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Home My WebLink About20073932.tiff STATE OF COLORADO BilfOwens,Governor 0•cot° Douglas H.Benevento,Executive Director ° Dedicated to protecting and improving the health and environment of the people of Colorado h o 4300 Cherry Creek Dr.S. Laboratory Services Division * Denver,Colorado 80246-1530 8100 Lowry Blvd. \1876 Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department TDD Line(303)691-7700 (303)692-3090 Located-in Glendale,Colorado Weld County Planning Department of Public Health http://www.cdphe.state.co.us GREELEY OFFICE and Environment APR 2 3 2007 April 10,2007 RECEIVED Steve Moreno Weld County Clerk 1402 N. 17th Ave. Greeley,CO 80631 Dear Mr.Moreno: On April 14,2007,the Air Pollution Control Division will publish a public notice for Cheyenne Plains Gas Pipeline Co. in the Greeley Tribune. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty(30)days from the date the public notice is published. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health&Environment APCD-SS-B 1 4300 Cherry Creek Drive South Denver,Colorado 80246-1530 Attention: Jacquie N.Barela Regards, Jo Matson for Jacqueline N.Barela Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure Ara At-303)Zi 12ed kii4003 UG mil a , i?fi (11 )c- Q-1 zoo1y93z ?L1s1 NOTICE OF 'ROPOSED RENEWAL TITLE V --MATING PER---:WARRANTING PUBLIC COMP fT NOTICE is hereby given that an application to renew an Operating Permit has been submitted to the Colorado Air Pollution Control Division, 4300 Cherry Creek Drive South,Denver, Colorado 80246-1530, for the following source of air pollution: Applicant: Cheyenne Plains Gas Pipeline Company P. O.Box 1087 Colorado Springs, CO 80944 Facility: Cheyenne Plains Gas Pipeline Company—Cheyenne Plains Compressor Station Section 5,T11N,R66W, (approx.4 miles south of Rockport),Weld County Co. Cheyenne Plains Gas Pipeline Co has applied for an Operating Permit for their facility in Weld County, CO.. A copy of the applications, including supplemental information, the Division analysis, and a draft of the Operating Permit 05OPWE281 has been filed with the Weld County Clerk's office. Based on the information submitted by the applicant,the Division has prepared the draft renewal operating permit for approval. Any interested person may contact Jacquie Joyce at the Division at 303-692-3267 to obtain additional information. Any interested person may submit written comments to the Division concerning 1)the sufficiency of the preliminary analysis, 2)whether the permit application should be approved or denied, 3) the ability of the proposed activity to comply with applicable requirements, 4)the air quality impacts of, alternatives to, and control technology required on the source or modification, and 5) any other appropriate air quality considerations. Any interested person may submit a written request to the Division for a public comment hearing before the Colorado Air Quality Control Commission (Commission). If requested, the hearing will be held before the Commission at their regularly scheduled meeting within 60 days of its receipt of the request for a hearing unless a longer time period is agreed upon by the Division and the applicant. The hearing request must: 1) identify the individual or group requesting the hearing, 2) state his or her address and phone number, and 3) state the reason(s) for the request,the manner in which the person is affected by the proceedings, and an explanation of why the pemon's interests are not already adequately represented. The Division will receive and consider the written public comments and requests for any hearing for thirty calendar days after the date of this Notice. RELEASED TO: The Greeley Tribune PUBLISHED: April 14, 2007 April 10, 2007 COLORADO DEPARTMENT OF PUBLIC HEALTH AND EN DNMENT AIR POLLUTION CONTROL DIVISION OPERATING PERMIT SUMMARY • PERMIT NUMBER: 05OPWE281 AIRS ID#: 1230051 DATE:April 10, 2007 APPLICANT: Cheyenne Plains Gas Pipeline Co—Cheyenne Plains CS REVIEW ENGINEER: Jacqueline Joyce SOURCE DESCRIPTION Cheyenne Plains Gas Pipeline Co. has applied for an Operating Permit for the Cheyenne Plains Compressor Station located at Section 5,T11 N, R66W, approximately 4 miles north of Rockport, in Weld County. This facility is designed to compress and transmit natural gas from the Wyoming area east into Kansas and is classified under SIC 4922. This is achieved by using three(3)natural gas fired combustion turbines driving natural gas compressors. The facility also includes a CO2 treatment plant,which consists of a glycol dehydrator and an amine treatment unit. Emissions from the glycol dehydrator regenerator(still)vent and flash tank and amine unit flash tank are routed to a flare to reduce VOC emissions. Emissions from the amine unit regenerator vent are routed to a SulfaTreat H2S control system to reduce HZS emissions. There are two (2)45 mmBtu/hr natural gas fired heaters associated with the amine treatment unit and an emergency generator that are considered significant emission units. The Cheyenne Plains Compressor Station was constructed in 2004 at the site of an existing mainline compressor station (Cheyenne Station). As such the two facilities are considered a single source for purposes of Prevention of Significant Deterioration (PSD)review requirements and Title V permitting requirements. Equipment associated with the Cheyenne Compressor Station is addressed in a separate Title V operating permit(95OPWE090). This facility is located in an area designated as attainment for all criteria pollutants. This source is classified as a major stationary source with respect to Prevention of Significant Deterioration (PSD)requirements. Wyoming and Nebraska are within 50 miles of this facility and are affected states. Rocky Mountain National Park, a Federal Class I designated area is within 100 km of this facility. This source is not subject to the Accidental Release provisions of section 112(r)of the Federal Clean Air Act. Since controlled emissions from the flare are less than the major source level,the flare is not subject to the Compliance Assurance Monitoring(CAM)requirements in 40 CFR Part 64 until renewal of this permit. FACILITY EMISSION SUMMARY Pollutant Potential to Emit(tons/yr) 95OPWE090 I 05OPWE281 I Facility NOx 624.3 106.6 730.9 CO 262.8 172.1 434.9 VOC 291.3 58.9 350.2 HAPS 60.7 14.1 74.8 EMISSION SOURCES Turbines (CP CG-7101, CP CG-7201 and CP CG-7301)—The turbines were subject to BACT review for NON, CO and VOC and have BACT limits for those pollutants. BACT for the turbines is low NOx design and good combustion practices (CO and VOC). The turbines are subject to NSPS GG (NOx and SO2 limits), as well as Reg 1 limits for opacity, PM and SO2 and Reg 6, Part B limits for opacity, PM and SO2. Streamlining of less stringent requirements has been done as appropriate. The turbines are also subject to annual fuel consumption limits and annual NOx, CO and VOC emission limits. Quarterly portable monitoring is required to monitor compliance with the NOx and CO BACT limits. The permit requires that fuel consumption be recorded monthly and used to calculate emissions. Monthly fuel consumption and emissions are to be used in rolling twelve-month totals to monitor compliance with the annual limitations. Compliance with the Reg 1 opacity, PM and SO2 limitations shall be presumed, in the absence of credible evidence to the contrary, since natural gas is the only fuel permitted to be used in the turbines. Hot Oil Heaters (H-8701 and H-8702)—The hot oil heaters were subject to BACT review for NOx, CO and VOC and have BACT limits for those pollutants. BACT for the heaters is low NOx burners and good combustion practices (for CO and VOC). The heaters are also subject to record keeping requirements in 40 CFR Part 60 Subpart Dc(monthly recording of fuel consumed), Reg 1 PM and opacity limits, Reg 6 Part B PM and opacity limits and annual emission limitations for NOx, CO and VOC, as well as annual fuel consumption limits. Streamlining of less stringent requirements has been done as appropriate. The heaters are also subject to the provisions in 40 CFR Part 63 Subpart DDDDD (industrial boiler and process heater MACT)and as such are required to meet a CO ppm limit and conduct annual performance tests. Compliance with the NOx and CO BACT limits shall be monitored by conducting annual performance tests in conjunction with the required annual MACT tests. The permit requires that fuel consumption be recorded monthly and used to calculation emissions. Monthly fuel consumption and emissions are to be used in rolling twelve-month totals to monitor compliance with the annual limitations. Compliance with the Reg 1 PM and opacity limits, shall be presumed since natural gas is the only fuel permitted to be used in the heaters. CO,Treatment plant—Flare Vent(FL-8921)and Amine Unit Regenerator Vent(ST-8931)—The CO2 treatment plant consists of an amine treatment unit and a glycol dehydrator,with a capacity for 300 mmSCF/day. The CO2 treatment plant was subject to BACT review for VOC emissions and BACT was determined to be a flare. The glycol dehydrator regenerator(still)vent and flash tank emissions and the amine unit flash tank emissions are routed.to the flare for reduction of VOC emissions. Emissions from the amine unit regenerator are routed to a SulfaTreat H2S Control system for reduction of H2S emissions. The CO2 treatment plant is subject to annual emission limits for VOC, NOx, H2S and benzene emissions,as well as annual limitations on the quantity of natural gas processed. The glycol dehydrator is subject to the requirements in 40 CFR Part 63 Subpart HHH (Natural Gas Transmissions and Storage MACT)and as such is subject to operating and monitoring requirements for the flare and is required to keep benzene emission below 0.9 megagrams (1984 Ibs/yr). The source will be required to monitor and record GLYCalc and AMINE Calc parameters daily and perform GLYCaIc and AMINE Calc runs as necessary based on the results of that monitoring. The source will also be required to continuously monitor the H2S sulfur concentration on the outlet of the SulfaTreat unit to determine the need to replace the SulfaTreat material. Emergency Generator(CP EG-6141)—The emergency generator is subject to the APEN reporting requirements but is exempt from the minor source permitting requirements in Reg 3, Part B provided it runs no more than 250 hours per year. Therefore, the source will be required to record hours of operation and calculate emissions annually. The engine is also subject to the Reg 1 opacity requirement. Compliance with the Reg 1 opacity limit is presumed since natural gas is the only fuel permitted to be used in the engine. INSIGNIFICANT ACTIVITIES A list of insignificant activities is included in the draft Operating Permit. ALTERNATIVE OPERATING SCENARIOS No alternative operating scenarios are included in the draft Operating Permit. TECHNICAL REVIEW DOCUMENT For OPERATING PERMIT 05OPWE281 Cheyenne Plains Gas Pipeline Company— Cheyenne Plains Compressor Station Weld County Source ID 1230051 Prepared by Jacqueline Joyce September and October 2006 Revised November 2006, January and March 2007 I. Purpose This document establishes the basis for decisions made regarding the Applicable Requirements, Emission Factors, Monitoring Plan and Compliance Status of Emission Units covered within the Operating Permit proposed for this site. It is designed for reference during review of the proposed permit by the EPA, the Public and other interested parties. Conclusions made in this report are based on information provided by the applicant in the Title V application submitted December 15, 2005, comments on the draft permit and technical review document received on January 11, 2007, additional information submitted on March 30, 2007, various telephone conversations and e-mail correspondence with the source and review of Division files. This narrative is intended as an adjunct to the reviewer and has no legal standing. Any revisions made to the underlying construction permits associated with this facility made in conjunction with the processing of this operating permit application have been reviewed in accordance with the requirements of Regulation No. 3, Part B, Construction Permits, and have been found to meet all applicable substantive and procedural requirements. This operating permit incorporates and shall be considered to be a combined construction/operating permit for any such revision, and the permittee shall be allowed to operate under the revised conditions upon issuance of this operating permit without applying for a revision to this permit or for an additional or revised construction permit. II. Description of Source The facility is a natural gas compression facility as defined under Standard Industrial Classification 4922. This facility is a mainline compressor station. Its main function is to compress and transmit natural gas from the Wyoming area east into Kansas. This is achieved by using three (3) natural gas fired combustion turbines driving natural gas compressors. The facility also includes a CO2 Treatment Plant, which consists of a glycol dehydrator and amine treatment unit. Emissions from the glycol dehydrator still (regenerator) vent and flash tank and emissions from the amine unit flash tank are routed to a flare to reduce VOC emissions. The amine unit regenerator vent is equipped with a SulfaTreat H2S control system to reduce H2S emissions. There are Page 1 also two (2) 45 mmBtu/hr natural gas fired heaters associated with the amine unit and • an emergency generator that are included in Section II of the permit as significant emission units. - The Cheyenne Plains Compressor Station was constructed in 2004 at the site of an existing mainline compressor station (Cheyenne Station), whose main function is to compress and transmit natural gas from the Wyoming area to the Colorado Front Range area. As such the two facilities are considered a single source for purposes of Prevention of Significant Deterioration (PSD) review requirements and Title V permitting requirements. Equipment associated with the Cheyenne Compressor Station is addressed in a separate Title V operating permit (95OPWE090). The facility is located approximately 4 miles north of Rockport in Weld County on Highway 85. The area in which the plant operates is designated as attainment for all criteria pollutants. There are two affected states within 50 miles of the plant: Wyoming and Nebraska. Rocky Mountain National Park, a Federal Class I designated area is within 100 kilometers of the plant. The facility is considered to be a major stationary source (Potential to Emit (PTE) ≥250 tons/yr). Facility wide potential emissions are shown on the following tables: Facility Wide Emissions (95OPWE090 and 05OPWE281) Pollutant Potential to Emit(tons/yr) 95OPWE090 I 05OPWE281 I Facility PM1 35.23 11.71 46.94 PM1o' 35.23 11.71 46.94 SO21 1.33 3.44 4.77 NOx 624.3 108.53 732.83 CO 262.8 153.22 416.02 VOC 291.3 58.17 349.47 HAPS 60.7 14.1 74.8 'Emissions for each emission unit are typically below the APEN de minimis level, so emission limits have generally not been included in the construction permits and/or Title V permit. 05OPWE281 Emissions Emission Unit Potential to Emit(tons/yr) PM I PKo I SO2 I NOx I CO I VOC I HAPS Turbine CP CG-7101 2.1 2.1 1.06 31.6 38.5 11.3 See Turbine CP CG-7201 2.1 2.1 1.06 31.6 38.5 11.3 Table on Turbine CP CG-7301 2.1 2.1 1.06 20.1 20.9 11.3 Page 29 Page 2 Emission Unit Potential to Emit(tons/yr) PM I PM10 I SO2 I NOx I CO I VOC I HAPS Hot Oil Heater H- 1.58 1.58 0.13 8.9 7.3 3.15 See 8701 Table on Hot Oil Heater H- 1.58 1.58 0.13 8.9 7.3 3.15 Page 29 8702 Flare Vent FL-8921 2.25 2.25 7.0 39.42 5.8 Amine Unit 11.8 Regenerator(COO Vent ST-8931 Emergency Generator 0.43 1.30 0.37 CP EG-6141 Total 11.71 11.71 3.44 108.53 153.22 58.17 14.1 The PTE for NOx, CO and VOC for the turbines, hot oil heaters, flare and CO2 vent are based on permitted emissions. PTE for PM, PM10 and SO2 from the turbines and heaters are based on AP-42 emission factors and the fuel consumption limits provided in the permit. PM and PM10 emissions from the flare are based on AP-42 emission factors for natural gas fired boilers, the design rate of the flare (13.54 mmBtu/hr) and a gas heat content of 300 Btu/scf. Note that emission limits for many of these pollutants were not included in the permit since emissions do not exceed the APEN de minimis levels. The criteria pollutant PTE for the emergency generator is based on emission factors (manufacturer's for NOx, CO and VOC and AP-42 for PM, PM10 and SO2), design rate and 250 hrs/yr of operation (construction permit exemption under Colorado Regulation No. 3, Part B, Section Il.d.1.c.(ii)). Even though actual emissions are typically much less than permitted emissions, the source usually reports permitted emissions as actual emissions, which is an acceptable practice; therefore actual emissions are not shown in the above tables. The breakdown of HAP emissions by emission unit and individual HAP is provided on page 29 of this document. As indicated in the footnotes for the table on page 29, the HAP PTE was determined as follows: for the turbines and hot oil heaters, HAP emissions are based on AP-42 emission factors, design rate and 8760 hrs/yr of operation, for the emergency generator, it is based on design rate, AP-42 emission factors and 250 hrs/yr of operation and for the flare vent and amine unit regenerator (still) vent it is based on the GLYCaIc run used to set the permit limits. MACT Requirements Natural Gas Transmission and Storage MACT (40 CFR Part 63 Subpart HHH) The glycol dehydrator is subject to the MACT requirements for Natural Gas Transmission and Storage Facilities in 40 CFR Part 63 Subpart HHH and had to comply with the provisions in the MACT upon initial startup. The appropriate requirements for Page 3 the dehydrator are discussed in further detail under the discussion on the dehydrator later in this document. Reciprocating Internal Combustion Engine (RICE) MACT (40 CFR Part 63 Subpart Z777) The final rule for RICE was published in the Federal Register on June 15, 2004. There is only one engine, the emergency generator, associated with the Cheyenne Plains equipment. In accordance with the provisions in 40 CFR Part 63 Subpart 7777 § 63.6590(b)(1)(i), new or reconstructed existing emergency RICE (commenced construction or reconstruction after December 19, 2002) do not have to meet the requirements in 40 CFR Part 63 Subparts A and Z777, except for the initial notification requirements. Note that the definition of emergency stationary RICE does not include a limitation on hours of operation for emergency situation and for routine testing and maintenance. In addition, an emergency stationary RICE may also operate an additional 50 hrs per year in non-emergency situations. The initial notification was submitted for this engine on December 13, 2004. Combustion Turbine MACT (40 CFR Part 63 Subpart YYYY) The final rule for combustion turbines was signed on August 29, 2003 and was published in the Federal Register on March 5, 2004. The turbines are considered "new" turbines (commenced construction after January 14, 2003) and are subject to the MACT. However, in the August 18, 2004 version of the Federal Register, the EPA issued a stay for gas-fired lean premix and diffusion flame turbines. Therefore, the "new" turbines at this facility are only subject to the initial notification requirements and need not comply with any other requirement of 40 CFR Part 63 Subpart YYYY until EPA takes final action to require compliance and publishes a document in the Federal Register. An initial notification was submitted for turbines CG-7101 and CG-7201 on June 15, 2005 and an initial notification was submitted for turbine CG-7301 on April 14, 2006. Industrial, Commercial and Institutional Boilers and Process Heaters MACT (40 CFR Part 63 Subpart DDDDD) The final rule for industrial, commercial and institutional boilers and process heaters was published in the Federal Register on September 13, 2004. All the heaters associated with Cheyenne Plains are natural gas fired. There are two (2) hot oil heaters (45 mmBtu/hr), one utility heater (4.5 mmBtu/hr) and the glycol dehydrator reboiler (2 units, total 4.97 mmBtu/hr). The provisions in 40 CFR Part 63 Subpart DDDDD (§ 63.7506(c)(4)) exempt new (constructed after January 13, 2003) small gaseous fired units (≤ 10 mmBtu/hr) from the requirements in 40 CFR Part 63 Subparts A and DDDDD, including the initial notification requirements. The two hot oil heaters are subject to requirements in Subpart DDDDD and an initial notification was submitted on March 14, 2005. The appropriate requirements for the dehydrator are discussed in further detail under the discussion on the dehydrator later in this document. Page 4 Compliance Assurance Monitoring (CAM) Requirements CAM applies to any emission unit that is subject to an emission limitation, uses a control device to achieve compliance with that emission limitation and has potential pre-control emissions greater than major source levels. None of the engines addressed in the current Title V permit are equipped with control devices; therefore, CAM does not apply to any of the equipment included in the current Title V permit. The turbines are equipped with dry low NOx (DLN) combustion systems to reduce NOx emissions. The hot oil heaters are equipped with low NOx burners (LNB). However, DLN and LNB are not considered control devices as defined in 40 CFR Part 64 § 64.1, as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV, since DLN and LNB are considered inherent process equipment. The glycol dehydrator regenerator (still) vent and flash tank vent and the amine unit flash tank vent are routed to a flare to reduce VOC and HAP emissions. Uncontrolled VOC and HAP emissions from the flare vent are 287 tons/yr and 131.9 tpy, respectively. Therefore, uncontrolled emissions exceed the major source level and CAM applies. With respect to HAP emissions, the HAP limit associated with the dehydrator (1 tpy of benzene) is the MACT limit and MACT limits are exempt from CAM as provided for in 40 CFR Part 64 § 64.2(b)(1)(i). Controlled VOC emissions from the flare vent are less than the major source level (permitted VOC emissions are 5.74 tons/yr), therefore,the unit is not considered a large pollutant specific emission unit and a CAM plan is not required until renewal in accordance with the provisions of 40 CFR Part 64 § 64.5(b). The amine unit regenerator (still) vent is routed to a SulfaTreat system to reduce H2S emissions. Uncontrolled emissions for H2S from the amine unit regenerator vent are 19.7 tpy and are therefore below the major source level. As a result, the CAM requirements do not apply to the amine unit regenerator (still) vent. Ill. Emission Sources CP CG-7101 - Solar Taurus, Model No. 70-10302S, Serial No. 0251 B, Natural Gas Fired Combustion Turbine. The turbine is rated at 9,816 hp and 71.42 mmBtu/hr. This turbine is equipped with a dry low NOx combustion system to reduce NOx emissions. This turbine powers a natural gas compressor. CP CG-7201 - Solar Taurus, Model No. 70-10302S, Serial No. 0250B, Natural Gas Fired Combustion Turbine. The turbine is rated at 9,816 hp and 71.42 mmBtu/hr. This turbine is equipped with a dry low NOx combustion system to reduce NOx emissions. This turbine powers a natural gas compressor. CP CG-7301 - Solar Taurus, Model No. 70-10302S, Serial No. 0286B, Natural Gas Fired Combustion Turbine. The turbine is rated at 9,816 hp and 71.42 mmBtu/hr. Page 5 This turbine is equipped with a dry low NOx combustion system to reduce NOx emissions. This turbine powers a natural gas compressor. 1. Applicable Requirements—An initial approval construction permit (03WE0910) was issued for turbines CG-7101 and CG-7201 on June 10, 2004. In November 2004, the source applied for a modification to the permit in order to include alternative BACT limits for periods when the temperature is below 0 ° F. A revised construction permit was issued on March 29, 2005. Also in November 2004, the source applied for a construction permit for a third turbine, the construction permit (04WE1390) was issued on March 29, 2005. Turbines CG-7101 and CG-7201 started up on December 15, 2004. Turbine CG-7301 started up on October 29, 2005. The source self-certified compliance with construction permit 03WE0910 on June 15, 2005, presumably with regards to the March 29, 2005 revised construction permit, but has not received a final approval permit. The source self-certification compliance with construction permit 04WE1390 on July 19, 2006, but has not received a final approval permit. Therefore, under the provisions of Colorado Regulation No. 3, Part C, Section V.A.3, the Division will not issue a final approval construction permit and is allowing the initial approval construction permit to continue in full force and effect. The appropriate applicable requirements from the modified initial approval construction permit have been incorporated into the renewal permit as follows: • Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes (03WE0910, condition 1, 04WE1390, condition 1 and Regulation No. 1, Section II.A.1. &4). Note that Colorado Regulation No. 1 does not identify the 20% opacity requirement as a condition that only applies during normal operation. In addition, there are more specific activities under which the 30% opacity requirement applies than identified in the construction permit. The specific activities under which the 30% opacity standard applies are: building a new fire, cleaning of fire boxes, soot blowing, startup, any process modification, or adjustment or occasional cleaning of control equipment. Based on engineering judgment the Division considers that building a new fire, cleaning of fire boxes and soot- blowing does not apply to the operation of combustion turbines. In addition, these turbines do not have add-on control devices, so adjustment or occasional cleaning of control devices do not apply to these turbines. Process modifications may apply to the turbines, however, based on engineering judgment, the Division believes that such activities would be unlikely to occur for longer than six minutes. Therefore, the 30% opacity requirement has been included in the operating permit for startup of these units. • Construction of this source must commence within 18 months of permit issuance (04WE1390, condition 2). Page 6 • Startup notice shall be submitted within 30 days (04WE1390, condition 3). As previously mentioned, CG-7301 has commenced operation, therefore, the above two requirements will not be included in the operating permit. • Manufacturer, model and serial number shall be provided prior to final approval (03WE0910, condition 2 and 04WE1390, condition 4). The source has supplied the manufacturer, model and serial number for each of the turbines, therefore, this requirement will not be included in the operating permit. • Each turbine is subject to the requirements of Prevention of Significant Deterioration (PSD). Best Available Control Technology (BACT) shall be applied for control of Oxides of Nitrogen (NOx), Carbon Monoxide (CO) and Volatile Organic Compounds (VOC) (03WE0910, condition 4 and 04WE1390, condition 6), as follows: NOx: o SoLoNOx II (DLN) combustion systems has been determined to be BACT for turbine CG-7301. o SoLoNOx (DLN) combustion systems has been determined to be BACT for turbines CG-7101 and CG-7201. o Except as provided for below, NOx emissions from turbine CG-7301 shall not exceed 15 ppmvd at 15% O2 on a 1-hr average. o Except as provided for below, NOx emissions from turbines CG-7101 and CG-7201 shall not exceed 24.5 ppmvd at 15% O2 on a 1-hr average. o When the ambient temperature is less than 0 ° F but greater than or equal to—20 ° F, NOx emissions shall not exceed 42 ppmvd. o When the ambient temperature is less than —20 ° F, NOx emissions shall not exceed 120 ppmvd. CO: o Good combustion practices has been determined to be BACT for the turbines. o Except as provided for below, CO emissions from turbines CG-7101 and CG-7201 shall not exceed 48.8 ppmvd at 15% O2 on a 1-hr average. o Except as provided for below, CO emissions from turbine CG-7301 shall not exceed 25 ppmvd at 15% O2 on a 1-hr average. o When the ambient temperature is less than 0 ° F but greater than or equal. to —20 ° F, CO emissions shall not exceed 100 ppmvd. o When the ambient temperature is less than —20 ° F, CO emissions shall not exceed 150 ppmvd. Page 7 VOC: o Good combustion practices and use of pipeline quality natural gas as fuel have been determined to be BACT for this turbine. o Except as provided for below, VOC emissions shall not exceed 3 ppmvd at 15% O2 on a 1-hr average o When the ambient temperature is less than 0 ° F but greater than or equal to—20 ° F, VOC emissions shall not exceed 5 ppmvd. o When the ambient temperature is less than —20 ° F, VOC emissions shall not exceed 8 ppmvd. o For the alternative BACT limits during colder temperatures the source is required to keep records of the number of hours the temperature meets the specified criteria. o Compliance with the BACT limits shall be demonstrated by conducting the performance tests required by the permits. Thereafter compliance with the NOx and CO BACT limits will be monitored by conducting quarterly portable monitoring tests. At least annually, such portable monitoring shall be conducted at the low temperatures for which alternative BACT limits have been required, unless ambient conditions or extended periods at those temperatures are not sufficient to conduct monitoring. • Each turbine is subject to the requirements in 40 CFR Part 60 Subpart GG Standards of performance for Stationary Gas Turbines, including, but not limited to the following (03WE0910, condition 5 and 04WE1390, condition 7): o NOx limits shall not exceed 189.5 ppmvd at 15% O2 and ISO conditions (§ 60.332(a)(2)) o SO2 emissions not to exceed 150 ppmvd at 15% O2 or sulfur content of fuel not to exceed 0.8 % by weight (§ 60.333(a) and (b)) The construction permit specifies that compliance with the SO2 emissions limits shall be presumed when burning pipeline quality natural gas and that the methods in 40 CFR Part 60 § 60.334(h)(3). • In addition, the turbines are also subject to the NSPS General Provisions in 40 CFR Part 60 Subpart A, including, but not limited to the following (03WE0910, condition 5 and 04WE1390, condition 7): o Good practices (§ 60.11(d)) o Circumvention (§ 60.12) o Record startup, shutdowns and malfunctions (§ 60.7(b)) Note that other requirements were noted in the construction permit but some of these requirements no longer apply (i.e. startup notification, performance test). Page 8 EPA promulgated new source performance standards for combustion turbines under 40 CFR Part 60 Subpart KKKK on July 6, 2006. These requirements apply to turbines that commenced construction, modification or reconstruction after February 18, 2005. Turbines CG-7101 and CG-7201 commenced operation on December 15, 2004, therefore, they are not subject to the requirements for newer turbines in 40 CFR Part 60 Subpart KKKK. The source submitted the application to add the turbine CG-7301 to the facility on November 10, 2004, although the permit was not issued until March 29, 2005. Commenced construction means that "the owner or operator has undertaken a continuous program of construction or modification or that an owner or operator has entered into a contractual obligation to undertake and complete, within a reasonable time, a continuous program of construction or modification." The source had entered into a contractual agreement to. purchase the turbine prior to February 18, 2005. Therefore, turbine CG-7301 is not subject to the requirements in Subpart KKKK. • Each turbine is subject to Regulation No. 6 —Standards of Performance for New Stationary Sources, Part B— Specific Facilities and Sources, Non-Federal NSPS, . II -Standards of Performance for New Fuel-Burning Equipment, D— Standard for Sulfur Dioxide, 3—Combustion Turbines (03WE0910, condition 7 and 04WE1390, condition 9). These are state-only requirements. o SO2 emissions shall not exceed 0.8 lbs/mmBtu. o Opacity of emissions shall not exceed 20% Although not specifically identified in the construction permit, the turbines are also subject to the particulate matter requirements in Reg 6, Part B, as follows: o Particulate matter emissions shall not exceed 0.5(Fl)-°.26 lbs/mmBtu, • where Fl = fuel input in mmBtu/hr • Sulfur dioxide emissions from each turbine shall not exceed 0.8 lb/mmBtu (03WE0910, condition 8 and 04WE1390, condition 10 and Reg 1, Section Vl.B.4.c.(i)) • Particulate matter emissions from each turbine shall not exceed 0.5(Fl)-o.26 lbs/mmBtu, where Fl = fuel input in mmBtu/hr (03WE0910, condition 9 and 04WE1390, condition 11 and Reg 1, Section III.A.1.b). • Each turbine shall be subject to the following fuel use limits (03WE0910, condition 10 and 04WE1390, condition 12): Consumption of natural gas shall not exceed 56.2 mmSCF/mo and 661.5 mmSCF/yr Note that the monthly fuel consumption limits apply during the first year of operation following issuance of the initial approval construction permit (04WE1390) modified initial approval construction permit (03WE0910) both Page 9 issued on March 29, 2005 and since all three turbines will have been operating for more than one year upon issuance of this permit, the monthly limitations will not be included in the operating permit. • Each turbine shall be subject to the following emission limits (03WE0910, condition 11 and 04WE1390, condition 13): PM: 0.18 tons/mo and 2.10 tons/yr PMK° 0.18 tons/mo and 2.10 tons/yr NOx, CG-7101 & CG-72012.68 tons/mo and 31.6 tons/yr NOx, CG-7301 1.71 tons/mo and 20.1 tons/yr CO 3.27 tons/mo and 38.5 tons/yr VOC 0.96 tons/mo and 11.3 tons/yr Note that the monthly emission limits apply during the first year of operation following issuance of the initial approval construction permit (04WE1390) modified initial approval construction permit (03WE0910) both issued on March 29, 2005 and since all three turbines will have been operating for more than one year upon issuance of this permit, the monthly limitations will not be included in the operating permit. In the construction permit for CG-7301 (04WE1390), the Division included a lower CO BACT limit than the source had originally requested in their application (25 ppm vs. 48.8 ppm). However, the annual CO emission limit included in the construction permit was based on the 48.8 ppm CO emission rate, rather than the permitted 25 ppm emission rate. Therefore', in the Title V permit, the Division lowered the CO emission limit to 20.9 tons/yr as indicated on the APEN submitted on March 30, 2007. • The source is subject to the odor requirements in Regulation No. 2 (03WE0910, condition 6 and 04WE1390, condition 8). Turbines are not generally a source of odor therefore this condition,will not be specifically included in the permit but is included in the General Conditions (Section IV) of the permit. • Source compliance tests shall be conducted on the turbines to demonstrate compliance with the emission limitations (03WE0910, condition 12 and 04WE1390, Condition 14). Compliance tests have been completed on all three turbines, therefore, the performance test requirements will not be included in the permit. • MACT initial notification requirements (03WE0910, condition 13 and 04WE1390, condition 15). Page 10 As discussed previously, the initial notifications have been submitted for the combustion turbines. The initial notification was submitted for CG-7101 and CG- 7201 on June 15, 2005 and for CG-7301 on April 14, 2006. Therefore, this requirements will not be included in the permit. • An application shall be submitted within one year of commencing operation to revise the Title V permit application (03WE0910, condition 14 and 04WE1390, condition 16). An application for a separate Title V permit for the Cheyenne Plains equipment was submitted on December 15, 2005. Therefore, this requirement will not be included in the permit. • Within 180 days after commencement of operation, compliance with the conditions contained on this permit shall be demonstrated to the Division (03WE0910, condition 15 and 04WE1390, condition 17). As discussed above, the source submitted self-certifications for turbines CG- 7101 and CG-7201 on June 10, 2005 and for CG-7301 on July 19, 2006. Therefore, this requiremert will not be included in the permit. • APEN reporting requirements (03WE0910, condition 16 and 04WE1390, condition 18) The APEN reporting requirements will not be identified in the permit as a specific condition but are included in Section IV (General Conditions) of the permit, condition 22.e. Streamlining of Applicable Requirements Opacity The turbines are subject to the Regulation No. 1 opacity standards and the Regulation No. 6, Part B opacity requirement The Reg 1 20% opacity requirement applies at all times, except for certain specific operating conditions under which the Reg 1 30% opacity requirement applies. Reg 6, Part B, Section I.A, adopts, by reference, the 40 CFR Part 60 Subpart A general provisions. 40 CFR Part 60 Subpart A § 60.11(c) specifies that the opacity requirement are not applicable during periods of startup, shutdown and malfunction. The Reg 1 20%/30%opacity requirements are more stringent than the Reg 6 Part B opacity requirements during periods of startup, shutdown and malfunction (see attached opacity grid). While the Reg 6, Part B 20% opacity requirement is more stringent during fire building, cleaning of fire boxes, soot blowing, process modifications and adjustment or occasional cleaning of control equipment. However, as discussed previously, the Division considers that for the turbine the only specific activity under which the 30% opacity standard would apply is startup. Therefore, since the Reg 1 20%/30% opacity requirements are more stringent Page 11 than the Reg 6, Part B requirements the Reg 6 Part B opacity requirement has been streamlined out of the permit. PM and SO, The turbines are subject to the Regulation No. 1 and No. 6, Part B PM and SO2 standards. The PM and SO2 requirements in both Reg 1 and Reg 6, Part B are the same standard. The Regulation No. 6, Part B requirement is a state-only requirement. Reg 6, Part B, Section I.A, adopts, by reference, the 40 CFR Part 60 Subpart A general provisions. Although not specifically stated in the general provisions, the Division has concluded after reviewing EPA determinations that the NSPS standards are not • applicable during startup, shutdown and malfunction, unless indicated otherwise in the specific subpart, although any excess emissions during these periods must be reported in the excess emission reports. Specifically, EPA has indicated (4/18/75, determination control no. A007) that when 40 CFR Part 60 Subpart A § 60.11(d) was developed "...it was recognized that sources which ordinarily comply with the standards may during periods of startup, shutdown and malfunction unavoidably release pollutants in excess of the standards." In addition,EPA has also indicated (5/15/74, determination control number D034) that "[s]ection 60.11(a) makes it clear that the data obtained from these reports are not used in determining violations of the emission standards. Our purpose in requiring the submittal of excess emissions is to determine whether affected facilities are being operated and maintained 'in a manner consistent with good air pollution control practices for minimizing emissions' as required by 60.11(d)." Therefore, the Division considers that the Reg 6, Part B PM and SO2 requirements do not apply during periods of startup, shutdown and malfunction. Therefore, the Regulation No. 1 PM and SO2 requirements are more stringent than the Regulation No. 6, Part B requirements and the Regulation No. 6, Part B requirements will be streamlined out of the permit. NOx The turbines are subject to the NSPS Subpart GG NOx limits and BACT NOx limits. The NSPS Subpart GG and BACT concentration limits are in the same units and therefore they can be compared for purposes of streamlining. The BACT averaging time is hourly. For purposes of reporting excess emissions under NSPS GG, turbines equipped with water and steam injection and continuous monitoring systems to record the fuel consumption and the ratio of water/steam to fuel need to report every hour that the steam/water to fuel ratio falls below the acceptable level as determined by the performance test. This implies that the standard is on a 1-hour average. However, under the NSPS GG revisions, for units equipped with a continuous emission monitoring device or continuous parametric monitoring device, excess emissions are reported on a 4-hour rolling average. Therefore, the NSPS GG limit may be on either a 1-hour or a 4- hour rolling average, which is either an equal or less stringent averaging time than the BACT limit. The BACT concentration limits are applicable at all times. The Division considers that the NSPS Subpart GG requirements are not applicable during periods of startup, shutdown and malfunction (as discussed in the PM and SO2 streamlining section above). Therefore, since the NSPS Subpart GG limits are less stringent than Page 12 the BACT concentration limits, the NSPS Subpart GG limits will be streamlined out of the operating permit. Miscellaneous The turbines are subject to the NSPS general provisions (40 CFR Part 60) on a federal and state basis (the units are subject to 40 CFR Part 60 Subpart GG) and on a state- only basis (the units are subject to Reg 6, Part B, Section II and the NSPS general provisions are adopted by reference in Reg 6, Part B, Section I.A). Therefore, the Division will streamline the state-only NSPS general provisions out of the permit in favor of the state and federal NSPS general provisions. In addition, since BACT for VOC is use of pipeline quality natural gas as fuel limits the sulfur content below the level of natural gas as defined in § 60.331(u), the Division will streamline out the sulfur monitoring requirements in NSPS GG (§ 60.334(h)(3)). 2. Emission Factors —The following emission factors shall be used to monitor compliance with the annual limitations: Emission Factors Emission Factor Source NOx CO I VOC T>0° F: T>0° F: T>0°F: Manufacturer's Info: CG-7101 &CG- CG-7101 &CG- 0.035 lb/mmBtu T>0°F: CG-7101 and CG-7201: 7201: 7201: -20° F <T<0 ° F: based on 100% load, at 0°F. NOx 0.098 b/mmBtu 0.119 lb/mmBtu 0.070 Ib/mmBtu based on adjusting 0.10 lb/mmBtu CG-7301: CG-7301: T<-20°F: factor to 24.5 rather than 25 ppm. CO 0.060 lb/mmBtu 0.061 lb/mmBtu 0.105 lb/mmBtu is based on adjusting the 0.122 -20°F <T< 0 ° F: -20° F <T< 0° F: lb/mmBtu factor to 48.8 pm, rather 0.177 Ib/mmBtu 0.257 lb/mmBtu than 50 ppm. T< -20° F: T< -20° F: CG-7301: NOx and CO based on manufacturers data sheet(at 59 F). 0.504 lb/mmBtu 0.384 lb/mmBtu All Turbines: VOC based on total UHC. For the lower temperatures the emission factors are based on the above emission factors adjusted to the higher ppm limit. Emissions of PM, PM10 and SO2 were estimated using the following emission factors (from AP-42, Section 3.1 (dated April 200), Table 3.1-2a): Pollutant Emission Factor PM 6.6 x 10'3 lb/mmBtu PM10 6.6 x 10"3 lb/mmBtu SO2 3.4 x 10"3 lb/mmBtu Page 13 Note that since SO2 emissions from each turbine are below the APEN de minimis level, so a limit for SO2 is not included in the permit; however, emissions from all criteria pollutants are to be included on any revised APENS. 3. Monitoring Requirements -The source will be required to monitor fuel consumption and calculate monthly emissions to monitor compliance with the fuel consumption and emission limitations. Quarterly portable monitoring shall be required to monitor compliance with the NOx and CO BACT emission limitations, emission factors and annual emission limitations. Compliance with the VOC BACT emission limits is presumed provided pipeline quality natural gas is used as fuel and good combustion practices are applied. 4. Compliance Status —The source indicated in the Title V permit application that these emission units were in compliance with the applicable requirements. The Division would agree with this assessment. H-8701: Heatec, Model No. VHC1-160101-40-G, Serial No. 04-074-151, Natural Gas-Fired Hot Oil Heater, Rated at 45 mmBtu/hr. H-8702: Heatec, Model No. VHC1-160101-40-G, Serial No. 04-074-152, Natural Gas-Fired Hot Oil Heater, Rated at 45 mmBtu/hr. 1. Applicable Requirements -An initial approval construction permit (03WE0913) was issued for heaters H-8701 and H-8702 on June 10, 2004. The hot oil heaters commenced operation on January 30, 2005. After conducting the performance tests on these units, the source submitted an application on October 31, 2005 to modify the permit for these units to revise the NOx BACT limit and to remove the utility heater from the permit. The source requested the modification because the heaters were unable to comply with the NOx BACT limits when operating at lower loads and the utility heater burners would be replaced with new burners, which would make reduce the capacity of the heater to 4.5 mmBtu/hr, thus making the unit exempt from the APEN reporting and construction permit requirements. The source had not submitted a self-certification for these units because they could not meet the BACT limits for NOx at low loads. The due date of the first semi-annual monitoring report required by this operating permit will be more than 180 days after the heaters commenced operation. Therefore, under the provisions of Regulation No. 3, Part C, Section V.A.2., the Division is allowing the initial approval construction permit to continue in full force and effect and will consider the Responsible Official certification submitted with that report to serve as the demonstration required pursuant to Regulation No. 3, Part B, Section Ili.G.2 and no final approval construction permit will be issued. The appropriate provisions of the initial approval construction permit have been directly incorporated into this operating permit as indicated in the following discussion: • Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or Page 14 adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes (condition 1 and Regulation No. 1, Section II.A.1. &4). As discussed above under the turbines, Reg 1 does not identify the 20% opacity requirement as a condition that only applies during normal operation. In addition, there are more specific activities under which the 30% opacity requirement applies than identified in the construction permit. The specific activities under which the 30% opacity standard applies are: building a new fire, cleaning of fire boxes, soot blowing, startup, any process modification, or adjustment or occasional cleaning of control equipment. Based on engineering judgment the Division considers that building a new fire, cleaning of fire boxes and soot- blowing does not apply to the operation of the hot oil heaters. In addition, the heaters do not have an add-on control device, so adjustment or occasional cleaning of control devices do not apply to these heaters. Process modifications may apply to the heaters, however, based on engineering judgment, the Division believes that such activities would be unlikely to occur for longer than six minutes. Therefore, the 30% opacity requirement has been included in the operating permit for startup of the heaters. • Manufacturer, model and serial number shall be provided prior to final approval (condition 2). The source has supplied the manufacturer and model. The Division will request the serial number for each of the heaters during the pre-public comment review period. • Each heater is subject to the requirements of Prevention of Significant Deterioration (PSD). Best Available Control Technology (BACT) shall be applied for control of Oxides of Nitrogen (NOx), Carbon Monoxide (CO) and Volatile Organic Compounds (VOC) (condition 4), as follows: NOx o Low NOx burners shall be used to limit the NOx emissions from each heater to 0.045 lb/mmBtu, on a 1-hr average. CO : o Good combustion practices shall be used to limit the CO emissions from each heater to 0.037 lb/mmBtu, on a 1-hr average. VOC : o Good combustion practices shall be used to limit the VOC emissions from each heater to 0.016 lb/mmBtu, on a 1-hr average. • Each heater shall be subject to the following fuel use limits (condition 5): Page 15 Consumption of natural gas shall not exceed 416.8 mmSCF/yr • Each heater shall be subject to the following emission limits (condition 6): o NOx 8.9 tons/yr o CO 7.3 tons/yr o VOC 3.15 tons/yr • Particulate matter emissions from each heater shall not exceed 0.5(FI)'o.26 Ibs/mmBtu, where Fl =fuel input in mmBtu/hr (condition 7 and Reg 1, Section III.A.1.b). • Each heater is subject to the requirements in 40 CFR Part 60 Subpart Dc Standards of performance for Small Industrial-Commercial-Institutional Steam Generating Units, including, but not limited to the following (condition 8): o Notification requirements in accordance with 40 CFR Part 60 Subpart Dc § 60.48c(a). o Record quantity so fuel burned per calendar month in accordance with 40 CFR Part 60 Subpart Dc § 60.48c(g). o Retain records for two years in accordance with 40 CFR Part 60 Subpart Dc § 60.48c(i). Note that the notification requirements have been fulfilled; therefore, that requirement will not be included in the permit. • In addition, the heaters are also subject to the NSPS General Provisions in 40 CFR Part 60 Subpart A, including, but not limited to the following (condition 8): o Good practices (§ 60.11(d)) o Circumvention (§ 60.12) o Record startup, shutdowns and malfunctions (§ 60.7(b)) • Each heater is subject to Regulation No. 6—Standards of Performance for New Stationary Sources, Part B — Specific Facilities and Sources, Non-Federal NSPS, II - Standards of Performance for New Fuel-Burning Equipment, D — Standard for Sulfur Dioxide, 3—Combustion Turbines (condition 9). These are state-only requirements. o Opacity of emissions shall not exceed 20% o Particulate matter emissions shall not exceed 0.5(Fi)-°.26 lbs/mmBtu, where Fl = fuel input in mmBtu/hr Page 16 • An application shall be submitted within one year of commencing operation to revise the Title V permit application (condition 10). An application for a separate Title V permit for the Cheyenne Plains equipment was submitted on December 15, 2005. Therefore, this requirement will not be included in the permit. • APEN reporting requirements (condition 11). The APEN reporting requirements will not be identified in the permit as a specific condition but are included in Section IV (General Conditions) of the permit, condition 22.e. • The source is subject to the odor requirements in Regulation No. 2 (condition 12). Heaters are not generally a source of odor therefore this condition will not be specifically included in the permit but is included in the General Conditions (Section IV) of the permit. • Each heater is subject to Regulation No. 8, part E, Section fill — Federal Maximum Achievable Control Technology (MACT) requirements in 40 CFR Part 63 Subpart DDDDD— National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial and Institutional Boilers and Process Heaters, including but no limited to the following requirements; o Each heater shall comply by November 12, 2004 or upon startup, whichever is later (40 CFR Part 63 Subpart DDDDD § 63.7595(a)) o Emission limitations and work practice standards (40 CFR Part 63 Subpart DDDDD § 63.7500(a)(1)). 400 ppm by volume on a dry basis corrected to 3 % O2 (3-run average). o General compliance requirements in 40 CFR Part 63 Subpart DDDDD § 63.7505. o Initial compliance requirements in 40 CFR Part 63 Subpart DDDDD §§ 63.7510 and 63.7530. o Subsequent performance tests — annually in 40 CFR Part 63 Subpart DDDDD §§ 63.7515, 63.7520 and 63.7540. o Notification, Reports and Records in 40 CFR Part 63 Subpart DDDDD §§ 63.7545, 63.7550 and 63.7555. Note that the initial notification and notification of intended construction was submitted on March 14, 2005, therefore, these notification requirements will not be included in the permit. The Division's records do Page 17 not indicate that a notification of compliance status has been submitted, therefore, this requirements will be included in the permit. In addition, the general provisions from 40 CFR Part 63 Subpart A also apply and will be included as appropriate. • Within 180 days after commencement of operation, compliance with the conditions contained on this permit shall be demonstrated to the Division (condition 14). As discussed above, the Division will consider that the Responsible Official's certification submitted with the first semi-annual monitoring report will serve as the self-certification that these emission units can comply with the applicable requirements. • No rain caps or other obstructions are allowed on the exhaust stacks for these heaters (condition 15). Streamlining of Applicable Requirements Opacity The heaters are subject to the Regulation No. 1 opacity standards and the Regulation No. 6, Part B opacity requirement. The Reg 1 20% opacity requirement applies at all times, except for certain specific operating conditions under which the Reg 1 30% opacity requirement applies. Reg 6, Part B, Section I.A, adopts, by reference, the 40 CFR Part 60 Subpart A general provisions. 40 CFR Part 60 Subpart A § 60.11(c) specifies that the opacity requirements are not applicable during periods of startup, shutdown and malfunction. The Reg 1 20%/30%opacity requirements are more stringent than the Reg 6 Part B opacity requirements during periods of startup, shutdown and malfunction (see attached opacity grid). While the Reg 6, Part B 20% opacity requirement is more stringent during fire building, cleaning of fire boxes, soot blowing, process modifications and adjustment or occasional cleaning of control equipment. However, as discussed previously, the Division considers that for the heaters the only specific activity under which the 30% opacity standard would apply is startup. Therefore, since the Reg 1 20%/30% opacity requirements are more stringent than the Reg 6, Part B requirements the Reg 6 Part B opacity requirement has been streamlined out of the permit. PM The heaters are subject to the Reg 1 particulate matter requirements and the state-only, Reg 6, Part B particulate matter requirements. The particulate matter requirements in both Reg 1 and Reg 6, Part B are the same standard. The Reg 1 particulate matter requirements apply at all times. As indicated under the particulate matter and sulfur dioxide streamlining section for the turbines the Reg 6, Part B particulate matter Page 18 requirements are not applicable during startup, shutdown and malfunction. As a result, the Reg 6, Part B requirements have been streamlined out of the permit. Recordkeepinq NSPS Dc requires that records be kept for a period of 2 years, while Reg 3, Part C, Section V.C.6 requires that records be retained for five (5). Therefore, the NSPS recordkeeping requirement will be streamlined out of the permit. Miscellaneous The heaters are subject to the NSPS general provisions (40 CFR Part 60) on a federal and state basis (the units are subject to 40 CFR Part 60 Subpart GG) and on a state- only basis (the units are subject to Reg 6, Part B, Section II and the NSPS general provisions are adopted by reference in Reg 6, Part B, Section I.A). Therefore, the Division will streamline the state-only NSPS general provisions out of the permit in favor of the state and federal NSPS general provisions. 2. Emission Factors -The following emission factors shall be used to monitor compliance with the annual limitations: Unit Emission Factors(lbs/mmBtu) Emission Factor Source NOx CO VOC H-8701 0.045 0.037 0.016 CO and VOC from Manufacturer's Data. H-8702 0.045 0.037 0.016 NOx based on performance test conducted on June 8, 2005 for H-8701 at 43% load. 3. Monitoring Requirements —The source will be required to record fuel use and calculate emission monthly to monitor compliance with the annual limitations. Since the source is required to perform compliance tests annually to verify compliance with the MACT CO emission limitation, the Division will require annual testing to verify compliance with the NOx and CO BACT emission limitations. Compliance with the PM and opacity limitations are presumed, in the absence of credible evidence to the contrary since natural gas is the only fuel permitted for use in these units. 4. Compliance Status —The source indicated in the Title V permit application that the heaters were in compliance with all applicable requirements. The Division agrees that upon issuance of the construction permit to revise the NOx BACT limits [October 19, 2006] for these units that the heaters are in compliance with all applicable requirements. CO2 Treatment Plant— Glycol Dehydrator and Amine Unit Rated at 300 mmSCF/day FL-8921: Flare Vent. Emissions from the Glycol Dehydrator Regenerator (Still) Vent and Flash Tank and the Amine Unit Flash Tank are Routed to the Flare. The flare is rated at 13.54 mmBtu/hr. Page 19 ST-8931: Amine Unit Regenerator(Still) Vent, Routed to SulfaTreat H2S Control System. 1. Applicable Requirements -An initial approval construction permit (03WE0916) was issued for the CO2 Treatment Plant on June 10, 2004. A revised construction permit was issued on May 23, 2005, to correct errors in the monthly emission rates. The CO2 plant commenced operation on January 30, 2005. The source self-certified compliance with construction permit 03WE0916 on July 29, 2005, but has not received a final approval permit. Therefore, under the provisions of Colorado Regulation No. 3, Part C, Section V.A.3, the Division will not issue a final approval construction permit and is allowing the initial approval construction permit to continue in full force and effect. The appropriate applicable requirements from the modified initial approval construction permit have been incorporated into the renewal permit as follows: • Visible Emissions shall not exceed 20 % opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes (condition 1 and Regulation No. 1, Section II.A.1. & 4). The 20% /30 % opacity requirement applies to the amine unit regenerator vent (the flare is subject to a different Reg 1 opacity requirement as mentioned below). However, the regenerator vent exhaust consists primarily of CO2 and VOC emissions. Typically the Division does not include the opacity limit in permits for VOC sources, therefore, the 20% /30% opacity.limit will not be included in the permit. • 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 six minutes in any sixty consecutive minutes (condition 2 and Regulation No. 1, Section II.A.5). • Construction of this source must commence within 18 months of initial approval permit issuance (condition 3). As previously indicated, the CO2 plant commenced operation on January 30, 2005; therefore, this condition will not be included in the permit. • The manufacturer, model number and serial number of the subject equipment shall be provided for the Division prior to Final Approval (condition 4). The source provided this information with their self-certification, therefore, this condition will not be included in the permit. Page 20 • The permittee shall notify the Division of startup (condition 6). As previously indicated, the CO2 plant commenced operation on January 30, 2005; therefore, this condition will not be included in the permit. • The CO2 treatment plant is subject to the requirements of Prevention of Significant Deterioration (PSD). Best Available Control Technology (BACT) shall be applied for Volatile Organic Compounds (VOC) (condition 7), as follows: VOC: o Use of an elevated flare shall be used to reduce emissions of VOC by 98%. Note that the flare is an air-assisted flare. o Compliance with the 98% control efficiency is presumed, provided the flare is operated in accordance with the requirements in 40 CFR Part 63 Subpart HHH and the supplemental fuel requirement is met. • The amine unit is.subject to Regulation No. 6 — Standards of Performance for New Stationary Sources (NSPS),'Part A, Subpart LLL— Standards of Performance for Onshore Natural Gas Processing: SO2 Emissions, as follows: o The owner or operator shall keep for the life of the facility, an analysis demonstrating that the facility's design capacity is less than 2 long tons per day of H2S expressed as sulfur (40 CFR part 60 Subpart LLL § 60.647(c)). Because this unit is exempt from the control requirements, the Division has presumed that the unit is also exempt from the requirements in 40 CFR Part 60 Subpart A. • The glycol dehydrator is subject to Regulation No. 8, Part E, Section Ill — Federal Maximum Achievable Control (MACT) requirements in 40 CFR Part 63 Subpart HHH — National Emission Standards for Hazardous Air Pollutants for Natural Gas Transmission and Storage Facilities, including but not limited to the following: o The unit shall comply upon startup (40 CFR Part 63 Subpart HHH § 63.1270(d)(2)). o Startup, shutdown and malfunction requirements in 40 CFR Part 63 Subpart HHH § 63.1272. o General standards in 40 CFR Part 63 Subpart HHH § 63.1274. o Glycol dehydrator unit process vent standards in 40 CFR Part 63 Subpart HHH § 63.1275. o Control equipment requirements in 40 CFR Part 63 Subpart HHH § 63.1281. o Test Methods, Compliance Procedures and Compliance Demonstrations Page 21 requirements in 40 CFR Part 63 Subpart HHH § 63.1282. o Inspection and Monitoring requirements in 40 CFR Part 63 Subpart HHH § 63.1283. o Recordkeeping requirements in 40 CFR Part 63 Subpart HHH § 63.1284. o Reporting requirements 40 CFR Part 63 Subpart HHH § 63.1285. In addition, the general provisions from 40 CFR Part 63 Subpart A also apply and will be included as appropriate. • Emissions from the amine unit regenerator vent shall be routed to the SulfaTreat H2S control system at all times the amine unit is operation. A control efficiency of 75% may be used to calculate emissions is the unit is operated and maintained in accordance with manufacturer's recommendations and good engineering practices (condition 10). • Emissions from the glycol dehydrator regenerator and flash tank and emissions from the amine unit flash tank shall be routed to the flare at all times the glycol dehydrator and amine unit are operating. A control efficiency of 98% for the flare may be used to calculate emissions provided the flare is operated in accordance with the requirements in 40 CFR part 63 Subpart A§ 63.11(b) and 40 CFR Part 63 Subpart HHH (condition 1.1) • The CO2 Treatment Plant shall be subject to the following emission limits (condition 12): Flare Vent o VOC 0.5 tons/mo and 5.8 tons/yr o NOx 0.63 tons/mo and 7.4 tons/yr o CO 3.4 tons/mo and 39.42 tons/yr CO2 Vent (Amine Unit Regenerator) o VOC 1.0 tons/mo and 11.8 tons/yr o H2S 0.42 tons/mo and 5.0 tons/yr Note that the monthly emission limits apply during the first year of operation and since the CO2 treatment plant has been operating for more than one year the monthly limits will not be included in the operating permit. In addition, under the Natural Gas Transmission and Storage MACT, the source indicated that they would meet the 1 ton/yr benzene emission limitations. The NGTS MACT does not include procedures to calculate benzene emissions from the dehydrator. The MACT only addresses the method required to demonstrate that a source is exempt from the MACT control requirements because actual benzene emissions are less than 1 ton/yr (40 CFR Part 63 Subpart HHH § 63.1282(a)). Therefore, the Division has included a benzene emission limit in the Page 22 permit for the dehydrator. The benzene emission limit is based on the GLYCaIc run used to set the VOC permit limits and are set at 0.90 tons/yr of benzene. • The CO2 Treatment Plant shall be subject to the following processing/throughput limits (condition 13): o Processing of natural gas to the plant shall not exceed: 9.300 mmscf/mo and 109,500 mmSCF/yr o Supplemental fuel to the flare shall not be less than 0.335 mmBtu/hr Note that the monthly processing/throughput limits apply during the first year of operation and since the CO2 treatment plant has been operating for more than one year the monthly limits will not be included in the operating permit. In their comments on the draft permit, received on January 11, 2007, the source indicated that the supplemental fuel requirement, which was based on the GLYCaIc run used to set the permit limits, did not take into account the additional gases from the amine unit flash tank that are routed to the flare. They indicated that since the amine unit always runs when the glycol dehydrator runs; therefore, the supplemental fuel requirement is fulfilled by the amine unit flash tank emissions that are routed to the flare. The Division reviewed the data in the GLYCaIc and AMINE Calc runs that were used to set the permit limits and agree that the heat content of the gases routed to the flare exceed 300 Btu/scf without supplemental fuel. Therefore, the supplemental fuel requirement was not included in the draft permit. However, the Division did include a requirement that the glycol dehydrator and the amine unit shall always be run at the same time (e.g. the glycol dehydrator cannot run if the amine unit is not running and vice versa). • The source is subject to the odor requirements in Regulation No. 2 (condition 14). Heaters are not generally a source of odor therefore this condition will not be specifically included in the permit but is included in the General Conditions (Section IV) of the permit. • An application shall be submitted within one year of commencing operation to revise the Title V permit application (condition 15). An application for a separate Title V permit for the Cheyenne Plains equipment was submitted on December 15, 2005. Therefore, this requirement will not be included in the permit. • Within 180 days after commencement of operation, compliance with the conditions contained on this permit shall be demonstrated to the Division (condition 16). Page 23 As discussed above, the source submitted a self-certification on July 28, 2005, therefore, this requirement will not be included in the permit. • Prior to issuance of final approval, the source shall submit to the Division for approval an operating and maintenance plan for all control equipment and control practices (condition 17). An operations and maintenance plan was submitted for the flare on August 1, 2005 but no plan was submitted for the SulfaTreat unit. The operating permit will include the appropriate requirements to monitor compliance with the permit terms. The operating and maintenance requirements proposed by the source in their operating and maintenance plan have been considered for inclusion in the permit. • APEN reporting requirements (condition 18). The APEN reporting requirements will not be identified in the permit as a specific condition but are included in Section IV (General Conditions) of the permit, condition 22.e. 2. Emission Factors —The CO2 Treatment Plant operates as a single train, with natural gas passing through the amine unit to remove primarily CO2 (with some H2S removed also) then through the glycol dehydrator. In the amine unit, natural gas is processed through an aqueous solution of monoethanolamine (MEA) that will absorb H2S, CO2 and VOCs. After the amine solution is saturated with the acid gases it is piped to the amine regenerator. The regenerator heats the amine solution and the acid gases and VOCs are released. In the glycol dehydration unit, triethylene glycol is contacted with the natural gas stream to remove moisture. This glycol-water mixture is heated in the still vent portion of the unit which drives off the water and some entrained VOCs. Emissions from the amine unit are estimated using the Gas Research Institute's AMINECaIc Model and emissions from the glycol dehydrator are estimated using Gas Research Institute's GLYCaIc Model. Emission factors of VOC and various HAPs are dependent upon the variables input into these models. Variables for the amine unit include lean amine weight, pressure, temperature and flowrate, H2S and CO2 loading, control device efficiency, flash tank pressure, number of trays in the column and the pressure, temperature, flowrate and composition of the inlet gas. Variables for the glycol dehydrator include glycol recirculation rate, cubic feet of gas processed, inlet temperature and pressure of the processed wet gas, flash tank temperature and pressure, the control efficiency of the flare and percentage breakdown by volume of constituents in the natural gas. Emissions of NOx and CO are generated from the flare when the gases from supplemental fuel and the glycol dehydrator still vent and flash tank vent are Page 24 combusted. Emissions for these pollutants are estimated using the following emission factors: Pollutant Emission Factor Source NOX 0.068 lb/mmBtu AP-42, Section 13.5 (dated 9/91), Table 13.5-1 CO 0.37 lb/mmBtu Note that there are additional VOC emissions generated from the combustion of the supplemental fuel by the flare. However, compared to the VOC emission from the glycol dehydrator, these emissions are insignificant (less than 0.5 ton/yr) and will therefore not be included in the permit. 3. Monitoring Requirements —The wet gas (inlet) temperature, glycol recirculation rate, and gas BTEX content as the three critical inputs to the GRI GLYCaIc Model for triethylene glycol units. Changes to the gas flow rate and inlet pressure do not radically affect emissions from glycol dehydrators. Therefore, parametric monitoring of the inlet temperature, recirculation rate and BTEX content will be required as part of the monitoring plan for the glycol dehydrator. Inlet pressure and flash tank temperature and pressure will be held constant for modeling purposes. Modeling will only be required when the defined values for inlet temperature, recirculation rate and BTEX content are not indicative of operating conditions during the month. The frequency of sampling and analysis of the wet gas BTEX concentration is quarterly, with provisions to reduce sampling and analysis if the concentrations used in the GLYCaIc analysis are met. Frequency of monitoring for other parameters (wet gas temperature and glycol circulation rate) will be daily. The performance of the flare shall be monitored as required by the MACT. The Division has less information on AMINECaIc but we would assume that similar important parameters would be monitored. Therefore, the Division will require monitoring of the lean amine flowrate, the inlet gas temperature and the BTEX composition of the inlet gas. As with the GLYCaIc parameters, required frequency of monitoring would be daily for the lean amine flowrate and the inlet gas temperature and the Division would require quarterly analysis to determine the BTEX composition of the inlet gas, with provisions to reduce the frequency if the concentrations used in the AMINECalc analysis are met. The amine regenerator vent is routed through the SulfaTreat to reduce H2S emissions. Manufacturer's information on this unit indicates that the only required monitoring is the outlet H2S concentration in order to determine when the SulfaTreat material must be replaced. 4. Compliance Status —The source indicated that the CO2 Treatment Plant is in compliance with all applicable requirements. The Division would agree with this assessment. CP EG-6141: Caterpillar, Model No. 3516B LE, Serial No. CTW00511, 4-Cycle Lean Bum Internal Combustion Engine, Rates at 1557 hp and 10.95 mmBtu/hr. This engine is used to drive an emergency generator. Page 25 1. Applicable Requirements - Based on the size of the generator, this unit would be exempt from the APEN reporting requirements provided that the unit is operated for no more than 100 hrs/yr (Colorado Regulation No. 3, Part A, Section. II.D.1.ttt(ii)). However, in their construction permit application for the Cheyenne Plains facility, the source indicated that this unit would operate more than 100 hrs/yr but less than 250 hrs/yr. As a result an APEN would be required for the engine but a construction permit was not required under the provisions of Colorado Regulation No. 3, Part B, Section II.D.1.c.(ii)). Since the emergency generator is not exempt from the APEN reporting requirements, it cannot be considered an insignificant activity. Therefore, the emergency generator will be included in the Title V permit as a significant emission unit. In addition to the APEN reporting requirements, the Division considers the engine is also subject to the 20% and 30 % opacity requirements in Colorado Regulation No. 1, Sections II.A.4. The 30% opacity requirement applies during certain specific conditions (building of a new fire, cleaning of fire boxes, soot blowing, start-up, any process modification, or adjustment or occasional cleaning of control equipment. The Division considers that building a new fire, cleaning of fire boxes and soot blowing are activities that do not apply to natural gas fired internal combustion engines. In addition, the engine is not equipped with any add-on control device, so adjustment or occasional cleaning of control equipment do not apply to this engine. In addition; although process modifications and/or start-up are conditions that would apply to this engine, the Division considers that such activities would not last for more than six minutes; therefore, the Division considers that the 30% opacity requirement does not apply to this engine. 2. Emission Factors - Emissions from this engine is from the combustion of natural gas. The pollutants of concern are Particulate Matter, (PM and PM1o), Nitrogen Oxides (NOx), Sulfur Dioxide (SO2), Carbon Monoxide (CO), and Volatile Organic Compounds (VOC). Some hazardous air pollutants (HAPs) are generated through the combustion process, although emissions are minimal. Approval of emission factors for this unit is necessary to the extent that accurate actual emissions are required to verify the need to submit revised APENs to update the Division's Emission Inventory. In the Title V permit application the source indicated that they were basing emissions. from the engine on NOx, CO and VOC emissions factors from the manufacturer, they estimated PM, PM10 and SO2 emissions from AP-42, Section 3.2 (dated July 200), Table 3.2-2 (4-stroke lean burn engines). The emission factors as follows: Pollutant Emission Factor PM 9.99 x 10"3 lb/mmBtu PM,o 9.99 x 10-3 lb/mmBtu SO2 5.88 x 104 lb/mmBtu NOx 1 g/hp-hr CO 3.04 g/hp-hr VOC 0.86 g/hp-hr Page 26 Note that at 250 hrs/yr of operation, PM, PM10, VOC and SO2 emissions are below the APEN de minimis level, so the source will not be required to calculate emissions of these pollutants from this unit; however, emissions from all criteria pollutants are to be included on any revised APENS. 3. Monitoring Requirements -The source will be required to record hours of operation annually for purposes of calculating emissions to determine APEN reporting requirements. Emissions shall be based on hours of operation and the maximum horsepower of the engine. Note that in the absence of credible evidence to the contrary, compliance with the opacity limitation is presumed since natural gas is the only fuel permitted to be used as fuel for this engine. 4. Compliance Status —The Title V permit application did not include the emergency generator. However, since the generator is only subject to APEN reporting requirements and an APEN was submitted indicating actual emissions as potential emissions (based on 250 hrs/yr of operation) within the last five years, the engine is in compliance with the APEN reporting requirements. IV. Insignificant Activities The source indicated that the following general categories of insignificant activities at this site include: individual fuel burning equipment < 5 mmBtu/hr and emission units with emissions less than APEN de minimis levels. The following list of specific insignificant activities was included in the Title V application. Units with emissions less than APEN de minims —criteria pollutants (Reg 3, Part C.II.E.3.b) • Emergency shutdowns (VOC emissions < 2 tons/yr) Fugitive VOC emissions from Equipment leaks (VOC emissions < 2 tons/yr) Compresser blowdowns (VOC emissions < 2 tons/yr) Turbine startups (VOC emissions < 2 tons/yr) Fuel (gaseous) burning equipment < 5 mmBtu/hr (Reg 3, Part C.II.E.3.k) Utility heater, 4.5 mmBtu/hr Glycol dehydrator reboiler (4.97 mmBtu/hr total, two burners, each 2.485 mmBtu/hr) V. Alternative Operating Scenarios No alternative operating scenarios were requested for this facility. VI. Permit Shield Permit Shield for Non-Applicable Requirements The source did not request the permit shield for any non-applicable requirements. Page 27 Permit Shield For Streamlined Requirements These requirements are applicable to the emission units at the Cheyenne Plains Compressor Station. As discussed previously in this document, under streamlining of applicable requirements, the Division has included the above requirements, as appropriate in the permit shield for streamlined/subsumed conditions. The following applicable requirements were streamlined out of the permit for the turbines and have been included in the permit shield. • State-only—20% opacity (Reg 6, Part B, Section II.C.3), streamlined out since Reg 1 20% / 30% opacity requirement is more stringent. • State-only— PM emissions shall not exceed 0.5(FI)"°.26 lb/mmBtu (Reg 6, Part B, Section II.C.2), streamlined out since Reg 1 PM requirement is more stringent. • State-only— 0.35 lbs/mmBtu SO2 requirement (Reg 6, Part B, Section II.D.3.b), streamlined out since Reg 1 SO2 requirement is more stringent. • State-only— NSPS general provisions (Reg 6, Part B, Section I), streamlined out since units are subject to federal NSPS general provisions. • 189.5 ppmvd NOx at 15% O2 and ISO conditions (40 CFR Part 60 Subpart GG § 60.332(c)) streamlined out since NOx BACT limit is more stringent. • Monitor sulfur content of fuel (40 CFR Part 60 Subpart GG § 60.334(h)(3)), streamlined out in favor of the BACT requirement to use pipeline quality natural gas. The following applicable requirements were streamlined out of the permit for the hot oil heaters and have been included in the permit shield. • State-only—20% opacity (Reg 6, Part B, Section II.C.3), streamlined out since Reg 1 20% / 30% opacity requirement is more stringent. • State-only— PM emissions shall not exceed 0.5(FI)-°.26 lb/mmBtu (Reg 6, Part B, Section II.C.2), streamlined out since Reg 1 PM requirement is more stringent. • State-only— NSPS general provisions (Reg 6, Part B, Section I), streamlined out since units are subject to federal NSPS general provisions. • Retain records for two (2) years (40 CFR Part 60 Subpart Dc § 60.48c(i)) streamlined in favor of Title V recordkeeping requirements. Page 28 HAPs Per Division Analysis (05OPWE281) Hazardous Air Pollutant Emissions, in Tons/yr Unit a) c c - w a) c >, Cl) a) -c a) a) , m c a) c *a Tei N N a) c c d' Q co . X G c�0 a) j, O CV +�. a) Z .C H E a) E c 03 t0 S E Turbine(CG-7101) 0.01 0.00 0.01 0.22 0.04 0.02 0.30 Turbine(CG-7201) 0.01 0.00 0.01 0.22 0.04 0.02 0.30 Hot Oil Heater(H- 0.00 0.02 0.00 0.00 0.38 0.40 8701) Hot Oil Heater(H- 0.00 0.02 0.00 0.00 0.38 0.40 8703) Dehydrator 0.87 1.56 0.11 2.54 Amine Unit 7.35 2.30 0.10 9.74 Phase II Turbine 0.01 0.00 0.01 0.22 0.04 0.02 0.30 (CG-7301) Emergency 0.01 0.07 0.01 0.09 Generator(CP EG- 6141)** Total 0.04 8.23 0.03 0.76 3.97 0.06 0.00 0.00 0.00 0.96 0,01 14.07 Insignificant activities included in HAP total in the preliminary analyses for the FREP, CPP and CPP Phase II turbine are not included here. **Based on 250 hrs/yr of operation Page 29 Opacity Streamlining Grid Reqmt Source Normal Start-up Shutdown Malfunction Fire Building Cleaning of Soot Process Adjustment/ 1 Fire Boxes Blowing Modifications Cleaning of Control Equipment -. .. �' -s,."Ni xy7 �"ax _ 'Yws 7.X x- iw �a- �ti sy ».�;,` Y.;'-rw: ::'-� s.:.. .,K'; ,e„.,0.; .:,:. �-. 0: /-.< �x:-,;•_� -�. - >i.,.,x 0;. •� ;.:t�'.�., ,.v ;�L ;.O i. t,�,:�'� `��t �,�e;3`y, .�-��... 4�.,. � � tj�'�.�. x Reg 1 20%r; 3Oe%withrs >2 % 20 /o. �Y,: o�wfl, Of/olth t s3�%mow a o t; fz 'of ._ M k _ � Y�` ;.-,• .., yo m,,�� .-,- �� r4 �� 3 /0°+awL� ,y. x Sections rt gone 6 mmu#e one ute ohm' ute� �v' 0 / ,�, o�.Wltll .-,t .z' fvY.< .« � � t �''fi"�.�ss, �''<ti .��.'.G. ez1.f:•� r 4 't k :,; interval i late illlte wln a a.1 ,,,o , -mike I[.A.l & _� ,. ~�, x�� Y � � :�� ua��-> f � rrl*e �e mt a tte��`grni' �-��' �:�� R m�,.s -Ym•a Six G z n excess3of.'sx 7rr. u aexce p l exee "' n ±s',t { ? �z :t 3 r a. h '" . ' , .� .al.ui exce �ei a • I!I erh+ 30% grx �1f o �P,� p�'t, ;r �� <w - ' Fj r*^�a,.• t', �q��sr.a�' . at 'i,'`3 r� a. •;';r.-s .x r6 :,.<� 5.°-s"- ':'.≤•[ "�".�. .S„v: ,ink. ..�....,.. < sF,.�z"z O�d ):`rET.'₹. :t: Y.rc Yr�en,,...W,si.'? .P „.,<t.-a�...,r .. ..r ..... , Reg 6, Part B, 20% No standard' No standard No standard 20% 20"/0 20% 20% 20% Section 11.C.3 -State Only 'Although the opacity standards are not applicable during start-up, shutdown and malfunction 40 CFR§60.7(c)(2)requires the source to report each period of excess emissions that occurs during startups, shutdowns,and malfunctions,the nature of the malfunction and the corrective action taken or preventative measures adopted. Note that for Reg 6, Part B requirements,the NSPS general provisions are adopted by reference and so any opacity exemption provided in the NSPS applies to source subject to Reg 6,Part B. * Shaded regions are the most stringent Federal requirements ** Values in bold are the most stringent State-only requirements however federal requirements cannot be streamlined out of thepermit due to more stringent state-only requirements Indicates that the Division considers that the activity does not apply to emission units or that the activity will last less than 6 minutes. . • H:\SOURCES\operating permits to be issued\cheyenne plains\Opacity Streamlining Grid.doc OF CO,Z ) 4s, ? ‘..! ep -411?) *4 X876 � Colorado Department of Public Health and Environment OPERATING PERMIT Cheyenne Plains Compressor Station First Issued: DRAFT AIR POLLUTION CONTROL DIVISION COLORADO OPERATING-PERMIT FACILITY NAME: Cheyenne Plains OPERATING PERMIT NUMBER Compressor Station FACILITY ID: 1230051 05OPWE281 ISSUED: EXPIRATION DATE: MODIFICATIONS: See Appendix F of Permit Issued in accordance with the provisions of Colorado Air Pollution Prevention and Control Act, 25-7-101 et seq. and applicable rules and regulations. ISSUED TO: PLANT SITE LOCATION: Cheyenne Plains Gas Pipeline Company Section 5, T11N, R66W(—4 miles N of Rockport) P.O. Box 1087 Rockport, CO Colorado Spring, CO 80944 Weld County INFORMATION RELIED UPON Operating Permit Application Received: December 12, 2005 And Additional Information Received: March 30, 2007 Nature of Business: Natural Gas Transmission Primary SIC: 4922 RESPONSIBLE OFFICIAL (PRIMARY) FACILITY CONTACT PERSON Name: Gary R. Stuart Name: Barry Schatz Title: Cheyenne Area Manager Title: Principal Environmental Scientist, Pipelines West Environmental Phone: (970) 897-3241 Phone: (719) 388-5717 RESPONSIBLE OFFICIAL (SECONDARY) Name: Matthew J. Mask Title Director, Rocky Mountain Division Phone: (719) 288-5701 SUBMITTAL DEADLINES Semi-Annual Monitoring Periods: EXAMPLE(March 1 —Aug. 30, September 1 —February 28(29)) Semi-Annual Monitoring Report: EXAMPLE(Due Oct. 1, 2006 &Apr. 1, 2007 & subsequent years) First Annual Compliance Period: EXAMPLE(March 1 —August 30) Subsequent Annual Compliance Periods: EXAMPLE(September 1 —August 30) Annual Compliance Certification: EXAMPLE(Due October 1, 2006 & 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(PSD) 2 4. Accidental Release Prevention Program(112(r)) 2 5. Compliance Assurance Monitoring (CAM) 6. Summary of Emission Units 3 SECTION II - Specific Permit Terms 4 1. CG-7101, CG 7201 & CG-7301: Solar Taurus 70-7800S, Combustion Turbines S/Ns: 0251B, 0250B & 0286B 4 2. H-8701 and H-8702: Heatec,Natural Gas Fired Hot Oil Heaters, Each Rated at 45 mmBtu/hr 10 3. Flare Stack (FL-8921) and CO2 Vent (ST-8931): CO2 Treatment Plant— Glycol Dehydrator and Amine Unit, Each Rated at 300 mmSCF/day 18 4. EG-6141- Caterpillar, Model No. 3516B LE, Emergency Generator Rated at 1557 hp 35 5. Portable Monitoring (6/1/06 version) 35 SECTION III-Permit Shield 37 1. Specific Conditions 37 2. General Conditions 37 3. Streamlined Conditions 37 SECTION IV- General Permit Conditions 39 1. Administrative Changes 39 2. Certification Requirements 39 3. Common Provisions 39 4. Compliance Requirements 43 5. Emergency Provisions 44 6. Emission Standards for Asbestos 44 7. Emissions Trading, Marketable Permits, Economic Incentives 44 8. Fee Payment 44 9. Fugitive Particulate Emissions 45 10. Inspection and Entry 45 11. Minor Permit Modifications 45 12. New Source Review 45 13. No Property Rights Conveyed 45 14. Odor 45 15. Off-Permit Changes to the Source 46 16. Opacity 46 17. Open Burning 46 18. Ozone Depleting Compounds 46 19. Permit Expiration and Renewal.. 46 20. Portable Sources 46 21. Prompt Deviation Reporting 46 22. Record Keeping and Reporting Requirements 47 23. Reopenings for Cause 48 24. Section 502(b)(10) Changes 48 25. Severability Clause 49 TABLE OF CONTENTS: 26. Significant Permit Modifications 49 27. Special Provisions Concerning the Acid Rain Program..._ 49 28. Transfer or Assignment of Ownership 49 29. Volatile Organic Compounds 49 30. Wood Stoves and Wood burning Appliances 50 APPENDIX A-Inspection Information 1 Directions to Plant: 1 Safety Equipment Required: 1 Facility Plot Plan- 1 List of Insignificant Activities: 1 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 Required 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 • • . I Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 1 SECTION I- General Activities and Summary 1. Permitted Activities 1.1 The facility is a natural gas compression facility as defined under Standard Industrial Classification 4922. This facility is a mainline compressor station. Its main function is to compress and transmit natural gas from the Wyoming area east into Kansas. This is achieved by using three (3) natural gas fired combustion turbines driving natural gas compressors. The facility also includes a CO2 Treatment Plant, which consists of glycol dehydrator and amine treatment unit. Emissions from the glycol dehydrator still (regenerator) vent and flash tank and emissions from the amine unit flash tank are routed to a flare to reduce VOC emissions. The amine unit regenerator vent is equipped with a SulfaTreat H2S control system to reduce H2S emissions. There are also two (2) 45 mmBtu/hr natural gas fired heaters associated with the amine unit and an emergency generator that are included in Section II of the permit as significant emission units. The Cheyenne Plains Compressor Station was constructed in 2004 at the site of an existing mainline compressor station (Cheyenne Station), whose main function is to compress and transmit natural gas from the Wyoming are to the Colorado Front Range area. As such the two facilities are considered a single source for purposes of Prevention of Significant Deterioration (PSD) review requirements and Title V permitting requirements. Equipment associated with the Cheyenne Compressor Station is addressed in a separate Title V operating permit (95OPWE090). The facility is located approximately 4 miles north of Rockport in Weld County on Highway 85. The area in which the plant operates is designated as attainment for all criteria pollutants. There are two affected states within 50 miles of the plant: Wyoming and Nebraska. The following Federal Class I designated area is 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: 03WE0910, 03WE0913, 03WE0916 and 04WE1390. 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 Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit#05OPWE28l Page 2 otherwise specified. State-only enforceable conditions are: Permit Condition Number(s): Section IV - Conditions 3.4, 3.d, 3.g(last paragraph), 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. 2. Alternative Operating Scenarios 2.1 The permittee shall be allowed to make the following changes to its method of operation without applying for a revision of this permit. 2.1.1 No separate operating scenarios have been specified. 3. Prevention Of Significant Deterioration (PSD) 3.1 This facility is located in an area designated attainment for all pollutants. It is categorized as a major stationary source (Potential to Emit> 250 tons per year for NOx, CO and VOC). Future modifications at this facility resulting in a significant net emissions increase (see Regulation No. 3, Part D, Section II.A.26 and 42) for any pollutant as listed in Regulation No. 3, Part D, Section II.A.42 or a modification which is major by itself will result in the application of the PSD review requirements. 3.2 The following Operating Permits are associated with this facility for purposes of determining applicability of Prevention of Significant Deterioration regulations: 95OPWE090 (Cheyenne Compressor Station) 4. Accidental Release Prevention Program(112(r)) 4.1 Based on the information provided by the applicant,the facility is not subject to the provisions of the Accidental Release Prevention Program(section 112(r)of the Federal Clean Air Act). 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: The CAM requirements do not apply to the flare(FL-8921)until the renewal of this permit. Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyv11.1e Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 3 6. Summary of Emission Units 6.1 The emissions units regulated by this permit are the following: Facility AIRS Description Startup Date Pollution Identifier Stack Control Number Device CP CG- 015 Solar Taurus Natural Gas Fired Turbine,Model No.70- December Dry Low 7101 10302S,Serial No.0251B. The turbine is rated at 9,816 hp 15,2004 NOx and 71.42 mmBtu/hr. Combustion System CP CG- 016 Solar Taurus Natural Gas Fired Turbine,Model No.70- December Dry Low 7201 10302S,Serial No.0250B. The turbine is rated at 9,816 hp 15,2004 NOx and 71.42 mmBtu/hr. Combustion System CP CG- 024 Solar Taurus Natural Gas Fired Turbine,Model No.70- October 29, Dry Low 7301 10302S, Serial No.0286B. The turbine is rated at 9,816 hp 2005 NOx and 71.42 mmBtu/hr. Combustion System H-8701 018 Heatec,Model No.VHC1-16010-40-G,Serial No.04-074- January 30, Low NOx 151,Natural Gas Fired Hot Oil Heater,Rated at 45 mmBtu/hr. 2005 Burners This heater is part of the amine treatment unit H-8702 019 Heatec,Model No.VHC1-16010-40-G, Serial No.04-074- January 30, Low NOx 152,Natural Gas Fired Hot Oil Heater,Rated at 45 mmBtu/hr. 2005 Burners This heater is part of the amine treatment unit FL-8921 022 Flare Vent: Emissions from the glycol dehydrator regenerator January 30, Air-Assisted, (still)vent and flash tank and the amine unit flash tank are 2005 Elevated routed to the flare. The glycol dehydrator and amine unit are Flare each rated at 300 mmSCF/day. The flare is rated at 13.54 mmBtu/hr. ST-8931 021 Amine Unit Regenerator(CO2)Vent. Amine unit is rated at January 30, Su lfaTreat 300 mmSCF/day. 2005 H2SControl System CP EG- 023 Caterpillar,Model No.3516B LE,Serial No.CTW00511,4- December None. 6141 Cycle Lean Burn Natural Gas-Fired Internal Combustion 2004 Engine,rated at 1557 hp and 10.95 mmBtu/hr. This engine is used to drive an emergency generator. Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 4 SECTION II - Specific Permit Terms 1. CG-7101, CG 7201 & CG-7301: Solar Taurus 70-7800S, Combustion Turbines S/Ns: 0251B, 0250B & 0286B. Unless Otherwise Specified Limitations Apply to Each Turbine Parameter Permit Limitations for each turbine Compliance Monitoring Condition Short Term Long Term Emission Method Interval Number Factor BACT 1.1. See Condition 1.1. Requirements NOx 1.2 CG-7101 &7201: 24.5 ppmvd at 15% See Condition Recordkeeping& Monthly O2,except as provided for below: 1.2. Calculation CG-7301: 15 ppmvd at 15%O2,except as provided for below: All Turbines: 20°F<T<0°F:42 ppmvd at 15%O2 T<-20°F: 120 ppmvd at 15%O2 All limits on a 1-hr average N//A CG-7101&7210: 31.6 tons/yr CG-7301: 20.1 tons/yr CO CG-7101 &7201:48.8 ppmvd at 15% Portable Flue Gas Quarterly O2,except as provided for below: Analyzer CG-7301:25 ppmvd at 15%O2,except as provided for below: All Turbines: -20°F<T<0°F: 100 ppmvd at 15%O2 T<-20°F: 150 ppmvd at 15%O2 All limits on a 1-hr average N/A CG-7101 &7201: 38.5 tons/yr CG-7301: 20.9 tons/yr VOC All Turbines: See Condition 1.2.1. 3 ppmvd at 15%O2,except as provided for below: -20°F<T<0°F: 5 ppmvd at 15%O2 T<-20°F: 8 ppmvd at 15%O2 All limits on a 1-hr average N/A 11.3 tons/yr Recordkeeping Monthly and Calculation Natural Gas 1.3. N/A 661.5 MMscf/yr `f Recordkeeping Monthly Consumption Operating Permit Number: 05OPWE281 Issued: DRAFT CD O.. Pipeline Company Air Pollution Control Division Cheyenne Plains.Gas p p y Colorado Operating Permit Cheyenne Plains Compressor,Station Permit# 05OPWE281 Page 5 Parameter Permit Limitations for each turbine Compliance Monitoring Condition Short Term Long Term Emission Method Interval Number Factor SO2 1.4. 150 ppmvd @ 15%O2 OR Use of Fuel 1 .. Fuel Restriction Only Pipeline Which Contains Less than 0.8 Weight% ^�# n ��'u" 1fi . Quality Sulfur t34` �� w ,i,,, Natural Gas / m '" " 4' is Used as ,BRA f i i ik '� 4+r� ,Oi Fuel 0.8 ibs/MIviBtu ,vfr h 1 110Afoi l PM 1.5. ' 0.165 lbs/MMBtu s r ` ' ,�� Fuel Restriction Only Pipeline ,z it =- A= r,i Quality 11:10 {�,E i' ti' Natural Gas s;1 �t�o �� is Used as .�kkg2 101 Fuel ' N/A i 2.10 tons/yr 6.6 x 10"3 Recordkeeping Monthly lb/mmBtu and Calculation PM to N/A 2.10 tons.yr 6.6 x 10"3 lb/mmBtu Ci�7� o Y':'y,. 1 72 tS v T S fii ss -�,ti Y, oaf n P" x` "v w,,,t 4r ll Heat Content 1.6. ,2 1 a >, "`e O, 7, i i, F, Aq Y ASTM. Methods Semi-Annual w ' 'dl,y �a ,#fi x ,'14 1:'; G , '10,14V,!:1400013 or In Lme Gas AID y� t $ a�rx * s 'S'..kp e i -;AA 1 0 �V 44 1m Jitl eNti gaig l iAllt Argi .' �.s�ra�'`...zk .a t L kt . ....s .;[e Chromatograph Opacity 1.7. Not to Exceed 20%Except as Provided �� r" Sr o p Fuel Restriction Only Pipeline for Below`t , { '-t�. Quality },I�R. !S 5� l�. 11�'�'�i�Cr� Q 'J For Startup-Not to Exceed 30%,for a � � ..i Natural Gas ,��,� '`� �,�� is Used as Period (6)Minutes in any e60 Congatingsecutire ve 1:P="1101-.44' �� Fuel Minutes i*Ski-AW :AI r v 11 1 v s rz k'1 1 r °� +'9".t? 4 a i'�.�rl�"� NSPS General 1.8. E a t ,if i �ri,M�'r A,; x.k s �� ^t 's�'&70 P ;IM V Vr'��' �, , See Condition 1.8. Provisions '�S ;,.r�`..�ru..fi+ �a�»a �a< u.M3 .` �.. a r£w��hw;n�5r �5�,',ag r ✓r jtur-S iit 1.1 Each turbine is subject to the requirements of the Prevention of Significant Deterioration (PSD) Program. Best Available Control Technology (BACT) shall be applied for control of Nitrogen- Oxides (NOx), Carbon Monoxide (CO) and Volatile Organic Compounds (VOC). BACT has been determined to be as follows: 1.1.1 BACT for NOx has been determined to be SoLoNOX (dry low NOx (DLN)) . combustion technology for turbine CG-7101 and CG-7201 and SoLoNOx II (DLN) combustion technology for turbine CG-7301 with emission limits as identified in Condition 1.2.1.1 (Colorado Construction Permits 03WE0910 and 04WE1390). 1.1.2 BACT for CO has been determined to be good combustion practices with emission limits as identified in Condition 1.2.1.2 (Colorado Construction Permits 03WE0910 •and 04WE1390). 1.1.3 BACT for VOC has been determined to be.good combustion practices and use of pipeline quality natural gas, as fuel with emission limits as identified in Condition 1.2.1.3 (Colorado Construction Permits 03WE0910 and 04WE1390). Operating Permit Number: 05OPWE281 Issued: DRAFT O O Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 • Page 6 1.2 Nitrogen Oxide (NOx), Carbon Monoxide (CO) and Volatile Organic Compound (VOC) emissions from this Turbine are subject to the following requirements: 1.2.1 For purposes of BACT NOx, CO and VOC are subject to the following limitations (Colorado Construction Permits 03WE0910 and 04WE1390). All limitations are at 15% O2, on a 1-hr average, a 1.2.1.1 Except as provided for below,NOx emissions from turbines CG-7101 and CG-7201 shall not exceed 24.5 ppmvd and NOx emissions from turbine CG-7301 shall not exceed 15 ppmvd. a. When the ambient temperature is less than 0 F but greater than or equal to—20°F,NOx emissions shall not exceed 42 ppmvd. b. When the ambient temperature is less than —20 ° F, NOx emissions shall not exceed 120 ppmvd:., 1.2.1.2 Except as provided for below, CO emissions from turbines CG-7101 and CG-7201 shall not exceed 48.8 ppmvd and CO emissions from.turbine CG-7301 shall not exceed 25 ppmvd. a. When the ambient temperature is less than 0 ° F. but greater than or equal to—20 °F, CO emissions shall not exceed 100 ppmvd. b. When the ambient temperature is less than-20 °F, CO emissions shall not exceed 150 ppmvd. 1.2.1.3 Except as provided for below,VOC emissions shall not exceed 3 ppmvd. a. When the ambient temperature is less than 0 ° F but greater than or equal to—20°F,VOC emissions shall not exceed 5 ppmvd. b. When the ambient temperature is less than —20 ° F, VOC emissions shall not exceed 8 ppmvd. 1.2.1.4 The source shall monitor the number of hours that each turbine operates when the ambient temperature meets the criteria in Conditions 1.2.1.1.a & b, 1.2.1.2.a&b and 1.2.1.3.a& b above. The hours meter on the transient pilot shall be used to monitor and record the number of hours the turbine runs when ambient temperatures are below 0 ° F. Hours of turbine operation when the ambient temperatures are below -20 ° F shall be recorded manually. Portable monitoring shall be conducted quarterly in accordance with the requirements in Condition 5 to monitor compliance with the NOx and CO BACT limits. At least annually, such portable monitoring shall be conducted at the temperatures specified in Conditions 1.2.1.1.a & b and 1.2.1.2.a & b above, unless ambient conditions or extended periods at those temperatures are not sufficient to conduct the monitoring. In the event that it is not -feasible to conduct a portable monitoring test at the temperatures''specified in Conditions 1.2.1.1.a & b and 1.2.1.2.a & b, due to ambient conditions or insufficient time, a written explanation shall be submitted with the Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 7 annual compliance certification describing the reasons that portable monitoring was not conducted. In the absence of credible evidence to the contrary, compliance with the VOC BACT limit is presumed provided that the natural gas used as fuel meets the requirements in Condition 1.4.1. 1.2.2 NOx, CO and VOC emissions shall not exceed the annual emission limitations stated above (Colorado Construction Permits 03WE0910 and 04WE1390, 04WE01390 as modified under the provisions of Section I, Condition 1.3, to revise the CO emissions as indicated on the APEN received on March 30, 2007). Compliance with the emission limitations shall be monitored as follows: 1.2.2.1 Except as provided below, the emission factors listed in the table below (from the manufacturer) have been approved by the Division and shall be used to calculate emissions from the turbines as follows: NOx CO VOC T>0°F: T>0°F: 1>0°F: CG-7101 &CG-7201: CG-7101 &CG-7201: 0.035 lb/mmBtu 0.0981b/mmBtu 0.1191b/mmBtu -20°F<T<0°F: CG-7301: CG-7301: 0.070 lb/mmBtu 0.060 lb/mmBtu 0.061 lb/mmBtu T<-20°F: -20°F<T<0°F: -20°F<T<0°F: 0.105 lb/mmBtu 0.177 lb/mmBtu 0.257 lb/mmBtu T<-20°F: T<-20°F: 0.504 lb/mmBtu 0.384 lb/mmBtu Monthly emissions shall be calculated by the end of the subsequent month for each turbine using the above emission factors, the monthly natural gas consumption and the lower heating value of the gas, as specified in Condition 1.6, in the equation below: tons/mo=JEF(lbs/MMBtu)1 x[Fuel Use(MMscf/mo)l x[Heat Content of Fuel(MMBtu/MMscfll 2000 lbs/ton Monthly emissions from each turbine shall be used in a twelve-month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months' data. 1.2.2.2 Portable Monitoring shall be conducted quarterly in accordance with the requirements in Condition 5 to monitor compliance with the NOx and CO emission limitations.. Note that the second to the last paragraph in Condition 5 (apply for a permit modification within 60 days if the portable analyzer test indicates Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 8 that the emission rates/factors are greater than the emission rates/factors identified in the permit) does not apply to these emission units. 1.3 Natural gas consumption for each turbine shall not exceed the limitations stated above (Colorado Construction Permits 03WE0910 and 04WE1390). Natural gas consumption shall be recorded monthly using each turbine's fuel meter. Monthly natural gas consumption shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months data. 1.4 Sulfur Dioxide (SO2)emissions shall not exceed the following limitations: 1.4.1 Each turbine shall meet one of the following requirements: 1.4.1.1 Sulfur Dioxide (SO2) emissions from the turbine shall not exceed 150 ppmvd at 15%O2, OR 1.4.1.2 No fuel, which contains sulfur in excess of 0.8 percent by weight, shall be used in this combustion turbine (Colorado Construction Permits 03WE0910 and 04WE1390 and 40 CFR Part 60 Subpart GG §§ 60.333(a) & (b), as adopted by reference in Colorado Regulation No. 6,Part A). In the absence of credible evidence to the contrary, compliance with the above requirements is presumed since only pipeline quality natural gas is permitted to be used as fuel in these turbines. The permittee shall maintain records demonstrating that the natural gas burned meets the definition of pipeline quality natural gas as defined in 40 CFR Part 72 (0.5 grains or less of total sulfur per 100 standard cubic feet). The demonstration shall be made using the gas quality characteristics in a current, valid purchase contract, tariff sheet or transportation contract for the gaseous fuel. These records shall be made available to the Division upon request. 1.4.2 Sulfur Dioxide (SO2) emissions from each turbine shall not exceed 0.8 lbs/MMBtu, on a 3-hr rolling average (Colorado Regulation No. 1, Section VI.B.4.c.(i) and VI.B.2). In the absence of credible evidence to the contrary, compliance with the SO2 limitations is presumed since only pipeline quality natural gas is permitted to be used as fuel in these turbines. 1.5 Particulate Matter Emissions (PM and PMI() shall not exceed the following limitations: 1.5.1 Particulate Matter (PM) emissions from each turbine shall not exceed the above limitations (Colorado Regulation No. 1, Section III.A.1). In the absence of credible evidence to the contrary, compliance with the particulate matter emission limit is presumed since only pipeline quality natural gas is permitted to be used as fuel in these turbines. The numeric PM standard was determined using the design heat input of each turbine (71.42 MMBtu/hr) in the following equation: Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Chey Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 9 PE=0.5 x(FI)-°26' where: PE=particulate standard in lbs/mmBtu FI=fuel input in mmBtu/hr 1.5.2 PM and PM10 emissions shall not exceed the annual emission limitations stated above (Colorado Construction Permits 03WE0910 and 04WE1390). Compliance with the emission limitations shall be monitored as follows: 1.6 The Btu content of the natural gas used to fuel these turbines shall be verified semi-annually using the appropriate ASTM Methods or equivalent, if approved in advance by the Division. In lieu of collecting a sample,the Btu content of the natural gas may be determined using the in-line gas chromatograph to determine the gas composition and the appropriate ASTM Methods or equivalent, if approved in advance by the Division,to calculate the Btu content. The Btu content of the gas shall be calculated for January and July, using the average composition of the gas as determined by the in-line gas chromatograph for those months. The Btu content of the natural gas shall be based on the lower heating value of the fuel. If sampling is conducted, calculations of monthly emissions shall be made using the heat content derived from the most recent required analysis. If the gas chromatograph data is used, calculations of monthly emissions for January through June shall be made using the January average Btu content and calculations of monthly emissions for July through December shall be made using the July average Btu content. 1.7 Each turbine is subject to the following opacity requirements: 1.7.1 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 Regulation No. 1, Section A.II.1). 1.7.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from start-up which is in excess of 30% opacity for a period or periods aggregating more than six(6) minutes in any sixty(60) consecutive minutes (Colorado Regulation No. 1, Section II.A.4). In the absence of credible evidence to the contrary, compliance with the above opacity requirements shall be presumed since only pipeline quality natural gas is permitted to be used as fuel for these turbines. 1.8 Each turbine is subject to the NSPS Subpart A, General Provisions requirements (Colorado Regulation No. 6, Part A, Federal 40 CFR 60.1 through 60.19). Specifically, these units are subject to the following: 1.8.1 No article, machine, equipment or process shall be used to conceal an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gasses discharged to the atmosphere. (40 CFR § 60.12) Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 10 1.8.2 Records of.startups, shutdowns, and malfunctions shall be maintained, as required under 40 CFR § 60.7. 1.8.3 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. (40 CFR § 60.11(d)). 2. H-8701 and H-8702: Heatec,Natural Gas Fired Hot Oil Heaters,Each Rated at 45 mmBtu/hr Unless Otherwise Specified Limitations Apply to Each Heater Parameter Permit Limitations Compliance Monitoring Condition Short Term Long Term Emission Factor Method Interval Number BACT 2.1. See Condition 2.1. Requirements NOx 2.2. 0.045 lb/MMBtu,on a 1-hr average 0.045 lb/MMBtu Recordkeeping& Monthly N/A I 8.9 tons/yr Calculation CO 0.037 lb/MMBtu,on a 1-hr average 0.037 lb/MMBtu Performance Test Annually N/A I 7.3 tons/yr VOC 0.016 lb/MMBtu,on a 1-hr average 0.016 lb/MMBtu N/A 3.15 tons/yr Natural Gas 2.3. N/A 416.8 MMscf/yr Recordkeeping Monthly Consumption Particulate 2.4. 0.185 lb/mmBtu - Fuel Restriction Only Natural Matter Gas is Used as Fuel NSPS General 2.5. See Condition 2.5. Provisions Heat Content 2.6. ASTM Methods Semi-Annual or In-Line Gas Chromatograph Opacity 2.7. Not to Exceed 20%Except as Fuel Restriction Only Natural Provided for Below Gas is Used For Startup-Not to Exceed 30%,for as Fuel a Period or Periods Aggregating More than Six(6)Minutes in any 60 Consecutive Minutes MACT 2.8. CO—400 ppmvd,corrected to 3%O2 Performance Test Annually Requirements (3-run average) Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 11 Parameter Permit Limitations Compliance Monitoring Condition Short Term Long Term Emission Factor Method Interval Number MACT 2.9. See Condition 2.9. General Provisions Stack 2.10. No Rain Caps or Other Obstructions Certification Annually Requirements are Allowed on the Exhaust Stacks for `-; these Heaters 2.1 Each heater is subject to the requirements of the Prevention of Significant Deterioration (PSD) Program. Best Available Control Technology (BACT) shall be applied for control of Nitrogen Oxides (NOx), Carbon Monoxide (CO) and Volatile Organic Compounds (VOC). BACT has been determined to be as follows: 2.1.1 BACT for NOx has been determined to be low NOx burners with emission limits as identified in Condition 2.2.1.1 (Colorado Construction Permit 03WE0913). 2.1.2 BACT for CO has been determined to be good combustion practices with emission limits as identified in Condition 2.2.1.2 (Colorado Construction Permit 03WE0913). 2.1.3 BACT for VOC has been determined to be good combustion practices with emission limits as identified in Condition 2.2.1.3 (Colorado Construction Permit 03WE0913). 2.2 Nitrogen Oxide (NOx), Carbon Monoxide (CO) and Volatile Organic Compound (VOC) emissions from each heater are subject to the following requirements: 2.2.1 For purposes of BACT NOx, CO and VOC are subject to the following limitations (Colorado Construction Permit 03WE0913): 2.2.1.1 NOx emissions shall not exceed 0.045 lb/MMBtu, on a 1-hour average. 2.2.1.2 CO emissions shall not exceed 0.037 lb/MMBtu, on a 1-hour average. 2.2.1.3 VOC emissions shall not exceed 0.016 lb/MMBtu, on a 1-hour average. Compliance with the NOx and CO emission limitations shall be monitored by conducting annual performance tests in conjunction with the annual tests required by Condition 2.8.9. In the absence of credible evidence to the contrary compliance with the VOC BACT limits is presumed since only pipeline quality natural gas is permitted to be used as fuel in these heaters. 2.2.2 NOx, CO and VOC emissions from each heater shall not exceed the annual emission limitations stated above (Colorado Construction Permit 03WE0913) Monthly emissions from each heater shall be calculated by the end of the subsequent month using the above emission factors (from the manufacturer), the monthly fuel Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 12 consumption and the lower heating value of the fuel, as specified in Condition 2.6, in the equation below: tons/mo=[EF(Ibs/MMMBtu)]x[Fuel Use(MMscf/mo)1 x[Heat Content of Fuel(MMBtu/MMscffl 2000 lbs/ton Monthly emissions from each heater 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. 2.3 Natural gas consumption from each heater shall not exceed the limitations stated above (Colorado Construction Permit 03WE0913). Natural gas consumed in each heater shall be recorded monthly, as required by 40 CFR Part 60 Subpart Dc § 60.48c(g), as adopted by reference in Colorado Regulation No. 6, Part A. Natural gas use shall be recorded monthly using the fuel meter for each heater. Monthly natural gas use for each heater 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. 2.4 Particulate matter emissions from each heater shall not exceed the above limitations (Colorado Regulation No. 1, Section III.A.1). In the absence of credible evidence to the contrary, compliance with the particulate matter emission limit is presumed since only pipeline quality natural gas is permitted to be used as fuel in these heaters. The numeric PM standard was determined using the design heat input for each heater (45 MMBtu/hr) in the following equation: PE=0.5 x(FI)"°'26. where: PE=particulate standard in lbs/mmBtu FI=fuel input in mmBtu/hr 2.5 Each heater is subject to the NSPS Subpart A, General Provisions requirements (Colorado Regulation No. 6, Part A, Federal 40 CFR 60.1 through 60.19). Specifically, these units are subject to the following: 2.5.1 No article, machine, equipment or process shall be used to conceal an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gasses discharged to the atmosphere. (40 CFR § 60.12) 2.5.2 Records of startups, shutdowns, and malfunctions shall be maintained, as required under 40 CFR § 60.7. 2.5.3 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 13 information available to the Administrator which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. (40 CFR § 60.11(d)) 2.6 The Btu content of the natural gas used to fuel these heaters shall be verified semi-annually using the appropriate ASTM Methods or equivalent, if approved in advance by the Division. In lieu of collecting a sample, the Btu content of the natural gas may be determined using the in-line gas chromatograph to determine the gas composition and the appropriate ASTM Methods or equivalent,if approved in advance by the Division,to calculate the Btu content. The Btu content of the gas shall be calculated for January and July, using the average composition of the gas as determined by the in-line gas chromatograph for those months. The Btu content of the natural gas shall be based on the lower heating value of the fuel. If sampling is conducted, calculations of monthly emissions shall be made using the heat content derived from the most recent required analysis. If the gas chromatograph data is used, calculations of monthly emissions for January through June shall be made using the January average Btu content and calculations of monthly emissions for July through December shall be made using the July average Btu content. 2.7 Each heater is subject to the following opacity requirements: 2.7.1 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 Regulation No. 1, Section A.II.1). 2.7.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from start-up which is in excess of 30% opacity for a period or periods aggregating more than six(6)minutes in any sixty (60) consecutive minutes (Colorado Regulation No. 1, Section II.A.4). In the absence of credible evidence to the contrary, compliance with the above opacity requirements shall be presumed since only natural gas is permitted to be used as fuel for these heaters. 2.8 Each heater is subject to the requirements in 40 CFR Part 63 Subpart DDDDD, "National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial and Institutional Boilers and Process Heaters", as adopted by reference in Colorado Regulation No. 8, Part E, requirements include but are not limited to the following. Note that the compliance date for each heater is the startup date (January 30, 2005) as specified in 40 CFR Part 63 Subpart DDDDD § 63.7495(a). Emission Limits and Work Practice Standards Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 14 2.8.1 Carbon monoxide emissions shall not exceed 400 ppm by volume on a dry basis corrected to 3 percent oxygen (3-run average) (40 CFR Part 63 Subpart DDDDD § 63.7500(a)(1) and table 1, item 8). General Requirements 2.8.2 You must be in compliance with the emission limits (including operating limits) and the work practice standards in Condition 2.8.1 at all times, except during periods of startup, shutdown, and malfunction(40 CFR Part 63 Subpart DDDDD § 63.7505(a)). 2.8.3 You must always operate and maintain your affected source, including air pollution control and monitoring equipment according to the provisions in 40 CFR Part 63 Subpart A § 63.6(e)(1)(i) (40 CFR Part 63 Subpart DDDDD § 63.7505(b)). 2.8.4 If you have an applicable emission limit or work practice standard, you must develop a written startup, shutdown and malfunction plan (SSMP) according to the provisions in 40 CFR Part 63 Subpart A § 63.6(e)(3) (40 CFR Part 63 Subpart DDDDD § 63.7505(e)). Initial Compliance Requirements 2.8.5 For affected sources that have an applicable work practice standard, your initial compliance requirements depend on the subcategory and rated capacity of your boiler or process heater. If your boiler or process heater is in any of the limited use subcategories or has a heat input capacity less than 100 MMBtu per hour, you initial compliance demonstration is conducting a performance test for carbon monoxide according to Table 5 in 40 CFR Part 60 Subpart DDDDD (40 CFR Part 63 Subpart DDDDD § 63.7510(c)). 2.8.6 If your new or reconstructed affected source commenced construction or reconstruction between January 13, 2003 and November 12, 2004, you must demonstrate initial compliance with either the proposed emission limits and work practice standard or the promulgated emission limits and work practice standards no later than 180 days after startup of the source, which ever is later according to 40 CFR Part 63 Subpart A § 63.7(a)(2)(iix) (40 CFR Part 63 Subpart DDDDD § 63.7510(e)). 2.8.7 You must demonstrate initial compliance with each emission limit and work practice standard that applies to you by either conducting initial performance tests and establishing operating limits, as applicable, according to §63.7520, paragraph (c) of this section, and Tables 5 and 7 to this subpart OR conducting initial fuel analyses to determine emission rates and establishing operating limits, as applicable, according to §63.7521, paragraph (d) of this section, and Tables 6 and 8 to this subpart (40 CFR Part 63 Subpart DDDDD § 63.7530(a)). Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 15 2.8.8 You must submit the Notification of Compliance Status containing the results of the initial compliance demonstration according to the requirements in 40 CFR Part 63 Subpart DDDDD § 63.7545(e) (40 CFR Part 63 Subpart DDDDD § 63.7530(e)). Subsequent Performance Tests 2.8.9 If you have an applicable work practice standard for carbon monoxide and your boiler or process heater is in any of the limited use subcategories or has a heat input capacity less than 100 MMBtu per hour, you must conduct annual performance tests for carbon monoxide according to 40 CFR Part 63 Subpart DDDDD § 63.7520 (Conditions 2.8.11 through 2.8.13). Each annual performance test must be conducted between 10 and 12 months after the previous performance test (40 CFR Part 63 Subpart DDDDD § 63.7515(e)). 2.8.10 You must report the results of performance tests and fuel analyses within 60 days after the completion of the performance tests or fuel analyses. This report should also verify that the operating limits for your affected source have not changed or provide documentation of revised operating parameters established according to 40 CFR Part 63 Subpart DDDDD § 63.7530 and Table 7 of 40 CFR Part 63 Subpart DDDDD, as applicable. The reports for all subsequent performance tests and fuel analyses should include all applicable information required in 40 CFR Part 63 Subpart DDDDD § 63.7550 (Condition 2.8.19) (40 CFR Part 63 Subpart DDDDD § 63.7515(g)). 2.8.11 You must conduct each performance test according to the requirements in Table 5 of 40 CFR Part 63 Subpart DDDDD (40 CFR Part 63 Subpart DDDDD § 63.7520(b)). These requirements include the following: You Must.... Using Select the sampling ports location and the number Method 1 in Appendix A of 40 CFR Part 60 of traverse points. Determine oxygen and carbon dioxide Method 3A or 3B in Appendix A of 40 CFR Part concentrations for the stack gas. 60 or ASTM D6522-00(IBR,see §63.14(b)),or ASME PTC 19,part 10(1981)(IBR,see § 63.14(i)). Measure the moisture content of the stack gas Method 4 in Appendix A of 40 CFR Part 60 Measure the carbon monoxide emission Method 10, 10A or 10B in Appendix A of 40 concentration. CFR Part 60 or ASTM D6522-00(IBR,see§ 63.14(b))when the fuel is natural gas. 2.8.12 You must not conduct performance tests during periods of startup, shutdown or malfunction(40 CFR Part 63 Subpart DDDDD § 63.7520(e)). 2.8.13 You must conduct three separate test runs for each performance test required in this section, as specified in 40 CFR Part 63 Subpart A § 63.7(e)(3). Each test run must last at least 1 hour. (40 CFR Part 63 Subpart DDDDD § 63.7520(f)). Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit#05OPWE281 Page 16 2.8.14 You must report each instance in which you did not meet each emission limit, operating limit, and work practice standard in Tables 1 through 4 of 40 CFR Part 63 Subpart DDDDD that apply to you. You must also report each instance during a startup, shutdown, or malfunction when you did not meet the applicable emission limit, operating limit, and work practice standard. These instances are deviations from the emission limits and work practice standards in this subpart. These deviations must be reported according to the requirements in 40 CFR Part 63 Subpart DDDDD § 63.7550 (Condition 2.8.19) (40 CFR Part 63 Subpart DDDDD § 63.7540(b)). 2.8.15 Consistent with §§ 63.6(e) and 63.7(e)(1), deviations that occur during a period of startup, shutdown, or malfunction are not violations if you demonstrate to the EPA Administrator's satisfaction that you were operating in accordance with § 63.6(e)(1). The EPA Administrator will determine whether deviations that occur during a period of startup, shutdown, or malfunction are violations, according to the provisions in §63.6(e) (40 CFR Part 63 Subpart DDDDD § 63.7540(d)). Notification,Reports and Records 2.8.16 You must submit all of the notifications in §§63.7(b) and (c), 63.8 (e), (f)(4) and (6), and 63.9 (b) through (h) that apply to you by the dates specified (40 CFR Part 63 Subpart DDDDD § 63.7545(a)). 2.8.17 If you are required to conduct a performance test you must submit a Notification of Intent to conduct a performance test at least 30 days before the performance test is scheduled to begin(40 CFR Part 63 Subpart DDDDD § 63.7545(d)). 2.8.18 If you are required to conduct an initial compliance demonstration as specified in § 63.7530(a), you must submit a Notification of Compliance Status according to § 63.9(h)(2)(ii). For each initial compliance demonstration, you must submit the Notification of Compliance Status, including all performance test results and fuel analyses,before the close of business on the 60th day following the completion of the performance test and/or other initial compliance demonstrations according to § 63.10(d)(2). The Notification of Compliance Status report must contain all the information specified in §§ 63.7545(e)(1) through (9), as applicable (40 CFR Part 63 Subpart DDDDD § 63.7545(e)). 2.8.19 Compliance reports shall be submitted as semi-annually as required by 40 CFR Part 63 Subpart DDDDD §§ 63.7550(a), (b), (c), (d) and(f). 2.8.20 Records shall be kept as specified in 40 CFR part 63 Subpart DDDDD § 63.7555(a) in the manner and for the time frames specified in § 63.7560. 2.9 Each heater is subject to the requirements in 40 CFR part 63 Subpart A "General Provisions", as adopted by reference in Colorado Regulation No. 8, Part E, Section I as specified in 40 CFR Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 17 Part 63 Subpart DDDDD § 63.7565. These requirements include, but are not limited to the following: 2.9.1 Prohibited activities and circumvention in § 63.4. 2.9.2 Operation and maintenance requirements in § 63.6(e)(1). 2.9.3 Startup, shutdown and malfunction plan requirements in § 63.6(e)(3). 2.9.4 Performance test requirements in § 63.7. 2.9.5 Monitoring requirements in § 63.8. 2.9.6 Notification requirements in § 63.9. 2.9.7 Recordkeeping requirements in § 63.10. 2.10 No rain caps or other obstructions are allowed on the exhaust stacks for these heaters (Colorado Construction Permit 03WE0913). Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit#05OPWE281 Page 18 3. Flare Stack (FL-8921) and CO2 Vent (ST-8931): CO2 Treatment Plant— Glycol Dehydrator and Amine Unit,Each Rated at 300 mmSCF/day. Parameter Permit Limitation Compliance Monitoring Condition Emission Factor Method Interval Number BACT Requirements 3.1. See Condition 3.1. Opacity—Applies to 3.2. Not to Exceed 30% See Condition 3.2. Flare Only NSPS Subpart LLL 3.3. Design Capacity<2 t` Maintain Records Life of Facility Requirements— Long Tons/Day H2S � Applies to the Amine Unit Only NOX 3.4. 7.4 tpy 1.7 lbs/hr Recordkeeping and Monthly CO 39.42 tpy 9 lbs/hr Calculation VOC—Flare Stack 3.5 5.8 tpy See Condition Parametric Daily 3.5 VOC-CO2 Stack 11.8 tpy HZS-CO2 Stack 5.0 tpy Benzene—Glycol 0.90 tpy Dehydrator Extended Gas Analysis ASTM Methods Quarterly Natural Gas Processed 3.6 109,500 MMscf/yr Flow Meter Monthly Operating 3.7. The glycol dehydrator See Condition 3.7. Requirements and amine treatment unit shall be operated .. F together at all times. Hours of Operation 3.8. Recordkeeping I Monthly MACT Requirements 3.9. Benzene emissions See Condition 3.9. less than 1,984 lbs/yr MACT General 3.10. See Condition 3.10. Provisions Flare Requirements 3.11. Visible Emission Visible Emissions Monthly Requirements Observations A Flame Shall be Temperature Sensor or Continuously Present at all times ddr Flame Detection Device that the Flare is �tE with Alarm Operated ' 3 Flare Specifications— � � E � Certification Annually Btu Content of Gas and Velocity ,.......z.... Flare Shall be � �, : Certification Annually Operating at all Times that the Dehydrator is Operated SulfaTreat H2S Control 3.12. H2 Emissions Shall See Condition 3.12. System Be Reduced by 75% ,��...,..._.,.,._s_.-� n�� Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 19 3.1 The CO2 Treatment Plat is subject to the requirements of the Prevention of Significant Deterioration (PSD) Program. Best Available Control Technology (BACT) shall be applied for control Volatile Organic Compounds (VOC). BACT has been determined to be use of an elevated flare to reduce VOC emissions from the glycol dehydrator regenerator (still) vent and flash tank and the amine unit flash tank by 98 % (Colorado Construction Permit 03WE0916). In the absence of credible evidence to the contrary, compliance with the 98% control efficiency requirement is met provided the requirements in Conditions 3.7, 3.9, 3.10 and 3.11 are met. 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 Construction Permit 03WE0916 and Colorado Regulation No. 1, Section II.A.5). This opacity requirement applies to the flare only. In the absence of credible evidence to the contrary, compliance with this opacity requirement is presumed provided the requirements in Condition 3.11.4 are met. 3.3 Amine Unit Only: To certify that a facility is exempt from the control requirements of 40 CFR Part 60 Subpart LLL, each owner or operator of a facility with a design capacity that is less than 2 long tons per day of H2S in the acid gas (expressed as sulfur) shall keep, for the life of the facility, an analysis demonstrating that the facility's design capacity is less than 2 long tons per day of H2S expressed as sulfur(40 CFR Part 60 Subpart LLL § 60.647(c)). 3.4 NOx and CO emissions from the flare shall not exceed the,limitation stated above (Colorado Construction Permit 03WE0916). Monthly emissions of NOx and CO shall be calculated by the end of the subsequent month using the above emission factors (from the manufacturer) and the number of hours the flare is operated in the following equation: Tons/mo=jEF(lb/hr)x Flare hours of operation(hrs/mo) 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. 3.5 VOC and H2S emissions from the flare vent and the CO2 vent and benzene emissions from the glycol dehydrator shall not exceed the limitations stated above (Colorado Construction Permit 03WE0916). Compliance with the VOC, benzene and H2S emission limitations shall be monitored as follows: 3.5.1 For the glycol dehydrator, inlet (wet) gas temperature, glycol recirculation rate, and stripping gas rate shall be measured and recorded daily. For the amine unit,the inlet (feed) gas temperature and the amine flow rate shall be measured and recorded daily. 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. The circumstances surrounding any day on Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit#05OPWE281 Page 20 which the required information fails to be recorded shall be described in a log to be maintained on site. Data from the last day for which data exists will be substituted for the missing values for purposes of calculating the monthly average. No data substitution is necessary for days on which the unit did not operate. Parameter I Value I Units I Criteria Amine Unit Inlet Gas Temperature 100 °F At or Above Amine Flow Rate 1,050 gpm At or Below Benzene 30 ppm At or Below Toluene 30 ppm At or Below Ethyl Benzene 0 ppm At or Below Xylene 0 ppm At or Below Glycol Dehydrator Inlet Gas Temperature 68 °F At or Above Glycol Recirculation 32 gpm At or Below Rate Stripping Gas Rate 2.5 scfm At or Below Benzene 30 ppm At or Below Toluene 30 ppm At or Below Ethyl Benzene 0 ppm At or Below Xylene 0 ppm At or Below 3.5.2 An extended natural gas analysis of inlet gas to the amine unit and the glycol dehydrator will be conducted quarterly, using ASTM methods or equivalent. Frequency of extended gas analyses shall move to semi-annually after the first year, then to annually after the second year if the BTEX concentrations remain consistently below the established values identified in Condition 3.5.1. Frequency will revert back to quarterly if any of the BTEX constituents exceed the listed values. The first quarterly sample shall be taken three months after the sample that indicated that a BTEX constituent exceeded the parameters in the above table was taken. Required analyses shall be conducted not less than one month apart. 3.5.3 If any monthly average of a parameter recorded daily(as required by Condition 3.5.1) or a concentration for a BTEX constituent does not meet the comparison criteria, the GRI GLYCalc (version 4.0 or higher) and AMINECalc (version 1.0 or higher) models shall be used to determine the monthly VOC emission rate. Inputs into the model shall be the monthly average value for the parameters, the BTEX concentrations from the latest extended gas analysis, and the following assumed • values: GLYCalc Dry Gas Water Content: 5 lbs H2O/MMscf Inlet(wet) Gas Pressure: 882 psig Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 21 Flash Tank Temperature: 150 degrees Fahrenheit Flash Tank Pressure: 60 psig Flare Control Efficiency: 98% Natural Gas Throughput 292 MMscf/day AMINE Cale Lean Amine Pressure: 893 psia Lean Amine Weight 50 % H2S Loading 0.0 mol/mol CO2 Loading 0.025 mol/mol Inlet(feed) Gas Pressure 300 MMscf/day Number of Trays in Column 20 Flash Tank Pressure 75 psia SulfaTreat H2S Control System Efficiency 75% GLYCaIc and/or AMINECalc model runs shall be conducted for the month(s) in which the monthly average value of a GLYCalc or AMINECalc parameter recorded daily was exceeded and for every month in which any BTEX constituent exceeds the values listed in Condition 3.5.1, beginning with the month in which the gas sample was taken which indicates the exceedance and ending in the month in which a gas sample is taken that indicates no exceedance. GLYCalc and/or AMINECalc model runs shall be completed by the end of the subsequent month. 3.5.4 A rolling twelve month total of VOC,benzene and H2S emissions shall be maintained to monitor compliance with the annual limitations. For any twelve month period for which a GLYCalc and/or AMINECalc run is not triggered and there are no uncontrolled emissions due to flare or SulfaTreat H2S control system downtime, the twelve month rolling total of VOC,benzene and H2S emissions may be assumed to be equal to the annual limitations. The calculation of the twelve month rolling total of VOC, benzene and H2S emissions shall be performed for any month a GLYCalc and/or an AMINECalc run is triggered or when there are uncontrolled emissions due to flare or SulfaTreat downtime. Calculation of twelve month rolling totals shall be conducted as follows: 3.5.4.1 If a GLYCalc and/or an AMINECalc run is required for any reason, the pounds per hour of emissions predicted by the model shall be multiplied by the number of hours the unit ran for that month to determine monthly VOC, benzene and/or H2S emissions. Note that a 98% control efficiency for the flare may be applied to uncontrolled emissions predicted by the model (AMINECalc) for the amine unit flash tank, for those hours that the flare was in operation. 3.5.4.2 The monthly VOC, benzene and H2S emissions used in the rolling twelve month total for months that do not trigger a GLYCaIc or AMINECalc run shall be the number of hours the unit operated in the month multiplied by the following emission rates (from GLYCalc run submitted with the Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 22 October 10, 2003 construction permit application and the AMINECalc run submitted February 4, 2004 in response to a request for information on the construction permit application, except that it is revised to reflect 75% control for the Sulfa.Treat H2S control system): Stream VOC(lbs/hr) Benzene(lbs/hr) H2S(lbs/hr) Glycol Dehydrator—Flash 0.8594 0.0030 N/A Tank Glycol Dehydrator — Still 0.2553 0.1967 N/A Vent Amine Unit—Flash Tank 0.195 N/A N/A Amine Unit-Still Vent 9.806 N/A 1.122 3.5.4.3 For months in which there are uncontrolled emissions from either the flare or the H2S SulfaTreat control system,VOC, benzene and/or H2S emissions shall be the number of the hours the unit operated with the flare and/or the SulfaTreat multiplied by the emission factors in Condition 3.5.4.2 and uncontrolled emissions from the flare and/or SulfaTreat as required by Conditions 3.11.5 and 3.12. 3.5.4.4 If the twelve month rolling totals for VOC, benzene and/or H2S calculated according to the provisions in Condition 3.5.4.1 through 3.5.4.3 exceed the annual limitations, VOC and/or H2S emissions for the previous months must be calculated using GLYCalc and/or AMINECalc using the parameters described in Condition 3.5.3 until the rolling twelve month total is in compliance with the annual limitations. 3.6 The quantity of natural gas processed by the CO2 Treatment Plant shall not exceed the limitation listed above (Colorado Construction Permit 03WE0916). The natural gas processed through the CO2 Treatment Plant shall be monitored using a flow meter and recorded monthly in a log that is available to the Division upon request. Monthly natural gas 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. 3.7 The glycol dehydrator and the amine unit shall operate together as a unit at all times. At no time shall the glycol dehydrator be operated without the amine unit also operating and at no time shall the amine unit be operated without the glycol dehydrator. 3.8 Hours of operation for the dehydration unit and the amine unit shall be monitored and recorded monthly in a log that is available to the Division upon request. The hours of operation shall be . used to calculate monthly emissions as required by Conditions 3.5.4.1 through 3.5.4.4. 3.9 The glycol dehydrator is subject to the requirements in 40 CFR Part 63 Subpart HHH, "National Emission Standards for Hazardous Air Pollutants for Natural Gas Transmission and Storage Facilities", as adopted by reference in Colorado Regulation No. 8, Part E, requirements include but are not limited to the following. Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 23 Note that the compliance date for the glycol dehydrator is the startup date (January 30, 2005) as specified in 40 CFR Part 63 Subpart HHH § 63.1270(d)(2). Startups, Shutdowns and Malfunctions 3.9.1 The provisions set forth in this subpart shall apply at all times except during startups or shutdowns, during malfunctions, and during periods of non-operation of the affected sources (or specific portion thereof) resulting in cessation of the emissions to which this subpart applies. However, during the startup, shutdown, malfunction, or period of non-operation of one portion of an affected source, all emission points which can comply with the specific provisions to which they are subject must do so during the startups shutdown, malfunction, or period of non-operation (40 CFR Part 63 Subpart HHH § 63.1272(a)). 3.9.2 The owner or operator shall not shut down items of equipment that are required or utilized for compliance with the provisions of this subpart during times when emissions are being routed to such items of equipment, if the shutdown would contravene requirements of this subpart applicable to such items of equipment. This paragraph does not apply if the item of equipment is malfunctioning, or if the owner or operator must shut down the equipment to avoid damage due to a contemporaneous startup, shutdown, or malfunction of the affected source or a portion thereof(40 CFR Part 63 Subpart HHH § 63.1272(b)). 3.9.3 During startups, shutdowns, and malfunctions when the requirements of this subpart do not apply pursuant to paragraphs (a) and (b) of this section, the owner or operator shall implement, to the extent reasonably available, measures to prevent or minimize excess emissions to the maximum extent practical. For purposes of this paragraph, the term"excess emissions" means emissions in excess of those that would have occurred if there were no startup, shutdown, or malfunction, and the owner or operator complied with the relevant provisions of this subpart. The measures to be taken shall be identified in the applicable startup, shutdown, and malfunction plan, and may include, but are not limited to, air pollution control technologies, recovery technologies, work practices, pollution prevention, monitoring, and/or changes in the manner of operation of the source. Back-up control devices are not required, but may be used if available (40 CFR Part 63 Subpart HHH § 63.1272(c)). 3.9.4 The owner or operator shall prepare a startup, shutdown, or malfunction plan as required in §63.6(e)(3), except that the plan is not required to be incorporated by reference into the source's title V permit as specified in §63.6(e)(3)(i). Instead, the owner or operator shall keep the plan on record as required by §63.6(e)(3)(v). The failure of the plan to adequately minimize emissions during the startup, shutdown, or malfunction does not shield an owner or operator from enforcement actions (40 CFR Part 63 Subpart HHH § 63.1272(d)). General Standards Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 0 Page 24 3.9.5 All reports required under this subpart shall be sent to the Administrator at the appropriate address listed in §63.13. Reports may be submitted on electronic media (40 CFR Part 63 Subpart HHH § 63.1274(b)). 3.9.6 In all cases where the provisions of this subpart require an owner or operator to repair leaks by a specified time after the leak is detected, it is a violation of this standard to fail to take action to repair the leak(s) within the specified time. If action is taken to repair the leak(s) within the specified time, failure of that action to successfully repair the leak(s) is not a violation of this standard. However, if the repairs are unsuccessful, a leak is detected and the owner or operator shall take further action as required by the applicable provisions of this subpart (40 CFR Part 63 Subpart HHH § 63.1274(g)). Glycol Dehydrator Unit Process Vent Standards • 3.9.7 The owner or operator shall connect the process vent to a control device or a combination of control devices through a closed-vent system and the outlet benzene emissions from the control device(s) shall be less than 0.90 megagrams per year (1,9841bs/yr). The closed-vent system shall be designed and operated in accordance with the requirements of §63.1281(c) (Conditions 3.9.9 through 3.9.11). The control device(s) shall be designed and operated in accordance with the requirements of §63.1281(d) (Conditions 3.9.12 and 3.9.13), except that the performance requirements specified in §63.1281(d)(1)(i) and (ii) do not apply (40 CFR Part 63 Subpart HHH § 63.1275(bX1)(ii)). Benzene emissions from the glycol dehydrator are limited to less than 1,984 pounds per year of benzene as specified in Condition 3.5 of this permit. 3.9.8 One or more safety devices that vent directly to the atmosphere may be used on the air emission control equipment installed to comply with paragraph (b)(1) of this section(40 CFR Part 63 Subpart HHH § 1275(b)(2)). Control Equipment Requirements Compliance with paragraphs (c) and (d) of this section (Conditions 3.9.9 through 3.9.13) will be determined by review of the records required by § 63.1284,the reports required by § 63.1285, by review of performance test results, and by inspections (40 CFR Part 63 Subpart HHH § 63.1281(a)). Closed-vent system requirements. 3.9.9. The closed-vent system shall route all gases, vapors, and fumes emitted from the material in a HAP emissions unit to a control device that meets the requirements specified in paragraph (d) of this section(Conditions 3.9.12 through 3.9.13) (40 CFR Part 63 Subpart HHH § 63.1281(c)(1)). Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 25 3.9.10 The closed-vent system shall be designed and operated with no detectable emissions (40 CFR Part 63 Subpart HHH § 63.1281(c)(2)). 3.9.11 If the closed-vent system contains one or more bypass devices that could be used to divert all or a portion of the gases, vapors, or fumes from entering the control device, the owner or operator shall meet the requirements specified in paragraphs (c)(3)(i) and (c)(3)(ii) of this section (Conditions 3.9.11.1 and 3.9.11.2) (40 CFR Part 63 Subpart HHH § 63.1281(c)(3)). 3.9.11.1 For each bypass device, except as provided for in paragraph (c)(3)(ii) of this section (Condition 3.9.11.2), the owner or operator shall either (40 CFR Part 63 Subpart HHH § 63.1281(c)(3)(i)): a. At the inlet to the bypass device that could divert the stream away from the control device to the atmosphere, properly install, calibrate, maintain, and operate a flow indicator that is capable of taking periodic readings and sounding an alarm when the bypass device is open such that the stream is being, or could be, diverted away from the control device to the atmosphere; or b. Secure the bypass device valve installed at the inlet to the bypass device in the non-diverting position using a car-seal or a lock-and-key type configuration. 3.9.11.2 Low leg drains, high point bleeds, analyzer vents, open-ended valves or lines, and safety devices are not subject to the requirements of paragraph (c)(3)(i) of this section (Condition 3.9.11.1) (40 CFR Part 63 Subpart HHH § 63.1281(c)(3)(ii)). Control device requirements. 3.9.12 The flare shall be designed and operated in accordance with the requirement of § 63.11(b), which are specified in Condition 3.11 (40 CFR Part 63 Subpart HHH § 63.1281(d)(1)(iii)). 3.9.13 Each control device used to comply with this subpart shall be operating at all times when gases, vapors, and fumes are vented from the emissions unit or units through the closed-vent system to the control device, as required under §63.1275, except when maintenance or repair of a unit cannot be completed without a shutdown of the control device. An owner or operator may vent more than one unit to a control device used to comply with this subpart(40 CFR Part 63 Subpart HHH § 63.1281(d)(4)(i)). Test Methods, Compliance Procedures, and Compliance Demonstrations No detectable emissions test procedure. (40 CFR Part 63 Subpart HHH § 63.1282(b)) 3.9.14 The procedure shall be conducted in accordance with Method 21, 40 CFR part 60, appendix A(40 CFR Part 63 Subpart HHH § 63.1282(b)(1)). Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit#05OPWE281 Page 26 3.9.15 The detection instrument shall meet the performance criteria of Method 21, 40 CFR part 60, appendix A, except the instrument response factor criteria in section 3.1.2(a) of Method 21 shall be for the average composition of the fluid, and not for each individual organic compound in the stream (40 CFR Part 63 Subpart HHH § 63,.1282(b)(2)). 3.9.16 The detection instrument shall be calibrated before use on each day of its use by the procedures specified in Method 21, 40 CFR part 60, appendix A (40 CFR Part 63 Subpart HHH § 63.1282(b)(3)). 3.9.17 Calibration gases shall be as follows(40 CFR Part 63 Subpart HHH § 63.1281(b)(4)): 3.9.17.1 Zero air(less than 10 parts per million by volume hydrocarbon in air); and 3.9.17.2 A mixture of methane in air at a methane concentration of less than 10,000 parts per million by volume. 3.9.18 An owner or operator may choose to adjust or not adjust the detection instrument readings to account for the background organic concentration level. If an owner or operator chooses to adjust the instrument readings for the background level, the background level value must be determined according to the procedures in Method 21 of 40 CFR part 60, appendix A(40 CFR Part 63 Subpart HHH § 63.1282(b)(5)). 3.9.19 Except as provided in paragraph (b)(6)(ii) of this section (Condition 3.9.20), the detection instrument shall meet the performance criteria of Method 21 of 40 CFR part 60, appendix A, except the instrument response factor criteria in section 3.1.2(a) of Method 21 shall be for the average composition of the process fluid not each individual volatile organic compound in the stream. For process streams that contain nitrogen, air, or other inerts which are not organic HAP or VOC, the average stream response factor shall be calculated on an inert-free basis (40 CFR Part 63 Subpart HHH § 63.1282(b)(6)(i)). 3.9.20 If no instrument is available at the facility that will meet the performance criteria specified in paragraph (b)(6)(i) of this section (Condition 3.9.19), the instrument readings may be adjusted by multiplying by the average response factor of the process fluid, calculated on an inert-free basis as described in paragraph (b)(6)(i) of this section(Condition 3.9.19)(40 CFR Part 63 Subpart HHH § 63.1282(b)(6)(ii)). 3.9.21 An owner or operator must determine if a potential leak interface operates with no detectable emissions using the applicable procedure specified in paragraph(b)(7)(i)or (b)(7)(ii) of this section (Conditions 3.9.21.1 or 3.9.21.2) (40 CFR Part 63 Subpart HHH § 63.1282(b)(7)). 3.9.21.1 If an owner or operator chooses not to adjust the detection instrument readings for the background organic concentration level, then the maximum organic concentration value measured by the detection instrument is compared directly to the applicable value for the potential Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 27 leak interface as specified in paragraph (b)(8) of this section (Condition 3.9.22) (40 CFR Part 63 Subpart HHH § 63.1282(b)(7)(i)). 3.9.21.2 If an owner or operator chooses to adjust the detection instrument readings for the background organic concentration level, the value of the arithmetic difference between the maximum organic concentration value measured by the instrument and the background organic concentration value as determined in paragraph (b)(5) of this section (condition 3.9.18) is compared with the applicable value for the potential leak interface as specified in paragraph (b)(8) of this section (Condition 3.9.22) (40 CFR Part 63 Subpart HHH § 63.1282(b)(7)(ii)). 3.9.22 A potential leak interface is determined to operate with no detectable organic emissions if the organic concentration value determined in paragraph (b)(7) (Condition 3.9.21) is less than 500 parts per million by volume (40 CFR Part 63 Subpart HHH § 63.1282(b)(8)). Control device performance test procedures 3.9.23 A flare that is designed and operated in accordance with the provisions of 40 CFR Part 63 Subpart A § 63.11(b) shall be exempt from the control device performance test procedures in 40 CFR Part 63 Subpart HHH § 63.1283(d), except for the following (40 CFR Part 63 Subpart HHH § 63.1282(d)(1)(i)): 3.9.24 An owner or operator shall design and operate each flare in accordance with the requirements specified in §63.11(b) and in paragraphs (d)(2)(i) and (d)(2)(ii) of this section (Conditions 3.9.24.1 and 3.9.24.2) (40 CFR Part 63 Subpart HHH § 63.1282(d)(2)). 3.9.24.1 The compliance determination shall be conducted using Method 22 of 40 CFR part 60, appendix A, to determine visible emissions (40 CFR Part 63 Subpart HHH § 63.1282(d)(2)(i)). 3.9.24.2 An owner or operator is not required to conduct a performance test to determine percent emission reduction or outlet organic HAP or TOC concentration when a flare is used (40 CFR Part 63 Subpart HHH § 63.1282(d)(2)(ii)). Inspection and Monitoring Requirements Closed vent system inspection and monitoring requirements 3.9.25 For each closed-vent system required to comply with this section, the owner or operator shall comply with the requirements of paragraphs (c)(2) through (7) (Conditions 3.9.26 through 3.9.31) of this section (40 CFR Part 63 Subpart HHH § 63.1283(c)(1)). Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit#05OPWE281 Page 28 3.9.26 Except as provided in paragraphs (c)(5) and (6) of this section (Conditions 3.9.29 and 3.9.30), each closed-vent system shall be inspected according to the procedures and schedule specified in paragraphs (c)(2)(i) and (ii) of this section (Conditions 3.9.26.1 and 3.9.26.2) and each bypass device shall be inspected according to the procedures of (c)(2)(iii) of this section (Condition 3.9.26.3) (40 CFR Part 63 Subpart HHH § 63.1283(c)(2)). 3.9.26.1 For each closed-vent system joints, seams, or other connections that are permanently or semi-permanently sealed (e.g., a welded joint between two sections of hard piping or a bolted or gasketed ducting flange), the owner or operator shall (40 CFR Part 63 Subpart HHH § 63.1283(c)(2)(i)): a. Conduct an initial inspection according to the procedures specified in §63.1282(b) (Conditions 3.9.14 through 3.9.22)to demonstrate that the closed-vent system operates with no detectable emissions. Inspection results shall be submitted with the Notification of Compliance Status Report as specified in §63.1285(d)(1) or(2). b. Conduct annual visual inspections for defects that could result in air emissions. Defects include,but are not limited to,visible cracks,holes, or gaps in piping; loose connections; or broken or missing caps or other closure devices. The owner or operator shall monitor a component or connection using the procedures specified in §63.1282(b) (Conditions 3.9.14 through 3.9.22) to demonstrate that it operates with no detectable emissions following any time the component or connection is repaired or replaced or the connection is unsealed. Inspection results shall be submitted in the Periodic Report as specified in §63.1285(e)(2)(iii). 3.9.26.2 For closed-vent system components other than those specified in paragraph (c)(2)(i) of this section (Condition 3.9.26.1), the owner or operator shall (40 CFR Part 63 Subpart HHH § 63.1283(c)(2)(ii)): a. Conduct an initial inspection according to the procedures specified in §63.1282(b) (Conditions 3.9.14 through 3.9.22)to demonstrate that the closed-vent system operates with no detectable emissions. Inspection results shall be submitted with the Notification of Compliance Status Report as specified in §63.1285(d)(1)or(2). b. Conduct annual inspections according to the procedures specified in §63.1282(b) (conditions 3.9.14 through 3.9.22) to demonstrate that the components or connections operate with no detectable emissions. Inspection results shall be submitted in the Periodic Report as specified in §63.1285(e)(2)(iii). c. Conduct annual visual inspections for defects that could result in air emissions. Defects include, but are not limited to, visible cracks, holes, or gaps in ductwork; loose connections; or broken or missing caps or Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 29 other closure devices. Inspection results. shall be submitted in the Periodic Report as specified in §63.1285(e)(2)(iii). 3.9.26.3 For each bypass device, except as provided for in §63.1281(c)(3)(ii) (Condition 3.9.11.2), the owner or operator shall either (40 CFR Part 63 Subpart HHH § 63.1283(c)(2)(iii)): a. At the inlet to the bypass device that could divert the steam away from the control device to the atmosphere, set the flow indicator to take a reading at least once every 15 minutes; or b. If the bypass device valve installed at the inlet to the bypass device is secured in the non-diverting position using a car-seal or a lock-and-key type configuration, visually inspect the seal or closure mechanism at least once every month to verify that the valve is maintained in the non-diverting position and the vent stream is not diverted through the bypass device. 3.9.27 In the event that a leak or defect is detected, the owner or operator shall repair the leak or defect as soon as practicable, except as provided in paragraph (c)(4) of this section(Condition 3.9.28) (40 CFR Part 63 Subpart HHH § 63.1283(c)(3)). 3.9.27.1 A first attempt at repair shall be made no later than 5 calendar days after the leak is detected. 3.9.27.2 Repair shall be completed no later than 15 calendar days after the leak is detected. 3.9.28 Delay of repair of a closed-vent system for which leaks or defects have been detected is allowed if the repair is technically infeasible without a shutdown, as defined in §63.1271, or if the owner or operator determines that emissions resulting from immediate repair would be greater than the fugitive emissions likely to result from delay of repair. Repair of such equipment shall be completed by the end of the next shutdown(40 CFR Part 63 Subpart HHH § 63.1283(c)(4)). 3.9.29 Any parts of the closed-vent system or cover that are designated, as described in paragraphs (c)(5) (i) and (ii) of this section (Conditions 3.9.29.1 and 3.9.29.2), as unsafe to inspect are exempt from the inspection requirements of paragraphs (c)(2) (i) and (ii) of this section (Conditions 3.9.26.1 and 3.9.26.2) if(40 CFR Part 63 Subpart HHH § 63.1283(c)(5)): 3.9.29.1 The owner or operator determines that the equipment is unsafe to inspect because inspecting personnel would be exposed to an imminent or potential danger as a consequence of complying with paragraph (c)(2)(i) or(ii) of this section(Conditions 3.9.26.1 and 3.9.26.2); and 3.9.29.2 The owner or operator has a written plan that requires inspection of the equipment as frequently as practicable during safe-to-inspect times. Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit#05OPWE281 Page 30 3.9.30 Any parts of the closed-vent system or cover that are designated, as described in paragraphs (c)(6) (i) and (ii) of this section (conditions 3.9.30.1 and 3.9.30.2), as difficult to inspect are exempt from the inspection requirements of paragraphs (c)(2) (i) and (ii) of this section (Conditions 3.9.26.1 and 3.9.26.2) if (40 CFR Part 63 Subpart HRH § 63.1283(c)(6)): 3.9.30.1 The owner or operator determines that the equipment cannot be inspected without elevating the inspecting personnel more than 2 meters above a support surface; and 3.9.30.2 The owner or operator has a written plan that requires inspection of the equipment at least once every 5 years. 3.9.31 Records shall be maintained as specified in §63.1284(b)(5) through (8) (40 CFR Part 63 Subpart HHH § 63.1283(c)(7)). Control device monitoring requirements 3.9.32 The owner or operator shall install and operate a continuous parameter monitoring system in accordance with the requirements of paragraphs (d)(3) through (9) of this section (Conditions 3.9.33 through 3.9.37)that will allow a determination to be made whether the control device is achieving the applicable performance requirements of §63.1281(d) (Conditions 3.9.12 and 3.9.13) or (e)(3). The continuous parameter monitoring system must meet the following specifications and requirements (40 CFR Part 63 Subpart HHH § 63.1283(d)(1)): 3.9.32.1 Each continuous parameter monitoring system shall measure data values at least once every hour and record either(40 CFR Part 63 Subpart HHH § 63.1283(d)(1)(i)): a. Each measured data value; or b. Each block average value for each 1-hour period or shorter periods calculated from all measured data values during each period. If values are measured more frequently than once per minute, a single value for each minute may be used to calculate the hourly (or shorter period) block average instead of all measured values. 3.9.32.2 The monitoring system must be installed, calibrated, operated, and maintained in accordance with the manufacturer's specifications or other written procedures that provide reasonable assurance that the monitoring equipment is operating properly (40 CFR Part 63 Subpart HHH § 63.1282(d)(1)(ii)). 3.9.33 The owner or operator shall install, calibrate, operate, and maintain a device equipped with a continuous recorder to measure the values of operating parameters appropriate for the control device as specified in either paragraph(d)(3)(i), (d)(3)(ii), or(d)(3)(iii) of this section (Condition 3.9.33.1) (40 CFR Part 63 Subpart HRH § 63.1283(d)(3)(i)). Operating Permit Number: 05OPWE281. Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 31 3.9.33.1 A continuous monitoring system that measures the following operating parameters as applicable (40 CFR Part 63 Subpart HHH § 63.1283(d)(3)(i)): a. For a flare, a heat sensing monitoring device equipped with a continuous recorder that indicates the continuous ignition of the pilot flame (40 CFR Part 63 Subpart HHH § 63.1283(d)(3)(i) (C)). 3.9.34 An excursion for a given control device is determined to have occurred when the monitoring data or lack of monitoring data result in any one of the criteria specified in paragraphs (d)(6)(i) through (d)(6)(iv) of this section (Conditions 3.9.34.1 and 3.9.34.2) being met. When multiple operating parameters are monitored for the same control device and during the same operating day, and more than one of these operating parameters meets an excursion criterion specified in paragraphs (d)(6)(i) through (d)(6)(iv) of this section (Conditions 3.9.34.1 and 3.9.34.2), then a single excursion is determined to have occurred for the control device for that operating day (40 CFR Part 63 Subpart HHH § 63.1283(d)(6)). 3.9.34.1 An excursion occurs when the monitoring data are not available for at least 75 percent of the operating hours in a day (40 CFR Part 63 Subpart HHH § 63.1283(d)(6)(iii)). 3.9.34.2 If the closed-vent system contains one or more bypass devices that could be used to divert all or a portion of the gases, vapors, or fumes from entering the control device, an excursion occurs when (40 CFR Part 63 Subpart HHH § 63.1283(d)(3)(iv)): a. For each bypass line subject to §63.1281(c)(3)(i)(A) (Condition 3.9.26.1.a) the flow indicator indicates that flow has been detected and that the stream has been diverted away from the control device to the atmosphere. b. For each bypass line subject to §63.1281(c)(3)(i)(B) (Condition 3.9.26.1.b), if the seal or closure mechanism has been broken, the bypass line valve position has changed, the key for the lock-and-key type lock has been checked out, or the car-seal has broken. 3.9.35 For each excursion, except as provided for in paragraph (d)(8) of this section (Condition 3.9.36), the owner or operator shall be deemed to have failed to have applied control in a manner that achieves the required operating parameter limits. Failure to achieve the required operating parameter limits is a violation of this standard (40 CFR Part 63 Subpart HHH § 63.1283(d)(7)). 3.9.36 An excursion is not a violation of the operating parameter limit as specified in paragraphs (d)(8)(i) and (d)(8)(ii) of this section (Conditions 3.9.36.1 and 3.9.36.2) (40 CFR Part 63 Subpart HHH § 63.1283(d)(8)). 3.9.36.1 An excursion does not count toward the number of excused excursions allowed under paragraph (d)(8)(ii) of this section (Condition 3.9.36.2) Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 32 when the excursion occurs during any one of the following periods (40 CFR Part 63 Subpart HHH § 63.1283(d)(8)(i)): a. During a period of startup, shutdown, or malfunction when the affected facility is operated during such period in accordance with §63.6(e)(1); or b. During periods of non-operation of the.unit or the process that is vented to the control device (resulting in cessation of HAP emissions to which the monitoring applies). 3.9.36.2 For each control device, or combinations of control devices, installed on the same HAP emissions unit, one excused excursion is allowed per semiannual period for any reason. The initial semiannual period is the 6- month reporting period addressed by the first Periodic Report submitted by the owner or operator in accordance with §63.1285(e) of this subpart (40 CFR Part 63 Subpart HHH § 63.1283(d)(8)(ii)). 3.9.37 Nothing in paragraphs (d)(1)through(d)(8) of this section(Conditions 3.9.32 through 3.9.36) shall be construed to allow or excuse a monitoring parameter excursion caused by any activity that violates other applicable provisions of this subpart (40 CFR Part 63 Subpart HHH § 63.1283(d)(9)). Recordkeeping and Reporting Requirements 3.9.38 Records shall be kept as required by 40 CFR Part 63 Subpart HHH § 63.1284(a), (b), (c) and (e). 3.9.39 Reports shall be submitted as required by 40 CFR Part 63 Subpart HHH § 63.1285. 3.10 The glycol dehydrator is subject to the requirements in 40 CFR part 63 Subpart A "General Provisions", as adopted by reference in Colorado Regulation No. 8, Part E, Section I as specified in 40 CFR Part 63 Subpart HHH § 63.1274(a). These requirements include, but are not limited to the following: 3.10.1 Prohibited activities and circumvention in § 63.4. 3.10.2 Operation and maintenance requirements in § 63.6(e)(1). 3.10.3 Startup, shutdown and malfunction plan requirements in § 63.6(e)(3). 3.10.4 Performance test requirements in § 63.7. 3.10.5 Monitoring requirements in § 63.8. 3.10.6 Notification requirements in § 63.9. 3.10.7 Recordkeeping requirements in § 63.10. Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 33 3.11 The flare is subject to the following requirements from 40 CFR Part 63 Subpart A § 63.11(b): 3.11.1 Owners or operators using flares to comply with the provisions of this part 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)). 3.11.2 Flares shall be steam-assisted, air-assisted, or non-assisted(40 CFR Part 63 Subpart A § 63.11(b)(2)). 3.11.3 Flares shall be operated at all times when emissions may be vented to them (40 CFR Part 63 Subpart A § 63.11(b)(3)). 3.11.4 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. Test Method 22 in appendix A of part 60 of this chapter shall be used to determine the compliance of flares with the visible emission provisions of this part. The observation period is 2 hours and shall be used according to Method 22. (40 CFR Part 63 Subpart A § 63.11(b)(4)) Compliance with the visible emission requirements shall be monitored by conducting a visible emission observation monthly when the flare is operating. Monthly observations shall last a minimum of five minutes. If no visible emissions are present during this observation, in the absence of credible evidence to the contrary, the flare will be considered in compliance with the above visible emissions requirement. If visible emissions are present during the monthly reading, a two (2) hour observation shall be conducted in accordance with Method 22 to determine if the flare is in compliance with the above visible emissions requirement. If visible emissions are present for five minutes or less (total) during the two-hour observation, then the flare shall be deemed in compliance. If visible emissions are present for more than five minutes (total) during the two-hour observation, then the flare shall be deemed out of compliance with the above visible emissions requirement. Subject to the provisions of C.R.S. § 25-7-123.1 and in the absence of credible evidence to the contrary, exceedance of the visible emission requirement shall be considered to exist from the time a Method 22 reading is taken that shows the flare is out of compliance (as defined above) until a Method 22 reading is taken that shows the flare is in compliance (as defined above). 3.11.5 Flares shall be operated with a flame present at all times. The presence of a flare pilot flame shall be monitored using a thermocouple or any other equivalent device to detect the presence of a flame (40 CFR Part 63 Subpart A § 63.11(b)(5))). The device must meet the specific requirements specified in Conditions 3.9.32 and 3.9.33. Records of the times and duration of all periods of pilot flame outages, and estimated emissions shall be maintained and made available to the Division upon request. Estimated emissions shall be used as specified in Condition 3.5.4.3 to monitor compliance with the VOC and benzene emission limitation in Condition 3.5 Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit#05OPWE281 Page 34 3.11.6 Flares shall be used only with the net heating value of the gas being combusted being 11.2 MJ/scm (300 Btu/scf) or greater if the flare is steam-assisted or air-assisted; or with the net heating value of the gas being combusted being 7.45 MJ/scm (200 Btu/scf) or greater if the flare is nonassisted (40 CFR Part 63 Subpart A § 63.11(b)(6)(ii)). The net heating value of the gas being combusted shall be calculated using the equation specified in 40 CFR Part 63 Subpart A § 63.11(b)(6)(ii). 3.11.7 Air-assisted flares shall be designed and operated with an exit velocity less than the velocity, Vm , as determined by 40 CFR Part 63 Subpart A § 63.11(b)(8) (40 CFR Part 63 Subpart A § 63.11(b)(8)). The actual exit velocity of a flare shall be determined by dividing by the volumetric flow rate of gas being combusted (in units of emission standard temperature and pressure), as determined by Test Method 2, 2A, 2C, or 2D in appendix A to 40 CFR part 60 of this chapter, as appropriate, by the unobstructed (free) cross-sectional area of the flare tip (40 CFR Part 63 Subpart A § 63.11(b)(7)(i)). 3.12 Emissions from the amine unit regenerator (still) vent shall be routed through a closed vent system to the Sulfa Treat H2S control system prior to being emitted. The SulfaTreat H2S control system shall be operated and maintained to reduce H2S emissions from the amine unit regenerator(still) vent by 75%or greater(Colorado Construction Permit 03WE0916). The outlet H2S concentration shall be continuously monitored in order to determine when the SulfaTreat material must be replaced. The permittee shall keep records from the manufacturer which indicate the H2S outlet concentration level that requires replacement of the SulfaTreat material. In the absence of credible evidence to the contrary, compliance with the 75% reduction requirement shall be presumed provided the SulfaTreat unit and associated H2S monitoring system are operated and maintained in accordance with manufacturer's recommendations and good engineering practices. Records of the times and duration of all periods the SulfaTreat unit was not operating and estimated emissions shall be maintained and made available to the Division upon request. Estimated emissions shall be used as specified in Condition 3.5.4.3 to monitor compliance with the H2S emission limitations in Condition 3.5. Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 35 4. EG-6141-Caterpillar, Model No. 3516B LE,Emergency Generator Rated at 1557 hp Parameter Permit Limitations Compliance Monitoring Condition Emission Factor Number Short Term Long Term Method Interval NOx 4.1. N/A N/A I g/hp-hr Recordkeeping Annually and Calculation CO N/A N/A 3.04 g/hp-hr Hours of 4.2. N/A N/A N/A Recordkeeping Annually Operation Opacity 4.3. Not to Exceed 20% N/A Fuel Restriction Only Natural Gas is Used as Fuel 4.1 The emission factors listed above have been approved by the Division and shall be used to calculated emissions from the emergency generator (from the manufacturer). Annual emissions of Nitrogen Oxide (NOx) and Carbon Monoxide (CO) emissions for purposes of APEN reporting and payment of annual fees shall be determined using the above emission factors, the maximum horsepower (1557 hp)and the hours of operation (as required by Condition 4.2) the following equation: Tons/yr=[EF(g/hp-hr)x hour of operation(hrs/yr)x maximum hpl [(453.6 g/lb)x(2000 lbs/ton)] 4.2 Hours of operation shall be monitored annually and recorded in a log to be made available to the Division upon request. Recorded data shall be used to calculate emissions as required by Condition 4.1. Note that if annual hours of operation exceed 250 hours in any year, the engine is no longer exempt from the permitting requirements in Colorado Regulation No. 3, Part B and the permittee shall submit an application to revise this permit within 30 days in order to include the appropriate applicable requirements. 4.3 No owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section II.A.1). In the absence of credible evidence to the contrary, compliance with the above opacity requirements shall be presumed since only natural gas is used permitted to be as fuel in this engine. The permittee shall maintain records that verify that only natural gas is used as fuel in this engine. 5. Portable Monitoring (6/1/06 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 the quarterly Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit#05OPWE281 Page 36 tests. Note that if the unit is operated for less than 100 hrs in any quarterly period,then the portable monitoring requirements do not apply. All portable analyzer testing required by this permit shall be conducted using the Division's Portable • Analyzer Monitoring Protocol (ver March 2006 or newer)as found on the Division's website at: http://wwvv.cdphe.state.co.us/ap/down/portanalyzeproto.pdf Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual or short term emission limit,the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year(whichever applies)in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year(8760), whichever applies. If the portable analyzer results indicate compliance with both the NOx and CO emission limitations, in the absence of credible evidence to the contrary,the source may certify that the unit is in compliance with both the NOx and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOx or CO emission limitations,the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOx and CO emission limitations or until the unit is taken offline. For comparison with the emission rates/factors, the emission rates/factors determined by the portable analyzer tests and approved by the Division shall be converted to the same units as the emission rates/factors in the permit. If the portable analyzer tests shows that either the NOx or CO emission rates/factors are greater than the relevant ones set forth in the permit, and in the absence of subsequent testing results to the contrary(as approved by the Division),the permittee shall apply for a modification to this permit to reflect, at a minimum,the higher emission rate/factor within 60 days of the completion of the test. Results of all tests conducted shall be kept on site and made available to the Division upon request. Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 37 SECTION III- Permit Shield Regulation No. 3, 5 CCR 1001-5, Part C, §§ I.A.4, V.D., &XIII.B and § 25-7-114.4(3)(a), C.R.S. 1. Specific Conditions Based on 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 modification or reconstruction on which construction commenced prior to permit issuance. The source did not specifically identify and justify any non-applicable requirements to be included in the permit shield. 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 Acid 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. 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. Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 38 Permit Condition Streamlined(Subsumed)Requirements Section II,Condition 40 CFR Part 60 Subpart GG § 60.332(b)(as adopted by reference in Regulation No. 6,Part 1.2.1.1 A, Subpart GG) [Nitrogen Oxide emissions shall not exceed 189.5 ppmvd at 15% oxygen and ISO standard day conditions] Section II,Condition 1.4.1 40 CFR Part 60 Subpart GG §60.334(h)(3),as adopted by reference in Colorado Regulation No.6,Part A[source shall monitor the sulfur content of the fuel] Section II,Conditions Colorado Regulation No. 6, Part B, Section II.C.2 [particulate matter emissions shall not 1.5.1 and 2.4 exceed 0.5(FI)4126 lbs/MIVVIBtu]—State Only Requirement Section II,Conditions 1.7 Colorado Regulation No. 6,Part B, Section II.C.3 [opacity of emissions shall not exceed and 2.7 20%]-State Only Requirement Section II,Condition 1.4.2 Colorado Regulation No. 6, Part B, Section II.D.3.a [SO2 emissions shall not exceed 0.8 lbs/MMBtu]—State Only Requirement Section II,Conditions 1.8 Regulation No.6,Part B,Section I[general provisions]-State-only Requirement and 2.5 Section IV,Conditions 40 CFR Part 60 Subpart Dc§60.48c(i)[retain records for 2 yrs] 22.b&c Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 39 SECTION IV- General Permit Conditions 1. Administrative Changes Regulation No.3,5 CCR 1001-5,Part A, §III. 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.1. The permittee 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, §§III.B.9.,V.C.16.a.&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; (i) the compliance status of the source; (ii) whether compliance was continuous or intermittent; (iii) method(s)used for determining the compliance status of the source,currently and over the reporting period; and (iv) 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 permittee 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 §§ILA.,ILB.,ILC.,II,.E.,ILF.,II.I,and II.J 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: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 40 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; (ii) Safe sampling platform(s); (iii) Safe access to sampling platform(s);and (iv) 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 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. Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 41 Nothing in this section shall abrogate the Division's authority to conduct its own performance tests)if so warranted. d. Affirmative Defense Provision for Excess Emissions during Malfunctions Note that until such time as the U.S.EPA approves this provision into the Colorado State Implementation Plan (SIP),it shall be enforceable only by the State. An affirmative defense to a claim of violation under these regulations is provided to owners and operators for civil penalty actions for excess emissions during periods of malfunction.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 evidence that: (i) The excess emissions were caused by a sudden,unavoidable breakdown of equipment,or a sudden, unavoidable failure of a process to operate in the normal or usual manner,beyond the reasonable control of the owner or operator; (ii) The excess emissions did not stem from any activity or event that could have reasonably been foreseen and avoided,or planned for,and could not have been avoided by better operation and maintenance practices; (iii) Repairs were made as expeditiously as possible when the applicable emission limitations were being exceeded; (iv) The amount and duration of the excess emissions(including any bypass)were minimized to the maximum extent practicable during periods of such emissions; (v) All reasonably possible steps were taken to minimize the impact of the excess emissions on ambient air quality; (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; (viii) The excess emissions were not part of a recurring pattern indicative of inadequate design,operation,or maintenance; (ix) At all times,the facility was operated in a manner consistent with good practices for minimizing emissions. This section 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;and (x) During the period of excess emissions,there were no exceedances of the relevant ambient air quality standards established in the Commissions' Regulations that could be attributed to the emitting source. The owner or operator of the facility experiencing excess emissions during a malfunction shall notify the division verbally as soon as possible, but no later than noon of the Division's next working day, and shall submit written notification following the initial occurrence of the excess emissions by the end of the source's next reporting period. 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 failures to meet federally promulgated performance standards or emission limits, including,but not limited to,new source performance standards and national emission standards for hazardous air pollutants. The affirmative defense provision does not apply to state implementation plan (sip) limits or permit limits that have been set taking into account potential emissions during malfunctions,including,but not necessarily limited to,certain limits with 30-day or longer averaging times, limits that indicate they apply during malfunctions,and limits that indicate they apply at all times or without exception. Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 050PWE281 Page 42 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 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; (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. Operating Permit Number: 050PWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 43 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 shall 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, SS 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 permittee,including 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. Any 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. Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 44 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. 5. 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 malfunction 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 Regulation No.3,5 CCR 1001-5,Part C, &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. §&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.R.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. Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 45 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, &III.D.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.1. 10. Inspection and Entry Regulation No. 3,5 CCR 1001-5,Part C, 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, &&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. 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, &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. Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit#05OPWE281 Page 46 15. Off-Permit Changes to the Source Regulation No.3,5 CCR 1001-5,Part C.&XII.B. The permittee 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, &&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.,II.D.,HI.N.,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 1001-5,Part C, &&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 term. Permit expiration terminates the permittee's right to operate unless a timely and complete renewal application is submitted. 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, &.II.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, &V.C.7.b. The permittee shall promptly report any deviation from permit requirements, including those attributable to malfunction conditions as defined in the permit,the probable cause of such deviations,and any corrective actions or preventive measures taken. Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 47 "Prompt"is defmed as follows: a. Any defmition of"prompt"or a specific timeframe for reporting deviations provided in an underlying applicable requirement as identified in this permit;or b. Where the underlying applicable requirement fails to address the time frame for reporting deviations,reports of deviations will be submitted based on the following schedule: (i) For emissions of a hazardous air pollutant or a toxic air pollutant(as identified in the applicable regulation) that continue for more than an hour in excess of permit requirements,the report shall be made within 24 hours of the occurrence; (ii) For emissions of any regulated air pollutant,excluding a hazardous air pollutant or a toxic air pollutant that continue for more than two hours in excess of permit requirements,the report shall be made within 48 hours;and (iii) For all other deviations from permit requirements,the report shall be submitted every six(6)months, except as otherwise specified by the Division in the permit in accordance with paragraph 22.d.below. c. If any of the conditions in paragraphs b.i or b.ii above are met,the source shall notify the Division by telephone (303-692-3155)or facsimile(303-782-0278)based on the timetables listed above. [Explanatory note: Notification by telephone or facsimile must speck that this notification is a deviation report for an Operating Permit.) A written notice,certified consistent with General Condition 2.a.above(Certification Requirements),shall be submitted within 10 working days of the occurrence. All deviations reported under this section shall also be identified in the 6-month report required above. "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, S 7I.:Part C, 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 defmed 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. Permittees 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 Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 48 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 permittee 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 compliance assurance monitoring rule,or the Division requires submission on a more frequent basis. All instances of deviations from any permit requirements must be clearly identified in such reports. e. The permittee 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. Permittees 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. Reopenings for Cause Regulation No.3, 5 CCR 1001-5,Part C, §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(b)(10)Changes Regulation No.3.5 CCR 1001-5,Part C, §XII.A. 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. Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 49 25. Severability Clause Regulation No.3,5 CCR 1001-5,Part C, &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. 26. Significant Permit Modifications Regulation No.3,5 CCR 1001-5,Part C, III.B.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 1 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, 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, &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, &§III&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 Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company Colorado Operating Permit Cheyenne Plains Compressor Station Permit#05OPWE281 Page 50 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. 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: 05OPWE281 Issued: DRAFT 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 *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: 05OPWE281 Issued: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix A Inspection Information Page 1 APPENDIX A-Inspection Information Directions to Plant: Cheyenne Plains Compressor Station is located approximately 4 miles north of Rockport in Weld County on Highway 85. Safety Equipment Required: Eye Protection Hard Hat Safety Shoes Hearing Protection Fire Retardant Clothing (i.e NOMEX®) Facility Plot Plan: Figure 1 (following page) shows the plot plan as submitted on April 20, 2005 with additional information used to support the processing of the Title V renewal permit for the Cheyenne Compressor Station(95OPWE090). 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. Insignificant activities and/or sources of emissions as submitted in the application are as follows: Units with emissions less than APEN de minims-criteria pollutants(Reg 3, Part C.II.E.3.b) Emergency shutdowns (VOC emissions <2 tons/yr) Fugitive VOC emissions from Equipment leaks(VOC emissions <2 tons/yr) Compresser blowdowns(VOC emissions<2 tons/yr) Turbine startups (VOC emissions<2 tons/yr) Fuel (gaseous)burning equipment<5 mmBtu/hr(Reg 3, Part C.II.E.3.k) Utility heater,4.5 mmBtu/hr Glycol dehydrator reboiler(4.97 mmBtu/hr total,two burners, each 2.485 mmBtu/hr) Operating Permit Number: 05OPWE281 Issued: DRAFT — REFERENCE DRAWINGS TT),2s __ • • I 3 T11N w ^-----.---- N 5 E h W 0+00'MOO COORDNDE 5/R-.RES. I BI �k a ..P.EP.Ea. , JAm' Assocwn ]/e'.xeaw\ E'x • a/e•r x[aw ,b.N. I • =g�fi ear i ik RE5bENf.Ex =I_ 'I S 310.. 8 I lea till W MK n T1 I wx �rlr � 1,:,;:. , ! I 11 x j �• i cD c ij F=a xaw,,,aoo I "� i e� I I j \ m_`aaa Jam' j j 1j• CD • 3 j Trltllwl� -'j II T 1 (WIC) a 'T w i j • \ a a aea.., JS o f I • R▪ i<R�R ; JEe l I I e ,( �I W n ® I N A .....• .. _. jRg `1` h, 4, I CHEYENNE COMPRESSOR MAHON §I T --9(.91 War O V i! I . • i I 0.' I ,..1.25, a ea,,.'1 � =;��—�LA •— III �= r' !I . 'g -O 1 I — - ; I l!g Poo « li . 1:1,7141;',g li, Cn j o owe • R x'. . • 1I m'Raw a'MAO'iC)_CHETENN6-iPNl9l/.TEq_5.,2+F5'-0• `._ I 'Lp'LL !IMF*-1W3'.011.. . /%�f � - 11304 ------ ;-/ i. // T I— (WIC)TRAIII U2ER MEIER 5TATbxI �1 1, i�• , 1 e. WE B.J R p ' Ii �___ gvbi.eMo�-ia xAih j t____�__ it�__-I•_ �?SCRPORS µF<S• �- —_ ---- --- or,N4m1 WN e11% ®` i-e.= I . ? - I R �:I■ I e sl.w Pro m� __ WE 4W4 • i,+ _ j- =4 —LOD, \+ _ I EA:PONe MEn5.yI-- ___ Exeemsmu I\ � I ".—___ , -x,,_50.a, x .rr �__—__ __—__—Co*ji:2.a'� — _ —______ T--__I ' ,',:_' —'t]umER 0EA£ H A .4.ens--aw•.I+ �� .e ^n�wai.cawm�'es5m. Ix. _ s_ IMO x•W MOSE II Eo4weiioR RW.idbf"o..wa °_=.4 ----- ____ �-,w aro37IWO)-ate a i II W35/04 wwsEExnn/wao RED NER nxwvw'Gu: Ii5om � ____— F I .� Inn]i5 EEOOB•R&RID _ ; �! I ,._R.- NO."DM R aEaaw ON sm...01s.e. REVISIONS I ---_ We4.5 `]' LCheyenne.Plains i I w ,m-W1-0-2A 11 0000Milli Gas Pipeline Company,LLC g T _ _____ __i__—J i , II PLOT PLAN 1 _ ' li CHEYENNE PLAINS GAS PIPELINE CO. I m I mn..E, R.3 I sI -I______)I a,M,,=w,. �µl' e5 CHEYENNE TREATING & COMPRESSION• COLORADO __—__—__—on c-TmN—__—_ 4wRa+.�a it-1.-If' " e law C.O.. 011Isn 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 2/20/07 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 requirements, including those attributable to malfunctions as defined in this Appendix, the probable cause of Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 2 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, "malfunction" shall refer to both emergency conditions and malfunctions. 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 as set forth in General Condition 21. 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 40CFR 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 40CFR Part 64 (the Compliance Assurance Monitoring (CAM)Rule)has occurred. 9=Other: When the deviation is not covered by any of the above categories 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 Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 3 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; • Whether or not the method(s) used by the owner or operator for determining the compliance status with each permit term and condition during the certification period was the method(s) specified in the permit. 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. Startup, Shutdown,Malfunctions and Emergencies Understanding the application of Startup, Shutdown, Malfunctions and Emergency 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 ' 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. Operating Permit Number: 05OPWE281 Issued: DRAFT • Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 4 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. Emergency Provisions Under the Emergency provisions of Part 70 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. • Operating Permit Number: 050PWE281 Issued: DRAFT 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 the Monitoring and Permit Deviation report to be submitted to the Division as set forth in General Condition 21. 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 malfunction 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 malfunctions)may be referenced and the form need not be filled out in its entirety. FACILITY NAME: Cheyenne Plains Gas Pipeline Company—Cheyenne Plains Compressor Station OPERATING PERMIT NO: 05OPWE281 REPORTING PERIOD: (see first page of the permit for specific reporting period and dates) Deviations Noted Deviation Malfunction/ During Period?' Code2 Emergency Condition Operating Reported During Permit Unit Period? ID Unit Description YES NO '1 YES NO CP CG-7101 Solar Taurus Natural Gas Fired Turbine,Model No. 70-10302S,Serial No. 0251B. The turbine is rated at 9,816 hp and 71.42 mmBtu/hr. CP CG-7201 Solar Taurus Natural Gas Fired Turbine,Model No. 70-10302S, Serial No. 0250B. The turbine is rated at 9,816 hp and 71.42 mmBtu/hr. CP CG-7301 Solar Taurus Natural Gas Fired Turbine,Model No. 70-10302S, Serial No. 0286B. The turbine is rated at 9,816 hp and 71.42 mmBtu/hr. H-8701 Heatec,Model No.VHC1-16010-40-G, Serial No. 04-074-151,Natural Gas Fired Hot Oil Heater, Rated at 45 mmBtu/hr. This heater is part of the amine treatment unit H-8701 Heatec,Model No. VHCI-16010-40-G,Serial No. 04-074-152,Natural Gas Fired Hot Oil Heater, Rated at 45 mmBtu/hr. This heater is part of the amine treatment unit FL-8921 Flare Vent: Emissions from the glycol dehydrator regenerator(still)vent and flash tank and the amine unit flash tank are routed to the flare. The glycol dehydrator and amine unit are each rated at 300 mmSCF/day. The flare is rated at 13.54 mmBtu/hr. ST-8931 Amine Unit Regenerator(CO2)Vent. Amine unit is rated at 300 mmSCF/day. CP EG-6141 Caterpillar,Model No.3516B LE,Serial No. CTW00511,4-Cycle Lean Burn Natural Gas-Fired Internal Combustion Engine,rated at 1557 hp and 10.95 mmBtu/hr. This engine is used to drive an emergency generator. Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 6 Deviations Noted Deviation Malfunction/ During Period?' Code2 Emergency Condition Operating Reported During Permit Unit Period? ID Unit Description YES NO YES NO 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. 2 Use 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 8=CAM: A situation in which an excursion or exceedance as defined in 40CFR 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: 05OPWE281 Issued: DRAFT 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: Cheyenne Plains Gas Pipeline Company—Cheyenne Plains Compressor Station OPERATING PERMIT NO: 05OPWE281 REPORTING PERIOD: Is the deviation being claimed as an: Emergency Malfunction 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 Malfunctions/Emergencies Reported(if applicable) Deviation Code Division Code QA: SEE EXAMPLE ON THE NEXT PAGE Operating Permit Number: 05OPWE281 Issued: DRAFT 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: 1/1/04 - 6/30/06 Is the deviation being claimed as an: Emergency Malfunction 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 4/10/06 END- 1800 4/10/06 Action Taken to Correct the Problem Line Blown Out Measures Taken to Prevent Reoccurrence of the Problem Replaced Line Filter Dates of Malfunction/Emergencies Reported(if applicable) 5/30/06 to A. Einstein,APCD Deviation Code Division Code QA: Operating Permit Number: 05OPWE281 Issued: DRAFT 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: Cheyenne Plains Gas Pipeline Company—Cheyenne Plains Compressor Station FACILITY IDENTIFICATION NUMBER: 1230051 PERMIT NUMBER: 05OPWE281 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: 05OPWE281 Issued: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix C Compliance Certification Report Page 1 APPENDIX C Required Format for Annual Compliance Certification Reports with codes ver 2/20/07 Following is the format for the Compliance Certification report to be submitted to the Division and the U.S. EPA annually based on the effective date of the permit. The Table below must be completed for all equipment or processes for which specific Operating Permit terms exist. FACILITY NAME: Cheyenne Plain Gas Pipeline Company—Cheyenne Plains Compressor Station OPERATING PERMIT NO: 05OPWE281 REPORTING PERIOD: 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- Permit Reported Method per Continuous or Intermittent?3 Unit ID Permit?2 Previous Current YES NO Continuous Intermittent CP CG- Solar Taurus Natural Gas Fired 7101 Turbine,Model No.70-10302S,Serial No.0251B. The turbine is rated at 9,816 hp and 71.42 mmBtu/hr. CP CG- Solar Taurus Natural Gas Fired 7201 Turbine,Model No.70-10302S,Serial No.0250B. The turbine is rated at 9,816 hp and 71.42 mmBtu/hr. CP CG- Solar Taurus Natural Gas Fired 7301 Turbine,Model No.70-10302S, Serial No.0286B. The turbine is rated at 9,816 hp and 71.42 mmBtu/hr. H-8701 Heatec,Model No.VHC1-16010-40- G,Serial No.04-074-151,Natural Gas Fired Hot Oil Heater,Rated at 45 mmBtu/hr. This heater is part of the amine treatment unit Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix C Compliance Certification Report Page 2 Operating Unit Description Deviations Monitoring Was Compliance- Permit Reported 1 Method per Continuous or Intermittent?3 Unit ID Permit?2 Previous Current YES NO Continuous Intermittent H-8701 Heatec,Model No.VHC1-16010-40- G, Serial No.04-074-152,Natural Gas Fired Hot Oil Heater,Rated at 45 mmBtu/hr. This heater is part of the amine treatment unit FL-8921 Flare Vent: Emissions from the glycol dehydrator regenerator(still)vent and flash tank and the amine unit flash tank are routed to the flare. The glycol dehydrator and amine unit are each rated at 300 mmSCF/day. The flare is rated at 13.54 mmBtu/hr. ST-8931 Amine Unit Regenerator(CO2)Vent. Amine unit is rated at 300 mmSCF/day. CP EG- Caterpillar,Model No.3516B LE, 6141 Serial No.CTW00511,4-Cycle Lean Burn Natural Gas-Fired Internal Combustion Engine,rated at 1557 hp and 10.95 mmBtu/hr. This engine is used to drive an emergency generator. General Conditions Insignificant Activities 4 If deviations were noted in a previous deviation report , 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. 3 Note whether the compliance status with of 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. NOTE: The Periodic Monitoring requirements 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 can demonstrate whether it 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 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. 4 Compliance status for these sources shall be based on a reasonable inquiry using readily available information. Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix C Compliance Certification Report Page 3 II. 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 All information for the Annual Compliance Certification 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. 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: 05OPWE281 Issued: DRAFT 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-B1 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 1595 Wynkoop Street Denver, CO 80202-1129 Permit Modifications, Off Permit Changes: Office of Partnerships and Regulatory Assistance Air and Radiation Programs, 8P-AR U.S. Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver, CO 80202-1129 Operating Permit Number: 05OPWE281 Issued: DRAFT 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 EF - Emission Factor EPA- Environmental Protection Agency FI- Fuel Input Rate in Lbs/mmBtu FR- Federal Register G- Grams Gal - Gallon GPM- Gallons per Minute HAPs- Hazardous Air Pollutants HP - Horsepower HP-HR- Horsepower.Hour(G/HP-HR=Grams per Horsepower Hour) LAER- Lowest Achievable Emission Rate LB S - 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 P - Process Weight Rate in Tons/Hr PE - Particulate Emissions PM - Particulate Matter PMIo - Particulate Matter Under 10 Microns PPM Parts Per Million Operating Permit Number: 05OPWE281 Issued: DRAFT Air Pollution Control Division E Colorado Operating Permit Appendixnge 2 Permit Acronyms PPMV Parts Per Million,by Volume PPMVD Parts Per Million,by Volume,Dry PSD - Prevention of Significant Deterioration PTE- Potential To Emit RACT- Reasonably Available Control Technology SCC - Source Classification Code 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: 05OPWE281 Issued:DRAFT 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 Operating Permit Number: 05OPWE281 Issued: DRAFT C QC V� `C J ® Cheyenne Plains � S Gas Piipelne Company,L.LC. o S al C i0 Two North Nevada Avenue s0(irCes�' Colxedo Springs CO 80903 719 473 2300 www.cheyenneplains.com December 13, 2005 Mr. Jackie Joyce Colorado Department of Public Health and Environment Air Pollution Control Division — SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Re: Title V operating. Permit Application Cheyenne Plains Gas Pipeline Dear Ms. Joyce: Enclosed, please find an original and three (3) copies of the Title V Operating Permit Application for the Cheyenne Plains Gas Pipelines ("CPGP") Compressor Station. As you know the CPGP facilities are co-located with Colorado Interstate Gas Company's Cheyenne Compressor Station. For business reasons, we are requesting a separate Title V permit for the treatment and compression associated with CPGP. You can contact me at (719) 520-4487 or via e-mail at vince.brindleyaelpaso.com if you have any questions or if you need any additional information. Sin erely Vincent L. Brindley Principal Environmental Engineer El Paso Corporation Enclosures Route: Sandra Miller, file: CO — Cheyenne Plains —Title V Barry Schatz— Briargate Gary Stuart— Cheyenne Station (Station Files) COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT OPERATING PERMIT APPLICATION Cheyenne Plains Gas Pipeline Company Cheyenne Plains Compressor Station Weld County, Colorado December 2005 RECEIVED' DEC 15 2005 Prepared for: Cheyenne Plains Gas Pipeline Company Prepared by: URS Corporation 8181 East Tufts Ave. Denver, CO 80237 TABLE OF CONTENTS Title Page 1.0 Introduction 1 2.0 Facility Emissions 2 2.1 Point Source Emissions 3 2.1.1 Internal Combustion Sources 3 2.1.2 Heaters 3 2.1.3 Amine Unit 4 2.1.4 Dehydration Unit 4 2.1.5 Flare 4 2.2 Fugitive Emissions 5 2.2.1 Equipment Leaks 5 2.2.2 Turbine Start-ups 5 2.2.3 Blowdown Emissions 5 2.2.4 Emergency Shutdown 5 2.2.5 Routine Maintenance 5 2.3 Insignificant Activities 6 3.0 Applicable Requirements 7 3.1 Permit Requirements 7 3.2 Applicable Regulation Analysis 8 3.2.1 Colorado Regulations 8 3.2.1 New Source Performance Standards 11 4.0 Compliance 12 4.1 Compliance Plan 12 4.2 Compliance Certification 12 List of Tables Table 2-1 Facility Emissions Summary Table 2-2 Facility Equipment Inventory List of Appendices Appendix A CDPHE Operating Permit Application Forms Appendix B Emissions Calculations/Data Cheyenne Plains Gas Pipeline Company i Operating Permit Application Cheyenne Plains Compressor Station November 2005 List of Acronyms percent AP-42 EPA AP-42 Emission Factors BTEX benzene, toluene, ethylbenzene, and xylene CAM Compliance Assurance Monitoring cf cubic feet CO carbon monoxide EPA Tank 4.0 U.S. Environmental Protection Agency Tanks Version 4.0 EPA U.S.Environmental Protection Agency ESD emergency shutdown ft feet gal gallons HAP hazardous air pollutant hp horsepower hr hour in inch lb pound lb/yr pounds per year m3 cubic meters MACT Maximum Achievable Control Technology min minute MMBtu 1,000,000 British thermal units Mscf 1000 standard cubic feet MMscf 1,000,000 standard cubic feet mol. molecular neg. negligible NOx nitrogen oxides NESHAPs National Emission Standards for Hazardous Air Pollutants NSPS New Source Performance Standard PM10 particulate matter, less than 10 microns psi pounds per square inch RMP Risk Management Plan scf standard cubic feet SIC Standard Industrial Classification SO2 sulfur dioxide SOx sulfur oxides tpy tons per year VOC volatile organic compound wt weight yr year Cheyenne Plains Gas Pipeline Company ii Operating Permit Application Cheyenne Plains Compressor Station November 2005 1.0 INTRODUCTION The emission sources currently located at the facility are grouped into the following categories: • Cheyenne Compressor Station (Includes Colorado Interstate Gas Units, Wyoming Interstate Company units, and Front Range Units) • Cheyenne Plains Compressor Station The Cheyenne Compressor Station has an Operating Permit #95OPWE090 that includes construction permits; 11WE 631-1, 11WE 631-2, 11WE631-3, 11WE 631-4, 13WE536- 1, 13WE526-2, 96WE039, 97WE0032, and 98WE0030. The Cheyenne Plains Gas Pipeline Company,LLC (CPGPC) and Colorado Interstate Gas Company(CIG)received construction permits for the addition of several units that make up the Cheyenne Plains Station. These include: • Construction Permit 03WE0910 o AIRS ID 123/0051/015: Solar Taurus 70 natural gas-fired compressor turbine o AIRS ID 123/0051/016: Solar Taurus 70 natural gas-fired compressor turbine • Construction Permit 04WE1390 o AIRS ID 123/0051/024: Solar Taurus 70 natural gas-fired compressor turbine • Construction Permit 03WE0913 o AIRS ID 123/0051/018: Hot Oil Heater o AIRS ID 123/0051/019: Hot Oil Heater o AIRS ID 123/0051/020: Utility Heater • Construction Permit 03WE0916 o AIRS ID 123/0051/021: Amine System Regenerator Vent o AIRS ID 123/0051/022: Flare The compression is required as part of a project to provide transmission capacity through the construction of a new natural gas pipeline. These compression and treatment projects are collectively referred to as the Cheyenne Plains Compressor Station. This Colorado Department of Public Health and Environment Operating Permit application includes detailed information on facility operations and associated emissions of all regulated pollutants of concern. The emission units are described in Section 2.0. The completed permit application forms are contained in Appendix A, and supporting calculation documentation is contained in Appendix B. Cheyenne Plains Gas Pipeline Company 1 Operating Permit Application Cheyenne Plains Compressor Station November 2005 2.0 FACILITY EMISSIONS Emission sources at the Cheyenne Plains Compressor Station include both point and fugitive sources. All facility emission source types are summarized as follows, with emissions from these sources summarized in Table 2-1. Emissions are shown in detail in Appendix B. • Compressor turbines • Heaters • Amine System • Glycol Dehydration System • Flare • Fugitive equipment leaks • Turbine startups • Compressor blowdowns • Routine maintenance (Emergency Shutdown [ESD] system operation) Table 2-1.Facility Emissions Summary Pollutant Emissions (tpy) NO, 105.75 CO 153.93 VOC 58.55 SO2 3.27 PMio 9.57 Single Greatest HAP (Benzene) 8.16 Total HAPs 13.87 Cheyenne Plains Gas Pipeline Company 2 Operating Permit Application Cheyenne Plains Compressor Station November 2005 The facility equipment inventory is summarized in Table 2-2. Table 2-2.Facility Equipment Inventory AIRS ID I Site ID I Source Usage I Source Description Significant Emissions 015 CG-1 Compression 9816 hp Solar Taurus 70 016 CG-2 Compression 9816 hp Solar Taurus 70 024 CG-3 Compression 9816 hp Solar Taurus 70 018 H-8701 Hot Oil Heater 45.00 MMBtu/hr Heater 019 H-8702 Hot Oil Heater 45.00 MMBtu/hr Heater 021 ST-8931 Amine Vent 13.00 MMscfd Hanover 022 FL-8921 Flare 13.54 MMBtu/hr Flare Insignificant Emissions 020 H-6111 Backup Utility Heater 16.00 MMBtu/hr Heater --- H-8721 Glycol Reboiler 4.97 MMBtu/hr Heater --- --- Glycol Dehydrator 300.00 scfd Dehydrator --- - Fugitive Emissions Equipment Leaks --- --- Fugitive Emissions Turbine Startups --- --- Fugitive Emissions Compressor Blowdowns --- -- Fugitive Emissions Emergency Shutdowns 2.1 Point Source Emissions Point source emissions operated at Cheyenne Plains Compressor Station include three Solar turbines, four heaters, an amine vent, a glycol dehydrator, and a flare. 2.1.1 Internal Combustion Sources Three Solar Taurus 70 natural gas fired compressor turbines (CG-1, CG-2, and CG-3) are operated at Cheyenne Plains Compressor Station. All three units are equipped with SoLoNOx and site-rated at 9,816 hp. Emissions of nitrogen oxides (NOx), carbon monoxide (CO), and volatile organic compounds (VOC) are calculated based on Best Available Control Technology (BACT) limits established in Construction Permits 03WE0910 and 04WE1390. Sulfur dioxide (SO2), particulate matter(PM10), and all hazardous air pollutants (HAPs) were estimated based on AP-42 emission factors. Emission factors and calculated potential emissions are presented in Appendix B. 2.1.2 Heaters Four natural gas fired heaters are operated at Cheyenne Plains Compressor Station. The two significant units, H-8701and H-8702, are 45.00 MMBtu/hr units used as hot oil Cheyenne Plains Gas Pipeline Company 3 Operating Permit Application Cheyenne Plains Compressor Station November 2005 heaters in the amine unit. The two insignificant units are a 16.00 MMBtu/hr unit, H- 6111, used for backup and a 4.97 MMBtu/hr unit, H-8721, used as a glycol reboiler. For units H-8701 and H-8702, emissions of NOR, CO, and VOC are calculated based on BACT limits established in Construction Permit 03WE0913. Recently, Cheyenne Plains Gas Pipeline Company submitted a request that this Construction Permit be modified to: • Allow a higher NOR emission limit for H-8701 and H-8702 for low load conditions. • Include a requirement to track the number of hours operated on units H-8701 and H-8702 below 50% load. • Change Heater H-6111 to a backup unit with an operating limit of 500 hours per year, which makes the unit insignificant and APEN-exempt. For unit H-8721, NOR, CO, and VOC emissions are estimated based on manufacturer's specifications, and for unit H-6111 NOR, CO, and VOC emissions are estimated based on AP-42 emission factors. For both units, SO2, PM10, and all HAPs were estimated based on AP-42 emission factors. Emission factors and calculated potential emissions are presented in Appendix B. 2.13 Amine Unit The amine unit consists of a single treatment train rated at 300 million standard cubic feet per day (MMscfd). The unit includes an amine treatment skid(contactor tower, pumps, piping, etc.) with dual hot oil heaters rated at 45 MMBtu/hr. Emissions from the flash tank are routed to a flare, and potential emissions from the regenerator vent are calculated using American Petroleum Institute (API) AMINECalc. Calculated potential emissions and the AMINECaIc output are presented in Appendix B. 2.1.4 Dehydration Unit A glycol dehydration unit is used to remove entrained water from the natural gas stream after it is treated in the amine system. This system is also rated at 300 MMscfd. The wet glycol mixture is dried using a glycol reboiler rated at 4.97 MMBtu/hr. Both the flash tank and regenerator vents are routed to a flare, and controlled emissions for this unit are described below. 2.1.5 Flare The amine unit flash tank vent, dehydrator regenerator vent, and dehydrator flash tank vent are sent to a flare. The flare is rated at approximately 13.54 MMBtu/hr, and the VOC destruction efficiency is 98%. Potential emissions of NOR, CO, and VOC are based on emission limits established in Construction Permit 03WE0916. Emissions of benzene, hexane, and toluene are estimated by Gas Research Institute (GRI) GLYCalc and API AMINECaic. Emissions from the flare and the GLYCalc and AMINECalc output files are presented in Appendix B. Cheyenne Plains Gas Pipeline Company 4 Operating Permit Application Cheyenne Plains Compressor Station November 2005 2.2 Fugitive Emissions Fugitive emissions include those from equipment leaks, engine startups, engine blowdowns, and routine maintenance involving ESD system testing. 2.2.1 Equipment Leaks The number of equipment components including connections, flanges, open-ended lines, pump seals, valves, and other components were used to estimate VOC and HAP emissions from equipment leaks with GRI HAPCalc 3.0. The HAPCalc output file can be found in Appendix B. 2.2.2 Turbine Start-ups Emissions resulting from gas-driven startups were estimated based on average gas flow rate through the starter, duration per start-up, and maximum number of start-ups predicted on an annual basis. Total VOC emissions were estimated based on the VOC fraction in the gas and the molecular weight of that VOC fraction. Start-up information and potential VOC emissions are summarized on the Vent Detail Sheet in Appendix B. 2.2.3 Blowdown Emissions Compressed gas is vented from the compressors when the units are shut down. The volume of gas emitted per event is used as the basis for estimating the amount of vented gas, and the data and resulting calculations are presented in Appendix B. 2.2.4 Emergency Shutdown During an Emergency Shutdown (ESD), system gas is vented to the atmosphere. The ESD system at Cheyenne Plains Compressor Station is generally tested twice a year per Department of Transportation requirements. ESD blowdown gas includes that gas volume vented from the compressors and from pipeline segments between the station ESD block valves. Compressor blowdown emissions are presented on the Vent Detail Sheet in Appendix B. 2.2.5 Routine Maintenance Routine maintenance includes activities such as pipe repair, valve replacement, equipment maintenance, and any other form of standard upkeep events. Cheyenne Plains Gas Pipeline Company 5 Operating Permit Application Cheyenne Plains Compressor Station November 2005 2.3 Insignificant Activities Insignificant emission levels are defined as individual emission points in attainment areas having uncontrolled actual emissions of any criteria pollutant of less than two tons per year [Colorado Regulation 3, Part C, II.E.3.a], and individual emission points of non- criteria reportable pollutants having uncontrolled actual emissions less than the de minimis levels [Colorado Regulation 3, Part C, II.E.3.a]. Based on the potential emission estimates presented above,the following sources are listed as insignificant activities for the Cheyenne Plains Compressor Station: • H-6111, Backup Utility Heater • H-8721, Glycol Reboiler • Glycol Dehydration Unit • Equipment Leaks • Turbine Start-ups • ESD • Blowdowns Cheyenne Plains Gas Pipeline Company 6 Operating Permit Application Cheyenne Plains Compressor Station November 2005 3.0 APPLICABLE REQUIREMENTS The Cheyenne Plains Compressor Station is located in Weld County, Colorado which is designated as an attainment area for all criteria pollutants. The Cheyenne Plains Compressor Station is considered major source for Title V under Regulation 3,Part C. For PSD Applicability the Cheyenne Plains Compressor Station is aggregated with the Cheyenne Compressor Station and is considered major for PSD and HAPs. 3.1 Permit Requirements CAQCC Regulation No. 3, Part B, §III.A requires that a construction permit be obtained prior to commencing construction or modification of a stationary source. Because the proposed Phase II source will be located at the Cheyenne Plains Gas Pipeline Company, LLC and Colorado Interstate Gas Company's existing Cheyenne Compressor Station, it meets the definition of a modification of an existing source; therefore a permit must be obtained. Because of the relatively short time span between issuance of the PSD permits for the Cheyenne Plains Project sources and the proposed installation of the Phase II source; and because of the inter-relatedness of the Phase II turbine to the permitted Taurus 70 turbines; APCD staff requested that this modification be presented as an supplement to the PSD permit application. As shown in Figures 3-1 through 3-6 of the original PSD permit application, the proposed Cheyenne Plains Project will be constructed in an area that is attainment for all criteria pollutants. The PSD program defines a major modification as a project that will result in an increase in emissions in excess of the PSD major modification thresholds. The Cheyenne Plains Project and the Phase II source will result in emissions in excess of 40 tons per year(tpy) for NOx, 100 tpy for CO, and 40 tpy for VOC. Therefore, the proposed project is a major modification of a stationary source for these pollutants. For sources subject to PSD,the level of review is greater if the potential increases in emissions from the proposed new emission units are equal to or greater than the respective pollutant's significant emission rate. The pollutants subject to the PSD program and their significance levels are listed in Table 2-2, of this document. As seen in Table 2-2, PTE for NOx, CO, and VOC from the emission units exceed the applicable significant emission rates. Under CAQCC, Regulation No. 3, Part B, §IV.D.3, the PSD permitting requirements that must be met for pollutants exceeding the significant emission rate are the following: • Determination of the Best Available Control Technology §IV.D.3.a.(i); • Performance of an Source Impact Analysis,'§IV.D.3.a.(ii); • Performance of an Ambient Air Quality Analysis, §IV.D.3.a.(iii); • Determine Applicability of Post Construction Monitoring, §IV.D.3.a.(iv); • Determine Applicability of Pre-Construction Monitoring, §IV.D.3.a.(v); • Analysis of impacts to soils, vegetation, and visibility, §IV.D.3.a.(vi); and Cheyenne Plains Gas Pipeline Company 7 Operating Permit Application Cheyenne Plains Compressor Station November 2005 • Analysis of Class I area impacts. These requirements apply to pollutants that have a PTE in excess of the significant emission rate thresholds. As stated above, for the new emission units, NOx, CO, and VOC are above the significant emission rate thresholds. 40 Code of Federal Regulations (CFR)Part 63, Subpart B, requires a HAP control technology review for new major sources of HAPs. A major source is defined as emitting any individual HAP or collective HAPs in excess of 10 and 25 tpy, respectively. Because this project is a major HAP source for formaldehyde, a HAP control review is required. 3.2 Applicable Regulation Analysis To obtain a construction permit, the proposed installation of the new emission units must comply with all applicable regulations. To determine the regulations of concern, a regulatory applicability analysis must be conducted. Regulations that require an applicability determination include the CAQCC's Code of Colorado Regulations (CCR) and federal regulations. A variety of project-specific details regarding the proposed sources are necessary to determine regulatory applicability. This information is provided in this section. The project is located in Weld County, an area that is currently classified as attainment for all criteria pollutants. The facility will have NOx and CO emissions greater than 250 tons per year, and is therefore considered to be a major source subject to PSD review. The facility will also generate emissions of PM, PM10, SO2, and VOCs (the regulated compound for ozone (O3)). The following state and federal regulations are applicable to the facility. A description of how the proposed project will comply with each regulation is provided. Documentation of all calculated values is presented in Appendix A. 3.2.1 Colorado Regulations The State of Colorado has established regulations limiting the amount of PM and SO2 a source may emit to the atmosphere. It has also set opacity limitations. Colorado has adopted and incorporated by reference numerous regulations of Title 40 of the CFR, including New Source.Performance Standards (NSPS) (40 CFR Part 60), National Emission Standards for Hazardous Air Pollutants (NESHAPs) (40 CFR Part 61), and National Emission Standards for Hazardous Air Pollutants for Source Categories (MACT Standards) (40 CFR Part 63). Cheyenne Plains Gas Pipeline Company 8 Operating Permit Application Cheyenne Plains Compressor Station November 2005 Regulation No. 1 —Emission Control for Particulates,Smokes, Carbon Monoxide, and Sulfur Oxides SMOKE AND OPACITY Regulation No. 1, §II.A.1 —Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20 percent opacity. This standard is based on 24 consecutive opacity readings taken at 15-second intervals for six minutes. The approved reference test method for visible emissions measurement on which these standards are based is USEPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of§II.A and §II.B of this regulation. Regulation No. 1, §II.A.4—Fire Building, Cleaning of Fire Boxes, Soot Blowing, Start- up,Process Modification or Adjustment of Control Equipment Except as provided in Sections II.A.6, no owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, any process modification, or adjustment or occasional cleaning of control equipment, which is in excess of 30 percent opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. PARTICULATE MATTER Regulation No. 1, §III.A.1.b. For fuel burning equipment with designed heat inputs greater than lx 106 BTU per hour,but less than or equal to 500 x 10 British thermal units (Btu) per hour, the following equation will be used to determine the allowable particulate emission limitation. • PE=0.5(FI)-o.26 Where: PE=Particulate Emission in pounds per million British thermal units (lb/MMBtu) heat input. FI=Fuel Input in MMBtu/hr. • NOTE: Particulate emissions for this standard are based on filterable particulate only (i.e., front half of USEPA Method 5). Regulation No. 1, §III.D.1.a.(i)—Every owner or operator of a source or activity which is subject to this Section III.D shall employ such control measures and operating procedures as are necessary to minimize fugitive particulate emissions into the atmosphere through the use of all available practical methods which are technologically feasible and Cheyenne Plains Gas Pipeline Company 9 Operating Permit Application Cheyenne Plains Compressor Station November 2005 economically reasonable and which reduce, prevent and control emissions so as to facilitate the achievement of the maximum practical degree of air purity in every portion of the State. SULFUR DIOXIDE EMISSION REGULATIONS Regulation No. 1, §VI.B.2. -The averaging time for all new source emissions standards for SO2 shall be three hours, and any three-hour rolling average of emission rates which exceeds these standards is a violation of this regulation. ODOR Regulation No. 2, §I.A.1. -No person, wherever located, shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors, which are measured in excess of the following limits: A. For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7) or more volumes of odor free air. B. In all other land use areas, it is a violation if odors are detected after the odorous air has been diluted with fifteen (15) or more volumes of odor free air. STANDARDS OF PERFORMANCE FOR NEW STATIONARY SOURCES Regulation No. 6, Part A -Part A of this regulation adopts the 40 CFR 60 NSPS by reference. The applicability and description of these requirements are outlined in Section 3.2.2 of this document. Regulation No. 6, Part B -Part B of this regulation specifies standards of performance for new stationary sources as developed by the State of Colorado. The State developed these standards for sources unique to Colorado and for sources of concern for which federal NSPS have not yet been set. The applicable portions of Regulation No. 6, Part B restrict emissions from turbines. These restrictions mirror those established in Regulation 1 as described above. CONTROL OF HAZARDOUS AIR POLLUTANTS Regulation No. 8, Part A - Part A of this regulation adopts the 40 CFR Part 61, Chapter I, Federal NESHAPs by reference. Regulation No. 8, Part E - Part E of this regulation adopts the 40 CFR Part 63,Chapter I, Federal MACT by reference. Cheyenne Plains Gas Pipeline Company 10 Operating Permit Application Cheyenne Plains Compressor Station November 2005 Regulation No. 8, Part E. §III.Z. - NESHAPs for Source Category: Natural Gas Transmission and Storage, 40 CFR. Part 63, Subparts HHH(June 17, 1999, 64 Federal Register 32610), as amended on June 29, 2001 (66 FR 34548), and on February 22, 2002 (67 FR 8202). Additional equipment that may be affected by future MACT standards includes: Boilers and Process Heaters, Stationary Combustion Turbines, Reciprocating Internal Combustion Engines, and Organic Liquids Distribution. Turbines CG-1, CG-2, and CG-3 are subject to Initial Notification of MACT Applicability for 40 CFR 63 Subpart YYYY—National Emission Standards for Hazardous Air Pollutants for Stationary Combustion Turbines. These units are"new units" as defined by Subpart YYYY. Their compliance date is therefore upon start-up, or December 15, 2004, for CG-1 and CG-2, and March 15, 2005, for CG-3. This notification of applicability was sent to CDPHE on June 14, 2005. These units are not currently subject to emissions or operational limitations due to the stay issued by the EPA on August 18, 2004 for this turbine type. 3.2.1 New Source Performance Standards Certain NSPS of 40 CFR 60 have been adopted and incorporated by reference as Regulation No. 6,Part A. Cheyenne Plains Gas Pipeline Company 11 Operating Permit Application Cheyenne Plains Compressor Station November 2005 4.0 COMPLIANCE Compliance issues are addressed under two primary categories in the permitting process: compliance plan development and compliance certification. The former is intended to address points of non-compliance and the actions necessary to bring the facility into full compliance, while the latter addresses the manner in which compliance will be demonstrated and verified. Each aspect is discussed separately below for the Cheyenne Plains Compressor Station. 4.1 Compliance Plan No applicable requirements have been identified for the Cheyenne Plains Compressor Station for which compliance has not been achieved. A compliance plan for this facility is therefore not included in this operating permit modification application, as full compliance is addressed in the compliance certification section. 4.2 Compliance Certification No applicable requirements have been identified for existing sources at the Cheyenne Plains Compressor Station for which compliance has not been achieved. A compliance plan for this facility is therefore not included in this Title V operating permit application, as full compliance is addressed in the compliance certification section. Cheyenne Plains Gas Pipeline Company 12 Operating Permit Application Cheyenne Plains Compressor Station November 2005 Appendix A Colorado Department of Public Health and Environment Air Pollution Control Division Operating Permit Application Operating Permit Application FACILITY IDENTIFICATION FORM 2000-100 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility Name and Name Cheyenne Plains Compressor Station Mailing Address Street or Route P.O. Box 1087 City, State, Zip Code Colorado Spring, CO 80944 2. Facility location Street Address Section 5, Ti 1N, R66W (No P.O. Box) City,County, Zip Code Rockport,Weld County 3. Parent corporation Name Cheyenne Plains Gas Pipeline Company Street or Route P.O. Box 1087 City, State, Zip Code Colorado Spring, CO 80944 Country (if not U.S.) U.S. 4. Responsible Name Gary Stuart(Primary RO) Matt J.Mask(Secondary RO) Official Title Cheyenne Area Manager Director, Rocky Mountain Division Telephone 970-897-3241 719-338-5701 5. Permit Contact Person Name Barry Schatz (If Different than 4) Title Principal Environmental Scientist Telephone 719-388-5717 6. Facility SIC code: 4922 7. Facility identification code: CO 123/0051 8. Federal Tax I. D. Number: 84-1618229 9. Primary activity of the operating establishment: Natural Gas Transmission 10. Type of operating permit ❑✓ New ❑ Modified ❑ Renewal 11. Is the facility located in a "nonattainment" area: ❑ Yes ❑✓ No If "Yes", check the designated "non-attainment" pollutant(s): ❑ Carbon Monoxide ❑ Ozone ❑ PM10 ❑ Other (specify 12. List all (Federal and State) air pollution permits (including grandfathered units), plan approvals and exemptions issued to this facility. List the number, date and what unit/process is covered by each permit. For a Modified Operating Permit, do not complete this item. • Construction Permit No. 03WE0910 - March 29, 2005 — Airs ID 015 (Solar Taurus turbine) & Airs ID 016 (Solar Taurus turbine) • Construction Permit No. 04WE1390 - March 29, 2005 — Airs ID 024 (Solar Taurus turbine) • Construction Permit No. 03WE0913 - June 10, 2004 — Airs ID 018 (Hot Oil Heater), Airs ID 019 (Hot Oil Heater), Airs ID 020 (Utility Heater) - A modification request has been submitted for this permit • Construction Permit No. 03WE0916 - May 23, 2005 — Airs ID 021 (Regenerator CO2 Vent) & Airs ID 022 (Flare) Operating Permit Application FACILITY PLOT PLAN FORM 2000-101 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division Facility Name: Cheyenne Plains Compressor Station Facility Identification Code: CO 123/0051 The operating permit must be prepared and submitted on forms supplied by the Division. Use of this form is required for all operating permit applications. The Division will not consider or act upon your application unless each form used has been entirely completed. Completion of the information in the shaded area of this form is optional. Use "NA" where necessary to identify an information request that does not apply and is not in the optional shaded area. In order for a comprehensive air quality analysis to be accomplished, a facility plot plan MUST be included with the permit application. Drawings provided must fit on generic paper sizes of 8 1/2" X 11", 8 1/2" X 14" or 11"X 15", as appropriate to display the information being provided. Include the facility name and facility identification code on all sheets. For facilities with large areas, sketches of individual buildings, on separate drawings, may be needed to allow easy identification of stacks or vents. Insignificant activities do not need to be shown. ❑ 1. A plant layout (plan view) including all buildings occupied by or located on the site of the facility and any outdoor process layout. ❑ 2. The maximum height of each building (excluding stack height). ❑ 3. The location and coded designation of each stack. Please ensure these designations correspond to the appropriate stacks listed on the other permit forms in this application. The drawings need not be to scale if pertinent dimensions are annotated, including positional distances of structures, outdoor processes and free standing stacks to each other and the property boundaries. ❑ 4. The location of property boundary lines. ❑ 5. Identify direction "North" on all submittals. Are there any outdoor storage piles on the facility site with air pollution emissions that need to be reported? ❑ Yes ❑✓ No If"Yes", what is the material in the storage pile(s)? Are there any unpaved roads or unpaved parking lots on the facility site? ❑ Yes ❑✓ No List the name(s) of any neighboring state(s) within a 50 mile radius of your facility: Wyoming Operating Permit Application SOURCE AND SITE DESCRIPTIONS FORM 2000402 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division • Facility Name: Cheyenne Plains Compressor Station Facility Identification Code: CO 123/0051 The operating permit must be prepared and submitted on forms supplied by the Division. Use of this form is required for all operating permit applications. The Division will not consider or act upon your application unless each form used has been entirely completed. Completion of the information in the shaded area of this form is optional. Use "NA" where necessary to identify an information request that does not apply and is not in the optional shaded area. 1. Briefly describe the existing Unit(s) to be permitted. Attach copies of Form 2000-700 as needed to provide the information. Process flowsheets or line diagrams showing major features and locations of air pollution control equipment can be most effective in showing the location and relationships of the units. Providing mass flowrates/balances at critical points on the diagrams is very helpful when developing an understanding of the processes involved. Three (3) Solar Taurus, Model No. 70-1030S, natural gas fired combustion turbines rated at 71.42 MMBtu/hr and 9,816 hp each, equipped with dry low NOx (SoLoNOx) combustion systems to reduce NOx emissions, that power natural gas compressors. Two (2) Hot Oil Heaters rated at 45 MMBtu/hr each that are part of the amine treatment unit. One (1) Regenerator Vent rate at 13 scfd that is part of the amine treatment unit. One (1) Flare that is rated at 13.54 MMBtu/hr that is used to combust emissions from the amine unit flash tank and the glycol dehydrator flash tank and regenerator vent. 2. Site Location and Description (Include instructions needed to drive to remote sites not identifed by street addresses) Section 5, T11 N, R66W; on Highway 85, approximately 4 miles north of Rockport in Weld County, Colorado. 3. Safety Equipment Identify safety equipment required for performing an inspection of the facility: ❑✓ Eye Protection ❑✓ Other, specify Fire retardant clothing (i.e. NOMEX®) ❑✓ Hard Hat ❑✓ Safety shoes ❑ Hearing Protection ❑. Gloves Operating Permit Application SOURCE DESCRIPTION - APENS FORM 2000-102A Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division Facility Name: Cheyenne Plains Compressor Station Facility Identification Code: CO 123/0051 NOTE: Each new or updated Air Pollutant Emission Notice (APEN) submitted must be accompanied by payment of$100 per APEN. 1. For each emission unit enclose a copy of the most current complete Air Pollutant Emission Notice (APEN) on file with the Division. If the most current APEN was not completely and correctly filled out, a revised APEN is required. List an APEN number, date, and a brief description of the unit/process covered by the APEN. (No filing fees are needed for these copies) The following APENs are on file: 'AIRS ID # Stack#Source 015 CP01 9,816 hp Solar Taurus 70 turbine 016 CP02 9,816 hp Solar Taurus 70 turbine 024 CP05 9,816 hp Solar Taurus 70 turbine 021 CPT6 Amine Regenerator Vent 022 CPT5 Flare The following APENs were recently updated: AIRS ID # Stack#Source 018 CPT1 45 MMBtu/hr Hot Oil heater 019 CPT2 45 MMBtu/hr Hot Oil heater 020 CPT3 16 MMBtu/hr Utility heater 2. No APEN exists for an emission unit. List the new APEN and the appropriate descriptive information here. Submit the APEN with a construction permit application. New APEN and permit application submitted ❑with this application OR ❑ under separate cover to Construction Permits Section 3. A revised APEN was prepared and enclosed for an emission unit. List the APEN and the appropriate descriptive information here. A revised APEN is needed where a significant increase in emissions has occurred, or is planned; or a major modification of the unit has occurred or is planned; or the existing information needs correction or completion. A construction permit application may need to be submitted. Revised APEN submitted as part of this application: ❑Yes ❑✓ No ❑ Filing Fee Enclosed New permit application enclosed: ❑✓ Yes ❑ No Permit modification application enclosed: ❑ Yes ❑ No NOTE: Use additional copies of Form 2000-700 as needed to provide the above information. Operating Permit Application SOURCE DESCRIPTION - INSIGNIFICANT ACTIVITIES FORM 2000402B Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division Facility Name: Cheyenne Plains Compressor Station Facility Identification Code: CO 123/0051 NOTE:The operating permit must be prepared and submitted on forms supplied by the Division. This is a supplemental form for use only when necessary to provide complete information in the operating permit application.The Division will not consider or act upon your application unless each form used has been entirely completed. Certain categories of sources and activities are considered to be insignificant contributors to air pollution and are listed below. A source solely comprised of one or more of these activities is not required to obtain an operating permit pursuant to Regulation 3, unless the source's emissions trigger the major source threshold as defined in Part A, Section I.B.58 of Regulation 3. For the facility, mark all insignificant existing or proposed air pollution emission units, operations, and activities listed below. ❑ (a) noncommercial (in-house) experimental and analytical laboratory equipment which is bench scale in nature including quality control/quality assurance laboratories, process support laboratories, environmental laboratories supporting a manufacturing or industrial facility, and research and development laboratories. (b) research and development activities which are of a small pilot scale and which process less than 10,000 pounds of test material per year. (c) small pilot scale research and development projects less than six months in duration with controlled actual emissions less than 500 pounds of any criteria pollutant or 10 pounds of any non-criteria reportable pollutant ❑ Disturbance of surface areas for purposes of land development, which do not exceed 25 contiguous acres and which do not exceed six months in duration. (This does not include mining operations or disturbance of contaminated soil). ❑✓ Each individual piece of fuel burning equipment, other than smokehouse generators and internal combustion engines, which uses gaseous fuel, and which has a design rate less than or equal to 5 million Btu per hour. (See definition of fuel burning equipment, Common Provisions Regulation). [Glycol Reboiler] ❑ Petroleum industry flares, not associated with refineries, combusting natural gas containing no H2S except in trace (less than 500 ppmw) amounts, approved by the Colorado Oil and Gas Conservation Commission and having uncontrolled emissions of any pollutant of less than five tons per year. ❑ Chemical storage tanks or containers that hold less than 500 gallons, and which have a daily throughput less than 25 gallons. ❑ Landscaping and site housekeeping devices equal to or less than 10 H.P. in size (lawnmowers, trimmers, snow blowers, etc.). ❑ Crude oil or condensate loading truck equipment at crude oil production sites where the loading rate does not exceed 10,000 gallons per day averaged over any 30 day period. E] Chemical storage areas where chemicals are stored in closed containers, and where total storage capacity does not exceed 5000 gallons. This exemption applies solely to storage of such chemicals. This exemption does not apply to transfer of chemicals from, to, or between such containers. ❑ Oil production wastewater (produced water tanks), containing less than 1')/0 by volume crude oil, except for commercial facilities which accept oil production wastewater for processing. ❑ Storage of butane, propane, or liquified petroleum gas in a vessel with a capacity of less than 60,000 gallons, provided the requirements of Regulation No. 7, Section IV are met, where applicable. ❑ Storage tanks of capacity < 40,000 gallons of lubricating oils. ❑ Venting of compressed natural gas, butane or propane gas cylinders, with a capacity of 1 gallon or less. ❑ Fuel storage and dispensing equipment in ozone attainment areas operated solely for company-owned vehicles where the daily fuel throughput is no more than 400 gallons per day, averaged over a 30 day period. ❑ Crude oil or condensate storage tanks with a capacity of 40,000 gallons or less. ❑ Storage tanks meeting all of the following criteria: (i) annual throughput is less than 400,000 gallons; and (ii) the liquid stored is one of the following: (A) diesel fuels 1-D, 2-D, or 4-D; (B) fuel oils #1 through #6; (C) gas turbine fuels 1-GT through 4-GT; (D) an oil/water mixture with a vapor pressure lower than that of diesel fuel (Reid vapor pressure of .025 PSIA). ❑ Each individual piece of fuel burning equipment which uses gaseous fuel, and which has a design rate less than or equal to 10 million Btu per hour, and which is used solely for heating buildings for personal comfort. ❑ Stationary Internal Combustion Engines which: (i) power portable drilling rigs; or (ii) are emergency power generators which operate no more than 250 hours per year; or (iii) have actual emissions less than five tons per year or rated horsepower of less than 50. [' Surface mining activities which mine 70,000 tons or fewer of product material per year. A fugitive dust control plan is required for such sources. Crushers, screens and other processing equipment activities are not included in this exemption. ❑✓ Air pollution emission units, operations or activities with emissions less than the appropriate de minimis reporting level. [Utility Heater, Glycol Dehydrator, Equipment Leaks, Turbine Startups] NOTE: Material Data Safety Sheets (MSDS) do not have to be submitted for any insignificant activities. O O Operating Permit Application EMISSION UNIT HAZARDOUS AIR-POLLUTANTS FORM 2000-600 Colorado Department of Public Health and Environment ' Rev 06-95- Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. ` Facility name:Cheyenne'Plains 2. Facility identification code: CO. 123/0051.. - _ Compressor Station . - -- --.- l' - - - - 3. Stack identification•code:-NIA•-'' .— 4. Unit identification code: N/A 5. Unit material description: N/A-_, °,`'' ,` q ` -• ` 6. Complete the following summary of-hazardous air emissions from this unit. Attach-all calculations_ and emission factor references. Attached-Q Actual Emissions Data is for calendar year 19 • • Pollutant CAS Common or Generic Cw, t5 ,r. otua`ltemtssions ,�, Allowable OR ` a,.. �,�+A� ��im Potential to- emit. S .vyt yq xY Yg4hw e,:,40la i t 4 �.. :-Pollutant Name l a tit o !'eaasutseme ' Quantity Measureme 1-i , 444 r , yj °a � nt Units f. . nl44.O3ali _s�'Fv 1 5i'i';%';ti;.vifi... l�,t�..ys5'a r }�� r ti � " �` s� TPY See attached Emissions Calculations in Appendix B - p ,,, , A WP. �w 6.. �` :TPY i xs arrR4r a Al TPY - �a ' F ; > K ,� :, ,„O KC TPY - .tom �' "11,1,^a�:.�• a�T metal:*;t �. TPY ' I�a'�'i r D 31:-n'fNa WWII . t '1. � TPY. • Fitrf' 1 TPY l( yru ak'4 ..,,,,,44-,44"--,, �too'n} •.1 1 0 TPY-. s q, � sF :`4 TPY , git. ;: ' TPY - 'Va -T A t 4 ..4 O t ' .-.'t.i. TPY arAtatall teal': ig r `� o. 'tf a v t j " ` F Ok tF '- Y''''- r�� `� TPY 1 u. . , � ,�Ai , TPY 3 , �v- TPY t *� t Ear s, xy�� r Alt' g..ta"a�: ap,..;'. -,4 AS Y.0.4,---, - r.t.¢ra7:j tS;3a -- - - ` ' " ff kt,s ...�"� i= , ' — TPY I~� i - ` t 1 ¢ ill __ = 2w Yo t} $ TPY_ } x � c �44 TPY: Yk".xx.T•- ro,SA�li 3U' y , !Y Pik C'. �r �r{l .y �' i,, F } TPY Rte vela TPY - s " d't., at"' p TPY i trail , � rgxr � r#5trn+ � TPY`. YAil f- Y � Ion. T. TPY 6.�x �. a� ,� >�a.,..:�'»bA;r. tart`4.,.F --.,'NOTE: If there is a permit for this unit, the permit limits are the same as the potential to emit. O . O Operating Perniii Application PLANT-WIDE CRITERIA AIR POLLUTANTS FORM 2000-603 Colorado Department of Public Health and Environment R- _, ,; ;-Rev 09-94- „ _ Air Pollution Control Division SEE INSTRUCTIONS ON-REVERSE SIDE ' ---7-,-'.'-', '''''-'-r '-,O 7-' i,l'. ' , - -I - 2., Facility'identification coder CO 123/0051 • ) 1. Facility_name;Cheyenne Plains Compressor Station 4 Y 3. Complete the following emissions summary for the listed emissions at this facility,. ,° ` =t Potential to emit - Maximum allowable Air pollutant - �` `x ' its ACufi ` z •4� J�r �Lsyu 1 " TPY .PY - Particulates (TSP)' 3, 41 7O y iiCilaRiiiiiPM-1'0 . .- o `' k ri�� a' - - ' - ' - _ _ . ..- . Nitrogen oxides O k 1` - -- ' : . Volatile organic Raft` qr.'I;,1".1?„ ' - compounds - - --- w `"..: rr'•• --._ .• -. _ Carbon monoxide. ryr= qa , ,� _ .__ Lead -_-- ..--- __ Onf °N ' -_- -- -- -- _- ,- - - - - Sulfur dioxide . ----- F' i ` '' - --__,- • - - - _ _ -_- -..v -� _ _- --- - ._lazaTotal reduced sulfur r j 'k� �° E � f _ __-- -. - Reduced sulfur compounds -` 7 a - ,•Hydrogen sulfide .-. `'�t sm ��'�1r rj�'e� - --- Sulfuric acid mist__ ,�� ;� . Y, .�} i - -_ _ -_ ar 4t,. { 4a Cary 'Fluorides nVAZ ? Y 't'.i C See attached Emissions Calculations in Appendix B , ,y w e n r- y ^�fc Lay'r-�f�,�' ,f'1<lim,i,, ,.ct• :..s_...r7s,,3, ?'tn 1-,.it , ,7.,- 1 t 'I i i , _ z _ ��l O . Q Operating Permit Application PERMIT SHIELD PROTECTION. FORM 2000-605 Colorado Department of Public Health and Environment IDENTIFICATION Rev 06-95 Air Pollution Control Division ' SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Cheyenne Plains 2. Facility identification code: CO 123/0051 J' Compressor Station 3. Specify Emission Source: N/A • 4. Do not use 5. Pollutant, 6. Colorado Air Quality 7. Equipment, Regulations State or Only Process N/A N/A N/A 8. Other requirements (e.g., malfunction reporting, special operating State Only conditions from an existing permit such as material usage, operating hours, etc.) N/A • N/A • NOTE: REQUESTS FOR THE SHIELD MUST BE FOR A SPECIFIC REQUIREMENT IN THE REGULATIONS. USE FORM 2000-700 TO PROVIDE AN EXPLANATION OF WHY THE SHIELD IS REQUESTED 0 O Operating Permit Application EMISSION UNIT COMPLIANCE PLAN FORM 2000-606 Colorado Department of Public Health and EnvironmentCOMMITMENTS AND SCHEDULE 9-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Cheyenne Plains 2. Facility identification code: CO 123/0051 Compressor Station 3. Stack identification code: All 4. Unit identification code:All. 5. For Units that are presently in compliance with all applicable requirements, including any monitoring and compliance certification requirements of Colorado Air Quality Regulation 3, Part C that apply, complete the following. These commitments are part of the application for operating permits. ❑✓ We will continue to operate and maintain this Unit in compliance with all applicable requirements. Form 2000-604 includes new requirements that apply or will apply to this Unit during the term of the permit. We will meet such requirements on a timely basis. 6. For Units not presently fully in compliance, complete the following. ❑ This Unit is in compliance with all'applicable requirements except for those indicated below. We will achieve compliance according to the following schedule (If more space is needed attach additional copies of Form 2000-700): Applicable Requirement - . . Corrective Actions Deadline 1. N/A 2. • 3. • • Progress reports will be submitted: Start date: N/A and every six (6) months thereafter j V • 1./ 1 Operating Permit Application PLANT-WIDE COMPLIANCE PLAN FORM 2000-608 Colorado D epartment of Public Health and Environment COMMITMENTS AND SCHEDULE Rev 06-95 Air Pollution Control Division USE THIS FORM ONLY IF FORM 2000-607 USED ' SEE INSTRUCTIONS ON REVERSE,SIDE- 1. ` Facility name:Cheyenne Plains 2. Facility identification code: CO 123/0051 • . Compressor Station 3. For facilities,that are presently in compliance with all applicable requirements, including any monitoring and compliance certification requirements under Colorado Air Quality.Regulation 3, Part C that apply, complete the following. These commitments are part of the application for operating permits. ❑✓ We will continue to operate and maintain this facility in compliance with all applicable requirements. • ❑ ,Form 2000-607 includes new requirements that apply or will apply to this facility during the term of the permit. We will meet such requirements on a timely basis. 4. For facilities not presently fully in compliance, complete the following. ❑ This facility is in compliance with all applicable requirements except for those indicated below. We . will achieve compliance according to the following schedule (If more space is needed attach additional sheets.): Applicable • Requirement . , ` Corrective Actions Deadline 1. N/A . . • • 2. • • • • . 3. 11 Progress reports will be submitted: .�J Start date: N/A and every six (6) months thereafter THIS FORM IS NOT A SUBSTITUTE FOR FORM 2000-606 0 0 Operating Permit Application STACK IDENTIFICATION FORM 2000-200 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE • . - ' 1. Facility name: - 2.Facility identification code: CO 123/0051 Cheyenne Plains Compressor Station 3: Stack identification code: CP01 3a. Construction Permit Number: 03WE0910 4. Exhausting Unit(s), use Unit identification code,from appropriate Form(s) 2000-300, 301, 302, 303, 304, 305, 306, 307 2000-300 2000-301 2000-302 2000-303 . 2000-304 2000-305 2000-306 015 2000-307 5. Stack identified on the.plot plan required on Form 2000-101 X 6. Indicate by checking: ❑✓ This stack has an actual exhaust point. The parameters.are entered in Items 7-13. ❑ This stack serves to identify fugitive emissions. Skip items 7-13. 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"�3�.;₹4r. r�.�F3'.:+ �.k'z��:.?s. fi.,�,atu � l.'t≥J�n#�'��-'�`� .. _> ......bt.'��«u��v'�'+.trsY��rfi`✓.r?.•Mw�r�'"�A'1£, ��'.E.4t �� ;i'�?3t 7'.3'lu�,s:'�� lt-:,..r.�a *****Complete the appropriate'Air Permit Application Forms(s) 2000-300, 301, 302, 303, 304, ***** 305, 306, or 307 for each Unit exhausting through this stack. :) O O Operating Permit Application MISCELLANEOUS PROCESSES FORM 2000-306 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE --' 1. Facility name:Cheyenne Plains Compressor 2. Facility identification code: CO.123/0051 Station 3. Stack identification code: CP01 4. Process (Unit)code: 015 5. Unit description: 9816 hp Solar Taurus 70 6. Indicate the control technology status. ❑ Uncontrolled ❑✓ Controlled If the process is controlled, enter the control device code(s) from the appropriate form(s):. 2000-400 2000-401 2000-402• 2000-403 2000-404 2000-405 2000-406 _ 2000-407 ,..� - r';.i. i;.0 �Li'w :sR,?,.. � L iF :ah"...+. ti- �� 4-:' F qfi .rte Si4 ,h.:eo-� �, �. 6qy � 4sx`^ f'y e 4 �•••�:F..� i 1::r r t, 1. fAr- IL9 .h t� { + i -K ,,3 ,.. q�'w•a ,pry .�2,a i .L ��'p a''�f,Actual annualrocess � �;- _ °4 '+3`'`�rrxJ"`r, '- i. � ' : �.x?a` ^'-ail•. y Y�_ , ,rb. +i� '�4#''"� yy 1,? f..z• a•.+a. '"N:+Y. ^i`�GA ₹ti �kb5.to s;S��t��-_ 'rt.bxfi . .�sh• wYIs:43?rit. m...v..�t 5.9a.cv.�.,�t.h',�-�7a;. 8. Date first placed in service: 12/15/04 Date of last modification: _ 9. Normal operating schedule: 24' hrs./day. 7 days/wk. 8,760 hours/yr. 10. Describe this process (please attach a flow diagram of the process). Attached? ❑ Natural gas-fired combustion turbine that powers a natural gas compressor. 11. List the types and amounts of raw materials used in this process: ��4'""�..s��xi�;-ass �r � R�,, mss- Material Storage/material handling process - Actual usage A tuts Maximum Units igiittnt . k 49 ...� .;t�� <� .��,tr usage N/A g ltpl t �fi eanAdVattatrld Clean-up ¢ � F, solvents r' c- s₹ ` 1 s of rr. .zx_r.h.sn ± t ..k..s Other } " ; .7. (specify) (specify) it X �r 12. List the types and amounts of finished products: ,�i t,. .r� r a �. s+t �^� -��tea, Material Storage/material handling process t; cfial{amaurrt> i ri ts�a Maximum Units -,ti: r4 edg, os .1 amount ' � vox� u _ produced N/A � v • ��`�k� `'F r�k�"`�v,,y e�z�a7�j�` 1+tf tt l 's..iFltn "a•c t�aa =.ss,+� oY`n`a ��x# 13. Process fuel usage: Type of fuel Maximum heat F'' ctua`lzusag t lJt Maximum Units input to process f5xr`'-`r'i'i A₹,}�YS E'i`-Z � F, million BTU/hr t � 4 usage Natural Gas 71.42 'W `� ' 0.07551 MM -�. �� zy t E r rv, 51'-4'n .T".h. scf/hr 14. Describe any fugitive emissions associated with this process, such as outdoor storage piles, unpaved roads, open conveyors, etc.: ***** For this emissions unit, identify the method(s) of compliance demonstration by completing Form 2000-500, ***** • DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 and its attachment(s) to this form. ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** O O Operating Permit Application COMPLIANCE CERTIFICATION-MONITORING AND REPORTING FORM 2000-500 Colorado Department of Public Health and Environment DESCRIPTION OF METHODS USED Rev 06-95 Air Pollution Control Division FOR DETERMINING COMPLIANCE All applicants are required to certify compliance with all applicable air pollution permit requirements by including a statement within the permit application of the methods used for determining compliance. This statement must include a • description of the monitoring, recordkeeping, and reporting requirements and test methods. In addition, the application must include a schedule for compliance certification submittals during the permit term... These submittals must be no less frequent than annually, and • • may need to be more frequent if specified by the underlying applicable requirement or by the Division. SEE INSTRUCTIONS ON REVERSE SIDE • 1. Facility name Cheyenne Plains Compressor 2. Facility identification code: CO 123/0051 Station 3. Stack identification code: CP01 4. Unit identification code: 015 5. For this Unit the following method(s) for determining compliance with the requirements of the permit will be used (check all that apply and attach the appropriate form(s) to this form). ❑ Continuous Emission Monitoring (CEM) - Form 2000-501 Pollutant(s): • ❑✓ Periodic Emission Monitoring Using Portable Monitors - Form 2000-502 ' . Pollutant(s): • ❑ Monitoring Control System Parameters-or Operating Parameters of a Process - Form 2000-503 • Pollutant(s): . l� l ❑ Monitoring Maintenance Procedures - Form 2000-504 Pollutant(s): ❑✓ Stack Testing - Form 2000-505 Pollutant(s): • . • • ❑ Fuel Sampling and Analysis (FSA) - Form 2000-506 Pollutant(s): • ❑✓ Recordkeeping - Form 2000-507 • Pollutant(s): ❑ Other (please describe) - Form 2000-508 • Pollutant(s): _ . • • O O Compliance certification reports will be submitted to the Division according to the following :hedule: . Start date: and every 12 months thereafter. (12 month maximum interval) Compliance monitoring reports will be submitted to the Division according to the following schedule: Start date: and every 6 months thereafter. (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5. • O O Operating Permit Application COMPLIANCE DEMONSTRATION BY PERIODIC EMISSION FORM 2000-502 Colorado Department of Public Health and Environment MONITORING USING PORTABLE MONITORS Rev 06-95 Air Pollution Control Division 0 _ The use of a portable continuous emission monitor(CEM) may be acceptable as a compliance demonstration method. A monitoring pla shall contain the following information: the name and address of.the source; the source facility identification code; a general description 61 the process and the control equipment; the pollutant or diluent being monitored; the manufacturer, model number, and serial number of each portable monitor; the operating principles of each portable monitor; and a schematic of the CEM system showing the sample acquisition point and the location of the monitors while sampling. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: 2. Facility identification code: CO 123/0051 Cheyenne Plains Compressor Station 3. Stack identification code: CPO1 4. Unit identification code: 015 5. _ Pollutant(s)or diluent(s)being monitored: NOx and CO 6. Name of manufacturer: 7. Model &serial number: 8. Is this an existing system? ❑ Yes ❑✓ No bt 7{.S f,2�F:r5'.�_ ,i. 't��' peg ,- "6%- . 'v;'CF+ v'S.c ,, 56.E 10. Type: ❑In situ 0 Extractive ❑Dilution 0 Other(specify) 11. Very briefly explain the measurement design concept of the monitor: Per construction permit condition 4c, compliance with BACT limits shall be demonstrated by quarterly portable monitoring test. 12. Backup system: None 13. Compliance shall be demonstrated: ❑ Daily ❑Weekly 0 Monthly ❑✓ Other-specify (Quarterly) 14. Quality Assurance/Quality Control: • ❑ A quality assurance/quality control plan for the portable monitor is attached for Division review. ❑✓ The plan is not attached, but will be submitted to the Division by • ***** Any test value over the emission limit shall be reported as an excess emission. ***** ci) 1 Operating Permit Application COMPLIANCE DEMONSTRATION BY STACK TESTING FORM 2000-505 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division The performance of an EPA stack test method is acceptable for demonstrating compliance with an emission limitation. EPA test methods attain quality assurance procedures that shall be strictly adhered to by the source. The applicant shall propose an appropriate program of 'stack testing for compliance demonstration. The stack testing program shall correlate with the corresponding emission limitation in terms of the frequency and duration of the stack tests. The Division may approve the proposed stack testing program, or other programs which the Division determines to be appropriate. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: 2. Facility identification code: CO 123/0051 Cheyenne Plains Compressor Station 3. Stack identification code: CP01 4. Unit identification code: 015 5. Pollutant being monitored: NOx, CO, and VOC. 6. Procedure being monitored: Initial source test for turbine exhaust. 7. Is this an existing method of demonstrating 8. Program start date: compliance? ❑ Yes ❑✓ No 9. EPA or Division approved test method: EPA approved method for NOx, CO, and VOC. 10. Backup system None. 11. Compliance shall be demonstrated: Daily Weekly 0 Monthly 0 Other-specify(initial source test) ***** Any measured emission rate that exceeds an emission limitation established by the permit shall be ***** reported as an excess emission. 1 Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-507 Colorado Department of Public Health and Environment BY RECORDKEEPING Rev 06-95 Air Pollution Control Division Recordkeeping may be acceptable as a compliance demonstration method provided that a correlation between - the parameter value recorded and the emission rate of a particular pollutant is established in the form of a curve or chart of emission rate versus parameter values. This correlation may constitute the certification of the system. For-an existing program, the correlation demonstration must be attached for Division consideration for approval. If the correlation information has not yet been developed, please submit it within 60 days of the startup of the system. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Cheyenne Plains Compressor 2. Facility identification code: CO 123/0051 Station 3. Stack identification code: CP01 4. Unit identification code: 015 5. Pollutant(s) being monitored: PM-10, NOx, 6. Material or parameter being monitored and CO, and VOCs recorded: Hours of Natural Gas Usage & Ambient Temp. 7. Method of monitoring and recording (see information on back of this page): Natural gas consumption and ambient temperature are recorded. Emission factors for three different temperature ranges are used to determine emissions of NOx, CO, and VOCs. For PM-10, AP-42 emission factors are used to determine emission rates. Rolling 12 month totals are calculated. 8. List any EPA methods used: AP-42, Section 3.1 9. Is this an existing method of demonstrating 10. Start date: compliance? ❑✓ Yes ❑ No 11. Backup system: 12 a. Data collection frequency: ❑ Daily ❑ Weekly ❑✓ Monthly ❑ Batch (not to exceed monthly) ❑ Other - specify 12 b. Compliance shall be demonstrated: ❑ Daily ❑ Weekly ❑✓ Monthly ❑ Batch (not to exceed monthly) ❑ Other - specify 13. Quality Control/Quality Assurance: The monitoring system shall be subject to appropriate performance specifications, calibration requirements, and quality assurance procedures. ❑✓ A quality assurance/quality control plan for the recordkeeping system is attached for Division review. ❑ The plan is not attached, but will be submitted to the Division by 14. ❑ A proposed format for the compliance certification report and excess emission report is attached. ***** The compliance records shall be available for Division inspection. ***** The source shall record any malfunction that causes or may cause an emission limit to be exceeded. ***** Malfunctions shall be reported to the Division the next business day. Hazardous air releases shall be reported to the Division immediately. Operating Permit Application APPLICABLE REQUIREMENTS AND FORM 2000-604 Colorado Department of Public Health and Environment STATUS OF EMISSION UNIT Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Cheyenne Plains Compressor Sta. 2. Facility identification code: CO 123/0051 3. Stack identification code: CP01 4. Unit identification code: 015 5. Pollutant 6. Colorado Air Quality 7. 8. Limitation 9. Compliance Regulations State Status or Only IN OUT Construction Permit Number Opacity Permit#03WE0910, 20 %Opacity X Number 1 & 7a NOx Permit#03WE0910, 24.5 ppmvd ambient X Number 4a(BACT) temp. above 0°F 42 ppmvd ambient temp. 20°F -0°F 120 ppmvd ambient temp. less than-20° F CO Permit#03WE0910, 48.8 ppmvd ambient X Number 4b(BACT) temp. above 0° F 100 ppmvd ambient temp. -20° F- 0° F 120 ppmvd ambient temp. less than-20°F VOCs Permit#03WE0910, 3 ppmvd ambient temp. X Number 4c (BACT) above 0° F 5 ppmvd ambient temp. - 20° F- 0°F 8 ppmvd ambient temp. less than-20° F • NOx Permit# 03WE0910, 0.01895 ppmvd by X Number 5a(NSPS) volume dry basis at 15% oxygen SO2 Permit#03WE0910, .015 %by volume dry X Number 5b (NSPS) basis at 15 % oxygen, or sulfur content of fuel can't exceed 0.8 %by weight. SO2 Permit#03WE0910, * 0.8 lbs/mmBTU ` X Number 7b SO2 Permit#03WE0910, 0.8 lbs/mmBTU X Number 8 PM Permit#03WE0910, PE=0.5(FI)"°'z6 X Number 9 PM & PM-10 Permit#03WE0910, 0.18 tons/mo &2.1 tpy X Number 11 NOx Permit#03WE0910, 2.68 tons/mo &31.6 tpy X Number 11 CO Permit#03WE0910, 3.27 tons/mo & 38.5 tpy X Number 11 VOCs Permit#03WE0910, 0.96 tons/mo & 11.3tpy X Number 11 Odor Permit#03WE0910, * Regulation#2 X Number 8 _ 10. Other requirements (e.g., malfunction reporting, special operating State Only Compliance conditions from an existing permit such as material usage, hours of Status operation, etc.) IN OUT Permit condition#10—Consumption of natural gas for each turbine shall not X exceed 56.2 mmSCF/month or 661.5 mmSCF/year. **** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** 0 0 Operating Permit Application SUPPLEMENTAL INFORMATION FORM 2000-700 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Cheyenne Plains Compressor . 2.Facility identification code: CO 123/0051, Station 3. This form supplements Form 2000.- 604 for Emission Unit (e.g. B001, P001, etc.) 015' Additional Information, Diagrams Item Number Compliance was determined for each applicable requirement in Permit Number 03WE0910,as follows: #1, Opacity-compliance was determined by EPA Method 9 visual emissions evaluation. 9 #4 a,b,&c,NOx, CO, VOCs BACT requirement—compliance determined by stack test as 9 outlined in permit condition 12. Thereafter, compliance was determined by quarterly portable monitoring tests. #5 a&b,NOx & SO2 NSPS Subpart GG requirements—For NOx,the,BACT compliance 9 determination satisfies NSPS requirement. For SO2, compliance was assumed as long as pipeline quality natural gas per 40 CFR GG, 334(h)(3)is burned. • #7b,SO2 requirements of Reg 6 Part B—compliance.was assumed as long as pipeline 9 quality natural gas is burned. / ) #8, SO2 requirements of Reg 1, Section VI.B.4.c(i)—compliance was assumed as long as 9 pipeline quality natural gas is burned . #9,PM requirements of Reg 1, Section III.A.1.(b)—Compliance was determined by 9 tracking fuel input in mmBTU/hr and using the equation provided in permit condition #9. #11,PM,PM-10,NOx, CO, & VOCs emissions per year limitations—Compliance was 9 • determined by recording monthly natural gas usage at each ambient temperature, and using appropriate BACT and AP-42 emission factors. Emissions were calculated on a 12-month rolling total. • #6, Odor- • 9 • #10,natural gas usage—compliance was determined by maintaining monthly records of 10 actual natural gas consumption. . O O . Operating Permit Application STACK IDENTIFICATION FORM 2000-200 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: • 2.Facility identification code: CO 123/0051 Cheyenne Plains Compressor Station • 3. Stack identification code: CP02 3a. Construction Permit Number: 03WE0910 • 4. Exhausting Unit(s), use Unit identification code from appropriate Form(s) 2000-300,301, 302, 303, 304, 305, 306, 307 2000-300 2000-301 2000-302 2000-303 2000-304 2000-305 2000-306 016 2000-307 5. Stack identified on the plot plan required on Form 2000-101 X . 6. Indicate by checking: • ❑✓ This stack has an actual exhaust point. The parameters are entered in Items 7-13. ElThis.stack serves to identify fugitive emissions. Skip items 7-13. Go to next form. ❑ When stack height Good Engineering Practice (GEP) exceeds 65 meters (Colorado Air Quality Reg 3.A.VIII.D) data entry is required for Item 7. -Tx.'Yr•' ah i ion a, kr. a ,, r• as.,,^ -Sr- 4,kv ;� e t.. ..4 j ..,_ n 'C)r , '3 .••••,;0.01.41,. 4.0,''3Y4.. ..r .yomi. ifa .DlScha>G hei YEabove round levoL'�k. '72 et feet= F _ Aa y'�'�.��aMr`9ai,aeefrYt`id��i"Sk1x.Ya+:��H�i �N��l.a�e ,"' GA�f��+3r'�,xi�',.hl�"'kn,a.�{'L'•.F�4�.'T7''C.4:fSa��'. sfi• 7.`'!-Olt i�� ti:..3'�lEirJ+t '+.ax�a.H.�.t•'L5�.' Y. .-4.4.7'Et 1.R.ff 6` tee 4 x','S 4 js�0 9r W"' ,'P•V✓ 1*-.JW?.'PE,w n" ('2:7.y'L 41,...:i,q ,� ,:; , .'}i,�,.,.. ,. t 4 ! ,�' Sd d.mensionoat outlet etiecktkon -andtcom lei •'k 9 s ;-• -. �• 'r � 1�" 1�' .i t, , yct�,`3c f r10 ,a 1 Lt °' 'et 1 6{,f4-f' '9 fi ..,..a,,- t> i;%�2 SAS, ! 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", r of i,s ,,,4 tY ..] -n. v),,,: r 57 �'l L,,vo>r3 yMtt.rJi -„, •",,v, m r,Y+ ., r -tt,t.;x N, ,:-.e.::,,,,,,,,:, ,qr V5 7 Y 7_!?y5' h�a tigasrdisoha ige, o a v ✓ U;p ,fg ark i >�{�' o rf forizont4`t v °,, v ,ft.,..,, y� y x i ,,,,,,F' '-va'a r,- } .: .•a�'1,t i.- ' '�.x,"•F ',V, _F-r•t f��I�,y.e.g,4i �. ,,j .tid w '' a .tr ,.Sajt li { a-4t„,At. `* '" , O4 1�`�h �y z t p �h,J•.31! ,„-iii,i1 h' .T �1� 4 • '.. ,;•,,,,,,.,.4„,-,,,,,,,j-16,,.,.;•_..,;,„4,A1.,;, ,,] - • t4;..'✓i' 1 �'.,...' yF.ttA •t'f+,•... d _",.*3•C,-.4..-T i .:',.1.,-_,..n4 .jL,,9"t'.1 A4-.;,67'ivmei.4K:&:tl;. _ ..6"'y li `ira,. 3,w 3'�. ,,a �„r 4. ,.,ey �iC{=. .r.rbY0, t 3 ^l.. ,,rS°,'' 'v w.11-41,0-1.t.W < C .tr N.•-:•,;b . ,. rg ar I° th �i el gmpped'wahiazainha or4 ya rstraetso o;mew- cl,w4pf '„,v -5'0r,�� .. . a h !r r,,J.ra t f r 1 ;szvL ,e.Ykv rYs.. ., },y3}{ 1 _a, •':.•i; F,�.., ,5.,"•., FtiY-� ey, s-- t �•y rt ,•-a- +a, s ^�{s �^ :,t 0 it5'k�s:�s a !�r'�c 4 ;'L7'`1k''gr j�, i¢ }� ,1....r�+:�S4 fro.yt m� X14 �:f;. flieyexhaust ass or tthe star-1 t❑`Yeso +No`� ,' t r . bpi '> �,,y� t V.: � �T }'�"M1't' Mw k Y ��5�y4p��y.,. . 'a:gi ;•r..m:FT> `'.l;4M4...4<i`Xf1 ,fit a,t,:g.:':c,:7 r, . .Itik.4 YAYA� f Y.7.0-b 4114V4.14 Cif-,�t i,ti .,Y ' i.C' 'q `' ".4'. •zS>ri,. � .<. ... ,- Fx"h'Y��.k. nn..�.�.u. . ,+ .,cr,•. ..,...., .. ........r .-....a�3. �� , *****Complete the appropriate Air Permit.Application Forms(s) 2000-300, 301, 302, 303, 304, ***** 305, 306, or 307 for each Unit exhausting through this stack. . O O Operating Permit'Application, ) ' MISCELLANEOUS PROCESSES FORM 2000-306 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division , T1 SEE INSTRUCTIONS ON REVERSE SIDE , - 1. Facility name: 2. Facility identification code: CO 123/0051 Cheyenne Plains Compressor Station 3. Stack identification code: CP02 4. Process (Unit)code: 016 . 5. Unit description: 9816 hp Solar Taurus 70 , 6. Indicate the control technology status. ❑ Uncontrolled ❑✓ Controlled If the process is controlled, enter the control device code(s) from the appropriate form(s) , . 2000-400 2000-401 . 2000-402 •2000-403 2000-404 2000-405 2000-406 2000-407 :i r ny�tx,r, -�..f�,g 7,#- 7t"i��, ^'kzs ;:u:r.scx� °=xw 3: zYY*` �F- ;fi' -s ;3,t.ti��'+� �n•J�,,.s,y,: f� 6 d c*' IJI"- � '.+w�r.'gi� � T� g '2.. . x s: h - ?av i i x' h ,r33�"Ys. I 5w$�Sr3 r, � 7? � c a annua process rates�f 1Thtsi 9 - , 5;� 4 Y/ � , ,� x;f a . - „� y "�.� ,„?s .rt ?.:,1 i.s �`F.fJ:.l]�4:?ad{.hfm:LJ'L�CuN fii..:•a.�.. 1, -tYJYr�kL`Ix.Y. rc..:rr1 t.�. .,.tis..,_ .. .riV.tlF ,..�._ i,f C...s a. 3:. R ,r.�•�%��. Te{.�P '.O?� 8. Date first placed in service: 12/15/04 Date of last modification: 9. Normal operating.schedule: 24 hrs./day 7 days/wk. 8,760 hours/yr. 10. Describe this process (please attach a flow diagram of the process). Attached? ❑ Natural gas-fired combustion turbine that powers a natural gas compressor 11. List the types and amounts of raw materials used in this process: Material Storage/material handling process 1�,o to al�isage *MVO Maximum Units ic, ' ' +,,- � usage t?�° �w � , ,xzti�u� { .:,��H�'�-fit N/A ` 1 ,W it D Clean-up �"�` fih- ≥s-74.7.7-Tr ' ,- r�'� '�_ . ' solvents - t n 1 ' Other » .� � n 4141, (specify) 12. List the types and amounts of finished products: �a E �....�m mow, k � u c Material Storage/material handling process ! ctua t�0, • �.nt Maximum Units .r ws- 14, ` o c •, amount f10 ,41, �''�; produced N/A 'IIh� � � ai r 41%,15`:AMI61We SP= e-s F ate, If - 13. Process fuel usage: . . Type.of fuel Maximum heat '"`Acfttal=t gie+ 1IJJn>t Maximum Units �.`� �,�� -+sue. .4 input to process A 4-`.7l .. E "` usage million BTU/hr 1s- � '-� wf' .ix Natural Gas 71.42 }$1 $ �. 0.07551 MM 4 ;ag+ {-� ,,. ,�..'Mis:. scf/hr 14. Describe any fugitive emissions associated with this process, such as outdoor storage piles, unpaved roads, open conveyors, etc.: ***** For this emissions unit, identify the method(s) of compliance demonstration by completing Form 2000-500, ***** ( ) DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 \ and its attachment(s) to this form. ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** . • • • O O Operating Permit Application COMPLIANCE CERTIFICATION-MONITORING AND REPORTING FORM 2000-500 • Colorado Department of Public Health and Environment DESCRIPTION OF METHODS USED Rev 06-95 Air Pollution Control•Division FOR DETERMINING COMPLIANCE All applicants are required to certify compliance with all applicable air pollution permit requirements by including a statement within the permit application of the methods used for determining compliance. This statement must include a description of the.monitoring, recordkeeping, and reporting requirements and test methods. In addition, the application must include a schedule for compliance certification submittals during the permit term. These submittals must be no less frequent than annually, and • may need to be more frequent if specified by the underlying applicable requirement or by the Division. SEE INSTRUCTIONS ON REVERSE SIDE • • 1. Facility name Cheyenne Plains Compressor 2. Facility identification code: CO 123/0051 Station 3. .Stack identification code: CP02 4. Unit identification code: 016 5. For this Unit the following method(s) for determining compliance with the requirements of the permit will be used (check all that apply and attach the appropriate form(s) to this form). ❑ Continuous Emission Monitoring (CEM) - Form 2000-501 • Pollutant(s): • • ❑✓ Periodic Emission Monitoring Using Portable Monitors - Form 2000-502 • Pollutant(s):• • ❑ Monitoring Control System Parameters or Operating Parameters of a Process - Form 2000-503 Pollutant(s): ❑ Monitoring Maintenance Procedures - Form 2000-504 Pollutant(s): • ❑✓ Stack Testing - Form 2000-505 • • Pollutant(s) ❑ Fuel!;Sampling•and Analysis (FSA) Form 2000-506 • Pollutant(s): ❑✓ Recordkeeping - Form 2000-507 • Pollutant(s): ❑ Other(please describe) - Form 2000-508 S Pollutant(s): • • �. �� • • • • • O 0 • Compliance certification reports will be submitted to the Division according to the following i" zhedule: • Start date: - and every 12 months thereafter. (12 month maximum interval) • Compliance monitoring reports will be submitted to the Division according to the following schedule: Start date: and every 6 months thereafter., (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5. • J • 0 0 Operating Permit Application COMPLIANCE DEMONSTRATION BY PERIODIC EMISSION FORM 2000-502 Colorado Department of Public Health and Environment MONITORING USING PORTABLE MONITORS Rev 06-95 Air Pollution Control Division • The use of a portable continuous emission monitor(CEM) may be acceptable as a compliance demonstration method. A monitoring pla ) shall contain the following information: the name and address of the source; the source facility identification code; a general description'oi the process and the control equipment; the pollutant or diluent being monitored; the manufacturer, model number, and serial number of each portable monitor; the operating principles of each portable monitor; and a schematic of the CEM system showing the sample acquisition point'and the location of the monitors while sampling. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: 2. Facility identification code: CO 123/0051 Cheyenne Plains Compressor Station 3. Stack identification code: CPO2 4. Unit identification code: 016 5. Pollutant(s)or diluent(s) being monitored: NOx and CO • 6. Name of manufacturer: . 7. Model&serial number: 8. Is this an existing system? ❑Yes ❑✓ No • R 7�f� -.2.;w12113,.<22 a .;6 { fit Lj gg4r ` 10. Type: ❑ In situ ❑Extractive ❑Dilution ❑Other(specify) 11.. Very briefly explain the measurement design concept of the monitor: • Perconstruction permit condition 4c, compliance with BACT limits shall be demonstrated by quarterly portable monitoring test. • 12. Backup system: None 13. Compliance shall be demonstrated: ❑Daily ❑ Weekly ❑Monthly ❑✓ Other-specify (Quarterly) 14. Quality Assurance/Quality Control: • ❑ A quality assurance/quality control plan for the portable monitor is attached for Division review. ❑✓ The plan is not attached, but will be submitted to the Division by • ' *****Any test value over the emission limit shall be reported as an excess emission. ***** • I 1 Operating Permit Application COMPLIANCE DEMONSTRATION BY STACK TESTING FORM 2000-505 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division The performance of an EPA stack test method is acceptable for demonstrating compliance with an emission limitation. EPA test methods )ntain quality assurance procedures that shall be strictly adhered to by the source. The applicant shall propose an appropriate program of -,tack testing for compliance demonstration. The stack testing program shall correlate with the corresponding emission limitation in terms of the frequency and duration of the stack tests. The Division may approve the proposed stack testing program, or other programs which the Division determines to be appropriate. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: 2. Facility identification code: CO 123/0051 Cheyenne Plains Compressor Station 3. Stack identification code: CP02 4. Unit identification code: 016 5. Pollutant being monitored: NOx, CO, and VOC. 6. Procedure being monitored: Initial source test for turbine exhaust. 7. Is this an existing method of demonstrating 8. Program start date: compliance? ❑Yes ❑✓ No 9. EPA or Division approved test method: EPA approved method for NOx, CO, and VOC. 10. Backup system None. 11. Compliance shall be demonstrated:E Daily ❑Weekly ❑Monthly ❑✓ Other-specify (initial source test) ***** Any measured emission rate that exceeds an emission limitation established by the permit shall be ***** reported as an excess emission. • Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-507 Colorado Department of Public Health and Environment BY RECORDKEEPING Rev 06-95 Air Pollution Control Division Recordkeeping may be acceptable as a compliance demonstration method provided that a correlation between the parameter value recorded and the emission rate of a particular pollutant is established in the form of a curve or chart of emission rate versus parameter values. This correlation may constitute the certification of the system. For an existing program, the correlation demonstration must be attached for Division consideration for approval. If the correlation information has not yet been developed, please submit it within 60 days of the startup of the system. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Cheyenne Plains Compressor 2. Facility identification code: CO 123/0051 Station 3. Stack identification code: CP02 4. Unit identification code: 016 5. Pollutant(s) being monitored: 6. Material or parameter being monitored and recorded: Hours of natural gas usage & ambient temperature 7. Method of monitoring and recording (see information on back of this page): Natural gas consumption and ambient temperature are recorded. Emission factors for three different temperature ranges are used to determine emissions of NOx, CO, and VOCs. For PM-10, AP-42 emission factors are used to determine emission rates. Rolling 12 month totals are calculated. 8. List any EPA methods used: AP-42, Section 3.1 9. Is this an existing method of demonstrating 10. Start date: compliance? ❑✓ Yes ❑ No 11. Backup system: 12 a. Data collection frequency: ❑ Daily ❑ Weekly O Monthly ❑ Batch (not to exceed monthly) ❑ Other- specify 12 b. Compliance shall be demonstrated: ❑ Daily ❑ Weekly ❑✓ Monthly ❑ Batch (not to exceed monthly) ❑ Other- specify 13. Quality Control/Quality Assurance: The monitoring system shall be subject to appropriate performance specifications, calibration requirements, and quality assurance procedures. ❑ A quality assurance/quality control plan for the recordkeeping system is attached for Division review. ❑ The plan is not attached, but will be submitted to the Division by 14. ❑ A proposed format for the compliance certification report and excess emission report is attached. ***** The compliance records shall be available for Division inspection. ***** The source shall record any malfunction that causes or may cause an emission limit to be exceeded. ***** Malfunctions shall be reported to the Division the next business day. Hazardous air releases shall be reported to the Division immediately. Operating Permit Application APPLICABLE REQUIREMENTS AND FORM 2000-604 Colorado Department of Public Health and Environment STATUS OF EMISSION UNIT Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Cheyenne Plains Compressor 2. Facility identification code: CO 123/0051 Station 3. Stack identification code: CP02 4. Unit identification code: 016 5. Pollutant 6. Colorado Air Quality 7. 8. Limitation 9. Compliance Regulations State Status or Only IN OUT Construction Permit Number Opacity Permit#03WE0910, 20%Opacity X Number 1 & 7a NOx Permit#03WE0910, 24.5 ppmvd ambient X Number 4a (BACT) temp. above 0° F 42 ppmvd ambient temp. 20° F - 0°F 120 ppmvd ambient temp. less than-20° F CO Permit#03WE0910, 48.8 ppmvd ambient X Number 4b (BACT) temp. above 0° F 100 ppmvd ambient temp. -20° F - 0°F 120 ppmvd ambient temp. less than-20° F VOCs Permit#03WE0910, 3 ppmvd ambient temp. X Number 4c (BACT) above 0° F 5 ppmvd ambient temp. 20° F-0° F 8 ppmvd ambient temp. less than-20° F NOx Permit#03WE0910, 0.01895 ppmvd by X Number 5a(NSPS) volume dry basis at 15% oxygen SO2 Permit#03WE0910, .015 %by volume dry X Number 5b (NSPS) basis at 15 % oxygen, or sulfur content of fuel can't exceed 0.8 %by weight. SO2 Permit#03WE0910, * 0.8 lbs/mmBTU X Number 7b SO2 Permit#03WE0910, 0.8 lbs/mmBTU X Number 8 PM Permit#03WE0910, PE=0.5(FI)-°26 X Number 9 PM & PM-10 Permit#03WE0910, 0.18 tons/mo &2.1 tpy X Number 11 NOx Permit#03WE0910, 2.68 tons/mo & 31.6 tpy X Number 11 CO Permit#03WE0910, 3.27 tons/mo &38.5 tpy X Number 11 VOCs Permit# 03WE0910, 0.96 tons/mo & 11.3tpy X Number 11 Odor Permit#03WE0910, * Regulation#2 X Number 8 10. Other requirements (e.g., malfunction reporting, special operating State Only Compliance conditions from an existing permit such as material usage, hours of Status operation, etc.) IN OUT Permit condition#10—Consumption of natural gas for each turbine shall not X exceed 56.2 mmSCF/month or 661.5 mmSCF/year. **** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** 1 • O O • Operating permit Application STACK IDENTIFICATION - FORM 2000-200 Colorado Department of Public Health and Environment Rey 06-95 Air Pollution Control Division r / SEE INSTRUCTIONS ON REVERSE SIDE 1. ' Facility name: 2.Facility identification code: CO 123/0051. • Cheyenne Plains Compressor Station ' • 3. Stack identification code: CP05 3a. Construction Permit Number: 04WE1390 4. Exhausting Unit(s), use Unit identification code from appropriate Form(s) 2000-300, 301, 302, 303, 304, 305, 306, 307 - 2000-300 2000-301 2000-302 2000-303 • 2000-304 2000-305 2000-306 024 2000-307 5. Stackidentified on the plot plan required on Form 2000-101 X 6. Indicate by checking: • .❑✓ This stack has an actual;exhaust point. The parameters are entered in Items 7-13. • ❑ This stack serves to identify fugitive emissions. .Skip items 7-1'3. Go to next-form. ❑ When stack height Good Engineering Practice (GEP) exceeds 65 meters (Colorado Air Quality Reg 3 A VIII D) data entry is required for Item 7. ti:. .u�.r,i'•YE ta:�fr.'s. oc�r R5�. p>x 3, q'.� ,^'c� �'So _.;� i„aay{ `r t�` 5, > '�' - t i`�S,r-4r �'"'`.� ':'7 �< D,iseharbpa Chet` �abov [otin{davl u :k 7r2, i s ts7 of . .n,,, ;, r- �` ,J, , ?,, t}6, ks'4 tk- r x'�-71..17, :$�M.54 , r hisdild Nr.'Yrt'3:s yi+.t$_'•s r .i r*,—,,r�'. ,,,R 4'A ;C`.�."�a�_a ,!IT.M{,., ?4'.�,'Af4;: ri r x ati , ':9" X.r�t �G�plrc,i tS. 4 "e... 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Yt+:.ittt a ter' i u r t t,f9 ' Exhaust flow fat' Nur tali 92;807; (AC A,..1 s:i 4t,' 5M1 ' �9 r80 � �,� rip'- ','-''.14,,e"- v. '� ,# r �s�'w��ue� �'4 &pis ,.,?.r "(4' .y7',�, ,��4� y.�.'_a 4 �,t0�' ;`f ::Y." ,ss ,�.� 4.?:- {y 1.4b......„ � �,� � � �; �'C ? T-,c....J"�( .S,��L'�h✓jiu��i��CYt ..:ik��j h� s �, �a �i e � kh $; Y r a'N' ..t'5f✓.s t ! `t`6��t {� >'' r ; 'y$ai��a t�la f w klt4u ' via.,.. t, V r l .[..,4a t f� 'C3C�:, i C �+ t�0: t S J. -.5 : ,: `1, F`s� a.:t"r-."v'w es af+.. ��,� ,�y i, ,}"rilb< v tfa„. 9".ek t[�t-Av bra, ..,0 y._F'� `� 5.," 'sm ,i4 u.,d`F , i r�r �:i�.?et� } '��'k •�• �'l'I h �.aY 5., T� '� .a4 ?7 cf .,�� '{�• f`�':Y'' �YN��; '�.R. '� 1 Velocity,�M $TC3 '4C ; S); y{Caleulated�j'[ tackfTes ift„ � tal •44,1, . M: .4 147,:. ffi W kY koat 'a "F j- r .'t twit 0. 0A -Ir,a..r ,tgc.wir "fin"r' 50.,,t,,,,.n kS T in,`e1�r•Si' 'tt 4>.rz te,,"r ..'J . ,4 t e i�'^�a r g,- S / v )w X . Si ,b1'5S.A)**c 1 t 11S7":�i' - } xY� • « >i x,�u�•'trr.,:-zi this n •;a _ t_ ,. i, ,a �>£n r e.z*a'� '�: §Y.P: ,,;103 .i�:Exhaust$' asttem+etta v( o 7 1 la o Q °r"i a +� 4 s r ' '.re ' 0 t .t µa ' c'' `# • g fir, 'QQ n r '. ` i t r j F e '�t ,p t ry `t° t • a ?'i`,(,�:., � y . � b K to �p�s'� st "LT r 'dy)�. J.` "s, ��" �t x � ��7 �v' +�^� ��' � nG�`5 1,.u•,.��r{Zv�.�� "xz.:�.4�y`�aaY.n ^�. �Xe,-r- .na' K-�a FlY � ca r x, fir, ht;�it, k auc „, r i..� z ~ �t,. a� *a -ufwa a r a:ae a r ,.. '�₹tlk a ;,,x r"vi₹;-4o 1�1 t'+ Does1.roeeSs=mot '� katnl ient5 is �c rote t;` .,,Yes ✓ 4 'or ;;N' �'�.»m r' r x 4 ro* tas. .i n t-.-,..X ya- i• + } s •_ >B ,�S t'''"s' r f ��,'K vw.9F',t�v'"`j( S, ..�'t w4, .M R. s �`� rr • §@'L r i E„ ��, - V i,;; t7F,� «"•. F, t 5410?4�. 1. f{_ ... '' .a`LI. .__'Art F,r .1 ,t, b t c t i «' „ i'tr�t`}�'��t;ts��' ti#r?:ss ,�' � �, �, w pr.,r!a�' ��t �('sw,p, to .r t E.��f fie- A� ,� ?fit Owe��,y�y c :•Ifs Yes , exhaust has ni tore ut��1Iorma _ perce>� ,s 1Vlaximuu� �sece ��S5 hpf :.,,g.1 Ci�tix5., ,}"t. •:cd,a y 2: ,y. 5 .,: vy; 'x ;�tt q s -� '.4,t Y -°vsi L4,74.'d rz,t.t ;' 'A';r�'Kr 3 % 6' ?' d� o. ? t a` ';,1 '`1 r ,',�,, r Y. sts w� rr�' � .r.fi-0 �*t !y ▪,. . "`,t s -'d �' `_i.� `fr ,ib4{4r-�, A-,,, a•:, content �� u,��- t r x. y77 ��.w -F' =� � 42 �.r�, �.��_� r�� «..;�+ 4 1S r t-y.�.+ �§c r '�vz->�r,¢.z'8' _ ��c�`�vtt� n _w!.,� �';,.'+�'r s`i ur �.s�r� �s��n��J�si-r�S, a ?tc�G r r • rgi SLY a,r. p� +tr# ' `t: Y'`.a+ a-,,-•4r i S's, I ©Wnr - iv 4 x ior+zon a ki'.t .$ , wFi7',;.: 12 r Exhaust}ti7gasf dtsohar " %a5 w' •P4 %c� h i v, F:• gz h .s e ?.(r'S,bs A r, A ,r -�„,,.,,: a7iyr^s1.;, .'4 ?be t5W. i,,^fc }".a 'P 7- a ,7 `„t".',_•• C:s ,,,k1 -,•. "i Y' x#454-xyi,y" '+k y-;,, +•rr,... +Ytj',':!.. "i. 4,,, T' " �f ��, ,u r a s. r rr': a *. s 1,,' -IA.' r 1`.' .a a r C rr k n , � F , F 3 ,�3�}^s t to��, .r 9 f d1reCLlOn .d a ;4a.1w',a i a,..,t�. .�..i^ ' ns r'a`�x.,.T'.17`t `� ..,,,',,,3!Ws� x �",., or. -t G... a .` e, j r � .�,a r°^ vs'ts=r K�x w r R z.,x, �rF-n:x�s x',rr Hr rt 4y kt ,f ,, }� u' y�-, 4"Fgiz' :.'4 7, z Is this sta k,,'e ut, p d,,iit`. .,,,, _ha anyfiob tru ₹ion}toathe free flov o, ' ' r ,. , j ,,,� ", S •.y�. \ ! (!] X TSa fa{.J2�"(+�i"a,1r .�}`+� •1C 'Y r• .' ' b x '�.'fr ^�. �'4' Xr., s 'r xrtE.ok ". f n s ... '.t .tlicil,,t .. t +f' •ti 4 ttti yi^. . t r °tEri- �gtki '¢ ti f t$,the-exhaust#Base froi tl dAm.e t . E;S' 8 =gs'r. ,,�`�u,�y} zs xe k.«r i. s`�t�' - r S '°7� 'r , ei F', r �' cil•t��tp�'5;t ,.s�.r++� s 'S7 � '.�w.a-;°,''+gay;+ 'a �Y - :. , �?.i^'G'�e A y3,s�C,�. '-:oy '� 'as �s r r,J 111 1 .4q1{... ;,,,'' .,_+.`-file[ .,4...,3Eil.r+f�. 4ffet�':ii4 't$ ra_r•+14 .':", r:3'.,.�.,. t, .y. ._crJr_P2L'yItr'� .t??"S . ,r•F c.. .� 1,.6415 9,4'4,4:'1 *****Complete the appropriate Air Permit Application Forms(s) 2000-300, 301, 302, 303, 304, ***** • • 305, 306, or 307 for each Unit exhausting through this stack. 0 0 Operating Permit Application MISCELLANEOUS PROCESSES FORM 2000-306 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: . - _ 2. Facility identification code: CO 123/0051 Cheyenne Plains Compressor Station - 3. Stack identification code: CP05 .4. Process (Unit) code: 024 5. Unit description: 9816 hp Solar Taurus 70 6. Indicate the control technology status. ❑✓ Uncontrolled ❑ Controlled If the process is controlled, enter the control device codes) from the appropriate form(s): 2000-400 2000-401 2000-402 2000-403 2000-404 2000-405 • 2000-406 2000-407 s •f k t- o 'r y 3 <a i is H:r'...' v .1''YF ypt ,,,'t1y >Z.i.'r- i7s5 ✓P '�i4 ..,, t3;, I i�` " s.sKe. A?xh ,;A4#".N,. .:. •:•C:.i; ws-.C,_°..1,F..:+..rn nno.:.. Yc?,..:k:,..iFn,?F�-.l..f�fd'it�i. _ .S"*i+'?;mud...�.. .. ..._ ,_.ry,�,�7i:?".:f✓.,e,txA.�:t�.WpSiR�6.;YY..�..;i`.r? �F,..�•�J'=�n1 8. Date first placed in service: 10/29/05 Date of last modification: • 9. Normal operating schedule: 24 hrs./day 7 days/wk. 8,760 hours/yr. 10. Describe this process (please attach a flow diagram of the process). Attached? ❑ Natural gas-fired combustion turbine that powers a natural gas compressor 11. List the types and amounts of raw materials used in this process: Material Storage/material handling process Actu�"al usage-4+ ;U,iut`ss g ;;.Maximum Units usage N/AEi £7tt r taWq . ,,fi t• V4-, 1 A Clean-up • urY t`i' t raj �F's� x solvents AY�3`A fsl t .Yaw rty:.+4 {F;*04. „ Otherti•AffAi (specify) Lk it`' , ` , •ali .i 3 . 12. List the types and amounts of finished products: Material Storage/material handling process Klieliial amount , f UnrtrTMti Maximum Units cxi *� amount produced f^� " ''i ' produced N/A te rr no* 13. Process fuel usage: • Type of fuel Maximum heat ti,=Actual°usage `tUnits t Maximum Units , .�} �.TS 4 .. i f1"•Fe- [a fj'lyr input to process y x _ : usage million BTU/hr F x .414 Natural Gas 71.42 A`^{ _ .07551 MM , L : scf/hr :, 14. Describe any fugitive emissions associated with this process, such as outdoor storage piles, unpaved roads, open conveyors, etc.: ***** For this emissions unit, identify the method(s) of compliance demonstration by completing Form 2000-500, ***** DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 and its attachments) to this form. ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** - O • 0 • Operating Permit Application COMPLIANCE CERTIFICATION-MONITORING AND REPORTING • FORM 2000-500 Colorado Department of Public Health and Environment DESCRIPTION OF METHODS USED Rev 06-95 Air Pollution Control Division FOR DETERMINING COMPLIANCE All applicants are required to certify compliance with all applicable air pollution permit requirements by --' including a statement within the permit application of the methods used for determining compliance.. This statement must include a description of the monitoring, recordkeeping, and reporting requirements and test methods. In addition, the application must include a schedule for compliance certification submittals during the permit term. These submittals must be no less frequent than annually, and may need to be more frequent if specified by the underlying applicable requirement or by the Division. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility.name: Cheyenne Plains 2. Facility identification code: CO 123/0051 Compressor Station 3. Stack identification code: CP05 4. Unit identification code: 024 5. For this Unit the following method(s) for determining compliance with the requirements of the • permit will be used (check all that apply and attach the appropriate form(s) to this form). ❑ Continuous Emission Monitoring (CEM) - Form 2000-501 Pollutant(s): . • • ❑✓ Periodic Emission Monitoring Using Portable Monitors - Form 2000-502 Pollutant(s): . ❑ Monitoring Control System Parameters or Operating Parameters of a Process - Form 2000-503 Pollutant(s): • ❑ Monitoring Maintenance Procedures - Form 2000-504- Pollutant(s): ❑✓ Stack Testing - Form 2000-505 Pollutant(s): ❑ Fuel Sampling and Analysis (FSA) - Form 2000-506 Pollutant(s): • • Recordkeeping.- Form 2000-507 . Pollutant(s): ❑ Other (please describe) - Form 2000-508 Pollutant(s): O 0 Compliance certification reports will be submitted to the Division according to the following zhedule: j Start date: and every 12 months thereafter. (12 month maximum interval) Compliance monitoring reports will be submitted to the Division according to the following schedule: Start date: and every 6 months thereafter. (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5. ,�� 0 0 Operating Permit Application COMPLIANCE DEMONSTRATION BY PERIODIC EMISSION FORM 2000-502 Colorado Department of Public Health and Environment MONITORING USING PORTABLE MONITORS Rev 06-95 r Pollution Control Division e use of a portable continuous emission monitor(CEM)may be acceptable as a compliance demonstration method. A monitoring plan shall contain the following information:the name and address of the source; the source facility identification code; a general description of the process and the control equipment; the pollutant or diluent being monitored; the manufacturer,model number, and serial number of each portable monitor; the operating principles of each portable monitor; and a schematic of the CEM system showing the sample acquisition point and the location of the monitors while sampling. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: 2. Facility identification code:-CO 123/0051 Cheyenne Plains Compressor Station 3. Stack identification code: CPO5 4. Unit identification code: 024 - - 5. Pollutant(s)or diluent(s) being monitored: NOx and CO 6. Name of manufacturer: 7. Model &serial number: 8. Is this an existing system? Yes ✓ No 9 s�r� "` Y ❑ ❑ x.,�t� �� x 'k jl c � y. :- „ ' ."t if @@fie Na it:;v4 ,,,t� v� '3..,�.:Tor,—.14,4:. r. i 4N.;u�!�1.Y'Fn�`di�_.._..:C. ��L 10. Type: ❑In situ ❑ Extractive ❑Dilution ❑Other(specify) 11. Very briefly explain the measurement design concept of the monitor: Per construction permit condition 6, compliance with BACT limits shall be demonstrated by quarterly portable monitoring test._ 12. Backup system: Norte 13. Compliance shall be demonstrated:c❑Daily ❑ Weekly ❑ Monthly. ❑✓ Other-specify (Quarterly) 14. Quality Assurance/Quality Control: - (❑ A quality assurance/quality control plan for the portable monitor is attached for Division review. ❑✓ The plan is not attached, but will be submitted to the Division by ***** Any test value over the emission limit shall be reported as an excess emission. ***** • . • • O • O Operating Permit Application COMPLIANCE DEMONSTRATION BY STACK TESTING FORM 2000-505 Colorado Department of Public Health and Environment - 09-94 Air Pollution Control Division The performance of an EPA stack test method is acceptable for demonstrating compliance with an emission limitation. EPA test method''` contain quality assurance procedures that shall be strictly adhered to by the source. The applicant shall propose an appropriate program., ) stack testing for compliance demonstration. The stack testing program shall correlate with the corresponding emission limitation in terms of the frequency and duration of the stack tests. The Division may approve the proposed stack testing program, or other programs which the Division determines to be appropriate. • SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: 2. Facility identification.code: CO 123/0051 Cheyenne Plains Compressor Station 3. Stack identification code: CP05 4. Unit identification code: 024 5. Pollutant being monitored: NOx, CO, and VOC. • 6. Procedure being monitored: Initial source test for turbine exhaust. 7. Is this an existing method of demonstrating . 8. Program start date: compliance? ❑ Yes ❑✓ No 9. EPA or Division approved test method: EPA approved method for NOx, CO, and VOC. • 10. Backup system None. . 11. Compliance shall be demonstrated:❑Daily O Weekly ❑Monthly 2 Other-specify.(initial source test) '1 ***** Any measured emission rate that exceeds an emission limitation established by the permit shall be ***** reported as an excess emission. • • • • • • 1 • Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-507 Colorado Department of Public Health and Environment BY RECORDKEEPING Rev 06-95 Air Pollution Control Division , Recordkeeping may be acceptable as a compliance demonstration method provided that a correlation between the parameter value recorded and the emission rate of a particular pollutant is established in the form of a curve or chart of emission rate versus parameter values. This correlation may constitute the certification of the system. For an existing program, the correlation demonstration must be attached for Division consideration for approval. If the correlation information has not yet been developed, please submit it within 60 days of the startup of the system. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Cheyenne Plains Compressor 2. Facility identification code: CO 123/0051 Station 3. Stack identification code: CP05 4. Unit identification code: 024 5. Pollutant(s) being monitored: PM, PM-10, 6. Material or parameter being monitored and NOx, CO, VOCs recorded: Hours of natural gas usage and ambient temperature. 7. Method of monitoring and recording (see information on back of this page): Natural gas consumption and ambient temperature are recorded. Emission factors for three different temperature ranges are used to determine emissions of NOx, CO, and VOCs. For PM-10, AP-42 emission factors are used to determine emission rates. Rolling 12 month totals are calculated. 8. List any EPA methods used: AP-42, Section 3.1 9. Is this an existing method of demonstrating 10. Start date: compliance? ❑✓ Yes ❑ No 11. Backup system: 12 a. Data collection frequency: ❑ Daily ❑ Weekly ❑✓ Monthly ❑ Batch (not to exceed monthly) ❑ Other - specify 12 b. Compliance shall be demonstrated: ❑ Daily ❑ Weekly ❑✓ Monthly ❑ Batch (not to exceed monthly) ❑ Other - specify 13. Quality Control/Quality Assurance: The monitoring system shall be subject to appropriate performance specifications, calibration requirements, and quality assurance procedures. ❑ A quality assurance/quality control plan for the recordkeeping system is attached for Division review. ❑ The plan is not attached, but will be submitted to the Division by 14. ❑ A proposed format for the compliance certification report and excess emission report is attached. ***** The compliance records shall be available for Division inspection. ***** The source shall record any malfunction that causes or may cause an emission limit to be exceeded. ***** Malfunctions shall be reported to the Division the next business day. Hazardous air releases shall be reported to the Division immediately. Operating Permit Application APPLICABLE REQUIREMENTS AND FORM 2000-604 Colorado Department of Public Health and Environment STATUS OF EMISSION UNIT Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: 2. Facility identification code: CO 123/0051 Cheyenne Plains Compressor Station 3. Stack identification code: CP05 4. Unit identification code: 024 5. Pollutant 6. Colorado Air Quality 7. 8. Limitation 9. Compliance Regulations State Status or Only IN OUT Construction Permit Number Opacity Permit#03WE1390, 20 %Opacity X Number 1 &7a NOx Permit#03WE0910, 24.5 ppmvd ambient X Number 6a(BACT) temp. above 0° F 42 ppmvd ambient temp. -20° F - 0° F 120 ppmvd ambient temp. less than-20° F CO Permit#03WE0910, 48.8 ppmvd ambient X Number 6b (BACT) temp. above 0°F 100 ppmvd ambient temp. -20° F- 0°F 120 ppmvd ambient temp. less than-20° F VOCs Permit#03WE0910, 3 ppmvd ambient temp. X Number 6c (BACT) above 0° F 5 ppmvd ambient temp. - 20° F- 0° F 8 ppmvd ambient temp. less than-20° F NOx Permit#03WE0910, 0.01895 ppmvd by X Number 7a(NSPS) volume dry basis at 15% oxygen SO2 Permit#03WE0910, .015 % by volume dry X Number 7b (NSPS) basis at 15 % oxygen,or sulfur content of fuel can't exceed 0.8 %by weight. SO2 Permit#03WE0910, * 0.8 lbs/mmBTU X Number 9b SO2 Permit#03WE0910, 0.8 lbs/mmBTU X Number 10 PM Permit#03WE0910, PE=0.5(FI)-°Z6 X Number 11 PM & PM-10 Permit#03WE0910, 0.18 tons/mo &2.1 tpy X Number 13 NOx Permit#03WE0910, 2.68 tons/mo & 31.6 tpy X Number 13 CO Permit#03WE0910, 3.27 tons/mo & 38.5 tpy X Number 13 VOCs Permit#03WE0910, 0.96 tons/mo & 11.3tpy X Number 13 Odor Permit#03WE0910, * Regulation #2 X Number 13 10. Other requirements (e.g., malfunction reporting, special operating State Only Compliance conditions from an existing permit such as material usage, hours of Status operation, etc.) IN OUT Permit condition#12—Consumption of natural gas shall not exceed 56.2 X mmSCF/month or 661.5 mmSCF/year. **** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** Operating Permit Application SUPPLEMENTAL INFORMATION FORM 2000-700 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: 2. Facility identification code: CO 123/0051 Cheyenne Plains Compressor Station 3. This form supplements Form 2000 - 604 for Emission Unit (e.g. B001, P001, etc.) 018 Additional Information, Diagrams Item Number Compliance was determined for each applicable requirement in Permit Number 03WE0913,as follows: #1, Opacity—compliance was determined by EPA Method 9 visual emissions evaluation. 9 #6a,b,&c,NOx, CO, VOCs BACT requirement—compliance determined by stack test as 9 outlined in permit condition 14. #8,NOx, CO, &VOCs emissions per year limitations—Compliance was determined by 9 recording monthly natural gas usage at each percentage of load, and using appropriate BACT emission factors from the permit. Emissions were calculated on a 12-month rolling total. #15, Odor- 9 #7, natural gas usage—compliance was determined by maintaining monthly and annual 10 records of actual natural gas consumption. Operating Permit Application STACK IDENTIFICATION FORM 2000-200 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division _ SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: 2. Facility identification code: CO 123/0051 Cheyenne Plains Compressor Station 3. Stack identification code: CPTI 3a. Construction Permit Number: 03WE0913 4. Exhausting Unit(s), use Unit identification code from appropriate Form(s) 2000-300, 301, 302, 303, 304, 305, 306, 307 2000-300 018 2000-301 2000-302 2000-303 2000-304 2000-305 2000-306 2000-307 5. Stack identified on the plot plan required on Form 2000-101 X 6. Indicate by checking: ❑✓ This stack has an actual exhaust point. The parameters are entered in Items 7-13. [1 This stack serves to identify fugitive emissions. Skip items 7-13. Go to next form. ❑ When stack height Good Engineering Practice (GEP) exceeds 65 meters (Colorado Air Quality Reg 3.A.VIII.D)A.VIII.D) data entry is required for Item 7. 7 Discharge height above'ground"level: 27.5 (feet) g Inside dimensions`a,t outlet(check one and complete), Circular 3 5 (feet) ,"' ❑ Rectangular - . . Length (feet) width",(feet) E Exhaust flow rate:.` Normal 21,216,. (ACFM) Maximum 21,216 (ACFM) ';Velocity. "36 7 (FPS): Calculated ❑ Stack"Test `10 Exhaust gas temperature°(normal): 600 (°F) ,. 11 {a Does process modify ambient air moisture content? ❑ Yes Q No If "Yes", exhaust gas moisture Normal percent.t., Maximum percent . content 12 Exhaust gas discharge ❑✓ Up a°Down" ❑"Horizontal direction '.. 13 Is this stack equipped.with-a raii�hat or any obstruction to:the free flow of . the exhaust gases from the stack? ❑ Yes ❑✓ No ***** *****Complete the appropriate Air Permit Application Forms(s) 2000-300, 301, 302, 303, 304, 305, 306, or 307 for each Unit exhausting through this stack. Operating Permit Application BOILER OR FURNACE OPERATION FORM 2000-300 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: 2. Facility identification code: CO 123/0051 Cheyenne Plains Compressor Station 3. Stack identification code: CPT1 4. Unit code: 018 5. Unit description: Hot oil heater rated at 45 mmBTU/hr. 6. Seasonal Fuel Dec-Feb: 25 Mar-May: 25 Jun-Aug: 25 Sep-Nov: 25 Usage(%) 7. Normal Hours/Day: 24 Days/Week: 7 Hours/Year: 8. Space Heat(%) Operation of Unit 8,760 0 9. Indicate the boiler/furnace control technology status. ❑ Uncontrolled ❑ Controlled If the boiler/furnace is controlled, enter the control device number(s) from the appropriate forms: 2000-400 2000-401 2000-402 2000-403 2000-404 2000-405 2000-406 2000-407 10. Furnace type: Hot oil heater 11. Max continuous rating(mmBTU/hr): 45 12. Manufacturer: Heatec 13. Model & Serial #: Serial # - unknown Model#-VHCI-16010-40-G 14. Date first placed in service: 01/30/2005 Date of last modification: 15. Fuels and firing conditions: Primary fuel Backup fuel #1 Backup fuel #2 Fuel name Natural Gas Higher heating value (with units) 945.83 BTU/scf Maximum sulfur content (Wt.%) Maximum ash content (Wt.%) Excess;Combustion Air ORz%.02„:(Circle. ,s£r 4r choice) Moisture content(as fired) (%) Maximum hourly fuel usage (units/hr.) .047578 MMscf/hr Actual annual fuel.usage:far 19 ; a ***** For this emissions unit, identify the method of compliance demonstration by completing Form 2000-500, ***** DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 and its attachment(s) to this form. ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** Operating Permit Application COMPLIANCE CERTIFICATION-MONITORING AND REPORTINGFORM 2000-500 Colorado Department of Public Health and Environment DESCRIPTION OF METHODS USED Rev 06-95 Air Pollution Control Division FOR DETERMINING COMPLIANCE i All applicants are required to certify compliance with all applicable air pollution permit requirements by including a statement within the permit application of the methods used for determining compliance. This statement must include a description of the monitoring, recordkeeping, and reporting requirements and test methods. In addition, the application must include a schedule for compliance certification submittals during the permit term. These submittals must be no less frequent than annually, and may need to be more frequent if specified by the underlying applicable requirement or by the Division. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: 2. Facility identification code: CO 123/0051 Cheyenne Plains Compressor Station 3. Stack identification code: CPT1 4. Unit identification code: 018 5. For this Unit the following method(s) for determining compliance with the requirements of the permit will be used (check all that apply and attach the appropriate form(s) to this form). ❑ Continuous Emission Monitoring (CEM) - Form 2000-501 Pollutant(s): ❑ Periodic Emission Monitoring Using Portable Monitors - Form 2000-502 Pollutant(s): ❑ Monitoring Control System Parameters or Operating Parameters of a Process - Form 2000-503 • Pollutant(s): ❑ Monitoring Maintenance Procedures -Form 2000-504 Pollutant(s): ❑✓ Stack Testing - Form 2000-505 Pollutant(s): ❑ Fuel Sampling and Analysis (FSA) - Form 2000-506 Pollutant(s): Recordkeeping - Form 2000-507 Pollutant(s): ►l Other(please describe) - Form 2000-508 Pollutant(s): Compliance certification reports will be submitted to the Division according to the following :.hedule: Start date: and every 12 months thereafter. (12 month maximum interval) Compliance monitoring reports will be submitted to the Division according to the following schedule: Start date: and every 6 months thereafter. (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5. Operating Permit Application COMPLIANCE DEMONSTRATION BY STACK TESTING FORM 2000-505 Colorado Departmemt of Public Health and Environment 09-94 Air Pollution Control Division The performance of an EPA stack test method is acceptable for demonstrating compliance with an emission limitation. EPA test methods )ntain quality assurance procedures that shall be strictly adhered to by the source. The applicant shall propose an appropriate program of stack testing for compliance demonstration. The stack testing program shall correlate with the corresponding emission limitation in terms of the frequency and duration of the stack tests. The Division may approve the proposed stack testing program, or other programs which the Division determines to be appropriate. • SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: 2. Facility identification code: CO 123/0051 Cheyenne Plains Compressor Station 3. Stack identification code: CPT1 4. Unit identification code: 018 5. Pollutant being monitored: NOx, CO, and VOC. 6. Procedure being monitored: Initial source test for heater exhaust. 7. Is this an existing method of demonstrating 8. Program start date: compliance? ❑Yes No 9. EPA or Division approved test method: EPA approved method for NOx, CO, and VOC. 10. Backup system None. 11. Compliance shall be demonstrated:❑Daily ❑Weekly ❑Monthly El Other- specify(initial source test) ***** Any measured emission rate that exceeds an emission limitation established by the permit shall be ***** reported as an excess emission. 1 Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-507 Colorado Department of Public Health and Environment BY RECORDKEEPING Rev 06-95 Air Pollution Control Division Recordkeeping may be acceptable as a compliance demonstration method provided that a correlation between, the parameter value recorded and the emission rate of a particular pollutant is established in the form of a curve or chart of emission rate versus parameter values. This correlation may constitute the certification of the system. For an existing program, the correlation demonstration must be attached for Division consideration for approval. If the correlation information has not yet been developed, please submit it within 60 days of the startup of the system. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: 2. Facility identification code: CO 123/0051 Cheyenne Plains Compressor Station 3. Stack identification code: CPTI 4. Unit identification code: 018 5. Pollutant(s) being monitored: NOx, VOCs, 6. Material or parameter being monitored and CO recorded: Actual consumption of natural gas. 7. Method of monitoring and recording (see information on back of this page): Natural gas consumption is recorded. Emission factors are used to determine emissions of NOx, CO, and VOCs. Rolling 12 month totals are calculated. 8. List any EPA methods used: 9. Is this an existing method of demonstrating 10. Start date: compliance? ❑✓ Yes ❑ No 11. Backup system: 12 a. Data collection frequency: ❑✓ Daily ❑ Weekly ❑ Monthly ❑ Batch (not to exceed monthly) ❑ Other - specify 12 b. Compliance shall be demonstrated: ❑ Daily ❑ Weekly ❑✓ Monthly ❑ Batch (not to exceed monthly) ❑ Other - specify 13. Quality Control/Quality Assurance: The monitoring system shall be subject to appropriate performance specifications, calibration requirements, and quality assurance procedures. ❑ A quality assurance/quality control plan for the recordkeeping system is attached for Division review. ❑ The plan is not attached, but will be submitted to the Division by 14. ❑ A proposed format for the compliance certification report and excess emission report is attached. ***** The compliance records shall be available for Division inspection. ***** The source shall record any malfunction that causes or may cause an emission limit to be exceeded. ***** Malfunctions shall be reported to the Division the next business day. Hazardous air releases shall be reported to the Division immediately. Operating Permit Application APPLICABLE REQUIREMENTS AND FORM 2000-604 Colorado Department of Public Health and Environment STATUS OF EMISSION UNIT Rev 06-95 Air Pollution Control Division , SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: 2. Facility identification code: CO 123/0051 Cheyenne Plains Compressor Station 3. Stack identification code: CPT1 4. Unit identification code: 018 5. Pollutant 6. Colorado Air Quality 7. 8. Limitation 9. Compliance Regulations State Status or Only IN OUT Construction Permit Number Opacity Permit# 03WE0913 20% X Number 1 & llb NOx Permit#03WE0913 At 50- 100% load, X Number 6a 0.035 lbs/mmBTU, on a 1 hour average. At less than 50% load, 0.056 lbs/mmBTU, on a 1 hour average. CO Permit#03WE0913 0.037 lbs/mmBTU, on a X Number 6b 1 hour average VOCs Permit# 03WE0913 0.016 lbs/mmBTU, on a X Number 6c 1 hour average NOx Permit# 03WE0913 6.9— 11.1 tons/yr. X Number 8 emissions VOCs Permit# 03WE0913 3.15 tons/yr emissions X Number 8 CO Permit#03WE0913 7.3 tons/yr emissions X Number 8 PM Permit#03WE0913 PE =0.5(FI)-0.26 X Number 9 & 11 a Odor Permit# 03WE0913 * Regulation#2 X Number 15 10. Other requirements (e.g., malfunction reporting, special operating State Only Compliance conditions from an existing permit such as material usage, hours of Status operation, etc.) IN OUT Permit condition #7—Consumption of natural gas for each oil heater shall X not exceed 35.4 mmSCF/month or 416.8 mmSCF/year. **** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** Compliance certification reports will be submitted to the Division according to the following :.hedule: Start date: and every 12 months thereafter. (12 month maximum interval) Compliance monitoring reports will be submitted to the Division according to the following schedule: Start date: and every 6 months thereafter. (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5. Operating Permit Application STACK IDENTIFICATION FORM 2000-200 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Cheyenne Plains Compressor 2. Facility identification code: CO 123/0051 Station 3. Stack identification code: CPT2 3a. Construction Permit Number: 03WE0913 4. Exhausting Unit(s), use Unit identification code from appropriate Form(s) 2000-300, 301, 302, 303, 304, 305, 306, 307 2000-300 019 2000-301 2000-302 2000-303 2000-304 2000-305 2000-306 2000-307 5. Stack identified on the plot plan required on Form 2000-101 X 6. Indicate by checking: i This stack has an actual exhaust point. The parameters are entered in Items 7-13. ❑ This stack serves to identify fugitive emissions. Skip items 7-13. Go to next form. n When stack height Good Engineering Practice (GEP) exceeds 65 meters (Colorado Air Quality Reg 3.A.VIII.D)A.VIII.D) data entry is required for Item 7. 7 Discharge height above ground level ;:' 27.5." (feet) 8 Inside:dimensions at outlet (check one and.complete) circular 3.5f` (feet) ( ] Rectari ular length;(feet) width:(feet) 9s Exhaust flaw rate:, Normat • "21,214 (ACFM) Maximum 2'1,216 (ACFM) Velocity' 36.7' (FPS) 71 Calculated ❑-Stack.Test 10., Exhaust gas tempe ature (norrrial): ' 60 (°F) 11 ;Does: rocessmodi ambient air moisture.content? ❑ Yes l of 6 If'°Yes", exhaust gas moisture Narma1. percent Maximum ,,:percent content 12 Exhaust gas:discharge :Up ❑ Down ❑J.Horizontal direction 13. `Is thisgstack equipped.with a rainhat or any,obstruction to=they free flow:of the exhaust gases from the stack? ❑ YesED;No *****Complete the appropriate Air Permit Application Forms(s) 2000-300, 301, 302, 303, 304, ***** 305, 306, or 307 for each Unit exhausting through this stack. Operating Permit Application BOILER OR FURNACE OPERATION FORM 2000-300 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Cheyenne Plains 2. Facility identification code: CO 123/0051 Compressor Station 3. Stack identification code: CPT2 4. Unit code: 019 5. Unit description: Hot oil heater rated at 45 mmBTU/hr 6. Seasonal Fuel Dec-Feb: 25 Mar-May: 25 Jun-Aug: 25 Sep-Nov: 25 Usage(%) 7. Normal Hours/Day: 24 Days/Week: 7 Hours/Year: 8. Space Heat(%) Operation of Unit 8,760 0 9. Indicate the boiler/furnace control technology status. ❑ Uncontrolled Controlled If the boiler/furnace is controlled, enter the control device number(s) from the appropriate forms: 2000-400 2000-401 2000-402 2000-403 2000-404 2000-405 2000-406 2000-407 10. Furnace type: Hot oil heater 11. Max continuous rating(mmBTU/hr): 45 12. Manufacturer: Heatec 13. Model & Serial #: Serial # unknown Model# VHCI-16010-40-G 14. Date first placed in service: 01/30/05 Date of last modification: 15. Fuels and firing conditions: Primary fuel Backup fuel #1 Backup fuel #2 Fuel name Natural Gas Higher heating value (with units) 945.83 BTU/scf Maximum sulfur content (Wt.%) Maximum ash content (Wt.%) `! kr x�yS'Y'z"a2��tg�46�'"'��Y� y{1K�gi�"+� �1�� xr1�x E „v,400.04460:4,004,11:0 f t t c:s Fo Moisture content (a fir (% ' L'''„r 0+' !;'.9�5 f r3 r 670, Maximum hourly fuel usage (units/hr.) .047578 MMscf/hr •Actu4annual fuel usage,fox-19i r r 3r ,il rr r r t x ***** For this emissions unit, identify the method of compliance demonstration by completing Form 2000-500, ***** DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 and its attachment(s) to this form. ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** Operating Permit Application COMPLIANCE CERTIFICATION - MONITORING AND REPORTINGFORM 2000-500 Colorado Department of Public Health and Environment DESCRIPTION OF METHODS USED Rev 06-95 Air Pollution Control Division FOR DETERMINING COMPLIANCE All applicants are required to certify compliance with all applicable air pollution permit requirements by including a statement within the permit application of the methods used for determining compliance. This statement must include a description of the monitoring, recordkeeping, and reporting requirements and test methods. In addition,the application must include a schedule for compliance certification submittals during the permit term. These submittals must be no less frequent than annually, and may need to be more frequent if specified by the underlying applicable requirement or by the Division. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Cheyenne Plains Compressor 2. Facility identification code: CO 123/0051 Station 3. Stack identification code: CPT2 4. Unit identification code: 019 5. For this Unit the following method(s) for determining compliance with the requirements of the permit will be used (check all that apply and attach the appropriate form(s) to this form). ❑ Continuous Emission Monitoring (CEM) - Form 2000-501 Pollutant(s): ❑ Periodic Emission Monitoring Using Portable Monitors - Form 2000-502 Pollutant(s): ❑ Monitoring Control System Parameters or Operating Parameters of a Process - Form 2000-503 Pollutant(s): ❑ Monitoring Maintenance Procedures - Form 2000-504 Pollutant(s): ❑ Stack Testing - Form 2000-505 Pollutant(s): ❑ Fuel Sampling and Analysis (FSA) - Form 2000-506 Pollutant(s): ❑✓ Recordkeeping - Form 2000-507 Pollutant(s): ❑ Other(please describe) - Form 2000-508 Pollutant(s): Compliance certification reports will be submitted to the Division according to the following ::hedule: Start date: and every 12 months thereafter. (12 month maximum interval) Compliance monitoring reports will be submitted to the Division according to the following schedule: Start date: and every 6 months thereafter. (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5. Operating Permit Application COMPLIANCE DEMONSTRATION BY STACK TESTING FORM 2000-505 Colorado Department of Public Health and Environment 09-94 Air Pollution Contrd Division The performance of an EPA stack test method is acceptable for demonstrating compliance with an emission limitation. EPA test methods intain quality assurance procedures that shall be strictly adhered to by the source. The applicant shall propose an appropriate program of stack testing for compliance demonstration. The stack testing program shall correlate with the corresponding emission limitation in terms of the frequency and duration of the stack tests. The Division may approve the proposed stack testing program, or other programs which the Division determines to be appropriate. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: 2. Facility identification code: CO 123/0051 Cheyenne Plains Compressor Station 3. Stack identification code: CPT2 4. Unit identification code: 019 5. Pollutant being monitored: NOx, CO, and VOC. 6. Procedure being monitored: Initial source test for heater exhaust. 7. Is this an existing method of demonstrating 8. Program start date: compliance? ❑Yes ONo 9. EPA or Division approved test method: EPA approved method for NOx, CO, and VOC. 10. Backup system None. 11. Compliance shall be demonstrated:❑ Daily L7 Weekly 0 Monthly 0✓ Other- specify (initial source test) ***** Any measured emission rate that exceeds an emission limitation established by the permit shall be ***** reported as an excess emission. 1 Operating Permit Application COMPLIANCE DEMONSTRATION BY STACK TESTING FORM 2000-505 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division The performance of an EPA stack test method is acceptable for demonstrating compliance with an emission limitation. EPA test method" contain quality assurance procedures that shall be strictly adhered to by the source. The applicant shall propose an appropriate program stack testing for compliance demonstration. The stack testing program shall correlate with the corresponding emission limitation in terms of the frequency and duration of the stack tests. The Division may approve the proposed stack testing program, or other programs which the Division determines to be appropriate. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: 2. Facility identification code: CO 123/0051 Cheyenne Plains Compressor Station 3. Stack identification code: CPT2 4. Unit identification code: 019 5. Pollutant being monitored: NOx, CO, and VOC. 6. Procedure being monitored: Initial source test for heater exhaust. 7. Is this an existing method of demonstrating 8. Program start date: compliance? ❑Yes ❑✓ No 9. EPA or Division approved test method: EPA approved method for NOx, CO, and VOC. 10. Backup system None. 11. Compliance shall be demonstrated: Daily ❑ Weekly ❑Monthly ❑✓ Other-specify(initial source test) ***** Any measured emission rate that exceeds an emission limitation established by the permit shall be ***** reported as an excess emission. 1 1 Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-507 Colorado Department of Public Health and Environment BY RECORDKEEPING Rev 06-95 Air Pollution Control Division Recordkeeping may be acceptable as a compliance demonstration method provided that a correlation between AL the parameter value recorded and the emission rate of a particular pollutant is established in the form of a curve or chart of emission rate versus parameter values. This correlation may constitute the certification of the system. For an existing program, the correlation demonstration must be attached for Division consideration for approval. If the correlation information has not yet been developed, please submit it within 60 days of the startup of the system. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Cheyenne Plains Compressor 2. Facility identification code: CO 123/0051 Station 3. Stack identification code: CPT2 4. Unit identification code: 019 5. Pollutant(s) being monitored: NOx, VOCs, 6. Material or parameter being monitored and and CO recorded: Actual consumption of natural gas. 7. Method of monitoring and recording (see information on back of this page): Natural gas consumption is recorded. Emission factors are used to determine emissions of NOx, CO, and VOCs. Rolling 12 month totals are calculated. 8. List any EPA methods used: 9. Is this an existing method of demonstrating 10. Start date: compliance? ❑✓ Yes ❑ No 11. Backup system: 12 a. Data collection frequency: ❑✓ Daily ❑ Weekly ❑ Monthly ❑ Batch (not to exceed monthly) ❑ Other - specify 12 b. Compliance shall be demonstrated: ❑ Daily ❑ Weekly ❑✓ Monthly ❑ Batch (not to exceed monthly) ❑ Other - specify 13. Quality Control/Quality Assurance: The monitoring system shall be subject to appropriate performance specifications, calibration requirements, and quality assurance procedures. ❑ A quality assurance/quality control plan for the recordkeeping system is attached for Division review. ❑ The plan is not attached, but will be submitted to the Division by 14. ❑ A proposed format for the compliance certification report and excess emission report is attached. ***** The compliance records shall be available for Division inspection. ***** The source shall record any malfunction that causes or may cause an emission limit to be exceeded. ***** Malfunctions shall be reported to the Division the next business day. Hazardous air releases shall be reported to the Division immediately. Operating Permit Application APPLICABLE REQUIREMENTS AND FORM 2000-604 Colorado Department of Public Health and Environment STATUS OF EMISSION UNIT Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: 2. Facility identification code: CO 123/0051 Cheyenne Plains Compressor Station 3. Stack identification code: CPT2 4. Unit identification code: 019 5. Pollutant 6. Colorado Air Quality 7. 8. Limitation 9. Compliance Regulations State Status or Only IN OUT Construction Permit Number Opacity Permit#03WE0913 20% X Number 1 & 11 b NOx Permit#03WE0913 At 50- 100%load, X Number 6a 0.035 lbs/mmBTU, on a 1 hour average. At less than 50%load, 0.056 lbs/mmBTU, on a 1 hour average. CO Permit#03WE0913 0.037 lbs/mmBTU, on a X Number 6b 1 hour average VOCs Permit#03WE0913 0.016 lbs/mmBTU, on a X Number 6c 1 hour average NOx Permit#03WE0913 6.9— 11.1 tons/yr. X Number 8 emissions VOCs Permit#03WE0913 3.15 tons/yr emissions X Number 8 CO Permit# 03WE0913 7.3 tons/yr emissions X Number 8 PM Permit# 03WE0913 PE=0.5(FI)"°'26 X Number 9 & 11 a Odor Permit#03WE0913 © Regulation# 2 X Number 15 10. Other requirements (e.g., malfunction reporting, special operating State Only Compliance conditions from an existing permit such as material usage, hours of Status operation, etc.) IN OUT Permit condition#7—Consumption of natural gas for each oil heater shall X not exceed 35.4 mmSCF/month or 416.8 mmSCF/year. **** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** • O . O , Operating Permit Application • STACK IDENTIFICATION FORM 2000-200 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE •• 1. Facility name: • 2.Facility identification code: CO 123/0051 - . • Cheyenne Plains Compressor Station . 3. Stack identification code: CPT5 3a. Construction Permit Number: 03WE0916 4. Exhausting Unit(s), use Unit identification code from appropriate Forms) 2000-300, 301, 302, 303, 304, 305, 306, 307 • 2000-300 2000-301 • 2000-302 2000-303 2000-304 2000-305 2000-306 022 2000-307 - • 5. •Stack identified on the plot plan required on Form 2000-101 X • 6. Indicate by checking: , ❑✓ This stack has an actual exhaust'point. The parameters are entered in Items 7-13. ❑ This stack serves to identify fugitive emissions. Skip items 7-13. Go to next form. ❑ When stack height Good Engineering Practice (GEP) exceeds 65 meters (Colorado Air Quality Reg 3.A.VIII.D) data entry is required for Item 7. •Y�` ...�:"_.q� &• "iX�..e ;d�'si.';Nt3 .n 73 rt�1- --s' f'.ivttt. -•. r;? .''r`3'�aCr'''-*. 4�6t pry 'r't�. ,,;q,r�ie c ', ''� f+' C y P.ia. 7i ''d '''7 r,7+ YDischarQQe-herghYabo e.3 roun Ievelt = 275x �f •et1k ,: _ . „0,a ' '' r ,�-� a.ty+r �y's.; .. g.v.„.1 f..`-'�`•rr :tr a�y�r,,-r' �,,, J'-•. 1.* �14',.i�.f `d' t ; ,i 4 f .1 j . -iA,4L 7 sr .y>:,,, e"ric'n v� ..di 'cit 44-1 I„_'�.hvJt .agt`,93f.<`i. ,dL"i:-h+I�Yw'3.VA:41 "Wn.. .. .k..Mi:;';,'.r-•'4�'rfC`C;>i.hxad.`.,.:*7..-.Ys?'�.ass-': _ ,nF' i..„.fl i,,e 4t, e +:1 _::e :�...° y,•L(:.n ,,, „, Y215.v2k.„ t..'?..........i.lw' F '3+ y'f . WS 5(. pF i„..v_ a � ta"�+..`ri..{'r%�.[^�'^�EY��-y �y'fit. t, J,i7:7- `,�.+�y_t, �t'8 'i "` +Inslde.,drmengip s atgou Yet pue:. v„:,i f dfsyweltoi -0 Tw+W{<'py.5 lY�°i Y _L' 1R'fI .., Li v sal' ' �'Ttgt At, +y 'k"�1'°rrh�i't�'��,.`�,7'7•��h'"�{�N6. ��j�{`�'b�.� c.. - ":tiw'�-c�;, ;pp,.}�„h:?5�Sr�'y,.. .btiZZ�`1��'aa--�''.��q,�. 1.3�--".,.'��+ �o-n �t r +tt''�`��r�°�""�r :�¢�'St�wxti; �I^��t�'' F��,y .-.,CL _s F)},'1" 7+iL x"' s<'''t+t P?}.j.. q:,y� .._fit.. ��:at. tL, ofk ""t� k::'�7.,t�d`₹f t ,�,,�rrN� l �s,,"�i�`�ivlk'^ ? •,�i".�i 3'�'�l." -F.`� }�k"•S - `Gtrcular,,r '.▪36S .si- >5 T`Rectangular00` � ..0„ ' °le gik (tfeet)� . ,_ width (feet) U: h 4:4'3•.n '%, :Y,r;✓J.,: 47,U .:64:•`••tY,g. AvJi7.5 r,_•2xtix <3i' .T-...h?.(kr.l"°Jk'b. +...?.A�'�X, r....7 �r.¢...v '_,3t .,,,„'''.:+ihAkt:.'f'Tw:4<..,..,w,fx tom.w.r;;:3.. ;,....q_ �7�.'�IK-i 1 5 {•�. ,Yb ,g��-'. �t.�,�H,rc,h•,'k, ray"y.� .,� n c'r�,� �+a L 1�a ry tSf ''1i4°i 3'I n : f .�au?�#•!tom �t S kgt . Exhaust flo . rate-y�� ;�.u'i0 Norniatt 21410. FACIEN.fl � mere₹nWr4l 1216, � v:'" P' it 'txc 7 +rg5 t �,< Y6..,'. - ,r ;7;f rS� a _.W.', se ,y�-?, ' '-. _ :r t ..�d i 7 :v� �c s ^u�gg '�.,N�i'c �sr'b!vt�za � .��rr�?� �F�.,? '� 3.'-� ''�.�.f > 'F"'tt � � � ,i' .'L^�., y- u- � a��.. ��',}� �. �,, �' �<,. r'rt' � '� r,h ..�c� x.,` ytKrgvnt�'t�` N"�" A��,-�' { :'�li''�'� vjyP•' i C-,.� 'g g .�•-�,} , 'e..'f,vt�'1 `� 'Cm �r q*ttiY f'+ �� P.sslr': r. �t)r'x.stF1'�v f,?..�'.i 4, ^ y nY�->uR ,} P'P°x(7vw;: 114 ,gm) 4k,<t,`^t�$ ' fs', �.'�' K;"14^•s:V'.''• .i r rgr tY' r� ., ro •L'I�;ri'O 3 a r '+:fu _.,a'txl �e' Of E'. ,s ` I '� �'' ' .�n�&c6`..�y�`t•� i'a r Fvelocit,5 36 7t b(FES),✓-G�alculated_,® S'tacl Tet~Y t i < i* '}� tt=og V i ,, _,y .,. , ..:47:.c. * . ...'''1tt b.i,.„.,...:'',,,,,t f�i,.:„,„n,„-*<S o..:.zzt�i s b'e'er' R;,A,co.i.,,.',k..+ .i'.e.),.w}'.A, A Jfi. 1.4,,•'`.-''Nato:..-F-•: .,: 'rtxr5 .je-.y' .• ..4,Vt^riser-"-.;.'Y--"5: A?Y nr + i" F - o, •.,ix �• ikV'7tY'x�a NtV, trig,*!4'it�Sif-7, Fj,�+e•1V_S t Y-" •.411, kP t0i,�,; Exhail*gaiSAttettlpera eR normal) 0.( ( F) L. >f ,. 0 414 , {'�}t:W "'�.?} i t•:`,...tt, ,f wf y U- _ t: L '�.T+t Y1.,lY.�L ;r n 3,:iN.,.,,e 'Vl,.R.:.'Ir. ;5-•-.Y O" ..h ;11 i '}, r.-, � ;...:. "}Y� l5€: � J{,4,x,, „+,7�,X..'e?.i$'^1T icnt,-Y ,.1k . ..'1 S.:-:1..C. �,.( i. :.L., _iY q<rF/+i:. <fi.�l`i r�-tF: - 5.i.,,.�, y., tt � VI W..TG<I,..X'.T,� �R�1< S^k '.i 5--Ztt 4jy '� f.'!' +N °°Y"'L-'t�Ft�' "`i`7r'CJ� M°{�'�r�' 7`v"�4{ 11-0, ,w--,,,,-,..,-4-< tocesg�maidt� `ambie l4Alt morsturer conCerla #eY,esi ;®f IKCA }r •• {ry vi u.: S r at f4. ASR.,',''t-,,,,. ^Y.1.,.4•,A45•...:".?•P.!,, r Y�,-,vtt ,i4 r "i 1 ,1 .', t• €. . a 7 x r 5 f�'} rt ei. , 4 ��x4 tr'� ;` „ r, v,Y, s t�.s n do ''�2 kY a T 'sb ` 4� •0, YYi.esrei exhaust as mo slure .%,;:,anal .` ercent q , � . Maxii4i1Nr ls ,,,percAenki r i:� ry. C �M1.'t �� Lt \C'f. 7 .�Z��i Y T � � 4"Y� S,�< �T 9 M��Y IA.YF w � �y �'F' �%IM��° Yj,`F') Yy -...,,- .'i.,,? 7 t, 3-v k°e, 64.V rf 4•;,w w ,a °if$ r_rtl u;' 5*� re w :i v l';h r �„e a s r GOnteiit i Ip#G" F .1r a r +M y t-.*<: , `. i.•do' . s 4..::.. t lz zp a:�a'` .�7 ..S4 �°.�c...�[��'��="i4 � .tea .-tit..::' c �r +� ...k.r.,:�•.p...,..,.$••••..,...,: .�.�,c^il'cia vra"�S:k.�. k . i vt.L r.T - f - :Y +.a-A(f rl .L't ,��, �I t C •e{Ts}+ °'f 1 } Ai WY -t'd'`%`� t71 ti@ 35.. �° d`5 7,cI"'Yr A t^N C I .�. 1 -z.q. "t. Y+ y,'a'f 1,2 _ `E,xhausl.,gasr usemme `-t; 1 ®pup _ , ,Y€�zv ,-4 t�I.7�ow �j .,, ."-A tal d � > - , y __,�yr .�" >-� � a"f'v of� ;�:j, ks x,.-, s#'K (( -. .s=�;:.'''-:----: 7t",- d 4 x a .z' .., `��,. 'Yv'3d� s• .I r.fAir eA r [.-x,r �F;S'itI d Y 'ff 1.eP4•V• f r & -' LX' ,.,.� ' �'i'$"`it ^'1. -'tireat0n k'v•fr ei ,: s v; :t ':'r 4t g i''---- - . - .'.• -." ��sx F 4.. _ Y •u>F- A "tr ��'w'�'�xarrh .., c ,. Ica {f 5'Y�' +S• ,,R v��5 G rc''y<�i,,r.�iC -&b�€5�� n �:.�'Y.:., k-cv' t yr,�,{', a�eR ^kf.Y+.,�J'4F•ht.l.M;tG'«zK N'S"R..."S"� r"`r.�K .:. .Gi 1 k!-SS+• w _ b'! �r z.�.A"+ � � 'el'a ia`[r �"s�,pr• •''°'S4 a: .t#3 �'�t t„•13 thik''''i ckeegili f edtwat''141a _11111 atnor any obshtiuctzonys tb the ee 10Vps t,ti ,may ¢0' 4 • `. t-41 k r.f. H ,.,, 61•.r R•••• dfT-' ; '<: ise 4.1 I;E '.,,sa d.tur' r— ' t= •�,:? t*d 34 . '',i" 4-.^, L'T t'11 :;ph.3 r�'f-. I'. the exhaustrgasestf,omi q 9taG 4 tyt eS,+®"No' ,.1 +�i�Y: .F s r y4�, a ,4, to �� m „ d° b h 1 r Y b 1 r v .�'.` r .,. t s."c3� ;,�5�Yriz 'rr`2t1i� �..._�:�.,rri,..:,•�r.t. . 4s� ..e,Er. .i"..Ctck;`4� �rt..,�'��'�,'.�r-v�.�t?;.� 'Cf..-c. ,>.< *****Complete the appropriate Air Permit Application Forms(s) 2000-300, 301, 302, 303, 304, ***** 305, 306, or 307 for each Unit exhausting through this stack. • J 0 0 Operating Permit Application MISCELLANEOUS PROCESSES FORM 2000-306 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE , 1. Facility name: 2. Facility identification code: CO 123/0051 • Cheyenne Plains Compressor Station 3. Stack identification code: CPT5 4. Process (Unit) code: 022 5. Unit description: Emissions from the amine unit and associated flash tank, and emissions from the glycol dehydrator regenerator (still) vent are routed to a flare to reduce VOC and HAPI emissions. 6. Indicate the control technology status. ❑ Uncontrolled „ ❑ Controlled If the process is controlled, enter the control device code(s) from the appropriate form(s): 2000-400 2000-401 2000-402 .. 2000-403 2000-404 2000-405 - 2000-406 = 2000-407 t .t y�Y_7�Sri'E� y � ,.. ,...,� _ .. �; :�, y... �: j'r-t. �r r,r r :Actual annualDroQess�ratesfar I'9�z" ;�t "',�,w,'�'rt•`�t u 1*r F�; i b v l�x �„�� .'�e'e' , z r"' r.:•.�,..?>s[. .��;qq.:�r.4,$:.T. "� �'a�.�r..��'fir^e"'°d.1��9'�w_��.�,.�.x32,r .x ��Yk: '�:e .,�i�.�+�F`��" �,r�`.Jl.� r��,2h�,.tv.*.,i.,�;;'t,�.' ,.:uy., 8. Date first placed in service: 01/30/05 Date of last modification: 9. Normal operating schedule: hrs./day days/wk. 8,760 hours/yr. 10. Describe this process (please attach a flow diagram of the process). Attached? ❑ Emissions from the amine unit and associated flash tank, and emissions from the glycol dehydrator regenerator (still) vent are routed to a flare to reduce VOC and HAP emissions. 11. List the types and amounts of raw materials used in this process: Material Storage/material handling process Acf0usa0t ��Unitfi Maximum ' Units q �,ir 4t .4` usage Al in tj„. r` a X'$ ir MriL'✓.."r.e}tS ., Clean-up solvents . Other aff;�3≥r<,;tort * , (specify) ' L;a"f ,6. '; 12. List the types and amounts of finished products: Material Storage/material handling process gwo4gowthit.--fvotws Maximum Units 3Ff1�1Fllroduced *u amount ctaiv.v. w ''p t r4� i� �s.�.�,�, �.. produced 101•143,'M M mgow r. 13. Process fuel usage: . Type of fuel Maximum heat tp4ctualusage_ Umts` Maximum Units input to process �rrt, ,,Y; :'�;ztyxy g y � usa e million BTU/hr. 001-04-L. Natural gas ? ± ` • 14. Describe any fugitive emissions associated with this process, such as outdoor storage piles, unpaved roads, open conveyors, etc.: ***** For this emissions unit, identify the method(s) of compliance demonstration byLcompleting Form 2000-500, ***** . . DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 and its attachment(s) to this form. ***** Please complete the Air Pollution Control Permit Application Forms 2000-60&and 2000-601 for this Unit. ***** O • • O Operating Permit Application COMPLIANCE CERTIFICATION -MONITORING AND REPORTINGFORM 2000-500 Colorado Department of Public Health and Environment DESCRIPTION OF METHODS,USED Rev 06-95 Air Pollution Control Division FOR DETERMINING COMPLIANCE ) All applicants are required to certify compliance with all applicable air pollution permit requirements by including a statement within the permit application of the methods used for determining compliance. •This statement must include a description of the monitoring, recordkeeping, and reporting requirements and test methods. In addition, the application must include a schedule for compliance certification submittals during the permit term. These submittals must be no less frequent than annually, and • may need to be more frequent if specified by the underlying applicable requirement or by the Division. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: 2. Facility identification code: CO 123/0051 ' Cheyenne Plains Compressor Station 3. • Stack identification code: CPT5 • 4. Unit identification code: 022 5. For this Unit the following method(s) for determining compliance with the,requirements of the • permit will be used (check all that apply and attach the appropriate form(s) to this form). ❑ Continuous Emission Monitoring (CEM) - Form 2000-501 Pollutant(s): • ❑ Periodic Emission Monitoring Using Portable Monitors - Form 2000-502 • Pollutant(s): ❑ Monitoring Control System Parameters or Operating Parameters of a Process - Form 2000-503 �..d Pollutant(s): ❑ Monitoring Maintenance Procedures - Form 2000-504 • s Pollutant(s): ❑ Stack.Testing - Form 2000-505 • Pollutant(s): ❑ Fuel Sampling and Analysis (FSA) - Form 2000-506 . Pollutant(s): • • ❑ Recordkeeping - Form 2000-507 • • Pollutant(s): • ❑ Other (please describe) - Form 2000-508 • Pollutant(s): • • • o oH• Compliance certification reports will be submitted to the Division according to the following zhedule: Start date: and every 12 months'thereafter. (12 month maximum interval) Compliance monitoring reports will be submitted to the Division according to the following schedule: Start date: ,! and every 6 . months thereafter. (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5. • • • • o • 0 Operating permit Application COMPLIANCE DEMONSTRATION FORM 2000-507 Colorado Department of Public Health and Environment BY RECORDKEEPING Rev 06-95 Air Pollution Control Division Recordkeeping may be acceptable as a compliance demonstration method provided that a correlation between the parameter value recorded and the emission rate of a particular pollutant is established in the form of a curve or chart of emission rate versus parameter values. This correlation may constitute the certification of the system. For an existing program, the correlation demonstration must be attached for Division consideration for approval. If the correlation information has not yet been developed, please submit it within 60 days of the startup of the system. - SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: 2. Facility identification code: CO 123/0051 • Cheyenne Plains Compressor Station 3. Stack identification code: CPT5 4. Unit identification code: 022 5. Pollutant(s) being monitored: VOCs, NOx, 6. ' Material or parameter being monitored and and CO - recorded: 7. Method of monitoring and recording (see information on back of this page): Compliance will be demonstrated by following 40 CFR Part 60 Subpart A. • • • 8. List any EPA methods used:• - • 9. Is this an existing method of demonstrating 10. Start date: • compliance? • ❑ Yes J No' 11. Backup system: • 12 a. Data collection frequency: ❑ Daily ❑ Weekly ❑ Monthly ❑ Batch (not to exceed monthly) ❑✓ Other - See Item7 12 b.. Compliance shall be demonstrated: ❑ Daily ❑ Weekly ❑ Monthly ❑ Batch (not to exceed monthly) ❑✓ Other - See Item7 13. Quality Control/Quality Assurance: • The monitoring system shall be subject to appropriate performance specifications, calibration requirements, and quality assurance procedures. ❑ A quality assurance/quality control plan for the recordkeeping system is attached for Division review. • • ❑ The plan is not attached, but will be submitted to the Division by 14. ❑ A proposed format for the compliance certification report and excess emission report is attached. ***** The compliance,records shall be available for Division inspection. ***** The source shall record any Malfunction that causes or may cause an emission limit to be exceeded. ***** Malfunctions shall be reported to the Division the next business day. Hazardous air releases shall be reported to the Division immediately. o o Operating Permit Application APPLICABLE REQUIREMENTS AND FORM 2000-604 Colorado Department of Public Health and Environment STATUS OF EMISSION UNIT Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE • - 1. Facility name: 2. Facility identification code: CO 123/0051 ' Cheyenne Plains Compressor Station 3. Stack identification code: CPT5 • 4. Unit identification code: 022;' 5. Pollutant 6. Colorado Air Quality 7. 8. Limitation 9. Compliance Regulations • State • Status • . or ' Only !' IN OUT • . Construction Permit Number Opacity • Permit#03WE0916 20% Opacity X Number 1 Opacity Permit#03WE0916 30% Opacity for a.period X Number 2 • or periods aggregating; more than 6 minutes in any sixty consecutive minutes. VOCs Permit#03WE0916 5.8 tons per year X Number 12 NOx Permit#03WE0916 7.4 tons per year X Number 12 CO Permit#,03WE0916 39.42 tons per year X Number 12 Odor Permit#03WE0916 * CAQCC Reg. 2 . " X Number 14 !; • 10. Other requirements (e.g., malfunction reporting, special operating • State Only Compliance conditions from an existing permit such as material usage, hours of Status operation, etc:) • IN ;; OUT Permit condition #13 —Processing of natural gas shall not exceed 9,300 X mmSCF/month or 109,500 mmSCF/year. Supplemental fuel to the flare shall • not be less than 0.335 mmBTU/hr • **** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** • .0 0 Operating Permit Application - STACK IDENTIFICATION FORM 2000-200- Colorado Department of Public Health and Environment •• Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name:Cheyenne Plains Compressor • 2. Facility identification code: CO 123/0051 Station . 3. Stack identification code:•CPT6 3a. Construction Permit Number: 03WE0916 4. Exhausting Unit(s), use Unit identification code from appropriate Form(s) 2000-300, 301, 302, 303, 304, 305, 306, 307 .. 2000-300 2000-301 2000-302 2000-303 ' • 2000-304 2000-305 2000-306 021 • 2000-307 • • 5. Stack identified.on the plot plan required on Form 2000-101 X 6. Indicate by checking: • . ' ❑✓ This stack has an actual exhaust point. The parameters are entered in Items 7-13. ❑ This stack serves to identify fugitive emissions. Skip items 7-13: Go to next form. , ❑ When stack height Good Engineering Practice (GEP) exceeds-65 meters (Colorado Air Quality Reg 3.A.VIII.D) data entry is required for Item 7. • ._. r >u'+.�•It6^+.: ..n,EY '•sM.:+,k'�t2{a.:*^,";;9P,S.l r iW"4y^'i..t'f",�:�. :• ▪ ''t. <. q rf.`1,t tinr,*r" el ti: 9`•!T fs' 1.} ' '+'si:>• A',"t:;" 4 ilia t. r r 3 , ,,rte -i� 4 a r, + t F :.p.e. 1t`r C, +x btt ^# , .7 r ;IYiseyharbge4,, eiRnita iove,grounevi vpf " dirga x▪(feet) ,i 4 . .e tt 4 -06.4144', ,} '` ,.? t'r'`c,,-t�vif 2'l�r,':;.'E-b ut ri.+ft a:.'!%` j�Jr-FiE7L't4 ,•:'L`,'s..rX�G�j:t,� � ,wY;1W'`.+! }..:z-,cc.,<-. .,r.".�.A. 3 3' '�tl..'+°_�C'Ra.k:a .,.a.^ef n.1,..:.413.4444?, . r..x .,, y r 'ff'..v,'r) t,,-3 Y: 4y� �,.�.., r ',_ [c `e` nee and com lete: t F `. r r F ' • • �t-,1) ii f a,�: ;- 8 Insidesdunensions at outlet.( h ck,.o p ;) rat i1��;,,1 V i . tW i , .. ,A ciX Y , y! i +a .,. yt, r,,,iv.., - S + h ,t R • r f•i 3 't 3 `,'` i rlii i�'c`•[^�( y tv ii A r k! } ry-'•. 1v,,+1- s7�4 �k+ -t.,a-',;rty/a!'laY•E�i, � -�,. �s #. '� k + 1'3.. t i A�S:� v . �yy j`P"` r;,f,,.' `�."fi '':Rft' rtiR � r'• ,Lt r = $x`4t w N r 7,0,1 .4 ,,,v, t4. v}: + �F) ,.! t k:'r� 4V n r.r•'-- ;.$4_ t c �'t is s :+ G °qt rP.: c7A- ' /P . ; O3 50,E ,,feet) �r 4.r :Ltq ` R•ect n ari,,,, �#. M * r� len �p ifee'l t '`ft* { k kwidttl tfeet1y; :._ ,G1rClilar',•tf�.i t° ! ( / iC'r4 � "�'n„yl r ❑GY- �r-x -t ,,1,�.,1 t gt�5\.,.. • )tit'y+ ≥.'7 "+� y'" ( � /s47Y. - ....g%-a t...x x`Ixt3,•.cx..eiselc,.E.; : . •r1c�3,1, :> .1-.04--4,:fR.i:.s'iio^... SLv.'.tYr r_3< ia.71,:r.l a,-,.sna+.,.,f..dv;Cgti(ffi eif__klfiw.aii4 tr,a. s•,n!1Vxo ifm.,:a'•7 ::5w::Tmi c'i M r ♦ 4e,,:ci v.CwYt+,♦ xt i' S`` `5"i +l .. .k;.t-t k'f'$ ,t ,!• t< w tiiv, 174.; 1 Y'y{1? t tt?,:N-014-„ td ' - r is ar rF 4 • 9 g' ` Exhaust afloN rate f -:,.....y,' ;t . ,Normal t•21,216t; et, u-• _> � ` ' , aximum -2x1 216N .C 4 r S'i igN'{V.,5..`h,,,iir c :' ,�'.i{- s ° 7.,,'b . d 'h9` .�(� -?: i,r t n 0 tice ....tit. +yr*,, a:il. ,,r . '.i - - ! - � F '`#` y.. bt`�.7 -.� 7� �t-i r... kt. r j!`.. 'i�fkiC. �,1F' �i Y. i+�"i •�. 'ti.�. '4 aci •nx`L .....:;??4,4.01.010.001*, ."� 1 4 t t� r';�StFiT', syi�, ru# a,� 7 j, a•S f. a -w,,}p�y_ r. ( rxx'�a'�Ifl"�'r`�gnC°..1� dCS�{+F C!t'v+t >k+t� �, i ,, Wi,)10, f,,r hiff ;#.- x t 7 .,:y..a r.-.rin�i c :, e v r .,- A;CEi.:iVi`�,f;,#yy z ,.V44 .f` Ly,•0:1', 7,, r.o ,y.. ,. II +,tz'te %"' ,,rit^.e':: }+' „*,...,it.. "M'fy5,tT1.,3 .�.,t i �Y�', :.,'.• IP,Atif ,.s: 1t Yp r w4 k ` a e 'Fsr iv +tF•a A .Y ,t,45 a. s •,..r,d Fik 4 x 4 . Veloci_tyr� 36. 7 ' (FPS) �✓ Calculated' ❑ �tacicTes� � � ��; I -� ��"' �� , n .,, 1 y S , 7 O41 e^!:v iz —0. 1 r i4 it'r d.-'' { r11eal °LY ai0{ [ t r�. e .tri :a{ •e Ntip ��{�t4Fnft��:,,..w•i..s-,x:�,ttr.:'s.{�t;Lr�{e".s;9xwls��,.�."aly4�ti/h-.�si.6 �=#.r•...F-.�t�r.'£[,��:... ,.k.. r**.Y>. .n.�k`''. ..+9.,.C,R'� �, .1'?,a. i'6?:n:FAY-.q'k�.�te..-+.Yti,�..1�itC'l�a......c..^'..:.yiYl: - t4 31 : tir. ..S,:_K,v 8: A,Str .Y :..,h.N?1.3 ;'t;7r#is..., 7t );Y 6'( ..0:!.'&7.—'..:S1.,"-,,:s :�+ > `<, *g :ij -i "'# '.c"•, 4�t;,r �: a '10 :i ;,Exhaust as,tem,,(era , normal) r� V '(t° r, a , ri..l Y �.�pM. 4' t^.,t % t r� } 1^. n k.—.Frr,,i f ri }g f At.v iti i.,F yi{'' FLT,". ^ ' r y. r'' s : �' F-we k', - k 'a r�i 4'�'Cxi'gTst.'.t't,}� !}; . {k-^ t t t 2 !/.:,4141 1s-yus.Y�uM2 _ :^c AKK...^',1,.L ya`:s4 [.a 3.::?'1 h t•+., �• . y,. 6",:i !A`, riCvt i a. tz.io„,r! AfiFic' y b r ' ,, r�D©es,pqr�ocess-amodif ambient ammoisture content >a Ye - ;ri✓ ou 3^�elj v,,. = IF:1 ,3'< 4j t +n * ` : ,, I ₹' 'x ,_,, ;y 3 a,�n iv y�. �`4t '` 4 s xx �° 4 t 'p cy0 s } ri �.v ?� „i t. t 4' #3 i , ,�1,�wy {,.y ''+'TM ,[ C �S�r+.c �: # � §• y,}.� !° , ''4x•' �}�t( �i•��'i• r z t,y„ k� "`�Yy rr..4,r-:*. t'°1ts'I`:1.,-;., C ilc :.'. 'S•I;45'44" ii.'r ta. 4;�,151 r<'".'i'j i' iit,.st.:t E,i 4-t•.wi '...t.t s'.'z4. 4,try' ijt` Z!` i#4oft".(-'a' .t '}�t.?pr1.r5. i IF Yes{ exhaust^ as„moistuE' • tl k s Normal kt "� ercent;- t1.�� Maximumrt . 14. percen �.C iii yt i arg# �.'...;F.r_ 1'7.PL^-';st: ei��` 45,12I s��','i,cs ,�s,54.1P 1 � a`ttitT,. �, rpy r -wl-c,,+,tp:1 • �,r �•- f'' znr rt?lj:u r�s rt` r j d }tr �,,,,,,v' t �. 4. t,5 r 14 f 1 .�.S' ! 4.4.4 g9' s sl �',f 4,,-,.)+ •,t,,:*4?�'it4x; of s. lf 'T'^61-+7"tj` M ', LM N'#1't 14`tf Sk r,�',,j r t'k n' 3y1 �7i } "lF+'t'+47.i r .,. a�1^s%.,>s.,s, �,tv conteil"'! 'K;F <111,,t b 1,,:t:.. •., ...:. ...01;46•t Y t,l^t €r.;:i'IrA .k ';r`A �,:... :s.i4�F. _. :.: ti ,1, 1 ay.�' iwg.i., ',`r#t'f. .,4 ,„ u..kfd i - ra a,t �s ;3, tQ:, ,te, t .. r ,�yx 4-;, a'°F T 14 .4.4,'� wx -:, e .'4,1..• r;:hX 12trr,�>£,Exhausty as iscuarg x 'rl * T� pis -7 r., z ❑uo it i₹ �a x ,,.'t a+„])for ZO l aly " c, ! �,�j W rU. g 'r'n Xr H, .g nV,P�v [r yt'.. ^i i.i m e r A,y "�3,••• . tP F•. }5�1�S,S i 4:0 �(-._�1 - Oir p._ '�` Ki,'";,.t,11, . fie �t 7� . r,.,; 9 at i c' k4 w•t I} >att, ,,,t4 ry- €1C-;,F,l '�..rc4 `t1 ,,,,5".r_'st.o , ^ direcUan 1K 'sl}r ti 7. '� r4,g,l„ .0,4,,,::41.rrai�t 46,,,-•-, ^#>.::: .}.: ,•. 6 , „ah-,.{ker.�. [ • z4;,k 4,A,il 7,.,ik`;y 4 r i,."A5{„tt:s: r� ; z 4:.w-ie r _: max F :.....11*,? ;d.,2, t y,.• r , t • ,,,,,fir,,,`-1,,l 1 V.s t sr;r la,...7 1��f 1, ,,,, ', ttc -13 �4.-liSsthi :stac eauippeagwitlirFa6rainhat or-an p*ol struchon+tog,the, erm, o L�ta{+ - . (tir„;,r, rr , .`f,-;; x F Ki,r• M ',+�: iy.'G. 3gr,'Va 4"ro.4'P'i ' o--L tvt y ..k, • •, '"r`+• th o'r,{,.e ayy t�4 a, •t.„'!:, 1. ' t;,' 40. l t, S,� 'k 'S &:".�2 3, :,Stata , byaaD l P lit p 4k-gi rt 'All FA V,214$41 �s^'i0-' ''''4`tF j� 1.:i* .'the exhaustsgases from�,the,Lstaekn?;.4'0:Yes,❑'�+l�ro � r r �,. � .� . C.,.,.....`�_ .�'^'s�.'��a:Vr�'��;"��.a.`�+`�,�'''�.tf�)+ k�i�, '��.i�r..._.. .�� a,4 �4i; ,�`.^5��s&. .u4 �r,�fiWt�r�;yA� �F� � �..,�ti`�ab.y' *****Complete the appropriate Air Permit Application Forms(s) 2000-300, 301, 302, 303, 304, ***** 305, 306, or 307 for each Unit exhausting through this stack. • I . O oH: Operating Permit Application MISCELLANEOUS PROCESSES FORM 2000-306 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1 1. Facility name: 2. Facility identification code: CO 123/0051 • Cheyenne Plains Compressor Station 3. Stack identification code: CPT6 4. Process (Unit) code: ,021 5. Unit description: Regenerator (CO2) vent of the amine unit equipped with.a Sulfa Treat H2S control 6. Indicate the control technology status. ❑ Uncontrolled EJ Controlled If the process is controlled, enter the control device code(s) from the appropriate form(s): 2000-400 2000-401 2000-402 2000-403 i. 2000-404 2000-405 • 2000-406 2000-407 a � � 'u �1�5+^ q., l� � .,.i - � Pdc3 t��.V�v.Etk 4 '4ts Jet'. x.+�� c � ;x7t J p,,4Actua1 annuala.process rates for _19 !i Y 5 ' '„x, 6 k+'�-�+rs�`�Y <r --�s `� x Y j 1 i °Y ..x.,ti.:, , _ ...,.�.}. s ..3 _a.!` �.....,.._3,,.ra._...,..'�.kk3;.�a_. ,, �,a_ 8. Date first placed in service: 01/30/05 • Date of last modification: 9. Normal operating schedule: hrs./day days/wk. 8,760 hours/yr. 10. Describe this process (please attach a flow diagram of the process). Attached? ❑ Emissions from the regenerator vent of the amine treatment unit of the CO2 treatment plant are routed to a SulfaTreat H2S control system at all times that the ' amine unit is operating. 11. List the types and amounts of raw materials used in this process: Material Storage/material handling process Act>sallusag ��flilt s :. Maximum Units fr w. rJ•* ''xr � mf> usage ' q $77,114000��q( e�� • Clean-up • ft �� { 4064" • ≥m�`�4 r L'A„„3Y t +'�. �Y !t solvents ` k A� v1 Other i =z = (specify) :lam {` ,;in.us fie,R Ac.4a:. •5. 'a...ssS:u 12. List the types and amounts of finished products: Material Storage/material handling process YAchn a amou it'W4'mts~ '. Maximum Units i:itgr-12410411,74 ' s amount `` „,, . - r produced etziw^y r•M 13. Process fuel usage: Type of fuel Maximum heat s,rcagr,IIzuis- Maximum Units + rt rw to input to process T �: t r}y� Tt �`� • usage `YI.O F�1ia �, t Zt-rA li million BTU/hr ifi_$1 ,` V5,-r . eta • m ;�, , A ' ,i - 40, 4 14. Describe any fugitive emissions associated with this process, such as outdoor storage piles, unpaved roads, open conveyors, etc.: ***** For this emissions unit, identify the method(s) of compliance demonstration by completing Form 2000-500, ***** ' DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 and its attachment(s) to this form. ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** Operating Permit Application COMPLIANCE CERTIFICATION-MONITORING AND REPORTINGFORM 2000-500 Colorado Department of Public Health and Environment DESCRIPTION OF METHODS USED Rev 06-95 Air Pollution Control Division FOR DETERMINING COMPLIANCE All applicants are required to certify compliance with all applicable air pollution permit requirements by including a statement within the permit application of the methods used for determining compliance. This statement must include a description of the monitoring, recordkeeping, and reporting requirements and test methods. In addition, the application must include a schedule for compliance certification submittals during the permit term. These submittals must be no less frequent than annually, and may need to be more frequent if specified by the underlying applicable requirement or by the Division. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: 2. Facility identification code: CO 123/0051 Cheyenne Plains Compressor Station 3. Stack identification code: CPT6 4. Unit identification code: 021 5. For this Unit the following method(s) for determining compliance with the requirements of the permit will be used (check all that apply and attach the appropriate form(s) to this form). ❑ Continuous Emission Monitoring (CEM) - Form 2000-501 Pollutant(s): ❑ Periodic Emission Monitoring Using Portable Monitors - Form 2000-502 Pollutant(s): ❑ Monitoring Control System Parameters or Operating Parameters of a Process - Form 2000-503 Pollutant(s): ❑ Monitoring Maintenance Procedures - Form 2000-504 Pollutant(s): ❑ Stack Testing - Form 2000-505 Pollutant(s): ❑ Fuel Sampling and Analysis (FSA) - Form 2000-506 Pollutant(s): El Recordkeeping - Form 2000-507 Pollutant(s): ❑ Other (please describe) - Form 2000-508 Pollutant(s): Compliance certification reports will be submitted to the Division according to the following ;:hedule: Start date: and every months thereafter. (12 month maximum interval) Compliance monitoring reports will be submitted to the Division according to the following schedule: Start date: and every months thereafter. (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5. Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-507 Colorado Department of Public Health and Environment BY RECORDKEEPING Rev 06-95 Air Pollution Control Division Recordkeeping may be acceptable as a compliance demonstration method provided that a correlation between the parameter value recorded and the emission rate of a particular pollutant is established in the form of a curve or chart of emission rate versus parameter values. This correlation may constitute the certification of the system. For an existing program, the correlation demonstration must be attached for Division consideration for approval. If the correlation information has not yet been developed, please submit it within 60 days of the startup of the system. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Cheyenne Plains Compressor 2. Facility identification code: CO 123/0051 Station 3. Stack identification code: CPT6 4. Unit identification code: 021 5. Pollutant(s) being monitored: 6. Material or parameter being monitored and recorded: 7. Method of monitoring and recording (see information on back of this page): Compliance will be demonstrated by following 40 CFR Part 60 Subpart A and 63 Subpart HHH. 8. List any EPA methods used: 9. Is this an existing method of demonstrating 10. Start date: compliance? ❑✓ Yes ❑ No 11. Backup system: None. 12 a. Data collection frequency: ❑ Daily ❑ Weekly ❑ Monthly ❑ Batch (not to exceed monthly) ❑✓ Other - See Item7 12 b. Compliance shall be demonstrated: ❑ Daily ❑ Weekly ❑ Monthly ❑ Batch (not to exceed monthly) ❑✓ Other - See Item7 13. Quality Control/Quality Assurance: The monitoring system shall be subject to appropriate performance specifications, calibration requirements, and quality assurance procedures. ❑A quality assurance/quality control plan for the recordkeeping system is attached for Division review. ❑ The plan is not attached, but will be submitted to the Division by 14. ❑ A proposed format for the compliance certification report and excess emission report is attached. ***** The compliance records shall be available for Division inspection. ***** The source shall record any malfunction that causes or may cause an emission limit to be exceeded. ***** Malfunctions shall be reported to the Division the next business day. Hazardous air releases shall be reported to the Division immediately. Operating Permit Application APPLICABLE REQUIREMENTS AND FORM 2000-604 Colorado Department of Public Health and Environment STATUS OF EMISSION UNIT Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Cheyenne Plains Compressor 2. Facility identification code: CO 123/0051 Station 3. Stack identification code: CPT6 4. Unit identification code: 021 5. Pollutant 6. Colorado Air Quality 7. 8. Limitation 9. Compliance Regulations State Status or Only IN OUT Construction Permit Number Opacity Permit#03WE0916 20% Opacity X Number 1 10. Other requirements (e.g., malfunction reporting, special operating State Only Compliance conditions from an existing permit such as material usage, hours of Status operation, etc.) IN OUT **** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** Operating Permit Application TABULATION OF PERMIT APPLICATION FORMS FORM 2000-800 Colorado Department of Health Rev 09-94 - Air Pollution Control Division Facility Name: Cheyenne Plains Compressor Station Facility Identification Code: CO 123/0051 I. ADMINISTRATION E1 This application contains the following forms: 0✓ Form 2000-100,Facility Identification Q Form 2000-101,Facility Plot Plan 0✓ Forms 2000-102,-102A,and-102B,Source and Site Descriptions II. EMISSIONS SOURCE Total Number DESCRIPTION of This Form This application contains the following forms 0✓ Form 2000-200,Stack Identification 7 (one form for each facility boiler.nrintine E✓ Form 2000-300,Boiler or Furnace Operation 2 • Form 2000-301,Storage Tanks El Form 2000-302,Internal Combustion Engine O Form 2000-303,Incineration ❑ Form 2000-304,Printing Operations • Form 2000-305,Painting and Coating Operations ❑✓ Form 2000-306,Miscellaneous Processes 5 Form 2000-307,Glycol Dehydration Unit III. AIR POLLUTION CONTROL Total Number SYSTEM of This Form This application contains the following forms: El Form 2000-400,Miscellaneous Form 2000-401,Condensers 0 Form 2000-402,Adsorbers El Form 2000-403,Catalytic or Thermal Oxidation El Form 2000-404,Cyclones/Settling Chambers Form 2000-405,Electrostatic Precipitators Form 2000-406,Wet Collection Systems • Form 2000-407,Baghouses/Fabric Filters IV. COMPLIANCE Total Number DEMONSTRATION of This Form This application contains the following forms 2 Form 2000-500,Compliance Certification-Monitoring and Reporting 7 (one for each facility boiler.nrintine El Form 2000-501,Continuous Emission Monitoring 2✓ Form 2000-502,Periodic Emission Monitoring Using Portable Monitors 3 ElForm 2000-503,Control System Parameters or Operation Parameters of a Process DForm 2000-504,Monitoring Maintenance Procedures O Form 2000-505,Stack Testing 5 • Form 2000-506,Fuel Sampling and Analysis 0✓ Form 2000-507,Recordkeeping 7 • Form 2000-508,Other Methods EMISSION SUMMARY AND Total Number of This Form jIPLIANCE CERTIFICATION This application contains the following forms _ Form 2000-600,Emission Unit Hazardous Air Pollutants quantifying emissions,certifying compliance with applicable requirements,and developing a compliance plan • Form 2000-601,Emission Unit Criteria Air Pollutants Form 2000-602,Facility Hazardous Air Pollutants Form 2000-603,Facility Criteria Air Pollutants �- • Form 2000-604,Applicable Requirements and Status of Emission Unit • Form 2000-605,Permit Shield Protection Identification Form 2000-606,Emission Unit Compliance Plan-Commitments and Schedule U Form 2000-607,Plant-Wide Applicable Requirements ❑ Form 2000-608,Plant-Wide Compliance Plan-Commitments and Schedule VI. SIGNATURE OF RESPONSIBLE OFFICIAL - FEDERAL/STATE CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and,based on information and belief formed after reasonable inquiry,I certify that the statements and information contained in this application are true,accurate and complete. B. CERTIFICATION OF FACILITY COMPLIANCE STATUS-FEDERAL/STATE CONDITIONS (check one box only) IV I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements. I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements,except for the following emissions unit(s): (list all non-complying units) WARNING: Any person who knowingly,as defined in§ 18-1-501(6),C.R.S.,makes any false material statement,representation, or certification in,or omits material information from this application is guilty of a misdemeanor and may be punished in accordance with the provisions of§25-7 122.1,C.R.S. Printed or Typed Name Title Gary Stuart Cheyenne Area Manager Signature , Date Signed -.4%/P etee /0V/2/0,5"- Operating Permit Application CERTIFICATION FOR STATE-ONLY CONDITIONS FORM 2000-800 09-94 Colorado Department of Health Air Pollution Control Division ity Name: Cheyenne Plains Compressor Station Facility Identification Code: CO 123/0051 VI. SIGNATURE OF RESPONSIBLE OFFICIAL-STATE ONLY CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and,based on information and belief formed after reasonable inquiry,I certify that the statements and information contained in this application are true,accurate and complete. B. CERTIFICATION OF FACILITY COMPLIANCE STATUS FOR STATE-ONLY CONDITIONS(check one box only) I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements. _ I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements,except for the following emissions unit(s): • (list all non-complying units) WARNING: Any person who knowingly,as defined in§18-1-501(6),C.R.S.,makes any false material statement,representation, or certification in,or omits material information from this application is guilty of a misdemeanor and may be punished in accordance with the provisions of§25-7 122.1,C.R.S. Printed or Typed Name Title Gary Stuart Cheyenne Area Manager Signature Date Signed 41/ 474"di /2// SEND ALL MATERIALS TO: COLORADO DEPARTMENT OF HEALTH APCD-SS-B 1 4300 CHERRY CREEK DRIVE SOUTH DENVER,CO 80246-1530 Appendix B Emissions Calculations/Data Cheyenne Plains Compressor Station General Facility Information Permit Number Construction Permits 03WE0910,04WE1390,03WE0913,&03WE0916 Owner Name Cheyenne Plains Gas Pipeline Company Address P.O.Box 1087 Colorado Springs,CO 80944 Phone 719-473-2300 Site Contact& Name Barry Schatz Responsible Official Title Principal Environmental Coordinator Phone 719-388-5717 Fax 719-388-5721 Site Mailing Address P.O.Box 370 Sinclair,WY 82334 SIC 4922 Location Description 4 miles north of Rockport,Colorado Legal Description SE 1/4, NE 1/4,Section 5,T11N,R 66W Weld County Inlet Gas Source of analysis: Cheyenne Plains Project Date of analysis: Unknown Molecular Mol. Gas Weight Weight Pollutant Weight Fraction Fraction (lb/lb-mol) (mol. %)1 (lb/lb-mol) (wt. %) Methane 16.04 93.5290% 15.0045 86.78% Ethane 30.07 0.3540% 0.1064 0.62% Total HC(Non-VOC) 93.8830% 15.1109 87.40% Propane 44.10 0.0740% 0.0326 0.19% i-Butane 58.12 0.0060% 0.0035 0.02% n-Butane 58.12 0.0100% 0.0058 0.03% i-Pentane 72.15 0.0020% 0.0014 0.01% n-Pentane 72.15 0.0020% 0.0014 0.01% n-Hexane 86.18 0.0000% 0.0000 0.00% Hexanes 87.18 0.0030% 0.0026 0.02% Heptanes 100.20 0.0000% 0.0000 0.00% Octanes 114.23 0.0000% 0.0000 0.00% Benzene 78.11 0.0000% 0.0000 0.00% Toluene 92.14 0.0000% 0.0000 0.00% Ethylbenzene 106.17 0.0000% 0.0000 0.00% Xylenes 106.17 0.0000% 0.0000 0.00% Total NMNE VOC 0.0970% 0.0474 0.27% Carbon Dioxide 43.99 2.7920% 1.2282 7.10% Nitrogen 28.02 3.2230% 0.9031 5.22% Hydrogen 2.02 0.0000% 0.0000 0.00% Helium 4.00 0.0000% 0.0000 0.00% Totals 100.00% 17.2896 100.00% NMNE VOC Content mol% 0.10% Average VOC Molecular Weight 76.94 lb/mol Cheyenne Plains TV Calcs 121205.xls Printed on 12/12/2005 Cheyenne Plains Compressor Station Emission Summary Sheet Source Potential Emissions m > o m .c 0_ 'p c 2 C 0 I �. N O N 2 2 N J N _ CO 7 N i— AIRS ID No. Usage Description NO, CO VOC SO2 PM1p °�' w E Q m ill. u_ 2 O a O 015 Compression 9816 hp Solar Taurus 70-10302S 31.61 38.51 11.31 1.00 2.06 1.25E-02 3.75E-03 1.00E-02 2.22E-01 4.01E-02 2.001-02 3.09E-01 016 Compression 9816 hp Solar Taurus 70-10302S 31.61 38.51 11.31 1.00 2.06 1.25E-02 3.75E-03 1.00E-02 2.22E-01 4.07E-02 2.00E-02 3.09E-01 024 Compression 9816 hp Solar Taurus 70 20.08 20.91 11.31 1.00 2.06 1.25E-02 3.75E-03 1.00E-02 2.22E-01 4.07E-02 2.00E-02 3.09E-01 018 Hot Oil Heater 45.00 MMBtu/hr Heater 6.90 7.29 3.15 0.13 1.58 4.38E-04 2.50E-04 1.56E-02 3.75E-01 7.09E-04 3.92E-01 019 Hot Oil Heater 45.00 MMBtu/hr Heater 6.90 7.29 3.15 0.13 1.58 4.38E-04 2.50E-04 1.56E-02 3.75E-01 7.09E-04 3.92E-01 020 Utility Heater 16.00 MMBtu/hr Heater 0.42 0.36 0.02 0.00 0.03 8.88E-06 5.07E-06 3.17E-04 7.61E-03 1,44E-05 7.96E-03 --- Glycol Reboiler 4.97 MMBtu/hr Heater 0.89 1.63 0.70 0.01 0.17 4.84E-05 2.76E-05 1.73E-03 4.14E-02 7.83E-05 4.33E-02 021 Amine Vent 13.00 scfd Hanover 11.79 7.23E+00 5.30E-02 2.20E+00 9.49E+00 -- Glycol Dehydrator 300.00 scfd Dehydrator — 0.00E+00 022 Flare 13.54 MMBtu/hr Flare 7.35 39.42 5.80 9.13E-01 1.23E-01 1.58E+00 2.62E+00 -- Fugitive Emissions Equipment Leaks 1.10 3.70E-03 6.00E-04 6.80E-03 2.10E-03 1.32E-02 -- Fugitive Emissions Turbine Start-ups 0.11 0.00E+00 --- Fugitive Emissions Compressor Blowdowns 0.34 0.00E+00 -- Fugitive Emissions Emergency Shutdowns 0.13 0.00E+00 Total Emissions 105.75 153.93 60.23 3.27 9.57 3.75E-02 8.16E+00 5.33E-04 3.06E-02 7.00E-01 9.75E-01 3.91E+00 6.22E-02 1.39E+01 Total Insignificant Emissions 0.00 0.00 1.68 0.00 0.00 0.00E+00 3.70E-03 0.00E+00 6.00E-04 0.00E+00 0.00E+00 6.80E-03 2.10E-03 1.32E-02 Total Facility Emissions(excluding Insignificant Sources) 105.75 153.93 58.55 3.27 9.57 0.04 8.16 0.00 0.03 0.70 0.98 3.90 0.06 13.87 Cheyenne Plains TV 121205.xIs Printed on 12/12/2 Cheyenne Plains Compressor Station Turbine Detail Sheet i - AIRS ID Number 015 Equipment ID CP CG-7101 Stack ID CP01 Engine Usage Compression Engine Make Solar Engine Model Taurus 70-10302S Serial Number 0251B Start-up Date 12/15/2004 Engine Configuration Turbine Emission Controls SoLoNOx Design Rating Unknown BHP Site Rating 9816 BHP Fuel Heating Value 945.83 Btu/scf Heat Rate 71.42 MMBtu/hr Engine Heat Rate 7276 Btu/hp-hr Potential Operation 8760 hr/yr Potential Fuel Usage 661.47 MMscNyr Potential Emissions Pollutant Emission Factor Nominal Hrs of Estimated Emissions Source of Rating Operation Emission (lb/MMBtu) (g/hp-hr) (hp) (hrs/yr) (lb/hr) (ton/month) (tpy) Factor NOx,>0degF,97% 0.098 3.23E-01 9816 8760 7.00E+00 2.55E+00 3.07E+01 BACT Limit' NOx,</=0degF>/=-20degF,2.7% 0.168 5.54E-01 9816 8760 1.20E+01 4.38E+00 5.26E+01 BACT Limit' NOx,<-20degF,0.3% 0.480 1.58E+00 9816 8760 3.43E+01 1.25E+01 1.50E+02 BACT Limit' Average NOx 7.2 2.6 31.6 Permit Limit' CO,>0degF,97% 0.119 3.93E-01 9816 8760 8.50E+00 3.10E+00 3.72E+01 BACT Limit' CO,</=0degF,2.7% 0.244 8.05E-01 9816 8760 1.74E+01 6.36E+00 7.63E+01 BACT Limit' CO,<-20degF,0.3% 0.366 1.21E+00 9816 8760 2.61E+01 9.54E+00 1.14E+02 BACT Limit' Average CO 8.8 3.2 38.5 Permit Limit' VOC,>0degF,97% 0.035 1.16E-01 9816 8760 2.50E+00 9.12E-01 1.09E+01 BACT Limit' VOC,</=0degF,2.7% 0.070 2.31E-01 9816 8760 5.00E+00 1.82E+00 2.19E+01 BACT Limit' VOC,<-20degF,0.3% 0.105 3.47E-01 9816 8760 7.50E+00 2.74E+00 3.28E+01 BACT Limit' Average VOC 2.6 0.9 11.3 Permit Limit' SO2 3.20E-03 1.05E-02 9816 8760 2.28E-01 8.33E-02 1.00E+00 AP-422 PM10 6.60E-03 2.18E-02 9816 8760 4.71E-01 1.72E-01 2.06E+00 AP-422 Acetaldehyde 4.00E-05 1.32E-04 9816 8760 2.86E-03 1.04E-03 1.25E-02 AP-423 Benzene 1.20E-05 3.96E-05 9816 8760 8.57E-04 3.13E-04 3.75E-03 AP-423 Ethylbenzene 3.20E-05 1.06E-04 9816 8760 2.29E-03 8.34E-04 1.00E-02 AP-423 Formaldehyde 7.10E-04 2.34E-03 9816 8760 5.07E-02 1.85E-02 2.22E-01 AP-423 Toluene 1.30E-04 4.29E-04 9816 8760 9.28E-03 3.39E-03 4.07E-02 AP-423 Xylene 6.40E-05 2.11E-04 9816 8760 4.57E-03 1.67E-03 2.00E-02 AP-423 1 BACT and Permit limits are from Construction Permit 03WE0910,March 29,2005 2 EPA AP-42,Volume I, Fifth Edition-April 2000,Table 3.1-2a, Emission Factors for Criteria Pollutants and Greenhouse Gases from Stationary Gas Turbines 3 EPA AP-42,Volume I, Fifth Edition-April 2000,Table 3.1-3,Emission Factors for Hazardous Air Pollutants from Natural Gas-Fired Stationary Gas Turbines Cheyenne Plains TV Calcs.xls Printed on 12/8/2005 Cheyenne Plains Compressor Station Turbine Detail Sheet i AIRS ID Number 016 Equipment ID CP CG-7201 Stack ID CP02 Engine Usage Compression Engine Make Solar Engine Model Taurus 70-10302S Serial Number 0250B Start-up Date 12/15/2004 Engine Configuration Turbine Emission Controls SoLoNOx Design Rating Unknown BHP Site Rating 9816 BHP Fuel Heating Value 945.83 Btu/scf Heat Rate 71.42 MMBtu/hr Engine Heat Rate 7276 Btu/hp-hr Potential Operation 8760 hr/yr Potential Fuel Usage 661.47 MMscf/yr Potential Emissions Pollutant Emission Factor Nominal Hrs of Estimated Emissions Source of Rating Operation Emission (lb/MMBtu) (g/hp-hr) (hp) (hrs/yr) (lb/hr) (ton/month) (tpy) Factor NOx,>0degF,97% 0.098 3.23E-01 9816 8760 7.00E+00 2.55E+00 3.07E+01 BACT Limit' NOx, </=0degF>/=-20degF,2.7% 0.168 5.54E-01 9816 8760 1.20E+01 4.38E+00 5.26E+01 BACT Limit' NOx, <-20degF,0.3% 0.480 1.58E+00 9816 8760 3.43E+01 1.25E+01 1.50E+02 BACT Limit' Average NOx 7.2 2.6 31.6 Permit Limit' CO,>0degF,97% 0.119 3.93E-01 9816 8760 8.50E+00 3.10E+00 3.72E+01 BACT Limit' CO,</=0degF,2.7% 0.244 8.05E-01 9816 8760 1.74E+01 6.36E+00 7.63E+01 BACT Limit' CO,<-20degF,0.3% 0.366 1.21E+00 9816 8760 2.61E+01 9.54E+00 1.14E+02 BACT Limit' Average CO 8.8 3.2 38.5 Permit Limit' VOC,>0degF,97% 0.035 1.16E-01 9816 8760 2.50E+00 9.12E-01 1.09E+01 BACT Limit' VOC,</=0degF,2.7% 0.070 2.31E-01 9816 8760 5.00E+00 1.82E+00 2.19E+01 BACT Limit' VOC,<-20degF,0.3% 0.105 3.47E-01 9816 8760 7.50E+00 2.74E+00 3.28E+01 BACT Limit' Average VOC 2.6 0.9 11.3 Permit Limit' SO2 3.20E-03 1.05E-02 9816 8760 2.28E-01 8.33E-02 1.00E+00 AP-422 PM10 6.60E-03 2.18E-02 9816 8760 4.71E-01 1.72E-01 2.06E+00 AP-422 Acetaldehyde 4.00E-05 1.32E-04 9816 8760 2.86E-03 1.04E-03 1.25E-02 AP-423 Benzene 1.20E-05 3.96E-05 9816 8760 8.57E-04 3.13E-04 3.75E-03 AP-423 Ethylbenzene 3.20E-05 1.06E-04 9816 8760 2.29E-03 8.34E-04 1.00E-02 AP-423 Formaldehyde 7.10E-04 2.34E-03 9816 8760 5.07E-02 1.85E-02 2.22E-01 AP-423 Toluene 1.30E-04 4.29E-04 9816 8760 9.28E-03 3.39E-03 4.07E-02 AP-423 Xylene 6.40E-05 2.11E-04 9816 8760 4.57E-03 1.67E-03 2.00E-02 AP-423 'BACT and Permit limits are from Construction Permit 03WE0910, March 29,2005 2 EPA AP-42,Volume I,Fifth Edition-April 2000,Table 3.1-2a,Emission Factors for Criteria Pollutants and Greenhouse Gases from Stationary Gas Turbines 3 EPA AP-42,Volume I,Fifth Edition-April 2000,Table 3.1-3, Emission Factors for Hazardous Air Pollutants from Natural Gas-Fired Stationary Gas Turbines Cheyenne Plains TV Calcs.xls Printed on 12/8/2005 Cheyenne Plains Compressor Station Turbine Detail Sheet AIRS ID Number 024 Equipment ID CP CG-7501 Stack ID CP05 Engine Usage Compression Engine Make Solar Engine Model Taurus 70 Serial Number Unknown Start-up Date 10/29/2005 Engine Configuration Turbine Emission Controls SoLoNOx Design Rating Unknown BHP Site Rating 9816 BHP Fuel Heating Value 945.83 Btu/scf Heat Rate 71.42 MMBtu✓hr Engine Heat Rate 7276 Btu/hp-hr Potential Operation 8760 hr/yr Potential Fuel Usage 661.47 MMscf/yr Potential Emissions Pollutant Emission Factor Nominal Hrs of Estimated Emissions Source of Rating Operation Emission (lb/MMBtu) (g/hp-hr) (hp (hrs/yr) (lb/hr) (ton/month) (tpy) Factor NOx,>0degF,97% 0.060 1.98E-01 9816 8760 4.29E+00 1.56E+00 1.88E+01 BACT Limit' NOx,</=0degF>/=-20degF,2.7% 0.168 5.54E-01 9816 8760 1.20E+01 4.38E+00 5.26E+01 BACT Limit' NOx,<-20degF,0.3% 0.480 1.58E+00 9816 8760 3.43E+01 1.25E+01 1.50E+02 BACT Limit' Average NOx 4.6 1.7 20.1 Permit Limit' CO,>0degF,97% 0.061 2.01E-01 9816 8760 4.36E+00 1.59E+00 1.91E+01 BACT Limit' 2 CO,</=0degF,2.7% 0.244 8.05E-01 9816 8760 1.74E+01 6.36E+00 7.63E+01 BACT Limit' CO,<-20degF,0.3% 0.366 1.21E+00 9816 8760 2.61E+01 9.54E+00 1.14E+02 BACT•Limit' Average CO 4.8 1.7 20.9 Permit Limit' VOC,>0degiF,97% 0.035 1.16E-01 9816 8760 2.50E+00 9.12E-01 1.09E+01 BACT Limit' VOC,</=0degF,2.7% 0.070 2.31E-01 9816 8760 5.00E+00 1.82E+00 2.19E+01 BACT Limit' VOC,<-20degF,0.3% 0.105 3.47E-01 9816 8760 7.50E+00 2.74E+00 3.28E+01 BACT Limit' Average VOC 2.6 0.9 11.3 Permit Limit' SO2 3.20E-03 1.05E-02 9816 8760 2.28E-01 8.33E-02 1.00E+00 AP-422 PM10 6.60E-03 2.18E-02 9816 8760 4.71E-01 1.72E-01 2.06E+00 AP-422 Acetaldehyde 4.00E-05 1.32E-04 9816 8760 2.86E-03 1.04E-03 1.25E-02 AP-423 Benzene 1.20E-05 3.96E-05 9816 8760 8.57E-04 3.13E-04 3.75E-03 AP-423 Ethylbenzene 3.20E-05 1.06E-04 9816 8760 2.29E-03 8.34E-04 1.00E-02 AP-423 Formaldehyde 7.10E-04 2.34E-03 9816 8760 5.07E-02 1.85E-02 2.22E-01 AP-423 Toluene 1.30E-04 4.29E-04 9816 8760 9.28E-03 3.39E-03 4.07E-02 AP-423 Xylene 6.40E-05 2.11E-04 9816 8760 4.57E-03 1.67E-03 2.00E-02 AP-423 1 BACT and Permit limits are from Construction Permit 04WE1390,March 29,2005 2 EPA AP-42,Volume I, Fifth Edition-April 2000,Table 3.1-2a,Emission Factors for Criteria Pollutants and Greenhouse Gases from Stationary Gas Turbines 3 EPA AP-42,Volume I, Fifth Edition-April 2000,Table 3.1-3,Emission Factors for Hazardous Air Pollutants from Natural Gas-Fired Stationary Gas Turbines Cheyenne Plains TV Calcs.xls Printed on 12/8/2005 Cheyenne Plains Compressor Station Heater Detail Sheet AIRS ID Number 018 Equipment ID H-8701 Stack ID CPT1 Equipment Usage Hot Oil Heater Equipment Make Heatec Equipment Model VHCI-16010-40-G Serial Number Unknown Start-up Date 01/30/2005 Emission Controls Low-NOx burners/FGR Fuel Heating Value 945.83 Btu/scf Design Heat Rate Unknown MMBtu/hr Site Heat Rate 45.00 MMBtu/hr Potential Operation 8760 hr/yr Potential Fuel Usage 416.78 MMscf/yr Potential Emissions Pollutant Emission Factor Nominal Hrs of Estimated Emissions Source of Rating Operation Emission (lb/MMscf) (lb/MMBtu) (MMBtu/hr) (hrs/yr) (lb/hr) (ton/month) (tpy) Factor NOx,50-100%Load 33.10 0.035 45.00 8760 1.58E+00 5.75E-01 6.90E+00 Permit Limit NOx,<50%Load 53.38 0.056 45.00 8760 2.54E+00 9.27E-01 1.11E+01 Manf.Spec.2 CO 35.00 0.037 45.00 8760 1.67E+00 6.08E-01 7.29E+00 Permit Limits VOC 15.13 0.016 45.00 8760 7.20E-01 2.63E-01 3.15E+00 Permit Limit SO2 0.60 — 45.00 8760 2.85E-02 1.04E-02 1.25E-01 AP-423 PM10 7.60 - 45.00 8760 3.62E-01 1.32E-01 1.58E+00 AP-423 Benzene 2.1E-03 - 45.00 8760 9.99E-05 3.65E-05 4.38E-04 AP-424 Dichlorobenzene 1.2E-03 - 45.00 8760 5.71 E-05 2.08E-05 2.50E-04 AP-424 Formaldehyde 7.5E-02 --- 45.00 8760 3.57E-03 1.30E-03 1.56E-02 AP-424 Hexane 1.8E+00 -- 45.00 8760 8.56E-02 3.13E-02 3.75E-01 AP-424 Toluene 3.4E-03 -- 45.00 8760 1.62E-04 5.90E-05 7.09E-04 AP-424 Permit limits are from Construction Permit 03WE0913,June 10,2004 2 Requested permit limit based on manufacturer's data for low load conditions 3 EPA AP-42,Volume I,Fifth Edition-July 1998,Table 1.4-2, Emission Factors for Criteria Pollutants and Greenhouse Gases from Natural Gas Combustion 4 EPA AP-42,Volume I,Fifth Edition-July 1998,Table 1.4-3, Emission Factors for Speciated Organic Compounds from Natural Gas Combustion Cheyenne Plains TV Calcs.xls Printed on 12/8/2005 Cheyenne Plains Compressor Station Heater Detail Sheet AIRS ID Number 019 Equipment ID H-8702 Stack ID CPT2 Equipment Usage Hot Oil Heater Equipment Make Heatec Equipment Model VHCI-16010-40-G Serial Number Unknown Start-up Date 01/30/2005 Emission Controls Low-NOx burners/FGR Fuel Heating Value 945.83 Btu/scf Design Heat Rate Unknown MMBtu/hr Site Heat Rate 45.00 MMBtu/hr Potential Operation 8760 hr/yr Potential Fuel Usage 416.78 MMscf/yr Potential Emissions Pollutant Emission Factor Nominal Hrs of Estimated Emissions Source of Rating Operation Emission (lb/MMscf) (Ib/MMBtu) (MMBtu/hr) (hrs/yr) (lb/hr) (ton/month) (tpy) Factor NOx,50-100%Load 33.10 0.035 45.00 8760 1.58E+00 5.75E-01 6.90E+00 Permit Limit NOx, <50%Load 53.38 0.056 45.00 8760 2.54E+00 9.27E-01 1.11E+01 Manf.Spec.2 CO 35.00 0.037 45.00 8760 1.67E+00 6.08E-01 7.29E+00 Permit Limit VOC 15.13 0.016 45.00 8760 7.20E-01 2.63E-01 3.15E+00 Permit Limit SO2 0.60 -- 45.00 8760 2.85E-02 1.04E-02 1.25E-01 AP-423 PM10 7.60 --- 45.00 8760 3.62E-01 1.32E-01 1.58E+00 AP-423 Benzene 2.1E-03 - 45.00 8760 9.99E-05 3.65E-05 4.38E-04 AP-424 Dichlorobenzene 1.2E-03 -- 45.00 8760 5.71E-05 2.08E-05 2.50E-04 AP-424 Formaldehyde 7.5E-02 -- 45.00 8760 3.57E-03 1.30E-03 1.56E-02 AP-424 Hexane 1.8E+00 --- 45.00 8760 8.56E-02 3.13E-02 3.75E-01 AP-424 Toluene 3.4E-03 -- 45.00 8760 1.62E-04 5.90E-05 7.09E-04 AP-424 I Permit limits are from Construction Permit 03WE0913,June 10,2004 2 Requested permit limit based on manufacturer's data for low load conditions 3 EPA AP-42,Volume I, Fifth Edition-July 1998,Table 1.4-2, Emission Factors for Criteria Pollutants and Greenhouse Gases from Natural Gas Combustion 4 EPA AP-42,Volume I, Fifth Edition-July 1998,Table 1.4-3,Emission Factors for Speciated Organic Compounds from Natural Gas Combustion Cheyenne Plains TV Calcs.xls Printed on 12/8/2005 Cheyenne Plains Compressor Station Heater Detail Sheet AIRS ID Number 020 Equipment ID H-6111 Stack ID CPT3 Equipment Usage Utility Heater Equipment Make Unknown Equipment Model Unknown Serial Number Unknown Start-up Date Unknown Emission Controls None Fuel Heating Value 945.83 Btu/scf Design Heat Rate Unknown MMBtu/hr Site Heat Rate 16.00 MMBtu/hr Potential Operation 500 hr/yr Potential Fuel Usage 8.46 MMscf/yr Potential Emissions Pollutant Emission Factor Nominal Hrs of Estimated Emissions Source of Rating Operation Emission (lb/MMscf) (lb/MMBtu) (MMBtu/hr) (hrs/yr) (lb/hr) (ton/month) (tpy) Factor NOx 100.00 --- 16.00 500 1.69E+00 3.52E-02 4.23E-01 AP-421 CO 84.00 --- 16.00 500 1.42E+00 2.96E-02 3.55E-01 AP-421 VOC 5.50 --- 16.00 500 9.30E-02 1.94E-03 2.33E-02 AP-422 SO2 0.60 --- 16.00 500 1.01E-02 2.11E-04 2.54E-03 AP-422 PM10 7.60 --- 16.00 500 1.29E-01 2.68E-03 3.21E-02 AP-422 Benzene 2.1E-03 --- 16.00 500 3.55E-05 7.40E-07 8.88E-06 AP-423 • Dichlorobenzene 1.2E-03 -- 16.00 500 2.03E-05 4.23E-07 5.07E-06 AP-423 Formaldehyde 7.5E-02 --- 16.00 500 1.27E-03 2.64E-05 3.17E-04 AP-423 Hexane 1.8E+00 -- 16.00 500 3.04E-02 6.34E-04 7.61 E-03 AP-423 Toluene 3.4E-03 --- 16.00 500 5.75E-05 1.20E-06 1.44E-05 AP-423 1 EPA AP-42,Volume I,Fifth Edition-July 1998,Table 1.4-1, Emission Factors for Nitrogen Oxides(NOx)and Carbon Monoxide(CO)from Natural Gas Combustion 2 EPA AP-42,Volume I,Fifth Edition-July 1998,Table 1.4-2, Emission Factors for Criteria Pollutants and Greenhouse Gases from Natural Gas Combustion 3 EPA AP-42,Volume I,Fifth Edition-July 1998,Table 1.4-3, Emission Factors for Speciated Organic Compounds from Natural Gas Combustion Cheyenne Plains TV Calcs.xls Printed on 12/8/2005 Cheyenne Plains Compressor Station Heater Detail Sheet AIRS ID Number -- Equipment IlD H-8721 Stack ID CPT4 Equipment Usage Glycol Reboiler Equipment Make Unknown Equipment Model Unknown Serial Number Unknown Start-up Date Unknown Emission Controls None Fuel Heating Value 945.83 Btu/scf Design Heat Rate Unknown MMBtu/hr Site Heat Rate 4.97 MMBtu/hr Potential Operation 8760 hr/yr Potential Fuel Usage 46.05 MMscf/yr Potential Emissions Pollutant Emission Factor Nominal Hrs of Estimated Emissions Source of Rating Operation Emission (lb/MMscf) (lb/MMBtu) (MMBtu/hr) (hrs/yr) (lb/hr) (ton/month) (tpy) Factor NOx 38.78 0.041 4.97 8760 2.04E-01 7.44E-02 8.93E-01 Manf. Spec. CO 70.94 0.075 4.97 8760 3.73E-01 1.36E-01 1.63E+00 Manf.Spec. VOC 30.27 0.032 4.97 8760 1.59E-01 5.81E-02 6.97E-01 Manf.Spec.' SO2 0.60 -- 4.97 8760 3.15E-03 1.15E-03 1.38E-02 AP-422 PM10 7.60 --- 4.97 8760 4.00E-02 1.46E-02 1.75E-01 AP-422 Benzene 2.1E-03 - 4.97 8760 1.10E-05 4.03E-06 4.84E-05 AP-423 1 Dichlorobenzene 1.2E-03 --- 4.97 8760 6.31E-06 2.30E-06 2.76E-05 AP-423 Formaldehyde 7.5E-02 -- 4.97 8760 3.94E-04 1.44E-04 1.73E-03 AP-423 Hexane 1.8E+00 -- 4.97 8760 9.46E-03 3.45E-03 4.14E-02 AP-423 Toluene 3.4E-03 -- 4.97 8760 1.79E-05 6.52E-06 7.83E-05 AP-423 1 Assumes V0C is expressed as propane 2 EPA AP-42,Volume I, Fifth Edition-July 1998,Table 1.4-2,Emission Factors for Criteria Pollutants and Greenhouse Gases from Natural Gas Combustion 3 EPA AP-42,Volume I, Fifth Edition-July 1998,Table 1.4-3, Emission Factors for Spectated Organic Compounds from Natural Gas Combustion Cheyenne Plains TV Calcs.xls Printed on 12/8/2005 Cheyenne Plains Compressor Station Amine Detail Sheet AIRS ID Number 021 Equipment ID ST-8931 Stack ID CPT6 Equipment Usage Amine Vent Equipment Make Hanover Equipment Model Unknown Serial Number Unknown Start-up Date 01/30/2005 Equipment Configuration N/A Emission Controls Flare&SulfaTreat Potential Operation 8760 hr/yr Potential Throughput 13.00 scfd Potential Uncontrolled Amine Unit Flash Tank Emissions Pollutant Estimated Source of Emission Factor Emissions (tPY) VOC 42.9480 API AMINECalc 1.0 Benzene 2.2320 API AMINECalc 1.0 Toluene 1.8870 API AMINECalc 1.0 Hexane 0.9010 API AMINECalc 1.0 Note:Amine Unit flash tank emissions are routed to the flare(AIRS ID 022), so controlled emissions are represented on the Flare Detail Sheet. Potential Controlled Amine Unit Regenerator Emissions Pollutant Estimated Source of Emission Factor Emissions (tPY) VOC 11.79 API AMINECalc 1.0 Hydrogen Sulfide 4.9148 API AMINECalc 1.0 Benzene 7.2340 API AMINECalc 1.0 Toluene 2.2000 API AMINECalc 1.0 Hexane 0.0530 API AMINECalc 1.0 • Cheyenne Plains TV Calcs.xls Printed on 12/8/2005 Cheyenne Plains Compressor Station Dehydrator Detail Sheet AIRS ID Number -- Equipment ID Dehy Stack ID -- Equipment Usage Glycol Dehydrator Equipment Make Unknown Equipment Model Unknown Serial Number Unknown Start-up Date Unknown Equipment Configuration N/A Emission Controls Flare Potential Operation 8760 hr/yr Potential Throughput 300 MMscfd Potential Uncontrolled Regenerator Vent/Flash Tank Emissions Pollutant Estimated Source of Emission Factor Emissions (tpY) VOC 4.8487 GRI GLYCalc 4.0 Benzene 0.8686 GRI GLYCaIc 4.0 Hexane 0.1050 GRI GLYCalc 4.0 Toluene 1.5436 GRI GLYCaIc 4.0 Note: Dehydrator regenerator vent and flash tank emissions are routed to the flare(AIRS MD 022),so controlled emissions are represented on the Flare Detail Sheet. Cheyenne Plains TV Calcs.xls Printed on 12/8/2005 Cheyenne Plains Compressor Station Flare Detail Sheet AIRS ID Number 022 Equipment ID FL-8921 Stack ID CPT5 Equipment Usage Flare Equipment Make Unknown Equipment Model Unknown Serial Number Unknown Start-up Date 01/30/2005 Equipment Configuration N/A Vent Heating Value 719 Btu/scf Vent Flow Rate 18831 scf/hr Vent Heat Input 13.54 MMBtu/hr Potential Operation 8760 hr/yr Potential Controlled Dehydrator Regenerator Vent/Flash Gas Emissions Pollutant Estimated Source of Emission Emissions Factor (tPY) VOC 4.8487 GRI GLYCaic 4.0 Benzene 0.8686 GRI GLYCaic 4.0 Hexane 0.1050 GRI GLYCaic 4.0 Toluene 1.5436 GRI GLYCaic 4.0 Potential Controlled Amine Unit Flash Tank Emissions Pollutant Estimated Source of Emission Emissions Factor (tPY) VOC 0.8590 API AMINECalc 1.0 Benzene 0.0446 API AMINECalc 1.0 Hexane 0.0180 API AMINECalc 1.0 Toluene 0.0377 API AMINECalc 1.0 Total Controlled Potential Emissions from Flare Pollutant Emission Factor Nominal Hrs of Estimated Emissions Source of Rating Operation Emission (lb/MMscf) (Ib/MMBtu) (MMBtu/hr) (hrs/yr) (lb/hr) (tpy) Factor NOx 89.2 0.124 13.54 8760 1.6789 7.35 Permit Limit' CO 477.9 0.665 13.54 8760 8.9997 39.42 Permit Limit' VOC 1841.7 0.098 13.54 8760 1.3242 5.80 Permit Limit' Benzene --- -- — -- 0.2085 0.91 AMINECalc/GLYCaic Hexane --- --- — --- 0.0281 0.12 AMINECalc/GLYCaic Toluene --- -- — -- 0.3610 1.58 AMINECalc/GLYCaic 1 Permit limits are from Construction Permit 03WE0916, May 23,2005. Cheyenne Plains Compressor Station Fugitive Emissions AIRS ID Number -- Source Description Fugitive Emissions Source Usage Equipment Leaks Potential operation 8760 hr/yr Potential Emissions Pollutant Hrs of Estimated Emissions Source of Emission Operation Factor (hrs/yr) (lb/hr) (tpy) VOC 8760 0.25 1.10 GRI-HAPCalc 3.0 Benzene 8760 0.0008 0.0037 GRI-HAPCalc 3.0 Toluene 8760 0.0016 0.0068 GRI-HAPCalc 3.0 Ethylbenzene 8760 0.0001 0.0006 GRI-HAPCalc 3.0 Xylene 8760 0.0005 0.0021 GRI-HAPCalc 3.0 HAP Total 0.01 Cheyenne Plains TV Calcs.xls Printed on 12/8/2005 Cheyenne Plains Compressor Station Vent Detail Sheet AIRS ID Number -- Source Description Fugitive Emissions Source Usage Turbine Start-ups Fuel Heating Value 945.83 Btu/scf Number of Startups 24 max/yr Potential Startup Emissions Engine ID Gas Emitted Max.#of Avg.VOC Avg MoI.Wt. VOC Fraction Total VOC Number per Startup Startups/year Content VOC Fraction Emitted Emissions (scf) (mol%) (lb/mol) (mol/yr) (tpy) CG-7101 15000 24 0.10% 77 0.97 0.037 CG-7201 15000 24 0.10% 77 0.97 0.037 CG-7501 15000 24 0.10% 77 0.97 0.037 TOTAL 0.11 Cheyenne Plains TV Calcs 121205.xls Printed on 12/12/2005 Cheyenne Plains Compressor Station Vent Detail Sheet AIRS ID Number -- Source Description Fugitive Emissions Source Usage Compressor Blowdowns Fuel Heating Value 945.83 Btu/scf Number of Blowdowns 24 max/yr Potential Emissions Engine ID Volume per Events per Avg.VOC Avg Mol.Wt. VOC Fractior Total VOC Number Event(STP) Year Content VOC Fraction Emitted Emissions (cf) (mol %) (lb/mol) (mol/yr) (tpy) CG-7101 45000 24 0.10% 77 2.92 0.11 CG-7201 45000 24 0.10% 77 2.92 0.11 CG-7501 45000 24 0.10% 77 2.92 0.11 TOTAL 0.34 i Cheyenne Plains TV Calcs 121205.xls Printed on 12/12/2005 Cheyenne Plains Compressor Station Vent Detail Sheet AIRS ID Number --- Source Description Fugitive Emissions Source Usage Emergency Shutdowns Fuel Heating Value 945.83 Btu/scf Number of Events 2 max/yr Potential Emissions Volume per Events per Avg.VOC Avg MoI.Wt. VOC Fraction Total VOC Event(STP) Year Content VOC Fraction Emitted Emissions (cf) (mol%) (lb/mol) (mol/yr) {tpy) Station 635000 2 0.10% 77 3.43 0.13 Cheyenne Plains TV Calcs 121205.xls Printed on 12/12/2005 Page: 1 GRI-GLYCalc VERSION 4.0 - AGGREGATE CALCULATIONS REPORT Case Name: Cheyenne Plains Compressor Station File Name: M: \Projects\22238160_Cheyenne_Plains\Task_01\7.0_Project_Workingfiles\Cheyenn e Plains GLYCalc.ddf Date: September 07, 2005 DESCRIPTION: Description: 300 MMscf/day TEG Dehydrator Annual Hours of Operation: 8760 .0 hours/yr EMISSIONS REPORTS: CONTROLLED REGENERATOR EMISSIONS Component lbs/hr lbs/day tons/yr Methane 0.2027 4. 866 0.8880 Ethane 0.0605 1.451 0.2648 Propane 0.0656 1.575 0.2873 Isobutane 0 .0303 0.726 0.1325 n-Butane 0.0492 1.180 0.2154 Isopentane 0.0222 0.534 0.0974 n-Pentane 0.0235 0.564 0.1029 n-Hexane 0.0173 0.414 0.0756 Other Hexanes 0 .0326 0.782 0.1427 Heptanes 0 .0269 0. 647 0.1180 Benzene 0. 1953 4. 687 0.8553 Toluene 0.3488 8.371 1.5277 C8+ Heavies 0.0387 0. 929 0.1696 Total Emissions 1.1136 26.726 4.8775 Total Hydrocarbon Emissions 1.1136 26.726 4 .8775 Total VOC Emissions 0.8504 20.409 3.7246 Total HAP Emissions 0.5613 13.472 2 .4586 Total BTEX Emissions 0.5441 13.058 2 .3830 UNCONTROLLED REGENERATOR EMISSIONS Component lbs/hr lbs/day tons/yr Page: 2 Methane 10.1374 243.298 44 .4019 Ethane 3 .0228 72.546 13.2397 ) Propane 3 .2802 78.725 14 .3673 Isobutane 1.5126 36.302 6.6252 n-Butane 2 .4591 59.017 10.7706 Isopentane 1.1122 26. 693 4.8716 n-Pentane 1 .1749 28. 198 5.1461 n-Hexane 0. 8629 20.710 3.7796 Other Hexanes 1 . 6293 39.104 7 .1364 Heptanes 1 .3474 32.338 5.9017 Benzene 9.7641 234.338 42 .7667 Toluene 17 . 4397 418.552 76.3857 C8+ Heavies 1 . 9361 46.467 8.4803 Total Emissions 55. 6787 1336.290 243.8728 Total Hydrocarbon Emissions 55. 6787 1336.290 243.8728 Total VOC Emissions 42 .5185 1020.445 186.2312 Total HAP Emissions 28.0667 673. 600 122.9320 Total BTEX Emissions 27.2038 652.890 119.1525 FLASH GAS EMISSIONS Component lbs/hr lbs/day tons/yr Methane 0 . 9610 23. 063 4 .2090 Ethane 0 .1807 4.337 0.7916 Propane 0 .1071 2.569 0.4689 Isobutane 0 .0348 0.836 0.1526 n-Butane 0 .0447 1.072 0.1957 Isopentane 0. 0182 0.436 0.0795 n-Pentane 0 .0157 0.377 0.0689 n-Hexane 0 .0067 0. 161 0.0294 Other Hexanes 0. 0164 0.393 0. 0716 Heptanes 0 . 0053 0. 128 0.0234 Benzene 0 .0030 0.073 0.0133 Toluene 0 . 0036 0.087 0.0158 C8+ Heavies 0 .0011 0.027 0.0049 Total Emissions 1.3983 33.560 6.1246 Total Hydrocarbon Emissions 1 .3983 33.560 6.1246 Total VOC Emissions 0.2566 6. 159 1.1241 Total HAP Emissions 0 . 0134 0.321 0.0585 Total BTEX Emissions 0.0066 0.160 0.0291 Page: 3 FLASH TANK OFF GAS Component lbs/hr lbs/day tons/yr Methane 48.0479 1153.151 210.4500 Ethane 9.0364 216.874 39.5795 Propane 5.3530 128.472 23.4461 Isobutane 1.7415 41.795 7. 6276 n-Butane 2.2341 53.618 9.7852 Isopentane 0. 9079 21.791 3. 9768 n-Pentane 0.7864 18 . 874 3.4446 n-Hexane 0.3357 8 .056 1.4703 Other Hexanes 0. 8178 19. 626 3.5818 Heptanes 0.2671 6.411 1.1700 Benzene 0.1515 3. 636 0. 6635 Toluene 0.1809 4 .341 0.7922 C8+ Heavies 0 .0558 1.339 0.2444 Total Emissions 69. 9160 1677 . 984 306.2320 Total Hydrocarbon Emissions 69.9160 1677 . 984 306.2320 Total VOC Emissions 12 .8316 307 . 959 56.2025 Total HAP Emissions 0 . 6681 16.033 2 . 9261 Total BTEX Emissions 0.3324 7 . 977 1.4558 COMBINED REGENERATOR VENT/FLASH GAS EMISSIONS Component lbs/hr lbs/day tons/yr Methane 1.1637 27 . 929 5.0970 Ethane 0.2412 5.788 1.0564 Propane 0.1727 4 .144 0.7563 Isobutane 0.0651 1 .562 0.2851 n-Butane 0 .0939 2 .253 0.4111 Isopentane 0.0404 0 .970 0.1770 n-Pentane 0.0392 0 . 941 0. 1718 n-Hexane 0.0240 0.575 0.1050 Other Hexanes 0 .0489 1 .175 0.2144 Heptanes 0.0323 0.775 0. 1414 Benzene 0.1983 4 .759 0. 8686 Toluene 0.3524 8 .458 1.5436 C8+ Heavies 0.0398 0 . 956 0.1745 Total Emissions 2.5119 60.285 11. 0021 Total Hydrocarbon Emissions 2.5119 60.285 11.0021 Total VOC Emissions 1.1070 26.568 4.8487 Total HAP Emissions 0.5747 13.793 2.5172 Page: 4 Total BTEX Emissions 0.5507 13.217 2.4122 ' COMBINED REGENERATOR VENT/FLASH GAS EMISSION CONTROL REPORT: Component Uncontrolled Controlled % Reduction tons/yr tons/yr Methane 254 .8519 5.0970 98.00 Ethane 52.8192 1.0564 98 .00 Propane 37 .8134 0.7563 98 .00 Isobutane 14.2528 0.2851 98.00 n-Butane 20 .5559 0.4111 98 .00 Isopentane 8 .8483 0.1770 98 .00 n-Pentane 8 .5906 0.1718 98.00 n-Hexane 5.2499 0.1050 98 .00 Other Hexanes 10.7182 0.2144 98 .00 Heptanes 7.0717 0. 1414 98 .00 Benzene 43.4303 0. 8686 98 .00 Toluene 77.1780 1.5436 98. 00 C8+ Heavies 8.7247 0.1745 98.00 Total Emissions 550.1049 11.0021 98 .00 Total Hydrocarbon Emissions 550.1049 11.0021 98 .00 Total VOC Emissions 242.4338 4.8487 98.00 Total HAP Emissions 125.8581 2. 5172 98 .00 Total BTEX Emissions 120. 6082 2.4122 98 .00 EQUIPMENT REPORTS: COMBUSTION DEVICE Ambient Temperature: 50. 00 deg. F Excess Oxygen: 5. 00 % Combustion Efficiency: 98. 00 % Supplemental Fuel Requirement: 3.32e-001 MM BTU/hr Component . Emitted Destroyed Methane 2 . 00% 98.00% Ethane 2 . 00% 98.00% Page: 5 Propane 2 .00% 98 .00% Isobutane 2 .00% 98 .00% n-Butane 2 .00% 98 .00% Isopentane 2 .00% 98 .00% n-Pentane 2.00% 98 .00% n-Hexane 2 .00% 98 .00% Other Hexanes 2 .00% 98.00% Heptanes 2.00% 98 .00% Benzene 2.00% 98 .00% Toluene 2 .00% 98.00% C8+ Heavies 2.00% 98 .00% ABSORBER NOTE: Because the Calculated Absorber Stages was below the minimum allowed, GRI-GLYCalc has set the number of Absorber Stages to 1.25 and has calculated a revised Dry Gas Dew Point. Calculated Absorber Stages: 1.25 Calculated Dry Gas Dew Point: 0 .73 lbs. H2O/MMSCF Temperature: 68.0 deg. F Pressure: 896.7 psig Dry Gas Flow Rate: 292.0000 MMSCF/day Glycol Losses with Dry Gas: 0.8625 lb/hr Wet Gas Water Content: Saturated Calculated Wet Gas Water Content: 23.58 lbs. H2O/MMSCF Calculated Lean Glycol Recirc. Ratio: 6.90 gal/lb H2O Remaining Absorbed Component in Dry Gas in Glycol Water 3.08% 96. 92% Nitrogen 99. 99% 0.01% Methane 99. 99% 0.01% Ethane 99. 96% 0.04% Propane 99. 94% 0.06% Isobutane 99. 91% 0 .09% n-Butane 99.88% 0. 12% Isopentane 99.88% 0 .12% n-Pentane 99. 84% 0.16% n-Hexane 99.71% 0.29% Other Hexanes 99.79% 0.21% Heptanes 99.44% 0.56% Benzene 86.81% 13.19% Toluene 80.13% 19.87% Page: 6 C8+ Heavies 99. 09% 0. 91% FLASH TANK Flash Control: Combustion device Flash Control Efficiency: 98.00 % Flash Temperature: 150.0 deg. F Flash Pressure: 60.0 psig Left in Removed in Component Glycol Flash Gas Water 99. 96% 0. 04% Nitrogen 7 .88% 92 . 12% Methane 8.01% 91. 99% Ethane 22. 61% 77.39% Propane 36.75% 63.25% Isobutane 45.75% 54.25% n-Butane 51. 91% 48. 09% Isopentane 54.84% 45. 16% n-Pentane 59. 81% 40. 19% n-Hexane 72.02% 27. 98% Other Hexanes 66.73% 33.27% Heptanes 83.50% 16.50% Benzene 98.55% 1.45% Toluene 99. 05% 0. 95% C8+ Heavies 97.53% 2.47% REGENERATOR Regenerator Stripping Gas: Dry Product Gas Stripping Gas Flow Rate: 2.5000 scfm Remaining Distilled Component in Glycol Overhead Water 36.84% 63. 16% Nitrogen 0.00% 100. 00% Methane 0.00% 100.00% Ethane 0. 00% 100.00% Propane 0. 00% 100. 00% Isobutane 0.00% 100. 00% n-Butane 0. 00% 100.00% Isopentane 0. 91% 99.09% Page: 7 n-Pentane 0 . 84% 99.16% n-Hexane 0 . 69% 99.31% Other Hexanes 1.50% 98.50% Heptanes 0. 60% 99.40% Benzene 5. 07% 94. 93% Toluene 7 . 98% 92.02% C8+ Heavies 12.34% 87 . 66% STREAM REPORTS: WET GAS STREAM Temperature: 68 . 00 deg. F Pressure: 911.40 psia Flow Rate: 1.22e+007 scfh Component Conc. Loading (vol%) (lb/hr) Water 4. 97e-002 2. 87e+002 Nitrogen 1.27e+000 1.14e+004 Methane 9.39e+001 4. 83e+005 Ethane 3.22e+000 3. 11e+004 Propane 9.79e-001 1.39e+004 Isobutane 1. 92e-001 3.58e+003 n-Butane 2.06e-001 3.84e+003 Isopentane 7.00e-002 1. 62e+003 n-Pentane 5. 10e-002 1. 18e+003 n-Hexane 1.50e-002 4.15e+002 Other Hexanes 4. 10e-002 1. 13e+003 Heptanes 9. 01e-003 2. 90e+002 Benzene 3.00e-003 7.52e+001 Toluene 3. 00e-003 8. 87e+001 C8+ Heavies 4. 00e-003 2.19e+002 Total Components 100. 00 5.52e+005 DRY GAS STREAM Temperature: 68. 00 deg. F Pressure: 911.40 psia Flow Rate: 1.22e+007 scfh Page: 8 Component Conc. Loading (volt) (lb/hr) Water 1. 53e-003 8.83e+000. Nitrogen 1.27e+000 1. 14e+004 Methane 9.39e+001 4.83e+005 Ethane 3.22e+000 3. 11e+004 Propane 9. 79e-001 1.38e+004 Isobutane 1 . 92e-001 3.58e+003 n-Butane 2 . 06e-001 3. 84e+003 Isopentane 6. 99e-002 1. 62e+003 n-Pentane 5.09e-002 1.18e+003 n-Hexane 1 .50e-002 4.14e+002 Other Hexanes 4 . 09e-002 1.13e+003 Heptanes 8 . 96e-003 2.88e+002 Benzene 2 . 61e-003 6.53e+001 Toluene 2 . 41e-003 7.11e+001 C8+ Heavies 3. 97e-003 2.17e+002 Total Components 100.00 5.52e+005 LEAN GLYCOL STREAM Temperature: 68.00 deg. F Flow Rate: 3.20e+001 gpm Component Conc. Loading (wt%) (lb/hr) TEG 9. 91e+001 1.79e+004 Water 9. 00e-001 1. 62e+002 Nitrogen 7 .89e-013 1.42e-010 Methane 9.74e-018 1.75e-015 Ethane 3. 06e-008 5.51e-006 Propane 1 . 91e-009 3. 44e-007 Isobutane 5.34e-010 9. 63e-008 n-Butane 6.39e-010 1.15e-007 Isopentane 5 .58e-005 1. 01e-002 n-Pentane 5. 43e-005 9. 78e-003 n-Hexane 3.33e-005 6. 00e-003 Other Hexanes 1 .36e-004 2. 46e-002 Heptanes 4 .49e-005 8. 10e-003 Benzene 2 . 90e-003 5.22e-001 Toluene 8 .39e-003 1.51e+000 C8+ Heavies 1.51e-003 2.72e-001 Total Components 100.00 1. 80e+004 Page: 9 RICH GLYCOL STREAM Temperature: 68 .00 deg. F Pressure: 911.40 psia Flow Rate: 3.28e+001 gpm NOTE: Stream has more than one phase. Component Conc. Loading (wt%) (lb/hr) TEG 9. 69e+001 1 . 79e+004 • Water 2 .39e+000 4.41e+002 Nitrogen 7.71e-003 1.42e+000 Methane 2. 83e-001 5.22e+001 Ethane 6.34e-002 1. 17e+001 Propane 4 .59e-002 8.46e+000 Isobutane 1.74e-002 3.21e+000 n-Butane 2.52e-002 4. 65e+000 Isopentane 1.09e-002 2. 01e+000 n-Pentane 1. 06e-002 1. 96e+000 n-Hexane 6.51e-003 1.20e+000 Other Hexanes 1.33e-002 2.46e+000 Heptanes 8 .79e-003 1. 62e+000 Benzene 5. 66e-002 1.04e+001 Toluene 1. 04e-001 1. 91e+001 C8+ Heavies 1.23e-002 2.26e+000 Total Components 100.00 1. 84e+004 FLASH TANK OFF GAS STREAM Temperature: 150.00 deg. F Pressure: 74 .70 psia Flow Rate: 1.36e+003 scfh Component Conc. Loading (volt) (lb/hr) Water 2. 94e-001 1. 90e-001 Nitrogen 1.30e+000 1.31e+000 Methane 8.35e+001 4. 80e+001 Ethane 8.38e+000 9. 04e+000 Propane 3.38e+000 5.35e+000 Isobutane 8.35e-001 1. 74e+000 n-Butane 1.07e+000 2.23e+000 Page: 10 Isopentane 3.51e-001 9 .08e-001 n-Pentane 3. 04e-001 7 . 86e-001 n-Hexane 1 . 09e-001 3 .36e-001 Other Hexanes 2. 65e-001 8 .18e-001 Heptanes 7.43e-002 2 . 67e-001 Benzene 5.41e-002 1 .51e-001 Toluene 5.47e-002 1 .81e-001 C8+ Heavies 9.13e-003 5.58e-002 Total Components 100. 00 7 .14e+001 FLASH TANK GLYCOL STREAM Temperature: 150.00 deg. F Flow Rate: 3.27e+001 gpm Component Conc. Loading (wt%) (lb/hr) TEG 9.73e+001 1.79e+004 Water 2.40e+000 4 .40e+002 Nitrogen 6.10e-004 1.12e-001 Methane 2.28e-002 4 .18e+000 Ethane 1.44e-002 2. 64e+000 Propane 1. 69e-002 3.11e+000 Isobutane 8.00e-003 1 .47e+000 n-Butane 1.31e-002 2 .41e+000 Isopentane 6.01e-003 1.10e+000 n-Pentane 6.38e-003 1 .17e+000 n-Hexane 4.71e-003 8 . 64e-001 Other Hexanes 8. 94e-003 1. 64e+000 Heptanes 7.37e-003 1.35e+000 Benzene 5. 60e-002 1.03e+001 Toluene 1. 03e-001 1. 90e+001 C8+ Heavies 1.20e-002 2 .21e+000 Total Components 100.00 1.84e+004 FLASH GAS EMISSIONS Flow Rate: 4 . 69e+003 scfh Control Method: Combustion Device Control Efficiency: 98 .00 Component Conc. Loading (volt) (lb/hr) Page: 11 Water 6.35e+001 1.41e+002 Carbon Dioxide 3.55e+001 1. 93e+002 Nitrogen 3.78e-001 1.31e+000 Methane 4 . 85e-001 9. 61e-001 Ethane 4 .87e-002 1.81e-001 Propane 1. 97e-002 1.07e-001 Isobutane 4.85e-003 3.48e-002 n-Butane 6.22e-003 4.47e-002 Isopentane 2 .04e-003 1.82e-002 n-Pentane 1.76e-003 1.57e-002 n-Hexane 6.31e-004 6.71e-003 Other Hexanes 1.54e-003 1. 64e-002 Heptanes 4 .32e-004 5.34e-003 Benzene 3.14e-004 3.03e-003 Toluene 3.18e-004 3. 62e-003 C8+ Heavies 5.30e-005 1. 12e-003 Total Components 100.00 3.37e+002 REGENERATOR OVERHEADS STREAM Temperature: 212 . 00 deg. F Pressure: 14 .70 psia Flow Rate: 6.35e+003 scfh. Component Conc. Loading (volt) (lb/hr) Water 9.23e+001 2. 78e+002 Nitrogen 5.39e-002 2.53e-001 Methane 3.78e+000 1.01e+001 Ethane 6.01e-001 3. 02e+000 Propane 4.45e-001 3.28e+000 Isobutane 1.56e-001 1.51e+000 n-Butane 2.53e-001 2. 46e+000 Isopentane 9.22e-002 1. 11e+000 n-Pentane 9.74e-002 1. 17e+000 n-Hexane 5. 99e-002 8. 63e-001 Other Hexanes 1.13e-001 1. 63e+000 Heptanes 8.04e-002 1.35e+000 Benzene 7.47e-001 9. 76e+000 Toluene 1.13e+000 1.74e+001 C8+ Heavies 6.80e-002 1. 94e+000 Total Components 100.00 3.34e+002 Page: 12 COMBUSTION DEVICE OFF GAS STREAM Temperature: 1000 . 00 deg. F Pressure: 14 .70 psia Flow Rate: 9. 68e+000 scfh Component Conc. Loading (volt) (lb/hr) Methane 4 . 96e+001 2.03e-001 Ethane 7 . 88e+000 6. 05e-002. Propane 5. 83e+000 6.56e-002 Isobutane 2 .04e+000 3. 03e-002 n-Butane 3.32e+000 4. 92e-002 Isopentane 1 .21e+000 2.22e-002 n-Pentane 1.28e+000 2.35e-002 n-Hexane 7 .85e-001 1.73e-002 Other Hexanes 1 .48e+000 3.26e-002 Heptanes 1 .05e+000 2. 69e-002 Benzene 9. 80e+000 1. 95e-001 Toluene 1.48e+001 3.49e-001 C8+ Heavies 8 . 92e-001 3. 87e-002 Total Components 100. 00 1.11e+000 Cheyenne Plains - Amine Plant Total Emissions Controlled Emissions Uncontrolled Emissions Component lb/h ton/yr lb/h ton/yr H2S 4.488 19.659 4.488 19.660 CO2 39140.829 171433.967 39140.829 171433.967 MEA 0.015 0.066 0.303 1.329 H2O 0.481 2.108 9.622 42.145 N2 0.341 1.491 3.952 17.307 C1 42.188 184.784 345.906 1515.046 C2 2.642 11.572 21.855 95.722 C3 0.903 3.955 8.186 35.851 i-C4 0.008 0.035 0.147 0.641 n-C4 0.009 0.037 0.158 0.689 i-05 0.006 0.023 0.095 0.413 n-05 0.003 0.017 0.069 0.304 Other Hexanes 0.013 0.059 0.193 0.846 Heptanes 0.001 0.007 0.024 0.107 Octanes 0.001 0.002 0.012 0.052 Benzene 1.677 7.345 2.162 9.466 Toluene 0.524 2.295 0.933 4.087 n-Hexane 0.022 0.098 0.218 0.954 Total Emissions: 39194.151 171667.52 39539.152 173178.586 VOC Emissions: 3.182 13.939 12.500 54.739 HAP Emissions: 2.223 9.738 3.313 14.507 lb/h ton/yr lb/h ton/yr Controlled Emissions equals controlled flash tank emissions plus uncontrolled amine regenerator emissions GRI-HAPCaIc®3.0 Fugitive Emissions Report Facility ID: CIG CHEYENNE PLAINS Notes: Operation Type: COMPRESSOR STATION Facility Name: CHEYENNE PLAINS COMPRESSOR User Name: Units of Measure: U.S.STANDARD Note: Emissions less than 5.00E-09 tons(or tonnes)per year are considered insignificant and are treated as zero. These emissions are indicated on the report with a"0". Emissions between 5.00E-09 and 5.00E-05 tons(or tonnes)per year are represented on the report with"0.0000". Fugitive Emissions Calculation Method: EPA Average Factors User Inputs Component Gas Service Light Liquid Service Heavy Liquid Service Connections: 35 10 0 Flanges 600 115 0 Open-Ended Lines: 2 4 0 Pumps: 0 10 0 Valves: 233 30 0 Others: 10 0 0 Calculated Emissions (ton/yr) Chemical Name Emissions HAPs Benzene 0.0037 Toluene 0.0068 Ethylbenzene 0.0006 Xylenes(m,p,o) 0.0021 Total 0.0132 Criteria Pollutants NMHC 1.9054 NMEHC 1.0992 AIR POLLUTANT EMISSION NOTICE PERMIT No.: 04WE1390 AIRS ID.: 1 U_0051 / 024 FIRM NAT Cheyenne Plains Gas Pipeline Company MAIL ADDRESS PO Box 1087,Colorado Springs. STATE:_CO ZIP: 80944 PLANT NAME&LOCATION Cheyenne Compressor Station,Section 5.TI IN,R66W t; rl C7 COUNTY:_Weld REQUEST PORTABLE SOURCE PERMIT HOME-BASE FOR PORTABLE SOURCE ````ff�t _ PERSON TO CONTACT REGARDING THIS INFORMATION_ Mr.Barry Schatz /39 TLE Principal Environmental Scientist PHONE 719-388-5717 GENERAL DESCRIPTION OF THIS PLANT'S FUNCTION Natural Gas Transmission by fuj t., AIL ADDRESS: Barry.Schatziitelpaso.com A.GENERAL.INFORMATION Normal Operation of This Source Process Seasonal Through-ut(%of Annual) ADDITIONAL INFORMATION OR REMARKS: CP CG-7301 Hours/Day Days/Week Weeks/Year Dec-Feb Mar-May Jun-Aug Sep-Nov 24 7 52 25% 25% 25% 25% APEN is for one unit.Emission estimates arc for one unit. B.STACK OR VENT INFORMATION (Identify below which stack if plant has two or more;refer to attached sketch of plant layout) Height Diameter Temperature Flow Rate Velocity Moisture Plant ID No.for Stack 72.2 ft 4.76 ft 860°F 93,105 ACFM 5,238 ttmin % CP CG-7301 AIRS stack 1#024 C.FUEL INFORMATION Design Input Rate Annual Fuel Consumption Fuel Heating Value: Percent by Weight Seasonal Fuel Use(%of Annual Use) Space Htg (10"BTU/hr) Kind of Fuel Requested level Actual level (BTU/Ib,BTU/gal,or (%Ann.) Description of Combustion Unit Burned MMscf/yr (Data year level) BTU/scf) Sulfur Ash Dec-Feb Mar-May Jun-Aug Sep-Nov 9,816 hp stationary gas-turbine 71.42 Natural Gas 661.5 661.5 960 Make/Model:Solar Taurus 70 Serial No.0286B D. PROCESS INFORMATION Raw Materials Used Raw Materials-Annual Consumption Design Process Rate Finished Product Finished Product-Annual Output Actual level Description Actual level Description of Processing Unit Description Requested level (Data year level) (Specify Units/Hour) Requested level (Data year level) Make/Model: Serial No.: — E.POLLUTION CONTROL EQUIPMENT Overall ESTIMATED EMISSIONS ACTUAL ESTIMATION CHECK ALI.BOXES THAT APPLY Pollutant Type of Control Equipment Collection (TONS/YEAR)AT THROUGHPUTS EMISSIONS METHOD ❑ New or previously unreported source* •Y .� • Efficiency REQUESTED ABOVE (from data year) ❑ Requesting modification of existing permit 41" Primary Secondary CONTROLLED UNCONTROLLED ❑ Change in emissions.throughputs or equip `ent I6 CIA Particulate 2.1 2.1 AP 42 ❑ Transfer of ownership • '��11�1rryy' PM,,, 2.1 2.1 (List previous owner in REMARKS secti n of box A)" ,, AP-`t2 X Previous APEN is expiring I ,j+ y ;' SO, El Request for Emission Reduction Credit H &$ CO '74> NO, SoL.oNOx II 20.1 20.1 �lfg.Est. O (Specify) �O VOC 11 3 11 3 * Complete all applicable portions of APEN es fi - Mfg.Est. * Complete ARequested Level@ values for permit 's CO 20.9 20.9 Mfg.Est. t Complete all information above box A.and those remaining PLEASE USE APCD NON-CRITERIA REPORTABLE AIR ❑ CHECK HERE IF YOU WISH THE DIVISION TO CALCULATE YOUR portions which reflect changes POLLUTANT ADDENDUM FORM TO REPORT SUCH POLLUTANTS OR POLLUTANTS NOT LISTED ABOVE. EMISSIONS.SEE"EMISSION ESTIMATES" INSTRUCTIONS ON BACK. Signature of Person Legally Authorized to Supply Data: _nn DATE: / YEAR FOR WHICH THE ACTUAL DATA APPLIES: G S C -e✓ 'N 2-ci C-7 2006 Typed Name and Title: Barry Schatz,Principal Environmental Scientist ✓ Date source began or will begin operation: 2006 THIS NOTICE.IS VALID FOR FIVE YEARS.A revised notice shall be filed prior to this $119.96 FILING FEE IS REQUIRED Colorado Dept.of Public Health& Environment APEN# I of 8 expiration date,whenever a permit limitation must be modified,whenever control equipment is FOR EACH NOTICE FILED. Air Pollution Control Dimision changed,and annually whenever a significant emission change occurs.-For specific details see 4300 Cherry Creek Drive South.APCD-SS-B I For Information.Call Regulation 3.Part A, ' II.C.I. Send completed forms with fees to: Denver,Colorado 80246-1530 (303) t92-315() INSTRUCTIONS FOR AIR POLLUTANT EMISSION NOTICE FOR NEW, EXISTING, AND MODIFIED SOURCES PLEASE RE U)THIS FIRST IF APPLYING FOR A PERMIT:Emission permits will limit the level of production/operation to that requested on the APEN.It is suggested that a 5-year growth protection be made.Please note this level under the annual consumption and output bows.as well as in the emission estimate section.You also need to enter your best estimate of produetion;operation for the-hr.!S ear of uperatf ii \n lei-or:1e estimate 0 r Ih:lint bill seat NON-CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDEND * (Instructions on reverse side) M Permit Number 04WE1390 AIRS Number 123/0051/024 Company Name: Cheyenne Plains Gas Pipeline Company Plant Location: Section 5,Township 11 North,Range 66 West Person to Contact: Barry Schatz,Principal Environmental Scientist County Weld Zip Code E-Mail Address: Barry.Schatz@elpaso.com Phone 719-520-4487 Fax 719-520-4716 Chemical Abstract Service Chemical Name Number Reporting Control Equipment/ Emission Factor Emission Factor Requested Emissions Actual Emissions from the Bin Efficiency q (include units) Source y ) Data Year(Ibs/yr) 50-00-0 Formaldehyde A (lbs/yr) 7.10E-04 Ib/MMBtu AP-42 444.2 444.2 * Use this form for reporting Hazardous Air Pollutants,Ozone Depleting Compounds,and other Non-Criteria Reportable Pollutant Year For Which The Actual Data Applies: 2006 Signature of a Responsible Ofti al (not 3/2-'007 a vendor or consultant) :,...< Date Barry Schatz Name of a Responsible Official (please print) Principal Environmental Scientist Title STATE OF COLORADO Bill Ritter,Jr.,Governor of coo James B.Martin,Executive Director � Dedicated to protecting and improving the health and environment of the people of Colorado •tr o 4300 Cherry Creek Dr.S. Laboratory Services Division *i *� Denver,Colorado 80246-1530 8100 Lowry Blvd. \ fl876�` Phone(303)692-2000 Denver,Colorado 80230-6928 TDD Line(303)691-7700 (303)692-3090 Colorado Department Located in Glendale,Colorado of Public Health http://www.cdphe.state.co.us and Environment March 27, 2007 Mr. Barry Schatz Principal Environmental Scientist Colorado Interstate Gas Co 2060 Briargate Parkway, Suite 200 Colorado Springs, CO 80920 RE: Cheyenne Plains Compressor Station,FID# 1230051, OP# 05OPWE281 SUBJECT: Response to Comments on Draft Renewal Operating Permit The comments you provided on the draft Operating Permit(05OPWE281) and Technical Review Document for the Cheyenne Plains Compressor Station were received on January 11, 2007. Based on the Division's review your comments were addressed as follows: Comment: Page 3, Table 6.1,Emission Unit Number, Box 3, "CP CG 7501 7301". Response: The change will be made as requested. Comment: Page 4, Table 1, Title, "CP 1 CG-7101, CP 2 CG-7201 &CP 5 CG-7301, Combustion Turbines S/Ns: 0251B, 0250B & 0286B." In addition please change the references to CP-1, CP-2, & CP-5 to CG-7101, CG-7201, &CG-7301 respectively, throughout the permit. On this same table the NOx permit limits are flipped. CG-7101 & CG-7201 should be 24.5 ppm and CG-7301 should be 15 ppm. Response: The changes will be made as requested. Comment: Page 17, Table 3, NOx,Permit Condition Number 3.4,Limitation Box 4, "7.0 tpy 7.4 tpy". The NOx emission limit listed for the flare in construction permit 03WE0916 is 7.4 tpy. Response: The change will be made as requested. Comment:. Page 21, 3.7 Please add a note that the supplemental fuel requirement is met with the amine flash gas. The additional heat input needed was calculated from GRI GlyCalc for Mr. Barry Schatz, Colorado I state Gas Co March 27, 2007 Response to Comments on Draft Permit Page 2 the dehydration section of the plant only. GLYCaic does not take into consideration the other streams that are routed to the same flare. Both systems run at the same time and there would not be any operational instances where the dehydrator would run by itself; thus flash gas will always be available to supplement the heat input to the flare. Response: The Division reviewed the GLYCaic and AMINECaic reports that were used to set the permit limits for the flare. Based on our analysis,the heat content of the streams being combusted in the flare exceed 300 Btu/scf without any supplemental fuel. Therefore,the Division will remove the supplemental fuel requirement in the permit. However,we will include a requirement in the permit that requires that the dehydrator and amine must both operate at the same time. The next step for this draft permit will be to put it out for a 30-day Public Comment period. After that, the proposed permit will go to EPA Region VIII for a 45-day review period. The regulations also require that the applicant receive written notice of their right to a formal hearing before the Air Quality Control Commission at the same time that the Public Comment packet goes out. You will receive a separate letter containing that information. We appreciate that you took the time to thoroughly review this draft. Please feel free to call me at(303) 692-3267 if you have any further questions. Sincerely, Jacqueline Joyce Operating Permit Unit Stationary Sources Program Air Pollution Control Division Jackie Joyce- Re: the enne Plains Comoressor Station-Monitorin of H2S Emissi^^c from the Sulfa Treat S stem an ' e 1 From: Jackie Joyce To: Schatz, Barry A Date: 3/27/07 3:37PM Subject: Re: Cheyenne Plains Compressor Station-Monitoring of H2S Emissions from the Sulfa Treat System and Tit FYI -I have changed the Btu language in the draft permit for Cheyenne Plains(based on the language David agreed to, note this is not the same as the language you requested), you need to submit a modification request to revise the language for Cheyenne Station. As discussed previously, this can be done as a minor modification but you need to follow the procedures in Reg 3, part C, Section X. My understanding was that CIG would be submitting an application that covered all of theirfacilites. >>>"Schatz, Barry A"<Barry.Schatz@ElPaso.com> 03/27/07 3:18 PM >>> Jackie, H2S emissions from the SulfaTreat system are being continuously monitored. The system uses a colorimetric test with an electronic output to determine H2S concentration. Emissions from the SulfaTreat system are routed to a detector that contains lead acetate tape. At negligible H2S concentrations the tape is clear. As H2S concentrations rise they stain the tape a dark color.A photo sensor reads through the tape and based on the clarity of the tape determines the concentration of H2S being emitted. The photo sensor reading is then converted into an electronic PPM concentration that can be viewed from a computer screen in the plant control room. The calibration sensor is checked once a month. Also, please change the language requiring the BTU determination in both the Cheyenne Plains Compressor Station Title V permit(#05OPWE281) sections 1.6 and 2.6 and The Cheyenne Station Title V permit (#95OPWE090) sections 1.3, 2.3, 3.3, 4.3, 5.5, 6.6 and 7.5 to read as follows: "The BTU content of the natural gas used to fuel these engines shall be verified semi-annually using the appropriate ASTM Methods or equivalent, if approved in advance by the Division. In lieu of collecting a sample, the BTU content of the natural gas may be determined using the in-line gas chromatograph to determine the gas composition and the appropriate ASTM Methods or equivalent, if approved in advance by the Division, to calculate the BTU content. The BTU content shall be calculated for April and October, using the average composition of the gas in those months. The BTU content of the natural gas shall be based on the lower heating value of the fuel. If sampling is conducted, calculations of monthly emissions shall be made using the heat content derived from the most recent required analysis. If the gas chromatograph data is used, calculations of monthly emissions for April through September shall be made using the April average BTU content and calculations of monthly emissions for October through March shall be made using the October average BTU content." Jackie Joyce-Re: Cheyenne Plains Cc---essor Station-Monitoring of H2S Emissi rom the Sulfa Treat System and'le 2 The BTU sampling months have been timed to be the first month of the semi-annual period. If you have any question or need additional information, please call me. Regards, Barry Schatz Principal Environmental Scientist Pipelines West-Environmental Colorado Interstate Gas Company 2060 Briargate Parkway Colorado Springs, Colorado 80920 (719)388-5717 office (719) 351-4198 cell (719)388-5721 fax Barrv.Schatz a(�ElPaso.com<mailto:Barrv.Schatz(a ElPpaso.com> This email and any files transmitted with it from the El Paso Corporation are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the sender. ****************************************************************** Jackie Joyce REKzCheyenne Plains Sprimi Numbers,, Pale 1 From: "Schatz, Barry A" <Barry.Schatz@ElPaso.com> To: "Jackie Joyce" <jejoyce@cdphe.state.co.us> Date: Tue, Feb 13, 2007 10:01 AM Subject: RE: Cheyenne Plains Serial Numbers Jackie, the serial numbers you requested are as follows: Emergency Generator(CAT 3516B LE): #CTW00511 Hot Oil Heater H-8701 (Permit#03WE0913, Airs ID#018):#04-074-151 Hot Oil Heater H-8702 (Permit#03WE0913, Airs ID#019):#04-074-152 Utility Heater H-6111 (Permit#03WE0913, Airs ID#020):#H104-159, New Burner Serial#2090828. Note, this unit was reduced in size from 16 MMBtu/hr to 4.5 MM Btu/hr and is now APEN exempt. Do you need a letter for your files with this information, or will this email suffice? Regards, Barry Schatz Principal Environmental Scientist Pipelines West- Environmental Colorado Interstate Gas Company 2060 Briargate Parkway Colorado Springs, Colorado 80920 (719) 388-5717 office (719) 351-4198 cell (719) 388-5721 fax Barry.Schatz@ElPaso.com Original Message--- From: Jackie Joyce[mailto:jejoyce@cdphe.state.co.us] Sent: Friday, January 19, 2007 10:03 AM To: Schatz, Barry A Subject: Cheyenne Plains Barry, Could you also give me the serial no of the emergency generator(the cat 3516B LE)? This email and any files transmitted with it from the ElPaso Corporation are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the sender. ****************************************************************** L Jackie Joyce RE Cheyenne Plains • Page 1 From: "Brindley, Vincent L" <Vince.Brindley@ElPaso.com> To: "Jackie Joyce" <Jackie.Joyce@state.co.us> Date: Thu, Feb 1, 2007 2:40 PM Subject: RE: Cheyenne Plains Jackie, Here is the input parameters for the Cheyenne Plains GRI GLYCalc. Le me know if you have any questions. Vince —Original Message From: Schatz, Barry A Sent: Thursday, February 01, 2007 2:03 PM To: Brindley, Vincent L Subject: FW: Cheyenne Plains Vince can you answer Jackie's question. Original Message----- From: Jackie Joyce[mailto:jejoyce@cdphe.state.co.us] Sent: Friday, January 19, 2007 10:44 AM To: Schatz, Barry A Subject: Cheyenne Plains Back in October when I was preparing the T5 permit, I had asked for the input paramter report from the GLYCalc run that was used in the construction permit. There is a parameter that I cannot verify from the aggregate report that was provided. Would you please fax this to me? Jackie Joyce Permit Engineer, Operating Permit Unit Colorado Air Pollution Control Division • 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, CO 80246 Phone: (303)692-3267 Fax: (303) 782-0278 Jackie.Joyce@state.co.us This email and any files transmitted with it from the ElPaso Corporation are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the sender. ****************************************************************** CC: "Schatz, Barry A" <Barry.Schatz@ElPaso.com> CHEYPL-1.TXT GRI-GLYCaic VERSION 4.0 - SUMMARY OF INPUT VALUES Case Name: Cheyenne Plains TEG File Name: C:\Program Files\GRI-GLYCalc4\CheyPlains from Amine Plant #2.ddf Date: February 01, 2007 DESCRIPTION: Description: After Amine stripper - 300MMSCFd Plant Annual Hours of Operation: 8760.0 hours/yr WET GAS: Temperature: 68.00 deg. F Pressure: 882.00 psig Wet Gas Water Content: Saturated Component Conc. (vol %) Nitrogen 1.2690 Methane 93.8340 Ethane 3.2170 Propane 0.9780 Isobutane 0.1920 n-Butane 0.2060 • Isopentane 0.0700 n-Pentane 0.0510 n-Hexane 0.0150 Other Hexanes 0.0410 Heptanes 0.0090 Benzene 0.0030 Toluene 0.0030 C8+ Heavies 0.0040 DRY GAS: Flow Rate: 292.0 MMSCF/day Water Content: 5.0 lbs. H20/MMSCF LEAN GLYCOL: Glycol Type: TEG Water Content: 0.9 wt% H2o Flow Rate: 32.0 gpm PUMP: Page 1 CHEYPL-1.TXT Glycol Pump Type: Electric/Pneumatic FLASH TANK: Flash Control : Combustion device Flash Control Efficiency: 98.00 % Temperature: 150.0 deg. F Pressure: 60.0 psig STRIPPING GAS: Source of Gas: Dry Gas Gas Flow Rate: 2.500 scfm REGENERATOR OVERHEADS CONTROL DEVICE: Control Device: Combustion Device Destruction Efficiency: 98.0 % Excess oxygen: 5.0 % Ambient Air Temperature: 50.0 deg. F Page 2 [ Jackie Joyce Cexir ne Plains Pa e10 From: Jackie Joyce To: barry.schatz@elpaso.com Date: Fri, Jan 19, 2007 10:43 AM Subject: Cheyenne Plains Back in October when I was preparing the T5 permit, I had asked for the input paramter report from the GLYCaIc run that was used in the construction permit. There is a parameter that I cannot verify from the aggregate report that was provided. Would you please fax this to me? Jackie Joyce Permit Engineer, Operating Permit Unit Colorado Air Pollution Control Division 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, CO 80246 Phone: (303)692-3267 Fax: (303)782-0278 Jackie.Joyce@state.co.us Jackie Joyce Che enne Plains Y...: Page 1 From: Jackie Joyce To: barry.schatz@elpaso.com Date: Fri, Jan 19, 2007 8:53 AM Subject: Cheyenne Plains Barry, I am looking at the comments on Cheyenne Plains and I realized that you never responded to any of the questions in the cover letter, so here they are again. Please resolve for me. 1. I want to reduce the annual CO emissions for the third turbine-annual emissions reflect 48.8 ppm CO BACT limit for the first 2 turbines but the third turbine is permitted at 25 ppm, annual CO emissions should be permitted at 20.9 tpy (you indicate this as PTE in your application). I need an APEN submitted for this change. 2. What are the serial numbers for the hot oil heaters? If there are none, then let me know. 3. I am requiring continuou monitoring of the HS2 concentration on the sulfatreat, are you guys doing that? We would accept less frequent monitoring if you submit adequate justification. Jackie Joyce Permit Engineer, Operating Permit Unit Colorado Air Pollution Control Division 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, CO 80246 Phone: (303) 692-3267 Fax: (303) 782-0278 Jackie.Joyce@state.co.us Cheyenne Plains C(S1 r Gas Pipeline Company,LLC �/ �l 2060 Briargate Parkway,Suite 200 ��'8 ` Colorado Springs,Colorado 80920 SK_q,0 ?�J 1 719.388.5730 SoGc''a� January 11, 2007 CERTIFIED—Return Receipt Requested Ms. Jacqueline Joyce Operating Permits Unit Colorado Department of Public Health & Environment Air Pollution Control Division 4300 Cherry Creek Drive South, APCD-SSP-B1 Denver, CO 80246-1530 Comments on Draft Operating Permit for Cheyenne Plains Compressor Station, #95OPWE281 Dear Ms. Joyce: Colorado Interstate Gas Company (CIG) is providing the following comments for the Title V Operating permit draft dated November 21, 2006. Air Pollution Control Division Colorado Operating Permit 95OPWE281 CIG is requesting that the following changes be made to the operating permit: Page 3, Table 6.1, Emission Unit Number, Box 3, "CP CG 7501 7301". Page 4, Table 1, Title, "CP-1 CG-7101, CP 2 CG-7201 & CP.5 CG-7301, Combustion Turbines S/Ns: 0251B, 0250B & 0286B." In addition please change the references to CP- 1, CP-2, & CP-5 to CG-7101, CG-7201, & CG-7301 respectively, throughout the permit. On this same table the NOx permit limits are flipped. CG-7101 & CG-7201 should be 24.5 ppm and CG-7301 should be 15 ppm. Page 17, Table 3, NOx, Permit Condition Number 3.4, Limitation Box 4, "7--.-0-tpy 7.4 tpy". The NOx emission limit listed for the flare in construction permit 03WE0916 is 7.4 tpy. Page 21, 3.7 Please add a note that the supplemental fuel requirement is met with the amine flash gas. The additional heat input needed was calculated from GRI GlyCalc for the dehydration section of the plant only. GLYCaIc does not take into consideration the other streams that are routed to the same flare. Both systems run at the same time and there would not be any operational instances where the dehydrator would run by itself, thus flash gas will always be available to supplement the heat input to the flare. If you have any questions about these comments, please contact me at 719-388-5717. s J Sincerely, lwv1 Barry Schatz Principal Environmental Scientist Pipelines West Environmental Cc: Route: S.D. Miller/V. L. Brindley/ File: CO - Cheyenne -Title V G.R. Stuart/ R.A. Harder/ File: Cheyenne Station — File 13.3- Operating Permits B.A. Schatz - ENVS Hello