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Colorado Department
of Public
and Environment
OPERATING PERMIT
Kerr-McGee Rocky Mountain Corporation
Ft. Lupton Compressor Station
Issued: October 1, 1998
Last Revised: July 3, 2002
2002-3310
AIR POLLUTION CONTROL DIVISION
COLORADO OPERATING PERMIT
FACILITY NAME: Ft. Lupton OPERATING PERMIT NUMBER
Compressor Station
FACILITY ID: 1230057 95OPWE013
ISSUE DATE: October 1, 1998
EXPIRATION DATE: October 1, 2003
MODIFICATIONS: See Appendix F of Permit i
Issued in accordance with the provisions of Colorado Air Quality Control Act, 25-7-101 et
sec. and applicable rules and regulations.
ISSUED TO: PLANT SITE LOCATION:
Kerr-McGee Rocky Mountain Corporation 16116 Weld County Road 22
1999 Broadway, Suite 3600 Ft.Lupton, CO 80621
Denver, CO 80202 Weld County
INFORMATION RELIED UPON
Operating Permit Application Received: January 1, 1995
And Additional Information Received: January 1,February 27,March 31, June 19, and
August 16, 1995; March 3, 1998; February 2, 2000; October 29, 2001
Nature of Business Natural Gas Compression
Primary SIC: 4922
RESPONSIBLE OFFICIAL FACILITY CONTACT PERSON
Name Dale Cantwell Name: Patrick Flynn
Title: Vice President-DJ District Title: Director,Environmental, Health
and Safety
Phone: (303)296-3600 Phone: (303)296-3600 X418
SUBMITTAL DEADLINES
Semi-Annual Monitoring Period: April- September, October-March
Semi-Annual Monitoring Report: May 1, 2001 &November 1, 2000 and subsequent years
Annual Compliance Period: Begins April 1 to March 31
Annual Compliance Certification: May 1, 2001 and subsequent years
TABLE OF CONTENTS:
SECTION I-General Activities and Summary 7 '
1. Permitted Activities 7
2. Alternative Operating Scenarios 8
3. Prevention of Significant Deterioration(PSD) 9 '
4. Accidental Release Prevention Program (112(r) 9
5. Summary of Emission Units 10
SECTION II- Specific Permit Terms 11
2. EU33,EU36 and EU37 -Fairbanks Morse MEP-12 ICEs (2166 HP each) 15
3. EU35 -Fairbanks Morse 45S1S Internal Combustion Engine (1859 HP) 19
4. EU04- Smith Triethylene Glycol Dehydration Unit 23
5. I001 -Elastec Inc., Smart Ash Energy Recovery Unit 25
6. F001 -Fugitive VOC Emissions From Equipment Leaks 27
SECTION III-Permit Shield 28
1. Specific Conditions 28
2. General Conditions 28
3. Streamlined Conditions 29
SECTION IV- General Permit Conditions
30
1. Administrative Changes 30
2. Certification Requirements 30
3. Compliance Requirements 30
4. Emergency Provisions 31
5. Emission Standards for Asbestos 32
6. Emissions Trading,Marketable Permits, Economic Incentives 32
7. Fee Payment 32
8. Fugitive Particulate Emissions 32
9. Inspection and Entry 33
10. Minor Permit Modifications 33
11. New Source Review 33
12. No Property Rights Conveyed 33
13. Odor 33
14. Off-Permit Changes to the Source 33
15. Opacity 34
16. Open Burning 34
17. Ozone Depleting Compounds 34
18. Permit Expiration and Renewal 34
19. Portable Sources 34
20. Prompt Deviation Reporting 34
21. Record Keeping and Reporting Requirements 35
22. Reopenings for Cause 35
23. Section 502(b)(10)Changes 36
24. Severability Clause 36
25. Significant Permit Modifications 36
TABLE OF CONTENTS:
26. Special Provisions Concerning the Acid Rain Program 36 ,
27. Transfer or Assignment of Ownership 37
28. Volatile Organic Compounds 37
29. Wood Stoves and Wood burning Appliances 37 ,
APPENDIX A-Inspection Information 39
Directions to Plant. 39
Safety Equipment Required: 39
Facility Plot Plan: 39
List of Insignificant Activities- 39
APPENDIX B 40
Reporting Requirements and Definitions 40
Monitoring and Permit Deviation Report -Part I 45
Monitoring and Permit Deviation Report -Part II 47
Monitoring and Permit Deviation Report -Part III 49
APPENDIX C Required Format for Annual Compliance Certification Report 50 j
APPENDIX D Notification Addresses 54
APPENDIX E Permit Acronyms 55
APPENDIX F Permit Modifications 57
APPENDIX G Fuel Allocation Calculation 58
Air Pollution Control Division Kerr-McGee Rocky Mountain Corporation
Colorado Operating Permit Ft. Lupton Compressor Station
Permit# 95OPWE013 Page 7
SECTION I- General Activities and Summary
1. Permitted Activities
1.1 This facility consists of 7 natural gas fired reciprocating compressor engines used to
compress and transmit gas from the gas field to sales pipelines, one triethylene glycol dehydrator
to remove water from the natural gas and an incinerator to dispose of nonhazardous combustibles
contaminated with oil. In addition, fugitive VOC emissions for equipment leaks are above
permit de minimis levels and therefore are included in the Operating Permit.
The facility is located near Fort Lupton in Weld County, Colorado. The area in which the plant
operates is designated as attainment for all criteria pollutants.
There are no affected states within 50 miles of the plant. The following Federal Class I
designated areas are within 100 kilometers of the plant:Rocky Mountain National Park.
1.2 Until such time as this permit expires or is modified or revoked, the permittee is allowed
to discharge air pollutants from this facility in accordance with the requirements, limitations, and
conditions of this permit.
1.3 This Operating Permit incorporates the applicable requirements contained in the
underlying construction permits, and does not affect those applicable requirements, except as
modified during review of the application or as modified subsequent to permit issuance using the
modification procedures found in Regulation No. 3, Part C. These Part C procedures meet all
applicable substantive New Source Review requirements for purposes of this Operating Permit
and shall survive reissuance. This Operating Permit incorporates the applicable requirements
(except as noted in Section II) from the following Colorado Construction Permit(s):
11 WE730-1 thru 3 Formerly issued to KN 96WE641 Formerly issued to KN
Wattenberg Transmission LLC Wattenberg Transmission LLC
11WE132 " 97WE0406 "
94WE760-4 66 97WE0180 HS Resources,Inc.
1.4 All information gathered pursuant to the requirements of this permit is subject to the
Record keeping and Reporting requirements listed under Condition 21 of the General Conditions
in Section IV of this permit. All conditions in this permit are enforceable by US Environmental
Protection Agency, Colorado Air Pollution Control Division (hereinafter Division) and its
agents, and citizens unless otherwise specified. State-only enforceable conditions are:
Permit Condition Number(s): Section IV-Conditions 13 and 17(as noted)
1.5 There are no other Operating Permits associated with this facility for purposes of
determining applicability of Prevention of Significant Deterioration regulations.
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
h Air Pollution Control Division Kerr-McGee Rocky Mountain Corporation
Colorado Operating Permit Ft. Lupton Compressor Station
Permit# 95OPWE013 Page 8 '
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 In the event of a compressor engine breakdown or periodic maintenance
which requires the use of a temporary replacement engine (defined as in
service for 3 months or less)the temporary replacement engine must meet
either of the following conditions:
2.1.1.1. A replacement engine that has a valid construction permit,
has demonstrated compliance with the construction permit
conditions, and has emission limits which are equal to or
lower than the NON, CO and VOC limits set forth in the
Operating Permit may be used as a temporary replacement
engine. A log shall be maintained to record the dates any
replacement engines were in use as well as the associated
construction permit number.
2.1.1.2. An onsite grandfathered engine or an engine brought in
from out-of-state or a newly-purchased engine that does not
have a Colorado Construction permit may be used as a
temporary replacement engine. In either case, emission
measurements of NON, CO and VOC from the engine shall
be conducted using a portable flue gas analyzer within 48
hours. Calibration of the analyzer shall be conducted
according to manufacturer's instructions. Results of the
tests shall be compared to the emission limits or the
emission factor for the original engine to determine
enforceable compliance or noncompliance. For
comparison with an annual emissions limit, the results of
the tests shall be converted to a lb/hr basis and multiplied
by the allowable operating hours in a year in order to
demonstrate 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 a year (8760). If the engine
that is replaced is grandfathered or permit exempt and the !
test results show an exceedance of the emission factor, then
the source must use the emission factor determined by the
test results to calculate emissions for the purposes of
payment of fees for the period the replacement engine is
operated. An exceedance of the emission limitations for
any pollutant during the initial portable analyzer analysis
shall require a portable analyzer analysis indicating
compliance with the annual limits within 10 days of the
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
' 4 Air Pollution Control Division Kerr-McGee Rocky Mountain Corporation
Colorado Operating Permit Ft. Lupton Compressor Station
Permit# 95OPWE013 Page 9
initial analysis. Calibration of the analyzer, following an
analysis that indicates an exceedance, shall be conducted
using calibration gases. If portable analyzer results fail to
indicate compliance with the emission limitations within
the 10 day period, the source will be considered out of
compliance from the time that the replacement engine came
on line until the engine is taken off line. If portable
analyzer results indicate compliance with the emission
limitations within the 10 day period, the source will be
considered to be in compliance from the time that the
replacement engine came on line until the engine is taken
off line.
Results of all portable analyzer analyses conducted shall be
kept on site and made available to the Division upon
request.
2.2 The facility must contemporaneously with making a change from one operating
scenario to another, maintain records at the facility of the scenario under which it
is operating. These records must be made available to the Division upon request
(Colorado Regulation No. 3,Part A, Section IV.A.1).
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/year).
Future modifications at this facility resulting in a significant net emissions
increase (see Regulation No. 3, Part A, Section I.B.37 and 58) for any pollutant as
listed in Regulation No. 3, Part A, Section I.B.58 or a modification which is major
by itself will result in the application of the PSD review requirements.
4. Accidental Release Prevention Program (112(r)
4.1 This facility is not subject to the provisions of the Accidental Release Prevention
Program (section 112(r)of the Federal Clean Air Act).
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
Air Pollution Control Division Kerr-McGee Rocky Mountain Corporation
Colorado Operating Permit Ft. Lupton Compressor Station
Permit# 95OPWEOI3 Page 10
5. Summary of Emission Units
5.1 The emissions units regulated by this permit are the following:
Emission AIRS Facility Description Pollution Control
Unit Stack Identifier Device
Number Number
EU31 S002 EU31 Waukesha, Model L-7042, 4-Cycle Rich Burn, Internal Non-Selective
Combustion Engine, Rated at 954 HP (Maximum), Serial No. Catalytic Convertor
250451.Natural Gas Fired.
EU32 S003 EU32 Waukesha, Model L-7042, 4-Cycle Rich Burn, Internal Non-Selective
Combustion Engine, Rated at 954 HP (Maximum), Serial No. Catalytic Convertor
288792 Natural Gas Fired.
EU34 S001 EU34 Waukesha, Model L-7042, 4-Cycle Rich Burn, Internal Non-Selective
Combustion Engine,Rated at 954 HP (Maximum), Serial No. Catalytic Convertor
288358. Natural Gas Fired.
EU33 S006 EU33 Fairbanks Morse, Model No. 384S8MEP-12, 2-Cycle Lean Uncontrolled
Burn, Internal Combustion Engine, Site Rated at 2166 HP,
Serial No.38D8780-30S1S12. Natural Gas Fired.
EU35 S007 EU35 Fairbanks Morse, Model No. 38D8750-45S1S, 2-Cycle Lean Uncontrolled
Burn, Internal Combustion Engine, Site Rated at 1859 HP,
Serial No.38DS8 MEP-10. Natural Gas Fired.
EU36 S004 EU36 Fairbanks Morse, Model No. 38DS8MEP-12, 2-Cycle Lean Uncontrolled
Burn,Internal Combustion Engine,Site Rated at 2166 HP,
Serial No.38D8780-24S1S12. Natural Gas Fired.
EU37 S005 EU037 Fairbanks Morse, Model No. 38D8780-28S1S, 2-Cycle Lean Uncontrolled
Burn,Internal Combustion Engine,Site Rated at 2166 HP,
Serial No.38D8780-28S1S12. Natural Gas Fired.
EU04 SO10 EU04 Smith,Model No.Unavailable,Triethylene Glycol Dehydration Uncontrolled
Unit,Rated at 30 MMscf/day,
Serial No.79-148.
I001 S014 I001 Elastec Inc.,Smart Ash Energy Recovery Unit,Model 100, Uncontrolled
Serial No.Unavailable.
F001 SO11 F001 Fugitive VOC Emissions from Equipment Leaks Uncontrolled
Operating Permit Number: 95OPWEOI3 ISSUE: October 10, 1998
Last Revised: July 3, 2002
Air Pollution Control Division Kerr-McGee Rocky Mountain Corporation
Colorado Operating Permit Ft. Lupton Compressor Station
Permit# 95OPWE013 Page 11
SECTION II- Specific Permit Terms
1. EU031,EU032,EU034-Three(3) Waukesha,L-7401 ICEs (954 HP each)
Limits are per engine
Parameter Permit Limitations Compliance Monitoring
Condition Emission Factor
Number Method Interval
NOx 1.1 23.0 tons/yr 0.69 lb/MMBtu Record keeping, Monthly
Calculation
CO 50.6 tons/yr 1.52 lb/MMBtu
VOC 9.2 tons/yr 0.275 lb/MMBtu
Fuel Use 1.2 73.54 MMscf/yr Fuel Meter and Monthly
Record keeping
Hours of 1.3 Record keeping Monthly
Operation
Opacity 1.4 Less Than or Fuel Restriction Annually
Equal to 20%
Portable 1.5 NOx<23.0 tons/yr Portable Flue Gas Quarterly
Monitoring CO<-50.6 tons/yr Analyzer
Performance 1.6 NOx<23.0 tons/yr EPA Reference One Time
Test CO<-50.6 tons/yr Method
Catalyst 1.7 Manufacturer's Record keeping Monthly
Parameters Specifications
Btu Content of 1.8 Record keeping and Semi-
Natural Gas Calculations Annually
1.1 Nitrogen Oxide, Carbon Monoxide and Volatile Organic Compounds emissions shall not
exceed the limitations stated above for each engine (Construction Permit#97WE0180).
1.1.1 Monthly emissions of each pollutant shall be calculated for each engine using the
listed compliance emission factors (EF),monthly fuel consumption , and the latest
BTU calculation from Condition 1.8 in the following equation:
lb/month=(EF)X(Monthly Fuel Use in MMscf)X(Heat Content of Fuel in MMBtu/MMscf)
1.1.2 A twelve month rolling total shall be maintained for each engine for
demonstration of compliance with the annual limitations. Each month a new
twelve month total shall be calculated using the previous twelve months data.
Emissions shall be calculated by the end of each subsequent month.
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
Air Pollution Control Division Kerr-McGee Rocky Mountain Corporation
Colorado Operating Permit Ft. Lupton Compressor Station
Permit# 95OPWE013 Page 12
1.2 Fuel consumption for each engine shall not exceed the limitations stated above
(Construction Permit#97WE0180)
1.2.1 Fuel use for this engine shall be measured and recorded each month. Within the
first seven days of every month, the fuel meter shall be read and recorded.
Allocation of fuel use shall be made using the methods detailed in Appendix G of
this permit. The fuel use shall be measured no more than one (1) hour from the
time that run time hours have been recorded. A twelve month rolling total shall
be maintained for demonstration of compliance with the annual limitations. Each
month a new twelve month total shall be calculated using the previous twelve
months data.
1.3 Hours of operation for each engine shall be monitored and recorded monthly for use in
fuel allocation.
1.4 Opacity from each engine shall not exceed 20% as stated in Regulation No. 1,
Section II, A. Natural gas shall be burned to monitor compliance with the opacity standard.
1.5 Emission measurements of nitrogen oxides (NOX) and carbon monoxide (CO) from each
engine shall be conducted quarterly using a portable flue gas analyzer. Calibration of the
analyzer shall be conducted according to manufacturer's instructions. Results of the portable
flue gas analyzer tests shall be used to monitor the compliance status of each engine. For
comparison with an annual or short term emissions 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.
An exceedance of either the NOX or CO emission limitation during the initial portable flue gas
analyzer test shall require a subsequent portable analyzer test indicating compliance with both
the NO), and CO emission limitations within 14 calendar days of the initial test. Calibration
gases shall be used to calibrate the portable analyzer for all tests conducted subsequent to the
initial test.
If portable flue gas analyzer results indicate compliance with both the NO), and CO emission
limitations within the 14 day period, the source may certify that the engine is in compliance with
both the NO),and CO emission limitations for the relevant time period.
If portable flue gas analyzer results fail to indicate the compliance of the engine with either the
NO„ or CO emission limitations within the 14 day period, the source will notify the Division in
writing within 10 calendar days of the end of the 14 day period. Results of all testing that
indicates noncompliance shall be submitted to the Division within 10 calendar days of the end of
the 14 day period. The source will be required to conduct EPA Reference Test Methods
(identified as Reference Method 7E and Reference Method 10, or Reference Method 19 (40 CFR
Part 60 Appendix A), hereinafter "EPA Reference Test Methods") or other test methods or
procedures acceptable to the Division within 45 calendar days of the end of the 14 day period
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
Air Pollution Control Division Kerr-McGee Rocky Mountain Corporation
Colorado Operating Permit Ft. Lupton Compressor Station
Permit# 95OPWE013 Page 13
allowed for the portable flue gas analyzer testing. The Division shall be notified at least 30
calendar days prior to the EPA Reference Test date, so that it may choose whether to observe the
testing.
If the EPA Reference Test results indicate compliance with both the NO„ and CO emission
limitations, the source may certify that the engine is in compliance with both the NO„ and CO
emission limitations for the relevant time period.
If the EPA Reference Tests fail to demonstrate compliance with either the NO„ or CO emission
limitations and in the absence of evidence to the contrary, the engine will be considered to be out
of compliance from the date of the initial portable flue gas analyzer test until the engine is taken
off line. Results of all testing that indicates noncompliance shall be submitted to the Division
within 14 calendar days after receipt of the test results.
Results of all tests conducted shall be kept on site and made available to the Division upon
request.
1.6 For an initial demonstration of compliance with the permit limits, compliance tests for the
engines shall be conducted to measure the emission rate(s) for nitrogen oxides, carbon monoxide '
and oxygen using EPA approved methods or other methods approved by the Division. Any stack
tests conducted to show compliance with a monthly or annual emission limit shall have the
results projected to the monthly or annual averaging time by multiplying the test results by the
allowable number of operating hours for that averaging time.
The compliance testing shall be completed and copies of the results provided to the Division
within 180 calendar days of the issuance of this operating permit. A copy of the engine test
results shall be provided to the Division within 60 calendar days of the completion of the tests.
The test protocol must be in accordance with the requirements of the Air Pollution Control
Division Compliance Test Manual and shall be submitted to the Division for review and
approval at least thirty (30) days prior to testing. No test shall be conducted without prior
approval from the Division.
1.7 The pressure and exhaust gas temperature differences across the catalyst and engine air to
fuel ratio will be monitored and recorded monthly to assess engine and non-selective catalytic
reduction system operating condition. During those months when portable monitoring is
scheduled these parameters are to be monitored and recorded during the portable monitoring
event. .
1.8 Samples of fuel gas shall be collected and analyzed to determine C1 through C6+
composition. The lower heating value of the fuel shall be calculated semi-annually using the
results of the analysis and published heats of combustion (on the basis that combustion occurs
with products and reactants in the vapor state) in terms of Btu/scf at 60 •F and 14.696 psia in the
following equation:
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
Air Pollution Control Division Kerr-McGee Rocky Mountain Corporation
Colorado Operating Permit Ft. Lupton Compressor Station
Permit# 95OPWE013 Page 14
E(C,mol%)(Hc,Btu/scf)
LHVBtu/scf= ' j
100
where:
Ci =Concentration of Component i mol%
Hc, = Heat of Combustion (vapor state of reactants) in Btu/scf @ 60 °F & 14.696 psia
Calculation of monthly emissions required under Condition 1.1.1 shall be made using the
calculated lower heating value based on the most recent required analysis in Condition 4.2.
1.9 These engines and non-selective catalytic reduction systems shall be operated and
maintained in accordance with internal operating and maintenance standards, which shall
consider manufacturer's recommendations and industry standard practices, at all times, including
periods of start-up, shutdown, and malfunction. Such internal operating and maintenance
standards shall be kept on site and made available to the Division upon request.
I
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
Air Pollution Control Division Kerr-McGee Rocky Mountain Corporation
Colorado Operating Permit Ft. Lupton Compressor Station
Permit# 95OPWE013 Page 15
2. EU33,EU36 and EU37-Fairbanks Morse MEP-12 ICEs (2166 HP each)
Limits are per engine
Parameter Permit Limitations Compliance Monitoring
Condition Emission
Number Short Term Long Term Factor Method Interval
PM 2.1 4.22 tons/yr 0.056 Record keeping Monthly
lb/MMBtu and Calculation
PM10 4.22 tons/yr 0.056
lb/MMBtu
NOx 55.0 lbs/hr 104.5 tons/yr 1.36
lb/MMBtu
CO 50.2 tons/yr 0.65
lb/MMBtu '
VOC 20.9 tons/yr 0.27
lb/MMBtu
Fuel Use 2.2 179.0 MMscf/yr Fuel Meter Monthly
Hours of 2.3 Record keeping Monthly
Operation
Opacity 2.4 Less Than or Equal to 20% Fuel Restriction Annually
Portable 2.5 NOx<55.0 lbs/hr Portable Flue Quarterly
Monitoring CO<50.2 tons/yr Gas Analyzer
Performance 2.6 NOx<55.0 lbs/hr EPA Reference One Time
Test CO<50.2 tons/yr Method
Btu Content of 2.7 Record keeping Semi-
Natural Gas and Annually
Calculations
2.1 Particulate Matter, Particulate Matter less than 10 microns, Nitrogen Oxide, Carbon
Monoxide and Volatile Organic Compounds emissions shall not exceed the limitations stated
above for each engine (Construction Permits#11 WE730 (1-3)).
2.1.1 Monthly emissions of each pollutant shall be calculated for each engine using the
listed compliance emission factors (EF), monthly fuel consumption , and the latest
BTU gas analysis from Condition 2.7 in the following equation:
lb/month=(EF)X(Monthly Fuel Use in MMsct)X(Heat Content of Fuel in MMBtu/MMscf)
2.1.2 A twelve month rolling total shall be maintained for each engine for
demonstration of compliance with the annual limitations. Each month a new
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
t Air Pollution Control Division Kerr-McGee Rocky Mountain Corporation
Colorado Operating Permit Ft. Lupton Compressor Station
Permit# 95OPWE013 Page 16
twelve month total shall be calculated using the previous twelve months data.
Emissions shall be calculated by the end of each subsequent month.
2.1.3 Compliance with the hourly emission limit for each engine shall be demonstrated
by dividing the monthly calculated emissions by the number of run-time hours in
the previous month to obtain an hourly average.
2.2 Fuel consumption for each engine shall not exceed the limitations stated above
(Construction Permits#11 WE730(1-3))
2.2.1 Fuel use for this engine shall be measured and recorded each month. Within the
first seven days of every month, the fuel meter shall be read and recorded.
Allocation of fuel use shall be made using the methods detailed in Appendix G of
this permit. The fuel use shall be measured no more than one (1) hour from the
time that run time hours have been recorded. A twelve month rolling total shall
be maintained for demonstration of compliance with the annual limitations. Each
month a new twelve month total shall be calculated using the previous twelve
months data.
2.3 Hours of operation for each engine shall be monitored and recorded monthly for use in
determining average hourly emissions and fuel allocation calculations.
2.4 Opacity from each engine shall not exceed 20% as stated in Regulation No. 1,
Section II,A. Natural gas shall be burned to monitor compliance with the opacity standard.
2.5 Emission measurements of nitrogen oxides (NOX) and carbon monoxide (CO) from each
engine shall be conducted quarterly using a portable flue gas analyzer. Calibration of the
analyzer shall be conducted according to manufacturer's instructions. Results of the portable
flue gas analyzer tests shall be used to monitor the compliance status of each engine. For
comparison with an annual or short term emissions 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.
An exceedance of either the NOX or CO emission limitation during the initial portable flue gas
analyzer test shall require a subsequent portable analyzer test indicating compliance with both
the NOX and CO emission limitations within 14 calendar days of the initial test. Calibration
gases shall be used to calibrate the portable analyzer for all tests conducted subsequent to the
initial test.
If portable flue gas analyzer results indicate compliance with both the NOX and CO emission
limitations within the 14 day period, the source may certify that the engine is in compliance with
both the NOX and CO emission limitations for the relevant time period.
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
A Air Pollution Control Division Kerr-McGee Rocky Mountain Corporation
Colorado Operating Permit Ft.Lupton Compressor Station
Permit# 95OPWE013 Page 17
If portable flue gas analyzer results fail to indicate the compliance of the engine with either the
NO„ or CO emission limitations within the 14 day period, the source will notify the Division in
writing within 10 calendar days of the end of the 14 day period. Results of all testing that
indicates noncompliance shall be submitted to the Division within 10 calendar days of the end of
the 14 day period. The source will be required to conduct EPA Reference Test Methods
(identified as Reference Method 7E and Reference Method 10, or Reference Method 19 (40 CFR
Part 60 Appendix A), hereinafter "EPA Reference Test Methods") or other test methods or
procedures acceptable to the Division within 45 calendar days of the end of the 14 day period
allowed for the portable flue gas analyzer testing. The Division shall be notified at least 30
calendar days prior to the EPA Reference Test date, so that it may choose whether to observe the
testing.
If the EPA Reference Test results indicate compliance with both the NO„ and CO emission
limitations, the source may certify that the engine is in compliance with both the NO„ and CO
emission limitations for the relevant time period.
If the EPA Reference Tests fail to demonstrate compliance with either the NO„ or CO emission
limitations and in the absence of evidence to the contrary, the engine will be considered to be out
of compliance from the date of the initial portable flue gas analyzer test until the engine is taken
off line. Results of all testing that indicates noncompliance shall be submitted to the Division
within 14 calendar days after receipt of the test results.
Results of all tests conducted shall be kept on site and made available to the Division upon
request.
2.6 For an initial demonstration of compliance with the permit limits, compliance tests for the
engines shall be conducted to measure the emission rate(s) for nitrogen oxides, carbon monoxide
and oxygen using EPA approved methods or other methods approved by the Division. Any stack
tests conducted to show compliance with a monthly or annual emission limit shall have the
results projected to the monthly or annual averaging time by multiplying the test results by the
allowable number of operating hours for that averaging time.
The compliance testing shall be completed and copies of the results provided to the Division
within 180 calendar days of the issuance of this operating permit. A copy of the engine test
results shall be provided to the Division within 60 calendar days of the completion of the tests.
The test protocol must be in accordance with the requirements of the Air Pollution Control
Division Compliance Test Manual and shall be submitted to the Division for review and
approval at least thirty (30) days prior to testing. No test shall be conducted without prior
approval from the Division.
2.7 Samples of fuel gas shall be collected and analyzed to determine C1 through C6+
composition. The lower heating value of the fuel shall be calculated semi-annually using the
results of the analysis and published heats of combustion (on the basis that combustion occurs
with products and reactants in the vapor state) in terms of Btu/scf at 60 •F and 14.696 psia in the
following equation:
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
i
Air Pollution Control Division Kerr-McGee Rocky Mountain Corporation
Colorado Operating Permit Ft. Lupton Compressor Station I
Permit# 95OPWE013 Page 18
E(C,mol%)(Hc,Btu/scf)
LHVBtu/scf= ' 100
where:
Ci=Concentration of Component i mol% '
Hc, = Heat of Combustion (vapor state of reactants) in Btu/scf @ 60 °F & 14.696 psia
Calculation of monthly emissions required under Condition 2.2.1 shall be made using the
calculated lower heating value based on the most recent required analysis in Condition 4.2.
2.8 These engines shall be operated and maintained in accordance with internal operating and
maintenance standards, which shall consider manufacturer's recommendations and industry
standard practices, at all times, including periods of start-up, shutdown, and malfunction. Such
internal operating and maintenance standards shall be kept on site and made available to the
Division upon request.
I
I
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
i 9 Air Pollution Control Division Kerr-McGee Rocky Mountain Corporation
Colorado Operating Permit Ft. Lupton Compressor Station
Permit# 95OPWE013 Page 19
3. EU35-Fairbanks Morse 45S1S Internal Combustion Engine(1859 HP)
Parameter Permit Limitations Compliance Emission Monitoring
Condition Factor
Number Method Interval
PM 3.1 3.61 tons/yr 0.055 lb/MMBtu Record Monthly
keeping and
PM10 3.61 tons/yr 0.055 lb/MMBtu Calculation
NOx 80.5 tons/yr 1.23 lb/MMBtu
CO 46.5 tons/yr 0.71 lb/MMBtu
VOC 17.9 tons/yr 0.27 lb/MMBtu
Fuel Use 3.2 144.5 MMscf/yr Fuel Meter and Monthly
Record
keeping
Hours of 3.3 Record Monthly
Operation keeping
Opacity 3.4 Less Than or Equal to Fuel Annually
20% Restriction
Portable 3.5 NOx<80.5 tons/yr Portable Flue Quarterly
Monitoring CO<-46 5 tons/yr Gas Analyzer
Performance Test 3.6 NOx<80.5 tons/yr EPA One Time
CO<-46.5 tons/yr Reference
Method
Btu Content of 3.7 Record Semi-
Natural Gas keeping and Annually
Calculation
3.1 Particulate Matter, Particulate Matter less than 10 microns, Nitrogen Oxide, Carbon
Monoxide and Volatile Organic Compounds emissions shall not exceed the limitations stated
above(Construction Permits#11WE132).
3.1.1 Monthly emissions of each pollutant shall be calculated for this engine using the
listed compliance emission factors (EF), monthly fuel consumption , and the latest
BTU gas analysis from Condition 3.7 in the following equation:
lb/month=(EF)X(Monthly Fuel Use in MMscf)X(Heat Content of Fuel in MMBtu/MMscf)
3.1.2 A twelve month rolling total shall be maintained for this engine for demonstration
of compliance with the annual limitations. Each month a new twelve month total
shall be calculated using the previous twelve months data. Emissions shall be
calculated by the end of each subsequent month.
3.2 Fuel consumption for this engine shall not exceed the limitations stated above
(Construction Permits#11 WE 132)
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
Air Pollution Control Division Kerr-McGee Rocky Mountain Corporation
Colorado Operating Permit Ft. Lupton Compressor Station
Permit# 95OPWE013 Page 20
3.2.1 Fuel use for this engine shall be measured and recorded each month.Within the
first seven days of every month, the fuel meter shall be read and recorded.
Allocation of fuel use shall be made using the methods detailed in Appendix G of
this permit. The fuel use shall be measured no more than one (1) hour from the
time that run time hours have been recorded. A twelve month rolling total shall
be maintained for demonstration of compliance with the annual limitations. Each
month a new twelve month total shall be calculated using the previous twelve
months data.
3.3 Hours of operation for this engine shall be monitored and recorded monthly for use in
determining fuel use allocation.
3.4 Opacity from this engine shall not exceed 20% as stated in Regulation No. 1,
Section II, A. Natural gas shall be burned to monitor compliance with the opacity standard.
3.5 Emission measurements of nitrogen oxides (NOX) and carbon monoxide (CO) from each
engine shall be conducted quarterly using a portable flue gas analyzer. Calibration of the
analyzer shall be conducted according to manufacturer's instructions. Results of the portable
flue gas analyzer tests shall be used to monitor the compliance status of each engine. For
comparison with an annual or short term emissions 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.
An exceedance of either the NOX or CO emission limitation during the initial portable flue gas
analyzer test shall require a subsequent portable analyzer test indicating compliance with both
the NOX and CO emission limitations within 14 calendar days of the initial test. Calibration
gases shall be used to calibrate the portable analyzer for all tests conducted subsequent to the
initial test.
If portable flue gas analyzer results indicate compliance with both the NOX and CO emission
limitations within the 14 day period,the source may certify that the engine is in compliance with
both the NOX and CO emission limitations for the relevant time period.
If portable flue gas analyzer results fail to indicate the compliance of the engine with either the
NOX or CO emission limitations within the 14 day period, the source will notify the Division in
writing within 10 calendar days of the end of the 14 day period. Results of all testing that
indicates noncompliance shall be submitted to the Division within 10 calendar days of the end of
the 14 day period. The source will be required to conduct EPA Reference Test Methods
(identified as Reference Method 7E and Reference Method 10, or Reference Method 19 (40 CFR
Part 60 Appendix A), hereinafter "EPA Reference Test Methods") or other test methods or
procedures acceptable to the Division within 45 calendar days of the end of the 14 day period
allowed for the portable flue gas analyzer testing. The Division shall be notified at least 30
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
Air Pollution Control Division Kerr-McGee Rocky Mountain Corporation
Colorado Operating Permit Ft. Lupton Compressor Station
Permit# 95OPWE013 Page 21
calendar days prior to the EPA Reference Test date, so that it may choose whether to observe the
testing.
If the EPA Reference Test results indicate compliance with both the NOX and CO emission
limitations, the source may certify that the engine is in compliance with both the NO„ and CO
emission limitations for the relevant time period.
If the EPA Reference Tests fail to demonstrate compliance with either the NO„ or CO emission
limitations and in the absence of evidence to the contrary, the engine will be considered to be out
of compliance from the date of the initial portable flue gas analyzer test until the engine is taken
off line. Results of all testing that indicates noncompliance shall be submitted to the Division
within 14 calendar days after receipt of the test results.
Results of all tests conducted shall be kept on site and made available to the Division upon
request.
3.6 For an initial demonstration of compliance with the permit limits, compliance tests for the
engines shall be conducted to measure the emission rate(s) for nitrogen oxides, carbon monoxide
and oxygen using EPA approved methods or other methods approved by the Division. Any stack
tests conducted to show compliance with a monthly or annual emission limit shall have the
results projected to the monthly or annual averaging time by multiplying the test results by the
allowable number of operating hours for that averaging time.
The compliance testing shall be completed and copies of the results provided to the Division
within 180 calendar days of the issuance of this operating permit. A copy of the engine test
results shall be provided to the Division within 60 calendar days of the completion of the tests.
The test protocol must be in accordance with the requirements of the Air Pollution Control
Division Compliance Test Manual and shall be submitted to the Division for review and
approval at least thirty (30) days prior to testing. No test shall be conducted without prior
approval from the Division.
3.7 Samples of fuel gas shall be collected and analyzed to determine C1 through C6+
composition. The lower heating value of the fuel shall be calculated semi-annually using the
results of the analysis and published heats of combustion (on the basis that combustion occurs
with products and reactants in the vapor state) in terms of Btu/scf at 60 •F and 14.696 psia in the
following equation:
E(C,mol%)(Hc,Btu/scf)
LHV Btu/scf= 1
100
where:
Ci=Concentration of Component i mol%
Hc,=Heat of Combustion(vapor state of reactants)in Btu/scf @ 60°F& 14.696 psia
Calculation of monthly emissions required under Condition 3.1.1 shall be made using the
calculated lower heating value based on the most recent required analysis in Condition 4.2.
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
Air Pollution Control Division Kerr-McGee Rocky Mountain Corporation
Colorado Operating Permit Ft.Lupton Compressor Station
Permit# 95OPWE013 Page 22
3.8 These engines shall be operated and maintained in accordance with internal operating and
maintenance standards, which shall consider manufacturer's recommendations and industry
standard practices, at all times, including periods of start-up, shutdown, and malfunction. Such
internal operating and maintenance standards shall be kept on site and made available to the
Division upon request.
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3,2002
Air Pollution Control Division Kerr-McGee Rocky Mountain Corporation
Colorado Operating Permit Ft. Lupton Compressor Station
Permit# 95OPWE013 Page 23
4. EU04-Smith Triethylene Glycol Dehydration Unit
Parameter Permit Limitations Compliance Monitoring
Condition Emission Factor
Number Method Interval
VOC 4.1 146.5 tons/yr Based on GRI Parametric Daily
G1yCaic Model
Extended Gas 4.2 EPA Quarterly
Analysis Reference
Methods (To Annually)
Performance 4.3 VOC<146.5 tons/yr Division One Time
Test Approved
Protocol
Natural Gas 4.4 9,125 MMsef/yr Flow Meter Monthly
Processed
4.1 Volatile Organic Compound emissions shall not exceed the limitations stated above
(Worst Case Dehydrator Emission Data Submitted to the Division on January 1, 1995). The
glycol dehydration unit shall be considered to be operating in compliance with the hourly
emission limit if all of the following conditions are met:
Parameter Value Units Criteria
Inlet(Wet)Gas Temperature 60 degrees Fahrenheit Above
Glycol Circulation Rate 4.0 gallons per minute Below
Benzene Content of Gas 130 parts per million Below
Toluene Content of Gas 95 parts per million Below
Ethyl Benzene Content of Gas 15 parts per million Below
Xylene Content of Gas 30 parts per million Below
The triethylene glycol circulation rate and inlet (wet) gas temperature for this unit 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 above. If the average glycol circulation rate or
inlet gas temperature do not meet the stipulated passing criteria, the GRI GlyCalc (Version 2.0 or
higher) model shall be run to determine daily and monthly emission rates. Inputs to the model
will be the recorded average values for inlet temperature, glycol circulation rate, gas data from
the most recent required analysis (see below), calculated daily inlet gas throughput required by
Condition 4.4 and the following assumed value of 720 psia for inlet gas pressure.
The circumstances surrounding any day on which the required parameters fail to be measured
and recorded shall be described in a log to be maintained on-site. Data from the last day for
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
Air Pollution Control Division Kerr-McGee Rocky Mountain Corporation
Colorado Operating Permit Ft. Lupton Compressor Station
Permit# 95OPWE013 Page 24
which data exists may be substituted for missing data in the event the calculation of a monthly-
average value is required.
If a GlyCalc run is required for any reason for a given month, the tons per month of emissions
predicted by the model shall be used in a rolling 12-month total for VOC emissions to
determine compliance with the annual limit. The 12-month total shall be assumed to be equal to
the annual limit for any 12-month period for which no GLYCalc runs were triggered and for any
period for which a GLYCalc run was triggered but the results of the run predict compliance with
the hourly VOC limit. If the source chooses, the 12-month rolling total may be based on actual
emissions, provided GLYCalc was run, using the average daily parameters as required by
condition 4.1, for each month. Records of actual annual emission calculations shall be
maintained and made available to the Division upon request. The calculation of the 12-month
total shall be performed for any month a GlyCalc run is triggered if the results of the run fail to
predict compliance with the VOC limit. If the 12-month total exceeds the annual limit,
emissions for the previous months must be calculated with GlyCalc using the parameters
described in above until the rolling 12-month total is in compliance with the annual limitation.
4.2 Samples of inlet gas shall be collected and analyzed (extended gas analysis) to determine
C1 to C6, n-hexane, benzene, toluene, ethyl benzene and total xylene (BTEX) composition once
per quarter. A GlyCalc model run will be conducted using the previous months data if any of
the concentrations for BTEX listed in the table above are exceeded. Frequency of extended gas
analyses shall move to semi-annually after the first year, then to annually after the second year if
BTEX concentrations remain consistently below the established values. Frequency will revert
back to quarterly if any of the BTEX constituents exceed the listed values.
4.3 For an initial demonstration of compliance with the permit limits, compliance test for the
dehydrator shall be conducted to measure the emission rate for volatile organic compounds using
EPA approved methods or other methods approved by the Division. Any stack tests conducted
to show compliance with a monthly or annual emission limit shall have the results projected to
the monthly or annual averaging time by multiplying the test results by the allowable number of
operating hours for that averaging time.
The compliance testing shall be completed and copies of the results provided to the Division
within 180 calendar days of the issuance of this operating permit. A copy of the stack test results
shall be provided to the Division within 60 calendar days of the completion of the tests. The test
protocol must be in accordance with the requirements of the Air Pollution Control Division
Compliance Test Manual and shall be submitted to the Division for review and approval at least
thirty (30) days prior to testing. No test shall be conducted without prior approval from the
Division.
4.4 The cubic feet of gas processed by this dehydration unit shall not exceed the limitations
stated above (Colorado Construction Permit 94WE760-4). The gas throughput to the
dehydration unit shall be recorded monthly using existing flow meters. A twelve month rolling
total will be maintained to verify compliance with annual throughput limitations.
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
Air Pollution Control Division Kerr-McGee Rocky Mountain Corporation
Colorado Operating Permit Ft. Lupton Compressor Station
Permit# 95OPWE013 Page 25
5. I001 -Elastec Inc., Smart Ash Energy Recovery Unit
Parameter Permit Limitations Compliance Monitoring
Condition Emission
Number Short Term Long Term Factor Method Interval
PM 5.1 0.084 tons/yr 1.4 lbs/ton Record keeping and Monthly
waste Calculation
PMIO 0.062 tons/yr 1.04 lbs/ton
waste
S02 0.09 tons/yr 1.5 lbs/ton
waste
NO2 0.6 tons/yr 10.0 lbs/ton
waste
Charge Limit 5.2 120 lbs/hr 120 tons/yr Record keeping Per Charge
Flash Point of 5.3 Greater than or Waste Restriction Per Charge
Waste Equal to 100•F
Particulates 5.4 0.10 gr/dscf corrected at Demonstrated See Condition
12%CO2 Compliance with 5.4
Conditions 5.2, 5.3
and 5.6
Waste Burning 5.5 No Burning of Radioactive Self Certification Annually
Restrictions or Hazardous Waste
Opacity 5.6 Less Than or Equal to 20% EPA Reference Annually
Method 9
Personnel 5.7 Trained Personnel Record keeping Per Charge
Requirements Operating Incinerator
5.1 Emissions of air pollutants shall not exceed the limitations above (Colorado Construction
Permit 97WE0406 as modified directly by this Operating Permit modification). Emissions from
this unit shall be calculated monthly and a twelve month rolling total to comply with the annual
limits using the equations below:
tons/month= [EF(lbs/ton waste)x waste burned (tons/month)x 1/2000 (ton/Ibs)]
5.2 The charge weight of the incinerator shall not exceed the limitations above (Colorado
Construction Permit 97WE0406 as modified directly by this Operating Permit modification).
Compliance with this requirement shall be demonstrated by monitoring and recording the weight
of each charge into the incinerator. These records shall be made available to the Division upon
request.
5.3 The flash point of materials being burned shall be higher than or equal to 100 degrees F
(Colorado Construction Permit 97WE0406). Compliance with this requirement shall be
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
4 } I
Air Pollution Control Division Kerr-McGee Rocky Mountain Corporation
Colorado Operating Permit Ft. Lupton Compressor Station
Permit# 95OPWE013 Page 26
demonstrated by monitoring and recording the materials being burned in each charge. Absorbent
materials that contain volatile liquids, such as gasoline or paint thinner shall not be burned in this
unit. These records shall be made available to the Division upon request.
In addition, liquid fuel shall not be used as start-up fuel (Colorado Construction Permit
97WE0406). An ample layer of dry paper or cardboard material supplies a fast, easy initial fuel
source for start-up.
5.4 Particulate emissions shall not exceed 0.1 grains per dry standard cubic feet, corrected to
12% CO2 (Colorado Construction Permit 97WE0406). Demonstrated compliance with
Conditions 5.2, 5.3, and 5.6 shall be adequate to ensure compliance with this particulate emission
limit.
5.5 No radioactive or hazardous waste may be burned in the incinerator without obtaining the
appropriate permits (Colorado Construction Permit 97WE0406). Compliance with this
requirement will be demonstrated by certifying annually that no radioactive or hazardous waste
was burned.
5.6 Opacity of emission shall not exceed 20% (Colorado Construction Permit 97WE0406).
Compliance with this requirement shall be demonstrated by conducting visual emission
observations, in accordance with EPA Reference Method 9, annually. Results of Method 9
readings and a copy of the certified Method 9 reader's certification shall also be kept on site and
made available to the Division upon request.
5.7 The incinerator must be operated by trained personnel (Colorado Construction Permit
97WE0406). Compliance with this requirement will be demonstrated by maintaining records of
personnel trained to operate the incinerator. The name of the personnel operating the incinerator
will be recorded for each charge of waste fed to the incinerator. These records shall be made
available to the Division upon request.
5.8 The incinerator shall be operated and maintained in accordance with manufacturer's
recommendations at all times, including periods of start-up, shutdown and malfunction.
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
•
Air Pollution Control Division Kerr-McGee Rocky Mountain Corporation
Colorado Operating Permit Ft. Lupton Compressor Station
Permit#95OPWE013 Page 27
6. F001 -Fugitive VOC Emissions From Equipment Leaks
Parameter Permit Limitation Compliance Emission Monitoring
Condition Factor
Number Method Interval
VOC 6.1 30.8 tons/yr By Component Type- Record keeping As Noted
EPA's Protocol for
Equipment Leaks
6.1 VOC emissions from equipment leaks shall not exceed the limitations stated above
(Colorado Construction Permit 96WE641). Emissions shall be calculated using the emission
factors and equations listed below:
Emission Factors for individual types of components in lbs/component-hr (Protocol for
Equipment Leak Emission Estimates, EPA-453/R-95-017).
Connectors=0.00044
Flanges=0.000858
Open-ended Line=0.0044
*Other=0.01936
Pump=0.00528
Valve=0.0099
* This "other" equipment type should be applied for any equipment type other than
connectors, flanges, open-ended lines, pumps or valves.
Emissions of VOC per component:
No. of Components x EF(lbs/component-hr)x 8760 hrs/yr x VOC content of gas
6.1.1 The most recent gas analysis as required under Conditions 4.2 of this Permit shall
be used to determine the appropriate%VOC to use in the above equation.
6.1.2 A component count shall be conducted within 90 days of the issuance of this
permit and every five (5) years thereafter to verify existing components and
inventory.
6.1.3 A running total shall be kept of all additions and subtractions to the component
count. The most recent count shall be used for emission calculations and
compliance purposes.
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
Air Pollution Control Division Kerr-McGee Rocky Mountain Corporation
Colorado Operating Permit Ft. Lupton Compressor Station
Permit#95OPWE013 Page 28
SECTION III- Permit Shield
Regulation No. 3, 5 CCR 1001-5, Part A, § I.B.43; Part C, §§ V.C.1.b. & D., XIII; §§ 25-7-
111(2)(I), 25-7-114.4(3)(a), C.R.S.
1. Specific Conditions
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.
Emission Unit Applicable Requirement Justification
Description&
Number
Facility 40 CFR 60, Subpart KKK, Standards of There is no existing natural gas liquid extraction unit
Performance for Equipment Leaks of VOC located at the Ft. Lupton facility. Any liquids recovered
From Onshore Natural Gas Processing Plants on-site are done through gravimetric separation processes
(Colorado Regulation No. 6, Part B, Subpart typical of inlet gas separation implemented at most
KKK) compressor stations.
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.
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
Air Pollution Control Division Kerr-McGee Rocky Mountain Corporation
Colorado Operating Permit Ft. Lupton Compressor Station
Permit# 95OPWE013 Page 29
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.
Permit Condition Streamlined(Subsumed)Requirements
NOT APPLICABLE
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
s .-
Air Pollution Control Division Kerr-McGee Rocky Mountain Corporation
Colorado Operating Permit Ft. Lupton Compressor Station
Permit# 95OPWE013 Page 30
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.36.a. 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;
(ii) the compliance status of the source;
(iii) whether compliance was continuous or intermittent;
(iv) the method(s) used for determining the compliance status of the source, currently and
over the reporting period;and I
(v) such other facts as the Air Pollution Control Division may require to determine the
compliance status of the source.
d. All compliance certifications shall be submitted to the Air Pollution Control Division and to the
Environmental Protection Agency at the addresses listed in Appendix D of this Permit.
e. If the permittee is required to develop and register a risk management plan pursuant to§ 112(r)of
the federal act, the 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. I
3. Compliance Requirements
Regulation No.3,5 CCR 1001-5,Part C,§§III.C.9.,V.C.11.& 16.d.,§§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.
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
I
Air Pollution Control Division Kerr-McGee Rocky Mountain Corporation
Colorado Operating Permit Ft. Lupton Compressor Station
Permit# 95OPWE013 Page 31
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.
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.
4. 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
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
. I
Air Pollution Control Division Kerr-McGee Rocky Mountain Corporation
Colorado Operating Permit Ft. Lupton Compressor Station
Permit# 95OPWE013 Page 32
d. the permittee submitted oral notice of the emergency to the Air Pollution Control Division no later
than noon of the next working day following the emergency, and followed by written notice
within one month of the time when emissions limitations were exceeded due to the emergency.
This notice must contain a description of the emergency, any steps taken to mitigate emissions,
and corrective actions taken.
This emergency provision is in addition to any emergency or upset provision contained in any applicable
requirement.
This emergency provision is also in addition to the Upset Conditions and Breakdowns provision set forth in
the Common Provisions, Section II.E, which states that upset conditions shall not be deemed to be in
violation of the Colorado regulations, provided the Division is notified as soon as possible, but not later
than two(2)hours after the start of the next working day,followed by a written notice explaining the cause
of the occurrence and that proper action has been or is being taken to correct the conditions causing the
violation and to prevent such excess emission in the future.
5. 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."
6. 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.
7. Fee Payment
Regulation No.3,5 CCR 1001-5,Part A,$VI.;Part C, V.C.12.
a. The permittee shall pay an annual emissions fee in accordance with Regulation No. 3, Part A,
Section VI. 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 of$50 per hour. If the Division estimates that
processing of the permit will take more than 30 hours,it will notify the permittee of its estimate of
what the actual charges may be prior to commencing any work exceeding the 30 hour limit.
c. The permittee shall pay an APEN fee of$100 for each APEN or revised APEN filed.
8. 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.
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
1
I
Air Pollution Control Division Kerr-McGee Rocky Mountain Corporation
Colorado Operating Permit Ft. Lupton Compressor Station
Permit# 95OPWE013 Page 33
9. 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.
10. 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.
11. 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.
12. 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.
13. Odor
Regulation No.2,5 CCR 1001-3
As a matter of state law only, the permittee shall comply with the provisions of Regulation No. 2
concerning odorous emissions.
14. 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.
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
Air Pollution Control Division Kerr-McGee Rocky Mountain Corporation
Colorado Operating Permit Ft. Lupton Compressor Station
Permit# 95OPWE013 Page 34
15. Opacity
Regulation No. 1,5 CCR 1001-3,,S$I..II.
The permittee shall comply with the opacity emissions limitation set forth in Regulation No. 1,§§I.-II.
16. Open Burning
Regulation No. 1,5 CCR 1001-3,88 II.C.1.
The permittee shall obtain a permit from the Division for any regulated open burning activities in
accordance with provisions of Regulation No. 1,§II.C.1.
17. 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.,III.IV., and V. of Regulation No. 15 shall be enforced as a
matter of state law only.
18. 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.
19. Portable Sources
Regulation No.3,5 CCR 1001-5,Part C,$II.D.
Portable Source permittees shall notify the Air Pollution Control Division at least 10 days in advance of
each change in location.
20. Prompt Deviation Reporting
Regulation No.3,5 CCR 1001-5,Part C, 8 V.C.7.b.
The permittee shall promptly report any deviation from permit requirements,including those attributable to
upset conditions as defined in the permit,the probable cause of such deviations,and any corrective actions
or preventive measures taken. Unless required by a permit term or condition to report deviations on a more
frequent basis,"prompt"reporting shall entail submission of reports of deviations from permit requirements
every six(6)months in accordance with paragraph 21.d.below. "Prompt reporting" does not constitute an
exception to the requirements of"Emergency Provisions"for the purpose of avoiding enforcement actions.
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
p
Air Pollution Control Division Kerr-McGee Rocky Mountain Corporation
Colorado Operating Permit Ft. Lupton Compressor Station
Permit# 95OPWE013 Page 35
21. Record Keeping and Reporting Requirements
Regulation No.3,5 CCR 1001-5,Part A,§II.;Part C,§$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 defined in the Operating Permit,and time of sampling or measurements;
(ii) date(s)on which analyses were performed;
(iii) the company or entity that performed the analysis;
(iv) the analytical techniques or methods used;
(v) the results of such analysis;and
(vi) the operating conditions at the time of sampling or measurement.
b. The permittee shall retain records of all required monitoring data and support information for a
period of at least five (5) years from the date of the monitoring sample, measurement, report or
application. Support information, for this purpose, includes all calibration and maintenance
records and all original strip-chart recordings for continuous monitoring instrumentation, and
copies of all reports required by the Operating Permit. With prior approval of the Air Pollution
Control Division,the permittee may maintain any of the above records in a computerized form.
c. 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 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 enhanced
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.
22. 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,
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
.
Air Pollution Control Division Kerr-McGee Rocky Mountain Corporation
Colorado Operating Permit Ft. Lupton Compressor Station
Permit# 95OPWE013 Page 36
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.
23. 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.
24. Severability Clause
Regulation No.3,5 CCR 1001-5,Part C,§V.C.l0.
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.
25. Significant Permit Modifications
I
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.
26. Special Provisions Concerning the Acid Rain Program
Regulation No.3,5 CCR 1001-5,Part C,§§V.C.1.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.
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
Air Pollution Control Division Kerr-McGee Rocky Mountain Corporation
Colorado Operating Permit Ft. Lupton Compressor Station
Permit# 95OPWE013 Page 37
27. 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.
28. 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 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.
29. 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.
END OF PERMIT REQUIREMENTS
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
Air Pollution Control Division
Colorado Operating Permit
Appendices Page 38
OPERATING PERMIT APPENDICES
A - INSPECTION INFORMATION
B - COMPLIANCE MONITORING REPORT FORMAT
C - COMPLIANCE CERTIFICATION REPORT FORMAT
D - NOTIFICATION ADDRESSES
E - PERMIT ACRONYMS
F - PERMIT MODIFICATIONS
G - FUEL CONSUMPTION ALLOCATION
*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: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3,2002
Air Pollution Control Division
Colorado Operating Permit Appendix A
Inspection Information Page 39
APPENDIX A-Inspection Information
Directions to Plant:
This facility is near the town of Ft. Lupton, located at 16116 Weld County Road 22.
Safety Equipment Required:
Hard Hat, Safety Shoes, Hearing Protection, Eye Protection and Flame Resistant
Clothing
Facility Plot Plan:
Figure 1 (following page) shows the plot plan as submitted on December 30, 1994 with
the source's Title V Operating Permit Application.
List of Insignificant Activities::
The following list of insignificant activities was provided by the source to assist in the
understanding of the facility layout. Since there is no requirement to update such a list,
activities may have changed since the last filing.
Insignificant activities and/or sources of emissions as submitted in the application are as
follows:
I
Methanol storage tank, 8800 gal
Two (2)glycol storage tanks, 5200& 5876 gal
Three(3)antifreeze storage tanks, 2x1000& 517 gal
Mineral spirits storage tank, 517 gal
Five(5)condensate storage tanks, all 8300 gal
Used engine oil storage, 1030 gal
New engine oil storage, 9450 gal
Condensate storage groundwater sump
Condensate overflow and vent tank
Dehydrator Unit,Natural gas-fired heater, 750,000 Btu/hr
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Format Page 40
APPENDIX B
Monitoring and Permit Deviation Reporting
with codes ver 9/1/00
Reporting Requirements and Definitions
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,
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Format Page 41
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 upset conditions and
malfunctions as defined in this Appendix, the probable cause of such deviations, and any
corrective actions or preventive measures taken. All deviations from any term or condition of
the permit are required to be summarized or referenced in the annual compliance certification.
For purposes of this operating permit, "upset" shall refer to both emergency conditions and
upsets. Additional discussion on these conditions is provided later in this Appendix.
For purposes of this operating permit, the Division is requiring that the permit deviation reports
are due every six months unless otherwise noted in the permit. Where the underlying applicable
requirement contains a definition of prompt or otherwise specifies a time frame for reporting
deviations, that definition or time frame shall govern. For example, quarterly Excess Emission
Reports required by an NSPS or Regulation No. 1, Section IV.
In addition to the monitoring deviations discussed above, included in the meaning of deviation
for the purposes of this operating permit are any of the following:
(1) A situation where emissions exceed an emission limitation or standard contained in the
permit;
(2) A situation where process or control device parameter values demonstrate that an emission
limitation or standard contained in the permit has not been met;
(3) A situation in which observations or data collected demonstrates noncompliance with an
emission limitation or standard or any work practice or operating condition required by the
permit; or,
(4) A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the
Compliance Assurance Monitoring(CAM)Rule)has occurred.
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Format Page 42
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 material information (i.e. information
beyond required monitoring that has been specifically assessed in relation to how the information
potentially affects compliance status), that information must be identified and addressed in the
compliance certification. The compliance certification must include the following:
• The identification of each term or condition of the permit that is the basis of the
certification;
• The identification of the method(s) or other means used by the owner or operator
for determining the compliance status with each permit term and condition during
the certification period and whether such methods or other means provide
continuous or intermittent data. Such methods and other means shall include, at a
minimum, the methods and means required in the permit. If necessary, the owner
or operator also shall identify any other material information that must be
included in the certification to comply with section 113(c)(2) of the Federal Clean
Air Act, which prohibits knowingly making a false certification or omitting
material information;
• The status of compliance with the terms and conditions of the permit, and whether
compliance was continuous or intermittent. The certification shall identify each
deviation and take it into account in the compliance certification. Note that not all
deviations are considered violations.'
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
, ` I
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Format Page 43
• 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 40CFR
Part 64 (the Compliance Assurance Monitoring(CAM)Rule)has occurred.
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.
1 For example, given the various emissions limitations and monitoring requirements to which a source may be
subject, a deviation from one requirement may not be a deviation under another requirement which recognizes an
exception and/or special circumstances relating to that same event. Further, periods of excess emissions during
startup, shutdown and malfunction may not be found to be a violation of an emission limitation or standard where
the source adequately shows that any potential deviations as a result of these infrequent periods were minimized to
the extent practicable and could not have been prevented through careful planning, design, or were unavoidable to
prevent loss of life,personal injury,or severe property damage.
Startup, Shutdown,Malfunctions,Emergencies,and Upsets
Understanding the application of Startup, Shutdown, Malfunctions, Emergency provisions, and
the Upset provisions is very important in both the deviation reports and the annual compliance
certifications.
Startup, Shutdown, and Malfunctions
Please note that exceedances of some New Source Performance Standards (NSPS) and
Maximum Achievable Control Technology (MACT) standards that occur during Startup,
Shutdown or Malfunctions may not be considered to be non-compliance since emission limits or
standards often do not apply unless specifically stated in the NSPS. Such exceedances must,
however, be reported as excess emissions per the NSPS/MACT rules and would still be noted in
the deviation report. In regard to compliance certifications, the permittee should be confident of
the information related to those deviations when making compliance determinations since they
are subject to Division review. The concepts of Startup, Shutdown and Malfunctions also exist
for Best Available Control Technology (BACT) sources, but are not applied in the same fashion
as for NSPS and MACT sources.
Emergencies and Upsets
Under the Emergency provisions of Part 70 and the Upset provisions of the State regulations,
certain operational conditions may act as an affirmative defense against enforcement action if
they are properly reported.
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Format Page 44
Definitions
Malfunction (NSPS)means any sudden, infrequent, and not reasonably preventable failure of air
pollution control equipment, process equipment, or a process to operate in a normal or usual
manner. Failures that are caused in part by poor maintenance or careless operation are not
malfunctions.
Malfunction (SIP)means any sudden and unavoidable failure of air pollution control equipment
or process equipment or unintended failure of a process to operate in a normal or usual manner.
Failures that are primarily caused by poor maintenance, careless operation, or any other
preventable upset condition or preventable equipment breakdown shall not be considered
malfunctions.
Emergency means any situation arising from sudden and reasonably unforeseeable events
beyond the control of the source, including acts of God, which situation requires immediate
corrective action to restore normal operation, and that causes the source to exceed a technology-
based emission limitation under the permit, due to unavoidable increases in emissions
attributable to the emergency. An emergency shall not include noncompliance to the extent
caused by improperly designed equipment, lack of preventative maintenance, careless or
improper operation, or operator error.
Upset means an unpredictable failure of air pollution control or process equipment which results
in the violation of emission control regulations and which is not due to poor maintenance,
improper or careless operations, or is otherwise preventable through exercise of reasonable care.
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Format Page 45
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 on a semi-annual basis unless otherwise noted in the permit. The Table below must be completed
for all equipment or processes for which specific Operating Permit terms exist.
2. Part II of this Appendix B shows the format and information the Division will require for describing
periods of monitoring and permit deviations, or upset or emergency conditions as indicated in the Table
below. One Part II Form must be completed for each Deviation. Previously submitted reports(e.g.EER's
or Upsets)may be referenced and the form need not be filled out in its entirety.
FACILITY NAME: Kerr-McGee RMC—Ft.Lupton Compressor Station
OPERATING PERMIT NO: 95OPWE013
REPORTING PERIOD: (see first page of the permit for specific reporting period and dates)
Deviations noted Deviation Upset/Emergency
Operating During Period?1 Code 2 Condition Reported
Permit Unit ID Unit Description During Period?
YES NO YES NO
EU31 Waukesha,Model L-7042,4-Cycle Rich Burn,
Internal Combustion Engine,Rated at 954 HP
(Maximum),Serial No.250451.Natural Gas Fired.
EU32 Waukesha,Model L-7042,4-Cycle Rich Burn,
Internal Combustion Engine,Rated at 954 HP
(Maximum),Serial No.288792 Natural Gas Fired.
EU34 Waukesha,Model L-7042,4-Cycle Rich Burn,
Internal Combustion Engine,Rated at 954 HP
(Maximum),Serial No.288358. Natural Gas
Fired.
EU33 Fairbanks Morse,Model No.384S8MEP-12,
2-Cycle Lean Burn,Internal Combustion Engine,
Site Rated at 2166 HP,
Serial No.38D8780-30S1S12. Natural Gas Fired.
EU35 Fairbanks Morse,Model No.38D8750-45SIS,
2-Cycle Lean Burn,Internal Combustion Engine,
Site Rated at 1859 HP,Serial No.38DS8 MEP-10.
Natural Gas Fired.
EU36 Fairbanks Morse,Model No.38DS8MEP-12,
2-Cycle Lean Burn,Internal Combustion Engine,
Site Rated at 2166 HP,
Serial No.38D8780-24S1512. Natural Gas Fired.
EU37 Fairbanks Morse,Model No.38D8780-28S1S,
2-Cycle Lean Burn,Internal Combustion Engine,
Site Rated at 2166 HP,
Serial No.38D8780-2851S12. Natural Gas Fired.
EU04 Smith,Model No.Unavailable,Triethylene Glycol
Dehydration Unit,Rated at 30 MMscf/day,
Serial No.79-148.
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Format Page 46
Deviations noted Deviation Upset/Emergency
Operating During Period?1 Code 2 Condition Reported
Permit Unit ID Unit Description During Period?
YES NO YES NO
I001 Elastec Inc.,Smart Ash Energy Recovery Unit,
Model 100,Serial No.Unavailable.
F001 Fugitive VOC Emissions from Equipment Leaks
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 4OCFR 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: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Format Page 47
Monitoring and Permit Deviation Report -Part II
FACILITY NAME: [Company Name] - [Facility Name]
OPERATING PERMIT NO: [Permit#
REPORTING PERIOD:
Is the deviation being claimed as an: Emergency Upset N/A
(For NSPS/MACT)Did the deviation occur during: Startup Shutdown
Malfunction Normal Operation
OPERATING PERMIT UNIT IDENTIFICATION:
Operating Permit Condition Number Citation
Explanation of Period of Deviation
Duration (start/stop date&time)
Action Taken to Correct the Problem
Measures Taken to Prevent a Reoccurrence of the Problem
Dates of Upsets/Emergencies Reported (if applicable)
Deviation Code: Division Code QA:
SEE EXAMPLE ON THE NEXT PAGE
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
.
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Format Page 48
EXAMPLE
FACILITY NAME: Acme Corp.
OPERATING PERMIT NO: 96OPZZXXX
REPORTING PERIOD: 1/1/96-6/30/96
Is the deviation being claimed as an: Emergency Upset XX N/A
(For NSPS/MACT)Did the deviation occur during: Startup Shutdown
Malfunction Normal Operation
OPERATING PERMIT UNIT IDENTIFICATION:
Asphalt Plant with a Scrubber for Particulate Control -Unit XXX
Operating Permit Condition Number Citation
Section II, Condition 3.1 -Opacity Limitation
Explanation of Period of Deviation
Slurry Line Feed Plugged
Duration
START- 1730 4/10/96
END- 1800 4/10/96
Action Taken to Correct the Problem
Line Blown Out
Measures Taken to Prevent Reoccurrence of the Problem
Replaced Line Filter
Dates of Upsets/Emergencies Reported(if applicable)
4/10/96 to S. Busch,APCD
Deviation Code: Division Code QA:
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
i
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Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Format Page 49
Monitoring and Permit Deviation Report -Part III
REPORT CERTIFICATION
SOURCE NAME: Kerr-McGee RMC—Ft. Lupton Compressor Station
FACILITY IDENTIFICATION NUMBER: 1230057
PERMIT NUMBER: 95OPWE013
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. The responsible official signing this certification must be pre-approved by
the Division in accordance with Colorado Regulation No. 3, Part A, Section I.B.54. 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 he 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 I
I
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: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
1
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Air Pollution Control Division
Colorado Operating Permit Appendix C
Compliance Certification Report Format Page 50
APPENDIX C
Required Format for Annual Compliance Certification Report
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: Kerr-McGee RIVIC—Ft Lupton Compressor Station
OPERATING PERMIT NO: 95OPWE013
REPORTING PERIOD:
I. Facility Status I
_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 continuous Was Data
Permit Unit Reported 1 Method per or intermittent?3 Continuous`?
ID Permit?2
Previous Current Yes No Continuous Intermittent Yes No
EU31 Waukesha,Model L-
7042,4-Cycle Rich
Burn,Internal
Combustion Engine, I
Rated at 954 HP
(Maximum),
Serial No.250451.
Natural Gas Fired.
EU32 Waukesha,Model L-
7042,4-Cycle Rich
Bum,Internal
Combustion Engine, I
Rated at 954 HP
(Maximum),
Serial No.288792
Natural Gas Fired.
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
tl
Air Pollution Control Division
Colorado Operating Permit Appendix C
Compliance Certification Report Format Page 51
Operating Unit Description Deviations Monitoring Was compliance continuous Was Data
Permit Unit Reported I Method per or intermittent?3 Continuous?°
ID Permit?Z
Previous Current Yes No Continuous Intermittent Yes No
EU34 Waukesha,Model L-
7042,4-Cycle Rich
Bum,Internal
Combustion Engine,
Rated at 954 HP
(Maximum),
Serial No.288358.
Natural Gas Fired.
EU33 Fairbanks Morse,
Model No.
384S8MEP-12,2-
Cycle Lean Burn,
Internal Combustion
Engine,Site Rated at
2166 HP,Serial No.
38D8780-3051512.
Natural Gas Fired.
EU35 Fairbanks Morse,
Model No.38D8750-
4551 S,2-Cycle Lean
Burn,Internal
Combustion Engine,
Site Rated at 1859 HP,
Serial No.38DS8
MEP-10. Natural Gas
Fired.
EU36 Fairbanks Morse,
Model No.
38DS8MEP-12,2-
Cycle Lean Burn,
Internal Combustion
Engine,Site Rated at
2166 HP,Serial No.
38D8780-24S1512.
Natural Gas Fired.
EU37 Fairbanks Morse,
Model No.38D8780- I
28S 1S,S,2-Cycle Lean
Bum,Internal
Combustion
Engine,Site Rated at
2166 HP,Serial No.
38D8780-2851S12.
Natural Gas Fired.
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
g Air Pollution Control Division
Colorado Operating Permit Appendix C
Compliance Certification Report Format Page 52
Operating Unit Description Deviations Monitoring Was compliance continuous Was Data
Permit Unit Reported' Method per or intermittent?3 Continuous?4
ID Permit?2
Previous Current Yes No Continuous Intermittent Yes No
EU04 Smith,Model No.
Unavailable,
Triethylene Glycol
Dehydration Unit,
Rated at 30
mmSCF/day,
Serial No.79-148.
I001 Elastec Inc.,Smart Ash
Energy Recovery Unit,
Model 100,Serial No.
Unavailable.
F001 Fugitive VOC
Emissions from
Equipment Leaks
General
Conditions 5
Insignificant
Activities 5
' If deviations were noted in the previous deviation report (i.e. for the first six months of the annual reporting
period), put an "X"under"previous". If deviations were noted in the current deviation report(i.e. for the last six
months of the annual reporting period),put an"X"under"current". Mark both columns if both apply.
2 Note whether the method(s) used to determine the compliance status with each term and condition was the
method(s)specified in the permit. If it was not,mark"no"and attach additional information/explanation.
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.
March 2000
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 record keeping required in its permit, even if such activities are done periodically and not
continuously, and if 2) such monitoring and record keeping 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 Note whether the method(s) used to determine the compliance status with each term and condition provided ,
continuous or intermittent data.
5 Compliance status for these sources shall be based on a reasonable inquiry using readily available information.
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
Air Pollution Control Division
Colorado Operating Permit Appendix C
Compliance Certification Report Format Page 53
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
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§25-7 122.1,
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: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
Air Pollution Control Division
Colorado Operating Permit Appendix C
Compliance Certification Report Format Page 54
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
U.S. Environmental Protection Agency,Region VIII
999 18th Street, Suite 500
Denver, CO 80202
Permit Modifications, Off Permit Changes:
Office of Pollution Prevention, State and Tribal Programs
Air Program, 8P2-A
U.S. Environmental Protection Agency,Region VIII
999 18th Street, Suite 500
Denver, CO 80202
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
a ry
Air Pollution Control Division
Colorado Operating Permit Appendix E
Permit Acronyms Page 55
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
LBS - Pounds
M - Thousand
MM- Million
MMscf- Million Standard Cubic Feet
MMscfd - Million Standard Cubic Feet per Day
N/A or NA- Not Applicable
NOx- Nitrogen Oxides
NESHAP- National Emission Standards for Hazardous Air Pollutants
NSPS - New Source Performance Standards
P- Process Weight Rate in Tons/Hr
PE- Particulate Emissions
PM - Particulate Matter
PM10 - Particulate Matter Under 10 Microns
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
a
Air Pollution Control Division
Colorado Operating Permit Appendix E
Permit Acronyms Page 56
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: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
.n
Air Pollution Control Division
Colorado Operating Permit Appendix F
Permit Modifications Page 57
APPENDIX F
Permit Modifications
DATE OF TYPE OF SECTION NUMBER, DESCRIPTION OF REVISION
REVISION REVISION CONDITION
NUMBER
March 21,2000 Administrative Cover Sheet Change of Ownership;Change of Responsible Official;
Amendment Change of Facility Contact Person;Change submittal date
for semi-annual reports and certification submittal.
Section II Correct typographical error for carbon monoxide limits.
Item 3,EU35- Limits corrected to identify limit as 46.5 tons per year and
Fairbanks Morse 45S1S not 17.9 tons per year as previously shown.
1859 HP IC Engine
Table
Appendix B Update formats and information to current standard
Appendix C version
October 20,2000 Minor Section II,Conditions Update language to current version
Modification 1.4,2.4 and 3.4
Section II,Conditions Update portable monitoring language to current version
1.5,2.5 and 3.5
Section II Correct typographical error for volatile organic compound
Item 3,EU35- limit. Limits corrected to identify limit as 17.9 tons per
Fairbanks Morse 45S1S year and 9.2 tons per year as previously shown.
1859 HP IC Engine
Table
Section II,Item 5,1001- Increase charge limits to 120 pounds per hour and 120 tons
Elastec Inc.,Smart Ash per year.
Energy Recovery Unit Increase PM limit to 0.084 tons per year.
Table Increase PM 10 limit to 0.062 tons per year.
Increase SO2 limit to 0.09 tons per year.
Increase NO2 limit to 0.6 tons per year.
Section II,Item 5, Modify wording to identify change in Construction Permit
Condition 5.1 97WE0406 conditions being made directly in this
Condition 5.2 Operating Permit modification.
Appendix B Update formats and information to current standard
Appendix C version
July 3,2002 Administrative Document Corporate name change
Amendment
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
Air Pollution Control Division
Colorado Operating Permit Appendix G
Permit Modifications Page 58
APPENDIX G
Fuel Allocation Calculation
Required Method for Fuel Consumption Allocation
*The methods outlined will be used if each unit doesn't have an individual fuel meter to
calculate fuel use from Internal Combustion Engines EU31-EU37
FUEL ALLOCATION TO INDIVIDUAL ENGINES
Allocated Fuel Consumption=[Design Heat RatellHrs.of Operationl1Site Rated Horsepower)X[Facility Fuel Use for Month]
[Sum of Numerator for Each Engine]
Unit Site Rated
Number Horsepower
EU31 954
EU32 954
EU34 954
EU33 2166
EU35 1859
EU36 2166
EU37 2166
Operating Permit Number: 95OPWE013 ISSUE: October 10, 1998
Last Revised: July 3, 2002
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