit No.07WE0798 Air DRAFT ion Initial Approval PERMIT _ ATTACHMENT A 1. Alternative Operating Scenarios The following Alternative Operating Scenario(AOS)for temporary engine replacement has been reviewed in accordance with the requirements of Regulation No.3.,Part A, Section IV.A,Operational FlexibilityAlternative Operating Scenarios,and Regulation No.3,Part B, Construction Permits,and Regulation No.3,Part D,Major Stationary Source Non-Attainment New Source Review and Prevention of Significant Deterioration,and 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. Note thatthe same fuel must be used in the replacement engine as in the existing engine. 1.1 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 a temporary replacement engine. "Temporary"is defined as in the same service for 90 operating days or less in any 12 month period. The 90 days is the total number of days that the engine is in operatnn. If the engine operates only part of a day,that day counts towards the 90 day total. Note that the compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring requred 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). 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. 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 to contemporaneously record the start and stop date of any engine replacement,the manufacturer,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. 1.1.1. 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 1.2. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 1.2. 1.2 Portable Analyzer Testing The permittee shall measure nitrogen oxide(NQ)and carbon monoxide(CO)emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven(7)operating days of commencing operation of the replacement engine. The seven days is the total number of days that the engine is in operation. If the engine operates only part of a day,that day counts towards the seven day total. 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 or short term emission limit,the results of the tests shall be converted to a lb/hr basis ani multiplied by the allowable operating hours in the month or year(whichever applies)in order to monitor compliance. If a AIRS ID: 123/0057/026 Page 9 of 12 Kerr-McGee Gathering LLC Colorado Department of Publi ent Permit No.07WE0798 Air DRAFT ion Initial Approval PERMIT _ 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. 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 theNOx 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 AIRS ID: 123/0057/026 Page 10 of 12 STATE OF COLORADO Bill Ritter,Jr.,Governor James B.Martin, Executive Director o?•COzo Dedicated to protecting and improving the health and environment of the people of Colorado ye o 4300 Cherry Creek Dr.S. Laboratory Services Division Denver,Colorado 80246-1530 8100 Lowry Blvd. *,� Phone(303)692-2000 Denver,Colorado 80230-6928 1876 TDD Line(303)691-7700 (303)692-3090 Colorado Department Located in Glendale,Colorado of Public Health http://www.cdphe.state.co.us and Environment ATTACHMENT B: General Operating and Maintenance Plan for Reciprocating Internal Combustion Engines February 26,2007 The Colorado Department of Public Health and Environment,Air Pollution Control Division(the Division)has developed the following General Operating and Maintenance Plan(O&M Plan)for natural gas-fired Reciprocating Internal Combustion Engines(RICE)that reduce emissions below major source thresholds,thus becoming a synthetic minor source in the State of Colorado. The General O&M Plan shall become the default O&M Plan for natural gas-fired RICE unless the source chooses to submit a specific O&M Plan to the Division for review and approval through the Final Approval permitting process. The source shall maintain records to demcnstrate compliance with either the General O&M Plan or another O&M Plan approved by the Division. The source shall provide documentation and recordkeeping to demonstrate compliance with the O&M Plan upon request by the Division. All engines shall comply with the following operating parameters and maintenance schedules: 1. The source shall follow the manufacturer's scheduled maintenance guide for the engine and document the date that activities were completed. If a company has established its own maintenance schedule then this schedule may be followed presuming it is consistent with good air pollution control practices for minimizing emissions as defined in the New Source Performance Standard(NSPS)general conditions. Determination of whether or not acceptable operating and maintenance procedures are being used will be based on information available to the Division,which may include,but is not limited to,monitoring results, opacity observations,review of operating and maintenance procedures,and inspecfon of the source. (Reference:Regulation No.6,Part A. General Provisions from 40 CFR 60.11) Parameters 2 and 3 apply only to rich burn engines equipped with an aiifuel ratio controller: 2. The source shall maintain records to verify that the air-fuel ratio controller(AFRC)is operated per the manufacturer's recommendations. The oxygen sensor millivolt(mV)reading of the AFRC shall be recorded per the schedule in Table 1. Additionally,the mV reading shall be tracked and recorded during each portable analyzer test. 3. The source shall follow the manufacturer's oxygen sensor replacement schedule if an oxygen sensor is utilized. If the equipment maintenance and replacement is dependent on the hours of operation then the hours shall be tracked and recorded and made available to the Division upon request. If the source is using a method other than hours of operation to track oxygen sensor replacement then tracking must be recorded and available to the Division upon request. Records of oxygen sensor replacement shall be made available to the Division upon request. 4. The source shall clean,recondition and replace the catalyst per the manufacturer's or packager's recommended schedule. A copy of this maintenance schedule shall be made available to the Divison upon request. If maintenance activities or actions are dependent upon hours of operation then engine operating hours shall be recorded and made available to the Division upon request. Records of the catalyst cleaning, reconditioning or replacement shall be documented and made available to the Division upon request. 5. The source shall record the inlet temperature into the catalyst per the schedule specified in Table 1. AIRS ID: 123/0057/026 Page 11 of 12 Kerr-McGee Gathering LLC Colorado Department of Publi ent DRAFT Permit No.07WE0798 Air ion Initial Approval PERMIT • For a rich burn engine with non-selective catalytic reduction(NSCR)emission control equipment the temperature into the catalyst shall be operated between 750°F and 1250°F. • For a lean burn engine with an oxidation catalystemission control equipment,the temperature shall be operated between 450°F and 1350°F. If the temperature is outside this range then the appropriate maintenance activities shall be performed. 6. The source shall monitor and record the pressure drop across the catalyst monthly. The pressure differential shall not deviate by more than 2 inches of water column from tie baseline value established by the source when the engine is operating at 90%- 110%load. Baseline pressure differential shall be established by the source and recorded during each portable analyzer test. If the pressure differential exceeds baseline Values by more 2 inches water column then the appropriate maintenance shall be performed. Note: If the pressure differential is not within the parameters established during a baseline performance test, then the source may forgo maintenance activities and perform a portable analyzer test of the engine to establish new pressure differential baseline. The most recent baseline pressure differential established during portable analyzer testing shall be used to determine compliance. 7. Compliance demonstration: a. Existing Permitted Engines: i. Pressure differential across the control equipment shall be established within the first 100 hours of engine operations from the date that the catalyst is cleaned,reconditioned,or replaced. b. Newly Permitted Engines or Engines Associated with a Permit Modification: i. Pressure differential across the control equipment shall be established within 180 days from the date of equipment startup for newly permitted engines or within 180 days from the date of permit issuance for engines associated with a modified permit. 8. The source shall perform portable analyzer testing for NOx,CO and O2 per the schedule in Table 1. Portable analyzer testing shall follow the Division's approved protocol and shall include emissions testing at the outlet of the catalyst. The protocol can be found at the Division's web page at the following link: httu://www.cdohe.state.co.us/ao/down/nortanalyzeoroto.ndf Table 1 Facility Permitted Emission Records of Record of Limits Inlet AFRC milli- Portable Analyzer Testing Temperature volt reading Engines at facilities with NOx or Quarterly Testing CO emissions greater than or If monitoring demonstrates compliance during equal to 80 tons per year. four consecutive quarters then the source shall Including portable engines Daily Weekly be allowed to test semi-annually. If any of the moved to these facilities semi-annual tests fail then the source shall return to quarterly tests. Engines at facilities with NOx or Semi-annually Testing CO emissions less than 80 tons If monitoring demonstrates compliance during per year. Including portable Weekly Weekly two consecutive semi-annual tests then the engines moved to these facilities source shall be allowed test annually. If any of the annual tests fail then the source shall return to semi-annual testing. All synthetic minor engines that do not have emission control equipment shall conduct portable exhaust gas analysis testing at least once per calendar year. AIRS ID: 123/0057/026 Page 12 of 12 DRAFT • PERMIT PERMIT NO: 07WE0799 Initial Approval DATE ISSUED: ISSUED TO: Kerr-McGee Gathering LLC THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural gas compression facility,known as the Fort Lupton Compressor Station,located at 16116 WCR 22,Fort Lupton, in Weld County,Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: One triethylene glycol dehydrator,Make,Model,and Serial No.: TBD,rated at 70 mmscf/day. The dehydrator emissions are controlled with a condensor&thermal oxidizer(regenerator emissions)and reboiler heater(flash gas emissions). Emission streams from the dehydrator are configured as follows: Flash tank emissions are routed to the reboiler heater, or the thermal oxidizer(if the heater is not operational). Regenerator vent emissions are routed to the 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: 1. The permit number shall be marked on the subject equipment for ease of identification.(Reference:I1gulation Number 3,Part B,III.E.)(State only enforceable) 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 visibb 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.) 3. This source shall be limited to a maximum lean glycolpump rate as listed below and all other activities, operational rates and numbers of equipment as stated in the application. Monthly records of the actual pump rate shall be maintained by the applicant and made available to the Division for inspection upon request. (Reference:Regulation No.3,Part B,II.A.4) Lean glycol recirculation pumping rate shall not exceed12.0 gallons per minute AIRS ID: 123/0057/027 Page 1 of 7 Kerr-McGee Gathering LLC Colorado Department of Publi lent Permit No.07WE0799 Air DRAFT ion Initial Approval PERJVIIT 4. Emissions of air pollutants shall not exceed the following limitations(as calculated in the Division's preliminay analysis): (Reference:Regulation No.3,Part B,II.A.4) Pollutant Annual Limit Monthly Limit (tpy) (lb/month) Oxides of Nitrogen: 3.1 526.6 Carbon Monoxide: 6.3 1070.1 Volatile Organic Compounds: 5.7 968.2 Benzene: 0.992 168.5 Each Individual Hazardous Air Pollutant(from all the glycol 8.0 1,358.9 dehydration units and storage vessels with the potential for flash at this facility): Total Hazardous Air Pollutants(from all the glycol dehydration 20.0 3,397.3 units and storage vessels with the potential for flash at this facility): Monthly limits are based on a 31-day month. The above Benzene emission limit is included to limit Benzene emissions such that this source will remain an"exempt"area source for MACT Subpart HH requirements. Compliance with the annual limits shall be determined on a rolling(12)month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate monthly emissions and keep a compliance record on site, or at a local field office with site responsibility for Division review. Emissions from all the glycol dehydration units and storage vessels with the potential for flash at this facility shall be included in the HAP limits as noted above. 5. This source shall be limited to a maximum 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,II.A.4). Processing of wet natural gas shall not exceed 2170 million scf per month(31 days)and 25,550 million scf per year. 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. 6. A GRI GlyCALC 4.0 analysis shall be performed monthly to calculate emissions. A new extended gas analysis shall be performed annually and made available to the Division for inspection upon request. 7. The reboiler burner shall be operating at all times that flash gas emissions are vented to it. Emissions may be routed to the thermal oxidizer in the event that the reboiler burner is not operational. Compliance with this requirement shall be recorded in a log on a daily basis whenever the Glycol Dehydrator is in operation,and shall be maintained by the applicant and made available to the Division for inspection upon request. AIRS ID: 123/0057/027 Page 2 of 7 Kerr-McGee Gathering LLC Colorado Department of Publi tent Permit No.07WE0799 Air DRAFT ion Initial Approval PER1VIIT 8. This source shall be equipped with a thermal oxidizer capable of reducing uncontrolled emissions of VOC and HAPs by at least 99.0%. Operating parameters of the control equipment shall be identified in the operation and maintanence plan to be submitted with the compliance certification within one hundred and eighty days(180) after commencement of operation. The identified operating parameters will replace the control efficiency requirement on the final permit.(Reference: Regulation No.3,Part B, Section III.E.) 9. Within one hundred and eighty days(180)after commencement of operation,a source compliance:est shall be conducted on the thermal oxidizer to measure the emission rate(s)for the pollutants listed below in order to show compliance with the emission limits and contrd efficiency. 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 compliaice test shall be conducted without prior approval from the Division. Emissions shall be reported in parts per million dry volume and lb/mmscf. Any stack test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time(Reference:Regulation No. 3,Part B., Section III.G.3) Volatile Organic Compounds using EPA approved methods. 10. Within one hundred and eighty days(180)after commencement of operation,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.) 11. 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. 12. The make,model,and serial number of the subject equipment shall be provided to the Division within one hundred and eighty days(180)after commencement of operation. (Reference:Regulation No.3,Parc B,III.E.) 13. Within one hundred and eighty days(180)after commencement of operation,compliance with the conditions contained on this permit shall be demonstrated to the Division. It is the permittee's responsibility to self-certify compliance with the conditions.Failure to demonstrate compliance within 180 days may result in revocation of the permit.(Reference: Regulation No. 3,Part B,II.G.2). 14. 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 initial approval permit or the date on which such cmstruction 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 tie estimated completion date(See General Condition No.6.,Item 1.).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.) AIRS ID: 123/0057/027 Page 3 of 7 Kerr-McGee Gathering LLC Colorado Department of Publi sent Permit No.07WE0799 Air DRAFT ion Initial Approval PERMIT _ 15. This source is subject to the odor requirements of Regulation No.2. (State only enforceable) 16. Any still vent and vent from any gas-condensate-glycol(GCG)separator(flash separator or flash tank),if present,on a glycol natural gas dehydrator located at an oil and gas exploration and production operaion, natural gas compressor station,drip station or gas-processing plant in the 8-hour Ozone Control Area shall reduce uncontrolled actual emissions of volatile organic compounds by at least 90 percent through the use of a condenser or air pollution control equipment(Regulation No. 7,XII.C). All air pollution control equipment required by this section XII shall be operated and maintained consistent with manufacturer specifications and good engineering and maintenance practices.The owner or operator shill keep manufacturer specifications on file. In addition,all such air pollution control equipment shall be adequately designed and sized to achieve the control efficiency rates required by this Section XII and to handle reasonably foreseeable fluctuations in emissions of volatile organic compounds.Fluctuations in emissions that occur when the separator dumps into the tank are reasonably foreseeable. The combustion device shall be enclosed,have no visible emissions,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,such as a continuous monitoring device,approved by the division,determine whether it is operating properly. 17. The following permit and AIRS Point will be canceled upon issuance of this permit: 01WE0370, 123/0057/019. 18. This source is subject to the TEG dehydrator area source requirements of 40 CFR,Part 63, Subpart HI-I- National Emission Standards for Hazardous Air Pollutants for Sotrce 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 (1.0 tons Benzene/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-GLYCalc TM , 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 AIRS ID: 123/0057/027 Page 4 of 7 Karr-McGee Gathering LLC Colorado Department of Publi lent Permit No.07WE0799 Air DRAFT ion Initial Approval PERMIT 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). By: By: Matthew S.Burgett,P.E. Roland Hea,P.E. Permit Engineer Unit Leader AIRS ID: 123/0057/027 Page 5 of 7 Kerr-McGee Gathering LLC Colorado Department of Publi tent Permit No.07WE0799 Air DRAFT ion Initial Approval PER1VIIT , 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 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/100102agcccommonprovisionseg.pdf. 3) The following emissions of non-criteria air pollutants(NCRPs)are estimated based upon the requested throughput information as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds. CAS Pollutant Uncontrolled Controlled % Control Reporting Reportable Emissions Emissions Threshold ? (lb/yr) (lb/yr) (Ib/yr) 1330207 Xylenes 10,452 80 99.24 1000 Yes (mixed isomers) 110543 n-Hexane 10,287 266 97.41 1000 Yes 71432 Benzene 67,941 709 98.96 50 Yes 108883 Toluene 59,559 573 99.04 1000 Yes 4) Emissions in this permit have been calculated using GRI GlyCALC 4.0. Combustion emissions are based on the following emission factors:NOx=0.138 lb/mmbtu,CO=0.2755 lb/mmbtu. 5) This source is subject to the provisions of Regulation No.3,Part C,Operating Permits(Title V of the 1990 Federal Clean Air Act Amendments).The application for the Operating Permit is due within one year of commencing operation. 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 January 9,2013. A revised APEN shall be submitted no later than 30 days before the five-year term expires. 7) This emission unit is classified as a: Minor Source This facility is classified as follows: Applicable Requirement Status Major: Operating Permit NOx,VOC,CO,HAPs PSD Major: CO NANSR Major: NOx,VOC MACT HH This unit is classified as an Area Source under Subpart HH AIRS ID: 123/0057/027 Page 6 of 7 'Kerr-McGee Gathering LLC Colorado Department of Publi tent Permit No.07WE0799 Air DRAFT ion Initial Approval 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 at least thirty days (fifteen days for portable sources) prior to 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: 123/0057/027 Page 7 of 7 Hello