HomeMy WebLinkAbout20202507.tiff C •r• COLORADO
•yt„ Department of Public
�� Health&Environment
RECEIVED
JUL 2 9 2020
Weld County - Clerk to the Board
1150 O St WELD COUNTY
PO Box 758 COMMISSIONERS
Greeley, CO 80632
July 22, 2020
Dear Sir or Madam:
On July 23, 2020, the Air Pollution Control Division will begin a 30-day public notice period for
Cheyenne Plains Gas Pipeline Company, LLC - Cheyenne Plains Compressor Station. A copy of this
public notice and the public comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention:.Public Notice Coordinator
Enclosure
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4300 Cherry Creek Drive S., Denver, Co 80246-1530 P 303-692-2000 www.colorado.gov/cdphe R'/ o `Q',.
Jared Polls, Governor I Jill Hunsaker Ryan,MPH, Executive Director R , *;.
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M�M�M Air Pollution Control Division
Notice Of A Proposed Renewal Title V Operating Permit
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Warranting Public Comment
Website Title: Cheyenne Plains Gas Pipeline Company, LLC - Cheyenne Plains Compressor Station - Weld
County
Notice Period Begins: July 23, 2020
NOTICE is hereby given that an application to renew an Operating Permit has been submitted to the
Colorado Air Pollution Control Division, 4300 Cherry Creek Drive South, Denver, Colorado 80246-1530, for
the following source of air pollution:
Applicant: Cheyenne Plains Gas Pipeline Company, LLC
2 North Nevada Avenue
Colorado Springs, CO 80903
Facility: Cheyenne Plains Compressor Station
Section 5, 7-11N, R66W
Weld County
Colorado
Cheyenne Plains Gas Pipeline Company, LLC has applied to renew the Operating Permit for the Cheyenne
Plains Compressor Station in Weld County, CO. Cheyenne Plains Compressor Station is a natural gas
compression facility that compresses and transmits natural gas from the Wyoming area east into Kansas The
permit was renewed with updates to secondary responsible official, and permit contact person; and various
other administrative changes. No emission changes was requested. A copy of the application, including
supplemental information, the Division's analysis, and a draft of the Renewal Operating Permit 05OPWE281
have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis
are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-
notices. The Division has made a preliminary determination of approval of the application. Based on the
information submitted by the applicant, the Division has prepared the draft renewal operating permit for
approval. Any interested person may contact Thang Nghiem of the Division at 303.692.3256 to obtain
additional information. Any interested person may submit written comments to the Division concerning 1)
the sufficiency of the preliminary analysis, 2) whether the permit application should be approved or denied,
3) the ability of the proposed activity to comply with applicable requirements, 4) the air quality impacts of,
alternatives to, and control technology required on the source or modification, and 5) any other appropriate
air quality considerations. Any interested person may submit a written request to the Division for a public
comment hearing before the Colorado Air Quality Control Commission (Commission) to receive comments
regarding the concerns listed above as well as the sufficiency of the preliminary analysis and whether the
Division should approve or deny the permit application. If requested, the hearing will be held before the
Commission within 60 days of its receipt of the request for a hearing unless a longer time period is agreed
upon by the Division and the applicant. The hearing request must: 1) identify the individual or group
requesting the hearing, 2) state his or her address and phone number, and 3) state the reason(s) for the
request, the manner in which the person is affected by the proceedings, and an explanation of why the
person's interests are not already adequately represented. The Division will receive and consider the
written public comments and requests for any hearing for thirty calendar days after the date of this Notice.
Comments may be submitted using the following options:
COLORADO
1ig_ "
Department of Public
S°'"` Health&Environment
• Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page
also includes guidance for public participation
• Send an email to cdphe.commentsapcd@state.co.us
• Send comments to our mailing address:
Thang Nghiem
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
Hearing requests may be submitted to the email address or the mailing address noted above.
_y,.. COLORADO
Department of Public
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Colorado Department
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OPERATING PERMIT
Cheyenne Plains Gas Pipeline Company, LLC
Cheyenne Plains Compressor Station
First Issued: October 1, 2007
Renewed: DRAFT
AIR POLLUTION CONTROL DIVISION
COLORADO OPERATING PERMIT
FACILITY NAME: Cheyenne Plains OPERATING PERMIT NUMBER
Compressor Station
FACILITY ID: 123/0051 05OPWE281
RENEWED: DA lEISSUED
EXPIRATION DATE: DATE_EXPIRES
MODIFICATIONS: See Appendix F of Permit
Issued in accordance with the provisions of Colorado Air Pollution Prevention and Control Act, 25-7-101 et
sue. and applicable rules and regulations.
ISSUED TO: PLANT SITE LOCATIONS:
Cheyenne Plains Gas Pipeline Company, LLC Cheyenne Plains Gas Pipeline Company, LLC
Cheyenne Plains Compressor Station
2 North Nevada Avenue Section 5, T11N, R66W (—4 miles North of Rockport)
Colorado Springs, CO 80903 Weld County
INFORMATION RELIED UPON
Operating Permit Renewal Applications Received: March 30, 2018
And Additional Information Received: DATES
Nature of Business: Natural Gas Transmission
Primary SIC: 4922
RESPONSIBLE OFFICIAL FACILITY CONTACT PERSON
Name: Bruce Jones Name: Matt Richards
Title: Division Director Title: Air Permitting and Compliance Specialist
Phone: (719) 520-4843 Phone: (719) 520-4855
SECONDARY RESPONSIBLE OFFICIAL
Name: Ron Bessette
Title: Vice President Operations
Phone: (713) 420-6012
SUBMITTAL DEADLINES-
First Semi-Annual Monitoring Period: January 1 -June 30,2019
Subsequent Semi-Annual Monitoring Periods: April 1 —September 30&October 1 —March 31
Semi-Annual Monitoring Reports: Due July 31,2019&January 31,2020& subsequent years
First Annual Compliance Period: January 1 —December 31,2019
Subsequent Annual Compliance Periods: October 1 —September 30
Annual Compliance Certification: Due November 1, 2014& subsequent years
Note that the Semi-Annual Monitoring Reports and Annual Compliance report must be received at the
Division office by 5:00 p.m. on the due date. Postmarked dates will not be accepted for the purposes of
determining the timely receipt of those reports.
TABLE OF CONTENTS:
SECTION I- General Activities and Summary 1
1. Permitted Activities 1
2. Alternative Operating Scenarios for Turbines—version 01/23/2013 2
3. Alternative Operating Scenarios for Engines—version 10/12/2013 9
4. Prevention of Significant Deterioration (PSD) 10
5. Accidental Release Prevention Program(112(r)) 10
6. Compliance Assurance Monitoring(CAM) 10
7. Summary of Emission Units 11
SECTION II - Specific Permit Terms 12
1. Points 015 & 024: Three Solar Taurus 70-10302S Combustion Turbines 12
2. Point 018 (H-8701 and H-8702): Heatec, Natural Gas Fired Hot Oil Heaters, Each Rated at
43.79 MMBtu/hr 19
3. Point 022 - Flare Stack (FL-8921) and CO2 Vent (ST-8931): CO2 Treatment Plant — Glycol
Dehydrator and Amine Unit, Each Rated at 300 MMscf/day 26
4. Point 023 (EG-6141): Caterpillar, Model No. 3516B LE, Emergency Generator Rated at 1557
hp 40
5. Portable Monitoring (06/26/2014) 43
6. Point 025 (H-8721) — Two Maxon, Model Tube-o-Flame, Reboiler Burners Rated at 3.8
MMBtu/hr each(Total of 7.6 MMBtu/hr) 44
7. Additional Colorado Regulation No. 7 Requirements 46
SECTION III -Permit Shield 47
1. Specific Non-Applicable Requirements 47
2. General Conditions 47
3. Stream-lined Conditions 47
SECTION IV- General Permit Conditions (version 01/21/2020) 49
A. Appendix A-Inspection Information 63
A.I. Directions to Plant: 63
A.II. Safety Equipment Required: 63
A.III. Facility Plot Plan: 63
A.IV. List of Insignificant Activities- 63
B. Appendix B—Reporting Requirements and Definitions 66
B.I. Appendix B—Monitoring and Permit Deviation Report- Part I 70
B.II. Appendix B—Monitoring and Permit Deviation Report- Part II 72
B.III. Appendix B —Monitoring and Permit Deviation Report- Part III 74
C. Appendix C—Required Format for Annual Compliance Certification Reports 75
D. Appendix D—Notification Addresses (May 24,2019 Version) 78
D.I. Air Pollution Control Division 78
D.II. United States Environmental Protection Agency 78
E. Appendix E—Permit Acronyms 79
•
F. Appendix F—Permit Modifications 81
Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC
Colorado Operating Permit Cheyenne Plains Compressor Station
Permit# 05OPWE281 Page 1
SECTION I - General Activities and Summary
1. Permitted Activities
1.1 The Cheyenne Plains Gas Pipeline Company, LLC, Cheyenne Plains Compressor Station is a natural gas
compression facility as defined under Standard Industrial Classification 4922. This facility is a mainline
compressor station. Its main function is to compress and transmit natural gas from the Wyoming area
east into Kansas. The sources addressed in this operating permit include three (3) natural gas fired
combustion turbines driving natural gas compressors. The facility also includes a CO2 Treatment Plant,
which consists of a triethylene glycol dehydrator and amine treatment unit. Emissions from the glycol
dehydrator still (regenerator)vent and flash tank and emissions from the amine unit flash tank are routed
to a flare to reduce VOC emissions. The amine unit regenerator vent is equipped with a SulfaTreat H2S
control system to reduce H2S emissions. There are also two (2) 43.79 MMBtu/hr natural gas fired
heaters associated with the amine unit and an emergency generator that are included in Section II of the
permit as significant emission units.
The Cheyenne Plains Compressor Station was constructed in 2004 at the site of an existing mainline
compressor station (Cheyenne Station), whose main function is to compress and transmit natural gas
from the Wyoming area to the Colorado Front Range area. As such the two facilities are considered a
single source for purposes of Prevention of Significant Deterioration (PSD)review requirements and
Title V permitting requirements. Equipment associated with the Cheyenne Compressor Station is
addressed in a separate Title V operating permit(95OPWE090).
The facility is located in Weld County on Highway 85 at Section 5, T11N, R66W (- 4 miles North of
Rockport). The area in which the plant operates is designated as attainment for all criteria pollutants.
There are two affected states within 50 miles of the plant: Wyoming and Nebraska. The following
Federal Class I designated area is within 100 kilometers of the plant: Rocky Mountain National Park.
1.2 Until such time as this permit expires or is modified or revoked, the Source is allowed to discharge air
pollutants from this facility in accordance with the requirements, limitations, and conditions of this
permit.
1.3 The 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
Colorado Regulation No. 3, Part C. These Part C procedures meet all applicable substantive New Source
Review requirements of Part B. Any revisions made using the provisions of Regulation No. 3, Part C
shall become new applicable requirements for purposes of this Operating Permit and shall survive
reissuance. This permit incorporates the applicable requirements (except as noted in Section II) from the
following construction permits: 03WE0910, 03WE0913, 03WE0916 and 04WE1390.
1.4 All conditions in this permit are enforceable by the United States Environmental Protection Agency
(EPA), 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 3.g (last paragraph), 14, 18 (as noted) & 30 (as noted); and Section II, Condition 7.1 & 7.2.
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC
Colorado Operating Permit Cheyenne Plains Compressor Station
Permit# 05OPWE281 Page 2
1.5 All information gathered pursuant to the requirements of this permit is subject to the Recordkeeping and
Reporting requirements listed under Condition 22 of the General Conditions in Section IV of this permit.
Either electronic or hard copy records are acceptable.
2. Alternative Operating Scenarios for Turbines—version 01/23/2013
2.1 Routine Turbine Component Replacements
The following physical or operational changes to the turbines in this permit are not considered a
modification for purposes of NSPS GG, major stationary source NSR/PSD, or Regulation No. 3, Part B.
Note that the component replacement provisions apply ONLY to those turbines subject to NSPS GG.
Neither pre-GG turbines nor post GG turbines (i.e. KKKK turbines) can use those provisions. In the
event that EPA promulgates amendments to Subparts GG and/or KKKK that further define or alter the
definition of component replacements that will not trigger modifications,the provisions of those rules
shall supersede the component replacement provisions listed below.
2.1.1 Replacement of stator blades, turbine nozzles,turbine buckets, fuel nozzles, combustion
chambers, seals, and shaft packings, provided that they are of the same design as the original.
2.1.2 Changes in the type or grade of fuel used, if the original gas turbine installation, fuel nozzles, etc.
were designed for its use.
2.1.3 An increase in the hours of operation (unless limited by a permit condition)
2.1.4 Variations in operating loads within the engine design specification.
2.1.5 Any physical change constituting routine maintenance, repair, or replacement.
Turbines undergoing any of the above changes are subject to all federally applicable and state-only
requirements set forth in this permit(including monitoring and record keeping), and shall be subject to
any shield afforded by this permit. If replacement of any of the components listed in (1) or(5) above
results in a change in serial number for the turbine, a letter explaining the action as well as a revised
APEN and appropriate filing fee shall be submitted to the Division within 30 days of the replacement.
Note that the repair or replacement of components must be of genuinely the same design. Except in
accordance with the Alternate Operating Scenario set forth below,the Division does not consider that
this allows for the entire replacement(or reconstruction) of an existing turbine with an identical new one
or one similar in design or function. Rather,the Division considers the repair or replacements to
encompass the repair or replacement of components at a turbine with the same (or functionally similar)
components.
2.2 Alternative Operating Scenarios
The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of
combustion turbines and turbine components has been reviewed in accordance with the requirements of
Regulation No. 3., Part A, Section IV.A, Operational Flexibility-Alternative Operating Scenarios,
Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC
Colorado Operating Permit Cheyenne Plains Compressor Station
Permit# 05OPWE281 Page 3
New Source Review and Prevention of Significant Deterioration, and it has been found to meet all
applicable substantive and procedural requirements. This permit incorporates and shall be considered a
Construction Permit for any turbine or turbine component replacement performed in accordance with
this AOS, and the permittee shall be allowed to perform such turbine or turbine component replacement
without applying for a revision to this permit or obtaining a new Construction Permit.
2.2.1 General Requirements for Turbine Replacements
The following AOS is incorporated into this permit in order to deal with a turbine breakdown or
periodic routine maintenance and repair of an existing onsite turbine that requires the use of a
temporary or permanent replacement turbine. The definitions of"Temporary" and"Permanent"
for each permitted unit are defined in Condition 2.2.7. The compliance demonstrations required
by this AOS are in addition to any compliance demonstrations or periodic monitoring required
by this permit.
All replacement turbines are subject to all federally applicable and state-only requirements set
forth in this permit(including monitoring and record keeping), and shall be subject to any shield
afforded by this permit.
The results of all tests and the associated calculations required by this AOS shall be submitted to
the Division within 30 calendar days of the test or within 60 days of the test if such testing is
required to demonstrate compliance with the NSPS requirements. Results of all tests shall be
kept on site for five (5) years and made available to the Division upon request.
2.2.2 Portable Analyzer Testing
Note: In some cases there may be conflicting and/or duplicative testing requirements due to
overlapping Applicable Requirements. In those instances, please contact the Division Field
Services Unit to discuss streamlining the testing requirements.
Note that the testing required by this Condition may be used to satisfy the periodic testing
requirements specified by the permit for the relevant time period (i.e. if the permit requires
quarterly portable analyzer testing,this test conducted under the AOS will serve as the quarterly
test and an additional portable analyzer test is not required for another three months).
The permittee may conduct a reference method test, in lieu of the portable analyzer test required
by this Condition, if approved in advance by the Division.
The permittee shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the
exhaust from the replacement turbine using a portable flue gas analyzer within seven (7) calendar
days of commencing operation of the replacement turbine.
All portable analyzer testing required by this permit shall be conducted using the most current
version of the Division's Portable Analyzer Monitoring Protocol as found on the Division's
website. Results of the portable analyzer tests shall be used to monitor the compliance status of
this unit.
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC
Colorado Operating Permit Cheyenne Plains Compressor Station
Permit# 05OPWE281 Page 4
For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the
results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating
hours in the month or year(whichever applies) in order to monitor compliance. If a source is not
limited in its hours of operation the test results will be multiplied by the maximum number of
hours in the month or year(8760), whichever applies.
For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-
hr) or concentration based (ppmvd @ 15% O2)that the existing unit is currently subject to or the
replacement turbine will be subject to, the results of the test shall be converted to the appropriate
units as described in the above-mentioned Portable Analyzer Monitoring Protocol document.
If the portable analyzer results indicate compliance with both the NOX and CO emission
limitations, in the absence of credible evidence to the contrary, the source may certify that the
turbine is in compliance with both the NOX and CO emission limitations for the relevant time
period.
Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the
contrary, if the portable analyzer results fail to demonstrate compliance with either the NOX or
CO emission limitations, the turbine will be considered to be out of compliance from the date of
the portable analyzer test until a portable analyzer test indicates compliance with both the NOX
and CO emission limitations or until the turbine is taken offline.
2.2.3 Recordkeeping Requirements for Turbine Replacements
The permittee shall maintain a log on-site to contemporaneously record the start and stop date of
any turbine replacement,the manufacturer and serial number of the turbine(s)that are replaced
during the term of this permit, and the manufacturer and serial number of the replacement
turbine.
2.2.4 Specific Requirements for Temporary Replacements
The permittee may temporarily replace an existing turbine covered by this permit as specified in
Condition 2.2.7 with the exact make and model turbine without modifying this permit so long as
the replacement turbine complies with the emission limitations and other requirements applicable
to the original turbine as well as any new applicable requirements for the replacement turbine.
Measurement of emissions from the temporary replacement turbine shall be made as set forth in
Condition 2.2.2.
The permittee may temporarily replace a grandfathered or permit exempt turbine or a turbine that
is not subject to emission limits without modifying this permit. In this circumstance, potential
annual emissions of NOX and CO from the temporary replacement turbine must be less than or
equal to the potential annual emissions of NOX and CO from the original grandfathered or permit
exempt turbine or for the turbine that is not subject to emission limits, as determined by applying
appropriate emission factors (e.g. AP-42 or manufacturer's emission factors).
2.2.5 Specific Requirements for Permanent Replacements
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC
Colorado Operating Permit Cheyenne Plains Compressor Station
Permit# 05OPWE281 Page 5
The permittee may permanently replace an existing turbine covered by this permit as specified in
Condition 2.2.7 with the exact make and model turbine without modifying this permit so long as
the replacement turbine complies with the emission limitations and other requirements applicable
to the original turbine as well as any new applicable requirements for the replacement turbine.
Measurement of emissions from the temporary replacement turbine shall be made as set forth in
Condition 2.2.2.
This AOS cannot be used for permanent turbine replacement of a grandfathered or permit
exempt turbine or a turbine that is not subject to emission limits.
This AOS cannot be used in areas designated as non-attainment or attainment/maintenance for
VOC, CO,NOX SO2 and PMio.
The AOS cannot be used for the permanent replacement of an entire turbine at any source that is
an existing major stationary source for a regulated NSR Pollutant unless the existing turbine has
federally enforceable emission limits that are below the significance levels in Reg 3, Part D,
II.A.44.
This AOS cannot be used for the permanent replacement of an entire turbine at any source
where: (1)the facility-wide potential to emit of CO2e is equal to or greater than 100,000 tpy of
CO2e, and (2)the originally permitted turbine does not have a CO2e emission limit below 75,000
tpy CO2e. In the absence of a numerical CO2e limit,the PTE of CO2e should be based on 8760
hours per year of operation and emission factors from AP-42 Chapter 3.1, 40 CFR Part 75,
and/or other factors approved by the Division.
Nothing in this AOS shall preclude the Division from taking an action, based on any permanent
turbine replacement(s), for circumvention of any state or federal PSD/NANSR requirement.
Additionally, in the event that any permanent turbine replacement(s) constitute(s) a
circumvention of applicable PSD/NANSR requirements, nothing in this AOS shall excuse the
permittee from complying with PSD/NANSR and applicable permitting requirements.
2.2.5.1 Turbines Relocated into Colorado from Outside of Colorado
Note that under the provisions of Regulation No. 6, Part B, Section I.B., as referenced in Part A,
the following turbines that are exempt from federal NSPS requirements based on dates of
construction, reconstruction or relocation that occurred outside of the State of Colorado will
become subject to NSPS requirements after relocation into the State as follows:
a. Replacement Units Previously Exempt from NSPS GG
This condition applies to units that originally commenced construction outside of
Colorado prior to October 3, 1977 and have not been reconstructed or modified
after October 3, 1977.
If these units were previously installed within the State of Colorado during the
applicability dates of NSPS Subpart GG (October 3, 1977 — February 18, 2005),
they will be subject to Subpart GG upon relocation into the State of Colorado. The
applicable requirements of Subpart GG shall be determined based on the date on
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC
Colorado Operating Permit Cheyenne Plains Compressor Station
Permit# 05OPWE281 Page 6
which the unit was previously installed within the State of Colorado.
If these units were not previously installed within the State of Colorado during the
applicability dates of NSPS Subpart GG, they will be subject to the requirements
for new units under Subpart KKKK upon commencement of construction in
Colorado.
b. Units Subject to NSPS Subpart GG
This condition applies to units that originally commenced construction outside of
Colorado after October 3, 1977 but prior to February 18, 2005 and have not been
reconstructed or modified after February 18, 2005. These units will remain subject
to NSPS Subpart GG upon relocation into Colorado, and the applicable
requirements under Subpart GG shall not be changed or re-determined based on the
date of relocation into Colorado.
c. Units subject to NSPS Subpart KKKK
This condition applies to units that originally commenced construction outside of
Colorado after February 18,2005. These units will remain subject to NSPS Subpart
KKKK upon relocation into Colorado, and the applicable requirements under
Subpart KKKK shall not be changed or re-determined based on the date of
relocation into Colorado.
2.2.5.2 Air Pollutant Emission Notice (APEN) Submittals
An APEN that includes the specific manufacturer, model, and serial number of any permanent
replacement turbine shall be filed with the Division for the permanent replacement turbine within
14 calendar days of commencing operation of the replacement turbine. The APEN shall be
accompanied by the appropriate APEN filing fee and a cover letter explaining that the permittee
is exercising an alternative operating scenario and is installing a permanent replacement turbine.
The permittee shall agree to pay fees based on the normal permit processing rate for review of
information submitted to the Division in regard to any permanent turbine replacement.
The owner or operator shall include, with the APEN, a regulatory applicability analysis to
address the requirements of the replacement unit. At a minimum,the applicability analysis shall
include:
• An analysis of any requirements applicable to the replacement turbine that
differ from those applicable to the permitted unit. Applicable requirements
include, but are not limited to, Federal NSPS, MACT and/or Colorado Air
Quality Control Commission regulations. For example, if an original unit that
qualifies as a reconstructed gas turbine subject to an NSPS KKKK NOx limit
of 150 ppm is replaced with a Subpart KKKK unit that has not been modified
or reconstructed, the NOx limit of the replacement unit will be 42 ppm. The
analysis should also address any testing, monitoring, recordkeeping and
reporting differences between the original and replacement units.
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC
Colorado Operating Permit Cheyenne Plains Compressor Station
Permit# 05OPWE281 Page 7
• The applicability determination shall list the most recent date that the turbine
was modified or reconstructed as per the definitions in 40 CFR §§60.2 and
60.14. If the turbine has never been modified or reconstructed,the
applicability determination shall include a statement to verify that no
modifications or reconstructions have occurred.
• The applicability determination shall also list the most recent date that the
turbine was overhauled, and an explanation of whether the overhaul qualifies
or does not qualify as a modification or reconstruction. Supporting
documentation, including cost estimates shall be submitted for those that do
not qualify as reconstructions.
• The applicability analysis must be certified by either 1) for Operating Permits,
a Responsible Official as defined in Colorado Regulation No. 3, Part A,
Section I.B.38, or 2) for Construction and General Permits,the person legally
authorized to act on behalf of the source. This signed certification document
must be packaged with the documents being submitted. The certification shall
include the following statement:
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.
2.2.6 Additional Sources
The replacement of an existing turbine with a new turbine is viewed by the Division as the
installation of a new emissions unit, not"routine replacement" of an existing unit. The AOS is
therefore essentially an advanced construction permit review. The AOS cannot be used for
additional new emission points for any site; a turbine that is being installed as an entirely new
emission point and not as part of an AOS-approved replacement of an existing onsite turbine has
to go through the appropriate Construction/Operating permitting process prior to installation.
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC
Colorado Operating Permit Cheyenne Plains Compressor Station
Permit# 05OPWE281 Page 8
2.2.7 Allowable Replacements
Table 1 —Turbine Replacements Allowed by the AOS—Units Relocated from Outside the State of
Colorado
Permitted Turbine Allowable Replacements'
Point Applicable NSPS
Make/Model Requirement Status/Type Restrictions
Units that predate NSPS
Subpart GG but were
previously installed within the
CP CG-7101 state of Colorado during the Temporary replacement units may operate up to
CP CG-7201 Subpart GG applicability 90 days in any 12 month period2
CP CG-7301 period(Oct 4, 1977—Feb 18, Permanent replacement units may operate more
2005) than 90 days in any 12 month period'
Subpart GG
Solar Taurus -OR-
Natural Gas Fired Units subject to Subpart GG
Turbines,Model Temporary replacement units may operate up to
No.70-10302S 270 days in any 12 month period2
All Others
Permanent replacement units:not allowed(new
permit or modification required)
Note 1:Replacement unit must be of the same make and model as the permitted unit
Note 2:The temporary replacement period is the total number of operating days that the replacement unit may operate in the same service.
If the temporary replacement turbine operates only part of a day,that day counts toward the total.Temporary replacement units shall
comply with all requirements in Conditions 2.2.1,2.2.2 and 2.2.3,and with the specific requirements for temporary replacements in
Condition 2.2.4.
Note 3:Permanent replacement units shall comply with all requirements in Conditions 2.2.1,2.2.2 and 2.2.3,and with the specific
requirements for permanent replacements in Condition 2.2.5.
Table 2—Turbine Replacements Allowed by the AOS—Units Relocated from Within the State of
Colorado
Permitted Turbine Allowable Replacements'
Point Applicable NSPS
Make/Model Requirement Status/Type Restrictions
CP CG-7101 Temporary replacement units may operate up to
CP CG-7201 90 days in any 12 month period2
Units subject to Subpart GG
CP CG-7301 Permanent replacement units may operate more
than 90 days in any 12 month period3
Subpart GG
Solar Taurus Temporary replacement units may operate up to
Natural Gas Fired 270 days in any 12 month period2
All Others
Turbines,Model Permanent replacement units:not allowed(new
No.70-10302S permit or modification required)
Note 1:Replacement unit must be of the same make and model as the permitted unit
Note 2:The temporary replacement period is the total number of operating days that the replacement unit may operate in the same service.
If the temporary replacement turbine operates only part of a day,that day counts toward the total.Temporary replacement units shall
comply with all requirements in Conditions 2.2.1,2.2.2 and 2.2.3,and with the specific requirements for temporary replacements in
Condition 2.2.4.
Note 3:Permanent replacement units shall comply with all requirements in Conditions 2.2.1,2.2.2 and 2.2.3,and with the specific
requirements for permanent replacements in Condition 2.2.5.
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air.Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC
Colorado Operating Permit Cheyenne Plains Compressor Station
Permit# 05OPWE281 Page 9
3. Alternative Operating Scenarios for Engines—version 10/12/2013
The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of
natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the
requirements of Regulation No. 3.,Part A, Section IV.A, Operational Flexibility-Alternative Operating
Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major
Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been
found to meet all applicable substantive and procedural requirements. This permit incorporates and shall
be considered a Construction Permit for any engine replacement performed in accordance with this
AOS, and the permittee shall be allowed to perform such engine replacement without applying for a
revision to this permit or obtaining a new Construction Permit.
The following AOS contains the provisions for temporary replacements of engines that are not subject to
emission limits and periodic monitoring requirements.
3.1 Engine Replacement
The following AOS is incorporated into this permit in order to deal with a compressor or other engine
breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use
of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service
for 90 operating days or less in any 12 month period. "Permanent" is defined as in the same service for
more than 90 operating days in any 12 month period. The 90 days is the total number of days that the
engine is in operation. If the engine operates only part of a day, that day shall count as a single day
towards the 90-day total. The compliance demonstrations and any periodic monitoring required by this
AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit.
All replacement engines are subject to all federally applicable and state-only requirements set forth in
this permit(including monitoring and record keeping), and shall be subject to any shield afforded by this
permit.
The results of all tests and the associated calculations required by this AOS shall be submitted to the
Division within 30 calendar days of the test or within 60 days of the test if such testing is required to
demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for
five (5)years and made available to the Division upon request.
The permittee shall maintain a log on-site and contemporaneously record the start and stop date of any
engine replacement,the manufacturer, date of manufacture, model number, horsepower, and serial
number of the engine(s)that are replaced during the term of this permit, and the manufacturer, model
number, horsepower, and serial number of the replacement engine.
3.1.1 The permittee may temporarily replace a grandfathered or permit exempt engine or an engine
that is not subject to emission limits without modifying this permit. In this circumstance,
potential annual emissions of NOX and CO from the temporary replacement engine must be less
than or equal to the potential annual emissions of NOX and CO from the original grandfathered or
permit exempt engine or for the engine that is not subject to emission limits, as determined by
applying appropriate emission factors (e.g. AP-42 or manufacturer's emission factors).
Operating Permit#05OPWE281 First Issued: October 1,2007
Renewed: DRAFT
Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC
Colorado Operating Permit Cheyenne Plains Compressor Station
Permit# 05OPWE281 Page 10
3.2 Additional Sources
The replacement of an existing engine with a new engine is viewed by the Division as the installation of
a new emissions unit, not"routine replacement" of an existing unit. The AOS is therefore essentially an
advanced construction permit review. The AOS cannot be used for additional new emission points for
any site; an engine that is being installed as an entirely new emission point and not as part of an AOS-
approved replacement of an existing onsite engine has to go through the appropriate
Construction/Operating permitting process prior to installation.
Table 1 -Internal Combustion Engine Information for AOS
Emission Replacement Engine Periodic Subject to
Point Monitoring CAM?
CP EG- Caterpillar,Model No.3516B LE,4-Cycle Lean
6141 Bum Natural Gas-Fired Internal Combustion N/A No
Engine,rated at 1557 hp and 10.95 MMBtu/hr.
4. Prevention of Significant Deterioration (PSD)
4.1 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 for NOR, CO and VOC). Future modifications at
this facility resulting in a significant net emissions increase (see Reg 3, Part D, Sections II.A.27 and 44)
for any pollutant as listed in Regulation No. 3, Part D, Section II.A.44 or a modification which is major
by itself(i.e. a Potential to Emit of>250 TPY of any pollutant listed in Regulation No. 3, Part D,
Section II.A.44) may result in the application of the PSD review requirements.
4.2 The following Operating Permit is associated with this facility for purposes of determining the
applicability of PSD regulations:
4.2.1 95OPWE090 (Cheyenne Compressor Station)
5. Accidental Release Prevention Program (112(r))
5.1 Based on the information provided by the Source,this facility is not subject to the provisions of the
Accidental Release Prevention Program in Section 112(r) of the Federal Clean Air Act(CAA).
6. Compliance Assurance Monitoring (CAM)
6.1 The following emission points at this facility use a control device to achieve compliance with an
emission limitation or standard to which they are subject and have pre-control emissions that exceed or
are equivalent to the major source threshold. They are therefore subject to the provisions of the CAM
program as set forth in 40 CFR Part 64, as adopted by reference in Colorado Regulation No. 3, Part C,
Section XIV:
The glycol dehydrator is not subject to CAM since at the time the CAM plan was required the Title V
permit specified a continuous compliance determination method (40 CFR Part 64 § 64.2(b)(1)(vi), as
adopted by reference in Colorado Regulation No. 3, Part C, Section XIV).
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC
Colorado Operating Permit Cheyenne Plains Compressor Station
Permit# 05OPWE281 Page 11
All other units at the facility either have uncontrolled emissions below CAM applicability thresholds, or
do not use devices considered to be control devices for the purposes of CAM applicability.
7. Summary of Emission Units
7.1 The emissions units regulated by this permit are the following:
Facility AIRS ID Description Startup Date Pollution Control
ID Device
CP CG- Solar Taurus Natural Gas Fired Turbine,Model No.70-10302S,
Engine Serial No.OHC10-B8166.The turbine is rated at 9,816 hp
7101
and 71.42 mmBtu/hr.Package Skid Serial Number TC04639. December Dry Low NO„
015 15,2004 Combustion
CP CG- Solar Taurus Natural Gas Fired Turbine,Model No. 70-10302S, System
7201 Engine Serial No.OHL09-B4243.The turbine is rated at 9,816 hp
and 71.42 mmBtu/hr.Package Skid Serial Number TC04638.
CP CG-
Solar Taurus Natural Gas Fired Turbine,Model No.70- 10302S, October 29 Dry Low NO„
024 Engine Serial No.OHB16-B8446.The turbine is rated at 9,816 hp Combustion
7301 and 71.42 mmBtu/hr.Package Skid Serial Number TC05362. 2004 System
Heatec,Model No.VHC1-16010-40-G,Serial No.04-074-
H-8701 151,Natural Gas Fired Hot Oil Heater,Rated at 43.79 mmBtu/hr.
This heater is part of the amine treatment unit January 30, Low NO),
018 2005 Burners
Heatec,Model No.VHC1-16010-40-G,Serial No.04-074-
H-8702 152,Natural Gas Fired Hot Oil Heater,Rated at 43.79 mmBtu/hr.
This heater is part of the amine treatment unit
Flare Vent:Emissions from the triethylene glycol dehydrator
regenerator(still)vent and flash tank and the amine unit flash tank
FL-8921 022 are routed to the flare.The glycol dehydrator and amine unit are January 30, Air-Assisted,
each rated at 300 mmSCF/day.The flare is rated at 13.54 2005 Elevated Flare
mmBtu/hr.
ST-8931 021 Amine Unit Regenerator(CO2)Vent.Amine unit is rated at January 30, SulfaTreat H2S
300 mmSCF/day. 2005 Control System
Caterpillar,Model No.3516B LE,Serial No.CTW00511,4-
CP EG- Cycle Lean Burn Natural Gas-Fired Internal Combustion December
6141 023 Engine,rated at 1557 hp and 10.95 mmBtu/hr.This engine is 2004 None
used to drive an emergency generator.
Maxon Tube-o-Flame Natural Gas Fired Reboiler burners,
associated with the glycol dehydrator listed under Facility ID FL- January 30,
H-8721 025 8921.The unit consists of two burners with a rating of 3.8 2005 None
MMBtu/hr or each burner.SN:H8721-101387
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC
Colorado Operating Permit Cheyenne Plains Compressor Station
Permit# 05OPWE281 Page 12
SECTION II - Specific Permit Terms
1. Points 015 & 024: Three Solar Taurus 70-10302S Combustion Turbines
CG-7101, S/N OHC10-B8166 (Package Skid Serial Number TC04639)
CG-7201, S/N OHL09-B4243 (Package Skid Serial Number TC04638)
CG-7301, S/N OHB16-B8446 (Package Skid Serial Number TC05362)
Unless Otherwise Specified Limitations Apply to Each Turbine
Permit Compliance Monitoring
Parameter Condition Limitation Emission
Number Factor Method Interval
BACT 1.1 See Condition 1.1
Requirements
CG-7101 &7201:24.5 ppmvd at 15%
O2,except as provided for below:
CG-7301: 15 ppmvd at 15%O2,except as Recordkeeping
provided for below: See and Calculation Monthly
NO„ 1 2 All Turbines: ° Condition
-20 F<T<0°F:42 ppmvd at 15%O2
T<-20°F: 120 ppmvd at 15%O2 1.2 Portable Flue Gas Quarterly
All limits on a 1-hr average Analyzer
CG-7101 &7201:31.6 tons/yr each
CG-7301:20.1 tons/yr
CG-7101 &7201:48.8 ppmvd at 15%
O2,except as provided for below:
CG-7301:25 ppmvd at 15%O2,except as Recordkeeping
provided for below: See and Calculation Monthly
All Turbines:
CO 1.2 Condition
-20°F<T<0°F: 100 ppmvd at 15%O2
T<-20°F: 150 ppmvd at 15%O2 1.2 Portable Flue Gas Quarterly
All limits on a 1-hr average Analyzer
CG-7101 &7201: 38.5 tons/yr each
CG-7301:20.9 tons/yr
All Turbines:
3 ppmvd at 15%O2,except as provided
for below: See Condition 1.2.1
-20°F<T<0°F:5 ppmvdat 15%O2
VOC 1.2 T<-20°F: 8 ppmvd at 15%O2
All limits on a 1-hr average
See Recordkeeping
11.3 tons/year each Condition and Calculation Monthly
1.2.2
Natural Gas 1.3 661.5 MMscf/year Recordkeeping p S Monthly
Consumption
Table Continues to Next Page
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC
Colorado Operating Permit Cheyenne Plains Compressor Station
Permit# 05OPWE281 Page 13
Permit Compliance Monitoring
Parameter Condition Limitation Emission
Number Factor Method Interval
150 ppmvd @ 15%O2 OR Use of Fuel Only Pipeline
Which Contains Less than 0.8 Weight% Quality Natural
Sulfur Gas is Used as
SO2 1.4 Fuel Restriction Fuel
0.8 lbs/MMBtu
Only Pipeline
0.165 Ibs/NIlMIBtu ' Fuel Restriction Quality Natural
Gas is Used as
PM
Fuel
1.5
2.10 tons/year each 6.6 x 10-3 Recordkeeping Monthly
lbs/MMBtu and Calculation
6.6
PMio 2.10 tons/year each x 10 3 Recordkeeping
Monthly
lbs/MMBtu and Calculation
ASTM Methods
Heat Content
H Natural Gas 1.6 or In-Line Gas Semi-Annual
of Chromatograph
Not to Exceed 20%Except as Provided Only Pipeline
for Below
Quality Natural
Opacity 1.7 For Startup-Not to Exceed 30%,for a Fuel Restriction
Gas is Used as
Period or Periods Aggregating More Than Six Fuel
(6)Minutes in any 60 consecutive Minutes
NSPS General 1 8 See Condition 1.8
Provisions
1.1 Each turbine is subject to the requirements of the Prevention of Significant Deterioration (PSD)
Program. Best Available Control Technology (BACT) shall be applied for control of Nitrogen Oxides
(NOx), Carbon Monoxide (CO) and Volatile Organic Compounds (VOC). BACT has been determined to
be as follows:
1.1.1 BACT for NOx has been determined to be SoLoNOX (dry low NOx (DLN)) combustion
technology for turbine CG-7101 and CG-7201 and SoLoNOX II (DLN) combustion technology
for turbine CG-7301 with emission limits as identified in Condition 1.2.1.1 (Colorado
Construction Permits 03WE0910 and 04WE1390).
1.1.2 BACT for CO has been determined to be good combustion practices with emission limits as
identified in Condition 1.2.1.2 (Colorado Construction Permits 03WE0910 and 04WE1390).
1.1.3 BACT for VOC has been determined to be good combustion practices and use of pipeline quality
natural gas as fuel with emission limits as identified in Condition 1.2.1.3 (Colorado Construction
Permits 03WE0910 and 04WE1390).
1.2 Nitrogen Oxide (NOx), Carbon Monoxide (CO) and Volatile Organic Compound (VOC) emissions from
this turbine are subject to the following requirements:
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC
Colorado Operating Permit Cheyenne Plains Compressor Station
Permit# 05OPWE281 Page 14
1.2.1 For purposes of BACT NON, CO and VOC are subject to the following limitations (Colorado
Construction Permits 03WE0910 and 04WE1390). All limitations are at 15% O2, on a 1-hr
average.
1.2.1.1 Except as provided for below,NON emissions from turbines CG-7101 and CG-7201
shall not exceed 24.5 ppmvd and NON emissions from turbine CG-7301 shall not
exceed 15 ppmvd.
a. When the ambient temperature is less than 0 °F but greater than or equal to—20 °
F,NON emissions shall not exceed 42 ppmvd.
b. When the ambient temperature is less than—20 °F,NON emissions shall not
exceed 120 ppmvd.
1.2.1.2 Except as provided for below, CO emissions from turbines CG-7101 and CG-7201
shall not exceed 48.8 ppmvd and CO emissions from turbine CG-7301 shall not
exceed 25 ppmvd.
a. When the ambient temperature is less than 0 °F but greater than or equal to—20 °
F, CO emissions shall not exceed 100 ppmvd.
b. When the ambient temperature is less than—20 °F, CO emissions shall not exceed
150 ppmvd.
1.2.1.3 Except as provided for below, VOC emissions shall not exceed 3 ppmvd.
a. When the ambient temperature is less than 0 °F but greater than or equal to—20 °
F, VOC emissions shall not exceed 5 ppmvd.
b. When the ambient temperature is less than—20 °F, VOC emissions shall not
exceed 8 ppmvd.
1.2.1.4 The source shall monitor the number of hours that each turbine operates when the
ambient temperature meets the criteria in Conditions 1.2.1.1a& 1.2.1.1b, 1.2.1.2a&
1.2.1.2b and 1.2.1.3a& 1.2.1.3b above. Hours of turbine operation when the ambient
temperatures are below 0 °F and—20 °F, as specified above, shall be monitored and
recorded in a log to be made available to the Division upon request.
Portable monitoring shall be conducted quarterly in accordance with the requirements in Condition 5 to
monitor compliance with the NON and CO BACT limits. At least annually, such portable monitoring
shall be conducted at the temperatures specified in Conditions 1.2.1.1a& 1.2.1.1b and 1.2.1.2a&
1.2.1.2b above, unless ambient conditions or extended periods at those temperatures are not sufficient to
conduct the monitoring. In the event that it is not feasible to conduct a portable monitoring test at the
temperatures specified in Conditions 1.2.1.1a& 1.2.1.1b and 1.2.1.2a& 1.2.1.2b, due to ambient
conditions or insufficient time, a written explanation shall be submitted with the annual compliance
certification describing the reasons that portable monitoring was not conducted.
In the absence of credible evidence to the contrary, compliance with the VOC BACT limit is presumed
provided that the natural gas used as fuel meets the requirements in Condition 1.4.1.
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC
Colorado Operating Permit Cheyenne Plains Compressor Station
Permit# 05OPWE281 Page 15
1.2.2 NOR, CO and VOC emissions shall not exceed the annual emission limitations stated above
(Colorado Construction Permits 03WE0910 and 04WE1390 as modified under the provisions of
Section I, Condition 1.3,to revise the CO emissions as indicated on the APEN received on
March 30, 2007). Compliance with the emission limitations shall be monitored as follows:
1.2.2.1 Except as provided below, the emission factors listed in the table below(from the
manufacturer)have been approved by the Division and shall be used to calculate
emissions from the turbines as follows:
NO, CO VOC
T> 0 °F: T> 0 °F: T>0 °F:
CG-7101 & CG-7201: CG-7101 & CG-7201: 0.035 lb/mmBtu
0.098 lb/mmBtu 0.119 lb/mmBtu -20 °F <T< 0 °F:
CG-7301: 0.060 CG-7301: 0.061 0.070 lb/mmBtu
lb/mmBtu lb/mmBtu T<-20 °F:
-20 °F <T< 0 °F: -20 °F <T <0 °F: 0.105 lb/mmBtu
0.177 lb/mmBtu 0.257 lb/mmBtu
T<-20 °F: T<-20 °F:
0.504 lb/mmBtu 0.384 lb/mmBtu
Monthly emissions shall be calculated by the end of the subsequent month for each turbine using
the above emission factors, the monthly natural gas consumption and the lower heating value of
the gas, as specified in Condition 1.6, in the equation below:
Tons _ 1/ Ibs MMscf MMBtu ton
Month = EF\MMBtu� x Fuel Use(Month)
x Fuel Heat Content(MMtu) x (too°lb)
Monthly emissions from each turbine shall be used in a twelve-month rolling total to monitor
compliance with the annual limitations. Each month a new twelve month total shall be calculated
using the previous twelve months' data.
1.2.2.2 Portable Monitoring shall be conducted quarterly in accordance with the requirements
in Condition 5 to monitor compliance with the NO,and CO emission limitations.
Note that the second to the last paragraph in Condition 5 (apply for a permit modification within
60 days if the portable analyzer test indicates that the emission rates/factors are greater than the
emission rates/factors identified in the permit) does not apply to these emission units.
1.3 Natural gas consumption for each turbine shall not exceed the limitations stated above (Colorado
Construction Permits 03WE0910 and 04WE1390).Natural gas consumption shall be recorded monthly
using each turbine's fuel meter. Monthly natural gas consumption shall be used in a twelve month
rolling total to monitor compliance with the annual limitations. Each month, a new twelve month total
shall be calculated using the previous twelve months data.
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC
Colorado Operating Permit Cheyenne Plains Compressor Station
Permit# 05OPWE281 Page 16
1.4 Sulfur Dioxide (SO2) emissions shall not exceed the following limitations:
1.4.1 Each turbine shall meet one of the following requirements:
1.4.1.1 Sulfur Dioxide (SO2) emissions from the turbine shall not exceed 150 ppmvd at 15%
O2,
OR
1.4.1.2 No fuel, which contains sulfur in excess of 0.8 percent by weight, shall be used in this
combustion turbine (Colorado Construction Permits 03WE0910 and 04WE1390 and
40 CFR Part 60 Subpart GG §§ 60.333(a) & (b), as adopted by reference in Colorado
Regulation No. 6, Part A).
In the absence of credible evidence to the contrary, compliance with the above requirements is presumed
since only pipeline quality natural gas is permitted to be used as fuel in these turbines. The permittee
shall maintain records demonstrating that the natural gas burned meets the definition of pipeline quality
natural gas as defined in 40 CFR Part 72 (0.5 grains or less of total sulfur per 100 standard cubic feet).
The demonstration shall be made using the gas quality characteristics in a current, valid purchase
contract,tariff sheet or transportation contract for the gaseous fuel. These records shall be made
available to the Division upon request.
1.4.2 Sulfur Dioxide (SO2) emissions from each turbine shall not exceed 0.8 lbs/MMBtu, on a 3-hr
rolling average (Colorado Regulation No. I, Section VI.B.4.c.(i) and VI.B.2). In the absence of
credible evidence to the contrary, compliance with the SO2 limitations is presumed since only
pipeline quality natural gas is permitted to be used as fuel in these turbines.
1.5 Particulate Matter Emissions (PM and PM to) shall not exceed the following limitations:
1.5.1 Particulate Matter(PM) emissions from each turbine shall not exceed the above limitations
(Colorado Regulation No. 1, Section III.A.1). In the absence of credible evidence to the contrary,
compliance with the particulate matter emission limit is presumed since only pipeline quality
natural gas is permitted to be used as fuel in these turbines.
The numeric PM standard was determined using the design heat input of each turbine (71.42
MMBtu/hr) in the following equation:
PE= 0.5 x(FI)-°26 where: PE=particulate standard in lbs/MMBtu
FI =fuel input in MMBtu/hr
1.5.2 PM and PMio emissions shall not exceed the annual emission limitations stated above (Colorado
Construction Permits 03WE0910 and 04WE1390). Compliance with the emission limitations
shall be monitored as follows:
Monthly emissions shall be calculated by the end of the subsequent month for each turbine using
the emission factors specified in the table above,the monthly natural gas consumption and the
lower heating value of the gas, as specified in Condition 1.6, in the equation below:
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division Cheyenne Plains Gas Pipeline Company,LLC
Colorado Operating Permit Cheyenne Plains Compressor Station
Permit# 05OPWE281 Page 17
Tons _ ( lbs
l MMscf x ( ton
Month — EF\MMBtu/ X Fuel Use(Month X Fuel Heat Content("Btu)MMscf 2000 lb)
Monthly emissions from each turbine shall be used in a twelve-month rolling total to monitor
compliance with the annual limitations. Each month a new twelve month total shall be calculated
using the previous twelve months' data.
1.6 The Btu content of the natural gas used to fuel these turbines shall be verified semi-annually using the
appropriate ASTM Methods or equivalent, if approved in advance by the Division. In lieu of collecting a
sample,the Btu content of the natural gas may be determined using the in-line gas chromatograph to
determine the gas composition and the appropriate ASTM Methods or equivalent, if approved in
advance by the Division,to calculate the Btu content. The Btu content of the gas shall be calculated for
January and July, using the average composition of the gas as determined by the in-line gas
chromatograph for those months. The Btu content of the natural gas shall be based on the lower heating
value of the fuel.
If sampling is conducted, calculations of monthly emissions shall be made using the heat content derived
from the most recent required analysis. If the gas chromatograph data is used, calculations of monthly
emissions for January through June shall be made using the January average Btu content and
calculations of monthly emissions for July through December shall be made using the July average Btu
content.
1.7 Each turbine is subject to the following opacity requirements:
1.7.1 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air
pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section II.A.1).
1.7.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air
pollutant resulting from start-up which is in excess of 30%opacity for a period or periods
aggregating more than six (6) minutes in any sixty (60) consecutive minutes (Colorado
Regulation No. 1, Section II.A.4).
In the absence of credible evidence to the contrary, compliance with the above opacity requirements
shall be presumed since only pipeline quality natural gas is permitted to be used as fuel for these
turbines.
1.8 Each turbine is subject to the NSPS Subpart A, General Provisions requirements (Colorado Regulation
No. 6, Part A, Federal 40 CFR 60.1 through 60.19). Specifically,these units are subject to the following:
1.8.1 No owner or operator subject to the provisions of this part shall build, erect, install, or use any
article, machine, equipment or process, the use of which conceals an emission which would
otherwise constitute a violation of an applicable standard. Such concealment includes, but is not
limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a
standard which is based on the concentration of a pollutant in the gases discharged to the
atmosphere. (40 CFR § 60.12)
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC
Colorado Operating Permit Cheyenne Plains Compressor Station
Permit# 05OPWE281 Page 18
1.8.2 Records of startups, shutdowns, and malfunctions shall be maintained, as required under 40 CFR
§ 60.7.
1.8.3 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall,to the extent practicable, maintain and operate any affected facility including associated air
pollution control equipment in a manner consistent with good air pollution control practice for a
minimizing emissions. Determination of whether acceptable operating and maintenance
procedures are being used will be based on information available to the Administrator which
may include, but is not limited to, monitoring results, opacity observations, review of operating
and maintenance procedures, and inspection of the source. (40 CFR § 60.11(d)).
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC
Colorado Operating Permit Cheyenne Plains Compressor Station
Permit# 05OPWE281 Page 19
2. Point 018 (H-8701 and H-8702): Heatec,Natural Gas Fired Hot Oil Heaters,Each Rated at 43.79
MMBtu/hr
Unless Otherwise Specified Limitations Apply to Each Heater
Permit Limitation Compliance Monitoring
Condition Emission Factor
Parameter Number Method Interval
BACT Requirements 2.1 See Condition 2.1
0.045 lb/MMBtu,on a 1-hr Portable Flue Gas Annually
average Analyzer
NOX 2.2 - 0.0451b/MlViBtu
Recordkeeping&
8.9 tons/year each Monthly
Calculation
0.037 lb/MMBtu,on a 1-hr Portable Flue Gas Annually
average Analyzer
CO 2.2 0.037 lb/MMBtu
Recordkeeping& Monthly
7.3 tons/year each Calculation
0.016 lb/MA/Btu,on a 1-hr See Condition 2.2.1
average
VOC 2.2 0.016 lb/MMBtu Recordkeeping&
3.15 tons/year each Calculation Monthly
Natural Gas 2.3 416.8 MMscf/year Recordkeeping Monthly
Consumption
Only Natural
PM 2.4 0.185 lb/M1v1Btu Fuel Restriction Gas is Used as
Fuel
NSPS General 2 5 See Condition 2.5
Provisions
ASTM Methods or Semi-Annual
Heat Content of
Natural Gas 2.6 In-Line Gas
Chromatograph
Not to Exceed 20%Except
as Provided for Below
For Startup-Not to Only Natural
Opacity 2 7 Exceed 30%,for Fuel Restriction Gas is Used as
a Period or Periods Fuel
Aggregating More
than Six(6)Minutes in any
60 Consecutive Minutes
MACT Subpart
DDDDD 2.8 See Condition 2.8
Requirements
No Rain Caps or Other
Stack Requirements 2.9 Obstructions are Allowed Certification Annually
on the Exhaust Stacks for
these Heaters
Hours of Operation 2.10 Recordkeeping Monthly
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2.1 Each heater is subject to the requirements of the Prevention of Significant Deterioration (PSD)
Program. Best Available Control Technology (BACT) shall be applied for control of Nitrogen Oxides
(NOR), Carbon Monoxide (CO) and Volatile Organic Compounds (VOC). BACT has been determined to
be as follows:
2.1.1 BACT for NOR has been determined to be low NOx burners with emission limits as identified in
Condition 2.2.1.1 (Colorado Construction Permit 03WE0913).
2.1.2 BACT for CO has been determined to be good combustion practices with emission limits as
identified in Condition 2.2.1.2 (Colorado Construction Permit 03WE0913).
2.1.3 BACT for VOC has been determined to be good combustion practices with emission limits as
identified in Condition 2.2.1.3 (Colorado Construction Permit 03WE0913).
2.2 Nitrogen Oxide (NOR), Carbon Monoxide (CO) and Volatile Organic Compound (VOC) emissions from
each heater are subject to the following requirements:
2.2.1 For purposes of BACT NOx, CO and VOC are subject to the following limitations (Colorado
Construction Permit 03WE0913):
2.2.1.1 NOR emissions shall not exceed 0.045 lb/MMBtu, on a 1-hour average.
2.2.1.2 CO emissions shall not exceed 0.037 lb/MMBtu, on a 1-hour average.
2.2.1.3 VOC emissions shall not exceed 0.016 lb/MMBtu, on a 1-hour average.
Compliance with the NOR and CO emission limitations shall be monitored by conducting
portable monitoring annually in accordance with the requirements in Condition 5.
In the absence of credible evidence to the contrary compliance with the VOC BACT limits is
presumed since only pipeline quality natural gas is permitted to be used as fuel in these heaters.
2.2.2 NOR, CO and VOC emissions from each heater shall not exceed the annual emission limitations
stated above (Colorado Construction Permit 03WE0913). Monthly emissions from each heater
shall be calculated by the end of the subsequent month using the above emission factors (from
the manufacturer), the monthly fuel consumption and the lower heating value of the fuel, as
specified in Condition 2.6, in the equation below:
Tons Ibs MMscf MMBtu ton l
_
Month — EF MMBtu� x Fuel Use(Month x Fuel Heat Content MMscf� X (2000lb/
Monthly emissions from each heater shall be used in a twelve-month rolling total to monitor
compliance with the annual limitation. Each month a new twelve month total shall be calculated
using the previous twelve months' data.
2.3 Natural gas consumption from each heater shall not exceed the limitations stated above (Colorado
Construction Permit 03WE0913, as modified under the provisions of Section I, Condition 1.3,to allow
for use of a combined fuel meter instead of individual fuel meters for the hot oil heaters).Natural gas
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consumed in each heater shall be recorded monthly, as required by 40 CFR Part 60 Subpart Dc §
60.48c(g), as adopted by reference in Colorado Regulation No. 6, Part A.Natural gas use shall be
recorded monthly using the fuel meter associated with the two heaters and the supplemental flare fuel,
and allocation of fuel used by each heater shall be made using the equation shown below. Monthly
natural gas use for each heater shall be used in a twelve month rolling total to monitor compliance with
the annual limitation. Each month, a new twelve month total shall be calculated using the previous
twelve months data.
(MMscf) (MMscf) MMscfl X Hours OperationH
(
\Month/H \Month/Total — Month)Flare Hours operationHs7o1+H8702
Where:
(MMscf)
Month/ii = Fuel use for Heater H-8701 or H-8702,as applicable
(MMscf)
= Total fuel use recorded at the fuel meter
\Month/Total
(MMscf' Fuel use recorded at the flare supplemental fuel meter,as required by
Month/Flare Condition 3.12
Hours of operation for Heater H-8701 or H-8702,as applicable,as required
Hours OperationH — by Condition 2.10
Hours OpeartionH87oi+ = Hours of operation for H-8701 &H-8702 combined
H8702
2.4 Particulate matter emissions from each heater shall not exceed the below limitations (Colorado
Regulation No. 1, Section III.A.1). In the absence of credible evidence to the contrary, compliance with
the particulate matter emission limit is presumed since only pipeline quality natural gas is permitted to
be used as fuel in these heaters.
The numeric PM standard was determined using the design heat input of each heater(45 MMBtu/hr) in
the following equation:
PE=0.5 x (FI)-0.26 where: PE =particulate standard in lbs/MMBtu
FI =fuel input in MMBtu/hr
2.5 Each heater is subject to the NSPS Subpart A, General Provisions requirements (Colorado Regulation
No. 6, Part A, Federal 40 CFR 60.1 through 60.19). Specifically, these units are subject to, including,
but not limited to, the following:
2.5.1 No owner or operator subject to the provisions of this part shall build, erect, install, or use any
article, machine, equipment or process,the use of which conceals an emission which would
otherwise constitute a violation of an applicable standard. Such concealment includes, but is not
limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a
standard which is based on the concentration of a pollutant in the gases discharged to the
atmosphere (40 CFR § 60.12).
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2,5.2 Records of startups, shutdowns, and malfunctions shall be maintained, as required under 40 CFR
§ 60.7.
2.5.3 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall,to the extent practicable, maintain and operate any affected facility including associated air
pollution control equipment in a manner consistent with good air pollution control practice for
minimizing emissions. Determination of whether acceptable operating and maintenance
procedures are being used will be based on information available to the Administrator which
may include, but is not limited to, monitoring results, opacity observations, review of operating
and maintenance procedures, and inspection of the source (40 CFR § 60.11(d)).
2.6 The Btu content of the natural gas used to fuel these heaters shall be verified semi-annually using the
appropriate ASTM Methods or equivalent, if approved in advance by the Division. In lieu of collecting a
sample, the Btu content of the natural gas may be determined using the in-line gas chromatograph to
determine the gas composition and the appropriate ASTM Methods or equivalent, if approved in
advance by the Division,to calculate the Btu content. The Btu content of the gas shall be calculated for
October and April, using the average composition of the gas as determined by the in-line gas
chromatograph for those months. The Btu content of the natural gas shall be based on the lower heating
value of the fuel.
If sampling is conducted, calculations of monthly emissions shall be made using the heat content derived
from the most recent required analysis. If the gas chromatograph data is used, calculations of monthly
emissions for October through March shall be made using the October average Btu content and
calculations of monthly emissions for April through September shall be made using the April average
Btu content.
2.7 Each heater is subject to the following opacity requirements:
2.7.1 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air
pollutant which is in excess of 20%opacity (Colorado Regulation No. 1, Section II.A.1).
2.7.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air
pollutant resulting from start-up which is in excess of 30% opacity for a period or periods
aggregating more than six(6) minutes in any sixty (60) consecutive minutes (Colorado
Regulation No. 1, Section II.A.4).
In the absence of credible evidence to the contrary, compliance with the above opacity requirements
shall be presumed since only natural gas is permitted to be used as fuel for these heaters.
2.8 These heaters are subject to the requirements in 40 CFR Part 63 Subpart DDDDD, "National Emission
Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional
Boilers and Process Heaters", including, but not limited to,the following:
The requirements below reflect the current rule language as of the revisions to 40 CFR Part 63 Subpart
DDDDD published in the Federal Register on November 20, 2015. However, if revisions to this Subpart
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•
are published at a later date,the owner or operator is subject to the requirements contained in the revised
version of 40 CFR Part 63, Subpart DDDDD.
When do I have to comply with this subpart? (sC 63.7495)
2.8.1 If you have an existing boiler or process heater, you must comply with this subpart no later than
January 31, 2016, except as provided in 40 CFR 63.6(i) (§63.7495(b)).
2.8.2 You must meet the notification requirements in Condition Error! Reference source not found.
according to the schedule in Conditions Error! Reference source not found. and Error!
Reference source not found. and in subpart A of 40 CFR Part 63. Some of the notifications
must be submitted before you are required to comply with the emission limits and work practice
standards in this subpart(§63.7495(d)).
What emission limitations, work practice standards, and operating limits must I meet? (sC 63.7500)
2.8.3 You must meet the requirements in Conditions 2.8.3.1 and 2.8.3.2. You must meet these
requirements at all times the affected unit is operating (§63.7500(a)).
Boilers and process heaters in the units designed to bum gas I fuels subcategory are not subject
to the emission limits in Tables 1 and 2 or 11 through 13 to this subpart, or the operating limits in
Table 4 of Subpart DDDDD (§63.7500(e)). The work practice standards in Table 3 that apply to
these heaters are:
2.8.3.1 A new or existing boiler or process heater without a continuous oxygen trim system
and with heat input capacity of 10 million Btu per hour or greater: Conduct a tune-up
of the boiler or process heater annually as specified in § 63.7540 (40 CFR Part 63
Subpart DDDDD, Table 3, item 3).
2.8.3.2 At all times, you must operate and maintain any affected source including associated
air pollution control equipment and monitoring equipment, in a manner consistent
with safety and good air pollution control practices for minimizing emissions.
Determination of whether such operation and maintenance procedures are being used
will be based on information available to the Administrator that may include, but is
not limited to, monitoring results, review of operation and maintenance procedures,
review of operation and maintenance records, and inspection of the source
(§63.7500(a)(3)).
When must I conduct subsequent tune-ups? (63.7515)
2.8.4 You must conduct an annual performance tune-up according to 40 CFR 63.7540(a)(10), (11), or
(12), respectively. Each annual tune-up specified in 40 CFR 63.7540(a)(10) must be no more
than 13 months after the previous tune-up. (§63.7515(d)).
2.8.5 For affected sources that have not operated since the previous compliance demonstration and
more than one year has passed since the previous compliance demonstration, you must complete
a subsequent tune-up by following the procedures described in 40 CFR 63.7540(a)(10)(i)
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through (vi) and the schedule described in 40 CFR 63.7540(a)(13) for units that are not operating
at the time of their scheduled tune-up (§63.7515(g)).
How do I demonstrate continuous compliance with the work practice standards? (§63.7540)
2.8.6 You must demonstrate continuous compliance with the work practice standards in Condition
2.8.3 according to the following methods:
2.8.6.1 You must conduct an annual tune-up of the boiler or process heater to demonstrate
continuous compliance as specified in 40 CFR §§63.7540(a)(10)(i) through (vi)
(§63.7540(a)(10)).
2.8.6.2 If the unit is not operating on the required date for a tune-up,the tune-up must be
conducted within 30 calendar days of startup (§63.75401(a)(13)).
Notification, Reports, and Records
2,8.7 You must submit annual compliance reports as follows (§63.7550(b)):
2.8.7.1 Subsequent annual compliance reports must cover the applicable 1-year period from
January 1 to December 31.
2.8.7.2 Subsequent annual compliance reports must be postmarked or submitted no later than
January 31.
2.8.8 A compliance report must contain the information specified in §63.7550(c)(5)(i)through (iv) and
(xiv) (§63.7550(c)).
2.8.9 You must keep the following records:
2.8.9.1 A copy of each notification and report that you submitted to comply with this subpart,
including all documentation supporting any Initial Notification or Notification of
Compliance Status or compliance report that you submitted, according to the
requirements in § 63.10(b)(2)(xiv) (§63.7555(a)(1)).
2.8.9.2 Records of performance tests, fuel analyses, or other compliance demonstrations and
performance evaluations as required in § 63.10(b)(2)(viii) (§63.7555(a)(2)).
2.8.9.3 Your records must be in a form suitable and readily available for expeditious review,
according to § 63.10(b)(1) (§63.7560(a)).
2.8.9.4 As specified in § 63.10(b)(1), you must keep each record for 5 years following the
date of each occurrence, measurement, maintenance, corrective action, report, or
record (§63.7560(b)).
2.8.9.5 You must keep each record on site, or they must be accessible from on site (for
example, through a computer network), for at least 2 years after the date of each
occurrence, measurement, maintenance, corrective action, report, or record, according
to § 63.10(b)(1). You can keep the records off site for the remaining 3 years
(§63.7560(c)).
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What parts of the General Provisions apply to me? ('63.7565)
2.8.10 Table 10 of 40 CFR Part 63 Subpart DDDDD shows which parts of the General Provisions in §§
63.1 through 63.15 apply to you. (§ 63.7565) These requirements include but are not limited to
the following:
2.8.10.1 Prohibited activities in § 63.4.
2.8.10.2 Notification requirements in § 63.9.
2.9 No rain caps or other obstructions are allowed on the exhaust stacks for these heaters (Colorado
Construction Permit 03WE0913).
2.10 Hours of operation for the each heater shall be monitored and recorded monthly in a log that is
available to the Division upon request. The hours of operation shall be used to calculate monthly fuel
consumption for each heater as required by Condition 2.3 (Colorado Construction Permit 03WE0913, as
modified under the provisions of Section I, Condition 1.3,to allow for use of a combined fuel meter
instead of individual fuel meters for the hot oil heaters).
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3. Point 022 - Flare Stack(FL-8921) and CO2 Vent(ST-8931): CO2 Treatment Plant—Glycol
Dehydrator and Amine Unit,Each Rated at 300 MMscf/day
Permit Limitation Compliance Monitoring
Condition Emission Factor
Parameter Number Method Interval
Error!
Reference See Condition Error! Reference
BACT Requirements source source not found.
not
found.
Opacity—Applies to See Condition 3.2
3.2 Not to exceed 30%
the Flare Only
NO„ 3.3 7.4 tons/year 1.7 lbs/hr Recordkeeping& Monthly
CO 39.42 tons/year 9 lbs/hr
Calculation
VOC—Flare Stack 5.8 tons/year
VOC—CO2 Stack 11.8 tons/year See Condition
Parametric Daily
H2S—CO2 Stack 3.4 5.0 tons/year 3.4
Benzene—Glycol
0.90 tons/year
Dehydrator
Extended Gas Analysis ASTM Methods Quarterly
Natural Gas Processed 3.5 109,500 MMscf/year Flow Meter Monthly
The glycol dehydrator and
Operating amine treatment unit shall See Condition 3.6
Requirements 3'6 be operated together at all
times
Hours of Operation 3.7 Recordkeeping Monthly
MACT Subpart HHH Benzene emissions less See Condition 3.8
Requirements 3'8 than 1,984 lbs/year
MACT General 3.9 See Condition 3.9
Provisions
Visible Emission Visible Emissions Monthly
Requirements Observations
Temperature
A Flame Shall be Present
Sensor or Flame
at all times that the Flare is Continuously
Operated Detection Device
Flare Requirements 3.10 with Alarm
Flare Specifications—Btu Certification Annually
Content of Gas&Velocity
Flare Shall be Operating at
all Times that the Certification Annually
Dehydrator is Operated
SulfaTreat H2S Control 3.11 H2S Emissions Shall Be See Condition 3.11
System Reduced by 75%
Supplemental Fuel 3.12 Recordkeeping Monthly
Consumed in the Flare
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3.1 The CO2 Treatment Plant is subject to the requirements of the Prevention of Significant Deterioration
(PSD) Program. Best Available Control Technology (BACT) shall be applied for control Volatile
Organic Compounds (VOC). BACT has been determined to be use of an elevated flare to reduce VOC
emissions from the glycol dehydrator regenerator(still) vent and flash tank and the amine unit flash tank
by 98% (Colorado Construction Permit 03WE0916). In the absence of credible evidence to the contrary,
compliance with the 98%control efficiency requirement is met provided the requirements in Conditions
3.6, 3.8, 3.9 and 3.10 are met.
3.2 No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or
cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period
or periods aggregating more than six minutes in any sixty consecutive minutes (Colorado Construction
Permit 03WE0916 and Colorado Regulation No. 1, Section II.A.5). This opacity requirement applies to
the flare only. In the absence of credible evidence to the contrary, compliance with this opacity
requirement is presumed provided the requirements in Condition 3.10.4 are met.
3.3 NOx and CO emissions from the flare shall not exceed the limitation stated above (Colorado
Construction Permit 03WE0916). Monthly emissions of NOx and CO shall be calculated by the end of
the subsequent month using the above emission factors (from the manufacturer) and the number of hours
the flare is operated in the following equation:
Tons (—hr)
hours ton
Month = EF\hr) x Flare hours of operation(hours)
x kz000 Ib)
A twelve month rolling total of emissions will be maintained to monitor compliance with the annual
emission limitations. Each month, a new twelve month total shall be calculated using the previous
twelve months data.
3.4 VOC and H25 emissions from the flare vent and the CO2 vent and benzene emissions from the glycol
dehydrator shall not exceed the limitations stated above (Colorado Construction Permit 03WE0916).
Compliance with the VOC, benzene and H2S emission limitations shall be monitored as follows:
3.4.1 For the dehydration unit: VOC and HAP emissions shall be calculated monthly using the Gas
Research Institute's GLYCalc Model, Version 4.0 or higher, as follows:
Monthly averages of the following monitored values shall be determined for use as inputs to the
GLYCalc Model. Values of parameters shall be representative of the unit's operation during the
month.
Parameter Monitoring Frequency
Flash Tank Temperature
Flash Tank Pressure
Wet Gas Inlet Temperature
Daily
Wet Gas Inlet Pressure
Stripping Gas Rate
Triethylene Glycol Recirculation Rate
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The GLYCaIc model shall also use following inputs: the most recent extended gas analysis
results (inlet gas to the dehydrator) as specified in Condition 3.4.4,the hours of operation for the
flare as specified in Condition 3.10.5,the hours of operation for the dehydration unit as specified
in Condition 3.7 and the average daily gas throughput value calculated as specified in 3.5.
A 98%control efficiency for the flare may be applied to uncontrolled emissions predicted by the
model (GLYCalc) for the dehydrator, for those hours that the flare was in operation, provided
that the requirements of Conditions 3.8, 3.9 and 3.10 are met.
3.4.2 For the amine unit, VOC, HAP and H2S emissions shall be calculated monthly using the
ProMax model, as follows:
Monthly averages of the following monitored values shall be determined for use as inputs to the
ProMax Model. Values of parameters shall be representative of the unit's operation during the
month.
Parameter I Monitoring Frequency
Inlet Gas Temperature
Inlet Gas Pressure
Daily
Stripping Gas Rate
Lean Amine Recirculation Rate
The ProMax model shall also use following inputs: the most recent extended gas analysis results
(inlet gas to the amine unit) as specified in Condition 3.4.4,the hours of operation for the flare as
specified in Condition 3.10.5, the hours of operation for the SulfaTreat system as specified by
Condition 3.11, the hours of operation for the amine unit as specified in Condition 3.7 and the
average daily gas throughput value calculated as specified in 3.5.
A 75% control efficiency for the SulfaTreat system may be applied to uncontrolled H2S
emissions predicted by the model (ProMax) for the amine unit, for those hours that the
SulfaTreat system was in operation, provided that the requirements of Condition 3.11 are met.
A 98% control efficiency for the flare may be applied to uncontrolled VOC and HAP emissions
predicted by the model (ProMax) for the flash tank emissions from the amine unit, for those
hours that the flare was in operation,provided that the requirements of Conditions 3.8, 3.9 and
3.10 are met.
3.4.3 Monthly calculation of emissions shall be conducted by the end of the subsequent month.
Monthly emissions shall be used in a twelve month rolling total of VOC, benzene and H2S to
monitor compliance with the annual emission limitation. Each month, a new twelve month total
shall be calculated using the previous twelve months data. Records of calculations shall be kept
in a log to be made available to the Division upon request. Monthly calculations are not required
when the dehydration unit and amine unit did not operate during the month.
3.4.4 An extended natural gas analysis of inlet gas to the amine unit and the glycol dehydrator shall be
conducted quarterly, using ASTM methods or equivalent. Frequency of extended gas analyses
Operating Permit#05OPWE281 First Issued: October 1, 2007
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shall move to semi-annually after the first year,then to annually after the second year if the
BTEX concentrations remain consistently below the established values identified in the table
below. Frequency will revert back to quarterly if any of the BTEX constituents exceed the listed
values. The first quarterly sample shall be taken three months after the sample that indicated that
a BTEX constituent exceeded the parameters in the above table was taken. Required analyses
shall be conducted not less than one month apart.
Constituent Value Criteria
Benzene 30 At or below
Toluene 30 At or below
Ethylbenzene 0 Not to exceed
Xylene 0 Not to exceed
3.5 The quantity of natural gas processed by the CO2 Treatment Plant shall not exceed the limitation listed
above (Colorado Construction Permit 03WE0916). The natural gas processed through the CO2
Treatment Plant shall be monitored using a flow meter and recorded monthly in a log that is available to
the Division upon request. Monthly natural gas processed shall be used in a twelve month rolling total to
monitor compliance with the annual limitation. Each month, a new twelve month total shall be
calculated using the previous twelve months data.
An average daily gas throughput rate shall be determined as follows:
MMScf Month 24hrs
Average Daily Gas Throughput= Gas Throughput monthxxrs Operation day
This average daily gas throughput rate shall be used in the monthly GLYCalc and ProMax runs and
emission calculations required by Conditions 3.4.1 and 3.4.2.
3.6 The glycol dehydrator and the amine unit shall operate together as a unit at all times. At no time shall
the glycol dehydrator be operated without the amine unit also operating and at no time shall the amine
unit be operated without the glycol dehydrator.
3.7 Hours of operation for the dehydration unit and the amine unit shall be monitored and recorded monthly
in a log that is available to the Division upon request. The hours of operation shall be used to calculate
monthly emissions as required by Conditions 3.4.1 and 3.4.2.
3.8 The glycol dehydrator is subject to the National Emission Standards for Hazardous Air Pollutants of
Regulation No. 8, Part E, Subpart HHH (40 CFR Part 63, Subpart HHH), for Natural Gas Transmission
and Storage Facilities, including, but not limited to,the following:
The requirements below reflect the current rule language as of the revisions to 40 CFR Part 60 Subpart
HHH published in the Federal Register on August 16, 2012. However, if revisions to this Subpart are
published at a later date, the owner or operator is subject to the requirements contained in the revised
version of 40 CFR Part 60, Subpart HHH.
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Note that the compliance date for the glycol dehydrator is the startup date (January 30, 2005) as
specified in 40 CFR Part 63 Subpart HHH § 63.1270(d)(2).
Affirmative defense for violations of emission standards during malfunction
3.8.1 The provisions set forth in this subpart(Condition 3.8) shall apply at all times.
3.8.2 In response to an action to enforce the standards set forth in Subpart HHH,you may assert an
affirmative defense to a claim for civil penalties for violations of such standards that are caused
by malfunction, as defined at § 63.2. Appropriate penalties may be assessed; however, if you fail
to meet your burden of proving all of the requirements in the affirmative defense, the affirmative
defense shall not be available for claims for injunctive relief(§ 63.1272(d)).
3.8.3 To establish the affirmative defense in any action to enforce such a standard, you must timely
meet the reporting requirements in § 63.1272(d)(2). The affirmative defense must satisfy the
requirements of§ 63.1272(d)(1). (§ 63.1272(d)(2)).
General Standards
18.4 All reports required under this subpart shall be sent to the Administrator at the appropriate
address listed in §63.13. Reports may be submitted on electronic media(40 CFR Part 63 Subpart
HHH § 63.1274(b)).
3.8.5 In all cases where the provisions of this subpart require an owner or operator to repair leaks by a
specified time after the leak is detected, it is a violation of this standard to fail to take action to
repair the leak(s) within the specified time. If action is taken to repair the leak(s) within the
specified time, failure of that action to successfully repair the leak(s) is not a violation of this
standard. However, if the repairs are unsuccessful, a leak is detected and the owner or operator
shall take further action as required by the applicable provisions of this subpart(40 CFR Part 63
Subpart HHH § 63.1274(g)).
3.8.6 At all times the owner or operator must operate and maintain any affected source, including
associated air pollution control equipment and monitoring equipment, in a manner consistent
with safety and good air pollution control practices for minimizing emissions. Determination of
whether such operation and maintenance procedures are being used will be based on information
available to the Administrator which may include, but is not limited to, monitoring results,
review of operation and maintenance procedures, review of operation and maintenance records,
and inspection of the source (§63.1274(h)).
Glycol Dehydrator Unit Process Vent Standards
3.8.7 The owner or operator shall connect the process vent to a control device or a combination of
control devices through a closed-vent system and the outlet benzene emissions from the control
device(s) shall be less than 0.90 megagrams per year (1,984 lbs/yr). The closed-vent system shall
be designed and operated in accordance with the requirements of§63.1281(c) (Conditions 3.8.9
through 3.8.11). The control device(s) shall be designed and operated in accordance with the
Operating Permit#05OPWE281 First Issued: October 1, 2007
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Permit# 05OPWE281 Page 31
requirements of§63.1281(d) (Conditions 3.8.12 and 3.8.13), except that the performance
requirements specified in §63.1281(d)(1)(i) and(ii) do not apply (40 CFR Part 63 Subpart HHH
§ 63.1275(b)(1)(ii)).
Benzene emissions from the glycol dehydrator are limited to less than 1,984 pounds per year of
benzene as specified in Condition 3.4 of this permit.
3.8.8 One or more safety devices that vent directly to the atmosphere may be used on the air emission
control equipment installed to comply with paragraph (b)(1) (Condition 3.8.7) of this section (40
CFR Part 63 Subpart HHH § 1275(b)(2)).
Control Equipment Requirements
Compliance with paragraphs (c) and (d) of this section (Conditions 3.8.9 through 3.8.13)will be
determined by review of the records required by § 63.1284,the reports required by § 63.1285, by review
of performance test results, and by inspections (40 CFR Part 63 Subpart HHH § 63.1281(a)).
Closed-vent system requirements
3.8.9 The closed-vent system shall route all gases, vapors, and fumes emitted from the material in an
emissions unit to a control device that meets the requirements specified in paragraph (d) of this
section (Conditions 3.8.12 through 3.8.13) (40 CFR Part 63 Subpart HHH § 63.1281(c)(1)).
3.8.10 The closed-vent system shall be designed and operated with no detectable emissions (40 CFR
Part 63 Subpart HHH § 63.1281(c)(2)).
3.8.11 If the closed-vent system contains one or more bypass devices that could be used to divert all or
a portion of the gases, vapors, or fumes from entering the control device,the owner or operator
shall meet the requirements specified in paragraphs (c)(3)(i) and (c)(3)(ii) of this section
(Conditions 3.8.11.1 and 3.8.11.2) (40 CFR Part 63 Subpart HHH § 63.1281(c)(3)).
3.8.11.1 For each bypass device, except as provided for in paragraph (c)(3)(ii) of this section
(Condition 3.8.11.2),the owner or operator shall either(40 CFR Part 63 Subpart
HHH § 63.1281(c)(3)(i)):
a. At the inlet to the bypass device that could divert the stream away from the
control device to the atmosphere, properly install, calibrate, maintain, and operate
a flow indicator that is capable of taking periodic readings and sounding an alarm
when the bypass device is open such that the stream is being, or could be, diverted
away from the control device to the atmosphere; or
b. Secure the bypass device valve installed at the inlet to the bypass device in the
non-diverting position using a car-seal or a lock-and-key type configuration.
3.8.11.2 Low leg drains, high point bleeds, analyzer vents, open-ended valves or lines, and
safety devices are not subject to the requirements of paragraph(c)(3)(i) of this section
(Condition 3.8.11.1) (40 CFR Part 63 Subpart HHH § 63.1281(c)(3)(ii)).
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Control device requirements.
3.8.12 The flare shall be designed and operated in accordance with the requirement of§ 63.11(b),which
are specified in Condition 3.10 (40 CFR Part 63 Subpart HHH § 63.1281(d)(1)(iii)).
3.8.13 Each control device used to comply with this subpart shall be operating at all times when gases,
vapors, and fumes are vented from the emissions unit or units through the closed-vent system to
the control device, as required under §63.1275. An owner or operator may vent more than one
unit to a control device used to comply with this subpart(40 CFR Part 63 Subpart HHH §
63.1281(d)(4)(i)).
Test Methods, Compliance Procedures, and Compliance Demonstrations
No detectable emissions test procedure. (40 CFR Part 63 Subpart HHH § 63.1282(b))
3.8.14 The procedure shall be conducted in accordance with Method 21, 40 CFR part 60, appendix A
(40 CFR Part 63 Subpart HHH § 63.1282(b)(1)).
3.8.15 The detection instrument shall meet the performance criteria of Method 21, 40 CFR part 60,
appendix A, except the instrument response factor criteria in section 3.1.2(a) of Method 21 shall
be for the average composition of the fluid, and not for each individual organic compound in the
stream (40 CFR Part 63 Subpart HHH § 63.1282(b)(2)).
3.8.16 The detection instrument shall be calibrated before use on each day of its use by the procedures
specified in Method 21, 40 CFR part 60, appendix A (40 CFR Part 63 Subpart HHH §
63.1282(b)(3)).
3.8.17 Calibration gases shall be as follows (40 CFR Part 63 Subpart HHH § 63.1281(b)(4)):
3.8.17.1 Zero air(less than 10 parts per million by volume hydrocarbon in air); and
3.8.17.2 A mixture of methane in air at a methane concentration of less than 10,000 parts per
million by volume.
3.8.18 An owner or operator may choose to adjust or not adjust the detection instrument readings to
account for the background organic concentration level. If an owner or operator chooses to adjust
the instrument readings for the background level,the background level value must be determined
according to the procedures in Method 21 of 40 CFR part 60, appendix A (40 CFR Part 63
Subpart HHH § 63.1282(b)(5)).
3.8.19 Except as provided in paragraph (b)(6)(ii) of this section(Condition 3.8.20), the detection
instrument shall meet the performance criteria of Method 21 of 40 CFR part 60, appendix A,
except the instrument response factor criteria in section 3.1.2(a) of Method 21 shall be for the
average composition of the process fluid not each individual volatile organic compound in the
stream. For process streams that contain nitrogen, air, or other inerts which are not organic HAP
or VOC,the average stream response factor shall be calculated on an inert-free basis (40 CFR
Part 63 Subpart HHH § 63.1282(b)(6)(i)).
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18.20 If no instrument is available at the facility that will meet the performance criteria specified in
paragraph(b)(6)(i) of this section (Condition 3.8.19),the instrument readings may be adjusted by ,
multiplying by the average response factor of the process fluid, calculated on an inert-free basis
as described in paragraph (b)(6)(i) of this section (Condition 3.8.19) (40 CFR Part 63 Subpart
HHH § 63.1282(b)(6)(ii)).
3.8.21 An owner or operator must determine if a potential leak interface operates with no detectable
emissions using the applicable procedure specified in paragraph (b)(7)(i) or(b)(7)(ii) of this
section (Conditions 3.8.21.1 or 3.8.21.2) (40 CFR Part 63 Subpart HHH § 63.1282(b)(7)).
3.8.21.1 If an owner or operator chooses not to adjust the detection instrument readings for the
background organic concentration level, then the maximum organic concentration
value measured by the detection instrument is compared directly to the applicable
value for the potential leak interface as specified in paragraph (b)(8) of this section
(Condition 3.8.22) (40 CFR Part 63 Subpart HHH § 63.1282(b)(7)(i)).
3.8.21.2 If an owner or operator chooses to adjust the detection instrument readings for the
background organic concentration level, the value of the arithmetic difference
between the maximum organic concentration value measured by the instrument and
the background organic concentration value as determined in paragraph (b)(5) of this
section (condition 3.8.18) is compared with the applicable value for the potential leak
interface as specified in paragraph (b)(8) of this section (Condition 3.8.22) (40 CFR
Part 63 Subpart HHH § 63.1282(b)(7)(ii)).
3.8.22 A potential leak interface is determined to operate with no detectable organic emissions if the
organic concentration value determined in paragraph(b)(7) (Condition 3.8.21) is less than 500
parts per million by volume (40 CFR Part 63 Subpart HHH § 63.1282(b)(8)).
Control device performance test procedures
3.8.23 A flare that is designed and operated in accordance with the provisions of 40 CFR Part 63
Subpart A § 63.11(b) shall be exempt from the control device performance test procedures in 40
CFR Part 63 Subpart HHH § 63.1283(d), except for the following (40 CFR Part 63 Subpart HHH
§ 63.1282(d)(1)(i)):
3.8.24 An owner or operator shall design and operate each flare in accordance with the requirements
specified in §63.11(b) and the compliance determination shall be conducted using Method 22 of
40 CFR part 60, appendix A,to determine visible emissions. (40 CFR Part 63 Subpart HHH §
63.1282(d)(2)).
Inspection and Monitoring Requirements
Closed vent system inspection and monitoring requirements
3.8.25 For each closed-vent system required to comply with this section, the owner or operator shall
comply with the requirements of paragraphs (c)(2)through (7) (Conditions 3.8.26 through
3.8.31) of this section(40 CFR Part 63 Subpart HHH § 63.1283(c)(1)).
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3.8.26 Except as provided in paragraphs (c)(5) and (6) of this section (Conditions 3.8.29 and 3.8.30),
each closed-vent system shall be inspected according to the procedures and schedule specified in
paragraphs (c)(2)(i) and(ii) of this section (Conditions 3.8.26.1 and 3.8.26.2) and each bypass
device shall be inspected according to the procedures of(c)(2)(iii) of this section (Condition
3.8.26.3) (40 CFR Part 63 Subpart HHH § 63.1283(c)(2)).
3.8.26.1 For each closed-vent system joints, seams, or other connections that are permanently
or semi-permanently sealed (e.g., a welded joint between two sections of hard piping
or a bolted or gasketed ducting flange),the owner or operator shall (40 CFR Part 63
Subpart HHH § 63.1283(c)(2)(i)):
a. Conduct annual visual inspections for defects that could result in air emissions.
Defects include, but are not limited to, visible cracks, holes, or gaps in piping;
loose connections; or broken or missing caps or other closure devices. The owner
or operator shall monitor a component or connection using the procedures
specified in §63.1282(b) (Conditions 3.8.14 through 3.8.22)to demonstrate that it
operates with no detectable emissions following any time the component or
connection is repaired or replaced or the connection is unsealed. Inspection results
shall be submitted in the Periodic Report as specified in §63.1285(e)(2)(iii).
3.8.26.2 For closed-vent system components other than those specified in paragraph (c)(2)(i)
of this section (Condition 3.8.26.1),the owner or operator shall (40 CFR Part 63
Subpart HHH § 63.1283(c)(2)(ii)):
a. Conduct an initial inspection according to the procedures specified in §63.1282(b)
(Conditions 3.8.14 through 3.8.22)to demonstrate that the closed-vent system
operates with no detectable emissions. Inspection results shall be submitted with
the Notification of Compliance Status Report as specified in §63.1285(d)(1) or
(2).
b. Conduct annual inspections according to the procedures specified in §63.1282(b)
(conditions 3.8.14 through 3.8.22)to demonstrate that the components or
connections operate with no detectable emissions. Inspection results shall be
submitted in the Periodic Report as specified in §63.1285(e)(2)(iii).
c. Conduct annual visual inspections for defects that could result in air emissions.
Defects include, but are not limited to,visible cracks, holes, or gaps in ductwork;
loose connections; or broken or missing caps or other closure devices. Inspection
results shall be submitted in the Periodic Report as specified in
§63.1285(e)(2)(iii).
3.8.26.3 For each bypass device, except as provided for in §63.1281(c)(3)(ii) (Condition
3.8.11.2), the owner or operator shall either(40 CFR Part 63 Subpart HHH §
63.1283(c)(2)(iii)):
a. At the inlet to the bypass device that could divert the steam away from the control
device to the atmosphere, set the flow indicator to take a reading at least once
every 15 minutes; or
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b. If the bypass device valve installed at the inlet to the bypass device is secured in
the non-diverting position using a car-seal or a lock-and-key type configuration,
visually inspect the seal or closure mechanism at least once every month to verify
that the valve is maintained in the non-diverting position and the vent stream is
not diverted through the bypass device.
3.8.27 In the event that a leak or defect is detected,the owner or operator shall repair the leak or defect
as soon as practicable, except as provided in paragraph (c)(4) of this section (Condition 3.8.28)
(40 CFR Part 63 Subpart HHH § 63.1283(c)(3)).
3.8.27.1 A first attempt at repair shall be made no later than 5 calendar days after the leak is
detected.
3.8.27.2 Repair shall be completed no later than 15 calendar days after the leak is detected.
3.8.28 Delay of repair of a closed-vent system for which leaks or defects have been detected is allowed
if the repair is technically infeasible without a shutdown, as defined in §63.1271, or if the owner
or operator determines that emissions resulting from immediate repair would be greater than the
fugitive emissions likely to result from delay of repair. Repair of such equipment shall be
completed by the end of the next shutdown (40 CFR Part 63 Subpart HHH § 63.1283(c)(4)).
3.8.29 Any parts of the closed-vent system or cover that are designated, as described in paragraphs
(c)(5) (i) and (ii) of this section (Conditions 3.8.29.1 and 3.8.29.2), as unsafe to inspect are
exempt from the inspection requirements of paragraphs (c)(2) (i) and (ii) of this section
(Conditions 3.8.26.1 and 3.8.26.2) if(40 CFR Part 63 Subpart HHH § 63.1283(c)(5)):
3.8.29.1 The owner or operator determines that the equipment is unsafe to inspect because
inspecting personnel would be exposed to an imminent or potential danger as a
consequence of complying with paragraph (c)(2)(i) or(ii) of this section (Conditions
3.8.26.1 and 3.8.26.2); and
3.8.29.2 The owner or operator has a written plan that requires inspection of the equipment as
frequently as practicable during safe-to-inspect times.
3.8.30 Any parts of the closed-vent system or cover that are designated, as described in paragraphs
(c)(6) (i) and (ii) of this section (conditions 3.8.30.1 and 3.8.30.2), as difficult to inspect are
exempt from the inspection requirements of paragraphs (c)(2) (i) and (ii) of this section
(Conditions 3.8.26.1 and 3.8.26.2) if(40 CFR Part 63 Subpart HHH § 63.1283(c)(6)):
3.8.30.1 The owner or operator determines that the equipment cannot be inspected without
elevating the inspecting personnel more than 2 meters above a support surface; and
3.8.30.2 The owner or operator has a written plan that requires inspection of the equipment at
least once every 5 years.
3.8.31 Records shall be maintained as specified in §63.1284(b)(5)through(8) (40 CFR Part 63 Subpart
HHH § 63.1283(c)(7)).
Control device monitoring requirements
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3.8.32 The owner or operator shall install and operate a continuous parameter monitoring system in
accordance with the requirements of paragraphs (d)(3), (d)(6) and (d)(7) of this section
(Conditions 3.8.33 through 3.8.36). The continuous parameter monitoring system must meet the
following specifications and requirements (40 CFR Part 63 Subpart HHH § 63.1283(d)(1)):
3.8.32.1 Each continuous parameter monitoring system shall measure data values at least once
every hour and record either(40 CFR Part 63 Subpart HHH § 63.1283(d)(1)(i)):
a. Each measured data value
3.8.32.2 A site-specific monitoring plan must be prepared that addresses the monitoring
system design, data collection, and the quality assurance and quality control elements
outlined in 40 CFR Part 63 §63.1282(d)(1)(ii) and in § 63.8(d). Each CPMS must be
installed, calibrated, operated, and maintained in accordance with the procedures in
your approved site-specific monitoring plan. Using the process described in §
63.8(0(4), you may request approval of monitoring system quality assurance and
quality control procedures alternative to those specified in paragraphs (d)(1)(ii)(A)
through (E) of this section in your site-specific monitoring plan. (40 CFR Part 63
Subpart HHH § 63.1283(d)(1)(ii)).
3.8.32.3 The owner or operator must conduct the CPMS equipment performance checks,
system accuracy audits, or other audit procedures specified in the site-specific
monitoring plan at least once every 12 months. (40 CFR Part 63 Subpart HHH §
63.1283(d)(1)(iii)).
3.8.32.4 The owner or operator must conduct a performance evaluation of each CPMS in
accordance with the site-specific monitoring plan. (40 CFR Part 63 Subpart HHH §
63.1283(d)(1)(iv)).
3.8.33 The owner or operator shall install, calibrate, operate, and maintain a device equipped with a
continuous recorder to measure the values of operating parameters appropriate for the control
device as specified in either paragraph (d)(3)(i), (d)(3)(ii), or(d)(3)(iii) of this section (Condition
3.8.33.1) (40 CFR Part 63 Subpart HHH § 63.1283(d)(3)(i)).
3.8.33.1 A continuous monitoring system that measures the following operating parameters as
applicable (40 CFR Part 63 Subpart HHH § 63.1283(d)(3)(i)):
a. For a flare, a heat sensing monitoring device equipped with a continuous recorder
that indicates the continuous ignition of the pilot flame (40 CFR Part 63 Subpart
HHH § 63.1283(d)(3)(i) (C)).
3.8.34 An excursion for a given control device is determined to have occurred when the monitoring data
or lack of monitoring data result in any one of the criteria specified in paragraphs (d)(6)(i)
through(d)(6)(iv) of this section (Conditions 3.8.34.1 and 3.8.34.2) being met. When multiple
operating parameters are monitored for the same control device and during the same operating
day, and more than one of these operating parameters meets an excursion criterion specified in
paragraphs (d)(6)(i)through (d)(6)(iv) of this section(Conditions 3.8.34.1 and 3.8.34.2),then a
single excursion is determined to have occurred for the control device for that operating day (40
CFR Part 63 Subpart I-IHH § 63.1283(d)(6)).
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3.8.34.1 An excursion occurs when the monitoring data are not available for at least 75 percent
of the operating hours in a day (40 CFR Part 63 Subpart HHH § 63.1283(d)(6)(iii)).
Note that this requirement applies to the data monitored for the flare as required by
Condition 3.8.32.
3.8.34.2 If the closed-vent system contains one or more bypass devices that could be used to
divert all or a portion of the gases, vapors, or fumes from entering the control device,
an excursion occurs when (40 CFR Part 63 Subpart HHH § 63.1283(d)(3)(iv)):
a. For each bypass line subject to §63.1281(c)(3)(i)(A) (Condition 3.8.11.1a the flow
indicator indicates that flow has been detected and that the stream has been
diverted away from the control device to the atmosphere.
b. For each bypass line subject to §63.1281(c)(3)(i)(B) (Condition 3.8.11.Ib), if the
seal or closure mechanism has been broken,the bypass line valve position has
changed, the key for the lock-and-key type lock has been checked out, or the car-
seal has broken.
3.8.35 For each excursion,the owner or operator shall be deemed to have failed to have applied control
in a manner that achieves the required operating parameter limits. Failure to achieve the required
operating parameter limits is a violation of this standard. (40 CFR Part 63 Subpart HHH §
63.1283(d)(7)).
3.8.36 Nothing in paragraphs (d)(1)through (d)(8) of this section (Conditions 3.8.32 through 3.8.35)
shall be construed to allow or excuse a monitoring parameter excursion caused by any activity
that violates other applicable provisions of this subpart(40 CFR Part 63 Subpart HHH §
63.1283(d)(9)).
Recordkeeping and Reporting Requirements
3.8.37 Records shall be kept as required by 40 CFR Part 63 Subpart HHH § 63.1284(a), (b), (c) and (e).
3.8.38 Reports shall be submitted as required by 40 CFR Part 63 Subpart HHH § 63.1285.
3.8.39 The owner or operator shall maintain records of the occurrence and duration of each malfunction
of operation ( i.e., process equipment) or the air pollution control equipment and monitoring
equipment. The owner or operator shall maintain records of actions taken during periods of
malfunction to minimize emissions in accordance with § 63.1274(h) (Conditions 3.8.1 through
3.8.3), including corrective actions to restore malfunctioning process and air pollution control
and monitoring equipment to its normal or usual manner of operation (§ 63.1284(f)).
3.9 The glycol dehydrator is subject to the General Provisions in Regulation No. 8, Part E, Section I (40
CFR Part 63, Subpart A), as specified in 40 CFR Part 63 Subpart HHH § 63.1274(a). These
requirements include, but are not limited to the following:
3.9.1 Prohibited activities and circumvention in § 63.4.
3.9.2 Performance test requirements in § 63.7 except for § 63.7(e)(1)
Operating Permit#05OPWE281 First Issued: October 1, 2007
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3.9.3 Monitoring requirements in § 63.8.
3.9.4 Notification requirements in § 63.9.
3.9.5 Recordkeeping requirements in § 63.10.
3.10 The flare is subject to the following requirements from 40 CFR Part 63 Subpart A § 63.11(b):
3.10.1 Owners or operators using flares to comply with the provisions of this part shall monitor these
control devices to assure that they are operated and maintained in conformance with their designs
(40 CFR Part 63 Subpart A § 63.11(b)(1)).
3.10.2 Flares shall be steam-assisted, air-assisted, or non-assisted (40 CFR Part 63 Subpart A §
63.11(b)(2)).
3.10.3 Flares shall be operated at all times when emissions may be vented to them (40 CFR Part 63
Subpart A § 63.11(b)(3)).
3.10.4 Flares shall be designed for and operated with no visible emissions, except for periods not to
exceed a total of 5 minutes during any 2 consecutive hours. Test Method 22 in appendix A of
part 60 of this chapter shall be used to determine the compliance of flares with the visible
emission provisions of this part. The observation period is 2 hours and shall be used according to
Method 22. (40 CFR Part 63 Subpart A § 63.11(b)(4))
Compliance with the visible emission requirements shall be monitored by conducting a visible
emission observation monthly when the flare is operating. Monthly observations shall last a
minimum of five minutes. If no visible emissions are present during this observation, in the
absence of credible evidence to the contrary,the flare will be considered in compliance with the
above visible emissions requirement. If visible emissions are present during the monthly reading,
a two (2)hour observation shall be conducted in accordance with Method 22 to determine if the
flare is in compliance with the above visible emissions requirement. If visible emissions are
present for five minutes or less (total) during the two-hour observation,then the flare shall be
deemed in compliance. If visible emissions are present for more than five minutes (total) during
the two-hour observation, then the flare shall be deemed out of compliance with the above
visible emissions requirement. Subject to the provisions of C.R.S. § 25-7-123.1 and in the
absence of credible evidence to the contrary, exceedance of the visible emission requirement
shall be considered to exist from the time a Method 22 reading is taken that shows the flare is out
of compliance (as defined above) until a Method 22 reading is taken that shows the flare is in
compliance (as defined above).
3.10.5 Flares shall be operated with a flame present at all times. The presence of a flare pilot flame shall
be monitored using a thermocouple or any other equivalent device to detect the presence of a
flame (40 CFR Part 63 Subpart A § 63.11(b)(5))). The device must meet the specific
requirements specified in Conditions 3.8.32 and 3.8.33. Records of the times and duration of all
periods of pilot flame outages, and estimated emissions shall be maintained and made available
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to the Division upon request. Estimated emissions shall be used as specified in Condition 3.4.1 to
monitor compliance with the VOC and benzene emission limitation in Condition 3.4.
3.10.6 Flares shall be used only with the net heating value of the gas being combusted being 11.2
MJ/scm (300 Btu/scf) or greater if the flare is steam-assisted or air-assisted; or with the net
heating value of the gas being combusted being 7.45 MJ/scm (200 Btu/scf) or greater if the flare
is nonassisted (40 CFR Part 63 Subpart A § 63.11(b)(6)(ii)). The net heating value of the gas
being combusted shall be calculated using the equation specified in 40 CFR R Part 63 Subpart A §
63.11(b)(6)(ii).
3.10.7 Air-assisted flares shall be designed and operated with an exit velocity less than the velocity,
Vmax, as determined by 40 CFR Part 63 Subpart A § 63.11(b)(8) (40 CFR Part 63 Subpart A §
63.11(b)(8)). The actual exit velocity of a flare shall be determined by dividing by the volumetric
flow rate of gas being combusted (in units of emission standard temperature and pressure), as
determined by Test Method 2, 2A, 2C, or 2D in appendix A to 40 CFR part 60 of this chapter, as
appropriate, by the unobstructed (free) cross-sectional area of the flare tip (40 CFR Part 63
Subpart A § 63.11(b)(7)(i)).
3.10.8 The permittee shall maintain records from the September 2005 performance test indicating
compliance with the requirements of Conditions 3.10.6 and 3.10.7. The results of the monitoring
required under 3.10.4 shall be used to assess compliance with the requirements in Conditions
3.10.6 and 3.10.7.
3.11 Emissions from the amine unit regenerator(still)vent shall be routed through a closed vent system to the
Sulfa Treat H2S control system prior to being emitted. The SulfaTreat H2S control system shall be
operated and maintained to reduce H2S emissions from the amine unit regenerator(still) vent by 75%or
greater(Colorado Construction Permit 03WE0916). The outlet H2S concentration shall be continuously
monitored in order to determine when the SulfaTreat material must be replaced. The permittee shall
keep records from the manufacturer which indicate the H2S outlet concentration level that requires
replacement of the SulfaTreat material. In the absence of credible evidence to the contrary, compliance
with the 75%reduction requirement shall be presumed provided the SulfaTreat unit and associated H2S
monitoring system are operated and maintained in accordance with manufacturer's recommendations
and good engineering practices.
Records of the times and duration of all periods the SulfaTreat unit was not operating and estimated
emissions shall be maintained and made available to the Division upon request. Estimated emissions
shall be used as specified in Condition 3.4.2 to monitor compliance with the H2S emission limitations in
Condition 3.4.
3.12 Supplemental fuel consumed in the flare shall be monitored and recorded monthly in a log that is
available to the Division upon request. The amount of supplemental fuel consumed shall be used to
calculate monthly fuel consumption for each heater as required by Condition 2.3 (Colorado Construction
Permit 03WE0913, as modified under the provisions of Section I, Condition 1.3, to allow for use of a
combined fuel meter instead of individual fuel meters for the hot oil heaters).
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4. Point 023 (EG-6141): Caterpillar,Model No. 3516B LE,Emergency Generator Rated at 1557 hp
Permit Limitation Compliance Monitoring
Condition Emission Factor
Parameter Number Method Interval
NO), 1 g/hp-hr Recordkeeping&
4.1 3.04 g/hp-hr Calculation Annually
CO
Hours of Operation 4.2 Recordkeeping Annually
Only Natural
Opacity 4.3 Not to exceed 20% Fuel Restriction Gas is Used as
Fuel
MACT Subpart ZZZZ 4.4 See Condition 4.4
Requirements
4.1 The emission factors listed above have been approved by the Division and shall be used to calculate
emissions from the emergency generator(from the manufacturer). Annual emissions of Nitrogen Oxide
(NOx) and Carbon Monoxide (CO) emissions for purposes of APEN reporting and payment of annual
fees shall be determined using the above emission factors, the maximum horsepower(1557 hp) and the
hours of operation (as required by Condition 4.2)the following equation:
Tonslb ton
Year = EF(hphr) x hours of operation( ) x Max HPx (Yr 453.6 g) x (2000 ton/
4.2 Hours of operation shall be monitored annually and recorded in a log to be made available to the
Division upon request. For each operational period,the log shall note whether the engine was operated
for purposes of: (1)maintenance checks and readiness testing, (2) emergency operation, or(3) non-
emergency operation. Recorded data shall be used to calculate emissions as required by Condition 4.1,
and to monitor the engine's exemption status under 40 CFR Part 63 Subpart ZZZZ as required by
Condition 4.4.1.
Note that if annual hours of operation exceed 250 hours in any year,the engine is no longer exempt from
the permitting requirements in Colorado Regulation No. 3, as per Part B Section II.D.1.c.(ii).Note also
that if annual hours of operation exceed 250 hours per year in any year,the exemption from the
requirement to install controls under Colorado Regulation No. 7, Section XVII.E.3.b.(ii) is no longer
applicable (based on the approval letter provided by the Division dated December 21, 2009). In the
event that hours of operation exceed 250 hours per year,the permittee shall submit an application to
revise this permit within 30 days in order to include the appropriate applicable requirements.
4.3 No owner or operator of a source shall allow or cause the emission into the atmosphere of any air
pollutant which is in excess of 20%opacity (Colorado Regulation No. 1, Section II.A.1). In the absence
of credible evidence to the contrary, compliance with the above opacity requirements shall be presumed
since only natural gas is used permitted to be as fuel in this engine. The permittee shall maintain records
that verify that only natural gas is used as fuel in this engine.
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC
Colorado Operating Permit Cheyenne Plains Compressor Station
Permit# 05OPWE281 Page 41
4.4 This engine qualifies as a new emergency stationary RICE greater than 500 hp located at a major source.
As such, this engine is only subject to the initial notification requirements the National Emissions
Standards for Hazardous Air Pollutants requirements of Regulation No. 8, Part E, Subpart ZZZZ (40
CFR Part 63, Subpart ZZZZ), for Stationary Reciprocating Internal Combustion Engines.
The requirements below reflect the rule language in 40 CFR Part 63 Subpart ZZZZ as of the latest
revisions to 40 CFR Part 63 Subpart ZZZZ published in the Federal Register on February 27, 2014.
However, if revisions to this Subpart are published at a later date, the owner or operator is subject to the
requirements contained in the revised version of 40 CFR Part 63 Subpart ZZZZ.
The D.C. Circuit Court issued a mandate on May 4, 2016 for vacatur for certain requirements allowing
emergency engines to operate for limited hours for demand response. Upon issuance of the mandate, 40
CFR Part §63.6640(f)(2)(ii) - (iii) (Conditions 4.4.1.2.b and 4.4.1.2.c) have no legal effect. Operation of
emergency engines is limited to emergency situations specified in §63.6640(O(1) (Condition 4.4.1.1);
maintenance checks and readiness testing for a limited number of hours per year as specified in
§63.6640(f)(2)(i) (Condition 4.4.1.2.a); and certain non-emergency situations for a limited number of
hours per year as specified in §63.6640(f)(3) (Condition 4.4.1.3). See EPA memorandum dated April 15,
2016 regarding"Guidance on Vacatur of RICE NESHAP and NSPS Provisions for Emergency Engines"
for more information.
It should be noted that additional revisions to the requirements to 40 CFR Part 63 Subpart ZZZZ are
expected to be made in response to issues related to legal action associated with the allowable hours of
operation provisions for emergency engines regarding engines used for demand response. If such
revisions are finalized prior to issuance of the permit,they will be included in the permit.
As of the date of this permit issuance [DATE],the requirements in 40 CFR Part 63 Subpart ZZZZ
promulgated after July 1, 2007 have not been adopted into Colorado Regulation No. 8, Part E and are
therefore not state-enforceable. In the event that these requirements are adopted into Colorado
Regulations,they will become state-enforceable.
4.4.1 If you own or operate an emergency stationary RICE, you must operate the emergency stationary
RICE according to the requirements in Conditions 4.4.1.1 through 4.4.1.3. In order for the engine
to be considered an emergency stationary RICE under this subpart, any operation other than
emergency operation, maintenance and testing, emergency demand response, and operation in
non-emergency situations for 50 hours per year, as described in Condition 4.4.1.3, is prohibited.
If you do not operate the engine according to the requirements in Conditions 4.4.1.1 through
4.4.1.3,the engine will not be considered an emergency engine under this subpart and must meet
all requirements for non-emergency engines (§63.6640(f)).
4.4.1.1 There is no time limit on the use of emergency stationary RICE in emergency
situations.
4.4.1.2 You may operate your emergency stationary RICE for any combination of the
purposes specified in Condition 4.4.1.2.a below for a maximum of 100 hours per
calendar year. Any operation for non-emergency situations as allowed by 4.4.1.3
counts as part of the 100 hours per calendar year allowed by this Condition 4.4.1.2.
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC
Colorado Operating Permit Cheyenne Plains Compressor Station
Permit# 05OPWE281 Page 42
a. Emergency stationary RICE may be operated for maintenance checks and
readiness testing,provided that the tests are recommended by federal, state or
local government, the manufacturer,the vendor,the regional transmission
organization or equivalent balancing authority and transmission operator, or the
insurance company associated with the engine. The owner or operator may
petition the Administrator for approval of additional hours to be used for
maintenance checks and readiness testing, but a petition is not required if the
owner or operator maintains records indicating that federal, state, or local
standards require maintenance and testing of emergency RICE beyond 100 hours
per calendar year.
b. Emergency stationary RICE may be operated for emergency demand response for
periods in which the Reliability Coordinator under the North American Electric
Reliability Corporation(NERC) Reliability Standard EOP-002-3, Capacity and
Energy Emergencies (incorporated by reference, see § 63.14), or other authorized
entity as determined by the Reliability Coordinator, has declared an Energy
Emergency Alert Level 2 as defined in the NERC Reliability Standard EOP-002-
3.
c. Emergency stationary RICE may be operated for periods where there is a
deviation of voltage or frequency of 5 percent or greater below standard voltage
or frequency.
4.4.1.3 Emergency stationary RICE located at major sources of HAP may be operated for up
to 50 hours per calendar year in non-emergency situations. The 50 hours of operation
in non-emergency situations are counted as part of the 100 hours per calendar year for
maintenance and testing and emergency demand response provided in Condition
4.4.1.2. The 50 hours per year for non-emergency situations cannot be used for peak
shaving or non-emergency demand response, or to generate income for a facility to
supply power to an electric grid or otherwise supply power as part of a financial
arrangement with another entity.
The records maintained as required by Condition 4.2 shall be used to monitor the hours and type
of operation for this emergency engine.
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC
Colorado Operating Permit Cheyenne Plains Compressor Station
Permit# 05OPWE281 Page 43
5. Portable Monitoring (06/26/2014)
Emission measurements of nitrogen oxides (NOx) and carbon monoxide (CO) shall be conducted
quarterly using a portable flue gas analyzer. At least one calendar month shall separate the quarterly
tests. Note that if the engine is operated for less than 100 hrs in any quarterly period, then the portable
monitoring requirements do not apply.
All portable analyzer testing required by this permit shall be conducted using the Division's Portable
Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's website at:
https://www.colorado.aov/pacific/cdphe/portable-analyzer-monitoring-protocol
Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For
comparison with an annual or short term emission limit,the results of the tests shall be converted to a
lb/hr basis and multiplied by the allowable operating hours in the month or year(whichever applies) in
order to monitor compliance. If a source is not limited in its hours of operation the test results will be
multiplied by the maximum number of hours in the month or year(8760), whichever applies.
If the portable analyzer results indicate compliance with both the NOx and CO emission limitations, in
the absence of credible evidence to the contrary, the source may certify that the engine is in compliance
with both the NOx and CO emission limitations for the relevant time period.
Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if
the portable analyzer results fail to demonstrate compliance with either the NOx or CO emission
limitations,the engine will be considered to be out of compliance from the date of the portable analyzer
test until a portable analyzer test indicates compliance with both the NOx and CO emission limitations
or until the engine is taken offline.
For comparison with the emission rates/factors,the emission rates/factors determined by the portable
analyzer tests and approved by the Division shall be converted to the same units as the emission
rates/factors in the permit. If the portable analyzer tests shows that either the NOx or CO emission
rates/factors are greater than the relevant ones set forth in the permit, and in the absence of subsequent
testing results to the contrary (as approved by the Division), the permittee shall apply for a modification
to this permit to reflect, at a minimum, the higher emission rate/factor within 60 days of the completion
of the test.
Results of all tests conducted shall be kept on site and made available to the Division upon request.
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC
Colorado Operating Permit Cheyenne Plains Compressor Station
Permit# 05OPWE281 Page 44
6. Point 025 (H-8721)—Two Maxon, Model Tube-o-Flame,Reboiler Burners Rated at 3.8 MMBtu/hr
each (Total of 7.6 MMBtu/hr)
Permit Limitation Compliance Monitoring
Condition Emission Factor
Parameter Number Method Interval
NOx 0.12 lb/MMBtu Recordkeeping&
Annually
CO 6.1 0.1471b/MMBtu Calculation
Hours of Operation 6.2 Recordkeeping Annual
Not to exceed 20%Except
as Provided for Below
For Startup-Not to Only Natural
Opacity 6.3 Exceed 30%,for Fuel Restriction Gas is Used as
a Period or Periods Fuel
Aggregating More
than Six(6)Minutes in any
60 Consecutive Minutes
Only Natural
Particulate Matter
(PM) 6.4 0.30 lb/MMBtu Fuel Restriction Gas is Used as
Fuel
Note that this emission unit is exempt from the construction permit requirements in Regulation No.3,Part B.
6.1 The emission factors listed above have been approved by the Division and shall be used to calculate
emissions from the reboiler burners (from the manufacturer). Annual emissions of Nitrogen Oxide
(NOx) and Carbon Monoxide (CO) emissions for purposes of APEN reporting and payment of annual
fees shall be determined using the above emission factors, the maximum rating for both burners
combined (7.6 MMBtu/hr) and the hours of operation(as required by Condition 4.2)the following
equation:
Tons ( lb hr MMBtu ( lb ton
Year Eyr_ F(MMBtu) x hours of operation(_) x Rating( hr x (453.6 g) x (z000 ton)
6.2 Hours of operation shall be monitored annually and recorded in a log to be made available to the
Division upon request. Recorded data shall be used to calculate emissions as required by Condition 6.1.
6.3 The reboiler burners are subject to the following opacity requirements:
6.3.1 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air
pollutant which is in excess of 20%opacity (Colorado Regulation No. 1, Section II.A.1).
6.3.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air
pollutant resulting from start-up which is in excess of 30%opacity for a period or periods
aggregating more than six(6) minutes in any sixty (60) consecutive minutes (Colorado
Regulation No. 1, Section II.A.4).
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC
Colorado Operating Permit Cheyenne Plains Compressor Station
Permit# 05OPWE281 Page 45
In the absence of credible evidence to the contrary, compliance with the above opacity requirements
shall be presumed since only natural gas is used permitted to be as fuel in these burners. The permittee
shall maintain records that verify that only natural gas is used as fuel in these burners.
6.4 Particulate Matter(PM) emissions from the reboiler burners shall not exceed the above limitation
(Colorado Regulation No. 1, Section III.A.1.b). In the absence of credible evidence to the contrary,
compliance with the particulate matter emission limits is presumed since only natural gas and is
permitted to be used as fuel for the boiler and process heaters. The permittee shall maintain records that
verify that only natural gas is used as fuel in the boiler and process heaters.
Note that the numeric PM standard for the reboiler burners was determined using the design heat input
rate for the unit(7.6 MMBtu/hr) in the following equation:
PE= 0.5 x (FI)-°26 where: PE =particulate standard in lb/MMBtu
FI = fuel input in MMBtu/hr
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC
Colorado Operating Permit Cheyenne Plains Compressor Station
Permit# 05OPWE281 Page 46
7. Additional Colorado Regulation No. 7 Requirements
7.1 Colorado Regulation No. 7, Part D, Section IV.B.4. - Beginning January 1, 2021, each segment owner or
operator will (State-Only Enforceable)
7.1.1 Colorado Regulation No. 7, Part D, Section IV.B.4.a. - Implement company specific BMP plans.
7,1.2 Colorado Regulation No. 7, Part D, Section IV.B.4.b. - Collect emissions inventory data in
accordance with the inventory protocol and its company-specific BMP plan.
7.2 Colorado Regulation No. 7, Part D, Section IV.D.5. - Segment owners or operators must submit an
annual certification to the Division by June 30 of each year(beginning June 30, 2021)that includes
(State-Only Enforceable)
7.2.1 Colorado Regulation No. 7, Part D, Section IV.D.5.a. -A certification that the company-specific
BMP plan was developed or reviewed in accordance with Section IV.B.3.
7.2.2 Colorado Regulation No. 7, Part D, Section IV.D.5.b. -A certification that the company-wide
report was submitted to the third-party contractor in accordance with Section IV.D.3.
7.2.3 Colorado Regulation No. 7, Part D, Section IV.D.5.c. - Beginning in 2022, a certification of
company BMP plan compliance in accordance with Section IV.B.4., including
7.2.3.1 Colorado Regulation No. 7, Part D, Section IV.D.5.c.(i) - The company's
implementation of the BMPs in the company-specific BMP plan.
7.2.3.2 Colorado Regulation No. 7, Part D, Section IV.D.5.c.(ii) - Instances of non-
conformance with the company-specific BMP plan,reason(s) for non-conformance,
and any modifications of the applicable element(s) of the BMP plan.
7.2.3.3 Colorado Regulation No. 7, Part D, Section IV.D.5.c.(iii) -Any use of alternative
emission reduction approaches not specified in the company-specific BMP plan.
7.2.4 Colorado Regulation No. 7, Part D, Section IV.D.5.d. - With each submission under Sections
IV.D.5.a.through IV.D.5.c., a certification by a responsible official that, based on information
and belief after reasonable inquiry, the statements and information in the document are true,
accurate, and complete.
"Best management practice" (BMP)means a demonstrated and commercially available or innovative
emission-reducing technology or work practice (Colorado Regulation No. 7, Part D, Section IV.A.1.).
"Best management practices plan" (BMP plan) means a written plan that includes, but is not limited to,
each natural gas transmission and storage segment owner or operator's planned and implemented BMPs
to reduce methane emissions from its facilities within the natural gas transmission and storage segment
(Colorado Regulation No. 7, Part D, Section IV.A.2.).
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC
Colorado Operating Permit Cheyenne Plains Compressor Station
Permit# 05OPWE281 Page 47
SECTION III- Permit Shield
Regulation No. 3, 5 CCR 1001-5, Part C, §§ I.A.4, V.D. & XIII.B; § 25-7-114.4(3)(a), C.R.S.
1. Specific Non-Applicable Requirements
Based on the information available to the Division and supplied by the applicant, the following
parameters and requirements have been specifically identified as non-applicable to the facility to which
this permit has been issued. This shield does not protect the source from any violations that occurred
prior to or at the time of permit issuance. In addition, this shield does not protect the source from any
violations that occur as a result of any modifications or reconstruction on which construction
commenced prior to permit issuance.
The source did not specifically identify and justify any non-applicable requirements to be included in the
permit shield.
2. General Conditions
Compliance with this Operating Permit shall be deemed compliance with all applicable requirements
specifically identified in the permit and other requirements specifically identified in the permit as not
applicable to the source. This permit shield shall not alter or affect the following:
2.1 The provisions of§§ 25-7-112 and 25-7-113, C.R.S., or § 303 of the federal act, concerning enforcement
in cases of emergency;
2.2 The liability of an owner or operator of a source for any violation of applicable requirements prior to or
at the time of permit issuance;
2.3 The applicable requirements of the federal Acid Rain Program, consistent with § 408(a) of the federal
act;
2.4 The ability of the Air Pollution Control Division to obtain information from a source pursuant to §25-7-
111(2)(I), C.R.S., or the ability of the Administrator to obtain information pursuant to § 114 of the
federal act;
2.5 The ability of the Air Pollution Control Division to reopen the Operating Permit for cause pursuant to
Regulation No. 3, Part C, § XIII.
2.6 Sources are not shielded from terms and conditions that become applicable to the source subsequent to
permit issuance.
3. Stream-lined Conditions
The following applicable requirements have been subsumed within this operating permit using the
pertinent streamlining procedures approved by the U.S. EPA. For purposes of the permit shield,
compliance with the listed permit conditions will also serve as a compliance demonstration for purposes
of the associated subsumed requirements.
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC
Colorado Operating Permit Cheyenne Plains Compressor Station
Permit# 05OPWE281 Page 48
Emission Unit and Applicable Requirement Justification
Condition
Points 015&024:Combustion 40 CFR Part 60 Subpart GG§60.332(b)(as adopted by BACT requirements are more stringent
Turbines-Section II,Condition reference in Regulation No.6,Part A,Subpart GG)
1.2.1.1 [Nitrogen Oxide emissions shall not exceed 189.5
ppmvd at 15%oxygen and ISO standard day conditions]
Points 015&024:Combustion 40 CFR Part 60 Subpart GG§60.334(h)(3),as adopted Numerical SO2 emissions requirements(pipeline
Turbines-Section II,Condition by reference in Colorado Regulation No.6,Part A quality natural gas as defined in 40 CFR Part 72
1.4.1 [source shall monitor the sulfur content of the fuel] (0.5 grains or less of total sulfur per 100 standard
cubic feet)is more stringent than the non-
monitoring demonstration requirement of 20.0
grains/100 scf or less.
Combustions turbines,hot oil Colorado Regulation No.6,Part B,Section II.C.2 Regulation No.6,Part B,Section II.C.2 are state-
heaters,and reboiler burners- [particulate matter emissions shall not exceed 0.5(FI)-°26 only requirements
Section II,Conditions 1.5.1 and lbs/MMBtu]—State Only Requirement
2.4 and 6.4
Combustions turbines,hot oil Colorado Regulation No.6,Part B,Section II.C.3 Regulation No.6,Part B,Section II.C.3 are state-
heater,and reboiler burners- [opacity of emissions shall not exceed 20%]-State only requirements
Section II,Conditions 1.7 and Only Requirement
2.7 and 6.3
Combustion Turbines-Section Colorado Regulation No.6,Part B,Section II.D.3.a Regulation No.6,Part B,Section II.D.3.a are
II,Condition 1.4.2 [SO2 emissions shall not exceed 0.8 lbs/MMBtu]—State state-only requirements
Only Requirement
Combustions turbines&hot oil Regulation No.6,Part B,Section I[general provisions] Regulation No.6,Part B,Section I are state-only
heaters-Section II,Conditions -State-only Requirement requirements
1.8 and 2.5
Section IV,Conditions 22.b and 40 CFR Part 60 Subpart Dc § 60.48c(i) [retain records Title V program requires a record retention period
c for 2 yrs] of 5 years.
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC
Colorado Operating Permit Cheyenne Plains Compressor Station
Permit# 05OPWE281 Page 49
SECTION IV- General Permit Conditions (version 01/21/2020)
1. Administrative Changes
Regulation No.3,5 CCR 1001-5,Part A,§III.
The permittee shall submit an application for an administrative permit amendment to the Division for those permit changes that
are described in Regulation No. 3, Part A, § I.B.1.The permittee may immediately make the change upon submission of the
application to the Division.
2. Certification Requirements
Regulation No.3,5 CCR 1001-5,Part C,§§III.B.9.,V.C.16.a.&e.and V.C.17.
a. Any application,report,document and compliance certification submitted to the Air Pollution Control Division
pursuant to Regulation No.3 or the Operating Permit shall contain a certification by a responsible official of the
truth,accuracy and completeness of such form,report or certification stating that,based on information and belief
formed after reasonable inquiry,the statements and information in the document are true,accurate and complete.
b. All compliance certifications for terms and conditions in the Operating Permit shall be submitted to the Air Pollution
Control Division at least annually unless a more frequent period is specified in the applicable requirement or by the
Division in the Operating Permit.
c. Compliance certifications shall contain:
(i) the identification of each permit term and condition that is the basis of the certification;
(ii) the compliance status of the source;
(iii) whether compliance was continuous or intermittent;
(iv) method(s)used for determining the compliance status of the source,currently and over the reporting
period;and
(v) such other facts as the Air Pollution Control Division may require to determine the compliance status of the
source.
d. All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental
Protection Agency at the addresses listed in Appendix D of this Permit.
e. If the permittee is required to develop and register a risk management plan pursuant to § 112(r)of the federal act,the
permittee shall certify its compliance with that requirement;the Operating Permit shall not incorporate the contents
of the risk management plan as a permit term or condition.
3. Common Provisions
Common Provisions Regulation,5 CCR 1001-2 §§ II.A.,II.B.,II.C.,II.E.,II.F.,II.I,and II.J
a. To Control Emissions Leaving Colorado
When emissions generated from sources in Colorado cross the State boundary line,such emissions shall not cause
the air quality standards of the receiving State to be exceeded,provided reciprocal action is taken by the receiving
State.
b. • Emission Monitoring Requirements
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC
Colorado Operating Permit Cheyenne Plains Compressor Station
Permit# 05OPWE281 Page 50
The Division may require owners or operators of stationary air pollution sources to install,maintain,and use
instrumentation to monitor and record emission data as a basis for periodic reports to the Division.
c. Performance Testing
The owner or operator of any air pollution source shall,upon request of the Division,conduct performance test(s)
and furnish the Division a written report of the results of such test(s)in order to determine compliance with
applicable emission control regulations.
Performance test(s)shall be conducted and the data reduced in accordance with the applicable reference test
methods unless the Division:
(i) specifies or approves,in specific cases,the use of a test method with minor changes in methodology;
(ii) approves the use of an equivalent method;
(iii) approves the use of an alternative method the results of which the Division has determined to be adequate
for indicating where a specific source is in compliance;or
(iv) waives the requirement for performance test(s)because the owner or operator of a source has demonstrated
by other means to the Division's satisfaction that the affected facility is in compliance with the standard.
Nothing in this paragraph shall be construed to abrogate the Commission's or Division's authority to
require testing under the Colorado Revised Statutes,Title 25,Article 7,and pursuant to regulations
promulgated by the Commission.
Compliance test(s)shall be conducted under such conditions as the Division shall specify to the plant operator based
on representative performance of the affected facility.The owner or operator shall make available to the Division
such records as may be necessary to determine the conditions of the performance test(s).Operations during period of
startup,shutdown,and malfunction shall not constitute representative conditions of performance test(s)unless
otherwise specified in the applicable standard.
The owner or operator of an affected facility shall provide the Division thirty days prior notice of the performance
test to afford the Division the opportunity to have an observer present.The Division may waive the thirty day notice
requirement provided that arrangements satisfactory to the Division are made for earlier testing.
The owner or operator of an affected facility shall provide,or cause to be provided,performance testing facilities as
follows:
(i) Sampling ports adequate for test methods applicable to such facility;
(ii) Safe sampling platform(s);
(iii) Safe access to sampling platform(s);and
(iv) Utilities for sampling and testing equipment.
Each performance test shall consist of at least three separate runs using the applicable test method.Each run shall be
conducted for the time and under the conditions specified in the applicable standard.For the purpose of determining
compliance with an applicable standard,the arithmetic mean of results of at least three runs shall apply.In the event
that a sample is accidentally lost or conditions occur in which one of the runs must be discontinued because of
forced shutdown,failure of an irreplaceable portion of the sample train,extreme meteorological conditions,or other
circumstances beyond the owner or operator's control,compliance may,upon the Division's approval,be
determined using the arithmetic mean of the results of the two other runs.
Nothing in this section shall abrogate the Division's authority to conduct its own performance test(s)if so warranted.
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC
Colorado Operating Permit Cheyenne Plains Compressor Station
Permit# 05OPWE281 Page 51
d. Affirmative Defense Provision for Excess Emissions during Malfunctions
An affirmative defense to a claim of violation under these regulations is provided to owners and operators for civil
penalty actions for excess emissions during periods of malfunction.To establish the affirmative defense and to be
relieved of a civil penalty in any action to enforce an applicable requirement,the owner or operator of the facility
must meet the notification requirements below in a timely manner and prove by a preponderance of evidence that:
(i) The excess emissions were caused by a sudden,unavoidable breakdown of equipment,or a sudden,
unavoidable failure of a process to operate in the normal or usual manner,beyond the reasonable control of
the owner or operator;
(ii) The excess emissions did not stem from any activity or event that could have reasonably been foreseen and
avoided,or planned for,and could not have been avoided by better operation and maintenance practices;
(iii) Repairs were made as expeditiously as possible when the applicable emission limitations were being
exceeded;
(iv) The amount and duration of the excess emissions(including any bypass)were minimized to the maximum
extent practicable during periods of such emissions;
(v) All reasonably possible steps were taken to minimize the impact of the excess emissions on ambient air
quality;
(vi) All emissions monitoring systems were kept in operation(if at all possible);
(vii) The owner or operator's actions during the period of excess emissions were documented by properly
signed,contemporaneous operating logs or other relevant evidence;
(viii) The excess emissions were not part of a recurring pattern indicative of inadequate design,operation,or
maintenance;
(ix) At all times,the facility was operated in a manner consistent with good practices for minimizing emissions.
This section is intended solely to be a factor in determining whether an affirmative defense is available to
an owner or operator,and shall not constitute an additional applicable requirement;and
(x) During the period of excess emissions,there were no exceedances of the relevant ambient air quality
standards established in the Commissions' Regulations that could be attributed to the emitting source.
The owner or operator of the facility experiencing excess emissions during a malfunction shall notify the division
verbally as soon as possible, but no later than noon of the Division's next working day, and shall submit written
notification following the initial occurrence of the excess emissions by the end of the source's next reporting period.
The notification shall address the criteria set forth above.
The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief.
The Affirmative Defense Provision does not apply to failures to meet federally promulgated performance standards
or emission limits, including, but not limited to,new source performance standards and national emission standards
for hazardous air pollutants.The affirmative defense provision does not apply to state implementation plan(sip)limits
or permit limits that have been set taking into account potential emissions during malfunctions, including, but not
necessarily limited to, certain limits with 30-day or longer averaging times, limits that indicate they apply during
malfunctions,and limits that indicate they apply at all times or without exception.
e. Circumvention Clause
A person shall not build,erect,install,or use any article,machine,equipment,condition,or any contrivance,the use
of which,without resulting in a reduction in the total release of air pollutants to the atmosphere,reduces or conceals
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an emission which would otherwise constitute a violation of this regulation.No person shall circumvent this
regulation by using more openings than is considered normal practice by the industry or activity in question.
f. Compliance Certifications
For the purpose of submitting compliance certifications or establishing whether or not a person has violated or is in
violation of any standard in the Colorado State Implementation Plan,nothing in the Colorado State Implementation
Plan shall preclude the use,including the exclusive use,of any credible evidence or information,relevant to whether
a source would have been in compliance with applicable requirements if the appropriate performance or compliance
test or procedure had been performed.Evidence that has the effect of making any relevant standard or permit term
more stringent shall not be credible for proving a violation of the standard or permit term.
When compliance or non-compliance is demonstrated by a test or procedure provided by permit or other applicable
requirement,the owner or operator shall be presumed to be in compliance or non-compliance unless other relevant
credible evidence overcomes that presumption.
g. Affirmative Defense Provision for Excess Emissions During Startup and Shutdown
An affirmative defense is provided to owners and operators for civil penalty actions for excess emissions during
periods of startup and shutdown.To establish the affirmative defense and to be relieved of a civil penalty in any
action to enforce an applicable requirement,the owner or operator of the facility must meet the notification
requirements below in a timely manner and prove by a preponderance of the evidence that:
(i) The periods of excess emissions that occurred during startup and shutdown were short and infrequent and
could not have been prevented through careful planning and design;
(ii) The excess emissions were not part of a recurring pattern indicative of inadequate design,operation or
maintenance;
(iii) If the excess emissions were caused by a bypass(an intentional diversion of control equipment),then the
bypass was unavoidable to prevent loss of life,personal injury,or severe property damage;
(iv) The frequency and duration of operation in startup and shutdown periods were minimized to the maximum
extent practicable;
(v) All possible steps were taken to minimize the impact of excess emissions on ambient air quality;
(vi) All emissions monitoring systems were kept in operation(if at all possible);
(vii) The owner or operator's actions during the period of excess emissions were documented by properly
signed,contemporaneous operating logs or other relevant evidence;and,
(viii) At all times,the facility was operated in a manner consistent with good practices for minimizing emissions.
This subparagraph is intended solely to be a factor in determining whether an affirmative defense is
available to an owner or operator,and shall not constitute an additional applicable requirement.
The owner or operator of the facility experiencing excess emissions during startup and shutdown shall notify the
Division verbally as soon as possible,but no later than two(2)hours after the start of the next working day,and shall
submit written quarterly notification following the initial occurrence of the excess emissions. The notification shall
address the criteria set forth above.
The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief.
The Affirmative Defense Provision does not apply to State Implementation Plan provisions or other requirements that
derive from new source performance standards or national emissions standards for hazardous air pollutants, or any
other federally enforceable performance standard or emission limit with an averaging time greater than twenty-four
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hours.In addition,an affirmative defense cannot be used by a single source or small group of sources where the excess
emissions have the potential to cause an exceedance of the ambient air quality standards or Prevention of Significant
Deterioration(PSD)increments.
In making any determination whether a source established an affirmative defense,the Division shall consider the
information within the notification required above and any other information the Division deems necessary,which
may include,but is not limited to,physical inspection of the facility and review of documentation pertaining to the
maintenance and operation of process and air pollution control equipment.
4. Compliance Requirements
Regulation No.3,5 CCR 1001-5,Part C, III.C.9.,V.C.11.& 16.d.and§25-7-122.1(2),C.R.S.
a. The permittee must comply with all conditions of the Operating Permit.Any permit noncompliance relating to
federally-enforceable terms or conditions constitutes a violation of the federal act,as well as the state act and
Regulation No.3.Any permit noncompliance relating to state-only terms or conditions constitutes a violation of the
state act and Regulation No.3,shall be enforceable pursuant to state law,and shall not be enforceable by citizens
under§304 of the federal act.Any such violation of the federal act,the state act or regulations implementing either
statute is grounds for enforcement action,for permit termination,revocation and reissuance or modification or for
denial of a permit renewal application.
b. It shall not be a defense for a permittee in an enforcement action or a consideration in favor of a permittee in a
permit termination,revocation or modification action or action denying a permit renewal application that it would
have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of
the permit.
c. The permit may be modified,revoked,reopened,and reissued,or terminated for cause.The filing of any request by
the permittee for a permit modification,revocation and reissuance,or termination,or any notification of planned
changes or anticipated noncompliance does not stay any permit condition,except as provided in§§ X.and XI.of
Regulation No.3,Part C.
d. The permittee shall furnish to the Air Pollution Control Division,within a reasonable time as specified by the
Division,any information that the Division may request in writing to determine whether cause exists for modifying,
revoking and reissuing,or terminating the permit or to determine compliance with the permit.Upon request,the
permittee shall also furnish to the Division copies of records required to be kept by the permittee, including
information claimed to be confidential.Any information subject to a claim of confidentiality shall be specifically
identified and submitted separately from information not subject to the claim.
e. Any schedule for compliance for applicable requirements with which the source is not in compliance at the time of
permit issuance shall be supplemental,and shall not sanction noncompliance with,the applicable requirements on
which it is based.
f. For any compliance schedule for applicable requirements with which the source is not in compliance at the time of
permit issuance,the permittee shall submit,at least every 6 months unless a more frequent period is specified in the
applicable requirement or by the Air Pollution Control Division,progress reports which contain the following:
(i) dates for achieving the activities,milestones,or compliance required in the schedule for compliance,and
dates when such activities,milestones,or compliance were achieved;and
(ii) an explanation of why any dates in the schedule of compliance were not or will not be met,and any
preventive or corrective measures adopted.
g. The permittee shall not knowingly falsify,tamper with,or render inaccurate any monitoring device or method
required to be maintained or followed under the terms and conditions of the Operating Permit.
5. Emergency Provisions
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Regulation No.3,5 CCR 1001-5,Part C,§VII
An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source,
including acts of God,which situation requires immediate corrective action to restore normal operation, and that causes the
source to exceed the technology-based emission limitation under the permit due to unavoidable increases in emissions
attributable to the emergency. "Emergency" does not include noncompliance to the extent caused by improperly designed
equipment, lack of preventative maintenance, careless or improper operation,or operator error. An emergency constitutes an
affirmative defense to an enforcement action brought for noncompliance with a technology-based emission limitation if the
permittee demonstrates,through properly signed,contemporaneous operating logs,or other relevant evidence that:
a. an emergency occurred and that the permittee can identify the cause(s)of the emergency;
b. the permitted facility was at the time being properly operated;
c. during the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that
exceeded the emission standards,or other requirements in the permit; and
d. the permittee submitted oral notice of the emergency to the Air Pollution Control Division no later than noon of the
next working day following the emergency,and followed by written notice within one month of the time when
emissions limitations were exceeded due to the emergency.This notice must contain a description of the emergency,
any steps taken to mitigate emissions,and corrective actions taken.
This emergency provision is in addition to any emergency or malfunction provision contained in any applicable requirement.
6. Emission Controls 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,"asbestos control."
7. Emissions Trading,Marketable Permits,Economic Incentives
Regulation No.3,5 CCR 1001-5,Part C,& V.C.13.
No permit revision shall be required under any approved economic incentives,marketable permits,emissions trading and other
similar programs or processes for changes that are specifically provided for in the permit.
8. Fee Payment
C.R.S §§25-7-114.1(6)and 25-7-114.7
a. The permittee shall pay an annual emissions fee in accordance with the provisions of C.R.S. §25-7-114.7.A 1%per
month late payment fee shall be assessed against any invoice amounts not paid in full on the 91st day after the date
of invoice,unless a permittee has filed a timely protest to the invoice amount.
b. The permittee shall pay a permit processing fee in accordance with the provisions of C.R.S. §25-7-114.7.If the
Division estimates that processing of the permit will take more than 30 hours,it will notify the permittee of its
estimate of what the actual charges may be prior to commencing any work exceeding the 30 hour limit.
c. The permittee shall pay an APEN fee in accordance with the provisions of C.R.S. §25-7-114.1(6)for each APEN or
revised APEN filed.
9. Fugitive Particulate Emissions
Regulation No. 1,5 CCR 1001-3, §III.D.1.
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The permittee shall employ such control measures and operating procedures as are necessary to minimize fugitive particulate
emissions into the atmosphere, in accordance with the provisions of Regulation No. 1, §III.D.1.
10. Inspection and Entry
Regulation No.3,5 CCR 1001-5,Part C, &V.C.16.b.
Upon presentation of credentials and other documents as may be required by law,the permittee shall allow the Air Pollution
Control Division,or any authorized representative,to perform the following:
a. enter upon the permittee's premises where an Operating Permit source is located,or emissions-related activity is
conducted,or where records must be kept under the terms of the permit;
b. have access to,and copy,at reasonable times,any records that must be kept under the conditions of the permit;
c. inspect at reasonable times any facilities,equipment(including monitoring and air pollution control equipment),
practices,or operations regulated or required under the Operating Permit;
d. sample or monitor at reasonable times,for the purposes of assuring compliance with the Operating Permit or
applicable requirements,any substances or parameters.
11. Minor Permit Modifications
Regulation No.3,5 CCR 1001-5,Part C, &§X.&XI.
The permittee shall submit an application for a minor permit modification before making the change requested in the
application.The permit shield shall not extend to minor permit modifications.
12. New Source Review
Regulation No.3,5 CCR 1001-5,Parts B&D
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,Parts B and/or D,as applicable,without first receiving a construction permit.
13. No Property Rights Conveyed
Regulation No.3,5 CCR 1001-5,Part C,&V.C.11.d.
This permit does not convey any property rights of any sort,or any exclusive privilege.
14. Odor
Regulation No.2,5 CCR 1001-4,Part A
As a matter of state law only,the permittee shall comply with the provisions of Regulation No.2 concerning odorous emissions.
15. Off-Permit Changes to the Source
Regulation No.3,5 CCR 1001-5,Part C, §XII.B.
The permittee shall record any off-permit change to the source that causes the emissions of a regulated pollutant subject to an
applicable requirement, but not otherwise regulated under the permit, and the emissions resulting from the change, including
any other data necessary to show compliance with applicable ambient air quality standards. The permittee shall provide
contemporaneous notification to the Air Pollution Control Division and to the Environmental Protection Agency at the
addresses listed in Appendix D of this Permit.The permit shield shall not apply to any off-permit change.
16. Opacity
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Regulation No. 1,5 CCR 1001-3, I.,II.
The permittee shall comply with the opacity emissions limitation set forth in Regulation No. 1, §§ I.-II.
17. Open Burning
Regulation No.9,5 CCR 1001-11
The permittee shall obtain a permit from the Division for any regulated open burning activities in accordance with provisions
of Regulation No.9.
18. Ozone Depleting Compounds
Regulation No. 15,5 CCR 1001-19
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.
19. Permit Expiration and Renewal
Regulation No.3,5 CCR 1001-5,Part C,$$III.B.6.,IV.C.,V.C.2.
a. The permit term shall be five(5)years.The permit shall expire at the end of its term.Permit expiration terminates
the permittee's right to operate unless a timely and complete renewal application is submitted.
b. Applications for renewal shall be submitted at least twelve months,but not more than 18 months,prior to the
expiration of the Operating Permit.An application for permit renewal may address only those portions of the permit
that require revision,supplementing,or deletion,incorporating the remaining permit terms by reference from the
previous permit.A copy of any materials incorporated by reference must be included with the application.
20. Portable Sources
Regulation No.3,5 CCR 1001-5,Part C,§II.D.
Portable Source permittees shall notify the Air Pollution Control Division at least 10 days in advance of each change in location.
21. Prompt Deviation Reporting
Regulation No.3,5 CCR 1001-5,Part C,§V.C.7.b.
The permittee shall promptly report any deviation from permit requirements, including those attributable to malfunction
conditions as defined in the permit,the probable cause of such deviations, and any corrective actions or preventive measures
taken.
"Prompt"is defined as follows:
a. Any definition of"prompt"or a specific timeframe for reporting deviations provided in an underlying applicable
requirement as identified in this permit;or
b. Where the underlying applicable requirement fails to address the time frame for reporting deviations,reports of
deviations will be submitted based on the following schedule:
(I) For emissions of a hazardous air pollutant or a toxic air pollutant(as identified in the applicable regulation)
that continue for more than an hour in excess of permit requirements,the report shall be made within 24
hours of the occurrence;
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(ii) For emissions of any regulated air pollutant,excluding a hazardous air pollutant or a toxic air pollutant that
continue for more than two hours in excess of permit requirements,the report shall be made within 48
hours;and
(iii) For all other deviations from permit requirements,the report shall be submitted every six(6)months,
except as otherwise specified by the Division in the permit in accordance with paragraph 22.d.below.
c. If any of the conditions in paragraphs b.i or b.ii above are met,the source shall notify the Division by telephone
(303-692-3155)or facsimile(303-782-0278)based on the timetables listed above.[Explanatory note:Notification
by telephone or facsimile must sped that this notification is a deviation report for an Operating Permit.]A written
notice,certified consistent with General Condition 2.a.above(Certification Requirements),shall be submitted
within 10 working days of the occurrence.All deviations reported under this section shall also be identified in the 6-
month report required above.
"Prompt reporting"does not constitute an exception to the requirements of"Emergency Provisions"for the purpose of avoiding
enforcement actions.
22. Record Keeping and Reporting Requirements
Regulation No.3,5 CCR 1001-5,Part A, 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 compliance assurance monitoring rule,or the Division requires
submission on a more frequent basis.All instances of deviations from any permit requirements must be clearly
identified in such reports.
e. The permittee shall file an Air Pollutant Emissions Notice("APEN")prior to constructing,modifying,or altering
any facility,process,activity which constitutes a stationary source from which air pollutants are or are to be emitted,
unless such source is exempt from the APEN filing requirements of Regulation No.3,Part A, §II.D or as provided
for in Regulation No.3,Part A,§II.A.2 for oil and gas well production facilities.A revised APEN shall be filed
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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,
except an APEN shall be filed once per year for control equipment at condensate storage tanks located at oil and gas
exploration and production facilities subject to Regulation No.7,Part D§I.Annual fees are based on the most
recent APEN on file with the Division.
23. Reopenings for Cause
Regulation No.3,5 CCR 1001-5,Part C, §XIII.
a. The Air Pollution Control Division shall reopen,revise,and reissue Operating Permits;permit reopenings and
reissuance shall be processed using the procedures set forth in Regulation No.3,Part C, §III.,except that
proceedings to reopen and reissue permits affect only those parts of the permit for which cause to reopen exists.
b. The Division shall reopen a permit whenever additional applicable requirements become applicable to a major
source with a remaining permit term of three or more years,unless the effective date of the requirements is later than
the date on which the permit expires,or unless a general permit is obtained to address the new requirements;
whenever additional requirements(including excess emissions requirements)become applicable to an affected
source under the acid rain program;whenever the Division determines the permit contains a material mistake or that
inaccurate statements were made in establishing the emissions standards or other terms or conditions of the permit;
or whenever the Division determines that the permit must be revised or revoked to assure compliance with an
applicable requirement.
c. The Division shall provide 30 days' advance notice to the permittee of its intent to reopen the permit,except that a
shorter notice may be provided in the case of an emergency.
d. The permit shield shall extend to those parts of the permit that have been changed pursuant to the reopening and
reissuance procedure.
24. Requirements for Major Stationary Sources
Regulation No.3,5 CCR 1001-5,Part D, §§V.A.7.c&d,VI.B.5&VI.B.6
The following provisions apply to projects at existing emissions units at a major stationary source (other than projects at a
source with a PAL) that are not part of a major modification and where the owner or operator relies on projected actual
emissions. The definitions of baseline actual emissions, major modification, major stationary source, PAL, projected actual
emissions,regulated NSR pollutant and significant can be found in Regulation No.3,Part D, § II.A.
a. Before beginning actual construction of the project,the owner or operator shall document and maintain a record of
the following information:
(i) a description of the project;
(ii) identification of the emissions unit(s)whose emissions of a regulated NSR pollutant could be affected by
the project;and
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(iii) a description of the applicability test used to determine the project is not a major modification for any
regulated NSR pollutants,including the baseline actual emissions,the projected actual emissions,the
amount of emissions excluded and an explanation for why such amount was excluded,and any netting
calculations, if applicable.
b. The owner or operator shall monitor emissions of any regulated NSR pollutant that could increase as a result of the
project from any emissions units identified in paragraph a.(ii)and calculate and maintain a record of the annual
emissions,in tons per year on a calendar year basis,for a period of five(5)years following resumption of regular
operation after the change,or for a period of ten(10)years following resumption of regular operation after the
change if the project increases the design capacity or potential to emit of that regulated NSR pollutant at such
emissions unit.
c. For existing electric utility steam generating units the following requirements apply:
(i) Before beginning actual construction,the owner or operator shall provide a copy of the information
required by paragraph a above to the Division.The owner or operator is not required to obtain a
determination from the Division prior to beginning actual construction.
(ii) The owner or operate shall submit a report to the Division within sixty days after the end of each year
during which records must be generated under paragraph b above setting out the unit's annual emissions
during the calendar year that preceded submission of the report.
d. For existing emissions units that are not electric utility steam generating units,the owner or operator shall submit a
report to the Division if the annual emissions from the project,in tons per year,exceed the baseline actual emissions
(documented and maintained per paragraph a(iii))by a significant amount for that regulated NSR pollutant,and if
such emissions differ from the preconstruction projection(documented and maintained per paragraph a.(iii)). Such
report shall be submitted to the Division within sixty days after the end of such year.The report shall contain the
following:
(i) The name,address and telephone number of the owner or operator;
(ii) The annual emissions as calculated per paragraph b;and
(iii) Any other information that the owner or operator wishes to include in the report.
e. The owner of operation of the source shall make the information in paragraph a available for review upon request to
the Division or the general public.
25. 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.
26. Severability Clause
Regulation No.3,5 CCR 1001-5,Part C,§V.C.10.
In the event of a challenge to any portion of the permit,all emissions limits,specific and general conditions,monitoring,record
keeping and reporting requirements of the permit,except those being challenged,remain valid and enforceable.
27. Significant Permit Modifications
Regulation No.3,5 CCR 1001-5,Part C,§III.B.2.
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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.
28. 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.
29. 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.
30. Volatile Organic Compounds
Regulation No.7,5 CCR 1001-9,Part B,§§ I&III.
The requirements in paragraphs a, b and e apply to sources located in the Denver 1-hour ozone attainment/maintenance area,
any nonattainment area for the 1-hour ozone standard and to the 8-hour Ozone Control Area and on a state-only basis to sources
located in any ozone nonattainment area,which includes areas designated nonattainment for either the 1-hour or 8-hour ozone
standard,unless otherwise specified in Regulation No.7,Part A,Section I.A.1.c.The requirements in paragraphs c and d apply
statewide.
a. 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,Part B,Section VI.C.3.
b. Except as 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.
c. No person shall dispose of volatile organic compounds by evaporation or spillage unless Reasonably Available
Control Technology(RACT)is utilized.
d. No owner or operator of a bulk gasoline terminal,bulk gasoline plant,or gasoline dispensing facility as defined in
Colorado Regulation No. 7,Part B,Sections IV.C.2.,IV.C.3. and VII.A.3.,shall permit gasoline to be intentionally
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spilled,discarded in sewers,stored in open containers,or disposed of in any other manner that would result in
evaporation.
e. Beer production and associated beer container storage and transfer operations involving volatile organic compounds
with a true vapor pressure of less than 1.5 psia actual conditions are exempt from the provisions of paragraph b,
above.
31. Wood Stoves and Wood burning Appliances
Regulation No.4,5 CCR 1001-6
The permittee shall comply with the provisions of Regulation No.4 concerning the advertisement,sale,installation,and use of
wood stoves and wood burning appliances.
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division company_name
Colorado Operating Permit facility_name
Appendices Page 62
Operating Permit Appendices
Appendix A—Inspection Information
Appendix B—Monitoring and Permit Deviation Report
Appendix C—Compliance Certification Report
Appendix D—Notification Addresses
Appendix E—Permit Acronyms
Appendix F—Permit Modifications
DISCLAIMER:None of the information found in these Appendices shall be considered to be State or
Federally enforceable, except as otherwise provided in the permit, and is presented to assist the source,
permitting authority, inspectors, and citizens.
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix A
Inspection Information Page 63
A. Appendix A - Inspection Information
A.I. Directions to Plant:
From 1-25 take exit 293 through the town of Carr, Colorado to Rockport, Colorado.
The Cheyenne Plains Compressor Station is located approximately four(4) miles north of Rockport
in Weld County on Highway 85.
A.II. Safety Equipment Required:
Eye Protection
Hard Hat
Safety Shoes
Hearing Protection
Fire Retardant Clothing (i.e.NOMEX®)
A.III. Facility Plot Plan:
The attached figure shows the plot plan as submitted on April 20, 2005 with additional information
used to support the processing of the Title V renewal permit for the Cheyenne Compressor Station
(95OPWE090).
A.IV. 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.
The asterisk(*) denotes an insignificant activity source category based on the size of the activity,
emissions levels from the activity or the production rate of the activity. The owner or operator of
individual emission points in insignificant activity source categories marked with an asterisk(*)
must maintain sufficient record keeping verifying that the exemption applies. Such records shall be
made available for Division review upon request(Colorado Regulation No. 3, Part C, Section II.E).
Insignificant activities and/or sources of emissions identified by the permittee are as follows:
A.IV.1. Units with emissions less than APEN de minimis—criteria pollutants (Reg 3, Part
C.II.E.3.b)*
Emergency shutdowns (VOC emissions <2 tons/yr).
Fugitive VOC emissions from Equipment leaks (VOC emissions <2 tons/yr)
Turbine startups (VOC emissions <2 tons/yr)
Waste Tank T-8807 (VOC emissions <2 tons/yr)
Waste Tank T-8811 (VOC emissions <2 tons/yr)
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix A
Inspection Information Page 64
A.IV.2. Fuel (gaseous) burning equipment< 5 mmBtu/hr(Reg 3, Part C.II.E.3.k)*
Utility heater, 5 MMBtu/hr
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix A
Inspection Information Page 65
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Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Compliance Certification Report Page 66
B. Appendix B — 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 Source must comply with all conditions of this operating permit. Any permit noncompliance
constitutes a violation of the Act and is grounds for enforcement action; for permit termination,
revocation and reissuance, or modification; or for denial of a permit renewal application.
The Part 70 Operating Permit program requires three types of reports to be filed for all permits. All
required reports must be certified by a responsible official.
Report#1: Monitoring Deviation Report (due at least every six months)
For purposes of this operating permit, the Division is requiring that the monitoring reports are due
every six months unless otherwise noted in the permit. All instances of deviations from permit
monitoring requirements must be clearly identified in such reports.
For purposes of this operating permit, monitoring means any condition determined by observation, by
data from any monitoring protocol, or by any other monitoring which is required by the permit as well
as the recordkeeping associated with that monitoring. This would include, for example, fuel use or
process rate monitoring, fuel analyses, and operational or control device parameter monitoring.
Report#2: Permit Deviation Report(must be reported "promptly")
In addition to the monitoring requirements set forth in the permits as discussed above, each and every
requirement of the permit is subject to deviation reporting. The reports must address deviations from
permit requirements, including those attributable to malfunctions as defined in this Appendix, the.
probable cause of 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.
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Compliance Certification Report Page 67
For purposes of this operating permit, "malfunction" shall refer to both emergency conditions and
malfunctions. Additional discussion on these conditions is provided later in this Appendix.
,For purposes of this operating permit, the Division is requiring that the permit deviation reports are due
as set forth in General Condition 21. Where the underlying applicable requirement contains a definition
of prompt or otherwise specifies a time frame for reporting deviations,that definition or time frame shall
govern. For example, quarterly Excess Emission Reports required by an NSPS or Regulation No. 1,
Section IV.
In addition to the monitoring deviations discussed above, included in the meaning of deviation for the
purposes of this operating permit are any of the following:
(1) A situation where emissions exceed an emission limitation or standard contained in the permit;
(2) A situation where process or control device parameter values demonstrate that an emission
limitation or standard contained in the permit has not been met;
(3) A situation in which observations or data collected demonstrates noncompliance with an emission
limitation or standard or any work practice or operating condition required by the permit; or,
(4) A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the Compliance
Assurance Monitoring(CAM)Rule) has occurred. (only if the emission point is subject to CAM)
For reporting purposes, the Division has combined the Monitoring Deviation Report with the Permit
Deviation Report. All deviations shall be reported using the following codes:
1 = Standard: When the requirement is an emission limit or standard
2 =Process: When the requirement is a production/process limit
3=Monitor: When the requirement is monitoring
4=Test: When the requirement is testing
5=Maintenance: When required maintenance is not performed
6=Record: When the requirement is recordkeeping
7=Report: When the requirement is reporting
8=CAM: A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the
Compliance Assurance Monitoring (CAM) Rule) has occurred.
9=Other: When the deviation is not covered by any of the above categories
Report#3: Compliance Certification (annually, as defined in the permit)
Submission of compliance certifications with terms and conditions in the permit, including emission
limitations, standards, or work practices, is required not less than annually.
Compliance Certifications are intended to state the compliance status of each requirement of the permit
over the certification period. They must be based, at a minimum, on the testing and monitoring methods
specified in the permit that were conducted during the relevant time period. In addition, if the owner or
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Compliance Certification Report Page 68
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;
• Whether or not the method(s) used by the owner or operator for determining the compliance
status with each permit term and condition during the certification period was the method(s)
specified in the permit. Such methods and other means shall include, at a minimum,the methods
and means required in the permit. If necessary,the owner or operator also shall identify any other
material information that must be included in the certification to comply with section 113(c)(2)
of the Federal Clean Air Act, which prohibits knowingly making a false certification or omitting
material information;
• The status of compliance with the terms and conditions of the permit, and whether compliance
was continuous or intermittent. The certification shall identify each deviation and take it into
account in the compliance certification.Note that not all deviations are considered violations.'
• Such other facts as the Division may require, consistent with the applicable requirements to
which the source is subject,to determine the compliance status of the source.
The Certification shall also identify as possible exceptions to compliance any periods during which
compliance is required and in which an excursion or exceedance as defined under 40 CFR Part 64 (the
Compliance Assurance Monitoring(CAM) Rule) has occurred(only for emission points subject to
CAM).
Note the requirement that the certification shall identify each deviation and take it into account in the
compliance certification. Previously submitted deviation reports, including the deviation report
submitted at the time of the annual certification, may be referenced in the compliance certification.
For example, given the various emissions limitations and monitoring requirements to which a source may be
subject, a deviation from one requirement may not be a deviation under another requirement which recognizes
an exception and/or special circumstances relating to that same event.
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Compliance Certification Report Page 69
Startup, Shutdown, Malfunctions and Emergencies,
Understanding the application of Startup, Shutdown, Malfunctions and Emergency Provisions, is very important
in both the deviation reports and the annual compliance certifications.
Startup, Shutdown, and Malfunctions
Please note that exceedances of some New Source Performance Standards (NSPS) and Maximum Achievable
Control Technology (MACT) standards that occur during Startup, Shutdown or Malfunctions may not be
considered to be non-compliance since emission limits or standards often do not apply unless specifically stated
in the NSPS. Such exceedances must, however, be reported as excess emissions per the NSPS/MACT rules and
would still be noted in the deviation report. In regard to compliance certifications, the permittee should be
confident of the information related to those deviations when making compliance determinations since they are
subject to Division review. The concepts of Startup, Shutdown and Malfunctions also exist for Best Available
Control Technology (BACT) sources, but are not applied in the same fashion as for NSPS and MACT sources.
Emergency Provisions
Under the Emergency provisions of Part 70 certain operational conditions may act as an affirmative defense
against enforcement action if they are properly reported.
DEFINITIONS
Malfunction (NSPS) means any sudden, infrequent, and not reasonably preventable failure of air pollution
control equipment, process equipment, or a process to operate in a normal or usual manner. Failures that are
caused in part by poor maintenance or careless operation are not malfunctions.
Malfunction (SIP) means any sudden and unavoidable failure of air pollution control equipment or process
equipment or unintended failure of a process to operate in a normal or usual manner. Failures that are primarily
caused by poor maintenance, careless operation, or any other preventable upset condition or preventable
equipment breakdown shall not be considered malfunctions.
Emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of
the source, including acts of God, which situation requires immediate corrective action to restore normal
operation, and that causes the source to exceed a technology-based emission limitation under the permit, due to
unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance
to the extent caused by improperly designed equipment, lack of preventative maintenance, careless or improper
operation, or operator error.
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Compliance Certification Report Page 70
B.I. Appendix B—Monitoring and Permit Deviation Report-Part I
B.I.1. Following is the required format for the Monitoring and Permit Deviation report to be
submitted to the Division as set forth in General Condition 21. The Table below must be
completed for all equipment or processes for which specific Operating Permit terms exist.
B.I.2. Part II of this Appendix B shows the format and information the Division will require for
describing periods of monitoring and permit deviations, or malfunction or emergency
conditions as indicated in the Table below. One Part II Form must be completed for each
Deviation. Previously submitted reports (e.g. EER's or malfunctions) may be referenced
and the form need not be filled out in its entirety.
FACILITY NAME: Cheyenne Plains Gas Pipeline Company, LLC—Cheyenne Plains Compressor Station
OPERATING PERMIT NO: 05OPWE281
REPORTING PERIOD: (see first page of the permit for specific reporting period and dates)
Deviations noted Deviation Malfunction/Emergency
Emission Unit Condition Reported
During Period? Code z
Facility ID During Period?
Unit Description YES NO YES NO
CP CG-7101 Solar Taurus Natural Gas Fired Turbine,
Model No.70-10302S,Engine Serial No.
OHC10-B8166.The turbine is rated at 9,816
hp and 71.42 mmBtu/hr. Package Skid
Serial Number TC04639.
CP CG-7201 Solar Taurus Natural Gas Fired Turbine,
Model No.70-10302S,Engine Serial No.
OHL09-B4243.The turbine is rated at 9,816
hp and 71.42 mmBtu/hr.Package Skid Serial
Number TC04638.
CP CG-7301 Solar Taurus Natural Gas Fired Turbine,
Model No.70- 10302S,Engine Serial No.
OHB16-B8446.The turbine is rated at 9,816
hp and 71.42 mmBtu/hr.Package Skid Serial
Number TC05362.
H-8701 Heatec,Model No.VHC1-16010-40-G,
Serial No.04-074-151,Natural Gas Fired
Hot Oil Heater,Rated at 43.79 mmBtu/hr.
This heater is part of the amine treatment
unit
H-8702 Heatec,Model No.VHC1-16010-40-G,
Serial No.04-074-152,Natural Gas Fired
Hot Oil Heater,Rated at 43.79 mmBtu/hr.
This heater is part of the amine treatment
unit
FL-8921 Flare Vent:Emissions from the glycol
dehydrator regenerator(still)vent and flash
tank and the amine unit flash tank are routed
to the flare.The glycol dehydrator and amine
unit are each rated at 300 mmSCF/day.The
flare is rated at 13.54 mmBtu/hr. •
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Compliance Certification Report Page 71
Deviations noted Deviation Malfunction/Emergency
Emission Unit Condition Reported
During Period?I Code 2 p
Facility ID During Period?
Unit Description YES NO +'' YES I NO
ST-8931 Amine Unit Regenerator(CO2)Vent.Amine
unit is rated at 300 mmSCF/day.
CP EG-6141 Caterpillar,Model No.3516B LE,Serial No.
CTW00511,4-Cycle Lean Burn Natural
Gas-Fired Internal Combustion Engine,rated
at 1557 hp and 10.95 mmBtu/hr.This engine
is used to drive an emergency generator.
H-8721 Two Maxon,Model Tube-o-Flame,Reboiler
Burners Rated at 3.8 MMBtu/hr each(Total
of 7.6 MMBtu/hr)
General Conditions
Insignificant Activities
'See previous discussion regarding what is considered to be a deviation.Determination of whether or not a deviation has occurred shall
be based on a reasonable inquiry using readily available information.
2 Use the following entries,as appropriate
1 =Standard: When the requirement is an emission limit or standard
2=Process: When the requirement is a production/process limit
3=Monitor: When the requirement is monitoring
4=Test: When the requirement is testing
5=Maintenance: When required maintenance is not performed
6=Record: When the requirement is recordkeeping
7=Report: When the requirement is reporting
8=CAM: A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the
Compliance Assurance Monitoring(CAM) Rule) has occurred.
9=Other: When the deviation is not covered by any of the above categories
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Compliance Certification Report Page 72
B.II. Appendix B—Monitoring and Permit Deviation Report- Part II
FACILITY NAME: Cheyenne Plains Gas Pipeline Company, LLC—Cheyenne Plains Compressor Station
OPERATING PERMIT NO: 05OPWE281
REPORTING PERIOD:
Is the deviation being claimed as an: Emergency Malfunction N/A
(For NSPS/MACT) Did the deviation occur during: Startup_Shutdown_Malfunction_
Normal Operation
OPERATING PERMIT UNIT IDENTIFICATION:
Operating Permit Condition Number Citation
Explanation of Period of Deviation
Duration (start/stop date& time)
Action Taken to Correct the Problem
Measures Taken to Prevent a Reoccurrence of the Problem
Dates of Malfunctions/Emergencies Reported (if applicable)
Deviation Code Division Code QA:
SEE EXAMPLE ON THE NEXT PAGE
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Compliance Certification Report Page 73
EXAMPLE
FACILITY NAME: Acme Corp.
OPERATING PERMIT NO: 96OPZZXXX
REPORTING PERIOD: 1/1/04 - 6/30/06
Is the deviation being claimed as an: Emergency/Malfunction/N/A
(For NSPS/MACT) Did the deviation occur during: Startup/Shutdown/Malfunction /Normal Operation
OPERATING PERMIT UNIT IDENTIFICATION:
Asphalt Plant with a Scrubber for Particulate Control - Unit XXX
Operating Permit Condition Number Citation
Section II, Condition 3.1 - Opacity Limitation
Explanation of Period of Deviation
Slurry Line Feed Plugged
Duration
START- 1730 4/10/06
END- 1800 4/10/06
Action Taken to Correct the Problem
Line Blown Out
Measures Taken to Prevent Reoccurrence of the Problem
Replaced Line Filter
Dates of Malfunction/Emergencies Reported (if applicable)
5/30/06 to Alan Smithee, APCD
Deviation Code Division Code QA:
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Compliance Certification Report Page 74
B.III. Appendix B—Monitoring and Permit Deviation Report-Part III
REPORT CERTIFICATION
SOURCE NAME: Cheyenne Plains Gas Pipeline Company, LLC —Cheyenne Plains Compressor Station
FACILITY IDENTIFICATION NUMBER: 123/0051
PERMIT NUMBER: 05OPWE281
REPORTING PERIOD: (see first page of the permit for specific reporting period and dates)
All information for the Title V Semi-Annual Deviation Reports must be certified by a responsible official as
defined in Colorado Regulation No. 3, Part A, Section I.B. This signed certification document must be packaged
with the documents being submitted.
STATEMENT OF COMPLETENESS
I have reviewed the information being submitted in its entirety and,based on information and belief formed
after reasonable inquiry,I certify that the statements and information contained in this submittal are true,
accurate and complete.
Please note that the Colorado Statutes state that any person who knowingly, as defined in Sub-Section 18-
1-501(6), C.R.S., makes any false material statement, representation, or certification in this document is
guilty of a misdemeanor and may be punished in accordance with the provisions of Sub-Section 25-7 122.1,
C.R.S.
Printed or Typed Name Title
Signature of Responsible Official Date Signed
Note: Deviation reports shall be submitted to the Division at the address given in Appendix D of this permit.
No copies need be sent to the U.S. EPA.
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix C
Notification Addresses Page 75
C. Appendix C — Required Format for Annual Compliance Certification
Reports
Following is the format for the Compliance Certification report to be submitted to the Division and the U.S. EPA
annually based on the effective date of the permit. The Table below must be completed for all equipment or
processes for which specific Operating Permit terms exist.
FACILITY NAME: Cheyenne Plains Gas Pipeline Company, LLC—Cheyenne Plains Compressor Station
OPERATING PERMIT NO: 05OPWE281
REPORTING PERIOD:
I. Facility Status
During the entire reporting period, this source was in compliance with ALL terms and conditions contained in
the Permit, each term and condition of which is identified and included by this reference. The method(s) used to
determine compliance is/are the method(s) specified in the Permit.
With the possible exception of the deviations identified in the table below,this source was in compliance with all
terms and conditions contained in the Permit, each term and condition of which is identified and included by this
reference, during the entire reporting period. The method used to determine compliance for each term and
condition is the method specified in the Permit,unless otherwise indicated and described in the deviation report(s).
Note that not all deviations are considered violations.
Monitoring Was compliance
Emission Unit Deviations Reported' Method per continuous or
Facility ID Unit Description Permit?2 Intermittent?3
Previous I Current YES I NO Continuous I Intermittent
CP CG-7101 Solar Taurus Natural Gas Fired
Turbine,Model No.70-10302S,
Engine Serial No.OHC 10-B8166.
The turbine is rated at 9,816 hp and
71.42 mmBtu/hr. Package Skid
Serial Number TC04639.
CP CG-7201 Solar Taurus Natural Gas Fired
Turbine,Model No.70-10302S,
Engine Serial No.OHL09-B4243.
The turbine is rated at 9,816 hp and
71.42 mmBtu/hr.Package Skid
Serial Number TC04638.
CP CG-7301 Solar Taurus Natural Gas Fired
Turbine,Model No.70- 10302S,
Engine Serial No.OHB16-B8446.
The turbine is rated at 9,816 hp and
71.42 mmBtu/hr.Package Skid
Serial Number TC05362.
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix C
Notification Addresses Page 76
Monitoring Was compliance
Emission Unit Deviations Reported' Method per continuous or
Facility ID Unit Description Permit?2 Intermittent?3
Previous I Current YES I NO Continuous I Intermittent
H-8701 Heatec,Model No.VHC1-16010-
40-G,Serial No.04-074-151,
Natural Gas Fired Hot Oil Heater,
Rated at 43.79 mmBtu/hr.This
heater is part of the amine treatment
unit
H-8702 Heatec,Model No.VHC1-16010-
40-G,Serial No.04-074-152,
Natural Gas Fired Hot Oil Heater,
Rated at 43.79 mmBtu/hr.This
heater is part of the amine treatment
unit
FL-8921 Flare Vent:Emissions from the
glycol dehydrator regenerator(still)
vent and flash tank and the amine
unit flash tank are routed to the
flare.The glycol dehydrator and
amine unit are each rated at 300
mmSCF/day.The flare is rated at
13.54 mmBtu/hr.
ST-8931 Amine Unit Regenerator(CO2)
Vent.Amine unit is rated at 300
mmSCF/day.
CP EG-6141 Caterpillar,Model No.3516B LE,
Serial No.CTW00511,4-Cycle
Lean Burn Natural Gas-Fired
Internal Combustion Engine,rated
at 1557 hp and 10.95 mmBtu/hr.
This engine is used to drive an
emergency generator.
H-8721 Two Maxon,Model Tube-o-Flame,
Reboiler Burners Rated at 3.8
MMBtu/hr each(Total of 7.6
MMBtu/hr)
General Conditions
IInsignificant Activities
If deviations were noted in a previous deviation report,put an"X"under"previous".If deviations were noted in the current deviation
report(i.e.for the last six months of the annual reporting period),put an"X"under"current".Mark both columns if both apply.
2 Note whether the method(s)used to determine the compliance status with each term and condition was the method(s)specified in the
permit.If it was not,mark"no"and attach additional information/explanation.
3 Note whether the compliance status with of each term and condition provided was continuous or intermittent. "Intermittent
Compliance"can mean either that noncompliance has occurred or that the owner or operator has data sufficient to certify compliance
only on an intermittent basis.Certification of intermittent compliance therefore does not necessarily mean that any noncompliance has
occurred.
NOTE: The Periodic Monitoring requirements of the Operating Permit program rule are intended to provide assurance that even in the
absence of a continuous system of monitoring the Title V source can demonstrate whether it has operated in continuous compliance for
the duration of the reporting period. Therefore, if a source 1) conducts all of the monitoring and recordkeeping required in its permit,
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix C
Notification Addresses Page 77
even if such activities are done periodically and not continuously, and if 2)such monitoring and recordkeeping does not indicate non-
compliance,and if 3)the Responsible Official is not aware of any credible evidence that indicates non-compliance,then the Responsible
Official can certify that the emission point(s)in question were in continuous compliance during the applicable time period.
4 Compliance status for these sources shall be based on a reasonable inquiry using readily available information.
II. Status for Accidental Release Prevention Program:
A. This facility is subject is not subject to the provisions of the Accidental Release Prevention
Program (Section 112(r) of the Federal Clean Air Act)
B. If subject: The facility is is not in compliance with all the
requirements of section 112(r).
1. A Risk Management Plan will be has been submitted to the appropriate authority and/or
the designated central location by the required date.
III. Certification
All information for the Annual Compliance Certification must be certified by a responsible official as defined in
Colorado Regulation No. 3, Part A, Section I.B. This signed certification document must be packaged with the
documents being submitted.
I have reviewed this certification in its entirety and, based on information and belief formed after
reasonable inquiry, I certify that the statements and information contained in this certification are true,
accurate and complete.
Please note that the Colorado Statutes state that any person who knowingly, as defined in § 18-1-501(6),
C.R.S., makes any false material statement, representation, or certification in this document is guilty of a
misdemeanor and may be punished in accordance with the provisions of§ 25-7 122.1, 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#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix D
Notification Addresses Page 78
D. Appendix D — Notification Addresses (May 24, 2019 Version)
D.I. Air Pollution Control Division
Colorado Department of Public Health and Environment
Air Pollution Control Division
Operating Permits Unit
APCD-SS-B 1
4300 Cherry Creek Drive S.
Denver, CO 80246-1530
ATTN: Matt Burgett
D.II. United States Environmental Protection Agency
Compliance Notifications:
Office of Enforcement and Compliance Assurance
Mail Code 8ENF-AT
U.S. Environmental Protection Agency, Region VIII
1595 Wynkoop Street
Denver, CO 80202-1129
502(b)(10) Changes, Off Permit Changes:
Air and Radiation Division
Mail Code 8P-AR
U.S. Environmental Protection Agency, Region VIII
1595 Wynkoop Street
Denver, CO 80202-1129
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix E
Permit Acronyms Page 79
E. 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 MMBtu/hr
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
PM to- Particulate Matter Under 10 Microns
PSD - Prevention of Significant Deterioration
PTE - Potential To Emit
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix E
Permit Acronyms Page 80
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#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix H
Engine AOS Applicability Reports Page 81
F. Appendix F — Permit Modifications
DATE OF TYPE OF SECTION NUMBER, DESCRIPTION OF REVISION
REVISION REVISION CONDITION NUMBER
Operating Permit#05OPWE281 First Issued: October 1, 2007
Renewed: DRAFT
TECHNICAL REVIEW DOCUMENT
For
DRAFT RENEWAL OF OPERATING PERMIT 05OPWE281
Cheyenne Plains Gas Pipeline Company, LLC - Cheyenne Plains Compressor Station
Weld County
Source ID 1230051
Issued: Date
Operating Permit Engineer: Thang Nghiem
Operating Permit Supervisor review: Blue Parish
Field Services Unit review: Joe Wright
I. Purpose
This document establishes the basis for decisions made regarding the applicable
requirements, emission factors, monitoring plan and compliance status of emission
units covered by the renewed Operating Permit for the Cheyenne Plains Compressor
Station. The previous Operating Permit for this facility was issued on October 1, 2007,
was renewed on April 1, 2014 and expired on April 1, 2019. However, since a timely
and complete renewal application was submitted, under Colorado Regulation No. 3,
Part C, Section IV.C all of the terms and conditions of the existing permit shall not
expire until the renewal operating permit is issued and any previously extended permit
shield continues in full force and operation.
This document is designed for reference during the review of the proposed permit by
the EPA, the public, and other interested parties. The conclusions made in this report
are based on information provided in the renewal application submitted on March 30,
2018, comments on the draft permit submitted on [date], previous inspection reports
and various email correspondence. Please note that copies of the Technical Review
Document for the original permit and any Technical Review Documents associated
with subsequent modifications of the original Operating Permit may be found in the
Division files as well as on the Division website at www.colorado.gov/cdphe/airTitleV.
This narrative is intended only as an adjunct for the reviewer and has no legal
standing.
Any revisions made to the underlying construction permits associated with this facility
made in conjunction with the processing of this operating permit application have been
reviewed in accordance with the requirements of Regulation No. 3, Part B,
Construction Permits, and have been found to meet all applicable substantive and
procedural requirements. This operating permit incorporates and shall be considered
to be a combined construction/operating permit for any such revision, and the
permittee shall be allowed to operate under the revised conditions upon issuance of
this operating permit without applying for a revision to this permit or for an additional or
revised construction permit.
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Cheyenne Plains Gas Pipeline Company, LLC—Cheyenne Plains Compressor Station
Operating Permit No. 05OPWE281
Technical Review Document—Renewal Operating Permit
II. Description of Source
The Cheyenne Plains Gas Pipeline Company, LLC, Cheyenne Plains Compressor
Station is a natural gas compression facility as defined under Standard Industrial
Classification 4922. This facility is a mainline compressor station. Its main function is
to compress and transmit natural gas from the Wyoming area east into Kansas. The
sources addressed in this operating permit include three (3) natural gas fired
combustion turbines driving natural gas compressors. The facility also includes a CO2
Treatment Plant, which consists of a triethylene glycol dehydrator and amine
treatment unit. Emissions from the glycol dehydrator still (regenerator) vent and flash
tank and emissions from the amine unit flash tank are routed to a flare to reduce VOC
emissions. The amine unit regenerator vent is equipped with a SulfaTreat H2S control
system to reduce H2S emissions. There are also two (2) 43.79 MMBtu/hr natural gas
fired heaters associated with the amine unit and an emergency generator that are
included in Section II of the permit as significant emission units.
The Cheyenne Plains Compressor Station was constructed in 2004 at the site of an
existing mainline compressor station (Cheyenne Station), whose main function is to
compress and transmit natural gas from the Wyoming area to the Colorado Front
Range area. As such the two facilities are considered a single source for purposes of
Prevention of Significant Deterioration (PSD) review requirements and Title V
permitting requirements. Equipment associated with the Cheyenne Compressor
Station is addressed in a separate Title V operating permit (95OPWE090).
The facility is located in Weld County on Highway 85 at Section 5, T11 N, R66W (— 4
miles North of Rockport). The area in which the plant operates is designated as
attainment for all criteria pollutants.
Prevention of Significant Deterioration (PSD)
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 for NOx,
CO and VOC). Future modifications at this facility resulting in a significant net
emissions increase (see Reg 3, Part D, Sections II.A.27 and 44) for any pollutant as
listed in Regulation No. 3, Part D, Section II.A.44 or a modification which is major by
itself(i.e. a Potential to Emit of≥ 250 TPY of any pollutant listed in Regulation No. 3,
Part D, Section II.A.44) may result in the application of the PSD review requirements.
Emissions
All emissions listed below remain unchanged from the previous TRD. Emissions for
the Dehydrator Reboiler Burners are based on manufacturer emission factors for NOx
and CO, and AP-42 Chapter 1.4 (7/1998) for all other pollutants. Potential to emit at
the facility (in tons/yr) is shown in the table below:
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Cheyenne Plains Gas Pipeline Company, LLC—Cheyenne Plains Compressor Station
Operating Permit No. 05OPWE281
Technical Review Document—Renewal Operating Permit
Facility Wide Emissions (95OPWE090 and 05OPWE281)
Potential to Emit
Actual Emissions2
Pollutant 95OPWE090 05OPWE281 Facility
PM' 35.23 11.96 47.19 5.60
PMio' 35.23 11.96 47.19 5.60
SO2' 1.33 3.44 4.77 1.53
NO. 624.3 112.52 736.82 94.46
CO 262.8 158.11 420.91 60.10
VOC 291.3 58.37 349.67 40.83
HAPs 60.7 14.14 74.80 7.63
'Emissions for each emission unit are typically below the APEN de minimis level, so emission limits
have generally not been included in the construction permits and/or Title V permit.
2Actual emissions are from the Division's Inventory System for the year 2018.
05OPWE281 Emissions
Potential to Emit
Emission Unit PM PM,o SO2 NO. CO VOC HAPs
Turbine CP CG-7101 2.1 2.1 1.06 31.6 38.5 11.3 See
Turbine CP CG-7201 2.1 2.1 1.06 31.6 38.5 11.3 Table
on
Turbine CP CG-7301 2.1 2.1 1.06 20.1 20.9 11.3 Page
13
Hot Oil Heater H-8701 1.58 1.58 0.13 8.9 7.3 3.15
Hot Oil Heater H-8701 1.58 1.58 0.13 8.9 7.3 3.15
Flare Vent FL-8921 2.25 2.25 7.0 39.42 5.8
Amine Unit Regenerator(CO2) 11.8
Vent ST-8931
Emergency Generator CP EG- 0.43 1.30 0.37
6141
Dehydrator Reboiler Burners H- 0.25 0.25 3.99 4.89 0.2
8721
TOTAL 11.96 11.96 3.44 112.52 158.11 58.37 14.14
III. Applicable Requirements
Accidental Release Program — 112(r)
Section 112(r) of the Clean Air Act mandates a new federal focus on the prevention of
chemical accidents. Sources subject to these provisions must develop and implement
risk management programs that include hazard assessment, a prevention program,
and an emergency response program. They must prepare and implement a Risk
Management Plan (RMP) as specified in the Rule
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Cheyenne Plains Gas Pipeline Company, LLC—Cheyenne Plains Compressor Station
Operating Permit No. 05OPWE281
Technical Review Document—Renewal Operating Permit
Based on the information provided by the applicant, this facility is not subject to the
provisions of the Accidental Release Prevention Program (Section 112(r) of the
Federal Clean Air Act).
Compliance Assurance Monitoring (CAM)
The following emission points at this facility use a control device to achieve
compliance with an emission limitation or standard to which they are subject and have
pre-control emissions that exceed or are equivalent to the major source threshold.
They are therefore subject to the provisions of the CAM program as set forth in 40
CFR Part 64 as adopted by reference into Colorado Regulation No. 3, Part C, Section
XIV:
None. The glycol dehydrator is not subject to CAM since at the time the CAM plan was
required the Title V permit specified a continuous compliance determination method
(40 CFR Part 64 § 64.2(b)(1)(vi), as adopted by reference in Colorado Regulation No.
3, Part C, Section XIV).
All other units at the facility either have uncontrolled emissions below CAM
applicability thresholds, or do not use devices considered to be control devices for the
purposes of CAM applicability. See previous versions of TRDs for more information on
CAM.
Hazardous Air Pollutants (HAPs)
This facility is major for HAPs. Potential to emit of total HAPs for both the Cheyenne
Plains Compressor Station (05OPWE281) and the Cheyenne Compressor Station
(95OPWE090) combined is above the major source threshold of 25 tpy.
40 CFR 63 Subpart YYYY - National Emission Standards for Hazardous Air Pollutants
for Stationary Combustion Turbines
Each turbine is considered to be a "new" turbine (commenced construction after
January 14, 2003) under Subpart YYYY. However, §63.6095(d) notes that standards
for new or reconstructed gas-fired lean premix and diffusion flame turbines are stayed
until EPA takes final action to require compliance, and only initial notification
requirements apply. An initial notification was submitted for turbines CG-7101 and CG-
7201 on June 15, 2005 and an initial notification was submitted for turbine CG-7301
on April 4, 2006.
At the time of this permit issuance, the provisions in §63.6095(d) are still current,
therefore, no Subpart YYYY requirements are included in this renewal permit.
40 CFR Part 63 Subpart ZZZZ—National Emissions Standards for Hazardous Air
Pollutants for Stationary Reciprocating Internal Combustion Engines
EG-6141 is a new emergency engine greater than 500 hp located at a major source of
HAP. As such, it is exempt from all requirements under Subpart ZZZZ except for initial
reporting requirements (§ 63.6590(b)(1)(i)). The initial notification for this unit was
submitted on December 13, 2004.
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Cheyenne Plains Gas Pipeline Company, LLC—Cheyenne Plains Compressor Station
Operating Permit No. 05OPWE281
Technical Review Document—Renewal Operating Permit
On January 30, 2013, EPA published changes to Subpart ZZZZ in the Federal
Register as a final rule to include a limit on the number of hours that this type of
emergency engine may operate in certain scenarios in order to qualify as an engine
subject to limited requirements. Prior to this date, the rule had no time limit on the use
of emergency engines for routine testing and maintenance. The Division modified the
existing permit requirement to track hours of operation so that it also tracks the type of
operation in order to qualify as an emergency engine under Subpart ZZZZ.
The D.C. Circuit Court issued a mandate on May 4, 2016 for vacatur for certain
requirements allowing emergency engines to operate for limited hours for demand
response. Upon issuance of the mandate, 40 CFR Part 63.6640(f)(2)(ii)-(iii) have no
legal effect. Operation of emergency engines is limited to emergency situations
specified in 63.6640(f)(1); maintenance checks and readiness testing for a limited
number of hours per year as specified in 63.6640(f)(2)(i); and certain non-emergency
situations as specified in 63.6640(0(3). See EPA memorandum dated April 15, 2016
regarding "Guidance on Vacatur of RICE NESHAP and NSPS Provisions for
Emergency Engines" for more information.
Note that the Subpart ZZZZ requirements for this unit are not currently state
enforceable, since the version of Subpart ZZZZ that is currently adopted into Colorado
Reg No. 8 states that new emergency engines are not subject to any requirements
except for the submittal of an initial notification.
40 CFR Part 60 Subpart JJJJ—Standards of Performance for Stationary Spark
Ignition Internal Combustion Engines
Subpart JJJJ applies to stationary spark ignition engines that commenced
construction, reconstruction or modification after June 12, 2006 and were
manufactured after specific dates. EG-6141 started up in 2004 and has not been
reconstructed or modified; Subpart JJJJ does not apply.
Colorado Regulation No. 7, Part D, Section IV- (State Only) Control of Emissions from
the Natural Gas Transmission and Storage Segment
The requirements of Section IV apply to transmission segment owners or operators,
and are generally applicable on a company-wide basis. Only the facility-specific
requirements of this section are included in the permit.
Colorado Regulation No. 7, Part E, Section I - Control of Emissions from Engines
On December 12, 2008, the Colorado Air Quality Control Commission (AQCC)
adopted revisions to Colorado Regulation No. 7 to include state-wide requirements for
existing (constructed or modified before February 1, 2009) internal combustion
engines greater than 500 hp. These requirements are set forth in Reg 7, XVII.E.3 (now
Part E, Section I.D.3.). Specifically these engines are required to install oxidation
catalysts per Section I.D.3.b.(i). However, Section I.D.3.b.(ii) specifies that sources
that could demonstrate that the retrofit cost was more than $ 5,000/ton were exempt
from the requirements, provided the demonstration was submitted by August 1, 2009.
The source requested an exemption from the control requirements from these engines
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Cheyenne Plains Gas Pipeline Company, LLC—Cheyenne Plains Compressor Station
Operating Permit No. 05OPWE281
Technical Review Document—Renewal Operating Permit
and the Division granted the exemption in a letter dated December 21, 2009,
contingent upon engine operation not exceeding 250 hours per year.
40 CFR Part 63 Subpart DDDDD - National Emission Standards for Hazardous Air
Pollutants for Maior Sources: Industrial, Commercial, and Institutional Boilers and
Process Heaters
The major source boiler MACT defines existing boilers and process heaters as those
that have commenced construction or reconstruction on or before June 10, 2010. The
two hot oil heaters (point 018 - H-8701 and H-8702) qualify as an existing affected
source in the subcategory: units designed to burn gas 1 fuels. Only work practice
standards apply to this subcategory: annual tune ups and an initial energy
assessment.
The two reboiler burners (point 025 - H-8721) associated with the glycol dehydrator
are also considered to be process heaters under the definition of Subpart DDDDD.
However, the reboiler burners qualify for exemption from Subpart DDDDD under
§63.7491(h): Any boiler or process heater that is part of the affected source subject to
another subpart of this part. The reboiler burners are part of the glycol dehydrator,
which is an affected source under 40 CFR Subpart HHH.
40 CFR Part 60 Subpart GG—Standards of Performance for Stationary Gas Turbines
Each of the three turbines (points 015 & 024) included in this permit are subject to
Subpart GG (stationary gas turbines with greater than 10 MMBtu/hr that commenced
construction, modification or reconstruction after October 3, 1977 and before February
8, 2005). The applicable requirements were included in the initial operating permit
(note that some of the Subpart GG requirements were streamlined out in favor of more
stringent requirements; see the TRD for the initial operating permit issuance for
details).
40 CFR Part 63 Subpart HH—National Emission Standards for Hazardous Air
Pollutants From Oil and Natural Gas Production Facilities
Subpart HH applies to facilities that process, upgrade, or store natural gas prior to the
point at which natural gas enters the natural gas transmission and storage source
category. This source is in the transmission and storage source category, and is
therefore subject to Subpart HHH instead of HH.
40 CFR Part 63 Subpart HHH—National Emission Standards for Hazardous Air
Pollutants From Natural Gas Transmission and Storage Facilities
The dehydrator is subject to control requirements under Subpart HHH, as described in
the TRD for the initial operating permit issuance and the requirements were updated
accordingly to revisions to Subpart HHH in the Federal Register on August 16, 2012
as a final rule, for the first operating permit renewal. There has been no update to this
subpart since that issuance. The source complies with the option to control to 0.90
Mg/year of benzene (§63.1275(b)(1)(ii)) by routing emissions through a closed vent
system to a flare. See previous version of the TRD for more Subpart HHH
discussions.
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Cheyenne Plains Gas Pipeline Company, LLC—Cheyenne Plains Compressor Station
Operating Permit No. 05OPWE281
Technical Review Document—Renewal Operating Permit
Colorado Regulation No. 7, Part D, Section II.D (State Only) Emission reductions from
glycol natural gas dehydrators
Colorado Regulation No. 7, Part D, Section II.D includes state-wide requirements for
glycol dehydrators with actual uncontrolled VOC emissions greater than 15 tons per
year. However, these requirements do not apply to glycol dehydrators located at
natural gas storage facilities. Therefore, Section II.D requirements do not apply to the
dehydrator at Cheyenne Plains Compressor Station.
Subpart LLL—Standards of Performance for SO2 Emissions From Onshore Natural
Gas Processing for Which Construction, Reconstruction, or Modification Commenced
After January 20, 1984, and on or Before August 23, 2011
The amine unit was previously determined to be an affected unit under this rule, but
was exempt from control requirements based on the facility's design capacity.
However, the Subpart LLL applies only to onshore natural gas processing plants.
Since this facility is not a gas processing plant, the requirement to maintain records
demonstrating the exemption under Subpart LLL will be removed from the renewal
permit.
In previous permitting actions when Subpart LLL was determined to apply, there was
no information within Subpart LLL that provided clarification on whether "Onshore
Natural Gas Processing" included natural gas processes located at facilities other than
natural gas processing plants. When NSPS Subpart OOOO was proposed on August
23, 2011, the preamble for that rule clarified that Subpart LLL was only applicable to
natural gas processing plants (reference 76 FR 52741 & 52754).
40 CFR Part 60 Subpart OOOO - Standards of Performance for Crude Oil and
Natural Gas Production, Transmission and Distribution
Subpart OOOO addresses gas wells, compressors, pneumatic controllers, storage
vessels, equipment leaks associated with process units, and some sweetening units.
Subpart OOOO applies to affected facilities that commenced construction,
modification or reconstruction after August 23, 2011. All equipment at Cheyenne
Plains Compressor Station was constructed prior to this applicability date and has not
since been reconstructed or modified.
Additionally, the following equipment does not qualify as an affected facility under
Subpart OOOO, regardless of construction/modification/relocation date for the
following reasons:
• Compressors are only affected facilities if they are located between the
wellhead and the natural gas transmission and storage segment. Since this
facility is a natural gas storage facility, all compressors do not qualify as
affected facilities.
• Pneumatic controllers > 6 scfs are only affected facilities if they are located
between the wellhead and the natural gas transmission and storage segment.
Other pneumatic controllers are only affected facilities if they are located at a
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Cheyenne Plains Gas Pipeline Company, LLC—Cheyenne Plains Compressor Station
Operating Permit No. 05OPWE281
Technical Review Document—Renewal Operating Permit
natural gas processing plant. Since this facility is a natural gas storage facility,
all pneumatic controllers do not qualify as affected facilities.
• Sweetening units (e.g., amine units) are only affected facilities if they are
located at natural gas processing plants. Since this facility is not a natural gas
processing plant, the amine unit is not an affected facility.
• Equipment leaks associated with process units (i.e., fugitive components) are
only affected facilities if they are located at natural gas processing plants. Since
this facility is not a natural gas processing plant, the amine unit is not an
affected facility.
• Note that there are no storage vessels associated with this permit, either as
permitted emission units or as insignificant activities.
40 CFR Part 60 Subpart KKK- Standards of Performance for Equipment Leaks of
VOC From Onshore Natural Gas Processing Plants
Subpart KKK does not apply to the Cheyenne Plains Compressor Station because it is
not a natural gas processing plant.
40 CFR Part 60 Subpart Kb - Standards of Performance for Volatile Organic Liquid
Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction,
Reconstruction, or Modification Commenced After July 23, 1984
As per§ 60.110b(d)(4), Subpart Kb does not apply to vessels with a design capacity
less than or equal to 1,589.874 m3 (approximately 10,000 bbl) used for petroleum or
condensate stored, processed, or treated prior to custody transfer. There are no such
tanks associated with this permit.
40 CFR Part 63 Subpart EEEE — National Emission Standards for Hazardous Air
Pollutants: Organic Liquids Distribution (Non-Gasoline)
Under §63.2334(c)(2), organic liquid distribution operations do not include activities
and equipment at natural gas transmission and storage facilities; therefore, Subpart
EEEE requirements do not apply.
Portable Monitoring Requirements
The previously issued version of the operating permit required quarterly portable
monitoring for NOx and CO emissions from the turbines. The requirement used the
Division's standard portable monitoring language, except that the following additional
language was included:
Note that the second to the last paragraph in Condition 5 (apply for a permit
modification within 60 days if the portable analyzer test indicates that the
emission rates/factors are greater than the emission rates/factors identified in the
permit) does not apply to these emission units.
This requirement was included because these turbines are subject to BACT limits for
NOx and CO, and the emission factors specified in the permit are associated with the
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Cheyenne Plains Gas Pipeline Company, LLC—Cheyenne Plains Compressor Station
Operating Permit No. 05OPWE281
Technical Review Document—Renewal Operating Permit
original BACT determination. This additional language will also be included in the
renewal permit.
Compliance Order
There has been no compliance order against CIG for violating requirements under
Operating Permit 05OPWE281.
IV. Modifications Requested by the Source
The renewal application received on March 30, 2018 requested the following
modifications:
• Update to the secondary responsible official.
• Update to the permit contact person.
• Changes to Summary of Emissions Units:
o Engine serial number of CG-7101 to be changed from OCH10-B8166 to
OHC10-B8166.
o Engine serial number of CG-7301 to be changed from OCH10-B0020 to
O H B 16-B8446.
• Addition of the following to the List of Insignificant Activities:
o Waste Tank T-8807.
o Waste Tank T-8811.
Cheyenne Plains Gas Pipeline Company, LLC provided comments to the draft permit
on July 13, 2020, and requested the requirement to use the hours meter on the pilot
monitor and record the number of hours the turbine runs when ambient temperatures
are below 0 ° F to be reassessed, since the current version of Solar's SoLoNOx
operating system does not turn the pilot on and off like the original SoLoNOx did.
The source's requested modifications were addressed as follows:
Page Following Cover Page
• Added Ron Bessette, VP Operations as secondary responsible official.
• Updated Matt Richards as the permit contact person (originally Justin Rivard in
the renewal application, but the contact has since changed).
Section I — General Activities and Summary
• Condition 7 - Summary of Emissions Units Table: updated serial numbers for
point 015 (CG-7101) & 024 (CG-7301).
Section II — Specific Permit Terms
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Cheyenne Plains Gas Pipeline Company, LLC—Cheyenne Plains Compressor Station
Operating Permit No. 05OPWE281
Technical Review Document—Renewal Operating Permit
• Condition 1.2.1.4: removed language requiring the hours meter on the pilot to
be used to monitor and record the number of hours the turbine runs when
ambient temperatures are below 0 ° F. Added language to require the source to
manually monitor and record the number of hours the turbine runs when
ambient temperatures are below 0 ° F, and record keeping requirement.
Appendices
• Appendix A - List of Insignificant Activities: added Waste Tank T-8807 & Waste
Tank T-8811 to the list.
V. Other Modifications
In addition to the source requested modifications, the Division has included changes
to make the permit more consistent with recently issued permits, include comments
made by EPA on other Operating Permits, as well as correct errors or omissions
identified during inspections and/or discrepancies identified during review of this
renewal. These changes are as follows:
Page Following Cover Page
• It should be noted that the monitoring and compliance periods and report and
certification due dates are shown as examples. The appropriate monitoring and
compliance periods and report and certification due dates will be filled in after
permit issuance and will be based on permit issuance date. Note that the
source may request to keep the same monitoring and compliance periods and
report and certification due dates as were provided in the original permit.
However, it should be noted that with this option, depending on the permit
issuance date, the first monitoring period and compliance period may be short
(i.e. less than 6 months and less than 1 year).
Section I — General Activities and Summary
• Revised the language in Condition 1.4 to include current conditions that are
state-only enforceable (adding Section IV, Condition 30).
• Condition 2.2.5: revised outdated references Reg 3, Part D, Sections II.A.42 to
the current II.A.44.
• Condition 4: revised outdated references Reg 3, Part D, Sections II.A.26 and 42
to the current II.A.27 and 44.
Section II — Specific Permit Terms
• Condition 1: updated facility IDs (typographical error"CG-7101" for all three
turbines to CG-7101, CG-7201 and CG-7301).
• Conditions 1.7.1, & 2.7.1: corrected typographical error"Section A.lI.1" to
"Section I I.A.1".
• Condition 2.4: corrected typographical error "above" to "below".
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Cheyenne Plains Gas Pipeline Company, LLC—Cheyenne Plains Compressor Station
Operating Permit No. 05OPWE281
Technical Review Document—Renewal Operating Permit
• Condition 2.5: added "but not limited to".
• Condition 2.8:
o Updated the revision date for 40 CFR Part 63 Subpart DDDDD from
January 31, 2013 to November 20, 2015.
o 2.8.1: corrected typographical error"§63.7435(b)" to "§63.7495(b)"
o 2.8.3.2: condition was removed. The one-time energy assessment was
performed on 07/30/15.
o 2.8.4 & 2.8.5: satisfied conditions were removed. CIG's initial notification
for MACT DDDD was received by the Division on May 23, 2013.
o 2.8.8 — 2.8.10: satisfied conditions were removed. CIG's Notification of
Compliance Status report for MACT DDDD was received by the Division.
o 2.8.12 — 2.8.14, 2.8.15.1 & 2.8.15.2: satisfied conditions were removed.
CIG's initial notification for MACT DDDD and Notification of Compliance
Status were received by the Division.
• Condition 3.12: removed redundant word "monthly".
• Condition 4.4: revised and added language for a vacatur for certain
requirements in a mandate issued on May 4, 2016 by D.C. Circuit Court.
• Condition 5: Portable Monitoring language was updated to the most current
version, including the new webpage address for monitoring protocol.
• Condition 6.3.1: corrected typographical error "Section A.II.1" to "Section II.A.1".
• Condition 7: new condition to incorporate Colorado Regulation No. 7, Part D,
Section IV - (State Only) Control of Emissions from the Natural Gas
Transmission and Storage Segment.
Section III — Permit Shield
• Updated the Stream-lined Conditions table, and added justifications.
Section IV— General Permit Conditions
• Updated the general permit conditions to the current version (01/21/2020)
o Condition 22.e: added a reference to Regulation No. 3, Part A, § II.A.2
and revised the language to indicate a revised APEN shall be filed once
per year for control equipment changes at condensate storage tanks
subject to the provisions in Regulation No. 3, Part D, Section I.
o Condition 30: corrected the citation, revised the introductory paragraph
to indicate the areas in which the requirements apply and note state-only
requirements, corrected the language in paragraph c, corrected the Reg
123/0051 Page 11 of 13
Cheyenne Plains Gas Pipeline Company, LLC—Cheyenne Plains Compressor Station
Operating Permit No. 05OPWE281
Technical Review Document—Renewal Operating Permit
7 citations in paragraphs a & d and made a minor change to paragraph e
(changed "PSIA" to "psia").
Appendices
• Updated Appendices A, B, C and D to a new format with references.
123/0051 Page 12 of 13
Cheyenne Plains Gas Pipeline Company, LLC—Cheyenne Plains Compressor Station
Operating Permit No. 05OPWE281
Technical Review Document—Renewal Operating Permit
VI. HAPs Per Division Analysis (05OPWE281)
Hazardous Air Pollutant Emissions,in Tons/yr
ai ai-a c w
t c N
aJ aJ O Y x
1 l O L •u y O
TO
4.4 al 7, E H X N v z = u
u CO O M 2 c Q
Q L J 6L
Unit Total
Turbine CP CG-7101 0.01 0.00 0.01 0.22 0.04 0.02 0.30
Turbine CP CG-7201 0.01 0.00 0.01 0.22 0.04 0.02 0.30
Hot Oil Heater H-8701 0.00 0.02 0.00 0.00 0.38 0.40
Hot Oil Heater H-8701 0.00 0.02 0.00 0.00 0.38 0.40
Dehydrator 0.87 1.56 0.11 2.54
Amine Unit 7.35 2.3 0.10 9.75
Turbine CP CG-7301 0.01 0.00 0.01 0.22 0.04 0.02 0.30
Emergency Generator CP EG-6141** 0.01 0.07 0.01 0.09
Dehydrator Reboiler Burners H-8721 0.06 0.06
Total 0.04 8.22 0.03 0.77 3.98 0.06 0.00 0.00 0.00 1.03 0.01 14.14
Insignificant activities included in HAP total in the preliminary analyses for the FREP, CPP and CPP Phase II turbine are not included here.
**Based on 250 hrs/yr of operation.
123/0051 Page 13 of 13
7/20/2020 State.co.us Executive Branch Mail-Cheyenne Plains Compressor Station OP Renewal Draft Source Comments Request
'A" STATE OF
SlotCOLORADO Nghiem -CDPHE,Thang<thang.nghiem@state.co.us>
Cheyenne Plains Compressor Station OP Renewal Draft Source Comments Request
6 messages
Nghiem-CDPHE,Thang <thang.nghiem@state.co.us> Mon, Jun 15, 2020 at 5:58 PM
To:"Richards, Matt"<Matt_Richards@kindermorgan.com>
Hi Matt,
Please find attached the draft permit&TRD for the Cheyenne Plains Compressor Station OP Renewal#2. Please
respond within 30 days. Let me know if you have any questions or need more time in reviewing the documents.Thank
you!
Regards,
Thang Nghiem
Permit Engineer
Title V Operating Permit Unit
Stationary Sources Program
-- COLORADO
t Air Pollution Control Division
Department of Public Health fr Environment
P 303.692.3256 I F 303.782.5493
4300 Cherry Creek Drive South, Denver, CO 80246-1530
Thang.Nghiem@state.co.us I www.colorado.gov/aiphe/aped
Are you curious about ground-level ozone in Colorado?Visit our ozone webpage to learn more.
2 attachments
05OPWE281 renew2 dop.docx
691K
05OPWE281 renew2 draft trd.docx
54K
Richards, Matt<Matt_Richards@kindermorgan.com> Mon, Jul 13, 2020 at 10:08 AM
To: "Nghiem-CDPHE,Thang"<thang.nghiem@state.co.us>
Good Morning Thang,
After reviewing the draft permit there was one item that I would like to discuss with you, and that is the language
pertaining to the pilot hours on the turbine. Currently we don't have a "clock" on the pilot. This version of
Solar's Solonox operating system does not turn the pilot on and off like the original Solonox did. We
manually track both <0 and <20 hrs (and have mechanical meters for<0 hours). With this is mind will our
current recordkeeping be acceptable or would it be best to change the language in the draft to just general
hour tracking rather than with a clock?
https://mail.google.com/mail/u/1?ik=0c94807f4c&view=pt&search=all&permthid=thread-a%3Ar-8488480080157367949&si mpl=msg-a%3Ar-84868275... 1/3
7/20/2020 State.co.us Executive Branch Mail-Cheyenne Plains Compressor Station OP Renewal Draft Source Comments Request
Appreciate your help!
Matt Richards I EHS Specialist II I Air Permitting and Compliance
KINDERA MORGAN I Natural Gas Pipelines
2 North Nevada Avenue I Colorado Springs,CO 80903
Office: 719-520-4855 I Cell:719-235-6643
From: Nghiem-CDPHE,Thang<thang.nghiem@state.co.us>
Sent: Monday,June 15, 2020 5:58 PM
To: Richards, Matt<Matt_Richards@kindermorgan.com>
Subject:Cheyenne Plains Compressor Station OP Renewal Draft Source Comments Request
[This email message was received from the Internet and came from outside of
Kinder Morgan]
[Quoted text hidden]
Nghiem-CDPHE,Thang <thang.nghiem@state.co.us> Mon, Jul 13, 2020 at 12:03 PM
To: "Richards, Matt"<Matt Richards@kindermorgan.com>
Hi Matt,
Since this is related to BACT, I will need to do some more research and digging to make sure this doesn't get messier
than it has to, and discuss this with my supervisor. I'll get back to you on this soon.
[Quoted text hidden]
Nghiem -CDPHE,Thang <thang.nghiem@state.co.us> Mon, Jul 13, 2020 at 3:38 PM
To: "Richards, Matt"<Matt Richards@kindermorgan.com>
Matt,
I was able to remove the language associated with the hours meter in Condition 1.2.4.1,and mentioned about this
change in the TRD. If everything looks good to you, I'll send it to public comment.
[Quoted text hidden]
2 attachments
05OPWE281 renew2 draft trd.docx
54K
05OPWE281 renew2 dop.docx
691K
Richards, Matt<Matt Richards@kindermorgan.com> Mon, Jul 13, 2020 at 3:53 PM
To: "Nghiem-CDPHE,Thang"<thang.nghiem@state.co.us>
Great,appreciate you looking into that for us. We are ready for it to go to comment then.
https://mail.google.com/mail/u/1?ik=0c94807f4c&view=pt&search=al I&permthid=th read-a%3Ar-8488480080157367949&simpl=msg-a%3Ar-84868275... 2/3
7/20/2020 State.co.us Executive Branch Mail-Cheyenne Plains Compressor Station OP Renewal Draft Source Comments Request
Thank you much!
[Quoted text hidden]
Nghiem-CDPHE,Thang <thang.nghiem@state.co.us> Mon,Jul 13, 2020 at 3:54 PM
To: "Richards, Matt"<Matt_Richards@kindermorgan.com>
You're welcome!
[Quoted text hidden]
https://mail.google.com/mail/u/1?ik=0c94807f4c&view=pt&search=all&permthid=thread-a%3Ar-8488480080157367949&simpl=msg-e%3Ar-84868275... 3/3
ks L 4
Cheyenne Plains
Gas None caviattt G l
370 Van Gordon Street
Lakewood, CO 80228
March 28, 2018
Mr. Thang Nghiem Via FEDEX#7802 6333 6576
Colorado Department of Public Health and Environment
APCD-SS-81
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Dear Mr. Nghiem,
Cheyenne Plains Gas Pipeline Company, L.L.C. (CHP) is submitting the enclosed Title V renewal
application for the Cheyenne Plains Compressor Station Title V Operating Permit 05OPWE281 as
required under Section IV, Condition 19; one year prior to the expiration date of April 1, 2019.The
enclosed original Cheyenne Plains Compressor Station Title V renewal application plus three copies are
included for your review. Please see the requested updates to the Title V permit below.
• CHP is requesting an update to the secondary responsible official effective April 1, 2017 as
follows. Colorado APCD Form 2000-100 is enclosed as required.
Name: Ron Bessette
Vice President Operations
Phone: (713)420-6012
• CHP is requesting an update to the permit contact person effective July 1, 2017 as follows.
Colorado APCD Form 2000-100 is enclosed as required.
Name:Justin Rivard
Title: Air Permitting and Compliance Specialist
Phone: (303) 914-7608
• Changes to Summary of Emission Units - Page 12
o The engine serial number of CG-7101 should be changed from OCH10-B8166 to OHC10-
B8166
o The engine serial number of CG-7301 should be changed from OCH10-B0020 to OHB16-
B8446
The insignificant activities list in Appendix A was reviewed and the following comments are being
submitted for revisions into the list. Colorado APCD Form 2000-700 is enclosed as required.
Cheyenne Plains
A—.P.pendix A Page 1—List of Insignificant Activities—Units with emissions less than APEN de minimis—
crit2ollutants
• Add "Waste Tank T-8807" to the list. Please note the calculation below, using Colorado APCD PS
Memo 14-03 condensate emission factor, supports the listing of T-8807 as APEN de minimis.The
calculation below is also assumed to be highly conservative since the primary liquids in the tank
will be liquids off the separator dumps (mostly compressor oil)„ water, and some glycol.The
combination of which has a much lower VOC content and vapor pressure compared to
condensate.
13.7 lbs VOC x 250 bbls
bbl yr = 1.71 tpy of VOC
2000 ton
• Add "Waste Tank T-8811" to the list. Please note the calculation below, using Colorado APCD PS
Memo 14-03 condensate emission factor, supports the listing of T-8811 as APEN de minimis.The
calculation below is also assumed to be highly conservative since the primary liquids in the tank
will be liquids off the separator dumps (mostly compressor oil),water, and some glycol.The
combination of which has a much lower V0C content and vapor pressure compared to
condensate.
13.7 lbs VOC x 250 bbls
bbl yr = 1.71 tpy of VOC
lbs
2000 to—
n
If you have any additional questions, please contact Justin Rivard at (303) 914-7608 or at
Justin Rivard@kindermorgan.com.
Sincerely,
\y,, h a'1c k.
Matt Mask
Operations Director—Division 2
2 ' Page
Cheyenne Plains Compressor Station
Title V Renewal
March 28, 2018
0Perating pc
r,
hnit AnnItcala ado tie FACILITY IDENTIFICATION
Air l'olluli parrment of public Heaid%and Env ironment FORM 2000-144
n CUntrpl F>ivision
Rev 06-95
1�""---- am SSITINS TRIIC'rioNS ON REVERSE' SIDE
Faeiliti n name and Name
Cheyenne Plains Compressor Station
mailing address
Street or Route 370 Van Gordon Street
Cih. State, Zip Code Lakewood, CO 80228
2. Facility lacatiort
Street Address Section 5,T11N R66W
(No P.O. Box) City, County,Zip Code
Carr,Weld 80612
3.
Parent corporation Name Cheyenne Plains Gas Pipeline Company, LLC
Street or Route 370 Van Gordon Street
City, State,Zip Code Lakewood, CO 80228
Country(if not U.S.)
Responsible Name Ron Bessette (Secondary RO)
official Title Vice President Operations
Telephone (719)329-5637
5. Permit contact person Name Justin Rivard
Title Air Permitting and Compliance Specialist
(If Different than 4) Telephone (303)914-7608
6. Facility SIC code:4922 7. Facility identification code: CO 1230051
8. Federal Tax I. D. Number: 840173305
9. Primary activity of the operating establishment: Natural Gas Transmission and Processing
10. Type of operating permit • New • Modified X Renewal
I I. Is the facility located in a "nonattainment"area: • Yes X No
If"Yes", check the designated "non-attainment" pollutant(s):
• Carbon Monoxide • Ozone • PM 10 • Other(specify)
12. List all (Federal and State)air pollution permits(including grandfathered units), plan approvals and exemptions issued
to this facility. List the number, date and what unit/process is covered by each permit. For a Modified Operating Permit,do not
complete this item.
FACILITY IDENTIFICATION-- Form 2000-100
AIR POLLUTION CONTROL OPERATING PERMIT APPLICATION INSTRUCTIONS
NOTE,The operaGn
Division
will trot €Perm,t must be prepared and submitted on turns,upplted by the Divicion. Use of this form is required for all operating
request that consider or act upon'our application unless each form used has hcen entirely completed. Use"NA"where necessary. o identify an informationit ls. The
does not apple.
One form should be included w ith each application.
Item I Provide full business name and address of corporation.con pan polrtical subdivision of the state submitting the application. 1 y' association,society,firm,partnership,individual or
Item 2 Street address where the air pollution sources are or will be located. For remote locations, land plat descriptions(Township,
Range. Section, Subsection location)are acceptable.
Item 3 If wholly or partly ow ned by another entity. identify that entity.
Item 4 The responsible official is a person legally responsible for the operation of the permitted air pollution sources. For a
corporation, this person must be the president, vice-president,secretary or treasurer,or other person with a similar level of
responsibility in the company.
rior to filing the application, if you want the Division to approve your choice of responsible official you may send a letter to the Division
lescribing that persons authority in the company and requesting the Division's approval.
Item 5 Individual to contact during the permitting process for additional information concerning the air pollution sources.
Item 6 The primary Standard Industrial Classification(SIC)code for the facility where the source(s)are located.
Item 7 Provide the facility identification(FID)code. The Division has assigned a unique code to your facility. The code begins
with "CO" (Colorado)and has 7 digits.
Item 8 Provide the Facility Federal Tax Number. This is a nine-digit number.
Item 9 Provide a short statement about your facility's activities such as"lead-acid battery manufacture"or"sulfite paper mill."
Item 10 Indicate the type of permit application being submitted. An applicant may at any time request an operating permit that is
otherwise not required.
Item 11 Indicate whether the facility is located in a nonattainment areaeven if your facility does not emit the pollutant. Please refer to
the instruction booklet and Appendix G of the instruction book. If the area is attainment for all pollutants,enter"Attainment for all
Pollutants".
Item 12 Identify all facility air pollution permits, plan approvals(fugitive dust),and exemptions issued by U.S. EPA or Colorado
APCD that are still in effect. Include grandfathered emission units. Please do not list old permits,exemptions,etc.that have expired
or been superseded by more recent approvals. List the permit number,date,and unit or operation covered by the permit.
Example: 88DE 189 May 15, 1989 Incinerator
Fugitive Dust Sept I, 1992 Gravel Pit
Grandfathered Feb 2, 1972 Smith Boiler
Operating Pet Application
SUPPLEMENTAL INFORMATION FORM 2000-700
Air Pollution DePartmeControl nbof Division 09-94
Health and Environment
09-94
SEE INSTRUCTIONS ON REVERSE SIDE
Facility name CIie enne Plains Compressor Station 2. Facility identification code: CO 1230051
3 This form supplements Form 2000 800 for Emission Unit(e.g. B001, P001,etc.)
Insignificant Activities
Additional Information, Diagrams
Item Number
Please Update the insignificant activities list as specified
in the cover letter
Operating Permit
Colorado D Application TABULATION OF PERMIT APPLICATION FORMS FORM 2000-800
Air Pollution of Flealth
on Control 09-94
Facili Division
Name Cheyenne Plains Compressor Station
Facility Identification Code: CO 1230051
ADMINISTRATION
Tltts n contains the tolloscing forms: F Form 2000-100,Facilit Identification
• Form 2000-101,Facility Plot Plan
• Forms 2000-102.-102A.and-1020,Source and Site Descriptions
FM
DESCl2IPTIONSSiONS SOURCE
Total Number
Tln ` of This Form
pplication contains the following forms •(one fo Form 2000-200,Stack Identification
tm for each facility boiler,prinune
• Form 2000-300,Boiler or Furnace Operation
• Form 2000-301,Storage Tanks
• Form 2000-302,Internal Combustion Engine
• Form 2000-303,Incineration
• Form 2000-304,Printing Operations
• Form 2000-305,Painting and Coating Operations
• Form 2000-306,Miscellaneous Processes
• Form 2000-307,Glycol Dehydration Unit
III. AIR POLLUTION CONTROL
SYSTEM Total Number
of This Form
This application contains the following forms: • Form 2000-400,Miscellaneous
• Form 2000-401,Condensers
• Form 2000-402,Adsorbers
• Form 2000-403,Catalytic or Thermal Oxidation
• Form 2000-404,Cyclones/Settling Chambers
• Form 2000-405,Electrostatic Precipitators
• Form 2000-406,Wet Collection Systems
• Form 2000-407,Baghouses/Fabric Filters
IV. COMPLIANCE
DEMONSTRATION Total Number
of This Form
This application contains the following forms • Form 2000-500,Compliance Certification-Monitoring and Reporting
(one for each facility boiler.printing operation.
• form 2000-501,Continuous Emission Monitoring
• Form 2000-502,Periodic Emission Monitoring Using Portable Monitors
• Form 2000-503,Control System Parameters or Operation Parameters of a Process
• Form 2000-504,Monitoring Maintenance Procedures
• Form 2000-505,Stack Testing
• Form 2000-506,Fuel Sampling and Analysis
• Form 2000-507,Recordkeeping
• Form 2000-508,Other Methods
93
COiY1PLl [`•�11S51C1N'SUMMARY AND
ANC G CERTIFICATIONTotal Number
of This Form
This application contains the follmcine litrnts • Furm 2000-600.(:mission Unii I lazardous Air Pollutants
quantilj-in emission.,ccrtifyinh,
with applicable "e I I iancc
compliant rcqurrcmcnts,and dr�uop n_ae plan
• Form 2000-601,Emission Unit Criteria Air I'ollutanIs
• Form 2000-602,Facility Hazardous Air Pollutants
• Form 2000-603,Facility Criteria Air Pollutants
• Form 2000-604,Applicable Requirements and Status of Emission Unit
• Form 2000-605,Permit Shield Protection Identification
• Form 2000-606.Emission Unit Compliance Plan-Commitments and Schedule
• Form 2000-607,Plant-Wide Applicable Requirements
• Form 2000-608,Plant-Wide Compliance Plan-Commitments and Schedule
\/1
SIGNATURE OF RESPONSIBLE OFFICIAL - FEDERAL/STATE CONDITIONS
A, STATEMENT OF COMPLETENESS
I have reviewed this application in its entirety and,based on information and belief formed after reasonable inquiry, I certify that
the statements and information contained in this application are true,accurate and complete.
B. CERTIFICATION OF-FACILITY COMPLIANCE STATUS-FEDERAL/STATE CONDITIONS(check one box only)
X I certify that the facility described in this air pollution permit application is fully in compliance with all applicable
requirements.
• I certify that the facility described in this air pollution permit application is fully in compliance with all applicable
requirements,except for the following emissions unit(s):
(list all non-complying units)
WARNING: Any person who knowingly,as defined in § 18-1-501(6),C.R.S.,makes any false material statement, representation,
or certification in,or omits material information from this application is guilty of a misdemeanor and may be punished in
accordance with the provisions of§25-7 122.1,C.R.S.
Printed or Typed Name
Matt Mask Title
Director-Operations
Signature Date Signed
r 1k 3 08 a?O 8
Operating
Department olHealti,permit Application
Colo
CERTIFICATION FOR STATE-ONLY CONDITIONS FORM 2000-800
Air p 09-94
ollution Control Division
Facility Name:
Cheyenne Plains Compressor Station Facility Identification Code:CO 1230051
V SIGNATURE OF RESPONSIBLE OFFICIAL-STATE ONLY CONDITIONS
A. STATEMENT OF COMPLETENESS
I have reviewed this application in its entirety and,based on information and belief formed after reasonable inquiry, I certify that
the statements and information contained in this application are true,accurate and complete.
B. CERTIFICATION OF FACILITY COMPLIANCE STATUS FOR STATE-ONLY CONDITIONS(check one box only)
X I certify that the facility described in this air pollution permit application is fully in compliance with all applicable
requirements.
• I certify that the facility described in this air pollution permit application is fully in compliance with all applicable
requirements,except for the following emissions unit(s):
(list all non-complying units)
WARNING: Any person who knowingly,as defined in§ 18-1-501(6),C.R.S.,makes any false material statement, representation,
or certification in,or omits material information from this application is guilty of a misdemeanor and may be punished in
accordance with the provisions of§25-7 122.1,C.R.S.
Printed or Typed Name Title
Matt J Mask Director-Operations
Signature Date Signed
3/,28/O.. D)8
SEND ALL MATERIALS TO:
COLORADO DEPARTMENT OF HEALTH
APCD-SS-B I
4300 CHERRY CREEK DRIVE SOUTH
DENVER,CO 80246-1530
I. 95
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