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KERR-MCGEE GATHERING LLC 1099 18TH STREET • DENVER, COLORADO 80202 720-929-6000 411 KerrNtGee June 13, 2008 Weld County Planning and Zoning Department of Planning Services Attn: Kim Ogle 918 10th Street Greeley, Colorado 80631 Re: Mylar Submittal AMUSR- 468 Township 1 North, Ranqe 66 West, 6th P.M. Section 14: Part of the NW/4 Weld County, Colorado Dear Mr. Ogle: Please find the attached final Mylar for the above referenced Amended Use By Special Review for our Dougan Compressor Station site. We are also submitting recording fees for recording of the attached. Thank you for your assistance with this process. Please feel free to contact me at 720.929.6521 if you have any further questions regarding this matter. Sincerely yours, Kerr-McGee Gathering LLC CfPc alai Cheryl L. Diedrich Senior Landman Attachments cc: Patrick Groom A SUBSIDIARY OF ANADARKO PETROLEUM CORPORATION KERR-MCGEE GATHERING LLC 1099 18TH STREET • DENVER, COLORADO 80202 720-929-6000 k'i KerrlvtGee May 2, 2008 Weld County Planning and Zoning Department of Planning Services Attn: Kim Ogle 918 10`h Street Greeley, Colorado 80631 Re: Paper Copies for Mylar Submittals 2" AMUSR 468 Township 1 North, Range 66 West, 6'h P.M. Section 14: Part of NW4 Weld County, Colorado Dear Mr. Ogle: Please find attached three (3) copies of the above referenced 2ND AMUSR paper copies for the Mylar submittals along with the resolution requirements as set forth. The Condition #1.C. regarding the sewer system inspection has been forwarded to our Brighton office. They will forward approval of the system as per the condition requirements as soon as possible. Thank you for your review of this submittal. Upon your approval we will submit the final Mylar. I will be looking forward to hearing from you. Please feel free to contact me at 720.929.6521 if you have any further questions regarding this matter. Sincerely yours, Kerr-McGee Gathering LLC Cheryl L. Diedrich Senior Landman Attachments cc: Patrick Groom A SUBSIDIARY OF ANADARKO PETROLEUM CORPORATION Kerr-McGee Gathering, LLC Fugitive Dust Abatement Plan 2"d AMUSR- 468 Compressor Station 1. Control of unpaved roads on site. a. Watering as needed. b. Application of chemical stabilizer as needed. c. Vehicle speed limited to 10 MPH. d. Gravel will be utilized on facility roadways. 2. Control of disturbed surface areas on site. a. Watering as needed. b. Application of chemical stabilizer as needed. c. Vehicle speed limited to 10 MPH. d. Wind breaks will be utilized as needed. 3. Prevention of mud and dirt carried out onto paved surfaces. a. Gravel or pavement at entrance. b. Cleaning of vehicles as needed. Kerr-McGee Gathering, LLC Federal Lighting Requirements 2nd AMUSR- 468 Dougan Compressor Station Kerr-McGee's proposed tower complies will all federal lighting and marking requirements. Pursuant to 49 U.S.C. § 44718 and 14 C.F.R. § 77.13, towers in excess of 200 feet require FAA notification. The proposed tower will be smaller than 200 feet. Kerr-McGee Gathering, LLC Screening Plan 2nd AMUSR- 468 Dougan Compressor Station The facility covered by the subject USR has been in operation in Weld County for many years. The sort of operation does not generate any significant volume of waste requiring storage on site nor does it require storage of other materials on site. Waste is stored within containers provided by the waste removal company retained to handle the waste generated. Legacy operation in this manner has not resulted in any unsightly conditions at the facility. The plan is to continue operating with the storage of waste and materials secured within the facility boundary fence at the location specified on the associated plat for this facility. Kerr-McGee Gathering, LLC Lighting Plan rd AMUSR- 468 Dougan Compressor Station Kerr-McGee maintain's facility lighting for the safety of its employees. Facility lighting is and will remain downcast and pointed away from road,to the extent possible, so as not to interfere with area residents or drivers on roadway. Lights will be on for employee safety and security as needed. Kerr-McGee Gathering, LLC Signage Plan 2nd AMUSR- 468 Dougan Compressor Station Ken McGee has two facility identification signs located at the facility. A large 6' X4' sign listing the company name, the facility name and address is located at the entrance and facing the roadway. A smaller 24"X 18" sign repeating all information on the larger sign in addition to emergency phone numbers is located on the facility entrance gate. OS y . 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W KERR-MCGEE GATHERING LLC 1099 18TH STREET • DENVER, COLORADO 80202 720-929-6000 411 KerrlvtGee April 18, 2008 Weld County Planning and Zoning Department of Planning Services Attn: Kim Ogle 918 10`h Street Greeley, Colorado 80631 Re: Paper Copies for Mylar Submittals Re: Amended SUP 211 Ft. Lupton Compressor Station Township 2 North, Range 66 West, 6th P.M. Section 14: Part of NW4 Weld County, Colorado Dear Mr. Ogle: Please find attached three (3) copies each of the above referenced USR paper copies for the Mylar submittals and resolution requirement responses. Upon approval we will submit the final Mylars. Thank you for your review of this submittal. I will be looking forward to hearing from you. Please feel free to contact me at 720.929.6521 if you have any further questions regarding this matter. Sincerely yours, Kerr-McGee Gathering LLC & ` Cheryl L. Diedrich Senior Landman Attachments cc: Patrick Groom A SUBSIDIARY OF ANADARKO PETROLEUM CORPORATION . O? ' COlp w e i -,...riri Fag 2 N*%- rn c%gq N 0 K4 ..SINE NIJM��1876 14` Colorado Department of Public Health and Environment OPERATING PERMIT Ken-McGee Gathering LLC - Dougan Compressor Station First Issued November 1 , 1997 Renewed: December 1 , 2004 Last Revised: March 27, 2006 I AIR POLLUTION CONTROL DIVISION COLORADO OPERATING PERMIT FACILITY NAME: Dougan Compressor OPERATING PERMIT NUMBER Station FACILITY ID: 1230185 RENEWED: December 1, 2004 95OPWE033 EXPIRATION DATE: December 1,2009 MODIFICATIONS: See Appendix F of Permit Issued in accordance with the provisions of Colorado Air Pollution Prevention and Control Act, 25-7-101 et .m. and applicable rules and regulations. ISSUED TO: PLANT SITE LOCATION: Kerr-McGee Gathering LLC Sec. 14,TIN, R66W/16280 Weld County RD 10 1999 Broadway, Suite 3600 Fort Lupton,CO Denver,CO 80202 Weld County INFORMATION RELIED UPON Operating Permit Renewal Application Received: October 11,2001 And Additional Information Received: January 27, January 31 and July 18, 2003 and March 4 and July 12, 2004 Nature of Business: Natural Gas Gathering and Compression Primary SIC: 1311 RESPONSIBLE OFFICIAL FACILITY CONTACT PERSON Name Robert E. Justice Name: Jill Henderson Title: Manager, ICMG Gathering LLC Title: Senior Environmental Specialist Phon (303) 659-5922 Phone: (303)296-3600 SUBMITTAL DEADLINES First Semi-Annual Monitoring Period: December 1 —March 31 Subsequent Semi-Annual Monitoring Periods: April 1 - September 30, October 1 -March 31 Semi-Annual Monitoring Report: Due May 1, 2005 &November 1, 2005&subsequent years First Annual Compliance Period: December 1 —March 31 Subsequent Annual Compliance Period: April 1 -March 31 Annual Compliance Certification: Due May 1,2005 and subsequent years Note that the Semi-Annual Monitoring Reports and Annual Compliance Certifications must be received at the Division office by 5:00 p.m. on the due date. Postmarked dates will not be accepted for the purposes of determining the timely receipt of those reports/certifications. TABLE OF CONTENTS: SECTION I -General Activities and Summary 1 1. Permitted Activities 1 2. Alternative Operating Scenarios 2 3. Prevention of Significant Deterioration 4 4. Accidental Release Prevention Program(I 12(r)) 4 5. Compliance Assurance Monitoring(CAM) 5 6. Summary of Emission Units 5 SECTION II- Specific Permit Terms 6 1. Unit EU-21 -Cooper Bessemer Internal Combustion Engine 6 2. Unit D-01 -Custom Glycol Dehydration Unit Equipped with an Air-Assisted Flare 10 3. Unit F001 -Fugitive VOC Emissions from Equipment Leaks 15 4. T001 -Condensate Storage Tank Battery 16 5. Ozone Early Action Compact Requirements—State-Only Requirements 24 SECTION III-Permit Shield 28 1. Specific Non-Applicable Requirements 28 2. General Conditions 28 3. Streamlined Conditions 29 SECTION IV-General Permit Conditions 30 1. Administrative Changes 30 2. Certification Requirements 30 3. Common Provisions 30 4. Compliance Requirements 33 5. Emergency Provisions 34 6. Emission Standards for Asbestos 34 7. Emissions Trading,Marketable Permits, Economic Incentives 34 8. Fee Payment 35 9. Fugitive Particulate Emissions 35 10. Inspection and Entry 35 11. Minor Permit Modifications 35 12. New Source Review 36 13. No Property Rights Conveyed 36 14. Odor 36 15. Off-Permit Changes to the Source 36 16. Opacity 36 17. Open Burning 36 18. Ozone Depleting Compounds 36 19. Permit Expiration and Renewal 36 20. Portable Sources 37 21. Prompt Deviation Reporting 37 22. Record Keeping and Reporting Requirements 37 23. Reopenings for Cause 38 24. Section 502(6)(10)Changes 38 25. Severability Clause 38 26. Significant Permit Modifications 39 27. Special Provisions Concerning the Acid Rain Program 39 • TABLE OF CONTENTS: 28. Transfer or Assignment of Ownership 39 29. Volatile Organic Compounds 39 30. Wood Stoves and Wood burning Appliances 40 APPENDIX A-Inspection Information 1 Directions to Plant: 1 Safety Equipment Required: Facility Plot Plan. 1 List of Insignificant Activities: Appendix B 1 Reporting Requirements and Definitions 1 Monitoring and Permit Deviation Report-Part I 5 Monitoring and Permit Deviation Report -Part II 7 Monitoring and Permit Deviation Report -Part III 9 APPENDIX C 1 Format for Annual Compliance Certification Reports 1 APPENDIX D 1 Notification Addresses 1 APPENDIX E 1 Permit Acronyms 1 APPENDIX F 1 Permit Modifications 1 APPENDIX G 1 Compliance Assurance Monitoring Plan 1 Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit# 95OPWE033 Page 1 SECTION I- General Activities and Summary 1. Permitted Activities 1.1 This facility consists of one natural gas reciprocating compressor engine and a glycol dehydration unit designed to compress and condition natural gas for transmission to sales pipelines. Fugitive VOC emissions from equipment leaks and VOC emissions from condensate storage tanks are above APEN de minimis levels (2 tpy). The station receives natural gas from nearby gas fields. Condensates are separated by gravity from the field gas and stored in above ground tanks for transport off the site by truck. The reciprocating engine powers a compressor to pressurize the gas which is then dehydrated via contact with triethylene glycol within the dehydration unit. The dehydrator is equipped with a flare to control VOC emissions. Moisture is driven off the glycol by evaporation. Compressed gas is then delivered to sales pipelines. The facility is located near Fort Lupton, Colorado, in rural Weld County, an area, which is designated as attainment for all criteria pollutants, but is located in the 8-hr Ozone Control Area as defined in the Federal Register,Volume 69,No. 84,dated April 30, 2004. There are no affected states within 50 miles of the plant. The following designated Federal Class I areas are within 100 kilometers of the plant: Rocky Mountain National Park. 1.2 Until such time as this permit expires or is modified or revoked, the permittee is allowed to discharge air pollutants from this facility in accordance with the requirements, limitations, and conditions of this permit. 1.3 This Operating Permit incorporates the applicable requirements contained in the underlying construction permits, and does not affect those applicable requirements, except as modified during review of the application or as modified subsequent to permit issuance using the modification procedures found in Regulation No. 3, Part C. These Part C procedures meet all applicable substantive New Source Review requirements of Part B. Any revisions made using the provisions of Regulation No. 3, Part C shall become new applicable requirements for purposes of this Operating Permit and shall survive reissuance. This permit incorporates the applicable requirements (except as noted in Section II) from the following construction permits (formerly issued to KN Wattenberg Transmission, LLC): 13WE204 and 94WE760-1. 1.4 All conditions in this permit are enforceable by US Environmental Protection Agency, Colorado Air Pollution Control Division (hereinafter Division) and its agents, and citizens unless otherwise specified. State-only enforceable conditions are: Permit Condition Number(s): Section II, Condition 5 (ozone early action compact requirements) and Section IV - Conditions 3.g, 14 and 18 (as noted). 1.5 All information gathered pursuant to the requirements of this permit is subject to the Recordkeeping and Reporting requirements listed under Condition 22 of the General Conditions in Section IV of this permit, unless otherwise specified. All records required by General Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit#95OPWE033 Page 2 Condition 22 are to be retained at Kerr-McGee's Denver Office. Either electronic or hard copy records are acceptable. 2. Alternative Operating Scenarios The following Alternative Operating Scenario (AOS) for temporary and permanent engine replacement has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility-Alternative Operating Scenarios, and Regulation No. 3, Part B, Construction Permits,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. For purposes of Regulation No. 3, Part B, Section III.F.4.a., any engine replacement authorized under this AOS shall commence operation upon notation of same in the contemporaneous log as required below. Results of any testing required below shall be used for comparison to the applicable permitted emission limits. 2.1 Temporary Engine Replacement(ver 7/18/03) The following AOS is incorporated into this permit in order to deal with a compressor engine breakdown or periodic maintenance and repair 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 operation. If the engine operates only part of a day, that day counts towards the 90 day total. Note that the compliance demonstrations made as part of this AOS are in addition to any compliance demonstrations required by this permit. 2.1.1 The pennittee 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 described in Conditions 2.1.2 or 2.1.6 below. Measurement of emissions from the temporary replacement engine shall be made as follows: The permittee shall measure nitrogen oxide (NOx) and carbon monoxide (CO) emissions in the exhaust from the temporary replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the temporary replacement engine. Calibration of the analyzer shall be conducted according to manufacturer's instructions. Operating Penult Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit# 95OPWE033 Page 3 In the absence of credible evidence to the contrary, results of the portable flue gas analyzer test shall be determinative of enforceable compliance or noncompliance of the temporary replacement engine with the emission limitations of the existing permitted engine as described in Conditions 2.1.2 or 2.1.6 below. An exceedance of either the NOx or CO emission limitation during the initial portable flue gas analyzer test shall require a subsequent portable flue gas analyzer test indicating compliance with both the NOx and CO emission limitations within 14 calendar days of commencing operation of the replacement engine. Calibration gases shall be used to calibrate the portable analyzer for all tests conducted subsequent to the initial test. In the absence of credible evidence to the contrary, if portable flue gas analyzer results indicate compliance with both the NOx and CO emission limitations within the 14 day period, the temporary replacement engine will be considered to be in compliance for purposes of this AOS from the time that the replacement engine commenced operation until the replacement engine is taken off line. If portable flue gas analyzer results fail to indicate the compliance with either the NO,, or CO emission limitations within the 14 day period, the source will notify the Division in writing within 10 calendar days of the end of the 14 day period. In the absence of credible evidence to the contrary, the temporary replacement engine will be considered to be out of compliance from the time that the temporary replacement engine commenced operation until the engine is taken off line. Results of all testing that indicates noncompliance shall be submitted to the Division within 10 calendar days of the end of the 14 day period. 2.1.2 The permittee may temporarily replace a grandfathered or permit exempt engine or an engine that is not subject to emission limits without modifying this permit. Potential annual emissions of NOx and CO from the temporary replacement engine must be less than or equal to the potential annual emissions of NOx and CO from the original grandfathered or permit exempt engine or for the engine that is not subject to emission limits,as determined by applying appropriate emission factors. 2.1.3 Temporary replacement engines, whether of the same manufacturer, model, and horsepower, or of a different manufacturer, model, or horsepower, are subject to all federally applicable and state-only requirements set forth in this permit (including monitoring and record keeping), and shall be subject to any shield afforded by this permit. 2.1.4 The permittee shall maintain a log on-site to contemporaneously record the start and stop date of any temporary engine replacement, the manufacturer, model number, horsepower, and serial number of the engine(s) that are temporarily replaced during Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit#95OPWE033 Page 4 the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. 2.1.5 Results of all tests conducted pursuant to this AOS shall be kept on site for five (5) years and made available to the Division upon request. 2.1.6 For comparison with an annual NOx and CO emissions limit, the results of any testing required by this AOS shall be used to calculate the actual NOx and CO emissions for the time that the engine is operated. Such emissions shall be added to either the rolling 12 month total or the annual emissions, whichever is appropriate in order to monitor compliance. 2.2 Additional Sources Current State Air Quality Regulations do not allow for advanced New Source Review in the absence of discrete and verifiable information concerning future installations. Therefore, any additional operational changes requiring new equipment at this facility not addressed by these Alternative Operating Scenarios will need to undergo appropriate Regulation No. 3 review procedures. 3. Prevention of Significant Deterioration 3.1 This source is located in an area designated attainment for all pollutants,but is located in the 8-hr Ozone Control Area (as defined in the Federal Register, Volume 69, No. 84, dated April 30, 2004). Based on the information provided, it is not categorized as a major stationary source (no single criteria pollutant emissions with a Potential to Emit of greater than 250 tpy) as of the issue date of this permit. The source therefore is not subject to the PSD review requirements of 40 CFR 52.21 (Colorado Regulation No. 3, Part D, Section VI). Any future modification to this facility which is major by itself will result in the application of the PSD review requirements. Future modifications to this facility may result in an exceedance of the major stationary source threshold. Once that threshold is exceeded, future modifications at this facility resulting in a significant net emissions increase (see Regulation No. 3, Part D, Section II.A.27 and 44) for any pollutant as listed in Regulation No. 3, Part D, Section II.A.44 or a modification which is major by itself may result in the application of PSD review requirements. 3.2 There are no other Operating Permits associated with this facility for purposes of determining applicability of Prevention of Significant Deterioration regulations. 4. Accidental Release Prevention Program(112(r)) 4.1 Based on the information provided by the applicant, this facility is not subject to the provisions of the Accidental Release Prevention Program(Section 112(r)of the Federal Clean Air Act). Operating Permit Number:95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit#95OPWE033 Page 5 5. Compliance Assurance Monitoring(CAM) 5.1 The following emission points at this facility use a control device to achieve compliance with an emission limitation or standard to which they are subject and have pre-control emissions that exceed or are equivalent to the major source threshold. They are therefore subject to the provisions of the CAM program as set forth in 40 CFR Part 64, as adopted by reference in Colorado Regulation No. 3,Part C, Section XIV: Unit T001 —Condensate Tank Battery See Section II,Condition 4.7 for compliance assurance monitoring requirements. 6. Summary of Emission Units 6.1 The emissions units regulated by this permit are the following: Emission AIRS Facility . Description Pollution Control Unit Stack Identifier Device Number Number EU-2I 004 EU-21 Cooper Bessemer Model 12Q 1 15HC(155 Quad)S/N:48800,2- Uncontrolled Cycle Lean Burn,Natural Gas Fired Internal Combustion Engine, 5137 hp maximum,powering a natural gas compressor D-0 I 001 EU-01 Custom Triethylene Glycol Dehydration Unit,S/N GDUDO I W, Air-Assisted rated at 80MMscf/day,with associated electric glycol pump,flash Flare(installed tank and still vent. This glycol dehydrator is equipped with an air- February 2002) assisted flare to control VOC emissions. The flash tank emissions are routed to the reboiler or the flare. F001 005 F001 Fugitive Volatile Organic Compound Emissions from Equipment Uncontrolled Leaks T001 006 TOOL Condensate Storage Tank Battery-Four(4)225 bbl,one(1)200 Air-Assisted bbl and(1)300 bbl condensate storage tanks manifolded together Flare(installed to form a single vent line. June 2002) Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Mr Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit#95OPWE033 Page 6 SECTION II- Specific Permit Terms 1. Unit EU-21 -Cooper Bessemer Internal Combustion Engine Parameter Permit Limitations Compliance Monitoring Condition Short Term Long Term Emission Factor Method Interval Number NOx 1.1 N/A 244.8 tons/yr 1.73 lb/MMBtu Recordkeeping, Monthly, CO N/A 124.5 tons/yr 0.88 lb/MMBtu Calculation and Quarterly VOC N/A 53.8 tons/yr 0.38 lb/MMBtu Portable Monitoring (Condition 1.4) Fuel Use 1.2 N/A 267 MMscf)yr N/A Fuel Meter Monthly Opacity 1.3 Not to Exceed 20% N/A Fuel Restriction Whenever Natural Gas is Used as Fuel Portable 1.4 N/A N/A N/A Flue Gas Analyzer Quarterly Monitoring BTU Content 1.5 N/A N/A N/A ASTM Methods Semi- of Natural Gas Annually 1.1 Nitrogen Oxide (NOx), Carbon Monoxide (CO), and Volatile Organic Compound (VOC) emissions from this engine shall not exceed the limitations stated above (Colorado Construction Permit 13WE204, as modified under the provisions of Section I, Condition 1.3 and Colorado Regulation No. 3,Part B, Section II.A.6 and Part C, Section X,based on the requested emissions indicated on the APEN submitted March 24, 2004). Except as provided for below, the emission factors listed above(from manufacturer,converted to lbs/MMBtu based on an engine heat rate of 7,000 Btu/hp-hr) have been approved by the Division and shall be used to calculate emissions from this engine, as follows: Monthly emissions shall be calculated by the end of the subsequent month using the above emission factor, the monthly fuel consumption and the lower heating value of the fuel in the equation below: Tons/mo m CEF(lbs/MMBtu)x Monthly Fuel Use(MMscf/mo)x Heat Content of Fuel(MMBTU/MMscf) 2000 lbs/ton A twelve month rolling total of emissions will be maintained to monitor compliance with the annual emission limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. If a reference method test is conducted under the provisions of Condition 1.4, and the results of the testing show emissions of any pollutant to be above the emission factor(s) listed above, the emission factor determined during that test (or any future such tests) and approved by the Division shall be used in the above equation starting with the month that the test was performed and for all subsequent calculations. In addition, the permittee shall re-calculate all twelve month Operating Permit Number:95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit# 95OPWE033 Page 7 rolling total, annual, or short-term emissions (whichever apply) using the emission rates determined by the tests since the last Division-approved EPA Reference Tests. In the absence of credible evidence to the contrary, the engine(s) will be considered to be out of compliance for any periods that the re-calculated emissions are greater than either the NOx or CO emission limitations. In addition, the permittee shall apply for a modification to this permit to reflect the higher emission factor within 30 days of Division approval of the new emission factor. If the results of the reference method testing conducted under the provisions of Condition 1.4 are below the emission factor(s) listed above, emissions may be calculated using the new (lower) emission factor provided that subsequent testing as required by Condition 1.4 demonstrates compliance with this new factor. If the source chooses to use the new lower emission factor, the permittee shall apply for a modification to this permit to reflect the lower emission factor within 30 days of Division approval of the new emission factor. 1.2 Fuel Consumption for this engine shall not exceed the limitation stated above (Colorado Construction Permit 13WE204, as modified under the provisions of Section I, Condition 1.3). Within the first seven days of every month, the engine fuel meter shall be read and recorded. Monthly fuel use chill be used in a rolling twelve month total to monitor compliance with the annual limitation. 1.3 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant which is in excess of 20% opacity (Colorado Construction Permit 13 WE204 and Colorado Regulation No. 1, Section II.A.1). In the absence of credible evidence to the contrary, compliance with the 20% opacity limit shall be presumed whenever natural gas is used as fuel for this engine. 1.4 Portable Monitoring (8/26/02 version): Emission measurements of nitrogen oxides (NOx) and carbon monoxide (CO) shall be conducted quarterly using a portable flue gas analyzer. At least one calendar month shall separate subsequent quarterly tests. Note that if the engine is operated for less than 100 hrs in any quarterly period, then the portable monitoring requirements do not apply. A portable monitor testing protocol shall be submitted for Division approval at least thirty(30) calendar days prior to the initial test. The protocol shall include examples of all calculations to be used to determine the emission rates and factors set forth below. Written approval of the protocol must be received prior to any testing. Prior Division-approved protocols for either the facility or the owner/operator may be used without additional review. For the initial test, calibration of the analyzer shall be conducted according to manufacturer's instructions. Results of the portable flue gas 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 and multiplied by the allowable operating hours in the month Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Kerr-McGee Gathering LW Colorado Operating Permit Dougan Compressor Station Permit#95OPWE033 Page 8 or year(whichever applies)in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year(8760),whichever applies. For comparison with the emission rate/factor shown in the Table in Sections II.1 the results of the tests shall be converted to the same units as the emission rate/factor. An exceedance of either the NOx or CO emission limitation or either the NOx or CO emission rates/factors shown in the Table in Sections 11.1 during the initial portable flue gas analyzer test shall require a subsequent portable analyzer test indicating compliance with both the NOx and CO emission limitations as well as verifying that both the NOx and CO emission rates/factors are less than or equal to those set forth in the permit within 14 operating days of the initial test. Calibration gases shall be used to calibrate the portable analyzer for all tests conducted subsequent to the initial test. Note that if the unit is operated for any period of time during a day,then that day counts as an operating day. If the portable flue gas analyzer results indicate compliance with both the NOx and CO emission limitations and verifies both the NOx and CO emission rates/factors are less than or equal to those set forth in the permit within the 14 day period, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOx and CO emission limitations for the relevant time period. If the portable flue gas analyzer results fail to indicate compliance with either the NOx or CO emission limitations or fail to verify that both the NOx and CO emission rates/factors are less than or equal to those set forth in the permit within the 14 day period,the source will notify the Division in writing within 10 calendar days of the end of the 14 day period. Results of all such testing and the associated calculations shall be submitted to the Division within 10 calendar days of the end of the 14 day period. The source will be required to conduct EPA Reference Test Methods(identified as Reference Method 7E and Reference Method 10(40 C.F.R.Part 60 Appendix A),hereinafter"EPA Reference Test Methods')or other test methods or procedures acceptable to the Division within 45 calendar days of the end of the 14 day period allowed for the portable flue gas analyzer testing. A compliance testing protocol shall be submitted for Division approval at least thirty(30)calendar days prior to the test. The protocol shall include examples of all calculations to be used to determine the emission rates set forth below. Written approval of the protocol must be received prior to any testing. The Division shall be notified at least 30 calendar days prior to the EPA Reference Test date, so that it may choose whether to observe the testing. Results of all Reference Method tests and the associated calculations required below shall be submitted to the Division within 30 calendar days of the test. For comparison with an annual or short term emission limit,the results of the EPA Reference Tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit#95OPWE033 Page 9 month or year(whichever applies)in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year(8760),whichever applies. For comparison with the emission rates/factors shown in the Table in Sections II.1 the emission rates determined by the tests and approved by the Division shall be converted to the same units as the emission rates/factors in the permit. If the EPA Reference Test results indicate compliance with both the NOx and CO emission limitations and verify that both the NOx and CO emission rates/factors are less than or equal to those set forth in the permit, in the absence of credible evidence to the contrary,the source may certify that the engine or turbine is in compliance with both the NOx and CO emission limitations for the relevant time period. If the EPA Reference Tests fail to demonstrate compliance with either the NOx or CO emission limitations and in the absence of credible evidence to the contrary,the engine will be considered to be out of compliance from the date of the initial quarterly portable flue gas analyzer test for the corresponding quarter until the engine or turbine is taken off line. If the EPA Reference Tests fail to verify that both the NOx and CO emission rates/factors are less than or equal to those set forth in the permit,the source shall re-calculate any applicable twelve month rolling total, annual, or short-term emissions(whichever apply)using the emission rates determined by the tests and approved by the Division since the last Division-approved EPA Reference Tests using the procedures set forth in Condition 1.1. In the absence of credible evidence to the contrary, the engine will be considered to be out of compliance for any periods that the calculated emissions are greater than either the NOx or CO emission limitations. Results of all tests conducted shall be maintained and made available to the Division as required by Section I,Condition 1.5 and Section IV,Conditions 22.b and c of this permit. 1.5 The Btu content of the natural gas used to fuel this engine shall be verified semi-annually using the appropriate ASTM Methods or equivalent, if approved in advance by the Division. The Btu content of the natural gas shall be based on the lower heating value of the fuel. Calculations of monthly emissions shall be made using the heat content derived from the most recent required analysis. 1.6 This engine shall be operated and maintained in accordance with internal operating and maintenance standards, which shall consider manufacturer's recommendations and good engineering practices,at all times, including periods of start-up, shut-down and malfunction. Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit#95OPWE033 Page 10 2. Unit D-01-Custom Glycol Dehydration Unit Equipped with an Air-Assisted Flare Parameter Permit Limitations Compliance Monitoring Condition Short Term Long Tam Emission Factor Method Interval Number VOC 2.1. N/A 11 tons/yr Based on Gill Parametric Daily Individual N/A 8 tons/yr GlyCalc Model, HAPS Version 4.0 or Higher Extended Gas N/A N/A N/A EPA Reference Quarterly Analysis Methods Natural Gas 22. N/A 14,600 N/A Flow Meter Monthly Processed MMscf/yr Flare Operating 2.3. Flare Shall be Operated at all N/A Certification Annually Requirements Times that the Dehydrator is Operating. A Flame Shall be Present at all Temperature Continuously times that the Flare is Operated Sensor or Flame Detection Device with Alarm Visible Emissions/Opacity Visible Emission Monthly Requirements Observations Net Heating Value,Exit See Condition 2.3. Velocity Flash Tank 2A. N/A N/A N/A Certification Annually Requirements Supplemental 2.5. No Less than 0.153 MMBtu/hr N/A Fuel Meter Monthly Fuel Requirements Hours/Days of 2.6 N/A N/A N/A Recordkeeping Monthly Operation NOx 2.7. N/A 0.5 tons/yr 0.068 lbs/MMBtu Recordkeeeping Monthly CO 2.7 tons/yr 0.37 Ibs/MMBtu and Calculation 2.1 Volatile Organic Compound and Individual HAP emissions shall not exceed the limitations stated above (Colorado Construction Permit 94WE760-1, as modified under the provisions of Section I,Condition 1.3 and Colorado Regulation No. 3,Part C,Sections I.A.7 and III.B.7,based on the emissions identified on the APEN submitted on May 23, 2001 and Worst Case Dehydrator Emission Data Submitted to the Division on January 14, 2002). The methods for monitoring compliance with this limit are as follows: 2.1.1 The triethylene glycol circulation rate and inlet (wet) gas temperature for this unit shall be measured and recorded daily. The circumstances surrounding any day on which the required parameters fail to be measured and recorded shall be described in Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit#95OPWE033 Page 11 a log to be maintained on-site. The average value for each of these parameters shall be determined for any month during which a daily recorded parameter fails the stipulated passing criteria compared to the values listed in the table below. Data from the previous-most day for which data exists may be substituted for missing data in the event the calculation of a monthly-average value is required. Parameter Value Units Criteria Inlet(Wet)Gas Temperature &0 degrees Fahrenheit At or Above Glycol Circulation Rate 5 gallons per minute At or Below Benzene Content of Gas 220 parts per million At or Below Toluene Content of Gas 310 parts per million At or Below Ethyl Benzene Content of Gas 10 parts per million At or Below Xylene Content of Gas 90 parts per million At or Below 2.1.2 Samples of inlet gas shall be collected and analyzed (extended gas analysis) to determine C1 to C6, n-hexane, benzene, toluene, ethyl benzene and total xylene (BTEX) composition once per calendar quarter. Frequency of extended gas analyses shall move to semi-annually(calendar semi-annual period) after the first year, then to annually (calendar year) after the second year if BTEX concentrations remain consistently below the established values as identified in the above table. Frequency will revert back to quarterly (calendar quarter) if any of the BTEX constituents exceed the listed values. 2.1.3 The inlet gas pressure and the flash tank temperature and pressure shall be monitored and recorded weekly. The average value for inlet gas pressure and flash tank temperature and pressure shall be calculated for each month and used in any required GLYCaIc evaluation as required by Condition 2.1.4. 2.1.4 If the average glycol circulation rate, the average inlet gas temperature or the concentration of a BTEX constituent does not meet the stipulated passing criteria, the GRI GLYCalc (Version 4.0 or higher) model shall be run to determine monthly emission rates. Inputs to the model will be the recorded average values for average inlet temperature and glycol circulation rate, gas data from the most recent required analysis (Condition 2.1.2), the average daily gas throughput rate (Condition 2.2) and the following assumed values: Inlet Gas Pressure: Monthly average per Condition 2.1.3 Flash Tank Temperature: Monthly average per Condition 2.1.3 Flash Tank Pressure: Monthly average per Condition 2.1.3 Flare Control Efficiency 95% 2.1.5 A rolling 12-month total for VOC and individual HAP emissions shall be maintained to monitor compliance with the annual limitations. The 12-month total may be assumed to be equal to the annual limitations for any 12-month period for which no Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 • Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit#95OPWE033 Page 12 GLYCalc runs were triggered. The calculation of the 12-month total shall be performed for any month a GLYCa1c run is triggered. If a GLYCalc run is required for any mason for a given month, the pounds per hour of emissions predicted by the model shall be multiplied by number of hours the unit ran for that month. The monthly VOC and individual HAP emissions used in the rolling 12-month total for months that do not trigger a GLYCalc run shall be the number of operating hours in the month multiplied by an hourly VOC emission rate of 2.26 lbs/hr and individual HAP emission rate of 0.68 lbs/hr (Worst Case Dehydrator Emissions - Submitted to the Division on 1/14/02). If the 12-month rolling total of VOC and/or individual HAP emissions exceeds the annual limitation, emissions for the previous months must be calculated with GLYCalc using the parameters described in Condition 2.1.4 until the rolling 12-month total is less than the annual VOC and/or individual HAP limitation or all twelve months have been recalculated. 2.2 The cubic feet of gas processed by this dehydration unit shall not exceed the limitation stated above(Colorado Construction Permit 94WE760-1,as modified under the provisions of Section I, Condition 1.3). The gas throughput to the dehydration unit shall be recorded monthly using existing flow meters. A twelve month rolling total will be maintained to monitor compliance with annual throughput limitations. An average daily gas throughput rate shall be determined by dividing the monthly gas throughput by the number of operating days in the previous month. This average daily gas throughput rate shall be used in any required GlyCalc runs. 2.3 The flare is subject to the following requirements: 2.3.1 The flare shall be operated at all times when emissions may be vented to them (40 CFR Part 63 Subpart A § 63.11(b)(3), as adopted by reference in Colorado Regulation No. 8, Part E, Section I). The flare shall be operated at all times the dehydration unit is operated. 2.3.2 The flare shall be operated with a flame present at all times when emissions may be vented to them. The presence of a flare pilot flame shall be monitored continuously, when emissions may be vented to them,using a thermocouple or any other equivalent device to detect the presence of the flame (40 CFR Part 63 Subpart A § 63.11(6)(5), as adopted by reference in Colorado Regulation No. 8, Part E, Section 1). The device shall be equipped with an alarm to indicate no ignition of the pilot flame when emissions may be vented to them. Records of the times and duration of all periods of pilot flame outages shall be maintained and made available to the Division upon request. 2.3.3 The flare is subject to the following visible emission requirements: 2.3.3.1 Flares shall be designed for and operated with no visible emissions,except for periods not to exceed a total of 5 minutes during any 2 consecutive hours(40 CFR Part 63 Subpart A § 63.11(b)(4),as adopted by reference in Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit#95OPWE033 Page 13 Colorado Regulation No. 8, Part E, Section I). Compliance with the visible emission requirements, shall be monitored by conducting a visible emission observation monthly when the flare is operating. During the monthly check, when visible emissions persist for longer than fifteen (15) continuous minutes, the cause shall be determined and corrective actions taken. A record of the existing condition and the action taken shall be maintained and made available to the Division for review upon request. 2.3.3.2 No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes (Colorado Regulation No. 1, Section II.A.5). In the absence of credible evidence to the contrary, compliance with this opacity requirement shall be presumed provided the requirements in Condition 2.3.3.1 are met. 2.3.4 The flare shall be used only with the net heating value of the gas being combusted at 300 Btu/scf or greater (40 CFR Part 63 Subpart A § 63.11(b)(6)(ii), as adopted by reference in Colorado Regulation No. 8, Part E, Section I). Performance tests were conducted on October 7 and 25, 2002 and these tests indicated that the gas burned by the flare meets the net heating value requirement of 300 Btu/scf or greater. In the absence of credible evidence to the contrary, compliance with the net heating value requirement is presumed provided the requirements in Condition 2.3.6 are met. 2.3.5 The flare shall be designed and operated with an exit velocity less than the velocity V. as determined by 40 CFR Part 63 Subpart A § 63.11(b)(8) (40 CFR Part 63 Subpart A § 63.11(b)(8), as adopted by reference in Colorado Regulation No. 8, Part E, Section I). Performance tests were conducted on October 7 and 25,2002 and these tests indicated that the above exit velocity requirement has been met. In the absence of credible evidence to the contrary, compliance with the exit velocity requirement is presumed provided the requirements in Condition 2.3.6 are met. 2.3.6 Owners or operators of flares shall monitor these control devices to assure that they are operated and maintained in conformance with their designs (40 CFR Part 63 Subpart A § 63.11(b)(1), as adopted by reference in Colorado Regulation No. 8, Part E, Section I). 2.4 Emissions from the dehydrator flash tank shall be routed through a closed vent system to either the flare prior to being emitted or to the reboiler for use as fuel. 2.5 Supplemental fuel to the flare shall not be less than 0.153 MMBtu/hr (Colorado Construction Permit 94WE760-1, as modified under the provisions of Section I, Condition 1.3 and Colorado Regulation No. 3, Part C, Sections I.A.7 and Section III.B.7, based on the supplemental fuel requirement indicated in the GLYCaIc evaluation submitted on January 14, 2002). The monthly Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit#95OPWE033 Page 14 supplemental fuel flow to the flare shall be recorded monthly using a flow meter. The monthly heat input shall be calculated based on the monthly fuel flow and the heat content of the gas as determined by the latest analysis required by Condition 1.5. Compliance with the hourly supplemental fuel shall be monitored by dividing the monthly heat input by the number of hours the dehydrator operated during the month. 2.6 The Hours/Days of Operation shall be monitored monthly and recorded and maintained to be made available to the Division upon request. The hours of operation shall be used to calculate the monthly emissions in any month that a GLYCalc run is required as specified in Condition 2.1.5 and to calculate the hourly supplemental fuel to the flare (Condition 2.5). The days of operation shall be used to calculate an average daily gas throughput as specified in Condition 2.2. 2.7 NOx and CO emissions shall not exceed the above limitations (Colorado Construction Permit 94WE760-1, as modified under the provisions of Section I, Condition 1.3 and Colorado Regulation No. 3, Part C, Sections I.A.7 and III.8.7, based on the emissions indicated on the APEN submitted on April 30, 2004). Monthly emissions of each pollutant shall be calculated using the listed emission factors (from AP-42, September 1991, Section 13.5, Table 13.5-1) in the following equation: Tons/mo—(EF.lbs/MMBtu)x monthly heat input to flare(MMBtu/mo) 2000 lbs/ton Heat input to flare—heat input from supplemental fuel+heat input from glycol still vent Heat input from supplemental fuel as determined by Condition 2.5. Heat input from glycol still vent is either. If is GLYCaIc run triggered: 1,260 ft�x 1197 Btu/ft x hours of operation(hrs/mo) Where: 1,260 ft'/hr is the regnerator off gas flow rate from the GLYCalc run submitted 1/14/02 (worst case analysis) 1197 Btu/ft'is the net heating value of flare gas determined by the performance test Hours of operation as determined by Condition 2.6 If GLYCalc run is triggered: Regenerator off-gas flow rate from GLYCaIc run(ft'/hr)x 1197 Btu/ft'x hours of operation(hrs/mo) Emissions shall be calculated by the end of the subsequent month. A twelve-month rolling total shall be maintained to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months' data. Operating Permit Number. 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 1 Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit# 95OPWE033 Page 15 3. Unit F001 -Fugitive VOC Emissions from Equipment Leaks Parameter Permit Limitations Compliance Monitoring Condition Short Term Long Term Emission Factor Method Interval Number VOC 3.1.,3.2 N/A 25.02 tons/yr EPA Protocol for Equation Based Annual Equipment Leak on Component Estimates Count 8 3.1 VOC emissions from equipment leaks shall not exceed the limitation stated above (As provided for under the provisions of Section I, Condition 1.3). Emissions shall be calculated using the emission factors and equations listed below: Emission Factors for individual types of components in lbs-component/hr (EPA-453/R-95-017, EPA's Protocol for Equipment Leak Emission Estimates, Table 2.4,November 1995): Valves=0.0099 Pump Seals= 0.00529 Others* =0.0194 Connectors=0.00044 Flanges=0.000859 Open-Ended Lines=0.0044 *Other should be applied for any equipment type other than connectors, flanges, open- ended lines,pumps or valves Annual Emissions of VOC per Component: (No. of Components)x EF(lbs/component-hr) x(8760 hrs/year)x(Wt%VOC of Gas) Total Fugitive VOC emissions will be the sum of emissions for each component. The most recent gas analysis as required under Condition 2.1.2 of this Permit shall be used to determine the weight percent VOC to be used in the above equation. 3.2 An initial physical hard-count of facility components will be conducted within one year of issuance of the renewal permit [December 1, 2004] to verify existing hardware inventory. A physical hard-count of facility components shall be conducted annually following the initial count required under this condition. Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit#95OPWE033 -Page 16 4. T001 -Condensate Storage Tank Battery Parameter Permit Limitations Compliance Monitoring Condition Short Term Long Tenn Emission Factor Method Interval Number VOC Emissions 4.1. N/A N/A API E&P Tanks Calculation Monthly Version 2.0 or Higher E&P Tanks 4.2. N/A N/A 0.37 lbs/MMBtu Recordkeeping Monthly, Input Parameters and Analysis Semi- Annually Condensate 4.3. N/A 11,000 bbls/yr N/A Recordkeeping Monthly Produced Sales 4.4. N/A N/A N/A Analytical Per Sale, Condensate Methods Annually Analysis Flare Operating 4.5. Flare Shall be Operated at all N/A Certification Annually Requirements Times that the Dehydrator is Operating. A Flame Shall be Present at all See Condition 4.5. times that the Flare is Operated Visible Emissions/Opacity Performance Test, Within 180 Requirements Visible Emission Days,Monthly Observations Flare 4.6. Visible Emissions,Btu Content N/A As Specified in Within 180 Performance and Velocity 40 CFR Part 63 Days Test Subpart A§ 63.11(b) Compliance 4.7. N/A N/A N/A See Condition 4.7. Assurance Monitoring Commence 4.8. Construction Must Commence N/A See Condition 4.8. Construction Within 18 Months Startup 4.9. Notify Division within 30 Days N/A Notification Within 30 Notification Prior to Startup Days Compliance 4.10. Certify Compliance within 180 N/A Certification Within 180 Certification Days of Startup Days 4.1 VOC emissions from the tank battery shall not exceed the above limitations (as provided for under the provisions of Section I, Condition 1.3 and Colorado Regulation No. 3, Part C. Sections I.A.7 and III.B.7, based on the APEN submitted on July 15, 2004). Monthly emissions shall be calculated using API's E& P Tanks Version 2.0. Emissions for each month shall be calculated using the input parameters specified in Condition 4.2, the monthly quantity of condensate sold and the sales oil properties as determined by Condition 4.4. Monthly emissions shall be used in a rolling twelve month total to monitor compliance with the annual limitation. Each month a new twelve month total shall be calculated using the previous twelve months' data. Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Ken-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit#95OPWE033 Page 17 For purposes of calculating emissions a control efficiency of 95% may be assumed for the flare, provided the flare has been operated in accordance with the requirements in Conditions 4.5 and 4.6 and that the CAM requirements in Condition 4.7 have been met. 4.2 The input parameters to E& P Tanks shall be monitored as follows: 4.2.1 The separator temperature and pressure shall be monitored and recorded monthly. Monthly values shall be representative of the unit's operation during the month. The recorded values in each month for the separator temperature and pressure shall be used to calculate monthly emissions as required by Condition 4.1. 4.2.2 For purposes of calculating emissions as required by Condition 4.1, the permittee shall use the historical monthly mean temperature recorded at Denver International Airport(DIA). 4.2.3 The permittee shall sample and analyze the high pressure oil annually for the compositional E & P Tanks input requirements. A copy of the procedures used to obtain, collect and handle the samples shall be maintained and made available to the Division upon request. 4.3 The quantity of condensate processed through the tank battery shall not exceed the above limitations (as provided for under the provisions of Section I, Condition 1.3 and Colorado Regulation No. 3, Part C, Sections I.A.7 and Section III.B.7, based on the APEN submitted on July 15, 2004). The quantity of condensate processed through the tank battery shall be monitored and recorded monthly and used to calculate emissions as required by Condition 4.1. The monthly quantity of condensate processed shall be used in a twelve month rolling total to monitor compliance with the annual limitation. Each month a new twelve month total shall be calculated using the previous twelve months' data. 4.4 The sales condensate shall be analyzed as follows: 4.4.1 The sales condensate shall be sampled and analyzed annually to determine the reid vapor pressure (RVP). A copy of the procedures used to obtain, collect and handle the samples shall be maintained and made available to the Division upon request. The RVP determined by the analysis shall be used to calculate emissions as required by Condition 4.1. 4.4.2 Records of the actual API gravity from sales receipts shall be retained and made available to the Division upon request. All sales receipts for the monthly period shall be used to determine the average API gravity. The average API gravity shall be used to calculate emissions as required by Condition 4.1. 4.5 The flare is subject to the following requirements: Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 • Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit#95OPWE033 Page 18 4.5.1 The flare shall be operated at all times when emissions may be vented to them (40 CFR Part 63 Subpart A § 63.11(bx3), as adopted by reference in Colorado Regulation No. 8, Part E, Section D. The flare shall be operated at all times condensate is flashed. 4.5.2 The flare shall be operated with a flame present at all limes. The presence of a flare pilot flame shall be monitored continuously using a thermocouple or any other equivalent device to detect the presence of the flame (40 CFR Part 63 Subpart A § 63.11(6x5),as adopted by reference in Colorado Regulation No. 8, Part E, Section D. The device shall be equipped with an alarm to indicate no ignition of the pilot flame. The monitoring devices specified in the CAM Plan in Appendix G of this permit are sufficient to ensure the flare is operated with a flame present. 4.5.3 The flare is subject to the following visible emission requirements: 4.5.3.1 Flares shall be designed for and operated with no visible emissions, except for periods not to exceed a total of 5 minutes during any 2 consecutive hours(40 CFR Part 63 Subpart A § 63.11(bX4),as adopted by reference in Colorado Regulation No. 8, Part E, Section I). An initial compliance test to monitor compliance with the visible emission requirements shall be conducted as required by Condition 4.5. Compliance with the visible emission requirements, thereafter, shall be monitored by conducting a visible emission observation monthly when the flare is operating. During the monthly check, when visible emissions persist for longer than fifteen (15) continuous minutes, the cause shall be detc,arined and corrective actions taken. A record of the existing condition and the action taken shall be maintained and made available to the Division for review upon request. 4.5.3.2 No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes (Colorado Regulation No. 1, Section II.A.5). In the absence of credible evidence to the contrary, compliance with this opacity requirement shall be presumed provided the requirements in Condition 4.5.3.1 are met. 4.5.4 Owners or operators of flares shall monitor these control devices to assure that they are operated and maintained in conformance with their designs (40 CFR Part 63 Subpart A § 63.11(bxl), as adopted by reference in Colorado Regulation No. 8, Part E, Section I). 4.6 A performance test shall be conducted within 180 days of startup of the new 200 bbl condensate tank to verify that the flare meets the visibility, heat content and velocity specifications in 40 CFR Part 63 Subpart A §63.11(6). Performance tests shall be conducted as follows: Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit# 95OPWE033 Page 19 4.6.1 EPA Test Method 22 shall be used to determine the compliance of the flare with the visible emission requirement in Condition 4.5.3.1 of this permit. The observation period is 2 hours and shall be conducted according to EPA Method 22 (40 CFR Part 63 Subpart A § 63.11(b)(4), as adopted by reference in Colorado Regulation No. 8, Part E, Section I). 4.6.2 The flare shall be used only with the net heating value of the gas being combusted at 300 Btu/scf or greater. A performance test shall be conducted to determine the net heating value of the gas in accordance with the requirements in 40 CFR Part 63 Subpart A § 63.11(6)(ii) (40 CFR Part 63 Subpart A § 63.11(b)(6)(ii), as adopted by reference in Colorado Regulation No. 8, Part E, Section I). 4.6.3 The flare shall be designed and operated with an exit velocity less than the velocity as determined by 40 CFR Part 63 Subpart A § 63.11(b)(8) (40 CFR Part 63 Subpart A § 63.11(b)(8), as adopted by reference in Colorado Regulation No. 8, Part E, Section 0. A performance test shall be conducted to determine that the exit velocity is less than A performance testing protocol shall be submitted for Division approval at least thirty(30) calendar days prior to any performance of the test. No performance test shall be performed without prior written approval by the Division. The Division reserves the right to witness the test. The required number of copies of the compliance test results shall be submitted to the Division within thirty (30) calendar days of the completion of the test. 4.7 The Compliance Assurance Monitoring (CAM) requirements in 40 CFR Part 64, as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV, apply to the condensate tank battery with respect to the VOC limitations identified in Condition 4.1 as follows: 4.7.1 The permittee shall follow the CAM Plan provided in Appendix G of this permit. Excursions, for purposes of reporting are any time the thermal device indicates there is no flame present or no flame sensed and no audible detection of a spark for more than 22 seconds. Excursions shall be reported as required by Section IV, Conditions 21 and 22.d of this permit. 4.7.2 Operation of Approved Monitoring 4.7.2.1 At all times, the owner or operator shall maintain the monitoring, including but not limited to, maintaining necessary parts for routine repairs of the monitoring equipment (40 CFR Part 64 § 64.7(6),as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 4.7.2.2 Except for, as applicable, monitoring malfunctions, associated repairs, and required quality assurance or control activities (including, as applicable, calibration checks and required zero and span adjustments), the owner or operator shall conduct all monitoring in continuous operation (or shall Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit#95OPWE033 Page 20 collect data at all required intervals) at all times that the pollutant-specific emissions unit is operating. Data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities shall not be used for purposes of these CAM requirements, including data averages and calculations, or fulfilling a minimum data availability requirement, if applicable. The owner or operator shall use all the data collected during all other periods in assessing the operation of the control device and associated control system. A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions (40 CFR Part 64 § 64.7(c), as adopted by reference in Colorado Regulation No. 3,Part C, Section XIV). 4.7.2.3 Response to excursions or exceedances a. Upon detecting an excursion or exceedance, the owner or operator shall restore operation of the pollutant-specific emissions unit (including the control device and associated capture system) to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. The response shall include minimizing the period of any startup, shutdown or malfunction and taking any necessary corrective actions to restore normal operation and prevent the likely recurrence of the cause of an excursion or exraMdnnce (other than those caused by excused startup or shutdown conditions). Such actions may include initial inspection and evaluation, recording that operations returned to normal without operator action (such as through response by a computerized distribution control system), or any necessary follow-up actions to return operation to within the indicator range, designated condition, or below the applicable emission limitation or standard, as applicable (40 CFR Part 64 § 64.7(d)(1), as adopted by reference in Colorado Regulation No. 3,Part C, Section XIV). b. Determination of whether the owner of operator has used acceptable procedures in response to an excursion or exceedance will be based on information available, which may include but is not limited to, monitoring results, review of operation and maintenance procedures and records, and inspection of the control device, associated capture system, and the process (40 CFR Part 64 § 64.7(d)(2), as adopted by reference in Colorado Regulation No. 3,Part C, Section XIV). 4.7.2.4 After approval of the monitoring required under the CAM requirements,if the owner or operator identifies a failure to achieve compliance with an emission limitation or standard for which the approved monitoring did not provide an indication of an excursion or exceedance while providing valid Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit# 95OPWE033 Page 21 data, or the results of compliance or performance testing document a need to modify the existing indicator ranges or designated conditions,the owner or operator shall promptly notify the Division and, if necessary submit a proposed modification for this permit to address the necessary monitoring changes. Such a modification may include, but is not limited to, reestablishing indicator ranges or designated conditions, modifying the frequency of conducting monitoring and collecting data, or the monitoring of additional parameters (40 CFR Part 64 § 64.7(e), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 4.7.3 Quality Improvement Plan(QIP)Requirements 4.7.3.1 Based on the results of a determination made under the provisions of Condition 4.7.2.3.b, the Division may required the owner or operator to develop and implement a QIP (40 CFR Part 64 § 64.8(a), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 4.7.3.2 The owner or operator shall maintain a written QIP, if required, and have it available for inspection (40 CFR Part 64 § 64.8(bxl), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 4.7.3.3 The QIP initially shall include procedures for evaluating the control performance problems and, based on the results of the evaluation procedures, the owner or operator shall modify the plan to include procedures for conducting one or more of the following actions, as appropriate: a. Improved preventative maintenance practices (40 CFR Part 64 § 64.8(b)(2)(i), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). b. Process operation changes(40 CFR Part 64 § 64.8(b)(2)(ii), as adopted by reference in Colorado Regulation No. 3,Part C, Section XIV). c. Appropriate improvements to control methods (40 CFR Part 64 § 64.8(b)(2)(iii), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). d. Other steps appropriate to correct control performance (40 CFR Part 64 § 64.8(b)(2)(iv), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). e. More frequent or improved monitoring (only in conjunction with one or more steps under Conditions 4.7.3.3.a through d above) (40 CFR Part 64 § 64.8(b)(2)(v), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 4.7.3.4 If a QIP is required, the owner or operator shall develop and implement a QIP as expeditiously as practicable and shall notify the Division if the Operating Permit Number:95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit#95OPWE033 Page 22 period for completing the improvements contained in the QIP exceeds 180 days from the date on which the need to implement the QIP was determined (40 CFR Part 64 § 64.8(c), as adopted by reference in Colorado Regulation No. 3,Part C, Section XIV). 4.7.3.5 Following implementation of a QIP, upon any subsequent determination pursuant to Condition 4.7.2.3.b,the Division or the U.S. EPA may require that an owner or operator make reasonable changes to the QIP if the QIP is found to have: a. Failed to address the cause of the control device performance problems (40 CFR Part 64 § 64.8(d)(1), as adopted by reference in Colorado Regulation No. 3,Part C, Section XIV);or b. Failed to provide adequate procedures for correcting control device performance problems as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions (40 CFR Part 64 § 64.8(dX2), as adopted by reference in Colorado Regulation No. 3,Part C, Section XIV). 4.7.3.6 Implementation of a QIP shall not excuse the owner or operator of a source from compliance with any existing emission limitation or standard, or any existing monitoring, testing, reporting or recordkeeping requirement that may apply under federal, state, or local law, or any other applicable requirements under the federal clean air act (40 CFR Part 64 § 64.8(e), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 4.7.4 Reporting and Recordkeeping Requirements 4.7.4.1 Reporting Requirements: The reports required by Section IV, Condition 22.d, shall contain the information specified in Appendix B of the permit and the following information, as applicable: a. Summary information on the number, duration and cause (including unknown cause, if applicable), for monitor downtime incidents (other than downtime associated with zero and span or other daily calibration checks, if applicable) ((40 CFR Part 64 § 64.9(a)(2)(ii), as adopted by reference in Colorado Regulation No. 3,Part C, Section XIV); and b. The owner or operator shall submit, if necessary, a description of the actions taken to implement a QIP during the reporting period as specified in Condition 4.7.3 of this permit. Upon completion of a QIP, the owner or operator shall include in the next summary report documentation that the implementation of the plan has been completed and reduced the likelihood of similar levels of excursions or exceedances occurring (40 CFR Part 64 §64.9(a)(2Xiii), as adopted by reference in Colorado Regulation No. 3,Part C, Section XIV). Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit# 95OPWE033 Page 23 4.7.4.2 General Recordkeeping Requirements: In addition to the recordkeeping requirements in Section IV,Condition 22.a through c. a. The owner or operator shall maintain records of any written QIP required pursuant to Condition 3.5.3 and any activities undertaken to implement a QIP, and any supporting information required to be maintained under these CAM requirements (such as data used to document the adequacy of monitoring, or records of monitoring maintenance or corrective actions) (40 CFR Part 64 § 64.9(b)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). b. Instead of paper records, the owner or operator may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements (40 CFR Part 64 § 64.9(b)(2), as adopted by reference in Colorado Regulation No. 3,Part C, Section XIV). 4.7.5 Savings Provisions 4.7.5.1 Nothing in these CAM requirements shall excuse the owner or operator of a source from compliance with any existing emission limitation or standard, or any existing monitoring, testing, reporting or recordkeeping requirement that may apply under federal, state, or local law, or any other applicable requirements under the federal clean air act. These CAM requirements shall not be used to justify the approval of monitoring less stringent than the monitoring which is required under separate legal authority and are not intended to establish minimum requirements for the purposes of determining the monitoring to be imposed under separate authority under the federal clean air act, including monitoring in permits issued pursuant to title I of the federal clean air act. The purpose of the CAM requirements is to require, as part of the issuance of this Title V operating permit, improved or new monitoring at those emissions units where monitoring requirements do not exist or are inadequate to meet the requirements of CAM (40 CFR Part 64 § 64.10(a)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 4.7.5.2 Nothing in these CAM requirements shall restrict or abrogate the authority of the U.S. EPA or the Division to impose additional or more stringent monitoring,recordkeeping,testing or reporting requirements on any owner or operator of a source under any provision of the federal clean air act, including but not limited to sections 114(a)(1) and 504(b), or state law, as applicable (40 CFR Part 64 § 64.10(a)(2), as adopted by reference in Colorado Regulation No. 3,Part C, Section XIV). Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit#95OPWE033 Page 24 4.7.5.3 Nothing in these CAM requirements shall restrict or abrogate the authority of the U.S. EPA or the Division to take any enforcement action under the federal clean air act for any violation of an applicable requirement or of any person to take action under section 304 of the federal clean air act(40 CFR Part 64 § 64.10(a)(2), as adopted by reference in Colorado Regulation No. 3,Part C, Section XIV). 4.8 The permit conditions in this Section II.4 of this permit shall expire if construction of the new 200 bbl condensate tank does not commence within 18 months of issuance of this renewal permit [December 1, 2004]; construction is discontinued for a period of 18 months of more; or construction is not completed within a reasonable time of the estimated completion date (Colorado Regulation No. 3,Part B,Section III.F.4.a.(i)thru(ii)). 4.9 The permittee shall notify the Division, in writing, thirty (30) days prior to startup of the new 200 bbl condensate tank(Colorado Regulation No. 3,Part B,Section III.G.I). 4.10 Within one hundred eighty (180) calendar days after commencement of operation of the new 200 bbl condensate tank, the permittee shall certify compliance with the conditions in this Section II.4 of this permit(Colorado Regulation No. 3,Part B,Section III.G.2). Submittal of the first required semi-annual monitoring report (Appendix B), after startup of the new 200 bbl condensate tank shall serve as the self-certification that condensate tank battery can comply with the conditions in this Section II.4 of this permit. 5. Ozone Early Action Compact Requirements—State-Only Requirements 5.1 Condensate Tank Requirements Any owner or operator of an oil and gas exploration and production operation, natural gas compressor station or natural gas drip station located upstream of a natural gas-processing plant that collects, stores, or handles condensate in the 8-hour Ozone Control Area shall employ air pollution control technology to control emissions of volatile organic compounds associated with atmospheric condensate storage tanks as follows(Colorado Regulation No. 7, Section XII.A): 5.1.1 The owners and operators shall employ control technology to reduce emissions of volatile organic compounds by the dates and amounts listed below. Emission reductions shall not be required for each and every unit, but instead shall be based on overall reductions in uncontrolled actual emissions from all the gas exploration and production operations, natural gas compressor stations, and natural gas drip stations located upstream of a natural gas-processing plant that collect, store, or handle condensate-in the 8-hour Ozone Control Area for which the owner or operator filed, or was required to file, an APEN pursuant to Regulation No. 3. The dates and requisite reductions are as follows(Colorado Regulation No. 7, Section XII.A.1): 5.1.1.1 For calendar year 2005 such emissions shall be reduced by 37.5% from uncontrolled actual emissions; Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit# 95OPWE033 Page 25 5.1.1.2 For calendar year 2006 and each calendar year thereafter such emissions shall be reduced by 47.5%from uncontrolled actual emissions. 5.1.2 On or before April 30, 2006, and annually by April 30 of each year thereafter, each owner or operator shall submit a report describing the emissions controls that were implemented for the preceding calendar year and how it complied with the emission reductions required by Condition 5.1.1 of this permit. Such reports shall be submitted to the Division on a form provided by the Division for that purpose. At a minimum, the report shall include a listing of all sites subject to this Condition 5.1 identifying which operations are controlled by what types of devices; uncontrolled and controlled emissions levels; which methods of estimating emissions were used; total reductions achieved; whether or not the emissions reduction required by this Condition 5.1.1 has been achieved, and, if not, why not; and other information the Division may deem necessary to determine compliance with this Condition 5.1.1 (Colorado Regulation No. 7, Section XII.A.2). The reports shall be submitted in Exel electronic format. 5.1.3 Each owner or operator required to file a report pursuant to Condition 5.1.2 above shall, at all times, maintain an updated spreadsheet of information required by such report. Such updated spreadsheet shall be promptly provided by e-mail or fax to the Division upon its request. The U.S. mail may also be used if acceptable by the Division(Colorado Regulation No. 7, Section XII.A.3). 5.1.4 All control devices shall be adequately designed and sized to handle fluctuations in emissions of volatile organic compounds. If a flare is used to control emissions of volatile organic compounds, the flare shall be enclosed, smokeless, and designed so that an observer can,by means of visual observation from the outside of the enclosed flare, or by other convenient means approved by the Division, determine whether the flare is operating properly(Colorado Regulation No. 7, Section XII.A.5). Note that since the VOC emissions from the condensate tanks at this facility are not equipped with an enclosed flare,the emission reductions from these tanks may not be used for the VOC emissions reductions requirements specified in Condition 5.1.1. 5.1.5 Pollution prevention devices and processes installed or implemented after June I, 2004 shall qualify as air pollution control technology for purposes of this Condition 5.1 if the owner or operator demonstrates to the satisfaction of the Division that such pollution prevention will result in a quantifiable reduction in emissions of volatile organic compounds from the operation(Colorado Regulation No. 7, Section XII.A.7). 5.2 Glycol Dehydrators On or after May 1, 2005, 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 Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 • Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit#95OPWE033 Page 26 an oil and gas exploration and production operation, 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, flare or other emission control system(Colorado Regulation No. 7, Section XII.C). In the absence or credible evidence to the contrary, the glycol dehydrator at this facility is presumed to be in compliance with the above glycol dehydrator control requirements if the provisions in Conditions 2.3,2.4 and 2.5 are met. 53 General Requirements for Conditions 5.1 and 5.2. 5.3.1 All control devices required by Conditions 5.1 and 5.2 shall be operated pursuant to manufacturer specifications. All condensate collection, storage, processing and handling operations, regardless of size, shall be operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere. To the extent practicable, scheduled maintenance involving the shutdown of the air pollution control technology or release of volatile organic compounds shall be minimized between May 1 and September 1,unless delay or failure to perform such maintenance during such time period would violate any other regulatory requirement, violate any construction permit or Title V operating permit term, or condition, be inconsistent with a relevant equipment manufacturer specification, or endanger health or safety (Colorado Regulation No. 7, Section XII.D.2). 5.3.2 The emission estimates and emission reductions required by Conditions 5.1 and 5.2 shall be demonstrated using emissions factors or emissions testing methods that are based on good engineering principles and for which the Division has no objection (Colorado Regulation No. 7, Section XII.D.3). 5.4 Internal Combustion Engines 5.4.1 Any existing natural gas-fired stationary or portable reciprocating internal combustion engine with a manufacturer's design rate greater than 500 horsepower, which existing engine was operating in the 8-hour Ozone Control Area prior to June 1, 2004, shall employ air pollution control technology on and after May 1, 2005, as provided for in Condition 5.4.2(Colorado Regulation No. 7, Section XVI.A.2). 5.4.2 For lean burn reciprocating internal combustion engines, an oxidation catalyst, or other technology approved by the Division as equally effective at reducing emissions of volatile organic compounds, shall be required. A lean bum reciprocating internal combustion engine is one with a normal exhaust oxygen concentration of 2% by volume,or greater(Colorado Regulation No. 7, Section XVI.B.2). The permittee shall operate and maintain the engine and catalyst in accordance with manufacturer's recommendations and good engineering practices. The pressure and temperature differential across the catalyst will be monitored and recorded monthly to Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 .1 Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit# 95OPWE033 Page 27 assess engine and catalyst operating condition. During those months when portable monitoring is scheduled these parameters are to be monitored and recorded during the portable monitoring event. In addition, the oxygen concentration of the engine exhaust shall be monitored and recorded during the portable monitoring event. 5.4.3 Exemptions to air pollution control technology requirements 5.4.3.1 Non-road engines, as defined in Colorado Regulation No. 3 (Colorado Regulation No. 7, Section XVI.C.1). 5.4.3.2 Any emergency power generator exempt from APEN requirements pursuant to Regulation No. 3 (Colorado Regulation No. 7, Section XVI.C.3). 5.4.3.3 Any lean burn reciprocating internal combustion engine operating in the 8- hour Ozone Control Area prior to June 1, 2004, for which the owner or operator demonstrates to the Division that retrofit technology cannot be installed at a cost of less than$ 5,000 per ton of VOC emission reduction. Installation costs and the best information available for determining control efficiency shall be considered in determining such costs. In order to qualify for such exemption, the owner or operator must submit an application making such a demonstration, together with all supporting documents, to the Division by May 1, 2005. Any reciprocating internal combustion engine qualifying for this exemption shall not be moved to any other location within the 8-hour Ozone Control Area (Colorado Regulation No. 7, Section XVI.C.4). Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit#95OPWE033 Page 28 SECTION III- Permit Shield Regulation No. 3, 5 CCR 1001-5, Part C. &S I.A.4, V.C.1.b. & V.D., XIII.B: S& 25-7-111(2)(I), 25-7- 114.4(3)(a),C.R.S. 1. Specific Non-Applicable Requirements Based upon the information available to the Division and supplied by the applicant, the following parameters and requirements have been specifically identified as non-applicable to the facility to which this permit has been issued. This shield does not protect the source from any violations that occurred prior to or at the time of permit issuance. In addition, this shield does not protect the source from any violations that occur as a result of any modifications or reconstruction on which construction commenced prior to permit issuance. Emission Unit Non-Applicable Requirement Justification Description& Number Facility 40 CFR Part 60,Subpart KKK(as adopted These requirements are not applicable as this facility does not by reference in Colorado Regulation No.6, meet the definition of a natural gas processing plant(any Part A) processing site engaged in the extraction of natural gas liquids from field gas,fractionation of mixed natural gas liquids to natural gas products,or both)provided in§60.631. 2. General Conditions Compliance with this Operating Permit shall be deemed compliance with all applicable requirements specifically identified in the permit and other requirements specifically identified in the permit as not applicable to the source. This permit shield shall not alter or affect the following: 2.1 The provisions of §§ 25-7-112 and 25-7-113, C.R.S., or § 303 of the federal act, concerning enforcement in cases of emergency; 2.2 The liability of an owner or operator of a source for any violation of applicable requirements prior to or at the time of permit issuance; 2.3 The applicable requirements of the federal Mid Rain Program, consistent with § 408(a) of the federal act; 2.4 The ability of the Air Pollution Control Division to obtain information from a source pursuant to § 25-7-111(2)(I), C.R.S., or the ability of the Administrator to obtain information pursuant to § 114 of the federal act; 2.5 The ability of the Air Pollution Control Division to reopen the Operating Permit for cause pursuant to Regulation No. 3,Part C, §XIII. Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit#95OPWE033 Page 29 2.6 Sources are not shielded from terms and conditions that become applicable to the source subsequent to permit issuance. 3. Streamlined Conditions The following applicable requirements have been subsumed within this operating permit using the pertinent streamlining procedures approved by the U.S. EPA. For purposes of the permit shield, compliance with the listed permit conditions will also serve as a compliance demonstration for purposes of the associated subsumed requirements. No conditions have been streamlined. Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 • Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit#95OPWE033 Page 30 SECTION IV- General Permit Conditions 1. Administrative Changes Regulation No.3.5 CCR 1001-5.Part A.6111, The permittee shall submit an application for an administrative permit amendment to the Division for those permit changes that are described in Regulation No.3,Part A,§I.B.I. The pemmittee may immediately make the change upon submission of the application to the Division. 2. Certification Requirements Regulation No.3.5 CCR 1001-5.Part C.66 BI.B.9..V.C.l6a.&e.and V.C.17 a. Any application,report,document and compliance certification submitted to the Air Pollution Control Division pursuant to Regulation No.3 or the Operating Permit shall contain a certification by a responsible official of the truth,accuracy and completeness of such form,report or certification stating that,based on information and belief formed after reasonable inquiry,the statements and information in the document are true,accurate and complete. b. All compliance certifications for terms and conditions in the Operating Permit shall be submitted to the Air Pollution Control Division at least annually unless a more frequent period is specified in the applicable requirement or by the Division in the Operating Permit. c. Compliance certifications shall contain: (i) the identification of each permit term and condition that is the basis of the certification; (ii) the compliance status of the source; (iii) whether compliance was continuous or intermittent; (iv) method(s)used for determining the compliance status of the source,currently and over the reporting period;and (v) such other facts as the Air Pollution Control Division may require to determine the compliance status of the source. d. All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. e. If the permittee is required to develop and register a risk management plan pursuant to§ 112(r)of the federal act,the pennittee shall certify its compliance with that requirement;the Operating Permit shall not incorporate the contents of the risk management plan as a permit term or condition. 3. Common Provisions Common Provisions Regulation.5 CCR 1001-2 66 ILA..II B..11.C..IL.E..11.F..11.1.and IL] a. To Control Emissions Leaving Colorado When emissions generated from sources in Colorado cross the State boundary line,such emissions shall not cause the air quality standards of the receiving State to be exceeded,provided reciprocal action is taken by the receiving State. Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 • • Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit# 95OPWE033 Page 31 b. Emission Monitoring Requirements The Division may require owners or operators of stationary air pollution sources to install, maintain, and use instrumentation to monitor and record emission data as a basis for periodic reports to the Division. c. Performance Testing The owner or operator of any air pollution source shall, upon request of the Division, conduct performance test(s) and furnish the Division a written report of the results of such test(s) in order to determine compliance with applicable emission control regulations. Performance test(s) shall be conducted and the data reduced in accordance with the applicable reference test methods unless the Division: (i) specifies or approves,in specific cases,the use of a test method with minor changes in methodology; (ii) approves the use of an equivalent method; (iii) approves the use of an alternative method the results of which the Division has determined to be adequate for indicating where a specific source is in compliance;or (iv) waives the requirement for performance test(s)because the owner or operator of a source has demonstrated by other means to the Division's satisfaction that the affected facility is in compliance with the standard. Nothing in this paragraph shall be construed to abrogate the Commission's or Division's authority to require testing under the Colorado Revised Statutes,Title 25,Article 7,and pursuant to regulations promulgated by the Commission. Compliance test(s)shall be conducted under such conditions as the Division shall specify to the plant operator based on representative performance of the affected facility. The owner or operator shall make available to the Division such records as may be necessary to determine the conditions of the performance test(s).Operations during period of startup, shutdown, and malfunction shall not constitute representative conditions of performance test(s) unless otherwise specified in the applicable standard. The owner or operator of an affected facility shall provide the Division thirty days prior notice of the performance test to afford the Division the opportunity to have an observer present.The Division may waive the thirty day notice requirement provided that arrangements satisfactory to the Division are made for earlier testing. The owner or operator of an affected facility shall provide,or cause to be provided,performance testing facilities as follows: (i) Sampling ports adequate for test methods applicable to such facility; (v) Safe sampling platform(s); (vi) Safe access to sampling platform(s);and (vii) Utilities for sampling and testing equipment. Each performance test shall consist of at least three separate runs using the applicable test method.Each run shall be conducted for the time and under the conditions specified in the applicable standard.For the purpose of determining compliance with an applicable standard,the arithmetic mean of results of at least three runs shall apply.In the event that a sample is accidentally lost or conditions occur in which one of the runs must be discontinued because of forced shutdown.failure of an irreplaceable portion of the sample train,extreme meteorological conditions,or other Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 • Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit#95OPWE033 Page 32 circumstances beyond the owner or operator's control,compliance may,upon the Division's approval,be determined using the arithmetic mean of the results of the two other runs. Nothing in this section shall abrogate the Division's authority to conduct its own performance test(s)if so warranted. d. Upset Conditions and Breakdowns Upset conditions, as defined, shall not be deemed to be in violation of the Colorado regulations, provided that the Division is notified as soon as possible, but no later than two (2) hours after the start of the next working day, followed by a written notice to the Division explaining the cause of the occurrence and that proper action has been or is being taken to correct the conditions causing the violation and to prevent such excess emission in the future. e. Circumvention Clause A person shall not build,erect,install,or use any article,machine,equipment,condition,or any contrivance,the use of which,without resulting in a reduction in the total release of air pollutants to the atmosphere,reduces or conceals an emission which would otherwise constitute a violation of this regulation. No person shall circumvent this regulation by using more openings than is considered normal practice by the industry or activity in question. f. Compliance Certifications For the purpose of submitting compliance certifications or establishing whether or not a person has violated or is in violation of any standard in the Colorado State Implementation Plan, nothing in the Colorado State Implementation Plan shall preclude the use,including the exclusive use,of any credible evidence or information,relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed.Evidence that has the effect of making any relevant standard or permit term more stringent shall not be credible for proving a violation of the standard or permit term. When compliance or non-compliance is demonstrated by a test or procedure provided by permit or other applicable requirement the owner or operator shall be presumed to be in compliance or non-compliance unless other relevant credible evidence overcomes that presumption. g. Affirmative Defense Provision for Excess Emissions During Startup and Shutdown Note that until such time as the U.S. EPA approves this provision into the Colorado State Implementation Plan (SIP),it shall apply only to State-Only permit terms and conditions and shall be enforceable only by the State. An affirmative defense is provided to owners and operators for civil penalty actions for excess emissions during periods of startup and shutdown. To establish the affirmative defense and to be relieved of a civil penalty in any action to enforce an applicable requirement, the owner or operator of the facility must meet the notification requirements below in a timely manner and prove by a preponderance of the evidence that: (i) The periods of excess emissions that occurred during startup and shutdown were short and infrequent and could not have been prevented through careful planning and design; (ii) The excess emissions were not part of a recurring pattern indicative of inadequate design,operation or maintenance; (iii) If the excess emissions were caused by a bypass(an intentional diversion of control equipment),then the bypass was unavoidable to prevent loss of life,personal injury,or severe property damage; (iv) The frequency and duration of operation in startup and shutdown periods were minimized to the maximum extent practicable; (v) All possible steps were taken to minimize the impact of excess emissions on ambient air quality; Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 • Last Revised: 3/27/06 Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit#95OPWE033 Page 33 (vi) All emissions monitoring systems were kept in operation(if at all possible); (vii) The owner or operator's actions during the period of excess emissions were documented by properly signed,contemporaneous operating logs or other relevant evidence;and, (viii) At all times,the facility was operated in a manner consistent with good practices for minimizing emissions. This subparagraph is intended solely to be a factor in determining whether an affirmative defense is available to an owner or operator,and shall not constitute an additional applicable requirement. The owner or operator of the facility experiencing excess emissions during startup and shutdown shall notify the Division verbally as soon as possible,but no later than two(2)hours after the start of the next working day,and shall submit written quarterly notification following the initial occurrence of the excess emissions.The notification shall address the criteria set forth above. The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief. The Affirmative Defense Provision does not apply to State Implementation Plan provisions or other requirements that derive from new source performance standards or national emissions standards for hazardous air pollutants, or any other federally enforceable performance standard or emission limit with an averaging time greater than twenty- four hours. In addition, an affirmative defense cannot be used by a single source or small group of sources where the excess emissions have the potential to cause an exceedance of the ambient air quality standards or Prevention of Significant Deterioration(PSD)increments. In making any determination whether a source established an affirmative defense, the Division shalt consider the information within the notification required above and any other information the Division deems necessary, which may include,but is not limited to,physical inspection of the facility and review of documentation pertaining to the maintenance and operation of process and air pollution control equipment. 4. Compliance Requirements Regulation No.3.5 CCR 1001-5.Part C. &&III.C.9..V.C.11.& 16.d,and&25-7-122.1(2).C.R.S. a. The permittee must comply with all conditions of the Operating Permit. Any permit noncompliance relating to federally-enforceable terms or conditions constitutes a violation of the federal act,as well as the state act and Regulation No.3. Any permit noncompliance relating to state-only terms or conditions constitutes a violation of the state act and Regulation No.3,shall be enforceable pursuant to state law,and shall not be enforceable by citizens under§304 of the federal act. Any such violation of the federal act,the state act or regulations implementing either statute is grounds for enforcement action,for permit termination,revocation and reissuance or modification or for denial of a permit renewal application. b. It shall not be a defense for a permittee in an enforcement action or a consideration in favor of a permittee in a permit termination,revocation or modification action or action denying a permit renewal application that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of the permit. c. The permit may be modified,revoked,reopened,and reissued,or terminated for cause. The filing of any request by the permittee for a permit modification,revocation and reissuance,or termination,or any notification of planned changes or anticipated noncompliance does not stay any permit condition,except as provided in§§X.and XI.of Regulation No.3,Part C. d. The permittee shall furnish to the Air Pollution Control Division,within a reasonable time as specified by the Division,any information that the Division may request in writing to determine whether cause exists for modifying, revoking and reissuing,or terminating the permit or to determine compliance with the permit. Upon request,the permittee shall also furnish to the Division copies of records required to be kept by the pennittee, including Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Kea-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit#95OPWE033 Page 34 information claimed to be confidential. Any information subject to a claim of confidentiality shall be specifically identified and submitted separately from information not subject to the claim. e. My schedule for compliance for applicable requirements with which the source is not in compliance at the time of permit issuance shall be supplemental,and shall not sanction noncompliance with,the applicable requirements on which it is based. f. For any compliance schedule for applicable requirements with which the source is not in compliance at the time of permit issuance,the permittee shall submit,at least every 6 months unless a more frequent period is specified in the applicable requirement or by the Air Pollution Control Division,progress reports which contain the following: (i) dates for achieving the activities,milestones,or compliance required in the schedule for compliance,and dates when such activities,milestones,or compliance were achieved;and (ii) an explanation of why any dates in the schedule of compliance were not or will not be met,and any preventive or corrective measures adopted. g. The permittee shall not knowingly falsify,tamper with,or render inaccurate any monitoring device or method required to be maintained or followed under the terms and conditions of the Operating Permit. S. Emergency Provisions Regulation No.3.5 CCR 1001-5.Part C.&VII An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed the technology-based emission limitation under the permit due to unavoidable increases in emissions attributable to the emergency. "Emergency"does not include noncompliance to the extent caused by improperly designed equipment, lack of preventative maintenance, careless or improper operation, or operator error. An emergency constitutes an affirmative defense to an enforcement action brought for noncompliance with a technology-based emission limitation if the permittee demonstrates,through properly signed,contemporaneous operating logs,or other relevant evidence that: a. an emergency occurred and that the permittee can identify the cause(s)of the emergency; b. the permitted facility was at the time being properly operated; c. during the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that exceeded the emission standards,or other requirements in the permit;and d. the permittee submitted oral notice of the emergency to the Air Pollution Control Division no later than noon of the next working day following the emergency,and followed by written notice within one month of the time when emissions limitations were exceeded due to the emergency. This notice must contain a description of the emergency,any steps taken to mitigate emissions,and corrective actions taken. This emergency provision is in addition to any emergency or upset provision contained in any applicable requirement. 6. Emission Standards for Asbestos Regulation No.8.5 CCR 1001-10.Part B The permittee shall not conduct any asbestos abatement activities except in accordance with the provisions of Regulation No. 8,Part B,"emission standards for asbestos." 7. Emissions Trading,Marketable Permits,Economic Incentives Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit# 95OPWE033 Page 35 Regulation No.3, 5 CCR 1001-5.Part C,6 V,C.13. No permit revision shall be required under any approved economic incentives, marketable permits, emissions trading and other similar programs or processes for changes that are specifically provided for in the permit. 8. Fee Payment C.R.S. 66 25-7-114.1(6)and 25-7-114.7 a. The permittee shall pay an annual emissions fee in accordance with the provisions of C.R.S.§25-7-114.7. A 1% per month late payment fee shall be assessed against any invoice amounts not paid in full on the 91st day after the date of invoice,unless a permittee has filed a timely protest to the invoice amount. b. The permittee shall pay a permit processing fee in accordance with the provisions of C.I.S.§25-7-114.7. If the Division estimates that processing of the permit will take more than 30 hours,it will notify the permittee of its estimate of what the actual charges may be prior to commencing any work exceeding the 30 hour limit. c. The permittee shall pay an APEN fee in accordance with the provisions of C.R.S. §25.7.114.1(6)for each APEN or revised APEN filed. 9. Fugitive Particulate Emissions Regulation No. 1.5 CCR 1001-3. 6 IILD.1. The permittee shall employ such control measures and operating procedures as are necessary to minimize fugitive particulate emissions into the atmosphere,in accordance with the provisions of Regulation No. 1,§III.D.I. 10. Inspection and Entry Regulation No,3.5 CCR 1001-5,Part C.6 V.C.16.b. Upon presentation of credentials and other documents as may be required by law,the permittee shall allow the Air Pollution Control Division,or any authorized representative,to perform the following: a. enter upon the permittee's premises where an Operating Permit source is located,or emissions-related activity is conducted,or where records must be kept under the terms of the permit; b. have access to,and copy,at reasonable times,any records that must be kept under the conditions of the permit; c. inspect at reasonable times any facilities,equipment(including monitoring and air pollution control equipment), practices,or operations regulated or required under the Operating Permit; d. sample or monitor at reasonable times,for the purposes of assuring compliance with the Operating Permit or applicable requirements,any substances or parameters. 11. Minor Permit Modifications Regulation No.3.5 CCR 1001-5.Part C.66 X.&XI. The permittee shall submit an application for a minor permit modification before making the change requested in the application. The permit shield shall not extend to minor permit modifications. Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 • Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit#95OPWE033 Page 36 12. New Source Review Regulation No.3.5 CCR 1001-5.Part B The permittee shall not commence construction or modification of a source required to be reviewed under the New Source Review provisions of Regulation No.3,Part B,without first receiving a construction permit. 13. No Property Rights Conveyed Regulation No.3.5 CCR 1001-5.Part C.6 V.C.11,d, This permit does not convey any property rights of any sort,or any exclusive privilege. 14. Odor Regulation No.2.5 CCR 1001-4.Part A As a matter of state law only, the permittee shall comply with the provisions of Regulation No. 2 concerning odorous emissions. 15. Off-Permit Changes to the Source Regulation No.3.5 CCR 1001-5.Part C.6 XII.B The pennittee shall record any off-permit change to the source that causes the emissions of a regulated pollutant subject to an applicable requirement,but not otherwise regulated under the permit,and the emissions resulting from the change,including any other data necessary to show compliance with applicable ambient air quality standards. The permittee shall provide contemporaneous notification to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. The permit shield shall not apply to any off-permit change. 16. Opacity Regulation No. 1.5 CCR 1001-3.66 I..II, The permittee shall comply with the opacity emissions limitation set forth in Regulation No. 1, §§ 17. Open Burning Regulation No.9.5 CCR 1001-11 The permittee shall obtain a permit from the Division for any regulated open burning activities in accordance with provisions of Regulation No.9. 18. Ozone Depleting Compounds Regulation No, 15.5 CCR 1001-17 The permittee shall comply with the provisions of Regulation No. 15 concerning emissions of ozone depleting compounds. Sections I.,II.C.,❑.D.,III.IV.,and V.of Regulation No. 15 shall be enforced as a matter of state law only. 19. Permit Expiration and Renewal Regulation No.3.5 CCR 1001-S.Part C.66 III.B.6..IV.C..V.C.2 a. The permit term shall be five(5)years. The permit shall expire at the end of its tenn. Permit expiration terminates the permittee's right to operate unless a timely and complete renewal application is submitted. Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit#95OPWE033 Page 37 b. Applications for renewal shall be submitted at least twelve months,but not more than 18 months,prior to the expiration of the Operating Permit. An application for permit renewal may address only those portions of the permit that require revision,supplementing,or deletion,incorporating the remaining permit terms by reference from the previous permit. A copy of any materials incorporated by reference must be included with the application. 20. Portable Sources Regulation No.3.5 CCR 1001-5.Part C.&I1.D Portable Source permittees shall notify the Air Pollution Control Division at least 10 days in advance of each change in location. 21. Prompt Deviation Reporting Regulation No. 3.5 CCR 1001-5.Part C.6 V.C.7.b. The permittee shall promptly report any deviation from permit requirements,including those attributable to upset conditions as defined in the permit, the probable cause of such deviations, and any corrective actions or preventive measures taken. Unless required by a permit term or condition to report deviations on a more frequent basis, "prompt"reporting shall entail submission of reports of deviations from permit requirements every six(6)months in accordance with paragraph 22.d.below. "Prompt reporting" does not constitute an exception to the requirements of "Emergency Provisions" for the purpose of avoiding enforcement actions. 22. Record Keeping and Reporting Requirements Regulation No.3,5 CCR 1001-5,Part A. 6 H.:Part C. 66 V.C.6.,V.C.7. a. Unless otherwise provided in the source specific conditions of this Operating Permit,the permittee shall maintain compliance monitoring records that include the following information: (i) date,place as defined in the Operating Permit,and time of sampling or measurements; (ii) date(s)on which analyses were performed; (iii) the company or entity that performed the analysis; (iv) the analytical techniques or methods used; (v) the results of such analysis;and (vi) the operating conditions at the time of sampling or measurement. b. The permittee shall retain records of all required monitoring data and support information for a period of at least five (5)years from the date of the monitoring sample,measurement,report or application. Support information,for this purpose,includes all calibration and maintenance records and all original strip-chart recordings for continuous monitoring instrumentation,and copies of all reports required by the Operating Permit. With prior approval of the Air Pollution Control Division,the permittee may maintain any of the above records in a computerized form. c. Pennittees must retain records of all required monitoring data and support information for the most recent twelve (12)month period,as well as compliance certifications for the past five(5)years on-site at all times. A permittee shall make available for the Air Pollution Control Division's review all other records of required monitoring data and support information required to be retained by the pennittee upon 48 hours advance notice by the Division. d. The permittee shall submit to the Air Pollution Control Division all reports of any required monitoring at least every six(6)months,unless an applicable requirement,the enhanced monitoring rule,or the Division requires submission Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 • Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit#95OPWE033 Page 38 on a more frequent basis. All instances of deviations from any permit requirements must be clearly identified in such reports. e. The pemuttee shall file an Air Pollutant Emissions Notice("APEN")prior to constructing,modifying,or altering any facility,process,activity which constitutes a stationary source from which air pollutants are or are to be emitted, unless such source is exempt from the APEN filing requirements of Regulation No.3,Part A,§II.D. A revised APEN shall be filed annually whenever a significant change in emissions,as defined in Regulation No.3,Part A,§ II.C.2.,occurs;whenever there is a change in owner or operator of any facility,process,or activity;whenever new control equipment is installed;whenever a different type of control equipment replaces an existing type of control equipment;whenever a permit limitation must be modified;or before the APEN expires. An APEN is valid for a period of five years. The five-year period recommences when a revised APEN is received by the Air Pollution Control Division. Revised APENs shall be submitted no later than 30 days before the five-year term expires. Pennittees submitting revised APENs to inform the Division of a change in actual emission rates must do so by April 30 of the following year. Where a permit revision is required,the revised APEN must be filed along with a request for permit revision. APENs for changes in control equipment must be submitted before the change occurs. Annual fees are based on the most recent APEN on file with the Division. 23. Reopeningsfor Cause Regulation No.3.5 CCR 1001-5.Part C. 6 XIII a. The Air Pollution Control Division shall reopen,revise,and reissue Operating Permits;permit reopenings and reissuance shall be processed using the procedures set forth in Regulation No.3,Part C, §III.,except that proceedings to reopen and reissue permits affect only those parts of the permit for which cause to reopen exists. b. The Division shall reopen a permit whenever additional applicable requirements become applicable to a major source with a remaining permit term of three or more years,unless the effective date of the requirements is later than the date on which the permit expires,or unless a general permit is obtained to address the new requirements; whenever additional requirements(including excess emissions requirements)become applicable to an affected source under the acid rain program;whenever the Division determines the permit contains a material mistake or that inaccurate statements were made in establishing the emissions standards or other terms or conditions of the permit; or whenever the Division determines that the permit must be revised or revoked to assure compliance with an applicable requirement. c. The Division shall provide 30 days'advance notice to the permittee of its intent to reopen the permit,except that a shorter notice may be provided in the case of an emergency. d. The permit shield shall extend to those parts of the permit that have been changed pursuant to the reopening and reissuance procedure. 24. Section 502(bX10)Changes Regulation No.3.5 CCR 1001-5.Part C.6 XILA The permittee shall provide a minimum 7-day advance notification to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit The permittee shall attach a copy of each such notice given to its Operating Permit. 25. Severability Clause Regulation No.3.5 CCR 1001-5.Part C.6 V.C.10, In the event of a challenge to any portion of the permit, all emissions limits, specific and general conditions, monitoring, record keeping and reporting requirements of the permit,except those being challenged,remain valid and enforceable. Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit#95OPWE033 Page 39 26. Significant Permit Modifications Regulation No,3,5 CCR 1001-S.Part C.§11I.8.2. The permittee shall not make a significant modification required to be reviewed under Regulation No. 3, Part B ("Construction Permit" requirements) without first receiving a construction permit. The permittee shall submit a complete Operating Permit application or application for an Operating Permit revision for any new or modified source within twelve months of commencing operation,to the address listed in Item I in Appendix D of this permit. If the permittee chooses to use the "Combined Construction/Operating Permit" application procedures of Regulation No. 3, Part C, then the Operating Permit must be received prior to commencing construction of the new or modified source. 27. Special Provisions Concerning the Acid Rain Program Regulation No.3.5 CCR 1001-5.Part C. 66 V.C.I.b.&8 a. Where an applicable requirement of the federal act is more stringent than an applicable requirement of regulations promulgated under Title IV of the federal act,40 Code of Federal Regulations(CFR)Part 72,both provisions shall be incorporated into the permit and shall be federally enforceable. b. Emissions exceeding any allowances that the source lawfully holds under Title IV of the federal act or the regulations promulgated thereunder,40 CFR Part 72,are expressly prohibited. 28. Transfer or Assignment of Ownership Regulation No.3.5 CCR 1001-5,Part C. 6 II,C. No transfer or assignment of ownership of the Operating Permit source will be effective unless the prospective owner or operator applies to the Air Pollution Control Division on Division-supplied Administrative Permit Amendment forms, for reissuance of the existing Operating Permit. No administrative permit shall be complete until a written agreement containing a specific date for transfer of permit,responsibility,coverage,and liability between the permittee and the prospective owner or operator has been submitted to the Division. 29. Volatile Organic Compounds Regulation No.7.5 CCR 1001-9.$6 1II&V. a. For sources located in an ozone non-attainment area or the Denver Metro Attainment Maintenance Area,all storage tank gauging devices,anti-rotation devices,accesses,seals,hatches,roof drainage systems,support structures,and pressure relief valves shall be maintained and operated to prevent detectable vapor loss except when opened, actuated,or used for necessary and proper activities(e.g.maintenance). Such opening,actuation,or use shall be limited so as to minimize vapor loss. Detectable vapor loss shall be determined visually,by touch,by presence of odor,or using a portable hydrocarbon analyzer. When an analyzer is used, detectable vapor loss means a VOC concentration exceeding 10,000 ppm. Testing shall be conducted as in Regulation No.7,Section VIII.C.3. Except when otherwise provided by Regulation No.7,all volatile organic compounds,excluding petroleum liquids, transferred to any tank,container,or vehicle compartment with a capacity exceeding 212 liters(56 gallons),shall be transferred using submerged or bottom filling equipment. For top loading,the fill tube shall reach within six inches of the bottom of the tank compartment. For bottom-fill operations,the inlet shall be flush with the tank bottom. b. The permittee shall not dispose of volatile organic compounds by evaporation or spillage unless Reasonably Available Control Technology(RACT)is utilized, Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 • Air Pollution Control Division Kerr-McGee Gathering LLC Colorado Operating Permit Dougan Compressor Station Permit#95OPWE033 Page 40 c. No owner or operator of a bulk gasoline terminal,bulk gasoline plant,or gasoline dispensing facility as defined in Colorado Regulation No.7,Section VI,shall permit gasoline to be intentionally spilled,discarded in sewers,stored in open containers,or disposed of in any other manner that would result in evaporation. 30. Wood Stoves and Wood burning Appliances Regulation No.4.5 CCR 1001-6 The permittee shall comply with the provisions of Regulation No.4 concerning the advertisement,sale,installation,and use of wood stoves and wood burning appliances. Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Colorado Operating Permit Appendices OPERATING PERMIT APPENDICES A - INSPECTION INFORMATION B - MONITORING AND PERMIT DEVIATION REPORT C - COMPLIANCE CERTIFICATION REPORT D - NOTIFICATION ADDRESSES E - PERMIT ACRONYMS F - PERMIT MODIFICATIONS G - COMPLIANCE ASSURANCE MONITORING PLAN *DISCLAIMER: None of the information found in these Appendices shall be considered to be State or Federally enforceable, except as otherwise provided in the permit, and is presented to assist the source, permitting authority, inspectors, and citizens. Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Colorado Operating Permit Appendix A Inspection Information Page 1 APPENDIX A-Inspection Information Directions to Plant: Take old Highway 85 (Road 27) North from Brighton, CO four (4) miles to Road 10. Take Road 10 East three and one-quarter miles(3-1/4)miles to the plant site. Safety Equipment Required: Hard Hat Safety Shoes Hearing Protection Flame Resistant Clothing Facility Plot Plan: Figure 1 (following page) shows the plot plan as submitted on February 1, 1995 with the source's Title V Operating Permit Application. List of Insignificant Activities: The following list of insignificant activities was provided by the source to assist in the understanding of the facility layout. Since there is no requirement to update such a list,activities may have changed since the last filing. Tanks Glycol Storage Tank(T01) Coolant Storage Tanks(T02,T03) Methanol Storage Tank(T04) Used Oil Storage Tank(T05) New Oil Storage Tank(T10) Emergency Generators Caterpillar,Model 2T-8497, Serial No. 9NR05876,Diesel Fuel-Fired Internal Combustion Engine,rated at 320 hp,used to drive an emergency electricity generator Heaters/Boilerg Dehydrator Reboiler Unit- 1.5 MMBtu/hr Direct Fired Line Heater(H01) Miscellaneous Condensate Loading Equipment(emissions below de minimis) Blowdown Emissions Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 x r t S T Figure 1: Facility Plot Plan g Dougan Compressor Station I — I ii 1 ) i I. .. �t S g ea EJtI 1 I tot . to I i � ` I ON Z L ( 1 u_ ( t I Jw : ... �.• _ 7 i I .-a 211 • *� I t t I ao Ello ; •! 1 N I[ r— II Er l .`I s a u Ig I 1 ou 'r u1c a r•n 1 I i i . - 1 il III k i + lb I J a �r " ' I e' it E6 i 9 it. ill tt Milli MA il n t aW r it ;Mini ., II I ...u..... ...�... — .. 1.4. • II7p -i 0 w Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 1 Appendix B Reporting Requirements and Definitions with codes ver 2/1/01 Please note that,pursuant to 113(c)(2)of the federal Clean Air Act, any person who knowingly: (A) makes any false material statement, representation, or certification in, or omits material information from, or knowingly alters, conceals, or fails to file or maintain any notice, application, record, report, plan, or other document required pursuant to the Act to be either filed or maintained (whether with respect to the requirements imposed by the Administrator or by a State); (B) fails to notify or report as required under the Act; or (C) falsifies,tampers with,renders inaccurate, or fails to install any monitoring device or method required to be maintained or followed under the Act shall, upon conviction, be punished by a fine pursuant to title 18 of the United States Code, or by imprisonment for not more than 2 years, or both. If a conviction of any person under this paragraph is for a violation committed after a first conviction of such person under this paragraph, the maximum punishment shall be doubled with respect to both the fine and imprisonment. The permittee must comply with all conditions of this operating permit. Any permit noncompliance constitutes a violation of the Act and is grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application. The Part 70 Operating Permit program requires three types of reports to be filed for all permits. All required reports must be certified by a responsible official. Report#1: Monitoring Deviation Report(due at least every six months) For purposes of this operating permit, the Division is requiring that the monitoring reports are due every six months unless otherwise noted in the permit. All instances of deviations from permit monitoring requirements must be clearly identified in such reports. For purposes of this operating permit,monitoring means any condition determined by observation,by data from any monitoring protocol, or by any other monitoring which is required by the permit as well as the recordkeeping associated with that monitoring. This would include, for example, fuel use or process rate monitoring,fuel analyses,and operational or control device parameter monitoring. Report#2: Permit Deviation Report (must be reported "promptly") In addition to the monitoring requirements set forth in the permits as discussed above, each and every requirement of the permit is subject to deviation reporting. The reports must address deviations from permit Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 2 requirements, including those attributable to upset conditions and malfunctions as defined in this Appendix, the probable cause of such deviations,and any corrective actions or preventive measures taken. All deviations from any term or condition of the permit are required to be summarized or referenced in the annual compliance certification. For purposes of this operating permit, "upset" shall refer to both emergency conditions and upsets. Additional discussion on these conditions is provided later in this Appendix. For purposes of this operating permit, the Division is requiring that the permit deviation reports are due every six months unless otherwise noted in the permit Where the underlying applicable requirement contains a definition of prompt or otherwise specifies a time frame for reporting deviations, that definition or time frame shall govern. For example, quarterly Excess Emission Reports required by an NSPS or Regulation No. 1, Section IV. In addition to the monitoring deviations discussed above, included in the meaning of deviation for the purposes of this operating permit are any of the following: (1) A situation where emissions exceed an emission limitation or standard contained in the permit; (2) A situation where process or control device parameter values demonstrate that an emission limitation or standard contained in the permit has not been met; (3) A situation in which observations or data collected demonstrates noncompliance with an emission limitation or standard or any work practice or operating condition required by the permit; or, (4) A situation in which an excursion or exceedance as defined in 40 CFR Part 64 (the Compliance Assurance Monitoring(CAM) Rule) has occurred. (only if the emission point is subject to CAM) For reporting purposes, the Division has combined the Monitoring Deviation Report with the Permit Deviation Report. All deviations shall be reported using the following codes: 1 =Standard: When the requirement is an emission limit or standard 2=Process: When the requirement is a production/process limit 3=Monitor: When the requirement is monitoring 4=Test: When the requirement is testing 5=Maintenance: When required maintenance is not performed 6=Record: When the requirement is recordkeeping 7=Report: When the requirement is reporting 8-CAM: A situation in which an excursion or exceedance as defined in 40 CFR Part 64 (the Compliance Assurance Monitoring(CAM)Rule)has occurred. 9=Other: When the deviation is not covered by any of the above categories Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 3 Report#3: Compliance Certification(annually,as defined in the permit) Submission of compliance certifications with terms and conditions in the permit, including emission limitations, standards,or work practices, is required not less than annually. Compliance Certifications are intended to state the compliance status of each requirement of the permit over the certification period. They must be based,at a minimum, on the testing and monitoring methods specified in the permit that were conducted during the relevant time period. In addition,if the owner or operator knows of other material information(i.e. information beyond required monitoring that has been specifically assessed in relation to how the information potentially affects compliance status), that information must be identified and addressed in the compliance certification. The compliance certification must include the following: • The identification of each term or condition of the permit that is the basis of the certification; • The identification of the method(s)or other means used by the owner or operator for determining the compliance status with each permit term and condition during the certification period and whether such methods or other means provide continuous or intermittent data. Such methods and other means shall include, at a minimum, the methods and means required in the permit. If necessary, the owner or operator also shall identify any other material information that must be included in the certification to comply with section 113(c)(2) of the Federal Clean Air Act, which prohibits knowingly making a false certification or omitting material information; • The status of compliance with the terms and conditions of the permit, and whether compliance was continuous or intermittent. The certification shall identify each deviation and take it into account in the compliance certification. Note that not all deviations are considered violations.' • Such other facts as the Division may require, consistent with the applicable requirements to which the source is subject,to determine the compliance status of the source. The Certification shall also identify as possible exceptions to compliance any periods during which compliance is required and in which an excursion or exceedance as defined under 40 CFR Part 64 (the Compliance Assurance Monitoring(CAM)Rule)has occurred. (only for emission points subject to CAM) Note the requirement that the certification shall identify each deviation and take it into account in the compliance certification. Previously submitted deviation reports, including the deviation report submitted at the time of the annual certification,may be referenced in the compliance certification. For example, given the various emissions limitations and monitoring requirements to which a source may be subject, a deviation from one requirement may not be a deviation under another requirement which recognizes an exception and/or special circumstances relating to that same event. Further, periods of excess emissions during startup, shutdown and malfunction may not be found to be a violation of an emission limitation or standard where the source adequately shows that any potential deviations as a result of these infrequent periods were minimized to the extent practicable and could not have been prevented through careful planning, design, or were unavoidable to prevent loss of life,personal injury,or severe property damage. Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 4 Startup, Shutdown,Malfunctions,Emergencies,and Upsets Understanding the application of Startup, Shutdown, Malfunctions, Emergency provisions, and the Upset provisions is very important in both the deviation reports and the annual compliance certifications. Startup,Shutdown,and Malfunctions Please note that exceedances of some New Source Performance Standards (NSPS) and Maximum Achievable Control Technology (MACT) standards that occur during Startup, Shutdown or Malfunctions may not be considered to be non-compliance since emission limits or standards often do not apply unless specifically stated in the NSPS. Such exceedances must,however,be reported as excess emissions per the NSPS/MACT rules and would still be noted in the deviation report. In regard to compliance certifications, the permittee should be confident of the information related to those deviations when making compliance determinations since they are subject to Division review. The concepts of Startup, Shutdown and Malfunctions also exist for Best Available Control Technology(BACT)sources,but are not applied in the same fashion as for NSPS and MACT sources. Emergencies and Upsets Under the Emergency provisions of Part 70 and the Upset provisions of the State regulations, certain operational conditions may act as an affirmative defense against enforcement action if they are properly reported. DEFINITIONS Malfunction (NSPS)" means any sudden, infrequent, and not reasonably preventable failure of air pollution control equipment, process equipment, or a process to operate in a normal or usual manner. Failures that are caused in part by poor maintenance or careless operation are not malfunctions. Malfunction (SIP) means any sudden and unavoidable failure of air pollution control equipment or process equipment or unintended failure of a process to operate in a normal or usual manner. Failures that are primarily caused by poor maintenance, careless operation, or any other preventable upset condition or preventable equipment breakdown shall not be considered malfunctions. Emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed a technology-based emission limitation under the permit, due to unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by improperly designed equipment, lack of preventative maintenance, careless or improper operation,or operator error. Upset means an unpredictable failure of air pollution control or process equipment which results in the violation of emission control regulations and which is not due to poor maintenance, improper or careless operations, or is otherwise preventable through exercise of reasonable care. Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 5 Monitoring and Permit Deviation Report-Part I 1. Following is the required format for compliance monitoring reports to be submitted to the Division on a semi-annual basis unless otherwise noted in the permit. The Table below must be completed for all equipment or processes for which specific Operating Permit terms exist. 2. Part II of this Appendix B shows the format and information the Division will require for describing periods of monitoring and permit deviations, or upset or emergency conditions as indicated in the Table below. One Part II form must be completed for each Deviation. Previously submitted reports (e.g. EER's or Upsets)may be referenced and the form need not be filled out in its entirety. FACILITY NAME: Kerr-McGee Gathering LLC—Dougan Compressor Station OPERATING PERMIT NO: 95OPWE033 REPORTING PERIOD: (see first page of the permit for specific reporting period and dates) Deviations Noted Deviation Upset/Emergency Operating During Period' Code2 Condition Reported Permit Unit , During Period Xr ID Unit Description YES NO 'a e; YES NO EU-21 Cooper Bessemer,Model 12Q115HC(155 Quad),Serial No.48800,Natural Gas Fired Combustion Engine,Rated at 5137 hp maximum. Powers a Natural Gas Compressor. EU-01 Custom Triethylene Glycol Dehydration Unit,Serial No. GDUD0I W,rated at 80 mmSCF/day,with associated electric glycol pump,flash tank and till vent. This glycol dehydrator is equipped with an air-assisted flare to control VOC emissions. The flash tank emissions are routed to the reboiler or flare. F001 Fugitive VOC Emissions from Equipment Leaks T001 Condensate Storage Tank Battery General Conditions Insignificant Activities See previous discussion regarding what is considered to be a deviation. Determination of whether or not a deviation has occurred shall be based on a reasonable inquiry using readily available information. 2Use the following entries as appropriate: 1=Standard: When the requirement is an emission limit or standard 2=Process: When the requirement is a production/process limit 3=Monitor: When the requirement is monitoring 4=Test: When the requirement is testing 5=Maintenance: When required maintenance is not performed 6=Record: When the requirement is recordkeeping 7=Report: When the requirement is reporting ti=CAM: A situation in which an excursion or exceedance as defined in 40CFR Part 64(the Compliance Assurance Monitoring(CAM)Rule)has occurred. Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 • Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 6 9-Other: When the deviation is not covered by any of the above categories Operating Permit Number:95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 7 Monitoring and Permit Deviation Report -Part II FACILITY NAME: Kerr-McGee Gathering LLC - Dougan Compressor Station OPERATING PERMIT NO: 95OPWE033 REPORTING PERIOD: Is the deviation being claimed as an: Emergency Upset N/A _ (For NSPS/MACT)Did the deviation occur during: Startup Shutdown Malfunction _ Normal Operation OPERATING PERMIT UNIT IDENTIFICATION: Operating Permit Condition Number Citation Explanation of Period of Deviation Duration (start/stop date&time) Action Taken to Correct the Problem Measures Taken to Prevent a Reoccurrence of the Problem Dates of Upsets/Emergencies Reported (if applicable) Deviation Code(for Division Use Only) Division Code QA: SEE EXAMPLE ON THE NEXT PAGE Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 • Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 8 EXAMPLE FACILITY NAME: Acme Corp. OPERATING PERMIT NO: 96OPZZXXX REPORTING PERIOD: 1/1/96 -6/30/96 Is the deviation being claimed as an: Emergency Upset XX N/A (For NSPS/MACT)Did the deviation occur during: Startup Shutdown Malfunction Normal Operation _ OPERATING PERMIT UNIT IDENTIFICATION: Asphalt Plant with a Scrubber for Particulate Control -Unit XXX Operating Permit Condition Number Citation Section II,Condition 3.1 - Opacity Limitation Explanation of Period of Deviation Slurry Line Feed Plugged Duration START- 1730 4/10/96 END- 1800 4/10/96 Action Taken to Correct the Problem Line Blown Out Measures Taken to Prevent Reoccurrence of the Problem Replaced Line Filter Dates of Upsets/Emergencies Reported(if applicable) 4/10/96 to S. Busch,APCD Deviation Code(for Division Use Only) Division Code QA: Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 9 Monitoring and Permit Deviation Report - Part III REPORT CERTIFICATION SOURCE NAME: Kerr-McGee Gathering LLC -Dougan Compressor Station FACILITY IDENTIFICATION NUMBER: 1230185 PERMIT NUMBER: 95OPWE033 REPORTING PERIOD: (see first page of the permit for specific reporting period and dates) All information for the Title V Semi-Annual Deviation Reports must be certified by a responsible official as defined in Colorado Regulation No. 3, Part A, Section I.B.38. This signed certification document must be packaged with the documents being submitted. STATEMENT OF COMPLETENESS I have reviewed the information being submitted in its entirety and, based on information and belief formed after reasonable inquiry,I certify that the statements and information contained in this submittal are true,accurate and complete. Please note that the Colorado Statutes state that any person who knowingly,as defined in Sub-Section 18- 1-501(6), C.R.S., makes any false material statement, representation, or certification in this document is guilty of a misdemeanor and may be punished in accordance with the provisions of Sub-Section 25-7 122.1, C.R.S. Printed or Typed Name Title Signature of Responsible Official Date Signed Note: Deviation reports shall be submitted to the Division at the address given in Appendix D of this permit. No copies need be sent to the U.S.EPA. Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 • Air Pollution Control Division Colorado Operating Permit Appendix C Compliance Certification Report Page 1 APPENDIX C Format for Annual Compliance Certification Reports FACILITY NAME: Kerr-McGee Gathering LLC—Dougan Compressor Station OPERATING PERMIT NO: 95OPWE033 I. Facility Status: _During the entire reporting period,this source was in compliance with ALL terms and conditions contained in the Permit, each term and condition of which is identified and included by this reference. The method(s) used to determine compliance is/are the method(s)specified in the Permit. With the possible exception of the deviations identified in the table below, this source was in compliance with all terms and conditions contained in the Permit, each term and condition of which is identified and included by this reference, during the entire reporting period. The method used to determine compliance for each term and condition is the method specified in the Permit, unless otherwise indicated and described in the deviation report(s). Note that not all deviations are considered violations. Operating Unit Description Deviations Monitoring Was compliance Was Data Permit Reported' Method per continuous or Continuous?' Unit ID Permit? intermittent? Previous Current YES NO continuous intermittent YES NO EU-21 Cooper Bessemer, Model 12Q115HC(155 Quad),Serial No. 48800,Natural Gas Fired Internal Combustion Engine, Rated at 5137 hp maximum. Powers a Natural Gas Compressor. EU-01 Custom Triethylene Glycol Dehydration units,Serial No. GDUD0I W,Rated at 80 MMsctlday,with associated electric glycol pump,flash tank and still vent. This glycol dehydrator is equipped with an air- assisted flare to control VOC emissions. The flash tank emissions are routed to the reboiler a Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Colorado Operating Permit Appendix C Compliance Certification Report Page 2 Operating Unit Description Deviations Monitoring Was compliance Was Data Permit Reported Method per continuous or Continuous?" Unit ID Permit?' intermittent?' Previous Current YES NO continuous intermittent YES NO flare. F001 Fugitive VOC Emissions from Equipment Leaks TOO I Condensate Storage Tank Battery General Conditions Insignificant Activities S ' If deviations were noted in the previous deviation report(i.e.for the first six months of the annual reporting period),put an"X"under "previous". If deviations were noted in the current deviation report(i.e.for the last six months of the annual reporting period),put an "X"under"current". Mark both columns if both apply. 2 Note whether the method(s)used to determine the compliance status with each term and condition was the method(s)specified in the permit. If it was not,mark"no"and attach additional information/explanation. Note whether the compliance status with each term and condition provided was continuous or intermittent. "Intermittent Compliance"can mean either that noncompliance has occurred or that the owner or operator has data sufficient to certify compliance only on an intermittent basis. Certification of intermittent compliance therefore does not necessarily mean that any noncompliance has occurred. The Periodic Monitoring requirement of the Operating Permit program rule are intended to provide assurance that even in the absence of a continuous system of monitoring the Title V source has operated in continuous compliance for the duration of the reporting period. Therefore, if a source 1)conducts all of the monitoring and recordkeeping required in its permit,even if such a activities are done periodically and not continuously,and if 2)such monitoring and recordkeeping does not indicate non-compliance, and if 3)the Responsible Official is not aware of any credible evidence that indicates non-compliance, then the Responsible Official can certify that the emission point(s)in question were in continuous compliance during the applicable time period. ° Note whether the method(s) used to determine the compliance status with each term and condition provided continuous or intermittent data. ° Compliance status for these sources shall be based on a reasonable inquiry using readily available information. Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 • Air Pollution Control Division Colorado Operating Permit Appendix C Compliance Certification Report Page 3 III. Status for Accidental Release Prevention Program: A. This facility is subject is not subject to the provisions of the Accidental Release Prevention Program(Section 112(r)of the Federal Clean Air Act) B. If subject: The facility is is not in compliance with all the requirements of section 112(r). 1. A Risk Management Plan will be has been submitted to the appropriate authority and/or the designated central location by the required date. III. Certification I have reviewed this certification in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this certification are true, accurate and complete. Please note that the Colorado Statutes state that any person who knowingly, as defined in § 18-1-501(6), C.R.S.,makes any false material statement, representation,or certification in this document is guilty of a misdemeanor and may be punished in accordance with the provisions of §25-7122.1,C.R.S. Printed or Typed Name Title Signature Date Signed NOTE: All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Colorado Operating Permit Appendix D Notification Addresses Page 1 APPENDIX D Notification Addresses 1. Air Pollution Control Division Colorado Department of Public Health and Environment Air Pollution Control Division Operating Permits Unit APCD-SS-B 1 4300 Cherry Creek Drive S. Denver, CO 80246-1530 ATTN: Jim King 2. United States Environmental Protection Agency Compliance Notifications: Office of Enforcement, Compliance and Environmental Justice Mail Code 8ENF-T U.S.Environmental Protection Agency,Region VIII 999 18th Street, Suite 300 Denver, CO 80202 Permit Modifications,Off Permit Changes: Office of Partnerships and Regulatory Assistance Air and Radiation Programs,8P-AR U.S. Environmental Protection Agency,Region VIII 999 18th Street, Suite 300 Denver, CO 80202 Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 • Air Pollution Control Division Colorado Operating Permit Appendix E Permit Acronyms Page 1 APPENDIX E Permit Acronyms Listed Alphabetically: AIRS- Aerometric Information Retrieval System AP-42 - EPA Document Compiling Air Pollutant Emission Factors APEN- Air Pollution Emission Notice(State of Colorado) APCD- Air Pollution Control Division(State of Colorado) ASTM - American Society for Testing and Materials BACT- Best Available Control Technology BTU- British Thermal Unit CAA- Clean Air Act(CAAA=Clean Air Act Amendments) CCR- Colorado Code of Regulations CEM- Continuous Emissions Monitor CF- Cubic Feet(SCF= Standard Cubic Feet) CFR- Code of Federal Regulations CO - Carbon Monoxide COM- Continuous Opacity Monitor CRS- Colorado Revised Statute EPA- Environmental Protection Agency FR- Federal Register G- Grams Gal - Gallon HAPs- Hazardous Air Pollutants HP- Horsepower HP-HR- Horsepower Hour(G/HP-HR=Grams per Horsepower Hour) LAER- Lowest Achievable Emission Rate LBS- Pounds M- Thousand MM - Million MMscf- Million Standard Cubic Feet MMscfd- Million Standard Cubic Feet per Day N/A or NA- Not Applicable NOx- Nitrogen Oxides NESHAP- National Emission Standards for Hazardous Air Pollutants NSPS - New Source Performance Standards PM- Particulate Matter PMio - Particulate Matter Under 10 Microns PSD- Prevention of Significant Deterioration PTE- Potential To Emit RACT- Reasonably Available Control Technology SCC- Source Classification Code Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Colorado Operating Permit Appendix E Permit Acronyms Page 2 SCF- Standard Cubic Feet SIC- Standard Industrial Classification SO2 - Sulfur Dioxide TPY- Tons Per Year TSP - Total Suspended Particulate VOC - Volatile Organic Compounds Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Colorado Operating Permit Appendix F Permit Modifications Page 1 APPENDIX F Permit Modifications DATE OF TYPE OF SECTION DESCRIPTION OF REVISION REVISION REVISION NUMBER, CONDITION NUMBER January 21, Minor Section II, Revised language to reflect revisions made to CAM plan in Appendix G. 2005 Modification Condition 4.7.1 Appendix G Revised CAM Plan. March 27, Administrative Page Following Changed the company name from Kerr-McGee Rocky Mountain Corp to 2006 Amendment Cover Page Kerr-McGee Gathering,LLC. Changed the permit contact and removed one Responsible Official. Page Headers Changed the company name from Kerr-McGee Rocky Mountain Corp to Kerr-McGee Gathering,LLC in the tables, Appendices B and Changed the company name from Kerr-McGee Rocky Mountain Corp to C Kerr-McGee Gathering,LLC in the tables. Operating Permit Number. 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Air Pollution Control Division Colorado Operating Permit Appendix G Compliance Assurance Monitoring Plant Page 1 APPENDIX G Compliance Assurance Monitoring Plan I. Background a. Emission Unit Description: Condensate Tank Battery—Four(4)225 bbl,one(1) 200 bbl and one(1) 300 bbl manifolded together to form a single vent line. b. Applicable Regulation. Emission Limit.Monitoring Requirements: Regulations: Operating Permit Section II, Condition 4.1 Emission Limitations: VOC 7 tons/yr c. Control Technology: Air-Assisted Flare II. Monitoring Approach Indicator No. I Indicator No.2 I. Indicator Presence of Flame Pilot Light Spark Measurement Approach Thermal Device Audible II. Indicator Range An excursion is defined as no flame present An excursion is defined as no audible or no flame sensed. detection for more than twenty two Excursions trigger the permittee to seconds. investigate the flare performance and make Excursions trigger the permittee to any repairs or adjustments necessary. Any investigate the flare performance and make adjustments or repairs shall be recorded in a any repairs or adjustments necessary. Any log,to be made available to the Division adjustments or repairs shall be recorded in a upon request. log,to be made available to the Division upon request. III. Performance Criteria a. Data Representativeness The thermal device monitors the presence Audible sound is high voltage arcing on of a flame, so either a flame or no flame is igniter head. If spark is not functioning the indicated. pilot flame will not re-ignite after a flame- out situation. b. Verification of If the flame goes out,a call-out is initiated. Failure of pilot flame ignition and lack of Operational Status audible sound. Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 4 Mr Pollution Control Division Colorado Operating Permit Appendix G Compliance Assurance Monitoring Plant Page 2 Indicator No. I Indicator No.2 c. QA/QC Practices and The thermal device is fail-safe. If the Audible is fail-safe. If the spark Criteria thermal device is not functioning,the malfunctions and the flame goes out,the control system assumes the flame is out flame cannot be re-ignited and will result in The thermal device is repaired or replaced the thermal device noting that the flame is if not working.. out and initiate call-out. The pilot light is repaired or replaced if not working. d. Monitoring Frequency Flame status monitored continuously by Audible sound for two seconds every thermal device. twenty seconds. Because the presence of a spark is audible, it is only monitored when an operator is present on site. f. Data Collection A visual check for the presence of a flame Repairs or replacements of the pilot spark Procedures is made and recorded daily. are noted in a log. Excursions and any adjustments or repairs Excursions and any adjustments or repairs made to the flare following an excursion made to the flare following an excursion shall be noted in daily log. shall be noted in daily log. e. Averaging Time N/A N/A III. Justification a. Background: When natural gas is delivered to a compressor station, it is at a pressure between 80 and 140 psig. The associated water and condensate must be"flashed"down to near atmospheric pressure in order to be separated and shipped. A flare is used to destroy the volatile organic compounds (VOC)emitted during the flash. b. Rational for Selection of Performance Indicators and Indicator Ranges: As noted above, the destruction of VOC is dependant upon combustion. The flare is provided with burner control panels that provide constant assurance of a lit flame and re-occurring spark. The burner control panel provides a spark for two seconds every twenty seconds. The spark is audible and the absence of the audible can be detected when operators are on-site (the facility is unmanned). The flare is also equipped with a thermal device to ensure that a flame is present. If the thermal device indicates there is no flame detected,the pilot flame may be re-lit by the spark. If the flame is not re-lit within two to three cycles of the spark(40-60 seconds),the operator on call is notified via a wireless alarm system. The CAM rule specifies that presumptively acceptable monitoring includes monitoring required for any standards that are exempt from CAM (i.e. MACT standards), provided the monitoring is applicable to the control device (40 CFR Part 64 § 64.4(b)(4), as adopted by reference in Colorado Regulation No. 3,Part C, Section XIV). Monitoring a flare for the presence of a flame is monitoring consistent with the provisions in 40 CFR Part 63 Subparts HH and HHH, the Oil Operating Permit Number:95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 ',- Air Pollution Control Division Colorado Operating Permit Appendix G Compliance Assurance Monitoring Plant Page 3 and Natural Gas Production and Natural Gas Storage and Transmission MACTs (note that subparts HH and HHH require the flare to meet the requirements in subpart A, § 63.11(b)). Both MACTs require a glycol dehydrator to be equipped with a control device (a flare being one option) to reduce HAP emissions. Since the monitoring is directly applicable, the Division considers monitoring the flare for the presence of a flame to be presumptive CAM. Note that monitoring the pilot light spark is not required under § 63.11(b) but is an additional measure proposed by the source to prevent flame outages. Operating Permit Number: 95OPWE033 First Issued: 11/01/97 Renewed: 12/1/04 Last Revised: 3/27/06 Weld • unty Referral D U D November 8, 20O7 21 200 Weld County planning Department WI ID O NOV GREELEY OFFICE • av FEB 191008 COLORADO RECEIVED The Weld County Department of Planning Services has received the following item for review: Applicant Kerr-McGee Gathering, LLC Case Number 2nd AmUSR-468 Please Reply By December 7, 2007 Planner Kim Ogle Project A Site Specific Development Plan and an Amended Special Review Permit for Mineral Resource Development Facility including Oil and Gas Support and Service (Natural Gas Processing Facility and one or more microwave or other communication transmission or relay towers over seventy(70)feet in height in the A(Agricultural)Zone District. Legal Part of the NW4, Section 14, Ti N, R66W of the 6th P.M., Weld County, Colorado. Location South of and adjacent to CR 10; 1/4 mile east of CR 33. Parcel Number 1471 14 000012 The application is submitted to you for review and recommendation. Any comments or recommendation you consider relevant to this request would be appreciated. Please reply by the above listed date so that we may give full consideration to your recommendation. Any response not received before or on this date may be deemed to be a positive response to the Department of Planning Services. If you have any further questions regarding the application, please call the Planner associated with the request. Please note that new information may be added to applications under review during the review process. If you desire to examine or obtain this additional information, please call the Department of Planning Services. Weld County Planning Commission Hearing (if applicable) January 15, 2007 ❑ We have reviewed the request and find that it does/does not comply with our Comprehensive Plan ❑ We have reviewed the request and find no conflicts with our interests. ❑ See attached letter. ❑ Please notify �me�of any public hearings regarding this request. �/ � //^ �Coomments: (�' 'r/' C/OM ME-3 �] 0�f �j (01CF0 /co h$ir c/ &4O L-7 'tll Kc f /Ace S 0( 1J Wl✓to ( or I WW17`Zto O -� I T ga/(J,0S4 / / S 4e/Of-1'71i 24 ood 0-ft 'A(fe use� �� tar ' q 6 ew Or e mat MIL r .� 246' / leg e Signature �� / �/�/��/ 7 Date y Agency &fermi ! 14-Pie( j 2��, Y/r✓i +Weld County Planning Dept. +918 10th Street,Greeley,CO. 80631 4(970)353-6100 ext.3540 ❖(970)304-6498 fax DEPARTMENT OF PLANNING SERVICES NORTH OFFICE 91Y10Street GREELEY, CO 80631631 PHONE: (970) 353-6100, Ext. 3540 11 ' FAX: (970) 304-6498 Ci COLORADO December 17, 2007 Kerr-McGee Gathering LLC c/o Cheryl Diedrich 1999 Broadway, Ste 3700 Denver CO 80202 Subject: 2n° AmUSR-468- Request for a Site Specific Development Plan and an Amended Special Review Permit for Mineral Resource Development Facility including Oil and Gas Support and Service (Natural Gas Processing Facility and one or more microwave or other communication transmission or relay towers over seventy(70)feet in height in the A (Agricultural) Zone District for on a parcel of land described as Part of the NW4, Section 14, Ti N, R66W of the 6th P.M., Weld County, Colorado. Dear Cheryl: Three items. The Planning Commission hearing date has been scheduled for January 15, 2007, at 1:30 p.m. This meeting will take place in the Hearing Room, Southwest Weld County Planning Department, 4209 CR 24.5, Longmont, Colorado. Two, it is the applicant's responsibility to comply with state statutes regarding notice to mineral estate owners. Colorado Revised Statute, C.R.S.24-65.5-103 (adopted as part of H.B.01-1088) requires notification of all mineral estate owners 30 days prior to any public hearing. The applicant shall provide the Weld County Planning Department with written certification indicating the above requirements have been met. Three, as a condition of approval for this pending amendment to the existing land use permit, The Department of Public Works is requesting paperwork be completed for the use of Section Line roadway thereby creating a legal access to the Dougan compressor Station facility. Questions on this topic may be addressed to David Snyder with Public Works at 970 356 4000 extension 3750. If you have any questions concerning this matter, please call. Respectfully, Kim Ogle Planner pc:2ndAmUSR-468 Hello