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Home My WebLink About20201469.tiffC/Ilt' 1 as7.1.s, ni: P.O. Box 9597 • Fort Collins, CO 80525 • (303) 329-9295 • FAX (303) 329-9299 • Maggieairbasics@aol.com August 21, 2002 Mr. Geof Drissel, Permit Engineer Operating Permit Unit/APCD-SS-B 1 Colorado Dept. of Public Health & Env. 4300 Cherry Creek Drive South Denver, CO 80246-1530 RE: Minor Modification of Operating Permit 99OPWE207 for EnCana's Fort Lupton Plant Dear Mr. Drissel: Last year, North American Resources Company (now EnCana) permitted and installed a Solar turbine engine at its Fort Lupton plant. Permit 01 WE0290 was issued on August 7, 2001. The engine did not begin operating until October 31, 2001. According to Reg. 3, Part C, Section II1.B.2, a new or modified source shall submit a complete application for an operating permit revision within 12 months of commencing operation. Attached is a complete application for revision of Operating Permit 99OPWE207. Please process this application as a minor permit modification in accordance with the provisions of Regulation 3, Part C, Section X.D. 1. The turbine was permitted for the following emissions: NOx - 49.0 tpy and 8,162.7 lbs/month CO- 35.5 tpy and 5,917.3 lbs/month VOC- 10.2 tpy and 1.692.4 lbs/month. All new applicable regulations were detailed in the construction permit and are included in Section II, 11. of the draft permit. 2. The suggested draft permit. An annotated version of the current operating permit is provided, which incorporates the requirements of construction permit 01 WE0290. 3. Certification by a responsible official that the proposed modification meets the criteria for use of the minor permit modification procedures is attached. RECEIVED AUG `� 2 2002 AIR POLLUTION .CONTROL 2.TATIONARY SOURCES PROGRA ' Pvbfc Rev:e.r 6/01 ,f9to c c : pL(Ta), H�Ux), p 4(s.lt .Icr►/cKc), o&@ ) 5 /a IaO 2oao-l96'1 4. It is our understanding that the Division is responsible for supplying forms to notify EPA and affected states of this permit revision. 5. All applicable regulations have been enumerated in construction permit 01 WE0290. There are no new increases in NOx or CO emissions which have not already been modeled during the processing of the construction permit. C. A copy of the APEN dated June 17, 2002 is attached. Please issue this permit to EnCana Energy Resources Inc. The documentation substantiating the change from North American Resources Company to EnCana has been submitted under separate cover. Please contact me at (303) 329-9295 if you have any questions on this application. Thank you, Air Basics, Inc. Maggie Scher Air Quality Specialist AIR POLLUTION CONTROL DIVISION COLORADO OPERATING PERMIT FACILITY NAME: Ft. Lupton Plant OPERATING PERMIT NUMBER FACILITY ID: 1230319 ISSUE DATE: EXPIRATION DATE: MODIFICATIONS: October 1, 1999 October 1, 2004 See Appendix F of Permit 99OPWE207 Issued in accordance with the provisions of Colorado Air Quality Control Act, 25-7-101 et seq. (1989 & 1995 Supp.) and applicable rules and regulations. ISSUED TO: EN Ca^a Enet•9Y Resources INC. uIm Ktuc[1Laii 1Ccsuutees OH LJidny 16157 Weld County Road 22 3ia bi .ite A'e n Ae Ft. Lupton, CO 80621 8,,,I tai•^g No. PLANT SITE LOCATION: 16157 Weld County Road 22 Ft. Lupton, CO 80621 Weld County INFORMATION RELIED UPON Operating Permit Application Received: And Additional Information Received: Nature of Business: Primary SIC: RESPONSIBLE OFFICIAL Name: Jim Benner -'� Title: V i ce President Phone: 10G) 723 54-54 (340a) !.Z3-L3oo February 24, 1999 Natural Gas Plant 1311 FACILITY CONTACT PERSON Name: Jeff Reale Title: Senior Operations Superintendant Phone: (303) 659-7740 SUBMITTAL DEADLINES Semi -Annual Monitoring Period: Semi -Annual Monitoring Report: Annual Compliance Period: Annual Compliance Certification: October 1 - March 31, April 1 - September 30 May 1.2000 & November 1, 2000 and subsequent years Begins October 1 to September 30 November 1, 2000 and subsequent years 1 TABLE OF CONTENTS: SECTION I - General Activities and Summary Permitted Activities 1 Alternative Operating Scenarios 2 Prevention of Significant Deterioration 2 Accidental Release Prevention Program (112(r)) 2 Summary of Emission Units 3 SECTION II - Specific Permit Terms S001 -S004 - Four Ajax 2 -Cycle Lean Burn ICEs (514 HP each) 5 S007 - Fugitive VOC Emissions 7 S008 - Flare Industries 16" Flare 9 S009 - Amine Treating Unit (2,500 bbl/d) 10 S010 - Elastec Smart Ash (48 lbs/hr) 12 S012 - Ajax 2 -Cycle Lean Burn (550 HP) 14 S013 - Born Amine Unit Heater (10.7 MMBtu/hr) 16 S014 - Born Natural Gas Fired Hot Oil Heater (32 MMBtu/hr) 17 S015 -S017 - Three Ajax 2 -Cycle Lean Burn ICEs (550 HP each) 18 S018 -S019 - Two Caterpillar 4 -Cycle Lean Burn ICEs (980 HP each) 20 Portable Monitoring 21 --� S02O - ph.. Sob( �o,,,�- NO,, IC -rurb“.G (L1 -too FFp) SECTION III - Permit Shield Specific Non -Applicable Requirements 23 General Conditions 23 Streamlined Conditions 24 SECTION IV - General Permit Conditions Administrative Changes 25 Certification Requirements 25 Compliance Requirements 25 Emergency Provisions 26 Emission Standards for Asbestos 27 Emissions Trading, Marketable Permits, Economic Incentives 27 Fee Payment 27 Fugitive Particulate Emissions 28 Inspection and Entry 28 Minor Permit Modifications 28 New Source Review 28 No Property Rights Conveyed 28 Odor 29 Off -Permit Changes to the Source 29 Opacity 29 Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 North American Resources Company Ft. Lupton Plant Page 1 SECTION I - General Activities and Summary 1. Permitted Activities This facility consists of a natural gas processing plant defined under Standard Industrial Classification 1311. Raw natural gas is received in the Ft. Lupton plant and goes through one of two cryogenic processing trains. An engine compresses the inlet gas, an amine unit fired by a heater removes CO2 and H2S. The remaining residue compression is completed by sim-severk additional engines. Two fractionation trains separate out ethane, propane, butane and natural gasoline. Heat to the fractionation plant is provided by a natural gas fired hot oil heater. Refrigeration compression is provided by three engines. In addition the plant has a flare, fugitive VAC emissions from miscellaneous equipment at the plant, and an incinerator used for the combustion of oily solid waste. The facility is located in Ft. Lupton in Weld County. The area in which the plant operates is designated as attainment for all criteria pollutants. There are no affected states within 50 miles of the plant. The following Federal Class I designated area is within 100 kilometers of the plant; Rocky Mountain National Park. 1.2. Until such time as this permit expires or is modified or revoked, the permittee is allowed to discharge air pollutants from this facility in accordance with the requirements, limitations, and conditions of this permit. 1.3. This Operating Permit incorporates the applicable requirements contained in the underlying construction permits, and does not affect those applicable requirements, except as modified during review of the application or as modified subsequent to permit issuance using the modification procedures found in Regulation No. 3, Part C. These Part C procedures meet all applicable substantive New Source Review requirements of Part B. Any revisions made using the provisions of Regulation No. 3, Part C shall become new applicable requirements for purposes of this Operating Permit and shall survive reissuance. This Operating Permit incorporates the applicable requirements (except as noted in Section II) from the following Colorado Construction Permits: 93WE157-(1-4, 7, 8), 95WE683, 97WE0722, 97WE0723, 97WE0724, 97WE0725, 97WE0726, 97WE0727, 97WE0728,71mil 97WE0729a-+J oiweozyo, 1.4. All conditions in this permit are enforceable by US Environmental Protection Agency, Colorado Air Pollution Control Division (hereinafter Division) and its agents, and citizens unless otherwise specified. State -only enforceable conditions are: Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 7 Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 North American Resources Company Ft. Lupton Plant Page 4 S014 014 P014 Born, Inc Natural Gas Fired Hot Oil Heater, Design Rated at 32 MMBtu/hr, SN: 1963. Uncontrolled S015 015 P015 Ajax DPC-2803LE, 2 -Cycle Lean Burn, Low NOx design, Natural Gas Fired Internal Combustion Engine, Site Rated at 550 HP, SN: 84308. Uncontrolled S016 016 P016 Ajax DPC-2803LE, 2 -Cycle Lean Burn, Low NOx design, Natural Gas Fired Internal Combustion Engine, Site Rated at 550 HP, SN: 84288. Uncontrolled S017 017 P017 Ajax DPC-2803LE, 2 -Cycle Lean Burn, Low NOx design, Natural Gas Fired Internal Combustion Engine, Site Rated at 550 HP, SN: 84287. Uncontrolled S018 018 P018 Caterpillar G3516TALE, 4 -Cycle Lean Burn, Natural Gas Fired Internal Combustion Engine, Site Rated at 980 HP, SN: 3RCO1237. Uncontrolled S019 019 P019 Caterpillar G3516TALE, 4 -Cycle Lean Burn, Natural Gas Fired Internal Combustion Engine, Site Rated at 980 HP, SN: 3RCO1240. Uncontrolled —� Sozo j 020 Po2.o spur CeMau '}G, Law- t44 , Natural Gws F4fed 1�}trned Combut4:on TueWoe., S;4e Qa4cd a4 4'700 H P, SN: bee. m2d8. u.►co„rr*Utd Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 1. North American Resources Company Ft. Lupton Plant Page 5 SECTION II - Specific Permit Terms S001 -S004 - Four Ajax 2 -Cycle Lean Burn ICEs (514 HP each) Parameter Permit Condition Number Limitations for each engine Short Term Long Term Compliance Emission Factor Monitoring Method Interval NOx 1.1. NA 11.6 tons/yr 0.514 lb/MMBtu Recordkeeping, Monthly, CO NA 11.6 tons/yr 0.30 lb/MMBtu Calculations and Portable Quarterly VOC NA 5.8 tons/yr 0.15 lb/MMBtu Monitoring Fuel Use 1.2. NA 42.57 MMscf/yr NA Fuel Allocation (see Appendix H) Monthly Hours of Operation 1.3. NA NA NA Recordkeeping Monthly Opacity 1.4. Less Than or Equal to 20% NA Fuel Restriction At All Times Btu Content 1.5. NA NA NA ASTM Analysis Method Semi - Annually Emissions of Nitrogen Oxides, Carbon Monoxide and Volatile Organic Compounds from each engine shall not exceed the limitations stated above (Colorado Construction Permits 93WE157- (1-4)). Emissions shall be calculated by the end of the subsequent month using the listed compliance emission factors (EF) in the following equation: Lbs/month = [EF x monthly fuel use (MMscf/month) x heat content of gas (Btu/scf)] A twelve-month rolling total shall be maintained for demonstration of compliance with annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months data. Emission measurements of nitrogen oxides (NO„) and carbon monoxide (CO) from each engine shall be conducted quarterly using a portable flue gas analyzer as specified in Condition- 12.1 Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 North American Resources Company Ft. Lupton Plant Page 15 limitations. Each month, a new twelve month total shall be calculated using the previous twelve months data. Emission measurements of nitrogen oxides (NO„) and carbon monoxide (CO) frerm each engine ° shall be conducted quarterly using a portable flue gas analyzer as specified in Condition 144. 12 1 6.2. Fuel consumption shall not exceed the limitations above (Colorado Construction Permit 97WE0722). Within the first seven days of every month, the fuel meter shall be read and recorded. Allocation of fuel use shall be made using the methods detailed in Appendix H of this permit. The fuel use shall be measured no more than twelve (12) hours from the time that run time hours have been recorded. A twelve month rolling total shall be maintained for demonstration of compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 6.3. Hours of operation shall be recorded on a monthly basis for use in fuel allocation calculations. 6.4. Opacity of emissions shall not exceed 20 % (Colorado Construction Permit 97WE0722). In the absence of evidence to the contrary, compliance with the 20% opacity limit shall be presumed whenever natural gas is used as fuel for these engines. 6.5. The Btu content of the natural gas used to fuel this engine shall be determined semi-annually using ASTM Analysis Method D1945 or equivalent. Calculation of monthly emissions outlined under Condition 6.1 shall be based on the most recent BTU analysis. The BTU Content shall be based on the lowest gross heating value of the fuel. 6.6. This engine shall be operated and maintained in accordance with manufacturer's recommendations at all times, including periods of start-up, shutdown, and malfunction. Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 North American Resources Company Ft. Lupton Plant Page 19 engine shall not exceed the limitations stated above (Colorado Construction Permits 97WE0725, 97WE0726 and 97WE0727). Emissions shall be calculated by the end of the subsequent month using the listed compliance emission factors (EF) in the following equation: Lbs/month = [EF x monthly fuel use (MMscf/month) x heat content of gas (Btu/scf)] A twelve-month rolling total shall be maintained for demonstration of compliance with annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months data. Emission measurements of nitrogen oxides (NOr) and carbon monoxide (CO) from each engine sball be conducted quarterly using a portable flue gas analyzer as specified in Condition . -7 12 I 9.2. Fuel consumption for each engine shall not exceed the limitations above (Colorado Construction Permits 97WE0725, 97WE0726 and 97WE0727). Within the first seven days of every month, the fuel meter shall be read and recorded. Allocation of fuel use shall be made using the methods detailed in Appendix H of this permit. The fuel use shall be measured no more than twelve (12) hours from the time that run time hours have been recorded. A twelve month rolling total shall be maintained for demonstration of compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 9.3. Hours of operation for each engine shall be recorded on a monthly basis for use in fuel allocation calculations. 9.4. Opacity of emissions from each engine shall not exceed 20 % (Colorado Construction Permits 97WE0725, 97WE0726 and 97WE0727). In the absence of evidence to the contrary, compliance with the 20% opacity limit shall be presumed whenever natural gas is used as fuel for these engines. 9.5. The Btu content of the natural gas used to fuel these engines shall be determined semi-annually using ASTM Analysis Method D 1945 or equivalent. Calculation of monthly emissions outlined under Condition 9.1 shall be based on the most recent BTU analysis. The BTU Content shall be based on the lowest gross heating value of the fuel. 9.6. These engines shall be operated and maintained in accordance with manufacturer's recommendations at all times, including periods of start-up, shutdown, and malfunction. Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 North American Resources Company Ft. Lupton Plant Page 20 10. S018 -S019 - Two Caterpillar 4 -Cycle Lean Burn ICEs (980 HP each) Parameter Permit Condition Number Limitations for each engine Short Term Long Term Compliance Emission Factor Monitoring Method Interval NOx 10.1. NA 18.9 tons/yr 0.585 lb/MMBtu Recordkeeping, Calculation and Monthly, Quarterly CO NA 18.9 tons/yr 0.492 lb/MMBtu Portable Monitoring VOC NA 9.5 tons/yr 0.18 lb/MMBtu Fuel Use 10.2. NA 63.4 MMscf/yr NA Fuel Allocation (See Appendix H) Monthly Hours of Operation 10.3. NA NA NA Recordkeeping Monthly Opacity 10.4. Less Than or Equal to 20% NA Fuel Restriction At All Times Btu Content 10.5. NA NA NA ASTM Analysis Method Semi - Annually 10.1. Emissions of Nitrogen Oxides, Carbon Monoxide and Volatile Organic Compounds from each engine shall not exceed the limitations stated above (Colorado Construction Permits 97WE0728 and 97WE0729). Emissions shall be calculated by the end of the subsequent month using the listed compliance emission factors (EF) in the following equation: Lbs/month = [EF x monthly fuel use (MMscf/month) x heat content of gas (Btu/scf)] A twelve-month rolling total shall be maintained for demonstration of compliance with annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months data. Emission measurements of nitrogen oxides (NOx) and carbon monoxide (CO) from each engine shall be conducted quarterly using a portable flue gas analyzer as specified in Condition -I-H. 7 12.1 10.2. Fuel consumption for each engine shall not exceed the limitations above (Colorado Construction Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 North American Resources Company Ft. Lupton Plant Page 21 Permits 97WE0728 and 97WE0729). Within the first seven days of every month, the fuel meter shall be read and recorded. Allocation of fuel use shall be made using the methods detailed in Appendix H of this permit. The fuel use shall be measured no more than twelve (12) hours from the time that run time hours have been recorded. A twelve month rolling total shall be maintained for demonstration of compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 10.3. Hours of operation for each engine shall be recorded on a monthly basis for use in fuel allocation calculations. 10.4. Opacity of emissions from each engine shall not exceed 20 % (Colorado Construction Permits 97WE0728 and 97WE0729). In the absence of evidence to the contrary, compliance with the 20% opacity limit shall be presumed whenever natural gas is used as fuel for these engines. 10.5. The Btu content of the natural gas used to fuel these engines shall be determined semi-annually using ASTM Analysis Method D1945 or equivalent. Calculation of monthly emissions outlined under Condition 10.1 shall be based on the most recent BTU analysis. The BTU Content shall be based on the lowest gross heating value of the fuel. 10.6. These engines shall be operated and maintained in accordance with manufacturer's recommendations at all times, including periods of start-up, shutdown, and malfunction. (I„seat' Sec.hon it, aEFar,l l 44, Portable Monitoring 12. -1++. Emission measurements of nitrogen oxides (NO„) and carbon monoxide (CO) from each engine 12 • t shall be conducted quarterly using a portable flue gas analyzer. Calibration of the analyzer shall be conducted according to manufacturer's instructions. Results of the portable flue gas analyzer tests shall be used to monitor the compliance status of each engine. For comparison with an annual or short term emissions limit, the results of the tests shall be converted to a lb/hr basis aild multiplied by the allowable operating hours in the month or year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever applies. An exceedance of either the NO„ or CO emission limitation during the initial portable flue gas analyzer test shall require a subsequent portable analyzer test indicating compliance with both the NOX and CO emission limitations within 14 calendar days of the initial test. Calibration gases shall be used to calibrate the portable analyzer for all tests conducted subsequent to the initial test. Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 11. S020 — One Solar Centaur Low-NOx IC Turbine (4700 HP) Parameter Permit Condition Number Limitations Short Term Long Term Compliance Emission Factor Monitoring Method Interval NOx 11.1 NA 49.0 tons/yr 0.30 Ib/MMBtu Recordkeeping, Calculation and Portable Monitoring Monthly, Quarterly CO NA 35.5 tons/yr 0.21 lb/MMBtu VOC NA 10.2 tons/yr 0.06 Ib/MMBtu NSPS Subpart GG 11.2 NOx - 157.5 ppmv* NA Fuel Restriction Annually SO2— 150 ppmv* NA Fuel Sulfur content < 0.8% by weight NA NSPS , General Provisions 11.3 NA NA NA As Defined As Defined Fuel Use 11.4 NA 320 MMSCF/yr NA Fuel Meter Monthly Opacity 11.5 Less than or Equal to 20% NA Fuel Restriction At All Times Btu Content 11.6 NA NA NA ASTM Analysis Method Semi - Annually * at 15% O2 on a dry basis 11.1 Emissions of Nitrogen Oxides, Carbon Monoxide and Volatile Organic Compounds shall not exceed the limitations stated above (Colorado Construction Permit 01WE0290). Emissions shall be calculated by the end of the subsequent month using the listed compliance emission factors (EF) in the following equation: Lbs/month = [EF x monthly fuel use (MMscf/month) x heat content of gas (Btu/scf)] A twelve-month rolling total shall be maintained for demonstration of compliance with annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months data. Emissions measurements of nitrogen oxides (NOx) and carbon monoxide (CO) from each engine shall be conducted quarterly using a portable flue gas analyzer as specified in Condition 12.1. 11.2 This source is subject to the New Source Performance Standards (NSPS) requirements of Regulation No. 6, Part A, Subpart GG, Standards of Performance for Stationary Gas Turbines (as adopted by reference from 40 CFR 60, Subpart GG, and as cited in Colorado Construction Permit 01WE0290): 11.2.1. Emissions of Nitrogen Oxides (NOx) shall not exceed the limitations stated above (NSPS Subpart GG, §60.332). 11.2.2. Emissions of Sulfur Dioxide (SO2) shall not exceed the limitations stated above (NSPS Subpart GG, §60.333). Compliance with these standards and with the monitoring provisions of §60.334(b) was demonstrated by determining fuel -bound nitrogen when permitting the engine, and by conducting a performance test in accordance with the provisions of Regulation No. 6, Part A, Subpart A, Section 60.8, on March 6, 2002. In the absence of evidence to the contrary, ongoing compliance with these standards, the monitoring provisions of §60.334(b), and the testing methods of §60.335(e) shall be presumed whenever pipeline quality natural gas is used as fuel for the turbine. 11.3 The following requirements of Regulation No. 6, Part A, Subpart A, General Provisions also apply (as adopted by reference from 40 CFR 60): 11.3.1 At all times, including periods of start-up, shutdown, and malfunction, the facility and control equipment shall, to the extent practicable, be maintained and operated in a manner consistent with good air pollution control practices for minimizing emissions. Determination of whether or not acceptable operating and maintenance procedures are being used will be based on information available to the Division, which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. (NSPS Subpart A, §60.11, and Colorado Construction Permit 01WE0290) 1 1.3.2 No article, machine, equipment or process shall be used to conceal an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gases discharged to the atmosphere. (NSPS Subpart A,§60.12, and Colorado Construction Permit 01WE0290) 11.3.3 A notification of any physical or operational change to an existing facility which may increase the emission rate of NOx or SO2 (NSPS Subpart A, §60.7 (a)(4)). 11.3.4 Records of startups, shutdowns, and malfunctions shall be maintained, as required. (NSPS Subpart A, §60.7, and Colorado Construction Permit 01 WE0290) 11.4 Fuel consumption shall not exceed the limitations above (Colorado Construction Permit 01 WE0290). Within the first seven days of each month, fuel use shall be recorded. A twelve month rolling total shall be maintained for demonstration of compliance with the annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months' data. I I.5 Opacity of emissions shall not exceed 20% (Colorado Construction Permit 01 WE0290). In the absence of evidence to the contrary, compliance with the 20% opacity limit shall be presumed whenever natural gas is used as fuel for this engine. 11.6 The Btu content of the natural gas used to fuel this engine shall be determined semiannually using ASTM Analysis Method D1945 or equivalent. Calculation of monthly emissions outlined under Condition 11.1 shall be based on the most recent Btu analysis. The Btu content shall be based on the low gross heating value of the fuel. 11.7 These engines shall be operated and maintained in accordance with manufacturer's recommendations at all times, including periods of start-up, shut -down and malfunction. Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 SECTION III - Permit Shield North American Resources Company Ft. Lupton Plant Page 23 Regulation No. 3, 5 CCR 1001-5, Part A, & I.B.43; Part C, §§ V.C.1.b. & D., XIII; §§ 25-7-111(2)(I), 25- 7-114.4(3)(a), C.R.S. 1. Specific Non -Applicable Requirements The following parameters and requirements have been specifically identified as non -applicable to the facility to which this permit has been issued: Emission Unit Description & Number Applicable Requirement Justification Unit S009 Regulation No. 3, Part B, Section III.A Unit S009 is exempt from construction permitting requirements per exemption letter (95WE409.XP). Criteria emissions are below deminimis, however H2S emissions are above non -criteria reportable thresholds. Entire Facility Regulation No. 3, Part B, Section IV.D.3 (PSD) Based on the information provided, this facility is not a major stationary source (no criteria pollutant emissions potential to emit > 250 tons per year) with respect to Prevention of Significant Deterioration (PSD) requirements as of the issue date of this permit. Unit S014 Regulation No. 6, Part A, Subpart Dc (40 CFR 60 Subpart Dc §§60.42c; 60.43c, 60.44c; 60.45c; 60.46c; 60.47c; 60.48c(b), (c), (d), (e) and (f)) These sections are based on the use of either coal or fuel oil. This source utilizes only natural gas. see htle'cliecl taster 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 Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 SECTION III — Permit Shield Please add the following to the permit shield: Emission Unit Description & Number Applicable Requirement Justification Unit S020 Regulation No. 6, Part A, Subpart GG (40 CFR 60) §§60.334 (a) and (c) (1) and §60.335 (c)(2). These sections pertain to the use of water injection to control NOx. This source uses lean premixed combustion instead. Unit S020 Regulation No. 6, Part A, Subpart GG (40 CFR 60) §60.334 (c) (2) The use of natural gas as fuel is sufficient to demonstrate compliance with the fuel sulfur content limit, thus the reference to excess emissions does not apply. Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Format Appendix B Page 7 Operating Permit Unit ID Unit Description Deviations noted During Period?' Deviation Code Upset/Emergency Condition Reported During Period? YES NO YES NO S017 Ajax DPC-2803LE, 2 -Cycle Lean Burn, Low NOx design, Natural Gas Fired Internal Combustion Engine, Site Rated at 550 HP, SN: 84287. S018 ' Caterpillar G3516TALE, 4 -Cycle Lean Burn, Natural Gas Fired Internal Combustion Engine, Site Rated at 980 HP, SN: 3RCO1237. S019 Caterpillar G3516TALE, 4 -Cycle Lean Burn, Natural Gas Fired Internal Combustion Engine, Site Rated at 980 HP, SN: 3RCO1240. 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:: 2 = Process: 3 = Monitor: 4 = Test: 5 = Maintenance: 6 = Record: 7 = Report: 8 = Other: When the requirement is an emission limit or standard When the requirement is a production/process limit When the requirement is monitoring When the requirement is testing When required maintenance is not performed When the requirement is recordkeeping When the requirement is reporting. When the deviation is not covered by any of the above categories S02O Solar Ctn}Aur 440, tow- N0k, ts1a4,.e..1 Gat Pre) f 1-erwal Co•.bt.akan Twrbiwe, S;i-c.2.4.J eel- 4.700 NPR 514: DcclCamg. Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 fr Air Pollution Control Division Colorado Operating Permit Compliance Certification Report Format Appendix C Page 4 Operating Permit Unit ID Unit Description Deviations Reported' Compliance Status?' Monitoring Method per Permit?' Was Data Continuous?' Previous Current IN OUT YES NO YES NO S019 Caterpillar G3516TALE, 4 - Cycle Lean Burn, Natural Gas Fired Internal Combustion Engine, Site Rated at 980 HP, SN: 3 RCO 1240. General Conditions Insignificant Activities 5 ' If deviations were noted in the previous deviation report (i.e. for the first six months of the annual reporting period) nut an "Y" under 5 "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. Z Fill in this column for all listed points. 3 Note whether the method(s) used to determine the compliance status with each term and condition was the method(s) specified in the permit. If it was not, mark "no"and attach additional information/explanation. 'Note whether the method(s) used to determine the compliance status with each term and condition provided continuous or intermittent data. 5 Compliance status for these sources shall be based on a reasonable inquiry using readily available information. solo _ Solar Ce04awr +fog f.osa- /OA, Na4 tat fe►s F:tecl Ih4e+ro.l Cnw.,s1;0•• Tw.b:Ae, S:4. Rake( a+ `Mo° OP, SN: 'DCG mzefg, Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 Air Pollution Control Division Colorado Operating Permit Permit Modifications Appendix F Page 1 APPENDIX F Permit Modifications DATE OF REVISION TYPE OF REVISION SECTION NUMBER, CONDITION NUMBER DESCRIPTION OF REVISION Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 Please process the attached permit modification for 99OPWE207, Fort Lupton Plant under the minor modification procedures outlined in Colorado Regulation 3, Part C, Section X. To the best of my knowledge and understanding, these documents meet the criteria outlined in Regulation 3, Part C, Section X.D. for processing as a minor permit modification. James J. Benner Vice President, Gathering Services EnCana Oil & Gas (USA) Inc. (formerly North American Resources Company) 8/2t X02 Date ADMINISTRATIVE PERMIT AMENDMENT FORM SEE INSTRUCTIONS ON REVERSE SIDE. Mail completed application, APENs, and filing fee to: Colorado Department of Public Health and Environment Air Pollution Control Division 4300 Cherry Creek Drive South, APCD-SS-BI Denver, Colorado 80246-1530Telephone: (303) 692-3150 1. Permit previously issued to: North American Resources Company 2. Permit to be issued to: EnCana Oil & Gas (USA) Inc. 3. Mailing Address: 1313 Denver Avenue, Building #1 State: Colorado Fort Lupton Zip Code: 80621 4. Agent for Service: Mary A. Viviano (303) 623-2300 5. Air Pollution Source Existing Permit Number(s) and Description(s): 99OPWE207 Fort Lupton Plant AIRS No. 1230319 95OPAR104 Mitchell Compressor Station AIRS No. 0051113 95OPAD190 Radar Compressor Station AIRS No. 0010229 6. Source Location Address (Include Location Map): Plant: 16157 Weld County Road 22, Fort Lupton, CO 80621 (Weld) County: Mitchell: NE/4 NE/4 Section 32 T4S R63W (Arapahoe) Radar: NW/4 Section 34 T2S R64W (Adams) 7. STATUS RECEIVED SEP . 2uuz A;tR POLLUTION CONTHOL each factiiiy.N �pY SOURCES PROOF -4%i O Transfer of Ownership • Name Change to Existing Permit Other: 8. Projected Source Startup Date: Existing 9. Enclose check to cover APEN FILING FEES. One APEN should be filed for NOTE: Additional processing fees must also be paid prior to permit issuance. Signature Of Le Authorize et off (NO Vendor or Equipment Manufacturer) Date Signed: Phone: (303) 659-7740 ,� e � P P Ls. Jeff Re Senior Operations Superintendent Type or vnntname and official title of person signing above 10. Check appropriate box if you want: Fax: (303) 857-1259 For Division Use Only: Permit Number: • Copy of preliminary analysis conducted by Division ❑ To review a draft of the permit prior to issuance Note Checking either item could result in increased fees and/or processing time. See Reverse. AIRS ID: Revised July 2001 http://www.cdphe.state.co.us/ap/stationary.asp 4r Basics, Inc P.O. Box 9597 • Fort Collins, CO 80525 • (303) 329-9295 • FAX (303) 329-9299 • Maggieairbasics@aol.com August 22, 2002 Operating Permit Unit/APCD-SS-B1 Colorado Dept. of Public Health & Environment 4300 Cherry Creek Drive South Denver, CO 80246-1530 Re: Name Change for Title V permits for Fort Lupton Plant (99OPWE207), Radar Compressor Station (95OPAD 190), and Mitchell Compressor Station (95OPAR104) To Whom It May Concern: Enclosed are the following legal documents which substantiate the change from North American Resources Company (NARCO) to EnCana Energy Resources Inc. — • Articles and Plan of Merger of Entech Gas Ventures, Inc., The Montana Power Gas Company, Xeno, Inc. and North American Resources Company filed on December 28, 2001 (3 pages), which shows how NARCO became PanCanadian Energy Resources Inc. • Montana Secretary of State's certificate of filing for the above merger dated January 8, 2002 (1 page). • Articles of Amendment for Name Change for Profit Corporation signed April 3, 2002 (1 page), which shows how PanCanadian Energy Resources Inc. became EnCana Energy Resources Inc. • Montana Secretary of State's certificate of filing for the above name change dated April 8, 2002 (1 page). Please contact me at (303) 329-9295 if you have any questions on this name change. Sincerely, Air Basics, Inc. Ma gig 'Scher Air Quality Specialist do srq q,9 404,444070 UG "Ito 64" /444 RUG 22 2002 10:18AM HP LRSERJET 3200 P . 2 ARTICLES OF MERGER OF ENTECH GAS VENTURES, INC., THE MONTANA POWER GAS COMPANY, XENO, INC. AND NORTH AMERICAN RESOURCES COMPANY To the Secretary of State State of Montana FILED DEC �j.o SECRETARY OF STATE ' Pursuant to the provisions of the Montana Business Corporation Act, the undersigned Montana business corporations do hereby submit the following Articles of Merger. 1. Annexed hereto and made a part hereof is a Plan of Merger for merging Entech Gas Ventures, Inc., The Montana Power Gas Company and Xeno, Inc. with and into North American Resources Company, as approved by the Board of Directors of all of the corporations on December 19, 2001. PanCanadian Energy Inc., a Delaware corporation, as the holder of all of the issued and outstanding shares of each of the four corporations party to the mergers, approved the Plan of Merger on December 19, 2001 and waived the requirements of mailing a copy of the Plan of Merger. 2. The aforesaid Plan of Merger was adopted in accordance with the provisions of Section 35-1-813 of the Montana Business Corporation Act on December 19, 2001. 3. The effective time and date of the mergers herein provided for shall be 11:00 p.m on December 31, 2001. Executed on December d0 , 2001 ENTECH GAS VENTURES, INC. Bp: 14 ,A.4Q N of offi . Rachel Desroches Title of officer: Assistant Secretary THE MONTANA POWER GAS COMPANY By: Name of officer. Rachel Desroches Title of officer: Assistant Secretary XENO, INC. By: Name of officer: Rachel Desroches Title of officer. Assistant Secretary NORTH AMERICAN RESOURCES COMPANY By: 401,4Aatho Nana of officer. Rachel Desroches Title of officer: Assistant Secretary RUG 22 2002 10:18RM HP LASERJET 3200 p.3 PLAN OF MERGER 1. Entech Gas Ventures, Inc., a business corporation of the State of Montana, ("EGVI"), The Montana Power Gas Company, a business corporation of the State of Montana ("MPGC") and Xeno, Inc., a business corporation of the State of Montana ("Xcno"), arc hereby merged with and into North American Resources Company, a business corporation of the State of Montana ("NARCO"), pursuant to the provisions of Section 35.1.813 of the Montana Business Corporation Act. All of the issued and outstanding shares of EGVI, MPGC, Xeno and NARCO are owned by PanCanadian Energy Inc. a business corporation of the State of Delaware. 2. The separate existence of EGVI, MPGC and Xeno shall cease at the effective time and date of the mergers, and NARCO shall continue its existence as the surviving corporation pursuant to the provisions of the Montana Business Corporation Act. 3. The issued shares of EGVI, MPGC and Xeno shall not be converted in any manner, but each said share, which is issued at the effective time and date of the mergers, shall be surrendered and extinguished. 4. The Articles of Incorporation of the surviving corporation, as now in force and effect, shall continue to be the Articles of Incorporation of said surviving corporation, except as amended in accorrlaree with paragraph 5 below, and said Articles of Incorporation as so amended shall continue in full force and effect until further amended and changed in the manner prescribed by the provisions of the Montana Business Corporation Act. 5. At the effective time of the mergers Article I of the surviving corporation's Articles of Incorporation will be amended to change the name of the surviving corporation to PanCanadian Energy Resources Inc. 6. The present by-laws of the surviving corporation will be the by-laws of said surviving corporation and will continue in full force and effect until changed, altered, or amended as therein provided and in the manner prescribed by the provisions of the Montana Business Corporation Act. 7. The directors and officers in office of the surviving corporation at the effective time of the mergers shall remain and be the members of the Board of Directors and the officers of the surviving corporation, all of whom shall hold their directorships and offices until the election and qualification of their respective successors or until their tenure is otherwise terminated in accordance with the by-laws of the surviving corporation. 8. The Board of Directors and the proper officers of each of EGVI, MPGC, Xeno and NARCO are hereby authorized, empowered, and directed to do any and all acts and things, and to make, execute, deliver, file, and/or record any and all instruments, papers, and documents which shall be or become necessary, proper, or convenient to carry out or put into effect any of the provisions of this Plan of Merger or of the mergers herein provided for. ..1 AUG 22 2002 10:19RM HP LASERJET 3200 16:11 DEC' 28, 2001 TEL N0: 212-894-8888 PARTLFILES\PANCIDN\Nam* \DodlAddendu to Axttnasga-dx262001.xxttaa#9.doc ADDENDUM TO ARTICT.FS OF MERGER p.4 *206424 PAGE: 2/2 The Plan of Merger for merging Entech Gas Ventures, Inc., The Montana Power Gas Company and Xeno, Inc. with and into North American Resources Company, was approved by the Unanimous Written Consents of the respective Board of Directors of all of the corporations on December 19, 2001. PanCanadian Energy Inc., a Delaware corporation, ("PEI") as the holder of all of the issued and outstanding shares of each of the four corporations party to the merger approved the Plan of Merger on December 19, 2001 by Written Consent of the Sole Shareholder. PEI (a) owns 10 shares of common stock of Entech Gas Ventures, Inc. and voted all such shares in favor of the Plan of Merger; (b) owns 10 shares of common stock of The Montana Power Gas Company and voted all such shares in favor of the Plan of Merger; (c) owns 300 shares of common stock of Xeno, Inc. and voted all suds shares in favor of the Plan of Mexge., and (d) owns 49,000 shares of common stock of North American Resources Company and voted all such shares in Favor of the Plan of Merger. AUG 22 2002 10:18RM HP LASERJET 3200 p.1 SECRETARY OF STATE STATE OF MONTANA BOB BROWN Business Services Bureau Pat Haffey, Deputy ROBERT T LINCOLN DUNNINOTON BARTHOLOW & MILLER 666 THIRD AVENUE NEW YORK NY 10017-5683 January 8, 2002 Dear Mr. Lincoln: I've approved the filing of the documents for the above named entity. The document number and filing date have been recorded on the original document. This letter serves as your certificate of filing and should be maintained in your files for future reference. PRIORITY Montana State Capitol PO Box 202801 Helena, MT 59620-2801 (406)444-3665 hup://www.state.mt.us/sos/ • Thank you for giving this office the opportunity to serve you. If you have any questions in this regard, or need additional assistance, please do not hesitate to contact the Business Services Bureau professionals at (406) 444-3665. Sincerely, Bob Brown Secretary of State Enclosure You can correspond with our office via facsimile. Our fax number is (406) 444-3976. You can now fax in your search, copy, and certificate requests. AUG 22 2002 10:20AM HP LASERJET 3200 P.6 •STATE OF MONTANA 11114411 4. ARTICLES of AMENDMENT for NAME CHANGE for PROFIT CORPORATION MAIL: BOB BROWN Secretary of State P.O. Box 202801 Helena, MT 59620-2801 PHONE: n(406)444-3665 FAX: (406)444-3976 WEB SITE: www.sisIgastess/ses Prepare, sip sod submit ea ORIGINAL AND COPY wltk fee. adshmam (ibie specs for we by doe Smeary of$aeeont ) 01041 STATE OF MONTANA FILED #40,/, APR U z$ 2002 1 r SECRETARY OF STATE: Ap1 Fa: S 15.0 Priority Flagg (add additional $20.00) • FittsT: The current name of this Corporation is: PonCanadian Energy Resources Inc. ▪ SECo1VD: The name is hereby amended to be EnCaPa Energy Resata'ces Inc. p Ti mRD: The date this amendment was adopted is April 1, 2002, (mo/day/year) • FOURTH: Choose either (1) or (2): (I) This amendment was adopted by a sufficient vote of the Board of Directors. A vote of the shareholders was not required. or (2) This amendment was adopted by a vote of the shareholders. There were 49.000 . shares issued; 49,000 voted (specific #) (specific #) for the amendment; 0 voted against. (sPecific #) ZZ=II101 8—adViuJ Si g�eture or Chair of the Board of Assistant Secretary Title April 3. 2002 Date r.1f'orteslsp-1 Revised: 01/02/2001 AUG 22 2002 10:19AM HP LASERJET 3200 p.5 • SECRETARY OF STATE PRIORITY STATE OF MONTANA BOB BROWN Business Services Bureau Pat Halley, Deputy RACHEL DESROCHES ANALYST -LAW PANCANADIAN ENERGY CORPORATION 150 9TH AVENUE SW CALGARY AB 72P 3119 CANADA April 8, 2002 Dear Ms. Desroches: Montana State Capitol PO Box 202801 Helena, MT 59620-2801 (406)444-3665 http://www.state.mkus/sos/ I've approved the filing of the documents for the above named entity. The document number and filing date have been recorded on the original document. This letter serves as your certificate of filing and should be maintained in your files for future reference. Thank you for giving this office the opportunity to serve you. If you have any questions in this regard, or need additional assistance, please do not hesitate to contact the Business Services Bureau professionals at (406) 444-3665. Sincerely, (?dl (3-„Aw-, Bob Brown Secretary of State Enclosure You can correspond with our office via facsimile. Our fax number is (406) 44439%. You can now fax in your search, copy, and certificate requests, /I 404.)/ c, r Basics, Inc.. P.Q. Box 9597 • Fort Collins, CO 80525 • (303) 329-9295 • FAX (303) 329-9299 • Maggieairbasics@aol.com Colorado Dept. of Public Health & Environment APCD-SS-B 1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 July 8, 2002 RECEIVED JUL 08 2002 STATIONARYSOURCES PROAIR POLLUTION GRAM Re: Corporate name change for North American Resources Company to EnCana 1 4 90 j /�.! O To Whom It May Concern: In late 2000, North American Resources Company's (NARCO) parent company, Montana Power, was purchased by PanCanadian Energy. Colorado facilities continued to operate under the North American Resources Co. name until earlier this year. Then on April 5, 2002, PanCanadian Energy and Alberta Energy Company Ltd. merged to form EnCana. Enclosed are 46 revised APENs that reflect the name change and update the actual emissions for active sources in Colorado. Table 1 provides an overview of these sources. Where an APEN reflects an increase in actual emissions, the increase is small enough so that it does not constitute a "significant change" as defined in Regulation 3, Part A II.C.2. Also enclosed is a check for $5,638.12, which is $119.96 more than the required APEN filing fee. Please remit the balance to: Ms. Pat Linderholm EnCana 1311 Denver Avenue, Building #1 Fort Lupton, CO 80621. In addition to the active sources listed in Table 1, please re -issue permit 00DE0267R (Third Creek ERC permit) in EnCana's name. It is our understanding that an APEN is not required for this source. TABLE 1 EnCana Sources Requiring an APEN RECEIVED aeilityVaure t par • asC,Fs 1 Y"cY atilt' 51 33�'f jyLc "F "1't S.* �" a'"r Sotirc 4 � *Ties�6ptid3't): ` �' 1'� ,y d p , t., } ° LJ'6 �h.sck ,'%r 'R ""�` "l 100 Lateral 123/0471 001 002 Superior Engine D-215 Superior Engine D-220 Aristocrat 123/0127 001 004 006 Ajax Engine 180-A Ajax Engine 180-B Caterpillar Rental Engine Dragoon 005/0051 006 008 009 Superior Engine S006 Fugitive VOC Barnhart 1'FG Dehy 777/1247 001 Portable Smart Ash Unit Frederick 123/0151 004 005 Waukesha Engine D-225 Waukesha Engine D-300 777/1248 001 Portable Smart Ash Unit Ft. Lupton 123/0319 001 002 003 004 007 008 009 010 012 013 014 015 016 017 018 019 020 Ajax Engine C -101A Ajax Engine C -101B Ajax Engine C-101 C Ajax Engine C-101 D Fugitive VOC Flare Amine Treating Unit Smart Ash Unit Ajax Engine C-210 Born Heater E-460 Born Heater HX-500 Ajax Engine C-324 Ajax Engine BC -323 Ajax Engine BC -314 Caterpillar Engine S018 Caterpillar Engine S019 Solar Turbine Engine Kallsen 001/0628 006 007 008 Fugitive VOC Superior Engine #8 Barnhart TEG Dehy Mitchell 005/1113 004 005 007 008 Waukesha Engine #23B Caterpillar Engine #1 Fugitive VOC Barnhart TEG Dehy Radar 001/0229 005 006 008 ???* Caterpillar Engine #20B Fugitive VOC Barnhart TEG Dehy Caterpillar Engine #2 State 001/0627 002 004 005 006 Caterpillar Engine #7B Fugitive VOC Barnhart TEG Dehy Caterpillar Engine #11 Taylor 001/1267 002 003 Waukesha Engine D-410 Barnhart TEG Dehy *This source was permitted under Title V #95OPAD 190 without an AIRS number. rR0L R0GRAM AIR POLLUTANT EMISSION NOTICE FIRM NAME EnCana T,T~RMIT No.: 99OPWE207 AIRS ID.: 123 / 0319 / 001 MAIL ADDRESS 1313 Denver Avenue, Building #1 Fort Lupton PLANT NAME & LOCATION_Fort Lupton Plant: 16157 Weld County Road 22, Ft. Lupton, CO 80621 REQUEST PORTABLE SOURCE PERMIT HOME -BASE FOR PORTABLE SOURCE PERSON TO CONTACT REGARDING THIS INFORMATION Jeff Reale GENERAL DESCRIPTION OF THIS PLANT'S FUNCTION Natural gas processing plant STATE: _CO ZIP: 80621 COUNTY: Weld A. GENERAL INFORMATION Normal Operation of This Source Hours/Day 24 TITLE Senior Operations Superintendent PHONE (303) 659-7740 E-MAIL ADDRESS: Jeff.Reale@EnCana.com Process Seasonal Through ut ° Th h (3' of Annual) Dec -Feb 25 Days/Week 7 Weeks/Year 52 Mar -May Jun -Aug 25 25 Sep -Nov 25 ADDITIONAL INFORMATION OR REMARKS: Formerly North American Resources Company B. STACK OR VENT INFORMATION (Identify below which stack if plant has two or more; refer to attached sketch of plant layout) Height 25.25 ft Diameter 1.44 ft Temperature 465 °F Flow Rate 4280 ACFM Velocity 2628 ft/min Moisture 8 Plant ID No. for Stack S001, C -101A C. FUEL INFORMATION Description of Combustion Unit Design nput Rate (106 BTU/hr) Kind of Fuel Burned Annual Fuel Consumption Requested level Actual level (Data year level) Fuel Heating Value: (BTU/lb, BTU/gal, or BTU/scf) Percent by Weight Sulfur Ash Seasonal Fuel Use .(% of Annual Use) Dec -Feb Mar -May Jun -Aug Sep -Nov Space Htg (% Ann.) 514 hp (site rated) Compressor Engine Natural Gas 0 0 25 25 25 25 Make/Model: Ajax DPC-540 LE Serial No. 83891 D. PROCESS INFORMATION Description of Processing Unit Make/Model: Raw Materials Used Description REC Raw Materials -Annual Consume t' Requested level Actual, (DJl .vrJ_ 5fA I IUllNAAF4Y EIVED 1se0, 2O2 sig recess Rate SUUN E„ PROGRAM SU C � PROGR�an/ Finished Product Description Finished Product -Annual Output Requested level Actual level (Data year level) Serial No.: E. POLLUTION CONTROL EQUIPMENT Overall ESTIMATED EMISSIONS (TONS/YEAR) AT THROUGHPUTS REQUESTED ABOVE ACTUAL EMISSIONS (from data year) ESTIMATION METHOD CHECK ALL BOXES THAT APPLY ❑ New or previously unreported source* ❑ Requesting modification of existing permit t$ ❑ Change in emissions, throughputs or equipment: ■ Transfer of ownership (List previous owner in REMARKS section of box A.): ■ Previous APEN is expiring: O Request for Emission Reduction Credit t: O (Specify) Pollutant Type of Control Equipment Collection Efficiency Primary Secondary CONTROLLED UNCONTROLLED Particulate PMio SO, NO, Lean Burn 8.1 VOC Lean Burn 2.4 CO Lean Burn 4.7 PLEASE USE APCD NON -CRITERIA REPORTABLE AIR POLLUTANT ADDENDUM FORM TO REPORT SUCH POLLUTANTS OR POLLUTANTS NOT LISTED ABOVE. O CHECK HERE IF YOU WISH THE DIVISION TO CALCULATE YOUR EMISSIONS. SEE "EMISSION ESTIMATES" INSTRUCTIONS ON BACK. * Complete all applicable portions of APEN t Complete ' Requested Level' values for permit limits : Complete all information above box A, and those remaining portions which reflect changes Signature of Person Legally Authorized to Supp Data /�E�-f�� DATE' �� L YEAR FOR WHICH THE ACTUAL DATA APPLIES: 2001 Typed Name and Title: Jeff Reale : enior - rations Superintendent Date source began or will begin operation: 1993 THIS NOTICE IS VALID FOR FI' YEARS. A.x 4s notice shall be filed prior to this expiration date, whenever a permit canon must be modified, whenever control equipment is changed, and annually whenever a significant emission change occurs. For specific details see Regulation 3, Part A, § II.C.1. A $119.96 FILING FEE IS REQUIRED FOR EACH NOTICE FILED. Send completed forms with fees to: Colorado Dept. of Public Health & Environment Air Pollution Control Division 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 APEN For Information, Call (303) 692-3150 NON -CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM* (Instructions on reverse side) Permit Number 99OPWE207 Company Name: EnCana AIRS Number 123/0319/001 Plant Location: Fort Lupton Plant Person to Contact: Jeff Reale, Senior Operations Superintendent E -Mail Address: Jeff.Reale@EnCana.com County Weld Zip Code 80621 Phone (303) 659-7740 Fax (303) 857-1259 Chemical Abstract Service Number Chemical Name Reporting Bin Control Equipment/ Efficiency Emission Factor (include units) Emission Factor Source Requested Emissions (Ibs/yr) Actual Emissions from the Data Year (Ibs/yr) 75070 Acetaldehyde A Lean Burn HAPCalc v. 2.01 100 50000 Formaldehyde A Lean Burn HAPCalc v. 2.01 1780 * Use this form for reporting Hazardous Air Pollutants, Ozone Depleting Compounds. and other Non -Criteria Reportable Pollutants Year For Which The Actual Data Applies: Signature of a Responsible Jeff Re le ( fficial not a en or consultant Date Senior Operations Superintendent Name of a Responsible Of 'al (please print) Title 2001 AIR POLLUTANT EMISSION NOTICE FIRM NAME EnCana MAIL ADDRESS 1313 Denver Avenue, Building #1 Fort Lupton PLANT NAME & LOCATION Fort Lupton Plant: 16157 Weld County Road 22, Ft. Lupton, CO 80621 REQUEST PORTABLE SOURCE PERMIT HOME -BASE FOR PORTABLE SOURCE PERSON TO CONTACT REGARDING THIS INFORMATION Jeff Reale GENERAL DESCRIPTION OF THIS PLANT'S FUNCTION Natural gas processing plant A. GENERAL INFORMATION Normal Operation of This Source Process Seasonal Throughput (% of Annual) ADDITIONAL INFORMATION OR REMARKS: Formerly North American Resources Company Hours/Day 24 Days/Week 7 Weeks/Year 52 Dec -Feb 25 Mar -May 25 Jun -Aug 25 Sep -Nov 25 B. STACK OR VENT INFORMATION (Identify below which stack if plant has two or more; refer to attached sketch of plant layout) Height 25.25 ft Diameter 1.44 ft Temperature 465 °F Flow Rate 4280 ACFM Velocity 2628 ft/min Moisture 8 % Plant ID No. for Stack S002, C -101B C. FUEL INFORMATION Description of Combustion Unit Design Input Rate (106 BTU/hr) Kind of Fuel Burned Annual Fuel Consumption Fuel Heating Value: (BTU/lb, BTU/gal, or BTU/scf) Percent b Weight Seasonal Fuel Use % of Annual Use) Space Htg Requested level Actual level (Data year level) Sulfur Ash Dec -Feb Mar -May Jun -Aug Sep -Nov (% Ann.) 514 hp (site rated) Compressor Engine Natural Gas 0 0 25 25 25 25 Make/Model: Ajax DPC-540 LE RECEIVED Serial No. 83892 D. PROCESS INFORMATION Raw Materials Used Raw Materials -Annual Co .il :,mrr tr' Process Rate 9N(¢ t tlyaits/Hour) Finished Product Description Finished Product-Annua Output Description of Processing Unit Description Requested level Actual level (DO#AKIIIMI Requested level Actual level (Data year level) Make/Model: ..TATIONARY SO RCES PROCi 1 Serial No.: E. POLLUTION CONTROL EQUIPMENT Overall ESTIMATED EMISSIONS (TONS/YEAR) AT THROUGHPUTS REQUESTED ABOVE ACTUAL EMISSIONS (from data year) ESTIMATION METHOD CHECK ALL BOXES THAT ❑ New or previously unreported source* APPLY Pollutant Type of Control Equipment Collection Efficiency Primary Secondary CONTROLLED UNCONTROLLED O Requesting modification of existing permit t$ Particulate O Change in emissions, throughputs or equipment PMio ■ Transfer of ownership S0:1 previous owner in REMARKS section of box A.) ; NO, Lean Burn 8.0 • Previous APEN is expiring $ VOC Lean Burn 2.3 O Request for Emission Reduction Credit t$ Co Lean Burn 4.7 O (Specify) PLEASE USE APCD NON -CRITERIA REPORTABLE AIR POLLUTANT ADDENDUM FORM TO REPORT SUCH POLLUTANTS OR POLLUTANTS NOT LISTED ABOVE. O CHECK HERE IF YOU WISH THE DIVISION TO CALCULATE YOUR EMISSIONS. SEE "EMISSION ESTIMATES" INSTRUCTIONS ON BACK. * Complete all applicable portions of APEN t Complete ' Requested Level' values for permit limits $ Complete all information above box A, and those remaining portions which reflect changes Signature of Person Legally Authorized up Da DATE/ 6,7/2(61 YEAR FOR WHICH THE ACTUAL DATA APPLIES: 2001 �lt— Typed Name and Title: Je Reale, Senior ations Superintendent Date source began or will begin operation: 1993 THIS NOTICE IS VALID FOR YEARS. A rev' d notice shall be filed prior to this expiration date, whenever a permit fins' a modified, whenever control equipment is changed, and annually whenever a significant emission change occurs. For specific details see Regulation 3, Part A, § II.C.1. A $119.96 FILING FEE IS REQUIRED FOR EACH NOTICE FILED. Send completed forms with fees to: Colorado Dept. of Public Health & Environment APEN # 2 of 17 Air Pollution Control Division 4300 Cherry Creek Drive South, APCD-SS-B1 For Information, Call Denver, Colorado 80246-1530 (303) 692-3150 PERMIT No.: 99OPWE207 AIRS ID.: 123 / 0319 / 002 3 STATE: _CO ZIP: 80621 COUNTY: Weld TITLE Senior Operations Superintendent PHONE (303) 659-7740 -MAIL ADDRESS: NON -CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM* (Instructions on reverse side) Permit Number 99OPWE207 Company Name: EnCana AIRS Number 123/0319/002 Plant Location: Fort Lupton Plant Person to Contact: Jeff Reale, Senior Operations Superintendent E -Mail Address: Jeff.Reale@EnCana.com County Weld Zip Code 80621 Phone (303) 659-7740 Fax (303) 857-1259 Chemical Abstract Service Number Chemical Name Reporting Bin Control Equipment/ Efficiency Emission Factor (include units) Emission Factor Source Requested Emissions (Ibs/yr) Actual Emissions from the Data Year (lbs/yr) 75070 Acetaldehyde A Lean Burn HAPCalc v. 2.01 100 50000 Formaldehyde A Lean Burn HAPCalc v. 2.01 1780 : Use this form for reporting Hazardous Air Pollutants, Ozone Depleting Compounds. and other Non -Criteria Reportable Pollutants Year For Which The Actual Data Applies: Signature of a Re6nsible Official Jeff Reale aw4dor or consultant) 4at:(4e2 Senior Operations Superintendent Name of a Respon Official (please Title 2001 AIR POLLUTANT EMISSION NOTICE FIRM NAME EnCana MAIL ADDRESS 1313 Denver Avenue, Building #1 Fort Lupton PLANT NAME & LOCATION Fort Lupton Plant: 16157 Weld County Road 22, Fort Lupton, CO 80621 REQUEST PORTABLE SOURCE PERMIT HOME -BASE FOR PORTABLE SOURCE PERMIT No.: 99OPWE207 AIRS ID.: 123 / 0319 / 003 i raJ,?4 Y PERSON TO CONTACT REGARDING THIS INFORMATION Jeff Reale TITLE Senior Operations Superintendent PHONE (303) 659-7740 GENERAL DESCRIPTION OF THIS PLANT'S FUNCTION Natural gas processing plant A. GENERAL INFORMATION Normal Operation of This Source Process Seasonal Throughput (% of Annual) ADDITIONAL INFORMATION OR REMARKS: Formerly North American Resources Company Hours/Day 24 Days/Week 7 Weeks/Year 52 Dec -Feb 25 Mar -May 25 Jun -Aug 25 Sep -Nov 25 B. STACK OR VENT INFORMATION (Identify below which stack if plant has two or more; refer to attached sketch of plant layout) Height 25.25 ft Diameter 1.44 ft Temperature 465 °F Flow Rate 4280 ACFM Velocity 2628 ft/min Moisture 8 % Plant ID No. for Stack S003, C -101C C. FUEL INFORMATION Description of Combustion Unit Design Input Rate (106 BTU/hr) Kind of Fuel Burned Annual Fuel Consumption Fuel Heating Value: Percent by Weight Seasonal Fuel Use (% of Annual Use) Space Htg Requested level Actual level (Data year level) (BTU/lb, BTU/gal, or BTU/scf) Sulfur Ash Dec -Feb Mar -May Jun -Aug Sep -Nov (% Ann.) 514 hp (site rated) Compressor Engine Natural Gas 0 0 25 25 25 25 Make/Model: Ajax DPC-540 LE NECEIVED Serial No. 83889 11.{.l Oa D. PROCESS INFORMATION Description of Processing Unit Raw Materials Used Raw Materials -Annual Consumpption Design Process Rate Finished Product Finished Product -Annual Output Description Requested level ActtlfAlF�eAEDLLL1Tl (13fty Amy N GOI�YR , Description Requested level Actual level (Data year level) Make/Model: Serial No.: E. POLLUTION CONTROL EQUIPMENT Overall ESTIMATED EMISSIONS (TONS/YEAR) AT THROUGHPUTS REQUESTED ABOVE ACTUAL EMISSIONS (from data year) ESTIMATION METHOD CHECK ALL BOXES THAT APPLY 0 New or previously unreported source* 0 Requesting modification of existing permit t$ 0 Change in emissions, throughputs or equipment $ • Transfer of ownership (List previous owner in REMARKS section of box A.) $ ■ Previous APEN is expiring $ ❑ Request for Emission Reduction Credit t; ❑ (Specify) Pollutant Type of Control Equipment Collection Efficiency Primary Secondary CONTROLLED UNCONTROLLED Particulate PKo SO, NO, Lean Burn 8.1 VOC Lean Burn 2.4 CO Lean Burn 4.8 PLEASE USE APCD NON -CRITERIA REPORTABLE AIR POLLUTANT ADDENDUM FORM TO REPORT SUCH POLLUTANTS ORt POLLUTANTS NOT LISTED ABOVE. 0 CHECK HERE IF YOU WISH THE DIVISION TO CALCULATE YOUR EMISSIONS. SEE "EMISSION ESTIMATES" INSTRUCTIONS ON BACK. * Complete all applicable portions of APEN Complete ' Requested Level' values for permit limits $ Complete all information above box A, and those remaining portions which reflect changes Signature of Person Legally Authorized to S Data: �� DATE ��24 z_ YEAR FOR WHICH THE ACTUAL DATA APPLIES: 2001 Typed Name and Title: Jef eale, Senior e ations Superintendent Date source began or will begin operation: 1993 THIS NOTICE IS VALID FOR FI revised otice shall be filed prior to this expiration date, whenever a permit limitation must e modified, whenever control equipment is changed, and annually whenever a significant emission change occurs. For specific details see Regulation 3, Part A, § II.C.1. A $119.96 FILING FEE IS REQUIRED FOR EACH NOTICE FILED. Send completed forms with fees to: Colorado Dept. of Public Health & Environment APEN N 3 of 17 Air Pollution Control Division 4300 Cherry Creek Drive South, APCD-SS-B1 For Information, Call Denver. Colorado 80246-1530 (303) 692-3150 - STATE: _CO ZIP: 80621 COUNTY: Weld E-MAIL ADDRESS: Jeff.RealetWEnCana.com NON -CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM* (Instructions on reverse side) Permit Number 99OPWE207 Company Name: EnCana Plant Location: Person to Contact: E -Mail Address: AIRS Number 123/0319/003 Fort Lupton Plant Jeff Reale, Senior Operations Superintendent Jeff.Reale@EnCana.com County Weld Zip Code 80621 Phone (303) 659-7740 Fax (303) 857-1259 Chemical Abstract Service Number Chemical Name Reporting Bin Control Equipment/ Efficiency Emission Factor (include units) Emission Factor Source Requested Emissions (Ibs/yr) Actual Emissions from the Data Year (Ibs/yr) 75070 Acetaldehyde A Lean Burn HAPCalc v. 2.01 100 50000 Formaldehyde A Lean Burn HAPCalc v. 2.01 1780 * Use this form for reporting Hazardous Air Pollutants. Ozone Depleting Compounds, and other Non -Criteria Reportable Pollutants Year For Which The Actual Data Applies: r:�rt Signature of a Responsible Offici not a yen or su ltant) Jeff Real 6j, ,/e L Date Senior Operations Superintendent Name of a Responsible Offict io Title 2001 AIk 'POLLUTANT EMISSION NOTICE, , ,., r PERMIT No.: FIRM NAME EnCana MAIL ADDRESS 1313 Denver Avenue, Building #1 Fort Lupton PLANT NAME & LOCATION Fort Lupton Plant: 16157 Weld County Road 22, Fort Lupton, CO 80621 REQUEST PORTABLE SOURCE PERMIT HOME -BASE FOR PORTABLE SOURCE PERSON TO CONTACT REGARDING THIS INFORMATION Jeff Reale GENERAL DESCRIPTION OF THIS PLANT'S FUNCTION Natural gas processing plant 99OPWE207 AIRS ID.: 123 / 0319 / 004 A. GENERAL INFORMATION Normal Operation of This Source Hours/Day 24 Days/Week 7 Weeks/Year 52 fly STATE: CO ZIP: 80621 COUNTY: Weld TITLE Senior Operations Superintendent PHONE (303) 659-7740 E-MAIL ADDRESS: Jeff.Reale@EnCana.com Process Seasonal Through u o Th h t (% of Annual) Dec -Feb 25 Mar -May Jun -Aug 25 25 Sep -Nov 25 ADDITIONAL INFORMATION OR REMARKS: Formerly North American Resources Company B. STACK OR VENT INFORMATION (Identify below which stack if plant has two or more; refer to attached sketch of plant layout) Height 25.25 ft Diameter 1.44 ft Temperature 465 °F Flow Rate 4280 ACFM Velocity 2628 ft/min Moisture 8 % Plant ID No. for Stack S004, C -101D C. FUEL INFORMATION Description of Combustion Unit Design Input Rate (106 BTU/hr) Kind of Fuel Burned Annual Fuel Consumption Requested level Actual level (Data year level) Fuel Heating Value: (BTU/lb, BTU/gal, or BTU/scf) Percent by Weight Sulfur Ash Seasonal Fuel Use (% of Annual Use) Dec -Feb Mar -May Jun -Aug Sep -Nov Space Htg (% Ann.) 514 hp (site rated) Compressor Engine Natural Gas 0 0 25 25 25 25 Make/Model: Ajax DPC-540 LE Serial No. 83890 REC EIVED D. PROCESS INFORMATION Description of Processing Unit Make/Model: Raw Materials Used Description Raw Materials -Annual ConsumptiofiU Requested level Actual level (Data year STATIONAR L D�Si3t FIZZO2 Rate �' c.�E iVc ff`li r) Y SOURCES PROGRtit, Finished Product Description Finished Product -Annual Output Requested level Actual level (Data year level) Serial No.: E. POLLUTION CONTROL EQUIPMENT Overall ESTIMATED EMISSIONS (TONS/YEAR) AT THROUGHPUTS REQUESTED ABOVE ACTUAL EMISSIONS (from data year) ESTIMATION METHOD CHECK ALL BOXES THAT APPLY O New or previously unreported source* O Requesting modification of existing permit tt. O Change in emissions, throughputs or equipment T. ■ Transfer of ownership (List previous owner in REMARKS section of box A.) $ is Previous APEN is expiring $ O Request for Emission Reduction Credit t+ O (Specify) Pollutant Type of Control Equipment Collection Efficiency Primary Secondary CONTROLLED UNCONTROLLED Particulate PMto SO, NO, Lean Burn 8.0 VOC Lean Burn 2.3 CO Lean Burn 4.7 PLEASE USE APCD NON -CRITERIA REPORTABLE AIR POLLUTANT ADDENDUM FORM TO REPORT SUCH POLLUTANTS OR POLLUTANTS NOT LISTED ABOVE. O CHECK HERE IF YOU WISH THE DIVISION TO CALCULATE YOUR EMISSIONS. SEE "EMISSION ESTIMATES" INSTRUCTIONS ON BACK. * Complete all applicable portions of APEN t Complete ' Requested Level' values for permit limits $ Complete all information above box A, and those remaining portions which reflect changes Signature of Person Legally Authorized to Supply Data: / / DATE:,,.YEAR /�� ),D Z FOR WHICH THE ACTUAL DATA APPLIES: 2001 Typed Name and Tide: Jeff Reale, Se ' Operatio uperintendent Date source began or will begin operation: 1993 THIS NOTICE IS VALID FOR FIVE YEARS A.rgvised noticaall be filed prior to this expiration date, whenever a permit limitation must be modTed, whenever control equipment is changed, and annually whenever a significant emission change occurs. For specific details see Regulation 3, Part A, § II.C.1. A $119.96 FILING FEE IS REQUIRED FOR EACH NOTICE FILED. Send completed forms with fees to: Colorado Dept. of Public Health & Environment Air Pollution Control Division 4300 Cherry Creek Drive South, APCD-SS-81 Denver. Colorado 80246-1530 APEN For Information, Call (303) 692-3150 NON -CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM* (Instructions on reverse side) Permit Number 99OPWE207 Company Name: EnCana AIRS Number 123/0319/004 Plant Location: Fort Lupton Plant Person to Contact: Jeff Reale, Senior Operations Superintendent E -Mail Address: Jeff.Reale@EnCana.com County Weld Zip Code 80621 Phone (303)659-7740 Fax (303)857-1259 Chemical Abstract Service Number Chemical Name Reporting Bin Control Equipment/ Efficiency Emission Factor (include units) Emission Factor Source Requested Emissions (Ibs/yr) Actual Emissions from the Data Year (lbs/yr) 75070 Acetaldehyde A Lean Burn HAPCalc v. 2.01 100 50000 Formaldehyde A Lean Burn HAPCalc v. 2.01 1780 * Use this form for reporting Hazardous Air Pollutants. Ozone Depleting Compounds, and other Non -Criteria Reportable Pollutants Signature of a Responsible Officia of a ven..riffconsultant) Jeff Reale Name of a Responsible Official (ple Year For Which The Actual Data Applies: Date Senior Operations Superintendent Title 2001 AIR POLLUTANT EMISSION NOTICE, �, It 6 FIRM NAME EnCana PERMIT No.: 99OPWE207 AIRS ID.: 123 / 0319 / 007 MAIL ADDRESS 1313 Denver Avenue, Building #1 Fort Lupton PLANT NAME & LOCATION Fort Lupton Plant: 16157 Weld County Road 22, Fort Lupton, CO 80621 REQUEST PORTABLE SOURCE PERMIT HOME -BASE FOR PORTABLE SOURCE PERSON TO CONTACT REGARDING THIS INFORMATION Jeff Reale GENERAL DESCRIPTION OF THIS PLANT'S FUNCTION Natural gas processing plant LLS STATE: CO ZIP: 80621 COUNTY: Weld A. GENERAL INFORMATION Normal Operation of This Source Hours/Day 24 Days/Week 7 Weeks/Year 52 TITLE Senior Operations Superintendent PHONE (303) 659-7740_ E-MAIL ADDRESS: Jeff.Reale@EnCana.com Process Seasonal Through u o t (% of Annual) Dec -Feb 25 Mar -May Jun -Aug 25 25 Sep -Nov 25 ADDITIONAL INFORMATION OR REMARKS: Formerly North American Resources Company B. STACK OR VENT INFORMATION (Identify below which stack if plant has two or more: refer to attached sketch of plant layout) Height ft Diameter ft Temperature °F Flow Rate ACFM Velocity ft/min Moisture Plant ID No. for Stack S007 C. FUEL INFORMATION Description of Combustion Unit Make/Model: Serial No. D. PROCESS INFORMATION Design Input Rate (lob BTU/hr) Kind of Fuel Burned Annual Fuel Consumption Fuel Heating Value: (BTU/lb, BTU/gal, or BTU/scf) Percent by Weight Seasonal Fuel Use(% Mar -May of Annual Jun -Aug Use) Sep -Nov Space Htg (% Ann.) Requested level Actual level (Data year level) Sulfur Ash Dec -Feb �. RECEIVED Description of Processing Unit Fugitive VOC emissions Make/Model: Raw Materials Used Raw Materials -Annual Consume {11 g'2f117 ss Rate Actual level (Data yxklevel)t • _(Specify Units/Hour) S tATION��At(RRRY tt00 Description Requested level Serial No.: tv t,ON rHOI SOURCES PROGRHm Finished Product Description Finished Product -Annual Output Requested level Actual level (Data year level) E. POLLUTION CONTROL EQUIPMENT Pollutant Type of Control Equipment Primary Secondary Overall Collection Efficiency ESTIMATED EMISSIONS (TONS/YEAR) AT THROUGHPUTS REQUESTED ABOVE CONTROLLED UNCONTROLLED ACTUAL EMISSIONS (from data year) ESTIMATION METHOD Particulate PMio SO, NO, VOC 17.9 EPA Publication CO PLEASE USE APCD NON -CRITERIA REPORTABLE AIR POLLUTANT ADDENDUM FORM TO REPORT SUCH POLLUTANTS OR POLLUTANTS NOT LISTED ABOVE. Signature of Person Legally Authorized to Supply Data: Typed Name and Title: Jeff Reale, Senior O ❑ CHECK HERE IF YOU WISH THE DIVISION TO CALCULATE YOUR EMISSIONS. SEE "EMISSION ESTIMATES" INSTRUCTIONS ON BACK. DATE: 4/,z CHECK ALL BOXES THAT APPLY ❑ New or previously unreported source* ❑ Requesting modification of existing permit t: ❑ Change in emissions, throughputs or equipment: IN Transfer of ownership (List previous owner in REMARKS section of box A.): ❑ Previous APEN is expiring: ❑ Request for Emission Reduction Credit t: O (Specify) * Complete all applicable portions of APEN t Complete ' Requested Level' values for permit limits : Complete all information above box A, and those remaining portions which reflect changes YEAR FOR WHICH THE ACTUAL DATA APPLIES: 2001 Date source began or will begin operation: 1998 THIS NOTICE IS VALID FOR FIVE YEARS. A revised n. r . . prior to this expiration date, whenever a permit limitation must be modified, whenever control equipment is changed, and annually whenever a significant emission change occurs. For specific details see Regulation 3, Part A, § II.C.1. A $119.96 FILING FEE IS REQUIRED FOR EACH NOTICE FILED. Send completed forms with fees to: Colorado Dept. of Public Health & Environment Air Pollution Control Division 4300 Cherry Creek Drive South, APCD-SS-BI Denver, Colorado 80246-1530 APEN N 5of_17 For Information, Call (303) 692-3150 NON -CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM* Permit Number 99OPWE207 Company Name: EnCana AIRS Number 123/0319/007 Plant Location: Fort Lupton Plant Person to Contact: Jeff Reale, Senior Operations Superintendent E -Mail Address: Jeff.Reale@EnCana.com County Weld Zip Code 80621 Phone (303) 659-7740 Fax (303) 857-1259 Chemical Abstract Service Number Chemical Name Reporting Bin Control Equipment/ Efficiency Emission Factor (include units) Emission Factor Source Requested Emissions (Ibs/yr) Actual Emissions from the Data Year (Ibs/yr) 71432 Benzene A HAPCalc v. 2.01 1160 * Use this form for reporting Hazardous Air Pollutants, Ozone Depleting Compounds. and other Non -Criteria Reportable Pollutants Year For Which The Actual Data Applies: ttant Signature of a Responsible . ficial (not a yen' or ) Jeff Reale C/ 7/4". Date Senior Operations Superintendent 2001 Name of a Responsible O • • - . e .rin Title AIR POLLUTANT EMISSION NOTICE FIRM NAME EnCana PERMIT No.: 99 WE207 AIRS ID.: 123 / 0319 / 008 l'- -'5 ' MAIL ADDRESS 1313 Denver Avenue, Building #1 Fort Lupton PLANT NAME & LOCATION Fort Lupton Plant: 16157 Weld County Road 22, Fort Lupton, CO 80621 REQUEST PORTABLE SOURCE PERMIT HOME -BASE FOR PORTABLE SOURCE PERSON TO CONTACT REGARDING THIS INFORMATION Jeff Reale GENERAL DESCRIPTION OF THIS PLANT'S FUNCTION Natural gas processing plant A. GENERAL INFORMATION Normal Operation of This Source Hours/Day 24 Days/Week 7 Weeks/Year 52 STATE: CO ZIP: 80621 COUNTY: Weld TITLE Senior Operations Superintendent PHONE(303) 659-7740 _ E-MAIL ADDRESS: Jeff.Reale@EnCana.com Process Seasonal Through t (R f Annual) Dec -Feb 25 roug u o 0 Mar -May Jun -Aug 25 25 Sep -Nov 25 ADDITIONAL INFORMATION OR REMARKS: Formerly North American Resources Company B. STACK OR VENT INFORMATION Identify below which stack if plant has two or more; refer to attached sketch of plant layout) Height ft Diameter ft Temperature °F Flow Rate ACFM Velocity ft/min Moisture % Plant ID No. for Stack S008, Flare C. FUEL INFORMATION Description of Combustion Unit Design Input Rate (10° BTU/hr) Kind of Fuel Burned Annual Fuel Consumption Requested level Actual level (Data year level) Fuel Heating Value: (BTU/lb, BTU/gal, or BTU/scf) Percent by Weight Sulfur Ash Seasonal Fuel Use (% of Annual Use) Dec -Feb Mar -May Jun -Aug Sep -Nov Space Htg (% Ann.) Flare Industries 16" Flare 6.11 Natural Gas 0 0 25 25 25 25 Make/Model: 250 Serial No. 97-671 RECEI VED D. PROCESS INFORMATION Description of Processing Unit Make/Model: Raw Materials Used Description Raw Materials -Annual Coakhfttpticiri Requested level Actual level (D��Y STATIONARY 8 414 Process Rate 'f' rtits/Hour) ROES PROGRo, Finished Product Description Finished Product -Annual Output Requested level Actual level (Data year level) Serial No.: E. POLLUTION CONTROL EQUIPMENT Pollutant Type of Control Equipment Primary Secondary Overall Collection Efficiency ESTIMATED EMISSIONS (TONS/YEAR) AT THROUGHPUTS REQUESTED ABOVE CONTROLLED UNCONTROLLED ACTUAL EMISSIONS (from data year) ESTIMATION METHOD Particulate PM10 SO, NO, VOC TBD CO PLEASE USE APCD NON -CRITERIA REPORTABLE AIR POLLUTANT ADDENDUM FORM TO REPORT SUCH POLLUTANTS OR POLLUTANTS NOT LISTED ABOVE. TBD ❑ CHECK HERE IF YOU WISH THE DIVISION TO CALCULATE YOUR EMISSIONS. SEE "EMISSION ESTIMATES" INSTRUCTIONS ON BACK. CHECK ALL BOXES THAT APPLY ❑ New or previously unreported source* ❑ Requesting modification of existing permit t$ ❑ Change in emissions, throughputs or equipment : • Transfer of ownership (List previous owner in REMARKS section of box A.): ❑ Previous APEN is expiring ❑ Request for Emission Reduction Credit t: ❑ (Specify) * Complete all applicable portions of APEN t Complete ' Requested Level' values for permit limits Complete all information above box A. and those remaining + Signature of Person Legally Authorized to Su y ata: <<�C DATE: G/,,V,r� YEAR FOR WHICH THE ACTUAL DATA APPLIES: 2001 `. Typed Name and Title: J Reale, Senior a ons Superintendent Date source began or will begin operation: 1998 THIS NOTICE IS VALID FOR TVE-ku:0=,$5 A revised nail shall be filed prior to this expiration date, whenever a permit limitation mus be maduied, whenever control equipment is changed, and annually whenever a significant emission change occurs. For specific details see Regulation 3, Part A, § II.C.1. A $119.96 FILING FEE IS REQUIRED FOR EACH NOTICE FILED. Send completed forms with fees to: Colorado Dept. of Public Health & Environment Air Pollution Control Division 4300 Cherry Creek Drive South, APCD-SS-BI Denver, Colorado 80246-1530 APEN A'_6 of 17 For Information, Call (303) 692-3150 AIR POLLUTANT EMISSION NOTICE . , :.; a PERMIT No.:_99OPWE207_ AIRS ID.:_123_/_0319/009 J FIRM NAME EnCana _ MAIL ADDRESS 1313 Denver Avenue, Building #1 Fort Lupton PLANT NAME & LOCATION Fort Lupton Plant: 16157 Weld County Road 22, Fort Lupton, CO 80621 REQUEST PORTABLE SOURCE PERMIT HOME -BASE FOR PORTABLE SOURCE PERSON TO CONTACT REGARDING THIS INFORMATION Jeff Reale TITLE Senior Operations Superintendent PHONE_(303) 659-7740 GENERAL DESCRIPTION OF THIS PLANT'S FUNCTION Natural gas processing plant A. GENERAL INFORMATION Normal Operation of This Source Process Seasonal Through ut (% of Annual) ADDITIONAL INFORMATION OR REMARKS: Formerly North American Resources Company Hours/Day 24 Days/Week 7 Weeks/Year 52 Dec -Feb 25 Mar -May I 25 Jun -Aug 25 Sep -Nov 25 B. STACK OR VENT INFORMATION (Identify below which stack if plant has two or more; refer to attached sketch of plant layout) Height ft Diameter ft Temperature °F Flow Rate ACFM Velocity ft/min Moisture % Plant ID No. for Stack S009, Amine Treating Unit C. FUEL INFORMATION Description of Combustion Unit Design Input Rate (106 BTU/hr) Kind of Fuel Burned Annual Fuel Consumption Fuel Heating Value: Percent b Weight Seasonal Fuel Use (% of Annual Use) Space Htg (% Ann.) Sulfur Ash Dec -Feb Mar -May Jun -Aug Sep -Nov Requested level Actual level (Data year level) (BTU/lb, BTU/gal, or BTU/scf) Make/Model: RECE VED Serial No. .. D. PROCESS INFORMATION Description of Processing Unit Amine Treating Unit Raw Materials Used Raw Materials-Annua Consumption Design Process Rate R�3�Idits/Hour) Finished Product Finished Product-Annua Output Description Requested level Actual level (Data year level) Description Requested level { Pt', Make/Model: • IP'R0U RA nr Serial No.: E. POLLUTION CONTROL EQUIPMENT Overall ESTIMATED EMISSIONS (TONS/YEAR) AT THROUGHPUTS REQUESTED ABOVE ACTUAL EMISSIONS (from data year) ESTIMATION METHOD CHECK ❑ New or previously unreported 0 Requesting modification ❑ Change in emissions. • Transfer of ownership (List previous owner ❑ Previous APEN is expiring: ❑ Request for Emission ❑ (Specify) ALL BOXES THAT source* of existing permit throughputs or equipment: in REMARKS section Reduction Credit t: APPLY t: of box A.): Pollutant Type of Control Equipment Collection Efficiency Primary Secondary CONTROLLED UNCONTROLLED H2S 1.45 Engineer's Calcs. PM10 SO, NO, VOC CO PLEASE USE APCD NON -CRITERIA REPORTABLE AIR POLLUTANT ADDENDUM FORM TO REPORT SUCH POLLUTANTS OR POLLUTANTS NOT LISTED ABOVE. 0 CHECK HERE IF YOU WISH THE DIVISION TO CALCULATE YOUR EMISSIONS. SEE "EMISSION ESTIMATES" INSTRUCTIONS ON BACK. * Complete all applicable portions of APEN t Complete ' Requested Level' values for permit limits : Complete all information above box A, and those remaining portions which reflect changes Signature of Person Legally Authorized to y Data: �sr t DATE: G// 7/c, e YEAR FOR WHICH THE ACTUAL DATA APPLIES: 2001 Typed Name and Title: Jeff R ale, Senior Opera ons SuPIerintendent Date source began or will begin operation: 1998 THIS NOTICE IS VALID FOR FIVE YEARS. ' ed notices be filed prior to this expiration date, whenever a permit limitation must be m enever control equipment is changed, and annually whenever a significant emission change occurs. For specific details see Regulation 3, Part A, § II.C.1. A $119.96 FILING FEE IS REQUIRED FOR EACH NOTICE FILED. Send completed forms with fees to: Colorado Dept. of Public Health & Environment APEN k 7 of_17_ Air Pollution Control Division — — 4300 Cherry Creek Drive South, APCD-SS-BI For Information, Call Denver, Colorado 80246-1530 (303) 692-3150 LS, STATE: CO ZIP: 80621 COUNTY: Weld E-MAIL ADDRESS: Jeff.Reale@EnCana.com AIR POLLUTANT EMISSION NOTICE PERMIT No.: FIRM NAME MAIL ADDRESS 1313 Denver Avenue, Building #1 Fort Lupton PLANT NAME & LOCATION Fort Lupton Plant: 16157 Weld County Road 22, Fort Lupton, CO 80621 REQUEST PORTABLE SOURCE PERMIT HOME -BASE FOR PORTABLE SOURCE PERSON TO CONTACT REGARDING THIS INFORMATION Jeff Reale GENERAL DESCRIPTION OF THIS PLANT'S FUNCTION Natural gas processing plant A. GENERAL INFORMATION Normal Operation of This Source Process Seasonal Through ut (% of Annual) ADDITIONAL INFORMATION OR REMARKS: Formerly North American Resources Company Hours/Day 24 Days/Week 7 Weeks/Year 52 Dec -Feb 25 Mar -May 25 Jun -Aug 25 Sep -Nov 25 B. STACK OR VENT INFORMATION (Identify below which stack if plant has two or more: refer to attached sketch of plant layout) Height 3.5 ft Diameter 0.5 ft Temperature 845 °F Flow Rate <457 ACFM Velocity ft/min Moisture 6.7 % Plant ID No. for Stack SO10, Smart Ash Unit C. FUEL INFORMATION Description of Combustion Unit Design Input Rate (106 BTU/hr) Kind of Fuel Burned Annual Fuel Consumption Fuel Heating Value: Percent by Weight Seasonal Fuel Use (% of Annual Use) Space Htg (% Ann.) Requested level Actual level (Data year level) (BTU/lb, BTU/gal, or BTU/scf) Sulfur Ash Dec -Feb Mar -May Jun -Aug Sep -Nov Make/Model: Serial No. ePC'�/ R ECEI F D D. PROCESS INFORMATION Description of Processing Unit Raw Materials Used V Raw Materials -Annual Consumption Design Process Rate Finished Product Finished Product -Annual Output Description Requested level �yt�t�Ilw��yyee (De t arYEv ) V .O ,ecify Units/Hour) Description Requested level Actual level (Data year level) Smart Ash Unit 6 R POLLUTION CONTRI): Make/Model: Elastec Model SA100 Oily Solid Waste 'AT IONARV SOURCES PROGRr.i " Serial No.: SA 18894 E. POLLUTION CONTROL EQUIPMENT Overall ESTIMATED EMISSIONS (TONS/YEAR) AT THROUGHPUTS REQUESTED ABOVE ACTUAL EMISSIONS (from data year) ESTIMATION METHOD CHECK ALL BOXES THAT APPLY ❑ New or previously unreported source* O Requesting modification of existing permit t; O Change in emissions, throughputs or equipment ■ Transfer of ownership (List previous owner in REMARKS section of box A.) $ O Previous APEN is expiring $ O Request for Emission Reduction Credit t; O (Specify) Pollutant Type of Control Equipment Collection Efficiency Primary Secondary CONTROLLED UNCONTROLLED Particulate 1.58 SCC.503001 PMio SO, NO, VOC 1.58 SCC.503001 CO 2.10 SCC.503001 PLEASE USE APCD NON -CRITERIA REPORTABLE AIR POLLUTANT ADDENDUM FORM TO REPORT SUCH POLLUTANTS OR POLLUTANTS NOT LISTED ABOVE. O CHECK HERE IF YOU WISH THE DIVISION TO CALCULATE YOUR EMISSIONS. SEE "EMISSION ESTIMATES" INSTRUCTIONS ON BACK. * Complete all applicable portions of APEN t Complete ' Requested Level' values for permit limits $ Complete all information above box A, and those remaining portions which reflect changes Signature of Person Legally Authorized to Supply Data: �,/� �f�,•�C DAT r,/ ye z YEAR FOR WHICH THE ACTUAL DATA APPLIES: 2001 Typed Name and Title: Jeff Real , Senior Operati s Superintendent / Date source began or will begin operation: 1995 THIS NOTICE IS VALID FOR FIVE YEA revised not' e shall be filed prior to this expiration date, whenever a permit limitation m ' ed, whenever control equipment is changed, and annually whenever a significant emission change occurs. For specific details see Regulation 3, Part A, § II.C.1. A $119.96 FILING FEE IS REQUIRED FOR EACH NOTICE FILED. Send completed forms with fees to: Colorado Dept. of Public Health & Environment APEN /t 8 of 17 Air Pollution Control Division — — — 4300 Cherry Creek Drive South, APCD-SS-B1 For Information, Call Denver, Colorado 80246-1530 (303) 692-3150 a c,, EnCana 99OPWE207 AIRS ID.: 123 / 0319 / 010 STATE: _CO ZIP: 80621 COUNTY: Weld TITLE Senior Operations Superintendent PHONE (303) 659-7740 E-MAIL ADDRESS: Jeff.Reale�EnCana .com NON -CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM* Permit Number 99OPWE207 Company Name: EnCana AIRS Number 123/0319/010 Plant Location: Fort Lupton Plant Person to Contact: Jeff Reale, Senior Operations Superintendent E -Mail Address: Jeff.Reale@EnCana.com County Weld Zip Code 80621 Phone (303) 659-7740 Fax (303) 857-1259 Chemical Abstract Service Number Chemical Name Reporting Bin Control Equipment/ Efficiency Emission Factor (include units) Emission Factor Source Requested Emissions (Ibs/yr) Actual Emissions from the Data Year (Ibs/yr) 7647010 Hydrogen Chloride A None 2.15 lb/ton AP -42 Tbl. 2.1-9 7/93 500 * Use this form for reporting Hazardous Air Pollutants. Ozone Depleting Compounds. and other Non -Criteria Reportable Pollutants Year For Which The Actual Data Applies: Signature of a Responsible Official ( eta vendor or con ltant Jeff Reale Name of a Responsible Official (please print) _ Date 2001 Senior Operations Superintendent Title AIR 'POLLUTANT EMISSION NOTICE FIRM NAME EnCana MAIL ADDRESS 1313 Denver Avenue, Building #1 Fort Lupton PLANT NAME & LOCATION Fort Lupton Plant: 16157 Weld County Road 22, Fort Lupton, CO 80621 REQUEST PORTABLE SOURCE PERMIT HOME -BASE FOR PORTABLE SOURCE PERSON TO CONTACT REGARDING THIS INFORMATION Jeff Reale GENERAL DESCRIPTION OF THIS PLANT'S FUNCTION Natural gas processing plant PERMIT No.:99OPWE207 AIRS ID.: 123 / 0319 / 012 STATE: CO ZIP: 80621 COUNTY: Weld A. GENERAL INFORMATION Normal Operation of This Source Hours/Day 24 Days/Week 7 Weeks/Year 52 TITLE Process Seasonal Throughput (% of Annual) Dec -Feb 25 Mar -May 25 Jun -Aug 25 Senior Operatio uperintendent PHONE (303) 659-7740 _ E-MAIL ADDRESS: Jeff.Reale@EnCana.com Sep -Nov 25 ADDITIONAL INFORMATION OR REMARKS: Formerly North American Resources Company B. STACK OR VENT INFORMATION (Identify below which stack if plant has two or more; refer to attached sketch of plant layout) Height 32 ft Diameter 1.44 ft Temperature 515 °F Flow Rate 4500 ACFM Velocity 2773 ft/min Moisture 7 Plant ID No. for Stack S012, C-210 C. FUEL INFORMATION Description of Combustion Unit Design Input Rate (106 BTU/hr) Kind of Fuel Burned Annual Fuel Consumption Requested level Actual level (Data year level) Fuel Heating Value: (BTU/Ib, BTU/gal, or BTU/scf) Percent by Weight Sulfur Ash Seasonal Fuel Use (% of Annual Use) Dec -Feb Mar -May Jun -Aug Sep -Nov Space Htg (% Ann.) 550 hp (site rated) Compressor Engine Natural Gas 0 0 25 25 25 25 Make/Model: Ajax DPC-2803 LE RECEIVED Serial No. 84286 D. PROCESS INFORMATION Description of Processing Unit Make/Model: Raw Materials Used Description to A Raw Materials -Annual Consumption I Design Process Rate Reques Serial No.: RM` 0 Units/Hour) Finished Product Description Finished Product -Annual Output Requested level Actual level (Data year level) E. POLLUTION CONTROL EQUIPMENT Pollutant Type of Control Equipment Primary Secondary Overall Collection Efficiency ESTIMATED EMISSIONS (TONS/YEAR) AT THROUGHPUTS REQUESTED ABOVE CONTROLLED UNCONTROLLED ACTUAL EMISSIONS (from data year) ESTIMATION METHOD Particulate PM,o SO' NO, VOC Low NOx 9.31 2.58 5.15 Stack Test Low NOx AP -42 CO PLEASE USE APCD NON -CRITERIA REPORTABLE AIR POLLUTANT ADDENDUM FORM TO REPORT SUCH POLLUTANTS OR POLLUTANTS NOT LISTED ABOVE. Low NOx AP -42 Signature of Person Legally Authorized to Supply Data: Typed Name and Title: Jeff Reale, Senior Opera ❑ CHECK HERE IF YOU WISH THE DIVISION TO CALCULATE YOUR EMISSIONS. SEE "EMISSION ESTIMATES" INSTRUCTIONS ON BACK. s Super' nd(n CHECK ALL BOXES THAT APPLY ❑ New or previously unreported source* ❑ Requesting modification of existing permit t: ❑ Change in emissions, throughputs or equipment $ ❑ Transfer of ownership (List previous owner in REMARKS section of box A.) $ ❑ Previous APEN is expiring $ ❑ Request for Emission Reduction Credit t: ❑ (Specify) * Complete all applicable portions of APEN t Complete ' Requested Level' values for permit limits * Complete all information above box A, and those remaining portions which reflect changes DATE: C,//�/UZ YEAR FOR WHICH THE ACTUAL DATA APPLIES: 2001 Date source began or will begin operation: 1997 THIS NOTICE IS VALID FOR FIVE YEARS. A revised notice shall be filed prior to this expiration date, whenever a permit limitation must be modified, whenever control equipment is changed, and annually whenever a significant emission change occurs. For specific details see Regulation 3, Part A, § II.C.1. A $119.96 FILING FEE IS REQUIRED FOR EACH NOTICE FILED. Send completed forms with fees to: Colorado Dept. of Public Health & Environment Air Pollution Control Division 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 APEN # 9 of 17 — — — For Information, Call (303) 692-3150 NON -CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM* Permit Number 99OPWE207 Company Name: EnCana Plant Location: Person to Contact: E -Mail Address: AIRS Number 123/0319/012 Fort Lupton Plant Jeff Reale, Senior Operations Superintendent Jeff.Reale@EnCana.com County Weld Zip Code 80621 Phone (303) 659-7740 Fax (303) 857-1259 Chemical Abstract Service Number Chemical Name Reporting Bin Control Equipment/ Efficiency Emission Factor (include units) Emission Factor Source Requested Emissions (Ibs/yr) Actual Emissions from the Data Year (Ibs/yr) 75070 Acetaldehyde A Lean Burn HAPCalc v. 2.01 120 50000 Formaldehyde A Lean Burn HAPCalc v. 2.01 1920 * Use this form for reportine Hazardous Air Pollutants. Ozone Depleting Compounds. and other Non -Criteria Reportable Pollutants Year For Which The Actual Data Applies: Signature of a Responsible Official (n• a vendor or . sul nt) Jeff Reale Dat 2001 Senior Operations Superintendent Name of a Responsible Official (please print) Title AIR POLLUTANT EMISSION NOTICE , , t PERMIT No.: FIRM NAME EnCana MAIL ADDRESS 1313 Denver Avenue, Building #1 Fort Lupton PLANT NAME & LOCATION Fort Lupton Plant: 16157 Weld County Road 22, Fort Lupton, CO 80621 REQUEST PORTABLE SOURCE PERMIT HOME -BASE FOR PORTABLE SOURCE PERSON TO CONTACT REGARDING THIS INFORMATION Jeff Reale GENERAL DESCRIPTION OF THIS PLANT'S FUNCTION Natural as rocessin A. GENERAL INFORMATION Normal Operation of This Source Process Seasonal Throughput (% of Annual) ADDITIONAL INFORMATION OR REMARKS: Formerly North American Resources Company Hours/Day 24 Days/Week 7 Weeks/Year 52 Dec -Feb 25 Mar -May 25 Jun -Aug 25 Sep -Nov 25 B. STACK OR VENT INFORMATION (Identify below which stack if plant has two or more; refer to attached sketch of plant layout) Height 40 ft Diameter 3.3 ft Temperature 750 °F Flow Rate 7498 ACFM Velocity 859 ft/min Moisture % Plant ID No. for Stack S013, E-460 Heater ant TITLE 99OPWE207 AIRS ID.: 123 / 0319 / 013 STATE: _CO ZIP: 80621 COUNTY: Weld Senior Operations Superintendent PHONE (303) 659-7740 E-MAIL ADDRESS: Jeff.Reale@EnCana.com C. FUEL INFORMATION Description of Combustion Unit Design Input Rate (106 BTU/hr) Kind of Fuel Burned Annual Fuel Consumption Requested level Actual level (Data year level) Fuel Heating Value: (BTU/lb, BTU/gal, or BTU/scf) Percent by Weight Sulfur Ash Seasonal Fuel Use (% of Annual Use) Dec -Feb Mar -May Jun -Aug Sep -Nov Space Htg (% Ann.) 10.7 MMBtu/hr Amine Heater Make/Model: Born 10.7 Natural Gas RECEIV ED 0 0 25 25 25 25 Serial No. 2885-0 JUL ('8 2002 D. PROCESS INFORMATION Raw Materials Used Raw Materials c gikeiQIY CQICFI$e?rocess Rate Finished Product Finished Product -Annual Output Description of Processing Unit Description Requested level I RCEC (Data year level) ppA 7Spec unnt/Hour) Description Requested level Actual level (Data year level) Make/Model: Serial No.: E. POLLUTION CONTROL EQUIPMENT Pollutant Type of Control Equipment Primary Secondary Overall ESTIMATED EMISSIONS Collection (TONS/YEAR) AT THROUGHPUTS Efficiency REQUESTED ABOVE CONTROLLED UNCONTROLLED ACTUAL EMISSIONS (from data year) ESTIMATION METHOD Particulate PMio SO, NO, VOC 4.05 AP -42 CO PLEASE USE APCD NON -CRITERIA REPORTABLE AIR POLLUTANT ADDENDUM FORM TO REPORT SUCH POLLUTANTS OR POLLUTANTS NOT LISTED ABOVE. 3.4 AP -42 Signature of Person Legally Authorized to Supply Data: ❑ CHECK HERE IF YOU WISH THE DIVISION TO CALCULATE YOUR EMISSIONS. SEE "EMISSION ESTIMATES" INSTRUCTIONS ON BACK. Typed Name and Title: Jeff Reale, Senior Op=. ations Super t .„A„ DATE: CHECK ALL BOXES THAT APPLY ❑ New or previously unreported source* ❑ Requesting modification of existing permit t ❑ Change in emissions, throughputs or equipment ❑ Transfer of ownership (List previous owner in REMARKS section of box A.) ❑ Previous APEN is expiring ❑ Request for Emission Reduction Credit tt ❑ (Specify) * Complete all applicable portions of APEN t Complete ' Requested Level' values for permit limits $ Complete all information above box A, and those remaining portions which reflect changes YEAR FOR WHICH THE ACTUAL DATA APPLIES: 2001 Date source began or will begin operation: 1998 THIS NOTICE IS VALID FOR FIVE YEARS. A revised notice shalibe filed prior to this expiration date, whenever a permit limitation must be modified, whenever control equipment is changed, and annually whenever a significant emission change occurs. For specific details see Regulation 3, Part A, § II.C.1. A $119.96 FILING FEE IS REQUIRED FOR EACH NOTICE FILED. Send completed forms with fees to: Colorado Dept. of Public Health & Environment APEN # 10 of 17 Air Pollution Control Division 4300 Cherry Creek Drive South, APCD-SS-BI For Information, Call Denver, Colorado 80246-1530 (303) 692-3150 AIR POLLUTANT EMISSION NOTICE 3 1 f -j o L PERMIT No.:_99OPWE207_ AIRS ID. :_123_/_0319_/_014_ FIRM NAME EnCana MAIL ADDRESS 1313 Denver Avenue, Building #1 Fort Lupton PLANT NAME & LOCATION Fort Lupton Plant: 16157 Weld County Road 22, Fort Lupton, CO 80621 REQUEST PORTABLE SOURCE PERMIT HOME -BASE FOR PORTABLE SOURCE PERSON TO CONTACT REGARDING THIS INFORMATION Jeff Reale GENERAL DESCRIPTION OF THIS PLANT'S FUNCTION Natural gas processing plant A. GENERAL INFORMATION Normal Operation of This Source Process Seasonal Through ut (% of Annual) ADDITIONAL INFORMATION OR REMARKS: Formerly North American Resources Company Hours/Day 24 - Days/Week 7 Weeks/Year 52 Dec -Feb 25 Mar -May Jun -Aug 25 25 Sep -Nov 25 B. STACK OR VENT INFORMATION (Identify below which stack if plant has two or more; refer to attached sketch of plant layout) Height 40 ft Diameter 3.3 ft Temperature 750 °F Flow Rate 7498 ACFM Velocity 859 ft/min Moisture % Plant ID No. for Stack S014, HX-500 Heater C. FUEL INFORMATION Description of Combustion Unit Design nput Rate (106 BTU/hr) Kind of Fuel Burned Annual Fuel Consumption Fuel Heating Value: Percent by Weight Seasonal Fuel Use (% of Annual Use) Space Htg Requested level Actual level (Data year level) (BTU/lb, BTU/gal, or BTU/scf) Sulfur Ash Dec -Feb Mar -May Jun -Aug Sep -Nov (% Ann.) 32 MMBtu/hr Hot Oil Heater 32 Natural Gas 0 0 25 25 25 25 Make/Model: Born RECEIVED Serial No. 1963 JUl i,d 20D2 D. PROCESS INFORMATION Description of Processing Unit Raw Materials Used Raw Materials -Anna aggs uu,, Design Process Rate Finished Product Finished Product -Annual Output Description Requested level SF u"ON ( a (P/F$$ipyq[31µoa CONTROL ur) Description Requested level Actual level (Data year level) Make/Model: Serial No.: E. POLLUTION CONTROL EQUIPMENT Overall ESTIMATED EMISSIONS ACTUAL ESTIMATION CHECK ALL BOXES THAT APPLY ❑ New or previously unreported source* ❑ Requesting modification of existing permit t$ 0 Change in emissions, throughputs or equipment $ • Transfer of ownership (List previous owner in REMARKS section of box A.) $ ❑ Previous APEN is expiring : 0 Request for Emission Reduction Credit t$ 0 (Specify) Pollutant Type of Control Equipment Collection Efficiency (TONS/YEAR) AT THROUGHPUTS REQUESTED ABOVE EMISSIONS (from data year) METHOD Primary Secondary CONTROLLED UNCONTROLLED Particulate PMi0 SO, NO, 12.2 AP -42 VOC CO 10.25 AP -42 PLEASE USE APCD NON -CRITERIA REPORTABLE AIR POLLUTANT ADDENDUM FORM TO REPORT SUCH POLLUTANTS OR POLLUTANTS NOT LISTED ABOVE. ❑ CHECK HERE IF YOU WISH THE DIVISION TO CALCULATE YOUR EMISSIONS. SEE "EMISSION ESTIMATES" INSTRUCTIONS ON BACK. * Complete all applicable portions of APEN t Complete ' Requested Level' values for permit limits $ Complete all information above box A, and those remaining portions which reflect changes Signature of Person Legally Authorized to Supply Data: /(r.9/4-DAT,F -,-,/,`",,/i- L YEAR FOR WHICH THE ACTUAL DATA APPLIES: 2001 Typed Name and Title: Jeff Reale, Senior O rations Super e ent Date source began or will begin operation: 1998 THIS NOTICE IS VALID FOR FIVE YEARS. A revised notice Cded p for to this expiration date, whenever a permit limitation must be modified, whenever rol equipment is changed, and annually whenever a significant emission change occurs. For specific details see Regulation 3, Part A, § II.C.1. A $119.96 FILING FEE IS REQUIRED FOR EACH NOTICE FILED. Send completed forms with fees to: Colorado Dept. of Public Health & Environment APEN # 11 of 17 Air Pollution Control Division 4300 Cherry Creek Drive South, APCD-SS-Bl For Information, Call Denver, Colorado 80246-1530 (303) 692-3150 f -I C-2 STATE: _CO ZIP: 80621 COUNTY: Weld TITLE Senior Operations Superintendent PHONE (303) 659-7740 E-MAIL ADDRESS: Jeff.RealeEnCana.com AIR POLLUTANT EMISSION NOTICE . PERMIT No.: FIRM NAME EnCana MAIL ADDRESS 1313 Denver Avenue, Building #1 Fort Lupton PLANT NAME & LOCATION Fort Lupton Plant: 16157 Weld County Road 22, Fort Lupton, CO 80621 REQUEST PORTABLE SOURCE PERMIT HOME -BASE FOR PORTABLE SOURCE ` PERSON TO CONTACT REGARDING THIS INFORMATION Jeff Reale TITLE Senior Operations Superintendent PHONE GENERAL DESCRIPTION OF THIS PLANT'S FUNCTION Natural gas processing plant rn 99OPWE207 AIRS ID.:_123_/_0319_/_015_ i STATE: CO ZIP: 80621 COUNTY: Weld E-MAIL ADDRESS: Jeff.RealeEnCana.co (303) 659-7740 _ A. GENERAL INFORMATION Normal Operation of This Source Process Seasonal Throughput (% of Annual) ADDITIONAL INFORMATION OR REMARKS: Formerly North American Resources Company Hours/Day 24 Days/Week 7 Weeks/Year 52 Dec -Feb 25 Mar -May 25 Jun -Aug 25 Sep -Nov 25 B. STACK OR VENT INFORMATION (Identify below which stack if plant has two or more; refer to attached sketch of plant layout) Height 32 ft Diameter 1.44 ft Temperature 515 °F Flow Rate 4500 ACFM Velocity 2773 ft/min Moisture 7 % Plant ID No. for Stack S015, C-324 C. FUEL INFORMATION Description of Combustion Unit Design Input Rate (106 BTU/hr) Kind of Fuel Burned Annual Fuel Consumption Fuel Heating Value: Percent b Weight Seasonal Fuel Use % of Annual Use) Space Htg Requested level Actual level (Data year level) (BTU/lb, BTU/gal, or BTU/scf) Sulfur Ash Dec -Feb Mar -May Jun -Aug Sep -Nov (% Ann.) 550 hp (site rated) Compressor Engine Natural Gas 0 0 25 25 25 25 Make/Model: Ajax DPC-2803 LE RECEIVED Serial No. 84308 D. PROCESS INFORMATION Descri.tion of Processin_ Unit Raw Matenals UsedRaw Materials -Annual Consumption Design Process Rate - _�j ',y, L nits/Hour) Finished Product Description Finished Product-Annua Output Re nested leve a-, 4 i . -1. Re. ested level Actual level Data ear level Make/Model: - z . • Serial No.: E. POLLUTION CONTROL EQUIPMENT Overall ESTIMATED (TONS/YEAR) REQUESTED EMISSIONS AT THROUGHPUTS ABOVE ACTUAL EMISSIONS (from data year) ESTIMATION METHOD CHECK ALL BOXES THAT APPLY ❑ New or previously unreported source* Pollutant Type of Control Equipment Collection Efficiency Primary Secondary CONTROLLED UNCONTROLLED ❑ Requesting modification of existing permit t; Particulate 0 Change in emissions, throughputs or equipment $ PM10 ■ Transfer of ownership SO, (List previous owner in REMARKS section of box A.) $ NO, Lean Burn 7.45 Stack Test 0 Previous APEN is expiring t VOC Lean Burn 2.06 AP -42 ❑ Request for Emission Reduction Credit t$ CO Lean Burn 4.11 AP -42 0 (Specify) PLEASE USE APCD NON -CRITERIA REPORTABLE AIR POLLUTANT ADDENDUM FORM TO REPORT SUCH POLLUTANTS OR POLLUTANTS NOT LISTED ABOVE. 0 CHECK HERE IF YOU WISH THE DIVISION TO CALCULATE YOUR EMISSIONS. SEE "EMISSION ESTIMATES" INSTRUCTIONS ON BACK. * Complete all applicable portions of APEN 1 Complete ' Requested Level' values for permit limits $ Complete all information above box A, and those remaining portions which reflect changes Signature of Person Legally Authorized to Suppl Data // - / ,C3 X DATE: G/i,� 2.. YEAR FOR WHICH THE ACTUAL DATA APPLIES: 2001 Typed Name and Title: Jeff R le, Senior Ope tie& Superintendent Date source began or will begin operation: 1998 THIS NOTICE IS VALID FOR FIVE YEARS. A re shall be filed prior to this expiration date, whenever a permit limitation must be modified, whenever control equipment is changed, and annually whenever a significant emission change occurs. For specific details see Regulation 3, Part A, § II.C.1. A $119.96 FILING FEE IS REQUIRED FOR EACH NOTICE FILED. Send completed forms with fees to: Colorado Dept. of Public Health & Environment APEN # 12 of 17 Air Pollution Control Division — — — 4300 Cherry Creek Drive South, APCD-SS-BI For Information, Call Denver, Colorado 80246-1530 (303) 692-3150 NON -CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM* Permit Number 99OPWE207 Company Name: EnCana AIRS Number 123/0319/015 Plant Location: Fort Lupton Plant Person to Contact: Jeff Reale, Senior Operations Superintendent E -Mail Address: Jeff.Reale@EnCana.com County Weld Zip Code 80621 Phone (303) 659-7740 Fax (303) 857-1259 Chemical Abstract Service Number Chemical Name Reporting Bin Control Equipment/ Efficiency Emission Factor (include units) Emission Factor Source Requested Emissions (lbs/yr) Actual Emissions from the Data Year (Ibs/yr) 75070 Acetaldehyde A Lean Burn HAPCalc v. 2.01 120 50000 Formaldehyde A Lean Burn HAPCalc v. 2.01 1920 * Use this form for reporting Hazardous Air Pollutants, Ozone Depleting Compounds. and other Non -Criteria Reportable Pollutants Year For Which The Actual Data Applies: 2001 Signature of a Responsible °ffic of a vend r consultant) Jeff Reale ate Senior Operations Superintendent Name of a Responsible Official (please print) Title AIR POLLUTANT EMISSION NOTICE PERMIT No.: FIRM NAME EnCana MAIL ADDRESS 1313 Denver Avenue, Building #1 Fort Lupton _ STATE: CO ZIP: 80621 PLANT NAME & LOCATION Fort Lupton Plant: 16157 Weld County Road 22, Fort Lupton, CO 80621 l�\ ( COUNTY: Weld REQUEST PORTABLE SOURCE PERMIT HOME -BASE FOR PORTABLE SOURCE _ PERSON TO CONTACT REGARDING THIS INFORMATION Jeff Reale GENERAL DESCRIPTION OF THIS PLANT'S FUNCTION Natural gas processing plant A. GENERAL INFORMATION Normal Operation of This Source Process Seasonal Through ut (% of Annual) ADDITIONAL INFORMATION OR REMARKS: Formerly North American Resources Company Hours/Day 24 Days/Week 7 Weeks/Year 52 Dec -Feb 25 Mar -May 25 Jun -Aug 25 Sep -Nov 25 B. STACK OR VENT INFORMATION (Identify below which stack if plant has two or more; refer to attached sketch of plant layout) Height 32 ft Diameter 1.44 ft Temperature 515 °F Flow Rate 4500 ACFM Velocity 2773 ft/min Moisture 7 % Plant ID No. for Stack S016, BC -323 :x.91 %'4 99OPWE207 AIRS ID.: 123 / 0319 / 016 TITLE Senior Ope . ' i Superintendent PHONE (303) 659-7740 E-MAIL ADDRESS: Jeff.Reale@EnCana.com C. FUEL INFORMATION Description of Combustion Unit Design Input Rate (106 BTU/hr) Kind of Fuel Burned Annual Fuel Consumption Fuel Heating Value: Percent by Weight Seasonal Fuel Use(% of Annual Use) Space Htg Requested level Actual level (BTU/lb, BTU/gal, (% Ann.) (Data year level) or BTU/scf) Sulfur Ash Dec -Feb Mar -May Jun -Aug Sep -Nov 550 hp (site rated) Compressor Engine Natural Gas 0 0 25 25 25 25 Make/Model: Ajax DPC-2803 LE RECEIVED Serial No. 84288 D. PROCESS INFORMATION Description of Processing Unit Make/Model. Raw Materials Used Raw Materials -Annual Consumption 2002 Design Process Rate Finished Product Description Finished Product -Annual Output D q Q1fDR�t7h�rE4Iv(lE*L'�itftlftaP��u ) Q ( ) Descri tion Re uested level / ON r Re uested level Actual level Data year level Serial No.: E. POLLUTION CONTROL EQUIPMENT Overall ESTIMATED EMISSIONS (TONS/YEAR) AT THROUGHPUTS REQUESTED ABOVE ACTUAL EMISSIONS (from data year) ESTIMATION METHOD CHECK ALL BOXES THAT APPLY O New or previously unreported source* ❑ Requesting modification of existing permit t; O Change in emissions, throughputs or equipment $ ■ Transfer of ownership (List previous owner in REMARKS section of box A.) t O Previous APEN is expiring $ ❑ Request for Emission Reduction Credit t: O (Specify) Pollutant Type of Control Equipment Collection Efficiency Primary Secondary CONTROLLED UNCONTROLLED Particulate PM") SO. NO, Lean Burn 7.45 Stack Test VOC Lean Burn 2.06 AP -42 CO Lean Burn 4.11 AP -42 PLEASE USE APCD NON -CRITERIA REPORTABLE AIR POLLUTANT ADDENDUM FORM TO REPORT SUCH POLLUTANTS OR POLLUTANTS NOT LISTED ABOVE. O CHECK HERE IF YOU WISH THE DIVISION TO CALCULATE YOUR EMISSIONS. SEE "EMISSION ESTIMATES" INSTRUCTIONS ON BACK. * Complete all applicable portions of APEN t Complete ' Requested Level' values for permit limits $ Complete all information above box A, and those remaining portions which reflect changes Signature of Person Legally Authorized to Supply Data: fi t</v-- DATE: /)//s' 2 YEAR FOR WHICH THE ACTUAL DATA APPLIES: 2001 Typed Name and Title: Jeff Reale, Senior Ope '• Lions Super' end nt Date source began or will begin operation: 1998 THIS NOTICE IS VALID FOR FIVE YEARS. A revised notice SIra1F fed prior to this expiration date, whenever a permit limitation must be modified, whenever control equipment is changed, and annually whenever a significant emission change occurs. For specific details see Regulation 3, Part A, § II.C.1. A $119.96 FILING FEE IS REQUIRED FOR EACH NOTICE FILED. Send completed forms with fees to: Colorado Dept. of Public Health & Environment APEN #_13 of 17 Air Pollution Control Division 4300 Cherry Creek Drive South, APCD-SS-B1 For Information, Call Denver, Colorado 80246-1530 (303) 692-3150 NON -CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM* (Instructions on reverse side) Permit Number 99OPWE207 Company Name: EnCana AIRS Number 123/0319/016 Plant Location: Fort Lupton Plant Person to Contact: Jeff Reale, Senior Operations Superintendent E -Mail Address: Jeff.Reale@EnCana.com County Weld Zip Code 80621 Phone (303) 659-7740 Fax (303) 857-1259 Chemical Abstract Service Number Chemical Name Reporting Bin Control Equipment/ Efficiency Emission Factor (include units) Emission Factor Source Requested Emissions (Ibs/yr) Actual Emissions from the Data Year (Ibs/yr) 75070 Acetaldehyde A Lean Burn HAPCalc v. 2.01 120 50000 Formaldehyde A Lean Burn HAPCalc v. 2.01 1920 * Use this form for reporting Hazardous Air Pollutants, Ozone Depleting Compounds, and other Non -Criteria Reportable Pollutants Year For Which The Actual Data Applies: Signature of a Responsible Of Jeff Reale Name of a Responsible Official (please a vencifyhi consultant) Da e e Senior Operations Superintendent Title 2001 AIR POLLUTANT EMISSION NOTICE 9 1.1 : 5 PERMIT No.: 99OPWE207 FIRM NAME EnCana MAIL ADDRESS 1313 Denver Avenue, Building #1 Fort Lupton PLANT NAME & LOCATION Fort Lupton Plant: 16157 Weld County Road 22, Fort Lupton, CO 80621 REQUEST PORTABLE SOURCE PERMIT HOME -BASE FOR PORTABLE SOURCE PERSON TO CONTACT REGARDING THIS INFORMATION Jeff Reale GENERAL DESCRIPTION OF THIS PLANT'S FUNCTION Natural gas processing plant AIRS ID.: 123 / 0319 / 017 VA C )I I STATE: _CO ZIP: 80621 COUNTY: Weld A. GENERAL INFORMATION Normal Operation of This Source Hours/Day 24 Days/Week 7 Weeks/Year 52 TITLE Senior Operations Superintendent PHONE_(303) 659-7740__ E-MAIL ADDRESS: Jeff.Reale@EnCana.com Process Seasonal Through u c Th h t (9 of Annual) Dec -Feb 25 Mar -May Jun -Aug 25 25 Sep -Nov 25 ADDITIONAL INFORMATION OR REMARKS: Formerly North American Resources Company B. STACK OR VENT INFORMATION (Identify below which stack if plant has two or more; refer to attached sketch of plant layout) Height 32 ft Diameter 1.44 ft Temperature 515 °F Flow Rate 4500 ACFM Velocity 2773 ft/min Moisture 7 % Plant ID No. for Stack S017, BC -314 C. FUEL INFORMATION Description of Combustion Unit Design Input Rate (10° BTU/hr) Kind of Fuel Burned Annual Fuel Consumption Requested level Actual level (Data year level) Fuel Heating Value: (BTU/lb, BTU/gal, or BTU/scf) Percent by Weight Sulfur Ash Seasonal Fuel Use (% of Annual Use) Dec -Feb Mar -May Jun -Aug Sep -Nov Space Htg (% Ann.) 550 hp (site rated) Compressor Engine Make/Model: Ajax DPC-2803 LE Natural Gas RECE IVED 0 0 25 25 25 25 Serial No. 84287 JUL 8 2002 D. PROCESS INFORMATION Description of Processing Unit Make/Model: Raw Materials Used Description Raw Materials-Anttua Cpot Requested level c41 Ory atay I TKFds Rate DU $gg3%I ek,Ar) Finished Product Description Finished Product-Annua Output Requested level Actual level (Data year level) Serial No.: E. POLLUTION CONTROL EQUIPMENT Overall ESTIMATED EMISSIONS (TONS/YEAR) AT THROUGHPUTS REQUESTED ABOVE ACTUAL EMISSIONS (from data year) ESTIMATION METHOD CHECK ALL BOXES THAT APPLY O New or previously unreported source* O Requesting modification of existing permit t$ O Change in emissions, throughputs or equipment $ • Transfer of ownership (List previous owner in REMARKS section of box A.) $ O Previous APEN is expiring $ O Request for Emission Reduction Credit t: O (Specify) Pollutant Type of Control Equipment Collection Efficiency Primary Secondary CONTROLLED UNCONTROLLED Particulate PMio SO, N(:) Burn 9.51 Stack Test VOC Lean Burn 2.63 AP -42 CO Lean Burn 5.26 AP -42 PLEASE USE APCD NON -CRITERIA REPORTABLE AIR POLLUTANT ADDENDUM FORM TO REPORT SUCH POLLUTANTS OR POLLUTANTS NOT LISTED ABOVE. O CHECK HERE IF YOU WISH THE DIVISION TO CALCULATE YOUR EMISSIONS. SEE "EMISSION ESTIMATES" INSTRUCTIONS ON BACK. * Complete all applicable portions of APEN t Complete ' Requested Level' values for permit limits $ Complete all information above box A, and those remaining portions which reflect changes Signature of Person Legally Authorized to Supply Data: i�/��.f��/1� DAT t YEAR FOR WHICH THE ACTUAL DATA APPLIES: 2001 Typed Name and Tide: Jeff Reale, Senior Operations Su ntendent Date source began or will begin operation: 1998 THIS NOTICE IS VALID FOR FIVE YEARS. A revised no be file) prior to this expiration date, whenever a permit limitation must be modified, whenever control equipment is changed, and annually whenever a significant emission change occurs. For specific details see Regulation 3, Part A, § II.C.1. A $119.96 FILING FEE IS REQUIRED FOR EACH NOTICE FILED. Send completed forms with fees to: Colorado Dept. of Public Health & Environment APEN # 14 of 17 Air Pollution Control Division 4300 Cherry Creek Drive South, APCD-SS-BI For Information, Call Denver, Colorado 80246-1530 (303) 692-3150 NON -CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM* (Instructions on reverse side) Permit Number 99OPWE207 Company Name: EnCana AIRS Number 123/0319/017 Plant Location: Fort Lupton Plant Person to Contact: Jeff Reale, Senior Operations Superintendent E -Mail Address: Jeff.Reale@EnCana.com County Weld Zip Code 80621 Phone (303) 659-7740 Fax (303) 857-1259 Chemical Abstract Service Number Chemical Name Reporting Bin Control Equipment/ Efficiency Emission Factor (include units) Emission Factor Source Requested Emissions (Ibs/yr) Actual Emissions from the Data Year (Ibs/yr) 75070 Acetaldehyde A Lean Burn HAPCalc v. 2.01 120 50000 Formaldehyde A Lean Burn HAPCalc v. 2.01 1920 * Use this form for reporting Hazardous Air Pollutants, Ozone Depleting Compounds, and other Non -Criteria Reportable Pollutants Year For Which The Actual Data Applies: Signature of a Responsible Name of a Responsible Official vend or consultant) at 2001 Senior Operations Superintendent Title AIR -POLLUTANT EMISSION NOTICE j 9 ,, :; gERMIT No.:99OPWE207_ AIRS ID.:_123_/_0319_/_018_ FIRM NAME EnCana n s25---, MAIL ADDRESS 1313 Denver Avenue, Building #1 Fort Lupton n STATE: CO ZIP: 80621 PLANT NAME & LOCATION Fort Lupton Plant: 16157 Weld County Road 22, Fort Lupton, CO 80621 � COUNTY: Weld REQUEST PORTABLE SOURCE PERMIT HOME -BASE FOR PORTABLE SOURCE c _1 DZ, PERSON TO CONTACT REGARDING THIS INFORMATION Jeff Reale TITLE Senior Operations Superintendent_PHONE_(303) 659-7740 GENERAL DESCRIPTION OF THIS PLANT'S FUNCTION Natural gas processing plant E-MAIL ADDRESS: Jeff.Reale@EnCana.com A. GENERAL INFORMATION Normal Operation of This Source Process Seasonal Through ut (% of Annual) ADDITIONAL INFORMATION OR REMARKS: Hours/Day 24 Days/Week 7 Weeks/Year 52 Dec -Feb 25 Mar -May 25 Jun -Aug 25 Sep -Nov 25 Formerly North American Resources Company B. STACK OR VENT INFORMATION (Identify below which stack if plant has two or more: refer to attached sketch of plant layout) Height 20 ft Diameter 0.67 ft Temperature 863 °F Flow Rate 6356 ACFM Velocity 18028 ft/min Moisture % Plant ID No. for Stack S018 C. FUEL INFORMATION Design nput Rate Annual Fuel Consumption Fuel Heating Value: Percent by Weight Seasonal Fuel Use (% of Annual Use) Space Htg Description of Combustion Unit (10° BTU/hr) Kind of Fuel Burned Requested level Actual level (Data year level) (BTU/lb, BTU/gal, or BTU/scf) Sulfur Ash Dec -Feb Mar -May Jun -Aug Sep -Nov (% Ann.) 980 hp (site rated) Compressor Engine Natural Gas 0 0 25 25 25 25 Make/Model: Caterpillar G3516TALE RECEI ED Serial No. 3RCO1237 D. PROCESS INFORMATION Raw Materials Used Raw Materials-Annua Consumption Design Process Rate Finished Product Finished Product -Annual Output Descri tion of Processin Unit Descri tion Re uested leve •' AllaiikDithtigrIC ! NT our) Description Re uested level Actual level (Data ear level Make/Model: Serial No.: E. POLLUTION CONTROL EQUIPMENT Overall ESTIMATED EMISSIONS ACTUAL ESTIMATION CHECK ALL BOXES THAT APPLY Pollutant Type of Control Equipment Collection Efficiency (TONS/YEAR) AT THROUGHPUTS REQUESTED ABOVE EMISSIONS (from data year) METHOD O New or previously unreported source* Primary Secondary CONTROLLED UNCONTROLLED O Requesting modification of existing permit t: Particulate O Change in emissions, throughputs or equipment: PM10 • Transfer of ownership SO, (List previous owner in REMARKS section of box A.) `+ NO, Lean Burn 16.85 Stack Test O Previous APEN is expiring $ VOC Lean Burn 5.19 AP -42 ❑ Request for Emission Reduction Credit t: CO Lean Burn 14.18 Stack Test D (Specify) PLEASE USE APCD NON -CRITERIA REPORTABLE AIR POLLUTANT ADDENDUM FORM TO REPORT SUCH POLLUTANTS OR POLLUTANTS NOT LISTED ABOVE. O CHECK HERE IF YOU WISH THE DIVISION TO CALCULATE YOUR EMISSIONS. SEE "EMISSION ESTIMATES" INSTRUCTIONS ON BACK. * Complete all applicable portions of APEN t Complete Requested Level' values for permit limits $ Complete all information above box A, and those remaining portions which reflect changes Signature of Person Legally Authorized to Supply D : "C-44 DAT • // 0' L YEAR FOR WHICH THE ACTUAL DATA APPLIES: 2001 Typed Name and Title: Jeff ale, Senior Op atio s Superintendent Date source began or will begin operation: 1998 THIS NOTICE IS VALID FOR FI ARS. A revised no ce shall be filed prior to this expiration date, whenever a permit limi be ' ed, whenever control equipment is changed, and annually whenever a significant emission change occurs. For specific details see Regulation 3, Part A, § II.C.1. A $119.96 FILING FEE IS REQUIRED FOR EACH NOTICE FILED. Send completed forms with fees to: Colorado Dept. of Public Health & Environment APEN N 15 of 17 Air Pollution Control Division — — — 4300 Cherry Creek Drive South, APCD-SS-B1 For Information, Call Denver, Colorado 80246-1530 (303) 692-3150 NON -CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM* (Instructions on reverse side) Permit Number 99OPWE207 Company Name: EnCana AIRS Number 123/0319/018 Plant Location: Fort Lupton Plant Person to Contact: Jeff Reale, Senior Operations Superintendent E -Mail Address: JeffReale@EnCana.com County Weld Zip Code 80621 Phone (303) 659-7740 Fax (303) 857-1259 Chemical Abstract Service Number Chemical Name Reporting Bin Control Equipment/ Efficiency Emission Factor (include units) Emission Factor Source Requested Emissions (lbs/yr) Actual Emissions from the Data Year (lbs/yr) 75070 Acetaldehyde A Lean Burn HAPCalc v. 2.01 100 107028 Acrolein A Lean Burn HAPCalc v. 2.01 140 50000 Formaldehyde A Lean Burn HAPCalc v. 2.01 2180 ' Use this form for reporting Hazardous Air Pollutants. Ozone Depleting Compounds, and other Non -Criteria Reportable Pollutants Signature of a Responsible Offi al (not a yen or c ultant ) Jeff Reale Year For Which The Actual Data Applies: to 77 z Senior Operations Superintendent 2001 Name of a Responsible Official (please prin Title 'AIR POLLUTANT EMISSION NOTICE ; (' '.., PERMIT No.: 99OPWE207_ AIRS ID.:_123_/_0319_/_019_ FIRM NAME EnCana � n1 _1 X MAIL ADDRESS 1313 Denver Avenue, Building #1 Fort Lupton PLANT NAME & LOCATION Fort Lupton Plant: 16157 Weld County Road 22, Fort Lupton, CO 80621 REQUEST PORTABLE SOURCE PERMIT HOME -BASE FOR PORTABLE SOURCE PERSON TO CONTACT REGARDING THIS INFORMATION Jeff Reale GENERAL DESCRIPTION OF THIS PLANT'S FUNCTION Natural gas processing plant \ \— C\- i t STATE: CO ZIP: 80621 COUNTY: Weld G-..� L--._... A. GENERAL INFORMATION Normal Operation of This Source Hours/Day 24 TITLE Senior Operations Superintendent PHONE_(303) 659-7740 E-MAIL ADDRESS: Jeff.Reale@EnCana.com Process Seasonal Through u o Th h t (% f Annual) Dec -Feb 25 Days/Week 7 Weeks/Year 52 Mar -May Jun -Aug 25 25 Sep -Nov 25 ADDITIONAL INFORMATION OR REMARKS: Formerly North American Resources Company B. STACK OR VENT INFORMATION (dentify below which stack if plant has two or more; refer to attached sketch of plant layout) Height 20 ft Diameter 0.67 ft Temperature 863 °F Flow Rate 6356 ACFM Velocity 18028 ft/min Moisture Plant ID No. for Stack S019 C. FUEL INFORMATION Description of Combustion Unit Design Input Rate (106 BTU/hr) Kind of Fuel Burned Annual Fuel Consumption Requested level Actual level (Data year level) Fuel Heating Value: (BTU/lb, BTU/gal, or BTU/scf) Percent by Weight Sulfur Ash Seasonal Fuel Use (% of Annual Use) Dec -Feb Mar -May Jun -Aug Sep -Nov Space Htg (% Ann.) 980 hp (site rated) Compressor Engine Natural Gas 0 0 25 25 25 25 Make/Model: Caterpillar G3516TALE Serial No. 3RCO1240 D. PROCESS INFORMATION Description of Processing Unit Make/Model: Raw Materials Used Description Raw Materials -Annual Requested level RECEI VED Cotsumption DesignFPrrAolcess Rate S�1 1 JN(E is/Hour) ! AFiY S HL ti PROGRAM Finished Product Description Finished Product -Annual Output Requested level Actual level (Data year level) Serial No.: E. POLLUTION CONTROL EQUIPMENT Pollutant Type of Control Equipment Primary Secondary Overall Collection Efficiency ESTIMATED EMISSIONS (TONS/YEAR) AT THROUGHPUTS REQUESTED ABOVE CONTROLLED UNCONTROLLED ACTUAL EMISSIONS (from data year) ESTIMATION METHOD Particulate PM10 SO' NO,, VOC Lean Burn 16.85 5.19 14.18 Stack Test Lean Burn AP -42 CO PLEASE USE APCD NON -CRITERIA REPORTABLE AIR POLLUTANT ADDENDUM FORM TO REPORT SUCH POLLUTANTS OR POLLUTANTS NOT LISTED ABOVE. Lean Burn Stack Test ❑ CHECK HERE IF YOU WISH THE DIVISION TO CALCULATE YOUR EMISSIONS. SEE "EMISSION ESTIMATES" INSTRUCTIONS ON BACK. CHECK ALL BOXES THAT APPLY O New or previously unreported source* O Requesting modification of existing permit t$ O Change in emissions, throughputs or equipment IN Transfer of ownership (List previous owner in REMARKS section of box A.) ❑ Previous APEN is expiring $ ❑ Request for Emission Reduction Credit t: ❑ (Specify) * Complete all applicable portions of APEN t Complete ' Requested Level' values for permit limits Complete all information above box A, and those remaining portions which reflect changes Signature of Person Legally Authorized to Supply ata:; L-4-- DAyTE 40, �, 2 YEAR FOR WHICH THE ACTUAL DATA APPLIES: 2001 Typed Name and Title: Jeff Re , etlior ra Superintendent Date source began or will begin operation: 1998 THIS NOTICE IS VALID FOR Fl ARS. A revis notice shall be Filed prior to this expiration date, whenever a permit limita modified, whenever control equipment is changed, and annually whenever a significant emission change occurs. For specific details see Regulation 3, Part A, § ILC.1. A $119.96 FILING FEE IS REQUIRED FOR EACH NOTICE FILED. Send completed forms with fees to: Colorado Dept. of Public Health & Environment APEN #_16_of 17 Air Pollution Control Division 4300 Cherry Creek Drive South, APCD-SS-B1 For Information, Call Denver, Colorado 80246-1530 (303) 692-3150 NON -CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM* (Instructions on reverse side) Permit Number 99OPWE207 Company Name: EnCana AIRS Number 123/0319/019 Plant Location: Fort Lupton Plant Person to Contact: Jeff Reale, Senior Operations Superintendent E -Mail Address: Jeff.Reale@EnCana.com County Weld Zip Code 80621 Phone (303) 659-7740 Fax (303) 857-1259 Chemical Abstract Service Number Chemical Name Reporting Bin Control Equipment/ Efficiency Emission Factor (include units) Emission Factor Source Requested Emissions (Ibs/yr) Actual Emissions from the Data Year (Ibs/yr) 75070 Acetaldehyde A Lean Burn HAPCalc v. 2.01 100 107028 Acrolein A Lean Burn HAPCalc v. 2.01 140 50000 Formaldehyde A Lean Burn HAPCalc v. 2.01 2180 Use this form for reporting I-lazardous Air Pollutants. Ozone Depleting Compounds. and other Non -Criteria Reportable Pollutants Year For Which The Actual Data Applies: Signature of a Responsi Official (not veo or consultant) Jeff Reale _ Date Senior Operations Superintendent 2001 Name of a Responsible Official (please print) Title AIR POLLUTANT EMISSION NOTICE PERMIT No.: FIRM NAME EnCana U :i 8 MAIL ADDRESS 1313 Denver Avenue, Building #1 Fort Lupton PLANT NAME & LOCATION Fort Lupton Plant: 16157 Weld County Road 22, Fort Lupton, CO 80621 REQUEST PORTABLE SOURCE PERMIT HOME -BASE FOR PORTABLE SOURCE PERSON TO CONTACT REGARDING THIS INFORMATION Jeff Reale GENERAL DESCRIPTION OF THIS PLANT'S FUNCTION Natural gas processing plant 01WE0290 AIRS ID.:_123/0319/020 S-7� A. GENERAL INFORMATION Normal Operation of This Source Hours/Day 24 Days/Week 7 Weeks/Year 52 STATE: _CO ZIP: 80621 COUNTY: Weld C. TITLE Senior Operations Superintendent PHONE (303) 659-7740 E-MAIL ADDRESS: Jeff.Reale@EnCana.com Process Seasonal Through ut o Th h (% of Annual) Dec -Feb 25 Mar -May Jun -Aug 25 25 Sep -Nov 25 ADDITIONAL INFORMATION OR REMARKS: Formerly North American Resources Company B. STACK OR VENT INFORMATION (Identify below which stack if plant has two or more; refer to attached sketch of plant layout) Height 27 ft Diameter 3.3 ft Temperature 650? °F Flow Rate 33386 ACFM Velocity ft/min Moisture Plant ID No. for Stack S020, Turbine C. FUEL INFORMATION Description of Combustion Unit 4700 hp Turbine Engine Make/Model: Solar Centaur 40 Serial No. D. PROCESS INFORMATION Description of Processing Unit Make/Model: Serial No.: Design Input Rate (106 BTU/hr) Kind of Fuel Burned Annual Fuel Consumption Fuel Heating Value: (BTU/lb, BTU/gal, or BTU/scf) Percent by Weight Seasonal Fuel Use (% of Annual Use) Space Htg (% Ann.) Requested level Actual level (Data year level) Sulfur Ash Dec -Feb Mar -May Jun -Aug Sep -Nov Natural Gas 0 0 25 25 25 25 RECEIVED Raw Materials Used Description Raw Materials -Annual Consumption Requested level Actual level (Data year level) - TA •fl gn!t e2UUL (Specify Units/Hour) R POLLUTION CONTRA ?NARY SOURCES PRO R;ti� Finished Product Description Finished Product -Annual Output Requested level Actual level (Data year level) E. POLLUTION CONTROL EQUIPMENT Overall ESTIMATED EMISSIONS (TONS/YEAR) AT THROUGHPUTS REQUESTED ABOVE ACTUAL EMISSIONS (from data year) ESTIMATION METHOD CHECK ALL BOXES THAT APPLY O New or previously unreported source* O Requesting modification of existing permit t: O Change in emissions, throughputs or equipment: IN Transfer of ownership (List previous owner in REMARKS section of box A.): O Previous APEN is expiring: O Request for Emission Reduction Credit t: O (Specify) Pollutant Type of Control Equipment Collection Efficiency Primary Secondary CONTROLLED UNCONTROLLED Particulate PM,0 SO, NO, Lean Premixed Combustion 44.7 Mfg. Data VOC 9.3 Mfg. Data CO 32.4 ' Mfg. Data PLEASE USE APCD NON -CRITERIA REPORTABLE AIR POLLUTANT ADDENDUM FORM TO REPORT SUCH POLLUTANTS OR POLLUTANTS NOT LISTED ABOVE. O CHECK HERE IF YOU WISH THE DIVISION TO CALCULATE YOUR EMISSIONS. SEE "EMISSION ESTIMATES" INSTRUCTIONS ON BACK. * Complete all applicable portions of APEN t Complete ' Requested Level' values for permit limits : Complete all information above box A, and those remaining portions which reflect changes Signature of Person Legally Authorized to Supply ta: C /Kd:' 4 120/9'E: � /7 ? YEAR FOR WHICH THE ACTUAL DATA APPLIES: 2001 ( Typed Name and Title: eff Reale, Senior ratl6ds Superintendent Date source began or will begin operation: 2001 THIS NOTICE IS VALID FOR FIVE YEARS. A revised notice shall be filed prior to this expiration date, whenever a permit limitation must be modified, whenever control equipment is changed, and annually whenever a significant emission change occurs. For specific details see Regulation 3, Part A, § II.C.1. A $119.96 FILING FEE IS REQUIRED FOR EACH NOTICE FILED. Send completed forms with fees to: Colorado Dept. of Public Health & Environment APEN M 17 of 17 Air Pollution Control Division 4300 Cherry Creek Drive South, APCD-SS-B1 For Information, Call Denver, Colorado 80246-1530 (303) 692-3150 NON -CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM* (Instructions on reverse side) Permit Number 01WE0290 Company Name: EnCana AIRS Number 123/0319/020 Plant Location: Fort Lupton Plant Person to Contact: Jeff Reale, Senior Operations Superintendent E -Mail Address: Jeff.Reale@EnCana.com County Weld Zip Code 80621 Phone (303) 659-7740 Fax (303) 857-1259 Chemical Abstract Service Number Chemical Name Reporting Bin Control Equipment/ Efficiency Emission Factor (include units) Emission Factor Source Requested Emissions (lbs/yr) Actual Emissions from the Data Year (lbs/yr) 75070 Acetaldehyde A HAPCalc v. 2.01 2160 71432 Benzene A HAPCalc v. 2.01 180 50000 Formaldehyde A HAPCalc v. 2.01 300 Use this form for reporting Hazardous Air Pollutants, Ozone Depleting Compounds, and other Non -Criteria Reportable Pollutants Year For Which The Actual Data Applies: Signature of a Responsible Of 'al (not a vend r.Qr c isultant) Jeff Reale Date Senior Operations Superintendent Name of a Responsible Official (please print) Title 2001 Q./ r Ba..cu:s; Lill: 135 Hudson St. • Denver, CO 80220 • (303) 329-9295 • FAX (303) 329-9299 • Maggieairbasics@aol.com November 14, 2002 Mr. Geof Drissel, Permit Engineer Operating Permit Unit/APCD-SS-B 1 Colorado Dept. of Public Health & Env. 4300 Cherry Creek Drive South Denver, CO 80246-1530 RE: (Another) Minor Modification of Operating Permit 99OPWE207 for EnCana's Fort Lupton Plant Dear Mr. Drissel: EnCana Oil & Gas (USA) Inc. would like to install individual fuel meters on certain souces at its Fort Lupton Plant in order to obtain more accurate data on fuel consumption. This necessitates language changes to the Title V permit, which was written for the sole use of a central fuel meter. EnCana also wants to change the language on the fuel Btu analyses so that it matches the laboratory reports. Attached is a complete application for revision of Operating Permit 99OPWE207. This revision is in addition to the application submitted on August 22 of this year, adding the turbine engine S020 to the Title V permit. Please process this application as a minor permit modification in accordance with the provisions of Regulation 3, Part C, Section X.D. Attached are the following - 1. Descriptions of the changes are included above. There are no new emissions nor applicable regulations resulting from these changes. 2. An annotated version of the current operating permit, which reflects the requested changes. 3. The required certification by a responsible official. 4. These forms are not applicable. It is our understanding that the Division is responsible for supplying forms to notify EPA and affected states of this permit revision. 5. No new regulations will apply due to these language changes. 6. APENs do not apply to these changes. ReCoveb ter, G ?uo i,1,=gill P�Lc 2 77oNav 0 "okCOAIr` Please issue the modified permit to EnCana Oil & Gas (USA) Inc., not to EnCana Energy Resources, as previously requested. Documentation substantiating the change from North American Resources Company to EnCana was submitted on September 30, 2002. Please contact me at (303) 329-9295 if you have any questions on this submittal. Thank you, Air Basics, Inc. • /444,_ Maggl &her Air Quality Specialist AIR POLLUTION CONTROL DIVISION COLORADO OPERATING PERMIT FACILITY NAME: Ft. Lupton Plant FACILITY ID: 1230319 ISSUE DATE: EXPIRATION DATE: MODIFICATIONS: October 1, 1999 October 1, 2004 See Appendix F of Permit OPERATING PERMIT NUMBER 99OPWE207 Issued in accordance with the provisions of Colorado Air Quality Control Act, 25-7-101 et sec . (1989 & 1995 Supp.) and applicable rules and regulations. 0:l s Gat LtisA) ISSUED TO: F&tAtr„ Rcsuoc.ces North American Resources Company Ft. Lupton, CO 80621 3t2 Oe_..ver AvtnNt 11o. PLANT SITE LOCATION: 16157 Weld County Road 22 Ft. Lupton, CO 80621 Weld County T 2002 INFORMATION RELIED UPON Operating Permit Application Received: And Additional Information Received: Nature of Business: Primary SIC: RESPONSIBLE OFFICIAL Name: Jim Benner Title: " Pre/sident February 24, 1999 Natural Gas Plant 1311 Phone: (106) 723 5154 (3c3) 623-Z3oo FACILITY CONTACT PERSON Name: Jeff Reale Title: Senior Operations Superintendant Phone: (303) 659-7740 SUBMITTAL DEADLINES Semi -Annual Monitoring Period: Semi -Annual Monitoring Report: Annual Compliance Period: Annual Compliance Certification: October 1 - March 31, April 1 - September 30 May 1.2000 & November I, 2000 and subsequent years Begins October 1 to September 30 November 1, 2000 and subsequent years Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 1. North American Resources Company Ft. Lupton Plant Page 5 SECTION II - Specific Permit Terms S001 -S004 - Four Ajax 2 -Cycle Lean Burn ICEs (514 HP each) Parameter Permit Condition Number Limitations for each engine Short Term Long Term Compliance Emission Factor Monitoring Method Interval NOx 1.1. NA 11.6 tons/yr 0.514 lb/MMBtu Recordkeeping, Monthly, CO NA 11.6 tons/yr 0.30 lb/MMBtu Calculations and Portable Monitoring Quarterly VOC NA 5.8 tons/yr 0.15 lb/MMBtu Fuel Use 1.2. NA 42.57 MMscf/yr NA fuel Ma.Ver or / Fuel Allocation (see Appendix H) Monthly Hours of Operation 1.3. NA NA NA Recordkeeping Monthly Opacity 1.4. Less Than or Equal to 20% NA Fuel Restriction At All Times Btu Content 1.5. NA NA NA ASTM Analysis Method Semi - Annually Emissions of Nitrogen Oxides, Carbon Monoxide and Volatile Organic Compounds from each engine shall not exceed the limitations stated above (Colorado Construction Permits 93 WE 157- (1-4)). Emissions shall be calculated by the end of the subsequent month using the listed compliance emission factors (EF) in the following equation: Lbs/month = [EF x monthly fuel use (MMscf/month) x heat content of gas (Btu/scf)] A twelve-month rolling total shall be maintained for demonstration of compliance with annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months data. Emission measurements of nitrogen oxides (NO,) and carbon monoxide (CO) from each engine shall be conducted quarterly using a portable flue gas analyzer as specified in Condition 11.1. Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 North American Resources Company Ft. Lupton Plant Page 6 1.2. Fuel consumption for each engine shall not exceed the limitations above (Colorado Construction Permits 93WE157-(1-4)). Within the first seven days of every month, the fuel meter shall be read and recorded.t. • 6f fuel use shall be made using the methods detailed in Appendix H of this permit. ' fuel use shall be measured no more than twelve (12) hours from the time that i 4►.ere- is o feet run time hours have been recorded. A twelve month rolling total shall be maintained for w.e 1 tr s Peu Q' +o +Lem demonstration of compliance with the annual limitations. Each month a new twelve month total ev.zp.e, 4-1"eshall be calculated using the previous twelve months data. altoca.�'o^ I f neede6, hou r/ 1.3. , Hours of operation for each engine shall be recorded on a monthly basis for use in fuel allocation calculations. 1.4. Opacity of emissions from each engine shall not exceed 20 % (Colorado Construction Permits 93 WE 157-(1-4)). In the absence of evidence to the contrary, compliance with the 20% opacity limit shall be presumed whenever natural gas is used as fuel for these engines. 1.5. The Btu conte t of e t;t ed to fuel t ese - n ine hall be determined semi-annually using A M Analysis Method D194 or equivalent. alculation of monthly emissions outlined under Condition 1.1 shall be based on the most recent BTU analysis. The BTU Content shall be based on the lowest gross heatirlgvalue of the fgel. dry' t,,;cp -- LA", t � tA-(1- d -1 (? 1.6. These engines shall be operated and maintained in accordance with manufacturer's recommendations at all times, including periods of start-up, shutdown, and malfunction. Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 6. North American Resources Company Ft. Lupton Plant Page 14 5.7. The incinerator must be operated by trained personnel (Colorado Construction Permit 95WE683). Compliance with this requirement will be monitored by maintaining records of personnel trained to operate the incinerator. The name of the personnel operating the incinerator will be recorded for each charge of waste fed to the incinerator. 5.8. The incinerator shall be operated and maintained in accordance with manufacturer's recommendations at all times, including periods of start-up, shutdown and malfunction. S012 - Ajax 2 -Cycle Lean Burn (550 HP) I"^' Parameter Permit • Condition Number Limitations Short Term Long Term Compliance Emission Factor Monitoring Method Interval NOx 6.1. NA 16.8 tons/yr 0.543 lb/MMBtu Recordkeeping, Monthly, CO NA 20.1 tons/yr 0.3 lb/MMBtu Calculations and Portable Quarterly VOC NA 6.7 tons/yr 0.15 lb/MMBtu Monitoring,/ Fuel Use 6.2. NA 47.24 MMscf/yr NA eI I .e4e - or Fuel Allocation (See Appendix H) Monthly Hours of Operation 6.3. NA NA . NA Recordkeeping Monthly Opacity 6.4. Less Than or Equal to 20% NA Fuel Restriction At All Times Btu Content 6.5. NA NA NA ASTM Analysis Method Semi - Annually 6.1. Emissions of Nitrogen Oxides, Carbon Monoxide and Volatile Organic Compounds shall not exceed the limitations stated above (Colorado Construction Permit 97WE0722). Emissions shall be calculated by the end of the subsequent month using the listed compliance emission factors (EF) in the following equation: Lbs/month = [EF x monthly fuel use (MMscf/month) x heat content of gas (Btu/scf)] A twelve-month rolling total shall be maintained for demonstration of compliance with annual Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 North American Resources Company Ft. Lupton Plant Page 15 limitations. Each month, a new twelve month total shall be calculated using the previous twelve months data. Emission measurements of nitrogen oxides (NO,) and carbon monoxide (CO) from each engine shall be conducted quarterly using a portable flue gas analyzer as specified in Condition 11.1. 6.2. Fuel consumption shall not exceed the limitations above (Colorado Construction Permit 97WE0722). Within the first seven days of every month, the fuel meter shall be read and ft recordeden of fuel use shall be made using the methods detailed in Appendix H of this TV +�e�e . s a permit. Tel use shall be measured no more than twelve (12) hours from the time that run time hours have been recorded. A twelve month rolling total shall be maintained for ft& rrc+e• specific demonstration of compliance with the annual limitations. Each month a new twelve month total 4-0 44.e. e•..c, -Kcy% all ocAkeshall be calculated using the previous twelve months data. •, .4, k cs 6.3. Hours of operation shall be recorded on a monthly basis for use in fuel allocation calculations. A 6.4. Opacity of emissions shall not exceed 20 % (Colorado Construction Permit 97WE0722). In the absence of evidence to the contrary, compliance with the 20% opacity limit shall be presumed whenever natural gas is used as fuel for these engines. 6.5. The Btu content of the natural gas used to fuel this engine shall be determined semi-annually using ASTM Analysis Method D1945 or equivalent. Calculation of monthly emissions outlined under Condition 6.1 shall be based on the most recent BTU analysis. The BTU Content shall be based on the lowest gloss he in value of the fuel. d•,y 1"`9^ gV 6.6. This engine shall be operated and maintained in accordance with manufacturer's recommendations at all times, including periods of start-up, shutdown, and malfunction. Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 Ifr-t.ete„o .Furl mere• 5peci f;c 4 4k& � `+ eaeN ansco. oN Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 7. North American Resources Company Ft. Lupton Plant Page 16 S013 - Born Amine Unit Heater (10.7 MMBtu/hr) • Parameter Permit Condition Number Limitations Short Term Long Term Compliance Emission Factor Monitoring Method Interval NOx 7.1. NA 6.8 tons/yr 100 lb/MMscf Recordkeeping Monthly CO NA 5.7 tons/yr 84 lb/MMscf and Calculations Fuel Use 7.2. NA 128 MMscf/yr NA fue► A t4er or Fuel Allocation (See Appendix H) Monthly Hours of Operation 7.3. NA NA NA Recordkeeping Monthly Opacity 7.4. Less Than or Equal to 20% NA Fuel Restriction At All Times 7.1. Emissions of Nitrogen Oxides and Carbon Monoxide shall not exceed the limitations stated above (Colorado Construction Permits 97WE0723 as modified under the provisions of Section I Condition 1.3). Emissions shall be calculated by the end of the subsequent month using the listed compliance emission factors (EF) and the monthly fuel use. A twelve-month rolling total shall be maintained for demonstration of compliance with annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months data. 7.2. Fuel consumption shall not exceed the limitations above (Colorado Construction Permit 97WE0723). Within the first seven days of every month, the fuel meter shall be read and recorded Alloeation of fuel use shall be made using the methods detailed in Appendix H of this permit. Thi fuel use shall be measured no more than twelve (12) hours from the time that run time hours have been recorded. A twelve month rolling total shall be maintained for demonstration of compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. If "ceded, kowrs 7.3. ,, Hours of operation shall be recorded on a monthly basis for use in fuel allocation calculations. 7.4. Opacity of emissions shall not exceed 20 % (Colorado Construction Permit 97WE0723). In the absence of evidence to the contrary, compliance with the 20% opacity limit shall be presumed whenever natural gas is used as fuel for this unit. Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 8. North American Resources Company Ft. Lupton Plant Page 17 7.5. This unit shall be operated and maintained in accordance with manufacturer's recommendations at all times, including periods of start-up, shutdown, and malfunction. S014 - Born Natural Gas Fired Hot Oil Heater (32 MMBtu/hr) Parameter Permit Condition Number Limitations Short Term Long Term Compliance Emission Factor Monitoring Method Interval NOx 8.1. NA 14.2 tons/yr 100 lb/MMscf Recordkeeping Monthly CO NA 11.9 tons/yr 84 lb/MMscf and Calculations Fuel Use 8.2. NA 270 MMscf/yr NA Fuel Allocation (See Appendix H) Monthly Hours of Operation 8.3. NA NA NA Recordkeeping Monthly NSPS Dc 8.4. NA NA NA Fuel Restriction At All Times Opacity 8.5. Less Than or Equal to 20% NA Fuel Restriction At All Times 8.1. Emissions of Nitrogen Oxides and Carbon Monoxide shall not exceed the limitations stated above (Colorado Construction Permit 97WE0724 as modified under the provisions of Section I Condition 1.3). Emissions shall be calculated by the end of the subsequent month using the listed compliance emission factor (EF) and the monthly fuel use. A twelve-month rolling total shall be maintained for demonstration of compliance with annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months data. 8.2. }1x.t is no .fs.el .tie4er specuf:c }o }6t. Intaitr, 4.6e," allota+oet Fuel consumption shall not exceed the limitations above (Colorado Construction Permit 97WE0724 as modified under the provisions of Section I Condition l.3).yithin the first seven days of every month, the fuel meter shall be read and _ recorded. Aalecatiun. of fuel use shall be made using the methods detailed in Appendix H of this permit. Thg fuel use shall be measured no more than twelve (12) hours from the time that run time hours have been recorded. A twelve month rolling total shall be maintained for demonstration of compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 9. North American Resources Company Ft. Lupton Plant Page 18 I{ ne.cdec0, fours 8.3. Hours of operation shall be recorded on a monthly basis for use in fuel allocation calculations. 8.4. This unit is subject to 40 CFR 60 Standards of Performance for New Stationary Sources, Subpart Dc Standards of Performance for Small Industrial -Commercial -Institutional Steam Generating Units as adopted by reference in Colorado Regulation No. 6, Part A, Subpart Dc. The source must certify annually that only natural gas was used as fuel for this unit. 8.5. Opacity of emissions shall not exceed 20 % (Colorado Construction Permit 97WE0724). In the absence of evidence to the contrary, compliance with the 20% opacity limit shall be presumed whenever natural gas is used as fuel for this unit. 8.6. This unit shall be operated and maintained in accordance with manufacturer's recommendations at all times, including periods of start-up, shutdown, and malfunction. S015 -S017 - Three Ajax 2 -Cycle Lean Burn ICEs (550 HP each) Parameter Permit Condition Number Limitations for each engine Short Term Long Term Compliance Emission Factor Monitoring Method Interval NOx 9.1. NA 10.6 tons/yr 0.543 lb/MMBtu Recordkeeping, Monthly, CO NA 10.6 tons/yr 0.30 lb/MMBtu Calculation and Portable Quarterly VOC NA 5.3 tons/yr 0.15 lb/MMBtu Monitoring Fuel Use 9.2. NA 38.3 MMscf/yr NA Fael Moo. "Joke. or/ Fuel Allocation (See Appendix H) Monthly Hours of Operation 9.3. NA NA NA Recordkeeping Monthly Opacity 9.4. Less Than or Equal to 20% NA Fuel Restriction At All Times Btu Content 9.5. NA NA NA ASTM Analysis Method Semi - Annually 9.1. Emissions of Nitrogen Oxides, Carbon Monoxide and Volatile Organic Compounds from each Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 North American Resources Company Ft. Lupton Plant Page 19 9.2. If +ere_ is rnor fuAL.l v.. 4.4.e r Specific 4 +ke. nl%occ or engine shall not exceed the limitations stated above (Colorado Construction Permits 97WE0725, 97WE0726 and 97WE0727). Emissions shall be calculated by the end of the subsequent month using the listed compliance emission factors (EF) in the following equation: Lbs/month = [EF x monthly fuel use (MMscf/month) x heat content of gas (Btu/scf)] A twelve-month rolling total shall be maintained for demonstration of compliance with annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months data. Emission measurements of nitrogen oxides (NO„) and carbon monoxide (CO) from each engine shall be conducted quarterly using a portable flue gas analyzer as specified in Condition 11.1. Fuel consumption for each engine shall not exceed the limitations above (Colorado Construction Permits 97WE0725, 97WE0726 and 97WE0727).ylthin the first seven days of every month, the fuel meter shall be read and recorded., of fuel use shall be made using the methods detailed in Appendix H of this permit. Th& el use shall be measured no more than twelve (12) hours from the time that run time hours have been recorded. A twelve month rolling total shall be maintained for demonstration of compliance with the annual limitations. Each month a new twelve month tot Y'shall be calculated using the previous twelve months data. i f ncedcd, keur s 9.3. Hours of operation for each engine shall be recorded on a monthly basis for use in fuel allocation calculations. 9.4. Opacity of emissions from each engine shall not exceed 20 % (Colorado Construction Permits 97WE0725, 97WE0726 and 97WE0727). In the absence of evidence to the contrary, compliance with the 20% opacity limit shall be presumed whenever natural gas is used as fuel for these engines. 9.5. The Btu content of the natural gas used to fuel these engines shall be determined semi-annually using ASTM Analysis Method D1945 or equivalent. Calculation of monthly emissions outlined under Condition 9.1 shall be based on the most recent BTU analysis. The BTU Content shall be based on the lowest gross living value of the fuel. P\V l 9.6. These engines shall be operated and maintained in accordance with manufacturer's recommendations at all times, including periods of start-up, shutdown, and malfunction. Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 North American Resources Company Ft. Lupton Plant Page 20 10. S018 -S019 - Two Caterpillar 4 -Cycle Lean Burn ICEs (980 HP each) Parameter Permit Condition Number Limitations for each engine Short Term Long Term Compliance Emission Factor Monitoring Method Interval NOx 10.1. NA 18.9 tons/yr 0.585 lb/MMBtu Recordkeeping, Calculation and Monthly, Quarterly CO NA 18.9 tons/yr 0.492 lb/MMBtu Portable Monitoring VOC NA 9.5 tons/yr 0.18 lb/MMBtu Fuel Use 10.2. NA 63.4 MMscf/yr NA Fact Mt4t.- or Fuel Allocation (See Appendix H) Monthly Hours of Operation 10.3. NA NA NA Recordkeeping Monthly Opacity 10.4. Less Than or Equal to 20% NA Fuel Restriction At All Times Btu Content 10.5. NA NA NA ASTM Analysis Method Semi - Annually r 10.1. Emissions of Nitrogen Oxides, Carbon Monoxide and Volatile Organic Compounds from each engine shall not exceed the limitations stated above (Colorado Construction Permits 97WE0728 and 97WE0729). Emissions shall be calculated by the end of the subsequent month using the listed compliance emission factors (EF) in the following equation: Lbs/month = [EF x monthly fuel use (MMscf/month) x heat content of gas (Btu/scf)] A twelve-month rolling total shall be maintained for demonstration of compliance with annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months data. Emission measurements of nitrogen oxides (NO„) and carbon monoxide (CO) from each engine shall be conducted quarterly using a portable flue gas analyzer as specified in Condition 11.1. 10.2. Fuel consumption for each engine shall not exceed the limitations above (Colorado Construction Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 Air Pollution Control Division Colorado Operating Permit Permit ti 99OPWE207 If }hue vno spec: f;c •ko }4c e."3414 44,1 11. 10.3. North American Resources Company Ft. Lupton Plant Page 21 Permits 97WE0728 and 97WE0729). Within the first seven days of every month, the fuel meter shall be read and recorded, 6 fuel use shall be made using the methods detailed in Appendix H of this permit. The fuel shall be measured no more than twelve (12) hours from /me time that run time hours have been recorded. A twelve month rolling total shall be aintained for demonstration of compliance with the annual limitations. Each month a new twelve month tot shall be calculated using the previous twelve months data. l ...text -cc hours Hours of operation for each engine shall be recorded on a monthly basis for use in fuel allocation calculations. 10.4. Opacity of emissions from each engine shall not exceed 20 % (Colorado Construction Permits 97WE0728 and 97WE0729). In the absence of evidence to the contrary, compliance with the 20% opacity limit shall be presumed whenever natural gas is used as fuel for these engines. 10.5. The Btu content of the natural gas used to fuel these engines shall be determined semi-annually using ASTM Analysis Method D1945 or equivalent. Calculation of monthly emissions outlined under Condition 10.1 shall be based on the most recent BTU analysis. The BTU Content shall be based on the lowest gross hating value of the fuel. dry, k;9a �..V 10.6. These engines shall be operated and maintained in accordance with manufacturer's recommendations at all times, including periods of start-up, shutdown, and malfunction. Portable Monitoring Emission measurements of nitrogen oxides (NO,) and carbon monoxide (CO) from each engine shall be conducted quarterly using a portable flue gas analyzer. Calibration of the analyzer shall be conducted according to manufacturer's instructions. Results of the portable flue gas analyzer tests shall be used to monitor the compliance status of each engine. For comparison with an annual or short term emissions limit, the results of the tests shall be converted to a lb/hr basis arid multiplied by the allowable operating hours in the month or year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever applies. An exceedance of either the NO, or CO emission limitation during the initial portable flue gas analyzer test shall require a subsequent portable analyzer test indicating compliance with both the NO, and CO emission limitations within 14 calendar days of the initial test. Calibration gases shall be used to calibrate the portable analyzer for all tests conducted subsequent to the initial test. Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 Air Pollution Control Division Colorado Operating Permit Fuel Allocation APPENDIX H Fuel Allocation Appendix -H — Page 1 *The methods outlined will be used to calculate fuel use for Uni s S001- S004, S008, S012 -S019 If daiw .E.e�. a. :nd:.r:duinl .f,,,.l mekee 15 A64- a4,;I,hic. A) FUEL ALLOCATION TO INDIVIDUAL UNITS For Each Piece of Equipment, Fuel Use = [Fuel Design Ratel [Hrs. of Operation] X [Facility Fuel Use for Month] [Sum of Numerator for Each Engine] Unit -Number Fuel Design Rate S001 4.01 MMBtu/hr S002 4.01 MMBtu/hr S003 4.01 MMBtu/hr 8004 4.01 MMBtu/hr S008 6.11 MMBtu/hr S012 4.46 MMBtu/hr S013 10.7 MMBtu/hr Unit Number , Fuel Design Rate S014 32 MMBtu/hr S015 4.46 MMBtu/hr S016 4.46 MMBtu/hr S017 4.46 MMBtu/hr S018 7.38 MMBtu/hr S019 7.38 MMBtu/hr *Allocated Fuel Use shall be determined within the first seven days of each month based on the monthly hours of operation for each listed piece of equipment from the previous month. Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 Please process the attached permit modification for 99OPWE207, Fort Lupton Plant under the minor modification procedures outlined in Colorado Regulation 3, Part C, Section X. To the best of my knowledge and understanding, these documents meet the criteria outlined in Regulation 3, Part C, Section X.D. for processing as a minor permit modification. James J. Benner Vice President, Gathering Services EnCana Oil & Gas (USA) Inc. (formerly North American Resources Company) //-/Y--v 2�- Date ENCANA_ September 30, 2003 Mr. Geoffrey Drissel Colorado Department of Public Health & Environment APCD-SS-BI 4300 Cherry Creek Drive South Denver, CO 80246-1530 RE: Renewal and Minor Modification of Operating Permit 99OPWE207 for the Fort Lupton Plant now owned by EnCana Gathering Services (USA) Inc. Dear Mr. Drissel: Attached is a timely and complete application for renewal of Title V permit 99OPWE207 for EnCana's Fort Lupton Plant. No changes are being requested for the operating permit except as identified in the attached documentation. In addition to the renewal forms, also attached is a complete application to include the new air -assisted flare (02WE0927) in the Title V permit. This modification application is being submitted within the 12 -month time frame. Please process this application as a minor permit modification in accordance with the provisions of Regulation 3, Part C, Section X.D. 1. Description of the changes. Last December, 2002, EnCana began operation of its new air -assisted flare (S021). This unit replaced the utility flare (S008). Changes in emissions are as follows: NOx CO VOC S008 (old flare) -2.68 -2.25 --- S021 (new flare) +3.5 +6.8 +1.2 Net change +0.82 +4.55 +1.2 The applicable regulations are included in Section II, 11. of the draft permit. EnCana Gathering Services, Inc. 16157 Weld County Road 22 • Ft. Lupton, Colorado 80621 Telephone: 303-659-7711 • Facsimile: 303-655-4439 2. The suggested draft permit. An annotated version of the current operating permit is attached. This documentation incorporates the requirements of construction permit 02WE0927 as well as the changes we requested in modification applications submitted on August 22, 2002 and on November 14, 2002. 3. Certification by a responsible official that the proposed modification meets the criteria for use of the minor permit modification procedures is attached. 4. It is our understanding that the Division is responsible for supplying forms to notify EPA and affected states of this permit revision. 5. All applicable regulations have been enumerated in construction permit 02WE0927. There are no new increases in NOx or CO emissions which have not already been modeled during the processing of the construction permit. 6. A copy of the most current APEN (October 9, 2002) is attached. Please issue this permit to EnCana Gathering Services (USA) Inc. The documentation substantiating the change from North American Resources Company to EnCana has been previously submitted. Please refer any questions on this submittal to Maggie Scher of Air Basics. She may be reached at (303) 329-9295 or at Ma.gicairbasics(u aol.com. Thank you. Sincerely, Wire4 esse Wood Acting Vice President Application for Renewal and Modification of Operating Permit 99OPWE207 Ft. Lupton Plant Contents Form 100 Form 101 — Updated Plot Plan Form 102 — Updated Process Description Form 102A — and APEN for new air -assisted Flare Form 102B — Updated List of Insignificant Activities Forms 200 - 604 for new, air -assisted Flare Form 603 — Updated Plant Totals Forms 800 (signed) Requested Changes to Permit Suggested Draft Permit (changed pages only) Certification by Responsible Official (minor modification) Operating Permit Application FACILITY IDENTIFICATION Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE FORM 2000-100 Rev 06-95 1. Facility name and Name mailing address Street or Route City, State, Zip Code EnCana Gathering Services (USA) Inc. 1313 Denver Avenue, Building No. 1 Fort Lupton, CO 80621 2. Facility location Street Address Fort Lupton Plant: 16157 Weld County Road 22 (No P.O. Box) City,County, Zip Code Fort Lupton, Weld County, 80621 3. Parent corporation Name Street or Route City, State, Zip Code Country (if not U.S.) EnCana Oil & Gas (USA) Inc. 950 17th Street, Suite 2600 Denver, CO 80202 4. Responsible Name official Title Telephone Jesse Wood Acting Vice President (303) 623-2300 5. Permit contact person Name Title (If Different than 4) Telephone Dena Lund DJ Field Superintendent (303) 659-7740 6. Facility SIC code: 1311 7. Facility identification code: CO 1230319 8. Federal Tax I. D. Number: _ _ 9. Primary activity of the operating establishment: Natural Gas Plant 10. Type of operating permit New • Modified • Renewal 11. Is the facility located in a "nonattainment" area: Yes • No If "Yes", check the designated "non -attainment" pollutant(s): Carbon Monoxide Ozone 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. 1 Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division FACILITY PLOT PLAN Facility Name: Fort Lupton Plant Facility Identification Code: CO _ 1230319 _ FORM 2000-101 Rev 06-95 The operating permit must be prepared and submitted on forms supplied by the Division. Use of this form is required for all operating permit applications. The Division will not consider or act upon your application unless each form used has been entirely completed. Completion of the information in the shaded area of this form is optional. Use "NA" where necessary to identify an information request that does not apply and is not in the optional shaded area. In order for a comprehensive air quality analysis to be accomplished, a facility plot plan MUST be included with the permit application. Drawings provided must fit on generic paper sizes of 8 1/2" X 1 1 ", 8 1/2" X 14" or 1 1 " X 15", as appropriate to display the information being provided. Include the facility name and facility identification code on all sheets. For facilities with large areas, sketches of individual buildings, on separate drawings, may be needed to allow easy identification of stacks or vents. Insignificant activities do not need to be shown. • 1. A plant layout (plan view) including all buildings occupied by or located on the site of the facility and any outdoor process layout. maximum 'laiJc llt stick liciq.l 'i.. • 3. The location and coded designation of each stack. Please ensure these designations correspond to the appropriate stacks listed on the other permit forms in this application. The drawings need not be to scale if pertinent dimensions are annotated, including positional distances of structures, outdoor processes and free standing stacks to each other and the property boundaries. Pmilerl} ounuia ✓ kries. • 5. Identify direction "North" on all submittals. Attached Are there any outdoor storage piles on the facility site with air pollution emissions that need to be reported? Yes • No If "Yes", what is the material in the storage pile(s)? Are there any unpaved roads or unpaved parking lots on the facility site? • Yes No List the name(s) of any neighboring state(s) within a 50 mile radius of your facility: None 2 C, (J. (s.w C.... t.... C 1•.. C(.f. .........--- — ..-- .. • -4_,N i . , ... ,.., . ,.., T .... .., , ,,, . ,- X ' ' �' ""' y "�� FT. LUPTON GAS PROCESSING PLANT _ ,, ,�(_= _ '_.L}.... ._ I I is, (I. (..m C,�. `r..W r ° --•-`pI+ (II.m C 1.m i.�� r E r J �r _ *' ODOOQQ Gir1.:f•'�/ .� (y}��am'( ��.�� .�.m 2 _L jWJ.. � r rr'�r .p ---C.,n;C _-...r. 1' r r 1 r 1 r r r r , t 1 r r r r r 1 r r / ' �1 r ..•a rv-----{'7-71—k 7-r-r-r''- fir' �.J2....1 1 1 I 1 O 1 I 1 I H I' / ,a ""•'O 0 0 0 K 1z �r ¢ w I .0p @9Y.,[1 _ ^i ��? [ n o .mom t ti } I ± G �'',' /�. -.......� —' _I I I I I r 1 1 } '...,.,,..�, 1 r 1 r r 1 r r 1 1 . 1 r r , I '„ • i ,,, * rte, .. a wp > 1...1-1-.L. ..- --- WEi6 COun1Y hQW 22 • • Fuaal-ra ..1i — (22CC p.vlbyt- OD, W(viSlMi 11.110E1,c ce p QW1r6EKCII♦4SCCMtES.KIC [I.YR4[r.14 1.1..1...(. i ..r(.1 y.C.0 1.-- ____ ...no--....W..W.. 41/.. .,.,. MIN WM . VIVO, ru BA-97097 F1. LUPTON GAS PROCESSING PLAN[ .....w+o.a--.st..0O•X.0O•X. "1". Of car .1C W...4• PLOT PLAN nuw• VW. � w N...eau. v...WS( MM.1 ..CD.C...c1nov.K.. ' 1.K •7� WELD COUNTY. COLORADO —.��--..._._.—,_._...._ —_ r i1-»-1ws-i Y,i..(s( a/1y.s cC ICKi MpgWAC wlvP.(I(1r1p [ya.'CRLCR t RSSOLUrEs.DC _ _ .[ rKu .W pr _. �- -' _-- . n 1141 1'^"'1... Q Ma C mrLA SCALE DELTOID 1 DRUG NO 10-00-001 1 I al'I I REV Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division SOURCE AND SITE DESCRIPTIONS Facility Name: Fort Lupton Plant Facility Identification Code: CO _ 1230319 _ FORM 2000-102 Rev 06-95 The operating permit must be prepared and submitted on forms supplied by the Division. Use of this form is required for all operating permit applications. The Division will not consider or act upon your application unless each form used has been entirely completed. Completion of the information in the shaded area of this form is optional. Use "NA" where necessary to identify an information request that does not apply and is not in the optional shaded area. 1. Briefly describe the existing Unit(s) to be permitted. Attach copies of Form 2OOO-7OO as needed to provide the information. Process flowsheets or line diagrams showing major features and locations of air pollution control equipment can be most effective in showing the location and relationships of the units. Providing mass flowrates/balances at critical points on the diagrams is very helpful when developing an understanding of the processes involved. This facility consists of a natural gas processing plant defined under Standard Industrial Classification 1311. Raw natural gas is received in the Ft. Lupton plant and goes through one of two cryogenic processing trains. There are a total of eleven (11) engines for inlet compression, refrigeration and residue compression. An amine unit fired by a heater removes CO2 and H2S. Two fractionation trains separate out ethane, propane. butane and natural gasoline. Heat to the fractionation plant is provided by a natural gas fired hot oil heater. In addition, the plant has a flare, fugitive VOC emissions from miscellaneous equipment at the plant, and an incinerator used for the combustion of oily solid waste. 2. Site Location and Description (Include instructions needed to drive to remote sites not identified by street address From Fort Lupton, follow US 85 north approximately 4 miles to Weld County Road 22. Turn right, cross the railroad tracks and continue east along WCR 22 approximately 3 miles. Ft. Lupton plant is on the left (north) side of the road. 3. Safety Equipment Identify safety equipment required for performing an inspection of the facility: Protection • Hard Hat • Safety shoes is Hearing Protection Gloves Other, specify Flame -resistant clothing_ Safety glasses 3 Operating Permit Application SOURCE DESCRIPTION - APENS Colorado Department of Public Health and Environment Air Pollution Control Division Facility Name: Fort Lupton Plant FORM 2000-102A Rev 06-95 Facility Identification Code: CO _1230319 _ _ NOTE: Each new or updated Air Pollutant Emission Notice (APEN) submitted must be accompanied by payment of $100 per APEN. 1. For each emission unit enclose a copy of the most current complete Air Pollutant Emission Notice (APEN) on file with the Division. If the most current APEN was not completely and correctly filled out, a revised APEN is required. List an APEN number, date, and a brief description of the unit/process covered by the APEN. (No filing fees are needed for these copies) APEN # 02WE0927 dated October 9, 2002 for the Flare Industries Air -assisted Flare (attached) 2. No APEN exists for an emission unit. List the new APEN and the appropriate descriptive information here. Submit the APEN with a construction permit application. New APEN and permit application submitted with this application OR under separate cover to Construction Permits Section 3. A revised APEN was prepared and enclosed for an emission unit. List the APEN and the appropriate descriptive information here. A revised APEN is needed where a significant increase in emissions has occurred, or is planned; or a major modification of the unit has occurred or is planned; or the existing information needs correction or completion. A construction permit application may need to be submitted. Revised APEN submitted as part of this application: Yes No Filing Fee Enclosed New permit application enclosed: Yes No Permit modification application enclosed: Yes No NOTE: Use additional copies of Form 2000-700 as reeded to provide the above information. 4 AIR POLLUTANT EMISSION NOTICE PERMIT No.: New_ AIRS ID.: 123 / 0319 / 021? FIRM NAME EnCana Oil & Gas (USA) Inc. MAIL ADDRESS 1313 Denver Avenue, Building #1_Fort Lupton STATE: CO ZIP: 80621 PLANT NAME & LOCATION Fort Lupton Plant: 16157 Weld County Road 22, Fort Lupton, CO 80621 COUNTY: Weld REQUEST PORTABLE SOURCE PERMIT HOME -BASE FOR PORTABLE SOURCE PERSON TO CONTACT REGARDING THIS INFORMATION Jeff Reale TITLE Senior Operations Superintendent _PHONE (303) 659-7740 GENERAL DESCRIPTION OF THIS PLANT'S FUNCTION Natural gas processing plant A. GENERAL INFORMATION Normal Operation of This Source Process Seasonal Throughput (% of Annual) ADDITIONAL INFORMATION OR REMARKS: Hours/Day 24 Days/Week 7 Weeks/Year 52 Dec -Feb 25 Mar -May 25 Jun -Aug 25 Sep -Nov 25 B. STACK OR VENT INFORMATION (Identify below which stack if plant has two or more: refer to attached sketch of plant layout) Height t O O R Diameter I. S ft Temperature °F Flow Rate ACFM I Velocity ft/min Moisture % Plant ID No, for Stack New Flare C. FUEL INFORMATION Description of Combustion Unit Design Input Rate (10' B'I`tJ/hr) Kind of Fuel Burned Annual Fuel Consumption Fuel Heating Value: (BTU/scf) Percent by Weight Seasonal Fuel Use (% of Annual Use) Space I (% Ant Requested level Actual level (Data year level) Sulfur Ash Dec -Feb Mar -May Jun -Aug Sep -Nov Flare Industries Air -assisted Flare Natural Gas 42.04 MMSCF-4 1047.7 0 0 25 25 25 25 Make/Model: Natural Gas 2.98 MMSCF ' - 1210.6 - 0 0 25 25 25 25 Serial No. Natural Gas 0.56 MMSCF 2000.0 0 0 25 25 25 25 D. PROCESS INFORMATION Description of Processing Unit Raw Materials Used ' Raw Materials -Annual Consumption Design Process Rate (Specify Units/Hour) Finished Product Finished Product -Annual Output Description Requested level Actual level (Datayear level) Description Requested level Actual level (Data year leve Make/Model: - Serial No.: (E. POLLUTION CONTROL EQUIPMENT Overall ESTIMATED EMISSIONS (TONS/YEAR) AT THROUGHPUTS REQUESTED ABOVE ACTUAL EMISSIONS (from data year) ESTIMATION METHOD CHECK ALL BOXES THAT APPLY ■ New or previously unreported sources O Requesting modification of existing permit t$ O Change in emissions, throughputs or equipment $ O Transfer of ownership (List previous owner in REMARKS section of box A.) $ O Previous APEN is expiring $ O Request for Emission Reduction Credit t$ ❑ (Specify) Pollutant Type of Control Equipment Collection Efficiency CONTROLLED UNCONTROLLED _ Primary Secondary Particulate PMa _ SO, NO, 3.41 3.41 VOC 1.17 1.17 CO 6.72 6.72 _ PLEASE USE POLLUTANT POLLUTANTS APCD NON -CRITERIA ADDENDUM FORM OR POLLUTANTS REPORTABLE AM TO REPORT SUCH NOT LISTED ABOVE. O CHECK HERE IF YOU WISH THE DIVISION TO CALCULATE YOUR * Complete all applicable portions of APEN t Complete ' Requested Level' values for permit limits $ Complete all information above box A, and those remaining portions which reflect cftart5es EMISSIONS. SEE "EMISSION ESTIMATES" INSTRUCTIONS ON BACK. ' Signature of Person Legally Authorized to Supply Data: />�� DATEE/ // pX Z,. YEAR FOR WHICH THE ACTUAL DATA APPLIES: 2003 Typed Name and Tide: Jeff Reale, S or Operations Su ndent T Date source began or will begin operation: 2003 s A $119.96 FILING FEE IS REQUIRED FOR EACH NOTICE FILED. 'Send completed forms with fees to: Colorado Dept. of Public Health & Environment APEN N_1 o Air Pollution Control Division 4300 Cherry Creek Drive South, APCD-SS-B1 For Information, Cal Denver, Colorado 80246-1530 (303) 692-3130 THIS NOTICE IS VALID FOR FIVE YEARSe prior to this iration date whenever a permit limitation must be e , w tenever centre' equipment is changed, and annually whenever a significant emission change occurs. For specific details see Regulation 3, Part A, * II.C.1. E-MAIL ADDRESS: Jeff.RealEnCana.com Operating Permit Application SOURCE DESCRIPTION - INSIGNIFICANT ACTIVITIES Colorado Department of Public Health and Environment Air Pollution Control Division Facility Name: Fort Lupton Plant Facility Identification Code: CO _ 1230319 FORM 2000-102B Rev 06-95 NOTE: The operating permit must be prepared and submitted on forms supplied by the Division. This is a supplemental form for use only when necessary to provide complete information in the operating permit application. The Division will not consider or act upon your application unless each form used has been entirely completed. Certain categories of sources and activities are considered to be insignificant contributors to air pollution and are listed below. A source solely comprised of one or more of these activities is not required to obtain an operating permit pursuant to Regulation 3, unless the source's emissions trigger the major source threshold as defined in Part A, Section I.B.58 of Regulation 3. For the facility, mark all insignificant existing or proposed air pollution emission units, operations, and activities listed below. ■ (a) noncommercial (in-house) experimental and analytical laboratory equipment which is bench scale in nature including quality control/quality assurance laboratories, process support laboratories, environmental laboratories supporting a manufacturing or industrial facility, and research and development laboratories. (b) research and development activities which are of a small pilot scale and which process less than 10,000 pounds of test material per year. (c) small pilot scale research and development projects less than six months in duration with controlled actual emissions less than 500 pounds of any criteria pollutant or 10 pounds of any non -criteria reportable pollutant. Disturbance of surface areas for purposes of land development, which do not exceed 25 contiguous acres and which do not exceed six months in duration. (This does not include mining operations or disturbance of contaminated soil). ■ Each individual piece of fuel burning equipment, other than smokehouse generators and internal combustion engines, which uses gaseous fuel, and which has a design rate less than or equal to 5 million Btu per hour. (See definition of fuel burning equipment, Common Provisions Regulation). Petroleum industry flares, not associated with refineries, combusting natural gas containing no H2S except in trace (less than 500 ppmw) amounts, approved by the Colorado Oil and Gas Conservation Commission and having uncontrolled emissions of any pollutant of less than five tons per year. ■ Chemical storage tanks or containers that hold less than 500 gallons, and which have a daily throughput less than 25 gallons. Landscaping and site housekeeping devices equal to or less than 10 H.P. in size (lawnmowers, trimmers, snow blowers, etc.). • Crude oil or condensate loading truck equipment at crude oil production sites where the loading rate does not exceed 10,000 gallons per day averaged over any 30 day period. Chemical storage areas where chemicals are stored in closed containers, and where total storage capacity does not exceed 5000 gallons. This exemption applies solely to storage of such chemicals. This exemption does not apply to transfer of chemicals from, to, or between such containers. Oil production wastewater (produced water tanks), containing less than 1% by volume crude oil, except for commercial facilities which accept oil production wastewater for processing. (Continues on other side) 5 • Storage of butane, propane, or liquified petroleum gas in a vessel with a capacity of less than 60,000 gallons, provided the requirements of Regulation No. 7, Section IV are met, where applicable. • Storage tanks of capacity < 40,000 gallons of lubricating oils. Venting of compressed natural gas, butane or propane gas cylinders, with a capacity of 1 gallon or less. Fuel storage and dispensing equipment in ozone attainment areas operated solely for company -owned vehicles where the daily fuel throughput is no more than 400 gallons per day, averaged over a 30 day period. ■ Crude oil or condensate storage tanks with a capacity of 40,000 gallons or less. Storage tanks meeting all of the following criteria: (i) annual throughput is less than 400,000 gallons; and (ii) the liquid stored is one of the following: (A) diesel fuels 1-D, 2-D, or 4-D; (B) fuel oils #1 through #6; (C) gas turbine fuels 1-GT through 4-GT; (D) an oil/water mixture with a vapor pressure lower than that of diesel fuel (Reid vapor pressure of .025 PSIA). Each individual piece of fuel burning equipment which uses gaseous fuel, and which has a design rate less than or equal to 10 million Btu per hour, and which is used solely for heating buildings for personal comfort. Stationary Internal Combustion Engines which: 0) power portable drilling rigs; or (ii) are emergency power generators which operate no more than 250 hours per year; or (iii)have actual emissions less than five tons per year or rated horsepower of less than 50. Surface mining activities which mine 70,000 tons or fewer of product material per year. A fugitive dust control plan is required for such sources. Crushers, screens and other processing equipment activities are not included in this exemption. • Air pollution emission units, operations or activities with emissions less than the appropriate de minimis reporting level. NOTE: Material Data Safety Sheets (MSDS) do not have to be submitted for any insignificant activities. USE FORM 2000-700 TO PROVIDE AN ITEMIZED LIST OF THE SOURCES OR ACTIVITIES BEING IDENTIFIED AS INSIGNIFICANT ACTIVITIES. DO NOT ITEMIZE INDIVIDUAL PIECES OF LANDSCAPING EQUIPMENT. THE LIST IS NEEDED TO ACCURATELY ACCOUNT FOR ALL ACTIVITIES AT THE FACILITY 6 Operating Permit Application SUPPLEMENTAL INFORMATION Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE FORM 2000-700 09-94 1. Facility name: Fort Lupton Plant 2. Facility identification code: CO 1230319 3. This form supplements Form 2000 - _102B for Emission Unit (e.g. B001, POOL etc.) Additional Information, Diagrams Stabilization heater, 1.02 MMBtu/hr Heater for Process Train 1, 1.09 MMBtu/hr Heater for Process Train 2, 3.17 MMbtu/hr Heater, "1.5 MMBtu/hr Three wastewater tanks, 8400 gallons each Two crude oil tanks, 23,000 gallons each One brine tank, 12,600 gallons One methylethanolamine (MDEA) tank, 8400 gallons One deionized water tank, 4200 gallons Two pressurized butane tanks, 24,600 gallons each Six pressurized raw mix tanks, 30,000 gallons each Six pressurized propane tanks, 30,000 gallons each One pressurized natural gasoline tank, 30,000 gallons Three pressurized butane tanks, 42,000 gallons each Three pressurized natural gasoline tanks, 42,000 gallons each One pressurized natural gasoline tank, 71,000 gallons Item Number Operating Permit Application STACK IDENTIFICATION FORM 2000-200 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Fort Lupton Plant 2. Facility identification code: CO_1230319__ 3. Stack identification code: S021 3a. Construction Permit Number: 02WE0927 4. Exhausting Unit(s), use Unit identification code from appropriate Form(s)2000-300, 301, 302, 303, 304, 305, 306,307 2000-300 X 2000-301 2000-302 2000-303 2000-304 2000-305 2000-306 2000-307 5. Stack identified on the plot plan required on Form 2000-101 • 6. Indicate by checking: ■ This stack has an actual exhaust point. l ite pdranteters are entered in I��n�ti ?:_1 ;: This stack serves to identify fugitive emissions. Skip items 7-13. Go to next form. When stack height Good Engineering Practice(GEP)exceeds 65 meters (Colorado Air Quality Reg 3.A.VIII.D)data entry is required for Item 7.4Aite . ta` e � a- 8 aa'a' ea o a aa-'.ia oaae - ` '• . 3 A r ^ a a i' -i.q..-, P-s e ,T ��'�e i eet) aFra 0 - 8 8a. II as (, CFlv1):' L ,Y 0 atr . �,I a8 18 k7Y A a� o :i a at 8 8 la 8 -a. . a too a s eta G7 -e."s N4'i s r fa a a a Peree �� »?4 _r - Percent y, itliWOAVa one e' D a a IIt3A ize tal i , f0 s. 7 e 'v ;. .w..' ^'t i 8 8 .-0ia 8 �}�.z'a l :o on. °' 8 ASja! 3 8a 8 r - 8-.0 Y # - *****Complete the appropriate Air Permit Application Forms(s)2000-300, 301, 302, 303, 304, ***** 305, 306, or 307 for each Unit exhausting through this stack. 8 Operating Permit Application BOILER OR FURNACE OPERATION FORM 2000-300 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Fort Lupton Plant 2. Facility identification code: CO_1230319_ 3. Stack identification code: S021 4. Unit code: P021 5. Unit description: Flare Industries Air-assisted Flare 6. Seasonal Fuel Dec-Feb: Mar-May: Jun-Aug: Sep-Nov: Usage(%) 25 25 25 25 7. Normal Operation Hours/Day: Days/Week: Hours/Year: 8. Space Heat(%) of Unit 24 7 8760 NA 9. Indicate the boiler/furnace control technology status. ■ Uncontrolled Controlled If the boiler/furnace is controlled, enter the control device number(s) from the appropriate forms: 2000-400 2000-401 2000-402 2000-403 2000-404 2000-405 2000-406 2000-407 10. Furnace type: NA 11. Max continuous rating(mmBTU/hr): NA 12. Manufacturer: Flare Industries 13. Model& Serial#: Model 300 Manual Flame Front Generator Control Systems & Model 245 Pilots; Project#02-552 14. Date first placed in service: December, 2002 Date of last modification: NA 15. Fuels and firing conditions: Primary fuel Backup fuel#1 Backup fuel#2 Fuel name Natural Gas Higher heating value (with units) Maximum sulfur content(Wt.%) Maximum ash content(Wt.%) 3,1�, > v-_'• ice•l ric F r ', u� �` .e. a: 's ''„a.3 H4( "-a �. �f .N '9u3•c _ '�, L, � kr . s w.. . sir. coat IN*V Maximum hourly fuel usage (units/hr.) Actual a Y,s S first �-. .. icy 't rr� �� fi ,emu v,„ .77.7 ***** For this emissions unit, identify the method of compliance demonstration by completing Form 2000-500, DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 and its attachment(s) to this form. ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. 9 Operating Permit Application COMPLIANCE CERTIFICATION - MONITORING AND REPORTING FORM 2000-500 Colorado Department of Public Health and Environment DESCRIPTION OF METHODS USED Rev 06-95 Air Pollution Control Division FOR DETERMINING COMPLIANCE All applicants are required to certify compliance with all applicable air pollution permit requirements by including a statement within the permit application of the methods used for determining compliance. This statement must include a description of the monitoring, recordkeeping, and reporting requirements and test methods. In addition, the application must include a schedule for compliance certification submittals during the permit term. These submittals must be no less frequent than annually, and may need to be more frequent if specified by the underlying applicable requirement or by the Division. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name Fort Lupton Plant 2. Facility identification code: CO _1230319 _ 3. Stack identification code: S021 4. Unit identification code: P021 5. For this Unit the following method(s) for determining compliance with the requirements of the permit will be used (check all that apply and attach the appropriate form(s) to this form). Continuous Emission Monitoring (CEM) Form 2000-501 Pollutant(s): Periodic Emission Monitoring Using Portable Monitors - Form 2000-502 Pollutant(s): Monitoring Control System Parameters or Operating Parameters of a Process - Form 2000-503 Pollutant(s): Monitoring Maintenance Procedures - Form 2000-504 Pollutant(s): Stack Testing - Form 2000-505 Pollutant(s): Fuel Sampling and Analysis (FSA) - Form 2000-506 Pollutant(s): ■ Recordkeeping - Form 2000-507 Pollutant(s): NOx, CO, Fuel rate Other (please describe) - Form 2000-508 Pollutant(s): 6. Compliance certification reports will be submitted to the Division according to the following schedule: Start date: and every months thereafter. (12 month maximum interval) Compliance monitoring reports will be submitted to the Division according to the following schedule: Start date: and every months thereafter. (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5. 10 Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-507 Colorado Department of Public Health and Environment BY RECORDKEEPING Rev 06-95 Air Pollution Control Division Recordkeeping may be acceptable as a compliance demonstration method provided that a correlation between the parameter value recorded and the emission rate of a particular pollutant is established in the form of a curve or chart of emission rate versus parameter values. This correlation may constitute the certification of the system. For an existing program, the correlation demonstration must be attached for Division consideration for approval. If the correlation information has not yet been developed, please submit it within 60 days of the startup of the system. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Fort Lupton Plant 2. Facility identification code: CO _1230319 _ 3. Stack identification code: S021 4. Unit identification code: P021 5. Pollutant(s) being monitored: NOx, CO 6. Material or parameter being monitored and recorded: Estimated fuel to flare 7. Method of monitoring and recording (see information on back of this page): Estimated fuel to flare will be recorded on a monthly basis and multiplied by the compliance emission factors to estimate monthly emissions. Annual emissions will be tracked on a 12 -month rolling total. 8. List any EPA methods used: 9. Is this an existing method of demonstrating compliance? is Yes No 10. Start date: 11. Backup system: 12 a. Data collection frequency: Daily Weekly • Monthly 12 b. Compliance shall be demonstrated: Daily Weekly ■ Monthly Batch (not to exceed monthly) Other - specify Batch (not to exceed monthly) Other - specify 13. Quality Control/Quality Assurance: The monitoring system shall be subject to appropriate performance specifications, calibration requirements, and quality assurance procedures. A quality assurance/quality control plan for the recordkeeping system is attached for Division review. The plan is not attached, but will be submitted to the Division by 14. A proposed format for the compliance certification report and excess emission report is attached. ***** The compliance records shall be available for Division inspection. The source shall record any malfunction that causes or may cause an emission limit to be exceeded. Malfunctions shall be reported to the Division the next business day. Hazardous air releases shall be reported to the Division immediately. 11 Operating Permit Application EMISSION UNIT HAZARDOUS AIR POLLUTANTS FORM 2000-600 Colorado Department of Public Health and Environment Rev 0fi-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Fort Lupton Plant 2. Facility identification code: CO 1230319 3. Stack identification code: S021 4. Unit identification code: P021 5. Unit material description: Air-assisted Flare 6. Complete the following summary of hazardous air emissions from this unit. Attach all calculations and emission factor references. Attached 1 teal ( mi xm<. Pak!I ` tor La \r:r i > Pollutant CAS Common or Generic i ns o Allowable OR P• otential to emit Pollutant Name Quant ty i asuremei�t Quantity Measurement •• J'nits :: Units IA dz, TPY • i r TPY TPY TPY No HAPs above reporting thresholds. 5R b jE TPY TPY TPY TPY SIP TPY x .� TPY TPY TPY �F + • era { TPY 1. TPY TPY TPY � � �� n TPY TPY NOTE: If there is a permit for this unit, the permit limits are the same as the potential to emit. 12 Operating Permit Application EMISSION UNIT CRITERIA AIR POLLUTANTS FORM 2000-601 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Fort Lupton Plant 2. Facility identification code: CO _ 1230319_ 3. Stack identification code: S021 4. Unit identification code: P021 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached Air pollutant 3 � Potential to emit Maximum allowable ty P U TPY Particulates (TSP) 12 TPY PM-10 � �, TPY Nitrogen oxides V klf, g it iekn V 3.5 TPY 3.5 Volatile organic � � 1.2 TPY 1.2 , compounds .0444 ' ; � , Carbon monoxide � ;�� '� �� q e`n4a 6.8 TPY 6.8 • Lead V V V TPY Sulfur dioxide V TPY Total reduced sulfur ` , ' TPY Reduced sulfur TPY compounds ,f Hydrogen sulfide TPY `nx7} etaMiMit Sulfuric Acid Mist �V Y TPY Fluorides TPY eD. TPY TPY TPY TPY Units (U) should be entered as follows: 1 = Ib/hr 2 = Ib/mm8TU 3 = grains/dscf 4 = lb/gallon 5 = ppmdv 6 = gram/HP-hour 7 = lb/mmscf 8 = other(specify) 9 = other (specify) 10 = other(specify) 13 Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE APPLICABLE REQUIREMENTS AND FORM 2000-604 STATUS OF EMISSION UNIT 1. Facility name: Fort Lupton Plant 2. Facility identification code: CO _1230319 _ 3. Stack identification code: S021 4. Unit identification code: P021 Rev 06-95 5. Pollutant 6. Colorado Air Quality Regulations or Construction Permit Number 7. State Only 8. Limitation 9. Compliance Status IN OUT NOx 02WE0927 3.5 tpy X CO 02WE0927 6.8 tpy X VOC 02WE0927 1.2 tpy X Fuel consumption 02WE0927 46.4 MMSCF/year X Opacity 02WE0927 20% X 10. Other requirements (e.g., malfunction reporting, special operating conditions existing permit such as material usage, hours of operation, etc.) from an State Only Compliance Status IN OUT **** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** 14 Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE SUPPLEMENTAL INFORMATION FORM 2000-700 09-94 1. Facility name: Fort Lupton Plant 2. Facility identification code: CO _ 1230319 3. This form supplements Form 2000 - 604 for Emission Unit (e.g. B001, P001, etc.) P021 Additional Information, Diagrams Item Number NOx, CO and VOC - calculated emissions as of August, 2003 were within permitted limits Fuel consumption - calculated fuel as of August, 2003 was within permitted limits 20% Opacity - source in compliance per proposed compliance plan 15 Operating Permit Application PLANT-WIDE CRITERIA AIR POLLUTANTS FORM 2000-603 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Fort Lupton Plant 2. Facility identification code: CO 1230319_ 3. Complete the following emissions summary for the listed emissions at this facility. Air pollutant _Actual, r_ Potential to Maximum r emit allowable TPY TPY TPY II Particulates (TSP) PM-10 Nitrogen oxides 206.51 mt Volatile compounds organic "' '' '' 96.78 g �, ; Carbon monoxide "' 198.1 • Lead Sulfur dioxide Total reduced sulfur Reduced sulfur compounds Hydrogen sulfide Sulfuric acid mist Fluorides t• 16 Operating Permit Application TABULATION OF PERMIT APPLICATION FORMS Colorado Department of Health Air Pollution Control Division Facility Name: Fort Lupton Plant I. ADMINISTRATION FORM 2000-800 09-94 Facility Identification Code: CO 1230319 This application contains the following forms: ■ Form 20(x)-100, Facility Identification • Form 2000-101, Facility Plot Plan • Forms 2000-102, -102A, and -102B, Source and Site Descriptions II. EMISSIONS SOURCE DESCRIPTION Total Number of This Form This application contains the following forms (one form for each facility boiler. printing • Form 2000-200, Stack Identification 1 • Form 2000-300, Boiler or Furnace Operation 1 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 I Form 2000-401, Condensers Form 2000-402, Adsorbers Form 20(x1-403, Catalytic or Thermal Oxidation Form 2000-404, Cyclones/Settling Chambers Form 2000-405, Electrostatic Precipitators Form 2000-406, Wet Collection Systems r1 Form 2000-407, Baghouses/Fabric Filters IV. COMPLIANCE DEMONSTRATION Total Number of This Form This application contains the following forms (one for each facility boiler. printing ■ Form 2000-500, Compliance Certification - Monitoring and 1 Form 2000-501, Continuous Emission Monitoring Form 2(X)0-502, 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 1 Form 200(1-508, Other Methods 17 V. EMISSION SUMMARY AND COMPLIANCE CERTIFICATION Total Number of This Form This application contains the following forms quantifying emissions, certifying compliance with applicable requirements, and developing a compliance plan ■ Form 2000-600, Emission Unit Hazardous Air Pollutants 1 ■ Form 2000-601, Emission Unit Criteria Air Pollutants 1 I ! Form 2000-602, Facility Hazardous Air Pollutants • Form 2000-603, Facility Criteria Air Pollutants 1 ■ Form 2000-604, Applicable Requirements and Status of Emission Unit 1 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 VI. SIGNATURE OF RESPONSIBLE OFFICIAL - FEDERAL/STATE CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this application are true, accurate and complete. B. CERTIFICATION OF FACILITY COMPLIANCE STATUS - FEDERAL/STATE CONDITIONS (check one box only) ■ 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 Jesse Wood Title Acting Vice President Signature /' I . Wi Date Signed Sep} `30 2003 18 Operating Permit Application Colorado Department of Health Air Pollution Control Division CERTIFICATION FOR STATE -ONLY CONDITIONS FORM 2000-800 09-94 Facility Name: Fort Lupton Plant Facility Identification Code: CO _1230319 VI. SIGNATURE OF RESPONSIBLE OFFICIAL - STATE ONLY CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this application are true, accurate and complete. B. CERTIFICATION OF FACILITY COMPLIANCE STATUS FOR STATE -ONLY CONDITIONS (check one box only) ■ I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements. I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements, except for the following emissions unit(s): (list all non -complying units) WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false material statement, representation, or certification in, or omits material information from this application is guilty of a misdemeanor and may be punished in accordance with the provisions of § 25-7 122.1, C.R.S. Printed or Typed Name Jesse Wood Title Acting Vice President Signature (LW ..b. L ar-rk Date Signed s eb.1. ; U, 20o3 o 3 SEND ALL MATERIALS TO: COLORADO DEPARTMENT OF HEALTH APCD-SS-B I 4300 CHERRY CREEK DRIVE SOUTH DENVER, CO 80246-1530 19 Requested Changes to Permit 99OPWE207 Changes to Specific Terms and Conditions Rationale for Change Cover — change company name to "EnCana Gathering Services (USA) Inc." Transfer of ownership Title Page — change company name and address, responsible official and title, and facility contact person and title as indicated on Form 100 Transfer of ownership, updating information Table of Contents — delete S008, change description of S009 from 2,500 bbl/d to 15,000 bbl/d, add new sources S020 (turbine) and S021 (air assisted flare), and renumber pages as necessary Updating permit for new sources Section I — General Activities and Summary Condition 1.1 — Update this section per Form 102 Permit flexibility Condition 1.3 — in the last sentence, delete the "8" in the reference to construction permit 93WE157-, add ", 01 WE0290 and 02WE0927." to the end of the sentence, and delete the other "and" for grammatical purposes. Replaced utility flare with air -assisted flare and added turbine Table 5.1 and Appendices B and C — delete S008 No longer in operation Table 5.1 and Appendices B and C — change rating for S009 from "2,500 bbl/d" to "15,000 bbl/d" and delete "and 0.4 MMBtu/hr." in description for S010 Incorrect descriptions in original permit Table 5.1 and Appendices B and C — add descriptions for S020 (turbine) and S021 (air -assisted flare) as indicated Added turbine and air - assisted flare to plant Section II — Specific Permit Terms 1.2, 6.2, 7.2, 8.2, 9.2, 10.2 (Tables), — change "Fuel Allocation" to "Fuel Meter or Fuel Allocation" Permit flexibility Conditions 1.1, 6.1, 9.1, 10.1 — in the fourth paragraph, change "Condition 11.1" to "Condition 12.1." Renumbering Conditions 1.2, 6.2, 9.2, 10.2 — add "If there is no fuel meter specific to the engine, then" before the third sentence and change "Allocation" to "allocation." In the fourth sentence, change "The fuel" to This fuel" Permit flexibility Conditions 1.3, 6.3, 7.3, 8.3, 9.3, 10.3 — add, "If needed" to the beginning of the sentence and change "Hours" to "hours." Permit flexibility Conditions 1.5, 6.5, 9.5, 10.5 — Change "lowest gross heating value" to "dry, high heating value" Clarification Condition 2.1.1 — delete entirely, and renumber two subsequent conditions Not necessary for permit renewal Condition 2.2 — change the first sentence to read, "Samples of representative gas shall be collected and analyzed once per year." Delete the second and third sentences. Annual frequency of analyses is adequate. Conditions 3.1-3.5 - Delete section for S008 entirely, and renumber subsequent sections as indicated. S008 replaced by air -assisted flare (S021) 4. (Renumbered as 3., Description) — change "2,500 bbl/d" to "15,000 bbl/d" Incorrect description in original permit Conditions 7.2 and 8.2 (now 6.2 and 7.2) - add "If there is no fuel meter specific to the heater, then" before the third sentence and change "Allocation" to "allocation." In the fourth sentence, change "The fuel" to This fuel" Permit flexibility Changes to Specific Terms and Conditions Rationale for Change Insert new sections 10 and 11 as indicated in the suggested draft permit New sources Section III — Permit Shield Insert attached sections for S020 as indicated in the draft permit Not applicable to this turbine Appendix A Update list of insignificant activities per the attachment to Form 102B Update Appendix H In the first sentence after Fuel Allocation, delete S008 and change "-S019" to "-S021" and add to the end of the sentence "if data from an individual fuel meter is not available." Throughout Permit (including headers and appendices) Change "North American Resources Company" to "EnCana Gathering Services (USA) Inc." Transfer of ownership Colorado Department of Public Health and Environment OPERATING PERMIT ErCa,na Qotr;..g Scfv;ce5 NSA) lnc. North American Resourees Company - Ft. Lupton Plant Issued October 1, 1999 AIR POLLUTION CONTROL DIVISION COLORADO OPERATING PERMIT FACILITY NAME: FACILITY ID: ISSUE DATE: EXPIRATION DATE: MODIFICATIONS: Ft. Lupton Plant OPERATING PERMIT NUMBER 1230319 October 1, 1999 October I, 2004 See Appendix F of Permit 99OPWE207 Issued in accordance with the provisions of Colorado Air Quality Control Act. 25-7-101 et sec . (1989 & 1995 Supp.) and applicable rules and regulations. ISSUED TO: Ga4kert.,9(u See ;c.es NSA) Inc. 1313 be -'tier M'^"e. Ft. Lupton, CO 80621 ,..;101;..t No. PLANT SITE LOCATION: 16157 Weld County Road 22 Ft. Lupton, CO 80621 Weld County INFORMATION RELIED UPON Operating Permit Application Received: And Additional Information Received: February 24, 1999 Nature of Business: Natural Gas Plant Primary SIC: 1311 RESPONSIBLE OFFICIAL Name: Jim Betu1Lc Jesse Wood Title: Nees 4 „t c4 Pees; de Phone: f'106) 723 5454 (3O3) (.33- 2.30c) FACILITY CONTACT PERSON Name: Jeff Reak Dews t.u.,d Title: Seffief-Opgratieffs Superintendant • tea geld Phone: (303) 659-7740 SUBMITTAL DEADLINES Semi -Annual Monitoring Period: Semi -Annual Monitoring Report: Annual Compliance Period: Annual Compliance Certification: October 1 - March 31. April 1 - September 30 May 1. 2000 & November 1, 2000 and subsequent years Begins October Ito September .70 November I.:000 and subsequent years Opacity TABLE OF CONTENTS: SECTION I - General Activities and Summary Permitted Activities Alternative Operating Scenarios Prevention of Significant Deterioration Accidental Release Prevention Program (112(r)) Summary of Emission Units 3 SECTION II - Specific Permit Terms S001 -S004 - Four Ajax 2 -Cycle Lean Burn ICEs (514 HP each) S007 - Fugitive VOC Emissions 7 1 1 , 1 S009 - Amine Treating Unit (2,508'6bU l)�''s 00o bbI14 S010 - Elastec Smart Ash (48 lbs/hr) S012 - Ajax 2 -Cycle Lean Burn (550 HP) 10 12 14 S013 - Born Amine Unit Heater (10.7 MMBtu/hr) 16 S014 - Born Natural Gas Fired Hot Oil Heater (32 MMBtu/hr) 17 S015 -S017 - Three Ajax 2 -Cycle Lean Burn ICEs (550 HP each) 18 S018 -S019 - Two Caterpillar 4 -Cycle Lean Burn ICEs (980 HP each) 20 Portable Monitoring 21 so2.o -Ona. War IoW -,.10, C. -(-,..bi", Cv7aoNP) so 2_ - Owl c1w,c kd1 s41— is IF;,-bsa sP„Flw+a SECTION III - Permit Shield Pss:s4c1 Specific Non -Applicable Requirements 23 General Conditions 23 Streamlined Conditions 24 SECTION IV - General Permit Conditions Administrative Changes 25 Certification Requirements ,5 Compliance Requirements 25 Emergency Provisions 26 Emission Standards for Asbestos 27 Emissions Trading, Marketable Permits, Economic Incentives 27 Fee Payment Fugitive Particulate Emissions 28 Inspection and Entry 17 18 Minor Permit Modifications ,g New Source Review 5 No Property Rights Conveyed 29 Off -Permit Changes to the Source ,9 Odor TABLE OF CONTENTS: Open Burning 29 Ozone Depleting Compounds 29 Permit Expiration and Renewal 2c) Portable Sources Prompt Deviation Reporting 30 Record Keeping and Reporting Requirements 30 Reopenings for Cause 31 Section 502(b)(10) Changes 32 Severability Clause 32 Significant Permit Modifications 32 Special Provisions Concerning the Acid Rain Program 2 Transfer or Assignment of Ownership 32 Volatile Organic Compounds 33 Wood Stoves and Wood burning Appliances APPENDIX A - Inspection Information Directions to Plant 1 Safety Equipment Required 1 Facility Plot Plan 1 List of Insignificant Activities APPENDIX B Reporting Requirements and Definitions 1 Required Format for Monitoring and Permit Deviation Report - Part I 5 Required Format for Deviation Report - Part II g Required Format for Deviation Report Certification - Part III 10 APPENDIX C Required Format for Annual Compliance Certification Report 1 APPENDIX D Notification Addresses 1 APPENDIX E Permit Acronyms APPENDIX F Permit Modifications :APPENDIX G VOC Testing Program 1 TABLE OF CONTENTS: APPENDIX H Fuel Allocation Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 North American Resources Company Ft. Lupton Plant Page 1 SECTION 1 - General Activities and Summary 1. Permitted Activities 1.1. This facility consists of a natural gas processing plant defined under Standard Industrial Classification 13 II. Raw natural gas is received in the Ft. Lupton plant and goes through one of two cryogenic processing train) n ^ Png n - -- `'- yet ,iin amine unit fired by a (--- heater removes CO2 and H2S. The remaining residue compression is completed by s-ix-sefte.,-'t- additional engines?` Two fractionation trains separate out ethane, propane, butane and natural -`h.„t, p„ ..4.4.1 o . gasoline. Heat to the fractionation plant is provided by a natural gas fired hot oil heater. GI pieN(.t►) o ^s C. _ __ ___ _____ rin addition the plant has a flare. fugitive i2 lee t -►e►- ttn4""'°„, VOC emissions from miscellaneous equipment at the plant, and an incinerator used for the esf,tgts.4:o"n 0.4 ,ef ress:e'" 'combustion of oily solid waste. ;d+c cQ The facility is located in Ft. Lupton in Weld County. The area in which the plant operates is designated as attainment for all criteria pollutants. There are no affected states within 50 miles of the plant. The following Federal Class I designated area is within 100 kilometers of the plant; Rocky Mountain National Park. 1.2. Until such time as this permit expires or is modified or revoked, the permittee is allowed to discharge air pollutants from this facility in accordance with the requirements, limitations, and conditions of this permit. 1.3. This Operating Permit incorporates the applicable requirements contained in the underlying construction permits. and does not affect those applicable requirements, except as modified during review of the application or as modified subsequent to permit issuance using the modification procedures found in Regulation No. 3, Part C. These Part C procedures meet all applicable substantive New Source Review requirements of Part B. Any revisions made using the provisions of Regulation No. 3, Part C shall become new applicable requirements for purposes of this Operating Permit and shall survive reissuance. This Operating Permit incorporates the applicable requirements lexcet ascnot;d in Section II) from the following Colorado Construction Permits: 93WEl57-(1-4. 7,'0°. 9�5WE683, 97WEI)722, 97WE0723. 97WE07?q, 97WE0725, 97WE07``6. 97WE0727. 97WE0728 a 97WE0729 oiweozgo o'J yo'6 .,dt-7 .S ,o. ) ot4 O2.V16O92.7. 1. 1. All conditions in this permit are enforceable by I;S Environmental Protection Agency, Colorado Air Pollution Control Division (hereinafter Division) and its agents. and citizens unless otherwise specified. State -only enforceable conditions are: Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 North American Resources Company Ft. Lupton Plant Page 2 Permit Condition Number(s): Section IV - Conditions 13 and 17 (as noted). 1.5. All information gathered pursuant to the requirements of this permit is subject to the Recordkeeping and Reporting requirements listed under Condition 21 of the General Conditions in Section IV of this permit. 2. Alternative Operating Scenarios 2.1. The permittee shall be allowed to make the following changes to its method of operation without applying for a revision of this permit. 2.1.1. No separate operating scenarios have been specified. 3 Prevention of Significant Deterioration 3.1. This facility is not a major stationary source (no criteria pollutant emissions with a Potential to Emit of greater than 250 tpy) for the purposes of Prevention of Significant Deterioration ( PSD) requirements (Colorado Regulation 3, Part B, Section IV.D.3). Future modifications to this facility may result in an exceedance of the major source threshold. Once that threshold is exceeded, future modifications at this facility resulting in a significant net emissions increase as listed in Colorado Regulation 3, Part A, Section I.B.58 or a modification which is major by itself will result in the application of the PSD review requirements. 3.2. There are no other Operating Permits associated with this facility for purposes of determining applicability of Prevention of Significant Deterioration regulations. 4. Accidental Release Prevention Program (112(r)) 4.1. This facility is subject to the provisions of the Accidental Release Prevention Program (Section 112(r) of the Federal Clean Air Act). 4.2. The Risk Management Plan required by the Act shall be submitted to the appropriate authority and/or a designated central location by June 20, 1999. 4.3. The source shall certify to the Division in writing that the source is in compliance with all requirements of 112(r) and that the Risk Management Plan has been submitted to the appropriate authority and/or a designated central location. Such certification shall be signed by the Responsible Official. Operating Permit Number: 90OP \\T-'07 ISSUED: 10/1;99 Air Pollution Control Division North American Resources Company Colorado Operating Permit Ft. Lupton Plant Permit # 99OPWE207 Page 3 5. Summary of Emission Units 5.1. The emissions units regulated by this permit are the following: Emission Unit Number AIRS Stack Number Facility Identifier Description Pollution Control Device S001 001 P001 Ajax DPC-540LE. 2 -Cycle Lean Burn, Low NOx design. Natural Gas Fired Internal Combustion, Site Rated at 514 HP, SN: 8389V Uncontrolled S002 002 P002 Ajax DPC-540LE, 2 -Cycle Lean Burn, Low NOx design, Natural Gas Fired Internal Combustion Engine, Site Rated at 5141113, SN: 83892.- Uncontrolled S003 003 P003 Ajax DPC-540LE, 2 -Cycle Lean Burn, Low NOx design, Natural Gas Fired Internal Combustion, Site Rated at 514 HP. SN: 83889' Uncontrolled S004 004 P004 Ajax DPC-540LE, 2 -Cycle Lean Burn, Low NOx design, Natural Gas Fired Internal Combustion Engine, Site Rated at 5141-IP, SN: 83890.' Uncontrolled S007 007 P007 Fugitive VOC Emissions Uncontrolled us S009 009 P009 Amine Treating Unit, Rated 2,500 bbl/d Natural at of Gas Liquids. 15, 00O Uncontrolled S010 010 P010 Elastec Smart Ash Model 100 Incinerator. SA18894,-- Design Rated 48 lbs/hr - Uncontrolled at and 0.4 NM Btu/lu. S012 012 P012 Ajax DPC-2803LE, 2 -Cycle Lean Burn, Low NOx design. Natural Gas Fired Internal Combustion. Site Rated at 550 -HP, SN: 84286.' Uncontrolled it S013 013 1 P013 Born Natural Gas Fired Amine Unit Heater, Design Rated at I0.TiMMBtwhr. Model and SN: 2885-0' Uncontrolled °)perating Permit Number: 99OPWE20T ISSUED: 10/1/99 Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 North American Resources Company Ft. Lupton Plant Pane 4 S014 014 P014 Born, Inc Natural Gas Fired Hot Oil Heater, Design Rated at 32 fvIMBtu/hr. SN: 1963.- Uncontrolled S015 015 P015 Ajax DPC-2803LE, 2 -Cycle Lean Burn, Low NOx design, Natural Gas Fired Internal Combustion Engine, Site Rated at 550'HP, SN: 84308.' Uncontrolled S016 016 P016 Ajax DPC-2803LE, 2 -Cycle Lean Burn, Low NOx design, Natural Gas Fired Internal Combustion Engine, Site Rated at 550TIP, SN: 84288.' Uncontrolled S017 017 P017 Ajax DPC-2803LE, 2 -Cycle Lean Burn, Low NOx design, Natural Gas Fired Internal Combustion Engine, Site Rated at 550 HP, SN: 84287.-- Uncontrolled S018 018 P018 Caterpillar G3516TALE, 4 -Cycle Lean Burn, Natural Gas Fired Internal Combustion Engine, Site Rated at 980-IP, SN: 3RC01237.-' Uncontrolled S019 019 P019 Caterpillar G3516TALE, 4 -Cycle Lean Burn, Natural Gas Fired Internal Combustion Engine, Site Rated at 980'HP, SN: 3RCO1240 ' Uncontrolled SDZO .02.e7 P020 Solar Gtnl'w.ar 4o, Lobs• Max. 1Jalu•aI Gas Reed In4eeaat Cowb.4046.9 �41.40,4TA. bine, Si4t �a} 4+7OO I+P, SA1t bcc 62ad8, lint0.eieollt� Soai ort Po 21 Flare, 1...A4 4e:es Mr - Assws+$Flare ur+caMeal led Operating Permit Number: 99OPWE207 ISSUED: 10/1,99 Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 North American Resources Company Ft. Lupton Plant Page 5 SECTION II - Specific Permit Terms S001 -S004 - Four Ajax 2 -Cycle Lean Burn ICEs (514 HP each) Parameter Permit Condition Number Limitations for each engine Short Term Long Term Compliance Emission Factor Monitoring Method Interval NOx 1.1. NA 1 1.6 tons/yr 0.514ib/MMBtu Recordkeeping, Calculations and Portable Monitoring Monthly, Quarterly CO NA 1 1.6 tons/vr 0.301b/MMBtu VOC NA 5.8 tons/yr 0.15-1b/MMBtu Fuel Use 1.2. NA 42.57 ' MMscf/yr NA ANU incite or ,Fuel Allocation (see Appendix H) Monthly Hours of Operation 1.3. NA NA NA Recordkeeping Monthly Opacity 1.4. Less Than or Equal to 20% NA Fuel Restriction At All Times Btu Content 1.5. NA NA NA ASTM Analysis Method Semi - Annually Emissions of Nitrogen Oxides, Carbon Monoxide and Volatile Organic Compounds from each engine shall not exceed the limitations stated above (Colorado Construction Permits 93WE157- (1-4)). Emissions shall be calculated by the end of the subsequent month using the listed compliance emission factors (EF) in the following equation: Lbs/month = [EF x monthly fuel use (Mlvlscf; month) x heat content of gas (Btu/scf)] A twelve-month rolling total shall be maintained for demonstration of compliance with annual limitations. Each month. a new twelve month total shall be calculated using the previous twelve months data. Emission measurements of nitrogen oxides (NO,.) and carbon monoxide (CO) from each engine shall be conducted quarterly using a portable flue gas analyzer as specified in Condition -1-1-.1. it Operating Permit Number: 99OPWE_07 ISSUED: 10/1/99 1♦ {•ke.t 1s 00 i04.i v t t t:c- +• after*, -they% Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 North American Resources Company Ft. Lupton Plant Palle 6 1.2. Fuel consumption for each engine shall not exceed the limitations above (Colorado Construction Permits 93 WE 157-(1-4)). Within the first seven days of every month, the fuel meter shall be read and recorded.)Alloeation of fuel use shall be made using the methods detailed in Appendix I -I of this permit. Thi fuel use shall be measured no more than twelve (12) hours from the time that run time hours have been recorded. A twelve month rolling total shall be maintained for demonstration of compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. If sedately kour7 1.3. „ Hours of operation for each engine shall be recorded on a monthly basis for use in fuel allocation calculations. 1.4. Opacity of emissions from each engine shall not exceed 20 % (Colorado Construction Permits 93WE157-(1-4)). In the absence of evidence to the contrary, compliance with the 20% opacity limit shall be presumed whenever natural gas is used as fuel for these engines. 1.5. The Btu content of the natural gas used to fuel these engines shall be determined semi-annually using ASTM Analysis Method D1945 or equivalent. Calculation of monthly emissions outlined under Condition 1.1 shall be based on the most recent BTU analysis. The BTU Content shall be based on the lowest gross heating value of the fuel. 1.6. These engines shall be operated and maintained in accordance with manufacturer's recommendations at all times, including periods of start-up, shutdown, and malfunction. Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 Air Pollution Control Division Colorado Operating Permit Permit 99OPWE207 S007 - Fugitive VOC Emissions North American Resources Company Ft. Lupton Plant Page 7 Parameter Permit Condition Number Limitations Short Term Lone Term Compliance Emission Factor Monitoring Method Interval VOC 2.1. NA 19 tons/yr By Component Type - EPA Protocol for Equipment Leak Estimates Recordkeeping As Noted Gas Analysis 2.2. NA NA NA EPA Reference Methods Quarterly (To Annually( General Provisions 2.3. NA NA NA Subject to NSPS General Provisions Leak Detection and Repair 2.4. NA NA NA Subject to NSPS KKK 2.1. Volatile Organic Compound emissions shall not exceed the limitations stated above (Colorado Construction Permit 93 WE 15 7-7 as modified under the provisions of Section I Condition 1.3.) Emissions shall be calculated using the emission factors and equations listed below. Emission Factors for individual types of components in lb/components-hrs (Protocol for Equipment Leak Emission Estimates, EPA -453/R-95-017): Leakers Non-Leakers Euuiprnent Gas Service Light Liq. Service Gas Service Light Liq. Service Connectors 5.70E-02 5.70E-02 2.20E -05v _.10E-05, Flanges 1.80E-01 I.60G01Z' 1.30E-05/' 5.30E -06 - Open -ended Line 1.20E-01- 0.70E-02-" 3.30E-05- 3.10E-05 ' 'Other 2.00E-01 ' 1.80E -0I' 2.60E-04- 2.40E-04 ' Pump 1.60E_0I • '.201/-) E 7.70E-04' 1.I0E-0;' Valve 2.20E-01 ' 1.90E -(t I '" 5.50E-05 4.2013-05 Operating Permit Number: 99OPWE207 ISSUED: 1/1/99 Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 North American Resources Company Ft. Lupton Plant Page 8 * This "other" equipment type should be applied for any equipment type other than connectors, flanges, open-ended lines, pumps or valves. Emissions of VOC per Component: Components Leaking x EF for Leakers (lbs/component-hr) x 8760 hrs/yr x VOC content of gas Components Non -leaking x EF for Non-Leakers (Ibs/component-hr) x 8 760 hrs/vr x VOC content of gas Total Fugitive VOC will be the sum of emissions for each component. nveucvr� 2.1.E A component count shall be conducted every five (5) years to verify existing components and inventory. 2.1.3. A running total shall be kept of all additions and subtractions to the component count. repee icc.1a.n 2.2. Samples of irtiet gas shall be collected and analyzed once per quarter. Frequcncy of gas analyses con year conc3}nfr tinnc r main rnncictPnt The most recent gas analysis shall be used in calculating emissions in Condition 2.1. 2.3. 40 CFR 60, Subpart A, General Provisions (as adopted by reference in Colorado Regulation No.6 Subpart A) applies as follows: 2.3.1. No article, machine, equipment or process shall be used to conceal an emissions which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to. the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gasses discharged to the atmosphere. ( §60.12) 2.3.2. Records of startups. shutdowns. and malfunctions shall be maintained, as required under §60.7. 2.4. This source is subject to 40 CFR Part 60.630. Subpart KKK, New Source Performance Standards (as adopted by reference in Colorado Regulation No. 6): Standards of Performance for Operating Permit Number: 99OPWE207 ISSUED: 10/1;99 Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 North American Resources Company Ft. Lupton Plant Page 9 y Equipment Leaks of VOC from Onshore Natural Gas Processing Plants. The following items apply: 2.4.1. Inspection and maintenance requirements as stated in federal NSPS 40 CFR §60.632, §60.633. and §60.634. 2.4.2. Record keeping requirements as stated in federal NSPS 40 CFR §60.635. 2.4.3. Reporting requirements as stated in federal NSPS 40 CFR §60.636. Reporting under this section is to be fulfilled concurrently with Appendix B compliance monitoring reporting and shall be submitted to the Division. 2.4.4. The source shall follow the VOC Testing Program following the Protocol set forth in Appendix G. S008 - Flare Industries 16" Flare Parameter ermit Co ition Numb Limitations Short Term Long Term Complian Emissio actor Monitoring Method Interval NOx 3.1. NA 2.68 tons,/yr 00 lb/MMscf Recordkeeping Monthly CO N. ?.25 tons/ 84 lb/MMscf and Calculation Fuel Use 3.2. NA -1 scf/yr NA Fuel Allocation (See Appendix H) Monthly Hours of Operation 3.3. NA NA NA Recordkeeping Monthly Opacity 3.4. Le Than or Equal to 20% NA Visual Observations Weekly 3.1. Emission: of Nitrogen Oxides and Carbon Monoxide shall n exceed the limitations stated abov- Colorado Construction Permits 93 WE 157-8 as modifie der the provisions of Section I C. dition 1.3.). Emissions shall he calculated by the end of the sub quent month using the isted compiiance emission factor (EF' and the monthly fuel use. A twe1 -month rolling total shall he maintained for demonstration of compliance with annual limitations. Each month. a new twelve month total shall he calculated using the previous twelve months data. Operating Permit Number: o1)t.)P\VE207 ISSUED: 10!1/ 9y Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 North American Resources Company Ft. Lupton Plant Page 10 3.7. Fuel , sumption shall not exceed the limitations above (Colorado Con uction Permits 93 WE 15 : as modified under the provisions of Section I Condition .3.). Within the first seven days of every onth, the fuel meter shall be read and recorded. ocation of fuel use shall be made using the m hods detailed in Appendix H of this permi The fuel use shall be measured no more than twelve 2) hours from the time that run tim- ours have been recorded. A twelve month rolling total sh. .e maintained for demonstrati of compliance with the annual limitations. Each month a w twelve month total all he calculated using the previous twelve months data. 3.3. Hours of operation shall be recorde• .n a onthly basis for use in fuel allocation calculations. 3.4. Opacity of emissions shall not exce= i 20 ' ' (Colorado Construction Permits 93WE157-8). Compliance with the opacity re.. rements s .11 be monitored by conducting visual observation of emissions weekly, during .rural operation. any visible emissions are observed, the source shall investigate equipme .erformance and make .ny adjustments necessary. If, after maintenance has been p; formed, visible emissions p: sist for longer than one hour, an EPA Reference Method 9 ' pacity observation shall be perfo ' ed to determine compliance with the opacity standard. e EPA Reference Method 9 opacity o:. ervations shall be performed by an observer with c .r ent and valid Method 9 certification. 3.5. This flare all be operated and maintained in accordance with m ufacturer's recommendations at all ti • -s, including periods of start-up, shutdown, and malfunction. ts1 eto 1,h1/dm S009 - Amine Treating Unit (2,500 bbl/d) Parameter Permit Condition Number Limitations Short Term Long Term Compliance Emission Factor Monitoring Method Interval H2S a. i 4--1-. NA NA Material Balance Recordkeeping and Calculation Annual Opacity 3.2 4a. Less Than or Equal to 20% NA Fuel Restriction At All Times Emissions shall be calculated annually for APEN reporting purposes (Regulation No. 3, Part A, 3.' Section II) Operating Permit Number: 99OPWE207 ISSUED: 10/1;99 Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 North American Resources Company Ft. Lupton Plant Page 11 4-?. Opacity of emissions shall not exceed 2(1 % (Colorado Regulation No. 1, Section A.II.I ). In the 3'a absence of evidence to the contrary. compliance with the 20% opacity limit shall be presumed whenever natural gas is used as fuel for this unit. This unit shall be operated and maintained in accordance with manufacturer's recommendations 3.3 at all times, including periods of start-up, shutdown, and malfunction. Operating Permit Number: 99OPWE20 ISSUED: 10/1/99 Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 North American Resources Company Ft. Lupton Plant Page 1 S010 - Elastec Smart Ash (48 Ibs/hr) Parameter Permit Condition Number Limitations Short Term Long Term Compliance Emission Factor Monitoring Method Interval PM 'f. I PMIO SO2 NO2 CO VOC NA 1.58 tons/yr 15.0 lbs/ton waste NA 0.6 tons/yr 5.7 lbs/ton waste NA 0.26 tons/yr 2.5 lbs/ton waste NA 0.21 tons/yr 2.0 lbs/ton waste NA 2.10 tons/yr 20.0 lbs/ton waste NA 1.58 tons/yr 15.0 lbs/ton waste Recordkeeping and Calculation Monthly Charge Limit Ste. z NA 210 tons/yr NA Recordkeeping Monthly Flash Point of Waste Greater than or Equal to 100 °F NA Waste Restriction Per Charge Particulates 5-4. 4+ 0.10 gr/dscf corrected at 12% CO2 NA Demonstrated Compliance with Conditions 5.2, 5.3 and 5.6 As Noted in Conditions 5.2, 5.3 and 5.6 Waste Burning Restrictions 575-1, s No Burning of Radioactive or Hazardous Waste NA Self Certification Annually Opacity 3-6.4. t. Less Than or Equal to 20% NA EPA Reference Method 9 Annually Personnel Requirements Trained Personnel Operating Incinerator NA Recordkeeping Per Charge Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 Air Pollution Control Division Colorado Operating Permit Permit 4 99OPWE207 ti:i• North American Resources Company Ft. Lupton Plant Page 13 Emissions of air pollutants shall not exceed the limitations above (Colorado Construction Permit 95WE683 as modified under the provisions of Section 1 Condition 1.3). Emissions from this unit shall be calculated monthly and a twelve month rolling total to comply with the annual limits using the equations below: tons/month = [EF (lbs/ton waste) x waste burned (tons/month) x 1/2000 (ton/lbs)] -?•. The charge weight of the incinerator shall not exceed the limitations above (Colorado 4.2- • Construction Permit 95WE683 as modified under the provisions of Section I Condition 1.3). Summarized monthly records of daily burning rates and hours of operation shall be maintained. The monthly charging rate shall he used in a twelve month rolling total to compare with the annual limitation. Each month a new twelve month total shall be calculated using the previous twelve months data. The flash point of materials being burned shall be higher than or equal to 100 degrees F 4••3 • (Colorado Construction Permit 95WE683). Compliance with this requirement shall be demonstrated by monitoring and recording the materials being burned in each charge. Absorbent materials that contain volatile liquids, such as gasoline or paint thinner shall not be burned in this unit. In addition, liquid fuel shall not be used as start-up fuel (Colorado Construction Permit 95WE683). An ample layer of dry paper or cardboard material supplies a fast, easy initial fuel source for start-up. -5-4. Particulate emissions shall not exceed 0.1 grains per dry standard cubic feet, corrected to 12% 4•y• CO, (Colorado Construction Permit 95WE683). Demonstrated compliance with Conditions 5.2., 5.3., and 5.6. shall be adequate to ensure compliance with this particulate emission limit. S. No radioactive or hazardous waste may be burned in the incinerator without obtaining the 4•S• appropriate permits (Colorado Construction Permit 95WE683). Compliance with this requirement will be demonstrated by certifying annually that no radioactive or hazardous waste was burned. 46. Opacity of emission shall not exceed 20% (Colorado Construction Permit 95WE683). +.6 Compliance with this requirement shall he monitored by conducting visual emission observations. in accordance with EPA Reference Method 9. annually. Results of Method 9 readings and a copy of the certified Method 9 reader's certification shall also be kept on site and made available to the Division upon request. Operating Permit Number: 99OPWE207 ISSUED: 10/1i99 Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 `t•1 North American Resources Company Ft. Lupton Plant Page 14 The incinerator must be operated by trained personnel (Colorado Construction Permit 95WE683). Compliance with this requirement will be monitored by maintaining records of personnel trained to operate the incinerator. The name of the personnel operating the incinerator will be recorded for each charge of waste fed to the incinerator. 5-8. The incinerator shall be operated and maintained in accordance with manufacturer's .t.. a recommendations at all times, including periods of start-up, shutdown and malfunction. 5 ft S012 - Ajax 2 -Cycle Lean Burn (550 HP) 1—'4;./ Parameter Permit Condition Number Limitations Short Term Long Term Compliance Emission Factor Monitoring Method Interval NOx -Fri-. NA 16.8'tons/yr 0.543 Cb/MMBtu Recordkeeping, Monthly, CO 5' I NA / 20.1 tons/yr 0.3 lb/MMBtu Calculations and Portable Quarterly VOC NA 6.7 tons/yr 0.15 lb/MMBtu Monitoring Fuel Use -&2. 5:"2- NA 47.24 ✓ MMscf/yr NA FtAal M t4tr or „Fuel Allocation (See Appendix H) Monthly Hours of Operation 6--3. S. ; NA NA NA Recordkeeping Monthly Opacity 6-4. Less Than or Equal to 20% NA Fuel Restriction At All Times sit Btu Content 6:§. s.s NA NA NA ASTM Analysis Method Semi- Annually Emissions of Nitrogen Oxides. Carbon Monoxide and Volatile Organic Compounds shall not exceed the limitations stated above (Colorado Construction Permit 97WE0722). Emissions shall be calculated by the end of the subsequent month using the listed compliance emission factors (EF) in the following equation: Lbs/month = [EF x monthly fuel use (MMscfhnonth) x heat content of gas Bttuscfl] A twelve-month rolling total shall be maintained for demonstration of compliance with annual Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 5. 2 North American Resources Company Ft. Lupton Plant Page 15 limitations. Each month. a new twelve month total shall be calculated using the previous twelve months data. Emission measurements of nitrogen oxides (NO.,) and carbon monoxide (CO) from each engine shall be conducted quarterly using a portable flue gas analyzer as specified in Condition 4-1--F. t2 t Fuel_copsumption shall not exceed the limitations above (Colorado Construction Permit 97WE0722). Within the first seven days of every month, the fuel meter shall be read and recorded. Allecatien of fuel use shall be made using the methods detailed in Appendix H of this permit. Thefuel use shall be measured no more than twelve (12) hours from the time that run time hours have been recorded. A twelve month rolling total shall be maintained for demonstration of compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. It w44441, hours 673. 14eurs of operation shall be recorded on a monthly basis for use in fuel allocation calculations. s. &4. S.9 63. S.5" Opacity of emissions shall not exceed 20 % (Colorado Construction Permit 97WE0722). In the absence of evidence to the contrary, compliance with the 20% opacity limit shall be presumed whenever natural gas is used as fuel for these engines. The Btu content of the natural gas used to fuel this engine shall be determined semi-annually using ASTM Analysis Method D 1945 or equivalent. Calculation of monthly emissions outlined under Condition 6.1 shall be based on the most recent BTU analysis. The BTU Content shall be based on the heating value of the fuel. 9h -676. This engine shall be operated and maintained in accordance with manufacturer's s.b recommendations at all times, including periods of start-up, shutdown, and malfunction. Operating Permit Number: 99(_)PWE207 ISSUED: 10/1/99 Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 North American Resources Company Ft. Lupton Plant Paste 16 S013 - Born Amine Unit Heater (10.7 MMBtu/hr) \"It ko 1 + Parameter Permit Limitations Compliance Monitoring Condition Emission Number Short Term Long Term Factor Method Interval NOx -7-.-I. (..•1 NA 6.8 tons/yr I001biMMscf Recordkeeping and Calculations Monthly CO NA 5.7 tons/yr 84 lbS/MMscf 'A.A.' A+ai�, e r Fuel Use 72. NA 128 i" NA Fuel Allocation Monthly `'Z' MMscf/vr (see Appendix H) Hours of Operation 7-3. t°' 3 NA NA NA Recordkeeping Monthly Opacity 7-:4. Less Than or Equal to 20% NA Fuel Restriction At All Times Emissions of Nitrogen Oxides and Carbon Monoxide shall not exceed the limitations stated above (Colorado Construction Permits 97WE0723 as modified under the provisions of Section 1 Condition 1.3). Emissions shall be calculated by the end of the subsequent month using the listed compliance emission factors (EF) and the monthly fuel use. A twelve-month rolling total shall be maintained for demonstration of compliance with annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months data. 72. Fuel consumption shall not exceed the limitations above (Colorado Construction Permit t.. z 97WE0723). Within the first seven days of every month, the fuel meter shall be read and recorded., Allocation of fuel use shall be made using the methods detailed in Appendix H of this if 46e,e, fs ►+o permit. Th@Ffuel use shall be measured no more than twelve (12) hours from the time that run srete•c time hours have been recorded. A twelve month rolling total shall be maintained for 4044.e. t,e_o1ee, demonstration of compliance with the annual limitations. Each month a new twelve month total �.�,�.. attoea}ieh shall be calculated using the previous twelve months data. Iih.r.sesled, kouac . 14tyttrs of operation shall be recorded on a monthly basis for use in fuel allocation calculations. (+• 3 7-4. `.4 Opacity of emissions shall not exceed 20 % (Colorado Construction Permit )7WE0723). In the absence of evidence to the contrary, compliance with the 20% opacity limit shall be presumed whenever natural gas is used as fuel for this unit. Operating Permit Number: t9OPWE207 ISSUED: 10/1/9Q -7. Air Pollution Control Colorado Operating Permit # 99OPWE207 Division Permit North American Resources Company Ft. Lupton Plant Page 17 ;--5-. This G'S at Fr. unit shall be operated and maintained in accordance with manufacturer's recommendations all times, including periods of start-up, shutdown, and malfunction. S014 - Born Natural Gas Fired Hot Oil Heater (32 MMBtu/hr) Parameter Permit Condition Number Limitations Short Term Long Term Compliance Emission Factor Monitoring Method Interval NOx 87-i. r NA 14.2 Eonslyr 100'Ib/MMscf Recordkeeping Monthly CO 7 - NA 11.9 tons/vr 84 lb/MMscf and Calculations I Fuel Use 8-:-.2. 7.Z' NA 270 MMscf'vr NA CMI.I Mt4to" p. Fuel Allocation (See Appendix H) Monthly Hours of Operation 8-3. 7.3 • NA NA NA Recordkeeping Monthly NSPS Dc 874. 7.4h NA NA NA Fuel Restriction At All Times Opacity 875.. 7.5 Less Than or Equal to 20% NA Fuel Restriction At All Times y 4.6„,_, ,F„,4 -4, +66- 4.t.,„ -8-71. Emissions 7. I above Condition listed shall twelve 8.:-.2. Fuel -7.7- 97WE0724 days of Nitrogen Oxides and Carbon Monoxide shall not exceed (Colorado Construction Permit 97WE0724 as modified under 1.3). Emissions shall be calculated by the end of the subsequent compliance emission factor (EF) and the monthly fuel use. be maintained for demonstration of compliance with annual month total shall be calculated using the previous twelve consumption shall not exceed the limitations above (Colorado as modified under the provisions of Section I Condition of every month, the fuel meter shall be read and recordedAllocation• , the limitations stated the provisions of Section I month using the A twelve-month rolling total limitations. Each month, a new months data. Construction Permit 1.3). Within the first seven of fuel use shall he fuel use shall be measured have been recorded. A twelve with the annual using the previous twelve ;3 „p made ,,,,,. Si,td.f;,. no testa, month auoe. 4+oi limitations. months using the methods detailed in Appendix Hof this permit. The more than twelve (12) hours from the time that run time hours rolling total shall be maintained for demonstration of compliance Each month a new twelve month total shall be calculated data. Operating Permit dumber: 9 QPWE20% ISSUED: 10'1i99 Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 North American Resources Company Ft. Lupton Plant Page 18 .e444, 46.6 s -8-73. Hours of operation shall be recorded on a monthly basis for use in fuel allocation calculations. 7.3 8.. This unit is subject to 40 CFR 60 Standards of Performance for New Stationary Sources. Subpart 7.4 Dc Standards of Performance for Small Industrial -Commercial -Institutional Steam Generating Units as adopted by reference in Colorado Regulation No. 6, Part A, Subpart Dc. The source must certify annually that only natural gas was used as fuel for this unit. 83. Opacity of emissions shall not exceed 20 % (Colorado Construction Permit 97WE0724). In the 7.s absence of evidence to the contrary, compliance with the 20% opacity limit shall be presumed whenever natural gas is used as fuel for this unit. 8-6. This unit shall be operated and maintained in accordance with manufacturer's recommendations m'1. at all times, including periods of start-up, shutdown, and malfunction. S015 -S017 - Three Ajax 2 -Cycle Lean Burn ICEs (550 HP each) Parameter Permit Condition Number Limitations for each engine Short Term Long Term Compliance Emission Factor Monitoring Method Interval NOx. W. I NA 10.6-fons/yr 0.543-l'b/MMBtu Recordkeeping, Calculation and Portable Monitoring Monthly. Quarterly CO NA 10.6-tons/yr 0.30'Ib/MMBtu VOC NA 5.3 tons/yr 0.15 fb/MMBtu Fuel Use 9a. $' Z NA 38.3,- MMscf/yr NA Fwa$ AAe+Fe.r ale Fuel Allocation (see Appendix H) Monthly Hours of Operation -9-3. g' 3 NA NA NA Recordkeeping Monthly Opacity 4.4. Less Than or Equal to 20% NA Fuel Restriction At All Times 8 .4 Btu Content 975.. s.s NA NA NA ASTM Analysis Method Semi- Annually 971. Emissions of Nitrogen Oxides. Carbon Monoxide and Volatile Organic Compounds from each s.i Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 9-6. g. Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 g.z I f ll-ue. 's ro MCite speck:4 4., 44- (Ad "` 4.I. alloco.4-; North American Resources Company Ft. Lupton Plant Page 19 engine shall not exceed the limitations stated above (Colorado Construction Permits 97WE0725, 97WE0726 and 97WE0727). Emissions shall be calculated by the end of the subsequent month using the listed compliance emission factors (EF) in the following equation: Lbs/month = [EF x monthly fuel use (MMsctimonth) x heat content of gas (Btuisct)] A twelve-month rolling total shall be maintained for demonstration of compliance with annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months data. Emission measurements of nitrogen oxides (NO3 and carbon monoxide (CO) from each engine shall be conducted quarterly using a portable flue gas analyzer as specified in Condition 4.14. 12.1 Fuel consumption for each engine shall not exceed the limitations above (Colorado Construction Permits 97WE0725, 97WE0726 and 97WE0727). Within the first seven days of every month, the fuel meter shall be read and recorded.Jt44lesaiell of fuel use shall be made using the methods detailed in Appendix H of this permit. Th$ fuel use shall be measured no more than twelve (12) hours from the time that run time hours have been recorded. A twelve month rolling total shall be maintained for demonstration of compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 1.1 hudcd, kours A-3. Hours of operation for each engine shall be recorded on a monthly basis for use in fuel . 3 allocation calculations. 974. 8.4 Opacity of emissions from each engine shall not exceed 20 % (Colorado Construction Permits 97WE0725, 97WE0726 and 97WE0727). In the absence of evidence to the contrary, compliance with the 20% opacity limit shall be presumed whenever natural gas is used as fuel for these engines. 9-5. The Btu content of the natural `gas used to fuel these engines shall be determined semi-annually 8. using ASTM Analysis Method D 1945 or equivalent. Calculation of monthly emissions outlined under Condition 9.1 shall be based on the most recent BTU analysis. The BTU Content shall be based on the lowest gross heating value of the fuel. day, h,ti These engines shall he operated and maintained in accordance with manufacturer's recommendations at all times, including periods of start-up, shutdown, and malfunction. Operating Permit Number: 99OPWE20 7 ISSUED: 10/1/99 Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 North American Resources Company Ft. Lupton Plant Page 20 4.143. S018 -S019 ,,„d - Two Caterpillar 4 -Cycle Lean Burn ICEs (980 HP each) Parameter Permit Condition Number Limitations for each engine Short Term Long Term Compliance Emission Factor Monitoring Method Interval NOx I$-1. `. i NA 18.9 Cons/ yr 0.585 - lb/MMBtu Recordkeeping, Calculation and Portable Monitoring Monthly, Quarterly CO NA 18.9Ions/vr 0.492. lb/MMBtu VOC NA 9.5'tons/yr 0.18 {b/MMBtu Fuel Use I$?. q. 2 NA 63.4 "IMscf/yr NA F.s.I Os..w. e . Fuel Allocation (See Appendix H) Monthly Hours of Operation l•9-3. `t• 3 NA NA NA Recordkeeping Monthly Opacity 1-0-4. 1.4 Less Than or Equal to 20% NA Fuel Restriction At All Times Btu Content 1.9,5. NA NA NA ASTM Analysis Method Semi - Annually Emissions of Nitrogen Oxides, Carbon Monoxide and Volatile Organic Compounds from each engine shall not exceed the limitations stated above (Colorado Construction Permits 97WE0728 and 97WE0729). Emissions shall be calculated by the end of the subsequent month using the listed compliance emission factors (EF) in the following equation: Lbs/month = [EF x monthly fuel use (MMscf/month) x heat content of gas (Btu/scf)] A twelve-month rolling total shall be maintained for demonstration of compliance with annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months data. Emission measurements of nitrogen oxides (NO,) and carbon monoxide (CO) from each engine shall be conducted quarterly using a portable flue gas analyzer as specified in Condition -1+-i. Iz. °t•Z 1-9-?. Fuel consumption for each engine shall not exceed the limitations above (Colorado Construction Operating Permit Number: )yOPWE'_'07 ISSUED: 10/1199 Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 t f 4.I.e.ea i t „, �i..l Ift•eiter SOat; t_ }s 444 ollocn440v. North American Resources Company Ft. Lupton Plant Page 21 Permits 97WE0728 and 97WE0729). Within the first seven days of every month, the fuel meter shall be read and recorded.,Allocation of fuel use shall be made using the methods detailed in Appendix H of this permit. TV fuel use shall be measured no more than twelve (12) hours from the time that run time hours have been recorded. A twelve month rolling total shall be maintained for demonstration of compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. {� Mteded. Ine urs X8-3. „Hours of operation for each engine shall be recorded on a monthly basis for use in fuel 9. i allocation calculations. 144. Opacity of emissions from each engine shall not exceed 20 % (Colorado Construction Permits 9 `t 97WE0728 and 97WE0729). In the absence of evidence to the contrary, compliance with the 20% opacity limit shall be presumed whenever natural gas is used as fuel for these engines. 1-675. The Btu content of the natural gas used to fuel these engines shall be determined semi-annually 4.s using ASTM Analysis Method D1945 or equivalent. Calculation of monthly emissions outlined under Condition 10.1 shall be based on the most recent BTU analysis. The BTU Content shall be based on the lowest gross heating value of the fuel. 14376. These engines shall be operated and maintained in accordance with manufacturer's recommendations at all times, including periods of start-up, shutdown, and malfunction. Onser+ Sxc4 ois )0 o.•d l�� s.11,41ed) Portable Monitoring -1-+--f. Emission measurements of nitrogen oxides (NO„) and carbon monoxide (CO) from each engine 12 •' shall be conducted quarterly using a portable flue gas analyzer. Calibration of the analyzer shall be conducted according to manufacturer's instructions. Results of the portable flue gas analyzer tests shall be used to monitor the compliance status of each engine. For comparison with an annual or short term emissions limit, the results of the tests shall be converted to a lb/hr basis aild multiplied by the allowable operating hours in the month or year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever applies. An exceedance of either the NO, or CO emission limitation during the initial portable flue gas analyzer test shall require a subsequent portable analyzer test indicating compliance with both the NO, and CO emission limitations within 14 calendar days of the initial test. Calibration cases shall be used to calibrate the portable analyzer for all tests conducted subsequent to the initial test. Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 10. S020 — One Solar Centaur Low-NOx IC Turbine (4700 HP) Parameter Permit Condition Number Limitations Short Term Long Term Compliance Emission Factor Monitoring Method Interval NOx 10.1 NA 49.0 tonsiyr 0.30 lb/MMBtu Recordkeeping, Calculation and Portable Monitoring Monthly, Quarterly CO NA 35.5 tons/yr 0.21 IbiMMBtu VOC NA 10.2 tons/yr 0.06 lb/MMBtu NSPS Subpart GG ' 10.2 NOx - 157.5 ppmv* NA Fuel Restriction Annually SO, — 150 ppmv* NA Fuel Sulfur content _ 0.8% by weight NA NSPS General Provisions 10.3 NA NA NA As Defined As Defined Fuel Use 10.4 NA 320 MMSCF/yr NA Fuel Meter Monthly Opacity 10.5 Less than or Equal to 20% NA Fuel Restriction At All Times Btu Content 10.6 NA NA NA ASTM Analysis Method Semi - Annually * at 15% O, on a dry basis 10.1 Emissions of Nitrogen Oxides, Carbon Monoxide and Volatile Organic Compounds shall not exceed the limitations stated above (Colorado Construction Permit 01WE0290). Emissions shall be calculated by the end of the subsequent month using the listed compliance emission factors (EF) in the following equation: Lbs/month = [EF x monthly fuel use (MMscf/month) x heat content of gas (Btu/scf)] A twelve-month rolling total shall be maintained for demonstration of compliance with annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months data. Emissions measurements of nitrogen oxides (NOx) and carbon monoxide (CO) from each engine shall be conducted quarterly using a portable flue gas analyzer as specified in Condition 12.1. 10.2 This source is subject to the New Source Performance Standards (NSPS) requirements of Regulation No. 6, Part A, Subpart GG, Standards of Performance for Stationary Gas Turbines (as adopted by reference from 40 CFR 60, Subpart GG, and as cited in Colorado Construction Permit 01W E0290 10.2.1. Emissions of Nitrogen Oxides (NOx) shall not exceed the limitations stated above (NSPS Subpart GG, §60.332). 10.2.2. Emissions of Sulfur Dioxide (SO2) shall not exceed the limitations stated above (NSPS Subpart GG. §60.333). Compliance with these standards and with the monitoring provisions of §60.334(b) was demonstrated by determining fuel -bound nitrogen when permitting the engine, and by conducting a performance test in accordance with the provisions of Regulation No. 6, Part A, Subpart A, Section 60.8. on March 6, 2002. In the absence of evidence to the contrary, ongoing compliance with these standards, the monitoring provisions of §60.334(b), and the testing methods of §60.335(e) shall be presumed whenever pipeline quality natural gas is used as fuel for the turbine. 10.3 The following requirements of Regulation No. 6, Part A, Subpart A, General Provisions also apply (as adopted by reference from 40 'CFR 60): 10.3.1 At all times, including periods of start-up, shutdown, and malfunction, the facility and control equipment shall, to the extent practicable, be maintained and operated in a manner consistent with good air pollution control practices for minimizing emissions. Determination of whether or not acceptable operating and maintenance procedures are being used will be based on information available to the Division, which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. (NSPS Subpart A, §60.1 I, and Colorado Construction Permit 01WE0290) 10.3.2 No article, machine, equipment or process shall be used to conceal an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gases discharged to the atmosphere. (NSPS Subpart A,§60.12, and Colorado Construction Permit 01WE0290) 10.3.3 A notification of any physical or operational change to an existing facility which may increase the emission rate of NOx or SO, (NSPS Subpart A, §60.7 (a)(4)). 10.3.4 Records of startups, shutdowns, and malfunctions shall be maintained, as required. (NSPS Subpart A, §60.7, and Colorado Construction Permit 01WE0290) 10.4 Fuel consumption shall not exceed the limitations above (Colorado Construction Permit 01WE0290). Within the first seven days of each month, fuel use shall be recorded. A twelve month rolling total shall be maintained for demonstration of compliance with the annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months' data. 10.5 Opacity of emissions shall not exceed 20% (Colorado Construction Permit 01WE0290). In the absence of evidence to the contrary, compliance with the 20% opacity limit shall be presumed whenever natural gas is used as fuel for this engine. 10.6 '1 he Btu content of the natural gas used to fuel this engine shall be determined semiannually using ASTM Analysis Method D1945 or equivalent. Calculation of monthly emissions outlined under Condition 1 1. I shall be based on the most recent Btu analysis. The Btu content shall be based on the low gross heating value of the fuel. 10.7 These engines shall be operated and maintained in accordance with manufacturer's recommendations at all times, including periods of start-up, shut -down and malfunction. 11. S021 — One Flare Industries Air -Assisted Flare Parameter Permit Limitations Compliance Emission Monitoring Condition Short Factor Number Term Long Term Method Interval I x CO VOC NA 3.5 tons/yr 6.8 tons/yr 1.2 tons/yr 46.4 MMSCF`yr NA 150.951 lb/MMSCF NA 295231 lb-'MMSCF NA 50.485 IbMMSCF Recordkeeping Monthly and Calculation Fuel Use 11.2 NA NA Estimate Monthly Opacity 11.3 NA NA Visual Observations Weekly Emissions of Nitrogen Oxides, Carbon Monoxide and Volatile Organic Compounds shall not exceed the limitations stated above (Colorado Construction Permit 02WE0927). Emissions shall be calculated by the end of the subsequent month using the listed compliance emission factors (EF) and the monthly fuel use. A twelve-month rolling total shall be maintained for demonstration of compliance with annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months data. 11.2 Fuel consumption shall not exceed the limitations above (Colorado Construction Permit 02WE0927). By the end of the subsequent month, the fuel shall be estimated. A twelve month rolling total shall be maintained for demonstration of compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 11.3 Opacity of emissions shall not exceed 20% (Colorado Construction Permit 02WE0927). Compliance with the permit limitations shall be monitored by conducting visual observation of emissions weekly, during normal operation. If excessive (> 20%) visible emissions are observed, the source shall investigate equipment performance and make any adjustments necessary. If, after maintenance has been performed, excessive visible emissions persist for longer than one hour, an EPA Reference Method 9 opacity observation shall be performed to determine compliance with the opacity standard. The EPA Reference Method 9 opacity observations shall be performed by an observer with current and valid Method 9 certification. Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 North American Resources Company Ft. Lupton Plant Page 22 If portable flue gas analyzer results indicate compliance with both the NO, and CO emission limitations within the 14 day period, the source may certify that the engine is in compliance with both the NO, and CO emission limitations for the relevant time period. If portable flue gas analyzer results fail to indicate the compliance of the engine with either the NO, or CO emission limitations within the 14 day period, the source will notify the Division in writing within 10 calendar days of the end of the 14 day period. Results of all testing that indicates noncompliance shall be submitted to the Division within 10 calendar days of the end of the 14 day period. The source will be required to conduct EPA Reference Test Methods (identified as Reference Method 7E and Reference Method 10. or Reference Method 19 (40C.F.R. Part 60 Appendix A), hereinafter "EPA Reference Test Methods") or other test methods or procedures acceptable to the Division within 45 calendar days of the end of the 14 day period allowed for the portable flue gas analyzer testing. The Division shall be notified at least 30 calendar days prior to the EPA Reference Test date, so that it may choose whether to observe the testing. If the EPA Reference Test results indicate compliance with both the NO, and CO emission limitations, the source may certify that the engine is in compliance with both the NO, and CO emission limitations for the relevant time period. If the EPA Reference Tests fail to demonstrate compliance with either the NO, or CO emission limitations and in the absence of evidence to the contrary, the engine will be considered to be out of compliance from the date of the initial portable flue gas analyzer test until the engine is taken off line. Results of all testing that indicates noncompliance shall be submitted to the Division within .14 calendar days after receipt of the test results. Results of all tests conducted shall be kept on site and made available to the Division upon request. Operating Permit Number: 99OPWE207 ISSUED: I0/1/99 Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 SECTION III - Permit Shield North American Resources Company Ft. Lupton Plant Page 23 Regulation No. 3, 5 CCR. 1001-5, Part A, S I.B.43: Part C, §§_ V.C.I.b. & D., XIII., 25-7-111(2)(I), 25- 7-114.4(3)(a), C.R.S. 1 Specific Non -Applicable Requirements The following parameters and requirements have been specifically identified as non -applicable to the facility to which this permit has been issued: Emission Unit Description & Number Applicable Requirement Justification Unit S009 Regulation No. 3, Part B, Section III.A Unit S009 is exempt from construction permitting requirements per exemption letter (95WE409.XP). Criteria emissions are below deminimis, however H2S emissions are above non -criteria reportable thresholds. Entire Facility Regulation No. 3, Part B, Section IV.D.3 (PSD) Based on the information provided, this facility is not a major stationary source (no criteria pollutant emissions potential to emit > 250 tons per year) with respect to Prevention of Significant Deterioration (PSD) requirements as of the issue date of this permit. Unit S014 Regulation No. 6, Part A, Subpart Dc (40 CFR 60 Subpart Dc §§60.42c; 60.43c, 60.44c; 60.45c: 60.46c; 60.47c; 60.48c(b), (c), (d), (e) and (f)) These sections are based on the use of either coal or fuel oil. This source utilizes only natural gas. t rer + kAodkd 2. General Conditions Compliance with this Operating Permit shall he 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 §S 25-7-112 and 25-7-1 13. C.R.S.. or § 303 of the federal act, concerning Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 SECTION III — Permit Shield Please add the following to the permit shield: Emission Unit Description & Number Applicable Requirement Justification Unit S020 Regulation No. 6, Part A, Subpart GG (40 CFR 60) §§60.334 (a) and (c) (I) and §60.335 (c)(2). These sections pertain to the use of water injection to control NOx. This source uses lean premixed combustion instead. Unit S020 Regulation No. 6, Part A, Subpart GG (40 CFR 60) §60.334 (c) (2) The use of natural gas as fuel is sufficient to demonstrate compliance with the fuel sulfur content limit, thus the reference to excess emissions does not apply. Air Pollution Control Division Colorado Operating Permit Appendices OPERATING PERMIT APPENDICES A - INSPECTION INFORMATION B - COMPLIANCE MONITORING REPORT FORMAT C - COMPLIANCE CERTIFICATION REPORT FORMAT D - NOTIFICATION ADDRESSES E - PERMIT ACRONYMS F - PERMIT MODIFICATIONS *DISCLAIMER: None of the information found in these Appendices shall be considered to be State or Federally enforceable and is presented to assist the source, permitting authority, inspectors, and citizens. Operating Permit Number: 9'OPWE 07 ISSUED: 10/1;99 Air Pollution Control Division Colorado Operating Permit Inspection Information Appendix A Page 1 APPENDIX A - Inspection Information 1. Directions to Plant: From Ft. Lupton, follow US 85 north approximately 4 miles to Weld County Road 22. Turn right, cross the railroad tracks and continue east along WCR approximately 3 miles. Ft. Lupton plant is on the left (north) side of the road. 2. Safety Equipment Required: Eye Protection, Hard Hat, Safety Shoes, and Hearing Protection. Facility Plot Plan: Figure 1 (following page) shows the plot plan as submitted on February 24, 1999 with the source's Title V Operating Permit Application. 4. List of Insignificant Activities: The following list of insignificant activities was provided by the source to assist in the understanding of the facility layout. Since there is no requirement to update such a list, activities may have changed since the last filing. Insignificant activities and/or sources of emissions as submitted in the application are as follows: Stabilization heater, 1.02 MMBtu/hr Heater for Process Train 1, 1.09 MMBtu/hr Heater for Process Train 2, 3.17 MMBtuihr cruder oil or wastewater tanks, 8400 gallons each ne brine tank, 8400 gallons J 2, (boo 5000 'Is One Methylethanolamine (MDEA) tank, 8400 gallons One deionized water tank, 4200 gallons Two pressurized butane tanks, 24,600 gallons each Six pressurized raw mix tanks. 30.000 gallons each Six pressurized propane tanks, 30.000 gallons each One pressurized natural gasoline tank. 30.000 gallons Three pressurized butane tanks, 42.000 gallons each Three pressurized natural gasoline tanks. 42.000 gallons each One pressurized natural gasoline tank. 71,000 gallons lck• +m MMg+►�/h/ ' I.c 1'wo crwit **it +oaks, 23,000 ao.l eoc1+ Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Format APPENDIX B Required Format for Monitoring and Permit Deviation Report - Part I Appendix B Page 5 L Following is the format for the Monitoring and Permit Deviation report to he submitted to the Division on a semi- annual basis unless otherwise noted in the permit. The Table below must he completed for all equipment or processes for which specific Operating Permit terms exist. Part El of this Appendix B shows the format and information the Division will require for describing periods of monitoring and permit deviations, or upset or emergency conditions as indicated in the Table below. One Part 11 Form must be completed for each Deviation. FACILITY NAME: North American Resources Company - Ft. Lupton Plant OPERATING PERMIT NO:99OPWE207 REPORTING PERIOD: (see first page of the permit for specific reporting period and dates) Operating Permit Unit ID Unit Description Deviations noted During Period?' Deviation Code Upset/Emergency Condition Reported During Period? YES NO YES NO S001 Ajax DPC-S40LE, 2 -Cycle Lean Burn, Low NOx design, Natural Gas Fired Internal Combustion Engine, Site Rated at 514 HP. SN: 83891. S002 Ajax DPC-540LE, 2 -Cycle Lean Burn, Low NOx design, Natural Gas Fired Internal Combustion Engine, Site Rated at 5.14 HP. SN: 83892. S003 Ajax DPC-540LE, 2 -Cycle Lean Burn. Low NOx design, Natural Gas Fired Internal Combustion Engine, Site Rated at 514 HP, SN: 83889. Operating Permit Number: 90O13W F207 ISSUED: 10:1:0() Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Format Appendix B Page 6 Operating Permit Unit ID Unit Description Deviations noted During Period?' Deviatipn Code Upset/Emergency Condition Reported During Period? YES NO YES NO I S004 Ajax DPC-540LE, 2 -Cycle Lean Burn, Low NOx design. Natural Gas Fired Internal Combustion Engine, Site Rated at 514 HP, SN: 83890. I S007 Fugitive VOC Emissions F u o I S009 Amine Treating Unit, Rated at 2,500 bbl/d of Natural Gas Liquids. 'S, 000 SO10 Elastec Smart Ash Model 100 Incinerator, fl SA 18894, Design Rated at 48 lbs/hr and 0.4 '1-- -MMDte/l,r. S012 Ajax DPC-2803LE, 2 -Cycle Lean Burn.. Low NOx design. Natural Gas Fired internal Combustion Engine, Site Rated at 550 HP. SN: 84286. S013 Born Natural Gas Fired Amine Unit Heater. Design Rated at 10.7 MMBtu/hr, Model and SN: 2885-0. S014 Born, Inc Natural Gas Fired Hot Oil Heater, Design Rated at 32 MMBtu/hr. SN: 1963. S015 Ajax DPC-2803 LE. 2 -Cycle Lean Burn. Low NOx design. Natural Gas Fired Internal Combustion Engine. Site Rated at 550 HP, SN: 84308. SO16 Ajax DPC-2803LE. 2 -Cycle Lean Burn. Low NOx design. Natural Gas Fired Internal Combustion Engine. Site Rated at 550 HP. SN: S4288. Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Format Appendix B Page 7 Operating Permit Unit ID Unit Description Deviations noted During Period. Deviation Code Upset/Emergene% Condition Reported During Per od? YES NO YES NO S017 Ajax DPC-2803LE, 2 -Cycle Lean Burn, Low NOx design, Natural Gas Fired Internal Combustion Engine, Site Rated at 550 HP, SN: 84287. S018 Caterpillar G3516TALE, 4 -Cycle Lean Burn, Natural Gas Fired Internal Combustion Engine, Site Rated at 980 HP, SN: 3RCO1237. S019 Caterpillar G3516TALE, 4 -Cycle Lean Burn, Natural Gas Fired Internal Combustion Engine, Site Rated at 980 HP, SN: 3RCO1240. 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. Use the following entries, as appropriate: 1 = Standard:: 2 = Process: 3 = Monitor: 4 = Test: 5 = Maintenance: 6 = Record: 7 = Report: 8 = Other: When the requirement is an emission limit or standard When the requirement is a production/process limit When the requirement is monitoring When the requirement is testing When required maintenance is not performed When the requirement is recordkeepin, When the requirement is reporting. When the deviation is not covered by any oldie above categories Se20 Solt Solar Ctn}aw '4.C Law -410x. Mallow Gas R,ed I�Ie•�4 ��,,,b.H+o•►?'t',.�D' e, Silt 4.+a/ at 417°4 MSD'it bee putt. Fiara. tndttS4,1 e, A- A4"''s"+mt Fiat. Operating Permit Number: 99OPWE207 ISSUED: I(1/;Po Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Format Required Format for Deviation Report - Part II FACILITY NAME: North American Resources Company - Ft. Lupton Plant OPERATING PERMIT NO: 99OPWE207 REPORTING PERIOD: Type of deviation (see footnote 2 above): Is the deviation being claimed as an: Emergency Upset N/A (For NSPS/MACT) Did the deviation occur during: Startup OPERATING PERMIT UNIT IDENTIFICATION: Operating Permit Condition Number Citation Explanation of Period of Deviation Appendix B Page 8 Shutdown Malfunction Normal Operation Duration (start/stop date & time Action Taken to Correct the Problem Measures Taken to Prevent a Reoccurrence of the Problem Dates of Upsets Emergencies Reported (if appiicable) SEE EXAMPLE ON THE NEXT PAGE Oneratimi Permit Number: 0QOPW 207 ISSUED: ' 0 i'9c) Air Pollution Control Division Colorado Operating Permit Compliance Certification Report Format APPENDIX C Appendix C Page I Required Format for Annual Compliance Certification Report Following is the format for the Compliance Certification report to be submitted to the Division and the U.S. EPA annually based on the effective date of the permit. The "Fable below must be completed for all equipment or processes for which specific Operating Permit terms exist. FACILITY NAME: North American Resources Company-- Ft. Lupton Plant OPERATING PERMIT NO: 99OPWE207 REPORTING PERIOD: I. Facility 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. 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, EXCEPT for the deviations identified in the table below. 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) If any deviations for any permit term or condition occurred during the annual reporting period, fill in the required information for all emission points (regardless of compliance status) in the following table. Operating Permit Unit ID Unit Description Deviations Reported ' Compliance Status?-- Monitoring Method per Permit?' Was Data Continuous?4 Previous Current IN OUT YES NO YES NO SOOT Ajax DPC-S4OLE. 2 -Cycle Lean Burn. Low NOx design, Natural Gas Fired Internal Combustion Engine, Site Rated at 514 HP. SN: 83891. Operating Permit Number: 900PWE'U7 1'SI 'ED: H)! 1:'9' Air Pollution Control Division Colorado Operating Permit Compliance Certification Report Format Appendix C Page 2 Operating Permit Unit ID Unit Description Deviations Reported ' Compliance Status?' Monitoring Method per Permit?' Was Data Continuous?' Previous 1 Current IN OUT YES NO YES NO S002 Ajax DPC-540LE, 2 -Cycle Lean Burn, Low NOx design, Natural Gas Fired Internal Combustion Engine, Site Rated at 514 HP, SN: 83892. S0011 Ajax DPC-540LE. 2 -Cycle Lean Burn, Low NOx design, Natural Gas Fired Internal Combustion Engine, Site Rated at 514 HP, SN: 83889. S004 Ajax DPC-540LE, 2 -Cycle Lean Burn, Low NOx design, Natural Gas Fired Internal Combustion Engine, Site Rated at 514 HP, SN: 83890. S007 Fugitive VOC Emissions S are --- \ �- 250 Flare S009 Amine Fc eating Unit, Rated at=4 bbl/d of Natural Gas Liquids. S010 Elastec Smart Ash Model 100 Incinerator, SA 18804, . Design Rated at 48 lbsihr S012 Ajax DPC-2803LE, 2 -Cycle Lean Burn, Low NOx design. Natural Gas Fired Internal Combustion Engine, Site Rated at 550 HP, SN: 84286. Operatin<e Permit Number: 0°OPWE207 ISSUED: 10/1199 Air Pollution Control Division Colorado Operating Permit Compliance Certification Report Format Appendix C Page 3 Operating Permit Unit ID Unit Description Deviations Reported ' Compliance Status?: Monitoring Method per Permit'" Vvas Data Continuous?' Previous Current IN OUT YES NO YES NO S013 Born Natural Gas Fired Amine lJnit Heater, Design Rated at 10.7 MMBtu/hr, Model and SN: 2885-0. S014 Born, Inc Natural Gas Fired Hot Oil Heater, Design Rated at 32 MMBtu/hr, SN: 1963. S015 Ajax DPC-2803LE, 2 -Cycle Lean Burn, Low NOx design, Natural Gas Fired Internal Combustion Engine, Site Rated at 550 HP, SN: 84308. S016 Ajax DPC-2803LE, 2 -Cycle Lean Burn, Low NOx design, Natural Gas Fired Internal Combustion Engine, Site Rated at 550 HP, SN: 84288. S017 Ajax DPC-2803LE, 2 -Cycle Lean Burn, Low NOx design, Natural Gas Fired Internal Combustion Engine, Site Rated at 550 HP, SN: 84287, S018 Caterpillar O3516TALE, 4 - Cycle Lean Burn, Natural Gas Fired Internal Combustion Engine, Site Rated at 980 HP. SN: 3RCO 1237. Operating Permit Number: Q9OPWE O7 ISSUED: '0r°O Air Pollution Control Division Colorado Operating Permit Compliance Certification Report Format Appendix C Page 4 Operating Permit Unit ID Unit Description Deviations Reported' Compliance Status?' Monitoring Method per Permit?' Was Data Continuous?' Previous Current IN OUT YES NO YES NO S019 Caterpillar G3516TALE, 4 - Cycle Lean Burn, Natural Gas Fired Internal Combustion Engine. Site Rated at 980 HP. SN: 3 RCO 1240. General Conditions Insignificant Activities s If deviations were noted in the previous deviation report (i.e. for the first six months of the annual reporting period), put an "X" under "previous". If deviations were noted in the current deviation report (i.e. for the last six months of the annual reporting period), put an "X" under "current". Mark both columns if both apply. 2 Fill in this column for all listed points. ' 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 informationiexplanation. "Note whether the method(s) used to determine the compliance status with each term and condition provided continuous or intermittent data. Compliance status for these sources shall he based on a reasonable inquiry using readily available information. `Jo2o Solar. CeA+nur 'Fo, L4 uw-nl0x) pl 4 eo1 69s Preal 1n4trna,l Cp..bu$+0„ TaolcuAe., S14ka+tJ a+ 4700 I+P StJ bCGO20$. 1nClNs' is A« - Ass;s4-ed Flare_ S02-1 1 )peratinu Permit Number: 99OPWE207 ISSUED: 1011/99 Air Pollution Control Division Colorado Operating Permit Fuel Allocation APPENDIX H Fuel Allocation Appendix H Page 1 *The methods outlined will be used to calculate fuel use for Units S001 - S004, S068t S012 -S01-9- i f da4t (•rem• a•* ;4'W46=t fast N+s.44tr- is v►a+svm:(ah►e.. 2.1 a•.• A) FUEL ALLOCATION TO INDIVIDUAL UNITS For Each Piece of Equipment, Fuel Use = [Fuel Design Rate] [Hrs. of Operation] X [Facility Fuel Use for Month] [Sum of Numerator for Each Engine] Unit Number Fuel Design Rate S001 4.01 MMBtu/hr S002 4.01 MMBtu/hr S003 4.01 MMBtu/hr S004 4.01 MMBtu/hr S008 6.11 MMBtu/hr S012 4.46 MMBtu/hr S013 10.7 MMBtu/hr Unit Number Fuel Design Rate S014 32 MMBtu/hr S015 4.46 MMBtu/hr S016 4.46 MMBtu/hr S017 4.46 MMBtu/hr S018 7.38 MMBtu/hr S019 7.38 MMBtu/hr *Allocated Fuel Use shall be determined within the first seven days of each month based on the monthly hours of operation for each listed piece of equipment from the previous month. Operating Permit Number: 99OPWE2'07 ISSUED: 10/1/99 Please process the attached permit modification for 99OPWE207, Fort Lupton Plant under the minor modification procedures outlined in Colorado Regulation 3, Part C, Section X. To the best of my knowledge and understanding, these documents meet the criteria outlined in Regulation 3, Part C, Section X.D. for processing as a minor permit modification. �. wo.J Jesse Wood Acting Vice President EnCana Gathering Services (USA) Inc. 3t>/ 20o Date c_nir 'Basics, Izt: 495 High Street • Denver, CO 50218 • (303) 329-9295 • FAX (303) 329-9295 • Maggieairbasics@aol.com April 27, 2004 Mr. Geof Drissel, Permit Engineer Operating Permit Unit/APCD-SS-B 1 Colorado Dept. of Public Health & Env. 4300 Cherry Creek Drive South Denver, CO 80246-1530 RE: Another Minor Modification of Operating Permit 99OPWE207 for EnCana's Fort Lupton Plant Dear Mr. Drissel: Some time ago, EnCana installed individual fuel meters on some of the equipment out at the Fort Lupton plant. It has recently become apparent that one of the engines is using more fuel than previously thought. At this rate, the engine will exceed its permitted fuel use and NOx limits some time in the future. Attached is a complete application to modify Operating Permit 99OPWE207 by increasing the fuel consumption and the NOx limit on this engine (S003) and all the other engines of its size (S001 - S004). Please process this application as a minor permit modification in accordance with the provisions of Regulation 3, Part C, Section X.D. 1. We are requesting the following increased fuel and emissions limits for S001 - S004: Fuel Consumption: 51.0 MMSCF/yr NOx — 14.0 tpy The CO and VOC limits can remain the same. 2. The suggested draft permit. An annotated version of the current operating permit is provided. 3. Certification by a responsible official that the proposed modification meets the criteria for use of the minor permit modification procedures is attached. 4. It is our understanding that the Division is responsible for supplying forms to notify EPA and affected states of this permit revision. 5. The applicable regulations remain the same. 6. A copy of the APEN dated April 27, 2002 is attached. Please issue this permit to EnCana Gathering Services (USA) Inc. Please contact me at (303) 329-9295 if you have any questions on this application. Thank you, Air Basics, Inc. Maggie Scher Air Quality Specialist Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 North American Resources Company Ft. Lupton Plant Page 5 SECTION II - Specific Permit Terms S001 -S004 - Four Ajax 2 -Cycle Lean Burn ICEs (514 HP each) Parameter Permit Condition Number Limitations for each engine Short Term Long Term Compliance Emission Factor Monitoring Method Interval NOx 1.1. NA 1+6 tons/yr 0.514 lb/MMBtu Recordkeeping, Monthly, CO NA 11.6 tons/yr 0.3b1b/MMBtu Calculations and Portable Monitoring Quarterly VOC NA 5.8 tons/yr 0.15Ib/MMBtu Fuel Use 1.2. NA 57. 57 '" MMscf/yr NA Fuel Allocation (see Appendix H) Monthly Hours of Operation 1.3. NA NA NA Recordkeeping Monthly Opacity 1.4. Less Than or Equal to 20% NA Fuel Restriction At All Times Btu Content 1.5. NA NA NA ASTM Analysis Method Semi - Annually Emissions of Nitrogen Oxides, Carbon Monoxide and Volatile Organic Compounds from each engine shall not exceed the limitations stated above (Colorado Construction Permits 93 WE 157- (1-4)). Emissions shall be calculated by the end of the subsequent month using the listed compliance emission factors (EF) in the following equation: Lbs/month = [EF x monthly fuel use (MMsef/month) x heat content of gas (Btu/scf)] A twelve-month rolling total shall be maintained for demonstration of compliance with annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months data. Emission measurements of nitrogen oxides (NO,) and carbon monoxide (CO) from each engine shall be conducted quarterly using a portable flue gas analyzer as specified in Condition -1-H-: ( Qtnu..Der) 12.1 Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 Pollution Control Division lorado Operating Permit uel Allocation APPENDIX H Fuel Allocation Appendix -H--- Page 1 *The methods outlined will be used to calculate fuel use for Units S001 - S004, S008, S012 -S019 da+a is ne{ c�la:lablc, A) FUEL ALLOCATION TO INDIVIDUAL UNITS For Each Piece of Equipment, Fuel Use = [Fuel Design Rate1[Hrs. of Operation] X [Facility Fuel Use for Month] [Sum of Numerator for Each Engine] Unit -Number Fuel Design Rate 5001 MMBtu/hr S002 S003 ti 44: [z S004 • MMBtu/hr MMBtu/hr -gi MMBtu/hr S008 6.11 MMBtu/hr S012 4.46 MMBtu/hr Unit Number S014 S015 S016 S017 S018 Fuel Design Rate 32 MMBtu/hr 4.46 MMBtu/hr 4.46 MMBtu/hr 4.46 MMBtu/hr 7.38 MMBtu/hr S019 7.38 MMBtu/hr S013 10.7 MMBtu/hr I *Allocated Fuel Use Shall be determined within the first seven days of each month based on the monthly hours of operation for each listed piece of equipment from the previous month. Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 Please process the attached permit modification for 99OPWE207, Fort Lupton Plant under the minor modification procedures outlined in Colorado Regulation 3, Part C, Section X. To the best of my knowledge and understanding, these documents meet the criteria outlined in Regulation 3, Part C, Section X.D. for processing as a minor permit modification. Dean Purcellit, Vice President EnCana Gathering Services (USA) Inc. -I-so - oy Date AIR POLLUTANT EMISSION NOTICE 5- . j..., PERMIT No.:99OPWE207_ AIRS ID.:_123_/0319_/ FIRM NAME EnCana Gathering Services (USA) Inc. ' -1-6,C975/ 1 MAIL ADDRESS 1313 Denver Avenue, Building #1_Fort Lupton f _ ) PLANT NAME & LOCATION Fort Lupton Plant: 16157 Weld County Road 22, Fort Lupton, CO "80621" " REQUEST PORTABLE SOURCE PERMIT HOME -BASE FOR PORTABLE SOURCE PERSON TO CONTACT REGARDING THIS INFORMATION Dena Lund GENERAL DESCRIPTION OF THIS PLANT'S FUNCTION Natural gas processin plant EMAIL ADDRESS Dena Lund�EnCana tom 4P," STATE: CO ZIP: 80621 COUNTY: Weld TITLE DJ Field Superintendent PHONE_(303) 659-7740_ A. GENERAL INFORMATION Normal Operation of This Source Process Seasonal Throukhput (% of Annual) ADDITIONAL INFORMATION OR REMARKS: Hours/Day 24 Days/Week 7 Weeks/Year 52 Dec -Feb 25 Mar -May 25 Jun -Aug 25 Sep -Nov 25 III,, LA B. STACK OR VENT INFORMATION (Identify below which stack if plant has two or more; refer to attached sketch of plant layout) Height 25.25 ft Diameter 1.44 ft Temperature 465 °F Flow Rate 1 4280 ACFM _r.. Velocity 2628 ft/min Moisture 8 % Plant ID No. for Stack S003, C -101C C. FUEL INFORMATION Design Input Rate wi►�-_. _._ _�._ _. Annual Fuel Consumption r.l Fuel Heating - Value: - Percent by Weight Seasonal Fuel Use (% of Annual Use) Space F Description of Combustion Unit (106 BTU/hr) Kind of Fuel Burned Requested level M •% g G F /),r , Actual level (Data year level) (BTU/lb, BTU/gal, or BTU/scf) Sulfur Ash Dec -Feb Mar -May Jun -Aug Sep -Nov (% Mr 514 hp (site rated) Compressor Engine Natural Gas 5. 0 0 0 25 25 25 25 Make/Model: Ajax DPC-540 LE Serial No. 83889•c) o --' D. PROCESS INFORMATION Raw Materials Used Raw Materials -Annual Consumption Design Process Rate Finished Product Finished Product -Annual Output Description of Processing Unit Description Requested level Actual level (Data year level) (Specify Units/Hour) Description Requested level Actual level (Data year leve Make/Model: Serial No.: . ...�.. .I p9w� _. W _r.I LI n �i.l. ��♦ abnAwA. I r 1 r ♦\ E. POLLUTION CONTROL EQUIPMENT Overall ESTIMATED EMISSIONS (TONS/YEAR) AT THROUGHPUTS REQUESTED ABOVE ACTUAL EMISSIONS (from data year) ESTIMATION METHOD CHECK ALL BOXES THAT APPLY O New or previously unreported source* Pollutant Type of Control Equipment Collection Efficiency Primary Secondary CONTROLLED UNCONTROLLED O Requesting modification of existing permit t$ Particulate ■ Ctiange in emissions, throughputs or equipment # PMI0 O Transfer of ownership SO, (List previous owner in REMARKS section of box A.) $ NO, Lean Burn Id. O I ( -0 .8:1 alow. O Previous APEN is expiring j VOC Lean Burn 3. 0 O Request for Emission Reduction Credit t2 CO Lean Burn to .b 4c8 O (Specify) PLEASE USE POLLUTANT APCD NON -CRITERIA REPORTABLE AIR ADDENDUM FORM TO REPORT SUCH OR POLLUTANTS NOT LISTED ABOVE. O CHECK HERE IF YOU WISH THE DIVISION TO CALCULATE YOUR * Complete all applicable portions of APEN "EMISSION t Complete Requested Level' values for permit limits EMISSIONS. SEE ESTIMATES" INSTRUCTIONS ON BACK. j Complete all information above box A, and those remaining which reflect changes Signature of Person Legally Authorized to Supply D 4,,,,,____(, DATE/2-2/0‘71-portions ( FEAR $0TWErin i`FiE3 Ci'I)AL DAIFA APPLIES: 2003 Date source began or will begin operation: 1993 Typed Name and Title: Dena Lund, DJ Field Superintendent A \I.. - - THIS NOTICE IS VALID FOR FIVE YEARS. A revised notice shall be filed prior to this expiration date, whenever a permit limitation must be modified, whenever control equipment is changed, and annually whenever a significant emission change occurs. For specific details see Regulation 3, Part A, § II.C.1. I \ 11 f 11r- r A A $119.96 FILING FEE IS REQUIRED FOR EACH NOTICE FILED. Send completed forms with fees to: Colorado Dept. of Public Health & Environment APEN k_4 of Air Pollution Control Division 4300 Cherry Creek Drive South, APCD-SS-B1 For Information, Call Denver, Colorado 80246-1530 (303) 692-3150 NON -CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM" (Instructions on reverse side) Permit Number 99OPWE207 Company Name: Plant Location: Person to Contact: E -Mail Address: EnCana Gathering Services (USA) Inc. AIRS Nu -fitter 123/0319/003q Fort Lupton Plant Dena Lund, DJ Field Superintendent Dena.Lund@EnCana.com County Weld Zip Code 80621 Phone (303) 659-7740 Fax (303) 857-1259 :.hemical Abstract Service Number Chemical Name Reporting Bin Control Equipment Efficiency Emission Factor (include units) Emission Factor Source Requested Emissions (Ibs/yr) Actual Emissions from the Data Year (Ibs/yr) 75070 Acetaldehyde A Lean Burn HAPCaIc v. 3.01 1004 50000 Formaldehyde A Lean Burn HAPCalc v. 3.01 1867 71432 Benzene A Lean Burn HAPCalc v. 3.01 72 107028 Acrolein A Lean Burn HAPCalc v. 3.01 237 Use this form for reporting Hazardous Air Pollutants, Ozone Depleting Compounds, and other Non -Criteria Reportable Pollutants Year For Which The Actual Data Applies: I._ Signature of a Responsible Official (not a vendor or consultant) Dena Lund 1 —77(Oy- Date DJ Field Superintendent 2003 Name of a Responsible Official (please print) Title (1.1 111. .l 3l.ci( , 495 High Street • Denver, CO 80218 • (303) 329-9295 • FAX (303) 329-9295 • Maggieairbasics@aol.com May 24, 2004 Mr. Geof Drissel, Permit Engineer Operating Permit Unit/APCD-SS-B 1 Colorado Dept. of Public Health & Env. 4300 Cherry Creek Drive South Denver, CO 80246-1530 RE: Another (yes!) Minor Modification of Operating Permit 99OPWE207 for EnCana's Fort Lupton Plant Dear Mr. Drissel: EnCana's Fort Lupton plant is subject to NSPS Subpart KKK for Onshore Natural Gas Processing Plants. Section 2.4 of the operating permit above enumerates sections of the KKK regulation which are applicable to the plant. Permit condition 2.4.4 also states adherence to the VOC Testing Program, which is attached as Appendix G to the permit. However, this Program includes monitoring requirements which are much more stringent than those required by Subpart KKK. I discussed this with Bob Jorgenson, who felt that having permit conditions which referenced the NSPS was sufficient for compliance, and that there was no need to include a testing program in addition. Attached is a complete application to modify Operating Permit 99OPWE207 by deleting condition 2.4.4 and the VOC Testing Program currently included in Appendix G. Please process this application as a minor permit modification in accordance with the provisions of Regulation 3, Part C, Section X.D. 1. The requested change is deletion of permit condition 2.4.4 and deletion of the VOC Testing Program in Appendix G. There will be no new emissions or new applicable requirements as a result of this change. The permitted VOC is already an extremely conservative number, and the applicable provisions of NSPS Subpart KKK are already sufficiently enumerated in permit conditions 2.3 and 2.4.1 — 2.4.3. 2. The suggested draft permit. An annotated version of the current operating permit is provided. Deletion of Appendix G will presumably make the current Appendix I -I (Fuel Allocation) into the new Appendix G, and so references to Appendix H in (old) permit conditions 1.2, 6.2, 7.2, 8.2, 9.2, and 10.2 must be changed accordingly. 3. Certification by a responsible official that the proposed modification meets the criteria for use of the minor permit modification procedures is attached 4. It is our understanding that the Division is responsible for supplying forms to notify EPA and affected states of this permit revision. 5. The applicable regulations remain the same. 6. An APEN is not pertinent to this modification. Please issue the modified permit to EnCana Gathering Services (USA) Inc. Please contact me at (303) 329-9295 or at Maggieairbasicsra aol.com if you have any questions on this application. Please note that Air Basics has moved to: 495 High Street, Denver, CO 80218. Thank you, Air Basics, Inc. Maggie Scher Air Quality Specialist Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 North Amvriran RPQnIlT •PC Company -� Ft. Lupton Plant Page 9 Equipment Leaks of VOC from Onshore Natural Gas Processing Plants. The following items apply: 2.4.1. Inspection and maintenance requirements as stated in federal NSPS 40 CFR §60.632, §60.633, and §60.634. 2.4.2. Record keeping requirements as stated in federal NSPS 40 CFR §60.635. 2.4.3. Reporting requirements as stated in federal NSPS 40 CFR §60.636. Reporting under this section is to be fulfilled concurrently with Appendix B compliance monitoring reporting and shall be submitted to the Division. -Appe'ndi--e- S008 - Flare Industries 16" Flare Parameter NOx CO Fuel Use Hours of Operation Opacity ' ermit Co ' ition Numb. 3.1. 3.2. 3.3. 3.4. Limitations Short Term Long Term NA N NA NA 2.68 tons/yr 2.25 tons/ NA Le - Than or Equal to 20% Complian Emissio ' actor 00 lb/MMscf 84 lb/MMscf NA NA NA Monitoring Method Interval Recordkeeping and Calculation Fuel Allocation (See Appendix H) Recordkeeping Monthly Monthly Monthly Visual Observations Weekly 3.1. Emissio . • of Nitrogen Oxides and Carbon Monoxide shall n exceed the limitations stated abov- Colorado Construction Permits 93WE157-8 as modifies der the provisions of Section I C • dition 1.3.). Emissions shall be calculated by the end of the sus - quent month using the isted compliance emission factor (EF) and the monthly fuel use. A tw e -month rolling total shall be maintained for demonstration of compliance with annual limitation . Each month, a new twelve month total shall be calculated using the previous twelve months data. Operating Permit Number: 99OPWE207 ISSUED: 10/1/99 Please process the attached permit modification for 99OPWE207, Fort Lupton Plant under the minor modification procedures outlined in Colorado Regulation 3, Part C, Section X. To the best of my knowledge and understanding, these documents meet the criteria outlined in Regulation 3, Part C, Section X.D. for processing as a minor permit modification. Dean Purcelli Vice President EnCana Gathering Services (USA) Inc. 5 2S_L� Date ENCANA,M EnCana Oil & Gas (USA) Inc. Mr. Geof Drissel, Permit Engineer Operating Permit Unit/APCD-SS-B 1 Colorado Dept. of Public Health & Env. 4300 Cherry Creek Drive South Denver, CO 80246-1530 ,i7,2 1,111 ih(,),t Stutr., `7(? ) Derl;er. w: (:303) 62:1 October 27, 2005 RE: The sixth (?) Minor Modification of Operating Permit 99OPWE207 for EnCana's Fort Lupton Plant Dear Mr. Drissel: EnCana would like to increase permitted fugitive VOC emissions (S007) from 19.0 tpy to 24.0 tpy. Recent monitoring has shown that fugitive VOC emissions are higher than previously thought, although still lower than the permitted limit. Attached is the following documentation to process this request as a minor permit modification in accordance with the provisions of Regulation 3, Part C, Section X.D. - 1. Emissions calculations which show that anticipated emissions are minimal. 2. The suggested draft permit. 3. Certification by a responsible official that the proposed modification meets the criteria for use of the minor permit modification. 4. (It is our understanding that the Division is responsible for supplying forms to notify EPA and affected states of this permit revision.) 5. The applicable requirements are included in the suggested draft permit. 6. An APEN. Please issue the modified permit to EnCana Oil & Gas (USA) Inc. Please contact me at (303) 329-9295 or at Maggieairbasics@aol.com if you have any questions on this application. Please note that Air Basics has moved (again!) to: 542 High Street, Denver, CO 80218. Thank you, Air Basics, Inc. RECtil�4_ S Maggie Scher, Air Quality Specialist ra pCr REcBVED mum NCO Sources r(ZUit M, nl I !It Caul Mr. it, tn I I,,I un�inr hcrnsr Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE207 EnCana Oil & Gas Ft. Lupton Plant Page 6 2. S007 - Fugitive VOC Emissions Parameter Permit Condition Number Limitations Short Term Long Term Compliance Emission Factor Monitoring Method Interval VOC 2.1 NA 49-tons/yr 1'+ By Component Type - EPA Protocol for Equipment Leak Estimates Recordkeeping As Noted Gas Analysis 2.2 NA NA NA EPA Reference Methods Quarterly (To Annually) General Provisions 2.3 NA NA NA Subject to NSPS General Provisions - Leak Detection and Repair 2.4 NA f NA NA Subject to NSPS KKK 2.1 Volatile Organic Compound emissions shall not exceed the limitations stated above (Colorado Construction Permit 93WE157-7 as modified under the provisions of Section I Condition 1.3.) Emissions shall be calculated using the emission factors and equations listed below. Emission Factors for individual types of components in lb/components-hrs (Protocol for Equipment Leak Emission Estimates, EPA -453/R-95-017): Leakers Non-Leakers Equipment Gas Service Light Liq. Service Gas Service Light Liq. Service Connectors - 5.70E-02 5.70E-02 2.20E-05 - 2.10E-05 - Flanges 1.80E-01 , I.60E-01- 1.30E-05- 5.30E-06 Open-ended Line 1.20E-01 - 9.70E-02 3.30E-05 . 3.10E-05 *Other 2.00E-01 1.80E-01- 2.60E-04 - 2.40E-04 Pump 1.60E-01 2.20E-01 7.70E-04 1.10E-03 Valve 2.20E-01 1.90E-01 5.50E-05 - 4.20E-05 Operating Permit Number: 99OPWE207 RENEWED: 3/1/05 CERTIFICATION Please process the attached permit modification for 99OPWE207, Fort Lupton Plant under the minor modification procedures outlined in Colorado Regulation 3, Part C, Section X. To the best of my knowledge and understanding, these documents meet the criteria outlined in Regulation 3, Part C, Section X.D. for processing as a minor permit modification. Date Dean Purcelli Vice President EnCana Oil & Gas (USA) Inc. EnCana Oil Gas (USA) Inc. Ft. Lupton Plant AIRS No./Unit No. S007 Unit Size NA Unit Descrip. Fugitive VOC Make/Model Serial No. Control C. Permit No. Date installed Last APEN filed No. Components Total Connectors 6,014 Flanges 2,962 Open-ended Line 1,077 Other* 162 Pump Seals 48 Valves 3,772 14,035 THC Emission Factors (lb/hr/component): EPA 453/R-95-017 11/95 Gas Svc: Connectors 5.70E-02 Flange 1.80E-01 Open-ended Line 1.20E-01 Other* 2.00E-01 Pump Seal 1.60E-01 Valve 2.20E-01 NA NA Gas Svc: Lt. Liq. Svc: 2,408 3,606 1,186 1,776 468 609 112 50 48 1,516 2,256 5,690 8,345 14,035 Lt. Liq. Svc: 5.70E-02 1.60E-01 9.70E-02 1.80E-01 2.20E-01 1.90E-01 VOC - Leakers (Estimate based on 4/05 - 9/05 KKK monitoring results) Connectors - gas service comps. * 5.70E-02 lb/hr/comp. 8760 hr/y Connectors - light liquid service comps. * 5.70E-02 lb/hr/comp. 8760 hr/y / Flanges - gas service comps. * 1.80E-01 lb/hr/comp. * 8760 hr/y 24.1 36.1 11.9 Flanges - light liquid service comps. * 1.60E-01 Ib/hr/comp. Open-ended Lines - gas service 17.8 4.7 comps. * 1.20E-01 lb/hr/comp. Open-ended Lines - light liquid service comps. * 9.70E-02 lb/hr/comp. Other* - gas service 2.9` nps. * Other* - light liquid service 1.4 comps. . 11.80E-01 I Ib/hr/comp. 6.1 2.00E-01 Pumps - light liquid service 9.0 comps. * Valves - gas service 18.3-6omps. * 12.20E-01 Ilb/hr/comp. Valves - light liquid service 27.5 comps. * 1.90E-01 lb/hr/comp. 2.20E-01 Ib/hr/comp. * 8760 hr/y / 2000 lb/t = Facility ID Code: CO 1230319 / 2000 lb/t = 6.01 tpy HC 2000 lb/t = 9.00 tpy HC / 2000 lb/t = 9.35 tpy HC 8760 hr/y / 2000 lb/t = 12.45 tpy HC 8760 hr/y / 2000 lb/t = 2.46 tpy HC 8760 hr/y / 2000 lb/t = 2.59 tpy HC tpy HC 8760 hr/y / 2000 lb/t = 1.13 tpy HC 2.53 Ib/hr/comp. * 8760 hr/y / 2000 lb/t = 8.67 tpy HC 8760 hr/y / 2000 lb/t = 17.65 tpy HC 8760 hr/y I 2000 lb/t = 22.87 tpy HC *Other includes compressors, diaphrams, drains, dump arms, hatches, instruments, meters, pressure relief valves, polished rods, relief valves, and vents. 94.71 18.53% 17.55 Calculated leaking components using #s from T. Thayer of PSI on 9/2/05: For connectors, flanges and open-ended lines (no KKK monitoring), estimate a 1% leak rate. The leak rate will be low (less than the valve leak rate), because there are no moving parts. This is in line with testing PSI has done at other plants. For "Other," used average leak values from 4/05 - 8/05 testing, which was 0 comprs leaking, and 4.8 prvs leaking per month; divided proportionally between gas and liquid. For pumps, used an average of 8.6 leakers per month; all are in Iliq service. For valves, used an average of 48.8 leakers per month; apportioned between g/v and Iliq. tpy HC Total (Leakers) VOC tpy VOC (Leakers) Air Basics, Inc. S007 - 2006 VOC (Leakers) 10/25/2005 EnCana Oil Gas (USA) Inc. Ft. Lupton Plant AIRS No./Unit No. Unit Size Unit Descrip. Make/Model Serial No. Control C. Permit No. Date installed Last APEN filed No. Components Total Connectors 6,014 Flanges 2,962 Open-ended Line 1,077 Other* 162 Pump Seals 48 Valves 3,772 14,035 THC Emission Factors (lb/hr/component): EPA 453/R-95-017 11/95 Connectors Flange Open-ended Line Other* Pump Seal Valve S007 NA NA NA Fugitive VOC NA NA NA NSPS KKK Monitoring 93WE157-7 Sep -93 6/17/2002 Gas Svc: 2,408 1,186 468 112 Lt. Liq. Svc: 3,606 1,776 609 50 48 1,516 2,256 5,690 8,345 14,035 Gas Svc: Lt. Liq. Svc: 2.20E-05 2.10E-05 1.30E-05 5.30E-06 3.30E-05 3.10E-05 2.60E-04 2.40E-04 7.70E-04 1.10E-03 5.50E-05 4.20E-05 VOC - Actual Emissions Calculations Connectors j; gas service 2,383.9 comps. • 2.20E-05 lb/hr/comp. * 8760 hr/y / 2000 lb/t = Connectors - light liquid service comps. * 2.10E-05 lb/hr/comp. * 8760 hr/y / 2000 lb/t = Flanges - gas service 3,569.9 1,174.1 comps. * Flanges - light liquid service 1.30E-05 1,758.2 comps. * 5.30E-06 lb/hr/comp. * 8760 hr/y / 2000 lb/t = Open-ended Lines - gas service 463.3 Ib/hr/comp. * 8760 hr/y / 2000 lb/t = comps. * 3.30E-05 Ib/hr/comp. * 8760 hr/y / 2000 lb/t = Open-ended Lines - light liquid service comps. * 3.10E-05 lb/hr/comp. * 8760 hr/y / 2000 lb/t = Other* - gas service 109.1jomps. * Ib/hr/comp. * 8760 hr/y / 2000 lb/t = Other* - light liquid service I 48.6{comps. * lb/hr/comp. * 8760 hr/y / 2000 lb/t = Pump Seals - gas service 602.9 0 2.60E-04 2.40E-04 comps. * 7.70E-041b/hr/comp. 8760 hr/y / 2000 lb/t = Pump Seals - light liquid service 39.0 comps. * 1.10E-03 lb/hr/comp. 8760 hr/y / 2000 lb/t Valves - gas service 1,497.71comps. * 5.50E-05 Ib/hr/comp. * 8760 hr/y / 2000 lb/t = Valves - light liquid service 2,228.5 f comps. * 4.20E-05 lb/hr/comp. * 8760 hr/y / 2000 lb/t = *Other includes compressors, diaphrams, drains, dump arms, hatches, instruments, meters, pressure relief valves, polished rods, relief valves, and vents. Comments Screening emission factors are used for all components since NARCO conducting KKK monitoring. 4/26/02: New wt. % of VOC is 17.85% based on combined inlet gas compositions run thru HYSYS from Justin O. 2005: New counts from T. Thayer of PSI on 9/2/05: Total connectors: 3594 in g/v service, 5382 in liquid svc. for a total of 8976. Of this #, estimate that 33% of the connectors are flanged. #s then become 2408 g/v connectors, 3606 Iliq connectors, 1186 g/v flanges and 1776 Iliq flanges. Open- ended lines: 468 g/v and 609 Iliq for a total of 1077. "Other" includes 12 compressors (all in g/v), 100 prvs in g/v service and 50 prvs in Iliq service for a total of 162. 48 pumps, all of which are in Iliq service. Valves: 1516 in g/v service and 2256 in Iliq service for a total of 3772. T. Thayer said if they were to estimate VOC emissions using correlation data from testing, that the leaks would decrease since EPA emission factors were so high. Facility ID Code: CO 1230319 0.23 0.33 0.07 0.04 L 0.07 0.08 0.12 0.05 0.00 0.19 0.36 0.41 1.95 18.53% 0.36 17.55 17.91 tpy HC tpy HC tpy HC tpy HC tpy HC tpy HC tpy HC tpy HC tpy HC tpy HC tpy HC tpy HC tpy HC Total (Non-leakers) VOC tpy VOC (Non-leakers) tpy VOC (Leakers) tpy VOC total 19.0 tpy VOC T5 Permit Limit Air Basics, Inc. S007 - 2005 VOC (Non-leakers) 10/25/2005 AIR POLLUTANT EMISSION NOTICE FIRM NAME EnCana Oil & Gas (USA) Inc. MAIL ADDRESS 1313 Denver Avenue, Building #1 Fort Lupton STATE: CO ZIP: 80621 PLANT NAME & LOCATION Fort Lupton Plant: 16157 Weld County Road 22, Fort Lupton, CO 80621 REQUEST PORTABLE SOURCE PERMIT HOME -BASE FOR PORTABLE SOURCE PERSON TO CONTACT REGARDING THIS INFORMATION Dena Lund TITLE DJ Field Superintendent PHONE (303) 659-7740 GENERAL DESCRIPTION OF THIS PLANT'S FUNCTION Natural gas processing plant PERMIT No.: 99OPWE207 AIRS ID.: 123 / 0319 / 007 COUNTY: Weld A. GENERAL INFORMATION Normal Operation of This Source Hours/Day 24 Days/Week 7 Weeks/Year 52 Process Seasonal Through u s Thr h t (% of Annual) Dec -Feb 25 Mar -May Jun -Aug 25 25 E-MAIL ADDRESS: Dena.Lund@EnCana.com Sep -Nov 25 ADDITIONAL INFORMATION OR REMARKS: B. STACK OR VENT INFORMATION (Identify below which stack if plant has two or more; refer to attached sketch of plant layout) Height ft Diameter ft Temperature °F Flow Rate ACFM Velocity ft/min Moisture Plant ID No. for Stack S007 C. FUEL INFORMATION Description of Combustion Unit Design Input Rate (106 BTU/hr) Kind of Fuel Bumed Annual Fuel Consumption Requested level Actual level (Data year level) Fuel Heating Value: (BTU/Ib, BTU/gal, or BTU/scf) Percent by Weight Sulfur Ash Seasonal Fuel Use (% of Annual Use) Dec -Feb Mar -May Jun -Aug Sep -Nov Space Htg (% Ann.) Make/Model: Serial No. D. PROCESS INFORMATION Description of Processing Unit Fugitive VOC emissions Make/Model: Serial No.: Raw Materials Used Description Raw Materials -Annual Consumption Requested level Actual level (Data year level) Design Process Rate (Specify Units/Hour) Finished Product Description Finished Product -Annual Output Requested level Actual level (Data year level) E. POLLUTION CONTROL EQUIPMENT Pollutant Type of Control Equipment Primary Secondary Overall Collection Efficiency ESTIMATED EMISSIONS (TONS/YEAR) AT THROUGHPUTS REQUESTED ABOVE CONTROLLED UNCONTROLLED ACTUAL EMISSIONS (from data year) ESTIMATION METHOD Particulate PM 10 SO, NO, VOC 24.0 18.0 EPA Publication CO PLEASE USE APCD NON -CRITERIA REPORTABLE AIR POLLUTANT ADDENDUM FORM TO REPORT SUCH POLLUTANTS OR POLLUTANTS NOT LISTED ABOVE. ❑ CHECK HERE IF YOU WISH THE DIVISION TO CALCULATE YOUR EMISSIONS. SEE "EMISSION ESTIMATES" INSTRUCTIONS ON BACK. CHECK ALL BOXES THAT APPLY ❑ New or previously unreported source* • Requesting modification of existing permit t$ • Change in emissions, throughputs or equipment ❑ Transfer of ownership (List previous owner in REMARKS section der ❑ Previous APEN is expiring 9O S ❑ Request for Emission Reduction Cre i1 ❑ (Specify) R * Complete all applicable portions of APEN t Complete ' Requested Level' values for permit limits $ Complete all information above box A, and those remaining Signature of Person Legally Authorized to Supply ata: DATE:. Z `� /0...)._ 05 YEAR FOR WHICH THE ACTUAL DATA APPLIES: 2005 Typed Name and Title: Dena Lund, DJ Field Supn.iintcndent lD re. e, ,,y, Lecur -D, /1)6 6 xa_.6 , et cti-�1,1tv i.t ,, Date source began or will begin operation: Existing THIS NOTICE IS VALID FOR FIVE YEARS. A revised notice shall be filed prior to this expiration date, whenever a permit limitation must be modified, whenever control equipment is changed, and annually whenever a significant emission change occurs. For specific details see Regulation 3, Part A, § II.C.1. A $119.96 FILING FEE IS REQUIRED FOR EACH NOTICE FILED. Send completed forms with fees to: Colorado Dept. of Public Health & Environment Air Pollution Control Division 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 APEN #1_of 1 For Information, Call (303) 692-3150 NON -CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM* (Instructions on reverse side) Permit Number 99OPWE207 Company Name: Plant Location: Person to Contact: E -Mail Address: EnCana Oil & Gas (USA) Inc. AIRS Number 123/0319/007 Fort Lupton Plant Dena Lund, DJ Field Superintendent Dena.Lund@EnCana.com County Weld Zip Code 80621 Phone (303) 659-7740 Fax (303) 857-1259 Chemical Abstract Service Number Chemical Name Reporting Bin Control Equipment/ Efficiency Emission Factor (include units) Emission Factor Source Requested Emissions (Ibs/yr) Actual Emissions from the Data Year (Ibs/yr) 71432 Benzene A HAPCalc v. 3.01 269 * Use this form for reporting Hazardous Air Pollutants, Ozone Depleting Compounds. and other Non -Criteria Reportable Pollutants Year For Which The Actual Data Applies: Date Signature of a Responsible Official (not a vendor or consultant) Dena Lund nt Name of a Responsible Official (please print) 2005 Title FPO wt L 4 1)i J P&.r. (9e, WGR ASSET HOLDING COMPANY LLC 1099 18TH ST., SUITE 1800 • DENVER, COLORADO 80202 P.O. Box 173779 • DENVER, COLORADO 80217-3779 WGR Asset Holding Company LLC June 10, 2014 SENT VIA CERTIFIED MAIL NO: Matthew Burgett CDPHE/Air Pollution Control Division 4300 Cherry Creek Drive South Denver, CO 80246-1530 RE: Modification to Title V Permit No. 95OPWE013 Kerr-McGee Gathering LLC — Platte Valley Gas Plant Dear Mr. Burgett: Kerr-McGee Gathering LLC (KMG) is hereby requesting the CDPHE to incorporate into Operating Permit No. 95OPWE013 the provisions of construction permits 12WE1277 and 02WE0927. Construction permit 12WE1277, issued June 10, 2013, regulates an amine natural gas liquid sweetening system for CO2 and I-I2S removal at the Platte Valley Gas Plant (AIRS ID 123/0057/043). Construction permit 02WE0927, issued December 2, 2013, regulates the process flare at the Platte Valley Gas Plant. KMG is submitting the enclosed permit modification application package within the required timeframe. If you have any questions, or require additional information, please contact me at (720) 929-6498 or Natalie.Reeber@Anadarko.com Sincerely, KERR-MC iEI,GATHERING LLC Nat,,tdie E. Reeber Seriior HSE Representative Enclosures ec: J. Shea Attachment A SUBSIDIARY OF ANADARKO PETROLEUM CORPORATION APPENDIX: A. Title V Forms B. APENS C. Emission Calculations APPENDIX A SITE WIDE FORMS Operating Permit Application Colorado Department of Health Air Pollution Control Division TABULATION OF PERMIT APPLICATION FORMS FORM 2000-800 09-94 Facility Name: Platte Valley Gas Plant Facility Identification Code: CO 123/0057 I. ADMINISTRATION This application contains the following forms: x Form 2000-100, Facility Identification x Form 2000-101, Facility Plot Plan X Forms 2000-102, -I02A, and -102B, Source and .Site Descriptions II. EMISSIONS SOURCE DESCRIPTION Total Number of This Form This application contains the following forms (one form for each facility boiler, printing X Form 2000-200, Stack Identification 2 o Form 2000-300, Boiler or Furnace Operation o Form 2000-301, Storage Tanks o Form 2000-302, Internal Combustion Engine o Form 2000-303, Incineration o Form 2000-304, Printing Operations o Form 2000-305, Painting and Coating Operations x Form 2000-306, Miscellaneous Processes 2 o Form 2000-307, Glycol Dehydration Unit III. AIR POLLUTION CONTROL SYSTEM Total Number of This Form This application contains the following forms: o Form 2000-400, Miscellaneous o Form 2000-401, Condensers o Form 2000-402, Adsorbers x Form 2000-403, Catalytic or Thermal Oxidation 1 o Form 2000-404, Cyclones/Settling Chambers o Form 2000-405, Electrostatic Precipitators o Form 2000-406, Wet Collection Systems o Form 2000-407, Baghouses/Fabric Filters IV. COMPLIANCE DEMONSTRATION Total Number of This Form This application contains the following forms (one for each facility boiler, printing operation, ❑ Form 2000-500, Compliance Certification - Monitoring and Reporting I:] 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 J Form 2000-507, Recordkeeping ❑ Form 2000-508, Other Methods 1 V. EMISSION SUMMARY AM) COMPLIANCE CERTIFICATION Total Number of This Form This application contains the following forms quantifying emissions, certifying compliance with applicable requirements, and developing a compliance plan x Form 2000-600, Emission Unit Hazardous Air Pollutants 2 x Form 2000-601, Emission Unit Criteria Air Pollutants 2 x Form 2000-602, Facility Hazardous Air Pollutants 1 X Fonn 2000-603, Facility Criteria Air Pollutants 1 o Form 2000-604, Applicable Requirements and Status of Emission Unit o Form 2000-605, Permit Shield Protection Identification o Form 2000-606, Emission Unit Compliance Plan - Commitments and Schedule o Form 2000-607, Plant -Wide Applicable Requirements o Form 2000-608, Plant -Wide Compliance Plan - Commitments and Schedule VI. SIGNATURE OF RESPONSIBLE OFFICIAL - FEDERAL/STATE CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this application are true, accurate and complete. B. CERTIFICATION OF FACILITY COMPLIANCE STATUS - FEDERAL/STATE CONDITIONS (check one box only) X I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements. o 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 Miguel Del lerrera Title Operations Manager — Rockies Operations Signa Date Signed 2 Operating Permit Application FACILITY IDENTIFICATION Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE FORM 2000-100 Rev 06-95 1. Facility name and Name Platte Valley Gas Plant mailing address Street or Route P.O. Box 173779 City, State, Zip Code Denver Colorado 80217-3779 2. Facility location Street Address 16157 Weld County Road 22 (No P.O. Box) City, County, Zip Fort Lupton, Weld County Code Colorado 80621 3. Parent corporation Name Kerr-McGee Gathering, LLC Street or Route P.O. Box 173779 City, State, Zip Code Denver Country (if not U.S.) Colorado 80217-3779 4. Responsible official Name Title Telephone Miguel DeHerrera Operations Manager — Midstream Operations (720) 929-6000 5. Permit contact person Name Title (If Different than 4) Telephone Natalie Reeber Sr, HSE Representative (720) 929-6498 6. Facility SIC code: 1311 (NAICS: 21 1111) l l l) 7. Facility identification code: CO 123/0057 8. Federal Tax I. D. Number: 76-0146568 9. Primary activity of the operating establishment: Natural Gas Gathering, Processing and Compression 10. Type of operating permit 0 New X Modified 0 Renewal 11. Is the facility located in a "nonattainment" area: X Yes 0 No If "Yes", check the designated "non -attainment" pollutant(s): 0 Carbon Monoxide X Ozone O PMIO O Other (specify) 12. List ail (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. Operating Permit Application Colorado Department of Pubic l-lealth and environment Air Pollution Control Division FACILITY PLOT PLAN FORM 2000-101 Rev 06-95 Facility Name: Platte Valley Gas Plant Facility Identification Code: CO 123/0057 The operating permit must be prepared and submitted on forms supplied by the Division. Use of this form is required for all operating permit applications. The Division will not consider or act upon your application unless each form used has been entirely completed. Completion of the information in the shaded area of this form is optional. Use "NA" where necessary to identify an information request that does not apply and is not in the optional shaded area. In order for a comprehensive air quality analysis to be accomplished, a facility plot plan MUST be included with the permit application. Drawings provided must fit on generic paper sizes of 8 1/2" X 11", 8 1/2" X 14" or 11" X 15", as appropriate to display the information being provided. Include the facility name and facility identification code on all sheets. For facilities with large areas, sketches of individual buildings, on separate drawings, may be needed to allow easy identification of stacks or vents. Insignificant activities do not need to be shown. 1. A plant layout (plan view) including all buildings occupied by or located on the site of the facility and any outdoor process layout. 2. The maximum height of each building (excluding stack height). 3. The location and coded designation of each stack. Please ensure these designations correspond to the appropriate stacks listed on the other permit forms in this application. The drawings need not be to scale if pertinent dimensions are annotated, including positional distances of structures, outdoor processes and free standing stacks to each other and the property boundaries. 4. The location of property boundary lines. 5. Identify direction "North" on all submittals. Are there any outdoor storage piles on the facility site with air pollution emissions that need to be reported? o Yes X No If "Yes", what is the material in the storage pile(s)? Are there any unpaved roads or unpaved parking lots on the facility site? X Yes o No List the name(s) of any neighboring state(s) within a 50 mile radius of your facility: Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division SOURCE DESCRIPTION - APENS FORM 2000-102A Rev 06-95 Facility Name: Platte Valley Gas Plant Facility Identification Code: CO 123/0057 NOTE: Each new or updated Air Pollutant Emission Notice (APEN) submitted must be accompanied by payment of $100 per APEN. 1. For each emission unit enclose a copy of the most current complete Air Pollutant Emission Notice (APEN) on file with the )ivision. If the most current APEN was not completely and correctly filled out, a revised APEN is required. List an APEN number, late, and a brief description of the unit/process covered by the APEN. (No filing fees are needed for these copies) AIRS ID Date Description 123/0057/043 One amine natural gas liquids sweetening system 123/0057/053 One process flare 2. No APEN exists for an emission unit. List the new APEN and the appropriate descriptive information here. Submit the APEN vith a construction permit application. Jew APEN and permit application submitted o with this application OR o under separate cover to Construction Permits Section. N/A 3.A revised APEN was prepared and enclosed for an emission unit. List the APEN and the appropriate descriptive information 'ere. A revised APEN is needed where a significant increase in emissions has occurred, or is planned; or a major modification of ne unit has occurred or is planned; or the existing information needs correction or completion. A construction permit application nay need to be submitted. Zevised APEN submitted as part of this application: o Yes X No o Filing Fee Enclosed New permit application enclosed: O Yes O No Permit modification application enclosed: O Yes o No Operating Permit Application PLANT -WIDE HAZARDOUS AIR POLLUTANTS Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE FORM 2000-602 Rev 06-95 1. Facility name: Platte Valley Gas Plant 2. Facility identification code: CO 123/0057 3. Complete the following emissions summary for all hazardous air emissions at this facility. Calculations attached. Attach a copy of all calculations to this form. Pollutant CAS Common or Generic Pollutant Name Actual emissions Allowable OR Potential to emit Quantity Units Quantity Units 50000 Formaldehyde 23.1 TPY 75070 Acetaldehyde 5.0 TPY 71432 Benzene 2.0 TPY 108883 Toluene 1.3 TPY 100414 Ethylbenzene 0 TPY 1330207 Xylene 0.9 TPY 110543 n -Hexane 3.3 TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY NOTE: If there is a permit for this unit, the permit limits are the same as the potential to emit. 1 Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE PLANT -WIDE CRITERIA AIR POLLUTANTS FORM 2000-603 09-94 Facility name: Platte Valley Gas Plant 2.Facility identification code: CO 123/0057 3. Complete the following emissions summary for the listed emissions at this facility. Air pollutant Actual Potential to emit Maximum allowable TPY TPY TPY Particulates (TSP) PM -10 17.8 17.8 Nitrogen oxides 611.2 611.2 Volatile organic compounds 333.4 333.4 Carbon monoxide 507.6 507.6 Lead Sulfur dioxide 8.3 8.3 Total reduced sulfur Reduced sulfur compounds Hydrogen sulfide Sulfuric acid mist Fluorides 2 AMINE UNIT FORMS (AIRS ID 123/0057/043) Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE STACK IDENTIFICATION FORM 2000-200 Rev 06-95 1. Facility name: Platte Valley Gas Plant 2. Facility identification code: CO 123/0057 3. Stack identification code: 123/0057/043 3a. Construction Permit Number: I2WE1277 4. Exhausting Unit(s), use Unit identification code from appropriate Form(s) 2000-300, 301, 302, 303, 304, 305, 306, 307 2000-300 2000-304 2000-301 2000-302 2000-305 2000-306 S009 2000-303 2000-307 5. Stack identified on the plot plan required on Form 2000-101 X 6. Indicate by checking: X This stack has an actual exhaust point. The parameters are entered in Items 7-13. 0 This stack serves to identify fugitive emissions. Skip items 7-13. Go to next form. O When stack height Good Engineering Practice (GEP) exceeds 65 meters (Colorado Air Quality Reg 3.A.VIII.D) data entry is required for Item 7. 7. Discharge height above ground level: 30 (feet) 8. Inside dimensions at outlet (check one and complete): X Circular 24 (inches) 0 Rectangular length (feet) width (feet) 9. Exhaust flow rate: Normal (ACFM) Maximum (ACFM) Velocity (FPS) 0 Calculated 0 Stack Test 10. Exhaust gas temperature (normal): 1400 (deg. F) 11. Does process modify ambient air moisture content? 0 Yes X No If "Yes", exhaust gas moisture content: Normal percent Maximum percent 12. Exhaust gas discharge direction: X Up 0 Down 0 Horizontal 13. Is this stack equipped with a rainhat or any obstruction to the free flow of the exhaust gases from the stack? O Yes O No *****Complete the appropriate Air Permit Application Forms(s) 2000-300, 301, 302, 303, 304, 305, 306, or 307 for each Unit exhausting through this stack. Operating Permit Application Colorado Department of Public I leapt' and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE MISCELLANEOUS PROCESSES FORM 2000-306 Rev 06-95 1. Facility name: Platte Valley Gas Plant 2. Facility identification code: CO 123/0057 3. Stack identification code: 123/0057/043 4. Process (Unit) code: S009 5. Unit description: Amine Treating Unit 6. Indicate the control technology status. If the process is controlled, enter the control device 2000-400 2000-401 2000-404 2000-405 o Uncontrolled X Controlled code(s) from the appropriate form(s): 2000-402 2000-403 X 2000-406 2000-407 7. Actual annual process rates for 19 8. Date first placed in service: 06/10/2013 Date of last modification: 2013 9. Normal operating schedule: 24 hrs/day 7 days/wk. 8760 hours/yr. 10. Describe this process (please attach a flow diagram of the process). Attached? (Included in overall PFD) Amine Treating Unit 11. List the types and amounts of raw materials used in this process: Material Storage/material handling process Actual Units usage Maximum usage Units NGL Clean-up solvents Other (specify) 12. List the types and amounts of finished products: Material Storage/material handling process Actual Units amount produced Maximum Units amount produced N/A 13. Process fuel usage: Type of fuel Maximum heat input to process million BTU/hr. Actual Units usage Maximum usage Units N/A 14. Describe any fugitive emissions associated with this process, such as outdoor storage piles, unpaved roads, open conveyors, etc. NA ***** For this emissions unit, identify the method(s) of compliance demonstration by completing Form 2000-500, DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 and its attachment(s) to this form. ***This form has been submitted previously *** ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** Operating Permit Application CONTROL EQUIPMENT - CATALYTIC OR THERMAL OXIDATION Form 2000-403 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE Section A 1. Facility name: Platte Valley Gas Plant 3. Stack identification code: 123/0057/0043 2. Facility identification code: CO 123/0057 4. Unit identification code: S009 5. Control device code: S009 6. Manufacturer and model number: Zeeco Vertical Forced Air TO 7. Date placed in service: 6/10/2013 8. Describe the oxidation system. Attach a diagram of the system. Thermal oxidizer used to control flash gas and still vent gas from the amine unit Date last modified: 2013 9. List the pollutants to be controlled by this equipment and the expected control efficiency for each pollutant on the table below. X Documentation attached EITHER the outlet pollutant concentration OR the control efficiency must be provided. Pollutant Inlet pollutant concentration Outlet pollutant concentration Control Efficiency (%) gr/acf ppmv gr/acf ppmv Emission Capture Pollutant Destruction VOC 990 10: Check one: ❑ Catalytic 11. Discuss how the spent catalyst will be handled for reuse or disposal. x Thermal oxidizer 12. Prepare a malfunction prevention and abatement plan for this pollution control system. The plan does not have to be submitted with the application. It is suggested the plan include, but not be limited to the following: a. Identification of the individuals(s), by title, responsible for inspecting, maintaining and repairing this device. b. Operation variables such as temperature that will be monitored in order to detect a malfunction or breakthrough, the correct operating range of these variables, and a detailed description of monitoring or surveillance procedures that will be used to show compliance. c. An inspection schedule and items or conditions that will be inspected. For catalytic oxidizers, discuss the replacement and/or regeneration schedule for the bed and steps you have taken to ensure the bed's proper functioning throughout its expected lifetime. d. Where is this plan available for review? Section B The following questions must be answered by sources installing new equipment or existing Units which cannot document control efficiency of this device by other means. (Catalytic/Thermal dependent on item 10) Catalytic oxidation Thermal oxidation 13a. Max Operating temperature (EF): Min b. Max Operating temperature (°F): Min 14a. Catalyst bed volume (ft3): b. Combustion chamber volume (ft3): 15a. Gas volumetric flow rate at combustion conditions (ACFM): b. Maximum gas velocity through the device (ft./sec): 16a. Type of fuel used: b. Type of fuel used: 17a. Max fuel use rate (BTU/Hr): b. Maximum fuel used (BTU/Hr): 18a. Type and volume of catalyst used (ft3): 19a. Residence time (seconds): b. Residence time (seconds): 1 EMISSION UNIT HAZARDOUS AIR POLLUTANTS Colorado Department of Public I Iealth and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE FORM 2000-600 Rev 06-95 1. Facility name: Platte Valley Gas Plant 2. Facility identification code: 123/0057 3. Stack identification code: 123/0057/043 4. Unit identification code: S009 5. Unit material description: Process Gas and Natural gas 6. Complete the following summary of hazardous air emissions from this unit. Attach all calculations and emission factor references. Pollutant CAS Common or Generic Pollutant Name Actual emissions Allowable OR Potential to emit Quantity Measurement Units Quantity Measurement Units None TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY .l'PY TPY TPY NOTE: If there is a permit for this unit, the permit limits are the same as the potential to emit. Operating Permit Application EMISSION UNIT CRITERIA AIR POLLUTANTS Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE FORM 2000-601 09-94 1. Facility name: Platte Valley Gas Plant 2. Facility identification code: CO 123/0057 3. Stack identification code: 123/0057/043 4. Unit identification code: S009 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached x Air pollutant Actual Potential to emit Maximum allowable Quantity U TPY U TPY Nitrogen oxides 6.5 TPY 0.10 2 6.5 Carbon monoxide 5.5 TPY 0.08 2 5.5 Volatile organic compounds 1.1 TPY 0.04 8 1.1 Particulates (TSP) TPY PM -10 TPY Lead TPY Sulfur dioxide TPY Total reduced sulfur TPY Reduced sulfur compounds TPY Hydrogen sulfide TPY Sulfuric Acid Mist TPY Fluorides TPY TPY TPY TPY TPY Units (U) should be entered as follows: 1= lb/hr 2 = Ib/mmBTU 3 = grains/dscf 4 = lb/ gallon 5 = ppmdv 6 = gram/HP-hour 7= lb/mmscf 8 = other (specify) lb/bbl 9 = other (specify) 10 = other (specify) FLARE FORMS (AIRS ID 123/0057/053) Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE STACK IDENTIFICATION FORM 2000-200 Rev 06-95 1. Facility name: Platte Valley Gas Plant 2. Facility identification code: CO 123/0057 3. Stack identification code: 001/0025/053 3a. Construction Permit Number: 02WE0927 4. Exhausting Unit(s), use Unit identification code from appropriate Fonn(s) 2000-300, 301, 302, 303, 304, 305, 306, 307 2000-300 2000-301 2000-304 2000-305 2000-302 2000-306 S053 2000-303 2000-307 5. Stack identified on the plot plan required on Form 2000-101 X 6. Indicate by checking: X This stack has an actual exhaust point. The parameters are entered in Items 7-13. O This stack serves to identify fugitive emissions. Skip items 7-13. Go to next form. O When stack height Good Engineering Practice (GEP) exceeds 65 meters (Colorado Air Quality Reg 3.A.VIII.D) data entry is required for Item 7. 7. Discharge height above ground level: 100 (feet) 8. Inside dimensions at outlet (check one and complete): X Circular (inches) O Rectangular length (feet) width (feet) 9. Exhaust flow rate: Normal 824 (ACFM) Maximum (ACFM) Velocity (FPS) O Calculated O Stack Test 10. Exhaust gas temperature (normal): 1800 (deg. F) 11. Does process modify ambient air moisture content? O Yes X No If "Yes", exhaust gas moisture content: Normal percent Maximum percent 12. Exhaust gas discharge direction: X Up O Down O Horizontal 13. Is this stack equipped with a rainhat or any obstruction to the free flow of the exhaust gases from the stack? O Yes O No *****Complete the appropriate Air Permit Application Forms(s) 2000-300, 301, 302, 303, 304, 305, 306, or 307 for each Unit exhausting through this stack. Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE MISCELLANEOUS PROCESSES FORM 2000-306 Rev 06-95 1. Facility name: Platte Valley Gas Plant 2. Facility identification code: CO 123/0057 3. Stack identification code: 125/0057/053 4. Process (Unit) code: P029 5. Unit description: John Zink Flare 6. Indicate the control technology status. o Uncontrolled X Controlled If the process is controlled, enter the control device code(s) from the appropriate form(s): 2000-400 2000-401 2000-402 2000-403 2000-404 2000-405 2000-406 2000-407 7. Actual annual process rates for 19 8. Date first placed in service: 12/17/2002 Date of last modification: 2013 9. Normal operating schedule: 24 hrs/day 7 days/wk. _ 8760 hours/yr. 10. Describe this process (please attach a flow diagram of the process). Attached? (Included in overall PFD) This is an emergency flare for when the T.O. is not operational, other process upsets or MSS events as well as closed drain system flash emission control. 11. List the types and amounts of raw materials used in this process: Material Storage/material handling process Actual Units usage Maximum usage Units N/A Clean-up solvents Other (specify) 12. List the types and amounts of finished products: Material Storage/material handling process Actual Units amount produced Maximum Units amount produced N/A Bbls/yr 13. Process fuel usage: Type of fuel Maximum heat input to process million BTU/hr. Actual Units usage Maximum usage Units Process Gas 18.3 64.3 MMScf /yr 100 MMScf/yr Pilot Gas (Natural Gas) 0.09 0.77 MMscf/yr Purge Gas (Natural Gas) 0.31 2.6 MMscf/yr 14. Describe any fugitive emissions associated with this process, such as outdoor storage piles, unpaved roads, open conveyors, etc. NA ***** For this emissions unit, identify the method(s) of compliance demonstration by completing Form 2000-500, ***** DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 and its attachment(s) to this form. ***This form has been submitted previously *** ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** EMISSION UNIT HAZARDOUS AIR POLLUTANTS Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE FORM 2000-600 Rev 06-95 1. Facility name: Platte Valley Gas Plant 2. Facility identification code: 123/0057 3. Stack identification code: 123/0057/0053 4. Unit identification code: 053 5. Unit material description: Process Gas and Natural gas 6. Complete the following summary of hazardous air emissions from this unit. Attach all calculations and emission factor references. Pollutant CAS Common or Generic Pollutant Name Actual emissions Allowable OR. Potential to emit Quantity Measurement Units Quantity Measurement Units None T'PY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY NOTE: If there is a permit for this unit, the permit limits are the same as the potential to emit. Operating Permit Application EMISSION UNIT CRITERIA AIR POLLUTANTS Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE FORM 2000-601 09-94 1. Facility name: Platte Valley Gas Plant 2. Facility identification code: CO 123/0057 3. Stack identification code: 123/0057/053 4. Unit identification code: S053 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached x Air pollutant Actual Potential to emit Maximum allowable Quantity U TPY U TPY Nitrogen oxides 0.138 2 4 . 9 11.3 TPY 0.138 2 11.3 Carbon monoxide 0.28 2 1. 6 22.5 TPY 0.28 2 22.5 Volatile organic compounds 0.01 2 9. 5 1.1 TPY 0.01 2 1.1 Particulates (TSP) TPY PM -10 TPY Lead TPY Sulfur dioxide TPY Total reduced sulfur TPY Reduced sulfur compounds TPY Hydrogen sulfide TPY Sulfuric Acid Mist TPY Fluorides TPY TPY TPY TPY TPY Units (U) should be entered as follows: 1 = Ib/hr 2 = lb/mmBTU 3 = grains/dscf 4 = lb/ gallon 5 = ppmdv 6 = gram/HP-hour 7 = lb/mmscf 8 = other (specify) 9 = other (specify) 10 = other (specify) APPENDIX B AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Amine Sweetening Unit - Permit Number: Facility Equipment ID: S009 [Leave blank unless APCD has already assigned a permit # & AIRS ID] Emission Source AIRS ID: 123 / 0057 / 043 Section 01— Administrative Information Company Name: Kerr-McGee Gathering LLC [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.) Section 02 — Requested Action (Check applicable request boxes) ❑ Request for NEW permit or newly reported emission source Source Name: Platte Valley Gas Plant Source Location: 16157 Weld County Road 22 Fort Lupton, CO 80621 Mailing Address: P. O. Box 173779 Denver, CO Person To Contact: Jennifer L. Shea E-mail Address: Jennifer.Sheaaknadarko.com Section 03 — General Information NAICS, or SIC Code: County: Elevation: ZIP Code: 1311 Weld 4,920 Feet 80217 Phone Number: (720) 929-6028 Fax Number: (720) 929-7028 For existing sources, operation began on: / / Normal Hours of Source Operation: 24 hours/day 7 days/wee General description of equipment and purpose: NGL amine treating unit controlled ► Will this equipment be operated in any NAAQS nonattainment area? (http:/www.cdphe.state.co.us/atilattainmaintain.html) E Yes ❑ No O Don't know ► Does this facility have a design capacity less than 2 long tons/day of H2S in the acid gas? Section 04 — Amine Sweetening Unit Equipment Information E Request MODIFICATION to existing permit (check each box below that applies) O Change process or equipment O Change company name E Change permit limit ❑ Transfer of ownership O Other ❑ Request to limit HAPs with a Federally enforceable limit on PTE ❑ Request APEN update only (check the box below that applies) O O Addl. Info. & Notes: Revision to actual calendar year emissions for emission inventory Update 5 -Year APEN term without change to permit limits or previously reported emissions Request to install a thermal oxidizer(TO) to control amine unit still vent. Flash gas used as fuel for the TO, and sent to flare during TO downtime. For new or reconstructed sources, the projected startup date is: k 52 weeks/year by a thermal oxidizer and fired by a 10.7 MMBtu/hr reboiler (separate permit). Manufacturer: Rcboilcr Rating: Amine Type: Model: 10.7 tilMBtu/hr Absorber Column Stages: ❑ MEA ❑ DEA ❑ TEA Amine Pump Make & Model: Electric amine pump (one as back-up) Sweet Gas Throughput: Design Capacity: IvMSCF/day Requested': 15,000 bbUd Provide docwnentation. E Yes O No O Don't know Serial No.: stages MDEA 4 of Pumps: Inlet Gas: Pressure: psig Temperature: Rich Amine Feed: Pressure: 514.7 psia Temperature: Lean Amine Stream: Pressure: —21 psia Temperature: Calendar year actual: °F 97.4 °F 120 °F wt. % amine: 9.4 Mole loading H2S: 0.00011 Sour Gas Input: Pressure: psia Temperature: NGL Input: Pressure: 500 psia Temperature: 80 Flash Tank: Pressure: 89.9 psia Temperature: 98.49 'Requested values will become permit limitations. O DGA 2 Flowrate: Flowrate: Mole loading CO2: °F °F Flowrate: Flowrate: °F O None MIV1SCF/yr. MMSCF/yr. 100 gal/min 80 gal/min 2.182 MMSCF/day 425.1 galimin Additional Information Required: ❑ Attach a process flow diagram E Attach the simulation model inputs & emission report E Attach composition reports for the rich amine feed, sour gas feed, NGL feed, & outlet stream (emissions) E Attach the extended gas analysis (including BTEX & n -Hexane, 1I2S, CO2, 2,2,4 Trimethylpentane) FORM APCD-206 Page 1 of 2 Colorado Department of Public Health and Environment Air Pollution Control Division (APCD) This notice is valid for five (5) years. Submit a revised APEN prior to expiration of five-year term, or when a significant change is made (increase production, new equipment, change in fuel type, etc). Mail this form along with a check for 5152.90 to: Colorado Department of Public Health & Environment APCD-SS-Bl 4300 Cherry Creek Drive South Denver, CO 80246-1530 For guidance on how to complete this APEN form: Air Pollution Control Division: (303) 692-3150 Small Business Assistance Program (SBAP): (303) 692-3148 or (303) 692-3175 APEN forms: http://wwlv.cdphe.state.co.us/ap/downloadforms.html Application status: http://www.cdphestate.co.us/ap/ss/sspcnt.html E Check box to request copy of draft permit prior to issuance. E Check box to request copy of draft permit prior to public notice. 2013-01-29 PLV APEN Amine with TO3.doc AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Amine Sweetening Unit - Permit Number: Emission Source AIRS ID: 123 / 0057 / 043 Section 05 — Stack Information (Combustion stacks must be listed here) Operator Stack ID No. Stack Base Elevation (feet) Stack Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) Moisture (%) ATO-3 4,920 1 30 Direction of stack outlet (check one): ® Vertical ❑ Vertical with obstructing rainca Exhaust Opening Shape & Size (check one): ® Circular: Inner Diameter (inches) = 24 Section 06 —Stack (Source, if no combustion) Location (Datum & either Lat/Long or UTM) Horizontal Datum (NAD27, NAD83, UTM Zone UTM Easting or Longitude UTM Northing or Latitude Method, of Collection for Location Data (e.g. map, WGS84) (12 or 13) (meters or degrees) (meters or degrees) GPS, GoogleEarth) 13 ❑ Horizontal ❑ Down ❑ Other: Length (inches) = Section 07 — Control Device Information (Indicate if a control device controls the flash tank and/or regenerator emissions) ❑ Other (Describe): Width (inches) = ■ Condenser used for control of: ►.1 Combustion Device used for control of: Flash and Still Vent Gas Rating: 13.8 MMBtu/hr Type: Make/Model: Type: Thermal Oxidizer Make/Model/Serial #: Zeeco Vertical Forced Air TO Temperature (°F): Maximum: Average: VOC & HAP Control Efficiency: Requested: 99 % Manufacturer Guaranteed: Waste gas heat content: Pilot burner ratin: • 99 % Requested VOC & HAP Control Efficiency: % Minimum temp. to achieve requested control: 1400 °F 58 Btu/scf • VRU used for control of: Constant ' ilot li:ht? ■ Yes ■ No $.0 MMBtu/hr Size: Make/Model: ■ Closed loop system used for control of: Requested VOC & HAP Control Efficiency: % % Description: Annual time that VRU is bypassed (emissions vented): • Describe Any Other: Section 08 — Emissions Inventory Information & Emission Control Information El Emission Factor Documentation attached Data year for actual calendar yr. emissions below & gas throughput above (e.g. 2007): Pollutant Control Device Description Control Efficiency (% Reduction) Emission Factor Actual Calendar Year Emissionsz Requested Permitted Emissions3 Estimation Method or Emission Factor Source Primary Secondary Uncontrolled Basis Units Uncontrolled (Tons/Year) Controlled (Tons/Year) Uncontrolled (Tons/Year) ( ) Controlled (Tons/Year) NOX Identify in ;Section 07 0.10 Ib/MMBtu 6.5 1 AP -42 Chpt 1 VOC 0.04 lb/bbl 105.8 1.1 ProMax Sim. CO 0.08 lb/MMBtu 5.5 AP -42 Chpt 1 Benzene 1.47E-03 lb/bbl 4.0 0.0 ProMax Sim. Toluene 2.56E-04 lb/bbl 0.7 0.0 ProMax Sim. Ethylbenzene 2.68E-06 lb/bbl below de minimis ProMax Sim. Xylene 1.80E-05 lb/bbl below de minimis ProMax Sim. n -Hexane 1.30E-04 lb/bbl below de minimis ProMax Sim. Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Annual emission fees will be based on actual emissions reported here. If left blank, annual emission fees will be based on requested emissions. 'If Requested Permitted Emissions is left blank, the APCD will calculate emissions based on the information supplied in sections 03 - 08. Section —Annlicant Certificat1on - I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. / �(/u� 1/29/2013 Signatufe of PersolLegally uthorized to Supply Data Date Jennifer L. Shea Name of Legally Authorized Person (Please print) Title Staff EHS Representative Page 2 of 2 2013-01-29 PLV APEN Amine with TO3.doc NON -CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM (See reverse side for guidance on completing this form) Permit Number: Company Name: Plant Location: Person to Contact: E-mail Address: S009 Kerr-McGee Gathering LLC Platte Valley Gas Plant Jennifer L. Shea Jennifer.Shea@Anadarko.com AIRS ID Number: 123/0057/043 County: Weld Phone Number: 720-929-6028 Zip Code: Fax Number: 720-929-7028 Chemical Abstract Service (CAS) Number Chemical Name Reporting BIN Control Equipment / Reduction (%) Emission Factor (Include Units) Emission Factor Source Uncontrolled Actual Emissions (lbs/year) Controlled Actual Emissions (lbs/year) 7783064 Hydrogen Sulfide A 99% For Thermal Oxidizer (TO) (H2S to SO2) .000161b/bbl uncontrolled Simulation 856.6 (no TO) 8.6 (with TO) 0.0000016 lb/bbl controlled Reporting Scenario (1, 2 or 3): Calendar Year for which Actual Data Applies: Sign ure of Person Legally Authorized to Supply Data Jennifer L. Shea Name of Person Legally Authorized to Supply Data (Please print) et/g-0( Date Staff EHS Representative Title of Person Legally Authorized to Supply Data Form Revision Date: December 4, 2006 AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — General Permit Number: 02WE0927 Facility Equipment ID: S021 -Flare Section 01— Administrative Information Company Name: Kerr Mc -Gee Gathering LLC [Leave blank unless APCD has already assigned a permit # & AIRS ID] Emission Source AIRS ID: 123 / 0057 / 053 [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] Source Name: Platte Valley Gas Plant Source Location: 16116 and 16157 WCR 22 Fort Lupton, CO 80621 Portable Source N/A Home Base: NAICS, or SIC Code: 1321 County: Fort Lupton Elevation: 5,060 Feet Mailing Address: P.O. Box 173779 ZIP Code: 80217 Denver, CO Person To Contact: Jennifer L. Shea Phone Number: (720) 929 - 6028 E-mail Address: Jennifer.Shea@Anadarko.com Fax Number: (720) 929 - 7000 Section 03 — General Information For existing sources, operation began on: Normal Hours of Source Operation: General description of equipment and purpose: Section 02 — Requested Action (check applicable request boxes) El Request for NEW permit or newly reported emission source El Request PORTABLE source permit ® Request MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment El Change company name ® Change permit limit ❑ Transfer of ownership O Other ❑ Request to limit HAPs with a Federally enforceable limit on PTE ❑ Request APEN update only (check the box below that applies) ❑ Revision to actual calendar year emissions for emission inventory Update 5 -Year APEN term without change to permit limits or previously reported emissions Additional Info. & Increase gas to the flare amount to 103.4 MMscf/yr. Notes: 12 / 17 / 2002 For new or reconstructed sources, the projected startup date is: 24 hours/day 7 days/ veek 52 weeks/year Process Flare / / Will this equipment be operated in any NAAQS nonattainment area? (http:// vww.cdphe.state.co.us/ap/attainmaintain.html) ® Yes ❑ No ❑ Section 04 — Processing/Manufacturina Equipment Information & Material Use Description of equipmentu: Manufacturer: Flare Industries Model No.: Air Assisted Flare Serial No.: Don't know Description Actual Level (For Data Year) Annual Requested Permitted Level- (Specify Units) Design Process Rate (Specify Units/Hour) Raw Materials: F Finished Products: Other Process: If additional space is required. please attach a separate list of equipment, materials and throughputs. 'Requested values will become permit limitations. Requested level should consider process growth over the next five years. FORM APCD-200 Page 1 of 2 Colorado Department of Public Health and Environment Air Pollution Control Division (APCD) This notice is valid for five (5) years. Submit a revised APEN prior to expiration of five-year term, or when a significant change is made (increase production, new equipment, change in fuel type, etc). Mail this form along with a check for S152.90 to: Colorado Department of Public Health & Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 For guidance on how to complete this APEN form: Air Pollution Control Division: (303) 692-3150 Small Business Assistance Program (SBAP): (303) 692-3148 or (303) 692-3175 APEN forms: httn://www.cdphe.state.co.us/ap/downloadforms.htmI Application status: http://www.cdphe.statc.co.us/ap/ss/sspcpthtml ® Check box to request copy of draft permit prior to issuance. ® Check box to request copy of draft permit prior to public notice. Attachment B - ForrnAPCD-200-Genera1APEN-Ver,9-10-2008.doc AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — General Permit Number: 02WE0927 Emission Source AIRS ID: 123 / 0057 / 053 Section 05 — Emission Release Information (Attach a separate sheet with relevant information in the event of multiple releases; provide datum & either Lat/Long or UTM) Operator Stack ID No. Base Elevation (feet) Discharge Height Above Ground Level (Feet) Temp. Tem (�F) Flow Rate (ACFM) Velocity Moisture o (ft/see) (/fl) Horizontal Datum (NAD27, NAD83, WGS84) UTM Zone (12 or 13) UTM Easting or Longitude (meters or degrees) UTM Northing or Latitude (meters or degrees) Method of Collection for Location Data (e.g. map, GPS, GoogleEarth) S021 5,060 100 1800 824 65 0 NAD83 13 521031 4443535 GoogleEarth Direction of outlet (check one): ® Vertical ❑ Vertical with obstructing raincap Exhaust Opening Shape & Size (check one): ® Circular: Inner Diameter (inches) Section 06 — Combustion Equipment & Fuel Consumption Information Company equipment Identification No.: Manufacturer: ❑ Horizontal ❑ Down ❑ Other: Length (inches) = Model: ❑ Other (Describe): Width (inches) = Serial No.: Fuel Type Design Input Rate (106 Btu/hr) Actual Level (For Data Year) Annual Requested Permitted Level' (Specify Units) Fuel Heating Value (Indicate: Btu/lb, Btu/gal, Btu/SCF) Percent by Weight Seasonal Fuel Use (% of Annual Use) Sulfur Ash Dec -Feb Mar -May Jun -Aug Sep -Nov 25 I Process Gas 18.3 64.3 MMSCF/yr 100 MMSCF/yr 1600 Btu/scf 25 25 25 Pilot Gas 0.09 0.77 NEVISCF/yr 1020 Btu/scf 25 25 25 25 Purge Gas 0.31 2.6 MMSCF/yr 1020 Btu/scf 25 25 25 25 'Requested values will become permit limitations. Requested level should consider process growth over the next five years. Section 07 — Emissions Inventory Information & Emission Control Information Attach any emission calculations and emission factor documentation to this APEN form. ® Emission Factor Documentation attached Data year for actual calendar yr. emissions below & throughput above (e.g. 2007): 2011 Pollutant — Control Device Description Overall Collection Efficiency Control Efficiency (% Reduction) Emission Factor Actual Calendar Year Emissions3 Requested Permitted Emissions" Estimation Method or Emission Factor Source Primary Secondary Uncontrolled Basis Units Uncontrolled (Tons/Year) Controlled (Tons/Year) Uncontrolled (Tons/Year) Controlled (Tons/Year) r TSP PM10 PM2.5 Sox NOx 0.138 lb/MMBtu 4.9 11.3 TCEQ VOC 0.01 lb/MMBtu 1.6 1.1 AP -42 TOC x 10% VOC CO 0.28 lb/MMBtu 9.5 22.5 TCEQ Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. s Annual emission fees will be based on actual emissions reported here. If left blank, annual emission fees will be based on requested emissions. 4If Requested Permitted Emissions is left blank, the APCD will calculate emissions based on the information supplied in sections 03 - 07. Secti 08 —Applic nt Certification - I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. z 1 JOJ Jennifer L. Shea Sign e of Person Legally Authorized to Supply Data Da e Name of Legally Authorized Person (Please print) Title Staff EHS Representative Page 2 of 2 Attachment B - FormAPCD-200-GeneralAPEN-Ver.9-10-2008.doc APPENDIX C Platte Valley Gas Plant Amine Unit Emission Calculations Unit Description: Operation: Throughput. NGL Amine Treating Unit controlled by Thermal Oxidizer 8760 Annual Estimated Operation (hr/yr) 15,000 bbl/d Vapor Flow (MSCFD) = scf/hr= lb-mollhr= Still Vent Flash Tank Vent Note: Flash vapors routed to the TO for fuel and to flare during TO downtime. Note: Vapor flow rates and lb-mol/hr values from simulation run. 516 21515 56.69 II 461 1.22 Total MW Total Emissions Composition Still Vent Flash Tank Vent lb/hr lb/bbl (+10%) Uncontrolled , Controlled Mol % Ibmol/hr Mol % Ibmol/hr Ibmol/hr (Ib/Ib-mol) tpy+10% Carbon Dioxide 92.607 52.50 1.094 0.01 52,52 44.01 2311.3 4.1 11,136 - CO2e 11,157 Nitrogen 0.000 0.00 0.000 0.00 0.00 28.01 - - - - Methane 0.006 0.00 0.844 0.01 0,01 16.04 0.21 3.78E-04 1.0 - Ethane 0.860 0.49 71.966 0.87 1.36 30.07 40.96 7.21E-02 197.3 - Propane 0.206 0.12 20.751 0.25 0.37 44.1 16.28 2.87E-02 78.4 0.8 i-Butanc 0.009 001 1.249 0.02 0.02 58.12 1.19 2.09E-03 5.7 0.1 n -Butane 0.029 0.02 2.645 0.03 0.05 58.12 2.83 4.98E-03 13.6 0.1 iC5 0.002 0.00 0.252 0.00 0.00 72.15 0.30 5.26E-04 1.4 0.0 nC5 0.002 0.00 0.208 0.00 0.00 72.15 0,26 4.58E-04 1.3 0.0 Cyclopcntane 0.001 0.00 0.016 0.00 0.00 70,1 0.04 6.60E-05 0.2 0.0 n -Hexane + Other Hex 0,000 0.00 0.04 0.00 0.00 86.17 0.05 1.30E-04 0.2 0.0 Cyclohexane 0.000 000 0.006 0.00 0.00 84.16 0.02 3.53E-05 0.1 0.0 C7 0 000 000 0.002 0.00 0.00 86.18 0.00 3.41E-06 0.0 0.0 Methylcyclohexane 0.000 0.00 0.001 0.00 0.00 98.19 0.00 4.54E-06 0.0 0.0 2,2,4-Trimethylpentane 0.000 0.00 0.000 0.00 0.00 114.23 0.00 1.08E-07 0.0 0.0 Benzene 0019 0.01 0.01 0.00 0.01 78.11 0.84 1.47E-03 4.0 0.0 Toluene 0003 0.00 0.00 0,00 0.00 92.14 0.15 2.56E-04 0.7 0.0 Ethylbenzene 0.000 0.00 0.00 0.00 0.00 106.16 0.00 2.68E-06 0.0 0.0 p-Xylene 0.000 000 0.00 0.00 0.00 106.16 0.01 1.80E-05 0.0 0.0 CS 0.000 0.00 0.000 0.00 0.00 114.23 0,00 1.96E-07 0.0 0.0 C9 0000 0.00 0.000 0.00 0.00 128.26 0.00 0.00E+00 0.0 0.0 CIO 0.000 000 0.000 0.00 0.00 86.18 0.00 0.00E+00 0.0 0.0 Water 6.252 3.54 0.915 0.01 3.56 18.02 - - - - Total VOC's 4.49 0.04 105.8 1.1 Platte Valley Process Flare Plant Flare Source ID Number AIRS ID Source Description Flare Make Flare Model Serial Number Date in Service Flare Configuration Fuel Heating Value Flare Pilot Rating Purge Gas Rate Purge Gas Heat Rate Process Gas to Flare Process Gas Heating Value Process Gas Heat Rate S053 123-0057-053 Process Flare Flare Industries Air Assisted Flare 12/17/2002 Air -Assisted 1020 Btu/scf 0.09 MMBtu/hr 300 scf/hr 0.306 MMBtu/hr 100.0 MMscf/yr 1600.0 Btu/scf 18.3 MMBtu/hr SCC Source Location Zone: Horizontal: Potential Operation Potential Fuel Usage Stack Height Stack Diameter Exit Velocity Exit Temperature Volume Flow Rate Combustion Emission Calculations Heat Input hrs/yr MMBtu/hr 18.66 I 8760 Pollutant I Ib/MMBtu1 I lb/hr I ton/yr NOx1 0.138 2.58 11.3 CO1 0.28 5.14 22.5 TOC2 0.14 IIIIIIIIIIIIIIIIIIIIIIIL VOC` 0.01 0.26 1.1 Emissions from Permit 99OPAD102 2 AP -42 emission factor for TOC, Table 13.5-1, Assumed VOC is 10% WI of gas CO2e Emission Calculations Conversions: 1 Metric Ton = 2204.62 lbs 1 kg = 0.001 metric tons Pollutant kglmmbtu metric ton/yr tpy CO2 53.02 8,667 9,553.73 CH4 0.001 0.16 0.18 N2O 0.0001 0.02 0.02 CO2e = 9,563 CO2. = CO2 + (CH,*21) + (N2O.310) SO2 Emission Calculations Conversions: Inlet H2S Concentration 4 ppm Molar Volume to Molar Mass 379.3 scf/lb-mole SO2 Atomic Weight 64.05 amu H2S Atomic Weight 34.08 amu Pollutant H2S Process Gas lb/yr 35.94 tpy 0.02 SO2 0.03 Total SO2 emissions (tpy)* 0.04 * Total emissions * 1.1 factor 8760 hr/yr 103.4 MMscf/yr 100 ft 4.5 in 65.0 ft/s 1800 deg F 824 ft'/min �1J KerrAtGee July 30, 2018 Sent Via Certified Mail No: 91 7199 9991 7034 5668 0863 Matthew Burgett Air Pollution Control Division Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South Denver, CO 80246-1530 RE: Title V Permit 95OPWE013 Fort Lupton Complex Kerr-McGee Gathering LLC Dear Mr. Burgett: Kerr-McGee Gathering 1.LC P.O. Box 173779, Denver, CO 80217-3779 720-929-6000 Fax 720-929-7000 AUG — 3 201 d Kerr-McGee Gathering LLC (KMG) is hereby requesting the CDPHE to modify Operating Permit No. 95OPWE0l3 for the Fort Lupton Gas Processing complex (AIRS ID 123-0057) as follows: • Incorporate provisions of construction permit 12WE1492 Issuance 3, issued August II, 2017, the Lancaster Plant expansion to the Fort Lupton natural gas processing complex (AIRS ID 123/0057). • Incorporate provisions of construction permit I7WE0053, issued December I I, 2017, pertaining to natural gasoline loading operations at the Platte Valley plant (AIRS ID 123/0057/073). KMG is requesting the CDPHE issue an Operating Permit reflecting all equipment at the Fort Lupton complex comprised of the Fort Lupton Gas Plant, the Platte Valley Gas Plant, and Trains 1 & 2 of the Lancaster Plant. KMG is submitting this modification application within the required timeframe, i.e., within one year of permit issuance of 12WE1492 Issuance 3 and 17WE0053. This modification request includes the following: 1. Required Title V forms, 2. Current APENs, 3. Emission Calculations In an email dated June 4, 2018, Joshua Jones provided a list of which Title V forms would be required for this Title V permit modification request. As such, forms 200, 300, 400, 500, 600, 601 and 604 were not included in the permit application. If you have any questions, or require additional information, please contact me at (720) 929-4374 or Jillian.Yamartino@Anadarko.com Si►y4erely, KI -MCGEE GA"I UI:RING LLC J' ran Yamartin S nior USE Representative Enclosures Operating Permit Application FACILITY IDENTIFICATION FORM 2000-100 Colorado Department of Public Health and 1 nvironment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name and Name mailing address Street or Route City, State, Zip Code Fort Lupton Complex (Lancaster, Fort Lupton and Platte Valley Plants) P.O. Box 173779 - Denver Colorado 80217 - 3779 2. Facility location Street Address (No P.O. Box) City, County, Zip Code 16116 WCR 22 Fort Lupton, Weld County Colorado 80621 3. Parent corporation Name Street or Route City, State, Zip Code Country (if not •U.S.) Kerr-McGee Gathering, LLC P.O. Box 173779 Denver Colorado 80217 - 3779 4. Responsible Name official Title Telephone Miguel DeFlerrera Director, Midstream Operations (720) 929-6000 5. Permit contact Name person Title (If Different than 4) Telephone Jillian Yamartino Sr VISE Representative (720) 929-4374 6. Facility SIC code: 1311 (NAICS: 211111) 7. Facility identification code: CO 123'0057 8. 9. Federal Tax I. D. Number: 76-0146568 Primary activity of the operating establishment: Natural Gas Gathering, Processing and Compression 10. Type of operating permit O New X Modified O Renewal II. Is the facility located in a "nonattainment" area: If "Yes", check the designated "non -attainment" pollutant(s): 0 Carbon Monoxide X Ozone X Yes O No 0 PMI0 0 0 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. Operating Permit Application Colorado Department of Public t lealth and Environment Air Pollution Control Division Facility Name: Fort Lupton Complex SOURCE AND SITE DESCRIPTIONS FORM 2000-102 Rev 0(95 Facility Identification Code: CO 123-0057 The operating permit must be prepared and submitted on forms supplied by the Division. Use of this form is required for all operating permit applications. The Division will not consider or act upon your application unless each form used has been entirely completed. Completion of the information in the shaded area of this form is optional. Use "NA" where necessary to identify an information request that dyes not apply and is not in the optional shaded area. 1.Briefly describe the existing Unit(s) to be permitted. Attach copies of Form 2000-700 as needed to provide the information. 'rocess flowsheets or line diagrams showing major features and locations of air pollution control equipment can be most effective in bowing the location and relationships of the units. Providing mass flowrates/balances at critical points on the diagrams is very lelpful when developing an understanding of the processes involved. The following units are requested to be added and/or modified in the existing Title V permit. Permit No Equipment ID AIRS Point Status Description 12WE1492 E-2015 057 Existing Train 1 Mole sieve regeneration gas heater 12WE1492 E-2016 058 Existing Train 2 Mole sieve regeneration gas heater 12WE1492 H-6051 059 Existing Train I Amine heat medium heater 12WE1492 H-6052 060 Existing Train 1 Amine heat medium heater 12WE1492 H-6053 061 Existing Train 2 Amine heat medium heater 12WE1492 H-6054 062 Existing Train 2 Amine heat medium heater 12WE1492 IA 063 Existing Train I MDEA natural gas sweetening system 12WEI492 I B 064 Existing Train I MDEA natural gas sweetening system 12WE1492 2A 065 Existing Train 2 MDEA natural gas sweetening system 12WE1492 2B 066 Existing Train 2 MDEA natural gas sweetening system 12WE1492 FUG3 067 Existing Train I Fugitive component leak emissions 12WE1492 F-2 068 Existing Train I Process Flare 12 WE 1492 F-3 069 Existing Train 2 Process Flare 12WE1492 FUG4 071 Existing Train 2 Fugitive component leak emissions 17WE0053 NG-TL-01 073 New Truck Loadout of pressurized natural gasoline liquids (located at Platte Valley') 2. Site Location and Description (Include instructions needed to drive to remote sites not identified by street addresses) 16270 WCR 22, Ft. Lupton, CO. 80621 in Weld County. Colorado 3. Safety Equipment Identify safety equipment required for performing an inspection of the facility: Protection x Hard Hat x Safety shoes x Hearing Protection x Gloves Other, specify Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division SOURCE DESCRIPTION - APENS FORM 2000-102A Rev On -95 Facility Name: Fort Lupton Complex Facility Identification Code: CO 123/.005.7_ NOTE: Each new or updated Air Pollutant Emission Notice (APEN) submitted must be accompanied by payment of $100 per APEN. 1. For each emission unit enclose a copy of the most current complete Air Pollutant Emission Notice (APEN) on file with the )ivision. If the most current APEN was not completely and correctly filled out, a revised APEN is required. List an APEN number, late, and a brief description of the unit/process covered by the APEN. (No filing fees are needed for these copies) AIRS ID Date Description 123/0057/057 04/27/2017 F.-2015 - One (1) Mole sieve regeneration gas heater, 27.5 MMBtu'hr, equipped with ultra low NOx burners. 123/0057/058 1 I/1/2016 E-2016 - One (I) Mole sieve regeneration gas heater. 27.5 MMBtu/hr, equipped with ultra low NOx burners. 123;0057/059 I I/I/2016 . H-6051 - One (1) Amine heat medium heater. 66 MMBtu/hr, equipped with ultra low NOx burners. 123/0057/060 11!1/2016 H-6052 - One (1) Amine heat medium heater, 66 MMBtu;hr, equipped with ultra low NOx burners. 123/0057/061 1 1/1/2016 H-6053 - One (1) Amine heat medium heater, 66 MMBtu/hr, equipped with ultra low NOx burners. 123/0057'062 04/27/2017 H-6054 - One ( I) Amine heat medium heater, 66 MMBtu hr, equipped with ultra low NOx burners. 123/0057/063 11/1/2016 IA - One (I) MDEA natural gas sweetening unit for acid gas removal, 165 MMSCFD capacity. 123/0057/064 1 1/ 1/2016 I B - One (1) MDEA natural gas sweetening unit for acid gas removal, 165 MMSCFD capacity. 123/0057/065 11/1/2016 2A - One (I) MDEA natural gas sweetening unit for acid gas removal, 165 MMSCFD capacity. 123/0057/066 11;1/2016 2B - One (I) MDEA natural gas sweetening unit for acid gas removal, 165 MMSCFD capacity. 123/0057/067 I 12:08/2014 Fugitive emissions - Train 1 Subject to 40 CFR 60 Subpart 0000a 123/0057/068 I 12/01/2016 F-2 — Lancaster Train I Process Flare 123/0057/069 I 12/01/2016 F-3 — Lancaster Train 2 Process Flare 123/0057/071 ' 12/08/2014 Fugitive emissions - Train 2 Subject to 40 CFR 60 Subpart 0000a 123/0057/073 I 01/I 1/2017 Truck Loadout of pressurized natural gasoline liquids controlled by 95% ECD 2. No APEN exists for an emission unit. List the new APEN and the appropriate descriptive information here. Submit the APEN ✓ith a construction permit application. Jew APEN and permit application submitted o with this application OR o under separate cover to Construction Permits Section. N/A 3.A revised APEN was prepared and enclosed for an emission unit. List the APEN and the appropriate descriptive information sere. A revised APEN is needed where a significant increase in emissions has occurred, or is planned; or a major modification of le unit has occurred or is planned; or the existing information needs correction or completion. A construction permit application nay need to be submitted. tevised APEN submitted as part of this application: 0 Yes X No o Filing Fee Enclosed New permit application enclosed: o Yes X No Permit modification application enclosed: o Yes X No Operating Permit Application SOURCE DESCRIPTION - INSIGNIFICANT ACTIVITIES Colorado Department of Public Health and I{nvironment Air Pollution Control Division Facility Name: Fort Lupton Complex Facility Identification Code: CO 123'0057 FORM 2000-102B Rev 0-95 NOTE: The operating permit must he prepared and submitted on forms supplied by the Division. this is a supplemental form for use only when necessary to provide complete information in the operating permit application.The Division will not consider or act upon your application unless each lorm used has been entirely completed. ;ertain categories of sources and activities are considered to be insignificant contributors to air pollution and are listed below. A .ource solely comprised of one or more of these activities is not required to obtain an operating permit pursuant to Regulation 3, lnless the source's emissions trigger the major source threshold as defined in Part A, Section I.B.58 of Regulation 3. For the acility, mark all insignificant existing or proposed air pollution emission units, operations, and activities listed below. (a) noncommercial (in-house) experimental and analytical laboratory equipment which is bench scale in nature including quality control/quality assurance laboratories, process support laboratories, environmental laboratories supporting a manufacturing or industrial facility, and research and development laboratories. (b) research and development activities which are of a small pilot scale and which process less than 10,000 pounds of test material per year. (c) small pilot scale research and development projects less than six months in duration with controlled actual emissions less than 500 pounds of any criteria pollutant or 10 pounds of any non -criteria reportable pollutant. Disturbance of surface areas for purposes of land development, which do not exceed 25 contiguous acres and which do not exceed six months in duration. (This does not include mining operations or disturbance of contaminated soil). Each individual piece of fuel burning equipment, other than smokehouse generators and internal combustion engines, which uses gaseous fuel, and which has a design rate less than or equal to 5 million Btu per hour. (See definition of fuel burning equipment, Common Provisions Regulation). Petroleum industry flares, not associated with refineries, combusting natural gas containing no H2S except in trace (less than 500 ppmw) amounts, approved by the Colorado Oil and Gas Conservation Commission and having uncontrolled emissions of any pollutant of less than five tons per year. Chemical storage tanks or containers that hold less than 500 gallons, and which have a daily throughput less than 25 gallons. Landscaping and site housekeeping devices equal to or less than 10 H.P. in size (lawnmowers, trimmers, snow blowers, etc.). Crude oil or condensate loading truck equipment at crude oil production sites where the loading rate does not exceed 10,000 gallons per day averaged over any 30 day period. Chemical storage areas where chemicals are stored in closed containers, and where total storage capacity does not exceed 5000 gallons. This exemption applies solely to storage of such chemicals. This exemption does not apply to transfer of chemicals from, to, or between such containers. Oil production wastewater (produced water tanks), containing less than 1% by volume crude oil, except for commercial facilities which accept oil production wastewater for processing. Storage of butane, propane, or liquified petroleum gas in a vessel with a capacity of less than 60,000 gallons, provided the requirements of Regulation No. 7, Section IV are met, where applicable. Storage tanks of capacity < 40,000 gallons of lubricating oils. Venting of compressed natural gas, butane or propane gas cylinders, with a capacity of 1 gallon or less. Fuel storage and dispensing equipment in ozone attainment areas operated solely for company -owned vehicles where the daily fuel throughput is no more than 400 gallons per day, averaged over a 30 day period. Crude oil or condensate storage tanks with a capacity of 40,000 gallons or less. Storage tanks meeting all of the following criteria: (i) annual throughput is less than 400,0O0 gallons; and (ii) the liquid stored is one of the following: (A) diesel fuels 1-D, 2-D, or 4-D; (B) fuel oils #1 through #6; (C) gas turbine fuels 1-GT through 4-GT; (D) an oil/water mixture with a vapor pressure lower than that of diesel fuel (Reid vapor pressure of .025 PSIA). Each individual piece of fuel burning equipment which uses gaseous fuel, and which has a design rate less than or equal to 10 million Btu per hour, and which is used solely for heating buildings for personal comfort. x Stationary Internal Combustion Engines which: (i) power portable drilling rigs; or (ii) are emergency power generators which operate no more than 250 hours per year; or (iii)have actual emissions less than five tons per year or rated horsepower of less than 50. Surface mining activities which mine 70,000 tons or fewer of product material per year. A fugitive dust control plan is required for such sources. Crushers, screens and other processing equipment activities are not included in this exemption. Air pollution emission units, operations or activities with emissions less than the appropriate de minimis reporting level. NOTE: Material Data Safety Sheets (MSDS) do not have to be submitted for any insignificant activities. USE FORM 2000-700 TO PROVIDE AN ITEMIZED LIST OF THE SOURCES OR ACTIVITIES BEING IDENTIFIED AS INSIGNIFICANT ACTIVITIES. DO NOT ITEMIZE INDIVIDUAL PIECES OF LANDSCAPING EQUIPMENT. THE LIST IS NEEDED TO ACCURATELY ACCOUNT FOR ALL ACTIVITIES AT THE FACILITY Operating Permit Application PLANT -WIDE HAZARDOUS AIR POLLUTANTS Colorado Department of Public Health and Invironment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE FORM 2000-602 Rev 06-95 Facility name: Fort Lupton Complex 2. Facility identification code: CO 123/0057 3. Complete the following emissions summary for all hazardous air emissions at this facility. Calculations attached. Attach a copy of all calculations to this form. Pollutant CAS Common or Generic Pollutant Name Actual emissions Allowable OR Potential to emit Quantity Units Quantity Units 50000 Formaldehyde 19.7 TPY 75070 Acetaldehyde 4.7 TPY 71432 Benzene 8.4 TPY 108883 Toluene 13.6 TPY 100414 Ethylbenzenc 6.6 TPY 1330207 Xylene 9.5 TPY 110543 n -Hexane 15.4 TPY 107028 Acrolein 3.1 TPY 67561 Methanol 0.7 TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TRY TPY TPY TPY TPY NOTE: If there is a permit for this unit, the permit limits are the same as the potential to emit. 1 Operating Permit Application Colorado Department of Public Health and Iinvironment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE PLANT -WIDE CRITERIA AIR POLLUTANTS FORM 2000-603 09-94 Facility name: : Fort Lupton Complex 2.Facility identification code: CO 123/0057 3. Complete the following emissions summary for the listed emissions at this facility. Air pollutant Actual Potential to emit Maximum allowable TPY TPY TPY Particulates (TSP) PM -10 22.2 22.2 Nitrogen oxides 637.5 637.5 Volatile organic compounds 443.1 443.1 Carbon monoxide 534.3 534.3 Lead Sulfur dioxide 1 1.7 1 1.7 Total reduced sulfur Reduced sulfur compounds Hydrogen sulfide Sulfuric acid mist Fluorides 2 Operating Permit Application Colorado Department of Public I lealth and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE PERMIT SHIELD PROTECTION IDENTIFICATION FORM 2000-605 Rev 06-95 I. Facility name: Ft. Lupton Complex 2. Facility identification code: CO 1230057 3. Specify Emission Source: Facility Wide 4. Do not use 5. Pollutant. Equipment, or Process 6. Colorado Air Quality Regulations 7. State Only Criteria pollutant and non -criteria pollutants Rey. No. I Criteria pollutant and non -criteria pollutants Reg. No 4 Criteria pollutant and non -criteria pollutants Reg. No 6 Criteria pollutant and non -criteria pollutants Reg. No 7 Criteria pollutant and non -criteria pollutants Reg. No. 8 Criteria pollutant and non -criteria pollutants Reg. No. 9 Criteria pollutant and non -criteria pollutants Reg. No. 10 Criteria pollutant and non -criteria pollutants Reg. No. I 1 Criteria pollutant and non -criteria pollutants Rey. No. 12 Criteria pollutant and non -criteria pollutants ReyNoI . . Criteria pollutant and non -criteria pollutants Rey. No. 16 Criteria pollutant and non -criteria pollutants Reg. No. 18 Criteria pollutant and non -criteria pollutants Rey No. 19 8. Other requirements (e.g., malfunction reporting, special operating conditions from an existing permit such as material usage, operating hours, etc.) State Only NOTE: REQUESTS FOR THE SHIELD MUST BE FOR A SPECIFIC REQUIREMENT IN THE REGULATIONS. USE FORM 2000-700 TO PROVIDE AN EXPLANATION OF WHY THE SHIELD IS REQUESTED Operating Permit Application EMISSION UNIT COMPLIANCE PLAN FORM 2000-606 Colorado Department of Public Health and Environment COMMITMENTS AND SCHEDULE 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Ft. Lupton 2. Facility identification code: CO 1230057 3. Stack identification code: Facility Wide 4. Unit identification code: Facility Wide 5. For Units that are presently in compliance with all applicable requirements, including any monitoring and compliance certification requirements of Colorado Air Quality Regulation 3, Part C that apply, complete the following. These commitments are part of the application for operating permits. x We will continue to operate and maintain each source in compliance with all applicable requirements. Form 2000-604 includes new requirements that apply or will apply to this Unit during the term of the permit. We will meet such requirements on a timely basis. 6. For Units not presently fully in compliance, complete the following. This Unit is in compliance with all applicable requirements except for those indicated below. We will achieve compliance according to the following schedule (If more space is needed attach additional copies of Form 2000-700): Applicable Requirement 1 2. 3. Corrective Actions Deadline Progress reports will be submitted: Start date: and every six (6) months thereafter Operating Permit Application Colorado Department of I Iealth Air Pollution Control Division Facility Name: Fort Lupton Complex TABULATION OF PERMIT APPLICATION FORMS FORM 2000-800 09-94 Facility Identification Code: CO 123/0057 I. ADMINISTRATION This application contains the following forms: Form 2000-100, Facility Identification Form 2000-101, Facility Plot Plan Forms 2000-102. -I 02A, and -I 02B. Source and Site Descriptions II. EMISSIONS SOURCE DESCRIPTION Total Number of 'ibis Form This application contains the following forms (one form for each facility boiler, nrinting Form 2000-200, Stack Identification 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, Adsorhers Form 2000-403. Catalytic or Thermal Oxidation Form 2000-404. Cyclones/Settling Chambers Form 2000-405, Electrostatic Precipitators Form 200(1-406. Wet Collection Systems Form 2000-407. BaghousesiFabric Filters IV. COMPLIANCE DEMONSTRATION Total Number of This Form This application contains the following forms (one for each facility boiler. nrinting oneration. Form 2000-500. Compliance Certification - Monitoring and Reporting Form 2000-501. Continuous Emission Monitoring Form 2000-502, Periodic Emission Monitoring fixing 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 V. EMISSION SUMMARY AND COMPLIANCE CERTIFICATION Total Number of This Form This application contains the following forms quantifying emissions, certifying compliance with applicable requirements, and developing a compliance plan Form 2000-600, Emission Unit I lazardous Air Pollutants Form 2000-601. Emission Unit Criteria Air Pollutants Form 2000-602, Facility Hazardous Air Pollutants I Form 2000-603, Facility Criteria Air Pollutants I Form 2000-604, Applicable Requirements and Status of Em scion Unit Form 2000-605, Permit Shield Protection Identification 1 Form 2000-606, Emission Unit Compliance Plan - Commitments and Schedule 1 Form 2000-607, Plant -Wide Applicable Requirements Form 2000-608, Plant -Wide Compliance Plan - Commitments and Schedule VI. SIGNATURE OF RESPONSIBLE OFFICIAL - FEDERAL/STATE CONDITIONS A. STATEMENT OF COMPLETENESS 1 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 o 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 Miguel DeHerrera Title Director, Midstream Operations Signal a _1 Date Signed 7 i3o/; °, FCrm adopted from CDPHE, Operating Permit Application - Tabulation of Permit Application Forms 2 Operating. Permit Application Colorado Department of Health Air Pollution Control Division Facility Name: Fort Lupton Complex CERTIFICATION FOR STATE -ONLY CONDITIONS FORM 2000-800 p9-94 Facility Identification Code: CO 123/0057 VI. SIGNATURE OF RESPONSIBLE OFFICIAL - STATE ONLY CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and, based on information and belief formed after reasonable inquiry. I certify that the statements and information contained in this application are true, accurate and complete. B. CERTIFICATION OF FACILITY COMPLIANCE STATUS FOR STATE -ONLY CONDITIONS (check one box only) X I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements. c 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 Miguel DeHerrera Title Director, Midstream Operations Signat Date Signed SEND ALL MATERIALS TO: COLORADO DEPARTMENT OF HEALTH APCD-SS-B I 4300 CHERRY CREEK DRIVE SOUTH DENVER, CO 80246-1530 3 General APEN - Form APCD-200 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. There may be a more specific APEN for your source (e.g. paint booths, mining operations, engines, etc.). A list of specialty APENs is available on the Air Pollution Control Division (APCD) website at: www.colorado. eov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, If.C. for revised APEN requirements. Permit Number: 12WE1492 AIRS ID Number: 123 / 0057 [Leave blank unless APCD has already assigned a permit # and AIRS ID] / 057 Section 1 - Administrative Information Company Name1: Kerr-McGee Gathering LLC Site Name: Lancaster Plant Site Location: 16270 WCR 22, Fort Lupton Mailing Address: (Include Zip Code) P. O. Box 173779 Denver, CO 80217-3779 Portable Source Home Base: Site Location County: Weld NAICS or SIC Code: 1321 Permit Contact: Jillian Yamartino Phone Number: 720-929-4374 jillian.yamartino®anadarko.c E -Mail Address2: om I Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-2OO -General APEN - Revision 1/2017 38603 ®W GOl OR 1 �WJ �,rm..,re,Aa0�O x. nn M1 �nv��nnmsnr Permit Number: 12WE1492 AIRS ID Number: 123 / 0057 / 057 [Leave blank unless APCD has already assigned a permit A and AIRS ID] Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source (check one below) ❑ STATIONARY source ❑ PORTABLE source - OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below) - OR - • APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) ❑ APEN submittal for permit exempt/grandfathered source Additional Info Et Notes: Annual APEN update 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: 25 MMBtu/hr mole sieve regeneration gas heater with ultra low NOx burners. Assumed 84 % efficiency Manufacturer: ZEECO Model No.: Serial No.: Company equipment Identification No. (optional): E-2015 For existing sources, operation began on: 04/18/2014 For new or reconstructed sources, the projected start-up date is: ❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day days/week weeks/year Seasonal use percentage: Dec -Feb: 25.00 Mar -May: 25.00 June -Aug: 25.00 Sept -Nov: 25.00 Form APCD-2OO - General APEN - Revision 1/2017 COLORADO 2 I ®' � o:w�:aorwam Hull.• F fnvi�ann�• nl Permit Number: 12WE1492 AIRS ID Number: 123 / 0057 / 057 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 4 - Processing/Manufacturing Information Ft Material Use ® Check box if this information is not applicable to source or process From what year is the actual annual amount? ILI I t J 'e< 4-ice `i �n � � s7 i,) 71 fit tei !V A t r'{ e 1 t J '� +�`"^RT�yi''a�ai " aYA '-are< i 91,41 I*'I I''i(('jl. "Requested values will become permit limitations. Requested timit(s)should consider future process growth. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UrM) 40.1427, -104.7476 O Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. 01u at��4aJ:' lI +�Jol:> •� { 'S i?.1 )pa It l r 1 e„ 19�,�__�It )� . I......_ :3 _ _...u..._ >_�..__..'I,._.... N,.y/�J1. a .I_ u.; .` r .L'i$21,. E-2015 75.00 .00.00 24000.00 60.00 Indicate the direction of the Stack outlet: (check one) ® Upward ❑ Downward O Upward with obstructing raincap ❑ Horizontal ❑ Other(describe): Indicate the stack opening and size: (check One) ® Circular Interior stack diameter(inches): 48.00 O Square/Rectangle Interior stack diameter(inches): Interior stack depth (inches): ❑ Other(describe): COLOR ADO 3 Form APCD 200 General APEN Revision 1/2017 Permit Number: 12WE1492 AIRS ID Number: 123 / 0057 / 057 [Leave blank unless APCD has already assigned a permit fi and AIRS ID] Section 6 - Fuel Data and Throughput information ❑ Check box if this information is not applicable to the source (e.g. there is no fuel-burning equipment associated with this emission source) NtAi 0 M ur� t w" Y7 x t' o w ,n y ii r - }" e -a p t �� 25.00 182 229.5 From what year is the actual annual fuel use data? 2016 Indicate the type of fuel used5: El Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf) ❑ Field Natural Gas Heating Value: BTU/scf ❑ Ultra Low Sulfur Diesel (assumed fuel heating value of 138,000 BTU/gallon) ❑ Propane (assumed fuel heating value of 2,300 BTU/scf) El Coal Heating Value: BTU/lb Ash Content: Sulfur Content: ❑ Other(describe): Heating Value (give units): 4 Requested values will become permit limitations.Requested limit(s)should consider future process growth, 'If fuel heating value is different than the listed assumed value,provide this information in the"Other"field. Section 7- Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? Eg Yes ❑ No If yes, describe the control equipment AND state the overall control efficiency(% reduction): 'i,i �• 7x� .Y L pmt a A�'1 ,9 Yr%f ".ke B • t +rye t)K-2 [rr!li i��r`4} 1rY 11 'x "r u� TSP (PM) PMto PM2.5 SOX NOx Ultra Low NOx Design VOC CO Other: AL. COLORADO Form APCD-200-General APEN - Revision 1/2017 4 (mvi. x„''`',,,�o v, Permit Number: 12WE1492 AIRS ID Number: 123 / 0057 / 057 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 7 (continued) From what year is the following reported actual annual emissions data? 2016 Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) 4446' $ira4"1 ='°tt S+<! �4 v r Yy'A�, rY ? s R N� �',..�� r t 4 �' {1-_15.4,O tbaT t • blt tra I d „ too? .qtr p rte. ' #. -7,3k , . A� � 'tvs'r onsI/eb b TSP (PM) PM10 PM2.5 0.007 lb/MMbtu AP-42 0.70 0.90 SOx NOx 0.04 Ib/MMbtu Mfg. 4.00 4.70 CO 0.04 lb/MMbtu Mfg. 4.00 4.70 VOC 0.019 lb/MMbtu Mfg. 1.90 2.20 Other: 4 Requested values will become permit limitations.Requested limit(s)should consider future process growth. 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Section 8 - Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteria pollutants (e.g. HAP-hazardous air pollutant) emissions equal to or greater than ❑ Yes ❑ No 250 lbs/year? If yes, use the following table to report the non-criteria pollutant (HAP)emissions from source: - , F' +ri-r4; k tkii�a k �t� a o tr o b,t e f1 r �7� 411 ,` Pe cenG + lA�HG � t • ' i.J rr )frl� I� I leelt �l Lrt .� S f ak"` Y ¢ t til r7�1 ir�a rte';(at i t -Ir a �L 'na") R 151a ;Jilt 6 Annual emission fees will be based on actual controlled emissions reported.If source has not yet started operating, leave blank. s COLORADO Form APCD-200-General APEN - Revision 1/2017 5 1 M Permit Number: 12WE1492 AIRS ID Number: 123 / 0057 / 057 [Leave blank unless APCD has already assigned a permit k and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. 4/27/2017 Signa(ure of Legally Aut�fiorized Person (not a vendor or consultant) Date Jill an Yamartino 11 Sr. HSE Representative Name (print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notices is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 to: For more information or assistance call: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Or visit the APCD website at: Denver, CO 80246-1530 Make Check payable to: https://www.colorado.gov/cdphe/apcd Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Form APCD-2OO - General APEN - Revision 1/2017 Small Business Assistance Program (303 692-3175 or (303) 692-3148 Av COLORADO 6 H..hOrn m AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — General Permit Number: Facility Equipment ID: E-2016 12WE1492 Section 01 — Administrative Information Company Name: Kerr-McGee Gathering LLC Source Name: Lancaster Plant Source Location: 16270 WCR 22, Fort Lupton Portable Source Home Base: Mailing Address: Person To Contact: E-mail Address: [Leave blank unless APCD has already assigned a permit # & AIRS ID] Emission Source AIRS ID: 123 / 0057 / 058 [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.) P. O. Box 173779 Denver, CO 80217-3779 Jillian Yamartino Jillian.Yamartino I Anadarko.com Section 03 — General Information For existing sources, operation began on: Normal Hours of Source Operation: General description of equipment and purpose: NAICS, or 1321 SIC Code: County: Weld Elevation: 5,030 Feet ZIP Code: 80217 Phone Number: 720-929-4374 Fax Number: 06 ! 23 / 2015 24 hours/day 7 days/week Section 02 — Requested Action (check applicable request boxes) ❑ Request for NEW permit or newly reported emission source ® Request PORTABLE source permit ❑ Request MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment 0 Change company name ® Change permit limit ❑ Transfer of ownership O Request to limit HAPs with a Federally enforceable limit on PTE ❑ Request APEN update only (check the box below that applies) ❑ Revision to actual calendar year emissions for emission inventory Additional Info. & Notes: ❑ Other Update 5 -Year APEN term without change to permit limits or previously reported emissions Update PTE and annual operating hours from 8,760 to 7,150 For new or reconstructed sources, the projected startup date is: / 1 52 weeks/year 25 MMBtu/hr mole sieve regeneration gas heater with ultra low NOx burners. Assumed 84 % efficiency Will this equipment be operated in any NAAQS nonattainmeul area? (httn://www.cdphe.state.co. us/an/attainmaintain.html) Section 04— Processing/Manufacturing Equipment Information Si Material Use Description of equipment': Manufacturer: ZEECO Model No.: n/a Yes Serial No.: No Don't know Description Actual Level (For Data Year) Annual Requested Permitted Level'- (Specify Units) Design Process Rate (Specify Units/Hour) Raw Materials: Finished Products: Other Process: annual op' hours [ 7,150 hrs 'If additional space is required, please attach a separate list of equipment, materials and throughputs. =Requested values will become permit limitations. Requested level should consider process growth over the next five years. FORM APCD-200 386044 Page 1 of 2 Colorado Department of Public Health and Environment Air Pollution Control Division (APCD) This notice is valid for five (5) years. Submit a revised APEN prior to expiration of five-year term, or when a significant change is made (increase production, new equipment, change in fuel type, etc). Mail this form along with a check for S152.90 to: Colorado Department of Public Health & Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 For guidance on how to complete this APEN form: Air Pollution Control Division: (303) 692-3150 Small Business Assistance Program (SNAP): (303) 692-3148 or (303)692-.1.75 APEN forms: http://www.cdphestate.co.us/ap/downloadfonns.html Application status: http://www.cdphe.state.co.us/ap/ss/sspept.httnl ® Check box to request copy of draft permit prior to issuance. ® Check box to request copy of draft permit prior to public notice. 2016-10-31 LAN E-2016 APEN.doc AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — General Permit Number: 12WE1492 Emission Source AIRS ID: 123 / 0057 I 058 Section 05 — Emission Release information (Attach a separate sheet with relevant information in the event of multiple releases; provide datum & either Lat/Long or UTM) Operator Stack Base Elevation Discharge Height Above Ground Temp. Horizontal Datum (NAD27, NAD83, UTM Zone UTM Easting or Longitude UTM Northing or Latitude ID No. (feet) Level (Feet) (°F) (ACFM) (ft/sec) (%) WGS84) (12 or 13) (meters or degrees) (meters or degrees) Data (e.g. map, GPS, GoogleEarth) E-2016 5,030 r 75 a 400 24,000 60 14 _I 13 -104.7476 40.1427 I iMaps/Google Maps Direction of outlet (check one): ® Vertical ❑ Vertical with obstructing raincap ❑ Horizontal ❑ Down Exhaust Opening Shape & Size (check one): ® Circular: Inner Diameter (inches) = 48 ❑ Other: Length (inches) Section 06 — Combustion Equipment & Fuel Consumption Information Company equipment Identification No.: E-2016 Manufacturer: ZEECO USA, LLC Model: Ultra LowNOx ❑ Other (Describe): Width (inches) Serial No.: n/a Fuel Type Design Input Rate (10 Btu/hr) Actual Level (For Data Year) Annual Requested Permitted Level2 (Specify Units) Fuel Heating Value (Indicate: Btu/lb, Btu/gal, Btu/SCE) .. Percent by Weight Seasonal Fuel Use (% of Annual Use) Sulfur Ash Dec -Feb Mar -May Jun -Aug Sep -Nov Natural Gas 25 229.5 MMSCF/yr 1020 Btu/scf 25 25 25 25 (84% efficiency) =Requested values will become permit limitations. Requested level should consider process growth over the next five years. Section 07 — Emissions Inventory Information & Emission Control information Attach any emission calculations and emission factor documentation to this APEN form. ® Emission Factor Documentation attached Data year for actual calendar yr. emissions below & throughput above (e.g. 2007): Pollutant Control Device Description Overall Collection Efficiency Control Efficiency (% Reduction) Emission Factor Actual Calendar Year Emissions' Requested Permitted Emissions Estimation Method or Emission Factor Source Primary Secondary Uncontrolled Basis Units Uncontrolled (Tons/Year) Controlled (Tons/Year) Uncontrolled Tons/Year) Controlled (Tons/Year) TSP PN-Lt 7.6 Ib/MMSCF 0.34 0.7 0.9 AP -42 Tb 1.4-2 PM2 5 7.6 Ib/MMSCF 0.34 0.7 0.9 .AP -42 Tb 1.4-2 SOx 0.6 lb/MMSCF 0 0.1 AP -42, Tb 1.4-2 NOx Ultra low NOx 0.04 Iti/MMBtu L9 3.9 4.7 Manufacturer VOC 0.019 lb/MMBtu 0.94 1.8 2.2 Manufacturer CO 0.04 lb/MMti1Btu 1.9 3.9 4.7 Manufacturer Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. 2015 ' Annual emission fees will he based on actual emissions reported here. If left blank, annual emission fees will be based on requested emissions. ° If Requested Permitted Emissions is left blank, the APCD will calculate emissions based on the information supplied in sections 03 - 07. Sectiy�l 08 —Applicant certification - I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. Sign ure of Person If4gaily Authorized to Supply Data Date Jillian Vamartino Name of Legally Authorized Person (Please print) Title Sr HSE Representative Page 2 of 2 2016-10-31 LAN E-2016 APEN.doc AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit— General Permit Number: 12WE1492 Facility Equipment ID: H-6051 [Leave blank unless APCD has already assigned a permit ii & AIRS ID) Emission Source AIRS ID: 123 / 0057 / 059 Section 01 —Administrative Information Company Name: Kerr-McGee Gathering LLC [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.) Source Name: Lancaster Plant Source Location: 16270 WCR 22 Portable Source Home Base: Fort Lupton, CO I\AICS, or SIC Code: 1321 County: Weld Elevation: 5,030 Feet Mailing Address: P. O. Box 173779 ZIP Code: 80217 Denver, CO 80217-3779 Person To Contact: Jillian Yamartino Phone Number: 720-92911374 E-mail Address: Jillian.Yamartino@Anadarko.com Fax Number: Section 03 — General Information For existing. sources, operation began on: Normal Hours of Source Operation: General description of equipment and purpose: Section 02 — Requested Action (check applicable request boxes) ❑ Request for NEW permit or newly reported emission source ❑ Request PORTABLE source permit • Request MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ® Change permit limit ❑ Transfer of ownership ❑ Other ❑ Request to limit HAPs with a Federally enforceable limit on PTE ❑ Request APEN update only (check the box below that applies) ❑ Revision to actual calendar year emissions for emission inventory Additional Info. & Notes: Update 5 -Year APEN term without change to permit limits or previously reported emissions Emissions limits to reflect increase of 10%. 04 / 18 / 2014 For new or reconstructed sources, the projected startup date is: 24 hours!day 7 days/week 52 weeks/year 60 MMBtu/hr amine heat medium heater with low NOx burners to regenerate amine for IA. Assumed 78% efficiency. Will this equipment be operated in any NAAQS nonattaitmtent area? ® Yes (http://www.edohe.state.co.uslap/attainmaintain.htinl) Section 04 — Processing/Manufacturing Equipment Information & Material Use Description of equipment': Manufacturer: Sigma Thermal FRaw Materials: Model No.: HC2-50.0-11-SF Serial No.: No Don't know Description Actual Level Annual Requested Permitted Level' (For Data Year) (Specify Units) Design Process Rate (Specify Units/hour) Finished Products: If additional space is required, please attach a separate list of equipment, materials and throughputs. 'Requested values will become permit limitations. Requested level should consider process growth over the next five years. FORM APCD-200 386045 Page 1 of 2 / / Colorado Department of Public Health and Environment Air Pollution Control Division (APCD) This notice is valid for five (5) years. Submit a revised APEN prier to expiration of five-year term, or when a significant change is made (increase production, new equipment, change in fuel type; etc). Mail this form along with a check for 5152.90 to: Colorado Department of Public Health & Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 For guidance on how to complete this APEN form: Air Pollution Control Division: 1303) 692-3150 Small Business Assistance Program (SBAP): (303) 692.-3148 or (303) 692-3175 APEN forms: http://www.cdphe.state.coms/ap/downloadforms.html Application status: hita/hvww.edphe_state,co.us/ap/ss'sspcpt.html ® Check box to request copy of draft permit prior to issuance. ® Check box to request copy of draft permit prior to public notice. 2016-10-31 FTL II -6051 APEN.doc AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — General Permit Number: 12WE1492 Emission Source AIRS ID: 123 / 0057 / 059 Section 05 — Emission Release Information (Attach a separate sheet with relevant information in the event of multiple releases; provide datum & either Lat/Long or UTM) Operator Stack ID No. Base Elevation (feet) Discharge Height Above Ground Level (Feet) Temp. ( °F) Flow Rate ( ACF_ Velocity fft/see) Moisture /° (°) Horizontal Datum (NAD27, NAD83, WGS84) UTM Zone (12 or 13) UTM Fasting or Longitude (meters or degrees) UTM Northing or Latitude (meters or degrees) Method of Collection for Location Data (e,g. map. GPS, GoogleLarth) H-6051 13 Direction of outlet (check one): FM, Vertical O Vertical with obstructing raincap Exhaust Opening Shape & Size (check one): ® Circular: Inner Diameter (inches) _ Section 06 — Combustion Equipment & Fuel Consumption Information Company equipment Identification No.: H-6051 Manufacturer: Sigma Thermal ❑ Horizontal ❑ Down ❑ Other: Length (inches) Model: HC2-50.0-H-SF ❑ Other (Describe): Width (inches) = Serial No.: Fuel Type Design Input Rate (106 Btu/hr) Actual Level (For Data Year) Annual Requested Permitted Lever (Specify Units) Fuel Heating Value (Indicate: Btu/lb, Btu/gal, Btu/SCF) Percent by Weight Seasonal Fuel Use (% of Annual Use) Sulfur Ash Dec -Feb Mar -May Jun -Aug Sep -Nov Natural Gas 60 195 MMSCF/yr 726.7 MMSCF/yr 1020 Btu/scf 25 25 25 25 (78% efficiency) 'Requested values will become permit limitations. Requested level should consider process growth over the next five years. Section 07 — Emissions Inventory Information & Emission Control Information Attach any emission calculations and emission factor documentation to this APEN form. ® Emission Factor Documentation attached Data year for actual calendar yr. emissions below & throughput above (e.g. 2007): Pollutant Control Device Description Overall Collection Efficiency Control Efficiency (% Reduction) Emission Factor Actual Calendar Year Emissions' Requested Permitted Emissions4 Estimation Method or Emission Factor Source Primary Secondary Uncontrolled Basis Units Uncontrolled (Tons/Year) Controlled (Tons/Year) Uncontrolled (Tons/Year) Controlled (Tons/Year) TSP PMio 4.6 Ib/SIMSCF 0.54 1.7 Testing PM2s 4.6 Ib/.1MSCF 0.54 1.7 Testing SOx 0.6 Ib/MMSCF 0 0.22 AP -42, Th 1.4-2 NOx 0.04 Ih/MMBtu 4.35 14.8 Manufacturer VOC 5.5 Ib/MMSCF 0.58 2.0 AP -42 Tb 1.4-2 CO 0.04 Ib/MM'IBtu 4.35 14.8 Manufacturer Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. 2015 'Annual emission fees will be based on actual emissions reported here. Tf left blank, annual emission fees will be based on requested emissions If Requested Permitted Emissions is left blank, the APCD will calculate emissions based on the information supplied in sections 03 - 07. Secti ii 08 —Ai licant certification - I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. ure of Perso f egally Authorized to Supply Data Date (///7 r(,„ Jillian Yamartino Sr. HSE Representative Name of Legally Authorized Person (Please print) Title Page 2 of 2 2016-10-31 Fr -1,11-6051 APEN.doc Permit Number: 12WE1492 Facility Equipment ID: H-6052 AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — General Emission Source AIRS Ill: 123 / 0057 / 060 [Leave blank unless APCD has already assigned a permit # & MRS ID] [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] Section 01 —Administrative Information Company Name: Kerr-McGee Gathering LLC Source Name: Lancaster Plant Source Location: 16270 WCR 22 Portable Source Horne Base: Fort Lupton, CO NAICS. or SIC Code: 1321 County: Weld Elevation: 5,030 Feet Mailing Address: P. O. Box 173779 ZIP Code: 80217 Denver, CO 80217-3779 Person To Contact: Jillian Yamartino Phone Number: 720-929-4374 E-mail Address: Jillian.Yamartino(Onadarko.com Fax Number: Section 03 — General Information For existine sources, operation began on: Normal Hours of Source Operation: General description of equipment and purpose: Section 02 — Requested Action (check applicable request boxes) ❑ Request for NEW permit or newly reported emission source ❑ Request PORTABLE source permit ® Request MODIFICATION to existing permit (cheek each box below that applies) ❑ Change fuel or equipment ❑ Change company name ar. Change permit limit ❑ Transfer of ownership ❑ Request to limit HAPs with a Federally enforceable limit on PTE ❑ Request APEN update only (check the box below that applies) ❑ Revision to actual calendar year emissions for emission inventory CI Additional Info. & Notes: ❑ Other Update 5 -Year APEN term without change to permit limits or previously reported emissions Emissions limits to reflect increase of 10%. 04 r' 18 / 2014 For new or reconstructed sources, the projected startup date is: 24 hours/day 7 days/week 52 weeks/year 60 M7sBtu/hr amine heat medium heater with low NOx burners to regenerate amine for IA. Assumed 78% efficiency. Will this equipment be operated in any NAAQS nonattainment area'? (http://www.cdphe.state.co.us/aolattainmaintain.hunl) Section 04 — Processing/Manufacturing Equipment Information & Material Use Description of equipment': Manufacturer: Sigma Thermal Raw Materials: Finished Products: Other Process: Model No.: HC2-50.0-II-SF Serial No.: ® Yes ❑ No Don't know Description Actual Level (For Data Year) Annual Requested Permitted Leve- (Specify Units) Design Process Rate (Specify Units/Hour) If additional space is required, please attach a separate list of equipment, materials and throughputs. 'Requested values will become permit limitations. Requested level should consider process growth over the nest live years. FORM APCD-200 3506 Page 1 of 2 Colorado Department of Public Health and Environment Air Pollution Control Division (APCD) This notice is valid for five (5) years. Submit a revised APEN prior to expiration of five-year term, or when a significant change is made (increase production, new equipment, change in fuel type, etc). Mail this form along with a check for S1.52.90 to: Colorado Department of Public Health & Environment APCD-SS-BI 4300 Cherry Creek Drive South Denver, CO 80246-1530 For guidance on how to complete this APEN form: Air Pollution Control Division: (303) 692-3150 Small Business Assistance Program (SBAP): (303) 692-3148 or (303) 692-3175 APEN forms: htm://www.cdphe.state.co.us/a,p/dowvnloadfomis.html Application status: httg://wsvw.cdphe.state.co.us/ap/ssisspcpt.html Check box to request copy of draft permit prior to issuance. El Check box to request copy of draft permit prior to public notice. 2016-10-31 FTL H-6052 APEN.doe AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit— General Permit Number: 12WE1492 Emission Source AIRS ID: 123 / 0057 / 060 Section 05 — Emission Release Information (Attach a separate sheet with relevant information in the event of multiple releases; provide datum & either LatiLong or UTM) Operator Stack ID No. Base Elevation (feet) Discharge Height Above Ground Level (Feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) Moisture (%) Horizontal Datum (NAD27, NAD83, WGS84) Zone (12 or 13) UTM Fasting or Longitude (meters or degiees) UTM Northing or Method of Collection for Location Latitude (meters or degrees) Data (e.g. map, GYS, GoogleEarth) H-6052 I II I 13 [ Direction of outlet (check one): ® Vortical ❑ Vertical with obstructing raincap Exhaust Opening Shape & Size (check one): ® Circular: Inner Diameter (inches) = Section 06 — Combustion Equipment & Fuel Consumption Information Company equipment Identification No.: H-6052 Manufacturer: Sigma Thermal ❑ Horizontal E Down ❑ Other: Length (inches) Model: II C 2 -50.0 -H-S F ❑ Other (Describe): Width (inches) = Serial No.: Fuel Type Design Input Rate (106 Btu/hr) Actual Level (For Data Year) Annual Requested Permitted Levee — (Specify Units) Fuel Heating Value (Indicate. Btu/lb, Btu/gal, Btu/SCF) Percent by Weight Seasonal Fuel Use (% of Annual Use) 1 Sulfur Ash Dec -Feb Mar -May Jun -Au: Se. -Nov Natural Gas 60 204 MMSCF/yr 726.7 MLMSCF/yr 1020 Btu/sef 25 25 25 25 (78% efficiency) 2Requested values \will become permit limitations Requested level should corsider process growth over the nest five years. Section 07 — Emissions Inventory Information & Emission Control Information Attach any emission calculations and emission factor documentation to this APEN form. Emission Factor Documentation attached Data year for actual calendar yr. emissions below & throughput above (e.g. 2007): Pollutant Control Device Description Overall Collection Efficiency Control Efficiency (% Reduction) Emission Factor Actual Calendar Year Emissions' Requested Permitted Emissions Estimation Method or Emission Factor Source Primary Secondary Uncontrolled Basis Units Uncontrolled Tons/Year ( ) Controlled (Tons/Year) Uncontrolled (Tons/Year) Controlled (Tons/Year) TSP Phfto 4.6 IbI MSCF 0.57 1.7 'resting PMae 4.6 Ib/MMSCF 0.57 1.7 Testing SOx 0.6 Ib/MMSCF 0 0.22 AP -42, Tb 1.4-2 NOx 0.04 lb/MMBtu 4.57 14.8 Manufacturer VOC 5.5 Ib/MMSCF 0.62 2.0 Al' -42 7b 1.4-2 CO 0.04 lb/MMBtu 4.57 14.8 Manufacturer Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. 2015 'Annual emission fees will be based on actual emissions reported here. If left blank, annual emission fees will be based on requested emissions. 'If Requested Permitted Emissions is left blank, the .APCD will calculate emissions based on the information supplied in sec ions OS - 07. Sectio/08 —Applicant rtification - I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. re of Person I, gaily Authorized to Supply Data (ft/ Dae 'Z s t (. Jillian Yamartino Name of Legally Authorized Person (Please print) Title Page 2 of 2 Sr IISE Representative 2016-10-31 TL 11-6052 APEN.doc AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — General Permit Number: 12WE1492 Facility Equipment ID: H-6053 Section 01 — Administrative Information Company Name: Kerr-McGee Gathering LLC Source Name: Lancaster Plant Source location: 16270 WCR 22 Portable Source Home Base: [Leave blank unless APCD has already assigned a permit ## & AIRS ID] Emission Source AIRS ID: 123 / 0057 / 061 [Provide Facility Equipment IT.) to identify how this equipment is referenced within your organization.] Fort Lupton, CO Mailing Address: P. O. Box 173779 Denver, CO 80217-3779 NAICS, or 1321 SIC Code: County: Weld Elevation: 5,030 Feet ZIP Code: 80217 Person To Contact: Milian Yamartino Phone Number: 720-929-4374 E-mail Address: Jillian.Yamartinod6Anadarko.com Fax Number: Section 03 — General Information For existing sources, operation began on: Normal Hours of Source Operation: General description of equipment and purpose: Section 02 — Requested Action (check applicable request boxes) ❑ Request for NEW permit or newly reported emission source ❑ Request PORTABLE source permit 0 Request MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ® Change permit limit ❑ Transfer of ownership ❑ Other ❑ Request to limit HAPs with a Federally enforceable limit on PTE ❑ Request APEN update only (check the box below that applies) ❑ Revision to actual calendar year emissions for emission inventory Additional Info. & Notes: Update 5 -Year APEN term without change to permit limits or previously reported emissions Emissions limits to reflect increase of 10%. 06 / 23 / 2015 For new or reconstructed sources, the projected startup date is: 24 hours/day 7 days/week 52 weeks/year 60 MMBtu/hr amine heat medium heater with low NOx burners to regenerate amine for IA. Assumed 78% efficiency. Will this equipment be operated in any NAAQS nonattainment area? (http://wwivv.cdnhe.state.co.usiapiattairunaintain.hunl) Section 04 — Processing/Manufacturing Equipment Information & Material Use Description of equipment': Manufacturer: Sigma Thermal Model No.: HC2-50.0-H-SF ® Yes El Serial No.: No El Don't know Description Actual Level (For Data Year) Annual Requested Permitted i,evel2 (Specify Units) Design Process Rate (Specify Units/Hour) Raw Materials: Finished Products: Other Process: 'Ifadd itional space is required, please attach a separate list of equipment, materials and throughputs. 'Requested tallies will become permit limitations Requested level should consider process growth over the next five years. {_FORM APCD-200 386047 Page 1 of 2 / / Colorado Department of Public Health and Environment Air Pollution Control Division (APCD) This notice is valid for five (5) years. Submit a revised APEN prior to expiration of five-year term, or when a significant change is made (increase production, new equipment, change in fuel type, etc). Mail this form along with a check for S152.90 to: Colorado Department of Public lIealth & Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-153(1 For guidance on how to complete this API -.N fhrn: Air Pollution Control Division: (303) 692-3150 Small Business Assistance Program (SBAP): (303) 692-3148 or (303) 692-3175 A.PEN forms: http://wvwv.edphe.state.co.us/apidownloadfornu.html Application status: http://www.cdphe_state.co.usiap/ss/sspcpt.html ® Cheek box to request copy of drab permit prior to issuance. E] Check box to request copy of draft permit prior to public notice. 2.016-10-31 FTL H-6053 APEN.doc AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — General Permit Number: 12WE1492 Emission Source AIRS ID: 123 / 0057 / 061 Section 05 — Emission Release Information (Attach a separate sheet with relevant information in the event of multiple releases; provide datum & either Lat/Long or UTM) Operator Stack ID No. Base Elevation (feet) Discharge Height Above Ground Level (Feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) Moisture CA) Horizontal Datum (TvAD27, NAD83, WGS84) UTM Zone (12 or 13) UTMEastine or UTM Northing or Longitude Latitude (meters or degrees) i (meters or degrees) Method of Collection for Location Data (e.g. map, GPS, GoogleEarth) H-6053 13 Direction of outlet (check one): ® Vertical ❑ Vertical with obstructing raineap Exhaust Opening Shape & Size (check one): ® Circular: Inner Diameter (inches) = Section 06 — Combustion Equipment & Fuel Consumption Information Company equipment Identification No.: H-6053 Manufacturer: Sigma Thermal ❑ Horizontal ❑ Down ❑ Other: Length (inches)_ Model: HC2-50.0-H-SF ❑ Other (Describe): Width (inches) = Serial No.: Fuel Typc Design Input Rate (106 Btu/hr) Actual Level (For Data Year) Annual Requested Permitted Level2 (Specify Units) Fuel Heating Value (Indicate: Btu/lb, Btu/gal, Btu/SCF) Percent by Weight Seasonal Fuel Use (% of Annual Use) Sulfur Ash Dec Feb Mar.May Jun -Aug Se -Nov Natural Gas 60 197 MMSCF/yr 726.7 NPMSCF/yr 1920 Btu/scf 25 25 25 25 (78% efficiency) `Requested values will become permit limitations. Requested level should consider process growth over the next five years Section 07 — Emissions Inventory Information & Emission Control Information Attach any emission calculations and emission factor documentation to this APEN form. el Emission Factor Documentation attached Data year for actual calendar yr. emissions below & throughput above (e.g. 2007): Pollutant Control Device Description Overall Collection Efficiency Control Efficiency (°10 Reduction) Emission Factor Actual Calendar Year Emissions Requested Permitted Emissions Estimation Method or Emission Factor Source Primary Secondary Uncontrolled Basis Units Uncontrolled (Tons/Year) Controlled (Tons/Year) Uncontrolled (Tons/Year) Controlled (Tons/Year) PM le) 4.6 4.6 Ib/N1MSCF Ib/MMSCF 0.54 1.7 Testing PM...? s 0.54 1.7 Testing SOx 0.6 lb/M1MSCF 0 0.22 AP -42, Tb 1.4-2 NON 0.04 Ib/MMIBtu 4.36 14.8 Manufacturer VOC 5.5 Ih/MMSCF 0.54 2.0 AP -42 II 1.4-2 CO _ 0.04 IbiMMBtu 4.57 14.8 Manufacturer Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to reportLrllutants not listed above. 2015 Annual emission fees will he based on actual emissions reported here. If left blank, annual emission fees will be based on requested emissions If Requested Permitted Emissions is left blank, the APCD \sill calculate emissions based on the information supplied in sections 03 - 07. Section 08 —Applicant Certification - I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. Sitature of Person legally Authorized to Supply Data Date i c Jillian Yamartino Name of Legally Authorized Person (Please print) Title Page 2of2 Sr. HSE Representative 2016-10-31 PFL 11-6053 APEN.doc General APEN - Form APCD-200 Air Pollutant Emission Notice (APEN) and Application for Construction Permit AUG-32018 All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. There may be a more specific APEN for your source (e.g. paint booths, mining operations, engines, etc.). A list of specialty APENs is available on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 12WE1492 AIRS ID Number: 123 / 0057 [Leave blank unless APCD has already assigned a permit # and AIRS ID] / 062 Section 1 - Administrative Information Company Name1: Kerr-McGee Gathering LLC Site Name: Lancaster Plant Site Location: 16270 WCR 22, Fort Lupton Mailing Address: (Include Zip Code) P. 0. Box 173779 Denver, CO 80217-3779 Portable Source Home Base: Site Location County: Weld NAICS or SIC Code: 1321 Permit Contact: Phone Number: E -Mail Address2: Jillian Yamartino 720-929.4374 j itlian. yamartino® anadarko. c om 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-2OO -General APEN - Revision 1/2017 3O0 4' �V COLORADO j Permit Number: 12WE1492 AIRS ID Number: 123 / 0057 / 062 [Leave blank unless APCD has already assigned a permit At and AIRS ID] Section 2 - Requested Action ❑ NEW permit OR newly-reported emission source(check one below) O STATIONARY source O PORTABLE source - OR- I ❑ MODIFICATION to existing permit(check each box below that applies) O Change fuel or equipment ❑ Change company name ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership; O Other(describe below) i - OR- i • APEN submittal for update only(Blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- ❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) ❑ APEN submittal for permit exempt/grandfathered source Additional Info a Notes: Annual APEN update 3 For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted. Section 3 - General Information 60 MMBtu/hr amine heat medium heater with low NOx General description of equipment and purpose: burners to regenerate amine. Assumed 78% efficiency Manufacturer: Sigma Thermal Model No.: HC2-50.0-H-SF Serial No.: Company equipment Identification No. (optional): H-6054 For existing sources, operation began on: 06/26/2015 For new or reconstructed sources, the projected start-up date is: ® Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day days/week weeks/year Seasonal use percentage: Dec-Feb: 25.00 Mar-May: 25.00 June-Aug: 25.00 Sept-Nov: 25.00 COLORADO Form APCD 200 General APEN Revision 1/2017 2 i AV H whFnv qR ._ Permit Number: 12WE1492 AIRS ID Number: 123 / 0057 / 062 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 4 - Processing/Manufacturing Information Ft Material Use ® Check box if this information is not applicable to source or process From what year is the actual annual amount? rr .,�Yp1 1 �� in Yiiku [ I;7-77 7 l J^Ya� ` G'F ( i 4 01594,krti iF1c 5? i aff c :P.', i )ve?y V'p'^ `r • 41,A(i;fili[ I - I I r C!k ,Jn( lcI Requested values will become permit limitations.Requested limit(s)should consider future process growth. Section 5 - Stack Information Geographical Coordinates (Latitude Longitude or UTM) 40.1427, -104.7476 ❑ Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case,the rest of this section may remain blank. i { I II a 1 I TT 1, ar - nn r A CI r k 6q Ir ,II ';`,0lfl1ta/ ll, 1 , ,.. I �k lr ,gA �nx I H-6054 Indicate the direction of the Stack outlet: (check one) ® Upward ❑ Downward ❑ Upward with obstructing raincap ❑ Horizontal ❑ Other(describe): Indicate the stack opening and size: (Check One) ❑ Circular Interior stack diameter(inches): ❑ Square/Rectangle Interior stack diameter(inches): Interior stack depth (inches): O Other(describe): COLORADO Form APCD-2OO-General APEN - Revision 1/2017 3 I ANY, Fv�Tt,Tnvrnnnw� Permit Number: 12WE1492 AIRS ID Number: 123 / 0057 / 062 [Leave blank unless APCD has already assigned a permit fi and AIRS ID] Section 6 - Fuel Data and Throughput Information ❑ Check box if this information is not applicable to the source (e.g.there is no fuel-burning equipment associated with this emission source) ls. ® ll�l p� , . a y y- y '' E - lt: tE3.�'r21 �'.. .rt� 60.00 407 7267.7 From what year is the actual annual fuel use data? 2016 Indicate the type of fuel useds: ❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf) ❑ Field Natural Gas Heating Value: BTU/scf ❑ Ultra Low Sulfur Diesel (assumed fuel heating value of 138,000 BTU/gallon) ❑ Propane (assumed fuel heating value of 2,300 BTU/scf) ❑ Coal Heating Value: BTU/lb Ash Content: Sulfur Content: ❑ Other(describe): Heating Value (give units): Requested values will become permit limitations,Requested limit(s)should consider future process growth. 5 If fuel heating value is different than the listed assumed value,provide this information in the"Other"field. Section 7- Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ® Yes O No If yes, describe the control equipment AND state the overall control efficiency(%reduction): 1-t t S.�,4l r Ii��Y • S P i�0.e ite Q TSP (PM) PMso PM2.5 SOX NOx Low NOx VOC i I CO Other: ACOLORADO Form APCD-200-General APEN - Revision 1/2017 4 I mA� �"> t I I Permit Number: 12WE1492 AIRS ID Number: 123 / 0057 / 062 [Leave blank unless APCD has already assigned a permit/t and AIRS ID] Section 7 (continued) From what year is the following reported actual annual emissions data? 2016 Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) I - �I i s dS-rt�ii 1 � '� 1 a a V l ItIhl,In41r l� Iii $.\711-1;,...j rlly. 1q 4 a-Uc we�q l f •in°��le'iFs�,�p9r laa} r'�1�8 x�af!'1 JI 1'. (ta st,a; st,;� i ,,- , �� II Illnt I,i�l,4rl iU� l (P.;i- 9 I gar,,,,,-,.. ) .F7,k I ,I 1 � di( (y{ / 1 € 1 t !, ,(fi,00-(l+l'fIn1 7rt�rn?,A ,gt,71., .r a d)T.is/ TSP (PM) PM10 PMZ,s 4.6 Ib/MMSCF Testing 1.10 1.70 sox , NOx 0.04 Ib/MMbtu Mfg. 9.00 14.80 CO 0.04 Ib/MMbtu Mfg. 9.00 14.80 VOC 5.5 lb/MMSCF AP-42 1.10 2.00 Other: Requested values will become permit Limitations. Requested limit(s)should consider future process growth. 6 Annual emission fees will be based on actual controlled emissions reported.If source has not yet started operating, leave blank. Section 8 - Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteria pollutants (e.g. HAP-hazardous air pollutant)emissions equal to or greater than ❑ Yes ❑ No 250 lbs/year? If yes, use the following table to report the non-criteria pollutant (HAP) emissions from source: a I ,,jY„,, rnul �1- i . {� Ifs 4, I :-‘1,-/_,-,,,,v, I enrt l-iia s O,l ti fin,..,,,,,,;-,,,,--.10,7171,7,1;'f'• ,; 1,4" `�n.i nt 1 li .{it Iwo `e Iri d . s'>3 A ; 1, , +v .1,e‘":4". ;4-,1., $'.!';�f li o ,+14@PNI iaii• 11=er 77} 5 I( �3 )� I ",„,„t.,,,,;4"-,'�. f}>a1 �,( A' a , a 7! I ,, �vyfa so 14 0 A -013E 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. COLORADO Form APCD-2OO-General APEN - Revision 1/2017 5 I�� H;;,,n„i"w,2;', Permit Number: 12WE1492 AIRS ID Number: 123 / 0057 / 062 [Leave blank unless APCD has already assigned a permit A' and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. 4/27/2017 Signatfire of Legally Authorized Person (not a vendor or consultant) Date Jillian Yamartino Sr. HSE Representative Name (print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notices is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 to: For more information or assistance call: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Small Business Assistance Program (303 692-3175 or (303) 692-3148 Or visit the APCD website at: Make Check payable to: https: //www.colorado.gov/cdphelapcd Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Form APCD-200 - General APEN - Revision 1/2017 e� COLORADO 6I tDI+a4HV[nv7=e'n. AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Amine Sweetening Unit' - Permit Number: 12WE1492 Facility Equipment ID: 1 A Section 01 — Administrative Information Company Name: Kerr-McGee Gathering LLC [Leave blank unless APCD has already assigned a permit ii & AIRS 1Dl Emission Source AIRS ID: 123 / 0057 / 063 [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] Section 02 — Requested Action (Check applicable request boxes) ❑ Request for NEW' permit or newly reported emission source ® Request MODIFICATION to existing permit (check each box below that applies) Weld ❑ Change process or equipment ❑ Change company name 5,030 Feet ® Change permit limit ❑ Transfer of ownership ❑ Other 80217 ❑ Request to limit Till's with a Federally enforceable limit on PTE ❑ Request APEN update only (check the box below that applies) Phone Number: 720-929-4374 ❑ Revision to actual calendar year emissions for emission inventory Source Name: Lancaster Plant Source Location: 16270 WCR 22, Fort Lupton Mailing Address: P.O. Box 173779 Denver, CO 80217-3779 Person To Contact: Jillian Yamartino E-mail Address: jillian.yamartino @anadarko.com Section 03 — General Information 1321 NAiCS, or SIC Code: County: Elevation: ZIP Code: Fax Number: For existing sources, operation began on: 05 28 r 2014 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year General description of equipment and purpose: Addl. Info. & Notes: Update 5 -Year APEN term without change to permit limits or previously reported emissions Update AIRS Point description, PTE and throughput. For new or reconstructed sources, the projected startup date is: / Amine system to remove CO2 and II2S from field gas, 60 MMBtu/hr regenerator heater, and TO for acid gas control ► Will this equipment he operated in any NAAQS nonattainment area? (ww.v.colorado.eov/cdphe/attainment) ► Does this facility have a design capacity less than 2 long tons/day of licS in the acid gas? Provide documentation. Section 04 — Amine Sweetening Unit Equipment Information Manufacturer: N/A Model: N/A Serial No.: 13-12519-2223 Rehoiler Rating: 60 MMBtu/hr Amine Type: ❑ MEA ❑ DEA Amine Pump Make & Model: Absorber Column Stages: 20 stages Goulds 3393 4x6x10 A • ❑ TLA ® MDEA ❑ DGA it of Pumps: 3 Sweet Gas Throughput: Design Capacity: 165 Inlet Gas: Rich Amine Feed: Pressure: 1012 psia Temperature: 148 Lean Amine Stream: Pressure: 1 162 psia Temperature: 116.8 MMSCF/day Requested`: 60,225 MMSCF/yr. Calendar year actual: 686.2 MMSCF/vr. Pressure: 1025 psig Temperature: 110 mt.%amine: 45 Mole loading 11.2S: 2.1E-6 Sour Gas Input: Pressure: 20 psia Temperature: 120 NGt, Input: Pressure: psia Temperature: Flash Tank: Pressure: 60 psia Temperature: 157 'You will be charged an additional APEN fee if APEN is filled out incorrectly or information is missing and requires re -submittal. 'Requested values will become permit limitations. ® Attach a process flow diagram ❑ Attach the simulation model inputs & emission report ® Attach composition reports for the rich amine feed, sour gas feed, NOL feed, & outlet stream (emissions) ❑ Attach the extended gas analysis (including BTEX & n -Hexane, H2S. CO.22.2.4 Trimethylpentanc) °F } Flowrate: °F Flowrate: Mole loading CO.: 690 gal/min 690 gal/min 0.0142 Additional Information Required: ❑ Yes ❑ No ❑ Don't know ® Yes No ❑ Don't know Colorado Department of Public Health and Environment Air Pollution Control Division (APCD) This notice is valid for five (5) years. Submit a revised APEN prior to expiration of five-year term, or when a significant change is made (increase production, new equipment, change in fuel type, etc). Mail this form along with a check for S152.90 to: Colorado Department of Public Health & Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 For guidance on how to complete this APEN form: Air Pollution Control Division: (303) 692-3150 Small Business Assistance Program (SOAP): (303) 692-3148 or (303) 692-3175 APEN forms: w< iv colorado gov/cdphe/oileaspennits Application status: www.colorado.gov/cdphe/permitstanus AFt(LAPCD-206 386049 Flowrate: 6.65 MMSCF/day `F Flowrate: gal/min °F n None Page I of 2 Form Revision Date: August 2008 Check box to request copy of draft permit prior to issuance. ® Check box to request copy of draft permit prior to public notice. 2016-10-28 LAN IA Permit Number: 12WE1492 Section 05 — Stack Information (Combustion stacks must be listed here) AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Amine Sweetening Unit' - Emission Source AIRS ID: 123 / 0057 / 063 Section 06 —Stack (Source, if no combustion) Location (Datum & either Lat/Long or UTM) Operator Stack ID No. Stack Base Elevation (feet) Stack Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) Moisture (%) IATO 5,030 40 1500 37,511 26 10 Horizontal Datum (NAD27, NAD83, WGS84) UTM Zone (12 or 13) UTM Easting or Longitude (meters or degrees) UTM Northing or Latitude (meters or degrees) Method of Collection for Location Data (e.g. map, GPS, GoogleEarth) -104.7481 40.1443 iMaps/Google Maps Direction of stack outlet (check one): ® Vertical ❑ Vertical with obstructing raincap Exhaust Opening Shape & Size (check one): ® Circular: Inner Diameter (inches) = 66 ❑ Horizontal ❑ Down ❑ Other: Length (inches) = Section 07 - Control Device Information (Indicate if a control device controls the flash tank and/or regenerator emissions ❑ Other (Describe): Width (inches) = • VRU used for control of: Size: 1/ Combustion Device used for control of: Still vent 26.6 MMBtuihr Make/Model: Type: Thermal oxidizer Make/Model/Serial 4: MRW Requested VOC & IIAP Annual time that VRU is Control Efficiency: % VOC & HAP Control Efficiency: Requested: 99 % Manufacturer Guaranteed: 99% bypassed (emissions vented): % Minimum temp. to achieve requested control: 1400 °F Waste gas heat content: 34.5 Btu/scf Constant pilot light? ►ZI Yes ■ No Pilot burner rating: 8 MMBtu/hr ►.1 Describe Any Other: Flash tank overhead returned to the process via low pressure system. Section 08 — Emissions Inventory Information & Emission Control Information El Emission Factor Documentation attached Data year for actual calendar yr. emissions helms & gas throughput above (e.g. 2007): N 2015 Pollutant Control Device Description Control Efficiency (% Reduction) Emission Factor Actual Calendar Year Emissions- Requested Permitted Emissions Estimation Method or Emission Factor Source Primary Secondary Uncontrolled Basis Units Uncontrolled (Tons/Year) Controlled (Tons/Year) Uncontrolled jTons/Year) Controlled (Tons/Year) _ VOC Identify in Section 07 138.6 Ib/MMscf 1.05 168.2 2.9 Material Balance + AP -42 NOx 0.10 lb/MMBtu 4.88 11.8 11.8 AP -42 CO 0.07 lb/MMBtu 4.10 8.6 8.6 AP -42 SO2 2.9 Ib/MMscf 0 3.6 3.6 Material Balance PM2.5 0.96 Ib/MMscf 0.37 1.2 1.2 Emission Testing H2S 0.04 Ib/MMscf 0 de minims Material Balance Benzene 2.06E-06 Ib/MMscf 0 de minims Material Balance Toluene 3.33E-06 Ib/111Msef 0 de minims Material Balance Xylene de minims Material Balance n -Hexane de minims Material Balance Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. `You will be charged an additional APEN fee if APEN is filled out incorrectly or information is missing and requires ie-submittal. 'Annual emission fees will be based n actual emissions reported here. If left blank, annual emission fees will be based on requested emissions. Secti4 09 —Applicant Ce ification - I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. ///t/2 iCv Sig4ture of Person I ally Authorized to Supply Data Date APEN.docx Jillian Yamartino Name of Legally Authorized Person (Please print) Title Sr ELSE Representative Page 2 of 2 Form Revision Date: August 2008 2016-10-28 LAN 1A AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Amine Sweetening Units - Permit Number: 12WE1492 Facility Equipment ID: 1B Section 01 — Administrative Information Company Name: Kerr-McGee Gathering LLC [Leave blank unless APCD has already assigned a permit ii & AIRS ID] Emission Source AIRS Ill: 123 / 0057 / 064 [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] Section 02 — Requested Action (Check applicable request boxes) ❑ Request for NEW permit or newly reported emission source Source Name: Lancaster Plant Source Location: 16270 WCR22, Fort Lupton Mailing Address: P.O. Box 173779 Denver, CO 80217-3779 NAICS, or SIC Code: 1321 County: Weld Elevation: 5,030 Feet ZIP Code: 80217 Person To Contact: Jillian Yamartino Phone Number: 720-929-4374 E-mail Address: jillian.yamartino@anadarko.com Fax Number: Section 03 — General Information For existing_ sources, operation began on: Normal Hours of Source Operation: General description of equipment and purpose: El Request MODIFICATION to existing permit (check each box below that applies) ❑ Change process or equipment ❑ Change company name Z Change permit limit ❑ Transfer of ownership ❑ Other ❑ Request to limit HAPs with a Federally enforceable limit on PTE ❑ Request ADEN update only (check the box below that applies) Addl. Info. & Notes: Revision to actual calendar year emissions for emission inventory Update 5 -Year APEN term without change to permit limits or previously reported emissions Update AIRS Point description, PTE and throughput. 05 I 28 2014 For new or reconstructed sources, the projected startup date is: 24 hours/day 7 days/week 52 weeksiyear Amine system to remove CO2 and H2S from field gas, 60 MMBtu/hr regenerator heater, and f0 for acid gas control ► Will this equipment be operated in any NAAQS nonattainment area? (www.colorado.eov/cdphe/attainmenj ► Does this facility have a design capacity less than 2 long tons/day ofH2S in the acid gas? Provide documentation. Section 04 — Amine Sweetening Unit Equipment Information Manufacturer: N/A Model: N/A Serial No.: Reboiler Rating: 60 MMBW/lir Absorber Column Stages: Amine Type: ❑ MEA ❑ DEA ❑ TEA Amine Pump Make & Model: Goulds 3393 4x6x10A ZI Yes ❑ No ❑ Don't know ® Yes ❑ No ❑ Don't know 20 stages MDEA ❑ DGA 4 of Pumps: 3 60,225 MMSCF/yr. Sweet Gas Throughput: Design Capacity: 165 Inlet Gas: Pressure: 1025 MMSCF/day Requested': Calendar year actual: psig Temperature: 110 'F 480 Mi4ISCF.!yr. Rich Amine Feed: Pressure: 1012 psia Temperature: 148 'F Flowrate: 690 gal/min Lean Amine Stream: Pressure: 1162 psia Temperature: 116.8 'F Flowrate: 690 gal/min 1st % amine 45 Mole loading lisR 2.1E-6-�- Mole loading CO_. 0.0142 Sour Gas Input: Pressure: 20 psia 'temperature: 120 'F Flowrate: 6.65 NGl, Input: Pressure: psia Temperature: "F Flowrate: Flash Tank: Pressure: 60 psia Temperature: 157 'F H ] None 'You will be charged an additional API1N fee if APEN is filled out incorrectly or information is missing and requires re -submittal. =Requested values will become permit limitations. MMSC F/day gal/min Additional Information Required: Colorado Department of Public Health and Environment Air Pollution Control Division (APCD) This notice is valid for five (5) years. Submit a revised APEN prior to expiration of five-year term, or when a significant change is made (increase production, new equipment, change in fuel type, etc). Mail this form along with a check for S152.90 to: Colorado Department of Public Health & Environment APCD-SS-BI 4300 Cherry Creek Drive South Denver, CO 80246-1530 For guidance on how to complete this APEN form: Air Pollution Control Division: (303) 692-3130 Small Basiness Assistance Program (SBAP): (303) 692-3148 or (303) 692-3175 APEN forms: www.colorado.gov/cdphe/oilgaspermits Application status: www.colorado.ctov/cddphe/perntitstatus ® Attach a process flow diagram ❑ Attach the simulation model inputs & emission report Z Attach composition reports for the rich amine feed, sour gas feed, NGL feed, & outlet stream (emissions) I ® Check box to request copy of draft permit prior to issuance. ❑ Attach the extended gas analysis (including BMX & n -Hexane, HzS, CO2,2,2.4 Truncthylpenttute) i ® Check box to request copy of draft permit prior to public notice. A ' M: APCD-206 386050 Page 1 of 2 2016-10-28 LAN 113 Form Revision Date: August 2008 AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Amine Sweetening tnitl - Permit Number: 12WE1492 Section 05 — Stack Information (Combustion stacks must be listed here) Emission Source AIRS ID: 123 / 0057 / 064 Section 06 —Stack (Source, if no combustion) Location (Datum & either Lar/Long or UTM) Operator Stack ID No. Stack Base Elevation (feet) Stack Discharge Height Above Ground Level (feet) Temp. CF) Flow Rate (ACFM) Velocity (ft/sec) Moisture (%) 1B TO 5,030 40 26 10 Horizontal Datum (NAD27, NAD83, WGS84) UTM Zone (12 or 13) UTM Easting or Longitude (meters or degrees) UTM Northing or Latitude (meters or degrees) Method of Collection for Location Data (e.g. map, GPS, GoogleEarth) -104.7481 40.1443 iMaps/Google Maps Direction of stack outlet (check one): ® Vertical ❑ Vertical with obstructing raincap Exhaust Opening Shape & Size (check one): ® Circular: Inner Diameter (inches) = 66 ❑ Horizontal ❑ Down ❑ Other: Length (inches) ❑ Other (Describe): Width (inches) _ ection v / — s..,ontro► uevtce snrormation ttnatcate ii a control aevice controls me rrasn cant( annior regenerator emissions) ■ VRU used for control of: O Combustion Device used for control of: Still vent 26.6 M.MBtu/hr 99% Size: Make/Model: Type: Thermal oxidizer Make/Model/Serial #: MRW Requested VOC & HAP Control Efficiency: % VOC & HAP Control Efficiency: Requested: 99 % Manufacturer Guaranteed: Annual time that VRU is bypassed (emissions vented): % Minimum temp. to achieve requested control: 1400 °F Waste gas heat content: 34.5 Btu/scf MMBtu/hr Constant pilot light? Yes • No Pilot burner rating: 8 ►./ Describe Any Other: Flash tank overhead returned to the process via low pressure system. Section 08 — Emissions Inventory Information & Emission Control Information ® Emission Factor Documentation attached Data year for actual calendar yr. emissions below & gas throughput above (e.g. 2007): 2015 Pollutant Control Device Description Control Efficiency (% Reduction) Emission Factor Actual Calendar Year Emissions' Requested Permitted Emissions' Estimation Method or Emission Factor Source Primary Secondary Uncontrolled Basis Units Uncontrolled (Tons/Year) Controlled (_Tons/Year) Uncontrolled (Tons/Year) Controlled (Tons/Year) VOC Identify in Section 07 138.6 lb/MMscf 0.046 168.2 2.9 Material Balance t AP -42 NOx 0.10 lb/IVIMBtu 4.15 11.8 11.8 AP -42 CO 0.07 lb/MMEtu 3.49 8.6 8.6 AP -42 SO2 2.9 Ib/MMscf 0 3.6 3.6 Material Balance PM25 0.96 lb/MIVIscf 0.32 1.2 1.2 Emission Testing H2S 0.04 Ib/MMscf 0 de minims Material Balance Benzene 2.061"-06 lh/MMscf 0 de minims Material Balance Toluene 3.33E-06 Ib/MMscf 0 de minims Material Balance Xylene de minims Material Balance n -Hexane de minims Material Balance Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to re ort ollutants not listed above. 'You will be charged an additional APEN fee if Al'EN is filled out incorrectly or information is missing and requires re -submittal. 2 Annual emission fees will be based on actual emissions reported here. If left blank, annual emission fees will be based on requested emissions. Sectiorh►09 —Applicant Certification - I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. ture of Person gaily Authorized to Supply Data D APEN.docx ( G Jillian Yamartino ate/ Sr HSE Representative Name of Legally Authorized Person (Please print) Title Page 2 of 2 Form Revision Date: August 2008 2016-10-28 LAN 1B AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Amine Sweetening Unit' - Permit Number: 12WE1492 Facility Equipment ID: 2A Section 01 — Administrative Information Company Name: Kerr-McGee Gathering LLC [Leave blank unless APCD has already assigned a permit # & AIRS ID] Emission Source AIRS ID: 123 / 0057 / 065 [Provide Facility Equipment 1D to identify how this equipment is referenced within your organization ] Section 02 — Requested Action (Check applicable request boxes) ❑ Request for NEW permit or newly reported emission source Source Name: Lancaster Plant Source Location: 16270 WCR 22, Fort Lupton Mailing Address: P.O. Box 173779 Denver, CO 80217-3779 NAICS, or SIC Code: 1321 ® Request MODIFICATION to existing permit (check each box below that applies) County: Weld ❑ Change process or equipment ❑ Change company name ❑ Change permit limit ❑ Transfer of ownership ❑ Other ❑ Request to limit IJAPs with a Federally enforceable limit on PTE ❑ Request APEN update only (check the box below that applies) ❑ Revision to actual calendar year emissions for emission inventory Elevation: 5,030 Feet ZIP Code: 80217 Person To Contact: Jillian Yamartino Phone Number: 720-929-3374 E-mail Address: jillian.yamartino:?canadarko.com Fax Number: Section 03 — General Information For existing sources. operation began on: Normal flours of Source Operation: General description of equipment and purpose: 06 23 2015 24 hours/day 7 days/week Addl. Info. & Notes: Update 5 -Year APEN term without change to permit limits or previously reported emissions Update AIRS Point description, PTE and throughput. For new or reconstructed sources, the projected startup date is: 52 weeks/year Amine system to remove CO2 and 1-128 from field gas, 60 MMBtu/hr regenerator heater, and TO for acid gas control ► Will this equipment be operated in any NAAQS nonattainment area? (www.colorado.gov/cdphe/attainment) ► Does this facility have a design capacity less than 2 long tons/day of112S in the acid gas? Provide documentation. Section 04 — Amine Sweetening Unit Equipment Information Manufacturer: N/A Reboiler Rating: 60 MMI3tu/hr Amine Type: Model: N/A Serial No.: ® Yes ❑ No ❑ Don't know Z Yes ❑ No ❑ Don't know Absorber Column Stages: 20 stages ❑ MEA ❑ DEA ❑ TEA ® Iv1DEA Amine Pump Make & Model: Goulds 3393 4x6x10A # of Pumps: Sweet Gas Throughput: Design Capacity 165 1LMSCFday Requested'-: 60,225 Inlet Gas: Rich Amine Feed: Lean Amine Stream: Sour Gas input: NGL Input: Flash Tank: Pressure: 60 psia Temperature: 157 `P ❑ None 'You will be charged an additional APEN fee if APEN is filled out incorrectly or information is missing and requires re -submittal. 'Requested values will become permit limitations. ❑ DGA 3 Calendar year actual: 277 M M S C F/yr. MMSCF/yr. Pressure: 1025 psig Temperature: 110 °F Pressure: 1012 psia Temperature: 148 `'F Flowrate: 690 galimin Pressure: 1162 psia Temperature: 116.8 °F Flowrate: 690 gal/min wt. % amine: 45 Pressure: 20 Pressure: psis psia Mole loading112S. 2.1E-6 Mole loading CO,: 0.0142 Temperature: 120 °P Flowrate: 6.65 Temperature: °1 Flowrate: IN/MS(71'7day galilmin Additional ❑ Attach the simulation model inputs & emission report Information ® Attach composition reports for the rich amine iced, sour gas feed, NGL feed; & outlet stream (emissions) Required: ❑ Attach the extended gas analysis (including BTFX & n -Hexane, ticS. CO2. 2.2,4 "l'rimethvlpentanc) ® Attach a process flow diagram AFt ? XAPCD-206 386051 Colorado Department of Public Health and Environment Air Pollution Control Division (APCD) 'this notice is valid for five (5) years. Submit a revised APEN prior to expiration of five-year term. or when a significant change is made (increase production, new equipment, change in Mel type. etc). Mail this form along with a cheek for S152.90 to: Colorado Department of Public Health & Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 For guidance on how to complete this APEN form: Air Pollution Control Division: (303) 692-3150 Small Business Assistance Program (SBAP): (303) 692-3143 or (303) 692-3175 APEN forms: www.colorado.eov%cdphe/oilgasoennits Application status: wwcw.colorado.gov'cdphe/permitstatus Check box to request copy of draft permit prior to issuance. Cheek box to request copy of draft permit prior to public notice. Page 1 of 2 2016-10-28 LAN 2A Form Revision Date: August 2003 AIR POLLUTANT EMISSION NOTICE (ADEN) & Application for Construction Permit — Amine Sweetening Units - Permit Number: 12WE1492 Emission Source AIRS ID: 123 / 0057 / 065 Section OS — Stack Information (Combustion stacks must be listed here) Section 06 —Stack (Source, if no combustion) Location (Datum & either Lat/Long or UTM) Operator Stack ID No. Stack Base Elevation (feet) Stack Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) Moisture (%) 2A TO 5,030 40 26 10 Horizontal Datum (NAD27, NAD83, WGS84) UTM Zone (12 or 13) UTM Easting or Longitude (meters or degrees) UTM Northing or Latitude (meters or degrees) Method of Collection for Location Data (e.g. map, GPS, GoogleEarth) -104.7481 40.443 iMaps/Google Maps Direction of stack outlet (check one): ® Vertical ❑ Vertical with obstructing raincap Exhaust Opening Shape & Size (check one): ® Circular: Inner Diameter (inches) = 66 ❑ Horizontal ❑ Down ❑ Other: Length (inches) ------ Section 07 — Control Device Information (Indicate if a control device controls the flash tank and/or regenerator emissions ❑ Other (Describe): Width (inches) _ ■ VRU used for control of: Size: 1 Combustion Device used for control of: Still vent 26.6 MMBtu/hr Make/Model: Type: Thermal oxidizer Make/Model/Serial #: MR NV Requested VOC & HAP Annual time that VRU is Control Efficiency: % VOC & HAP Control Efficiency: Requested: 99 % Manufacturer Guaranteed: 99% bypassed (emissions vented): % Minimum temp. to achieve requested control: 1400 °F Waste gas heat content: 34.5 Rtu/scf Constant pilot light? Yes ■ No Pilot burner rating: 8 MrBtu/hr ►.1 Describe Any Other: Flash tank overhead returned to the process via low pressure system. Section 08 — Emissions Inventory Information & Emission Control Information Emission Factor Documentation attached Data year for actual calendar yr. emissions below & gas throughput above (e.g. 2007): 2015 Pollutant Control Device Description Control Efficiency (% Reduction) Emission Factor Actual Calendar Year Emiss ons2 Requested Permitted Emissions' Estimation Method or Emission Factor Source Primary Secondary Uncontrolled Basis Units Uncontrolled (Tons/Year) Controlled _I:Tons/Year) Uncontrolled (Tons/Year) Controlled (Tons/Year) VOC Identify in Section 07 138.6 lb/MMscf 0.046 168.2 2.9 Material Balance + AP -42 NOx 0.10 Ib/MMBtu 3.0 11.8 11.8 AP -42 CO 0.07 Ib/MMBtu 2.52 8.6 8.6 AP -42 SO2 2.9 lb/MMscf 0 3.6 3.6 Material Balance PM2.s 0.96 lb/MMscf 0.23 1.2 1.2 Emission Testing H2S 0.04 lb/MMscf 0 de minims Material Balance Benzene 2.06E-06 lb/INIMscf 0 de minims Material Balance Toluene 3.33E-06 lb/h'IMscf 0 de minims Material Balance Xylene de minims Material Balance n -Hexane de minims Material Balance Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to relnort pollutants not listed above. 'You will be charged an additional APEN fee if APEN is tilled out incorrectly or information is missing and requires re -submittal. `Annual emission fees will be based on actual emissions reported here. If Iett blank, annual emission fees will be based on requested emissions. Section 09 —Applicant Certification - I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. tl / f/7. t JillianYamartino S g atu e of PersgsyLegally Authorized to Supply Data Date APEN.docx Name of Legally Authorized Person (Please print) Page 2 of 2 Form Revision Date: August 2008 Sr HSE Representative Title 2016-10-28 LAN 2A AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Amine Sweetening Unit' - Permit Number: 12WE1492 [Leave blank unless APCD has already assigned a permit # & MRS ID] Emission Source AIRS ID: 123 / 0057 / 066 Facility Equipment ID: 28 Section 01 — Administrative Information Company Name: Source Name: Source Location: Kerr-McGee Gathering LLC [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] Section 02 — Requested Action (Check applicable request boxes) ❑ Request for NEW permit or newly reported emission source ® Request MODIFICATION to existing permit (check each box below that applies) County: Weld ❑ Change process or equipment ❑ Change company name Elevation: 5,030 Feet ® Change permit limit ❑ Transfer of ownership ZIP Code: 80217 ❑ Request to limit IIAPs with a Federally enforceable limit on PTE ❑ Request APEN update only (check the box below that applies) ❑ Revision to actual calendar year emissions for emission inventory Lancaster Plant 16270 WCR 22, Fort Lupton Mailing Address: P.O. Box 173779 Denver, CO 80217-3779 NAICS, or SIC Code: 1321 Person To Contact: Jillian Yamartino Phone Number: 720-929-4374 E-mail Address: jillian.vamartino,a anadarko.com Fax Number: Section 03 — General Information For existing sources, operation began on: Normal Hours of Source Operation: General description of equipment and purpose: Addl. Info. & Notes: ❑ Other Update 5 -Year APEN term without change to permit limits or previously reported emissions Update AIRS Point description, PTE and throughput. / For new or reconstructed sources, the projected startup date is: 24 hours/day 7 days/week 52 weeks/year Amine system to remove CO2 and 112S from field gas, 60 MMBtuihr regenerator heater, and TO for acid gas control / / ► Will this equipment be operated in any NAAQS nonattainment area? (www.colorado.eov/edphe/attainment) ► Does this facility have a design capacity less than 2 long tons/day of HzS in the acid gas? Provide documentation. Section 04 — Amine Sweetening Unit Equipment Information Manufacturer: N/A Model: N/A Serial No.: Reboiler Rating: 60 MMBtuihr Amine Type: ❑ MEA El DEA Amine Pump Make & Model: Goulds 3393 4x6x10A Sweet Gas Throughput: Design Capacity: 165 MMSCF/day Requested': 60,225 MMSCF/yr, Calendar year actual: 0 MIb1SCF/yr. Inlet Gas: Pressure: 1025 Temperature: 110 °F AIL Yes ❑ No ❑ Don't know Yes ❑ No ❑ Don't know Absorber Column Stages: 20 stages ❑ TEA ® MDEA ❑ DGA # of Pumps: 3 Rich Amine Feed: Pressure: 1012 Lean Amine Stream: Pressure: 1162 Sour Gas Input: NGL Input: Flash Tank: wt. % amine: 45 Pressure: 20 Pressure: psig psia psia Temperature: 148 'I'emperautre: 116,8 °F OF Mole loading 1121: 2.1E-6 Mole loading CO, 0.0142 psia Temperature: 120 °F Flowrate: 6.65 M,MSCF/day psia Temperature: °F Flowrate: gal/min Flowrate: 690_ _ gal/min Flowrate: 690 gal./min Pressure: 60 psia Temperature: _157_ °I' ❑ None 'You will be charged an additional .APEN fee if APEN is filled out incorrectly or information is missing and requires re -submittal. `Requested values will become permit limitations. Additional Information Required: ® Attach a process flow diagram ❑ Attach the simulation model inputs & emission report ® Attach composition reports for the rich amine feed, sour gas feed. NGL feed. & outlet stream (emissions) ❑ Attach the extended gas analysis (including BMX & n -Hexane, 112S, CO2, 2.2.4 Trimethylpentane) Colorado Department of Public Health and Environment Air Pollution Control Division (APCD) This notice is valid for five (5) years. Submit a revised APEN prior to expiration of five-year term, or when a significant change is made (increase production, new equipment change in fuel type. etc). Mail this form along with a check for S152.90 to: Colorado Department of Public Health & Environment APCD-SS-ftl 4300 Cherry Creek Drive South Denver, CO 80246-1530 For guidance on how to complete this APL/ form: Air Pollution Control Division: (303) 692-3150 Small Business Assistance Program (SOAP): (303) 692-3148 or (303) 692-3175 APEN forms: wsvw.Colorado.govrcdpheroilgaspermits Application status: www.colorado.gov/cdpheiperrnitstatais AF INIxAPCD-206 386052 ® Check box to request copy of draft permit prior to issuance. ® Check box to request copy of draft permit prior to public notice. Page 1 of 2 2016-10-2% LAN 2B Form Revision Date: August 2001 AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Amine Sweetening Unit' - Permit Number: 12WE1492 Section 05 — Stack Information (Combustion stacks must be listed here) Emission Source AIRS ID: 123 / 0057 / 066 Section 06 —Stack (Source, if no combustion) Location (Datum & either Lat/Long or UTM) Operator Stack ID No. Stack Base Elevation (feet) Stack Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) Moisture (%) 2B TO 5,030 40 26 10 Horizontal Datum (NAD27, NAD83, WGS84) UTM Zone (12 or 13) UTM Easting or Longitude (meters or degrees) UTM Northing or Latitude (meters or degrees) Method of Collection for Location Data (e.g. map, GPS, GoogleEarth) -104.7481 40.1443 i11-faps/Google Maps Direction of stack outlet (check one): ® Vertical ❑ Vertical with obstructing raincap Exhaust Opening Shape & Size (check one): ® Circular: Inner Diameter (inches) = 66 ❑ Horizontal ❑ Down O Other: Length (inches) _ Section 07 — Control Device Information (Indicate if a control device controls the flash tank and/or regenerator emissions ❑ Other (Describe): Width (inches) = ■ VRU used for control of: Size: /1 Combustion Device used for control of: Still vent 26.6 MMBtu/hr Make Model: Type: Thermal oxidizer Make/Model/Serial #: MRW Requested V0C & HAP Annual time that VRU is Control Efficiency: % VOC & HAP Control Efficiency: Requested: 99 % Manufacturer Guaranteed: 99% bypassed (emissions vented): % Minimum temp. to achieve requested control: 1400 °F Waste gas heat content: 34.5 Btu/scf Constant pilot light? /1 Yes ■ No Pilot burner rating: 8 MMBtu/hr ''4 Describe Any Other: Flash tank overhead returned to the process via low pressure system. Section 08 —Emissions Inventory Information & Emission Control Information El Emission Factor Documentation attached Data year for actual calendar yr. emissions below & gas throughput above (e.g. 2007): 2015 Pollutant Control Device Description Control Efficiency (% Reduction) Emission Factor Actual Calendar Year Emissions- Requested Pernutted Emissions 3 Estimation Method or Emission Factor Source Primary Secondary Uncontrolled Basis Units Uncontrolled (Tons/Year) Controlled (Tons/Year) Uncontrolled (Tons/Year) Controlled (Tons/Year) VOC Identify in Section 07 138.6 lb/MMscf 0 168.2 2.9 Material Balance + AP -42 NOx 0.10 Ib/MMBtu 0 11.8 11.8 AP -42 CO 0.07 lb/MMBtu 0 8.6 8.6 AP -42 SO2 2.9 Ib/Mtelscf 0 3.6 3.6 Material Balance PM2.s 0.96 Ib/MMscf 0 1.2 1.2 Emission Testing H≥S 0.04 Ib/MtMscf 0 de minims Material Balance Benzene 2.06E-06 Ib/MMscf 0 de minims Material Balance Toluene 3.33E-06 Ib/MN[scf 0 de minims Material Balance Xylene de minims Material Balance n -Hexane de minims Material Balance Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. 'You kill be charged an additional APEN fee if APEN is filled out incorrectly or information is missing and requires re -submittal. Annual emission fees will be based on actual emissions reported here. If left blank, annual emission fees will be based on requested emissions. Section t 9 —Applicant Certification - I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. II 1/Z-..) Sigtfatffre of Person Leahy Authorized to Supply Data Date APEN.docx Jillian Yamartino Name of Legally Authorized Person (Please print) Title Sr HSE Representative Page 2 of 2 Form Revision Date: August 2008 2016-10-28 LAN 2B AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Fugitive Component Leak Emissions' Permit Number: 12WE1492 Facility Equipment ID. P003 Section 01 —Administrative Information Company Name: Kerr-McGee Gathering LLC [leave blank unless APCD has already assigned a permit N & AIRS ID) Emission Source AIRS ID: 123 / 0057 / 067 [Provide Facility Equipment 11) to identify how this equipment is referenced within your organisation I Section 02 — Requested Action (Check applicable request boxes) O Request for NEW permit or newly reported emission source 1321 ❑J Request MODIFICATION to existing permit (check each box below that applies) County: Weld ❑ Change process or equipment ❑ Change company name Elevation: 5,030 Feet 0 Change permit limit ❑ Transfer of ownership 0 Other LIP Code: 80217 ❑ Request to limit IIAPs with a Federally enforceable limit on PTE ❑ APEN Submittal for update only (Please note blank APENs will not be accepted) Source Name: Lancaster Plant Source Location: 16270 WCR 22 Fort Lupton, CO Mailing Address: P. O. Box 173779 Denver, CO 80217-3779 NAICS, or SIC Code: Person To Contact: Natalie Reeber Phone Number: 720-929-6498 E-mail Address: Natalie.Reeber@Anadarko.com Fax Number: 720-929-7498 Section 03 — General Information For existing sources. operation began on: 4 18 / 2014 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Facility Type: O Well Production ❑ Natural Gas 0 Natural Gas Processing Plant Facility Compressor Station Will this equipment he operated in any NAAQS nonattainment area?. (btsr i'wavw.colorado.eov'ednhe'state-imnlemcntatiun-plans-sins) Section 04 — Regulatory Information Is this equipment subject to Regulation?, Section XVII.F? Is this equipment subject to NSPS 4(.1 CFR Part 60, subpart KKK? Is this equipment subject to NSPS 40 CFR Part 60, subpart 0000? Is this equipment subject to NESHAP 40 CFR Part 63, Subpart HIE? Section 05 — Stream Constituents Identify the VOC & HAP weight % content of each applicable stream. Stream VOC (wt. %) Benzene (wt %) . Toluene (yt. %) Ethylbeuzene (wt. %) Xylene (wt. %) n -Hexane (wt %) Gas 22,100 0.12, 0 0.15, 0 0-01, 0 0.05, 0 0.5, 0 Heavy Oil (or Heavy Liquid) 100 0 0 0 0 0 Light Oil (or Light Liquid) 99 2 5-5 0.4 4 9 Water/Oil 100 0 0 0 0 0 O 0 0 0 0 Yes Yes Yes Yes Yes O O No O No ❑ No O No No O O Modify'2WE?492 to separate plant fugitives for Lancaster Trains I and 2 into Additional separate AIRS Points. and to Increase `ugitive VCC emissions based on actual as- 1°fn. & butt Train 1 component counts. Notes: For new or reconstructed sources, the projected startup date is / 0 Other (Describe) ❑ Don't know Don't know Don't know Don't know Don't know O Submit a representative gas and liquid extended analysis (including BTEY) to support data above FORM APCD-203 I Page Iof2 Lancaster Train 1 fugitive emissions Colorado Department of Public Health and Environment Air Pollution Control Division (APC:D) This notice: is valid for live (5) years. Submit a revised APEN prior to expiration of live -year tern', or when a significant change is made (increase production, new equipment, change in fuel type, etch. Mail this form along with a cheek for 5192.90 for Colorado Department of Public. Health & Environment APCD-SS-RI 4300 Cherry Creek Drive South Denver, CO 80246-15311 For guidance on how to complete this APEN form, Air Pollution Control Division: (303) 692-3150 Small Business Assistance Program (SNAP): (303) 692-3148 or (303) 692-3175 APEN forms' heir://wwvv.coloradogey/cdphc/APENfortns Application status: http:/,/www.colorado.eov/edphe/permitstatus 0 Check box to request copy of draft permit prior to public notice or issuance. FormAPCD--20 3-Fugeti veC'omponentl.raksAPEN-Ver. II -13-2014 386053 AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Fugitive Component Leak Emissions) Permit Number: 12WE1492 Emission Source AIRS ID: 123 / 0057 / 067 Section 06 — Location Information (Provide Datum and either Lat/Long or UTM) Section 07 —Leak Detection & Repair (LDAR) Sr Control Information Florizontal Datum (NAD27, NAD83, UTM Zone UTM Fasting or Longitude UTM Northing or Latitude Method of Collection for Location Data (e.g. map, GPS. WGS84) (12 or 13) (meters or degrees) (meters or degrees) GoogleEarth) WGS84 13 -104.75252 40.75252 Google Earth Check appropriate boxes to identify LDAR program conducted at this site: LDAR per NSPS KKK / OOOO O LDAR Per Reg. 7, Section XVIT.F O No LDAR program ❑✓ Other: TCEQ control factors If LDAR per NSPS KKK / OOOO: O Monthly monitoring. Control 88% gas valve. 76% It hq. valve, 68% Itliq. pump ❑ Quarterly monitoring. Control. 70% gas valve61% It liq. valve, 45% It liq. pomp Section 08 — Emission Factor Information Identify the emission factor used to estimate emissions under "E.b along with the units relating to the emission factor (e. g lb/hr/component) Table 2.4' was used to estimate emissions. ❑ Table 2-8a (010,000 ppm) was used to estimate emissions. 'Tab! ea 2-4 and 2-8 arc found in U.S. EPA' Equipment Type Service Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil Count' E.F. Units Count' E.F. Units Count' E.F. Units Count' E.F. Units Connectors 8959 2635 2449 Flanges 1197 314 574 Open -Ended Lines Pump Seals 11 11 Valves 1534 312 850 Others 54 6 16 and to calculate the "Actual Calendar year E•.masions" he nw. 'The 'Other" equipment type should be applied for any equipment type other than connectors, flanges, open -coded lines, pumps, or valves. Section 09 —Emissions Inventory Information & Emission Control Information Emission Factor Documentation attached Estimated Count Data year for actual calendar year emissions blow (e.g. 2007): Actual Count conducted on the following dare: 91.2010 Pollutant Control Device Description Control Efficiency (% Reduction) Emission Factor Actual Calendar Year Emissions° Requested Permitted Emissions' Estimation Method or Emission Factor Source Primary I Secondary Uncontrolled Basis I Units Uncontrolled Slons/Year) Controlled (Tons/Year) Uncontrolled (Tons/Year) Controlled (Tons/Year) VOC - - Identify in Section 07 - - Identify in Section 08 112.9 23.8 EPA453/R-95-017 Benzene 0.7 0.1 Tables 2-4 Toluene 1.8 0.4 + 10% Variance fthylbenrene below de minimis w/ TCEQ Controls Xylene 1.3 0.3 n -Hexane 3.0 0.6 Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Yau may en charged an addmanal ADEN ftt if APEN is filled out mcome<ny or missing mformanon and requires re -submittal. 'Annual emission fees will be based on actual emissions reported here. S You may request permitted emissions in excess of actual emissions to account for component count and gas composition variability. Section Ap ' ant C cation - I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. / / 12/08/2014 Natalie E. Reeber Sr. HSE Representative Sign a of Person Legally Authorized to Supply Data Date FORM APCD-203 Name of Legally Authorized Person (Please print) Title Page 2 of 2 FormAPCD-203-FugitiveComponentLeaksAPEN- Ver.1 1- I3--2014 Permit Number: 12WE1492 Facility Equipment ID: F504 AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Fugitive Component Leak Emissions' [Leave blank unless APCD has already assigned a permit # & AIRS ID] Emission Source AIRS ID: Provide Facility Equipment ID to identity how this equipment is referenced within veer evzamraiii,n.l Section 01 — Administrative Information Company Name: Kerr-McGee Gathering LLC Source Name: Lancaster Plant Source Location: 16270 WCR 22 Fort Lupton, CO Mailing Address: P. 0. Box 173779 Denver, CO 80217-3779 NAILS, or SIC Code: 1321 County: Weld Elevation: 5,030 Feet ZIP Code: 80217 Person To Contact: Natalie Reeber Phone Number: 720-929-6498 E-mail Address Natalie.Reeber@Anadarko.com Fax Number: 720-929-7498 Section 03 — General Information For existing sourcm. operation began on: Normal Flours of Source Operation: Facility Type: 24 hoursiday Well Production ❑ Natural Gas Facility Compressor Station Will this equipment be operated in any NAAQS nonattninment area? (http/www colorado,eov'cduhe!stale-imnlementation-plans-sips) Section 04 — Regulatory Information Is this equipment subject to Regulation 7, Section XVI1.F? Is this equipment subject to NSI'S 40 CFR Part 60. subpart KKK? Is this equipment subject to NSPS 40 CFR Part 60, subpart 0000? Is this equipment subject to NESHAP 40 CFR Part 61, Subpart 1110 Section 05 — Stream Constituents Identify the VOC & HAP weight %content of each applicable stream. Stream VOC (wt. %) Benzene (wt. %) Toluene (wt. %) Ethylbenzene (wt. %) Xylene (wt. %) n -Hexane (wt, %) Gas 22,100 0.12, 0 0.15, 0 0.01, 0 0.05, 0 0.5, 0 Heave Oil (or Heavy Liquid) 100 0 0 0 0 0 Light Oil (or Light Liquid) 99 2 5.5 0.4 4 9 Water/Oil 100 0 0 0 0 0 7 daysweek 52 123 / 0057 I 071 Section 02 — Requested Action (Check applicable request boxes) ❑ Request for NEW permit or newly reported emission source ❑J Request MODIFICATION to existing permit (check each box below that applies) ❑ Change process or equipment ❑ Change company name ❑ Change permit limit ❑ Transfer ofownership Q Other ❑ Request to limit HAPs with a Federally enforceable limit on PTE ❑ APEN Submittal for update only (Please note blank APENs will not be accepted) weeks/year Modify 12WE1492 to separate plant fugitives for Lancaster Trains 1 and 2 into Additional separate AIRS Points, and to add fugitive VOC emissions for Train 2 based on actual Info. & as -built Train 1 component counts. Notes: For new or reconstructed sources. the projected startup date is. / Q Natural Gas Processing Plant Q Other (Describe) ❑ Yes ❑ No ❑ Yes El Yes © Yes 0 Yes • No ❑ No ❑ No ❑ No ❑ Don't know Don't know Don't know Don't know Don't know Submit a representative gas and liquid extended analysis including ESTE X) to support data above FORM APCD-203 Page 1 oft Lancaster Train 2 fugitive emissions Colorado Department of Public Health and Environment Air Pollution Control Division (APCD) This notice is valid for five (5) years. Submit a revised APEN prior to expiration of five-year terns, or when a significant change is made (increase production, new equipment. change in fuel type, etc). Mail this form along with a check for Sl52.90 to: Colorado Department of Public Health & Environment APCD-SS-RI 4300 Cherry ('reek Drive South Denver, CO 80246-1530 For guidance on how to complete this .APEN form: Air Pollution Control Division: (303)692-3110 Small Business Assistance Program (SNAP): (303) 692-3149 or (303) 692-3175 APEN forms: hop:': vssw.colorada.eov:cdplrc/API Nfonns Application status: http:!,ruxma.colorade.r ovicdphcipermitstatus Q Check box to request copy of draft permit prior to public notice or issuance. FormAI'CD-203-fugitivefbmponentt eaksAPtiN-Ver. II -B-2014 386054 AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit— Fugitive Component Leak Emissions) Permit Number: 12WE1492 Emission Source AIRS ID: 123 / 0057 / 071 Section 06— Location Information (Provide Datum and either Lat/Long or UTM) Section 07 —Leak Detection & Repair (LDAR) & Control Information Horizontal Datum (NAD27, NAD83, UTM Zone UTM Fasting or Longitude UTM Northing or Latitude Method of Collection for Location Data (e.g. map, GPS, WGS84) (12 or 13) (meters or degrees) (meters or degrees) GoogleEarth) WGS84 13 -104.75252 40.75252 Google Earth Check appropriate boxes to identify LDAR program conducted at this site: El LDAR per NSPS KKK ! 0000 O IDAR Per Reg. 7, Section XV ILF O No LDAR program 0 Other: TCEQ control factors If LDAR per NSPS KKK; 0000: ❑ Monthly monitoring. Control 88% gas valve, 76% It liq valve, 68% It. liq. pump ❑ Quarterly monitoring Control 70% gas valve, 61% It bq. valve, 45% It lot pump Section 08 — Emission Factor Information Identify the emission fctor used to estimate emissions under "E.F.", along with the units relating to the emission factor (e.g. 111/hr/component). Q Table 2-4" was used to estimate emissions. ❑ Table 2-8` (<I0,000 ppm) was used to estimate emissions. •Tables 2A and 2-8 are found in U S EPA's 1995 Protocol it.. ut t L ak E E . Equipment Type • q rpmert a tmssron strmrurs Service Gas Heavy Oil (or Heavy Liquid) Light Oil (or Ljght Liquid) Water/Oil. Count2 E.F. Units Count' E.F. Units Count' E.F. Units Count' E.F. Units Connectors 8959 2635 2449 Flanges 1197 314 574 Open -Ended Lines Pump Seals 11 11 Valves 1534 312 850 Other' 54 6 16 'The "Other" equipment type should be applied for any equipment type other than connectors, flanges, open-ended lines, pumps, or valves Section 09 — Emissions Inventory Information & Emission Control Information Estimated Count Emission Factor Documentation attached Data year for actual calendar veer emissions bNow (e g 2007)• Aerial Cow[ conducted on the following date: 9/2ata Pollutant Camtrol Device Description Control Efficiency (04 Reduction) Emission Factor Actual Calendar Year Emissions° Requested Permitted Emissions Estimation Method or Emission Factor Source Primary Secondary Uncontrolled Basis I Units Uncontrolled (Tons/Year) Controlled (Tons/Year) Uncontrolled (Tons/Year) Controlled (Tons/Year) VOC - .Identify In.Section 07 . _ - - _ Identify in Section 08 _ 112.9 23.8 EPA 453/R-95-017 Benzene 0.7 0.7 Table 2-4 Toluene 1.8 0.4 + 10% Variance Ethylbenzenc below de minimis WI TCEO Controls Xylene 1.3 0.3 n-llexane 3.0 0.6 Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. 'Annual emission fees will be bused on actual emissions reported here. ' You may request permitted emissions in excess of actual emissions to account for component count and gas composition variability Sectiou40 —An lip cant Certification - I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. 12/08/2014 Natalie E. Reeber Sr. HSE Representative Siature of Person Legally Authorized to Supply Data Date Name of Legally Authorized Person (Please print) Title FORM APCD-203 Page 2 of 2 ForrnAPCD-203-Fugi tiveC omponentt.caks.SPEN- Ver. 11-13-2014 General APEN - Form APCD-200 Air Pollutant Emission Notice (APEN) and Application for Construction Permit 414 ,41/8 All sections of this APEN and application must be completed for both new and existing facilities, including APEN /)i updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. There may be a more specific APEN for your source (e.g. paint booths, mining operations, engines, etc.). A list of specialty APENs is available on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 12WE1492 AIRS ID Number: 123 /0057 / 068 [Leave blank unless APCD has already assigned a permit ft and AIRS ID] Section 1 - Administrative Information Company Name': Kerr-McGee Gathering LLC Site Name: Lancaster Plant Site Location: 16270 WCR 22 Fort Lupton, CO Mailing Address: (Include Zip Code) PO Box 173779 Portable Source Home Base: Denver, CO 80217-3779 Site Location County: Weld NAICS or SIC Code: 1321 Permit Contact: Jillian Yamartino Phone Number: (720)929-4374 E -Mail Address2: jillian.yamartino@anadarko.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-200 - General APEN - Revision 10/2016 386055 ®® ,COLORADO Permit Number: 12WE1492 AIRS ID Number: 123 / 0057 /068 [Leave blank unless APCD has already assigned a permit #/ and AIRS ID] Section 2- Requested Action ❑ NEW permit OR newly -reported emission source (check one below) ❑ STATIONARY source ❑ PORTABLE source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership' ❑ Other (describe below) -OR- APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑i Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) ❑ APEN submittal for permit exempt/grandfathered source Additional Info & Notes: APEN update to show uncontrolled VOC emissions and uncontrolled and controlled HAP emissions. 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Air -Assisted process flare with pilot rating of 0.5 MMBtulhr, purge gas rating of 0.72 MMBtu/hr and process gas rating of 10.9 MMBtu/hr. Manufacturer: Model No.: Serial No.: Company equipment Identification No. (optional): For existing sources, operation began on: F-2 04/30/2014 For new or reconstructed sources, the projected start-up date is: El Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Seasonal use percentage: Dec -Feb: 25 Mar -May: 25 Form APCD-20O - General APEN - Revision 10/2016 days/week weeks/year June -Aug: 25 Sept -Nov: 25 2 I®�y1 COLOR4D0 AIRS ID Number: 123 /0057 /068 Permit Number: 12WE1492 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 4- Processing/Manufacturing Information €t Material Use ✓ Check box if this information is not applicable to source or process From what year is the actual annual amount? Design Process Actual Annual Requested Annual Description Rate Amount Permit Limit4 {Specify Units) (Specify Units) (Specify Units) Material . • Consumption: Finished, Product(s): 4 Requested values wilt become permit limitations. Requested timit(s)should consider future process growth. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) ❑Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. r t eigfi,'t 4P � s i r4 F O ra or x i�+,�+ �n e { � �. ik tow itat Velg-t Gr' Lac+a s r� y p roc c "i� i t} } y" .w�(� ��5"' "e'�1 .,�� .7+��i,�l�F'M�k3iF v'"�^` .�i ft13�� t�°•+�r,'�_ ;its $" U( et gJ *y +,� + .ty, t Gva�Ada j 'S, c�a �t +'R,yy�w-�•�.'`b+'."�. � � i� f1, "1s2 �'4'J""AY� r•4 '� �i.k�'.'ti;:�• � *s rw�••e.F :.�. IVY:'4,t,.� ..w .v'�t�+rr:',t:..:a,�.,, fi•z�.2 Y F-2 1000 17,671 60 Indicate the direction of the stack outlet: (check one) ✓❑ Upward ❑Downward ❑ Upward with obstructing raincap ❑ Horizontal O Other(describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter(inches): 30 ❑Square/rectangle Interior stack width (inches): Interior stack depth(inches): ❑ Other(describe): - pp COLORADO Form APCD-200-General APEN - Revision 10/2016 3 I m� „:N r�"gym Permit Number: 12WE1492 AIRS ID Number: 123 /0057 /068 [Leave blank unless APCD has already assigned a permit/r and AIRS ID] Section 6- Combustion Equipment £t Fuel Consumption Information ❑Check box if this information is not applicable to the source(e.g. there is no fuel-burning equipment associated with this emission source) Design Input Rate Actual Annual Fuel Use Requested Annual Permit Limit4 (MMBTU/hr) (Specify Units) (Specify Units) 12.12 (Fuel and Process Gas) 56.6 (Fuel and Process Gas) 85.4 MMscf/yr(Fuel and Process Gas) From what year is the actual annual fuel use data? 2015 Indicate the type of fuel used': 0 Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/SCF) ❑ Field Natural Gas Heating value: 1020 BTU/SCF ❑Ultra Low Sulfur Diesel (assumed fuel heating value of 138,000 BTU/gallon) ❑Propane (assumed fuel heating value of 2,300 BTU/SCF) ❑Coal Heating value: BTU/lb Ash Content: Sulfur Content: O Other(describe): Heating value(give units): a Requested values will become permit limitations. Requested limit(s)should consider future process growth. s If fuel heating value is different than the listed assumed value,provide this information in the"Other"field. Section 7- Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑No If yes, describe the control equipment AND state the overall control efficiency(%reduction): Overall Control Efficiency Pollutant Control Equipment Description (%reduction in emissions) TSP (PM) PMio PM2.5 SOS NO„ CO VOC Process Flare 98% Other: .COI ORA DO Form APCD-200-General APEN -Revision 10/2016 4 I �� Permit Number: 12WE1492 AIRS ID Number: 123 /0057 /068 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 7(continued) From what year is the following reported actual annual emissions data? 2015 Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Emission Uncontrolled `.Requested;Annual^Permit '. Factor -Actual Annual Emissions-• 4 Emission Emission Limits) Pollutant Source , Factor (Specify Units) (AP-42,Mfg. Uncontrolled Controlled6 Uncontrolled Controlled etc) (Tons/year) (Tons/year) (Tons/year) (Tons/year) TSP(PM) 7.6 lb/MMscf AP-42 1.4-2 0.25 0.3 0.3 PM,0 7.6 lb/MMscf AP-42 1.4-2 0.25 0.3 0.3 PM 2.5 7.6 Ib/MMscf AP-42 1.4-2 0.25 0.3 0.3 SOx 0.01 lb/hr Mass Balance 0 0 0 NOx 0.138 lb/MMBtu TCEQ 4.59 7.3 ' CO 0.276 lb/MMBtu TCEQ 9.31 14.6 VOC 1.54 Ib/MMBtu AP-42 x 22%VOC 1.0 81.9 1.6 Other: 4 Requested values will become permit limitations.Requested limit(s)should consider future process growth. 6 Annual emission fees will be based on actual controlled emissions reported.If source has not yet started operating,leave blank. Section 8 - Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteria pollutants(e.g. HAP-hazardous air pollutant)emissions equal to or greater than 250 ✓�Yes ❑No lbs/year? If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source: Uncontrolled Uncontrolled Controlled Overall Emission Factor CAS Emission Actual Actual Chemical Name Control Source Number Efficiency Factor (AP-42,Mfg.etc) Emissions Emissions • (specify units) (lbs/year) ((Ps/year) Benzene 98% 0.0052 lb/MMbtu AP-42(THC)x%Benzene 555.6 11.1 Toluene 98% 0.0254 lb/MMbtu AP-42(THC)x%Toluene 2702.4 54.0 Ethylbenzene 98% 0.006 lb/MMbtu AP-42(THC)x%Elhylbenzene 634.7 12.7 Xylenes 98% 0.0160 Ib/MMbtu AP-42(THC)x%Xylenes 1701.8 34.0 n-Hexane 98% 0.0079 Ib/MMbtu AP-42(THC)x%n-Hexane 841.0 16.8 6 Annual emission fees will be based on actual controlled emissions reported.If source has not yet started operating,leave blank. 5 I A� ,,,:r,:: °°`LORADO Form APCD-200-General APEN -Revision 10/2016 Permit Number: 12WE1492 AIRS ID Number: 123 /0057 /068 [Leave blank unless APCD has already assigned a permit N and AIRS ID] Section 9 -Applicant Certification hereby certify that all information contained herein and information submitted with this application is complete, true and correct. ( Let go Si ature of Legally Auth rized Person(not a vendor or consultant) Date Jillian Yamartino Sr. HSE Representative Name(print) Title Check the appropriate box to request a copy of the: E✓ Draft permit prior to issuance ❑� Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase, increase production, new equipment,change in fuel type,etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with$152.90, to: For more information or assistance call: Colorado Department of Public Health and Small Business Assistance Program Environment (303)692-3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Or visit the APCD website at: Denver, CO 80246-1530 Make check payable to: https://www.colorado.gov/cdphe/apcd Colorado Department of Public Health and Environment Telephone: (303)692-3150 Form APCD-200-General APEN -Revision 10/2016 6 I Ay COR ADO H,IN 4 ft+�dnnH,l ( AUG-32018 CDPHE General APEN - Form APCD-200 co el Air Pollutant Emission Notice (APEN)and Application for Construction Permit • All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re-submittal. There may be a more specific APEN for your source(e.g. paint booths, mining operations, engines, etc.). A list of specialty APENs is available on the Air Pollution Control Division (APCD)website at: www.colorado.Rov/cdphe/apcd. This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase, increase production, new equipment,change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 12WE1492 AIRS ID Number: 123 /0057 /069 [Leave blank unless APCD has already assigned a permit#and AIRS ID] • Section 1 -Administrative Information Company Name': Kerr-McGee Gathering LLC Site Name: Lancaster Plant Site Location Site Location: 16270 WCR 22 County: Weld Fort Lupton, CO NAICS or SIC Code: 1321 Mailing Address: (Include Zip Code) PO Box 173779 Denver, CO 80217-3779 Permit Contact: Jillian Yamartino Phone Number: (720)929-4374 Portable Source 2 E-Mail Address Home Base: jiilian.yamarlino@anadarko.com Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by APCD via e-mail to the address provided. 386056 COLORADO Form APCD-2OO-General APEN -Revision 10/2016 1 I �� O,r, ";°"°"t, Permit Number: 12WE 1492 AIRS ID Number: 123 / 0057 / 069 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action ❑ NEW permit OR newly -reported emission source (check one below) ❑ STATIONARY source ❑ PORTABLE source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership' ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) ❑ APEN submittal for permit exempt/grandfathered source Additional Info Et Notes: APEN update to show uncontrolled VOC emissions and uncontrolled and controlled HAP emissions. 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-1041 must be submitted. Section 3 - General Information General description of equipment and purpose: Air -Assisted process flare with pilot rating of 0.5 MMBtu/hr, purge gas rating of 0.72 MMBtu/hr and process gas rating of 10.9 MMBtu/hr. Manufacturer: Model No.: Serial No.: Company equipment Identification No. (optional): For existing sources, operation began on: F-3 06/23/2015 For new or reconstructed sources, the projected start-up date is: Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: 24 hours/day 7 days/week Seasonal use percentage: Dec -Feb: 25 Mar -May: 25 Form APCD-200 - General APEN - Revision 10/2016 52 weeks/year June -Aug: 25 Sept -Nov: 25 AW ', 'COLORADO Permit Number: 12WE1492 AIRS ID Number: 123 /0057 /069 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 4- Processing/Manufacturing Information Et Material Use ❑✓ Check box if this information is not applicable to source or process From what year is the actual annual amount? Design Process Actual Annual Requested Annual Description Rate Amount Permit Limit4 (Specify Units) (Specify Units) (Specify Units) Material Consumption: Finished Product(s): 4 Requested values will became permit limitations. Requested limit(s)should consider future process growth. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) ❑Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. OW' t 'WV"' °,c S9sx"tL'W` Asr' ��t '',r,•e 42.14.404.-71 4 +..1 by +�y'a. ,Opera r t 5� �e r �[ow lia eFs a sVelbnt R� rr fk --gat is 5}o;}`Stack;N «� v-� x �"( )' .R* �•r�.i CFM)� �t� .��a(��/secj�'1�a� �ti• e•a r t' Y �+� Feet wx 9 , fa�," r iy �i,g s °° k,41iN a «4 i i� "... x X;�"'. 'G.b:•''� �:$�n.� �. �gH4 ,.,(5�'� l� ... r.��'tr "+.Z.�..{x^,."Y''. ... . .� � ^.•S.` k, ip5C.".!ta��444' i�4�i�4..£� v, d +�. :.4: wr'A�."-�`.�c-'s..a� F-3 1000 17,671 60 Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑Downward ❑ Upward with obstructing raincap ❑ Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter(inches): 30 ❑Square/rectangle Interior stack width(inches): Interior stack depth(inches): ❑Other(describe): COLORADO Form APCD-200-General APEN-Revision 10/2016 3 I ��IHOiINb�nV�m Permit Number: 12WE1492 AIRS ID Number: 123 /0057 /069 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 6- Combustion Equipment ft Fuel Consumption Information ❑Check box if this information is not applicable to the source(e.g. there is no fuel-burning equipment associated with this emission source) Design Input Rate Actual Annual Fuel Use Requested Annual Permit Limit4 (MMBTU/hr) (Specify Units) (Specify Units) 12.12 (Fuel and Process Gas) 22 (Fuel and Process Gas) 85.4 MMscf/yr(Fuel and Process Gas) From what year is the actual annual fuel use data? 2015 Indicate the type of fuel used': El Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/SCF) ❑ Field Natural Gas Heating value: BTU/SCF El Ultra Low Sulfur Diesel (assumed fuel heating value of 138,000 BTU/gallon) ❑ Propane (assumed fuel heating value of 2,300 BTU/SCF) ❑Coal Heating value: BTU/tb Ash Content: Sulfur Content: ❑Other(describe): Heating value(give units): 4 Requested values will become permit limitations. Requested limit(s)should consider future process growth. 5 If fuel heating value is different than the Listed assumed value,provide this information in the"Other"field. Section 7-Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? El Yes El No If yes,describe the control equipment AND state the overall control efficiency(%reduction): Pollutant .• Control Equipment Description Overall Control Efficiency (%reduction in emissions) TSP (PM) PM10 PM2.5 SO„ NOx CO VOC Process Flare 98% Other: ©may COIORA5O Form APCD 200 General APEN Revision 10/2016 4 I m�6 rr wsur.nnmm Permit Number: 12WE1492 AIRS ID Number: 123 /0057 /069 (Leave blank unless APCD has already assigned a permit#and AIRS ID) Section 7(continued) From what year is the following reported actual annual emissions data? 2015 Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Emission Re uestedrAnnual Permit s.,' Uncontrolled q Factor Actual Annual Emissions 4 Emission Emission Llmit(s) Pollutant Source Factor (AP-42,Mfg. Uncontrolled Controlled6 Uncontrolled Controlled (Specify Units) etc) (Tons/year) (Tons/year) (Tons/year) (Tons/year) TSP(PM) 7.6 Ib/MMscf AP-42 1.4-2 0.12 0.3 0.3 PMto 7.6 lb/MMscf AP-42 1.4-2 0.12 0.3 0.3 PM2 5 7.6 lb/MMscf AP-42 1.4-2 0.12 0.3 0.3 SOx 0.01 lb/hr Mass Balance 0 0 0 NO,, 0.138 Ib/MMBtu TCEQ 2.2 7.3 CO 0.276 lb/MMBtu TCEQ 4.5 14.6 VOC 1.54 lb/MMBtu AP-42 x 22%VOC 0.48 81.9 1.6 Other: 4 Requested values will become permit limitations. Requested limit(s)should consider future process growth. 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,leave blank. Section 8 - Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteria pollutants(e.g. HAP-hazardous air pollutant)emissions equal to or greater than 250 ❑✓ Yes ❑No lbs/year? If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source: Uncontrolled Uncontrolled Controlled Overall Emission Factor CAS Emission Actual Actual. Chemical Name - Control Source 6 Number FactorEmissions Emissions Efficiency (specify units) {AP-41,Mfg.etc) (lbs/year) (lbs/year) Benzene 98% 0.0052 Ib/MMbtu AP-42(THC)x%Benzene 555.6 11.1 Toluene 98% 0.0254 Ib/MMbtu AP-42(THC)x%Toluene 2702.4 54.0 Ethylbenzene 98% 0.006 lb/MMbtu AP-42(THC)x%Ethylbenzene 634.7 12.7 Xylenes 98% 0.0160 Ib/MMbtu AP-42(THC)x%Xylenes 1701.8 34.0 n-Hexane 98% 0.0079 Ib/MMblu AP-42(THC)x%n-Hexane 841.0 16.8 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,leave blank. COLORADO Form APCD-200-General APEN- Revision 10/2016 5 I �`r!W t; "am`, Permit Number: 12WE1492 AIRS ID Number: 123 /0057 /069 [Leave blank unless APCD has already assigned a permit if and AIRS ID] Section 9 -Applicant Certification I hereby certify that alt information contained herein and information submitted with this application is complete, true and correct. -'- /Z/ I -Z-A3i(e, Ignature of Lega Authorized Person (not a vendor or consultant) Date !llian Yamartino Sr. HSE Representative Name(print) Title Check the appropriate box to request a copy of the: I]Draft permit prior to issuance El Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C.for revised APEN requirements. Send this form along with$152.90,to: For more information or assistance call: Colorado Department of Public Health and Small Business Assistance Program Environment (303)692-3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Or visit the APCD website at: Denver, CO 80246-1530 Make check payable to: https://www.colorado.gov/cdphe/apcd Colorado Department of Public Health and Environment Telephone: (303)692-3150 .. COLOADO Form APCD-2OO- General APEN-Revision 10/2016 6 I �w� Rmo n. Fort Lupton Gas Plant Lancaster Plant Mole Sieve Regeneration Gas Heater 1 and 2 Train 1 and Train 2 Heater Data Make: Mole Sieve Regeneration Gas Heater with Ultra Low NOx Burners Manufacturer: ZEECO USA, LLC Model 35M Megafire AIRS ID: 123/0057/057 and 058 Source ID E-2015&E-2016 Heat Output 25.0 (MMBtu/hr) Fuel Use 229.5 MMscf/yr Efficiency: 0.84 (decimal) 19.5 MMscf/mo* Heat Input: 32.7 (MMBtu/hr) *based on 31-day month Operation: 7150 (hr/yr) Fuel Heat Value: 1020 (Btu/scf) Emission Calculations Emission Factors Emissions Pollutant Source lb/MMscf Adjusted Ib/MMBtu lb/hr lb/mo* tpy Ib/MMscf* NOx manuf. 0.04 1.3 974 4.7 CO manuf. 0.040 1.3 974 4.7 VOC manuf. 0.019 0.6 463 2.2 PM10/PM2.5 AP-42 7.6 7.6 0.007 0.2 181 0.9 SO2 AP-42 0.6 0.6 0.001 0.02 14 0.1 CH2O AP-42 0.075 0.075 0.000 0.002 2 0.009 Benzene AP-42 0.0021 0.0021 0.0000 0.0001 0 0.0002 Toluene AP-42 0.0034 0.0034 0.0000 0.0001 0 0.0004 n-Hexane AP-42 1.8 _ 1.8000 0.0018 0.0578 35 0.2065 *Emission factor conversion based on footnote"a"of AP-42 Table 1.4-1 to convert from 1,020 Btu/scf to the above Fuel Heat Value in units of Btu/scf. * lb/mo based on 31-day month CO2e Emission Calculations Conversions: 1 Metric Ton= 2204.62 lbs 1 kg= 0.001 metric tons metric Pollutant kg/mmbtu tpy ton/mo* ton/yr CO2 53.02 12,411 13,681 1,162 CH4 0.001 0.23 0.26 0 N2O 0.0001 0.02 0.03 0 CO2e= 13,694 1,163 CO2 =002+(OH4'21)+(N2O'310) *ton/mo based on a 31-day month Fort Lupton Gas Plant Lancaster Plant Heat Medium Fired Heater 1-4 Train 1 and Train 2 Heater Data Make: Heat Medium Heater with Low NOx Burners Manufacturer: Sigma Thermal Model: HC2-50.0-H-SF Description H-6051, H-6052,H-6053&H-6054 Heat Output 60.00 (MMBtu/hr) Fuel Use 726.7 MMscf/yr Efficiency: 0.78 (decimal) 61.7 MMscf/mo* 'Heat Input: 84.6 (MMBtu/hr) 'based on 31-day month Operation: 8760 (hr/yr) Fuel Heat Value: 1020 (Btu/scf) 1 Heat input adjusted by 10%to account for increased throughput. Emission Calculations Emission Factors Emissions Adjusted2 Ib/MMBtu 4 Pollutant Source lb/MMscf Ib/MMscf lb/hr lb/mo4 NOx manuf. 0.04 3.4 2518 14.8 CO manuf. 0.04 3.4 2518 14.8 _ VOC AP-42 5.5 5.5 0.005 0.5 339 2.0 SO2 AP-42 0.6 0.6 0.001 0.05 37 0.22 CH2O AP-42 0.075 0.075 0.000 0.006 5 0.03 PM10/PM2.53 Testing 4.6 4.6 0.382 284 1.7 Benzene AP-42 0.0021 0.0021 0.0000 0.0002 0 0.00 Toluene AP-42 0.0034 0.0034 0.0000 0.0003 0 0.00 n-Hexane AP-42 1.8 1.8000 0.0018 _ 0.1493 111 0.6540 2 Emission factor conversion based on footnote"a"of AP-42 Table 1.4-1 to convert from • 1,020 Btu/scf to the above Fuel Heat Value in units of Btu/scf. 3 PM10/PM2.5 emission factor based on average PM2.5 testing results,see supplemental calculations. °lb/mo based on 31-day month • Lancaster Gas Plant Lancaster Plant Amine Treater Vent Stack Emissions-Train 1 and Train 2 Source ID 1A(formerly A-1),18(formerly A-2),2A(formerly A-3).&26(formerly A-4) AIRS ID 123/0057/063,064.065,066 Source Description 165 MMSCFD Amine Treating System.Train 1(2 each)and Train 2(2 each) Potential operation 8760 hrs/yr y.nd Gas' VOC Emission Calculations Flowrate IMMscfcl 0548 Pressure'pm, 20 4 Conversions Temperature,'°F) 120 Molar Volume to Molar Mass I 379.3jscfllb-mole Composition Mol r lb/lb-mole Ndrogen 2000E-04 28.01 VOC Calculation Acid Gas CO2 9'.102 44 Pollutant scf/yr tons/yr Hydrogen Sulfide 1 900E-03 34 08 210 ppm F Propane 9.25E+05 54 Methane 3 258E-01 16 04 n-Butane 2.43E+05 19 Ethane 8.780E-02 30 07 i-Butane 1.70E+04 1 Propane 3.810E-02 441 n-Pentane 5.58E+04 5 n-Butane 1 000E-02 5812 i-Pentane 1.94E+04 2 I-Butane 7 000E-04 58 12 n-Hexane 2.91E+04 3 r-Pentane 2.300E-03 7215 Uncontrolled VOC•2 Factors = 168.2 tons/yr I-Pentane 8 000E-04 72 15 Uncontrolled Emissions Factor= 138.6 Ib/MMscf n-Hexane 1.200E-03 8617 VOC x 99%Control Efficiency 1.7 tons/yr Other Sulfur 1 000E-03 60 07 See"Acid 286 ib/mo2 Water 8.398E+00 •VOC emissions based on Dow model outputs multiplied by a factor of 2 to account for Total 100 0 2lb/mo based on 31-day month 'Acid Gas composition and flowrate based on ProTreat simulatic Fort Lupton Gas Plant Lancaster Plant Amine Treater Thermal Oxidizer Emissions,Train I and Train 2 Source ID 1A TO,1B TO,2A TO),28 TO AIRS ID 123/0057/063,064,065.066 Source Description Train 1 and Train 2 Thermal Oxidizer to Control Amine Treaters 1A.1B.2A.and 2B Potential operation 8760 hrs/yr —stream will be routed to process flare when TO is down. Combustion Emission Calculations Acid Gas' Plumate IMMscfd) 6.648 Acid Gas Pressure(amp) 20 4 1 Molar Volume to Molar Mass j 379 3f sc1/Ib-mole I Temperature('F) 120 Composition Mork lb/lb-mole Heat of Nitrogen 0.0002 28 01 Combustion Amine still vent and Heat Content Component Formula tatullb] flash gas pb1hr (Btulhr] methane CH4 21502 38.1639 820599 CO2 91.1019 44 ethane C1N6 20416 19.21108 393637 Hydrogen Sulfide 0 0019 34 08 propane C3H8 79929 12.2785 244538 Methane 0.3258 1604 n-butane C4H10 19665 4.2445 83467 Ethane 0.0878 30.07 isobutane C4H/0 19676 0.2971 5828 Propane 0.0361 44.1 _._ --�__......• n-pentane CSH12 19499 1.2119 27671 n-Butane 0.0100 58.12 Isopentane 05812 19451 042t5 8199 rBurane 00007 58.12 n-Hexane C6H14 19200 0.7552 14499 n'Pentane 0 0023 72.15 Total 1Btumr)a 1594397 -Pentane 0.0008 72.15 Btuiscf= 5.8 n-Hexane 0.0012 86.17 rBTU/5cl adjusted= 34.8 Other Sulfur 0.0010 6007 Total Btulhr adjusted= 9566383.9 Water 8.39 'BTU!sef adjusted by factor of 6 due to variabliry in acid gas composition. Total 130 0 _Fuel Gas '009 Gas composition and rreurale based on ProTreat Heel Content 1070 btu/Scf s,mdauoa mode,for 165MMscid and 690 gore amine orcmauon rate TO Burner Heat Rate(pilot gas) 65 MMSCF/yr Auxiliary Fuel Gas(heat content make up) 81 MMSCF/yr Heal Input Total Heat Input hrs/yr (MMBtulhr) from Amine Still Auxiliary TO Bunter Heat Rating Vent and Flash Fuel Gas (MMBIu/hr) Gas(MMBtu/hrl (MMBtuhr) 8.00 9 6 9.90 27 5 8760 Pollutant Ib/MMsct 16/MMBtu Ibthr ton/yr Ib/mo' NO4 100 0.10 2.69 II,8 2003 CO 73 0.07 1.97 8.6 1463 TOC it 0.01 030 1.3 2204 PM(Total)' 1.03 0.29 1 2 204 S02 0.6 5.88E-04 0.02 S 1 20 CH2O 0.075 7.15E-05 0.00 0.0 2 Benzene 0.0021 2.06E-06 0.00 0.0 0 Toluene 0.003 3.33E-06 000 0.0 0 -AP-42 emission factors,Tables 1.4-1.1.4-2 and 1.4-3 'Assumed TOC=VOC 'Particulate emission factor based the average mass rate from IA.10,2A testing from 2016 muliplied by a • • factor 2 for variability in ambient background. • 302 Emission Calculations I H2S in Fuel Gas 4lppm Acid Gas Molar Volume to Molar Mass 379.3 scf/lb-mole SO2 Atomic Weight 64.05 awe H2S Atomic Weight 34.08 amu H2S Removal Bed Efficiency 95.00% Thermal Oxidizer Control Efficiency 99.00% Before H25 Removal Beds Sulfur to Thermal Oxidizers Pollutant Ib/MMSCF Iblhr tpy Ib/MMSCF lb/hr tpy 826(Acid Gas) 0 07 0 47 2.07 000 0.02 0 10 Other sulfur compounds 006 0.44 1.92 0.07 0.44 1,92 Acid Gas H2S(Fuel Gas) 1 11E-06 2.99E-06 2.62E-02 'Based on analytical data. ID ppm sulfur compounds other than H2S Thermal Oxidizer Emissions Emission Factors Controlled Emissions Controlled Units Ib/mos tpy H2S(Acid Gas) 3.44E-05 Ib/MMSCF 0.01 0.00 SO2(from acid gas H2S) 0.16 Ib/MMSCF 33.06 0.19 SO2(from other sulfur compounds) 1.69 Ib/MMSCF 348.03 2 05 SO2(Fuel Gas)' 0.60 Ib/MMSCF 7.44 0 04 Total SO2 388.53 2.29 s lb/mo based on a 31-day month Fort Lupton Gas Plant F-2 and F-3 Lancaster Plant Process Flare 1 and 2 Source ID Number F-2 and F-3 SCC AIRS ID 123/0057/068,069 Source Location Zone. Source Description Flare Horizontal: Flare Make Potential Operation 8760 hr/yr Flare Model Potential Fuel Usage 10.5 MMscf/yr Serial Number Date in Service Stack Height 40 ft Flare Configuration Air-Assisted Stack Diameter 30 in Fuel Heating Value 1020 Btu/scf Exit Velocity 60.0 ft/s Flare Pilot Rating 0.5 MMBtu/hr Exit Temperature 1000 deg F Flare Purge Gas Rate 707 scf/hr Volume Flow Rate 17.671 fts/min Purge Gas Heat Rate 0.721 MMBtu/hr Process Gas to Flare 75.0 MMscf/yr Process Gas Heating Value 1275.0 Btu/scf Process Gas Heat Rate 10.9 MMBtu/hr 7i,VOC Content of Process Gas 22.0 Combustion Emission Calculations Heat Input hrs/yr MMBtu/hr 12.14 I 8760 Uncontrolled Controlled Pollutant I Ib/MMBtut lb/hr I ton/yr lb/hr I ton/yr I Ib/mo' NOx 0.138 - - 1.67 7.3 1246 CO 0.28 - - 3.34 14.6 2488 PM2.5 - 0.3 - 0.3 54 VOC` 0.03 - 81.87 0.37 1.6 278 Uncontrolled Controlled HAPS I lb/MMBtu3 lb/hr I lb/yr lb/hr I lb/yr I lb/mo* Benzene 0.00010 0.06 555.60 0 00 11.1 0.9 toluene 0.00051 0.31 2702.38 0.01 54.0 5 Gthylbcnzenc 0.00012 0.07 634.69 0.00 12.7 1 Xy lenes 0.00032 0.19 ' 1701.79 0.00 34.0 3 n-l1exanc 0.00016 010 840.96 0.00 16.8 1 'NCA and no emission fartnrs from TOFU tm von FmimWns are based esf,mated w VOC,mnlfinlied by 4P-47'HC:emiss,nn fartnr 0 14 Ih/MMbhi 3 HAP emissinn factors based en most recent nas analysis nnrcentane of each HAP mvlhnlled by TOO factor 0 141htMMhtu 9bno is based on a 31-day month SO2 Emission Calculations Conversions: Inlet H2S Concentration 4 ppm Molar Volume to Molar Mass 379.3 scf/lb-mole SO2 Atomic Weight 64.05 amu H2S Atomic Weight 34.08 amu Process Gas Pollutant lb/yr I tpy H2S 2-918E+01 1.459E-02 SO2 0.03 f Total SO2 emissions(tpy)' I 0.03 1 " I otal emissions"1.1 factor nec 1,00,[040,40,44 Snob. Latta.,plant 04041,4,*r«na 42, t:e< py EVurynmt Mews al Centml ONE er.i•tia,,W�, v A x M0 i4pa Eraetwn anus, cox 0,14 Vx 1144 E.8040,4 ¶4,.4n n44540,4 npeeattnn 44,444 0140 004 440 n0, .4.on. ni xNp ..a 7404 p E,amean 444? 444.. Ileese0weal h5 IFY rv144 Q,pY EA ena Nf n-x101 104 11, 0 1144 Te11,4 ?Y MY n Spy m ea C.....0.0:1,1.1 ^k 0./001.0.0.01.1 00a. l5 F 00, ` C to. f` la „sl 0 010 ;., iz0 ,40n0,x r 0040%0 ,...'5 127 ., '200..7.000. 64340? /44, .• 0'. , 0050414% 0 rS 4.0 .x... p. .C., '0 -..+: :✓? �,.. Y. iiat0 .: )M u c _ w A m 04.'t U 0,0 wa 40 ' m ex 1., s .e r,, a.< emb ya„ c.,o. _ 1 .0 o.x to 0 0.4 : ,.:x, .1 it 0,c 11 ft o a5 ©ro 0 '10 ID - as-+um a._, IA �1d.Y Ra8 2a" t 00 aY 05 tits OA 0.7 a+ td ra:.x .-0 •004' 4444.[ 4...44.47 14.:, • Platte Valley Gas Plant Natural Gasoline Loading Platte Valley: Natural Gasoline Loadout Emission Calculations i ---.mp..n. if u,•.•.iryau..060008!P '.vy_caw lov0• • ._. 1 0 . glitsisMh.s t!w ro0G _S1 lash VepoFS-► ., Vu.•.wSk•:ca.ru+�; G'a lw,. f"Truck Flashing Losses"yOCs=60.49 ton/yr —Nawral Gasolin emlet ranks — Truck F lashing Los4es—► Trod -- •Salo_:NG- 2 Properties SatesNG n. ,! , Tempfralure(l dal) 75T F •Aa u•a t a um, deco• Std Liquid Vduml4rir Flow(Tolal) 1250'lbbVd • I :.�u.atm�n - 6'Tev... s.ec mn. ..als•Is • iaeves r. r 'llama nxel m.o?. 0, f 04.0 r 1•••4w1• •... 2.001 ' K1nia. e ! i ON, v.. •Valurnelucalee. id OiMvAn,we.; I�,C:-nb.r..san1� . ,2043• • AVaayma'. wb.Raman, •I I MY Tank loss eaknbtlons for-Sales NG" I'one..weasel_-'-"— . I.' loedIn losses ale 5749 fo floadedl d se... op !its• 9 Nyro liquid 1.-�na. p.�n"_. Y sits, Loaded Tank seioisv .m.! - In or Loading Losses ^•_._.l_ 11 tar Su wa... s .o..... ame N ix _ wr E"oze � l t OW,. �,x..u.vi ra_r ro•q. y.00n bv. . 22 ...nlpn•r._,Nuwv.. _ ✓- :wan 09Y ms R.13, '1{ OSE• Tout. ..- - - a.n"...twn...u..ca iv. •any Emission Summary Uncontrolled Uncontrolled Controlled EF(Iblbbl) VOC(TRY) 118.0 5.9 188.8 Benzene(113/yr) 505A 25.27 0.40432 Tolluene(Ib/yr) 107.6 5.38 0.08608'401 Reportable Etheylbenzene(Iblyr) 0.1368 0.00684 0.00010944 'Not Reportable Xylene(19/yr) 1.562 0.0781 0.0012496 'Not Reportable n-Hexane(tb/yr) 3900 195 3.12 2,2,4-Tdmethyipentane(Iblyr) 62.2 4.11 0.06576 'Not Reportable Platte Valley Gas Plant Platte Valley Natural Gas Loadout Combustion Emissions ' Source ID Number NG-TL-1 Stack Height 30 ft AIRS ID TBD Stack Diameter 48 in Source Description Enclosed Combustor Exit Velocity ft/s Flare Make John Zink Exit Temperature deg F Flare Model ZCT-1-4-30-X-1/6 Volume Flow Rate ft3/min Serial Number TBD Potential Hours 8760 hrs Date in Service TBD Combustion Emissions BTU Loading Source Heat Content Flow Rate to Flare (btu/scf) (scf/hr) (Mmbtu/hr) Truck Loading'11.121 1400 292 7.8 Supplemental Fuel 1080 581 0.6 Pilot Gas 1080 54 0.06 ill Heat content based on EPA Publication EPA-450/2-77-026 displaced gasoline vapor - (21 BTU loading based on maximum heat rating from manufacturer specs. Combustion Emissions Emission BTU Loading Emission Emission Criteria Pollutant Emission Factor Factors to Flare Rate Rate Ib/MMscf (lb/MMbtu) (MMbtu/hr) (lb/hr) (tpy) Carbon Monoxidei3l 0.2 1.70 7.4 Nitrogen Oxides13l 0.15 1.27 5.6 PM[4] 7.6 0.007 8.5 0.06 0.3 VOC(4l 5.5 0.005 0.05 0.2 SO2 i4l 0.6 0.001 0.00 0.0 PI Emission factors from manufacturer specs. l41 Emission factors from AP-42 Chapter 1.4 Table 1.4-2. CO2e Emissions Conversions: 1 Metric Ton= 2204.62 lbs 1 kg= 0.001 metric tons Pollutant kg/mmbtu metric ton/yr tpy CO2 53.02 3,941 4,344.64 CH4 0.001 0.1 0.08 N2O 0.0001 . 0.0 0.01 CO2e= 4,349 CO2e=CO2+(CH4*21)+(N2O*310) Colorado Departmeul of Public Health and En,irooiocnl r_—T F orni:ND-102 .)1r Pollution Control Division CDPHE Facility Wide Emissions Inventory Form Cony, A i,leil(' vourrn AIRS 11,!± - — "T P t iTR ,a7---1-111 -,-II','R Y me, 1.17 'I I .11i,—R11 ..J.I tIC r, 70, MK 11 1tn R/ 1,. \.i .i a thi il • ,I— • L, L. .. I vle 22 In. Imen .99.9 1,400 ,..xu I.9x ,-e vxw 16=69 J 000092 41119 I 37 n 00 at 1' II" 0170 W 0,13,1 91:9 - aPtn1M.ITrm f,emn.uurcr, ,_ _• e1i ..,1 1) 1 6e)a XJ9 14 10.14 n. AP,Onlit Maintain on on ult.. J. ? J. 1 n n 11 nt..,,p yn .•,..r,rc.. o u n u o u u n oa ? 113I. r.X I. Ji I n u n t. o u a u o 1 1 • _ :141 Io Jn u, 11.9 n. NM 1 s l n n n o o n n U o 4o In In na 11s ua Ie? u o 0 0 o n n n o Mane m ae„rrc,aI en 1 :,9 I ,a.I x+ I man,I.vn I ler.a i.0c--1 r.au+I ut'u I •mJu I=0161 I +100 _1.. .1) ,.e) 1 x41 I :,1 I •: I II,1,:1121.1 11.JJ ,9„ I r,.9 16„116w61nJ.9,1 In.=,•1,9.axnl,,,ie,,,e 110..16 n,,:mn„n«uar,wmm.,,,n,,.1 11.9{ , I ,.. I X.v I al I r., I Xx 1 :.J.6 1 n, I I•o I <m.,mn.ea.r.6m,,:ar.,,m1:-1 M.I 47 1 ,I 1 kJ 1 un I a.r.1 9.0 110.I a.,! Ca I.:..an..In alma.,,ll 0.11,10.,-1 1410 1 ..,.:•..L..,1::.,L,1I11,N.I,1 I'1 9,.a I F'onl:lule+: 'I'hai..--buidd br rul:pinied l:,lade&bail,cumin, rnd all propo5W n. „dlfa,on.rue.l vrs.on,wlirm 1r 1hn un,IMiuns wurcc Ia nu.,an zn,c,IMIJI oa0I',nldc,the Nam Na and AIRS ID data column, 11101'.1Ubnvialiwl5 incude St=Ilno,c. 2±-T511'-::4.Ia,aa,htlpenlurc 100-'1,1,,,,,, &Veral.b,a,2Ideh)de EH GhvlOa uene Aura•Oerolein 1>.I-Wene n-llea n3lexam• Halo a Four...0rda Math blechaoul -1 ANN Fun+n,):vipafuunl Sour,.Uluuld be minded,al;en,,urre,,led cot() vet) ' - =a= '= rte\-1:c) * 1876 4( Colorado Department of Public Health and Environment OPERATING PENWIT Kerr-McGee Gathering LLC Fort Lupton Complex First Issued: October 1, 1998 (Fort Lupton) October 1, 1999 (Platte Valley) Renewed: DATE AIR POLLUTION CONTROL DIVISION COLORADO OPERATING PERMIT FACILITY NAME: Fort Lupton Complex OPERATING PERMIT NUMBER FACILITY ID: 123/0057 95OPWE013 RENEWED: DATE EXPIRATION DATE: DATE MODIFICATIONS: See Appendix F of Permit Issued in accordance with the provisions of Colorado Air Pollution Prevention and Control Act, 25-7-101 et seq. and applicable rules and regulations. ISSUED TO: PLANT SITE LOCATION: Kerr-McGee Gathering LLC Fort Lupton Gas Plant P.O. Box 173779 16116 Weld County Road 22 Denver, CO 80217-3779 Fort Lupton, CO 80621 INFORMATION RELIED UPON Operating Permit Renewal Application Received: October 29, 2002 And Additional Information Received: Various dates (see Technical Review Documents) Nature of Business: Natural Gas Processing Plant Primary SIC: 1321 RESPONSIBLE OFFICIAL FACILITY CONTACT PERSON Name: Mr. Miguel DeHerrera Name: Mark Losowski Title: Director Title: HSE Representative Midstream Operations Phone: (720) 929-6000 Phone: (720) 929-3858 SUBMITTAL DEADLINES — First Semi-Annual Monitoring Period: TBD based on permit issuance Subsequent Semi-Annual Monitoring Periods: January 1 June 30, July 1 December 31 Semi-Annual Monitoring Reports: Due February 1, 2014 & August 1, 2014 &subsequent years First Annual Compliance Period: TBD based on permit issuance Subsequent Annual Compliance Periods: January 1 — December 31 Annual Compliance Certification: Due February 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 3 3. Non-Attainment New Source Review (NANSR) and Prevention of Significant Deterioration (PSD) 15 4. Accidental Release Prevention Program (112(r)) 16 5. Compliance Assurance Monitoring (CAM) 16 6. Summary of Emission Units 16 SECTION II - Specific Permit Terms — Ft Lupton 19 1. EU-33: One (1) Fairbanks Morse MEP-12, 2046 HP engine (AIRS point 004) 19 2. F001: Fugitive Emissions from Equipment Leaks (AIRS point 018) 27 3. EU-32: One (1) Waukesha L7042GSI, 1232 HP engine (AIRS point 030) 31 4. EU-101: One (1) Waukesha L7042GSI, 1478 HP engine (AIRS point 017) 38 5. EU-38, EU-39: Two (2) Caterpillar 3612 TALE, 3550 HP engines (AIRS point 020) 45 6. EU-34R: One (1) Waukesha L-7042 GSI, 1232 HP engine (AIRS point 025) 52 7. EU-103: One (1) Caterpillar G3616 TALE, 4262 HP engine (AIRS point 026) 59 8. EU-104: One (1) Caterpillar G3616 TALE, 4735 HP engine (AIRS point 028) 67 9. F-4: One(1) John Zink 65' Air-Assisted Process Flare (AIRS point 070) 75 10. Insignificant Engines Subject to NSPS Requirements: GEN 2 80 SECTION III - Specific Permit Terms — Platte Valley 83 1. S001-S004: Four (4) Ajax DPC-540LE, 514 HP engines (AIRS IDs 038-041) 83 2. S007: Platte Valley Plant Fugitive Emissions from Equipment Leaks (AIRS point 042) 88 3. S009: Natural Gas Liquids (NGL) Amine Sweetening Unit, 15,000 BBL/day (AIRS point 043) 92 4. S012: One (1) Ajax DPC-2803LE, 550 HP engine (AIRS point 044) 100 5. S013: One (1) Perry Gas Processors, Inc. Natural Gas Fired Amine Unit Heater, 10.7 MMBtulhr(AIRS point 045) 105 6. S015 — S017: Three (3) Ajax DPC-2803LE, 550 HP engines (AIRS points 047-049) 111 7. S018 — S019: Two (2) Caterpillar G3516 TALE, 980 HP engines (AIRS points 050 — 051) 116 8. S020: One (1) Solar Centaur 40, 4700 HP Gas Turbine engine (AIRS point 052) 124 9. S021: One (1) Flare Industries Air Assisted Process Flare (AIRS point 053) 132 10. NG-TL-01: One (1) Truck Loadout of Pressurized Natural Gasoline Liquids (AIRS point 073) 137 11. Insignificant Engines Subject to NSPS/MACT Requirements 143 12. S014: One (1) Born Natural Gas Fired Hot Oil Heater, 32.0 MMBtu/hr(AIRS point 046) 157 SECTION IV - Provisions Common to Multiple Units 163 1. Portable Monitoring (version 6/26/2014) 163 2. MACT HH Leaks Exemption/Reporting Requirements: FOOL and S007 163 3. NSPS 0000a: FOOL and S007 164 4. MACT ZZZZ for 4SRB RICE > 500 HP: Engines EU-32, EU-34R, and EU-101 169 5. MACT ZZZZ for new 4SLB > 500 HP: Engines EU-38, EU-39, EU-103, EU-104, S018, and S019 175 6. NSPS JJJJ: Engines EU-103 and EU-104 180 7. NSPS IIII- Engine GEN2 184 8. MACT DDDDD - S013 (point 045), S014 (point 046), various insignificant heaters 188 9. NSPS Subpart Dc — S013 (point 045), S014 (point 046) 198 TABLE OF CONTENTS: 10. NSPS Subpart A General Provisions: Fugitive Equipment Leaks F001 and S007; Engines EU-103 and EU-104; Process heaters S013 and S014; Engines GEN2 and PLY PLC GEN 198 11. MACT Subpart A — General Provisions: Engines EU-32, EU-34R, EU-38, EU-39, EU-101, EU-103, EU-104, 5018, 5019, and S022 199 12. Compliance Assurance Monitoring (CAM) 199 13. Colorado Regulation No. 7 Requirements 205 SECTION V - Permit Shield 211 1. Specific Non-Applicable Requirements 211 2. General Conditions 211 3. Stream-lined Conditions 212 SECTION VI - General Permit Conditions (ver 8/28/2018) 213 1. Administrative Changes 213 2. Certification Requirements 213 3. Common Provisions 213 4. Compliance Requirements 217 5. Emergency Provisions 218 6. Emission Controls for Asbestos 218 7. Emissions Trading, Marketable Permits, Economic Incentives 218 8. Fee Payment 218 9. Fugitive Particulate Emissions 219 10. Inspection and Entry 219 11. Minor Permit Modifications 219 12. New Source Review 219 13. No Property Rights Conveyed 219 14. Odor 219 15. Off-Permit Changes to the Source 220 16. Opacity 220 17. Open Burning 220 18. Ozone Depleting Compounds 220 19. Permit Expiration and Renewal 220 20. Portable Sources 220 21. Prompt Deviation Reporting 220 22. Record Keeping and Reporting Requirements 221 23. Reopenings for Cause 222 24. Requirements for Major Stationary Sources 222 25. Section 502(b)(10) Changes 223 26. Severability Clause 223 27. Significant Permit Modifications 224 28. Special Provisions Concerning the Acid Rain Program 224 29. Transfer or Assignment of Ownership 224 30. Volatile Organic Compounds 224 31. Wood Stoves and Wood burning Appliances 225 APPENDIX A - Inspection Information 227 1. Directions to Plant: 227 2. Safety Equipment Required: 227 TABLE OF CONTENTS: 3. Facility Plot Plan: 227 4. List of Insignificant Activities• 233 APPENDIX B 237 Reporting Requirements and Definitions 237 APPENDIX B: Monitoring and Permit Deviation Report - Part I 241 APPENDIX B: Monitoring and Permit Deviation Report - Part II 245 APPENDIX B: Monitoring and Permit Deviation Report - Part III 247 APPENDIX C 248 Required Format for Annual Compliance Certification Reports 248 APPENDIX D 254 Notification Addresses — January 27, 2020 Version 254 APPENDIX E 255 Permit Acronyms 255 APPENDIX F 257 Permit Modifications 257 APPENDIX G 258 Compliance Assurance Monitoring Plan— Rich Burn Engines 258 APPENDIX H 261 Compliance Assurance Monitoring Plan— Lean Burn Engines 261 APPENDIX I 264 Compliance Assurance Monitoring Plan Natural Gas Liquids Amine Sweetening Unit 264 APPENDIX J 267 Compliance Assurance Monitoring Plan— Truck Loadout of Pressurized Natural Gasoline Liquids 267 APPENDIX K 269 Engine AOS Applicability Reports 269 Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 1 SECTION I - General Activities and Summary Permitted Activities 1.1 The Fort Lupton Complex consists of three operating facilities and one permitted facility: Fort Lupton Gas Plant, Platte Valley Gas Plant, Lancaster Gas Plant and Lancaster 3 Plant. The Platte Valley Gas Plant was acquired by Kerr-McGee from Encana Oil & Gas USA on March 1, 2011, and was determined by the Division to be a single stationary source with the Fort Lupton gas plant according to the definition of stationary source in Colorado Regulation No. 3, Part A, Section I.B.43 (same industrial grouping, contiguous or adjacent properties, and under common control). Colorado Construction Permit 12WE1492 was issued to Kerr-McGee Gathering LLC on June 4, 2014 for the construction of the Lancaster Gas Plant adjacent to the Fort Lupton Gas Plant. Construction Permit 17WE1059 was issued on August 7, 2018 for the Lancaster 3 Plant. All four facilities are now considered a single stationary source. Fort Lupton is a natural gas processing facility, designated under Standard Industrial Classification (SIC) 1321. Fort Lupton receives both high and low pressure gas. Low pressure field gas is routed through inlet slug catchers, which capture free liquids through natural separation. These liquids are routed to stabilization processes, including de-ethanization (removal of ethane and lighter fractions from the gas stream), and are stored in atmospheric storage tanks. Field gas undergoes compression and is commingled with high pressure gas (from Hudson Compressor Station) for natural gas liquids recovery using propane refrigeration and Joules-Thomson (JT) expansion. Produced natural gas liquids are stored in pressurized bullet tanks. Platte Valley is a natural gas processing plant designated under SIC 1321, formerly permitted under Operating Permit 99OPWE207. This facility is designed to process natural gas to pipeline specifications and to recover and fractionate natural gas liquids. Free liquids are captured in the inlet slug catchers and routed to stabilization processes and then to natural gas liquid fractionation. Inlet gas is compressed and routed to one of two cryogenic processing trains for natural gas liquids recovery. Recovered natural gas liquids are treated to remove H25 and CO2 in an amine unit controlled by a thermal oxidizer. Treated natural gas liquids are sent to two fractionation trains which separate out ethane, propane, butane, and natural gasoline. Natural gas liquids and fractionated products are stored in pressurized tanks prior to sales. Lancaster is a natural gas processing plant designated under SIC 1321, located adjacent to the existing Fort Lupton facility. Lancaster receives third party gas from the Kerr-McGee Gathering LLC pipeline system. CO2 and H2S are removed from the inlet gas stream using four (4) 165 MMscfd amine treaters, each controlled by a thermal oxidizer and utilizing a hot oil heater for rich amine regeneration. The gas stream is then dehydrated using a molecular sieve. The dry gas is run through the cryogenic unit to super-cool the gas and remove natural gas liquids. The cryogenic unit is supplemented by six (6) 3,000 horsepower electric motor driven propane refrigeration compressors. Residue gas from the cryogenic unit is compressed using four (4) 12,000 horsepower electric motor driven compressors for delivery to the gas pipeline. Produced natural gas liquids are stored in pressurized tanks and transported from the facility via a pipeline. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 2 Lancaster 3 is a natural gas processing plant designated under SIC 1321, located at the Fort Lupton Complex. Construction Permit 17WE1059 was issued for the Lancaster 3 plant on August 7, 2018. This plant consists of two natural gas processing trains, each comprised of a hydrogen sulfide treating bed, an amine contactor, a molecular sieve natural gas dehydrator, a natural gas fired molecular sieve regenerator heater, and cryogenic processing equipment operated with electrical compression. One amine regeneration system is shared between the processing trains, which consists of one amine regenerator, one flash tank, and one natural gas fired amine regeneration heater. Lancaster 3 also has one thermal oxidizer for control of waste gas from the amine regenerator, a process flare, fugitive equipment leaks, and a diesel-fired engine for backup electricity generation. As of the date of permit issuance [DATE] none of the equipment permitted for the Lancaster 3 plant has commenced operation. This permit currently only covers the Fort Lupton and Platte Valley gas plants. The Lancaster Plant is currently operating under the provisions of Colorado Construction Permit 12WE1492, Issuance 4, issued August 8, 2019. The applicable requirements for the Lancaster Plant and Lancaster 3 will be incorporated into this operating permit upon receipt of the modification applications associated with the revised and initial permits. This complex is located approximately five miles northeast of Fort Lupton in Weld County, Colorado. The Fort Lupton Gas Plant is located at 16116 Weld County Road 22. The Lancaster Gas Plant is located at 16270 Weld County Road 22. The Platte Valley Gas Plant is located at 16157 Weld County Road 22. Lancaster 3 will also be located at 16116 Weld County Road 22 when constructed. This complex is located in an area classified as attainment for all pollutants except ozone. It is classified as non-attainment for the 8-hour ozone standard and is part of the 8-hour Ozone Control Area as defined in Regulation No. 7, Section II.A.1. There are no affected states within 50 miles of the facility. Rocky Mountain National Park is a Federal Class I designated area within 100 km of the plant. 1.2 Until such time as this permit expires or is modified or revoked, the permittee is allowed to discharge air pollutants from this facility in accordance with the requirements, limitations, and conditions of this permit. 1.3 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 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: Construction permits associated with the Fort Lupton Gas Plant: 97WE0180, 11WE730-1, 07WE0366, 01WE0763, 00WE0582, 00WE0583, 07WE0798, lOWE1071, 14WE0142. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 3 Construction permits associated with the Platte Valley Gas Plant: 93WE157-1, 93WE157-2, 93WE157-3, 93WE157-4, 93WE157-7, 97WE0722, 97WE0723, 97WE0724, 97WE0725, 97WE0726, 97WE0727, 97WE0728, 97WE0729, 01WE0290, 02WE0927, 12WE1277, 17WE0053, 12WE1206.XP. 1.4 All conditions in this permit are enforceable by US Environmental Protection Agency, Colorado Air Pollution Control Division (hereinafter Division) and its agents, and citizens unless otherwise specified. State-only enforceable conditions are: Permit Condition Number(s): Section II Condition 1.8; Section III- Condition 5.5.1, Condition 8.8.1, Condition 10.5.1; Section IV - Conditions 3.g (last paragraph), 14 & 18 (as noted) and 30 (as noted). 1.5 All information gathered pursuant to the requirements of this permit is subject to the Recordkeeping and Reporting requirements listed under Condition 22 of the General Conditions in Section IV of this permit. Either electronic or hard copy records are acceptable. 2. Alternative Operating Scenarios 2.1 Temporary and Permanent Engine Replacement (ver 10/12/12, with revisions according to the Reg. 6, Part B revisions adopted on March 21, 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. 2.1.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with a compressor engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 270 operating days or less in any 12 month period. "Permanent" is defined as in the same service for more than 270 operating days in any 12 month period. The 270 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 270-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. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 4 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, date of manufacture, model number, horsepower, and serial number of the replacement engine. In addition to the log, the permittee shall maintain a copy of all Applicability Reports required under section 2.1.1.2 and make them available to the Division upon request. 2.1.1.1 The permittee may temporarily replace an existing compressor engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other requirements applicable to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.1.2. The permittee may temporarily replace a grandfathered or permit exempt engine or an engine that is not subject to emission limits without modifying this permit. 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) 2.1.1.2 The permittee may permanently replace the existing compressor engine for the emission points specified in Table 1 with the manufacturer, model, and horsepower engines listed in Table 1 without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.1.2. The AOS cannot be used for the permanent replacement of an entire engine at any source that is currently a major stationary source for purposes of Prevention of Significant Deterioration or Non-Attainment Area New Source Review ("PSD/NANSR") unless the existing engine has emission limits that are below the significance levels in Reg 3, Part D, II.A.44. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 5 An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the permittee is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found in APPENDIX K. This submittal shall be accompanied by a certification from the Responsible Official indicating that "based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. 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 engine replacement. Nothing in this AOS shall preclude the Division from taking an action, based on any permanent engine replacement(s), for circumvention of any state or federal PSD/NANSR requirement. Additionally, in the event that any permanent engine 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. 2.1.2 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 engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 6 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.gov 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 (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 (1b/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine 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 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. 2.1.3 Applicable Regulations for Permanent Engine Replacements 2.1.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B § III.D.2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and NOx are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PMio attainment/maintenance area, RACT applies to PMio at any level of emissions and to NOx and SO2, as precursors to PMio,if the potential to emit of NOx or SO1 exceeds 40 tons/yr. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 7 For purposes of this AOS, the following shall be considered RACT for natural- gas fired reciprocating internal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOx: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PMio: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (§ 60.331) and 40 CFR Part 72 (§ 72.2),natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 2A.3.2 Control Requirements and Emission Standards: Regulation No. 7, Part E, Sections IA through I.C and Section I.D. (State-Only conditions). Control Requirements: Part E, Sections LA through I.C Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No. 7, Part E, Sections LA through I.C, as specified below: Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non-selective catalyst and air fuel controller to reduce emission. Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.1.2. Emission Standards: Part E, Section I.D State-only requirements Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Max Engine Construction or Emission Standards in G/hp-hr HP Relocation Date NOx CO VOC 100<Hp<500 January 1, 2008 2.0 4.0 LO Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 8 January 1, 2011 1.0 2.0 0.7 500≤Hp July 1, 2007 2.0 4.0 1.0 July 1, 2010 1.0 2.0 0.7 The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.1.2. 2.1.3.3 NSPS for spark ignition internal combustion engines: 40 CFR 60, Subpart JJJJ A permanent replacement engine that is manufactured on or after 1/1/09 for emergency engines greater than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject 40 CFR 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.1.2. Any testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition 2.1.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.1.2. Note that under the provisions of Regulation No. 6. Part B, Section I.C., upon adoption of NSPS JJJJ into Regulation No. 6, Part A, an internal combustion engine relocated from outside of the State of Colorado into the State of Colorado shall meet the most recent emission standard required in NSPS JJJJ. Engines with a manufacturer's rated horsepower of less than 500 and with a relocation date no later than 5 years after the manufacture date are exempt from this requirement per Regulation No. 6, Part B, Section I.C.2.a Relocation is defined in Section I.C.1.a. However, as of Permit Issuance DATE the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS JJJJ will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. 2.1.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 9 MACT can serve as the testing required by this AOS under Condition 2.L2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.L2. 2.1.4 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 the AOS Facility Replacement Engine Periodic Monitoring? Subject to CAM? ID Fort Lupton Engines Fairbanks Morse MEP-12,2-Stroke Lean ELT-33 Burn(site-rated at 2046 HP)with Oxidizing No Catalyst ELT-101 YesL7042GS1,4-Stroke Rich Bunt Yes (1478 HP),with AFR and NSCR Caterpillar G3612TALE,4-Stroke Lean Burn ELT-38 (site-rated at 3550 HP)with Oxidizing No Catalyst Caterpillar G3612TALE,4-Stroke Lean Burn Portable Monitoring ELT-39 (site-rated at 3550 HP)with Oxidizing Quarterly No Catalyst EU-34R Waukesha L7042GS1,4-Stroke Rich Bunt Yes (1232 HP)with AFR and NSCR EU 103 Caterpillar G3616 LE,4-Stroke Lean Burn Yes (site-rated at 4262 HP)with AFR and NSCR EU 104 Caterpillar G3616 LE,4-Stroke Lean Burn Yes (4735 HP)with Oxidizing Catalyst ELT-32 YesL7042GS1,4-Stroke Rich Bunt Yes (1232 HP)with AFR and NSCR Platte Valley Engines S001/ Ajax DPC-540LE,Natural Gas Fired 2-Stroke ELT-281Lean Burn, Site-rated at 514 HP No Portable Monitoring S0021 Ajax DPC-540LE,Natural Gas Fired 2-Stroke Quarterly No EU-282 Lean Burn, Site-rated at 514 HP S003/ Ajax DPC-540LE,Natural Gas Fired 2-Stroke ELT-283 Lean Bunt, Site-rated at 514 HP No Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 10 Facility Replacement Engine Periodic Monitoring? Subject to CAM? ID S004/ Ajax DPC-540LE,Natural Gas Fired 2-Stroke ELT-284Lean Burn, Site-rated at 514 HP No S012/ Ajax DPC-2803LE,Natural Gas Fired 2- No EU-285 Stroke Lean Burn, Site-rated at 550 HP S015r Ajax DPC-2803LE,Natural Gas Fired 2- No ELT-286 Stroke Lean Burn, Site-rated at 550 HP S016r Ajax DPC-2803LE,Natural Gas Fired 2- No ELT-287 Stroke Lean Burn, Site-rated at 550 HP S017/ Ajax DPC-2803LE,Natural Gas Fired 2- No EU-288 Stroke Lean Burn, Site-rated at 550 HP S0181 Caterpillar G3516 TALE,Natural Gas Fired 4-Stroke Lean Burn Internal Combustion No ELT-290 Engine, Site-rated at 980 HP S019/ Caterpillar G3516 TALE,Natural Gas Fired 4-Stroke Lean Burn Internal Combustion No ELT-289 Engine, Site-rated at 980 HP 2.2 Temporary and Permanent Turbine Replacement (ver. 1/23/2013 Modified [Issuance DATE] to Address Replacement of Turbine Cores) The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of combustion turbines and turbine cores 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 turbine replacement or turbine core replacement performed in accordance with this AOS, and the permittee shall be allowed to perform such turbine replacement or turbine core replacement without applying for a revision to this permit or obtaining a new Construction Permit. Unless otherwise specified, this section applies to all turbines. Turbine cores are defined as a collection of parts comprised of the compressor, combustor, and turbine. The core can be removed from the turbine housing as one unit and shipped to offsite repair facilities. The turbine housing, fuel, air, lubrication, and exhaust gas systems remain onsite while the turbine core is undergoing repair. A replacement core can be installed and entire turbine system will operate in a normal manner. Replacements of turbine cores are addressed in Condition 2.2.2 below. The replacement of an entire stationary combustion turbine consists of all equipment, including but not limited to the turbine, the fuel, air, lubrication and exhaust gas systems, control systems (except emissions control equipment), heat recovery system, and any ancillary components and sub-components comprising any simple cycle stationary combustion turbine, any regenerative/recuperative cycle Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 11 stationary combustion turbine, any combined cycle combustion turbine, and any combined heat and power combustion turbine-based system (NSPS KKKK §60.4420) and is addressed in Condition 2.2.3 below. 2.2.1 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. 2.2.1.1 Replacement of stator blades, turbine nozzles, turbine buckets, fuel nozzles, combustion chambers, seals, and seal packings, provided that they are of the same design as the original. 2.2.1.2 Changes in the type or grade of fuel used, if the original gas turbine installation, fuel nozzles, etc. were designed for its use. 2.2.1.3 An increase in the hours of operation (unless limited by a permit condition). 2.2.1.4 Variations in operating loads within the engine design specification. 2.2.1.5 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. 2.2.2 Turbine Core Replacements 2.2.2.1 General Requirements for Turbine Core Replacements Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 12 a. The replacement core must be the same make and model to the core that is being replaced, and the replacement must not change the basic design parameter(s) of the turbine. b. The replacement of the core must not result in an increase in the emission rate to the atmosphere of any pollutant to which a standard applies, based on an hourly emission rate. c. The fixed capital cost of any replacement core must be less than 50 percent of the fixed capital cost that would be required to construct a comparable entirely new facility. 2.2.2.2 Monitoring and Recordkeeping Requirements for Turbine Core Replacements a. All turbines that have undergone core replacements 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. b. The owner or operator shall maintain a log on-site to contemporaneously record the dates for all turbine core replacements that occur during the term of this permit. The records shall include the manufacturer, model and serial number of the replacement core, as well as the information demonstrating that the replacement core meets the requirements of Condition 2.2.2.1 above. These records shall be made available to the Division upon request. 2.2.3 Turbine Replacements 2.2.3.1 General Requirements for Turbine Replacements The following AOS is incorporated into this permit in order to address the need to replace an entire 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 2.2.3.6. 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. Note that permanent replacement turbines are not allowed for this facility. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 13 2.2.3.2 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. 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 (1b/MMBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O1) 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 Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 14 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. 2.2.3.3 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. 2.2.3.4 Specific Requirements for Temporary Replacements The permittee may temporarily replace an existing turbine covered by this permit as specified in Condition 2.2.3.6 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. 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 as projected by the portable analyzer testing results 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). 2.2.3.5 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. 2.2.3.6 Allowable Replacements Table 1 — Turbine Replacements Allowed by the AOS for Facilities Located in a Designated Attainment/Maintenance or Non-Attainment Area Permitted Turbine Allowable Replacements' Point Make/Model Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 15 Solar Centaur Temporary replacement units may operate up to 270 days in any 12 S0201 EU-291 month period2 Model 40 4700 HP Permanent replacement units: not allowed (new permit or permit 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 2.2.3.1, 2.2.3.2 and 2.2.3.3, and with the specific requirements for temporary replacements in Condition 2.2.3.4. 3. Non-Attainment New Source Review (NANSR) and Prevention of Significant Deterioration (PSD) 3.1 This facility is categorized as a NANSR major stationary source (Potential to Emit of VOC and NOx 50 Tons/Year). Future modifications at this facility resulting in a significant net emissions increase (see Reg 3, Part D, Sections II.A.27 and 44) for VOC or NOx or a modification which is major by itself (Potential to Emit of > 50 TPY of either VOC or NOx) may result in the application of the NANSR review requirements. 3.2 This facility is categorized as a PSD major stationary source (Potential to Emit>250 Tons/year for NOx, CO, VOC). Future modifications at this facility resulting in a significant net emissions increase (see Reg 3, Part D, Sections II.A.27 and 44) or a modification which is major by itself(Potential to Emit >250 TPY) for any pollutant listed in Regulation No. 3, Part D, Section II.A.44 for which the area is in attainment or attainment/maintenance may result in the application of the PSD review requirements. 3.3 The following Operating/Construction Permits are associated with this facility for purposes of determining the applicability of the PSD & NANSR regulations: Kerr-McGee — Fort Lupton Gas Plant Operating Permit 95OPWE013 Construction Permits: 00WE0582, 00WE0583, 01WE0763, 07WE0366, 07WE0798, lOWE1071, 14WE0142 Kerr-McGee —Platte Valley Gas Plant Operating Permit 99OPWE207 Construction Permits: 12WE1277, 01WE0290, 02WE0927, 17WE0053 Kerr-McGee — Lancaster Gas Plant 12WE1492 Kerr-McGee Lancaster 3 Gas Plant 17WE1059 The Platte Valley Gas Plant Operating Permit (99OPWE207) is being consolidated into this operating permit with this permitting action. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 16 4. Accidental Release Prevention Program (112(r)) 4.1 Based upon the information provided by the applicant, this complex is subject to the provisions of the Accidental Release Prevention Program (Section 112(r) of the Federal Clean Air Act). The most recent plan was submitted to the EPA on August 17, 2016. 5. Compliance Assurance Monitoring (CAM) 5.1 The following emission points at this facility use a control device to achieve compliance with an emission limitation or standard to which they are subject and have pre-control emissions that exceed or are equivalent to the major source threshold. They are therefore subject to the provisions of the CAM program as set forth in 40 CFR Part 64, as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV: Point 030 (EU-32) for NOx and CO Point 017 (EU-101) for NOx and CO Point 025 (EU-34R) for NOx and CO Point 026 (EU-103) for CO Point 028 (EU-104) for CO Point 043 (S009) for VOC Point 073 (NG-TL-01) for VOC 6. Summary of Emission Units 6A The emissions units regulated by this permit are the following: Facility ID AIRS ID Description Pollution Control Ft Lupton Gas Plant Fairbanks Morse MEP-12 Natural Gas Fired 2-Stroke Lean EU 33 004 Burn Internal Combustion Engine, Site rated at 2046 HP, Oxidation Catalyst Serial No. 38D8780-3051S12. This unit is equipped with an Air/Fuel Ratio controller. Waukesha L7042GSI Natural Gas Fired 4-Stroke Rich Burn EU-101 017 Internal Combustion Engine,Rated at 1478 HP(manuf. Non-Selective maximum), Serial No. 288358. This unit is equipped with an Catalytic Reduction Air/Fuel Ratio controller. F001 018 Fugitive Emissions from Equipment Leaks Leak Detection and Repair EU 38 020 Caterpillar G3612TALE Natural Gas Fired 4-Stroke Lean Oxidation Catalyst Burn Internal Combustion Engine, Low NOx design, Site Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 17 Facility ID AIRS ID Description Pollution Control rated at 3550 HP, Serial No. 1YG00238. Caterpillar G3612TALE Natural Gas Fired 4-Stroke Lean EU-39 Burn Internal Combustion Engine, Low NOx design, Site Oxidation Catalyst rated at 3550 HP, Serial No. 1YG00239. Waukesha L7042GSI Natural Gas Fired 4-Stroke Rich Burn EU 34R 025 Internal Combustion Engine,Rated at 1232 HP(manuf. Non-Selective maximum), Serial No. 250451. This unit is equipped with an Catalytic Reduction Air/Fuel Ratio controller. Caterpillar G3616 TALE Natural Gas Fired 4-Stroke Lean EU-103 026 Burn Internal Combustion Engine, Site rated at 4262 HP, Oxidation Catalyst Serial No.BLB00452. This unit is equipped with an Air/Fuel Ratio controller. Caterpillar G3616 LE Natural Gas Fired 4-Stroke Lean Burn Internal Combustion Engine,Rated at 4735 HP(manuf. EU-104 028 maximum), Serial No.BLB00539 This unit is equipped with Oxidation Catalyst an Air/Fuel Ratio controller. Waukesha L7042GSI Natural Gas Fired 4-Stroke Rich Burn EU-32 030 Internal Combustion Engine,Rated at 1232 HP, Serial No. Non-Selective 288792. This unit is equipped with an Air/Fuel Ratio Catalytic Reduction controller. One(1) John Zink 65' Air-Assisted Process Flare used to control emissions from process equipment blowdowns F-4 070 associated with maintenance activities, compressor NA blowdowns, and venting such as for pressure relief valves or plant shutdowns. Serial No. 9148687 Insignificant Engines with Permit Conditions at Fort Lupton One(1) Caterpillar,Model C 18 DITA, Serial Number EKW01075, diesel-fired, turbo-charged,reciprocating GEN2 NA internal combustion engine, site rated at 900 horsepower at None 1800 RPM.This unit is used for emergency power generation. Platte Valley Gas Plant S001/ Ajax DPC-540LE,Natural Gas Fired 2-Stroke Lean Burn EU-281 038 Internal Combustion Engine, Site-rated at 514 HP, SN: 83891 None S002/ 039 Ajax DPC-540LE,Natural Gas Fired 2-Stroke Lean Burn None EU-282 Internal Combustion Engine, Site-rated at 514 HP, SN: 83892 S003/ Ajax DPC-540LE,Natural Gas Fired 2-Stroke Lean Burn EU-285 040 Internal Combustion Engine, Site-rated at 514 HP, SN: 83889 None S004/ Ajax DPC-540LE,Natural Gas Fired 2-Stroke Lean Burn EU-284 041 Internal Combustion Engine, Site-rated at 514 HP, SN: 83890 None S007 042 Platte Valley Plant Fugitive Emissions Leak Detection and Repair One(1)natural gas liquids(NGL) amine sweetening unit Zeeco Vertical S009 043 with a design capacity of 15,000 BBL/day. The amine Forced Air Thermal solution is a specific formulated amine consisting of any Oxidizer(SN Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 18 Facility ID AIRS ID Description Pollution Control combination of MEA,DEA, TEA,MDEA, and DGA. This 15838), 99% system includes a NGL/amine contactor, a flash tank, a control efficiency. natural gas fired regeneration reboiler(AIRS point 045)and Flash emissions are two(2) electric amine recirculation pumps with a total design routed to the capacity of 100 gallons per minute. Thermal oxidizer burner process flare(point is rated at 5.0 MMBtu/hr. 021) and still vent emissions to the atmosphere during thermal oxidizer downtime. S012/ Ajax DPC-2803LE,Natural Gas Fired 2-Stroke Lean Burn EU-283 044 Internal Combustion Engine, Site-rated at 550 HP, SN: 84286 None S013 045 Perry Gas Processors, Inc.Natural Gas Fired Amine Unit None Heater,Design Rated at 10.7 MMBtu/hr, SN: 2885-0 S014 046 Born, Inc Natural Gas Fired Hot Oil Heater,Design Rated at None 32 MMBtu/hr, SN: 1963. S015/ Ajax DPC-2803LE,Natural Gas Fired 2-Stroke Lean Burn EU-286 047 Internal Combustion Engine, Site-rated at 550 HP, SN: 84308 None S016/ Ajax DPC-2803LE,Natural Gas Fired 2-Stroke Lean Burn EU-287 048 Internal Combustion Engine, Site-rated at 550 HP, SN: 84288 None S017/ Ajax DPC-2803LE,Natural Gas Fired 2-Stroke Lean Burn EU-288 049 Internal Combustion Engine, Site-rated at 550 HP, SN: 84287 None S018/ Caterpillar G3516 TALE,Natural Gas Fired 4-Stroke Lean 050 Burn Internal Combustion Engine, Site-rated at 980 HP Oxidation Catalyst EU-290 SN: 4EK03529 S019/ Caterpillar G3516 TALE,Natural Gas Fired 4-Stroke Lean 051 Burn Internal Combustion Engine, Site-rated at 980 HP Oxidation Catalyst EU-289 SN: 4EK02747 S020/ Solar Centaur 40, Low-NOx, Natural Gas Fired Internal 052 Combustion Turbine Engine,Nominally Rated at 4,700 HP, None EU-291 SN: DCC0208 S021 053 Flare Industries Air-Assisted Process Flare Air Assisted, Elevated Flare NG-TL-01 01 073 One(1)Truck Loadout of Pressurized Natural Gasoline Enclosed Flare Liquids Insignificant Engines with Permit Conditions at Platte Valley PLV PLC One(1)Mitsubishi Model 4G63S4M natural gas or propane GEN 054 fired 4SLB engine, 80 HP, SN: SKM5668;part of a Generac None Generator package used for emergency electrical generation S022 NA One(1) John Deere 115 HP diesel-fired engine,powering a None Grimmer Schmidt backup air compressor Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 19 SECTION II - Specific Permit Terms — Ft Lupton 1. EU-33: One (1) Fairbanks Morse MEP-12, 2046 HP engine (AIRS point 004) Permit Limitations Compliance Monitoring Parameter Condition Long Emission Factor Number Short Term Term Method Interval r 1.36 lb/MMBtu Recordkeeping Monthly NOx 55.0 lbs/hr 90.2 tons/yr and Calculation 1.1 CO 18.1 tons/yr 0.273 lb/MMBtu Portable Monitoring Quarterly PM 3.8 ton/yr 0.056 lb/MMBtu PM10 1.2 3.8 ton/yr 0.056 lb/MMBtu Recordkeeping Monthly and Calculation VOC 17.9 tons/yr 0.27 lb/MMBtu Individual Natural Gas 1.3 131.8 MMscf/yr Engine Fuel Monthly Consumption Meter ASTM or other Btu Content of 1 4 Division Semi-annually Natural Gas Approved Method Hours of Operation 1.5 Recordkeeping Monthly Not to exceed 20%, except as provided for below For Certain Operational Only Natural Opacity 1.6 Activities -Not to Exceed 30% Fuel Restriction Gas is Used as for a Period or Periods Fuel Aggregating More than Six(6) Minutes in any 60 Consecutive Minutes Colorado Regulation No. 7, 1.7 See Condition 1.7 Part E Colorado Regulation No. 7, 1.8 See Condition 1.8 Part D, Section II Engine and Catalyst Operation, Maintenance and 1.9 See Condition 1.9 Parameter Monitoring 1.1 Emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO) shall not exceed the limitations listed in Summary Table 1 above (Colorado Construction Permit 11WE730-1, as modified under the Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 20 provisions of Section I, Condition 1.3). Compliance with the emission limitations shall be monitored as follows: 1.1.1 Except as provided below, the emission factors listed in Summary Table 1 above have been approved by the Division and shall be used to calculate emissions from this engine as follows: Monthly emissions shall be calculated, by the end of the subsequent month, using the emission factors in Summary Table 1 above, the monthly natural gas consumption (required by Condition 1.3) and the Btu content of the natural gas (required by Condition 1.4) in the equation below: tons/mo =jEF (lb/MMBtu)x fuel use (MMscf/mo)x heat content of fuel (MMBtu/MMscf)] 2000 lb/ton Monthly emissions 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. Records of calculations shall be kept in a log to be made available to the Division upon request. If the results of the portable analyzer testing conducted under the provisions of Condition 1.1.2 show that either the NOx or CO emission rates/factors are greater than those listed above, 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 rates/factors within 60 days of the completion of the test. 1.1.2 Portable Monitoring shall be conducted quarterly in accordance with the requirements in SECTION IV - 1. 1.1.3 Compliance with the hourly NOx emission limit shall be demonstrated by dividing the monthly calculated emissions by the number of run-time hours in the month to obtain an hourly average. 1.2 Particulate Matter (PM), Particulate Matter less than 10 microns (PM10), and Volatile Organic Compound (VOC) emissions shall not exceed the limitations listed in Summary Table 1 above (Colorado Construction Permit 11WE730-1 as modified under the provisions of Section I, Condition 1.3). Monthly emissions shall be calculated, by the end of the subsequent month, using the emission factors in Summary Table 1 above, the monthly natural gas consumption (required by Condition 1.3), and the Btu content of the natural gas (required by Condition 1.4) in the equation below: tons/mo =jEF (lb/MMBtu)x fuel use (MMscf/mo)x heat content of fuel (MMBtu/MMscf)] 2000 lb/ton Monthly emissions shall be used in a twelve month rolling total to monitor compliance with the annual emission limitation. Each month, a new twelve month total shall be calculated using the previous twelve Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 21 months data. Records of calculations shall be kept in a log to be made available to the Division upon request. 13 Natural gas consumption shall not exceed the limitation shown in Summary Table 1 above. (Colorado Construction Permit 11WE730-1). Natural gas consumption shall be recorded monthly using the existing individual engine fuel meter. Monthly natural gas consumption 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. Records of calculations shall be kept in a log to be made available to the Division upon request. 1A The Btu content of the natural gas used to fuel this engine shall be verified semi-annually using the appropriate ASTM Methods or equivalent, if approved in advance by the Division. The Btu content of the natural gas shall be based on the lower heating value of the fuel. Calculations of monthly emissions shall be made using the heat content derived from the most recent required analysis. 1.5 Hours of operation shall be monitored monthly and recorded and maintained to be available to the Division upon request. Monthly hours of operation shall be used in a running total for each annual compliance period. The hours of operation shall be used to determine if portable monitoring is required as specified in SECTION IV - 1. 1.6 The following opacity requirements apply: 1.6.1 Except as provided for in Condition 1.6.2 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section II.A.1). 1.6.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, process modifications, or adjustment or occasional cleaning of control equipment 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 opacity requirements of this Condition 1.6 shall be presumed since only natural gas is permitted to be used as fuel in this engine. L7 This engine is subject to the requirements of Colorado Regulation No. 7, Part E, "Combustion Equipment and Major Source RACT", including, but not limited to, the following: [The requirements below reflect the current rule language as of the revisions to 5 CCR 1001-9 Colorado Regulation No. 7 published in the Colorado Register on 01/25/2020 and effective on 02/14/2020. However, if revisions to this rule are published at a later date, the owner or operator is subject to the requirements contained in the revised version of Colorado Regulation No. 7.] 1.7.1 The owner or operator of any natural gas-fired stationary or portable reciprocating internal combustion engine with a manufacturer's design rate greater than 500 horsepower commencing operations in the 8-hour Ozone Control Area on or after June 1, 2004 shall Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 22 employ air pollution control technology to control emissions, as provided in Section I.B (Condition 1.7.3). (Colorado Regulation No. 7, Part E, Section I.A.1) 1.7.2 The owner or operator of any existing natural gas-fired stationary or portable reciprocating internal combustion engine with a manufacturer's design rate greater than 500 horsepower, which existing engine was operating in the 8-hour Ozone Control Area prior to June 1, 2004, shall employ air pollution control technology on and after May 1, 2005, as provided in Section I.B (Condition 1.7.3). (Colorado Regulation No. 7, Part E, Section I.A.2) 1.7.3 Air pollution control technology requirements: 1.7.3.1 For lean burn reciprocating internal combustion engines, an oxidation catalyst shall be required. A lean burn reciprocating internal combustion engine is one with a normal exhaust oxygen concentration of 2% by volume, or greater. (Colorado Regulation No. 7, Part E, Section I.B.2) 1.7.3.2 The emission control equipment required by this Condition 1.7.3 shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. (Colorado Regulation No. 7, Part E, Section I.B.3) [Note that the following requirements of Colorado Regulation No. 7, Part E, Sections ILA.6, and ILA.7 apply to specific combustion equipment with uncontrolled actual emissions of NOx equal to or greater than five (5) tons per year, as specified in Part E, Section ILA.6.a, therefore, applicability may vary from year to yeas] Combustion Process Adjustment (Part E, Section ILA.6) 1.7.4 The owner or operator of a stationary internal combustion engine must conduct the following inspections and adjustments, as applicable (II.A.6.b.(iv)): 1.7.4.1 Change oil and filters as necessary. (II.A.6.b.(iv)(A)) 1.7.4.2 Inspect air cleaners, fuel filters, hoses, and belts and clean or replace as necessary. (II.A.6.b.(iv)(B)) 1.7.4.3 Inspect spark plugs and replace as necessary. (II.A.6.b.(iv)(C)) 1.7.5 The owner or operator must operate and maintain the stationary internal combustion engine consistent with manufacturer's specifications, if available, or good engineering and maintenance practices. (II.A.6.b.(vii)) 1.7.6 The owner or operator of stationary reciprocating internal combustion engines with uncontrolled actual emissions of NOx equal to or greater than five (5) tons per year that existed at major sources of NOx (greater than or equal to 100 tpy NOx) as of June 3, 2016, must conduct the initial combustion process adjustment by April 1, 2017. An owner or operator may rely on a combustion process adjustment conducted in accordance with Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 23 applicable requirements and schedule of a New Source Performance Standard in 40 CFR Part 60 (November 17, 2016) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (November 17, 2016) to satisfy the requirement to conduct an initial combustion process adjustment by April 1, 2017. (II.A.6.b.(viii)(A)) 1.7.7 The owner or operator must conduct subsequent combustion process adjustments at least once every twelve (12) months after the initial combustion adjustment, or on the applicable schedule according to Sections II.A.6.c.(i). or II.A.6.c.(ii) (Conditions 1.7.8.1 or 1.7.8.2). L7.8 As an alternative to the requirements described in Sections II.A.6.b.(iv), II.A.6.b.(vii) and II.A.6.b.(viii) (Conditions 1.7.4 through 1.7.7) (II.A.6.c.): L7.8.1 The owner or operator may conduct the combustion process adjustment according to the manufacturer recommended procedures and schedule (II.A.6.c.(i)); or L7.8.2 The owner or operator of combustion equipment that is subject to and required to conduct a periodic tune-up or combustion adjustment by the applicable requirements of a New Source Performance Standard in 40 CFR Part 60 (December 19, 2019) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (December 19, 2019) may conduct tune-ups or adjustments according to the schedule and procedures of the applicable requirements of 40 CFR Part 60 (December 19, 2019) or 40 CFR Part 63 (December 19, 2019). (II.A.6.c.(ii)) Recordkeeping (ILA.7) 1.7.9 The following records must be kept for a period of five years and made available to the Division upon request (II.A.7): 1.7.10 For stationary combustion equipment subject to the combustion process adjustment requirements in Section II.A.6 (Conditions 1.7.4 through 1.7.8), the following recordkeeping requirements apply (II.A.7.f.): 1.7.11 The owner or operator must create a record once every calendar year identifying the combustion equipment at the facility subject to Section ILA and including for each combustion equipment (II.A.7.f.(i)): 1.7.11.1 The date of the adjustment(II.A.7.f.(i)(A)); 1.7.11.2 Whether the combustion process adjustment under Section II.A.6.b.(iv) (Condition 1.7.4) was followed, and what procedures were performed (II.A.7.f.(i)(B)); 1.7.11.3 Whether a combustion process adjustment under Sections II.A.6.c.(i) and II.A.6.c.(ii) (Conditions 1.7.8.1 and 1.7.8.2) was followed, what procedures were Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 24 performed, and what New Source Performance Standard or National Emission Standard for Hazardous Air Pollutants applied, if any (II.A.7.f.(i)(C)); and L7.11.4 A description of any corrective action taken. (II.A.7.f.(i)(D)) L7.11.5 If the owner or operator conducts the combustion process adjustment according to the manufacturer recommended procedures and schedule and the manufacturer specifies a combustion process adjustment on an operation time schedule, the hours of operation. (II.A.7.f.(i)(E)) 1.7.12 The owner or operator must retain manufacturer recommended procedures, specifications, and maintenance schedule if utilized under II.A.6.c.(i) (Conditions 1.7.8.1) for the life of the equipment. (II.A.7.f.(ii)) 1.7.13 As an alternative to the requirements described in Section II.A.7.f.(i) (Condition 1.7.11), the owner or operator may comply with applicable recordkeeping requirements related to combustion process adjustments conducted according to a New Source Performance Standard in 40 CFR Part 60 (November 17, 2016) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (November 17, 2016). (II.A.7.f.(iii)) Note: 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. (Section VI Condition 22.b) 1.8 [State-Only Enforceable] This engine is subject to the requirements of Colorado Regulation No. 7, Part D, Section II, "Statewide Controls for Oil and Gas Operations", including, but not limited to, the following: [The requirements below reflect the current rule language as of the revisions to 5 CCR 1001-9 Colorado Regulation No. 7 published in the Colorado Register on 01/25/2020 and effective on 02/14/2020. However, if revisions to this rule are published at a later date, the owner or operator is subject to the requirements contained in the revised version of Colorado Regulation No. 7.] 1.8.1 At all times, including periods of start-up and shutdown, the facility and air pollution control equipment must be maintained and operated in a manner consistent with good air pollution control practices for minimizing emissions. Determination of whether or not acceptable operation and maintenance procedures are being used will be based on information available to the Division, which may include, but is not limited to, monitoring results, opacity observations, review of operation and maintenance procedures, and inspection of the source. (Colorado Regulation No. 7, Part D, Section II.B.1.b) 1.8.2 All air pollution control equipment must be operated and maintained pursuant to the manufacturing specifications or equivalent to the extent practicable, and consistent with technological limitations and good engineering and maintenance practices. The owner or operator must keep manufacturer specifications or equivalent on file. In addition, all such air pollution control equipment must be adequately designed and sized to achieve the control Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 25 efficiency rates and to handle reasonably foreseeable fluctuations in emissions of VOCs and other hydrocarbons during normal operations. (Colorado Regulation No. 7, Part D, Section II.B.2.a) 1.9 This engine shall be equipped with an oxidation catalyst for emission control. The oxidation catalyst shall be operated and maintained according to procedures necessary to reduce uncontrolled emissions of carbon monoxide from the unit to the emission level listed in Summary Table 1 above. (Colorado Construction Permit 11WE730-1). 1.9.1 This engine and associated oxidation catalyst shall be operated and maintained in accordance with internal operating and maintenance standards, which shall consider manufacturer's recommendations and good air pollution control practices for minimizing emissions, at all times, including periods of start-up, shut-down and malfunction. These internal operating and maintenance standards shall be kept on site and made available to the Division upon request. 1.9.2 Parameters associated with the oxidizing catalyst unit shall be monitored as follows: 1.9.2.1 Pressure drop across the catalyst shall be monitored and recorded monthly. The pressure drop shall not change by more than 2 inches of water column from the baseline value established by the source when the engine is operating at maximum achievable load, plus or minus 10%. This baseline pressure drop shall be established during portable monitoring events, required by Condition 1.1.2. If the pressure drop is outside of this range, appropriate maintenance shall be performed to bring the pressure within the current established range. a. In lieu of performing maintenance to bring the pressure within the established range, a portable analyzer test performed according to the provisions of SECTION IV - 1, which demonstrates compliance with the emission limits of Conditions 1.1, may be used to establish a new baseline pressure drop. b. For a new, cleaned, or reconditioned catalyst on an existing engine, the new pressure drop baseline shall be established within the first 7 days of engine/catalyst operation. 1.9.2.2 The catalyst inlet temperature shall be monitored and recorded daily and kept within the range of 450°F to 1350°F. 1.9.2.3 When portable monitoring is scheduled, the above parameters in Conditions 1.9.2.1 and 1.9.2.2 shall be monitored and recorded during the portable monitoring event. 1.9.2.4 The oxygen content in the engine exhaust gas shall be monitored and recorded during each portable monitoring event required by Condition 1.1.2. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 26 19.3 Records of all data and maintenance performed associated with the engine and catalyst operation and parameter monitoring of this Condition 1.9 shall be maintained for Division inspection upon request. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 27 2. F001: Fugitive Emissions from Equipment Leaks (AIRS point 018) Permit Monitoring Parameter Condition Limitations Number Emission Factor Method Interval By Component Type VOC 26.92 tons/yr —EPA Protocol for Recordkeeping and Monthly Equipment Leak Calculation 2.1 Estimates Gas/Liquids EPA/Division Semi-annually, Analysis Approved Methods See Condition 2.1 Colorado Regulation No. 7, 2.2 See Condition 2.2 Part D, Section I 40 CFR 60 2.3 See Condition 2.3 Subpart 0000a 40 CFR 60 Subpart A 2.4 See Condition 2.4 General Provisions 40 CFR 63 2.5 See Condition 2.5 Subpart MI 40 CFR 63 Subpart A 2.6 See Condition 2.6 General Provisions 2.1 Total VOC emissions from equipment leaks shall not exceed the limitation in Summary Table 2 above (Colorado Construction Permit 00WE0583 as modified under the provisions of Colorado Regulation No. 3, Part C, Section III.B.7). Emissions shall be calculated using the emission factors and equations listed below. Emission Factors for individual types of components in lb/component-hr from the reference Protocol for Equipment Leak Emission Estimates, EPA, November 1995, EPA-453/R-95-017, Table 2-4. The most appropriate emission factors for the EPA document shall be used. These emission factors are fixed until changed by established permit modification procedures. Emission Factors (lb/component-hr) Component Gas Service Light Oil Service Heavy Oil Service Valves 9.92 x 10-3 5.51 x 10-3 1.85 x 10-5 Connectors 4.41 x 10-4 4.63 x 10-4 1.65 x 10-5 Flanges 8.60 x 10-4 2.43 x 10-4 8.60 x 10-7 Pump Seals 5.29 x 10-3 2.87 x 10 1.13 x 10-3 (1) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 28 Open-Ended 4.41 X 10-3 3.09 X 10-3 3.09 X 10-4 Lines Other' 1.94 x 10 L65 X 10 7.05 X 10-5 'Emission factor for pump seals in heavy oil service proposed by Kerr-McGee. This represents a conservative estimate since no emission factor for this component and service is included in Table 2-4 of EPA-453/R-95-017. 'Other should be applied for any equipment type other than connectors, flanges, open-ended lines, pumps, or valves Monthly determination of VOC emissions shall be calculated by the end of the subsequent month using the appropriate emission factors from the table above, the control factors as specified below, the most recent extended gas and liquids analyses (as required by Condition 2.1.1), and the values from the most recent component count (as required by Condition 2.1.2) in the equation below: hr days 1 ton Emissions (tons/month) = CC x EF x 24 (—� x x x x Control Factor x day month 200010 Where: CC = component count,quantity EF = emission factor,lb/component * hr (per component and service type) x = VOC content instream,mass fraction Control Factor = 1 — (Control Effectiveness (—% )) loo The source shall be allowed to use the following values for control effectiveness (for only the equipment type and service referenced) when the Leak Detection and Repair program of Condition 2.3 is demonstrated. Equipment Type and Service Control Effectiveness (%) Valves — gas service 96 Valves light liquid service 95 Pumps — light liquid service 88 Connectors/Flanges all services 81 The total fugitive VOC emissions shall be the sum of emissions for each component type. Monthly VOC emissions 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. Records of calculations shall be maintained and made available to the Division upon request. 2.1.1 Site specific extended natural gas and natural gas liquids analyses shall be performed quarterly using ASTM methods or equivalent, if approved in advance by the Division, for each process stream representative of those used to develop the emissions limits for fugitive emissions associated with this AIRS point, as listed in the table below. Frequency of extended analyses shall move to semi-annually after the first year, then to annually after the second year if the VOC weight percent of the stream remains consistently at or below the Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 29 value listed. Frequency will revert back to quarterly if any of the VOC concentrations exceed the listed values. The VOC content from the most recent analyses shall be used to calculate emissions according to this Condition 2.1. Representative Fluid VOC Composition(wt%) Inlet Gas 25.0 Fuel Gas 9 Residue Gas 9 C3+ 100 NGL 98.0 Condensate 100 Methanol 100 2.1.2 A running tally shall be kept of all additions and subtractions to the component count. The most recent count shall be used for emission calculations and compliance purposes. Records of the component count running tally shall be kept and made available for Division review upon request. 2.2 This source is subject to the following requirements of Colorado Regulation No. 7, Part D, Section I, "Volatile Organic Compound Emissions from Oil and Gas Operations". [The requirements below reflect the current rule language as of the revisions to 5 CCR 1001-9 Colorado Regulation No. 7 published in the Colorado Register on 01/25/2020 and effective on 02/14/2020. However, if revisions to this rule are published at a later date, the owner or operator is subject to the requirements contained in the revised version of Colorado Regulation No. 7.] 2.2.1 For fugitive volatile organic compound emissions from leaking equipment, the leak detection and repair(LDAR) program as provided at 40 CFR Part 60, Subpart OOOO (July 1, 2017) applies, regardless of the date of construction of the affected facility, unless subject to the LDAR program provided at 40 CFR Part 60, Subpart 0000a (July 1, 2017). (Colorado Regulation No. 7, Part D, Section I.G.1) 2.2.2 All hydrocarbon liquids and produced water collection, storage, processing and handling operations, regardless of size, must be designed, operated and maintained so as to minimize emission of volatile organic compounds to the atmosphere to the maximum extent practicable. (Colorado Regulation No. 7, Part D, Section I.C.1.b) 2.3 These sources of fugitive emissions from equipment leaks are subject to the requirements in 40 CFR 60 Subpart OOOOa, "Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After September 18, 2015", as specified in SECTION IV - 3. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 30 2.4 These sources of fugitive emissions from equipment leaks are subject to the requirements in 40 CFR Part 60 Subpart A, "General Provisions"(as adopted by reference in Colorado Regulation No. 6, Part A, Subpart A), as specified in SECTION IV - 10. 2.5 These sources of fugitive emissions from equipment leaks are subject to the requirements in 40 CFR 63, Subpart HH, "National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities", as adopted by reference in Colorado Regulation No. 8, Part E, Section III, Subpart HH, as specified in SECTION IV - 2. Note: The conditions of 40 CFR 63 Subpart HH referenced here include periodic reporting requirements for sources that are subject to and controlled under the requirements specified in 40 CFR 60 Subpart OOOO. The equipment leak provisions of, 63.769 of Subpart HH do not apply to ancillary equipment subject to and controlled under 40 CFR 60 Subpart OOOO, except that periodic reports must be submitted as specified in §63.775(e), per§63.769(b). Per 40 CFR, Part 60, Subpart OOOO, a source is deemed to be in compliance with Subpart OOOO if the source is in compliance with all applicable provisions of 40 CFR, Part 60, Subpart 0000a (§60.5370(d). 2.6 These sources of fugitive emissions from equipment leaks are subject to the requirements in 40 CFR 63, Subpart A, "General Provisions", as adopted by reference in Colorado Regulation No. 8, Part E, Section I, Subpart A, as specified in SECTION IV - 11. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 31 3. EU-32: One (1) Waukesha L7042GSI, 1232 HP engine (AIRS point 030) Permit Monitoring Parameter Condition Limitations Number Emission Factor Method Interval NOx 23.0 tons/yr 0.689 lb/MMBtu Recordkeeping 3.1 CO 50.6 tons/yr 1.52 lb/MMBtu and Calculation Monthly VOC 3.2 9.20 tons/yr 0.275 lb/MMBtu 12 month rolling Natural Gas 3.3 73.54 MMscf/yr Individual Engine Monthly Consumption Fuel Meter Btu Content of ASTM or other Natural Gas 3.4 Division Semi-annually Approved Method Hours of Operation 3.5 Recordkeeping Monthly Not to exceed 20%, except as provided for below For Certain Operational Only Natural Opacity 3.6 Activities -Not to Exceed Fuel Restriction Gas is Used as 30%for a Period or Periods Fuel Aggregating More than Six (6)Minutes in any 60 Consecutive Minutes Colorado Regulation 3.7 See Condition 3.7 No. 7,Part E Engine and Catalyst Operation, 3.8 See Condition 3.8 Maintenance and Parameter Monitoring Limit concentration of formaldehyde in the 40 CFR 63 Subpart stationary RICE exhaust to ZZZZ 3.9 350 ppbvd or less at 15 See Condition 3.9 percent O2; or Reduce formaldehyde emissions by 76%or more. 40 CFR 63 Subpart A 3.10 See Condition 3.10 —General Provisions Compliance Assurance Monitoring 3.11 See Condition 3.11 (CAM) 3.1 Emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO) shall not exceed the limitations listed in Summary Table 3 above (Colorado Construction Permit 97WE0180, as modified under the provisions of Section I, Condition 1.3). Compliance with the emission limitations shall be monitored as follows: Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 32 3.1.1 Except as provided below, the emission factors listed in Summary Table 3 above have been approved by the Division and shall be used to calculate emissions from this engine as follows: Monthly emissions shall be calculated, by the end of the subsequent month, using the emission factors in Summary Table 3 above, the monthly natural gas consumption (required by Condition 3.3) and the Btu content of the natural gas (required by Condition 3.4) in the equation below: tons/mo =jEF (lb/MMBtu)x fuel use (MMscf/mo) x heat content of fuel(MMBtu/MMscf)J 2000 lb/ton Monthly emissions 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. Records of calculations shall be kept in a log to be made available to the Division upon request. If the results of the portable analyzer testing conducted under the provisions of Condition 3.1.2 show that either the NOx or CO emission rates/factors are greater than those listed above, 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 rates/factors within 60 days of the completion of the test. 3.1.2 Portable Monitoring shall be conducted quarterly in accordance with the requirements in SECTION IV - 1. 3.2 Volatile Organic Compound (VOC) emissions shall not exceed the limitation listed in Summary Table 3 above (Construction Permit 97WE0180, as modified under the provisions of Section I, Condition 1.3). Monthly emissions shall be calculated, by the end of the subsequent month, using the emission factors in Summary Table 3 above, the monthly natural gas consumption (required by Condition 3.3), and the Btu content of the natural gas (required by Condition 3.4) in the equation below: tons/mo = [EF (lb/MMBtu) x fuel use (MMscf/mo) x heat content of fuel(MMBtu/MMscf)] 2000 lb/ton Monthly emissions shall be used in a twelve month rolling total 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. 3.3 Natural gas consumption shall not exceed the limitation shown in Summary Table 3 above. (Colorado Construction Permit 97WE0180). Natural gas consumption shall be recorded monthly using the existing individual engine fuel meter. Monthly natural gas consumption 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. Records of calculations shall be kept in a log to be made available to the Division upon request. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 33 3.4 The Btu content of the natural gas used to fuel this engine shall be verified semi-annually using the appropriate ASTM Methods or equivalent, if approved in advance by the Division. The Btu content of the natural gas shall be based on the lower heating value of the fuel. Calculations of monthly emissions shall be made using the heat content derived from the most recent required analysis. 3.5 Hours of operation for this engine shall be monitored monthly and recorded and maintained to be available to the Division upon request. Monthly hours of operation shall be used in a running total for each annual compliance period. The hours of operation shall be used to determine if portable monitoring is required as specified in SECTION IV - 1. 3.6 The following opacity requirements apply to this engine: 3.6.1 Except as provided for in Condition 3.6.2 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section 3.6.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, process modifications, or adjustment or occasional cleaning of control equipment 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 opacity requirements of this Condition 3.6 shall be presumed since only natural gas is permitted to be used as fuel in these engines. 3.7 This engine is subject to the requirements of Colorado Regulation No. 7, Part E, "Combustion Equipment and Major Source RACT", including, but not limited to, the following: [The requirements below reflect the current rule language as of the revisions to 5 CCR 1001-9 Colorado Regulation No. 7 published in the Colorado Register on 01/25/2020 and effective on 02/14/2020. However, if revisions to this rule are published at a later date, the owner or operator is subject to the requirements contained in the revised version of Colorado Regulation No. 7.] 3.7.1 The owner or operator of any natural gas-fired stationary or portable reciprocating internal combustion engine with a manufacturer's design rate greater than 500 horsepower commencing operations in the 8-hour Ozone Control Area on or after June 1, 2004 shall employ air pollution control technology to control emissions, as provided in Section I.B (Condition 3.7.3). (Colorado Regulation No. 7, Part E, Section I.A.1) 3.7.2 The owner or operator of any existing natural gas-fired stationary or portable reciprocating internal combustion engine with a manufacturer's design rate greater than 500 horsepower, which existing engine was operating in the 8-hour Ozone Control Area prior to June 1, 2004, shall employ air pollution control technology on and after May 1, 2005, as provided in Section I.B (Condition 3.7.3). (Colorado Regulation No. 7, Part E, Section I.A.2) 3.7.3 Air pollution control technology requirements: Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 34 3.7.3.1 For rich burn reciprocating internal combustion engines, a non-selective catalyst reduction and an air fuel controller shall be required. A rich burn reciprocating internal combustion engine is one with a normal exhaust oxygen concentration of less than 2% by volume. (Colorado Regulation No. 7, Part E, Section I.B.1) 3.7.3.2 The emission control equipment required by this Condition 3.7.3 shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. (Colorado Regulation No. 7, Part E, Section I.B.3) [Note that the following requirements of Colorado Regulation No. 7, Part E, Sections II.A.6 and ILA.7 apply to specific combustion equipment with uncontrolled actual emissions of NOx equal to or greater than five (S) tons per year, as specified in Part E, Section II.A.6.a, therefore, applicability may vary from year to year] Combustion Process Adjustment (Part E, Section II.A.6) 3.7.4 The owner or operator of a stationary internal combustion engine must conduct the following inspections and adjustments, as applicable (II.A.6.b.(iv)): 3.7.4.1 Change oil and filters as necessary. (II.A.6.b.(iv)(A)) 3.7.4.2 Inspect air cleaners, fuel filters, hoses, and belts and clean or replace as necessary. (II.A.6.b.(iv)(B)) 3.7.4.3 Inspect spark plugs and replace as necessary. (II.A.6.b.(iv)(C)) 3.7.5 The owner or operator must operate and maintain the stationary internal combustion engine consistent with manufacturer's specifications, if available, or good engineering and maintenance practices. (II.A.6.b.(vii)) 3.7.6 The owner or operator of stationary reciprocating internal combustion engines with uncontrolled actual emissions of NOx equal to or greater than five (5) tons per year that existed at major sources of NOx (greater than or equal to 100 tpy NOx) as of June 3, 2016, must conduct the initial combustion process adjustment by April 1, 2017. An owner or operator may rely on a combustion process adjustment conducted in accordance with applicable requirements and schedule of a New Source Performance Standard in 40 CFR Part 60 (November 17, 2016) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (November 17, 2016) to satisfy the requirement to conduct an initial combustion process adjustment by April 1, 2017. (II.A.6.b.(viii)(A)) 3.7.7 The owner or operator must conduct subsequent combustion process adjustments at least once every twelve (12) months after the initial combustion adjustment, or on the applicable schedule according to Sections II.A.6.c.(i). or II.A.6.c.(ii) (Conditions 3.7.8.1 or 3.7.8.2). Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 35 3.7.8 As an alternative to the requirements described in Sections II.A.6.b.(iv), II.A.6.b.(vii) and II.A.6.b.(viii) (Conditions 3.7.4 through 3.7.7) (II.A.6.c.): 3.7.8.1 The owner or operator may conduct the combustion process adjustment according to the manufacturer recommended procedures and schedule (II.A.6.c.(i)); or 3.7.8.2 The owner or operator of combustion equipment that is subject to and required to conduct a period tune-up or combustion adjustment by the applicable requirements of a New Source Performance Standard in 40 CFR Part 60 (December 19, 2019) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (December 19, 2019) may conduct tune-ups or adjustments according to the schedule and procedures of the applicable requirements of 40 CFR Part 60 (December 19, 2019) or 40 CFR Part 63 (December 19, 2019). (II.A.6.c.(ii)) Recordkeeping (ILA.7) 3.7.9 The following records must be kept for a period of five years and made available to the Division upon request (II.A.7): 3.7.10 For stationary combustion equipment subject to the combustion process adjustment requirements in Section II.A.6 (Conditions 3.7.4 through 3.7.8), the following recordkeeping requirements apply (II.A.7.f.): 3.7.11 The owner or operator must create a record once every calendar year identifying the combustion equipment at the facility subject to Section ILA and including for each combustion equipment (II.A.7.f.(i)): 3.7.11.1 The date of the adjustment(II.A.7.f.(i)(A)); 3.7.11.2 Whether the combustion process adjustment under Section II.A.6.b.(iv) (Condition 3.7.4) was followed, and what procedures were performed (II.A.7.f.(i)(B)); 3.7.11.3 Whether a combustion process adjustment under Sections II.A.6.c.(i) and II.A.6.c.(ii) (Conditions 3.7.8.1 and 3.7.8.2) was followed, what procedures were performed, and what New Source Performance Standard or National Emission Standard for Hazardous Air Pollutants applied, if any (II.A.7.f.(i)(C)); and 3.7.11.4 A description of any corrective action taken. (II.A.7.f.(i)(D)) 3.7.11.5 If the owner or operator conducts the combustion process adjustment according to the manufacturer recommended procedures and schedule and the manufacturer specifies a combustion process adjustment on an operation time schedule, the hours of operation. (II.A.7.f.(i)(E)) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 36 3.7.12 The owner or operator must retain manufacturer recommended procedures, specifications, and maintenance schedule if utilized under II.A.6.c.(i) (Conditions 3.7.8.1) for the life of the equipment. (II.A.7.f.(ii)) 3.7.13 As an alternative to the requirements described in Section II.A.7.f.(i) (Condition 3.7.11), the owner or operator may comply with applicable recordkeeping requirements related to combustion process adjustments conducted according to a New Source Performance Standard in 40 CFR Part 60 (November 17, 2016) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (November 17,2016). (II.A.7.f.(iii)) Note: 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. (Section VI Condition 22.b) 3.8 This engine and associated non-selective catalyst reduction unit shall be operated and maintained in accordance with internal operating and maintenance standards, which shall consider manufacturer's recommendations and good air pollution control practices for minimizing emission, at all times, including periods of start-up, shut-down and malfunction. These internal operating and maintenance standards shall be kept on site and made available to the Division upon request. Parameters associated with this engine and non-selective catalyst reduction unit shall be monitored as follows: 3.8.1 The pressure drop across the catalyst and the catalyst inlet temperature shall be monitored according to SECTION IV - 4.1.13. 3.8.2 The air-to-fuel ratio controller (AFRC) millivolt reading shall be monitored and recorded weekly to assess the AFRC operating condition. During those months when portable monitoring is scheduled, the millivolt reading shall be monitored and recorded during the portable monitoring event. Recording of the millivolt reading shall be used to verify that the AFRC is operated in accordance with the manufacturer's recommendations. 3.8.3 The pressure drop across the catalyst and the catalyst inlet temperature shall be monitored and recorded during each portable monitoring event required by Condition 3.1.2. 3.8.4 The oxygen concentration in the engine exhaust gas shall be measured and recorded during each portable monitoring event required by Condition 3.1.2. Records of all data and maintenance performed associated with the engine and catalyst operation and parameter monitoring of this Condition 3.8 shall be maintained for Division inspection upon request. 3.9 This engine is subject to the requirements in 40 CFR Part 63 Subpart ZZZZ, "National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines", as specified in SECTION IV - 4. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 37 3.10 This engine is subject to the requirements in 40 CFR Part 63 Subpart A "General Provisions", as specified in SECTION IV - 11. 3.11 This engine is subject to the Compliance Assurance Monitoring (CAM)requirements with respect to the annual NOx and CO emission limitations in Condition 3.1. Compliance with the CAM requirements shall be monitored in accordance with the requirements in SECTION IV - 12 and the CAM Plan in APPENDIX G. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 38 4. EU-101: One (1) Waukesha L7042GSI, 1478 HP engine (AIRS point 017) Permit Compliance Monitoring Parameter Condition Limitations* Number Emission Factor Method Interval NOx 11.2 tons/yr 0.359 lb/MMBtu Recordkeeping 4.1 CO 11.2 tons/yr 0.359 lb/MMBtu and Calculation Monthly VOC 4.2 2.7 tons/yr 0.086 lb/MMBtu 12 month rolling Natural Gas Individual Engine Consumption 4.3 61.4 MMscf yr Fuel Meter Monthly Btu Content of ASTM or other Natural Gas 4.4 Division Approved Semi-annually Method Hours of Operation 4.5 Recordkeeping Monthly Not to exceed 20%, except as provided for below For Certain Operational Only Natural Opacity 4.6 Activities -Not to Exceed Fuel Restriction Gas is Used as 30%for a Period or Fuel Periods Aggregating More than Six(6)Minutes in any 60 Consecutive Minutes Colorado Regulation 4.7 See Condition 4.7 No. 7,Part E Engine and Catalyst Operation, 4.8 See Condition 4.8 Maintenance and Parameter Monitoring Limit concentration of formaldehyde in the 40 CFR 63 Subpart stationary RICE exhaust to ZZZZ 4.9 350 ppbvd or less at 15 See Condition 4.9 percent O2; or Reduce formaldehyde emissions by 76%or more. 40 CFR 63 Subpart A 4.10 See Condition 4.10 —General Provisions Compliance Assurance Monitoring 4.11 See Condition 4.11 (CAM) *The emissions and natural gas throughput limits for this engine are based on a maximum operational horsepower of 932.since this is the highest horsepower at which compliance with emission limits has been demonstrated during testing. 4.1 Emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO) from this engine shall not exceed the limitations listed in Summary Table 4 above (Colorado Construction Permit 00WE0582, as modified Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 39 under the provisions of Colorado Regulation No. 3, Part C, Section III.B.7). Compliance with the emission limitations shall be monitored as follows: 4.1.1 Except as provided below, the emission factors listed in Summary Table 4 above have been approved by the Division and shall be used to calculate emissions from this engine as follows: Monthly emissions shall be calculated, by the end of the subsequent month, using the emission factors in Summary Table 4 above, the monthly natural gas consumption (required by Condition 4.3) and the Btu content of the natural gas (required by Condition 4.4) in the equation below: tons/mo = [EF (lb/MMBtu) x fuel use (MMscf/mo) x heat content of fuel(MMBtu/MMscf)] 2000 lb/ton Monthly emissions 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. Records of calculations shall be kept in a log to be made available to the Division upon request. If the results of the portable analyzer testing conducted under the provisions of Condition 4.1.2 show that either the NOx or CO emission rates/factors are greater than those listed above, 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 rates/factors within 60 days of the completion of the test. 4.1.2 Portable Monitoring shall be conducted quarterly in accordance with the requirements in SECTION IV - 1. 4.2 Volatile Organic Compound (VOC) emissions from this engine shall not exceed the limitation listed in Summary Table 4 above (Construction Permit 00WE0582, as modified under the provisions of Colorado Regulation No. 3, Part C, Section III.B.7). Monthly emissions shall be calculated, by the end of the subsequent month, using the emission factors in Summary Table 4 above, the monthly natural gas consumption (required by Condition 4.3), and the Btu content of the natural gas (required by Condition 4.4) in the equation below: tons/mo =IEF (lb/MMBtu) x fuel use (MMscf/mo) x heat content of fuel(MMBtu/MMscf)] 2000 lb/ton Monthly emissions shall be used in a twelve month rolling total 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. 4.3 Natural gas consumption shall not exceed the limitation shown in Summary Table 4 above. (Colorado Construction Permit 00WE0582, as modified under the provisions of Colorado Regulation No. 3, Part C, Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 40 Section III.B.7). Natural gas consumption shall be recorded monthly using the existing individual engine fuel meter. Monthly natural gas consumption 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. Records of calculations shall be kept in a log to be made available to the Division upon request. 4.4 The Btu content of the natural gas used to fuel this engine shall be verified semi-annually using the appropriate ASTM Methods or equivalent, if approved in advance by the Division. The Btu content of the natural gas shall be based on the lower heating value of the fuel. Calculations of monthly emissions shall be made using the heat content derived from the most recent required analysis. 4.5 Hours of operation for this engine shall be monitored monthly and recorded and maintained to be available to the Division upon request. Monthly hours of operation shall be used in a running total for each annual compliance period. The hours of operation shall be used to determine if portable monitoring is required as specified in SECTION IV - 1. 4.6 The following opacity requirements apply to this engine: 4.6.1 Except as provided for in Condition 4.6.2 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section II.A.1). 4.6.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, process modifications, or adjustment or occasional cleaning of control equipment 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 opacity requirements of this Condition 4.6 shall be presumed since only natural gas is permitted to be used as fuel in this engine. 4.7 This engine is subject to the requirements of Colorado Regulation No. 7, Part E, "Combustion Equipment and Major Source RACT", including, but not limited to, the following: [The requirements below reflect the current rule language as of the revisions to 5 CCR 1001-9 Colorado Regulation No. 7 published in the Colorado Register on 01/25/2020 and effective on 02/14/2020. However, if revisions to this rule are published at a later date, the owner or operator is subject to the requirements contained in the revised version of Colorado Regulation No. 7.] 4.7.1 The owner or operator of any natural gas-fired stationary or portable reciprocating internal combustion engine with a manufacturer's design rate greater than 500 horsepower commencing operations in the 8-hour Ozone Control Area on or after June 1, 2004 shall employ air pollution control technology to control emissions, as provided in Section LB (Condition 4.7.3). (Colorado Regulation No. 7, Part E, Section I.A.1) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 41 4.7.2 The owner or operator of any existing natural gas-fired stationary or portable reciprocating internal combustion engine with a manufacturer's design rate greater than 500 horsepower, which existing engine was operating in the 8-hour Ozone Control Area prior to June 1, 2004, shall employ air pollution control technology on and after May 1, 2005, as provided in Section LB (Condition 4.7.3). (Colorado Regulation No. 7, Part E, Section I.A.2) 4.7.3 Air pollution control technology requirements: 4.7.3.1 For rich burn reciprocating internal combustion engines, a non-selective catalyst reduction and an air fuel controller shall be required. A rich burn reciprocating internal combustion engine is one with a normal exhaust oxygen concentration of less than 2% by volume. (Colorado Regulation No. 7, Part E, Section I.B.1) 4.7.3.2 The emission control equipment required by this Condition 4.7.3 shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. (Colorado Regulation No. 7, Part E, Section I.B.3) [Note that the following requirements of Colorado Regulation No. 7, Part E, Sections II.A.6 and ILA.7 apply to specific combustion equipment with uncontrolled actual emissions of NOx equal to or greater than five (5) tons per year, as specified in Part E, Section II.A.6.a, therefore, applicability may vary from year to yeas] Combustion Process Adjustment (Part E, Section II.A.6) 4.7.4 The owner or operator of a stationary internal combustion engine must conduct the following inspections and adjustments, as applicable (II.A.6.b.(iv)): 4.7.4.1 Change oil and filters as necessary. (II.A.6.b.(iv)(A)) 4.7.4.2 Inspect air cleaners, fuel filters, hoses, and belts and clean or replace as necessary. (II.A.6.b.(iv)(B)) 4.7.4.3 Inspect spark plugs and replace as necessary. (II.A.6.b.(iv)(C)) 4.7.5 The owner or operator must operate and maintain the stationary internal combustion engine consistent with manufacturer's specifications, if available, or good engineering and maintenance practices. (II.A.6.b.(vii)) 4.7.6 The owner or operator of stationary reciprocating internal combustion engines with uncontrolled actual emissions of NOx equal to or greater than five (5) tons per year that existed at major sources of NOx (greater than or equal to 100 tpy NOx) as of June 3, 2016, must conduct the initial combustion process adjustment by April 1, 2017. An owner or operator may rely on a combustion process adjustment conducted in accordance with applicable requirements and schedule of a New Source Performance Standard in 40 CFR Part 60 (November 17, 2016) or National Emission Standard for Hazardous Air Pollutants in 40 Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 42 CFR Part 63 (November 17, 2016) to satisfy the requirement to conduct an initial combustion process adjustment by April 1, 2017. (II.A.6.b.(viii)(A)) 4.7.7 The owner or operator must conduct subsequent combustion process adjustments at least once every twelve (12) months after the initial combustion adjustment, or on the applicable schedule according to Sections II.A.6.c.(i). or II.A.6.c.(ii) (Conditions 4.7.8.1 or 4.7.8.2). (II.A.6.b.(viii)(C)) 4.7.8 As an alternative to the requirements described in Sections II.A.6.b.(iv), II.A.6.b.(vii) and II.A.6.b.(viii) (Conditions 4.7A through 4.7.7) (II.A.6.c.): 4.7.8.1 The owner or operator may conduct the combustion process adjustment according to the manufacturer recommended procedures and schedule (II.A.6.c.(i)); or 4.7.8.2 The owner or operator of combustion equipment that is subject to and required to conduct a period tune-up or combustion adjustment by the applicable requirements of a New Source Performance Standard in 40 CFR Part 60 (December 19, 2019) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (December 19, 2019) may conduct tune-ups or adjustments according to the schedule and procedures of the applicable requirements of 40 CFR Part 60 (December 19, 2019) or 40 CFR Part 63 (December 19, 2019). (II.A.6.c.(ii)) Recordkeeping (II.A.7) 4.7.9 The following records must be kept for a period of five years and made available to the Division upon request (II.A.7): 4.7.10 For stationary combustion equipment subject to the combustion process adjustment requirements in Section II.A.6 (Conditions 4.7.4 through 4.7.8), the following recordkeeping requirements apply (II.A.7.f.): 4.7.11 The owner or operator must create a record once every calendar year identifying the combustion equipment at the facility subject to Section ILA and including for each combustion equipment (II.A.7.f.(i)): 4.7.11.1 The date of the adjustment (II.A.7.f.(i)(A)); 4.7.1L2 Whether the combustion process adjustment under Section II.A.6.b.(iv) (Condition 4.7.4) was followed, and what procedures were performed (II.A.7.f.(i)(B)); 4.7.1L3 Whether a combustion process adjustment under Sections II.A.6.c.(i) and II.A.6.c.(ii) (Conditions 4.7.8.1 and 4.7.8.2) was followed, what procedures were performed, and what New Source Performance Standard or National Emission Standard for Hazardous Air Pollutants applied, if any (II.A.7.f.(i)(C)); and Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 43 4.7.11.4 A description of any corrective action taken. (II.A.7.f.(i)(D)) 4.7.11.5 If the owner or operator conducts the combustion process adjustment according to the manufacturer recommended procedures and schedule and the manufacturer specifies a combustion process adjustment on an operation time schedule, the hours of operation. (II.A.7.f.(i)(E)) 4.7.12 The owner or operator must retain manufacturer recommended procedures, specifications, and maintenance schedule if utilized under II.A.6.c.(i) (Conditions 4.7.8.1) for the life of the equipment. (II.A.7.f.(ii)) 4.7.13 As an alternative to the requirements described in Section II.A.7.f.(i) (Condition 4.7.11), the owner or operator may comply with applicable recordkeeping requirements related to combustion process adjustments conducted according to a New Source Performance Standard in 40 CFR Part 60 (November 17, 2016) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (November 17,2016). (II.A.7.f.(iii)) Note: 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. (Section VI Condition 22.b) 4.8 This engine and associated non-selective catalyst reduction unit shall be operated and maintained in accordance with internal operating and maintenance standards, which shall consider manufacturer's recommendations and good air pollution control practices for minimizing emission, at all times, including periods of start-up, shut-down and malfunction. These internal operating and maintenance standards shall be kept on site and made available to the Division upon request. Parameters associated with this engine and non-selective catalyst reduction unit shall be monitored as follows: 4.8.1 The pressure drop across the catalyst and the catalyst inlet temperature shall be monitored according to SECTION IV - 4.1.13. 4.8.2 The air-to-fuel ratio controller (AFRC) O, sensor millivolt reading shall be monitored and recorded weekly for each engine to assess the AFRC operating condition. During those months when portable monitoring is scheduled, the millivolt reading shall be monitored and recorded during the portable monitoring event. Recording of the millivolt reading shall be used to verify that the AFRC is operated in accordance with the manufacturer's recommendations. 4.8.3 The pressure drop across the catalyst and the catalyst inlet temperature shall be recorded for this engine during each portable monitoring event required by Condition 4.1.2. 4.8.4 The oxygen concentration in the engine exhaust gas shall be measured and recorded for this engine during each portable monitoring event required by Condition 4.1.2. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 44 Records of all data and maintenance performed associated with the engine and catalyst operation and parameter monitoring of this Condition 4.8 shall be maintained for Division inspection upon request. 4.9 This engine is subject to the requirements in 40 CFR Part 63 Subpart ZZZZ, "National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines", as specified in SECTION IV - 4. 4.10 This engine is subject to the requirements in 40 CFR Part 63 Subpart A "General Provisions", as specified in SECTION IV - 11. 4.11 This engine is subject to the Compliance Assurance Monitoring (CAM) requirements with respect to the annual NOx and CO emission limitations in Condition 4.1. Compliance with the CAM requirements shall be monitored in accordance with the requirements in SECTION IV - 12 and the CAM Plan in APPENDIX G. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 45 5. EU-38, EU-39: Two (2) Caterpillar 3612 TALE, 3550 HP engines (AIRS point 020) [Emission and fuel consumption limits are total limits for both engines together] Permit Compliance Monitoring Parameter Condition Limitations Number Emission Factor Method Interval NOx 48.0 tons/yr 0.217 lb/MMBtu Recordkeeping 5.1 CO 12.0 tons/yr 0.054 lb/MMBtu and Calculation Monthly VOC 5.2 15.1 tons/yr 0.068 lb/MMBtu 12 month rolling Individual Natural Gas 5.3 440.0 MMscf/yr Engine Fuel Monthly Consumption Meters ASTM or other Btu Content of 5 4 Division Semi-annually Natural Gas Approved Method Hours of 5.5 Recordkeeping Monthly Operation Not to exceed 20%, except as provided for below For Certain Operational Only Natural Opacity 5.6 Activities -Not to Exceed 30% Fuel Restriction Gas is Used as for a Period or Periods Fuel Aggregating More than Six(6) Minutes in any 60 Consecutive Minutes Colorado Regulation No. 7, 5.7 See Condition 5.7 Part E Engine and Catalyst Operation, 5.8 See Condition 5.8 Maintenance and Parameter Monitoring Reduce CO emissions by 93%or more; or 40 CFR 63 5 9 Limit concentration of See Condition 5.9 Subpart ZZZZ formaldehyde in the stationary RICE exhaust to 14 ppmvd or less at 15 percent O2 40 CFR 63 Subpart A 5.10 See Condition 5.10 General Provisions Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 46 5.1 Total emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO) from both engines together shall not exceed the limitations listed in Summary Table 5 above (Colorado Construction Permit 01WE0763) Compliance with the emission limitations shall be monitored as follows: 5.1.1 Except as provided below, the emission factors listed in Summary Table 5 above have been approved by the Division and shall be used to calculate emissions from these engines as follows: Monthly emissions shall be calculated, by the end of the subsequent month, using the emission factors in Summary Table 5 above, the monthly natural gas consumption (required by Condition 5.3) and the Btu content of the natural gas (required by Condition 5.4) in the equation below: tons/mo = [EF (lb/MMBtu) x fuel use (MMscf/mo) x heat content of fuel(MMBtu/MMscf)] 2000 lb/ton Monthly emissions 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. Records of calculations shall be kept in a log to be made available to the Division upon request. If the results of the portable analyzer testing conducted under the provisions of Condition 5.1.2 show that either the NOx or CO emission rates/factors are greater than those listed above, 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 rates/factors within 60 days of the completion of the test. 5.1.2 Portable Monitoring shall be conducted quarterly in accordance with the requirements in SECTION IV - 1. Performance testing conducted to satisfy the requirements of SECTION IV - 5.1.4 (performance testing under 40 CFR 63 Subpart ZZZZ) shall also satisfy the requirement to conduct portable monitoring for the quarter in which the Subpart ZZZZ performance test occurs. 5.2 Total Volatile Organic Compound (VOC) emissions from both engines together shall not exceed the limitation listed in Summary Table 5 above (Colorado Construction Permit 01WE0763). Monthly emissions shall be calculated, by the end of the subsequent month, using the emission factors in Summary Table 5 above, the monthly natural gas consumption (required by Condition 5.3), and the Btu content of the natural gas (required by Condition 5.4) in the equation below: tons/mo = [EF (lb/MMBtu) x fuel use (MMscf/mo) x heat content of fuel(MMBtu/MMscf)] 2000 lb/ton Monthly emissions shall be used in a twelve month rolling total 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. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 47 5.3 Total natural gas consumption for both engines together shall not exceed the limitation listed in Summary Table 5 above. (Colorado Construction Permit 01WE0763). Natural gas consumption shall be recorded monthly using the existing individual engine fuel meters. Monthly natural gas consumption 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. Records of calculations shall be kept in a log to be made available to the Division upon request. 5.4 The Btu content of the natural gas used to fuel these engines shall be verified semi-annually using the appropriate ASTM Methods or equivalent, if approved in advance by the Division. The Btu content of the natural gas shall be based on the lower heating value of the fuel. Calculations of monthly emissions shall be made using the heat content derived from the most recent required analysis. 5.5 Hours of operation for these engines shall be monitored monthly and recorded and maintained to be available to the Division upon request. Monthly hours of operation shall be used in a running total for each annual compliance period. The hours of operation shall be used to determine if portable monitoring is required as specified in SECTION IV - 1. 5.6 The following opacity requirements apply to each engine: 5.6.1 Except as provided for in Condition 5.6.2 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section II.A.1). 5.6.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, process modifications, or adjustment or occasional cleaning of control equipment 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 opacity requirements of this Condition 5.6 shall be presumed since only natural gas is permitted to be used as fuel in these engines. 5.7 These engines are subject to the requirements of Colorado Regulation No. 7, Part E, "Combustion Equipment and Major Source RACT", including, but not limited to, the following: [The requirements below reflect the current rule language as of the revisions to 5 CCR 1001-9 Colorado Regulation No. 7 published in the Colorado Register on 01/25/2020 and effective on 02/14/2020. However, if revisions to this rule are published at a later date, the owner or operator is subject to the requirements contained in the revised version of Colorado Regulation No. 7.] 5.7.1 The owner or operator of any natural gas-fired stationary or portable reciprocating internal combustion engine with a manufacturer's design rate greater than 500 horsepower commencing operations in the 8-hour Ozone Control Area on or after June 1, 2004 shall employ air pollution control technology to control emissions, as provided in Section LB (Condition 5.7.3). (Colorado Regulation No. 7, Part E, Section I.A.1) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 48 5.7.2 The owner or operator of any existing natural gas-fired stationary or portable reciprocating internal combustion engine with a manufacturer's design rate greater than 500 horsepower, which existing engine was operating in the 8-hour Ozone Control Area prior to June 1, 2004, shall employ air pollution control technology on and after May 1, 2005, as provided in Section LB (Condition 5.7.3). (Colorado Regulation No. 7, Part E, Section I.A.2) 5.7.3 Air pollution control technology requirements: 5.7.3.1 For lean burn reciprocating internal combustion engines, an oxidation catalyst shall be required. A lean burn reciprocating internal combustion engine is one with a normal exhaust oxygen concentration of 2% by volume, or greater. (Colorado Regulation No. 7, Part E, Section I.B.2) 5.7.3.2 The emission control equipment required by this Condition 5.7.3 shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. (Colorado Regulation No. 7, Part E, Section I.B.3) [Note that the following requirements of Colorado Regulation No. 7, Part E, Sections II.A.6 and ILA.7 apply to specific combustion equipment with uncontrolled actual emissions of NOx equal to or greater than five (5) tons per year, as specified in Part E, Section ILA.6.a, therefore, applicability may vary from year to yeas] Combustion Process Adjustment (Part E, Section ILA.6) 5.7.4 The owner or operator of a stationary internal combustion engine must conduct the following inspections and adjustments, as applicable (II.A.6.b.(iv)): 5.7.4.1 Change oil and filters as necessary. (II.A.6.b.(iv)(A)) 5.7.4.2 Inspect air cleaners, fuel filters, hoses, and belts and clean or replace as necessary. (II.A.6.b.(iv)(B)) 5.7.4.3 Inspect spark plugs and replace as necessary. (II.A.6.b.(iv)(C)) 5.7.5 The owner or operator must operate and maintain the stationary internal combustion engine consistent with manufacturer's specifications, if available, or good engineering and maintenance practices. (II.A.6.b.(vii)) 5.7.6 The owner or operator of stationary reciprocating internal combustion engines with uncontrolled actual emissions of NOx equal to or greater than five (5) tons per year that existed at major sources of NOx (greater than or equal to 100 tpy NOx) as of June 3, 2016, must conduct the initial combustion process adjustment by April 1, 2017. An owner or operator may rely on a combustion process adjustment conducted in accordance with applicable requirements and schedule of a New Source Performance Standard in 40 CFR Part 60 (November 17, 2016) or National Emission Standard for Hazardous Air Pollutants in 40 Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 49 CFR Part 63 (November 17, 2016) to satisfy the requirement to conduct an initial combustion process adjustment by April 1, 2017. (II.A.6.b.(viii)(A)) 5.7.7 The owner or operator must conduct subsequent combustion process adjustments at least once every twelve (12) months after the initial combustion adjustment, or on the applicable schedule according to Sections II.A.6.c.(i). or II.A.6.c.(ii) (Conditions 5.7.8.1 or 5.7.8.2). (ILA.6.b.(viii)(C)) 5.7.8 As an alternative to the requirements described in Sections II.A.6.b.(iv), II.A.6.b.(Vii) and II.A.6.b.(viii) (Conditions 5.7A through 5.7.7) (II.A.6.c.): 5.7.8.1 The owner or operator may conduct the combustion process adjustment according to the manufacturer recommended procedures and schedule (II.A.6.c.(i)); or 5.7.8.2 The owner or operator of combustion equipment that is subject to and required to conduct a period tune-up or combustion adjustment by the applicable requirements of a New Source Performance Standard in 40 CFR Part 60 (December 19, 2019) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (December 19, 2019) may conduct tune-ups or adjustments according to the schedule and procedures of the applicable requirements of 40 CFR Part 60 (December 19, 2019) or 40 CFR Part 63 (December 19, 2019). (II.A.6.c.(ii)) Recordkeeping (II.A.7) 5.7.9 The following records must be kept for a period of five years and made available to the Division upon request (II.A.7): 5.7.10 For stationary combustion equipment subject to the combustion process adjustment requirements in Section II.A.6 (Conditions 5.7.4 through 5.7.8), the following recordkeeping requirements apply (II.A.7.f.): 5.7.11 The owner or operator must create a record once every calendar year identifying the combustion equipment at the facility subject to Section ILA and including for each combustion equipment (II.A.7.f.(i)): 5.7.11.1 The date of the adjustment (II.A.7.f.(i)(A)); 5.7.1L2 Whether the combustion process adjustment under Sections II.A.6.b.(iv) (Condition 5.7.4) was followed, and what procedures were performed (II.A.7.f.(i)(B)); 5.7.1L3 Whether a combustion process adjustment under Sections II.A.6.c.(i) and II.A.6.c.(ii) (Conditions 5.7.8.1 and 5.7.8.2) was followed, what procedures were performed, and what New Source Performance Standard or National Emission Standard for Hazardous Air Pollutants applied, if any (II.A.7.f.(i)(C)); and Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 50 5.7.11.4 A description of any corrective action taken. (II.A.7.f.(i)(D)) 5.7.11.5 If the owner or operator conducts the combustion process adjustment according to the manufacturer recommended procedures and schedule and the manufacturer specifies a combustion process adjustment on an operation time schedule, the hours of operation. (II.A.7.f.(i)(E)) 5.7.12 The owner or operator must retain manufacturer recommended procedures, specifications, and maintenance schedule if utilized under II.A.6.c.(i) (Condition 5.7.8.1) for the life of the equipment. (II.A.7.f.(ii)) 5.7.13 As an alternative to the requirements described in Section II.A.7.f.(i) (Condition 5.7.11), the owner or operator may comply with applicable recordkeeping requirements related to combustion process adjustments conducted according to a New Source Performance Standard in 40 CFR Part 60 (November 17, 2016) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (November 17,2016). (II.A.7.f.(iii)) Note: 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. (Section VI Condition 22.b) 5.8 These engines and associated oxidation catalysts shall be operated and maintained in accordance with internal operating and maintenance standards, which shall consider manufacturer's recommendations and good air pollution control practices for minimizing emissions, at all times, including periods of start- up, shut-down and malfunction. These internal operating and maintenance standards shall be kept on site and made available to the Division upon request. Parameters associated with each engine and oxidizing catalyst unit shall be monitored as follows: 5.8.1 The pressure drop across the catalyst and the catalyst inlet temperature shall be monitored according to SECTION IV - 5.1.13 5.8.2 The pressure drop across the catalyst and the catalyst inlet temperature shall be recorded for each engine during each portable monitoring event required by Condition 5.1.2. 5.8.3 The oxygen concentration in the engine exhaust gas shall be measured and recorded for each engine during each portable monitoring event required by Condition 5.1.2. Records of all data and maintenance performed associated with the engine and catalyst operation and parameter monitoring of this Condition 5.8 shall be maintained for Division inspection upon request. 5.9 These engines are subject to the requirements in 40 CFR Part 63 Subpart ZZZZ, "National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines", as specified in SECTION IV - 5. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 51 5.10 These engines are subject to the requirements in 40 CFR Part 63 Subpart A "General Provisions", as specified in SECTION IV - 11. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 52 6. EU-34R: One (1) Waukesha L-7042 GSI, 1232 HP engine (AIRS point 025) Permit Monitoring Parameter Condition Limitations Number Emission Factor Method Interval NOx 23.8 tons/yr 0.519 lb/MMBtu Recordkeeping 6.1 CO 35.7 tons/yr 0.778 lb/MMBtu and Calculation Monthly VOC 6.2 1.8 tons/yr 0.039 lb/MMBtu 12 month rolling Natural Gas Individual Engine Consumption 6.3 87.4 MMscf/yr Fuel Meter Monthly Btu Content of ASTM or other Natural Gas 6.4 Division Approved Semi-annually Method Hours of Operation 6.5 Recordkeeping Monthly Not to exceed 20%, except as provided for below For Certain Operational Only Natural Opacity 6.6 Activities -Not to Exceed Fuel Restriction Gas is Used as 30%for a Period or Periods Fuel Aggregating More than Six (6)Minutes in any 60 Consecutive Minutes Colorado Regulation No. 7, 6.7 See Condition 6.7 Part E Engine and Catalyst Operation, Maintenance and 6.8 See Condition 6.8 Parameter Monitoring Limit concentration of formaldehyde in the stationary RICE exhaust to 40 CFR 63 Subpart ZZZZ 6.9 350 ppbvd or less at 15 See Condition 6.9 percent O2; or Reduce formaldehyde emissions by 76%or more. 40 CFR 63 Subpart A—General 6.10 See Condition 6.10 Provisions Compliance Assurance 6.11 See Condition 6.11 Monitoring(CAM) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 53 6.1 Total emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO) shall not exceed the limitations listed in Summary Table 6 above (Colorado Construction Permit 07WE0366). Compliance with the emission limitations shall be monitored as follows: 6.1.1 Except as provided below, the emission factors listed in Summary Table 6 above have been approved by the Division and shall be used to calculate emissions from this engine as follows: Monthly emissions shall be calculated, by the end of the subsequent month, using the emission factors in Summary Table 6 above, the monthly natural gas consumption (required by Condition 6.3) and the Btu content of the natural gas (required by Condition 6.4) in the equation below: tons/mo = [EF (lb/MMBtu) x fuel use (MMscf/mo) x heat content of fuel(MMBtu/MMscf)] 2000 lb/ton Monthly emissions 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. Records of calculations shall be kept in a log to be made available to the Division upon request. If the results of the portable analyzer testing conducted under the provisions of Condition 6.1.2 show that either the NOx or CO emission rates/factors are greater than those listed above, 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 rates/factors within 60 days of the completion of the test. 6.1.2 Portable Monitoring shall be conducted quarterly in accordance with the requirements in SECTION IV - 1. 6.2 Total Volatile Organic Compound (VOC) emissions shall not exceed the limitation listed in Summary Table 6 above (Colorado Construction Permit 07WE0366). Monthly emissions shall be calculated, by the end of the subsequent month, using the emission factors in Summary Table 6 above, the monthly natural gas consumption (required by Condition 6.3), and the Btu content of the natural gas (required by Condition 6.4) in the equation below: tons/mo =IEF (lb/MMBtu)x fuel use (MMscf/mo) x heat content of fuel(MMBtu/MMscf)] 2000 lb/ton Monthly emissions shall be used in a twelve month rolling total 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. 6.3 Natural gas consumption shall not exceed the limitation listed in Summary Table 6 above. (Colorado Construction Permit 07WE0366). Natural gas consumption shall be recorded monthly using the existing Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 54 individual engine fuel meter. Monthly natural gas consumption 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. Records of calculations shall be kept in a log to be made available to the Division upon request. 6.4 The Btu content of the natural gas used to fuel this engine shall be verified semi-annually using the appropriate ASTM Methods or equivalent, if approved in advance by the Division. The Btu content of the natural gas shall be based on the lower heating value of the fuel. Calculations of monthly emissions shall be made using the heat content derived from the most recent required analysis. 6.5 Hours of operation for this engine shall be monitored monthly and recorded and maintained to be available to the Division upon request. Monthly hours of operation shall be used in a running total for each annual compliance period. The hours of operation shall be used to determine if portable monitoring is required as specified in SECTION IV - 1. 6.6 The following opacity requirements apply to this engine: 6.6.1 Except as provided for in Condition 6.6.2 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section II.A.1). 6.6.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, process modifications, or adjustment or occasional cleaning of control equipment 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 opacity requirements of this Condition 6.6 shall be presumed since only natural gas is permitted to be used as fuel in this engine. 6.7 This engine is subject to the requirements of Colorado Regulation No. 7, Part E, "Combustion Equipment and Major Source RACT", including, but not limited to, the following: [The requirements below reflect the current rule language as of the revisions to 5 CCR 1001-9 Colorado Regulation No. 7 published in the Colorado Register on 01/25/2020 and effective on 02/14/2020. However, if revisions to this rule are published at a later date, the owner or operator is subject to the requirements contained in the revised version of Colorado Regulation No. 7.] 6.7.1 The owner or operator of any natural gas-fired stationary or portable reciprocating internal combustion engine with a manufacturer's design rate greater than 500 horsepower commencing operations in the 8-hour Ozone Control Area on or after June 1, 2004 shall employ air pollution control technology to control emissions, as provided in Section LB (Condition 6.7.3). (Colorado Regulation No. 7, Part E, Section I.A.1) 6.7.2 The owner or operator of any existing natural gas-fired stationary or portable reciprocating internal combustion engine with a manufacturer's design rate greater than 500 horsepower, Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 55 which existing engine was operating in the 8-hour Ozone Control Area prior to June 1, 2004, shall employ air pollution control technology on and after May 1, 2005, as provided in Section LB (Condition 6.7.3). (Colorado Regulation No. 7, Part E, Section I.A.2) 6.7.3 Air pollution control technology requirements: 6.7.3.1 For rich burn reciprocating internal combustion engines, a non-selective catalyst reduction and an air fuel controller shall be required. A rich burn reciprocating internal combustion engine is one with a normal exhaust oxygen concentration of less than 2% by volume. (Part E, Section I.B.1) 6.7.3.2 The emission control equipment required by this Condition 6.7.3 shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. (Colorado Regulation No. 7, Part E, Section I.B.3) [Note that the following requirements of Colorado Regulation No. 7, Part E, Sections II.A.6 and ILA.7 apply to specific combustion equipment with uncontrolled actual emissions of NOx equal to or greater than five (S) tons per year, as specified in Part E, Section II.A.6.a, therefore, applicability may vary from year to year] Combustion Process Adjustment (Part E, Section II.A.6) 6.7.4 The owner or operator of a stationary internal combustion engine must conduct the following inspections and adjustments, as applicable (II.A.6.b.(iv)): 6.7.4.1 Change oil and filters as necessary. (II.A.6.b.(iv)(A)) 6.7.4.2 Inspect air cleaners, fuel filters, hoses, and belts and clean or replace as necessary. (II.A.6.b.(iv)(B)) 6.7.4.3 Inspect spark plugs and replace as necessary. (II.A.6.b.(iv)(C)) 6.7.5 The owner or operator must operate and maintain the stationary internal combustion engine consistent with manufacturer's specifications, if available, or good engineering and maintenance practices. (II.A.6.b.(vii)) 6.7.6 The owner or operator of stationary reciprocating internal combustion engines with uncontrolled actual emissions of NOx equal to or greater than five (5) tons per year that existed at major sources of NOx (greater than or equal to 100 tpy NOx) as of June 3, 2016, must conduct the initial combustion process adjustment by April 1, 2017. An owner or operator may rely on a combustion process adjustment conducted in accordance with applicable requirements and schedule of a New Source Performance Standard in 40 CFR Part 60 (November 17, 2016) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (November 17, 2016) to satisfy the requirement to conduct an initial combustion process adjustment by April 1, 2017. (II.A.6.b.(viii)(A)) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 56 6.7.7 The owner or operator must conduct subsequent combustion process adjustments at least once every twelve (12) months after the initial combustion adjustment, or on the applicable schedule according to Sections II.A.6.c.(i). or II.A.6.c.(ii) (Conditions 6.7.8.1 or 6.7.8.2). (ILA.6.b.(viii)(C)) 6.7.8 As an alternative to the requirements described in Sections II.A.6.b.(iv), II.A.6.b.(Vii) and II.A.6.b.(viii) (Conditions 6.7A through 6.7.7) (II.A.6.c.): 6.7.8.1 The owner or operator may conduct the combustion process adjustment according to the manufacturer recommended procedures and schedule (II.A.6.c.(i)); or 6.7.8.2 The owner or operator of combustion equipment that is subject to and required to conduct a period tune-up or combustion adjustment by the applicable requirements of a New Source Performance Standard in 40 CFR Part 60 (December 19, 2019) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (December 19, 2019) may conduct tune-ups or adjustments according to the schedule and procedures of the applicable requirements of 40 CFR Part 60 (December 19, 2019) or 40 CFR Part 63 (December 19, 2019). (II.A.6.c.(ii)) Recordkeeping (II.A.7) 6.7.9 The following records must be kept for a period of five years and made available to the Division upon request (II.A.7): 6.7.10 For stationary combustion equipment subject to the combustion process adjustment requirements in Section II.A.6 (Conditions 6.7.4 through 6.7.8), the following recordkeeping requirements apply (II.A.7.f.): 6.7.11 The owner or operator must create a record once every calendar year identifying the combustion equipment at the facility subject to Section ILA and including for each combustion equipment (II.A.7.f.(i)): 6.7.11.1 The date of the adjustment (II.A.7.f.(i)(A)); 6.7.1L2 Whether the combustion process adjustment under Sections II.A.6.b.(iv) (Condition 6.7.4) was followed, and what procedures were performed (II.A.7.f.(i)(B)); 6.7.1L3 Whether a combustion process adjustment under Sections II.A.6.c.(i) and II.A.6.c.(ii) (Conditions 6.7.8.1 and 6.7.8.2) was followed, what procedures were performed, and what New Source Performance Standard or National Emission Standard for Hazardous Air Pollutants applied, if any (II.A.7.f.(i)(C)); and 6.7.11.4 A description of any corrective action taken. (II.A.7.f.(i)(D)) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 57 6.7.11.5 If the owner or operator conducts the combustion process adjustment according to the manufacturer recommended procedures and schedule and the manufacturer specifies a combustion process adjustment on an operation time schedule, the hours of operation. (II.A.7.f.(i)(E)) 6.7.12 The owner or operator must retain manufacturer recommended procedures, specifications, and maintenance schedule if utilized under II.A.6.c.(i) (Conditions 6.7.8.1) for the life of the equipment. (II.A.7.f.(ii)) 6.7.13 As an alternative to the requirements described in Section II.A.7.f.(i) (Condition 6.7.11), the owner or operator may comply with applicable recordkeeping requirements related to combustion process adjustments conducted according to a New Source Performance Standard in 40 CFR Part 60 (November 17, 2016) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (November 17, 2016). (II.A.7.f.(iii)) Note: 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. (Section VI Condition 22.b) 6.8 This engine and associated non-selective catalyst reduction unit shall be operated and maintained in accordance with internal operating and maintenance standards, which shall consider manufacturer's recommendations and good air pollution control practices for minimizing emission, at all times, including periods of start-up, shut-down and malfunction. These internal operating and maintenance standards shall be kept on site and made available to the Division upon request. Parameters associated with this engine and non-selective catalyst reduction unit shall be monitored as follows: 6.8.1 The pressure drop across the catalyst and the catalyst inlet temperature shall be monitored according to SECTION IV - 4.1.13. 6.8.2 The air-to-fuel ratio controller (AFRC) millivolt reading shall be monitored and recorded weekly to assess the AFRC operating condition. During those months when portable monitoring is scheduled, the millivolt reading shall be monitored and recorded during the portable monitoring event. Recording of the millivolt reading shall be used to verify that the AFRC is operated in accordance with the manufacturer's recommendations. 6.8.3 The pressure drop across the catalyst and the catalyst inlet temperature shall be monitored and recorded during each portable monitoring event required by Condition 6.1.2. 6.8.4 The oxygen concentration in the engine exhaust gas shall be measured and recorded during each portable monitoring event required by Condition 6.1.2. Records of all data and maintenance performed associated with the engine and catalyst operation and parameter monitoring of this Condition 6.8 shall be maintained for Division inspection upon request. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 58 6.9 This engine is subject to the requirements in 40 CFR Part 63 Subpart ZZZZ, "National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines", as specified in SECTION IV - 4. 6.10 This engine is subject to the requirements in 40 CFR Part 63 Subpart A "General Provisions", as specified in SECTION IV - 11. 6.11 This engine is subject to the Compliance Assurance Monitoring (CAM) requirements with respect to the annual NOx and CO emission limitations in Condition 6.1. Compliance with the CAM requirements shall be monitored in accordance with the requirements in SECTION IV - 12 and the CAM Plan in APPENDIX G. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 59 7. EU-103: One (1) Caterpillar G3616 TALE, 4262 HP engine (AIRS point 026) Permit Monitoring Parameter Condition Limitations Number Emission Factor Method Interval NOx 30.4 tons/yr 0.225 lb/MMBtu Recordkeeping 7.1 CO 7.6 tons/yr 0.056 lb/MMBtu and Calculation Monthly VOC 7.2 19.1 tons/yr 0.141 lb/MMBtu 12 month rolling Natural Gas Individual 7.3 269.30 MMscf/yr Engine Fuel Monthly Consumption Meter ASTM or other Btu Content of 7 4 Division Semi-annually Natural Gas Approved Method Hours of Operation 7.5 Recordkeeping Monthly Not to exceed 20%, except as provided for below For Certain Operational Only Natural Opacity 7.6 Activities -Not to Exceed 30% Fuel Restriction Gas is Used as for a Period or Periods Fuel Aggregating More than Six(6) Minutes in any 60 Consecutive Minutes Colorado Regulation 7.7 See Condition 7.7 No. 7,Part E Engine and Catalyst Operation, Maintenance and 7.8 See Condition 7.8 Parameter Monitoring Reduce CO emissions by 93% or more; or 40 CFR 63 Subpart 7 9 Limit concentration of See Condition 7.9 ZZZZ formaldehyde in the stationary RICE exhaust to 14 ppmvd or less at 15 percent O2 40 CFR 63 Subpart A—General 7.10 See Condition 7.10 Provisions NOx: 2.0 g/hp-hr or 160 ppmvd 40 CFR 60 Subpart 7.11 CO: 4.0 g/hp-hr or 540 ppmvd See Condition 7.11 JJJJ VOC: 1.0 g/hp-hr or 86 ppmvd 40 CFR 60 Subpart A—General 7.12 See Condition 7.12 Provisions Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 60 Compliance Assurance 7.13 See Condition 7.13 Monitoring(CAM) 7.1 Emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO) from this engine shall not exceed the limitations listed in Summary Table 7 above (Colorado Construction Permit 07WE0798). Compliance with the emission limitations shall be monitored as follows: 7.1.1 Except as provided below, the emission factors listed in Summary Table 7 above have been approved by the Division and shall be used to calculate emissions from this engine as follows: Monthly emissions shall be calculated, by the end of the subsequent month, using the emission factors in Summary Table 7 above, the monthly natural gas consumption (required by Condition 7.3) and the Btu content of the natural gas (required by Condition 7.4) in the equation below: tons/mo = [EF (lb/MMBtu) x fuel use (MMscf/mo) x heat content of fuel(MMBtu/MMscf)] 2000 lb/ton Monthly emissions 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. Records of calculations shall be kept in a log to be made available to the Division upon request. If the results of the portable analyzer testing conducted under the provisions of Condition 7.1.2 show that either the NOx or CO emission rates/factors are greater than those listed above, 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 rates/factors within 60 days of the completion of the test. 7.1.2 Portable Monitoring shall be conducted quarterly in accordance with the requirements in SECTION IV - 1. Performance testing for CO, conducted to satisfy the requirements of SECTION IV - 5.1.4 (performance testing under 40 CFR 63 Subpart ZZZZ), shall also satisfy the requirement to conduct portable monitoring for the quarter in which the Subpart ZZZZ performance test occurs. 7.2 Volatile Organic Compound (VOC) emissions from this engine shall not exceed the limitation listed in Summary Table 7 above (Colorado Construction Permit 07WE0798). Monthly emissions shall be calculated, by the end of the subsequent month, using the emission factors in Summary Table 7 above, the monthly natural gas consumption (required by Condition 7.3), and the Btu content of the natural gas (required by Condition 7.4) in the equation below: tons/mo =IEF (lb/MMBtu)x fuel use (MMscf/mo) x heat content of fuel(MMBtu/MMscf)] 2000 lb/ton Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 61 Monthly emissions shall be used in a twelve month rolling total 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. 7.3 Natural gas consumption shall not exceed the limitation listed in Summary Table 7 above. (Colorado Construction Permit 07WE0798). Natural gas consumption shall be recorded monthly using the existing individual engine fuel meter. Monthly natural gas consumption 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. Records of calculations shall be kept in a log to be made available to the Division upon request. 7.4 The Btu content of the natural gas used to fuel this engine shall be verified semi-annually using the appropriate ASTM Methods or equivalent, if approved in advance by the Division. The Btu content of the natural gas shall be based on the lower heating value of the fuel. Calculations of monthly emissions shall be made using the heat content derived from the most recent required analysis. 7.5 Hours of operation for this engine shall be monitored monthly and recorded and maintained to be available to the Division upon request. Monthly hours of operation shall be used in a running total for each annual compliance period. The hours of operation shall be used to determine if portable monitoring is required as specified in SECTION IV - 1. 7.6 The following opacity requirements apply to this engine: 7.6.1 Except as provided for in Condition 7.6.2 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section II.A.1). 7.6.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, process modifications, or adjustment or occasional cleaning of control equipment 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 opacity requirements of this Condition 7.6 shall be presumed since only natural gas is permitted to be used as fuel in this engine. 7.7 This engine is subject to the requirements of Colorado Regulation No. 7, Part E, "Combustion Equipment and Major Source RACT", including, but not limited to, the following: [The requirements below reflect the current rule language as of the revisions to 5 CCR 1001-9 Colorado Regulation No. 7 published in the Colorado Register on 01/25/2020 and effective on 02/14/2020. However, if revisions to this rule are published at a later date, the owner or operator is subject to the requirements contained in the revised version of Colorado Regulation No. 7.] Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 62 7.7.1 The owner or operator of any natural gas-fired stationary or portable reciprocating internal combustion engine with a manufacturer's design rate greater than 500 horsepower commencing operations in the 8-hour Ozone Control Area on or after June 1, 2004 shall employ air pollution control technology to control emissions, as provided in Section LB (Condition 7.7.3). (Colorado Regulation No. 7, Part E, Section I.A.1) 7.7.2 The owner or operator of any existing natural gas-fired stationary or portable reciprocating internal combustion engine with a manufacturer's design rate greater than 500 horsepower, which existing engine was operating in the 8-hour Ozone Control Area prior to June 1, 2004, shall employ air pollution control technology on and after May 1, 2005, as provided in Section LB (Condition 7.7.3). (Colorado Regulation No. 7, Part E, Section I.A.2) 7.7.3 Air pollution control technology requirements: 7.7.3.1 For lean burn reciprocating internal combustion engines, an oxidation catalyst shall be required. A lean burn reciprocating internal combustion engine is one with a normal exhaust oxygen concentration of 2% by volume, or greater. (Colorado Regulation No. 7, Section Part E, Section I.B.2) 7.7.3.2 The emission control equipment required by this Condition 7.7.3 shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. (Colorado Regulation No. 7, Part E, Section I.B.3) Control of emissions from new, modified, existing, and relocated natural gas fired reciprocating internal combustion engines. (Part E, Section LD) 7.7.4 Except as provided in Section I.D.2.b below (Condition 7.7.5), the owner or operator of any natural gas fired reciprocating internal combustion engine that is either constructed or relocated to the state of Colorado from another state, on or after the date listed in the table below, shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below. (Colorado Regulation No. 7, Part E, Section I.D.2.a) 7.7.5 Actual emissions from natural gas fired reciprocating internal combustion engines shall not exceed the emission performance standards in the table below as expressed in units of grams per horsepower-hour (G/hp-hr) (Colorado Regulation No. 7, Part E, Section I.D.2.b) Table 2 from Colorado Regulation No. 7, Part E, Section I.D.2.b Maximum Construction or Emission Standard in g/hp-hr Engine Hp Relocation Date NOx CO VOC ≥ 500 HP On or after July 1, 2007 2.0 4.0 1.0 On or after July 1, 2010 1.0 2.0 0.7 Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 63 Compliance with the NOx and CO emission limitations shall be monitored by conducting portable monitoring quarterly as specified in SECTION IV - 1. For comparison with the short—term limits in this condition, the results of the portable monitoring test shall be converted to units of g/hp-hr to assess compliance with the NOx and CO emission limitations in this Condition 7.7.5 In the absence of credible evidence to the contrary, compliance with the VOC limitation is presumed provided the portable monitoring indicates compliance with the NOx and CO emission limitations in this Condition 7.7.5. [Note that the following requirements of Colorado Regulation No. 7, Part E, Sections II.A.6 and ILA.7 apply to specific combustion equipment with uncontrolled actual emissions of NOx equal to or greater than five (5) tons per year, as specified in Part E, Section II.A.6.a, therefore, applicability may vary from year to yeas] Combustion Process Adjustment (Part E, Section II.A.6) 7.7.6 The owner or operator of a stationary internal combustion engine must conduct the following inspections and adjustments, as applicable (II.A.6.b.(iv)): 7.7.6A Change oil and filters as necessary. (II.A.6.b.(iv)(A)) 7.7.6.2 Inspect air cleaners, fuel filters, hoses, and belts and clean or replace as necessary. (II.A.6.b.(iv)(B)) 7.7.6.3 Inspect spark plugs and replace as necessary. (II.A.6.b.(iv)(C)) 7.7.7 The owner or operator must operate and maintain the stationary internal combustion engine consistent with manufacturer's specifications, if available, or good engineering and maintenance practices. (II.A.6.b.(vii)) 7.7.8 The owner or operator of stationary reciprocating internal combustion engines with uncontrolled actual emissions of NOx equal to or greater than five (5) tons per year that existed at major sources of NOx (greater than or equal to 100 tpy NOx) as of June 3, 2016, must conduct the initial combustion process adjustment by April 1, 2017. An owner or operator may rely on a combustion process adjustment conducted in accordance with applicable requirements and schedule of a New Source Performance Standard in 40 CFR Part 60 (November 17, 2016) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (November 17, 2016) to satisfy the requirement to conduct an initial combustion process adjustment by April 1, 2017. (II.A.6.b.(viii)(A)) 7.7.9 The owner or operator must conduct subsequent combustion process adjustments at least once every twelve (12) months after the initial combustion adjustment, or on the applicable schedule according to Sections II.A.6.c.(i). or II.A.6.c.(ii) (Conditions 7.7.10A or 7.7.10.2). (II.A.6.b.(viii)(C)) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 64 7.7.10 As an alternative to the requirements described in Sections II.A.6.b.(iv), II.A.6.b.(vii) and II.A.6.b.(viii) (Conditions 7.7.6 through 7.7.9) (II.A.6.c.): 7.7.10.1 The owner or operator may conduct the combustion process adjustment according to the manufacturer recommended procedures and schedule (II.A.6.c.(i)); or 7.7.10.2 The owner or operator of combustion equipment that is subject to and required to conduct a period tune-up or combustion adjustment by the applicable requirements of a New Source Performance Standard in 40 CFR Part 60 (December 19, 2019) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (December 19, 2019) may conduct tune-ups or adjustments according to the schedule and procedures of the applicable requirements of 40 CFR Part 60 (December 19, 2019) or 40 CFR Part 63 (December 19, 2019). (II.A.6.c.(ii)) Recordkeeping (ILA.7) 7.7.11 The following records must be kept for a period of five years and made available to the Division upon request (II.A.7): 7.7.12 For stationary combustion equipment subject to the combustion process adjustment requirements in Section II.A.6 (Conditions 7.7.6 through 7.7.10), the following recordkeeping requirements apply(II.A.7I.): 7.7.13 The owner or operator must create a record once every calendar year identifying the combustion equipment at the facility subject to Section ILA and including for each combustion equipment (II.A.7.f.(i)): 7.7.13.1 The date of the adjustment(II.A.7.f.(i)(A)); 7.7.13.2 Whether the combustion process adjustment under Sections II.A.6.b.(iv) (Condition 7.7.6) was followed, and what procedures were performed (II.A.7.f.(i)(B)); 7.7.13.3 Whether a combustion process adjustment under Sections II.A.6.c.(i) and II.A.6.c.(ii) (Conditions 7.7.10.1 and 7.7.10.2) was followed, what procedures were performed, and what New Source Performance Standard or National Emission Standard for Hazardous Air Pollutants applied, if any (II.A.7.f.(i)(C)); and 7.7.13.4 A description of any corrective action taken. (II.A.7.f.(i)(D)) 7.7.13.5 If the owner or operator conducts the combustion process adjustment according to the manufacturer recommended procedures and schedule and the manufacturer specifies a combustion process adjustment on an operation time schedule, the hours of operation. (II.A.7.f.(i)(E)) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 65 7.7.14 The owner or operator must retain manufacturer recommended procedures, specifications, and maintenance schedule if utilized under II.A.6.c.(i) (Conditions 7.7.10.1) for the life of the equipment. (II.A.7.f.(ii)) 7.7.15 As an alternative to the requirements described in Section II.A.7.f.(i) (Condition 7.7.13), the owner or operator may comply with applicable recordkeeping requirements related to combustion process adjustments conducted according to a New Source Performance Standard in 40 CFR Part 60 (November 17, 2016) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (November 17, 2016). (II.A.7.f.(iii)) Note: 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. (Section VI Condition 22.b) 7.8 This engine and associated oxidation catalyst shall be operated and maintained in accordance with internal operating and maintenance standards,which shall consider manufacturer's recommendations and good air pollution control practices for minimizing emissions, at all times, including periods of start- up, shut-down and malfunction. These internal operating and maintenance standards shall be kept on site and made available to the Division upon request. Parameters associated with this engine and oxidizing catalyst unit shall be monitored as follows: 7.8.1 The pressure drop across the catalyst and the catalyst inlet temperature shall be monitored according to SECTION IV - 5.1.13. 7.8.2 The pressure drop across the catalyst and the catalyst inlet temperature shall be recorded for this engine during each portable monitoring event required by Condition 7.1.2. 7.8.3 The oxygen concentration in the engine exhaust gas shall be measured and recorded for this engine during each portable monitoring event required by Condition 7.1.2. Records of all data and maintenance performed associated with the engine and catalyst operation and parameter monitoring of this Condition 7.8 shall be maintained for Division inspection upon request. 7.9 This engine is subject to the requirements in 40 CFR Part 63 Subpart ZZZZ, "National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines", as specified in SECTION IV - 5. 7.10 This engine is subject to the requirements in 40 CFR Part 63 Subpart A "General Provisions", as specified in SECTION IV - 11. 7.11 This engine is subject to the requirements in 40 CFR Part 60 Subpart JJJJ, "Standards of Performance for Stationary Spark Ignition Internal Combustion Engines", as specified in SECTION IV - 6. 7.12 This engine is subject to the requirements in 40 CFR Part 60 Subpart A "General Provisions", as specified in SECTION IV - 10. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 66 7.13 This engine is subject to the Compliance Assurance Monitoring (CAM)requirements with respect to the annual CO emission limitation in Condition 7.1. Compliance with the CAM requirements shall be monitored in accordance with the requirements in SECTION IV - 12 and the CAM Plan in APPENDIX H. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 67 8. EU-104: One (1) Caterpillar G3616 TALE, 4735 HP engine (AIRS point 028) Permit Monitoring Parameter Condition Limitations Number Emission Factor Method Interval NOx 32.0 tons/yr 0.229 lb/MMBtu Recordkeeping 8.1 CO 8.0 tons/yr 0.057 lb/MMBtu and Calculation Monthly VOC 8.2 19.2 tons/yr 0.137 lb/MMBtu 12 month rolling Natural Gas Individual 8.3 278.9 MMscf/yr Engine Fuel Monthly Consumption Meter ASTM or other Btu Content of 8 4 Division Semi-annually Natural Gas Approved Method Hours of 8.5 Recordkeeping Monthly Operation Not to exceed 20%, except as provided for below For Certain Operational Only Natural Opacity 8.6 Activities -Not to Exceed 30% Fuel Restriction Gas is Used as for a Period or Periods Fuel Aggregating More than Six(6) Minutes in any 60 Consecutive Minutes Colorado Regulation No. 7, 8.7 See Condition 8.7 Part E Engine and Catalyst Operation, 8.8 See Condition 8.8 Maintenance and Parameter Monitoring Reduce CO emissions by 93%or more; or 40 CFR 63 8 9 Limit concentration of See Condition 8.9 Subpart ZZZZ formaldehyde in the stationary RICE exhaust to 14 ppmvd or less at 15 percent O2 40 CFR 63 Subpart A— 8.10 See Condition 8.10 General Provisions 40 CFR 60 8 11 NOx: 2.0 g/hp-hr or 160 ppmvd See Condition 8.11 Subpart JJJJ CO: 4.0 g/hp-hr or 540 ppmvd Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 68 VOC: 1.0 g/hp-hr or 86 ppmvd 40 CFR 60 Subpart A— 8.12 See Condition 8.12 General Provisions Compliance Assurance 8.13 See Condition 8.13 Monitoring (CAM) Stack Height 8.14 Minimum of 52.8 feet Recordkeeping Facility Enclosed 8.15 See Condition 8.15 by a Fence Line 8.1 Emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO) from this engine shall not exceed the limitations listed in Summary Table 8 above (Colorado Construction Permit 1OWE1071). Compliance with the emission limitations shall be monitored as follows: 8.1.1 Except as provided below, the emission factors listed in Summary Table 8 above have been approved by the Division and shall be used to calculate emissions from this engine as follows: Monthly emissions shall be calculated, by the end of the subsequent month, using the emission factors in Summary Table 8 above, the monthly natural gas consumption (required by Condition 8.3) and the Btu content of the natural gas (required by Condition 8.4) in the equation below: tons/mo = [EF (lb/MMBtu) x fuel use (MMscf/mo) x heat content of fuel(MMBtu/MMscf)] 2000 lb/ton Monthly emissions 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. Records of calculations shall be kept in a log to be made available to the Division upon request. If the results of the portable analyzer testing conducted under the provisions of Condition 8.1.2 show that either the NOx or CO emission rates/factors are greater than those listed above, 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 rates/factors within 60 days of the completion of the test. 8.1.2 Portable Monitoring shall be conducted quarterly in accordance with the requirements in SECTION IV - 1. Performance testing for CO, conducted to satisfy the requirements of SECTION IV - 5.1.4 (performance testing under 40 CFR 63 Subpart ZZZZ), shall also satisfy the requirement to conduct portable monitoring for the quarter in which the Subpart ZZZZ performance test occurs. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 69 8.2 Volatile Organic Compound (VOC) emissions from this engine shall not exceed the limitation listed in Summary Table 8 above (Colorado Construction Permit 1OWE1071). Monthly emissions shall be calculated, by the end of the subsequent month, using the emission factors in Summary Table 8 above, the monthly natural gas consumption (required by Condition 8.3), and the Btu content of the natural gas (required by Condition 8.4) in the equation below: tons/mo =jEF (lb/MMBtu)x fuel use (MMscf/mo) x heat content of fuel(MMBtu/MMscf)l 2000 lb/ton Monthly emissions shall be used in a twelve month rolling total 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. 8.3 Natural gas consumption shall not exceed the limitation listed in Summary Table 8 above (Colorado Construction Permit lOWE1071). Natural gas consumption shall be recorded monthly using the existing individual engine fuel meter. Monthly natural gas consumption 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. Records of calculations shall be kept in a log to be made available to the Division upon request. 8.4 The Btu content of the natural gas used to fuel this engine shall be verified semi-annually using the appropriate ASTM Methods or equivalent, if approved in advance by the Division. The Btu content of the natural gas shall be based on the lower heating value of the fuel. Calculations of monthly emissions shall be made using the heat content derived from the most recent required analysis. 8.5 Hours of operation for this engine shall be monitored monthly and recorded and maintained to be available to the Division upon request. Monthly hours of operation shall be used in a running total for each annual compliance period. The hours of operation shall be used to determine if portable monitoring is required as specified in SECTION IV - 1. 8.6 The following opacity requirements apply to this engine: 8.6.1 Except as provided for in Condition 8.6.2 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section II.A.1). 8.6.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, process modifications, or adjustment or occasional cleaning of control equipment 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 opacity requirements of this Condition 8.6 shall be presumed since only natural gas is permitted to be used as fuel in this engine. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 70 8.7 This engine is subject to the requirements of Colorado Regulation No. 7, Part E, "Combustion Equipment and Major Source RACT", including, but not limited to, the following: [The requirements below reflect the current rule language as of the revisions to 5 CCR 1001-9 Colorado Regulation No. 7 published in the Colorado Register on 01/25/2020 and effective on 02/14/2020. However, if revisions to this rule are published at a later date, the owner or operator is subject to the requirements contained in the revised version of Colorado Regulation No. 7.] 8.7.1 The owner or operator of any natural gas-fired stationary or portable reciprocating internal combustion engine with a manufacturer's design rate greater than 500 horsepower commencing operations in the 8-hour Ozone Control Area on or after June 1, 2004 shall employ air pollution control technology to control emissions, as provided in Section I.B (Condition 8.7.3). (Colorado Regulation No. 7, Part E, Section I.A.1) 8.7.2 The owner or operator of any existing natural gas-fired stationary or portable reciprocating internal combustion engine with a manufacturer's design rate greater than 500 horsepower, which existing engine was operating in the 8-hour Ozone Control Area prior to June 1, 2004, shall employ air pollution control technology on and after May 1, 2005, as provided in Section LB (Condition 8.7.3). (Colorado Regulation No. 7, Part E, Section I.A.2) 8.7.3 Air pollution control technology requirements: 8.7.3.1 For lean burn reciprocating internal combustion engines, an oxidation catalyst shall be required. A lean burn reciprocating internal combustion engine is one with a normal exhaust oxygen concentration of 2% by volume, or greater. (Colorado Regulation No. 7, Part E, Section I.B.2) 8.7.3.2 The emission control equipment required by this Condition 8.7.3 shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. (Colorado Regulation No. 7, Part E, Section I.B.3) Control of emissions from new, modified, existing, and relocated natural gas fired reciprocating internal combustion engines. (Part E, Section LD) 8.7.4 Except as provided in Section I.D.2.b below (Condition 8.7.5), the owner or operator of any natural gas fired reciprocating internal combustion engine that is either constructed or relocated to the state of Colorado from another state, on or after the date listed in the table below, shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below. (Colorado Regulation No. 7, Part E, Section I.D.2.a) 8.7.5 Actual emissions from natural gas fired reciprocating internal combustion engines shall not exceed the emission performance standards in the table below as expressed in units of grams per horsepower-hour (G/hp-hr) (Colorado Regulation No. 7, Part E, Section I.D.2.b) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 71 Table 2 from Colorado Regulation No. 7, Part E, Section I.D.2.b Maximum Construction or Emission Standard in g/hp-hr Engine Hp Relocation Date NOx CO VOC ≥ 500 HP On or after July 1, 2007 2.0 4.0 1.0 On or after July 1, 2010 1.0 2.0 0.7 Compliance with the NOx and CO emission limitations shall be monitored by conducting portable monitoring quarterly as specified in SECTION IV - 1. For comparison with the short—term limits in this condition, the results of the portable monitoring test shall be converted to units of g/hp-hr to assess compliance with the NOx and CO emission limitations in this Condition 8.7.5 In the absence of credible evidence to the contrary, compliance with the VOC limitation is presumed provided the portable monitoring indicates compliance with the NOx and CO emission limitations in this Condition 8.7.5. [Note that the following requirements of Colorado Regulation No. 7, Part E, Sections II.A.6 and ILA.7 apply to specific combustion equipment with uncontrolled actual emissions of NOx equal to or greater than five (5) tons per year, as specified in Part E, Section II.A.6.a, therefore, applicability may vary from year to yeas] Combustion Process Adjustment (Part E, Section II.A.6) 8.7.6 The owner or operator of a stationary internal combustion engine must conduct the following inspections and adjustments, as applicable (II.A.6.b.(iv)): 8.7.6.1 Change oil and filters as necessary. (II.A.6.b.(iv)(A)) 8.7.6.2 Inspect air cleaners, fuel filters, hoses, and belts and clean or replace as necessary. (II.A.6.b.(iv)(B)) 8.7.6.3 Inspect spark plugs and replace as necessary. (II.A.6.b.(iv)(C)) 8.7.7 The owner or operator must operate and maintain the stationary internal combustion engine consistent with manufacturer's specifications, if available, or good engineering and maintenance practices. (II.A.6.b.(vii)) 8.7.8 The owner or operator of stationary reciprocating internal combustion engines with uncontrolled actual emissions of NOx equal to or greater than five (5) tons per year that existed at major sources of NOx (greater than or equal to 100 tpy NOx) as of June 3, 2016, must conduct the initial combustion process adjustment by April 1, 2017. An owner or operator may rely on a combustion process adjustment conducted in accordance with applicable requirements and schedule of a New Source Performance Standard in 40 CFR Part 60 (November 17, 2016) or National Emission Standard for Hazardous Air Pollutants in 40 Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 72 CFR Part 63 (November 17, 2016) to satisfy the requirement to conduct an initial combustion process adjustment by April 1, 2017. (II.A.6.b.(viii)(A)) 8.7.9 The owner or operator must conduct subsequent combustion process adjustments at least once every twelve (12) months after the initial combustion adjustment, or on the applicable schedule according to Sections II.A.6.c.(i). or II.A.6.c.(ii) (Conditions 8.7.10.1 or 8.7.10.2). (ILA.6.b.(viii)(C)) 8.7.10 As an alternative to the requirements described in Sections II.A.6.b.(iv), II.A.6.b.(Vii) and II.A.6.b.(viii) (Conditions 8.7.6 through 8.7.9) (II.A.6.c.): 8.7.10.1 The owner or operator may conduct the combustion process adjustment according to the manufacturer recommended procedures and schedule (II.A.6.c.(i)); or 8.7.10.2 The owner or operator of combustion equipment that is subject to and required to conduct a period tune-up or combustion adjustment by the applicable requirements of a New Source Performance Standard in 40 CFR Part 60 (December 19, 2019)or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (December 19, 2019) may conduct tune-ups or adjustments according to the schedule and procedures of the applicable requirements of 40 CFR Part 60 (December 19, 2019) or 40 CFR Part 63 (December 19, 2019). (II.A.6.c.(ii)) Recordkeeping (II.A.7) 8.7.11 The following records must be kept for a period of five years and made available to the Division upon request (II.A.7): 8.7.12 For stationary combustion equipment subject to the combustion process adjustment requirements in Section II.A.6 (Conditions 8.7.6 through 8.7.10), the following recordkeeping requirements apply (ILA.7.f.): 8.7.13 The owner or operator must create a record once every calendar year identifying the combustion equipment at the facility subject to Section ILA and including for each combustion equipment (II.A.7.f.(i)): 8.7.13.1 The date of the adjustment (II.A.7.f.(i)(A)); 8.7.112 Whether the combustion process adjustment under Sections II.A.6.b.(iv) (Condition 8.7.6) was followed, and what procedures were performed (II.A.7.f.(i)(B)); 8.7.113 Whether a combustion process adjustment under Sections II.A.6.c.(i) and II.A.6.c.(ii) (Conditions 8.7.10.1 and 8.7.10.2) was followed, what procedures were performed, and what New Source Performance Standard or National Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 73 Emission Standard for Hazardous Air Pollutants applied, if any (II.A.7.f.(i)(C)); and 8.7.13.4 A description of any corrective action taken. (II.A.7.f.(i)(D)) 8.7.13.5 If the owner or operator conducts the combustion process adjustment according to the manufacturer recommended procedures and schedule and the manufacturer specifies a combustion process adjustment on an operation time schedule, the hours of operation. (II.A.7.f.(i)(E)) 8.7.14 The owner or operator must retain manufacturer recommended procedures, specifications, and maintenance schedule if utilized under II.A.6.c.(i) (Conditions 8.7.10.1) for the life of the equipment. (II.A.7.f.(ii)) 8.7.15 As an alternative to the requirements described in Section II.A.7.f.(i) (Condition 8.7.13), the owner or operator may comply with applicable recordkeeping requirements related to combustion process adjustments conducted according to a New Source Performance Standard in 40 CFR Part 60 (November 17, 2016) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (November 17, 2016). (II.A.7.f.(iii)) Note: 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. (Section VI Condition 22.b) 8.8 This engine and associated oxidation catalyst shall be operated and maintained in accordance with internal operating and maintenance standards, which shall consider manufacturer's recommendations and good air pollution control practices for minimizing emissions, at all times, including periods of start- up, shut-down and malfunction. These internal operating and maintenance standards shall be kept on site and made available to the Division upon request. Parameters associated with this engine and oxidizing catalyst unit shall be monitored as follows: 8.8.1 The pressure drop across the catalyst and the catalyst inlet temperature shall be monitored according to SECTION IV - 5.1.13. 8.8.2 The pressure drop across the catalyst and the catalyst inlet temperature shall be recorded for this engine during each portable monitoring event required by Condition 8.L2. 8.8.3 The oxygen concentration in the engine exhaust gas shall be measured and recorded for this engine during each portable monitoring event required by Condition 8.1.2. Records of all data and maintenance performed associated with the engine and catalyst operation and parameter monitoring of this Condition 8.8 shall be maintained for Division inspection upon request. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 74 8.9 This engine is subject to the requirements in 40 CFR Part 63 Subpart ZZZZ, "National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines", as specified in SECTION IV - 5. 8.10 This engine is subject to the requirements in 40 CFR Part 63 Subpart A "General Provisions", as specified in SECTION IV - 11. 8.11 This engine is subject to the requirements in 40 CFR Part 60 Subpart JJJJ, "Standards of Performance for Stationary Spark Ignition Internal Combustion Engines", as specified in SECTION IV - 6. 8.12 This engine is subject to the requirements in 40 CFR Part 60 Subpart A "General Provisions", as specified in SECTION IV - 10. 8.13 This engine is subject to the Compliance Assurance Monitoring (CAM) requirements with respect to the annual CO emission limitation in Condition 8.1. Compliance with the CAM requirements shall be monitored in accordance with the requirements in SECTION IV - 12 and the CAM Plan in APPENDIX H. 8.14 Emissions from this engine shall be released from an unobstructed vertical stack with a minimum height of 52.8 feet above ground level (Colorado Construction Permit lOWE1071). The source shall maintain records of the stack height for this engine to be made available to the Division upon request. 8.15 This facility shall be completely enclosed by a fence line and posted with no trespassing signs that preclude public access to this site as described in the modeling analysis for this facility. This requirement is imposed as a result of the modeled ambient air NOx impacts that result from the emissions from this source. (Colorado Construction Permit IOWE1071) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 75 9. F-4: One(1) John Zink 65' Air-Assisted Process Flare (AIRS point 070) Permit Compliance Monitoring Parameter Condition Limitations Number Emission Factor Method Interval Emissions Routed to Flare that Requirements for Certain Process 9.1 Achieves 98%Reduction in See Condition 9.1 VOC Emissions from Process Gases Gases NOx 9 2 8.5 tons/yr 0.138 lb/MMBtu Recordkeeping Monthly CO 17.0 tons/yr 0.2755 lb/MMBtu and Calculation Recordkeeping Monthly and Calculation Site Specific, VOC 9.3 12.7 tons/yr See Condition 9.3 i Ste Specific EF Development Quarterly Flow Meter and Gas Consumed by Process,Purge and pilot gas: Calculation the Flare 9.4 78.4 MMscf/yr See Condition Monthly 9.4 ASTM or other Btu Content of Division 9.5 Quarterly Flare Gas Streams Approved Method Flare Hours of 9.6 Recordkeeping Monthly Operation Visible Visible Emission Requirements Emissions Daily Observations Temperature A Flame Shall be Present at All Sensor or Flame Times the Flare is Operated Detection Continuously Flare Operational Device with 9.7 Alarm Requirements Flare Specifications—Btu Content of Gas and Tip See Condition 9.7 Velocity Flare Shall be Operated at All Times Emissions May be Certification Annually Vented to it Not to Exceed 30%for a Period or Periods Aggregating More Opacity 9.8 See Condition 9.8 than Six(6)Minutes in any 60 Consecutive Minutes Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 76 9.1 Emissions from maintenance activities, purge gas, and process malfunctions/upsets shall be routed through a closed vent system to the flare prior to being emitted. The flare shall be capable of reducing VOC emissions from these activities by 98% or greater (Colorado Construction Permit 14WE0142, as modified under the provisions of Section I, Condition 1.3). In the absence of credible evidence to the contrary, compliance with the 98% reduction requirement shall be presumed provided the requirements in Condition 9.7 are met. 9.2 Emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO) from the flare shall not exceed the limitations listed in Summary Table 9 above (Colorado Construction Permit 14WE0142). Monthly emissions shall be calculated, by the end of the subsequent month, using the emission factors in Summary Table 9 above and the total heat input of inlet gas streams routed to the flare (combined process/purge gas stream and pilot gas), in the equation below: lb tons EF ( }x Total Heat Input (NIMBI Emissions l mont month/ 2000 ton Total heat input to the flare from the combined process/purge gas stream and pilot gas stream shall be calculated in the following equation: p (MMBtu)= ` - (MMscf� (MMBtu) Total heat input /) Stream volume x Stream heat content mo month MMscf Each Stream The monthly stream volumes used to calculate total heat input shall be those metered/calculated as required by Condition 9.4. The heat contents of the input streams shall be determined as required by Condition 9.5. Monthly emissions shall be summed and 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. Records of calculations shall be kept in a log to be made available to the Division upon request. 9.3 Volatile Organic Compound (VOC) emissions shall not exceed the limitation listed in Summary Table 9 above (Colorado Construction Permit 14WE0142, as modified under the provisions of Section I, Condition 1.3). Compliance with the annual limitation shall be monitored as follows: On a quarterly basis, the operator shall complete a site specific extended gas analysis of the waste gas routed to the flare in order to verify the VOC contents of the combined process/purge gas stream. The extended gas analysis shall be conducted using ASTM methods or equivalent, if approved in advance by the Division. On an annual basis, the operator shall complete a site specific extended gas analysis of the residue/fuel gas at this site in order to verify the VOC contents of the pilot gas stream. The extended gas analysis shall be conducted using ASTM methods or equivalent, if approved in advance by the Division. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 77 Monthly emissions shall be calculated using the molar fraction of VOC constituents determined from the most recent extended gas analyses and the monthly flare throughput (volume of gases consumed in the flare, as required by Condition 9.4) in the equation below: s,f.(i VOC xi x Mi X month mol sample lb —mol tons mol i lg ) Flare Throughput ( I ( ( 379.3 X 2000 lb )� _ ([b—mtil (Cori/ Where: xi = Molar Fraction of VOC constituent i;mol constituent i/mol sample = Molar Mass VOC constituent i;lb/lb — mol Emissions from the combined process/purge gas stream and the pilot gas stream shall be summed for comparison to the annual limit. A control efficiency of 98% may be applied to the emissions calculated in this Condition 9.3 for any time that the flare is operated in compliance with Condition 9.7 (flare requirements). Emissions that occur during pilot flame outages (as recorded according to Condition 9.7.2) shall assume 0% control. For APEN reporting purposes, HAP emissions shall be calculated, in the equation above, using the molar mass and molar fraction of each individual HAP, as obtained from the periodic gas analyses. Monthly emissions 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. Records of extended gas analyses performed and emissions calculations shall be kept in a log to be made available to the Division upon request. 9.4 The total volume of all gases consumed in the flare shall not exceed the limitation listed in Summary Table 9 above (Colorado Construction Permit 14WE0142). The volume of process/purge gas routed to the flare shall be continuously monitored and recorded monthly using the existing combined stream flow meter. The volume of pilot gas consumed in the flare shall be calculated based on the maximum design rate of the pilot (88 scf/hr) and the hours of operation. Monthly volumes of metered process/purge gas and calculated pilot gas consumed in the flare shall be summed and used in a rolling twelve month total to monitor compliance with the annual limitation. Each month, a new twelve month total shall be calculated based on the previous twelve months' data. Records of calculations shall be kept in a log to be made available to the Division upon request. 9.5 The Btu content of the combined process/purge gas stream routed to this flare shall be verified quarterly using the appropriate ASTM methods or equivalent, if approved in advance by the Division. The Btu content of the stream shall be based on the higher heat content of the stream. Calculations of monthly emissions shall be made using the heat content derived from the most recent required analysis. The Btu content of the pilot gas stream routed to this flare shall be verified annually using the appropriate ASTM methods or equivalent, if approved in advance by the Division. The Btu content of Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 78 the streams shall be based on the higher heat content of the streams. Calculations of monthly emissions shall be made using the heat content derived from the most recent required analysis. 9.6 Hours of operation for the flare shall be monitored and recorded monthly. Hours of operation shall be used to determine the quantity of pilot gas burned as required by Condition 9.4. 9.7 The owner or operator shall design, construct, operate and maintain the flare according to the requirements set out in 40 CFR §60.18, including, but not limited to, the following (Colorado Construction Permit 14WE0142, as modified under the provisions of Section I, Condition 1.3): 9.7.1 Flares shall be designed for and operated with no visible emissions, as determined by the methods specified in Condition 9.7.1.1, except for periods not to exceed a total of 5 minutes during any 2 consecutive hours (§60.18(c)(1)). Test Method 22 of appendix A to 40 CFR 60 shall be used to determine the compliance of flares with the visible emission provisions of this subpart. The observation period is 2 hours and shall be used according to Method 22. Compliance with the visible emissions requirements shall be monitored as follows: 9.7.1.1 A visible emissions observation shall be conducted daily when the flare is operating. 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 daily 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). Records of all daily visible emissions observations and any Method 22 observations conducted shall be kept for Division review upon request. 9.7.2 Flares shall be operated with a flame present at all times (§60.18(c)(2)). The presence of a flare pilot flame shall be continuously monitored using a thermocouple or any other equivalent device to detect the presence of a flame (§60.18(f)(2)). The device shall be equipped with an alarm to indicate no ignition of the pilot flame. Records of the times and Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 79 duration of all periods of pilot flame outages and estimated emissions shall be maintained and made available to the Division upon request. Estimated emissions during pilot flame outages (uncontrolled emissions) shall assume 0% control and shall be used as specified in Condition 9.3 to monitor compliance with the VOC emission limitation. 9.7.3 This flare shall meet the following specifications (Construction Permit 14WE0142, as modified under the provisions of Section I, Condition 1.3): 9.7.3.1 This flare 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 (§60.18(c)(3)(ii)). The net heating value of the gas being combusted shall be determined by the methods specified in Condition 9.5. 9.7.3.2 Air-assisted flares shall be designed and operated with an exit velocity less than the velocity, Vmax, as determined by the method specified in 40 CFR §60.18(f)(6) (§60.18(c)(5)). The actual exit velocity of a flare shall be determined by dividing the volumetric flowrate (in units of standard temperature and pressure), as determined by Reference Methods 2, 2A, 2C, or 2D as appropriate; by the unobstructed (free) cross sectional area of the flare tip. ((§60.18(f)(4)) Compliance with the exit velocity limitation shall be monitored monthly by calculating the maximum exit velocity of the flare for the month, based on actual operating conditions, and comparing it to the limit specified by §60.18(f)(6). 9.7.3.3 This flare shall be monitored to ensure that it is operated and maintained in conformance with its design (§60.18(d)). Records of manufacturer operation and maintenance requirements and all maintenance performed on this flare shall be kept in a log to be made available to the Division upon request. 9.7.3.4 This flare shall be operated at all times when emissions may be vented to this flare (§60.18(e)). 9.8 No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Colorado Regulation No. 1, Section II.A.5) In the absence of credible evidence to the contrary, compliance with this opacity requirement shall be presumed provided the requirements in Condition 9.7.1.1 are met. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 80 10. Insignificant Engines Subject to NSPS Requirements: GEN 2 GEN2: One (1) Caterpillar C18 DITA, 900 HP emergency generator engine Permit Monitoring Parameter Condition Limitations Number Emission Factor Method Interval Hours of 10.1 Recordkeeping Annually Operation Only Diesel SO= 10.2 0.8 lb/MMBtu Fuel Restriction Fuel is Used as Fuel Not to exceed 20%, except as provided for below For Certain Operational Opacity 10.3 Activities -Not to Exceed 30% EPA Method 9 See Condition for a Period or Periods 10.3 Aggregating More than Six(6) Minutes in any 60 Consecutive Minutes 40CFR 60 NMITC+NOx-6.5 g/kW-hr 10.4 CO—3.5 g/kW-hr See Condition 10.4 Subpart IIII PM-0.20 g/kW-hr 40 CFR 60 Subpart A— 10.5 See Condition 10.5 General Provisions Stack Height 10.6 Engine stack height shall be no See Condition 10.6 Requirement less than 14 feet Note: This diesel generator engine is exempt from the APEN reporting requirements in Regulation No. 3,Part A provided actual uncontrolled emissions do not exceed the APEN de minimis level(1 ton/yr NOx)per Colorado Regulation No. 3,Part A, Section ILD.1.a. Based on manufacturer's emission factors(5.84 g/hp-hr) and design rate(900 hp), emissions exceed the APEN de minimis level at 173 hrs. 10.1 Hours of operation for this emergency generator engine shall be monitored annually (calendar year) and recorded in a log to be made available to the Division upon request. If annual hours of operation exceed 173, an APEN is required for this engine and shall be filed. If annual hours of operation equal or exceed 863 hours for this engine, the engine is no longer exempt from the permitting requirements in Colorado Regulation No. 3, Part B (per Reg. 3, Part B, Section II.D.1.c.(iii)) and the permittee shall submit an application to revise this permit within 30 days in order to include the appropriate applicable requirements. 10.2 Sulfur Dioxide (SO2) emissions from this engine shall not exceed 0.8 lbs/MMBtu (Colorado Regulation No. 1, Section VI.B.4.b.(i)). In the absence of credible evidence to the contrary, compliance with the SO2 emission limitation shall be presumed since only diesel fuel is permitted to be used as fuel in this Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 81 engine. The permittee shall maintain records that verify that only diesel fuel is used as fuel in this engine. 10.3 The following opacity requirements apply to this engine: 10.3.1 Except as provided for in Condition 10.3.2 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section II.A.1). 10.3.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, process modifications, or adjustment or occasional cleaning of control equipment 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). Compliance with these limitations shall be monitored by conducting opacity observations in accordance with EPA Reference Method 9 as follows: 10.3.3 To monitor compliance with the opacity limitation of Condition 10.3.1, a Method 9 opacity observation shall be performed at least once per calendar year of operation when the engine is operating under load during conditions suitable for properly performing a valid Method 9 observation. If the engine has not been operated under load, or if a valid Method 9 observation could not be performed when the engine did operate during the calendar year, the permittee is not required to operate the engine for the sole purpose of obtaining an annual opacity observation. Annual opacity observations for an individual engine shall be separated by a period of four(4) months. If an engine is operated more than 250 hours in any calendar year period, a second opacity observation shall be conducted. If two opacity readings are conducted in the annual (calendar year) period, such readings shall be conducted at least thirty days apart. 10.3.4 A Method 9 observation shall be performed any time an engine start-up requires longer than thirty (30) consecutive minutes. A record shall be kept of the date and time this engine was started and when it was shutdown. 10.3.5 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 opacity limit shall be considered to exist from the time a Method 9 reading is taken that shows an exceedance of the opacity limit until a Method 9 reading is taken that shows the opacity is less than the opacity limit. 10.3.6 All Method 9 opacity observations shall be performed by an observer with current and valid Method 9 certification. Results of Method 9 readings and a copy of the certified Method 9 reader's certificate shall be kept on site and made available to the Division upon request. 10.4 This engine is subject to the requirements in 40 CFR Part 60 Subpart IIII, "Standards of Performance for Stationary Compression Ignition Internal Combustion Engines", as specified in SECTION IV - 7. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 82 10.5 This engine is subject to the requirements in 40 CFR Part 60 Subpart A "General Provisions", as specified in SECTION IV - 10. 10.6 Emissions from this engine shall be released from an unobstructed vertical stack with a minimum height of 14 feet above ground level. (Construction Permit 10WE1587) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 83 SECTION III - Specific Permit Terms — Platte Valley 1. S001-S004: Four (4) Ajax DPC-540LE, 514 HP engines (AIRS IDs 038-041) [Limits Apply to Each Engine Individually] Permit Compliance Emission Monitoring Parameter Condition Limitations Number Factor Method Interval r 0.514 1b/MMBtu Recordkeeping Monthly NOx 11.6 tons/yr and Calculation 1.1 CO 11.6 tons/yr 0.3861b/MMBtu Portable uarterl Monitoring Q Y VOC 1.2 5.8 tons/yr 0.120 lb/MMBtu Recordkeeping Monthly and Calculation Natural Gas Individual Engine 1.3 42.57 MMscf/yr Monthly Consumption Fuel Meter ASTM or other Btu Content of 1 4 Division Semi-annually Natural Gas Approved Method Hours of 1.5 Recordkeeping Monthly Operation Not to exceed 20%, except as provided for below For Certain Operational Only Natural Opacity 1.6 Activities—Not to Exceed Fuel Restriction Gas is Used as 30%for a Period or Periods Fuel Aggregating More than Six (6)Minutes in any 60 Consecutive Minutes Engine Operation 1.7 See Condition 1.7 and Maintenance Colorado Regulation No. 7, 1.8 See Condition 1.8 Part E 1.1 Emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO) from each engine shall not exceed the limitations listed in Summary Table 1 above (Colorado Construction Permits 93WE157-(1-4)). Compliance with the emission limitations shall be monitored as follows: 1.1.1 Except as provided below, the emission factors listed in Summary Table 1 above have been approved by the Division and shall be used to calculate emissions from these engines as follows: Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 84 Monthly emissions shall be calculated, by the end of the subsequent month, using the emission factors in Summary Table 1 above, the monthly natural gas consumption (required by Condition 1.3) and the Btu content of the natural gas (required by Condition 1.4) in the equation below: tons/mo =fEF (1b/MMBtu)x fuel use (MMscf/mo)x heat content of fuel (MMBtu/MMscf)] 2000 lb/ton Monthly emissions 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. Records of calculations shall be kept in a log to be made available to the Division upon request. If the results of the portable analyzer testing conducted under the provisions of Condition 1.1.2 show that either the NOx or CO emission rates/factors are greater than those listed above, 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 rates/factors within 60 days of the completion of the test. 1.1.2 Portable Monitoring shall be conducted quarterly in accordance with the requirements in SECTION IV - 1. 1.2 Volatile Organic Compound (VOC) emissions from each engine shall not exceed the limitation listed in Summary Table 1 above (Colorado Construction Permits 93WE157-(1-4)). Monthly emissions shall be calculated, by the end of the subsequent month, using the emission factors in Summary Table 1 above, the monthly natural gas consumption (required by Condition 1.3), and the Btu content of the natural gas (required by Condition 1.4) in the equation below: tons/mo =jEF (1b/MMBtu)x fuel use (MMscf/mo)x heat content of fuel (MMBtu/MMscf)] 2000 lb/ton Monthly emissions shall be used in a twelve month rolling total 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. 1.3 Natural gas consumption for each engine shall not exceed the limitation listed in Summary Table 1 above. (Colorado Construction Permits 93WE157-(1-4)). Natural gas consumption for each engine shall be recorded monthly using the existing individual engine fuel meters. Monthly natural gas consumption 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. Records of calculations shall be kept in a log to be made available to the Division upon request. 1.4 The Btu content of the natural gas used to fuel these engines shall be verified semi-annually using the appropriate ASTM Methods or equivalent, if approved in advance by the Division. The Btu content of Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 85 the natural gas shall be based on the higher heating value of the fuel. Calculations of monthly emissions shall be made using the heat content derived from the most recent required analysis. 1.5 Hours of operation for each engine shall be monitored monthly and recorded and maintained to be available to the Division upon request. Monthly hours of operation shall be used in a running total for each annual compliance period. The hours of operation shall be used to determine if portable monitoring is required as specified in SECTION IV - 1. 1.6 The following opacity requirements apply: 1.6.1 Except as provided for in Condition 1.6.2 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section II.A.1). 1.6.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, process modifications, or adjustment or occasional cleaning of control equipment 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 opacity requirements of this Condition 1.6 shall be presumed since only natural gas is permitted to be used as fuel in these engines. 1.7 These engines shall be operated and maintained in accordance with internal operating and maintenance standards, which shall consider manufacturer's recommendations and good air pollution control practices for minimizing emissions, at all times, including periods of start-up, shut-down and malfunction. These internal operating and maintenance standards shall be kept on site and made available to the Division upon request. 1.8 These engines are subject to the requirements of Colorado Regulation No. 7, Part E, "Combustion Equipment and Major Source RACT", including, but not limited to, the following: [The requirements below reflect the current rule language as of the revisions to 5 CCR 1001-9 Colorado Regulation No. 7 published in the Colorado Register on 01/25/2020 and effective on 02/14/2020. However, if revisions to this rule are published at a later date, the owner or operator is subject to the requirements contained in the revised version of Colorado Regulation No. 7.] [Note that the following requirements of Colorado Regulation No. 7, Part E, Sections II.A.6 and ILA.7 apply to specific combustion equipment with uncontrolled actual emissions of NOx equal to or greater than five (S) tons per year, as specified in Part E, Section II.A.6.a, therefore, applicability may vary from year to yeas] Combustion Process Adjustment (Part E, Section II.A.6) 1.8.1 The owner or operator of a stationary internal combustion engine must conduct the following inspections and adjustments, as applicable (II.A.6.b.(iv)): Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 86 L8.1.1 Change oil and filters as necessary. (II.A.6.b.(iv)(A)) 1.8.1.2 Inspect air cleaners, fuel filters, hoses, and belts and clean or replace as necessary. (II.A.6.b.(iv)(B)) 1.8.1.3 Inspect spark plugs and replace as necessary. (II.A.6.b.(iv)(C)) L8.2 The owner or operator must operate and maintain the stationary internal combustion engine consistent with manufacturer's specifications, if available, or good engineering and maintenance practices. (II.A.6.b.(vii)) L8.3 The owner or operator of stationary reciprocating internal combustion engines with uncontrolled actual emissions of NOx equal to or greater than five (5) tons per year that existed at major sources of NOx (greater than or equal to 100 tpy NOx) as of June 3, 2016, must conduct the initial combustion process adjustment by April 1, 2017. An owner or operator may rely on a combustion process adjustment conducted in accordance with applicable requirements and schedule of a New Source Performance Standard in 40 CFR Part 60 (November 17, 2016) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (November 17, 2016) to satisfy the requirement to conduct an initial combustion process adjustment by April 1, 2017. (II.A.6.b.(viii)(A)) L8.4 The owner or operator must conduct subsequent combustion process adjustments at least once every twelve (12) months after the initial combustion adjustment, or on the applicable schedule according to Sections II.A.6.c.(i). or II.A.6.c.(ii) (Conditions 1.8.5.1 or 1.8.5.2). (II.A.6.b.(viii)(C)) 1.8.5 As an alternative to the requirements described in Sections II.A.6.b.(iv), II.A.6.b.(vii) and II.A.6.b.(viii) (Conditions 1.8.1 through 1.8.4) (II.A.6.c.): 1.8.5.1 The owner or operator may conduct the combustion process adjustment according to the manufacturer recommended procedures and schedule (II.A.6.c.(i)); or 1.8.5.2 The owner or operator of combustion equipment that is subject to and required to conduct a period tune-up or combustion adjustment by the applicable requirements of a New Source Performance Standard in 40 CFR Part 60 (December 19, 2019) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (December 19, 2019) may conduct tune-ups or adjustments according to the schedule and procedures of the applicable requirements of 40 CFR Part 60 (December 19, 2019) or 40 CFR Part 63 (December 19, 2019). (II.A.6.c.(ii)) Recordkeeping (II.A.7) 1.8.6 The following records must be kept for a period of five years and made available to the Division upon request (II.A.7): Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 87 L8.7 For stationary combustion equipment subject to the combustion process adjustment requirements in Section II.A.6 (Conditions L8.1 through 1.8.5), the following recordkeeping requirements apply (II.A.7.f.): 1.8.8 The owner or operator must create a record once every calendar year identifying the combustion equipment at the facility subject to Section ILA and including for each combustion equipment (II.A.7.f.(i)): 1.8.8.1 The date of the adjustment (II.A.7.f.(i)(A)); 1.8.8.2 Whether the combustion process adjustment under Sections II.A.6.b.(iv) (Condition 1.8.1) was followed, and what procedures were performed (II.A.7.f.(i)(B)); 1.8.8.3 Whether a combustion process adjustment under Sections II.A.6.c.(i) and II.A.6.c.(ii) (Conditions 1.8.5.1 and L8.5.2) was followed, what procedures were performed, and what New Source Performance Standard or National Emission Standard for Hazardous Air Pollutants applied, if any (II.A.7.f.(i)(C)); and L8.8.4 A description of any corrective action taken. (II.A.7.f.(i)(D)) 1.8.8.5 If the owner or operator conducts the combustion process adjustment according to the manufacturer recommended procedures and schedule and the manufacturer specifies a combustion process adjustment on an operation time schedule, the hours of operation. (II.A.7.f.(i)(E)) 1.8.9 The owner or operator must retain manufacturer recommended procedures, specifications, and maintenance schedule if utilized under II.A.6.c.(i) (Conditions 1.8.5.1) for the life of the equipment. (II.A.7.f.(ii)) 1.8.10 As an alternative to the requirements described in Section II.A.7.f.(i) (Condition 1.8.8), the owner or operator may comply with applicable recordkeeping requirements related to combustion process adjustments conducted according to a New Source Performance Standard in 40 CFR Part 60 (November 17, 2016) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (November 17, 2016). (II.A.7.f.(iii)) Note: 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. (Section VI Condition 22.b) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 88 2. S007: Platte Valley Plant Fugitive Emissions from Equipment Leaks (AIRS point 042) Permit Compliance Emission Monitoring Parameter Condition Limitation Number Factor Method Interval By Component Type VOC 46.7 tons/yr —EPA Protocol for Recordkeeping and Monthly Equipment Leak Calculation 2.1 Estimates EPA Division Gas Analysis Semi-Annually Approved Methods Colorado Regulation No. 7, 2.2 See Condition 2.2 Part D, Section I 40 CFR 60 2.3 See Condition 2.3 Subpart 0000a 40 CFR 60 Subpart A 2.4 See Condition 2.4 General Provisions 40 CFR Part 63 2.5 See Condition 2.5 Subpart MI 40 CFR Part 63 Subpart A 2.6 See Condition 2.6 General Provisions 2.1 Total VOC emissions from equipment leaks shall not exceed the limitation listed in Summary Table 2 above (Colorado Construction Permit 93WE157-7 and Colorado Regulation No. 3, Part C, Section III.B.7, as modified under the provisions of Section 1, Condition L3). Emissions shall be calculated using the emission factors and equations listed below. Emission Factors for individual types of components in lb/component-hr from the reference Protocol for Equipment Leak Emission Estimates, EPA, November 1995, EPA-453/R-95-017, Table 2-4. The most appropriate emission factors from the EPA document shall be used. These emission factors are fixed until changed by established permit modification procedures. Emission Factors (lb/component-hr) Component Gas Service Light Oil Service Heavy Oil Service Valves 9.92 x 10-3 5.51 x 10-3 L85 x 10-5 Connectors 4.41 x 10-4 4.63 x 10-4 1.65 x 10-5 Flanges 8.60 x 10-4 2.43 x 10-4 8.60 x 10-' Pump Seals 5.29 x 10-3 2.87 x 10 L13 x 10-3 (1) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 89 Open-Ended 4.41 X 10-3 3.09 X 10-3 3.09 X 10-4 Lines Other' 1.94 x 10 L65 X 10 7.05 X 10-5 'Emission factor for pump seals in heavy oil service proposed by Kerr-McGee. This represents a conservative estimate since no emission factor for this component and service is included in Table 2-4 of EPA-453/R-95-017. 'Other should be applied for any equipment type other than connectors, flanges, open-ended lines, pumps, or valves Monthly determination of VOC emissions shall be calculated by the end of the subsequent month using the appropriate emission factors from the table above, the control factors as specified below, the most recent extended gas and liquids analyses (as required by Condition 2.1.1), and the values from the most recent component count (as required by Condition 2.1.2) in the equation below: hr days 1 ton Emissions (tons/month) = CC x EF x 24 (—) x x x x Control Factor x ( day month 200010 Where: CC = component count,quantity EF = emission factor,lb/component * hr (per component and service type) x = VOC content instream,mass fraction Control Factor = 1 — (Control Effectiveness (—% )) loo The source shall be allowed to use the following values for control effectiveness (for only the equipment type and service referenced) when the Leak Detection and Repair program of Condition 23 is demonstrated. Equipment Type and Service Control Effectiveness (%) Valves — gas service 96 Valves light liquid service 95 Pumps — light liquid service 88 Connectors/Flanges — all services 81 The total fugitive VOC emissions shall be the sum of emissions for each component type. Monthly VOC emissions 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. Records of calculations shall be maintained and made available to the Division upon request. 2.1.1 Site specific extended natural gas and natural gas liquids analyses shall be performed quarterly using ASTM methods or equivalent, if approved in advance by the Division, for each process stream representative of those used to develop the emissions limits for fugitive emissions associated with this AIRS point, as listed in the table below. Frequency of Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 90 extended analyses shall move to semi-annually after the first year, then to annually after the second year if the VOC weight percent of the streams remain consistently at or below the values listed. Frequency will revert back to quarterly if any of the VOC concentrations exceed the listed values. The VOC content from the most recent analyses shall be used to calculate emissions according to this Condition 2.1. Representative Fluid VOC Composition(wt%) Inlet Gas 25 Fuel Gas or Residue Gas 9 NGL or C3+ 100 Heavy Oil or Light Oil 100 2.1.2 A running tally shall be kept of all additions and subtractions to the component count. The most recent count shall be used for emission calculations and compliance purposes. Records of the component count running tally shall be kept and made available for Division review upon request. 2.2 This source is subject to the following requirements of Colorado Regulation No. 7, Part D, Section I, "Volatile Organic Compound Emissions from Oil and Gas Operations". [The requirements below reflect the current rule language as of the revisions to 5 CCR 1001-9 Colorado Regulation No. 7 published in the Colorado Register on 01/25/2020 and effective on 02/14/2020. However, if revisions to this rule are published at a later date, the owner or operator is subject to the requirements contained in the revised version of Colorado Regulation No. 7.] 2.2.1 For fugitive volatile organic compound emissions from leaking equipment, the leak detection and repair(LDAR) program as provided at 40 CFR Part 60, Subpart OOOO (July 1, 2017) applies, regardless of the date of construction of the affected facility, unless subject to the LDAR program provided at 40 CFR Part 60, Subpart 0000a (July 1, 2017). (Colorado Regulation No. 7, Part D, Section I.G.1) 2.2.2 Natural gas processing plants within the 8-hour Ozone Control Area constructed before January 1, 2018 must comply with the requirements of Section I.G beginning January 1, 2019. (Colorado Regulation No. 7, Part D, Section I.G.3) 2.2.3 All hydrocarbon liquids and produced water collection, storage, processing and handling operations, regardless of size, must be designed, operated and maintained so as to minimize emission of volatile organic compounds to the atmosphere to the maximum extent practicable. (Colorado Regulation No. 7, Part D, Section I.C.1.b) 2.3 These sources of fugitive emissions from equipment leaks are subject to the requirements in 40 CFR 60 Subpart OOOOa, "Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After September 18, 2015", as specified in SECTION IV - 3. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 91 2.4 These sources of fugitive emissions from equipment leaks are subject to the requirements in 40 CFR Part 60 Subpart A, "General Provisions"(as adopted by reference in Colorado Regulation No. 6, Part A, Subpart A), as specified in SECTION IV - 10. 2.5 These sources of fugitive emissions from equipment leaks are subject to the requirements in 40 CFR 63, Subpart HH, "National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities", as adopted by reference in Colorado Regulation No. 8, Part E, Section III, Subpart HH, as specified in SECTION IV - 2. Note: The conditions of 40 CFR 63 Subpart HH referenced here include periodic reporting requirements for sources that are subject to and controlled under the requirements specified in 40 CFR 60 Subpart OOOO. The equipment leak provisions of, 63.769 of Subpart HH do not apply to ancillary equipment subject to and controlled under 40 CFR 60 Subpart OOOO, except that periodic reports must be submitted as specified in §63.775(e), per§63.769(b). Per 40 CFR, Part 60, Subpart OOOO, a source is deemed to be in compliance with Subpart OOOO if the source is in compliance with all applicable provisions of 40 CFR, Part 60, Subpart 0000a (§60.5370(d). 2.6 These sources of fugitive emissions from equipment leaks are subject to the requirements in 40 CFR 63, Subpart A, "General Provisions", as adopted by reference in Colorado Regulation No. 8, Part E, Section I, Subpart A, as specified in SECTION IV - 11. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 92 3. S009: Natural Gas Liquids (NGL) Amine Sweetening Unit, 15,000 BBL/day (AIRS point 043) Permit Compliance Emission Monitoring Parameter Condition Limitation Number Factor Method Interval NOx 3 1 6.5 tons/yr 0.098 lb/MMBtu Recordkeeping and Monthly CO 5.5 tons/yr 0.082 lb/MMBtu Calculation VOC 1.1 tons/yr As Developed According Recordkeeping and Monthly to Condition 3.3.1 Calculation Extended Gas 3.2 Analysis of Gases ASTM Methods or Routed to the Equivalent Semi-annually Thermal Oxidizer Periodic Compliance EPA Approved Tests Methods Every 6 Months 3.3 Emission Factor See Condition Development 3.3.1 Every 6 Months Natural Gas Liquids Flow Meter and 3.4 5,475,000 BBL/yr Monthly Processed Recordkeeping Combustion of Waste Gas and 3.5 301.4 MMscf/yr Flow Meters and Monthly Supplemental Fuel Recordkeeping Hours of Operation 3.6 Recordkeeping Monthly Amine Solution Flow Meter and Recirculation Rate 3.7 100 gallons/minute Recordkeeping Monthly Amine Standard Industry Concentration in 3.8 45%by weight Method Weekly Solution Thermal Oxidizer 1400 °F, or Minimum temperature of the Combustion 3.9 most recent Thermocouple Continuously Division approved Temperature stack test Not to exceed 20%, except as provided for below Opacity 3.10 For Certain See Condition 3.10 Operational Activities—Not to Exceed 30% 40 CFR 60 3.11 See Condition 3.11 Subpart LLL 40 CFR 60 Subpart A—General 3.12 See Condition 3.12 Provisions Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 93 Operation and 3.13 See Condition 3.13 Maintenance Compliance Assurance 3.14 See Condition 3.14 Monitoring(CAM) 3.1 NOx and CO emissions from the thermal oxidizer(controlling emissions from the natural gas liquids amine unit) shall not exceed the limitations listed in Summary Table 3 above (Colorado Construction Permit 12WE1277). Compliance with the NOx and CO limits shall be monitored as follows: Monthly emissions of NOx and CO shall be calculated by the end of the subsequent month using the emission factors above and the total heat input of inlet gas streams routed to the thermal oxidizer including acid gas, flash gas, and fuel gas (thermal oxidizer burner and supplemental fuel) in the equation below: tons EF ( `v ) x Total Heat Input ( '"��` ) Emissions = month 2000 (tin) Total heat input to the thermal oxidizer (acid gas, flash gas, and fuel gas input streams) shall be calculated in the following equation: MMBtu MMBtu Total heat input ( ) _ (Stream volume (MMscf) x Stream heat content ) month month MMscf Each Stream The monthly stream volumes used to calculate total heat input shall be those metered as required by Condition 3.5. The heat contents of the individual input streams shall be determined as required by Condition 3.1.1. Monthly emissions shall be used in a twelve month rolling total to monitor compliance with the annual emission limitations. 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. 3.1.1 The Btu content of the acid gas, flash gas, and fuel gas (supplemental and thermal oxidizer burner fuel) streams shall be determined semi-annually using appropriate ASTM methods or equivalent, if approved in advance by the Division. The semi-annual periods are those defined on the second page of this operating permit. At least two calendar months shall separate the monitoring events. The Btu content of all streams shall be based on the higher heating value of the streams. Calculations of monthly emissions shall be made using the heat content derived from the most recent required analysis. 3.2 Volatile Organic Compound (VOC) emissions from the natural gas liquids amine sweetening unit shall not exceed the limitation listed in Summary Table 3 above (Colorado Construction Permit 12WE1277). Compliance with the VOC limit shall be monitored as follows: Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 94 Upon issuance of this permit, results from the most recent Division approved compliance test shall be used to develop a VOC emission factor according to Condition 3.3.1, and emissions shall be calculated according to the methods below. A new VOC emission factor shall be developed after each subsequent Division approved compliance test conducted according to Condition 3.3. 3.2.1 VOC emissions shall be calculated monthly using the emission factor developed from the most recent compliance test approved by the Division, as required in Condition 3.3.1, and the total volume of natural gas liquids processed by the amine unit for the month, as required by Condition 3.4, in the equation below: tons EF (7,L) x Total NGL Input Volume Emissions (month) 2000 (L) tun 3.2.2 Emissions from the NGL amine regenerator still vent and flash tank shall be routed to the thermal oxidizer. The VOC emission factors developed as required in Condition 3.3.1, which represent controlled emissions, may be used to calculate actual emissions for the hours that the thermal oxidizer was in operation, provided that the requirements of Condition 3.9 are met. 3.2.3 For periods that the thermal oxidizer is not in operation or monitoring indicates that the requirements of Condition 3.9 have not been met, emissions shall be calculated as uncontrolled using the molar fraction of VOC constituents determined from the most recent extended gas analyses (required by Condition 3.2.5) and the volume of the gas streams routed to the thermal oxidizer for the period, in the equation below: TO Throughput ( . 1. ) VOC ( tons )_1(x, mol i )x M lb ) x scf event�� month mol sample lb—mol 379,3 ( ) x 2000 (—) [6—mo[ ton Where: xi = Molar Fraction of V0C constituent i;mol constituent i/mol sample ML =Molar Mass V0C constituent i;lb/lb—mol TO Throughput= Total volume of stream for periods where the thermal oxidizer is not operating or monitoring indicates that the requirements of Condition 3.9 have not been met;scf/event Emissions from all gas streams routed to the thermal oxidizer shall be summed for calculation of uncontrolled emissions when required by this Condition 3.2.3. Any emissions calculated as uncontrolled shall be summed with the controlled emissions calculated according to Condition 3.2.1 to obtain the monthly total. 3.2.4 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 to monitor compliance with the annual emission limitation. Each month, a new twelve month total shall be calculated Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 95 using the previous twelve months' data. Records of calculations shall be kept in a log to be made available to the Division upon request. 3.2.5 On a semi-annual basis, the operator shall complete a site specific extended gas analysis of the gases routed to the thermal oxidizer(including acid gas, flash gas, and fuel gas) in order to verify the VOC contents of the streams. The extended gas analyses shall be conducted using ASTM methods or equivalent, if approved in advance by the Division. The semi- annual periods are those defined on the second page of this operating permit. At least two calendar months shall separate the monitoring events. Records of extended natural gas analyses shall be kept in a log to be made available to the Division upon request. 3.3 Source compliance tests shall be conducted on the thermal oxidizer controlling emissions from the natural gas liquids amine unit at least once every six months to measure the emission rates of NOx, CO, VOC, BTEX, and n-Hexane in order to monitor compliance with the emission limits in this Condition 3 and to demonstrate the thermal oxidizer achieves a minimum destruction efficiency of 99.0% for VOC. Periodic tests shall be conducted at least thirty (30) days apart. All tests must be performed according to EPA reference methods. Process models shall not be used to determine the flow rate or composition of the waste gas sent to the thermal oxidizer for the purposes of this test. The natural gas liquids throughput, lean amine circulation rate, all amine concentrations, the combustion zone temperature and the total volume of gases routed to the thermal oxidizer(including acid gas, flash gas, and fuel gas) shall be monitored and recorded during this test. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time. (Colorado Construction Permit 12WE1277, as modified under the provisions of Section I, Condition 1.3) The test protocol, test, and test report must be in accordance with the requirements of the APCD Compliance Test Manual (https:-',,rwww.colorado.gov'pacific/cdphe'inspections-and-enforcement). A stack testing protocol shall be submitted for Division approval at least forty-five (45) calendar days prior to any performance of the test required under this condition. No stack test required herein shall be performed without prior approval of the protocol by the Division. The Division reserves the right to witness the test. In order to facilitate the Division's ability to make plans to witness the test, notice of the date(s) for the stack test shall be submitted to the Division at least thirty (30) calendar days prior to the test. The Division may for good cause shown, waive this thirty (30) day notice requirement. The compliance test results shall be submitted to the Division within forty-five (45) calendar days of the completion of the test unless a longer period is approved by the Division. 3.3.1 Results of the compliance testing performed according to this Condition 3.3 shall be used to determine emission factors as follows for VOC, for use in actual emissions calculations according to Condition 3.2. Results of compliance testing shall also be used to determine emission factors for BTEX and n-Hexane for APEN reporting purposes. Emission factors for VOC shall be developed in units of pounds per barrel of natural gas liquids processed (lb/BBL), based on the rate of controlled VOC emissions emitted and the barrels of natural gas processed during the test. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 96 A new VOC emission factor shall be developed after each test, based on the most recent testing results as approved by the Division, and used to calculate actual emissions according to Condition 3.2. Records of emission factor calculations shall be maintained for Division inspection upon request. 3.4 The quantity of natural gas liquids processed by the NGL amine unit shall not exceed the limitation in Summary Table 3 above (Colorado Construction Permit 12WE1277). The natural gas liquids processed through the NGL amine unit shall be monitored using a flow meter and recorded monthly in a log that is available to the Division upon request. A twelve month rolling total of natural gas liquids processed by the NGL amine unit shall be maintained to monitor compliance with the annual limitation. Each month, a new twelve month total shall be calculated using the previous twelve months' data. The monthly volume of natural gas liquids recorded shall be used to calculate VOC emissions, as required by Condition 3.2. 3.5 The total volume of waste gas (acid and flash) and fuel gas (supplemental fuel and thermal oxidizer burner fuel) combusted in the thermal oxidizer shall not exceed the limitation listed in Summary Table 3 above (Colorado Construction Permit 12WE1277). The volumes of acid gas, flash tank off gas, and fuel gas routed to the thermal oxidizer shall be continuously monitored using flow meters and recorded monthly in a log that is available to the Division upon request. A twelve month rolling total of waste gas and fuel gas routed to the thermal oxidizer shall be maintained to monitor compliance with the annual limitation. Each month, a new twelve month total shall be calculated using the previous twelve months' data. The monthly acid gas, flash gas and fuel gas volumes recorded shall be used to calculate NOx and CO emissions, as required by Condition 3.1. 3.6 The hours of operation for the NGL amine unit and associated thermal oxidizer shall be monitored and recorded monthly in a log that is available to the Division upon request. 3.7 The maximum recirculation rate of lean amine solution for the NGL amine unit shall not exceed the limitation listed in Summary Table 3 above (Colorado Construction Permit 12WE1277). The lean amine solution recirculation rate shall be recorded daily in a log maintained on site and made available to the Division for inspection upon request. 3.8 The concentration of amine (MEA, DEA, TEA, MDEA, and/or DGA plus piperazine) in the lean amine stream shall not exceed 45 weight percent on a monthly average basis (Colorado Construction Permit 12WE1277). The concentration of amine is defined as the combined weight percent of all amine solutions and piperazine in the lean amine stream. The concentration of amine in the lean amine stream shall be measured and recorded on a weekly basis and kept in a log to be made available to the Division upon request. No measurement of amine concentration shall be required for any week in which the amine unit did not operate. 3.9 The operating temperature of the thermal oxidizer used to control emissions from this NGL amine unit shall be greater than or equal to 1400 °F, or the temperature established during the most recent stack test demonstrating compliance with permitted limits and approved by the Division, at all times that any NGL Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 97 amine unit still vent or flash tank emissions are routed to the thermal oxidizer(Colorado Construction Permit 12WE1277). Combustion chamber temperature of the thermal oxidizer shall be monitored according to the Compliance Assurance Monitoring plan of SECTION IV - 12 and APPENDIX I. Records of combustion chamber temperature shall be kept in a log to be made available to the Division upon request. 3.10 This unit is subject to the following opacity requirements: 3.10.1 Except as provided for in Condition 3.10.2 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section II.A.1). 3.10.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, process modifications, or adjustment or occasional cleaning of control equipment 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). Compliance with the above opacity limitations shall be monitored as follows: 3.10.3 A qualitative visual emissions observation shall be conducted daily on the thermal oxidizer stack during normal operation of the source. Records of the results of the qualitative visual emissions observations shall be kept in a log and made available to the Division upon request. 3.10.4 If any visible emissions are observed during the daily observation, an EPA Reference Method 9 observation shall be performed. 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 limit shall be considered to exist from the time a Method 9 reading is taken that shows an exceedance of the opacity limit until a Method 9 reading is taken that shows the opacity is less than the opacity limit. 3.10.5 All opacity observations shall be performed by an observer with current and valid Method 9 certification. Results of Method 9 readings and a copy of the certified Method 9 reader's certificate shall be kept on site and made available to the Division upon request. 3.11 The amine sweetening system is subject to the requirements in 40 CFR 60 Subpart LLL, "Standards of Performance for SO1 Emissions from Onshore Natural Gas Processing" (as adopted by reference in Colorado Regulation No. 6, Part A), including, but not limited to the following requirements: [The requirements below reflect the current rule language as of the revisions to 40 CFR Part 60 Subpart LLL 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 LLL.] Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 98 Applicability and designation of affected facilities. 3.11.1 Facilities that have a design capacity less than 2 long tons per day (LT/D) of hydrogen sulfide (H2S) in the acid gas (expressed as sulfur) are required to comply with §60.647(c) but are not required to comply with §§60.642 through 60.646. (§60.640(b)) Recordkeeping and reporting requirements. 3.11.2 To certify that a facility is exempt from the control requirements of these standards, each owner or operator of a facility with a design capacity less that 2 LT/D of HAS in the acid gas (expressed as sulfur) shall keep, for the life of the facility, an analysis demonstrating that the facility's design capacity is less than 2 LT/D of H1S expressed as sulfur. (§60.647(c)) 3.12 The amine sweetening system and thermal oxidizer are subject to the requirements in 40 CFR Part 60, Subpart A— General Provisions, as adopted by reference in Colorado Regulation No. 6, Part A, Subpart A, and Part B, Section LA, including, but not limited to, the following: 3.12.1 No article, machine, equipment or process shall be used to conceal an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gasses discharged to the atmosphere. (40 CFR 60 Subpart A §60.12, as adopted by reference in Colorado Regulation No. 6, Part A, Subpart A, and Part B, Section LA). 3.12.2 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 Division 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 Subpart A §60.11(d), as adopted by reference in Colorado Regulation No. 6, Part A, Subparts A, and Part B, Section LA). 3.12.3 Records shall be maintained of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the source; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative (40 CFR Part 60 Subpart A §60.7(b), as adopted by reference in Colorado Regulation No. 6, Part A, Subpart A, and Part B, Section I.A). 3.13 This facility shall follow manufacturer recommendations for the operation and maintenance of equipment and control devices. These schedules and practices, as well as any maintenance records showing compliance with these recommendations, shall be made available to the Divisions upon request. (Colorado Construction Permit 12WE1277 and most recent Division approved Operation and Maintenance plan) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 99 3.14 This amine unit is subject to the Compliance Assurance Monitoring (CAM) requirements with respect to the annual VOC emission limitation in Condition 3.2. Compliance with the CAM requirements shall be monitored in accordance with the requirements in SECTION IV - 12 and the CAM Plan in APPENDIX I. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 100 4. S012: One (1) Ajax DPC-2803LE, 550 HP engine (AIRS point 044) Permit Monitoring Parameter Condition Limitations Number Factor Method Interval NOx 16.8 tons/yr 0.543 lb/MMBtu Recordkeeping Monthly 4.1 and Calculation Portable CO 20.1 tons/yr 0.386 lb/MMBtu Monitoring Quarterly VOC 4.2 6.7 tons/yr 0.120 lb/MMBtu Recordkeeping Monthly and Calculation Natural Gas Individual Engine 4.3 47.24 MMscf/yr Monthly Consumption Fuel Meter ASTM or other Btu Content of 4 4 Division Semi-annually Natural Gas Approved Method Hours of 4.5 Recordkeeping Monthly Operation Not to exceed 20%, except as provided for below For Certain Operational Only Natural Opacity 4.6 Activities—Not to Exceed Fuel Restriction Gas is Used as 30%for a Period or Periods Fuel Aggregating More than Six (6)Minutes in any 60 Consecutive Minutes Engine Operation 4.7 See Condition 4.7 and Maintenance Colorado Regulation No. 7, 4.8 See Condition 4.8 Part E 4.1 Emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO) shall not exceed the limitations listed in Summary Table 4 above (Colorado Construction Permit 97WE0722). Compliance with the emission limitations shall be monitored as follows: 4.1.1 Except as provided below, the emission factors listed in Summary Table 4 above have been approved by the Division and shall be used to calculate emissions from this engine as follows: Monthly emissions shall be calculated, by the end of the subsequent month, using the emission factors in Summary Table 4 above, the monthly natural gas consumption (required by Condition 4.3) and the Btu content of the natural gas (required by Condition 4.4) in the equation below: Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 101 tons/mo =jEF (lb/MMBtu)x fuel use (MMscf/mo)x heat content of fuel (MMBtu/MMscf)] 2000 lb/ton Monthly emissions 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. Records of calculations shall be kept in a log to be made available to the Division upon request. If the results of the portable analyzer testing conducted under the provisions of Condition 4.1.2 show that either the NOx or CO emission rates/factors are greater than those listed above, 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 rates/factors within 60 days of the completion of the test. 4.1.2 Portable Monitoring shall be conducted quarterly in accordance with the requirements in SECTION IV - 1. 4.2 Volatile Organic Compound (VOC) emissions shall not exceed the limitation listed in Summary Table 4 above (Colorado Construction Permit 97WE0722). Monthly emissions shall be calculated, by the end of the subsequent month, using the emission factors in Summary Table 4 above, the monthly natural gas consumption (required by Condition 4.3), and the Btu content of the natural gas (required by Condition 4.4) in the equation below: tons/mo =fEF (lb/MMBtu)x fuel use (MMscfmo)x heat content of fuel (MMBtu/MMscfn 2000 lb/ton Monthly emissions shall be used in a twelve month rolling total 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. 4.3 Natural gas consumption shall not exceed the limitation listed in Summary Table 4 above. (Colorado Construction Permit 97WE0722). Natural gas consumption shall be recorded monthly using the existing individual engine fuel meter. Monthly natural gas consumption 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. Records of calculations shall be kept in a log to be made available to the Division upon request. 4.4 The Btu content of the natural gas used to fuel this engine shall be verified semi-annually using the appropriate ASTM Methods or equivalent, if approved in advance by the Division. The Btu content of the natural gas shall be based on the higher heating value of the fuel. Calculations of monthly emissions shall be made using the heat content derived from the most recent required analysis. 4.5 Hours of operation shall be monitored monthly and recorded and maintained to be available to the Division upon request. Monthly hours of operation shall be used in a running total for each annual Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 102 compliance period. The hours of operation shall be used to determine if portable monitoring is required as specified in SECTION IV - 1. 4.6 The following opacity requirements apply: 4.6.1 Except as provided for in Condition 4.6.2 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section II.A.1). 4.6.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, process modifications, or adjustment or occasional cleaning of control equipment 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 opacity requirements of this Condition 4.6 shall be presumed since only natural gas is permitted to be used as fuel in this engine. 4.7 This engine shall be operated and maintained in accordance with internal operating and maintenance standards, which shall consider manufacturer's recommendations and good air pollution control practices for minimizing emissions, at all times, including periods of start-up, shut-down and malfunction. These internal operating and maintenance standards shall be kept on site and made available to the Division upon request. 4.8 This engine is subject to the requirements of Colorado Regulation No. 7, Part E, "Combustion Equipment and Major Source RACT", including, but not limited to, the following: [The requirements below reflect the current rule language as of the revisions to 5 CCR 1001-9 Colorado Regulation No. 7 published in the Colorado Register on 01/25/2020 and effective on 02/14/2020. However, if revisions to this rule are published at a later date, the owner or operator is subject to the requirements contained in the revised version of Colorado Regulation No. 7.] [Note that the following requirements of Colorado Regulation No. 7, Part E, Sections II.A.6 and ILA.7 apply to specific combustion equipment with uncontrolled actual emissions of NOx equal to or greater than five (S) tons per year, as specified in Part E, Section II.A.6.a, therefore, applicability may vary from year to year] Combustion Process Adjustment (Part E, Section II.A.6) 4.8.1 The owner or operator of a stationary internal combustion engine must conduct the following inspections and adjustments, as applicable (II.A.6.b.(iv)): 4.8.1.1 Change oil and filters as necessary. (II.A.6.b.(iv)(A)) 4.8.1.2 Inspect air cleaners, fuel filters, hoses, and belts and clean or replace as necessary. (II.A.6.b.(iv)(B)) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 103 4.8.1.3 Inspect spark plugs and replace as necessary. (II.A.6.b.(iv)(C)) 4.8.2 The owner or operator must operate and maintain the stationary internal combustion engine consistent with manufacturer's specifications, if available, or good engineering and maintenance practices. (II.A.6.b.(vii)) 4.8.3 The owner or operator of stationary reciprocating internal combustion engines with uncontrolled actual emissions of NOx equal to or greater than five (5) tons per year that existed at major sources of NOx (greater than or equal to 100 tpy NOx) as of June 3, 2016, must conduct the initial combustion process adjustment by April 1, 2017. An owner or operator may rely on a combustion process adjustment conducted in accordance with applicable requirements and schedule of a New Source Performance Standard in 40 CFR Part 60 (November 17, 2016) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (November 17, 2016) to satisfy the requirement to conduct an initial combustion process adjustment by April 1, 2017. (II.A.6.b.(viii)(A)) 4.8.4 The owner or operator must conduct subsequent combustion process adjustments at least once every twelve (12) months after the initial combustion adjustment, or on the applicable schedule according to Sections II.A.6.c.(i). or II.A.6.c.(ii) (Conditions 4.8.5.1 or 4.8.5.2). (ILA.6.b.(viii)(C)) 4.8.5 As an alternative to the requirements described in Sections II.A.6.b.(iv), II.A.6.b.(vii) and II.A.6.b.(viii) (Conditions 4.8.1 through 4.8.4) (II.A.6.c.): 4.8.5.1 The owner or operator may conduct the combustion process adjustment according to the manufacturer recommended procedures and schedule (II.A.6.c.(i)); or 4.8.5.2 The owner or operator of combustion equipment that is subject to and required to conduct a period tune-up or combustion adjustment by the applicable requirements of a New Source Performance Standard in 40 CFR Part 60 (December 19, 2019) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (December 19, 2019) may conduct tune-ups or adjustments according to the schedule and procedures of the applicable requirements of 40 CFR Part 60 (December 19, 2019) or 40 CFR Part 63 (December 19, 2019). (II.A.6.c.(ii)) Recordkeeping (II.A.7) 4.8.6 The following records must be kept for a period of five years and made available to the Division upon request (II.A.7): 4.8.7 For stationary combustion equipment subject to the combustion process adjustment requirements in Section II.A.6 (Conditions 4.8.1 through 4.8.5), the following recordkeeping requirements apply (II.A.7.f.): Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 104 4.8.8 The owner or operator must create a record once every calendar year identifying the combustion equipment at the facility subject to Section ILA and including for each combustion equipment (II.A.7.f.(i)): 4.8.8.1 The date of the adjustment (II.A.7.f.(i)(A)); 4.8.8.2 Whether the combustion process adjustment under Sections II.A.6.b.(iv) (Condition 4.8.1) was followed, and what procedures were performed (II.A.7.f.(i)(B)); 4.8.8.3 Whether a combustion process adjustment under Sections II.A.6.c.(i) and II.A.6.c.(ii) (Conditions 4.8.5.1 and 4.8.5.2) was followed, what procedures were performed, and what New Source Performance Standard or National Emission Standard for Hazardous Air Pollutants applied, if any (II.A.7.f.(i)(C)); and 4.8.8.4 A description of any corrective action taken. (II.A.7.f.(i)(D)) 4.8.8.5 If the owner or operator conducts the combustion process adjustment according to the manufacturer recommended procedures and schedule and the manufacturer specifies a combustion process adjustment on an operation time schedule, the hours of operation. (II.A.7.f.(i)(E)) 4.8.9 The owner or operator must retain manufacturer recommended procedures, specifications, and maintenance schedule if utilized under II.A.6.c.(i) (Conditions 4.8.5.1) for the life of the equipment. (II.A.7.f.(ii)) 4.8.10 As an alternative to the requirements described in Section II.A.7.f.(i) (Condition 4.8.8), the owner or operator may comply with applicable recordkeeping requirements related to combustion process adjustments conducted according to a New Source Performance Standard in 40 CFR Part 60 (November 17, 2016) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (November 17, 2016). (II.A.7.f.(iii)) Note: 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. (Section VI Condition 22.b) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 105 5. S013: One (1) Perry Gas Processors, Inc. Natural Gas Fired Amine Unit Heater, 10.7 MMBtu/hr (AIRS point 045) Permit Monitoring Parameter Condition Limitations Number Factor Method Interval NOx 6.8 tons/yr 0.098 lb/MMBtu Recordkeeping 5.1 and Calculation Monthly CO 5.7 tons/yr 0.082 lb/MMBtu 12 month rolling Natural Gas Individual Heater 5.2 128 MMscf/yr Monthly Consumption Fuel Meter ASTM or other Btu Content of 5 3 Division Semi-annually Natural Gas Approved Method Hours of 5.4 Recordkeeping Monthly Operation Not to exceed 20%(state- only) Not to exceed 20%, except Only Natural Opacity 5.5 as provided for below Fuel Restriction Gas is Used as For Certain Operational Fuel Activities—Not to Exceed 30% Only Natural PM 5.6 0.270 lb/MMBtu Fuel Restriction Gas is Used as Fuel 40 CFR 63 5.7 See Condition 5.7 Subpart DDDDD 40 CFR 63 Subpart A— 5.8 See Condition 5.8 General Provisions 40 CFR 60 5.9 See Condition 5.9 Subpart Dc 40 CFR 60 Subpart A— 5.10 See Condition 5.10 General Provisions Colorado Regulation No. 7, 5.11 See Condition 5.11 Part E Process Heater Operation and 5.12 See Condition 5.12 Maintenance Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 106 5.1 Emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO) shall not exceed the limitations listed in Summary Table 5 above (Colorado Construction Permit 97WE0723). Monthly emissions shall be calculated by the end of the subsequent month using the emission factors in Summary Table 5 above, the monthly fuel consumption (required by Condition 5.2), and the Btu content of the natural gas (required by Condition 5.3) in the equation below: tons/mo =jEF (1b/MMBtu)x fuel use (MMscf/mo)x heat content of fuel (MMBtu/MMscf)] 2000 lb/ton Monthly emissions 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. Records of calculations shall be kept in a log to be made available to the Division upon request. 5.2 Natural gas consumption shall not exceed the limitation listed in Summary Table 5 above (Colorado Construction Permit 97WE0723). Natural gas consumption shall be recorded monthly using the existing individual heater fuel meter. Monthly natural gas consumption 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. Records of calculations shall be kept in a log to be made available to the Division upon request. 5.3 The Btu content of the natural gas used to fuel this heater shall be verified semi-annually using the appropriate ASTM Methods or equivalent, if approved in advance by the Division. The Btu content of the natural gas shall be based on the higher heating value of the fuel. Calculations of monthly emissions shall be made using the heat content derived from the most recent required analysis. 5.4 Hours of operation shall be monitored monthly and recorded and maintained to be available to the Division upon request. 5.5 This heater is subject to the following opacity requirements: 5.5.1 [State-only] Visible emissions of any particulate matter shall not exceed 20% opacity (Colorado Regulation No. 6, Part B, Section II.C.3) This opacity requirement applies at all times except during periods of startup, shutdown, and malfunction (40 CFR Part 60, Subpart A, §60.11(c), as adopted by reference in Colorado Regulation No. 6, Part B, Section LA). Note that this opacity requirement is more stringent than the opacity requirement in Condition 5.5.3 except during periods of startup. 5.5.2 Except as provided for in Condition 5.5.3 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section II.A.1). 5.5.3 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 107 start-up, process modifications, or adjustment or occasional cleaning of control equipment 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 opacity requirements of this Condition 5.5 shall be presumed since only natural gas is permitted to be used as fuel in this heater. 5.6 Particulate Matter (PM) emissions shall not exceed the above limitation (Colorado Regulation No. 1, Section III.A.1.b). The numeric PM standard was determined using the design heat input for the heater(10.7 MMBtu/hr) in the following equation: PE = 0.5 x (FI)-°'6 where: PE =particulate standard in lbs/MMBtu FI = fuel input in MMBtu/hr In the absence of credible evidence to the contrary, compliance with the particulate matter emission limit is presumed since only natural gas is permitted to be used as fuel in the heater. 5.7 This heater is 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", as specified in SECTION IV - 8. 5.8 This heater is subject to the requirements in 40 CFR Part 63 Subpart A "General Provisions", as specified in SECTION IV - 11. 5.9 This heater is subject to the requirements in 40 CFR Part 60 Subpart Dc, "Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units", as specified in SECTION IV - 9. 5.10 This heater is subject to the requirements in 40 CFR Part 60 Subpart A, "General Provisions", as specified in SECTION IV - 10. 5.11 This process heater is subject to the requirements of Colorado Regulation No. 7, Part E, "Combustion Equipment and Major Source RACT", including, but not limited to, the following: [The requirements below reflect the current rule language as of the revisions to 5 CCR 1001-9 Colorado Regulation No. 7 published in the Colorado Register on 01/25/2020 and effective on 02/14/2020. However, if revisions to this rule are published at a later date, the owner or operator is subject to the requirements contained in the revised version of Colorado Regulation No. 7.] [Note that the following requirements of Colorado Regulation No. 7, Part E, Sections II.A.6 and ILA.7 apply to specific combustion equipment with uncontrolled actual emissions of NOx equal to or greater than five (S) tons per year, as specified in Part E, Section II.A.6.a, therefore, applicability may vary from year to yeas] Combustion Process Adjustment (Part E, Section II.A.6) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 108 5.1 1.1 When burning the fuel that provides the majority of the heat input since the last combustion process adjustment and when operating at a firing rate typical of normal operation, the owner or operator must conduct the following inspections and adjustments of boilers and process heaters, as applicable: (II.A.6.b.(i)): 5.11.1.1 Inspect the burner and combustion controls and clean or replace components as necessary. (II.A.6.b.(i)(A)) 5.11.1.2 Inspect the flame pattern and adjust the burner or combustion controls as necessary to optimize the flame pattern. (II.A.6.b.(i)(B)) 5.11.1.3 Inspect the system controlling the air-to-fuel ratio and ensure that it is correctly calibrated and functioning properly. (II.A.6.b.(i)(C)) 5.11.1.4 Measure the concentration in the effluent stream of carbon monoxide and nitrogen oxide in ppm, by volume, before and after the adjustments in Sections II.A.6.b.(i)(A) through (C) (Conditions 5.11.1.1 through 5.11.1.3). Measurements may be taken using a portable analyzer. (II.A.6.b.(i)(D)) 5.11.2 The owner or operator must operate and maintain the process heater consistent with manufacturer's specifications, if available, or good engineering and maintenance practices. (II.A.6.b.(vii)) 5.11.3 The owner or operator of process heaters with uncontrolled actual emissions of NOx equal to or greater than five (5) tons per year that existed at major sources of NOx (greater than or equal to 100 tpy NOx) as of June 3, 2016, must conduct the initial combustion process adjustment by April 1, 2017. An owner or operator may rely on a combustion process adjustment conducted in accordance with applicable requirements and schedule of a New Source Performance Standard in 40 CFR Part 60 (November 17, 2016) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (November 17, 2016) to satisfy the requirement to conduct an initial combustion process adjustment by April 1, 2017. (II.A.6.b.(viii)(A)) 5.11.4 The owner or operator must conduct subsequent combustion process adjustments at least once every twelve (12) months after the initial combustion adjustment, or on the applicable schedule according to Sections II.A.6.c.(i). or II.A.6.c.(ii) (Conditions 5.11.5.1 or 5.11.5.2). (II.A.6.b.(viii)(C)) 5.11.5 As an alternative to the requirements described in Sections II.A.6.b.(i), II.A.6.b.(vii) and II.A.6.b.(viii) (Conditions 5.11.1 through 5.11.4) (II.A.6.c.): 5.11.5.1 The owner or operator may conduct the combustion process adjustment according to the manufacturer recommended procedures and schedule (II.A.6.c.(i)); or 5.11.5.2 The owner or operator of combustion equipment that is subject to and required to conduct a period tune-up or combustion adjustment by the applicable Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 109 requirements of a New Source Performance Standard in 40 CFR Part 60 (December 19, 2019)or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (December 19, 2019) may conduct tune-ups or adjustments according to the schedule and procedures of the applicable requirements of 40 CFR Part 60 (December 19, 2019) or 40 CFR Part 63 (December 19, 2019). (II.A.6.c.(ii)) Recordkeeping (ILA.7) 5.11.6 The following records must be kept for a period of five years and made available to the Division upon request (II.A.7): 5.11.7 For stationary combustion equipment subject to the combustion process adjustment requirements in Section II.A.6 (Conditions 5.11.1 through 5.11.5), the following recordkeeping requirements apply(II.A.7.f.): 5.11.8 The owner or operator must create a record once every calendar year identifying the combustion equipment at the facility subject to Section ILA and including for each combustion equipment (II.A.7.f.(i)): 5.11.8.1 The date of the adjustment(II.A.7.f.(i)(A)); 5.11.8.2 Whether the combustion process adjustment under Sections II.A.6.b.(i) (Conditions 5.11.1) was followed, and what procedures were performed (II.A.7.f.(i)(B)); 5.11.8.3 Whether a combustion process adjustment under Sections II.A.6.c.(i) and II.A.6.c.(ii) (Conditions 5.11.5.1 and 5.11.5.2) was followed,what procedures were performed, and what New Source Performance Standard or National Emission Standard for Hazardous Air Pollutants applied, if any (II.A.7.f.(i)(C)); and 5.11.8.4 A description of any corrective action taken. (II.A.7.f.(i)(D)) 5.11.8.5 If the owner or operator conducts the combustion process adjustment according to the manufacturer recommended procedures and schedule and the manufacturer specifies a combustion process adjustment on an operation time schedule, the hours of operation. (II.A.7.f.(i)(E)) 5.11.9 The owner or operator must retain manufacturer recommended procedures, specifications, and maintenance schedule if utilized under II.A.6.c.(i) (Conditions 5.11.5.1) for the life of the equipment. (II.A.7.f.(ii)) 5.11.10 As an alternative to the requirements described in Section II.A.7.f.(i) (Condition 5.11.8), the owner or operator may comply with applicable recordkeeping requirements related to combustion process adjustments conducted according to a New Source Performance Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 110 Standard in 40 CFR Part 60 (November 17, 2016) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (November 17, 2016). (II.A.7.f.(iii)) Note: 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. (Section VI Condition 22.b) 5.12 This process heater shall be operated and maintained in accordance with internal operating and maintenance standards, which shall consider manufacturer's recommendations and good air pollution control practices for minimizing emission, at all times, including periods of start-up, shut-down and malfunction. These internal operating and maintenance standards shall be kept on site and made available to the Division upon request. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 111 6. SO1S — 5017: Three (3) Ajax DPC-2803LE, 550 HP engines (AIRS points 047-049) [Limits Apply to Each Engine Individually] Permit Monitoring Parameter Condition Limitations Number Factor Method Interval r 0.543 Ib/MMBtu Recordkeeping Monthly NOx 10.6 tons/yr and Calculation 6.1 Portable CO 10.6 tons/yr 0.386 lb/MMBtu Monitoring Quarterly VOC 6.2 5.3 tons/yr 0.120 lb/MMBtu Recordkeeping Monthly and Calculation Natural Gas Individual Engine Consumption 6.3 38.3 MMscf/yr Fuel Meter Monthly ASTM or other Btu Content of 6 4 Division Semi-annually Natural Gas Approved Method Hours of 6.5 Recordkeeping Monthly Operation Not to exceed 20%, except as provided for below For Certain Operational Only Natural Opacity 6.6 Activities—Not to Exceed Fuel Restriction Gas is Used as 30%for a Period or Periods Fuel Aggregating More than Six (6)Minutes in any 60 Consecutive Minutes Engine Operation 6.7 See Condition 6.7 and Maintenance Colorado Regulation No. 7, 6.8 See Condition 6.8 Part E 6.1 Emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO) from each engine shall not exceed the limitations listed in Summary Table 6 above (Colorado Construction Permits 97WE0725, 97WE0726, and 97WE0727). Compliance with the emission limitations shall be monitored as follows: 6.1.1 Except as provided below, the emission factors listed in Summary Table 6 above have been approved by the Division and shall be used to calculate emissions from these engines as follows: Monthly emissions shall be calculated, by the end of the subsequent month, using the emission factors in Summary Table 6 above, the monthly natural gas consumption (required by Condition 6.3) and the Btu content of the natural gas (required by Condition 6.4) in the equation below: Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 112 tons/mo =jEF (lb/MMBtu)x fuel use (MMscf/mo)x heat content of fuel (MMBtu/MMscf)] 2000 lb/ton Monthly emissions 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. Records of calculations shall be kept in a log to be made available to the Division upon request. If the results of the portable analyzer testing conducted under the provisions of Condition 6.1.2 show that either the NOx or CO emission rates/factors are greater than those listed above, 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 rates/factors within 60 days of the completion of the test. 6.1.2 Portable Monitoring shall be conducted quarterly in accordance with the requirements in SECTION IV - 1. 6.2 Volatile Organic Compound (VOC) emissions from each engine shall not exceed the limitation listed in Summary Table 6 above (Colorado Construction Permits 97WE0725, 97WE0726, and 97WE0727). Monthly emissions shall be calculated, by the end of the subsequent month, using the emission factors in Summary Table 6 above, the monthly natural gas consumption (required by Condition 6.3), and the Btu content of the natural gas (required by Condition 6.4) in the equation below: tons/mo =fEF (lb/MMBtu)x fuel use (MMscf/mo)x heat content of fuel (MMBtu/MMscfn 2000 lb/ton Monthly emissions shall be used in a twelve month rolling total 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. 6.3 Natural gas consumption for each engine shall not exceed the limitation listed in Summary Table 6 above. (Colorado Construction Permits 97WE0725, 97WE0726, and 97WE0727). Natural gas consumption shall be recorded for each engine monthly using the existing individual engine fuel meters. Monthly natural gas consumption 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. Records of calculations shall be kept in a log to be made available to the Division upon request. 6.4 The Btu content of the natural gas used to fuel these engines shall be verified semi-annually using the appropriate ASTM Methods or equivalent, if approved in advance by the Division. The Btu content of the natural gas shall be based on the higher heating value of the fuel. Calculations of monthly emissions shall be made using the heat content derived from the most recent required analysis. 6.5 Hours of operation shall be monitored monthly and recorded and maintained to be available to the Division upon request. Monthly hours of operation shall be used in a running total for each annual Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 113 compliance period. The hours of operation shall be used to determine if portable monitoring is required as specified in SECTION IV - 1. 6.6 The following opacity requirements apply: 6.6.1 Except as provided for in Condition 6.6.2 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section II.A.1). 6.6.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, process modifications, or adjustment or occasional cleaning of control equipment 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 opacity requirements of this Condition 6.6 shall be presumed since only natural gas is permitted to be used as fuel in these engines. 6.7 These engines shall be operated and maintained in accordance with internal operating and maintenance standards, which shall consider manufacturer's recommendations and good air pollution control practices for minimizing emissions, at all times, including periods of start-up, shut-down and malfunction. These internal operating and maintenance standards shall be kept on site and made available to the Division upon request. 6.8 These engines are subject to the requirements of Colorado Regulation No. 7, Part E, "Combustion Equipment and Major Source RACT", including, but not limited to, the following: [The requirements below reflect the current rule language as of the revisions to 5 CCR 1001-9 Colorado Regulation No. 7 published in the Colorado Register on 01/25/2020 and effective on 02/14/2020. However, if revisions to this rule are published at a later date, the owner or operator is subject to the requirements contained in the revised version of Colorado Regulation No. 7.] [Note that the following requirements of Colorado Regulation No. 7, Part E, Sections II.A.6 and ILA.7 apply to specific combustion equipment with uncontrolled actual emissions of NOx equal to or greater than five (S) tons per year, as specified in Part E, Section II.A.6.a, therefore, applicability may vary from year to year] Combustion Process Adjustment (Part E, Section II.A.6) 6.8.1 The owner or operator of a stationary internal combustion engine must conduct the following inspections and adjustments, as applicable (II.A.6.b.(iv)): 6.8.1.1 Change oil and filters as necessary. (II.A.6.b.(iv)(A)) 6.8.1.2 Inspect air cleaners, fuel filters, hoses, and belts and clean or replace as necessary. (II.A.6.b.(iv)(B)) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 114 6.8.1.3 Inspect spark plugs and replace as necessary. (II.A.6.b.(iv)(C)) 6.8.2 The owner or operator must operate and maintain the stationary internal combustion engine consistent with manufacturer's specifications, if available, or good engineering and maintenance practices. (II.A.6.b.(vii)) 6.8.3 The owner or operator of stationary reciprocating internal combustion engines with uncontrolled actual emissions of NOx equal to or greater than five (5) tons per year that existed at major sources of NOx (greater than or equal to 100 tpy NOx) as of June 3, 2016, must conduct the initial combustion process adjustment by April 1, 2017. An owner or operator may rely on a combustion process adjustment conducted in accordance with applicable requirements and schedule of a New Source Performance Standard in 40 CFR Part 60 (November 17, 2016) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (November 17, 2016) to satisfy the requirement to conduct an initial combustion process adjustment by April 1, 2017. (II.A.6.b.(viii)(A)) 6.8.4 The owner or operator must conduct subsequent combustion process adjustments at least once every twelve (12) months after the initial combustion adjustment, or on the applicable schedule according to Sections II.A.6.c.(i). or II.A.6.c.(ii) (Conditions 6.8.5.1 or 6.8.5.2). (ILA.6.b.(viii)(C)) 6.8.5 As an alternative to the requirements described in Sections II.A.6.b.(iv), II.A.6.b.(vii) and II.A.6.b.(viii) (Conditions 6.8.1 through 6.8.4) (II.A.6.c.): 6.8.5.1 The owner or operator may conduct the combustion process adjustment according to the manufacturer recommended procedures and schedule (II.A.6.c.(i)); or 6.8.5.2 The owner or operator of combustion equipment that is subject to and required to conduct a period tune-up or combustion adjustment by the applicable requirements of a New Source Performance Standard in 40 CFR Part 60 (December 19, 2019)or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (December 19, 2019) may conduct tune-ups or adjustments according to the schedule and procedures of the applicable requirements of 40 CFR Part 60 (December 19, 2019) or 40 CFR Part 63 (December 19, 2019). (II.A.6.c.(ii)) Recordkeeping (II.A.7) 6.8.6 The following records must be kept for a period of five years and made available to the Division upon request (II.A.7): 6.8.7 For stationary combustion equipment subject to the combustion process adjustment requirements in Section II.A.6 (Conditions 6.8.1 through 6.8.5), the following recordkeeping requirements apply (II.A.7.f.): Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 115 6.8.8 The owner or operator must create a record once every calendar year identifying the combustion equipment at the facility subject to Section ILA and including for each combustion equipment (II.A.7.f.(i)): 6.8.8.1 The date of the adjustment (II.A.7.f.(i)(A)); 6.8.8.2 Whether the combustion process adjustment under Sections II.A.6.b.(iv) (Condition 6.8.1) was followed, and what procedures were performed (II.A.7.f.(i)(B)); 6.8.8.3 Whether a combustion process adjustment under Sections II.A.6.c.(i) and II.A.6.c.(ii) (Conditions 6.8.5.1 and 6.8.5.2) was followed, what procedures were performed, and what New Source Performance Standard or National Emission Standard for Hazardous Air Pollutants applied, if any (II.A.7.f.(i)(C)); and 6.8.8.4 A description of any corrective action taken. (II.A.7.f.(i)(D)) 6.8.8.5 If the owner or operator conducts the combustion process adjustment according to the manufacturer recommended procedures and schedule and the manufacturer specifies a combustion process adjustment on an operation time schedule, the hours of operation. (II.A.7.f.(i)(E)) 6.8.9 The owner or operator must retain manufacturer recommended procedures, specifications, and maintenance schedule if utilized under II.A.6.c.(i) (Conditions 6.8.5.1) for the life of the equipment. (II.A.7.f.(ii)) 6.8.10 As an alternative to the requirements described in Section II.A.7.f.(i) (Condition 6.8.8), the owner or operator may comply with applicable recordkeeping requirements related to combustion process adjustments conducted according to a New Source Performance Standard in 40 CFR Part 60 (November 17, 2016) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (November 17, 2016). (II.A.7.f.(iii)) Note: 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. (Section VI Condition 22.b) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 116 7. S018 - S019: Two (2) Caterpillar G3516 TALE, 980 HP engines (AIRS points 050 - 051) [Limits Apply to Each Engine Individually] Permit Compliance Emission Monitoring Parameter Condition Limitations Number Factor Method Interval ReNOx 20.4 tons/yr 0.530 lb/MMBtu and Calculation Monthly Y Calculation 7.1 CO 1.70 tons/yr 0.049 lb/MMBtu Portable uarterl Monitoring Q y VOC 7.2 1.6 tons/yr 0.045 lb/MMBtu Recordkeeping Monthly and Calculation Natural Gas Individual 7.3 63.4 MMscf/yr Engine Fuel Monthly Consumption Meter ASTM or other Btu Content of 7 4 Division Semi-annually Natural Gas Approved Method Hours of 7.5 Recordkeeping Monthly Operation Not to exceed 20%, except as provided for below For Certain Operational Only Natural Opacity 7.6 Activities—Not to Exceed Fuel Restriction Gas is Used as 30%for a Period or Periods Fuel Aggregating More than Six (6)Minutes in any 60 Consecutive Minutes Colorado Regulation No.7, 7.7 See Condition 7.7 Part E Engine and Catalyst Operation, 7.8 See Condition 7.8 Maintenance and Parameter Monitoring Reduce CO emissions by 93%or more; or 40 CFR 63 Limit concentration of Subpart ZZZZ 7.9 formaldehyde in the See Condition 7.9 stationary RICE exhaust to 14 ppmvd or less at 15 percent O, Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 117 40 CFR 63 Subpart A— 7.10 See Condition 7.10 General Provisions 7.1 Emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO) from each engine shall not exceed the limitations listed in Summary Table 7 above (Colorado Construction Permits 97WE0728 and 97WE0729, as modified under the provisions of Section I, Condition 1.3 and Colorado Regulation No. 3, Part C, Section III.B.7). Compliance with the emission limitations shall be monitored as follows: 7.1.1 Except as provided below, the emission factors listed in Summary Table 7 above have been approved by the Division and shall be used to calculate emissions from these engines as follows: Monthly emissions shall be calculated, by the end of the subsequent month, using the emission factors in Summary Table 7 above, the monthly natural gas consumption (required by Condition 7.3) and the Btu content of the natural gas (required by Condition 7.4) in the equation below: tons/mo =fEF (lb/MMBtu)x fuel use (MMscf/mo)x heat content of fuel (MMBtu/MMscfn 2000 lb/ton Monthly emissions 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. Records of calculations shall be kept in a log to be made available to the Division upon request. If the results of the portable analyzer testing conducted under the provisions of Condition 7.1.2 show that either the NOx or CO emission rates/factors are greater than those listed above, 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 rates/factors within 60 days of the completion of the test. 7.1.2 Portable Monitoring shall be conducted quarterly in accordance with the requirements in SECTION IV - 1. Performance testing for CO, conducted to satisfy the requirements of SECTION IV - 5.1.4 (performance testing under 40 CFR 63 Subpart ZZZZ), shall also satisfy the requirement to conduct portable monitoring for the quarter in which the Subpart ZZZZ performance test occurs. 7.2 Volatile Organic Compound (VOC) emissions from each engine shall not exceed the limitation listed in Summary Table 7 above (Colorado Construction Permits 97WE0728 and 97WE0729, as modified under the provisions of Section I, Condition 1.3 and Colorado Regulation No. 3, Part C, Section III.B.7). Monthly emissions shall be calculated, by the end of the subsequent month, using the emission factors in Summary Table 7 above, the monthly natural gas consumption (required by Condition 7.3), and the Btu content of the natural gas (required by Condition 7.4) in the equation below: Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 118 tons/mo =fEF (lb/MMBtu)x fuel use (MMscf/mo)x heat content of fuel (MMBtu/MMscf)] 2000 lb/ton Monthly emissions shall be used in a twelve month rolling total 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. 7.3 Natural gas consumption for each engine shall not exceed the limitation listed in Summary Table 7 above. (Colorado Construction Permits 97WE0728 and 97WE0729). Natural gas consumption shall be recorded for each engine monthly using the existing individual engine fuel meters. Monthly natural gas consumption 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. Records of calculations shall be kept in a log to be made available to the Division upon request. 7.4 The Btu content of the natural gas used to fuel these engines shall be verified semi-annually using the appropriate ASTM Methods or equivalent, if approved in advance by the Division. The Btu content of the natural gas shall be based on the higher heating value of the fuel. Calculations of monthly emissions shall be made using the heat content derived from the most recent required analysis. 7.5 Hours of operation shall be monitored monthly and recorded and maintained to be available to the Division upon request. Monthly hours of operation shall be used in a running total for each annual compliance period. The hours of operation shall be used to determine if portable monitoring is required as specified in SECTION IV - 1. 7.6 The following opacity requirements apply: 7.6.1 Except as provided for in Condition 7.6.2 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section II.A.1). 7.6.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, process modifications, or adjustment or occasional cleaning of control equipment 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 opacity requirements of this Condition 7.6 shall be presumed since only natural gas is permitted to be used as fuel in these engines. 7.7 These engines are subject to the requirements of Colorado Regulation No. 7, Part E, "Combustion Equipment and Major Source RACT", including, but not limited to, the following: [The requirements below reflect the current rule language as of the revisions to 5 CCR 1001-9 Colorado Regulation No. 7 published in the Colorado Register on 01/25/2020 and effective on 02/14/2020. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 119 However, if revisions to this rule are published at a later date, the owner or operator is subject to the requirements contained in the revised version of Colorado Regulation No. 7.] 7.7.1 The owner or operator of any natural gas-fired stationary or portable reciprocating internal combustion engine with a manufacturer's design rate greater than 500 horsepower commencing operations in the 8-hour Ozone Control Area on or after June 1, 2004 shall employ air pollution control technology to control emissions, as provided in Section LB (Condition 7.7.3). (Colorado Regulation No. 7, Part E, Section I.A.1) 7.7.2 The owner or operator of any existing natural gas-fired stationary or portable reciprocating internal combustion engine with a manufacturer's design rate greater than 500 horsepower, which existing engine was operating in the 8-hour Ozone Control Area prior to June 1, 2004, shall employ air pollution control technology on and after May 1, 2005, as provided in Section LB (Condition 7.7.3). (Colorado Regulation No. 7, Part E, Section I.A.2) 7.7.3 Air Pollution Control Technology Requirements: 7.7.3.1 For lean burn reciprocating internal combustion engines, an oxidation catalyst shall be required. A lean burn reciprocating internal combustion engine is one with a normal exhaust oxygen concentration of 2% by volume, or greater. (Colorado Regulation No. 7, Part E, Section I.B.2) 7.7.3.2 The emission control equipment required by this Condition 7.7.3 shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. (Colorado Regulation No. 7, Part E, Section I.B.3) Control of emissions from new, modified, existing, and relocated natural gas fired reciprocating internal combustion engines. (Part E, Section LD) 7.7.4 Except as provided in Section I.D.2.b below (Condition 7.7.5), the owner or operator of any natural gas fired reciprocating internal combustion engine that is either constructed or relocated to the state of Colorado from another state, on or after the date listed in the table below, shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below. (Colorado Regulation No. 7, Part E, Section I.D.2.a) 7.7.5 Actual emissions from natural gas fired reciprocating internal combustion engines shall not exceed the emission performance standards in the table below as expressed in units of grams per horsepower-hour (G/hp-hr) (Colorado Regulation No. 7, Part E, Section I.D.2.b) Table 2 from Colorado Regulation No. 7, Part E, Section I.D.2.b Maximum Construction or Emission Standard in g/hp-hr Engine Hp Relocation Date NOx CO VOC Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 120 Maximum Construction or Emission Standard in g/hp-hr Engine Hp Relocation Date ≥ 500 HP On or after July 1, 2007 2.0 4.0 1.0 On or after July 1, 2010 1.0 2.0 0.7 Compliance with the NOx and CO emission limitations shall be monitored by conducting portable monitoring quarterly as specified in SECTION IV - 1. For comparison with the short—term limits in this condition, the results of the portable monitoring test shall be converted to units of g/hp-hr to assess compliance with the NOx and CO emission limitations in this Condition 7.7.5 In the absence of credible evidence to the contrary, compliance with the VOC limitation is presumed provided the portable monitoring indicates compliance with the NOx and CO emission limitations in this Condition 7.7.5. [Note that the following requirements of Colorado Regulation No. 7, Part E, Sections II.A.6 and ILA.7 apply to specific combustion equipment with uncontrolled actual emissions of NOx equal to or greater than five (5) tons per year, as specified in Part E, Section II.A.6.a, therefore, applicability may vary from year to yeas] Combustion Process Adjustment (Part E, Section II.A.6) 7.7.6 The owner or operator of a stationary internal combustion engine must conduct the following inspections and adjustments, as applicable (II.A.6.b.(iv)): 7.7.6A Change oil and filters as necessary. (II.A.6.b.(iv)(A)) 7.7.6.2 Inspect air cleaners, fuel filters, hoses, and belts and clean or replace as necessary. (II.A.6.b.(iv)(B)) 7.7.6.3 Inspect spark plugs and replace as necessary. (II.A.6.b.(iv)(C)) 7.7.7 The owner or operator must operate and maintain the stationary internal combustion engine consistent with manufacturer's specifications, if available, or good engineering and maintenance practices. (II.A.6.b.(vii)) 7.7.8 The owner or operator of stationary reciprocating internal combustion engines with uncontrolled actual emissions of NOx equal to or greater than five (5) tons per year that existed at major sources of NOx (greater than or equal to 100 tpy NOx) as of June 3, 2016, must conduct the initial combustion process adjustment by April 1, 2017. An owner or operator may rely on a combustion process adjustment conducted in accordance with applicable requirements and schedule of a New Source Performance Standard in 40 CFR Part 60 (November 17, 2016) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (November 17, 2016) to satisfy the requirement to conduct an initial combustion process adjustment by April 1, 2017. (II.A.6.b.(viii)(A)) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 121 7.7.9 The owner or operator must conduct subsequent combustion process adjustments at least once every twelve (12) months after the initial combustion adjustment, or on the applicable schedule according to Sections II.A.6.c.(i). or II.A.6.c.(ii) (Conditions 7.7.10.1 or 7.7.10.2). (ILA.6.b.(viii)(C)) 7.7.10 As an alternative to the requirements described in Sections II.A.6.b.(iv), II.A.6.b.(Vii) and II.A.6.b.(viii) (Conditions 7.7.6 through 7.7.9) (II.A.6.c.): 7.7.10.1 The owner or operator may conduct the combustion process adjustment according to the manufacturer recommended procedures and schedule (II.A.6.c.(i)); or 7.7.10.2 The owner or operator of combustion equipment that is subject to and required to conduct a period tune-up or combustion adjustment by the applicable requirements of a New Source Performance Standard in 40 CFR Part 60 (December 19, 2019) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (December 19, 2019) may conduct tune-ups or adjustments according to the schedule and procedures of the applicable requirements of 40 CFR Part 60 (December 19, 2019) or 40 CFR Part 63 (December 19, 2019). (II.A.6.c.(ii)) Recordkeeping (II.A.7) 7.7.11 The following records must be kept for a period of five years and made available to the Division upon request (II.A.7): 7.7.12 For stationary combustion equipment subject to the combustion process adjustment requirements in Section II.A.6 (Conditions 7.7.6 through 7.7.10), the following recordkeeping requirements apply (II.A.7.f.): 7.7.13 The owner or operator must create a record once every calendar year identifying the combustion equipment at the facility subject to Section ILA and including for each combustion equipment (II.A.7.f.(i)): 7.7.13.1 The date of the adjustment (II.A.7.f.(i)(A)); 7.7.112 Whether the combustion process adjustment under Sections II.A.6.b.(iv) (Condition 7.7.6) was followed, and what procedures were performed (II.A.7.f.(i)(B)); 7.7.113 Whether a combustion process adjustment under Sections II.A.6.c.(i) and II.A.6.c.(ii) (Conditions 7.7.10.1 and 7.7.10.2) was followed, what procedures were performed, and what New Source Performance Standard or National Emission Standard for Hazardous Air Pollutants applied, if any (II.A.7.f.(i)(C)); and 7.7.13.4 A description of any corrective action taken. (II.A.7.f.(i)(D)) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 122 7.7.13.5 If the owner or operator conducts the combustion process adjustment according to the manufacturer recommended procedures and schedule and the manufacturer specifies a combustion process adjustment on an operation time schedule, the hours of operation. (II.A.7.f.(i)(E)) 7.7.14 The owner or operator must retain manufacturer recommended procedures, specifications, and maintenance schedule if utilized under II.A.6.c.(i) (Conditions 7.7.10.1) for the life of the equipment. (II.A.7.f.(ii)) 7.7.15 As an alternative to the requirements described in Section II.A.7.f.(i) (Condition 7.7.13), the owner or operator may comply with applicable recordkeeping requirements related to combustion process adjustments conducted according to a New Source Performance Standard in 40 CFR Part 60 (November 17, 2016) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (November 17, 2016). (II.A.7.f.(iii)) Note: 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. (Section VI Condition 22.b) 7.8 This engine and associated oxidation catalyst shall be operated and maintained in accordance with internal operating and maintenance standards, which shall consider manufacturer's recommendations and good air pollution control practices for minimizing emissions, at all times, including periods of start- up, shut-down and malfunction. These internal operating and maintenance standards shall be kept on site and made available to the Division upon request. Parameters associated with these engines and oxidizing catalyst units shall be monitored as follows: 7.8.1 The pressure drop across the catalyst and the catalyst inlet temperature shall be monitored according to SECTION IV - 5.1.13. 7.8.2 The pressure drop across the catalyst and the catalyst inlet temperature shall be recorded for these engines during each portable monitoring event required by Condition 7.1.2. 7.8.3 The oxygen concentration in the engine exhaust gas shall be measured and recorded for these engines during each portable monitoring event required by Condition 7.1.2. Records of all data and maintenance performed associated with the engine and catalyst operation and parameter monitoring of this Condition 7.8 shall be maintained for Division inspection upon request. 7.9 These engines are subject to the requirements in 40 CFR Part 63 Subpart ZZZZ, "National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines", as specified in SECTION IV - 5. 7.10 These engines are subject to the requirements in 40 CFR Part 63 Subpart A "General Provisions", as specified in SECTION IV - 11. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 123 Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 124 8. S020: One (1) Solar Centaur 40, 4700 HP Gas Turbine engine (AIRS point 052) Permit Limitations Compliance Monitoring Parameter Condition Emission Factor Number Short Term Long Term Method Interval NOx 157.5ppmvd* 49.0 tons/yr 0.295 lb/MMBtu Recordkeeping Monthly y and Calculation 8.1 CO 35.5 tons/yr 0.214 lb/MMBtu Portable Monitoring Quarterly VOC 8.2 10.2 tons/yr 0.061 lb/MMBtu Recordkeeping Monthly and Calculation 150 ppmvd @ 15%O2 or Natural Gas Sulfur Content Only Natural SO2 8.3 <0.8%by weight Fuel Restriction Gas is Used as Fuel 0.8 lb/MMBtu Only Natural PM 8.4 0.194 lb/MMBtu Fuel Restriction Gas is Used as Fuel Natural Gas Individual 8.5 320.0 MMscf/yr Turbine Fuel Monthly Consumption Meter ASTM or other Btu Content of 8 6 Division Semi-annually Natural Gas Approved Method Hours of 8.7 Recordkeeping Monthly Operation Not to exceed 20%(state-only) Not to exceed 20%, except as provided for below For Certain Operational Only Natural Opacity 8.8 Activities Not to Exceed 30% Fuel Restriction Gas is Used as for a Period or Periods Fuel Aggregating More than Six(6) Minutes in any 60 Consecutive Minutes 40 CFR 60 Subpart A— 8.9 See Condition 8.9 General Provisions Colorado Regulation No.7, 8.10 See Condition 8.10 Part E *At 15%oxygen and ISO conditions Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 125 8.1 Emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO) from this turbine shall not exceed the limitations listed in Summary Table 8 above (Colorado Construction Permit 01WE0290). Compliance with the emission limitations shall be monitored as follows: 8.1.1 Except as provided below, the emission factors listed in Summary Table 8 above have been approved by the Division and shall be used to calculate annual emissions from these engines as follows: Monthly emissions shall be calculated, by the end of the subsequent month, using the emission factors in Summary Table 8 above, the monthly natural gas consumption (required by Condition 8.5) and the Btu content of the natural gas (required by Condition 8.6), in the equation below: tons/mo = [EF (1b/MMBtu)x fuel use (MMscf/mo)x heat content of fuel (MMBtu/MMscf)] 2000 lb/ton Monthly emissions 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. Records of calculations shall be kept in a log to be made available to the Division upon request. If the results of the portable analyzer testing conducted under the provisions of Condition 8.1.2 show that either the NOx or CO emission rates/factors are greater than those listed above, 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 rates/factors within 60 days of the completion of the test. 8.1.2 Portable Monitoring shall be conducted quarterly in accordance with the requirements in SECTION IV - 1. 8.1.3 NOx emissions from this turbine shall not exceed 157.5 ppmv at 15% oxygen on a dry basis at ISO standard ambient conditions (Colorado Construction Permit 01WE0290 and 40 CFR Part 60, Subpart GG, §63.332(c) and (a)(2), as adopted by reference in Colorado Regulation No. 6, Part A). Compliance with this NOx limitation shall be monitored by conducting portable monitoring quarterly in accordance with the requirements in SECTION IV - 1. 8.2 Volatile Organic Compound (VOC) emissions from this turbine shall not exceed the limitation listed in Summary Table 8 above (Colorado Construction Permit 01WE0290). Monthly emissions shall be calculated, by the end of the subsequent month, using the emission factors in Summary Table 8 above, the monthly natural gas consumption (required by Condition 8.5), and the Btu content of the natural gas (required by Condition 8.6) in the equation below: tons/mo =fEF (1b/MMBtu)x fuel use (MMscf/mo)x heat content of fuel (MMBtu/MMscf)] 2000 lb/ton Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 126 Monthly emissions shall be used in a twelve month rolling total 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. 8.3 Sulfur Dioxide (SO2) emissions shall not exceed the following limitations: 8.3.1 This turbine shall meet one of the following requirements (40 CFR Part 60 Subpart GG §60.333(a) and (b), as adopted by reference in Colorado Regulation No. 6, Part A): 8.3.1.1 Sulfur Dioxide (SO2) emissions from the turbine shall not exceed 150 ppmvd at 15% oxygen (§60.333(a)); or 8.3.1.2 No fuel which contains total sulfur in excess of 0.8 percent by weight shall be burned in this turbine. (Colorado Construction Permit 01WE0290 and 40 CFR §60.333(b)) In the absence of credible evidence to the contrary, compliance with the above requirements is presumed since only natural gas is permitted to be used as fuel in this turbine. The permitee shall maintain records demonstrating that the natural gas burned meets the definition of natural gas in 40 CFR §60.331(u). The demonstration shall be made using one of the following methods: 8.3.1.3 The gas quality characteristics in a current, valid purchase contract, tariff sheet or transportation contract for the gaseous fuel, specifying that the maximum total sulfur content of the fuel is 20.0 grains/100 scf or less (40 CFR §60.334(h)(3)(i)); or 8.3.1.4 Representative fuel sampling data which show that the sulfur content of the gaseous fuel does not exceed 20 grains/100 scf. At a minimum, the amount of fuel sampling data specified in section 2.3.1.4 or 2.3.2.4 of appendix D to 40 CFR Part 75 is required. (40 CFR §60.334(h)(3)(ii)) Records of the natural gas demonstration shall be made available for the Division upon request. 8.3.2 Sulfur Dioxide (SO2) emissions from this turbine shall not exceed 0.8 lb/MMBtu, on a 3-hour rolling average (Colorado Regulation No. 1, Section VI.B.4.c.(i) and VI.B.2) In the absence of credible evidence to the contrary, compliance with the above SO2 limitation is presumed since only natural gas is permitted to be used as fuel in this turbine. 8.4 Particulate Matter (PM) emissions shall not exceed the above limitation (Colorado Regulation No. 1, Section III.A.1.b). Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 127 The numeric PM standard was determined using the design heat input for the turbine (37.9 MMBtu/hr) in the following equation: PE = 0.5 x (Fl)-°'6 where: PE =particulate standard in lbs/MMBtu FI = fuel input in MMBtu/hr In the absence of credible evidence to the contrary, compliance with the particulate matter emission limit is presumed since only natural gas is permitted to be used as fuel in the heater. 8.5 Natural gas consumption for this turbine shall not exceed the limitation listed in Summary Table 8 above. (Colorado Construction Permits 01WE0290). Natural gas consumption shall be recorded for this turbine engine monthly using the existing individual turbine fuel meter. Monthly natural gas consumption 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. Records of calculations shall be kept in a log to be made available to the Division upon request. 8.6 The Btu content of the natural gas used to fuel this turbine shall be verified semi-annually using the appropriate ASTM Methods or equivalent, if approved in advance by the Division. The Btu content of the natural gas shall be based on the higher heating value of the fuel. Calculations of monthly emissions shall be made using the heat content derived from the most recent required analysis. 8.7 Hours of operation shall be monitored monthly and recorded and maintained to be available to the Division upon request. Monthly hours of operation shall be used in a running total for each annual compliance period. The hours of operation shall be used to determine if portable monitoring is required as specified in SECTION IV - 1. 8.8 This turbine is subject to the following opacity requirements: 8.8.1 [State-only] Visible emissions of any particulate matter shall not exceed 20% opacity (Colorado Regulation No. 6, Part B, Section II.C.3) This opacity requirement applies at all times except during periods of startup, shutdown, and malfunction (40 CFR Part 60, Subpart A, §60.11(c), as adopted by reference in Colorado Regulation No. 6, Part B, Section LA). Note that this opacity requirement is more stringent than the opacity requirement in Condition 8.8.3 except during periods of startup. 8.8.2 Except as provided for in Condition 8.8.2 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section II.A.1). 8.8.3 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, process modifications, or adjustment or occasional cleaning of control equipment Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 128 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 opacity requirements of this Condition 8.8 shall be presumed since only natural gas is permitted to be used as fuel in this turbine. 8.9 This turbine is subject to the NSPS Subpart A, General Provisions requirements (Colorado Construction Permit 01WE0290 and 40 CFR 60.1 through 60.19, as adopted in Colorado Regulation No. 6, Part A, Subpart A), including but not limited to, the following: 8.9.1 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) 8.9.2 Records of startups, shutdowns, and malfunctions shall be maintained, as required under 40 CFR §60.7. 8.9.3 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. 8.10 This combustion turbine is subject to the requirements of Colorado Regulation No. 7, Part E, "Combustion Equipment and Major Source RACT", including, but not limited to, the following: [The requirements below reflect the current rule language as of the revisions to 5 CCR 1001-9 Colorado Regulation No. 7 published in the Colorado Register on 01/25/2020 and effective on 02/14/2020. However, if revisions to this rule are published at a later date, the owner or operator is subject to the requirements contained in the revised version of Colorado Regulation No. 7.] [Note:Applicability of the following requirements of Colorado Regulation No. 7, Part E, Sections ILA.4, ILA.5, and ILA.7.a, c, and d to this combustion turbine is dependent on the annual capacity factor and annual uncontrolled actual emissions of the turbine, as specified in the exemptions of Section ILA.2, therefore, applicability may vary from year to year] 8.10.1 Emission limitations. By October 1, 2021, no owner or operator of stationary combustion equipment may cause, allow or permit NOx to be emitted in excess of the following emission limitations. (II.A.4) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 129 8.10.1.1 Stationary combustion turbines with a maximum design heat input capacity equal to or greater than 10 MMBtu/hr and which commenced construction on or before February 18, 2005 must comply with the applicable NOx emission limits in 40 CFR Part 60, Subpart GG (July 1, 2017). (II.A.4.b.(i)) 8.10.2 Compliance demonstration. By October 1, 2021, the owner or operator of an affected unit must determine compliance with the applicable emission limitations contained in Section II.A.4. (Condition 8.10.1) according to the applicable methods contained in this Section II.A.5. (II.A.5.a) Initial and Periodic Performance Testing (II.A.5.c.(ii)) 8.10.2.1 An owner or operator of a stationary combustion turbine subject to 40 CFR Part 60, Subparts GG or KKKK that has used and continues to use performance testing to demonstrate compliance with either Subpart GG or KKKK, as applicable, may use those performance testing procedures to demonstrate continued compliance with an applicable limitation contained in Section II.A.4.b. (Condition 8.10.1.1), thereby satisfying the requirements of this section II.A.5.c.(ii). (II.A.5.c.(ii)(A)) 8.10.3 The following records must be kept for a period of five years and made available to the Division upon request (II.A.7): 8.10.3.1 The applicable emission limit. (II.A.7.a.) 8.10.3.2 The type and amount of fuel used. (II.A.7.c.) 8.10.3.3 The stationary combustion equipment's annual capacity factor on a calendar year basis. (II.A.7.d.) [Note that the following requirements of Colorado Regulation No. 7, Part E, Sections II.A.6 and ILA.7 apply to specific combustion equipment with uncontrolled actual emissions of NOx equal to or greater than five (5) tons per year, as specified in Part E, Section ILA.6.a, therefore, applicability may vary from year to yeas] Combustion Process Adjustment (Part E, Section ILA.6) 8.10.4 The owner or operator of a stationary combustion turbine must conduct the following inspections and adjustments, as applicable (II.A.6.b.(iii)): 8.10.4.1 Inspect turbine inlet systems and align,repair, or replace components as necessary. (II.A.6.b.(iii)(A)) 8.10.4.2 Inspect the combustion chamber components, combustion liners, transition pieces, and fuel nozzle assemblies and clean, repair, or replace components as necessary. (II.A.6.b.(iii)(B)) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 130 8.10.4.3 When burning the fuel that provides the majority of the heat input since the last combustion process adjustment and when operating at a firing rate typical of normal operation, confirm proper setting and calibration of the combustion controls. (II.A.6.b.(iii)(C)) 8.10.5 The owner or operator must operate and maintain the stationary combustion turbine consistent with manufacturer's specifications, if available, or good engineering and maintenance practices. (II.A.6.b.(vii)) 8.10.6 The owner or operator of stationary combustion turbines with uncontrolled actual emissions of NOx equal to or greater than five (5) tons per year that existed at major sources of NOx (greater than or equal to 100 tpy NOx) as of June 3, 2016, must conduct the initial combustion process adjustment by April 1, 2017. An owner or operator may rely on a combustion process adjustment conducted in accordance with applicable requirements and schedule of a New Source Performance Standard in 40 CFR Part 60 (November 17, 2016) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (November 17, 2016) to satisfy the requirement to conduct an initial combustion process adjustment by April 1, 2017. (II.A.6.b.(viii)(A)) 8.10.7 The owner or operator must conduct subsequent combustion process adjustments at least once every twelve (12) months after the initial combustion adjustment, or on the applicable schedule according to Sections II.A.6.c.(i). or II.A.6.c.(ii) (Conditions 8.10.8.1 or 8.10.8.2). (II.A.6.b.(viii)(C)) 8.10.8 As an alternative to the requirements described in Sections II.A.6.b.(iii), II.A.6.b.(vii) and II.A.6.b.(viii) (Conditions 8.10.4 through 8.10.7) (II.A.6.c.): 8.10.8.1 The owner or operator may conduct the combustion process adjustment according to the manufacturer recommended procedures and schedule (II.A.6.c.(i)); or 8.10.8.2 The owner or operator of combustion equipment that is subject to and required to conduct a period tune-up or combustion adjustment by the applicable requirements of a New Source Performance Standard in 40 CFR Part 60 (December 19, 2019) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (December 19, 2019) may conduct tune-ups or adjustments according to the schedule and procedures of the applicable requirements of 40 CFR Part 60 (December 19, 2019) or 40 CFR Part 63 (December 19, 2019). (II.A.6.c.(ii)) Recordkeeping (ILA.7) 8.10.9 The following records must be kept for a period of five years and made available to the Division upon request (II.A.7): Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 131 8.10.10 For stationary combustion equipment subject to the combustion process adjustment requirements in Section II.A.6 (Conditions 8.10.4 through 8.10.8), the following recordkeeping requirements apply (II.A.71.): 8.10.11 The owner or operator must create a record once every calendar year identifying the combustion equipment at the facility subject to Section ILA and including for each combustion equipment (II.A.7.f.(i)): 8.10.11.1 The date of the adjustment (II.A.7.f.(i)(A)); 8.10.11.2 Whether the combustion process adjustment under Sections II.A.6.b.(iii) (Condition 8.10.4) was followed, and what procedures were performed (II.A.7.f.(i)(B)); 8.10.11.3 Whether a combustion process adjustment under Sections II.A.6.c.(i) and II.A.6.c.(ii) (Conditions 8.10.8.1 and 8.10.8.2) was followed, what procedures were performed, and what New Source Performance Standard or National Emission Standard for Hazardous Air Pollutants applied, if any (II.A.7.f.(i)(C)); and 8.10.11.4 A description of any corrective action taken. (II.A.7.f.(i)(D)) 8.10.11.5 If the owner or operator conducts the combustion process adjustment according to the manufacturer recommended procedures and schedule and the manufacturer specifies a combustion process adjustment on an operation time schedule, the hours of operation. (II.A.7.f.(i)(E)) 8.10.12 The owner or operator must retain manufacturer recommended procedures, specifications, and maintenance schedule if utilized under II.A.6.c.(i) (Conditions 8.10.8.1) for the life of the equipment. (II.A.7.f.(ii)) 8.10.13 As an alternative to the requirements described in Section II.A.7.f.(i) (Condition 8.10.11), the owner or operator may comply with applicable recordkeeping requirements related to combustion process adjustments conducted according to a New Source Performance Standard in 40 CFR Part 60 (November 17, 2016) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (November 17, 2016). (II.A.7.f.(iii)) Note: 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. (Section VI Condition 22.b) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 132 9. S021: One (1) Flare Industries Air Assisted Process Flare (AIRS point 053) Permit Compliance Monitoring Parameter Condition Limitations Number Emission Factor Method Interval Emissions Routed to Flare that Requirements for Certain Process 9.1 Achieves 98%Reduction in See Condition 9.1 VOC Emissions from Process Gases Gases NOx 9 2 5.6 tons/yr 0.068 lb/MMBtu Recordkeeping Monthly CO 25.4 tons/yr 0.31 lb/MMBtu and Calculation Recordkeeping Monthly Site Specific, and Calculation VOC 9.3 31.8 tons/yr See Condition 9.3 Site Specific EF Quarterly Development Flow Meter and Gas Consumed by Process,Purge and Pilot gas: Calculation the Flare 9.4 103.4 MMscf/yr See Condition Monthly 9.4 ASTM or other Btu Content of Division 9.5 Quarterly Flare Gas Streams uarterl Approved Method Flare Hours of 9.6 Recordkeeping Monthly Operation Visible Visible Emission Requirements Emissions Daily Observations Temperature A Flame Shall be Present at All Sensor or Flame Detection Continuously Flare Operational Times the Flare is Operated p 9.7 Device with Requirements Alarm Flare Specifications—Btu Content of Gas and Tip Velocity See Condition 9.7 Flare Shall be Operated at All Times Emissions May be Vented Certification Annually to it Not to Exceed 30%for a Period Opacity 9 8 or Periods Aggregating More See Condition 9.8 than Six(6)Minutes in any 60 Consecutive Minutes 9A Emissions from maintenance activities, purge gas, process malfunctions/upsets shall be routed through a closed vent system to the flare prior to being emitted. The flare shall be capable of reducing VOC Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 133 emissions from these activities by 98% or greater(Colorado Regulation No. 3, Part C, Section III.B.7 and Part B, Section III.E). In the absence of credible evidence to the contrary, compliance with the 98% reduction requirement shall be presumed provided the requirements in Condition 9.7 are met. 9.2 Emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO) from the flare shall not exceed the limitations listed in Summary Table 9 above (Colorado Construction Permit 02WE0927 and Colorado Regulation No. 3, Part C, Section III.B.7). Monthly emissions shall be calculated, by the end of the subsequent month, using the emission factors in Summary Table 9 above and the total heat input of inlet gas streams routed to the flare (combined process/purge gas stream and pilot gas), in the equation below: tons EF ( !? x Total Heat Input (4 3t1 MMBtu th Emissions = month 2000 (L) l ton J Total heat input to the flare from the combined process/purge gas stream and pilot gas stream shall be calculated in the following equation: MMBtu MMscf MMBtu Total heat input ( )= ) ( Stream volume ( )x Stream heat content ( } mo month MMscf /Each Stream The monthly stream volumes used to calculate total heat input shall be those metered/calculated as required by Condition 9.4. The heat contents of the individual input streams shall be determined as required by Condition 9.5. Monthly emissions shall be summed and 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. Records of calculations shall be kept in a log to be made available to the Division upon request. 9.3 Volatile Organic Compound (VOC) emissions shall not exceed the limitation listed in Summary Table 9 above (Colorado Construction Permit 02WE0927 and Colorado Regulation No. 3, Part C, Section III.B.7). Compliance with the annual limitation shall be monitored as follows: On a quarterly basis, the operator shall complete a site specific extended gas analysis of the waste gas routed to the flare in order to verify the VOC contents of the combined process/purge gas stream. Sampling of the process gas stream shall be performed upstream of the point where the process gas stream is combined with the purge gas stream. The extended gas analysis shall be conducted using ASTM methods or equivalent, if approved in advance by the Division. On an annual basis, the operator shall complete a site specific extended gas analysis of the residue/fuel gas at this site in order to verify the VOC contents of the pilot gas stream. The extended gas analysis shall be conducted using ASTM methods or equivalent, if approved in advance by the Division. Monthly emissions shall be calculated using the molar fraction of VOC constituents determined from the most recent extended gas analyses and the monthly flare throughput (volume of gases consumed in the flare, as required by Condition 9.4) in the equation below: Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 134 tons mol 1 lb Flare Throughput ( � ( ( 379.3 X 2000ft(ilb VOC x� x Ml X month mol sample lb —mol � _ ) ([L mo1� (ton Where: xi = Molar Fraction of VOC constituent i;mol constituent i/mol sample Mi = Molar Mass VOC constituent i;lb/lb — mol Emissions from the combined process/purge gas stream and the pilot gas stream shall be summed for comparison to the annual limit. A control efficiency of 98% may be applied to the emissions calculated in this Condition 9.3 for any time that the flare is operated in compliance with Condition 9.7 (flare requirements). Emissions that occur during pilot flame outages (as recorded according to Condition 9.7.2) shall assume 0% control. For APEN reporting purposes, HAP emissions shall be calculated, in the equation above, using the molar mass and molar fraction of each individual HAP, as obtained from the periodic gas analyses. Monthly emissions 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. Records of extended gas analyses performed and emissions calculations shall be kept in a log to be made available to the Division upon request. 9.4 The total volume of all gases consumed in the flare shall not exceed the limitations listed in Summary Table 9 above (Colorado Construction Permit 02WE0927 and Colorado Regulation No. 3, Part C, Section III.B.7). The volume of process/purge gas routed to the flare shall be continuously monitored and recorded monthly using the existing combined stream flow meter. The volume of pilot gas consumed in the flare shall be calculated based on the maximum design rate of the pilot (88 scf/hr) and the hours of operation. Monthly volumes of metered process/purge gas and calculated pilot gas consumed in the flare shall be summed and used in a rolling twelve month total to monitor compliance with the annual limitation. Each month, a new twelve month total shall be calculated based on the previous twelve months' data. Records of calculations shall be kept in a log to be made available to the Division upon request. 9.5 The Btu content of the combined process/purge gas stream routed to this flare shall be verified quarterly using the appropriate ASTM Methods or equivalent, if approved in advance by the Division. The Btu content of the stream shall be based on the higher heat content of the stream. Calculations of monthly emissions shall be made using the heat content derived from the most recent required analysis. The Btu content of the pilot gas stream routed to this flare shall be verified annually using the appropriate ASTM methods or equivalent, if approved in advance by the Division. The Btu content of the streams shall be based on the higher heat content of the streams. Calculations of monthly emissions shall be made using the heat content derived from the most recent required analysis. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 135 9.6 Hours of operation for the flare shall be monitored and recorded monthly. Hours of operation shall be used to determine the quantity of pilot gas burned as required by Condition 9.4. 9.7 The owner or operator shall design, construct, operate and maintain the flare according to the requirements set out in 40 CFR §60.18, including, but not limited to, the following (Colorado Construction Permit 02WE0927): 9.7.1 Flares shall be designed for and operated with no visible emissions, as determined by the methods specified in Condition 9.7.1.1, except for periods not to exceed a total of 5 minutes during any 2 consecutive hours (§60.18(c)(1)). Test Method 22 of appendix A to 40 CFR 60 shall be used to determine the compliance of flares with the visible emission provisions of this subpart. The observation period is 2 hours and shall be used according to Method 22. Compliance with the visible emissions requirements shall be monitored as follows: 9.7.1.1 A visible emissions observation shall be conducted daily when the flare is operating. 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 daily 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). Records of all daily visible emissions observations and any Method 22 observations conducted shall be kept for Division review upon request. 9.7.2 Flares shall be operated with a flame present at all times (§60.18(c)(2)). The presence of a flare pilot flame shall be continuously monitored using a thermocouple or any other equivalent device to detect the presence of a flame (§60.18(f)(2)). The device shall be equipped with an alarm to indicate no ignition of the pilot flame. Records of the times and duration of all periods of pilot flame outages and estimated emissions shall be maintained and made available to the Division upon request. Estimated emissions during pilot flame Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 136 outages (uncontrolled emissions) shall assume 0% control and shall be used as specified in Condition 9.3 to monitor compliance with the VOC emission limitation. 9.7.3 This flare shall meet the following specifications (02WE0927, as modified under the provisions of Section I, Condition 1.3): 9.7.3.1 This flare 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 (§60.18(c)(3)(ii)). The net heating value of the gas being combusted shall be determined by the methods specified in Condition 9.5. 9.7.3.2 Air-assisted flares shall be designed and operated with an exit velocity less than the velocity, Vmax, as determined by the method specified 40 CFR §60.18(f)(6) (§60.18(c)(5)). The actual exit velocity of a flare shall be determined by dividing the volumetric flowrate (in units of standard temperature and pressure), as determined by Reference Methods 2, 2A, 2C, or 2D as appropriate; by the unobstructed (free) cross sectional area of the flare tip. ((§60.18(f)(4)) Compliance with the exit velocity limitation shall be monitored monthly by calculating the maximum exit velocity of the flare for the month, based on actual operating conditions, and comparing it to the limit specified by §60.18(f)(6). 9.7.3.3 This flare shall be monitored to ensure that it is operated and maintained in conformance with its design (§60.18(d)). Records of manufacturer operation and maintenance requirements and all maintenance performed on this flare shall be kept in a log to be made available to the Division upon request. 9.7.3.4 This flare shall be operated at all times when emissions may be vented to this flare (§60.18(e)). 9.8 No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Colorado Regulation No. 1, Section II.A.5) In the absence of credible evidence to the contrary, compliance with this opacity requirement shall be presumed provided the requirements in Condition 9.7.1.1 are met. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 137 10. NG-TL-01: One (1) Truck Loadout of Pressurized Natural Gasoline Liquids (AIRS point 073) Permit Monitoring Parameter Condition Limitations Number Emission Factor Method Interval Simulation and VOC 10.1 5.9 tons/yr Twelve Month Monthly Rolling Total Calculation NOx 5.6 tons/yr 0.15 lb/MMBtu Recordkeeping and Twelve 10.2 Month Rolling Monthly CO 7.4 tons/yr 0.20 lb/MMBtu Total Calculation Natural Gasoline 10.3 456,250 bbl/yr Recordkeeping Monthly Liquids Loaded Extended Natural ASTM or other Gasoline Liquids 10.4 Division Semi-annually Analysis Approved Method Parametric 10.5 Recordkeeping Monthly Monitoring Loadout Operation and 10.6 See Condition 10.6 Maintenance Control Device Operation, 10.7 See Condition 10.7 Maintenance, and Monitoring Not to exceed 20%, except as provided for below Opacity 10.8 See Condition 10.8 For Certain Operational Activities—Not to Exceed 30% Compliance Assurance 10.9 See Condition 10.9 Monitoring (CAM) 10.1 Emissions of Volatile Organic Compounds (VOC) shall not exceed the limitations listed in Summary Table 10 above (Colorado Construction Permit 17WE0053, as modified under the provisions of Section I, Condition 1.3). Compliance with the emission limits shall be monitored as follows: 10.1.1 Monthly determination of VOC emissions shall be conducted by the end of the subsequent month using Bryan Research and Engineering's ProMax model. The process model shall be configured to determine "flashing" emissions, associated with the pressure drop when Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 138 loading natural gasoline liquids from a pressurized tank to an atmospheric tanker truck, as well as emissions associated with normal loading operations. The following parameters shall be input to the process model: 10.1.1.1 The monthly recorded natural gasoline liquids throughput, as required by Condition 10.3. 10.1.1.2 The natural gasoline liquids composition and applicable physical properties obtained from the most recent extended analysis, as required by Condition 10.4. 10.1.1.3 The recorded bulk pressure and temperature of the natural gasoline liquids, as required by Condition 10.5. 10.1.1.4 A control efficiency of 95% may be used during periods that emissions from the tanks are routed to the enclosed combustion device (ECD) while the combustion device is operating, provided the requirements of Condition 10.7 are met. 10.1.2 VOC emissions from flashing and loading shall be obtained from the ProMax model output and shall be used in the following equation to calculate monthly VOC emissions from the pressurized loadout: tons I LF ( 2g ) LL ( l8 month)I X (1 ——"(%)) VOC Emissions ( ) month iaa month 2000 2b Unit Conversion ) ton Where: LF = Flashing VOC Losses,lb/month LL = Loading VOC Losses,lb/month CE = Control Efficiency of Combuster,% Monthly emissions shall be calculated in a rolling twelve month total 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 and made available for Division review upon request. 10.1.3 Annual emissions of Hazardous Air Pollutants (HAP) for the purposes of APEN reporting and the payment of annual fees shall be calculated using HAP emissions derived from the same method as required for VOC emissions. 10.2 Emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO) shall not exceed the limitations listed in Summary Table 10 above (Colorado Construction Permit 17WE0053, as modified under the provisions of Section I, Condition 1.3). Monthly emissions of NOx and CO shall be calculated by the end of the subsequent month using the emission factors above and the total heat input of gas streams Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 139 routed to the enclosed combustion device (flashing and loading emissions, supplemental fuel and pilot gas) in the equation below: `v ( tons EF ( ) x Total Heat Input (N�NIBtU) Emissions �'"'�`u month lb 2000 (tin) Total heat input to the enclosed combustion device (flashing and loading emissions, supplemental fuel and pilot gas) shall be calculated in the following equation: MMBtu 0 MMBtu ( hours Total Heat Input (month) QLL X HCLF I ++ QLL X HCLL I + + .66( hour ) x `month! Where: QLF = Volumetric Flow of Flashing Losses,MMscf/month HCLF = Heat Content of flashing Losses,MMBtu/MMscf QLL = Volumetric Flow of Loading Losses,MMscf/month HCLL = Heat Content of Loading Losses,MMBtu/MMscf 0.66 = Total Heat Input of Supplemental Fuel and Pilot Gas,MMBtu/hour The volumetric flow and heat content of the flashing and loading loss streams shall be obtained from the monthly ProMax model runs required in Condition 10.1. For calculation of the total heat input from supplemental fuel and pilot gas, the hours per month shall be the total hours in the calendar month. Monthly emissions shall be calculated in a rolling twelve month total to monitor compliance with the annual emission limitations. 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 and made available for Division review upon request. 10.3 The maximum amount of natural gasoline liquids loaded shall not exceed the limitations listed in Summary Table 10 above (Colorado Construction Permit 17WE0053, as modified under the provisions of Section I, Condition 1.3). The natural gasoline liquids throughput shall be monitored and recorded monthly and 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. Records of calculations shall be maintained and made available to the Division upon request. The monthly natural gasoline liquids throughput shall be used as input to the monthly process model run, required by Condition 10.1, to monitor compliance with the annual VOC emission limitation. 10.4 An extended liquid analysis of the natural gasoline liquids loaded shall be performed semi-annually according to appropriate ASTM methods, or equivalent, if approved in advance by the Division. At least four months shall separate each semi-annual sample. Results of each natural gasoline liquids analysis shall be retained and made available to the Division upon request. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 140 The composition and physical properties indicated by the extended natural gas liquids analysis shall be used as inputs to the monthly process model run, as required by Condition 10.1, to monitor compliance with the annual VOC emission limitation. 10.5 The bulk liquid pressure of the natural gasoline liquids shall be monitored and recorded monthly. A log of the monthly recorded bulk liquid pressure shall be maintained and made available to the Division upon request. The bulk liquid pressure shall be used as an input to the monthly process model run, as required by Condition 10.1, to monitor compliance with the annual VOC emission limitation. 10.6 The following requirements apply to the operation of the natural gasoline liquids loadout: 10.6.1 The natural gasoline liquids loadout shall be operated and maintained with an enclosed flare in order to reduce emissions to less than or equal to the limits established in this Condition 11. (Colorado Construction Permit 17WE0053 and Colorado Regulation No. 7, Part A, Section II.C.1.a(i)) 10.6.2 Loadout of natural gasoline liquids to truck tanks shall utilize submerged fill loading (Colorado Construction Permit 17WE0053 and Colorado Regulation No. 7, Part A, Section II.C.1.a(i)). 10.6.3 All natural gasoline liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. (Colorado Construction Permit 17WE0053) 10.6.4 The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Colorado Construction Permit 17WE0053 and Colorado Regulation No. 3, Part B, Section III.D.2): 10.6.4.1 Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. 10.6.4.2 The owner or operator shall inspect onsite loading equipment during loading operations to monitor compliance with above conditions. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. 10.7 The following requirements apply to the operation of the enclosed combustion device and vapor collection equipment associated with the loadout (Colorado Construction Permit 17WE0053): 10.7.1 The owner or operator of a loadout that is controlled shall: 10.7.1.1 Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. 10.7.1.2 Include devices to prevent the release of vapor from vapor recovery hoses not in use. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 141 10.7.1.3 Use operating procedures to ensure that natural gasoline liquid cannot be transferred unless the vapor collection equipment is in use. 10.7.1.4 Operate all recovery and disposal equipment at a back pressure less than the pressure relief valve setting of transport vehicles. 10.7.1.5 Inspect pressure relief devices annually for proper operation and replace as necessary. Pressure relief devices shall be set to release at a pressure that will ensure flashing and loading losses are routed to the control device under normal operating conditions. 10.7.1.6 Document annual inspections of pressure relief devices with an indication of status, a description of any problems found, and their resolution. 10.7.2 Visible emissions observations shall be conducted daily according to Condition 10.8.3. 10.7.3 The enclosed combustion device shall be operated with the pilot light present at all times when natural gas liquids are being loaded. The presence of the pilot light during loading operations shall be monitored according to the Compliance Assurance Monitoring requirements of Condition 10.9. 10.8 This unit is subject to the following opacity requirements: 10.8.1 Except as provided for in Condition 10.8.2 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section II.A.1). 10.8.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, process modifications, or adjustment or occasional cleaning of control equipment 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). Compliance with the above opacity limitations shall be monitored as follows: 10.8.3 A qualitative visual emissions observation shall be conducted daily on the enclosed combustion device stack while natural gas liquids are being loaded. Records of the results of the qualitative visual emissions observations shall be kept in a log and made available to the Division upon request. 10.8.4 If any visible emissions are observed during the daily observation, an EPA Reference Method 9 observation shall be performed. 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 limit shall be considered to exist from the time a Method 9 reading is taken that shows an exceedance of the opacity limit until a Method 9 reading is taken that shows the opacity is less than the opacity limit. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 142 10.8.5 All opacity observations shall be performed by an observer with current and valid Method 9 certification. Results of Method 9 readings and a copy of the certified Method 9 reader's certificate shall be kept on site and made available to the Division upon request. 10.8.6 A daily visual emissions observation is not required for any day that the natural gasoline liquids loadout is not operated. 10.9 This natural gasoline liquids loadout is subject to the Compliance Assurance Monitoring (CAM) requirements with respect to the annual VOC emission limitation in Condition 10.1. Compliance with the CAM requirements shall be monitored in accordance with the requirements in SECTION IV - 12 and the CAM Plan in APPENDIX J. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 143 11. Insignificant Engines Subject to NSPS/MACT Requirements PLV PLC GEN: One (1) Mitsubishi Model 4G63S4M; 80 HP (AIRS point 054) Permit Monitoring Parameter Condition Limitations Number Emission Factor Method Interval Hours of 11.1 Recordkeeping Annually Operation Not to exceed 20%, except as provided for below For Certain Operational Only Natural Opacity 11.2 Activities -Not to Exceed 30% Fuel Restriction Gas/Propane for a Period or Periods are Used as Aggregating More than Six(6) Fuel Minutes in any 60 Consecutive Minutes 40 CFR 60 NMHC+NOx- 10 g/HP-hr 11.3 See Condition 11.3 Subpart JJJJ CO—387 g/HP-hr 40 CFR 60 Subpart A— 11.4 See Condition 11.4 General Provisions Note: This generator engine is exempt from the construction permitting requirements in Regulation No. 3,Part B provided uncontrolled actual emissions do not equal or exceed 5 ton/yr per Colorado Regulation No. 3,Part B, Section II.D.1.c.(iii). Based on manufacturer's emission factors (138.95 g/hp-hr for CO)and design rate(80 hp),emissions will equal 5 ton/yr at 409 hrs. 11.1 Hours of operation for this emergency generator engine shall be monitored annually (calendar year) and recorded in a log to be made available to the Division upon request. If annual hours of operation equal or exceed 409 hours for this engine, the engine is no longer exempt from the permitting requirements in Colorado Regulation No. 3, Part B and the permittee shall submit an application to revise this permit within 30 days in order to include the appropriate applicable requirements. 1L2 The following opacity requirements apply to this engine: 1L2.1 Except as provided for in Condition 11.2.2 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section II.A.1). 11.2.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, process modifications, or adjustment or occasional cleaning of control equipment 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 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 144 In the absence of credible evidence to the contrary, compliance with the opacity requirements of Condition 11.2 shall be presumed since only natural gas and/or propane are used as fuels in this engine. 11.3 [Federal-Only] This engine is subject to the requirements in 40 CFR Part 60, Subpart JJJJ, "Standards of Performance for Stationary Spark Ignition Internal Combustion Engines", 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 JJJJ published in the Federal Register on 8/30/2016. 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 JJJJ.] [These requirements have not been adopted into Colorado Regulation No. 6, Part A as of the date of this revised permit issuance [DATE], and are therefore not state-enforceable. In the event that these requirements are adopted into Colorado Regulations, they will become state-enforceable.] 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 §60.4243(d)(2)(ii)-(iii) (Conditions 11.3.5.2b and 11.3.5.2c) have no legal effect. Operation of emergency engines is limited to emergency situations specified in 60.4243(d)(1) (Condition 11.3.5.1); maintenance checks and readiness testing for a limited number of hours per year as specified in 60.4243(d)(2)(i) (Condition 11.3.5.2a); and certain non-emergency situations for a limited number of hours per year as specified in 60.4243(d)(3) (Condition 11.3.5.3). 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 in 40 CFR Part 60 Subpart JJJJ 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. What emission standards must I meet if I am an owner or operator of a stationary SI internal combustion engine? (60.4233) 11.3.1 Owners and operators of stationary SI ICE with a maximum engine power greater than 19 KW (25 HP) and less than 75 KW (100 HP) (except gasoline and rich burn engines that use LPG) must comply with the emission standards in Table 1 to this subpart for their emergency stationary SI ICE. Owners and operators of stationary SI ICE with a maximum engine power greater than 19 KW (25 HP) and less than 75 KW (100 HP) manufactured prior to January 1, 2011, that were certified to the standards in Table 1 to this subpart applicable to engines with a maximum engine power greater than or equal to 100 HP and less than 500 HP, may optionally choose to meet those standards. (§60.4233(d)) The emissions standards in Table 1 to Subpart JJJJ that apply to this engine are as follows: 11.3.1.1 Emissions of NOx + HC shall not exceed 10 g/hp-hr Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 145 11.3.1.2 Emissions of CO shall not exceed 387 g/hp-hr The emission standards applicable to emergency engines between 25 HP and 130 HP are in terms of NOx + HC. (footnote "c" to Table 1 of Subpart JJJJ) How long must I meet the emission standards ifI am an owner or operator of a stationary SI internal combustion engine? (60.4234) 11.3.2 Owners and operators of stationary SI ICE must operate and maintain stationary SI ICE that achieve the emission standards as required in §60.4233 (Condition 11.3.1) over the entire life of the engine. (§60.4234) What are the monitoring requirements if I am an owner or operator of an emergency stationary SI internal combustion engine? (60.4237) 11.3.3 If you are an owner or operator of an emergency stationary SI internal combustion engine that is less than 130 HP, was built on or after July 1, 2008, and does not meet the standards applicable to non-emergency engines, you must install a non-resettable hour meter upon startup of your emergency engine. (§60.4237(c)) What are my compliance requirements if I am an owner or operator of a stationary SI internal combustion engine? (60.4243) 11.3.4 If you are an owner or operator of a stationary SI internal combustion engine and must comply with the emission standards specified in §60.4233(d) (Condition 11.3.1) you must demonstrate compliance according to one of the methods specified in paragraphs (b)(1) and (2) of this section (This Condition 11.3.4). (§60.4243(b)) 11.3.4.1 Purchasing an engine certified according to procedures specified in this subpart, for the same model year and demonstrating compliance according to one of the methods specified in §60.4243(a) of Subpart JJJJ. (§60.4243(b)(1)) 11.3.4.2 Purchasing a non-certified engine and demonstrating compliance with the emission standards specified in §60.4233(d) (Condition 11.3.1) and according to the requirements specified in §60.4244, as applicable, and according to §60.4243(b)(2)(i) (Condition 12.3.4.2a). (§60.4243(b)(2)) a. If you are an owner or operator of a stationary SI internal combustion engine greater than 25 HP and less than or equal to 500 HP, you must keep a maintenance plan and records of conducted maintenance and must, to the extent practicable, maintain and operate the engine in a manner consistent with good air pollution control practice for minimizing emissions. In addition, you must conduct an initial performance test to demonstrate compliance. (§60.4243(b)(2)(i)) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 146 11.3.5 If you own or operate an emergency stationary ICE, you must operate the emergency stationary ICE according to the requirements in paragraphs (d)(1) through (3) of this section (Conditions 11.3.5.1 through 11.3.5.3). In order for the engine to be considered an emergency stationary ICE 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 paragraphs (d)(1) through (3) of this section (Conditions 11.3.5.1 through 11.3.5.3), is prohibited. If you do not operate the engine according to the requirements in paragraphs (d)(1) through (3) of this section (Conditions 11.3.5.1 through 11.3.5.3), the engine will not be considered an emergency engine under this subpart and must meet all requirements for non-emergency engines. (§60.4243(d)) 11.3.5.1 There is no time limit on the use of emergency stationary ICE in emergency situations. (§60.4243(d)(1)) 11.3.5.2 You may operate your emergency stationary ICE for any combination of the purposes specified in paragraphs (d)(2)(i) through (iii) of this section (Conditions 12.3.5.2a through 12.3.5.2c) for a maximum of 100 hours per calendar year. Any operation for non-emergency situations as allowed by paragraph (d)(3) of this section (Condition 11.3.5.3) counts as part of the 100 hours per calendar year allowed by this paragraph (d)(2) (Condition 11.3.5.2). (§60.4243(d)(2)) a. Emergency stationary ICE 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 ICE beyond 100 hours per calendar year. (§60.4243(d)(2)(i)) b. Emergency stationary ICE 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 §60.17), 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. (§60.4243(d)(2)(ii)) c. Emergency stationary ICE may be operated for periods where there is a deviation of voltage or frequency of 5 percent or greater below standard voltage or frequency. (§60.4243(d)(2)(iii)) 11.3.5.3 Emergency stationary ICE 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 Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 147 and testing and emergency demand response provided in paragraph (d)(2) of this section (Condition 11.3.5.2). Except as provided in paragraph (d)(3)(i) of this section (Condition 12.3.5.3a), 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 an electric grid or otherwise supply power as part of a financial arrangement with another entity. (§60.4243(d)(3)) a. The 50 hours per year for non-emergency situations can be used to supply power as part of a financial arrangement with another entity if all of the following conditions are met(§60.4243(d)(3)(i)): (i) The engine is dispatched by the local balancing authority or local transmission and distribution system operator (§60.4243(d)(3)(i)(A)); (ii) The dispatch is intended to mitigate local transmission and/or distribution limitations so as to avert potential voltage collapse or line overloads that could lead to the interruption of power supply in a local area or region. (§60.4243(d)(3)(i)(B)) (iii) The dispatch follows reliability, emergency operation or similar protocols that follow specific NERC, regional, state, public utility commission or local standards or guidelines. (§60.4243(d)(3)(i)(C)) (iv) The power is provided only to the facility itself or to support the local transmission and distribution system. (§60.4243(d)(3)(i)(D)) (v) The owner or operator identifies and records the entity that dispatches the engine and the specific NERC, regional, state, public utility commission or local standards or guidelines that are being followed for dispatching the engine. The local balancing authority or local transmission and distribution system operator may keep these records on behalf of the engine owner or operator. (§60.4243(d)(3)(i)(E)) 11.3.5.4 Owners and operators of stationary SI natural gas fired engines may operate their engines using propane for a maximum of 100 hours per year as an alternative fuel solely during emergency operations, but must keep records of such use. If propane is used for more than 100 hours per year in an engine that is not certified to the emission standards when using propane, the owners and operators are required to conduct a performance test to demonstrate compliance with the emission standards of§60.4233 (Condition 11.3.1). (§60.4243(e)) 11.3.5.5 If you are an owner or operator of a stationary SI internal combustion engine that is less than or equal to 500 HP and you purchase a non-certified engine or you do not operate and maintain your certified stationary SI internal combustion engine and control device according to the manufacturer's written emission-related instructions, you are required to perform initial performance testing as indicated in this section, but you are not required to conduct subsequent performance testing unless the stationary engine is rebuilt or undergoes major repair or Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 148 maintenance. A rebuilt stationary SI ICE means an engine that has been rebuilt as that term is defined in 40 CFR 94.11(a). (§60.4243(f)) What are my notification, reporting, and recordkeeping requirements if I am an owner or operator of a stationary SI internal combustion engine? (60.4245) 11.3.6 Owners or operators of stationary SI ICE must meet the following notification, reporting and recordkeeping requirements. (§60.4245) 11.3.6.1 Owners and operators of all stationary SI ICE must keep records of the information in paragraphs (a)(1) through (4) of this section (Conditions 12.3.6.1a through 12.3.6.1d). (§60.4245(a)) a. All notifications submitted to comply with this subpart and all documentation supporting any notification. (§60.4245(a)(1)) b. Maintenance conducted on the engine. (§60.4245(a)(2)) c. If the stationary SI internal combustion engine is a certified engine, documentation from the manufacturer that the engine is certified to meet the emission standards and information as required in 40 CFR parts 90, 1048, 1054, and 1060, as applicable. (§60.4245(a)(3)) d. If the stationary SI internal combustion engine is not a certified engine or is a certified engine operating in a non-certified manner and subject to §60.4243(a)(2), documentation that the engine meets the emission standards. (§60.4245(a)(4)) 11.3.6.2 For all stationary SI emergency ICE greater than 25 HP and less than 130 HP manufactured on or after July 1, 2008, that do not meet the standards applicable to non-emergency engines, the owner or operator of must keep records of the hours of operation of the engine that is recorded through the non-resettable hour meter. The owner or operator must document how many hours are spent for emergency operation, including what classified the operation as emergency and how many hours are spent for non-emergency operation. (§60.4245(b)) 11.3.6.3 Owners and operators of stationary SI ICE that are subject to performance testing must submit a copy of each performance test as conducted in §60.4244 within 60 days after the test has been completed. Performance test reports using EPA Method 18, EPA Method 320, or ASTM D6348-03 (incorporated by reference see 40 CFR 60.17) to measure VOC require reporting of all QA/QC data. For Method 18,report results from sections 8.4 and 11.1.1.4; for Method 320,report results from sections 8.6.2, 9.0, and 13.0; and for ASTM D6348-03 report results of all QA/QC procedures in Annexes 1-7. (§60.4245(d)) What parts of the General Provisions apply to me? (60.4246) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 149 11.3.7 Table 3 to Subpart JJJJ shows which parts of the General Provisions in §§60.1 through 60.19 apply to you. 11.4 This engine is subject to the requirements in 40 CFR Part 60 Subpart A "General Provisions", as specified in SECTION IV - 10. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 150 S022: One (1) John Deere 115 HP Diesel Generator Powering a Back-up Air Compressor Permit Compliance Monitoring Parameter Condition Limitations Number Emission Factor Method Interval Hours of 11.5 Recordkeeping Annually Operation Only Diesel SO= 11.6 0.8 lb/MMBtu Fuel Restriction Fuel is Used as Fuel Not to exceed 20%, except as provided for below For Certain Operational Opacity 11.7 Activities -Not to Exceed 30% EPA Method 9 See Condition for a Period or Periods 11.7 Aggregating More than Six(6) Minutes in any 60 Consecutive Minutes 40 CFR 63 11.8 Work/Management Practices See Condition 11.8 Subpart ZZZZ 40 CFR 63 Subpart A 11.9 See Condition 11.9 General Provisions Note: This diesel generator engine is exempt from the APEN reporting requirements in Regulation No. 3,Part A provided actual uncontrolled emissions do not exceed the APEN de minimis level(1 ton/yr NOx)per Colorado Regulation No. 3,Part A, Section II.D.1.a. Based on AP-42, Table 3.3-1 emission factors (4.41 lb/MMBtu for NOx),manufacturer's design rate(6.155 gallon/hour), and a diesel fuel heating value of 137,000 Btu/gallon emissions will exceed the APEN de minimis level at 538 hours of operation. 11.5 Hours of operation for this emergency generator engine shall be monitored annually (calendar year) and recorded in a log to be made available to the Division upon request. If annual hours of operation exceed 538, an APEN is required for this engine and shall be filed. If annual hours of operation equal or exceed 2689 hours for this engine, the engine is no longer exempt from the permitting requirements in Colorado Regulation No. 3, Part B (per Reg. 3, Part B, Section II.D.1.c.(iii)) and the permittee shall submit an application to revise this permit within 30 days in order to include the appropriate applicable requirements. 11.6 Sulfur Dioxide (SO2) emissions from this engine shall not exceed 0.8 lbs/MMBtu (Colorado Regulation No. 1, Section VI.B.4.b.(i)). In the absence of credible evidence to the contrary, compliance with the SO2 emission limitation shall be presumed since only diesel fuel is permitted to be used as fuel in this engine. The permittee shall maintain records that verify that only diesel fuel is used as fuel in this engine. 11.7 The following opacity requirements apply to this engine: Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 151 11.7.1 Except as provided for in Condition 1 L7.2 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section II.A.1). 11.7.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, process modifications, or adjustment or occasional cleaning of control equipment 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). Compliance with these limitations shall be monitored by conducting opacity observations in accordance with EPA Reference Method 9 as follows: 11.7.3 To monitor compliance with the opacity limitation of Condition 11.7A, a Method 9 opacity observation shall be performed at least once per calendar year of operation when the engine is operating under load during conditions suitable for properly performing a valid Method 9 observation. If the engine has not been operated under load, or if a valid Method 9 observation could not be performed when the engine did operate during the calendar year, the permittee is not required to operate the engine for the sole purpose of obtaining an annual opacity observation. Annual opacity observations for an individual engine shall be separated by a period of four(4) months. If an engine is operated more than 250 hours in any calendar year period, a second opacity observation shall be conducted. If two opacity readings are conducted in the annual (calendar year) period, such readings shall be conducted at least thirty days apart. 11.7.4 A Method 9 observation shall be performed any time an engine start-up requires longer than thirty (30) consecutive minutes. A record shall be kept of the date and time this engine was started and when it was shutdown. 11.7.5 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 opacity limit shall be considered to exist from the time a Method 9 reading is taken that shows an exceedance of the opacity limit until a Method 9 reading is taken that shows the opacity is less than the opacity limit. 11.7.6 All Method 9 opacity observations shall be performed by an observer with current and valid Method 9 certification. Results of Method 9 readings and a copy of the certified Method 9 reader's certificate shall be kept on site and made available to the Division upon request. 11.8 [Federal-Only Enforceable] This engine is subject to the requirements in 40 CFR Part 63 Subpart ZZZZ, "National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines", 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 ZZZZ published in the Federal Register on 2/27/2014. However, if revisions to this Subpart are Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 152 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.] [These requirements have not been adopted into Colorado Regulation No. 8, Part E as of the date of this permit issuance [DATE], and are therefore not state-enforceable. In the event that these requirements are adopted into Colorado Regulations, they will become state-enforceable.] 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 §63.6640(f)(2)(ii)-(iii) (Conditions 11.8.11.2b and 11.8.11.2c) have no legal effect. Operation of emergency engines is limited to emergency situations specified in 66.6640(f)(1) (Condition 11.8.11.1); maintenance checks and readiness testing for a limited number of hours per year as specified in 63.6640(f)(2)(i) (Condition 11.8.11.2a); and certain non-emergency situations for a limited number of hours per year as specified in 63.6640(f)(3) (Condition 11.8.11.3). 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 in 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. Compliance Date 11.8.1 If you have an existing stationary CI RICE with a site rating of less than or equal to 500 brake HP located at a major source of HAP emissions you must comply with the applicable emission limitations, operating limitations, and other requirements no later than May 3, 2013. (§63.6595(a)(1)) Emission and Operating Limitations 11.8.2 If you own or operate an existing stationary RICE with a site rating of equal to or less than 500 brake HP located at a major source of HAP emissions, you must comply with the emission limitations and other requirements in Table 2c to Subpart ZZZZ which apply to you. (§63.6602) The requirements in Table 2c to Subpart ZZZZ that apply to this engine are as follows: 11.8.2.1 Change oil and filter every 500 hours of operation or annually,whichever comes first. (Table 2c, Item l.a) 11.8.2.2 Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first, and replace as necessary (Table 2c, Item 1.b); 11.8.2.3 Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and replace as necessary. (Table 2c, Item 1.c) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 153 Notwithstanding the above requirements, the following applies: 11.8.2.4 If an emergency engine is operating during an emergency and it is not possible to shut down the engine in order to perform the work practice requirements on the schedule required in Table 2c of Subpart ZZZZ, or if performing the work practice on the required schedule would otherwise pose an unacceptable risk under federal, state, or local law, the work practice can be delayed until the emergency is over or the unacceptable risk under federal, state, or local law has abated. The work practice should be performed as soon as practicable after the emergency has ended or the unacceptable risk under federal, state, or local law has abated. Sources must report any failure to perform the work practice on the schedule required and the federal, state or local law under which the risk was deemed unacceptable. (Footnote 1 to Table 2c of Subpart ZZZZ) 1L8.2.5 Sources have the option to utilize an oil analysis program as described in §63.6625(i) (Condition 1L8.8) in order to extend the specified oil change requirement in Table 2c of Subpart ZZZZ. (Footnote 2 to Table 2c of Subpart ZZZZ) General Compliance Requirements 1L8.3 You must be in compliance with the emission limitations, operating limitations, and other requirements in this subpart that apply to you at all times. (§63.6605(a)) 1 L8.4 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. The general duty to minimize emissions does not require you to make any further efforts to reduce emissions if levels required by this standard have been achieved. 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. (§63.6605(b)) Monitoring, Installation, Collection, Operation, and Maintenance Requirements 1L8.5 If you own or operate an existing emergency stationary RICE with a site rating of less than or equal to 500 HP located at a major source of HAP emissions, you must operate and maintain the stationary RICE and after-treatment control device (if any) according to the manufacturer's emission-related written instructions or develop your own maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions. (§63.6625(e) and (e)(2)) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 154 11.8.6 If you own or operate an existing emergency stationary RICE with a site rating of less than or equal to 500 brake HP located at a major source of HAP emissions, you must install a non- resettable hour meter if one is not already installed. (§63.6625(f)) 1 L8.7 If you operate a new, reconstructed, or existing stationary engine, you must minimize the engine's time spent at idle during startup and minimize the engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes. (§63.6625(h)) 1 L8.8 If you own or operate a stationary CI engine that is subject to the work, operation or management practices in item 1 of Table 2c to Subpart ZZZZ (Condition 11.8.2), you have the option of utilizing an oil analysis program in order to extend the specified oil change requirement in Table 2c to Subpart ZZZZ (Condition 11.8.2.1). The oil analysis must be performed at the same frequency specified for changing the oil in Table 2c to Subpart ZZZZ (Condition 11.8.2.1). The analysis program must at a minimum analyze the following three parameters: Total Base Number, viscosity, and percent water content. The condemning limits for these parameters are as follows: Total Base Number is less than 30 percent of the Total Base Number of the oil when new; viscosity of the oil has changed by more than 20 percent from the viscosity of the oil when new; or percent water content (by volume) is greater than 0.5. If all of these condemning limits are not exceeded, the engine owner or operator is not required to change the oil. If any of the limits are exceeded, the engine owner or operator must change the oil within 2 business days of receiving the results of the analysis; if the engine is not in operation when the results of the analysis are received, the engine owner or operator must change the oil within 2 business days or before commencing operation, whichever is later. The owner or operator must keep records of the parameters that are analyzed as part of the program, the results of the analysis, and the oil changes for the engine. The analysis program must be part of the maintenance plan for the engine. (§63.6625(i)) Continuous Compliance Requirements 11.8.9 You must demonstrate continuous compliance with each emission limitation, operating limitation, and other requirements in Table 2c to Subpart ZZZZ (Condition 11.8.2) that apply to you according to methods specified in Table 6 to Subpart ZZZZ. (§63.6640(a)) The continuous compliance requirements in Table 6 to Subpart ZZZZ that apply to this engine are as follows: 11.8.9.1 You must operate and maintain the stationary RICE according to the manufacturer's emission-related operation and maintenance instructions (Table 6 to Subpart ZZZZ, Item 9.a.i); or 1 L8.9.2 Develop and follow your own maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions. (Table 6 to Subpart ZZZZ,Item 9.a.ii) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 155 11.8.10 You must also report each instance in which you did not meet the requirements in Table 8 to Subpart ZZZZ that apply to you. (§63.6640(e)) 11.8.11 If you own or operate an emergency stationary RICE,you must operate the emergency stationary RICE according to the requirements in paragraphs (f)(1) through (3) of§63.6640 (This Condition 11.8.11). 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 paragraphs (f)(1) through (3) of§63.6640 (This Condition 11.8.11), is prohibited. If you do not operate the engine according to the requirements in paragraphs (f)(1) through (3) of§63.6640 (This Condition 11.8.11), the engine will not be considered an emergency engine under this subpart and must meet all requirements for non-emergency engines. (§63.6640(f)) 11.8.11.1 There is no time limit on the use of emergency stationary RICE in emergency situations. (§63.6640(f)(1)) 11.8.11.2 You may operate your emergency stationary RICE for any combination of the purposes specified in paragraphs (f)(2)(i) through (iii) of§63.6640 (Conditions 11.8.11.2a through 11.8.11.2c) for a maximum of 100 hours per calendar year. Any operation for non-emergency situations as allowed by paragraphs (f)(3) of §63.6640 (Condition 11.8.11.3) counts as part of the 100 hours per calendar year allowed by this paragraph (f)(2) (Condition 11.8.11.2). (§63.6640(f)(2)) 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. (§63.6640(f)(2)(i)) 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. (§63.6640(f)(2)(ii)) 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. (§63.6640(f)(2)(iii)) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 156 11.8.11.3 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 paragraph (f)(2) of§63.6640 (Condition 11.8.11.2). 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. (§63.6640(f)(3)) Recordkeeping 11.8.12 If you own or operate an existing stationary emergency RICE, you must keep records of the maintenance conducted on the stationary RICE in order to demonstrate that you operated and maintained the stationary RICE and after-treatment control device (if any) according to your own maintenance plan. (§63.6655(e) and (e)(2)) 1L8.13 If you own or operate an existing emergency stationary RICE with a site rating of less than or equal to 500 brake HP located at a major source of HAP emissions that does not meet the standards applicable to non-emergency engines, you must keep records of the hours of operation of the engine that is recorded through the non-resettable hour meter. The owner or operator must document how many hours are spent for emergency operation, including what classified the operation as emergency and how many hours are spent for non-emergency operation. If the engine is used for the purposes specified in §63.6640(f)(2)(ii) or(iii) (Condition 11.8.11.2b or 11.8.11.2c), the owner or operator must keep records of the notification of the emergency situation, and the date, start time, and end time of engine operation for these purposes. (§63.6655(f) and (f)(1)) 1L8.14 Your records must be in a form suitable and readily available for expeditious review according to §63.10(b)(1). (§63.6660(a)) 1L8.15 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. (§63.6660(b)) 11.8.16 You must keep each record readily accessible in hard copy or electronic form for at least 5 years after the date of each occurrence, measurement, maintenance, corrective action,report, or record, according to §63.10(b)(1). (§63.6660(c)) General Provisions 11.8.17 Table 8 to Subpart ZZZZ shows which parts of the General Provisions in §§63.1 through 63.15 apply to you. (§63.6665(a)) 11.9 This engine is subject to the requirements in 40 CFR Part 63 Subpart A "General Provisions", as specified in SECTION IV - 11. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 157 12. S014: One (1) Born Natural Gas Fired Hot Oil Heater, 32.0 MMBtu/hr (AIRS point 046) Permit Monitoring Parameter Condition Limitations Number Factor Method Interval NOx 14.2 tons/yr 0.098 lb/MMBtu Recordkeeping 12.1 and Calculation Monthly CO 11.9 tons/yr 0.082 lb/MMBtu 12 month rolling Natural Gas Individual Heater 12.2 270 MMscf/yr Monthly Consumption Fuel Meter ASTM or other Btu Content of 12.3 Division Semi-annually Natural Gas Approved Method Hours of 12.4 Recordkeeping Monthly Operation Not to exceed 20%(state- only) Not to exceed 20%, except Only Natural Opacity 12.5 as provided for below Fuel Restriction Gas is Used as For Certain Operational Fuel Activities—Not to Exceed 30% Only Natural PM 12.6 0.203 lb/MMBtu Fuel Restriction Gas is Used as Fuel 40 CFR 63 12.7 See Condition 12.7 Subpart DDDDD 40 CFR 63 Subpart A— 12.8 See Condition 12.8 General Provisions 40 CFR 60 12.9 See Condition 12.9 Subpart Dc 40 CFR 60 Subpart A— 12.10 See Condition 12.10 General Provisions Colorado Regulation No. 7, 12.11 See Condition 12.11 Part E Process Heater Operation and 12.12 See Condition 12.12 Maintenance Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 158 12.1 Emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO) shall not exceed the limitations listed in Summary Table 12 above (Colorado Construction Permit 97WE0724). Monthly emissions shall be calculated by the end of the subsequent month using the emission factors in Summary Table 12 above, the monthly fuel consumption (required by Condition 12.2), and the Btu content of the natural gas (required by Condition 12.3) in the equation below: tons/mo =jEF (1b/MMBtu)x fuel use (MMscf/mo)x heat content of fuel (MMBtu/MMscf)] 2000 lb/ton Monthly emissions 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. Records of calculations shall be kept in a log to be made available to the Division upon request. 12.2 Natural gas consumption shall not exceed the limitation listed in Summary Table 12 above (Colorado Construction Permit 97WE0724). Natural gas consumption shall be recorded monthly using the existing individual heater fuel meter. Monthly natural gas consumption 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. Records of calculations shall be kept in a log to be made available to the Division upon request. 12.3 The Btu content of the natural gas used to fuel this heater shall be verified semi-annually using the appropriate ASTM Methods or equivalent, if approved in advance by the Division. The Btu content of the natural gas shall be based on the higher heating value of the fuel. Calculations of monthly emissions shall be made using the heat content derived from the most recent required analysis. 12.4 Hours of operation shall be monitored monthly and recorded and maintained to be available to the Division upon request. 12.5 This heater is subject to the following opacity requirements: 12.5.1 [State-only] Visible emissions of any particulate matter shall not exceed 20% opacity (Colorado Regulation No. 6, Part B, Section II.C.3) This opacity requirement applies at all times except during periods of startup, shutdown, and malfunction (40 CFR Part 60, Subpart A, §60.11(c), as adopted by reference in Colorado Regulation No. 6, Part B, Section LA). Note that this opacity requirement is more stringent than the opacity requirement in Condition 12.5.3 except during periods of startup. 12.5.2 Except as provided for in Condition 12.5.3 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section II.A.1). 12.5.3 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 159 start-up, process modifications, or adjustment or occasional cleaning of control equipment 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 opacity requirements of this Condition 12.5 shall be presumed since only natural gas is permitted to be used as fuel in this heater. 12.6 Particulate Matter (PM) emissions shall not exceed the above limitation (Colorado Regulation No. 1, Section III.A.1.b). The numeric PM standard was determined using the design heat input for the heater(32.0 MMBtu/hr) in the following equation: PE = 0.5 x (FI)-°'6 where: PE =particulate standard in lbs/MMBtu FI = fuel input in MMBtu/hr In the absence of credible evidence to the contrary, compliance with the particulate matter emission limit is presumed since only natural gas is permitted to be used as fuel in the heater. 12.7 This heater is 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", as specified in SECTION IV - 8. 12.8 This heater is subject to the requirements in 40 CFR Part 63 Subpart A "General Provisions", as specified in SECTION IV - 11. 12.9 This heater is subject to the requirements in 40 CFR Part 60 Subpart Dc, "Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units", as specified in SECTION IV - 9. 12.10 This heater is subject to the requirements in 40 CFR Part 60 Subpart A, "General Provisions", as specified in SECTION IV - 10. 12.11 This process heater is subject to the requirements of Colorado Regulation No. 7, Part E, "Combustion Equipment and Major Source RACT", including, but not limited to, the following: [The requirements below reflect the current rule language as of the revisions to 5 CCR 1001-9 Colorado Regulation No. 7 published in the Colorado Register on 01/25/2020 and effective on 02/14/2020. However, if revisions to this rule are published at a later date, the owner or operator is subject to the requirements contained in the revised version of Colorado Regulation No. 7.] [Note that the following requirements of Colorado Regulation No. 7, Part E, Sections II.A.6 and ILA.7 apply to specific combustion equipment with uncontrolled actual emissions of NOx equal to or greater than five (S) tons per year, as specified in Part E, Section II.A.6.a, therefore, applicability may vary from year to yeas] Combustion Process Adjustment (Part E, Section ILA.6) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 160 12.11.1 When burning the fuel that provides the majority of the heat input since the last combustion process adjustment and when operating at a firing rate typical of normal operation, the owner or operator must conduct the following inspections and adjustments of boilers and process heaters, as applicable: (II.A.6.b.(i)): 12.11.1.1 Inspect the burner and combustion controls and clean or replace components as necessary. (II.A.6.b.(i)(A)) 12.11.1.2 Inspect the flame pattern and adjust the burner or combustion controls as necessary to optimize the flame pattern. (II.A.6.b.(i)(B)) 12.11.1.3 Inspect the system controlling the air-to-fuel ratio and ensure that it is correctly calibrated and functioning properly. (II.A.6.b.(i)(C)) 12.11.1.4 Measure the concentration in the effluent stream of carbon monoxide and nitrogen oxide in ppm, by volume, before and after the adjustments in Sections II.A.6.b.(i)(A) through (C) (Conditions 12.11.1.1 through 12.11.1.3). Measurements may be taken using a portable analyzer. (II.A.6.b.(i)(D)) 12.11.2 The owner or operator must operate and maintain the process heater consistent with manufacturer's specifications, if available, or good engineering and maintenance practices. (II.A.6.b.(vii)) 12.11.3 The owner or operator of process heaters with uncontrolled actual emissions of NOx equal to or greater than five (5) tons per year that existed at major sources of NOx (greater than or equal to 100 tpy NOx) as of June 3, 2016, must conduct the initial combustion process adjustment by April 1, 2017. An owner or operator may rely on a combustion process adjustment conducted in accordance with applicable requirements and schedule of a New Source Performance Standard in 40 CFR Part 60 (November 17, 2016) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (November 17, 2016) to satisfy the requirement to conduct an initial combustion process adjustment by April 1, 2017. (II.A.6.b.(viii)(A)) 12.11.4 The owner or operator must conduct subsequent combustion process adjustments at least once every twelve (12) months after the initial combustion adjustment, or on the applicable schedule according to Sections II.A.6.c.(i). or II.A.6.c.(ii) (Conditions 12.11.5.1 or 12.11.5.2). (II.A.6.b.(viii)(C)) 12.11.5 As an alternative to the requirements described in Sections II.A.6.b.(i), II.A.6.b.(vii) and II.A.6.b.(viii) (Conditions 12.11.1 through 12.11.4) (II.A.6.c.): 12.11.5.1 The owner or operator may conduct the combustion process adjustment according to the manufacturer recommended procedures and schedule (II.A.6.c.(i)); or 12.11.5.2 The owner or operator of combustion equipment that is subject to and required to conduct a period tune-up or combustion adjustment by the applicable Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 161 requirements of a New Source Performance Standard in 40 CFR Part 60 (December 19, 2019)or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (December 19, 2019) may conduct tune-ups or adjustments according to the schedule and procedures of the applicable requirements of 40 CFR Part 60 (December 19, 2019) or 40 CFR Part 63 (December 19, 2019). (II.A.6.c.(ii)) Recordkeeping (ILA.7) 12.11.6 The following records must be kept for a period of five years and made available to the Division upon request (II.A.7): 12.11.7 For stationary combustion equipment subject to the combustion process adjustment requirements in Section II.A.6 (Conditions 12.11.1 through 12.11.5), the following recordkeeping requirements apply(II.A.7.f.): 12.11.8 The owner or operator must create a record once every calendar year identifying the combustion equipment at the facility subject to Section ILA and including for each combustion equipment (II.A.7.f.(i)): 12.11.8.1 The date of the adjustment(II.A.7.f.(i)(A)); 12.11.8.2 Whether the combustion process adjustment under Sections II.A.6.b.(i) (Condition 12.11.1) was followed, and what procedures were performed (II.A.7.f.(i)(B)); 12.11.8.3 Whether a combustion process adjustment under Sections II.A.6.c.(i) and II.A.6.c.(ii) (Conditions 12.11.5.1 and 12.11.5.2) was followed, what procedures were performed, and what New Source Performance Standard or National Emission Standard for Hazardous Air Pollutants applied, if any (II.A.7.f.(i)(C)); and 12.11.8.4 A description of any corrective action taken. (II.A.7.f.(i)(D)) 12.11.8.5 If the owner or operator conducts the combustion process adjustment according to the manufacturer recommended procedures and schedule and the manufacturer specifies a combustion process adjustment on an operation time schedule, the hours of operation. (II.A.7.f.(i)(E)) 12.11.9 The owner or operator must retain manufacturer recommended procedures, specifications, and maintenance schedule if utilized under II.A.6.c.(i) (Conditions 12.11.5.1) for the life of the equipment. (II.A.7.f.(ii)) 12.11.10 As an alternative to the requirements described in Section II.A.7.f.(i) (Condition 12.11.8), the owner or operator may comply with applicable recordkeeping requirements related to combustion process adjustments conducted according to a New Source Performance Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 162 Standard in 40 CFR Part 60 (November 17, 2016) or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (November 17, 2016). (II.A.7.f.(iii)) Note: 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. (Section VI Condition 22.b) 12.12 This process heater shall be operated and maintained in accordance with internal operating and maintenance standards, which shall consider manufacturer's recommendations and good air pollution control practices for minimizing emission, at all times, including periods of start-up, shut-down and malfunction. These internal operating and maintenance standards shall be kept on site and made available to the Division upon request. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 163 SECTION IV - Provisions Common to Multiple Units 1. Portable Monitoring (version 6/26/2014) 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.gov,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. 2. MACT HH Leaks Exemption/Reporting Requirements: F001 and 5007 2.1 These sources of fugitive emissions from equipment leaks are subject to the requirements in 40 CFR 63 Subpart HH, "National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities", as adopted by reference in Colorado Regulation No. 8, Part E, Section III, including, but not limited to, the following: Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 164 [The requirements below reflect the current rule language as of the revisions to 40 CFR Part 63 Subpart HH published in the Federal Register on 8/16/2012. 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 63 Subpart HH.] Equipment Leak Standards 2.1.1 This section does not apply to ancillary equipment and compressors for which the owner or operator is subject to and controlled under the requirements specified in subpart H of this part; or is subject to and controlled under the requirements specified in 40 CFR part 60, subpart OOOO. Ancillary equipment and compressors subject to and controlled under 40 CFR part 60, subpart OOOO shall submit the periodic reports specified in §63.775(e). (§63.769(b)) Reporting Requirements 2.1.2 Periodic Reports. An owner or operator of a major source shall prepare Periodic Reports in accordance with paragraphs (e) (1) and (2) of this section (Conditions 2.1.2.1 and 2.1.2.2) and submit them to the Administrator. (§63.775(e)) 2.1.2.1 An owner or operator shall submit Periodic Reports semiannually beginning 60 calendar days after the end of the applicable reporting period. The first report shall be submitted no later than 240 days after the date the Notification of Compliance Status Report is due and shall cover the 6-month period beginning on the date the Notification of Compliance Status Report is due. (§63.775(e)(1)) 2.1.2.2 The owner or operator shall include the information specified in paragraphs (e)(2)(i) through (ix) of this section (Condition 4.1.2.2a), as applicable. (§63.775(e)(2)) a. For each owner or operator subject to the provisions specified in §63.769, the owner or operator shall comply with the reporting requirements specified in 40 CFR 61.247, except that the Periodic Reports shall be submitted on the schedule specified in paragraph (e)(1) of this section (Condition 2.1.2.1). (§63.775(e)(2)(iv)) 3. NSPS OOOOa: F001 and S007 3.1 These sources of fugitive emissions from equipment leaks are subject to the requirements in 40 CFR 60 Subpart OOOOa, "Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After September 18, 2015", including, but not limited to, the following: [Kerr-McGee has as indicated in the response to information request received on October 18, 2019 and the notification of applicability as received by the Division on May 1, 2019 that these facilities are voluntarily complying with the requirements of NSPS OOOOa. The requirements below have been Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 165 included in this operating permit according to the combined construction/operating permit provisions of Colorado Regulation No. 3, Part C, Section III.B.7, as well as the provisions of Regulation No. 3, Part B, Section III.E, and Section I, Condition 1.3 of this permit. The citations below are included to reference requirements related to equipment leak provisions as effected in this operating permit issuance, and do not indicate federal rule applicability as specified in the provisions of 40 CFR 60 Subpart OOOOa.] 3.1.1 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall 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. The provisions for exemption from compliance during periods of startup, shutdown and malfunctions provided for in 40 CFR 60.8(c) do not apply to this subpart. (§60.5370a(b)) Equipment Leak Standards at Onshore Natural Gas Processing Plants 3.1.2 This section applies to the group of all equipment, except compressors, within a process unit. (§60.5400a) 3.1.3 You must comply with the requirements of§§60.482-1a(a), (b), and (d), 60.482-2a, and 60.482-4a through 60.482-11a, except as provided in §60.5401a. (Conditions 3.1.8 through 3.1.16). (§60.5400a(a)) 3.1.4 You may elect to comply with the requirements of§§60.483-1a and 60.483-2a, as an alternative. (§60.5400a(b)) 3.1.5 You must comply with the provisions of§60.485a except as provided in paragraph (f) of this section. (Condition 3.1.7). (§60.5400a(d)) 3.1.6 You must comply with the provisions of§§60.486a and 60.487a except as provided in §§60.5401a (Conditions 3.1.8 through 3.1.16), 60.5421a(Conditions 3.1.19 through 3.1.20), and 60.5422a, (Conditions 3.1.21 through 3.1.23) of this part. (§60.5400a(e)) 3.1.7 You must use the following provision instead of§60.485a(d)(1): Each piece of equipment is presumed to be in VOC service or in wet gas service unless an owner or operator demonstrates that the piece of equipment is not in VOC service or in wet gas service. For a piece of equipment to be considered not in VOC service, it must be determined that the VOC content can be reasonably expected never to exceed 10.0 percent by weight. For a piece of equipment to be considered in wet gas service, it must be determined that it contains or contacts the field gas before the extraction step in the process. For purposes of determining the percent VOC content of the process fluid that is contained in or contacts a piece of equipment, procedures that conform to the methods described in ASTM E169-93, E168-92, or E260-96 (incorporated by reference as specified in §60.17) must be used. (§60.5400a(f)) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 166 Exceptions to Equipment Leak Standards 3.1.8 You may comply with the following exceptions to the provisions of§60.5400a(a) and (b). (Conditions 3.1.3 and 3.1.4). (§60.5401a(a)) 3.1.9 Each pressure relief device in gas/vapor service may be monitored quarterly and within 5 days after each pressure release to detect leaks by the methods specified in §60.485a(b) except as provided in §§60.5400a(c) and in paragraph (b)(4) of this section (Condition 3.1.13), and §60.482-4a(a) through (c) of subpart VVa. (§60.5401a(b)(1)) 3.1.10 If an instrument reading of 500 ppm or greater is measured, a leak is detected. (§60.5401 a(b)(2)) 3.1.11 When a leak is detected, it must be repaired as soon as practicable, but no later than 15 calendar days after it is detected, except as provided in §60.482-9a. (§60.5401a(b)(3)(i)) 3.1.12 A first attempt at repair must be made no later than 5 calendar days after each leak is detected. (§60.5401 a(b)(3)(ii)) 3.1.13 Any pressure relief device that is located in a nonfractionating plant that is monitored only by non-plant personnel may be monitored after a pressure release the next time the monitoring personnel are onsite, instead of within 5 days as specified in paragraph (b)(1) of this section (Condition 3.1.9) and §60.482-4a(b)(1). (§60.5401a(b)(4)(i)) 3.1.13.1 No pressure relief device described in paragraph (b)(4)(i) of this section (Condition 3.1.13) must be allowed to operate for more than 30 days after a pressure release without monitoring. (§60.5401a(b)(4)(ii)) 3.1.14 Sampling connection systems are exempt from the requirements of§60.482-5a. (§60.5401a(c)) 3.1.15 An owner or operator may use the following provisions instead of§60.485a(e) (§60.5401a(f)): 3.1.15.1 Equipment is in heavy liquid service if the weight percent evaporated is 10 percent or less at 150 °Celsius (302 °Fahrenheit) as determined by ASTM Method D86-96 (incorporated by reference as specified in §60.17). (§60.5401a(f)(1)) 3.1.15.2 Equipment is in light liquid service if the weight percent evaporated is greater than 10 percent at 150 °Celsius (302 °Fahrenheit) as determined by ASTM Method D86-96 (incorporated by reference as specified in §60.17). (§60.5401 a(f)(2)) 3.1.16 An owner or operator may use the following provisions instead of§60.485a(b)(2): A calibration drift assessment shall be performed, at a minimum, at the end of each monitoring day. Check the instrument using the same calibration gas(es) that were used to calibrate the Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 167 instrument before use. Follow the procedures specified in Method 21 of appendix A-7 of this part, Section 10.1, except do not adjust the meter readout to correspond to the calibration gas value. Record the instrument reading for each scale used as specified in §60.486a(e)(8). Divide these readings by the initial calibration values for each scale and multiply by 100 to express the calibration drift as a percentage. If any calibration drift assessment shows a negative drift of more than 10 percent from the initial calibration value, then all equipment monitored since the last calibration with instrument readings below the appropriate leak definition and above the leak definition multiplied by (100 minus the percent of negative drift/divided by 100) must be re-monitored. If any calibration drift assessment shows a positive drift of more than 10 percent from the initial calibration value, then, at the owner/operator's discretion, all equipment since the last calibration with instrument readings above the appropriate leak definition and below the leak definition multiplied by(100 plus the percent of positive drift/divided by 100) may be re-monitored. (§60.5401 a(g)) Initial Compliance 3.1.17 For affected facilities at onshore natural gas processing plants, initial compliance with the methane and VOC standards is demonstrated if you are in compliance with the requirements of§60.5400a(Conditions 3.1.3 through 3.1.7). (§60.5410a(f)) Continuous Compliance 3.1.18 For affected facilities at onshore natural gas processing plants, continuous compliance with methane and VOC requirements is demonstrated if you are in compliance with the requirements of§60.5400a. (Conditions 3.1.3 through 3.1.7). (§60.5415a(f)) Additional Recordkeeping Requirements 3.1.19 You must comply with the requirements of paragraph (b) of this section (Condition 3.1.20) in addition to the requirements of§60.486a. (§60.5421a(a)) 3.1.20 The following recordkeeping requirements apply to pressure relief devices subject to the requirements of§60.5401a(b)(1) (Condition 3.1.9). (§60.5421a(b)) 3.1.20.1 When each leak is detected as specified in §60.5401a(b)(2) (Condition 3.1.10), a weatherproof and readily visible identification, marked with the equipment identification number, must be attached to the leaking equipment. The identification on the pressure relief device may be removed after it has been repaired. (§60.5421a(b)(1)) 3.1.20.2 When each leak is detected as specified in §60.5401a(b)(2) (Condition 3.1.10), the information specified in paragraphs (b)(2)(i) through (x) (Conditions 3.1.20.2 a through j) of this section must be recorded in a log and shall be kept in a readily accessible location (§60.5421a(b)(2)): Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 168 a. The instrument and operator identification numbers and the equipment identification number. (§60.5421a(b)(2)(i)) b. The date the leak was detected and the dates of each attempt to repair the leak. (§60.5421 a(b)(2)(ii)) c. Repair methods applied in each attempt to repair the leak. (§60.5421 a(b)(2)(iii)) d. "Above 500 ppm" if the maximum instrument reading measured by the methods specified in §60.5400a(d) (Condition 3.1.5) after each repair attempt is 500 ppm or greater. (§60.5421a(b)(2)(iv)) e. "Repair delayed" and the reason for the delay if a leak is not repaired within 15 calendar days after discovery of the leak. (§60.5421a(b)(2)(v)) f. The signature of the owner or operator (or designate) whose decision it was that repair could not be effected without a process shutdown. (§60.5421a(b)(2)(vi)) g. The expected date of successful repair of the leak if a leak is not repaired within 15 days. (§60.5421a(b)(2)(vii)) h. Dates of process unit shutdowns that occur while the equipment is unrepaired. (§60.5421 a(b)(2)(viii)) i. The date of successful repair of the leak. (§60.5421a(b)(2)(ix)) j. A list of identification numbers for equipment that are designated for no detectable emissions under the provisions of§60.482-4a(a). The designation of equipment subject to the provisions of§60.482-4a(a) must be signed by the owner or operator. (§60.5421 a(b)(2)(x)) Additional Reporting Requirements 3.1.21 You must comply with the requirements of paragraphs (b) and (c) of this section (Conditions 3.1.22 and 3.1.23) in addition to the requirements of§60.487a(a), (b), (c)(2)(i) through (iv), and (c)(2)(vii) through (viii). You must submit semiannual reports to the EPA via the Compliance and Emissions Data Reporting Interface (CEDRI). (CEDRI can be accessed through the EPA's Central Data Exchange (CDX) (https://cdx.epa.gov/).) Use the appropriate electronic report in CEDRI for this subpart or an alternate electronic file format consistent with the extensible markup language (XML) schema listed on the CEDRI Web site (https://www3.epa.govittn/chief/cedri/). If the reporting form specific to this subpart is not available in CEDRI at the time that the report is due, submit the report to the Administrator at the appropriate address listed in §60.4. Once the form has been available in CEDRI for at least 90 days, you must begin submitting all subsequent reports via CEDRI. The report must be submitted by the deadline specified in this subpart, regardless of the method in which the report is submitted. (§60.5422a(a)) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 169 3.1.22 An owner or operator must include the following information in the initial semiannual report in addition to the information required in §60.487a(b)(1) through (4): Number of pressure relief devices subject to the requirements of§60.5401a(b) (Conditions 3.1.9 to 3.L13) except for those pressure relief devices designated for no detectable emissions under the provisions of§60.482-4a(a) and those pressure relief devices complying with §60.482-4a(c). (§60.5422a(b)) 3.1.23 An owner or operator must include the information specified in paragraphs (c)(1) and (2) of this section (Conditions 3.1.23.1 and 3..23.2) in all semiannual reports in addition to the information required in §60.487a(c)(2)(i) through (vi) (§60.5422a(c)): 3..23.1 Number of pressure relief devices for which leaks were detected as required in §60.5401a(b)(2) (Condition 3.1.10) (§60.5422a(c)(1)); and 3..23.2 Number of pressure relief devices for which leaks were not repaired as required in §60.5401a(b)(3) (Conditions 3.1.11 and 3.1.12). (§60.5422a(c)(2)) General Provisions 3A.24 Table 3 to this subpart shows which parts of the General Provisions in §§60.1 through 60.19 apply to you. (§60.5425a) 4. MACT ZZZZ for 4SRB RICE > 500 HP: Engines EU-32, EU-34R, and EU-101 4.1 These engines are subject to the requirements in 40 CFR Part 63 Subpart ZZZZ, "National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines", as adopted by reference in Colorado Regulation No. 8, Part E, Section III, 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 ZZZZ published in the Federal Register on 2/27/2014. 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.] Emission and Operating Limitations 4.1.1 If you own or operate an existing, new, or reconstructed spark ignition 4SRB stationary RICE with a site rating of more than 500 brake HP located at a major source of HAP emissions, you must comply with the emission limitations in Table la to this subpart and the operating limitations in Table lb to this subpart which apply to you. (§63.6600(a)) You must comply with the emission limitations in Table la at 100 percent load, plus or minus 10 percent. The emission limitations from Table la to Subpart ZZZZ that apply to these engines are as follows: 4.1.1.1 Reduce formaldehyde emissions by 76 percent or more (Table la, Item 1.a); or Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 170 4.1.L2 Limit the concentration of formaldehyde in the stationary RICE exhaust to 350 ppbvd or less at 15 percent O2 (Table la, Item Lb) Compliance with the numerical emission limitations established in Conditions 4.1.1.1 and 4.1.1.2 is based on the results of testing the average of three 1-hour runs using the testing requirements and procedures in §63.6620 and Table 4 to Subpart ZZZZ. (§63.6600) The operating limitations from Table lb to Subpart ZZZZ that apply to these engines are as follows: 4.1.1.3 Maintain your catalyst so that the pressure drop across the catalyst does not change by more than 2 inches of water at 100 percent load plus or minus 10 percent from the pressure drop across the catalyst measured during the initial performance test(Table lb, Item 1.a); and 4.1.1.4 Maintain the temperature of your stationary RICE exhaust so that the catalyst inlet temperature is greater than or equal to 750 °F and less than or equal to 1250 °F. (Table lb, Item 1.b) The emission and operating limitations above are not applicable during periods of startup. General Compliance Requirements 4.1.2 You must be in compliance with the emission limitations, operating limitations, and other requirements in this subpart that apply to you at all times. (§63.6605(a)) 4.1.3 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. The general duty to minimize emissions does not require you to make any further efforts to reduce emissions if levels required by this standard have been achieved. 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. (§63.6605(b)) Testing and Initial Compliance Requirements 4.1.4 You must conduct subsequent performance tests as specified in Table 3 of Subpart ZZZZ. (§63.6615) As specified in Table 3 of Subpart ZZZZ, performance tests shall be conducted semiannually if you choose to demonstrate compliance with the outlet formaldehyde concentration limit of Condition 4.1.1.2. After you have demonstrated compliance for two consecutive tests, you may reduce the frequency of subsequent performance tests to annually. If the results of any subsequent annual performance test indicate the stationary RICE is not in compliance with the formaldehyde emission limitation, or you deviate from any of your Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 171 operating limitations,you must resume semiannual performance tests. (Table 3 to Subpart ZZZZ, Item 3 and footnote 1) 4.1.5 You must conduct each performance test in Tables 3 and 4 of Subpart ZZZZ that applies to you. (§63.6620(a)) 4.1.6 Each performance test must be conducted according to the applicable requirements specified in Table 4 to Subpart ZZZZ. If you own or operate a non-operational stationary RICE that is subject to performance testing, you do not need to start up the engine solely to conduct the performance test. Owners and operators of a non-operational engine can conduct the performance test when the engine is started up again. The test must be conducted at any load condition within plus or minus 10 percent of 100 percent load for non-emergency 4SRB stationary RICE with a site rating of greater than 500 brake HP located at a major source of HAP emissions. (§63.6620(b) and (b)(1)) 4.1.7 You must conduct three separate test runs for each performance test required in §63.6620, as specified in §63.7(e)(3). Each test run must last at least 1 hour, unless otherwise specified in this subpart. (§63.6620(d)) 4.1.8 The engine percent load during a performance test shall be determined and reported in the notification of compliance status as specified in §63.6620(i). 4.1.9 You must install, maintain and operate a continuous parameter monitoring system (CPMS) to continuously monitor the catalyst inlet temperature in accordance with the requirements in §§63.6625(b)(1) through (b)(6). (§63.6625(b); Table 5 to Subpart ZZZZ, Items 7.a.ii and 9.a.ii). 4.1.10 If you operate a new, reconstructed, or existing stationary engine, you must minimize the engine's time spent at idle during startup and minimize the engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after which time the emission standards applicable to all times other than startup in Conditions 4.1.1.1 and 4.1.1.2 apply. (§63.6625(h)) Continuous Compliance Requirements 4.1.11 Except for monitor malfunctions, associated repairs, required performance evaluations, and required quality assurance or control activities,you must monitor continuously at all times that the stationary RICE is operating. A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions. (§63.6635(b)) 4.1.12 You may not use data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities in data averages and calculations used to report emission or operating levels. You must, however, use all the valid data collected during all other periods. (§63.6635(c)) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 172 4.1.13 You must demonstrate continuous compliance with each emission limitation, operating limitation, and other requirements in Condition 4.1.1 according to methods specified in Table 6 to Subpart ZZZZ. (§63.6640(a)) The continuous compliance methods of Table 6 in Subpart ZZZZ associated with the formaldehyde reduction requirement of Condition 4.1.1.1 are as follows: 4.1.13.1 Collect the catalyst inlet temperature data according to §63.6625(b) (Table 6, Item 4.a.i); and 4.1.13.2 Reduce these data to 4-hour rolling averages (Table 6, Item 4.a.ii); and 4.1.13.3 Maintain the 4-hour rolling averages within the operating limitations for the catalyst inlet temperature (Table 6, Item 4.a.iii); and 4.1.13.4 Measure the pressure drop across the catalyst once per month and demonstrate that the pressure drop across the catalyst is within the operating limitation established during the performance test. (Table 6, Item 4.a.iv) The continuous compliance methods of Table 6 in Subpart ZZZZ associated with the formaldehyde concentration limit of Condition 4.1.1.2 are as follows: 4.1.13.5 Conduct semiannual performance tests for formaldehyde as specified in Condition 4.1.4 to demonstrate that your emissions remain at or below the formaldehyde concentration limit (Table 6, Item 7.a.i); and 4.1.13.6 Collect the catalyst inlet temperature data according to §63.6625(b) (Table 6, Item 7.a.ii); and 4.1.13.7 Reduce these data to 4-hour rolling averages (Table 6, Item 7.a.iii); and 4.1.13.8 Maintain the 4-hour rolling averages within the operating limitations for the catalyst inlet temperature (Table 6, Item 7.a.iv); and 4.1.13.9 Measure the pressure drop across the catalyst once per month and demonstrate that the pressure drop across the catalyst is within the operating limitation established during the performance test. (Table 6, Item 7.a.v) 4.1.14 You must report each instance in which you did not meet each emission limitation or operating limitation in Condition 4.1.1. These instances are deviations from the emission and operating limitations in this subpart. These deviations must be reported according to the requirements in §63.6650 (Conditions 4.1.19 and 4.1.20). If you change your catalyst, you must reestablish the values of the operating parameters measured during the initial performance test. When you reestablish the values of your operating parameters, you must also conduct a performance test to demonstrate that you are meeting the required emission limitation applicable to your stationary RICE. (§63.6640(b)) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 173 4.1.15 You must also report each instance in which you did not meet the requirements in Table 8 to Subpart ZZZZ that apply to you. (§63.6640(e)) Notifications, Reports, and Records 4A.16 You must submit all of the notifications in §§63.7(b) and (c), 63.8(e), (f)(4) and (f)(6), 63.9(b) through (e), and (g) and (h) that apply to you by the dates specified. (§63.6645(a)) 4A.17 If you are required to conduct a performance test, you must submit a Notification of Intent to conduct a performance test at least 60 days before the performance test is scheduled to begin as required in §63.7(b)(1). (§63.6645(g)) 4.1.18 You must submit a Notification of Compliance Status according to §63.9(h)(2)(ii) (§63.6645(h)) 4.1.18.1 For each initial compliance demonstration required in Table 5 to Subpart ZZZZ that includes a performance test conducted according to the requirements in Table 3 to Subpart ZZZZ, you must submit the Notification of Compliance Status, including the performance test results, before the close of business on the 60th day following the completion of the performance test according to §63.10(d)(2). (§63.6645(h)(2)) 4A.19 You must submit compliance reports semiannually according to the requirements of §63.6650(b) (§63.6650(a) and Table 7 to Subpart ZZZZ). The reports must contain the following: 4.1.19.1 The information in §§63.6650(c)(1) through (c)(6) (§63.6650(c)). 4.1.19.2 If there are no deviations from any emission limitations or operating limitations that apply to you, a statement that there were no deviations from the emission limitations or operating limitations during the reporting period. If there were no periods during which the CMS, including CEMS and CPMS, was out-of-control, as specified in §63.8(c)(7), a statement that there were not periods during which the CMS was out-of-control during the reporting period (Table 7 to Subpart ZZZZ, Item 1.a); or 4.1.19.3 If you had a deviation from any emission limitation or operating limitation during the reporting period, the information in §63.6650(d). If there were periods during which the CMS, including CEMS and CPMS, was out-of-control, as specified in §63.8(c)(7), the information in §63.6650(e) (Table 7 to Subpart ZZZZ, Item 1.b); or 4.1.19.4 If you had a malfunction during the reporting period, the information in §63.6650(c)(4). (Table 7 to Subpart ZZZZ, Item 1.c) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 174 4.1.20 Each affected source that has obtained a title V operating permit pursuant to 40 CFR part 70 or 71 must report all deviations as defined in Subpart ZZZZ in the semiannual monitoring report required by 40 CFR 70.6 (a)(3)(iii)(A) or 40 CFR 71.6(a)(3)(iii)(A). (§63.6650(f)) 4.1.21 You must keep the following records (§63.6655(a)): 4.1.21.1 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 that you submitted, according to the requirement in §63.10(b)(2)(xiv). (§63.6655(a)(1)) 4.1.21.2 Records of the occurrence and duration of each malfunction of operation (i.e., process equipment) or the air pollution control and monitoring equipment. (§63.6655(a)(2)) 4.1.2L3 Records of performance tests and performance evaluations as required in §63.10(b)(2)(viii). (§63.6655(a)(3)) 4.1.21.4 Records of all required maintenance performed on the air pollution control and monitoring equipment. (§63.6655(a)(4)) 4.1.2L5 Records of actions taken during periods of malfunction to minimize emissions in accordance with Condition 4.1.3, including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation. (§63.6655(a)(5)) 4.1.21.6 For each Continuous Parameter Monitoring System (CPMS), you must keep the records listed in §63.6655(b). 4.1.21.7 You must keep the records required in Condition 4.1.13 to show continuous compliance with each emission or operating limitation that applies to you. (§63.6655(d)) 4.1.22 Your records must be in a form suitable and readily available for expeditious review according to §63.10(b)(1). (§63.6660(a)) 4.1.23 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. (§63.6660(b)) 4.1.24 You must keep each record readily accessible in hard copy or electronic form for at least 5 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record, according to §63.10(b)(1). (§63.6660(c)) Other Requirements and Information Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 175 4.1.25 Table 8 to Subpart ZZZZ shows which parts of the General Provisions in §§63.1 through 63.15 apply to you. (§63.6665) 5. 1\IACT ZZZZ for new 4SLB > 500 HP: Engines EU-38, EU-39, EU-103, EU-104, S018, and S019 5.1 These engines are subject to the requirements in 40 CFR Part 63 Subpart ZZZZ, "National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines", as adopted by reference in Colorado Regulation No. 8, Part E, Section III, 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 ZZZZ published in the Federal Register on 2/27/2014. 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.] Emission and Operating Limitations 5.1.1 If you own or operate a new or reconstructed 4SLB stationary RICE with a site rating of more than 500 brake HP located at major source of HAP emissions you must comply with the emission limitations in Table 2a to this subpart and the operating limitations in Table 2b to this subpart which apply to you. (§63.6600(b)) You must comply with the emission limitations in Table 2a at 100 percent load, plus or minus 10 percent. The emission limitations from Table 2a to Subpart ZZZZ that apply to these engines are as follows: 5.1.1.1 Reduce CO emissions by 93 percent or more (Table 2a, Item 2.a); or 5.1.1.2 Limit concentration of formaldehyde in the stationary RICE exhaust to 14 ppmvd or less at 15 percent 02 (Table 2a, Item 2.b) Compliance with the numerical emission limitations established in Conditions 5.1.1.1 and 5.1.1.2 is based on the results of testing the average of three 1-hour runs using the testing requirements and procedures in §63.6620 and Table 4 to Subpart ZZZZ. (§63.6600) The operating limitations from Table 2b to Subpart ZZZZ that apply to these engines are as follows: 5.1.1.3 Maintain your catalyst so that the pressure drop across the catalyst does not change by more than 2 inches of water at 100 percent load plus or minus 10 percent from the pressure drop across the catalyst that was measured during the initial performance test (Table 2b, Item 1.a); and 5.1.1.4 Maintain the temperature of your stationary RICE exhaust so that the catalyst inlet temperature is greater than or equal to 450 °F and less than or equal to 1350 °F (Table 2b, Item 1.b) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 176 The emission and operating limitations above are not applicable during periods of startup. General Compliance Requirements 5.1.2 You must be in compliance with the emission limitations, operating limitations, and other requirements in this subpart that apply to you at all times. (§63.6605(a)) 5.1.3 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. The general duty to minimize emissions does not require you to make any further efforts to reduce emissions if levels required by this standard have been achieved. 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. (§63.6605(b)) Testing and Initial Compliance Requirements 5.1.4 You must conduct subsequent performance tests as specified in Table 3 of Subpart ZZZZ. (§63.6615) As specified in Table 3 of Subpart ZZZZ, performance tests shall be conducted semiannually whether you choose to demonstrate compliance with the CO reduction limit of Condition 5.1.1.1 or the outlet formaldehyde concentration limit of Condition 5.1.1.2. After you have demonstrated compliance for two consecutive tests, you may reduce the frequency of subsequent performance tests to annually. If the results of any subsequent annual performance test indicate the stationary RICE is not in compliance with the CO or formaldehyde emission limitation, or you deviate from any of your operating limitations, you must resume semiannual performance tests. (Table 3 to Subpart ZZZZ, Items 1 and 3 and footnote 1) 5.1.5 You must conduct each performance test in Tables 3 and 4 of this subpart that applies to you. (§63.6620(a)) 5.1.6 Each performance test must be conducted according to the applicable requirements specified in Table 4 to subpart ZZZZ. If you own or operate a non-operational stationary RICE that is subject to performance testing, you do not need to start up the engine solely to conduct the performance test. Owners and operators of a non-operational engine can conduct the performance test when the engine is started up again. The test must be conducted at any load condition within plus or minus 10 percent of 100 percent load for new non-emergency 4SLB stationary RICE with a site rating of greater than or equal to 250 brake HP located at a major source of HAP emissions. (§63.6620(b) and (b)(2)) 5.1.7 You must conduct three separate test runs for each performance test required in §63.6620, as specified in §63.7(e)(3). Each test run must last at least 1 hour, unless otherwise specified in this subpart. (§63.6620(d)) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 177 5.1.8 The engine percent load during a performance test shall be determined and reported in the notification of compliance status as specified in §63.6620(i). 5.1.9 You must install, maintain and operate a continuous parameter monitoring system (CPMS) to continuously monitor the catalyst inlet temperature in accordance with the requirements in §§63.6625(b)(1) through (b)(6). (§63.6625(b); Table 5 to Subpart ZZZZ, Items 1.a.ii and 9.a.ii). 5.1.10 If you operate a new, reconstructed, or existing stationary engine, you must minimize the engine's time spent at idle during startup and minimize the engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after which time the emission standards applicable to all times other than startup in Conditions 5.1.1.1 and 5.1.1.2 apply. (§63.6625(h)) Continuous Compliance Requirements 5.1.11 Except for monitor malfunctions, associated repairs, required performance evaluations, and required quality assurance or control activities,you must monitor continuously at all times that the stationary RICE is operating. A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions. (§63.6635(b)) 5.1.12 You may not use data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities in data averages and calculations used to report emission or operating levels. You must, however, use all the valid data collected during all other periods. (§63.6635(c)) 5.1.13 You must demonstrate continuous compliance with each emission limitation, operating limitation, and other requirements in Condition 5.1.1 according to methods specified in Table 6 to Subpart ZZZZ. (§63.6640(a)) The continuous compliance methods of Table 6 in Subpart ZZZZ associated with the CO reduction requirement of Condition 5.1.1.1 are as follows: 5.1.13.1 Conduct semiannual performance tests for CO as specified in Condition 5.1.4 to demonstrate that the required CO percent reduction is achieved (Table 6, Item 1.a.i); and 5.1.13.2 Collect the catalyst inlet temperature data according to §63.6625(b) (Table 6, Item 1.a.ii); and 5.1.13.3 Reduce these data to 4-hour rolling averages (Table 6, Item 1.a.iii); and 5.1.13.4 Maintain the 4-hour rolling averages within the operating limitations for the catalyst inlet temperature (Table 6,Item 1.a.iv); and Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 178 5.1.13.5 Measure the pressure drop across the catalyst once per month and demonstrate that the pressure drop across the catalyst is within the operating limitation established during the performance test. (Table 6, Item 1.a.v) The continuous compliance methods of Table 6 in Subpart ZZZZ associated with the formaldehyde concentration limit of Condition 5.1.1.2 are as follows: 5.1.13.6 Conduct semiannual performance tests for formaldehyde as specified in Condition 5.1.4 to demonstrate that your emissions remain at or below the formaldehyde concentration limit (Table 6, Item 7.a.i); and 5.1.13.7 Collect the catalyst inlet temperature data according to §63.6625(b) (Table 6, Item 7.a.ii); and 5.1.13.8 Reduce these data to 4-hour rolling averages (Table 6, Item 7.a.iii); and 5.1.13.9 Maintain the 4-hour rolling averages within the operating limitations for the catalyst inlet temperature (Table 6, Item 7.a.iv); and 5.1.13.10 Measure the pressure drop across the catalyst once per month and demonstrate that the pressure drop across the catalyst is within the operating limitation established during the performance test. (Table 6, Item 7.a.v) 5.1.14 You must report each instance in which you did not meet each emission limitation or operating limitation in Condition 5.1.1. These instances are deviations from the emission and operating limitations in this subpart. These deviations must be reported according to the requirements in §63.6650 (Conditions 5.1.19 and 5.1.20). If you change your catalyst, you must reestablish the values of the operating parameters measured during the initial performance test. When you reestablish the values of your operating parameters, you must also conduct a performance test to demonstrate that you are meeting the required emission limitation applicable to your stationary RICE. (§63.6640(b)) 5.1.15 You must also report each instance in which you did not meet the requirements in Table 8 to Subpart ZZZZ that apply to you. (§63.6640(e)) Notifications, Reports, and Records 5.1.16 You must submit all of the notifications in §§63.7(b) and (c), 63.8(e), (f)(4) and (f)(6), 63.9(b) through (e), and (g) and (h) that apply to you by the dates specified. (§63.6645(a)) 5.1.17 If you are required to conduct a performance test, you must submit a Notification of Intent to conduct a performance test at least 60 days before the performance test is scheduled to begin as required in §63.7(b)(1). (§63.6645(g)) 5.1.18 You must submit a Notification of Compliance Status according to §63.9(h)(2)(ii) (§63.6645(h)) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 179 5.1.18.1 For each initial compliance demonstration required in Table 5 to Subpart ZZZZ that includes a performance test conducted according to the requirements in Table 3 to Subpart ZZZZ, you must submit the Notification of Compliance Status, including the performance test results, before the close of business on the 60th day following the completion of the performance test according to §63.10(d)(2). (§63.6645(h)(2)) 5.1.19 You must submit compliance reports semiannually according to the requirements of §63.6650(b) (§63.6650(a) and Table 7 to Subpart ZZZZ). The reports must contain the following: 5.1.19.1 The information in §§63.6650(c)(1) through (c)(6) (§63.6650(c)). 5.1.19.2 If there are no deviations from any emission limitations or operating limitations that apply to you, a statement that there were no deviations from the emission limitations or operating limitations during the reporting period. If there were no periods during which the CMS, including CEMS and CPMS, was out-of-control, as specified in §63.8(c)(7), a statement that there were not periods during which the CMS was out-of-control during the reporting period (Table 7 to Subpart ZZZZ, Item 1.a); or 5.1.19.3 If you had a deviation from any emission limitation or operating limitation during the reporting period, the information in §63.6650(d). If there were periods during which the CMS, including CEMS and CPMS, was out-of-control, as specified in §63.8(c)(7), the information in §63.6650(e) (Table 7 to Subpart ZZZZ, Item 1.b); or 5.1.19.4 If you had a malfunction during the reporting period, the information in §63.6650(c)(4). (Table 7 to Subpart ZZZZ, Item 1.c) 5.1.20 Each affected source that has obtained a title V operating permit pursuant to 40 CFR part 70 or 71 must report all deviations as defined in Subpart ZZZZ in the semiannual monitoring report required by 40 CFR 70.6 (a)(3)(iii)(A) or 40 CFR 71.6(a)(3)(iii)(A). (§63.6650(f)) 5.1.21 You must keep the following records (§63.6655(a)): 5.1.21.1 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 that you submitted, according to the requirement in §63.10(b)(2)(xiv). (§63.6655(a)(1)) 5.1.21.2 Records of the occurrence and duration of each malfunction of operation (i.e., process equipment) or the air pollution control and monitoring equipment. (§63.6655(a)(2)) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 180 5.1.21.3 Records of performance tests and performance evaluations as required in §63.10(b)(2)(viii). (§63.6655(a)(3)) 5.1.21.4 Records of all required maintenance performed on the air pollution control and monitoring equipment. (§63.6655(a)(4)) 5.1.21.5 Records of actions taken during periods of malfunction to minimize emissions in accordance with Condition 5.L3, including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation. (§63.6655(a)(5)) 5.1.2L6 For each Continuous Parameter Monitoring System (CPMS), you must keep the records listed in §63.6655(b). 5.1.2L7 You must keep the records required in Condition 5.1.13 to show continuous compliance with each emission or operating limitation that applies to you. (§63.6655(d)) 5.1.22 Your records must be in a form suitable and readily available for expeditious review according to §63.10(b)(1). (§63.6660(a)) 5.1.23 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. (§63.6660(b)) 5.1.24 You must keep each record readily accessible in hard copy or electronic form for at least 5 years after the date of each occurrence, measurement, maintenance, corrective action,report, or record, according to §63.10(b)(1). (§63.6660(c)) Other Requirements and Information 5.1.25 Table 8 to Subpart ZZZZ shows which parts of the General Provisions in §§63.1 through 63.15 apply to you. (§63.6665) 6. NSPS JJJJ: Engines EU-103 and EU-104 6.1 [Federal-Only] These engines are subject to the requirements in 40 CFR Part 60, Subpart JJJJ, "Standards of Performance for Stationary Spark Ignition Internal Combustion Engines", 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 JJJJ published in the Federal Register on 8/30/2016. 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 JJJJ.] Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 181 [These requirements have not been adopted into Colorado Regulation No. 6, Part A as of the date of this revised permit issuance [DATE], and are therefore not state-enforceable. In the event that these requirements are adopted into Colorado Regulations, they will become state-enforceable.] What emission standards must I meet if I am an owner or operator of a stationary SI internal combustion engine? (60.4233) 6.1.1 Owners and operators of stationary SI ICE with a maximum engine power greater than or equal to 75 KW (100 HP) (except gasoline and rich burn engines that use LPG) must comply with the emission standards in Table 1 to Subpart JJJJ for their stationary SI ICE. (§60.4233(e)) The emission standards in Table 1 to Subpart JJJJ that apply to these engines are as follows: 6.1.1.1 Emissions of NOx shall not exceed 2.0 g/hp-hr or 160 ppmvd in the exhaust gas (at 15% O2) 6.1.1.2 Emissions of CO shall not exceed 4.0 g/hp-hr or 540 ppmvd in the exhaust gas (at 15% O2) 6.1.1.3 Emissions of VOC shall not exceed 1.0 g/hp-hr or 86 ppmvd in the exhaust gas (at 15% O2) Owners and operators of stationary non-certified SI engines may choose to comply with the emission standards in units of either g/HP-hr or ppmvd at 15 percent O2. (Footnote "a" to Table 1 of Subpart JJJJ) Owners and operators of new or reconstructed non-emergency lean burn SI stationary engines with a site rating of greater than or equal to 250 brake HP located at a major source that are meeting the requirements of 40 CFR part 63, subpart ZZZZ, Table 2a(Condition 5.1.1) do not have to comply with the CO emission standards of Table 1 of Subpart JJJJ (Condition 6.1.1.2). (Footnote "b" to Table 1 of Subpart JJJJ) For purposes of this subpart, when calculating emissions of volatile organic compounds, emissions of formaldehyde should not be included. (Footnote "d" to Table 1 of Subpart JJJJ) How long must I meet the emission standards ifI am an owner or operator of a stationary SI internal combustion engine? (60.4234) 6.1.2 Owners and operators of stationary SI ICE must operate and maintain stationary SI ICE that achieve the emission standards as required in Condition 6.1.1 over the entire life of the engine. (§60.4234) What are my compliance requirements if I am an owner or operator of a stationary SI internal combustion engine? (60.4243) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 182 6.1.3 If you are an owner or operator of a stationary SI internal combustion engine and must comply with the emission standards specified in §60.4233(e) (Condition 6.1.1), you must demonstrate compliance according to one of the methods specified in this Condition 6.L3. (§60.4243(b)) 6.1.3.1 Purchasing an engine certified according to procedures specified in Subpart JJJJ, for the same model year and demonstrating compliance according to one of the methods specified in paragraph §60.4243(a) of Subpart JJJJ. (§60.4243(b)(1)) 6.1.3.2 Purchasing a non-certified engine and demonstrating compliance with the emission standards specified in §60.4233(e) (Condition 6.1.1) and according to the requirements specified in §60.4244 (Condition 6.1.5), as applicable, and according to §60.4243(b)(2)(ii) (Condition 6.1.3.2.a) (§60.4243(b)(2)) a. If you are an owner or operator of a stationary SI internal combustion engine greater than 500 HP,you must keep a maintenance plan and records of conducted maintenance and must, to the extent practicable, maintain and operate the engine in a manner consistent with good air pollution control practice for minimizing emissions. In addition, you must conduct an initial performance test and conduct subsequent performance testing every 8,760 hours or 3 years, whichever comes first, thereafter to demonstrate compliance. (§60.4243(b)(2)(ii)) 6.1.4 Owners and operators of stationary SI natural gas fired engines may operate their engines using propane for a maximum of 100 hours per year as an alternative fuel solely during emergency operations, but must keep records of such use. If propane is used for more than 100 hours per year in an engine that is not certified to the emission standards when using propane, the owners and operators are required to conduct a performance test to demonstrate compliance with the emission standards of§60.4233 (Condition 6.1.1). (§60.4243(e)) What test methods and other procedures must I use if I am an owner or operator of a stationary SI internal combustion engine? (60.4244) 6.1.5 Owners and operators of stationary SI ICE who conduct performance tests must follow the procedures in Conditions 6.1.5.1 through 6.1.5.6. (§60.4244) 6.1.5.1 Each performance test must be conducted within 10 percent of 100 percent peak (or the highest achievable) load and according to the requirements in §60.8 and under the specific conditions that are specified by Table 2 to Subpart JJJJ. (§60.4244(a)) 6.1.5.2 You may not conduct performance tests during periods of startup, shutdown, or malfunction, as specified in §60.8(c). If your stationary SI internal combustion engine is non-operational, you do not need to startup the engine solely to conduct a performance test; however, you must conduct the performance test immediately upon startup of the engine. (§60.4244(b)) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 183 6.1.5.3 You must conduct three separate test runs for each performance test required in this section, as specified in §60.8(f). Each test run must be conducted within 10 percent of 100 percent peak (or the highest achievable) load and last at least 1 hour. (§60.4244(c)) 6.1.5.4 To determine compliance with the NOx mass per unit output emission limitation, convert the concentration of NOx in the engine exhaust using Equation 1 of §60.4244(d). (§60.4244(d)) 6.1.5.5 To determine compliance with the CO mass per unit output emission limitation, convert the concentration of CO in the engine exhaust using Equation 2 of §60.4244(e). (§60.4244(e)) 6.1.5.6 For purposes of this subpart, when calculating emissions of VOC, emissions of formaldehyde should not be included. To determine compliance with the VOC mass per unit output emission limitation, convert the concentration of VOC in the engine exhaust using Equation 3 of§60.4244(f). (§60.4244(f)) 6.1.5.7 If the owner/operator chooses to measure VOC emissions using either Method 18 of 40 CFR part 60, appendix A, or Method 320 of 40 CFR part 63, appendix A, then it has the option of correcting the measured VOC emissions to account for the potential differences in measured values between these methods and Method 25A. The results from Method 18 and Method 320 can be corrected for response factor differences using Equations 4 and 5 of§60.4244(g). The corrected VOC concentration can then be placed on a propane basis using Equation 6 of §60.4244(g). (§60.4244(g)) What are my notification, reporting, and recordkeeping requirements if I am an owner or operator of a stationary SI internal combustion engine? (00.4245) 6.1.6 Owners or operators of stationary SI ICE must meet the following notification, reporting and recordkeeping requirements. (§60.4245) 6.1.6.1 Owners and operators of all stationary SI ICE must keep records of the information in Conditions 6.1.6.1.a through 6.1.6.1.d. (§60.4245(a)) a. All notifications submitted to comply with this subpart and all documentation supporting any notification. (§60.4245(a)(1)) b. Maintenance conducted on the engine. (§60.4245(a)(2)) c. If the stationary SI internal combustion engine is a certified engine, documentation from the manufacturer that the engine is certified to meet the emission standards and information as required in 40 CFR parts 90, 1048, 1054, and 1060, as applicable. (§60.4245(a)(3)) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 184 d. If the stationary SI internal combustion engine is not a certified engine, documentation that the engine meets the emission standards. (§60.4245(a)(4)) 6.1.6.2 Owners and operators of stationary SI ICE that are subject to performance testing must submit a copy of each performance test as conducted in §60.4244 within 60 days after the test has been completed. Performance test reports using EPA Method 18, EPA Method 320, or ASTM D6348-03 (incorporated by reference see 40 CFR 60.17) to measure VOC require reporting of all QA/QC data. For Method 18, report results from sections 8.4 and 11.1.1.4; for Method 320, report results from sections 8.6.2, 9.0, and 13.0; and for ASTM D6348-03 report results of all QA/QC procedures in Annexes 1-7. (§60.4245(d)) 7. NSPS IIII— Engine GEN2 7.1 These engines are subject to the requirements in 40 CFR Part 60 Subpart IIII, "Standards of Performance for Stationary Compression Ignition Internal Combustion Engines", as adopted by reference in Colorado Regulation No. 6, Part A, 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 IIII published in the Federal Register on 7/7/2016. 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 HIE] 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 § 60.4211(f)(2)(ii)-(iii) (Conditions 7.1.9.2b and 7.1.9.2c) have no legal effect. Operation of emergency engines is limited to emergency situations specified in 60.4211(f)(1) (Condition 7.1.9.1); maintenance checks and readiness testing for a limited number of hours per year as specified in 60.4211(f)(2)(i) (Condition 7.1.9.2a); and certain non-emergency situations for a limited number of hours per year as specified in 60.4211(f)(3) (Condition 7.1.9.3). 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 in 40 CFR Part 60 Subpart IIII 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. Emission Standards for Owners and Operators 7.1.1 Owners and operators of 2007 model year and later emergency stationary CI ICE with a displacement of less than 30 liters per cylinder that are not fire pump engines must comply with the emission standards for new nonroad CI engines in §60.4202, for all pollutants, for the same model year and maximum engine power for their 2007 model year and later emergency stationary CI ICE. (§60.4205(b)) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 185 7.1.2 The emission standards for new nonroad CI engines in §60.4202 are as follows: 7.1.2.1 Stationary CI internal combustion engine manufacturers must certify their 2007 model year and later emergency stationary CI ICE with a maximum engine power less than or equal to 2,237 KW (3,000 HP) and a displacement of less than 10 liters per cylinder that are not fire pump engines to the emission standards specified in Condition 7.1.2.2. (§60.4202(a)) 7.1.2.2 For engines with a maximum engine power greater than or equal to 37 KW (50 HP), the certification emission standards for new nonroad CI engines for the same model year and maximum engine power in 40 CFR 89.112 and 40 CFR 89.113 for all pollutants beginning in model year 2007. (§60.4202(a)(2)) 7.1.2.3 The certification emission standards for new nonroad CI engines in 40 CFR 89.112 are as follows: a. Exhaust emission from nonroad engines to which this subpart is applicable shall not exceed the applicable exhaust emission standards contained in Table 1, as follows (§89.112(a)): The specific emissions limitations in Table 1 of 40 CFR 89.112 are as follows: Rated Power kW>560 Model Year 2006 and later Tier 2 Emission Standards (g/kW-hr) NMHC+NOx CO PM 6.4 3.5 0.20 7.1.3 Owners and operators of stationary CI ICE must operate and maintain stationary CI ICE that achieve the emission standards as required in Condition 7.1.2.3 over the entire life of the engine. (§60.4206) Fuel Requirements for Owners and Operators 7.1.4 Beginning October 1, 2010, owners and operators of stationary CI ICE subject to this subpart with a displacement of less than 30 liters per cylinder that use diesel fuel must use diesel fuel that meets the requirements of 40 CFR 80.510(b) for nonroad diesel fuel, except that any existing diesel fuel purchased (or otherwise obtained) prior to October 1, 2010, may be used until depleted. (§60.4207(b)) The fuel requirements for nonroad diesel fuel listed in 40 CFR 80.510(b) are as follows: 7.1.4.1 Sulfur content of 15 ppm maximum (80.510(b)(1)(i)) 7.1.4.2 A minimum cetane index of 40 or maximum aromatic content of 35 volume percent (80.510(b)(2)(i), (ii)) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 186 Compliance with the above fuel use limitations shall be demonstrated by maintaining records from the vendor indicating the diesel fuel purchased for use in the engine has been tested according to the appropriate ASTM methods, and meets the sulfur content and cetane index/aromatic content as described. Other Requirements for Owners and Operators 7.1.5 If you are an owner or operator of an emergency stationary CI internal combustion engine that does not meet the standards applicable to non-emergency engines, you must install a non-resettable hour meter prior to startup of the engine. (§60.4209(a)) 7.1.6 If you are an owner or operator of a stationary CI internal combustion engine equipped with a diesel particulate filter to comply with the emission standards in §60.4204, the diesel particulate filter must be installed with a backpressure monitor that notifies the owner or operator when the high backpressure limit of the engine is approached. (§60.4209(b)) Compliance Requirements 7.1.7 If you are an owner or operator and must comply with the emission standards specified in this subpart, you must do all of the following, except as permitted under Condition 7.1.10 (§60.4211(a)): 7.1.7.1 Operate and maintain the stationary CI internal combustion engine and control device according to the manufacturer's emission-related written instructions (§60.4211(a)(1)); 7.1.7.2 Change only those emission-related settings that are permitted by the manufacturer (§60.4211(a)(2)); and 7.1.7.3 Meet the requirements of 40 CFR parts 89, 94 and/or 1068, as they apply to you. (§60.4211(a)(3)) 7.1.8 If you are an owner or operator of a 2007 model year and later stationary CI internal combustion engine and must comply with the emission standards specified in §60.4205(b), you must comply by purchasing an engine certified to the emission standards in §60.4205(b) for the same model year and maximum engine power. The engine must be installed and configured according to the manufacturer's emission-related specifications, except as permitted in Condition 7.1.10. (§60.4211(c)) 7.1.9 If you own or operate an emergency stationary ICE, you must operate the emergency stationary ICE according to the requirements in Conditions 7.1.9.1 through 7A.9.3. In order for the engine to be considered an emergency stationary ICE 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 Conditions 7.1.9.1 through 7.1.9.3, is prohibited. If you do not operate the engine according to the requirements in Conditions 7.1.9.1 through 7.1.9.3, the engine will not be considered Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 187 an emergency engine under this subpart and must meet all requirements for non-emergency engines. (§60.4211(f)) 7.1.9.1 There is no time limit on the use of emergency stationary ICE in emergency situations. (§60.4211(f)(1)) 7.1.9.2 You may operate your emergency stationary ICE for any combination of the purposes specified in Conditions 7.1.9.2.a through 7.1.9.2.c for a maximum of 100 hours per calendar year. Any operation for non-emergency situations as allowed by Condition 7.1.9.3 counts as part of the 100 hours per calendar year allowed by this Condition 7.1.9.2. (§60.4211(f)(2)) a. Emergency stationary ICE 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 ICE beyond 100 hours per calendar year. (§60.4211(f)(2)(i)) b. Emergency stationary ICE 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 §60.17), 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. (§60.4211(f)(2)(ii)) c. Emergency stationary ICE may be operated for periods where there is a deviation of voltage or frequency of 5 percent or greater below standard voltage or frequency. (§60.4211(f)(2)(iii)) 7.1.9.3 Emergency stationary ICE 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 7.1.9.2. Except as provided in Condition 7.1.9.3.a, the 50 hours per calendar year for non- emergency situations cannot be used for peak shaving or non-emergency demand response, or to generate income for a facility to an electric grid or otherwise supply power as part of a financial arrangement with another entity. (§60.4211(f)(3)) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 188 a. The 50 hours per year for non-emergency situations can be used to supply power as part of a financial arrangement with another entity if all of the following conditions are met (§60.4211(f)(3)(i)): (i) The engine is dispatched by the local balancing authority or local transmission and distribution system operator (§60.4211(f)(3)(i)(A)); (ii) The dispatch is intended to mitigate local transmission and/or distribution limitations so as to avert potential voltage collapse or line overloads that could lead to the interruption of power supply in a local area or region. (§60.4211(f)(3)(i)(B)); (iii) The dispatch follows reliability, emergency operation or similar protocols that follow specific NERC,regional, state, public utility commission or local standards or guidelines. (§60.4211(f)(3)(i)(C)); (iv) The power is provided only to the facility itself or to support the local transmission and distribution system. (§60.4211(f)(3)(i)(D)); (v) The owner or operator identifies and records the entity that dispatches the engine and the specific NERC, regional, state, public utility commission or local standards or guidelines that are being followed for dispatching the engine. The local balancing authority or local transmission and distribution system operator may keep these records on behalf of the engine owner or operator. (§60.4211(f)(3)(i)(E)); 7.1.10 If you do not install, configure, operate, and maintain your engine and control device according to the manufacturer's emission-related written instructions, or you change emission-related settings in a way that is not permitted by the manufacturer, you must demonstrate compliance according to §60.4211(g)(3). (§60.4211(g)) Notification, Reports, and Records for Owners and Operators 7.1.11 If the stationary CI internal combustion engine is an emergency stationary internal combustion engine, the owner or operator is not required to submit an initial notification. (§60.4214(b)) General Provisions 7.1.12 Table 8 to this subpart shows which parts of the General Provisions in §§60.1 through 60.19 apply to you. (§60.4218) 8. MACT DDDDD - S013 (point 045), S014 (point 046), various insignificant heaters In addition to the heaters referenced in specific conditions of this Section II, the following insignificant heaters are subject to the requirements of MACT DDDDD: Facility ID Description Heat Rate(MMBtu/hr) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 189 H-ST2 Condensate Stabilizer heater 5.0 H-ST3 Condensate Stabilizer heater 5.0 H-ST4 Condensate Stabilizer heater 5.0 H-178 De-Ethanizer Reboiler heater 4.5 H-551 ST-1 Condensate Stabilizer 3.5 H-820 ST-1 Bath Heater 2.0 H-101 Process Regen Heater 1.09 H-420 Process Regen Heater 3.17 H-4400 NGL Regen Heater 1.79 HX-290 Stabilization Heater 1.2 8.1 These process heaters are subject to the requirements in 40 CFR 63 Subpart DDDDD, "National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters", as adopted by reference in Colorado Regulation No. 8, Part E, Section III, 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 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? 063.7495) 8.1.1 If you have a new or reconstructed boiler or process heater, you must comply with this subpart by April 1, 2013, or upon startup of your boiler or process heater, whichever is later. (§63.7495(a)) 8.1.2 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 §63.6(i). (§63.7495(b)) 8.1.3 You must meet the notification requirements in Conditions 8.1.15 through 8.1.18 (§63.7545) according to the schedule in Conditions 8.1.15 through 8.1.18 (§63.7545) 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? (O3.7500) 8.1.4 You must meet the requirements in Condition 8.1.4.1 and 8.1.4.2, except as provided for in Condition 8.1.4.3. You must meet these requirements at all times the affected unit is operating. (§63.7500(a)) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 190 8.1.4.1 You must meet each emission limit and work practice standard in Tables 1 through 3, and 11 through 13 of Subpart DDDDD that applies to your boiler or process heater, for each boiler or process heater at your source. (§63.7500(a)(1)) 8.1.4.2 At all times, you must operate and maintain any affected source (as defined in §63.7490), 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)) 8.1.4.3 Boilers and process heaters in the units designed to burn gas 1 fuels subcategory with a heat input capacity of less than or equal to 5 million Btu per hour must complete a tune-up every 5 years as specified in Condition 8.1.14 (§63.7540). Boilers and process heaters in the units designed to burn gas 1 fuels subcategory with a heat input capacity greater than 5 million Btu per hour and less than 10 million Btu per hour must complete a tune-up every 2 years as specified in Condition 8.1.14 (§63.7540). Boilers and process heaters in the units designed to burn gas 1 fuels subcategory are not subject to the emission limits in Tables 1 and 2 or 11 through 13 of Subpart DDDDD, or the operating limits in Table 4 of Subpart DDDDD. (§63.7500(e)) The work practice standards in Table 3 of Subpart DDDDD that apply to these heaters are as follows: 8.1.4.4 For a new or existing boiler or process heater with a continuous oxygen trim system that maintains an optimum air to fuel ratio, or a heat input capacity of less than or equal to 5 million Btu per hour, in the unit designed to burn gas 1 subcategory, or a limited use boiler or process heater, you must conduct a tune-up of the boiler or process heater every 5 years as specified in Condition 8.1.14 (§63.7540). (40 CFR 63 Subpart DDDDD, Table 3, Item 1) 8.1.4.5 For a new or existing boiler or process heater with heat input capacity of less than 10 million Btu per hour, but greater than 5 million Btu per hour, in the unit designed to burn gas 1 subcategory, you must conduct a tune-up of the boiler or process heater biennially as specified in Condition 8.1.14 (§63.7540). (40 CFR 63 Subpart DDDDD, Table 3, Item 2) 8.1.4.6 For 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, you must conduct a tune-up of the boiler or process heater annually as specified in Condition 8.1.14 (§63.7540). (40 CFR 63 Subpart DDDDD, Table 3, Item 3) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 191 8.1.4.7 For an existing boiler or process heater located at a major source facility, not including limited use units, you must have a one-time energy assessment performed by a qualified energy assessor. An energy assessment completed on or after January 1, 2008, that meets or is amended to meet the energy assessment requirements in this Condition 8.L4.7 (Table 3 of 40 CFR Part 63 Subpart DDDDD), satisfies the energy assessment requirement. A facility that operated under an energy management program developed according to the ENERGY STAR guidelines for energy management or compatible with ISO 50001 for at least one year between January 1, 2008 and the compliance date specified in Condition 8.1.1 or 8.1.2 (§63.7495) that includes the affected units also satisfies the energy assessment requirement. The energy assessment must include the following with extent of the evaluation for items a. to e. appropriate for the on-site technical hours listed in the Definition of Energy Assessment in §63.7575 (40 CFR 63 Subpart DDDDD, Table 3, Item 4): a. A visual inspection of the boiler or process heater system. b. An evaluation of operating characteristics of the boiler or process heater systems, specifications of energy using systems, operating and maintenance procedures, and unusual operating constraints. c. An inventory of major energy use systems consuming energy from affected boilers and process heaters and which are under the control of the boiler/process heater owner/operator. d. A review of available architectural and engineering plans, facility operation and maintenance procedures and logs, and fuel usage. e. A review of the facility's energy management program and provide recommendations for improvements consistent with the definition of energy management program, if identified. f. A list of cost-effective energy conservation measures that are within the facility's control. g. A list of the energy savings potential of the energy conservation measures identified. h. A comprehensive report detailing the ways to improve efficiency, the cost of specific improvements, benefits, and the time frame for recouping those investments. What are my initial compliance requirements and by what date must I conduct them? 063.7510) 8.1.5 For existing affected sources, you must complete an initial tune-up by following the procedures described in Conditions 8.1.14.1a through 8.1.14.1f(§63.7540(a)(10)(i) through (vi)) no later than the compliance date specified in Condition 8.1.2 (§63.7495), except as specified in Condition 8.1.7 (§63.7510(j)). You must complete the one-time energy Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 192 assessment specified in Condition 8.L4.7 (Table 3 to Subpart DDDDD) no later than the compliance date specified in Condition 8.1.2 (§63.7495). (§63.7510(e)) 8.1.6 For new or reconstructed affected sources, you must demonstrate initial compliance with the applicable work practice standards in Conditions 8.1.4.4 through 8.1.4.7 (Table 3 to Subpart DDDDD) within the applicable annual, biennial, or 5-year schedule as specified in Condition 8.1.8 (§63.7515(d)) following the initial compliance date specified in Condition 8.1.1 (§63.7495(a)). Thereafter, you are required to complete the applicable annual, biennial, or 5- year tune-up as specified in Condition 8.1.8 (§63.7515(d)). §(63.7510(g)) 8.1.7 For existing affected sources that have not operated between the effective date of the rule and the compliance date that is specified for your source in Condition 8.1.1 or 8.1.2 (§63.7495), you must complete an initial tune-up by following the procedures described in Conditions 8.1.14.1a through 8.1.14.1f(§63.7540(a)(10)(i) through (vi)) no later than 30 days after the re-start of the affected source and, if applicable, complete the one-time energy assessment specified in Condition 8.1.4.7 (Table 3 to Subpart DDDDD), no later than the compliance date specified in Condition 8.1.1 or 8.1.2 (§63.7495). (§63.7510(j)) When must I conduct subsequent tune-ups? O63.7515) 8.1.8 If you are required to meet an applicable tune-up work practice standard, you must conduct an annual, biennial, or 5-year performance tune-up according to Condition 8.1.14.1, 8.1.14.2, or 8.1.14.3,respectively (§63.7540(a)(10), (11), or(12),respectively). Each annual tune-up specified in Condition 8.1.14.1 (§63.7540(a)(10)) must be no more than 13 months after the previous tune-up. Each biennial tune-up specified in Condition 8.1.14.2 (§63.7540(a)(11)) must be conducted no more than 25 months after the previous tune-up. Each 5-year tune-up specified in Condition 8.1.14.3 (§63.7540(a)(12)) must be conducted no more than 61 months after the previous tune-up. For a new or reconstructed affected source (as defined in §63.7490), the first annual, biennial, or 5-year tune-up must be no later than 13 months, 25 months, or 61 months,respectively, after April 1, 2013 or the initial startup of the new or reconstructed affected source, whichever is later. (§63.7515(d)) 8.1.9 You must complete a subsequent tune-up by following the procedures described in Conditions 8.1.14.1a through 8.1.14.1f(§63.7540(a)(10)(i) through (vi)) and the schedule described in Condition 8.1.14.4 (§63.7540(a)(13)) for units that are not operating at the time of their scheduled tune-up. (§63.7515(g)) What fuel analyses,fuel specification, and procedures must I use? 063.7521) 8.1.10 You are not required to conduct the fuel specification analyses in paragraphs (g) through (i) of 40 CFR §63.7521 for natural gas or refinery gas. (§63.7521(f)(1)) 8.1.11 You are not required to conduct the fuel specification analyses in paragraphs (g) through (i) of 40 CFR §63.7521 for gas streams directly derived from natural gas at natural gas production sites or natural gas plants. (§63.7521(f)(4)) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 193 How do I demonstrate initial compliance with the work practice standards? (O3.7530) 8.1.12 You must include with the Notification of Compliance Status a signed certification that either the energy assessment was completed according to Condition 8.1.4.7 (Table 3 to Subpart DDDDD), and that the assessment is an accurate depiction of your facility at the time of the assessment, or that the maximum number of on-site technical hours specified in the definition of energy assessment applicable to the facility has been expended. (§63.7530(e)) 8.1.13 You must submit the Notification of Compliance Status containing the results of the initial compliance demonstration according to the requirements in Condition 8.1.18 (§63.7545(e)). (§63.7530(f)) How do I demonstrate continuous compliance with the work practice standards? (63.7540) 8.1.14 You must demonstrate continuous compliance with the work practice standards in Conditions 8.1.4.4 through 8.L4.7 (Table 3 to Subpart DDDDD) that apply to you according to the methods specified in Conditions 8.1.14.1 through 8.1.14.4 (§63.7540(a)(10) through (13)) (§63.7540(a)): 8.1.14.1 If your boiler or process heater has a heat input capacity of 10 million Btu per hour or greater, you must conduct an annual tune-up of the boiler or process heater to demonstrate continuous compliance as specified in Conditions 8.1.14.1a through 8.1.14.1f(§63.7540(a)(10)(i) through (vi)). This frequency does not apply to limited-use boilers and process heaters, as defined in 40 CFR §63.7575, or units with continuous oxygen trim systems that maintain an optimum air to fuel ratio. (§63.7540(a)(10)) a. As applicable, inspect the burner, and clean or replace any components of the burner as necessary (you may perform the burner inspection any time prior to the tune-up or delay the burner inspection until the next scheduled unit shutdown). At units where entry into a piece of process equipment or into a storage vessel is required to complete the tune-up inspections, inspections are required only during planned entries into the storage vessel or process equipment (§63.7540(a)(10)(i)); b. Inspect the flame pattern, as applicable, and adjust the burner as necessary to optimize the flame pattern. The adjustment should be consistent with the manufacturer's specifications, if available (§63.7540(a)(10)(ii)); c. Inspect the system controlling the air-to-fuel ratio, as applicable, and ensure that it is correctly calibrated and functioning properly (you may delay the inspection until the next scheduled unit shutdown) (§63.7540(a)(10)(iii)); d. Optimize total emissions of CO. This optimization should be consistent with the manufacturer's specifications, if available, and with any NOx requirement to which the unit is subject(§63.7540(a)(10)(iv)); Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 194 e. Measure the concentrations in the effluent stream of CO in parts per million, by volume, and oxygen in volume percent, before and after the adjustments are made (measurements may be either on a dry or wet basis, as long as it is the same basis before and after the adjustments are made). Measurements may be taken using a portable CO analyzer(§63.7540(a)(10)(v)); and f. Maintain on-site and submit, if requested by the Administrator, a report containing the information in Conditions (i) through (iii) (§63.7540(a)(10)(vi)(A) through (C)). (63.7540(a)(10)(vi)) (i) The concentrations of CO in the effluent stream in parts per million by volume, and oxygen in volume percent, measured at high fire or typical operating load, before and after the tune-up of the boiler or process heater (§63.7540(a)(10)(vi)(A)); (ii) A description of any corrective actions taken as a part of the tune-up (§63.7540(a)(10)(vi)(B)); and (iii) The type and amount of fuel used over the 12 months prior to the tune- up, but only if the unit was physically and legally capable of using more than one type of fuel during that period. Units sharing a fuel meter may estimate the fuel used by each unit. (§63.7540(a)(10)(vi)(C)) 8.1.14.2 If your boiler or process heater has a heat input capacity of less than 10 million Btu per hour (except as specified in Condition 8.1.14.3; §63.7540 (a)(12)), you must conduct a biennial tune-up of the boiler or process heater as specified in Conditions 8.1.14.1a through 8.1.14.1f(§63.7540(a)(10)(i) through (vi)) to demonstrate continuous compliance. (§63.7540(a)(11)) 8.1.14.3 If your boiler or process heater has a continuous oxygen trim system that maintains an optimum air to fuel ratio, or a heat input capacity of less than or equal to 5 million Btu per hour and the unit is in the units designed to burn gas 1 subcategory, or meets the definition of limited-use boiler or process heater in 40 CFR §63.7575, you must conduct a tune-up of the boiler or process heater every 5 years as specified in Conditions 8.1.14.1a through 8.1.14.1f(§63.7540(a)(10)(i) through (vi)) to demonstrate continuous compliance. You may delay the burner inspection specified in Conditions 8.1.14.1a (§63.7540(a)(10)(i)) until the next scheduled or unscheduled unit shutdown, but you must inspect each burner at least once every 72 months. If an oxygen trim system is utilized on a unit without emission standards to reduce the tune-up frequency to once every 5 years, set the oxygen level no lower than the oxygen concentration measured during the most recent tune-up. (§63.7540(a)(12)) 8.1.14.4 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. (§63.7540(a)(13)) Notification, Reports, and Records Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 195 8.1.15 You must submit to the Administrator the initial notification (§639(b)) and the notification of compliance status (§63.9(h)) by the dates specified. (§63.7545(a)) 8.1.16 As specified in 40 CFR §63.9(b)(2), if you startup your affected source before January 31, 2013, you must submit an Initial Notification not later than 120 days after January 31, 2013. (§63.7545(b)) 8.1.17 As specified in 40 CFR §63.9(b)(4) and (5), if you startup your new or reconstructed affected source on or after January 31, 2013, you must submit an Initial Notification not later than 15 days after the actual date of startup of the affected source. (§63.7545(c)) 8.1.18 If you are not required to conduct an initial compliance demonstration as specified in §63.7530(a), the Notification of Compliance Status must only contain the information specified in Condition 8.1.18.1 and 8.1.18.2 (§63.7545 (e)(1) and (8)) and must be submitted within 60 days of the compliance date specified at Condition 8.1.1 (§63.7495(b)). (§63.7545(e)) 8.1.18.1 A description of the affected unit(s) including identification of which subcategories the unit is in, the design heat input capacity of the unit, a description of the add-on controls used on the unit to comply with this subpart, description of the fuel(s) burned, including whether the fuel(s) were a secondary material determined by you or the EPA through a petition process to be a non- waste under §241.3 of this chapter, whether the fuel(s) were a secondary material processed from discarded non-hazardous secondary materials within the meaning of§241.3 of this chapter, and justification for the selection of fuel(s) burned during the compliance demonstration. (§63.7545(e)(1)) 8.1.18.2 In addition to the information required in 40 CFR §63.9(h)(2), your notification of compliance status must include the following certification(s) of compliance, as applicable, and signed by a responsible official (§63.7545(e)(8)): a. "This facility completed the required initial tune-up for all of the boilers and process heaters covered by 40 CFR part 63 subpart DDDDD at this site according to the procedures in §63.7540(a)(10)(i) through (vi)." (§63.7545(e)(8)(i)) b. "This facility has had an energy assessment performed according to §63.7530(e)." (§63.7545(e)(8)(ii)) What reports must I submit and when? (03.7550) 8.1.19 For units that are subject only to a requirement to conduct subsequent annual, biennial, or 5- year tune-up according to Condition 8.1.14.1, 8.1.14.2, or 8.1.14.3, respectively (§63.7540(a)(10), (11), or (12),respectively), and not subject to emission limits or Table 4 operating limits,you may submit an annual, biennial, or 5-year compliance report, as applicable, as specified in Conditions 8.1.19.1 through 8.1.19.4 (§63.7550(b)(1) through (4)), instead of a semi-annual compliance report. (§63.7550(b)) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 196 8.1.19.1 If submitting an annual, biennial, or 5-year compliance report, the first compliance report must cover the period beginning on the compliance date that is specified for each boiler or process heater in §63.7495 (Condition 8.1.1 or 8.1.2) and ending on December 31 within 1, 2, or 5 years, as applicable, after the compliance date that is specified for your source in §63.7495. (§63.7550(b)(1)) 8.1.19.2 The first annual or 5-year compliance report must be postmarked or submitted no later than January 31. (§63.7550(b)(2)) 8.1.19.3 Annual and 5-year compliance reports must cover the applicable 1- or 5-year periods from January 1 to December 31. (§63.7550(b)(3)) 8.1.19.4 Annual and 5-year compliance reports must be postmarked or submitted no later than January 31. (§63.7550(b)(4)) 8.1.19.5 For each affected source that is subject to permitting regulations pursuant to part 70 or part 71 of this chapter, and if the permitting authority has established dates for submitting semiannual reports pursuant to 40 CFR 70.6(a)(3)(iii)(A) or 71.6(a)(3)(iii)(A),you may submit the first and subsequent compliance reports according to the dates the permitting authority has established in the permit instead of according to the dates in Conditions 8.1.19.1 through 8.1.19.4 (§63.7550(b)(1) through (4)). (§63.7550(b)(5)) 8.1.20 A compliance report must contain the following information depending on how the facility chooses to comply with the limits set in this rule. (§63.7550(c)) 8.1.20.1 If the facility is subject to the requirements of a tune up you must submit a compliance report with the information in Conditions 8.1.20.1a through e (§63.7550(c)(5)(i) through (iii), (xiv) and (xvii)), and Condition f (§63.7550(c)(5)(iv)) for limited-use boiler or process heater. (§63.7550(c)(1)) a. Company and Facility name and address. (§63.7550(c)(5)(i)) b. Process unit information, emissions limitations, and operating parameter limitations. (§63.7550(c)(5)(ii)) c. Date of report and beginning and ending dates of the reporting period. (§63.7550(c)(5)(iii)) d. Include the date of the most recent tune-up for each unit subject to only the requirement to conduct an annual, biennial, or 5-year tune-up according to Condition 8.1.14.1, 8.1.14.2, or 8.1.14.3,respectively (§63.7540(a)(10), (11), or(12), respectively). Include the date of the most recent burner inspection if it was not done annually or on a 5-year period and was delayed until the next scheduled or unscheduled unit shutdown. (§63.7550(c)(5)(xiv)) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 197 e. Statement by a responsible official with that official's name, title, and signature, certifying the truth, accuracy, and completeness of the content of the report. (§63.7550(c)(5)(xvii)) f. The total operating time during the reporting period. (§63.7550(c)(5)(iv)) 8.1.21 You must submit the reports according to the procedures specified in Condition 8.1.21.1. (§63.7550(h)) 8.1.21.1 You must submit all reports required by Table 9 of this subpart electronically to the EPA via the CEDRI. (CEDRI can be accessed through the EPA's CDX.) You must use the appropriate electronic report in CEDRI for this subpart. Instead of using the electronic report in CEDRI for this subpart, you may submit an alternate electronic file consistent with the XML schema listed on the CEDRI Web site (http://www.epa.gov/ttn/chief/cedri/index.html), once the XML schema is available. If the reporting form specific to this subpart is not available in CEDRI at the time that the report is due, you must submit the report to the Administrator at the appropriate address listed in §63.13. You must begin submitting reports via CEDRI no later than 90 days after the form becomes available in CEDRI. (§63.7550(h)(3)) What records must I keep? (O3.7555) 8.1.22 You must keep the following records: 8.1.22.1 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)) 8.1.22.2 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)) 8.1.23 Your records must be in a form suitable and readily available for expeditious review, according to §63.10(b)(1). (§63.7560(a)) 8.1.24 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)) 8.1.25 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)) What parts of the General Provisions apply to me? (O3.7565) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 198 8.1.26 Table 10 to this subpart 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: 8.1.26.1 Prohibited activities and circumvention in §63.4. 8.1.26.2 Notification requirements in §63.9. 9. NSPS Subpart Dc — S013 (point 045), S014 (point 046) 9.1 These process heaters are subject to the requirements in 40 CFR 60 Subpart Dc, "Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units" (as adopted by reference in Colorado Regulation No. 6, Part A), including, but not limited to the following requirements: [The requirements below reflect the current rule language as of the revisions to 40 CFR Part 60 Subpart Dc published in the Federal Register on February 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 Dc.] 9.1.1 The owner or operator of an affected facility that combusts only natural gas shall record and maintain records of the amount of fuel combusted during each calendar month. (§60.48c(g) and (g)(2)) 9.1.2 The owner or operator of each affected facility shall submit notification of the date of construction or reconstruction and actual startup, as provided by §60.7 of this part. This notification shall include the items in §60.48c(a)(1) through §60.48c(a)(3), as applicable. (§60.48c(a)) 10. NSPS Subpart A— General Provisions: Fugitive Equipment Leaks F001 and S007; Engines EU- 103 and EU-104; Process heaters S013 and S014; Engines GEN2 and PLV PLC GEN 10.1 The requirements in 40 CFR Part 60 Subpart A "General Provisions" (as adopted by reference in Colorado Regulation No. 6, Part A, Subpart A) apply to those sources which are subject to 40 CFR Part 60 requirements, with respect to those Part 60 requirements. The Subpart A requirements include, but are not limited to, the following: 10.1.1 Written notification of construction and initial startup dates shall be submitted to the Division as required under § 60.7. 10.1.2 The owner or operator shall maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (60.7(b)) 10.1.3 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 Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 199 air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating procedures are being used will be based on information available to the Division which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. (60.11(d)) 10.1.4 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. (60.12) 11. MACT Subpart A — General Provisions: Engines EU-32, EU-34R, EU-38, EU-39, EU-101, EU-103, EU-104, S018, S019, and S022 11.1 The requirements in 40 CFR Part 63 Subpart A "General Provisions" (as adopted by reference in Colorado Regulation No. 8, Part E, Section I) apply to those sources that are subject to 40 CFR Part 63 requirements, with respect to those Part 63 requirements. The Subpart A requirements include, but are not limited to, the following: 11.1.1 Prohibited activities and circumvention in §63.4. 11.1.2 Compliance with standards and maintenance requirements in §63.6. 11.1.3 Performance test requirements in §63.7. 11.1.4 Monitoring requirements in §63.8. 11.1.5 Notification requirements in §63.9. 11.1.6 Recordkeeping and reporting requirements in §63.10. 12. Compliance Assurance Monitoring (CAM) 12.1 The Compliance Assurance Monitoring (CAM) requirements in 40 CFR Part 64, as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV, apply to the following emission units: Point 030 One (1) Waukesha L7042 GSI four stroke rich burn engine with respect to the NOx and CO emission limitations of SECTION II - 3.1. (EU-32) Point 017 One (1) Waukesha L7042 GSI four stroke rich burn engine with respect to the NOx and CO emission limitations of SECTION II - 4.1. (EU-101) Point 025 One (1) Waukesha L7042 GSI four stroke rich burn engine with respect to the NOx and CO emission limitations of SECTION II - 6.1. (EU-34R) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 200 Point 026 — One (1) Caterpillar G3616 TALE four stroke lean burn engine with respect to the CO emission limitation in SECTION II - 7.1. (EU-103) Point 028 — One (1) Caterpillar G3616 TALE four stroke lean burn engine with respect to the CO emission limitation in SECTION II - 8.1. (EU-104) Point 043 — One (1) Natural Gas Liquids Amine Sweetening Unit(15,000 bbl/day capacity) with respect to the VOC emission limitation in SECTION III - 3.2. (S009) Point 073 — One (1) Natural Gasoline Liquids Loadout with respect to the VOC emission limitation in SECTION III - 10.1 (NG-TL-01) 12.1.1 For the rich burn (Waukesha) engines, the permittee shall follow the CAM Plan provided in APPENDIX G of this permit. Excursions, for purposes of reporting, are any time the thermocouple temperature indicates a temperature less than 750° F or greater than 1250° F, or any monthly pressure drop across the catalyst that is not within + 2 inches of water column from the baseline value established by the source during the most recent quarterly portable analyzer test (as required by SECTION II - 3.1.2, SECTION II - 4.L2 and SECTION II - 6.1.2). This baseline pressure drop shall be established by the source during each quarterly portable analyzer test and may be reestablished during any portable analyzer test that demonstrates compliance with the NOx and CO annual emission limitations of the respective engine. For a new, cleaned or reconditioned catalyst, the new pressure drop baseline must be established by the operator within the first 14 days of engine/catalyst operation, during a portable analyzer test(as required by SECTION II - 3.1.2, SECTION II - 4.1.2 and SECTION II - 6.1.2) that demonstrates compliance with the NOx and CO annual emission limitations of the respective engine. Excursions shall be reported as required by Section IV, Conditions 21 and 22.d of this permit. 12.1.2 For the lean burn (Caterpillar) engines, the permittee shall follow the CAM Plan provided in APPENDIX H of this permit. Excursions, for purposes of reporting, are any time the thermocouple temperature indicates a temperature less than 450° F or greater than 1350° F, or any monthly pressure drop across the catalyst that is not within + 2 inches of water column from the baseline value established by the source during the most recent quarterly portable analyzer test(as required by SECTION II - 7.1.2 and SECTION II - 8.1.2). This baseline pressure drop shall be established by the source during each quarterly portable analyzer test and may be reestablished during any portable analyzer test that demonstrates compliance with the CO annual emission limitations of the respective engine. For a new, cleaned or reconditioned catalyst, the new pressure drop baseline must be established by the operator within the first 14 days of engine/catalyst operation, during a portable analyzer test(as required by SECTION II - 7.1.2 and SECTION II - 8.1.2) that demonstrates compliance with the CO annual emission limitations of the respective engine. Excursions shall be reported as required by Section IV, Conditions 21 and 22.d of this permit. 12.1.3 For the natural gas liquids amine unit (point 043), the permittee shall follow the CAM Plan provided in APPENDIX I of this permit. Excursions, for purposes of reporting, are defined Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 201 as any instance for which the combustion chamber temperature of the thermal oxidizer is less than 1400°F, or the temperature established during the most recent stack test demonstrating compliance with permitted limits and approved by the Division. 12.1.4 For the natural gasoline liquids loadout (point 073), the permittee shall follow the CAM Plan provided in APPENDIX J of this permit. Excursions, for purposes of reporting, are defined as any absence of a pilot flame for the ECD during a loadout event. 12.1.5 Operation of Approved Monitoring 12.1.5.1 At all times, the owner or operator shall maintain the monitoring, including but not limited to, maintaining necessary parts for routine repairs of the monitoring equipment (40 CFR Part 64 §64.7(b), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 12.1.5.2 Except for, as applicable, monitoring malfunctions, associated repairs, and required quality assurance or control activities (including, as applicable, calibration checks and required zero and span adjustments), the owner or operator shall conduct all monitoring in continuous operation (or shall collect data at all required intervals) at all times that the pollutant-specific emissions unit is operating. Data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities shall not be used for purposes of these CAM requirements, including data averages and calculations, or fulfilling a minimum data availability requirement, if applicable. The owner or operator shall use all the data collected during all other periods in assessing the operation of the control device and associated control system. A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions (40 CFR Part 64 §64.7(c), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 12.1.5.3 Response to excursions or exceedances a. Upon detecting an excursion or exceedance, the owner or operator shall restore operation of the pollutant-specific emissions unit (including the control device and associated capture system) to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. The response shall include minimizing the period of any startup, shutdown or malfunction and taking any necessary corrective actions to restore normal operation and prevent the likely recurrence of the cause of an excursion or exceedance (other than those caused by excused startup or shutdown conditions). Such actions may include initial inspection and evaluation, recording that operations returned to normal without operator action (such as through response by a computerized distribution control system), or any necessary follow-up actions to return Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 202 operation to within the indicator range, designated condition, or below the applicable emission limitation or standard, as applicable (40 CFR Part 64 §64.7(d)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). b. Determination of whether the owner of operator has used acceptable procedures in response to an excursion or exceedance will be based on information available, which may include but is not limited to, monitoring results, review of operation and maintenance procedures and records, and inspection of the control device, associated capture system, and the process (40 CFR Part 64 §64.7(d)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 12.1.5.4 After approval of monitoring under this part, if the owner or operator identifies a failure to achieve compliance with an emission limitation or standard for which the approved monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing indicator ranges or designated conditions, the owner or operator shall promptly notify the Division and, if necessary, submit a proposed modification for this permit to address the necessary monitoring changes. Such a modification may include, but is not limited to, reestablishing indicator ranges or designated conditions, modifying the frequency of conducting monitoring and collecting data, or the monitoring of additional parameters. (40 CFR Part 64 §64.7(e), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 12.1.6 Quality Improvement Plan (QIP) Requirements 12.1.6.1 Based on the results of a determination made under the provisions of Condition 12.1.5.3b (§64.7(d)(2)), the Division may require the owner or operator to develop and implement a QIP (40 CFR Part 64 §64.8(a), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 12.1.6.2 The owner or operator shall maintain a written QIP, if required, and have it available for inspection (40 CFR Part 64 §64.8(b)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 12.1.6.3 The QIP initially shall include procedures for evaluating the control performance problems and, based on the results of the evaluation procedures, the owner or operator shall modify the plan to include procedures for conducting one or more of the following actions, as appropriate: a. Improved preventative maintenance practices (40 CFR Part 64 §64.8(b)(2)(i), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). b. Process operation changes (40 CFR Part 64 §64.8(b)(2)(ii), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 203 c. Appropriate improvements to control methods (40 CFR Part 64 §64.8(b)(2)(iii), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). d. Other steps appropriate to correct control performance (40 CFR Part 64 §64.8(b)(2)(iv), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). e. More frequent or improved monitoring (only in conjunction with one or more steps under Conditions a through d above) (40 CFR Part 64 § 64.8(b)(2)(v), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 12.1.6.4 If a QIP is required, the owner or operator shall develop and implement a QIP as expeditiously as practicable and shall notify the Division if the period for completing the improvements contained in the QIP exceeds 180 days from the date on which the need to implement the QIP was determined (40 CFR Part 64 §64.8(c), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 12.1.6.5 Following implementation of a QIP, upon any subsequent determination pursuant to Condition 12.1.5.3b (§64.7(d)(2)), the Division or the U.S. EPA may require that an owner or operator make reasonable changes to the QIP if the QIP is found to have: a. Failed to address the cause of the control device performance problems (40 CFR Part 64 §64.8(d)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV); or b. Failed to provide adequate procedures for correcting control device performance problems as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions (40 CFR Part 64 §64.8(d)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 12.1.6.6 Implementation of a QIP shall not excuse the owner or operator of a source from compliance with any existing emission limitation or standard, or any existing monitoring, testing, reporting or recordkeeping requirement that may apply under federal, state, or local law, or any other applicable requirements under the federal clean air act (40 CFR Part 64 §64.8(e), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 12.1.7 Reporting and Recordkeeping Requirements 12.1.7.1 Reporting Requirements: The reports required by Section IV, Condition 22.d, shall contain the information specified in Appendix B of the permit and the following information, as applicable: Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 204 a. Summary information on the number, duration and cause (including unknown cause, if applicable), for monitor downtime incidents (other than downtime associated with zero and span or other daily calibration checks, if applicable) ((40 CFR Part 64 §64.9(a)(2)(ii), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV); and b. The owner or operator shall submit, if necessary, a description of the actions taken to implement a QIP during the reporting period as specified in Condition 12.1.6 of this permit. Upon completion of a QIP, the owner or operator shall include in the next summary report documentation that the implementation of the plan has been completed and reduced the likelihood of similar levels of excursions or exceedances occurring (40 CFR Part 64 §64.9(a)(2)(iii), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 12.1.7.2 General Recordkeeping Requirements: In addition to the recordkeeping requirements in Section IV, Condition 22.a through c. a. The owner or operator shall maintain records of any written QIP required pursuant to Condition 12.1.6 and any activities undertaken to implement a QIP, and any supporting information required to be maintained under these CAM requirements (such as data used to document the adequacy of monitoring, or records of monitoring maintenance or corrective actions) (40 CFR Part 64 §64.9(b)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). b. Instead of paper records, the owner or operator may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements (40 CFR Part 64 §649(b)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 12.1.8 Savings Provisions 12.1.8.1 Nothing in these CAM requirements shall excuse the owner or operator of a source from compliance with any existing emission limitation or standard, or any existing monitoring, testing, reporting or recordkeeping requirement that may apply under federal, state, or local law, or any other applicable requirements under the federal clean air act. These CAM requirements shall not be used to justify the approval of monitoring less stringent than the monitoring which is required under separate legal authority and are not intended to establish minimum requirements for the purposes of determining the monitoring to be imposed under separate authority under the federal clean air act, including monitoring in permits issued pursuant to title I of the federal clean air act. The purpose of the CAM requirements is to require, as part of the issuance of this Title V operating permit, improved or new monitoring at those emissions units where monitoring Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 205 requirements do not exist or are inadequate to meet the requirements of CAM (40 CFR Part 64 §64.10(a)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 12.1.8.2 Nothing in these CAM requirements shall restrict or abrogate the authority of the U.S. EPA or the Division to impose additional or more stringent monitoring, recordkeeping, testing or reporting requirements on any owner or operator of a source under any provision of the federal clean air act, including but not limited to sections 114(a)(1) and 504(b), or state law, as applicable (40 CFR Part 64 §64.10(a)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 12.1.8.3 Nothing in these CAM requirements shall restrict or abrogate the authority of the U.S. EPA or the Division to take any enforcement action under the federal clean air act for any violation of an applicable requirement or of any person to take action under section 304 of the federal clean air act (40 CFR Part 64 §64.10(a)(3), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 13. Colorado Regulation No. 7 Requirements [The requirements below reflect the current rule language as of the revisions to 5 CCR 1001-9 Colorado Regulation No. 7 published in the Colorado Register on 01/25/2020 and effective on 02/14/2020. However, if revisions to this rule are published at a later date, the owner or operator is subject to the requirements contained in the revised version of Colorado Regulation No. 7.] 13.1 Part D, Section I: Volatile Organic Compound Emissions from Oil and Gas Operations Reciprocating Compressors (Part D, Section LJ.2) 13.1.1 Beginning January 1, 2018, the rod packing on reciprocating compressors located between the wellhead and the point of custody transfer to the natural gas transmission and storage segment must be replaced every 26,000 hours of operation or every thirty six (36) months. A reciprocating compressor located at a well production facility, or an adjacent well production facility and servicing more than one well production facility, is not subject to Section I.J.2 (Conditions 13.1.1 through 13.1.4). (Colorado Regulation No. 7, Part D, Section I.J.2.a) 13.1.1.1 Owners or operators of reciprocating compressors located at a natural gas processing plant and constructed before January 1, 2018, must (Colorado Regulation No. 7, Part D, Section I.J.2.a.(i)) a. Begin monitoring the hours of operation starting January 1, 2018 (Colorado Regulation No. 7, Part D, Section I.J.2.a.(i)(A)); or b. Conduct the first rod packing replacement required under Section I.J.2. prior to January 1, 2021. (Colorado Regulation No. 7, Part D, Section I.J.2.a.(i)(B)) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 206 13.1.1.2 Owners or operators of reciprocating compressors located at a natural gas processing plant and constructed after January 1, 2018, must begin monitoring the hours or months of operation upon commencement of operation of the reciprocating compressor. (Colorado Regulation No. 7, Part D, Section I.J.2.a.(ii)) 13.1.2 As an alternative to the requirement described in Section I.J.2.a. (Condition 13.1.1), beginning May 1, 2018, the owner or operator may collect rod packing volatile organic compound emissions using a rod packing emissions collection system that operates under negative pressure and routes the rod packing emissions through a closed vent system to a process. (Part D, Section I.J.2.b.) 13.1.2.1 The owner or operator must conduct annual visual inspections of the cover and closed vent system for defects that could result in air emissions. Defects of the closed vent system include, but are not limited to, visible cracks, holes, gaps in piping, loose connections, liquid leaks, or broken or missing caps or other closure devices. Defects of the cover include, but are not limited to, visible cracks, holes, gaps in the cover or between the cover and separator wall, broken or damaged seals or gaskets on closure devices, broken or missing hatches or other closure devices. (Part D, Section I.J.2.b.(i)) 13.1.2.2 The owner or operator must conduct annual EPA Method 21 inspections of the cover and closed vent system to determine whether the cover and closed vent system operates with volatile organic compound emissions less than 500 ppm. (Part D, Section I.J.2.b.(ii)) 13.1.2.3 In the event that a defect that could result in air emissions or leak is detected, the owner or operator must make a first attempt to repair no later than five (5) days after detecting the defect or leak and complete repair no later than thirty (30) days after detecting the defect or leak. (Part D, Section I.J.2.b.(iii)) 13.1.2.4 Owners or operators may delay inspection or repair of a cover or closed vent system if(Part D, Section I.J.2.b.(iv)): a. Repair is technically infeasible without a shutdown. If shutdown is required, a repair attempt must be made during the next scheduled shutdown and final repair completed within two (2) years after discovery. (Part D, Section I.J.2.b.(iv)(A)) b. The cover or closed vent system is unsafe to inspect or repair because personnel would be exposed to an immediate danger as a consequence of completing the inspection or repair. (Part D, Section I.J.2.b.(iv)(B)) c. The cover or closed vent system is difficult to inspect or repair because personnel must be elevated more than two (2) meters above a supported surface or are unable to inspect or repair via a wheeled scissor-lift or hydraulic Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 207 type scaffold that allows access up to 7.6 meters (25 feet) above the ground. (Part D, Section I.J.2.b.(iv)(C)) d. The cover or closed vent system is inaccessible to inspect or repair because the cover or closed vent system is buried, insulated, or obstructed by equipment or piping that prevents access. (Part D, Section I.J.2.b.(iv)(D)) 13.1.3 Recordkeeping (Part D, Section I.J.2.c.) 13.1.3.1 Owners or operators must maintain the following records for at least five (5) years and make records available to the Division upon request (Colorado Regulation No. 7, Part D, Section I.J.2.c.(i)): a. Identification of each reciprocating compressor(Colorado Regulation No. 7, Part D, Section I.J.2.c.(i)(A)); b. The hours of operation or the number of months since the previous rod packing replacement, or a statement that emissions from the rod packing are being routed to a process through a closed vent system under negative pressure (Colorado Regulation No. 7, Part D, Section I.J.2.c.(i)(B)); c. The date of each rod packing replacement, or date of installation of a rod packing emissions collection system and closed vent system (Colorado Regulation No. 7, Part D, Section I.J.2.c.(i)(C)); d. Each cover and closed vent system inspection and any resulting responsive actions (Colorado Regulation No. 7, Part D, Section I.J.2.c.(i)(D)); and e. Each cover or closed vent system on the delay of inspection or repair list, the reason for and duration of the delay of inspection or repair, and the schedule for inspecting or repairing such cover or closed vent system. (Colorado Regulation No. 7, Part D, Section I.J.2.c.(i)(E)) 13.1.4 As an alternative to the inspection, repair, and recordkeeping provisions in Sections I.J.2.b., I.J.2.c.(i)(D), and I.J.2.c.(i)(E), the owner or operator may inspect,repair, and document the cover and closed vent system in accordance with the leak detection and repair program in Section I.L., including the inspection frequency. (Colorado Regulation No. 7, Part D, Section I.J.2.d.) 13.1.5 As an alternative to the emission control, inspection, repair, and recordkeeping provisions described in Sections I.J.2.a. through I.J.2.d. (Conditions 13.1.1 through 13.1.4), the owner or operator may comply with reciprocating compressor emission control, monitoring, recordkeeping, and reporting requirements of a New Source Performance Standard in 40 CFR Part 60 (November 16, 2017). (Colorado Regulation No. 7, Part D, Section I.J.2.e.) Pneumatic Pumps (Part D, Section I.K) 13.1.6 Beginning May 1, 2018, the owner or operator of each natural gas-driven diaphragm pneumatic pump located at a natural gas processing plant must ensure the pneumatic pump Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 208 has a volatile organic compound emission rate of zero. (Colorado Regulation No. 7, Part D, Section I.K.1) 13.1.7 Owners or operators must maintain the following records for at least five (5) years and make records available to the Division upon request: (Part D, Section I.K.3.a) 13.1.7.1 Identification of each natural gas-driven diaphragm pneumatic pump. (Part D, Section I.K.3.a.(i)) 13.1.8 As an alternative to the emission control, inspection, repair, and recordkeeping provisions described in Sections I.K.1 through I.K.4., (Conditions 13.1.6 and 13.1.7), the owner or operator may comply with natural gas-driven diaphragm pneumatic pump emission control, monitoring, recordkeeping, and reporting requirements of a New Source Performance Standard in 40 CFR Part 60 (November 16, 2017). (Part D, Section I.K.5) General Provisions (Part D, Section L C) 13.1.9 All air pollution control equipment used to demonstrate compliance with Sections I.J (Conditions 13.1.1 through 13.1.5) and I.K(Conditions 13.1.6 through 13.1.8) must meet a control efficiency of at least 95%. Failure to properly install, operate, and maintain air pollution control equipment is a violation of this regulation. (Colorado Regulation No. 7, Part D, Section I.C.1.c) 13.1.10 If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Sections I.J (Conditions 13.1.1 through 13.1.5) and I.K (Conditions 13.1.6 through 13.1.8), it must be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means, such as a continuous monitoring device, approved by the Division, determine whether it is operating properly. (Colorado Regulation No. 7, Part D, Section I.C.1.d) 13.1.11 All combustion devices used to control emissions of volatile organic compounds to comply with Sections I.J. (Conditions 13.1.1 through 13.1.5) and I.K (Conditions 13.1.6 through 13.1.8) must be equipped with and operate an auto-igniter as follows (Colorado Regulation No. 7, Part D, Section I.C.1.e): 13.1.11.1 All combustion devices installed on or after January 1, 2018, and used to comply with Sections I.J (Conditions 13.1.1 through 13.1.5) and I.K (Conditions 13.1.6 through 13.1.8) must be equipped with an operational auto-igniter upon installation of the combustion device. (Colorado Regulation No. 7, Part D, Section I.C.1.e.(iv)) 13.2 Part D, Section III: Natural Gas-Actuated Pneumatic Controllers Associated with Oil and Gas Operations Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 209 13.2.1 For Continuous bleed, natural gas-driven pneumatic controllers in the 8-Hour Ozone Control Area and located at a natural gas processing plant (Colorado Regulation No. 7, Part D, Section III.C.2.): 13.2.2 All pneumatic controllers placed in service on or after January 1, 2018, must have a natural gas bleed rate of zero, unless allowed pursuant to Section III.C.2.c (Condition 13.2.4). (Colorado Regulation No. 7, Part D, Section III.C.2.a) 13.2.3 All pneumatic controllers with a bleed rate greater than zero in service prior to January 1, 2018, must be replaced or retrofit such that the pneumatic controller has a natural gas bleed rate of zero by May 1, 2018,unless allowed pursuant to Section III.C.2.c (Condition 13.2.4). (Colorado Regulation No. 7, Part D, Section III.C.2.b). 13.2.4 All pneumatic controllers with a natural gas bleed rate greater than zero that remain in service due to safety and/or process purposes must comply with Sections III.D (Conditions 13.2.5 through 13.2.7) and III.E (Conditions 13.2.8 through 13.2.11). (Colorado Regulation No. 7, Part D, Section III.C.2.c). 13.2.4.1 For pneumatic controllers with a natural gas bleed rate greater than zero in service prior to January 1, 2018, the owner or operator must submit justification for pneumatic controllers to remain in service due to safety and /or process purposes by May 1, 2018. (Colorado Regulation No. 7, Part D, Section III.C.2.c.(1)) 13.2.4.2 For pneumatic controllers with a natural gas bleed rate greater than zero placed in service on or after January 1, 2018, the owner or operator must submit justification for pneumatic controllers to be installed due to safety and /or process purposes thirty (30) days prior to installation. (Colorado Regulation No. 7, Part D, Section III.C.2.c.(ii)) Monitoring (Part D, Section IILD) 13.2.5 This section applies to pneumatic controllers identified in Section III.C.2.c. (Condition 13.2.4) (Colorado Regulation No. 7, Part D, Section III.D) 13.2.6 Effective May 1, 2018, each pneumatic controller with a natural gas bleed rate greater than zero must be physically tagged by the owner or operator identifying it with a unique pneumatic controller number that is assigned and maintained by the owner or operator. (Colorado Regulation No. 7, Part D, Section III.D.2.a.) 13.2.7 Effective May 1, 2018, the owner or operator must inspect each pneumatic controller with a natural gas bleed rate greater than zero on a monthly basis,perform necessary maintenance (such as cleaning, tuning, and repairing leaking gaskets, tubing fittings, and seals; tuning to operate over a broader range of proportional band; eliminating unnecessary valve positioners), and maintain the pneumatic controller according to manufacturer specifications to ensure that the controller's natural gas emissions are minimized. (Colorado Regulation No. 7, Part D, Section III.D.2.b.) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 210 Recordkeeping (Part D, Section IILE) 13.2.8 By January 1, 2019, owners or operators must compile an estimate of the total number of continuous bleed, natural gas-driven pneumatic controllers in service prior to January 1, 2018, and documentation (e.g., manufacturer specification, engineering calculations) that the natural gas bleed rate is zero. (Colorado Regulation No. 7, Part D, Section III.E.1.b.(i)) 13.2.9 Beginning January 1, 2018, the owner or operator must maintain records of the make and model of each type of continuous bleed, natural gas-driven pneumatic controllers placed in service on or after January 1, 2018, and documentation (e.g., manufacturer specification, engineering calculations) that the natural gas bleed rate is zero. Owners or operators must use this information to update the estimate required in Section III.E.1.b.(i) (Condition 13.2.8) every three years (i.e., by January 1, 2022, January 1,2025, etc.). (Colorado Regulation No. 7, Part D, Section III.E.1.b.(ii)) 13.2.10 Records must be maintained for a minimum of five years and made available to the Division upon request. (Colorado Regulation No. 7, Part D, Section III.E.1.c.) 13.2.11 This section applies only to pneumatic controllers identified in Section III.C.2.c. (Condition 13.2.4) (Colorado Regulation No. 7, Part D, Section III.E.2.) 13.2.11.1 The owner or operator must maintain a log of the total number of pneumatic controllers and their associated controller numbers per facility, the total number of pneumatic controllers per company and the associated justification that the pneumatic controllers must be used pursuant to Section III.C.2.c. (Condition 13.2.4). The log shall be updated on a monthly basis. (Colorado Regulation No. 7, Part D, Section III.E.2.a.) 13.2.11.2 The owner or operator must maintain a log of necessary maintenance which shall include, at a minimum, inspection dates, the date of the maintenance activity, pneumatic controller number, description of the maintenance performed, results and date of any corrective action taken, and the printed name and signature of the individual performing the maintenance. The log shall be updated on a monthly basis. (Colorado Regulation No. 7, Part D, Section III.E.2.b.) 13.2.11.3 Records of maintenance of pneumatic controllers shall be maintained for a minimum of five years and readily made available to the Division upon request. (Section VI, Condition 22) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 211 SECTION V - 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. Emission Unit Description& Applicable Requirement Justification Number Platte Valley Regulation No. 6,Part A, Subpart Dc(40 CFR 60 These sections are based on the use of either coal S014 heater Subpart Dc §60.42c; §60.43c, §60.44c; §60.45c; or fuel oil. This source utilizes only natural gas. (AIRS point 046) §60.46c; §60.47c; §60.48c(b),(c), (d), (e) and(f)) S020 turbine This section pertains to the use of water injection (AIRS point 052) 40 CFR 60 Subpart GG, §60.334(a) to control NOR. This source uses lean premixed combustion instead. 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. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 212 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. Permit Condition I Streamlined(Subsumed)Requirements Fort Lupton SECTION II 1.7.3, Colorado Regulation No. 7,Part E, Section I.D.3.b: State-only state-wide requirement for SECTION II 5.7.3 existing lean burn reciprocating internal combustion engines greater than 500 HP to install oxidation catalysts by July 1, 2010 Platte Valley SECTION III-5.6, Colorado Regulation No. 6,Part B, Section II.C.2 [particulate matter emissions shall not SECTION III- 8.4, and exceed 0.5(FI)-°-6 lbs/MMBtu] —State Only Requirement SECTION III- 12.6 SECTION III- 8.3.2 Colorado Regulation No. 6,Part B, Section II.D.3.a [SO2 emissions shall not exceed 0.8 lbs/MMBtu] —State Only Requirement(turbine SO2 requirement) Section VI, Condition 22.b 40 CFR 60 Subpart Dc, §60.48c(i):All records required under this section shall be maintained by the owner or operator of the affected facility for a period of two years following the date of (five year record retention such record. provision) Applicable to Fort Lupton and Platte Valley Colorado Regulation No. 7,Part d, Section III.E.2.c [Records of maintenance of pneumatic controllers shall be maintained for a minimum of three years and readily made available to the Section VI, Condition 22.b Division upon request.] —Applicable to pneumatic controllers with bleed rates above limits (five year record retention that must remain in service due to safety and/or process purposes. provision) 40 CFR 60 Subpart OOOOa, §60.5421a(b)(2): When each leak is detected ... information must be recorded in a log and shall be kept for 2 years in a readily available location...(Only with respect to the requirement that records be kept for 2 years) Section IV Conditions SECTION IV- 13.2.1-SECTION IV- 13.2.4 (emission standards); Colorado Regulation No. 7: Part D, Section III.C.1 and III.C.3 (State Only) [Emission Conditions SECTION IV- standards for pneumatic controllers]; Part D, Section III.D.1 and III.D.3 (State Only) 13.2.5 —SECTION IV- [Monitoring];Part D, Section III.E.1.a [Recordkeeping] 13.2.7 (monitoring); Conditions SECTION IV- 13.2.8-SECTION IV- 13.2.9 (recordkeeping) Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 213 SECTION VI - General Permit Conditions (ver 8/28/2018) 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 §§ ILA., ILB., ILC., ILE., ILF.,II.I, and II.J a. To Control Emissions Leaving Colorado When emissions generated from sources in Colorado cross the State boundary line, such emissions shall not cause the air quality standards of the receiving State to be exceeded,provided reciprocal action is taken by the receiving State. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 214 b. Emission Monitoring Requirements The Division may require owners or operators of stationary air pollution sources to install,maintain, and use instrumentation to monitor and record emission data as a basis for periodic reports to the Division. c. Performance Testing The owner or operator of any air pollution source shall, upon request of the Division, conduct performance test(s) and furnish the Division a written report of the results of such test(s) in order to determine compliance with applicable emission control regulations. Performance test(s) shall be conducted and the data reduced in accordance with the applicable reference test methods unless the Division: (i) specifies or approves, in specific cases,the use of a test method with minor changes in methodology; (ii) approves the use of an equivalent method; (iii) approves the use of an alternative method the results of which the Division has determined to be adequate for indicating where a specific source is in compliance; or (iv) waives the requirement for performance test(s)because the owner or operator of a source has demonstrated by other means to the Division's satisfaction that the affected facility is in compliance with the standard. Nothing in this paragraph shall be construed to abrogate the Commission's or Division's authority to require testing under the Colorado Revised Statutes, Title 25,Article 7, and pursuant to regulations promulgated by the Commission. Compliance test(s) shall be conducted under such conditions as the Division shall specify to the plant operator based on representative performance of the affected facility. The owner or operator shall make available to the Division such records as may be necessary to determine the conditions of the performance test(s). Operations during period of startup, shutdown, and malfunction shall not constitute representative conditions of performance test(s)unless otherwise specified in the applicable standard. The owner or operator of an affected facility shall provide the Division thirty days prior notice of the performance test to afford the Division the opportunity to have an observer present. The Division may waive the thirty day notice requirement provided that arrangements satisfactory to the Division are made for earlier testing. The owner or operator of an affected facility shall provide, or cause to be provided,performance testing facilities as follows: (i) Sampling ports adequate for test methods applicable to such facility; (ii) Safe sampling platform(s); (iii) Safe access to sampling platform(s); and (iv) Utilities for sampling and testing equipment. Each performance test shall consist of at least three separate runs using the applicable test method. Each run shall be conducted for the time and under the conditions specified in the applicable standard.For the purpose of determining compliance with an applicable standard,the arithmetic mean of results of at least three runs shall apply. In the event that a sample is accidentally lost or conditions occur in which one of the runs must be discontinued because of forced shutdown, failure of an irreplaceable portion of the sample train, extreme meteorological conditions, or other circumstances beyond the owner or operator's control, compliance may,upon the Division's approval,be determined using the arithmetic mean of the results of the two other runs. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 215 Nothing in this section shall abrogate the Division's authority to conduct its own performance test(s)if so warranted. 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. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 216 e. Circumvention Clause A person shall not build, erect, install, or use any article,machine, equipment, condition, or any contrivance, the use of which,without resulting in a reduction in the total release of air pollutants to the atmosphere,reduces or conceals an emission which would otherwise constitute a violation of this regulation.No person shall circumvent this regulation by using more openings than is considered normal practice by the industry or activity in question. f. Compliance Certifications For the purpose of submitting compliance certifications or establishing whether or not a person has violated or is in violation of any standard in the Colorado State Implementation Plan,nothing in the Colorado State Implementation Plan shall preclude the use, including the exclusive use, of any credible evidence or information,relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed. Evidence that has the effect of making any relevant standard or permit term more stringent shall not be credible for proving a violation of the standard or permit term. When compliance or non-compliance is demonstrated by a test or procedure provided by permit or other applicable requirement,the owner or operator shall be presumed to be in compliance or non-compliance unless other relevant credible evidence overcomes that presumption. g. Affirmative Defense Provision for Excess Emissions During Startup and Shutdown An affirmative defense is provided to owners and operators for civil penalty actions for excess emissions during periods of startup and shutdown. To establish the affirmative defense and to be relieved of a civil penalty in any action to enforce an applicable requirement,the owner or operator of the facility must meet the notification requirements below in a timely manner and prove by a preponderance of the evidence that: (i) The periods of excess emissions that occurred during startup and shutdown were short and infrequent and could not have been prevented through careful planning and design; (ii) The excess emissions were not part of a recurring pattern indicative of inadequate design, operation or maintenance; (iii) If the excess emissions were caused by a bypass (an intentional diversion of control equipment), then the bypass was unavoidable to prevent loss of life,personal injury, or severe property damage; (iv) The frequency and duration of operation in startup and shutdown periods were minimized to the maximum extent practicable; (v) All possible steps were taken to minimize the impact of excess emissions on ambient air quality; (vi) All emissions monitoring systems were kept in operation(if at all possible); (vii) The owner or operator's actions during the period of excess emissions were documented by properly signed, contemporaneous operating logs or other relevant evidence; and, (viii) At all times, the facility was operated in a manner consistent with good practices for minimizing emissions. This subparagraph is intended solely to be a factor in determining whether an affirmative defense is available to an owner or operator, and shall not constitute an additional applicable requirement. The owner or operator of the facility experiencing excess emissions during startup and shutdown shall notify the Division verbally as soon as possible,but no later than two (2)hours after the start of the next working day, and shall submit written quarterly notification following the initial occurrence of the excess emissions. The notification shall address the criteria set forth above. The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 217 The Affirmative Defense Provision does not apply to State Implementation Plan provisions or other requirements that derive from new source performance standards or national emissions standards for hazardous air pollutants, or any other federally enforceable performance standard or emission limit with an averaging time greater than twenty- four hours. In addition, an affirmative defense cannot be used by a single source or small group of sources where the excess emissions have the potential to cause an exceedance of the ambient air quality standards or Prevention of Significant Deterioration(PSD) increments. In making any determination whether a source established an affirmative defense, the Division shall consider the information within the notification required above and any other information the Division deems necessary,which may include,but is not limited to,physical inspection of the facility and review of documentation pertaining to the maintenance and operation of process and air pollution control equipment. 4. Compliance Requirements Regulation No. 3, 5 CCR 1001-5,Part C, §§ III.C.9.,V.C.11. & 16.d. and § 25-7-122.1(2), C.R.S. a. The permittee must comply with all conditions of the Operating Permit. Any permit noncompliance relating to federally-enforceable terms or conditions constitutes a violation of the federal act, as well as the state act and Regulation No. 3. Any permit noncompliance relating to state-only terms or conditions constitutes a violation of the state act and Regulation No. 3, shall be enforceable pursuant to state law, and shall not be enforceable by citizens under§ 304 of the federal act. Any such violation of the federal act,the state act or regulations implementing either statute is grounds for enforcement action, for permit termination,revocation and reissuance or modification or for denial of a permit renewal application. b. It shall not be a defense for a permittee in an enforcement action or a consideration in favor of a permittee in a permit termination,revocation or modification action or action denying a permit renewal application that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of the permit. c. The permit may be modified,revoked,reopened, and reissued, or terminated for cause. The filing of any request by the permittee for a permit modification,revocation and reissuance, or termination, or any notification of planned changes or anticipated noncompliance does not stay any permit condition, except as provided in§§ X. and XI.of Regulation No. 3,Part C. d. The permittee shall furnish to the Air Pollution Control Division, within a reasonable time as specified by the Division, any information that the Division may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating the permit or to determine compliance with the permit. Upon request,the permittee shall also furnish to the Division copies of records required to be kept by the permittee, including information claimed to be confidential. Any information subject to a claim of confidentiality shall be specifically identified and submitted separately from information not subject to the claim. e. Any schedule for compliance for applicable requirements with which the source is not in compliance at the time of permit issuance shall be supplemental, and shall not sanction noncompliance with, the applicable requirements on which it is based. f. For any compliance schedule for applicable requirements with which the source is not in compliance at the time of permit issuance, the permittee shall submit, at least every 6 months unless a more frequent period is specified in the applicable requirement or by the Air Pollution Control Division,progress reports which contain the following: (i) dates for achieving the activities, milestones, or compliance required in the schedule for compliance, and dates when such activities,milestones, or compliance were achieved; and (ii) an explanation of why any dates in the schedule of compliance were not or will not be met, and any preventive or corrective measures adopted. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 218 g. The permittee shall not knowingly falsify, tamper with, or render inaccurate any monitoring device or method required to be maintained or followed under the terms and conditions of the Operating Permit. 5. Emergency Provisions Regulation No. 3, 5 CCR 1001-5,Part C, § VII An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God,which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed the technology-based emission limitation under the permit due to unavoidable increases in emissions attributable to the emergency. "Emergency" does not include noncompliance to the extent caused by improperly designed equipment, lack of preventative maintenance, careless or improper operation, or operator error. An emergency constitutes an affirmative defense to an enforcement action brought for noncompliance with a technology-based emission limitation if the permittee demonstrates,through properly signed,contemporaneous operating logs, or other relevant evidence that: a. an emergency occurred and that the permittee can identify the cause(s) of the emergency; b. the permitted facility was at the time being properly operated; c. during the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that exceeded the emission standards, or other requirements in the permit; and d. the permittee submitted oral notice of the emergency to the Air Pollution Control Division no later than noon of the next working day following the emergency, and followed by written notice within one month of the time when emissions limitations were exceeded due to the emergency. This notice must contain a description of the emergency, any steps taken to mitigate emissions, and corrective actions taken. This emergency provision is in addition to any emergency or malfunction provision contained in any applicable requirement. 6. Emission 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 maybe prior to commencing any work exceeding the 30 hour limit. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 219 c. The permittee shall pay an APEN fee in accordance with the provisions of C.R.S. § 25-7-114.1(6) for each APEN or revised APEN filed. 9. Fugitive Particulate Emissions Regulation No. 1, 5 CCR 1001-3, § III.D.1. The permittee shall employ such control measures and operating procedures as are necessary to minimize fugitive particulate emissions into the atmosphere, in accordance with the provisions of Regulation No. 1, § III.D.1. 10. Inspection and Entry Regulation No. 3, 5 CCR 1001-5,Part C, § V.C.16.b. Upon presentation of credentials and other documents as may be required by law, the permittee shall allow the Air Pollution Control Division, or any authorized representative, to perform the following: a. enter upon the permittee's premises where an Operating Permit source is located, or emissions-related activity is conducted, or where records must be kept under the terms of the permit; b. have access to, and copy, at reasonable times, any records that must be kept under the conditions of the permit; c. inspect at reasonable times any facilities, equipment(including monitoring and air pollution control equipment), practices, or operations regulated or required under the Operating Permit; d. sample or monitor at reasonable times, for the purposes of assuring compliance with the Operating Permit or applicable requirements, any substances or parameters. 11. Minor Permit Modifications Regulation No. 3, 5 CCR 1001-5,Part C, §§ X. &XI. The permittee shall submit an application for a minor permit modification before making the change requested in the application. The permit shield shall not extend to minor permit modifications. 12. New Source Review Regulation No. 3, 5 CCR 1001-5,Part B &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. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 220 15. Off-Permit Changes to the Source Regulation No. 3, 5 CCR 1001-5,Part C, § XII.B. The permittee shall record any off-permit change to the source that causes the emissions of a regulated pollutant subject to an applicable requirement,but not otherwise regulated under the permit, and the emissions resulting from the change, including any other data necessary to show compliance with applicable ambient air quality standards. The permittee shall provide contemporaneous notification to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. The permit shield shall not apply to any off-permit change. 16. Opacity Regulation No. 1, 5 CCR 1001-3, §§ I., II. The permittee shall comply with the opacity emissions limitation set forth in Regulation No. 1, §§ 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: Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 221 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; (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 specify 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. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit# 95OPWE013 Page 222 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 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. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 223 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 (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 Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 224 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. 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. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Kerr-McGee Gathering, LLC Colorado Operating Permit Fort Lupton Complex Permit # 95OPWE013 Page 225 b. Except when otherwise provided by Regulation No. 7, all volatile organic compounds, excluding petroleum liquids, transferred to any tank, container, or vehicle compartment with a capacity exceeding 212 liters(56 gallons), shall be transferred using submerged or bottom filling equipment. For top loading,the fill tube shall reach within six inches of the bottom of the tank compartment. For bottom-fill operations, the inlet shall be flush with the tank bottom. 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 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 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendices OPERATING PERMIT APPENDICES A - INSPECTION INFORMATION B - MONITORING AND PERMIT DEVIATION REPORT C - COMPLIANCE CERTIFICATION REPORT D - NOTIFICATION ADDRESSES E - PERMIT ACRONYMS F - PERMIT MODIFICATIONS G - COMPLIANCE ASSURANCE MONITORING PLAN - 4SRB H - COMPLIANCE ASSURANCE MONITORING PLAN - 4SLB I - COMPLIANCE ASSURANCE MONITORING PLAN - NATURAL GAS LIQUIDS AMINE UNIT J - COMPLIANCE ASSURANCE MONITORING PLAN - LOADOUT OF PRESSURIZED NATURAL GAS LIQUIDS K - ENGINE AOS APPLICABILITY REPORTS *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 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix A Monitoring and Permit Deviation Report Page 227 APPENDIX A - Inspection Information 1. Directions to Plant: This facility is near the town of Ft. Lupton, located at 16116 Weld County Road 22. 2. Safety Equipment Required: Eye Protection; Hard Hat; Safety Shoes; Hearing Protection; Fire Retardant Clothing 3. Facility Plot Plan: The attached Figures (following pages) show the plot plans for the Fort Lupton and Platte Valley plants, as submitted in the April 21, 2015 modification application, and the Lancaster Plant plot plan, as submitted in the March 4, 2016 modification application. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix A Monitoring and Permit Deviation Report Page 228 i If ,..0 I- I R I' I I I I I , I • y" - m i h' ' ''''' "': , x"i 'I-. '''''':‘,,1:'6-:.ILI' :I'''.—Li-1-7.'-';I' - y n - z J _ h; g1 7-J , _ 1 ,, F I'I I rj � 4 y � 'I i tiJ :` G'1 `� I 1 IXI �� ut .'. '1 III. a '3 i I I I I _ I -.m i - ,_ , , .„,, ,•,, I_ ,,, ,:, , , : ,,, F . • T. Operating Permit 95C = er 1, 1998 2 7.,i; !.d: DATE =1 Air Pollution Control Division Colorado Operating Permit Appendix A Monitoring and Permit Deviation Report Page 229 Platte Valley Plot Plan Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix A Monitoring and Permit Deviation Report Page 230 I I lh1I. E e t LI i I I I I I j A�J I 4.. I ` ''' I :III; ,-era I 114 .;il G x ri . €,_ _I I Ili`rGJ= " ]11" ] E � V{ I z J : 1=°— ,-;4�i N ;rr 9 11 c II m h =.:: , G ig -'',1- ,,., \,.-1 , ... .,, Ego I - �_ H e r 9` A S '. • g 5 First Issued: October 1, 1998 Ir Z ' Renewed: DATE Z 1 V. Air Pollution Control Division Colorado Operating Permit Appendix A Monitoring and Permit Deviation Report Page 231 Lancaster Plot Plan Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix A Monitoring and Permit Deviation Report Page 232 : L.::.:,,,...,, 4 _. .. I -dl i �,Q 1,e : OD z'-R �E < z .Jam'= *� i I I, C-_ - ■- II o III L—h '� ._. ='I AI I ,' 4 I -....- � is 1 1"' ' .:::it : - h !Ii I 'iV�EJ I _CI [ - y L_ �I ...... ,..,,,, .. -1 _ ., , „ • ,..I-077...Ai ,-. Ltilii -, _ ___:. ...._ CZadik . I1- . r! . ta m :: J, , H ffiI I d I II o ii I First Issued: October 1, 1998 Renewed: DATE - Air Pollution Control Division Colorado Operating Permit Appendix A Monitoring and Permit Deviation Report Page 233 4. 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. Note that some of these insignificant activities are associated with the Lancaster plant, though this issuance of the permit does not yet incorporate the requirements for Lancaster. 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 ILE). In the modification application received on April 21, 2015, Kerr-McGee indicated that there are emission units at the Fort Lupton complex that fall under the following categories of sources and activities which are considered to be insignificant contributors to air pollution: *Colorado Regulation No. 3, Part C, Section II.E.3.a: Individual emission points in nonattainment areas having uncontrolled actual emissions of any criteria pollutant (as defined in Section I.B.17. of Part A of this Regulation Number 3) of less than one ton per year, and individual emission points in attainment or attainment/maintenance areas having uncontrolled actual emissions of any criteria pollutant of less than two tons per year, and each individual emission point with uncontrolled actual emissions of lead less than one hundred pounds per year, regardless of where the source is located. Colorado Regulation No. 3, Part C, Section II.E.3.b: Individual emission points of non criteria reportable pollutants having uncontrolled actual emissions less than the de minimis levels as determined following the procedures set forth in Appendix A. *Colorado Regulation No. 3, Part C, Section II.E.3.k: Each individual piece of fuel burning equipment, other than smokehouse generators and internal combustion engines, that uses gaseous fuel, and that has a design rate less than or equal to five million British thermal units per hour. Colorado Regulation No. 3, Part C, Section II.E.3.zz: Storage of butane, propane, or liquefied petroleum gas in a vessel with a capacity of less than sixty thousand gallons, provided the requirements of Regulation Number 7, Section IV. are met, where applicable. Colorado Regulation No. 3, Part C, Section II.E.3.aaa: Storage tanks of capacity less than forty thousand gallons of lubricating oils or waste lubricating oils. *Colorado Regulation No. 3, Part C, Section II.E.3.fff: Storage Tanks meeting all of the following criteria: • II.E.fff.(i) Annual throughput is less than four hundred thousand gallons; and • II.E.3.fff.(ii) — The liquid stored is one of the following: Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix A Monitoring and Permit Deviation Report Page 234 o II.E.3.fff.(ii)(A) — Diesel fuels 1-D, 2-D, or 4-6; o II.E.3.fff.(ii)(B) Fuel Oils #1 - #6; o II.E.3.fff.(ii)(C) As turbine fuels 1-GT through 4-GT; o II.E.3.fff(ii)(D) An oil/water mixture with a vapor pressure less than or equal to that of diesel fuel (Reid vapor pressure of 0.25 psia). Colorado Regulation No. 3, Part C, Section II.E.3.ggg: Each individual piece of fuel burning equipment that uses gaseous fuel, and that has a design rate less than or equal to ten million British thermal units per hour, and that is used solely for heating buildings for personal comfort. Colorado Regulation No. 3, Part C, Section II.E.3.nnn: Stationary Internal Combustion Engines that: • II.E.3.nnn.(i): Are power portable drilling rigs; or • II.E.3.nnn.(ii): Are emergency power generators that operate no more than two hundred and fifty hours per year; or • II.E.3.nnn.(iii): Have uncontrolled actual emissions less than five tons per year or manufacturer's site-rated horsepower of less than fifty Kerr-McGee provided the following list of specific sources and activities that are considered insignificant: Tanks 1. T-603 Produced Condensate and Water 210 Bbls 2. T-504 Produced Condensate and Water 210 Bbls 3. T-605 Produced Condensate and Water 210 Bbls 4. T-101 Pressurized Raw Mix 30,000 gallons 5. T-102 Pressurized Raw Mix 30,000 gallons 6. T-103 Pressurized Raw Mix 30,000 gallons 7. T-104 Pressurized Propane tank 30,000 gallons 8. T-105 Pressurized Propane tank 30,000 gallons 9. T-106 Pressurized Propane tank 30,000 gallons 10. T-301 Pressurized Propane tank 30,000 gallons 11. T-302 Pressurized Propane tank 30,000 gallons 12. T-303 Pressurized Propane tank 30,000 gallons 13. T-304 Pressurized Propane tank 30,000 gallons 14. T-305 Pressurized Propane tank 30,000 gallons 15. T-306 Pressurized Propane tank 30,000 gallons 16. T-401 Pressurized Butane tank 24,600 gallons 17. T-402 Pressurized Butane tank 24,600 gallons 18. T-403 Pressurized Butane tank 44,000 gallons 19. T-404 Pressurized Butane tank 44,000 gallons 20. T-405 Pressurized Butane tank 44,000 gallons 21. T-501 Natural Gasoline 42,000 gallons 22. T-502 Natural Gasoline 60,000 gallons 23. T-503 Natural Gasoline 42,000 gallons Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix A Monitoring and Permit Deviation Report Page 235 24. T-504 Natural Gasoline 42,000 gallons 25. T-505 Pressurized Raw Mix 30,000 gallons 26. T-307 Refrigerant Grade Propane 12,000 gallons 27. 3V-206 Natural Gas Liquids 12,000 gallons 28. V-106 Natural Gas Liquids 10,000 gallons 29. V-710 Natural Gas Liquids 30,000 gallons 30. TK-161 Natural Gas Liquids 60,000 gallons 31. TK-162 Natural Gas Liquids 60,000 gallons 32. TK-163 Natural Gas Liquids 60,000 gallons 33. TK-561 Stabilized Condensate 10,000 gallons 34. TK-562 Stabilized Condensate 10,000 gallons 35. TK-563 Stabilized Condensate 10,000 gallons 36. TK-564 Stabilized Condensate 10,000 gallons 37. TK-101 Stabilized Condensate 30,000 gallons 38. TK-102 Stabilized Condensate 30,000 gallons 39. TK-103 Stabilized Condensate 30,000 gallons 40. TK-104 Stabilized Condensate 30,000 gallons 41. TK-105 Stabilized Condensate 30,000 gallons 42. TK-106 Stabilized Condensate 30,000 gallons 43. TK-201 Produced Condensate and Water 30,000 gallons 44. TK-202 Produced Condensate and Water 30,000 gallons 45. TK-203 Produced Condensate and Water 30,000 gallons 46. TK-204 Produced Condensate and Water 30,000 gallons 47. V-7100 Natural Gas Liquids 60,000 gallons 48. V-7200 Natural Gas Liquids 60,000 gallons 49. V-TBD Natural Gas Liquids 60,000 gallons 50. V-TBD Natural Gas Liquids 60,000 gallons Electric Motor Compressors 51. C-4100 Residue Gas Compressor 52. C-4201 Residue Gas Compressor 53. C-5100 Residue Gas Compressor 54. C-5200 Residue Gas Compressor 55. C-5300 Residue Gas Compressor 56. C-4300 Residue Gas Compressor 57. C-4401 Residue Gas Compressor 58. C-5500 Residue Gas Compressor 59. C-5600 Residue Gas Compressor 60. C-5700 Residue Gas Compressor 61. EU-105 Inlet Gas Compressor 62. EU-106 Inlet Gas Compressor 63. EU-107 Inlet Gas Compressor 64. EU-108 Inlet Gas Compressor Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix A Monitoring and Permit Deviation Report Page 236 65. EU-109 Inlet Gas Compressor Small Heaters 66. H-101 Process Regen Heater 1.09 MMBtu/hr 67. H-420 Process Regen Heater 3.17 MMBtu/hr 68. H-4400 NGL Regen Heater 1.79 MMBtu/hr 69. HX-290 Stabilization Heater 1.2 MMBtu/hr 70. H-ST2 Condensate Stabilizer <5 MMBtu/hr 71. H-ST3 Condensate Stabilizer <5 MMBtu/hr 72. H-ST4 Condensate Stabilizer <5 MMBtu/hr 73. H-178 QBJ De-Ethanizer Reboiler heater 4.5 MMBtu/hr 74. H-551 ST-1 Condensate Stabilizer 3.5 MMBtu/hr 75. H-820 ST-1 Bath Heater 2 MMBtu/hr Emergency Generators 76. EU-41, GEN1 Detroit KC750KWI Diesel Generator 1088 HP 77. GEN2 — Caterpillar C18 DITA Emergency Generator 900 HP 78. John-Deere Diesel Back-up Air Compressor 115 HP 79. PLC Genset-Generac QT0600, Mitsubishi 4G64S4M engine 80 HP 80. GEN3 Caterpillar C18 DITA Emergency Generator 839 HP Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 237 APPENDIX B Reporting Requirements and Definitions with codes ver 8/20/14 Please note that, pursuant to 113(c)(2) of the federal Clean Air Act, any person who knowingly: (A) makes any false material statement,representation, or certification in, or omits material information from, or knowingly alters, conceals, or fails to file or maintain any notice, application, record, report, plan, or other document required pursuant to the Act to be either filed or maintained (whether with respect to the requirements imposed by the Administrator or by a State); (B) fails to notify or report as required under the Act; or (C) falsifies, tampers with, renders inaccurate, or fails to install any monitoring device or method required to be maintained or followed under the Act shall, upon conviction, be punished by a fine pursuant to title 18 of the United States Code, or by imprisonment for not more than 2 years, or both. If a conviction of any person under this paragraph is for a violation committed after a first conviction of such person under this paragraph, the maximum punishment shall be doubled with respect to both the fine and imprisonment. The permittee must comply with all conditions of this operating permit. Any permit noncompliance constitutes a violation of the Act and is grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application. The Part 70 Operating Permit program requires three types of reports to be filed for all permits. All required reports must be certified by a responsible official. Report #1: Monitoring Deviation Report (due at least every six months) For purposes of this operating permit, the Division is requiring that the monitoring reports are due every six months unless otherwise noted in the permit. All instances of deviations from permit monitoring requirements must be clearly identified in such reports. For purposes of this operating permit, monitoring means any condition determined by observation, by data from any monitoring protocol, or by any other monitoring which is required by the permit as well as the recordkeeping associated with that monitoring. This would include, for example, fuel use or process rate monitoring, fuel analyses, and operational or control device parameter monitoring. Report#2: Permit Deviation Report (must be reported "promptly") In addition to the monitoring requirements set forth in the permits as discussed above, each and every requirement of the permit is subject to deviation reporting. The reports must address deviations from permit requirements, including those attributable to malfunctions as defined in this Appendix, the probable cause of Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 238 such deviations, and any corrective actions or preventive measures taken. All deviations from any term or condition of the permit are required to be summarized or referenced in the annual compliance certification. For purposes of this operating permit, "malfunction" shall refer to both emergency conditions and malfunctions. Additional discussion on these conditions is provided later in this Appendix. For ptupOses 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 Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 239 permit that were conducted during the relevant time period. In addition, if the owner or operator knows of other material information (i.e. information beyond required monitoring that has been specifically assessed in relation to how the information potentially affects compliance status), that information must be identified and addressed in the compliance certification. The compliance certification must include the following: • The identification of each term or condition of the permit that is the basis of the certification; • 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. 1 For example, given the various emissions limitations and monitoring requirements to which a source may be subject, a deviation from one requirement may not be a deviation under another requirement which recognizes an exception and/or special circumstances relating to that same event. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 240 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 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 241 APPENDIX B: Monitoring and Permit Deviation Report - Part I 1. Following is the required format for the Monitoring and Permit Deviation report to be submitted to the Division as set forth in General Condition 21. The Table below must be completed for all equipment or processes for which specific Operating Permit terms exist. 2. Part II of this Appendix B shows the format and information the Division will require for describing periods of monitoring and permit deviations, or malfunction or emergency conditions as indicated in the Table below. One Part II Form must be completed for each Deviation. Previously submitted reports (e.g. EER's or malfunctions) may be referenced and the form need not be filled out in its entirety. FACILITY NAME: Kerr-McGee Gathering LLC — Fort Lupton Complex OPERATING PERMIT NO: 95OPWE013 REPORTING PERIOD: (see first page of the permit for specific reporting period and dates) Deviations noted Deviation Malfunction/Emergency Operating Unit Description During Period?' Code= Condition Reported Permit Unit ID p During Period? YES NO YES NO Fort Lupton Gas Plant Fairbanks Morse MEP-12 Natural Gas Fired 2- Stroke Lean Burn Internal Combustion Engine, Site EU-33 rated at 2046 HP, Serial No. 38D8780-30S1S12. This unit is equipped with an Air/Fuel Ratio controller. Waukesha L7042GSI Natural Gas Fired 4-Stroke Rich Burn Internal Combustion Engine,Rated at EU-101 1478 HP(manuf.maximum), Serial No. 288358. This unit is equipped with an Air/Fuel Ratio controller. F001 Fugitive Emissions from Equipment Leaks Caterpillar G3612TALE Natural Gas Fired 4-Stroke EU-38 Lean Burn Internal Combustion Engine, Low NOx design, Site rated at 3550 HP, Serial No. 1YG00238. Caterpillar G3612TALE Natural Gas Fired 4-Stroke EU-39 Lean Burn Internal Combustion Engine, Low NOx design, Site rated at 3550 HP, Serial No. 1YG00239. Waukesha L7042GSI Natural Gas Fired 4-Stroke Rich Burn Internal Combustion Engine,Rated at EU-34R 1232 HP(manuf.maximum), Serial No.250451. This unit is equipped with an Air/Fuel Ratio controller. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 242 Deviations noted Deviation MalfunctionrEmergency Operating During Period?' Code ' Condition Reported Permit Unit ID Unit DescriptionDuring Period? YES NO YES NO Caterpillar G3616 TALE Natural Gas Fired 4-Stroke EU 103 Lean Burn Internal Combustion Engine, Site rated at 4262 HP, Serial No.BLB00452. This unit is equipped with an Air/Fuel Ratio controller. Caterpillar G3616 LE Natural Gas Fired 4-Stroke Lean Burn Internal Combustion Engine,Rated at EU-104 4735 HP(manuf.maximum), Serial No.BLB00539 This unit is equipped with an Air/Fuel Ratio controller. Waukesha L7042GSI Natural Gas Fired 4-Stroke EU-32 Rich Burn Internal Combustion Engine,Rated at 1232 HP, Serial No.288792. This unit is equipped with an Air/Fuel Ratio controller. One(1) John Zink 65' Air-Assisted Process Flare used to control emissions from process equipment F-4 blowdowns associated with maintenance activities, compressor blowdowns, and venting such as for pressure relief valves or plant shutdowns. Serial No. 9148687 One(1)Caterpillar,Model C18 DITA, Serial Number EKW01075,diesel-fired, turbo-charged, GEN2 reciprocating internal combustion engine, site rated at 900 horsepower at 1800 RPM. This unit is used for emergency power generation. Platte Valley Gas Plant S001/ Ajax DPC-540LE,Natural Gas Fired 2-Stroke Lean EU-281 Burn Internal Combustion Engine, Site-rated at 514 HP, SN: 83891 S002/ Ajax DPC-540LE,Natural Gas Fired 2-Stroke Lean EU-282 Burn Internal Combustion Engine, Site-rated at 514 HP, SN: 83892 S0031 Ajax DPC-540LE,Natural Gas Fired 2-Stroke Lean EU-283 Burn Internal Combustion Engine, Site-rated at 514 HP, SN: 83889 S004/ Ajax DPC-540LE,Natural Gas Fired 2-Stroke Lean EU-284 Burn Internal Combustion Engine, Site-rated at 514 HP, SN: 83890 S007 Platte Valley Plant Fugitive Emissions Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 243 Deviations noted Deviation MalfunctionrEmergency Operating During Period?' Code ' Condition Reported Permit Unit ID Unit DescriptionDuring Period? YES NO YES NO One(1)natural gas liquids (NGL) amine sweetening unit with a design capacity of 15,000 BBL/day. The amine solution is a specific formulated amine consisting of any combination of MEA,DEA, TEA, S009 MDEA, and DGA. This system includes a NGL/amine contactor, a flash tank, a natural gas fired regeneration reboiler(AIRS point 045) and two (2) electric amine recirculation pumps with a total design capacity of 100 gallons per minute. Thermal oxidizer burner is rated at 5.0 MMBtu/hr. S012/ Ajax DPC-2803LE,Natural Gas Fired 2-Stroke EU-285 Lean Burn Internal Combustion Engine, Site-rated at 550 HP, SN: 84286 Perry Gas Processors, Inc.Natural Gas Fired Amine S013 Unit Heater,Design Rated at 10.7 MMBtulhr, SN: 2885-0 S014 (point Born, Inc Natural Gas Fired Hot Oil Heater,Design 046) Rated at 32 MMBtu/hr, SN: 1963. S015/ Ajax DPC-2803LE,Natural Gas Fired 2-Stroke EU-286 Lean Burn Internal Combustion Engine, Site-rated at 550 HP, SN: 84308 S016/ Ajax DPC-2803LE,Natural Gas Fired 2-Stroke EU-287 Lean Burn Internal Combustion Engine, Site-rated at 550 HP, SN: 84288 S017/ Ajax DPC-2803LE,Natural Gas Fired 2-Stroke EU-288 Lean Burn Internal Combustion Engine, Site-rated at 550 HP, SN: 84287 S018/ Caterpillar G3516 TALE,Natural Gas Fired 4- EU-290 Stroke Lean Burn Internal Combustion Engine, Site- rated at 980 HP, SN: 4EK03529 S019/ Caterpillar G3516 TALE,Natural Gas Fired 4- EU 289 Stroke Lean Burn Internal Combustion Engine, Site- rated at 980 HP, SN: 4EK02747 S020/ Solar Centaur 40, Low-NOx, Natural Gas Fired Internal Combustion Turbine Engine,Nominally EU-291 Rated at 4,700 HP, SN:DCC0208 S021 Flare Industries Air-Assisted Process Flare NG TL 01 One(1) Truck Loadout of Pressurized Natural Gasoline Liquids One(1)Mitsubishi Model 4G63S4M natural gas or PLV PLC propane fired 4SLB engine, 80 HP, SN: SKM5668; GEN part of a Generac Generator package used for emergency electrical generation Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 244 Deviations noted Deviation MalfunctionrEmergency Operating During Period?' Code ' Condition Reported Permit Unit ID Unit DescriptionDuring Period? YES NO YES NO S022 One(1) John Deere 115 HP diesel-fired engine, powering a Grimmer Schmidt backup air compressor General Conditions Insignificant Activities 1 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 =CA111: 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 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 245 APPENDIX B: Monitoring and Permit Deviation Report - Part II FACILITY NAME: Kerr-McGee Gathering LLC — Fort Lupton Complex OPERATING PERMIT NO: 95OPWE13 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 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 246 EXAMPLE FACILITY NAME: Acme Corp. OPERATING PERMIT NO: 96OPZZXXX REPORTING PERIOD: 1/1/04 - 6/30/06 Is the deviation being claimed as an: Emergency Malfunction XX N/A (For NSPS/MACT) Did the deviation occur during: Startup Shutdown Malfunction Normal Operation OPERATING PERMIT UNIT IDENTIFICATION: Asphalt Plant with a Scrubber for Particulate Control - Unit XXX Operating Permit Condition Number Citation Section II, Condition 3.1 - Opacity Limitation Explanation of Period of Deviation Slurry Line Feed Plugged Duration START- 1730 4/10/06 END- 1 800 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 J. Garcia, APCD Deviation Code Division Code QA: Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 247 APPENDIX B: Monitoring and Permit Deviation Report - Part III REPORT CERTIFICATION SOURCE NAME: Kerr-McGee Gathering LLC — Fort Lupton Complex FACILITY IDENTIFICATION NUMBER: 123/0057 PERMIT NUMBER: 95OPWE013 REPORTING PERIOD: (see first page of the permit for specific reporting period and dates) All information for the Title V Semi-Annual Deviation Reports must be certified by a responsible official 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 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix C Compliance Certification Report Page 248 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: Kerr-McGee Gathering LLC — Fort Lupton Complex OPERATING PERMIT NO: 95OPWE013 REPORTING PERIOD: I. Facility Status During the entire reporting period, this source was in compliance with ALL terms and conditions contained in the Permit, each term and condition of which is identified and included by this reference. The method(s) used to determine compliance is/are the method(s) specified in the Permit. With the possible exception of the deviations identified in the table below, this source was in compliance with all terms and conditions contained in the Permit, each term and condition of which is identified and included by this reference, during the entire reporting period. The method used to determine compliance for each term and condition is the method specified in the Permit, unless otherwise indicated and described in the deviation report(s). Note that not all deviations are considered violations. Operating Deviations Monitoring etode Was compliance continuous p g Method per Permit Unit Description Reported' Permit?' or intermittent? Unit ID Previous Current YES NO Continuous Intermittent Fort Lupton Plant Fairbanks Morse MEP-12 Natural Gas Fired 2-Stroke Lean Burn Internal EU-33 Combustion Engine, Site rated at 2046 HP, Serial No.38D8780- 30S1S12. This unit is equipped with an Air/Fuel Ratio controller. Waukesha L7042GSI Natural Gas Fired 4-Stroke Rich Burn Internal EU 101 Combustion Engine,Rated at 1478 HP(manuf.maximum), Serial No. 288358. This unit is equipped with an Air/Fuel Ratio controller. F001 Fugitive Emissions from Equipment Leaks Caterpillar G3612TALE Natural Gas EU-38 Fired 4-Stroke Lean Burn Internal Combustion Engine, Low NOx design, Site rated at 3550 HP, Serial Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix C Compliance Certification Report Page 249 Deviations Monitoring etode Was compliance continuous Operating Method per p Permit Unit Description Reported' Permit?' or intermittent? Unit ID Previous Current YES NO Continuous Intermittent No. 1YG00238. Caterpillar G3612TALE Natural Gas Fired 4-Stroke Lean Burn Internal EU-39 Combustion Engine, Low NOx design, Site rated at 3550 HP, Serial No. 1YG00239. Waukesha L7042GSI Natural Gas Fired 4-Stroke Rich Burn Internal EU-34R Combustion Engine,Rated at 1232 HP(manuf.maximum), Serial No. 250451. This unit is equipped with an Air/Fuel Ratio controller. Caterpillar G3616 TALE Natural Gas Fired 4-Stroke Lean Burn Internal EU 103 Combustion Engine, Site rated at 4262 HP, Serial No.BLB00452. This unit is equipped with an Air/Fuel Ratio controller. Caterpillar G3616 LE Natural Gas Fired 4-Stroke Lean Burn Internal EU-104 Combustion Engine,Rated at 4735 HP(manuf.maximum), Serial No. BLB00539 This unit is equipped with an Air/Fuel Ratio controller. Waukesha L7042GSI Natural Gas Fired 4-Stroke Rich Burn Internal EU 32 Combustion Engine,Rated at 1232 HP, Serial No. 288792. This unit is equipped with an Air/Fuel Ratio controller. One(1) John Zink 65' Air-Assisted Process Flare used to control emissions from process equipment F-4 blowdowns associated with maintenance activities, compressor blowdowns, and venting such as for pressure relief valves or plant shutdowns. Serial No. 9148687 One(1)Caterpillar,Model C18 DITA, Serial Number EKW01075, diesel-fired,turbo-charged, GEN2 reciprocating internal combustion engine, site rated at 900 horsepower at 1800 RPM. This unit is used for emergency power generation. Platte Valley Plant Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix C Compliance Certification Report Page 250 Deviations Monitoring etode Was compliance continuous Operating Method per p Permit Unit Description Reported' Permit?'-- or intermittent? 3 Unit ID Previous Current YES NO Continuous Intermittent Ajax DPC-540LE,Natural Gas Fired S001/ 2-Stroke Lean Burn Internal EU-281 Combustion Engine, Site-rated at 514 HP, SN: 83891 Ajax DPC-540LE,Natural Gas Fired S002/ 2-Stroke Lean Burn Internal EU-282 Combustion Engine, Site-rated at 514 HP, SN: 83892 Ajax DPC-540LE,Natural Gas Fired S003/ 2-Stroke Lean Burn Internal EU-283 Combustion Engine, Site-rated at 514 HP, SN: 83889 Ajax DPC-540LE,Natural Gas Fired S004/ 2-Stroke Lean Burn Internal EU-284 Combustion Engine, Site-rated at 514 HP, SN: 83890 S007 Platte Valley Plant Fugitive Emissions One(1)natural gas liquids (NGL) amine sweetening unit with a design capacity of 15,000 BBL/day. The amine solution is a specific formulated amine consisting of any combination of MEA,DEA, TEA, MDEA, and DGA. This system S009 includes a NGL/amine contactor, a flash tank, a natural gas fired regeneration reboiler(AIRS point 045) and two (2) electric amine recirculation pumps with a total design capacity of 100 gallons per minute. Thermal oxidizer burner is rated at 5.0 MMBtu/hr. Ajax DPC-2803LE,Natural Gas Fired S012/ 2-Stroke Lean Burn Internal EU-285 Combustion Engine, Site-rated at 550 HP, SN: 84286 Perry Gas Processors, Inc.Natural S013 Gas Fired Amine Unit Heater,Design Rated at 10.7 MMBtu/hr, SN: 2885-0 S014 Born, Inc Natural Gas Fired Hot Oil (point Heater,Design Rated at 32 046) MMBtu/hr, SN: 1963. S015/ Ajax DPC-2803LE,Natural Gas Fired EU-286 2-Stroke Lean Burn Internal Combustion Engine, Site-rated at 550 Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix C Compliance Certification Report Page 251 Deviations Monitoring etode Was compliance continuous Operating Method per p Permit Unit Description Reported' Permit?'-- or intermittent? Unit ID Previous Current YES NO Continuous Intermittent HP, SN: 84308 Ajax DPC-2803LE,Natural Gas Fired S016/ 2-Stroke Lean Burn Internal EU-287 Combustion Engine, Site-rated at 550 HP, SN: 84288 Ajax DPC-2803LE,Natural Gas Fired S017/ 2-Stroke Lean Burn Internal EU-288 Combustion Engine, Site-rated at 550 HP, SN: 84287 Caterpillar G3516 TALE,Natural Gas S018/ Fired 4-Stroke Lean Burn Internal EU-290 Combustion Engine, Site-rated at 980 HP, SN: 4EK03529 Caterpillar G3516 TALE,Natural Gas S019/ Fired 4-Stroke Lean Burn Internal EU-289 Combustion Engine, Site-rated at 980 HP, SN: 4EK02747 Solar Centaur 40, Low-NOx,Natural S020/ Gas Fired Internal Combustion EU-291 Turbine Engine,Nominally Rated at 4,700 HP, SN: DCC0208 S021 Flare Industries Air-Assisted Process Flare NG-TL- One(1) Truck Loadout of Pressurized 01 Natural Gasoline Liquids One(1)Mitsubishi Model 4G63 S4M PLV PLC natural gas or propane fired 4SLB GEN engine, 80 HP, SN: SKM5668;part of a Generac Generator package used for emergency electrical generation One(1) John Deere 115 HP diesel- S022 fired engine,powering a Grimmer Schmidt backup air compressor General Conditions Insignificant Activities a 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. '- Note whether the method(s)used to determine the compliance status with each term and condition was the method(s) specified in the permit. If it was not,mark "no"and attach additional information/explanation. 'Note whether the compliance status with each term and condition provided was continuous or intermittent. "Intermittent Compliance"can mean either that noncompliance has occurred or that the owner or operator has data sufficient to certify compliance Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix C Compliance Certification Report Page 252 only on an intermittent basis. Certification of intermittent compliance therefore does not necessarily mean that any noncompliance has occurred. NOTE: The Periodic Monitoring requirements of the Operating Permit program rule are intended to provide assurance that even in the absence of a continuous system of monitoring the Title V source can demonstrate whether it has operated in continuous compliance for the duration of the reporting period. Therefore, if a source 1) conducts all of the monitoring and recordkeeping required in its permit, even if such activities are done periodically and not continuously, and if 2) such monitoring and recordkeeping does not indicate non-compliance, and if 3)the Responsible Official is not aware of any credible evidence that indicates non-compliance,then the Responsible Official can certify that the emission point(s) in question were in continuous compliance during the applicable time period. 4 Compliance status for these sources shall be based on a reasonable inquiry using readily available information. 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 Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix C Compliance Certification Report Page 253 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 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix D Notification Addresses Page 254 APPENDIX D Notification Addresses —January 27, 2020 Version 1. Air Pollution Control Division Colorado Department of Public Health and Environment Air Pollution Control Division Operating Permits Unit APCD-SS-B1 4300 Cherry Creek Drive S. Denver, CO 80246-1530 ATTN: Title V Unit Supervisor 2. United States Environmental Protection Agency Compliance Notifications: Enforcement and Compliance Assurance Division Air and Toxics Enforcement Branch Mail Code 8ENF-AT U.S. Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver, Colorado 80202-1129 502(b)(10) Changes, Off Permit Changes: Air and Radiation Division Air Permitting and Monitoring Branch Mail Code 8ARD-PM U.S. Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver, Colorado 80202-1129 Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix E Permit Acronyms Page 255 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 (40 CFR Part 60) P - Process Weight Rate in Tons/Hr PE - Particulate Emissions PM - Particulate Matter PMip - Particulate Matter Under 10 Microns Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix E Permit Acronyms Page 256 PSD - Prevention of Significant Deterioration PTE - Potential To Emit RACT - Reasonably Available Control Technology SCC - Source Classification Code SCF - Standard Cubic Feet SIC - Standard Industrial Classification SO2 - Sulfur Dioxide TPY - Tons Per Year TSP - Total Suspended Particulate VOC - Volatile Organic Compounds Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix F Permit Modifications Page 257 APPENDIX F Permit Modifications DATE OF TYPE OF SECTION NUMBER, DESCRIPTION OF REVISION REVISION REVISION CONDITION NUMBER Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix G Permit Modifications Page 258 APPENDIX G Compliance Assurance Monitoring Plan — Rich Burn Engines Background a. Emission Unit Description: EU-32: One (1) Waukesha L7042GSI Natural Gas Fired 4-Stroke Rich Burn Internal Combustion Engine, Rated at 1232 HP EU-101: One (1) Waukesha L7042GSI Natural Gas Fired 4-Stroke Rich Burn Internal Combustion Engine, Rated at 1478 HP EU-34R: One (1) Waukesha L7042GSI Natural Gas Fired 4-Stroke Rich Burn Internal Combustion Engine, Rated at 1232 HP b. Applicable Regulation, Emission Limit, Monitoring Requirements: Regulations: Operating Permit Section II, Condition 3A (EU-32), Condition 4.1 (EU-101), and Condition 6.1 (EU-34R) Emission Limitations: EU-32 —NOx: 23M tons/yr, CO: 50.6 tons/yr EU-101 -NOx: 11.2 tons/yr, CO: 11.2 tons/yr EU-34R-NOx: 23.8 tons/yr, CO: 35.7 tons/yr Monitoring Requirements: Catalyst inlet temperature and pressure drop across catalyst c. Control Technology: Non-Selective Catalytic Reduction Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix G Permit Modifications Page 259 II. Monitoring Approach Indicator 1 Indicator 2 I. Indicator Catalyst Inlet Temperature Pressure Drop Across the Catalyst Measurement Approach The temperature of the exhaust gas into the Pressure drop across the catalyst beds is catalyst will be measured using an in line measured using a differential pressure thermocouple. gauge. II. Indicator Range The exhaust gas into the catalyst shall be Pressure drop shall be within± 2 inches of greater than or equal to 750°F and less than water from the baseline value established as or equal to 1250°F. specified in SECTION IV - 12.1.1. Excursions trigger the permittee to Excursions trigger the permittee to investigate the engine performance and investigate the catalyst performance and make any repairs or adjustments necessary. make any repairs or adjustments necessary. Any adjustments or repairs shall be recorded Any adjustments or repairs shall be recorded in a log to be made available to the Division in a log to be made available to the Division upon request. upon request. In lieu of maintenance the source may choose to establish a new baseline pressure drop as specified in SECTION IV - 12.1.1. III. Performance Criteria a. Data Temperature is measured at the inlet to the The pressure drop across the catalyst is Representativeness catalyst. The minimum accuracy is±2%FS. measured while the engine is operating. The minimum accuracy is ±2%FS. b. Verification of NA NA Operational Status c. QA/QC Practices and Thermocouples shall be calibrated and Pressure gauges shall be calibrated and Criteria replace in accordance with manufacturer's replaced in accordance with manufacturer's recommendations. recommendations. d. Monitoring Frequency Daily Monthly e. Recordkeeping The catalyst inlet temperature shall be The pressure drop shall be recorded monthly recorded daily in a log to be made available in a log to be made available to the Division to the Division upon request. upon request. III. Justification a. Background The pollutant specific emission units are three (3) internal combustion engines used to drive compressors. Each engine is equipped with a non-selective catalytic reduction system to control NOx and CO emissions. b. Rational for Selection of Indicators Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix G Permit Modifications Page 260 The Division selected the pressure drop across the catalyst as it is an indicator of the catalyst performance. A change in the pressure drop across the catalyst can indicate if the catalyst is damaged or fouled, which would decrease catalyst performance. The inlet temperature to the catalyst was approved as an indicator since the temperature is important for the proper activation of the catalyst. The final RICE MACT requires continuous monitoring of the catalyst inlet temperature and monthly monitoring of pressure drop across the catalyst for 4-stroke Rich Burn engines using an NSCR catalyst for HAP/CO control. CO has been established in the rule as a surrogate for HAP. The CAM rule specifies that monitoring required for a MACT standard is presumptively acceptable monitoring, provided the monitoring is applicable to the performance of the control device (40 CFR Part 64 § 64.4(b)(4)). Since the MACT monitoring is for the same control device and the monitoring specified in the CAM plan is similar to the monitoring specified in the RICE MACT, the Division considers that the indicators are presumptively acceptable for CAM. c. Rational for Selection of Indicator Ranges The indicator ranges for the catalyst inlet temperature and the pressure drop cross the catalyst are the same ranges as specified in the final RICE MACT. The Division therefore considers that the indicator range is presumptively acceptable. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix H Permit Modifications Page 261 APPENDIX H Compliance Assurance Monitoring Plan — Lean Burn Engines Background a. Emission Unit Description: EU-103: One (1) Caterpillar G3616 TALE Natural Gas Fired 4-Stroke Lean Burn Internal Combustion Engine, Rated at 4262 HP EU-104: One (1) Caterpillar G3616 TALE Natural Gas Fired 4-Stroke Lean Burn Internal Combustion Engine, Rated at 4735 HP b. Applicable Regulation, Emission Limit, Monitoring Requirements: Regulations: Operating Permit Section II, Condition 7A (EU-103), Condition 8.1 (EU-104) Emission Limitations: EU-103 — CO: 7.6 tons/yr EU-104 - CO: 8.0 tons/yr Monitoring Requirements: Catalyst inlet temperature and pressure drop across catalyst c. Control Technology: These engines are equipped with oxidation catalysts for CO control. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix H Permit Modifications Page 262 II. Monitoring Approach Indicator 1 Indicator 2 I. Indicator Catalyst Inlet Temperature Pressure Drop Across the Catalyst Measurement Approach The temperature of the exhaust gas into the Pressure drop across the catalyst beds is catalyst will be measured using an in line measured using a differential pressure thermocouple. gauge. II. Indicator Range The exhaust gas into the catalyst shall be Pressure drop shall be within± 2 inches of greater than or equal to 450°F and less than water from the baseline value established as or equal to 1350°F. specified in SECTION IV - 12.1.2. Excursions trigger the permittee to Excursions trigger the permittee to investigate the engine performance and investigate the catalyst performance and make any repairs or adjustments necessary. make any repairs or adjustments necessary. Any adjustments or repairs shall be recorded Any adjustments or repairs shall be recorded in a log to be made available to the Division in a log to be made available to the Division upon request. upon request. In lieu of maintenance the source may choose to establish a new baseline pressure drop as specified in SECTION IV - 12.1.2. III. Performance Criteria a. Data Temperature is measured at the inlet to the The pressure drop across the catalyst is Representativeness catalyst. The minimum accuracy is±2%FS. measured while the engine is operating. The minimum accuracy is ±2%FS. b. Verification of NA NA Operational Status c. QA/QC Practices and Thermocouples shall be calibrated and Pressure gauges shall be calibrated and Criteria replace in accordance with manufacturer's replaced in accordance with manufacturer's recommendations. recommendations. d. Monitoring Frequency Daily Monthly e. Recordkeeping The catalyst inlet temperature shall be The pressure drop shall be recorded monthly recorded daily in a log to be made available in a log to be made available to the Division to the Division upon request. upon request. III. Justification a. Background The pollutant specific emission units are two (2) internal combustion engines used to drive compressors. Each engine is equipped with an oxidation catalyst to control CO emissions. b. Rational for Selection of Indicators Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix H Permit Modifications Page 263 The Division selected the pressure drop across the catalyst as it is an indicator of the catalyst performance. A change in the pressure drop across the catalyst can indicate if the catalyst is damaged or fouled, which would decrease catalyst performance. The inlet temperature to the catalyst was approved as an indicator since the temperature is important for the proper activation of the catalyst. The final RICE MACT requires continuous monitoring of the catalyst inlet temperature and monthly monitoring of pressure drop across the catalyst for 4-stroke Lean Burn engines using an oxidation catalyst for HAP/CO control. CO has been established in the rule as a surrogate for HAP. The CAM rule specifies that monitoring required for a MACT standard is presumptively acceptable monitoring, provided the monitoring is applicable to the performance of the control device (40 CFR Part 64 § 64.4(b)(4)). Since the MACT monitoring is for the same control device and the monitoring specified in the CAM plan is similar to the monitoring specified in the RICE MACT, the Division considers that the indicators are presumptively acceptable for CAM. c. Rational for Selection of Indicator Ranges The indicator ranges for the catalyst inlet temperature and the pressure drop cross the catalyst are the same ranges as specified in the final RICE MACT. The Division therefore considers that the indicator range is presumptively acceptable. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix I Permit Modifications Page 264 APPENDIX I Compliance Assurance Monitoring Plan —Natural Gas Liquids Amine Sweetening Unit I. Background a. Emission Unit Description: S009: One (1) Natural Gas Liquids Amine Sweetening Unit, rated at 15,000 bbl/day (AIRS point 043) b. Applicable Regulation, Emission Limit, Monitoring Requirements: Regulation: Operating Permit SECTION III - 3.2 Emission Limit: VOC — 1.1 tons/yr Monitoring Requirements: Thermal oxidizer combustion chamber temperature c. Control Technology: Still vent and flash tank emissions from the NGL amine unit are routed to a recuperative thermal oxidizer with a DRE of 99% for VOC and HAP control. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix I Permit Modifications Page 265 II. Monitoring Approach Compliance Indicator I. Indicator Thermal Oxidizer Combustion Chamber Temperature Measurement Approach The temperature of the thermal oxidizer combustion chamber will be measured using a thermocouple or equivalent heat sensing device. II. Indicator Range An excursion is defined as any temperature reading below 1400°F, or the temperature established during the most recent stack test demonstrating compliance with permitted limits and approved by the Division. Excursions trigger an investigation to determine the problem and to perform corrective action, recordkeeping related to the problem, and reporting of the problem when necessary. III. Performance Criteria a. Data Temperature is measured at the outlet of the combustion chamber. The Representativeness minimum accuracy is ±2% Full Scale. b. Verification of Operational Temperature reading within indicated range. Status c. QA/QC Practices and The thermocouple or equivalent heat sensing device shall be calibrated and Criteria maintained pursuant to manufacturer specifications. d. Monitoring Frequency The thermocouple shall continuously monitor the combustion chamber temperature. Daily records shall be kept of combustion chamber temperature. e. Data Collection Procedures Temperature automatically or manually recorded daily. Excursions and any adjustments or repairs made to the thermal oxidizer following an excursion shall be recorded in a log. f. Averaging Time None — thermocouple shall operate continuously. III. Justification a. Background The pollutant specific emissions unit is a natural gas liquids amine sweetening unit, which functions to remove acid gases from the inlet NGL stream. Flash tank emissions and still vent emissions from the amine regeneration system are routed to the recuperative thermal oxidizer for VOC and HAP control. b. Rational for Indicators The destruction of VOC/HAP is dependent on effective combustion. The combustion chamber temperature must meet a minimum temperature in order to achieve optimal combustion,resulting in the destruction efficiency necessary to comply with permitted limits. c. Rational for Indicator Ranges Construction permit 12WE1277 set a minimum operating temperature of 1400°F, or the temperature established during the most recent stack test approved by the Division, for the Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix I Permit Modifications Page 266 thermal oxidizer. Compliance tests have indicated that the thermal oxidizer can achieve the stated DRE of 99% with a temperature set point at 1400°F. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix J Permit Modifications Page 267 APPENDIX J Compliance Assurance Monitoring Plan — Truck Loadout of Pressurized Natural Gasoline Liquids I. Background a. Emission Unit Description: NG-TL-01: One (1) Truck Loadout of Pressurized Natural Gasoline Liquids (AIRS point 043) b. Applicable Regulation, Emission Limit, Monitoring Requirements: Regulation: Operating Permit SECTION III - 10.1 Emission Limit: VOC — 5.9 tons/yr Monitoring Requirements: Presence of pilot light on enclosed combustion device during loadout of natural gasoline liquids c. Control Technology: Vapors produced during truck loadout of natural gasoline liquids are routed to an enclosed combustion device with a DRE of 95% for VOC and HAP control. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix J Permit Modifications Page 268 II. Monitoring Approach Compliance Indicator I. Indicator Presence of Enclosed Combustion Device (ECD) Pilot Flame during loadout operations Measurement Approach Presence of a pilot flame is monitored with a thermocouple or equivalent heat sensing device during each loadout operation. II. Indicator Range An excursion is defined as any absence of a pilot flame for the ECD during a loadout event. Excursions trigger an investigation to determine the problem and to perform corrective action, recordkeeping related to the problem, and reporting of the problem when necessary. III. Performance Criteria a. Data A thermocouple or equivalent heat sensing device will determine the presence Representativeness or absence of a flame. b. Verification of Operational The observation of the presence of a flame will indicate that the device is Status operational. c. QA/QC Practices and The thermocouple or equivalent heat sensing device shall be calibrated and Criteria maintained pursuant to manufacturer specifications. d. Monitoring Frequency The thermocouple or equivalent heat sensing device shall monitor the presence of the pilot flame during loading operations. A record of pilot light presence shall be maintained for each loading event. e. Data Collection Procedures The presence of absence of the ECD pilot light is automatically or manually recorded for each loadout event. Excursions and any adjustments or repairs made to the ECD following an excursion shall be recorded in a log. f. Averaging Time None Presence/absence of flame recorded for each event III. Justification a. Background The pollutant specific emissions unit is a truck loadout of pressurized natural gasoline liquids. Emissions from the natural gasoline loadout, including flashing emissions associated with the drop to atmospheric pressure in the tanker truck, are routed to the enclosed combustion device for VOC and HAP control. b. Rational for Selection of Performance Indicators and Indicator Ranges The enclosed combustion device (ECD) has a manufacturer's guaranteed hydrocarbon destruction efficiency of 95% when operational. The ECD is not continuously operating but is started up before each loading event. The thermocouple will determine the presence of a pilot flame, verifying that the ECD is operational when loadout events occur. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix K Permit Modifications Page 269 APPENDIX K Engine AOS Applicability Reports ver 10/12/12 Note: A MS Word version of this Appendix can be found at: https:/ www colorado.gov pacific;cdpheialtcrnate-operating-scenario-aos-reporting-forms DISCLAIMER: These are only example reports and do not cover all possible requirements. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix K Permit Modifications Page 270 Engine AOS Applicability Report Certification Language All information for the Applicability Reports must be certified by either 1) for Operating Permits, a Responsible Official as defined in Colorado Regulation No. 3, Part A, Section LB. 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. 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. Further, I agree that by signing and submitting these documents I agree that any new requirements identified in the Applicability Report(s) shall be considered to be Applicable Requirements as defined in Colorado Regulation No. 3, Part A, Section I.B., and that such requirements shall be enforceable by the Division and its agents and shall be considered to be revisions to the underlying permit(s) referenced in the Report(s) until such time as the Permit is revised to reflect the new requirements. 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 Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix K Permit Modifications Page 271 Colorado Regulation No. 7 Part E, Sections I.A through I.D DISCLAIMER: This is only an example report and does not cover all possible Reg 7 requirements. Company: Acme Gas Processing Source ID: 9991234 Permit #: 93OPXX999 Date: October 1, 2008 Determination of compliance and reporting requirements for a Manufacturer: BestEngineCompany Model: 777 LowNox Nameplate HP: 1340 Construction date: July 1, 2007 Note: If the engine is exempt from a requirement due to construction date or was relocated from within Colorado, supporting documentation must be provided. Determination of Regulation No. 7 requirements: Regulation No. 7, Part E, §§ LA through LC n Does not apply to this engine. Engine is not located in the ozone nonattainment area or does not have a manufacturer's design rate greater than 500 horsepower or did not commence operation on or after June 1, 2004. n Does apply to this engine and applicable emissions controls have been installed. Regulation No. 7, Part E, § I.D n Does not apply to this engine. Engine does not have a maximum horsepower greater than or equal to 100 or the construction or relocation date precedes the applicability dates. n Does apply to this engine. The following emission limits apply to the engine: NOx (g/hp-hr): 2.0 CO (g/hp-hr): 4.0 VOC (g/hp-hr): LO Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix K Permit Modifications Page 272 Max Engine Construction or Emission Standards in g/hp-hr HP Relocation Date NOx CO VOC 100<Hp<500 January 1, 2008 2.0 4.0 1.0 January 1, 2011 1.0 2.0 0.7 500>Hp July 1, 2007 2.0 4.0 LO July 1, 2010 1.0 2.0 0.7 Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix K Permit Modifications Page 273 NSPS JJJJ Example Report Format DISCLAIMER: This is only an example report and does not cover all possible JJJJ requirements. Note that as of October 12, 2012 that the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS JJJJ will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, § I.C, upon adoption of NSPS JJJJ into Regulation No. 6, Part A, an internal combustion engine relocated from outside of the State of Colorado into the State of Colorado shall meet the most recent emission standard required in NSPS JJJJ. Engines with a manufacturer's rated horsepower of less than 500 and with a relocation date no later than 5 years after the manufacture date are exempt from this requirement per Regulation No. 6, Part B, Section I.C.2.a. Relocation is defined in Section I.C.l.a. NSPS Subpart JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines Company: Acme Gas Processing Source ID: 9991234 Permit #: 93OPXX999 Date: October 1, 2008 Manufacturer: BestEngineCompany Model: 777 LowNox Nameplate HP: 1340 Engine Type: 2 Stroke Rich Burn Manufacture Date: July 1, 2007 Date Engine Ordered: April 1, 2007 Note: If the engine is exempt from a requirement due to construction/manufacture date, supporting documentation must be provided. Upon adoption of NSPS Subpart JJJJ into Colorado Regulation No. 6, Part A, if the engine is exempt because the engine was relocated within the state of Colorado, supporting documentation must be provided. n NSPS JJJJ does not apply to this engine. n NSPS JJJJ does apply to this engine. Note: Using the format below, the source must submit to the Division an analysis of all of the NSPS JJJJ applicable requirements that apply to this specific engine. The analysis below is an example only, based on a hypothetical engine that is a rich burn engine, greater than 500 HP, with a manufacture date after July 1, 2007. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix K Permit Modifications Page 274 Determination of NSPS JJJJ requirements: 60.4230 Applicability (a)(4)(i) Applies to this engine since it is a rich burn engine, greater than 500 HP, with a manufacture date after July 1, 2007. 60.4233 Emission Standards for Owners and Operators (e) Owners and operators of stationary SI ICE with a maximum engine power greater than 100 HP must comply with the standards in Table 1. Non-Emergency SI, Natural Gas, HP>500, Manufactured after 7/1/2007 NOx 2.0 g/HP-hr or 160 ppmvd @ 15% O2 CO 4.0 g/HP-hr or 540 ppmvd @ 15% O2 VOC 1.0 g/HP-hr or 86 ppmvd@15% O2 Other Requirements for Owners and Operators 60.4234 Emission standards must be met for the lifetime of the engine. 60.4235 N/A - Sulfur content of gasoline. 60.4236 N/A (for now) - After July 1, 2009 owners and operators may not install engines with a power rating≥ 500HP that do not meet the emissions standards in 60.4233. 60.4237 N/A - Emergency Engines. 60.4238 - 60.4242 Compliance Requirements for Manufacturers — (Not Applicable) 60.4243 Compliance Requirements for Owners and Operators (b)(2)(ii) To maintain compliance with the emission limits in 60.4233, owners of SI ICE > 500HP must: • Keep a maintenance plan; • Keep records of conducted maintenance; • Maintain and operate the engine in a manner consistent with good air pollution control practice for minimizing emissions; • Conduct an initial performance test; and • Conduct subsequent performance tests every 8,760 hours or every three years, which ever comes first, in order to demonstrate compliance with the emission limits. (g) Air to fuel ratio controllers (AFRCs) must be maintained and operated appropriately in order to ensure proper operation of the engine and control device to minimize emissions at all times. 60.4244 Testing Requirements for Owners and Operators (a) Each performance test must be conducted within 10% of the highest achievable load and must comply with the testing requirements listed in 60.8 and Table 2 of NSPS JJJJ. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix K Permit Modifications Page 275 (b) Performance tests may not be conducted during periods of startup, shutdown, or malfunction, as specified in 60.8(c). If the engine is non-operational when a performance test is due, the engine does not need to be started up just to test it, but will need to be tested immediately upon startup. (c) Three separate test runs must be conducted for each performance test as specified by 60.8(f). Each run must be within 10% of max load and be at least 1 hour in duration. (d) To determine compliance with the NOR, CO, and VOC mass per unit output emission limitations, the measured concentration must be converted using the equations outlined in this section of NSPS JJJJ. 60.4245 Notification, Reports, and Records for Owners and Operators (a) Owners of all stationary SI ICE must keep records of the following: (1) All notifications submitted to comply with this subpart; (2) Maintenance conducted on the engine; (3) N/A - Manufacturer information for certified engines, and (4) Documentation that shows non-certified engines are in compliance with the emission standards. (b) N/A — For emergency engines only. (c) Owners of non-certified engines > 500HP must submit an initial notification as required in 60.7(a)(1) which includes the following information: (1) Name and address of the owner or operator; (2) The address of the affected source; (3) Engine information including make, model, engine family, serial number, model year, maximum engine power, and engine displacement; (4) Emission control equipment; and (5) Fuel used. CONCLUSION OF FINDINGS (EXAMPLE ONLY) In general, Acme's 1,235HP, Waukesha 7042 GSI engine is subject to the emissions limitations summarized in Table 1 of NSPS JJJJ. ACME will meet these emission limitations using an AFRC and a non-selective catalytic converter(NSCR). These emission rates will be met throughout the life of the engine. A maintenance plan will be kept and all maintenance activities will be recorded. Compliance with the emission limits will be confirmed by the initial performance tests, which shall be conducted following the procedures outlined in 60.4244. Copies of performance test results will be submitted within 60 days of the completion of each test. Since this is an uncertified engine, an initial notification will be submitted including all of the requested information in 40.4245 within 30 days of startup. ACME will keep records of all compliance related materials. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix K Permit Modifications Page 276 MACT ZZZZ Example Report Format DISCLAIMER: This is only an example report and does not cover all possible ZZZZ requirements. MACT Subpart ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Company: Acme Gas Processing Source ID: 9991234 Permit #: 93OPXX999 Date: October 1, 2008 Manufacturer: BestEngineCompany Model: 777 LowNox Nameplate HP: 1340 Engine Type: 2 Stroke Rich Burn Manufacture Date: July 1, 2007 Date Engine Ordered: April 1, 2007 Note: If the engine is exempt from a requirement due to construction/reconstruction date, supporting documentation must be provided. ▪ MACT ZZZZ does not apply to this engine. n MACT ZZZZ does apply to this engine. Note: Using the format below, the source must submit to the Division an analysis of all of the MACT ZZZZ applicable requirements that apply to this specific engine. The analysis below is an example only, based on a hypothetical new engine located at a major source of HAP emissions. Determination of MACT ZZZZ requirements: 63.6585 Applicability This subpart is applicable to Acme's engine since they are going to be operating a new stationary reciprocating internal combustion engine (RICE) at a major source of HAP emissions. 63.6590 What Parts of My Plant Does This Subpart Cover? This subpart covers Acme's new stationary reciprocating internal combustion engine. 63.6595 When do I have to comply with this Subpart? (a)(5) The engine must comply with the applicable emission limitations and operating limitations upon startup. 63.6600 Emission and operating limitations for RICE site rated at more than 500 hp Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix K Permit Modifications Page 277 (a) The engine is subject to the emission limits in Table la and the operating limits in Table lb. ACME will meet the emission limitations by reducing formaldehyde emissions by 76 percent and will maintain the catalyst such that the pressure drop does not change by more than 2 inches of I-I1O at 100 % load plus or minus 10 percent from the pressure drop measured during the initial performance test and will maintain the temperature of the engine exhaust so that the catalyst inlet temperature is greater than or equal to 750 ° F and less than or equal to 1250 ° F. The engine will be equipped with non-selective catalytic reduction and an air fuel controller to meet the emission limitations. 63.6601 & 63.6611 Requirements for 4SLB engines between 250 and 500 hp These requirements do not apply. 63.6605 General Requirements (a) The engine will comply with the emission and operating limitations at all times, except during periods of startup, shutdown and malfunction (SSM) (b) The engine, including air pollution control and monitoring equipment shall be operating in a manner consistent with good air pollution control practices for minimizing emissions at all times, including during SSM. 63.6610 Initial performance test (a) The performance tests specified in Table 4 (select sampling port and measure O2, moisture and formaldehyde at inlet and outlet of the control device) shall be conducted within 180 days of startup. (b) & (c) Not applicable. Construction did not commence between 12/19/02 and 6/15/04. (d) Previous performance tests have not been conducted on this unit within two years, therefore, this provision does not apply. 63.6615 Subsequent performance tests Subsequent tests will be conducted as specified in Table 3. No additional testing is required for 4SRB engines meeting the formaldehyde percent reduction requirements. 63.6620 Performance test procedures (b) Tests must be conducted at 100 % load plus or minus 10% (c) Tests may not be conducted during periods of SSM. (d) Must conduct three 1-hr test runs (e) Equation (e)(l) shall be used to determine compliance with the percent reduction requirement. (f), (g) & (h) Not applicable (i) Engine load during test shall be determined as specified in this paragraph. 63.6625 Monitoring, installation, operation and maintenance requirements (a), (c) & (d) Not applicable Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix K Permit Modifications Page 278 (b) A continuous parameter monitoring system (CPMS) shall be installed to measure the catalyst inlet temperature. The CPMS will meet the requirements in § 63.8. 63.6630 Demonstrating initial compliance (a) Initial compliance shall be determined in accordance with Table 5 (initial performance test must indicate formaldehyde reduction of 76 percent or more, a CPMS must be installed to measure inlet temperature of the catalyst and the pressure drop and catalyst inlet temperature must be recorded during the initial performance test). (b) Pressure differential will be established during the initial performance test. (c) Notification of compliance status will be submitted and will contain the results of the initial compliance demonstration. 63.6635 Monitoring to demonstrate continuous compliance (b) Except for monitor malfunctions, associated repairs, and required QA/QC activities monitoring must be continuous at all time the engine is operating. (c) Data recorded during monitoring malfunctions, associated repairs and required QA/QC activities must not be used in data averages and calculations to report operating levels, however, all the valid data collected during other periods shall be used. 63.6640 Demonstrating continuous compliance (a) Continuous compliance will be demonstrated as specified in Table 6 (collect catalyst inlet temperature data,reduce that data to 4-hr rolling average and maintain the 4-hr rolling averages to within the operating limitation and measuring the pressure drop across the catalyst once per month and demonstrating that the pressure drop meets the operating limitation). (b) Deviations from the emission and operating limitations must be reported per § 63.6550. If catalyst is changed the operating parameters established during the initial performance test must be re-established. When operating parameters re-established a performance test must also be conducted. 63.6645 Notifications (a) Submit notifications in §§ 63.7(b) & (c), 63.8(e), (f)(4) and (f)(6), 63.9(b) thru (e) & (g) & (h) that apply by dates specified. (b) Not applicable. Acme unit started after effective dated for Subpart ZZZZ. (c) Submit initial notification within 120 days after becoming subject to Subpart ZZZZ. (d) thru (f) Not applicable. Acme engine greater than 500 hp and subject to requirements in Subpart ZZZZ. (g) & (h) Submit notification of intent to conduct performance test and notification of compliance status. 63.6650 Reports (a) Submit reports required by Table 7 (compliance report and SSM reports (if actions inconsistent with SSM plan) (b) Not applicable, an alternate schedule for report submittal has been approved. Reports will be submitted with Title V reports. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE Air Pollution Control Division Colorado Operating Permit Appendix K Permit Modifications Page 279 (c) Compliance reports to contain the following information: company name and address, statement by responsible official certifying accuracy, date of report and beginning and end of reporting period, if SSM the information in 63.10(d)(5)(i), if no deviations a statement saying that, if no periods when CPMS out of control a statement saying that. (d) Not applicable, using CPMS (e) For each deviation the information in (e)(1) thru (e)(12) shall be provided. (f) Applicable. Compliance reports are submitted with Title V reports. Compliance reports under Subpart ZZZZ include all necessary info for Title V deviation report with respect to Subpart ZZZZ requirements. (g) Not applicable. Acme engine not firing landfill or digester gas. 63.6655 Recordkeeping (a) Retain records as follows: copy of each notification and report (including all documentation supporting any initial notification or notification of compliance status), records in 63.6(e)(iii) thru (v) related to SSM, and records of performance tests and evaluations. (b) CPMS records including records in 63.10(b)(2)(vi) thru (xi), previous versions of the performance evaluation plan required by 63.8(d)(3) and requests for alternatives to the relative accuracy test for CPMS as required by 63.8(f)(6)(i). (c) Not applicable. Acme engine not firing landfill or digester gas. (d) Will keep records required in Table 6 (monthly pressure drop readings, 4-hr averages of catalyst inlet temperature) to show continuous compliance with emission and operating limits. 63.6660 Form and length of records (a) Records must be in a form suitable and readily available for expeditious review. (b) Records must be retained for five years. (c) Records must be retained on-site for first 2 years, may be retained off-site for the remaining 3 years. 63.6665 General Provisions This engine must comply with the general provisions as indicated in Table 8. CONCLUSION OF FINDINGS (EXAMPLE ONLY) Since this engine is subject to the requirements of MACT Subpart ZZZZ. The engine will be installed with a non-selective catalyst to meet the formaldehyde reduction requirement of 76% or more. An initial performance test will be conducted within 180 days of startup to demonstrate compliance with the formaldehyde percent reduction requirement. During the initial performance test, the pressure drop across the catalyst will be measured. A CPMS will be installed to measure the catalyst inlet temperature. Continuous compliance will be demonstrated by keeping the 4-hr rolling averages of catalyst inlet temperature within the operating limitations and recording the pressure drop across the catalyst monthly and demonstrating that the pressure drop is within the operating limitation. Records, notifications and reports will be submitted as required. To that end required reports and notifications include initial notification, notice of intent to conduct performance test, notification of compliance status, SSM reports (if required) and semi-annual compliance reports. Operating Permit 95OPWE013 First Issued: October 1, 1998 Renewed: DATE TECHNICAL REVIEW DOCUMENT For DRAFT RENEWAL OF OPERATING PERMIT 95OPWE013 Kerr-McGee Gathering LLC — Fort Lupton Complex — Fort Lupton plant Weld County Source ID 123/0057 Issued DATE Operating Permit Engineer: Joshua Jones Operating Permit Supervisor review: Blue Parish Oil & Gas Unit review: Craig Giesecke 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 Fort Lupton and Platte Valley gas plants, which are part of the Fort Lupton Gas Processing Complex. The previous Operating Permit for this facility was issued on October 1 , 1998, was last revised on July 3, 2002 and expired on October 1 , 2003. Multiple requests for modifications to the operating permit have been submitted since the latest revision. Information on these modification requests and how they were incorporated into the operating permit can be found in Section IV: Modifications Requested by the Source and Section V: Emission Units. 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 various applications (as described in Section IV: Modifications Requested by the Source), 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 https://www.colorado.gov/cdphe/title-v-operating-permits. 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 00123/0057 Page 1 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit without applying for a revision to this permit or for an additional or revised construction permit. II. Description of Source The Fort Lupton Gas Processing Complex consists of three operating facilities and one permitted facility: Fort Lupton Gas Plant, Platte Valley Gas Plant, Lancaster Gas Plant, and Lancaster 3 Plant. The Platte Valley Gas Plant was acquired by Kerr-McGee from Encana Oil & Gas USA on March 1, 2011 , and was determined by the Division to be a single stationary source with the Fort Lupton gas plant according to the definition of stationary source in Colorado Regulation No. 3, Part A, Section I.B.43 (same industrial grouping, contiguous or adjacent properties, and under common control). Colorado Construction Permit 12WE1492 was issued to Kerr-McGee Gathering LLC on June 4, 2014 for the construction of the Lancaster Gas Plant adjacent to the Fort Lupton Gas Plant. Construction Permit 17WE1059 was issued on August 7, 2018 for the Lancaster 3 Plant. All four facilities are now considered a single stationary source. Fort Lupton is a natural gas processing facility, designated under Standard Industrial Classification 1321 . Fort Lupton receives both high and low pressure gas. Low pressure field gas is routed through inlet slug catchers, which capture free liquids through natural separation. These liquids are routed to stabilization processes, including de-ethanization (removal of ethane and lighter fractions from the gas stream), and are stored in atmospheric storage tanks. Field gas undergoes compression and is commingled with high pressure gas (from Hudson Compressor Station) for natural gas liquids recovery using propane refrigeration and Joules-Thomson (JT) expansion. Produced natural gas liquids are stored in pressurized bullet tanks. Platte Valley is a natural gas processing plant designated under SIC 1321 . This facility is designed to process natural gas to pipeline specifications and to recover and fractionate natural gas liquids. Free liquids are captured in the inlet slug catchers and routed to stabilization processes and then to natural gas liquid fractionation. Inlet gas is compressed and routed to one of two cryogenic processing trains for natural gas liquids recovery. Recovered natural gas liquids are treated to remove H2S and CO2 in an amine unit controlled by a thermal oxidizer. Treated natural gas liquids are sent to two fractionation trains which separate out ethane, propane, butane, and natural gasoline. Natural gas liquids and fractionated products are stored in pressurized tanks prior to sales. Lancaster is a natural gas processing plant designated under SIC 1321, located adjacent to the existing Fort Lupton facility. Lancaster receives third party gas from the Kerr- McGee Gathering LLC pipeline system. CO2 and H2S are removed from the inlet gas stream using four (4) 165 MMscfd amine treaters, each controlled by a thermal oxidizer and utilizing a hot oil heater for rich amine regeneration. The gas stream is then dehydrated using a molecular sieve. The dry gas is run through the cryogenic unit to super-cool the gas and remove natural gas liquids. The cryogenic unit is supplemented by six (6) 3,000 horsepower electric motor driven propane refrigeration compressors. Residue gas from the cryogenic unit is compressed using four (4) 12,000 horsepower electric motor driven compressors for delivery to the gas pipeline. Produced natural gas liquids are stored in pressurized tanks and transported from the facility via a pipeline. 123/0057 Page 2 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit Construction Permit 12WE1492 was originally issued for the Lancaster Plant on June 4, 2013. A modification was issued on June 11 , 2015 to split the fugitive emissions into two points and to increase total fugitive emissions limits. A second modification was issued on August 11 , 2017 to remove the GHG BACT requirements from the permit, to increase the plant capacity by 10%, and to include uncontrolled emissions for the plant flares. A third modification was issued on August 8, 2019 to increase VOC, H2S, and SOx emissions from each amine unit and associated thermal oxidizer to account for variability in waste gas stream composition. Lancaster 3 is a natural gas processing plant designated under SIC 1321 , located at the Fort Lupton Complex. Construction Permit 17WE1059 was issued for the Lancaster 3 plant on August 7, 2018. This plant consists of two natural gas processing trains, each comprised of a hydrogen sulfide treating bed, an amine contactor, a molecular sieve natural gas dehydrator, a natural gas fired molecular sieve regenerator heater, and cryogenic processing equipment operated with electrical compression. One amine regeneration system is shared between the processing trains, which consists of one amine regenerator, one flash tank, and one natural gas fired amine regeneration heater. Lancaster 3 also has one thermal oxidizer for control of waste gas from the amine regenerator, a process flare, fugitive equipment leaks, and a diesel-fired engine for backup electricity generation. As of the date of permit issuance [DATE] none of the equipment permitted for the Lancaster 3 plant has commenced operation. Since the significant work done on this operating permit was performed while the state of the Lancaster plant was in a transition to obtaining revised permit limits and requirements, and the current Fort Lupton and Platte Valley facilities are significantly past their five year renewal date requirements, the Division has decided to issue a revised operating permit that contains only the requirements for the Fort Lupton and Platte Valley plants. The provisions for the Lancaster Plant and any additions will be incorporated into this operating permit upon receipt of the modification applications for the revised permits. This stationary source is located approximately five miles northeast of Fort Lupton in Weld County, Colorado. The Fort Lupton Gas Plant is located at 16116 Weld County Road 22. The Lancaster Gas Plant is located at 16270 Weld County Road 22. The Platte Valley Gas Plant is located at 16157 Weld County Road 22. Lancaster 3 will also be located at 16116 Weld County Road 22 when constructed. This stationary source is located in an area classified as attainment for all pollutants except ozone. It is classified as non-attainment for the 8-hour ozone standard and is part of the 8-hour Ozone Control Area as defined in Regulation No. 7, Section II.A.1 . The 8- hour Ozone Control Area has been classified as a serious non-attainment area effective January 27, 2020. There are no affected states within 50 miles of the stationary source. Rocky Mountain National Park is a Federal Class I designated area within 100 km of the plant. This stationary source is categorized as a NANSR major stationary source (Potential to Emit of VOC and NOx ? 100 Tons/Year). Future modifications at this facility resulting in a significant net emissions increase (see Reg 3, Part D, Sections II.A.27 and 44) for VOC 123/0057 Page 3 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit or NOx or a modification which is major by itself (Potential to Emit of > 100 TPY of either VOC or NOx) may result in the application of the NANSR review requirements. This stationary source is categorized as a PSD major stationary source (Potential to Emit > 250 Tons/year for CO). Future modifications at this facility resulting in a significant net emissions increase (see Reg 3, Part D, Sections II.A.27 and 44) or a modification which is major by itself (Potential to Emit > 250 TPY) for any pollutant listed in Regulation No. 3, Part D, Section II.A.44 for which the area is in attainment or attainment/maintenance may result in the application of the PSD review requirements. Emissions (in tons/yr) for the Fort Lupton and Platte Valley plants are as follows: Pollutant Potential to Emit (tpy) Actual Emissions (tpy) NOx 497.1 392.4 VOC 267.5 227.81 CO 360.2 263.29 PM 23.3 4.34 Highest HAP: 27.0 17.05 Formaldehyde Total HAPs 60.1 29.76 Actual emissions have been compiled from the Division's CACTIS database for Inventory Year 2018. Detailed information on the Potential to Emit for units at the Fort Lupton and Platte Valley plants can be found at the end of this document. Ill. Applicable Requirements A Consent Decree (Civil Action No. 1 :07-cv-01034) between the U.S. EPA, the State of Colorado and Kerr-McGee Corporation was lodged with the U.S. District Court for the District of Colorado on May 17, 2007 and entered on March 27, 2008. This Consent Decree alleged violations of the Clean Air Act by Kerr-McGee and contained various emission reduction, administrative and reporting requirements for Kerr-McGee. Kerr- McGee has fulfilled all obligations of the consent decree related to the Fort Lupton facility, therefore, no applicable requirements are required to be added to this permit, however, modifications received according to the obligations of the Consent Decree have been incorporated into the operating permit as specified in Section IV: Modifications requested by the Source, below. 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 This complex is subject to the provisions of Section 112(r) of the Federal Clean Air Act. The most recent plan was submitted to the EPA on August 17, 2016. 123/0057 Page 4 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit 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: Point 030 (EU-32) for NOx and CO Point 017 (EU-101) for NOx and CO Point 025 (EU-34R) for NOx and CO Point 026 (EU-103) for CO Point 028 (EU-104) for CO All other emission units at this facility are not subject to the CAM provisions since they either have pre-control emissions below the major source threshold, are uncontrolled, are not subject to an emission limitation or standard for the applicable regulated air pollutant, or are only subject to an emission limitation or standard that is exempt under §64.2(b)(1)). Source Determination With this permit action, the Division revisited the source determination in regards to the natural gas operations in the area surrounding the Fort Lupton Gas Processing Complex to verify that the proper pollutant emitting activities are included in this permit as part of the facility. The applicant did not identify any other pollutant emitting activities in the vicinity of the facility that are dependent upon the facility to maintain operations. The Division considers the current determination for this facility to be accurate, and the proper pollutant emitting activities are included in this permit. Hazardous Air Pollutants (HAPs) The Fort Lupton Gas Plant is considered a major source of HAP with a potential to emit, considering controls, of more than 10 tons per year of any hazardous air pollutant and more than 25 tons per year of any combination of hazardous air pollutants. Applicability for specific subparts of 40 CFR Part 63 for National Emissions Standards for Hazardous Air Pollutants is found below. RACT — Colorado Regulation No. 3, Part B, Section III.D.2 and Regulation No. 7, Section II.C There are no emission sources at the Fort Lupton plant which necessitated a case by case analysis to satisfy the RACT requirements of Colorado Regulation No. 3, Part B, Section III.D.2 and Colorado Regulation No. 7, Part A, Section II.C.2. All sources are currently subject to a specific requirement in Colorado Regulation No. 7, are exempt from permitting requirements according to Regulation No. 3, Part B, Section II.D, or are currently subject to a federal maximum achievable control technology standard under 40 CFR Part 63 or a New Source Performance Standard under 40 CFR Part 60 that qualifies as RACT. No new or additional RACT requirements have been included pursuant to 123/0057 Page 5 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit Section III.D.2 since no units are being added or modified as part of this permitting action where RACT requirements were not already satisfied. Kerr-McGee has submitted a General Emission Limitation RACT analysis for the Fort Lupton plant, required under Regulation No. 7, Part A, Section 11.0.1.c.(ii) for existing sources with potential emissions greater than or equal to 100 tons per year of VOC. The Division sent a letter, dated August 5, 2009, stating that the facility was in compliance with Regulation No. 7 RACT requirements based on the information provided in the RACT analysis. The SIP RACT requirements of Reg. 7, Part E, Section II.A for combustion equipment have been included in the operating permit. These are discussed in the Regulation No. 7 section below. 40 CFR 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 Insignificant Tanks In a response to an information request, received on August 1, 2019, Kerr-McGee stated that none of the tanks listed as insignificant activities in Appendix A, as provided in the application received on April 21 , 2015, are subject to NSPS Kb. 40 CFR 60 Subpart KKK — Standards of Performance for Equipment Leaks of VOC From Onshore Natural Gas Processing Plants for Which Construction, Reconstruction, or Modification Commenced After January 20, 1984, and on or Before August 23, 2011 The fugitive emissions associated with the original issuance of this operating permit were not considered subject to NSPS KKK since the facility was not considered a natural gas processing plant (no natural gas liquid extraction) at the time. This facility subsequently underwent modifications in 2001 that included processes for natural gas liquids extraction. This facility is now classified as a natural gas processing plant (as defined in §60.631) subject to the provisions of this rule. In a response to an information request, received on May 2, 2017, Kerr-McGee indicated that additional modifications to the inlet of the plant had been completed in 2014 that qualified as a modification under the provisions of 40 CFR §60.14, thus subjecting the affected process units to the requirements of NSPS OOOO. Kerr-McGee elected to comply with the leak detection and repair (LDAR) requirements of NSPS OOOO for the entire facility at the time for consistency throughout the plant. In addition, Colorado Regulation No. 7, Part D, Section I.G.1 requires the LDAR program of NSPS OOOO for natural gas processing plants located in the 8-hour Ozone Control Area, beginning January 1, 2019, unless subject to the LDAR program provided at 40 CFR 60, Subpart OOOOa. In a response to an information request, received on October 18, 2019, Ker-McGee indicated that all plants at the Fort Lupton Complex had elected to comply with the requirements of NSPS OOOOa. The Division received a notification from Kerr-McGee on May 1 , 2019 stating that all process units at the Fort Lupton Complex have become 123/0057 Page 6 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit "affected facilities" under Subpart OOOOa, based on the requirements of Colorado Regulation No. 7, and that the date of construction was considered to be January 1 , 2019. The LDAR programs of NSPS OOOO and NSPS 0000a represent more stringent programs in terms of lower leak threshold definitions, more frequent monitoring, and instrument monitoring of connectors (not required in NSPS KKK). Since the requirements of NSPS KKK are less stringent and otherwise duplicative with NSPS OOOO/OOOOa, the provisions of NSPS KKK have been streamlined out of the operating permit in favor of the requirements of NSPS OOOOa. The Division has included the equipment leak standards of NSPS 0000a as applicable to the Fort Lupton and Platte Valley gas plants in the operating permit, since these requirements are equivalent to those of NSPS OOOO, except that the provisions of NSPS 0000a also apply to GHG (methane). 40 CFR 60 Subpart 1111 — Standards of Performance for Stationary Compression Ignition Internal Combustion Engines EU-41 — Detroit Diesel KC750KW1: In a response to an information request, received on August 11, 2017, Kerr-McGee specified that this engine is a diesel fired emergency power generator that was constructed before July 11 , 2005 and manufactured before April 1 , 2006. This engine is therefore not subject to NSPS 1111 per §60.4200(a)(2) and (a)(2)(i). GEN 2: This unit is a stationary compression ignition (CI) engine which commenced construction after July 11 , 2005 and was manufactured after April 1 , 2006; it is therefore subject to Subpart 1111 per §60.4200(a)(2) and (a)(2)(i). This unit is an emergency power generator subject to the provisions of §60.4205(b), which requires owners and operators to comply with the emission standards for new nonroad CI engines of §60.4202. This engine is certified to the Tier II emission standards of 40 CFR 89.112 and 89.113, as required by §60.4202. The fuel requirements of 40 CFR 80.510(b) are also applicable, as referenced by §60.4207(b). 40 CFR 60 Subpart JJJJ — Standards of Performance for Stationary Spark Ignition Internal Combustion Engines Compressor engine EU-103 was manufactured on June 9, 2008 and commenced construction on February 18, 2009. Compressor engine EU-104 was manufactured on March 13, 2009 and commenced construction on April 26, 2010. These engines are therefore subject to the requirements of Subpart JJJJ per §60.4230(a)(4)(i) since they have a maximum power greater than 500 horsepower, were manufactured on or after July 1 , 2007, and commenced construction after June 12, 2006. Applicable requirements include emission limits for NOx, CO and VOC, an initial performance test, and subsequent performance tests every three years or 8760 hours of operation to demonstrate continuous compliance. The initial notification required by 60.4245(c) has already been submitted to the Division. 40 CFR 60 Subpart OOOO — Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution for which Construction, Modification or Reconstruction Commenced After August 23, 2011, and on or before September 18, 2015 123/0057 Page 7 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit Equipment Leak Standards In a response to an information request, received on May 2, 2017, Kerr-McGee indicated that the Fort Lupton plant underwent modifications to the inlet in 2014 that qualified as a modification under the provisions of 40 CFR §60.14, thus subjecting the affected process units to the requirements of NSPS OOOO. Originally, Kerr-McGee had elected to comply with the requirements of NSPS OOOO on a facility-wide basis for consistency, and per the requirements of Colorado Regulation No. 7, Part D, Section I.G.1 , Kerr-McGee is required to comply with the requirements of NSPS OOOO for equipment leaks beginning January 1, 2019. The requirements of Reg. 7, Part D, Section I.G.1 are both state and federally enforceable. In a response to an information request, received on October 18, 2019, Ker-McGee indicated that all plants at the Fort Lupton Complex had elected to comply with the requirements of NSPS OOOOa. The Division received a notification from Kerr-McGee on May 1 , 2019 stating that all process units at the Fort Lupton Complex have become "affected facilities" under Subpart OOOOa, based on the requirements of Colorado Regulation No. 7, and that the date of construction was considered to be January 1 , 2019. The Division has included the equipment leak standards of NSPS 0000a as applicable to the Fort Lupton and Platte Valley gas plants in the operating permit, since these requirements are equivalent to those of NSPS OOOO, except that the provisions of NSPS 0000a also apply to GHG (methane). Insignificant Tanks In a response to an information request, received on August 1, 2019, Kerr-McGee stated that none of the tanks listed as insignificant activities in Appendix A, as provided in the application received on April 21 , 2015, are subject to NSPS OOOO. 40 CFR 60 Subpart 0000a — Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After September 18, 2015 In a response to an information request, received on October 18, 2019, Ker-McGee indicated that all plants at the Fort Lupton Complex had elected to comply with the requirements of NSPS OOOOa. The Division received a notification from Kerr-McGee on May 1 , 2019 stating that all process units at the Fort Lupton Complex have become "affected facilities" under Subpart OOOOa, based on the requirements of Colorado Regulation No. 7, and that the date of construction was considered to be January 1 , 2019. The Division has included the equipment leak standards of NSPS 0000a as applicable to the Fort Lupton and Platte Valley gas plants in the operating permit, since these requirements are equivalent to those of NSPS OOOO, except that the provisions of NSPS 0000a also apply to GHG (methane). 40 CFR 63 Subpart HH — National Emissions Standards for Hazardous Air Pollutant from Oil and Natural Gas Production Facilities The Fort Lupton facility is a natural gas processing plant, as defined in 40 CFR §63.761 , therefore HAP emissions from all HAP emission units are aggregated for major source 123/0057 Page 8 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit determination. This source is classified as a major source of HAP for Subpart HH, per the definition in 40 CFR §63.761. The group of all ancillary equipment intended to operate in volatile hazardous air pollutant (VHAP) service (as defined in §63.761) is an affected source for natural gas plants per §63.760(b)(1)(iii). "In VHAP service" is defined as a piece of equipment that contains or contacts a fluid having a VHAP concentration equal to or greater than 10 percent by weight as determined according to the provisions of §63.772(a), which specifies "Each piece of ancillary equipment and compressors are presumed to be in VHAP service or in wet gas service unless an owner or operator demonstrates that the piece of equipment is not in VHAP service or in wet gas service." Since it has not been specifically determined that there are no streams at the Fort Lupton gas plant that contain VHAP concentrations at greater than or equal to 10 percent, the provisions for equipment leak standards are applicable to this facility. Additionally, fugitive emission calculations submitted for re- permitting of this point to include the most recent component count and control efficiencies based on voluntary NSPS OOOO compliance indicated condensate streams containing 14% VHAP by weight. §63.769(b) provides an exemption for the equipment leak standards of Subpart HH for ancillary equipment and compressors subject to and controlled under the requirements of 40 CFR 60 Subpart OOOO. Since the requirements for equipment leaks of Subpart 0000a have been included in the operating permit as applicable to the Fort Lupton facility (see 40 CFR 60 Subpart OOOO, above), the equipment leak standards for ancillary equipment of Subpart HH have not been included in the operating permit. Ancillary equipment complying with the requirements of NSPS OOOO must still submit the periodic reports specified in §63.775(e), per §63.769(b). 40 CFR 63 Subpart ZZZZ — National Emissions Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines This facility is subject to the major source requirements of Subpart ZZZZ. The following reciprocating internal combustion engines (RICE) are affected sources under the rule: A stationary RICE located at a major source of HAP emissions with a site rating of more than 500 horsepower (HP) is classified as existing if construction was commenced before December 19, 2002 (§63.6590(a)(1)(i)), and as new if construction was commenced on or after December 19, 2002 (§63.6590(a)(2)(i)). A stationary RICE located at a major source of HAP emissions with a site rating of less than or equal to 500 HP is classified as existing if construction was commenced before June 12, 2006 (§63.6590(a)(1)(ii)), and as new if construction was commenced on or after June 12, 2006 (§63.6590(a)(2)(ii)). EU-33: This engine is classified as an existing two stroke lean-burn (2SLB) RICE site rated at more than 500 HP and therefore does not have to meet the requirements of Subpart ZZZZ per §63.6590(b)(3) and (b)(3)(i). EU-32 and EU-101 (existing); EU-34R (new): These engines are classified as four stroke rich-burn (4SRB) RICE site rated at more than 500 HP and are therefore subject to the 123/0057 Page 9 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit emissions and operating limitations of Tables 1a and 1 b of Subpart ZZZZ per §63.6600(a). EU-38 and EU-39; EU-103; EU-104: These engines are classified as new 4SLB RICE sited rated at more than 500 HP and are therefore subject to the emissions and operating limitations of Tables 2a and 2b of Subpart ZZZZ per §63.6600(b). GEN2: This engine is used for emergency power generation and is classified as a new RICE site rated at more than 500 HP. It does not have to meet the requirements of this subpart and of 40 CFR 60 Subpart A except for the initial notification requirements of §63.6645(f), per §63.6590(b)(1) and (b)(1)(i). This engine must be operated according to the requirements of §63.6640(f) in order to be considered an emergency stationary RICE under this subpart. The initial notification, required by §63.6645(f), was received by the Division for GEN2 on December 19, 2011 . Since the initial notification requirements for this engine has been completed, and the operational requirements for emergency engines for GEN2 will be included in the provisions for NSPS 1111, the MACT ZZZZ requirements for this generator have not been included in the operating permit. EU-41 — Detroit Diesel KC750KW1: In a response to an information request, received on August 11, 2017, Kerr-McGee specified that this engine is an emergency power generator that is classified as an existing emergency stationary RICE with a site rating of more than 500 horsepower located at a major source of HAP emissions. It is therefore exempt from the requirements of this subpart and Subpart A, including initial notification requirements, per §63.6590(b)(3) and (b)(3)(iii). 40 CFR Part 63 Subpart DDDDD — National Emissions Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters All process heaters, as defined in §63.7575, located at a major source of HAP are affected sources under this rule, as specified in §63.7485. This includes the process heaters described in the insignificant activity list in Appendix A of the operating permit, which have heat inputs of less than 5 MMBtu/hr. Colorado Regulation No. 1 GEN2: This diesel fired emergency power generator engine is subject to the Regulation No.1 , Section VI.B requirements for new sources of sulfur dioxide emissions. New sources are defined as those not having been issued an emission permit before the August 11, 1977 effective date of the amended regulation. Section VI.B.4.b.(i) contains a limit on SO2 emissions of 0.8 pounds per million BTU of oil heat input for oil-fired units with a heat input rate of less than 250 MMBtu/hr. Compliance with this requirement will be presumed, in absence of credible evidence to the contrary, since only diesel fuel is permitted to be used as fuel in this engine. Colorado Regulation No. 7 A revised Regulation No. 7, which has been reorganized from the previous version and revised to include requirements related to the serious nonattainment area designation for the Denver Metro North Front Range and revisions to several Colorado Revised Statutes, 123/0057 Page 10 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit was published in the Colorado Register on January 25, 2020 and became effective on February 14, 2020. Part E, Section I.A through I.D — Engines Part E, Sections I.A and I.B, contain requirements for Control of Emissions from Engines in the 8-hour Ozone Control Area. Part E, Section I.A contains applicability provisions which specify that any stationary or portable engine with a manufacturer's design rate greater than 500 horsepower operating in the 8-hour Ozone Control Area shall employ air pollution control technology. Part E, Section I.A contains different applicability dates for the employment of control technology for new and existing engines, based on the date an engine commences operation, however all of these applicability dates have passed so that all engines greater than 500 horsepower operating in the 8-hour Ozone Control Area are currently subject. Part E, Section I.B specifies the control required based on the engine category (rich or lean burn). Part E, Section I.D contains statewide requirements for new, modified, existing, and relocated natural gas fired reciprocating internal combustion engines. Part E, Section I.D.2 requirements for new and relocated engines include emission limits for NOx, CO, and VOC with applicability based on construction/relocation dates and engine size. Part E, Section I.D.3 contains emission control requirements for existing engines greater than 500 horsepower based on the engine category (rich or lean burn). For purposes of Part E, Section I.D.3, an existing engine is one that was constructed or modified before February 1, 2009. For lean burn engines greater than 500 horsepower that are subject to both the Part E, Sections I.B.2 and Section I.D.3.b requirements to install oxidation catalysts, the Section I.D.3.b requirement has been streamlined out of the permit since the Section I.B.2 requirement is both state and federally enforceable. The general provisions of Part D, Section II.B.1 related to prevention of emissions and good air pollution control practices and those of Section II.B.2 related to air pollution control equipment that are applicable to these engines have been included in the operating permit. EU-33: This engine is subject to the Part E, Section I.B.2 requirement to install an oxidation catalyst. Kerr-McGee had requested an exemption per Part E, Section I.C.4 but the exemption was denied. This engine is also subject to the Part E, Section I.D.3.b.(i) (State Only) requirement to install an oxidation catalyst. Since Section I.B.2 is both state and federally enforceable the Section I.D.3.b.(i) control requirement has been streamlined out of the operating permit (See Section VII: Streamlining of Applicable Requirements, below). The Part D, Section II.B general provisions applicable to this engine have been included. EU-32, EU-34R, and EU-101: These engines would be subject to the Part E, Section I.D.3.a.(i) requirement to install and operate a non-selective catalytic reduction system and air fuel controller but they are exempt per Section I.D.3.a.(i)(B) since they are subject to an emission control requirement in 40 CFR 63 Subpart ZZZZ. They are subject to the Part E, Section I.B.1 requirement to install NSCR and an air fuel controller. EU-38 and EU-39: These engines are subject to the (State Only) Part E, Section I.D.3.b.(i) requirement to install and operate oxidation catalysts. They are also subject to 123/0057 Page 11 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit the Part E, Section I.B.2 requirement to install oxidation catalysts. Since Section I.B.2 is both state and federally enforceable the Section I.D.3.b.(i) control requirement has been streamlined out of the operating permit (See Section VII: Streamlining of Applicable Requirements, below). EU-103 and EU-104: These engines are subject to the (State Only) Part E, Section I.D.2 emission standards for new, modified, and relocated engines. The exemption afforded theses engines, in what was previously Section XVII.B.5, due to the fact that they are subject to emissions control requirements in both 40 CFR 60 Subpart JJJJ and 40 CFR 63 Subpart ZZZZ, has been removed with the revisions to Reg. 7 effective February 14, 2020. They are also subject to the Part E, Section I.B.2 requirement to install an oxidation catalyst. Both requirements have been included in the operating permit. Part E, Section II.A — Combustion Equipment Part E, Section II.A contains requirements for stationary and portable combustion equipment that existed at a major source of NOx(greater than or equal to 100 tpy) as of June 3, 2016, or that existed at a major source of NOx (greater than or equal to 50 tpy) as of the date of reclassification of the ozone nonattainment area to serious (January 27, 2020), which are located in the 8-hour Ozone Control Area. Section II.A.4 contains equipment specific NOx emission limits. Compliance demonstration requirements for these limits are found in Section II.A.5. Section II.A.2 includes exemptions to the requirements of Section II.A.4, II.A.5, and the associated recordkeeping and reporting requirements of Sections II.A.7 and II.A.8. Section II.A.2.e contains an exemption for natural gas-fired internal combustion engines that are subject to an emission control requirement in Section I.A or I.B, though there are no emission limits applicable to natural gas-fired internal combustion engines in Section II.A.4. All permitted engines at the Fort Lupton plant are subject to the emission control requirements of Sections I.A and I.B. Compression ignition engines at the Fort Lupton plant have emissions below APEN reporting levels, and so meet the exemption of Section II.A.2.d for stationary combustion equipment with total uncontrolled actual emissions less than five tons per year of NOx. Section II.A.6 applies to combustion equipment (boilers, process heaters, duct burners, stationary combustion turbines, and stationary internal combustion engines) that have uncontrolled actual NOx emissions equal to or greater than five tons per year and that existed at a major source of NOx as of June 3, 2016, or that existed at a major source of NOx (greater than or equal to 50 tpy) as of the date of reclassification of the ozone nonattainment area to serious (January 27, 2020). Dryers, furnaces and ceramic kilns are also included in the emission units subject due to the nonattainment area reclassification. The following units at the Fort Lupton plant are potentially subject to the combustion process adjustment requirements of Section II.A.6: EU-33, EU-32, EU-101, EU-38, EU- 39, EU-34R, EU-103, and EU-104. Since applicability is based on uncontrolled actual emissions, individual unit applicability may vary from year to year. A note has been included in the operating permit that references the potential for changing unit applicability to this rule. Recordkeeping requirements for the combustion process adjustment provisions are included in Section II.A.7.f. Section II.A.7.f.(iii) allows an owner or operator to comply with the applicable recordkeeping requirements related to combustion process adjustments conducted as part of a NSPS or MACT requirement. A note has been added to this provision to specify that records must be retained for five 123/0057 Page 12 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit years according to the Title V recordkeeping requirements of Section VI, Condition 22.b, since NSPS and MACT recordkeeping requirements often allow a record retention time of less than five years. Part D, Section I — Volatile Organic Compound Emissions from Oil and Gas Operations Part D Section I applies to oil and gas operations that collect, store, or handle hydrocarbon liquids or produced water in the 8-hour Ozone Control Area. The following requirements represent revisions to Regulation No. 7 adopted to include RACT requirements based on EPA's control technique guidelines (CTGs) for the oil and gas industry. These requirements are applicable to sources in the 8-hour ozone nonattainment area and became effective on December 30, 2017. F001 — Fugitive Equipment Leaks: This facility is subject to Part D, Section I.G for natural gas processing gas plants located in the 8-hour Ozone Control Area. Section I.G.1 requires the application of the leak detection and repair (LDAR) program as provided in 40 CFR Part 60, Subpart OOOO, regardless of the date of construction of the facility, unless subject to the LDAR program provided at 40 CFR 60, Subpart OOOOa. Sources constructed before January 1 , 2018 must comply with these requirements beginning January 1, 2019, per Section I.G.3. Section I.G also states that gas plants shall comply with the general provisions requirement of Section I.C.1.b, as well as the requirements of Section I.J for compressors and Section I.K for pneumatic pumps. The Fort Lupton plant does not have any centrifugal compressors. Reciprocating compressors are subject to Section I.J.2, which requires control of VOC emissions through periodic rod packing replacements (based on hours of operation or calendar months) or through the collection and routing of VOC emissions to a process. Section I.K requires natural gas-driven diaphragm pneumatic pumps at natural gas processing plants to have a VOC emission rate of zero. Centrifugal compressors, reciprocating compressors and natural gas-driven pneumatic pumps are also subject to the definitions in Section I.B and the requirements of Sections I.C.1 .c through I.C.1 .e if they are using a control device to comply with specified requirements. Part D, Section III — Pneumatic Controllers This facility is technically subject to all the natural gas-driven pneumatic controller requirements of Section III.C, however, the more recently adopted requirements of Section III.C.2, for pneumatic controllers at gas plants located in the 8-hour Ozone Control Area, supersede and/or are redundant with the requirements of Sections III.C.1 and III.C.3. The provisions of Sections III.C.1 and III.C.3, and the associated monitoring and recordkeeping requirements in Sections III.D and III.E, have been streamlined out of the operating permit (See Section VII: Streamlining of Applicable Requirements, below). The provisions of Section III.C.2 and the associated monitoring and recordkeeping in Sections III.D and III.E have been included in the operating permit. In addition, the recordkeeping requirements of Section III.E.2.c, requiring records of pneumatic controller maintenance to be maintained for three years, has been streamlined for the five year recordkeeping requirement applicable to Title V sources in the General Conditions (Section VI Condition 22). Insignificant Tanks 123/0057 Page 13 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit In a response to an information request, received on August 1, 2019, Kerr-McGee stated that none of the tanks listed as insignificant activities in Appendix A, as provided in the application received on April 21 , 2015, are subject to Regulation No. 7. IV. Modifications Requested by the Source This section includes information about modifications requested by the source for emission units that have previously been incorporated into the operating permit as well as requests from the source to incorporate construction permits and construction permit modifications issued since the most recent revision to the operating permit. Details on modifications for emission units previously incorporated into the operating permit are in this section. Details on construction permit conditions for emissions units that are being incorporated into the operating permit with this issuance are found in Section V: Emission Units. A. Description of Permit Modification Requests The renewal application received on October 29, 2002 requested the following modifications: • Inclusion of the provisions of Construction Permits 00WE0581 , 00WE0582, 00WE0583. A cancellation request for permit 00WE0581 was received on March 10, 2005, therefore, the requirements from this permit have not been included in the operating permit. • Information for the inclusion of, and modification to, construction permit 01WE0764 was submitted as part of an additional information request; however, this modification was effected through the construction permit process. A cancellation request for the Elastec Inc., Smart Ash Energy Recovery Unit (AIRS point 0141 CP# 97WE0406) was received on June 11, 2003. A modification request was received on August 4, 2003 to include an emergency electrical generator in the operating permit. This generator is a Detroit Diesel KC750KWI site-rated at 1088 HP. This unit is considered APEN exempt per Colorado Regulation No. 3, Part A, Section II.D.1.a and II.D.1.b, and is considered an insignificant activity per Regulation No. 3, Part C, Section II.E.3.a and II.E.3.b, since uncontrolled actual emissions are below APEN reporting thresholds. A modification request was received on February 24, 2004 to increase the permitted emissions for compressor engines EU-31 , EU-32, and EU-34. This emissions increase was requested because the heat content of the natural gas used to fuel the engines had increased, which causes a corresponding increase in calculated emissions. The source stated in the modification request that measured fuel usage had not increased substantially, and therefore no increase in the permitted fuel usage level was requested. Since the Fort Lupton facility was categorized as a major source of NOx and CO for PSD during that period, an actual-to-potential analysis was 123/0057 Page 14 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit requested by the Division to determine if the modification qualified as a major modification under the PSD rules. An actual-to-potential analysis was received on January 13, 2006 that demonstrated the increase in NOx and CO emissions from the modification were below the significance levels necessary to qualify for a PSD major modification. In a response to an information request, received on March 27, 2017, the source indicated that this modification was no longer desired and requested to rescind the application. An addendum to the operating permit renewal application was received on April 30, 2004 that requested several changes be incorporated into the renewal permit: • A hard count of components for estimation of fugitive emissions from equipment leaks to be performed every year instead of keeping a running tally with a hard count every 5 years. In comments on an initial draft permit, received on November 9, 2017, Kerr- McGee requested to remove the hard count requirement since a running tally of components is maintained through the NSPS OOOO LDAR program. The Division has approved this request. • The requirements for fugitive emissions from equipment leaks remain separated into two individual categories: those associated with the original facility, which are not subject to NSPS KKK (F001), and those associated with the natural gas liquids extraction facility, which are subject to NSPS KKK. This request is no longer valid. All equipment leaks at the Ft Lupton facility were previously subject to NSPS KKK, now superseded by NSPS OOO, and a single consolidated annual allowable VOC emission limit for equipment leaks in VOC service was required by the Consent Decree entered into U.S. District Court in Colorado on March 27, 2008 (Civil Action No. 1:07-cv-01034). • Inclusion of the provisions of Construction Permit 01WE0370. This permit was for a glycol dehydrator that replaced the Smith dehydrator (EU04). This dehydrator has subsequently been replaced by another permitted under Construction Permit 07WE0799. A cancellation request for this unit and permit was received on October 20, 2008. • Inclusion of the provisions of Construction Permit 01WE0764 This permit was for a glycol dehydration unit (QBJ North Dehy) that has subsequently been cancelled. • An addition of an Alternative Operating Scenario (AOS) that would allow the glycol dehydration unit to operate up to 60 hours a year without the thermal oxidizer, in order to perform periodic maintenance on the thermal oxidizer. This request is no longer applicable since the dehydration units located at Fort Lupton have been shut down and their emission points cancelled. 123/0057 Page 15 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit • An addition of an Alternative Operating Scenario that would allow an engine break-in period of 100 hours following new engine installation or after an engine rebuild, in which the engine could be operated without a catalyst, in order to prevent catalyst fouling. This AOS has not been included in the operating permit. Colorado Regulation No. 7, Part E, Section I does not specifically allow for this practice when catalyst installation is required. The Division's compliance and enforcement personnel can consider special circumstances, such as when this maintenance practice is recommended by the manufacturer. • Referenced the June 10, 2003 submittal requesting deletion of Smart Ash Energy Recovery Unit. • Referenced request to increase emission limits for EU-31, 32, and 34, received February 24, 2004. • Revised O&M plans for subject engines and glycol dehydration units. • Revised CAM plans for subject engines and glycol dehydration units. • Requested to include an insignificant power generator (EU-41, point 023) previously submitted on August 1, 2003. This engine was described as being exempt from construction permitting requirements since it will operate less than 250 hours per year per Reg. 3, Section II.D.1 .c(ii)). An APEN cancellation letter was submitted for this source on September 18, 2018 since uncontrolled actual emissions of HAP and criteria pollutants are below APEN reporting thresholds. This engine has been listed in the insignificant activity list in Appendix A. An application was received on February 21 , 2006 that requested a name change to Kerr-McGee Gathering, LLC from Kerr-McGee Rocky Mountain Corporation. This application has been processed as an administrative modification. A modification request to revise the horsepower ratings listed for compressor engines EU-31 , EU-32, and EU-34 was received on July 19, 2006 (AIRS points 013, 030; all engines were under point 013 at the time). These engines, originally permitted at 954 HP, were discovered during testing to be operating at 1232 HP. No increase in permitted emission limits was requested since these limits are based on fuel usage. An email was received on September 1, 2006 requesting that the provisions of Colorado Construction Permit 01WE0763 (for EU-38 and EU-39, AIRS point 020) be included in the renewal operating permit. A letter, dated June 14, 2007, requested a consolidated annual fugitive VOC limit be specified in the renewal operating permit for the facility, consisting of the sum of the fugitive VOC limit specified in the operating permit (AIRS point 011, 30.8 tons/year) and that specified in Construction Permit 00WE0583 (AIRS point 018, 43.66 tons/year). A consolidated limit for the fugitive equipment leak emissions at Fort Lupton was required by Consent Decree 1 :07-cv-01034, entered into U.S. District 123/0057 Page 16 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit Court in Colorado on March 27, 2008. This requested limit has been superseded by the limit requested in the APEN received on September 25, 2018. A modification was received on July 24, 2008 that requested the operating permit be revised to include the installation of oxidation catalysts for compressor engines EU-33, EU-35, EU-36, and EU-37. These catalysts were installed pursuant to the Consent Decree lodged with the U.S. District Court for the District of Colorado on May 17, 2007 and entered on March 27, 2008 between the U.S. EPA, the State of Colorado and Kerr-McGee Corporation. The installed catalysts are required to have a 58% destruction efficiency for CO when the RICE are operating at a 90% load or higher. This application is superseded by the application received on July 2, 2009 and the cancellation requests received on June 2, 2014 and July 10, 2015. Modified Construction Permit 11WE730-1 was issued on February 9, 2017 to incorporate the catalyst control and associated reduction in horsepower for EU-33. A letter was received on August 8, 2008 requesting that the operating permit include compressor engine EU-34R and the provisions of Colorado Construction Permit 07WE0366 in the pending renewal. A letter was received on October 31, 2008 which requested again that the Operating Permit include revised horsepower ratings for EU-31 and EU-32 (AIRS IDs #013, 030). These engines, originally permitted at 954 HP, were discovered during testing to be operating at 1232 HP. No increase in permitted emission limits was requested since these limits are based on fuel usage. A modification application was received on July 2, 2009 that requested a reduction in the site-rated horsepower from 2,166 HP to 2,046 HP for compressor engines EU-33, EU-36, and EU-37, and from 1 ,859 HP to 1 ,756 HP for compressor engine EU-35. This horsepower adjustment was requested due to the installation of oxidation catalysts included in the July 24, 2008 modification request. A corresponding reduction in permitted emissions and natural gas consumption was also requested with the reduction in horsepower. Engines EU-35, EU-36, and EU-37 have since been removed from the facility and their APEN points cancelled. A revised Construction Permit 11WE730-1 was issued on February 9, 2017 that incorporated the requested revised horsepower and emission and operating limitations. The operating permit has been issued with these revised limits. A modification request was received on June 11 , 2009 to include compressor engine EU-103 and the provisions of Colorado Construction Permit 07WE0798 in the pending operating permit renewal. A modification request was received on January 20, 2010 to include the requirements of Construction Permit 07WE0799 for the South TEG Dehydrator in the operating permit. This application has been superseded by the cancellation request received on April 18, 2017. A letter was received on April 20, 2011 requesting the cancellation of engine EU-34. This unit was permanently removed from the facility on September 28, 2007. 123/0057 Page 17 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit A letter was received on June 2, 2011 that requested the Operating Permit incorporate the provisions of the modified construction permit 00WE0583, issued on August 4, 2010. This permit regulates emissions of equipment leaks from natural gas processing and has been modified to include the control effectiveness of a quarterly Leak Detection and Repair (LDAR) program as specified in Table 5-3 of EPA Guidance Document EPA-453/R-95-017. This application has been superseded by the one received on September 25, 2018. A modification application was received on March 1, 2012 requesting that the Division issue an operating permit reflecting all equipment at both the Fort Lupton and Platte Valley gas plants. Kerr-McGee acquired the Platte Valley Gas Plant from Encana Oil and Gas USA on March 1, 2011 . The equipment formerly permitted under Operating Permit 99OPWE207 and all equipment currently associated with the Platte Valley facility has been incorporated into Operating Permit 95OPWE013. Cancellation requests for engines EU-36 (point 005, CP# 11WE730-2) and EU-37 (point 006, CP# 11WE730-3) were received on June 2, 2014. These engines were permanently shut down on May 14, 2014 as part of the Lancaster plant project. A cancellation request for engine EU-35 (point 007, CP# 11WE132) was received on July 10, 2015. This engine was permanently shut down on June 17, 2015 as part of the Lancaster plant project. A cancellation request for engine EU-31 (point 013, CP# 97WE0180) was received on July 10, 2015. This engine was permanently shut down on June 17, 2015 as part of the Lancaster plant project. A modification application was received on April 21 , 2015 that requested the incorporation of the provisions of Construction Permit 12WE1492 pertaining to Train I of the Lancaster Plant expansion to the Ft Lupton Gas Processing Complex. This application also referenced the cancellation of units EU-36 and EU-37 and requested the provisions of Construction Permits 11WE730-2 E730-2 and 11WE730-3 be removed. A request for cancellation of Construction Permit 10WE1587 and the associated AIRS point (123-0057-029) was received on March 2, 2016. This emission unit is an engine associated with an emergency power generator (GEN2) which was previously only subject to APEN reporting and construction permitting due to the "catch-all" provisions in Colorado Regulation No. 3, Part A, Section II.D.1 (APEN reporting) and Part B, Section II.D (construction permitting). The "catch-all" provisions required emission units subject to a federal New Source Performance Standard (NSPS) or National Emission Standard for Hazardous Air Pollutants (NESHAP) to file an APEN and obtain a construction permit. The removal of the "catch-all" provisions was approved in a rulemaking adopted by the Colorado Air Quality Control Commission (AQCC) on February 23, 2014 (effective April 14, 2014). This engine is currently exempt from APEN reporting requirements based on uncontrolled actual emissions being less than the deminimis level of one ton per year of NOx (the highest emitted pollutant) per Reg. 3, Part A, Section II.D.1.a. This engine is still subject to the requirements of NSPS IIII for compression ignition internal combustion engines and the applicable requirements of this rule have been included in the operating permit. 123/0057 Page 18 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit A modification application was received on March 4, 2016 that requested the incorporation of the provisions of Construction Permit 12WE1492 pertaining to Train II of the Lancaster Plant expansion to the Fort Lupton Gas Processing Complex. This application also requested the following: • Incorporation of the provisions of Construction Permit 14WE0142, issued on July 9, 2015, pertaining to process flare F-4 at the Fort Lupton Gas Plant. • Reaffirm removal of the provisions of Construction Permit 11WE0132 for engine EU-35 (AIRS point 007). • Reaffirm removal of the provisions of Construction Permit 97WE0180 for engine EU-31 (AIRS point 013) • Reaffirm the consolidation of previously separate fugitive emission points at the Fort Lupton facility. A cancellation for both glycol dehydration units at the Fort Lupton facility, QBJ North Dehy (AIRS point 021) and TEG South Dehy (AIRS point 027) was received on April 18, 2017. All provisions related to these dehydration units have been removed from the operating permit. An application was received on February 5, 2018, that requested the incorporation of the provisions of modified Construction Permit 11 WE730-1 , issued February 9, 2017. This modification incorporated the emission control equipment, efficiencies, and requirements of the Consent Decree (Civil Action No. 1 :07-cv-01034) for compressor engine EU-33 (point 004) as well as a reduction in horsepower and corresponding emission and fuel use limits due to the installation of controls. A modification application was received on August 3, 2018 that requested the incorporation of Issuance 3 of 12WE1492 (issued August 11 , 2017) for the Lancaster Plant. An application was received on September 25, 2018 to modify the emission limits for engine EU-101 . This engine was previously permitted at the maximum design rate of the engine but was also given an operational horsepower limit because testing for the engine had only demonstrated compliance at a reduced load, creating conflicting permit conditions. The new requested limits reflect the maximum horsepower at which the engine has been tested, 932. See Section V: Emission Sources, for details on the incorporation of this unit into the operating permit. A modification request was received on September 25, 2018 that requested a revised fugitive emissions limit for the Fort Lupton facility (AIRS point 018). The new limit is based on an updated component count and control efficiencies based on the monthly leak detection and repair program of NSPS OOOOa. This new limit incorporates all emissions from fugitive sources of equipment leaks at the Fort Lupton facility. See Section V: Emission Sources, below. A modification application was received on December 5, 2018 that requested a revision to the controlled emission factors for engine EU-34R (AIRS point 025). Controlled emission factors for this engine were originally based on a different break 123/0057 Page 19 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit specific fuel consumption than what was used for the fuel and emission limits, leading to a situation where Kerr-McGee would exceed emission limits before the fuel consumption limit was reached. This application aligns the controlled emission factors with fuel consumption and emission limits. See Section V: Emission Sources, below for details on the revised emission factors. In a response to an information request, received on October 18, 2019, Ker-McGee indicated that all plants at the Fort Lupton Complex had elected to comply with the requirements of NSPS OOOOa. The Division received a notification from Kerr-McGee on May 1, 2019 stating that all process units at the Fort Lupton Complex have become "affected facilities" under Subpart OOOOa, based on the requirements of Colorado Regulation No. 7, and that the date of construction was considered to be January 1 , 2019. B. The source's requested modifications were addressed as follows: Page Following Cover Page • Revised owner name to reflect name change to Kerr-McGee Gathering, LLC • The designated Responsible Official was revised according to a response to comments received on September 27, 2018. The permit contact was revised per comments on the initial draft permit, received on November 9, 2017. These comments designated Mr. Miguel DeHerrera, Director of Midstream Operations, as the new Responsible Official, and Jillian Yamartino, Senior HSE Representative, as the new permit contact. A previous request to change the Responsible Official, received on September 29, 2017, designated Mr. Craig Collins, Senior Vice President and Chief Operating Officer, as the Responsible Official, and Mr. Mathew Berghorn as a Duly Authorized Representatives of the Company, who is delegated the authority to sign environmental permits and/or compliance reports on behalf of the Company. Section l — General Activities and Summary • Condition 1 .3: Removed CP references for cancelled units (11 WE132, 11 W E730-2, 11 W E730-3, 94W E760-4, 97W E0406, and 96W E641) and added CP references for units added (07WE0366, 01WE0763, 00WE0582, 00W E0583, 07W E0798, 10W E1071,1071, 14W E0142) • Updated Condition 2 to include the current version of the natural gas engine Alternative Operating Scenario (AOS) (10/12/12), as well as to add the current AOS for turbine replacement. Revised Table 1: Internal Combustion Engine Information for the AOS to include descriptions of engines currently permitted at the facility. • Condition 6 — Summary of Emission Units o Removed descriptions for the following units since these have been permanently shut down at this facility: EU-31 , EU-34, EU-35, EU-36, EU- 37, EU-04 and 1001. (See notes under Section II — Specific Permit Terms, below) 123/0057 Page 20 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document — Renewal 1 Operating Permit o Inserted descriptions for the following units that have been added since the previous issuance: EU-101, EU-38, EU-39, EU-34R, EU-103, EU- 104, GEN2, and F-4. o Revised description for F001. Fugitive emissions are now associated with point 018. Section II — Specific Permit Terms • Condition 1 (former Condition 2) for compressor engine EU-33 (AIRS point 004): o Removed all references to units EU-36 and EU-37 (AIRS points 005, 006) and associated construction permits. These engines were permanently shut down on May 14, 2014 as part of the Lancaster Plant project. Cancellation requests were received for these engines on June 2, 2014. o Revisions were made in the summary table for unit EU-33 to coincide with the modifications detailed in the items below. o Per the modification requests received on July 24, 2008, July 2, 2009, and February 5, 2018: Revised the CO emission factor, annual emission limitation, annual fuel consumption limit, and site -rated horsepower to reflect the installation of oxidation catalysts required by the Consent Decree. A control efficiency of 58% was granted for CO. These modifications were permitted in the February 9, 2017 issuance of 11WE730-1. (See Section V: Emission Sources, below) • Former Condition 3 for compressor engine EU-35 (AIRS point 007) was removed from the permit. This engine was permanently shut down on June 17, 2015 as part of the Lancaster plant project. The AIRS point and associated Construction Permit 11WE132 have been cancelled. • Former Condition 4 for the Smith Triethylene Glycol Dehydration Unit (EU-04, AIRS point 010) was removed from the permit. This dehydrator was removed from the facility in May of 2007 and the associated construction permit and AIRS point have been cancelled. • Former Condition 5 for the Elastec Inc. Smart Ash Energy Recovery Unit (1001, AIRS point 014) was removed from the permit. This unit was removed from the facility in June of 2003 and the associated construction permit and AIRS point have been cancelled. • Condition 2 (former Condition 6) for Fugitive Equipment Leaks (AIRS point 018 and formerly point 011): o Revisions were made in the summary table for emission point F001 to coincide with the modifications detailed in the items below. 123/0057 Page 21 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit o Per the letter dated June 14, 2007: Included a consolidated annual VOC emission limit for fugitive emissions, aggregated from Operating Permit 95OPWE057, Condition 6.1 , and Construction Permit 00WE0583, Condition 2, as required by the consent decree. o Per the modification request received on June 2, 2011 , incorporated the provisions of modified construction permit 00WE0583. This modification had included revised emission limits based on control efficiencies granted through the implementation of the quarterly LDAR program of NSPS KKK. The emission limits and LDAR monitoring have been revised according to the modification application received on September 25, 2018. o Per the modification application received on September 25, 2018 and the response to an information request received on October 18, 2019, included a revised emission limit for fugitive emissions from equipment leaks for the Fort Lupton facility based on updated component counts and control efficiencies based on the monthly leak detection and repair program of NSPS OOOOa. The provisions for fugitive emissions at the Fort Lupton site now include all fugitive emissions, not only those permitted by construction permit 00WE0583. (See Section V: Emission Sources, below) o Per Kerr-McGee's comments on draft permit conditions, received November 9, 2017, removed language requiring a component hard count be conducted every five years since additions and deletions of component counts are maintained through compliance demonstration for the LDAR program of NSPS OOOOa. • Condition 3 (former Condition 1) for compressor engines EU-31 , EU-32 and EU-34 (AIRS points 013 and 030): o Removed all references to engine EU-31. This unit was permanently shut down on June 17, 2015 as part of the Lancaster plant project. o Removed all references to engine EU-34. This unit was permanently removed from the facility on September 28, 2007. o Revisions were made in the summary table for unit EU-32 to coincide with the modifications detailed in the items below. o Per the modification request received on July 19, 2006: Revised the horsepower rating from 954 to 1232 HP. Appendices • The list of insignificant activities was updated according to the most recent application. V. Emission Sources 123/0057 Page 22 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit The applicable requirements of construction permits issued for emission units at this facility since the latest revision to this operating permit have been incorporated as follows (Note that only the conditions from the most recently modified versions of incorporated construction permits are included): A. Conditions Not Included in the Unit-Specific Conditions of the Operating Permit 1. Applicable Requirements: The following conditions are common to various construction permits detailed in this section (Emission Sources), but have not been included in the unit-specific conditions of the operating permit for the reasons specified below. They have been consolidated here to avoid repetition in the permit specific sections below. Any conditions from construction permits not discussed in the permit specific sections are represented here. Any conditions specified here that are still applicable to specific units or permits have been repeated in the permit specific sections to which they apply. • You must notify the APCD no later than thirty days (later revised to 15 days) after commencement of the permitted operation or activity by submitting a Notice of Startup (NOS) form to the APCD. All equipment covered by this operating permit has previously commenced operation. No equipment is being permitted for the first time using the combined construction/operating permit procedures. Therefore, this requirement has not been included in the operating permit. • The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self- certification process. (Reference: Regulation No. 3, Part B, Section III.E.) This condition is specifically applicable to construction permits and therefore has not been included in the operating permit. Specific conditions related to compliance testing or sampling that has not been completed have been included in the operating permit for the respective units. The self-certification status of each permit is discussed in the applicable requirements of the permit specific sections below. • The operator shall retain the permit final authorization letter issued by the Division after completion of self-certification with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. This condition is specifically applicable to construction permits and therefore has not been included in the operating permit. • This construction permit represents final permit approval and authority to operate this emissions source (Regulation 3, Part B, Section III.G.5). This condition is specifically applicable to construction permits and therefore has not been included in the operating permit. 123/0057 Page 23 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit • The permit and/or AIRS ID number shall be marked on the subject equipment for ease of identification. (Regulation No. 3, Part B, Section III.E) This condition is specifically applicable to construction permits and therefore has not been included in the operating permit. • This source is subject to the odor requirements of Regulation No. 2. This requirement is included in the General Conditions (Section IV) of the operating permit and therefore has not been included in the unit specific requirements for this emission source. • The make, model, and serial number of the subject equipment shall be provided to the Division within one hundred and eighty days (180) after commencement of operation. (Reference: Regulation No. 3, Part B, III.E.) All information for emission units currently operating at the Fort Lupton plant has been submitted and this one time requirement has been satisfied. This condition has not been included in the operating permit. • A revised Air Pollutant Emission Notice (APEN) shall be filed according to the requirements of Regulation No. 3, Part A, Section II.C The APEN reporting requirements are included in Section IV (General Conditions), Condition 22.e of the operating permit. • All previous versions of this permit are cancelled upon issuance of this permit. This condition is specifically applicable to construction permits and therefore has not been included in the operating permit. • This source is subject to the provisions of Regulation No. 3, Part C, Operating Permits. The provisions of this construction permit must be incorporated into the operating permit. The application for the modification to the Operating Permit is due within one year of the issuance of this permit (or commencement of operation). This condition has not been included in the operating permit since the requirement is fulfilled with this permit action. • Prevention of Significant Deterioration (PSD) requirements shall apply to this source at any such time that this source becomes major for PSD solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable PSD threshold will require a full PSD review of the source as though construction had not yet commenced on the source. (Reference: Regulation No.3, Part D, Section VI.B.4.) This condition has not been included in the operating permit since no actual requirements apply. The PSD status of this source is discussed in Section I, Condition 3 of the operating permit. 123/0057 Page 24 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit • Non-attainment New Source Review (NANSR) requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable NSR threshold will require a full NSR review of the source as though construction had not yet commenced on the source. (Regulation No. 3, Part D, V.A.7) This condition has not been included in the operating permit since no actual requirements apply. The NANSR status of this source is discussed in Section I, Condition 3 of the operating permit. • Within 180 days after commencement of operation (or within 180 days of permit issuance), compliance with the conditions in this permit shall be demonstrated to the Division. It is the permittee's (or owner or operator's) responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, Section III.G.2) This condition has not been included in the operating permit. The self- certification status of each permit is discussed in the applicable requirements of the permit specific sections below. Any self-certification not completed through the construction permitting process will be completed through the operating permit process according to the provisions of Regulation No. 3, Part C, Section V.A. • This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this initial approval permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) This condition is specifically applicable to construction permits and therefore has not been included in the operating permit. • Construction Permit General Conditions These conditions are standard conditions included in every construction permit. They have not been included in the operating permit. Any general conditions applicable to operating permits are included in Section IV of the operating permit. B. EU-33: One (1) Fairbanks Morse MEP 12, 2SLB natural gas-fired internal combustion engine, 2046 HP, Serial No. 38D8780-30S1S12, equipped with an oxidation catalyst (AIRS point 004) 123/0057 Page 25 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit 1. Applicable Requirements: Colorado Construction Permit 11WE730-1 was originally issued as Initial Approval on May 12, 1978 to Panhandle Eastern Pipeline Co., with final approval issued on April 9, 1979. A modification was issued on May 6, 1997 to revise emission factors and limits based on in-house testing as well as to transfer ownership to KN Wattenberg Transmission Co. A modification was issued as Final Approval on February 9, 2017 to incorporate emission control equipment, efficiencies, and requirements of the March 27, 2008 Consent Decree and a transfer of ownership to Kerr-McGee Gathering LLC. This modification also included a horsepower reduction from 2166 HP to 2046 HP due to the installation of controls and a corresponding reduction in emission and fuel use limits. The applicable requirements of Colorado Construction Permit 11WE730-1 have been directly incorporated into the operating permit as follows: • (Condition 2) Emissions of air pollutants shall not exceed the following limitations. Compliance with the annul limitations shall be determined on a rolling 12 month total. The permit holder shall calculate monthly emissions and keep a compliance record on site for Division Review (Regulation No. 3, Part B, Section II.A.4) o NOx - 90.2 tons/yr; CO — 18.1 tons/yr; VOC — 17.9 tons/yr; PMio/PM2.5/TSP — 3.8 tons/yr The annual emission limitations (calculated on a rolling 12-month total), associated compliance monitoring, and recordkeeping requirements have been included in the operating permit. • (Condition 3) The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) o EU-33: Oxidation catalyst and air/fuel ratio controller The requirement to operate the engine with an oxidation catalyst has been included in the operating permit. The emission limitations have been established based on control with an oxidation catalyst and air fuel ratio controller. • (Condition 4) Consumption of natural gas as fuel shall not exceed 131 .80 MMscf/year. Compliance with the yearly consumption limits shall be determined on a rolling twelve (12) month total. Monthly records of the actual consumption rate shall be maintained by the applicant and made available to the Division for inspection upon request. (Regulation No. 3, Part B, Section II.A.4) The natural gas consumption limit and associated compliance demonstration and recordkeeping requirements have been included in the operating permit. • (Condition 6) Visible emissions shall not exceed 20% opacity during normal operation of the source, during periods of startup, process modification, or 123/0057 Page 26 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1 , Section II.A.1 & 4) This condition has been included in the operating permit. This condition has been modified to include all of the operating scenarios applicable to the Section II.A.4 30% standard. Compliance with the opacity limits shall be presumed, in absence of credible evidence to the contrary, since only natural gas is permitted for use as fuel in this engine. • (Condition 8) This equipment is subject to the control requirements for stationary and portable engines in the 8-hour ozone control area under Regulation No. 7, Section XVI.B.2. For lean burn reciprocating internal combustion engines, an oxidation catalyst shall be required. The applicable requirements of Regulation No. 7, Part E, Sections I.A and I.B (previously Section XVI) have been included in the operating permit. • (Condition 9) This equipment is subject to the requirements for natural gas- fired reciprocating internal combustion engines under Regulation No. 7, Section XVII.E.3 (State only enforceable). Any lean burn reciprocating internal combustion engine constructed or modified before February 1 , 2009 with a manufacturer's name plate design rate greater than 500 horsepower shall install and operate an oxidation catalyst by July 1, 2010. The state-only Regulation No. 7, Part E, Section I.D (previously Section XVII.E) requirement has not been included in the operating permit, but has been streamlined in favor of the state and federally enforceable control requirement of Regulation No. 7, Part E, Sections I.A and I.B. (See Section VII: Streamlining of Applicable Requirements, below) • (Condition 10) Upon issuance of this permit, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) Operation and maintenance requirements, parameter monitoring, and recordkeeping requirements have been directly incorporated into the operating permit in order to monitor compliance with emission limitations and other requirements for this engine. • (Condition 11) This engine is subject to the periodic testing requirements as specified in the operating and maintenance (O&M) plan as approved by the Division. Revisions to your O&M plan are subject to Division approval. Replacements of this unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A. 123/0057 Page 27 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit Quarterly portable analyzer testing, as specified in the O&M plan, has been included in the operating permit to monitor compliance with the emission limits. Additional testing required for use of the Alternative Operating Scenario is included in that respective section. Although not specifically identified in Colorado Construction Permit 11WE730-1, this engine is subject to the following applicable requirements: • Colorado Regulation No. 7, Part E, Section II.A.6 (previously Section XVI.D.6) contains requirements (effective January 14, 2017) for combustion process adjustments for combustion equipment. Applicability is based on uncontrolled actual NOx emissions being greater than five tons per year. The requirements of Colorado Regulation No. 7, Part E, Section II.A.6 have been included in the operating permit. 2. Emission Factors Emission limits from the current construction permit have been incorporated into the operating permit. These emission limits are based on emission factors for NOx, CO, and VOC that were included in the previous operating permit issuance and were originally developed from in-house portable analyzer test results which were submitted for the May 1997 modification. These emission factors, as well as the emission factor for PM1o1PM2.5 and formaldehyde, the most abundant HAP emitted during operation of the engine, are shown in the table below. All other emissions (criteria and HAP) were calculated based on emission factors from AP- 42, Table 3.2-1. Emission Factors for EU-33 Pollutant Uncontrolled Controlled Source (lb/MMBtu) (lb/MMBtu) NOx 1.36 1.36 95OPWE013/in-house testing CO' 0.65 0.273 95OPWE013/in-house testing VOC 0.27 0.27 95OPWE013/in-house testing PM1o/PM2,5 0.056 0.056 95OPWE013 Formaldehyde 0.0552 0.0552 AP-42, Table 3.2-1 1Controlled emissions for CO based on an oxidation catalyst control efficiency of 58% 3. Monitoring Plan In order to monitor compliance with the annual emission and fuel consumption limits, the source will be required to monitor fuel consumption and calculate emissions on a monthly basis. The heat content of the natural gas used to fuel this engine is required to be determined semiannually in order to calculate emissions using recorded natural gas consumption. In addition, quarterly monitoring using a portable analyzer will be required to monitor compliance with the NOx and CO annual emission limits and emission rates. To ensure proper operation of the control equipment, monitoring of the catalyst inlet temperature (daily) and catalyst differential pressure (monthly) is required. 123/0057 Page 28 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit The catalyst inlet temperature must be maintained within the recommended range for lean burn engines and the differential pressure must be maintained within 2 inches of water column from the value recorded during the most current portable analyzer test that demonstrated compliance with the annual emission limits. Compliance with the opacity limits is presumed, in absence of credible evidence to the contrary, since only natural gas is permitted for use as fuel in these engines. 4. Compliance Status The Division completed a full compliance evaluation at the facility on August 31 , 2016. According to the inspection report, engine EU-33 was in compliance with Operating Permit 95OPWE013 and applicable air pollution control regulations. C. EU-101: One (1) Waukesha 7042GSI, 4SRB natural gas fired internal combustion engine, 1478 HP, Serial No. 288358, equipped with a Non-Selective Catalytic Reduction (NSCR) system, powering a propane refrigeration compressor (AIRS point 017) 1. Applicable Requirements: Colorado Construction Permit 00WE0582 was originally issued on December 22, 2000 as Initial Approval. A Final Approval was issued on December 23, 2009. The Final Approval incorporated the Division's standard Alternative Operating Scenario (AOS) for this engine and limited the operational horsepower of the engine to 923 HP, since this was the highest horsepower at which this engine had demonstrated compliance during stack tests. The operational horsepower limit in this permit creates conflicting conditions since emission and fuel use limits, based on operation at design rate, are much greater than could be achieved with this limit. It was suggested to the source that the engine be permitted at levels associated with the operational horsepower limit, and an application was received on September 25, 2018 that requested this engine be permitted at emission levels associated with 932 horsepower, achieved in a subsequent test done on June 16, 2016. The applicable requirements of Colorado Construction Permit 00WE0582 have been directly incorporated into the operating permit as follows, with revisions according to the application received on September 25, 2018: • (Condition 1) Visible emissions shall not exceed 20% opacity during normal operation of the source, during periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Opacity shall be measured by EPA Method 9. (Reference: Regulation No. 1 , Section I I.A.1 & 4) This condition has been included in the operating permit. The EPA Method 9 requirement has been replaced with language specifying that compliance with the opacity limits shall be presumed, in absence of credible evidence to the contrary, since only natural gas is permitted for use as fuel in this engine. This condition has been modified to include all of the operating scenarios applicable to the Section I I.A.4 30% standard. 123/0057 Page 29 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit • (Condition 3) Emissions of air pollutants shall not exceed the following limitations. Compliance with the annul limitations shall be determined on a rolling 12 month total. The permit holder shall calculate monthly emissions and keep a compliance record on site for Division Review (Regulation No. 3, Part B, Section II.A.4) o NOx — 17.8 tons/yr; CO — 17.8 tons/yr; VOC — 4.3 tons/yr These limits have been revised as follows according to the application received on September 25, 2018: o NOx — 11 .2 tons/yr; CO — 11 .2 tons/yr; VOC — 2.7 tons/yr The annual emission limitations (calculated on a rolling 12-month total), associated compliance monitoring, and recordkeeping requirements have been included in the operating permit. • (Condition 4) Consumption of natural gas as fuel shall not exceed 105.0 MMscf/year. Compliance with the yearly consumption limits shall be determined on a rolling twelve (12) month total. Monthly records of the actual consumption rate shall be maintained by the applicant and made available to the Division for inspection upon request. (Regulation No. 3, Part B, Section II.A.4) The natural gas consumption limit has been revised as follows according to the application received on September 25, 2018: o Natural gas consumption — 61.40 MMscf/yr The natural gas consumption limit and associated compliance demonstration and recordkeeping requirements have been included in the operating permit. • (Condition 5) This source is subject to the requirements of Regulation No. 8, Part E, Section III, Subpart ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines of 40 CFR 63, Subpart ZZZZ; and Regulation No. 8, Part E, Section I, Subpart A, National Emission Standards for Hazardous Air Pollutants for Source Categories: General Provisions, 40 CFR Part 63; including, but not limited to, the following: o Reduce formaldehyde by 76% or more; or limit the concentration of formaldehyde in the engine exhaust to 350 ppbvd or less at 15% O2. o Operating limitations related to catalyst inlet temperature and pressure drop The applicable requirements of 40 CFR 63 Subpart ZZZZ and Subpart A (as adopted in Regulation No. 8) have been included in the operating permit. • (Condition 6) This equipment is subject to the control requirements for stationary and portable engines in the 8-hour ozone control area under Regulation No. 7, Section XVI.B.1 . For rich burn reciprocating internal 123/0057 Page 30 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit combustion engines, a non-selective catalyst reduction system and an air fuel controller shall be required. The applicable requirements of Regulation No. 7, Part E, Section I.B (previously Section XVI.B) have been included in the operating permit. • (Condition 11) The engine shall not be operated in excess of 923 horsepower based upon the most recent Division-approved performance test. This limitation on the operating load for compressor engine EU-101 has been established because Kerr-McGee has been unable to test the emission rate of pollutants while operating within 90% of maximum horsepower (1478 HP). Subsequent testing on June 16, 2016 demonstrated compliance with permitted limits at 932 HP, and the source has requested to permit the engine at emission and fuel use levels associated with this load. Therefore, the operational horsepower limit has not been included in the operating permit, since emission and fuel use limits prevent this engine from being operated above a level at which emissions have been verified. • (Condition 12) The applicant shall follow the most current operating and maintenance plan and record keeping format approved by the Division in order to demonstrate compliance on an ongoing basis with the requirements of Condition Nos. 3 - 5 listed above. (Reference: Regulation No. 3, Part B, Section III.G.7.) Operation and maintenance requirements, parameter monitoring, and recordkeeping requirements have been directly incorporated into the operating permit in order to monitor compliance with emission limitations and other requirements for this engine. Although not specifically identified in Colorado Construction Permit 00WE0582, this engine is subject to the following applicable requirements: • Colorado Regulation No. 7, Part E, Section II.A.6 (previously Section XVI.D.6) contains requirements (effective January 14, 2017) for combustion process adjustments for combustion equipment. Applicability is based on uncontrolled actual NOx emissions being greater than five tons per year. The requirements of Colorado Regulation No. 7, Part E, Section II.A.6 have been included in the operating permit. 2. Emission Factors Emission limits from the current construction permit have been incorporated into the operating permit. These emission limits are based on manufacturer emission factors for NOx, CO, and VOC provided in the original application. The construction permit emission factors are in units of g/hp-hr; these have been converted to lb/MMBtu for the operating permit according to Division policy. These emission factors, as well as the emission factor for formaldehyde, the most abundant HAP emitted during operation of the engine, are shown in the table 123/0057 Page 31 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit below. All other emissions (criteria and HAP) were calculated based on emission factors from AP-42, Table 3.2-3. Emission Factors for EU-101 Pollutant Uncontrolled Controlled Uncontrolled Controlled Source (g/hp-hr) (g/hp-hr) (lb/MMBtu)1 (Ib/MMBtu)12 NOx 16.0 1.25 4.60 0.359 Manuf. CO 13.0 1.25 3.73 0.359 Manuf. VOC 0.30 0.30 0.086 0.086 Manuf. Formaldehyde 0.40 0.10 0.115 0.029 GRI 1Conversion from g/hp-hr to lb/MMBtu was made using a BSFC of 7675 Btu/hp-hr 'Controlled emission factors are based on control efficiencies using the NSCR system: NOx- 92%; CO 90%; Formaldehyde -80% 3. Monitoring Plan In order to monitor compliance with the annual emission and fuel consumption limits, the source will be required to monitor fuel consumption and calculate emissions on a monthly basis. The heat content of the natural gas used to fuel this engine is required to be determined semiannually in order to calculate emissions using recorded natural gas consumption. In addition, quarterly monitoring using a portable analyzer will be required to monitor compliance with the NOx and CO annual emission limits and emission rates. To ensure proper operation of the control equipment, monitoring of the catalyst inlet temperature (daily) and catalyst differential pressure (monthly) is required. The catalyst inlet temperature must be maintained within the recommended range for rich burn engines and the differential pressure must be maintained within 2 inches of water column from the value recorded during the most current portable analyzer test that demonstrated compliance with the annual emission limits. These control equipment parameters are monitored under the Compliance Assurance Monitoring requirements of 40 CFR Part 64. Compliance with the opacity limits is presumed, in absence of credible evidence to the contrary, since only natural gas is permitted for use as fuel in these engines. 4. Compliance Status The Division completed a full compliance evaluation at the facility on August 31 , 2016. It was found that Kerr-McGee failed to submit the appropriate Applicability Report following an AOS permanent engine replacement on February 15, 2016. The report was subsequently submitted on March 6, 2017 and no enforcement was recommended. The Division found that EU-101 was in compliance with all other requirements of Construction Permit 00WE0582 and applicable air pollution control regulations. D. F002: Fugitive Emissions from Equipment Leaks associated with the natural gas processing facility (AIRS point 018) 123/0057 Page 32 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit 1. Applicable Requirements: Colorado Construction Permit 00WE0583 was originally issued on December 22, 2000 as Initial Approval for fugitive emissions associated with the natural gas processing portion of this facility. Modification 1 was issued on January 7, 2002 for an increase in emissions. Modification 2 was issued on August 4, 2010 to incorporate the control efficiencies from Table 5-3 of EPA document EPA-453/R-95-017, based on a leak detection and repair program with quarterly monitoring. A Final Authorization to Operate letter was issued for this permit on June 4, 2012. The fugitive emissions associated with this permit have been included in a consolidated annual VOC emission limit for fugitive emissions, aggregated from Condition 6.1 of the original operating permit and this construction permit, as required by the consent decree. A modification to include a revised emission limit, based on updated component counts and control efficiencies based on the monthly leak detection and repair program specified by NSPS OOOOa, was received on September 25, 2018. The applicable requirements of Colorado Construction Permit 00WE0583 have been included in the operating permit as follows, with revisions according to the application received on September 25, 2018: • (Condition 4) Emissions of air pollutants shall not exceed the following limitations. Compliance with the annual limits shall be determined on a rolling twelve (12) month total. The permit holder shall calculate monthly emissions and keep a compliance record on site, or at a local field office with site responsibility, for Division review. (Reference: Regulation No. 3, Part B, II.A.4) o VOC — 43.66 tons/year, 3.7 tons/month (based on a 31 day month) The annual emission limit has been revised to 26.92 tons/yr according to the application received on September 25, 2018. This limit now includes all fugitive emissions from equipment leaks at the Fort Lupton facility. The monthly emission limit has not been included in the operating permit, as this was only required for the first 12 months of operation. The annual emission limitation (calculated on a rolling 12-month total), associated compliance monitoring, and recordkeeping requirements have been included in the operating permit. • (Condition 5) The operator shall calculate actual emissions from this emissions point based on representative actual component counts for the facility along with the most recent gas analysis. The requirement to calculate emissions based on actual component counts and the most recent gas analysis has been included in the operating permit. • (Condition 6) Visible emissions shall not exceed 20% opacity during normal operations of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1 , Section I I.A.1 & 4) The visible emissions limitations have not been included in the operating permit since this source only emits VOCs. 123/0057 Page 33 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit • (Condition 8) This source is subject to the requirements of 40 CFR Part 63, Subpart HH — National Emission Standards for Hazardous Air Pollutants from Oil and Natural Gas Production Facilities, including, but not limited to, the following: o §63.670 — Applicability and designation of affected source: §63.670(g)(1) exempts sources that are required to comply with 40 CFR 60, Subpart KKK from the provisions of 40 CFR 63, Subpart HH. MACT HH formerly exempted facilities if subject to NSPS Subpart KKK, but this exemption was removed in the latest revision, promulgated on August 16, 2012. An EPA Response on pg. 301 (Section 3.4.2.1) in Final Response to Public Comments on Proposed Rule, published April 17, 2012, specified that language in §63.760(g)(1) was deleted and language in §63.769(b) was revised to exclude NSPS KKK from the exemption because the valve leak definition in subpart HH was revised to 500 ppm and NSPS KKK has a 10,000 ppm leak definition for valves so they are no longer equivalent. The applicable provisions of MACT HH for equipment leaks have been streamlined out of the operating permit for the requirements of NSPS OOOOa. (See Section III: Applicable Requirements and Section VII: Streamlining of Applicable Requirements) • (Condition 9) This source is subject to Regulation No. 7, Section XII.C, General Provisions (State only enforceable). All condensate collection, storage, processing and handling operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. The Reg. 7, Part D, Section I.C.1 .b (previous Section XII.C.1 .b) requirement to minimize VOC leakage to the atmosphere from condensate operations is required in Part D, Section I.G for gas-processing plants. Though, in the construction permit, this condition states that this requirement is State only enforceable, this requirement is both State and Federally enforceable since the facility is located in the 8-hour Ozone Control Area. This requirement has been included in the operating permit. • (Condition 10) This source is subject to Regulation No. 7, Section XII.G.1 (State only enforceable). For fugitive VOC emissions from leaking equipment, the leak detection and repair (LDAR) program as provided at 40 CFR 60, Subpart KKK shall apply, regardless of the date of construction of the affected facility. Though this condition states that this requirement is State only enforceable, this requirement is both State and Federally-enforceable since the facility is located in the 8-hour Ozone Control Area. This requirement (current Reg. 7, Part D, Section I.G.1) has been updated in the revisions to Reg. 7 adopted on November 16, 2017 to require compliance with the leak detection and repair (LDAR) program of 40 CFR 60 Subpart OOOO, unless the natural gas- processing plant is subject to the LDAR program of Subpart OOOOa. This requirement has been included in the operating permit. 123/0057 Page 34 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit • (Condition 11) This facility is subject to the New Source Performance Standards requirements of Regulation No. 6, Part A, Subpart KKK, Standards of Performance for Onshore Natural Gas Processing Plants including, but not limited to, the following: o §60.632 - Standards; §60.633 — Exceptions; §60.632 — Recordkeeping; §60.632 — Reporting The applicable requirements from 40 CFR 60, Subpart KKK have not been included in the operating permit since the Fort Lupton facility is complying with the requirements of NSPS OOOOa. (See 40 CFR 60 Subpart KKK in Section Ill: Applicable Requirements, above). • (Condition 12) On an annual basis, the permittee shall complete a gas analysis of gas samples that are representative of VOC and HAP that may be released as fugitive emissions. This extended gas analysis shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. The requirement to conduct annual gas and liquids analyses of samples representative of VOC and HAP fugitive emissions, and to use these to demonstrate compliance with the annual emission limits, has been included in the operating permit. • (Condition 13) This facility is subject to the leak detection and repair (LDAR) requirements of 40 CFR Part 60, Subpart KKK. The applicable requirements from 40 CFR 60, Subpart KKK have not been included in the operating permit since the Fort Lupton facility is complying with the requirements of NSPS OOOOa. (See 40 CFR 60 Subpart KKK in Section Ill: Applicable Requirements, above). • (Condition 18) MACT Subpart HH requirements for major stationary sources shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit limitation. (Reference: Regulation No. 8, Part E) This condition was not included in the operating permit because it is in error; relaxation requirements apply only under Colorado Regulation No. 3, Part D. MACT applicability is based on HAP potential to emit. This facility is now considered a major source of HAP, subject to the requirements of MACT HH, however, Fort Lupton is currently complying with the requirements of NSPS OOOO and so is exempt from the equipment leak standards of MACT HH per §63.769(b). 2. Emission Factors Emissions from equipment leaks have been calculated based on emission factors from EPA's Protocol for Emission Leak Estimates (EPA 453/R-95-017, Table 2-4, Nov 1995). EPA factors (in kg/component-hr, converted to lb/component-hr) are given in terms of Total Organic Compounds and are multiplied by the number of 123/0057 Page 35 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit components of each type (e.g. Pump Seals) and the VOC weight fraction of the stream as determined in the most recent analysis. Emissions by component type are summed to calculate total emissions, assuming 8760 hours per year of operation. The Division has determined the following control efficiencies to be applicable to facilities following the LDAR program of 40 CFR Part 60 Subpart OOOO/OOOOa: 96% - gas valves, 95% - light liquid valves, 86% - light liquid pumps, 81% - connectors in all services. These control efficiencies have been approved for use in calculating fugitive emissions for this source. The table below contains the component counts used to develop the permit limits. Component Count' Component Gas Service Light Liquids Heavy Liquids Valves 6322 3680 590 Connectors 20353 10078 6386 Flanges 3977 1758 298 Pump Seals 0 16 19 Open-Ended Lines 0 0 0 Other 240 47 2 'Component counts are based on December 2016 actual component counts and multiplied by 120%to account for future modifications. The following streams and associated weight percentages of VOC and HAP were used to develop the emission limits: Composition(wt%)1 Representative VOC Benzene Toluene Ethyl- VOC n-Hexane 224-TMP Fluid Benzene Inlet Gas 25 0.2 0.2 0.2 0.2 0.5 0.2 Fuel Gas 9 0.2 0.2 0.2 0.2 0.2 0.2 Residue Gas 9 0.2 0.2 0.2 0.2 0.2 0.2 C3+ 100 0 0 0 0 0 0 NGL 98 0.5 0.2 0.2 0.2 3 3 Condensate 100 1.5 3 0.5 1.5 7.5 1.5 Methanol 100 0 0 0 0 0 0 'Anticipated fluid composition is based on actual fluid compositions (Representative gas and liquids analyses were received on September 25, 2018)with 120%to 150%factors to account for variability in samples. 3. Monitoring Plan A running tally of all additions and subtractions to the component count has been required to be maintained to verify existing components and inventory. Kerr- McGee has stated that this running tally is maintained through the method of compliance for the LDAR program. Ongoing extended gas analyses and light liquid analyses of the representative streams used in the most recent application (September 25, 2018) have been required in the operating permit and shall be 123/0057 Page 36 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit used to determine the VOC weight percent of the streams for emission calculations. Kerr-McGee is subject to the requirements of 40 CFR 60 Subpart KKK, Subpart OOOOa, and 40 CFR Part 63 Subpart HH for fugitive VOC emissions from equipment leaks. The requirements of NSPS KKK have been streamlined out of the operating permit for the more stringent requirements of 40 CFR 60 Subpart OOOOa. 4. Compliance Status The Division completed a full compliance evaluation at the facility on August 31 , 2016. Kerr-McGee reported that two piping components were found leaking on December 15, 2015, and repairs were not completed within the 15 day timeframe required by NSPS KKK. The repairs were made on January 2, 2016 and no enforcement was recommended. The Division determined that the fugitive equipment leaks at the Fort Lupton facility (F001) were in compliance with all other requirements of Construction Permit 00WE0583 and Operating Permit 95OPWE013 and applicable air pollution control regulations. E. EU-38, EU-39: Two (2) Caterpillar 3612 TALE, 4SLB natural gas fired internal combustion engines, site-rated at 3550 HP, low NOx design, Serial Nos. 1YG00238 and 1YG00239, equipped with oxidation catalysts (AIRS point 020) 1. Applicable Requirements: Colorado Construction Permit 01WE0763 was originally issued for these units on January 7, 2002 as Initial Approval. A Final Approval permit was issued on January 10, 2005 that revised the horsepower and emission factors according to updated manufacturer information. The applicable requirements of Construction Permit 01WE0763 have been included in the operating permit as follows: • (Condition 1) Visible emissions shall not exceed 20% opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Opacity shall be measured by EPA Method 9 (Reference: Regulation No. 1, Section II.A.1 & 4) This condition has been included in the operating permit. The EPA Method 9 requirement has been replaced with language specifying that compliance with the opacity limit shall be presumed, in absence of credible evidence to the contrary, since only natural gas is permitted for use as fuel in this engine. This condition has been modified to include all of the operating scenarios applicable to the Section I I.A.4 30% standard. • (Condition 3) Emissions of air pollutants, from the two engines, shall not exceed the following limitations. Compliance with the synthetic minor status of this facility shall be determined by recording the facility's annual permitted criteria pollutant emissions, from each emission unit, on a rolling (12) month total. The permit holder shall calculate monthly emissions and keep a compliance record 123/0057 Page 37 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit on site, or at a local field office with site responsibility, for Division review. (Reference: Regulation No. 3, Part B, II.A.4) o NOx — 48.0 tons/yr; VOC — 15.1 tons/yr; CO — 12.0 tons/yr The annual emission limitations (calculated on a rolling 12-month total), associated compliance monitoring, and recordkeeping requirements have been included in the operating permit. • (Condition 4) Total consumption of natural gas as fuel for both engines shall not exceed 440 MMscf/year. Compliance with the yearly consumption limits shall be determined on a rolling twelve (12) month total. The permit holder shall calculate monthly consumption of natural gas and keep a compliance record on site or at a local field office with site responsibility, for Division review. (Reference: Regulation 3, Part B, II.A.4) The natural gas consumption limit and associated compliance and recordkeeping requirements have been included in the operating permit. • (Condition 5) The applicant shall follow the most current operating and maintenance plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. (Reference: Regulation No. 3, Part B, III.G.7) Operation and maintenance requirements, parameter monitoring, and recordkeeping requirements have been directly incorporated into the operating permit in order to monitor compliance with emission limitations and other requirements for this engine. • (Condition 7) This source shall be subject to the requirements of 40 CFR 63, Subpart ZZZZ (National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines) on the date as stated in the rule, following publication of the final rule in the Federal Register. The applicable requirements of 40 CFR 63 Subpart ZZZZ have been included in the operating permit. • (Condition 8) Alternative Operating Scenario (AOS) for temporary engine replacement. A current version of the standard AOS, for temporary or permanent replacement, is included in Section I, Condition 2 of the operating permit. • (Condition 9) Alternative Operating Scenario (AOS) for permanent engine replacement. A current version of the standard AOS, for temporary or permanent replacement, is included in Section I, Condition 2 of the operating permit. Although not specifically identified in Colorado Construction Permit 01WE0763, these engines are subject to the following applicable requirements: 123/0057 Page 38 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit • Colorado Regulation No. 7: o Part E, Section I.A and I.B (previously Section XVI.A and XVI.B) requirement to employ catalysts for engines over 500 horsepower in the 8-hr Ozone Control Area. o Part E, Section II.A.6 (previously Section XVI.D.6) contains requirements (effective January 14, 2017) for combustion process adjustments for combustion equipment. Applicability is based on uncontrolled actual NOx emissions being greater than five tons per year. The requirements of Part E, Section II.A.6 have been included in the operating permit. 2. Emission Factors Emission limits from the current construction permit have been incorporated into the operating permit. These emission limits are based on manufacturer emission factors for NOx, CO, and VOC provided in the most recent modification application. These emission factors are shown in the table below, along with the emission factors for formaldehyde, acrolein and acetaldehyde, which are based on control efficiencies using the oxidation catalyst. The construction permit emission factors are in units of g/hp-hr; these have been converted to lb/MMBtu for the operating permit according to Division policy. All other emissions (criteria and HAP) were calculated based on emission factors from AP-42, Table 3.2-3. Emission Factors for EU-38, EU-39 Pollutant Uncontrolled Controlled Uncontrolled Controlled Source (g/hp-hr) (g/hp-hr) (lb/MMBtu)1 (Ib/MMBtu)1,2 NOx 0.70 0.70 0.217 0.217 Manuf. CO 2.50 0.175 0.776 0.054 Manuf. VOC 0.55 0.22 0.171 0.068 Manuf. Formaldehyde 0.4 0.028 0.1242 0.009 Manuf. Acetaldehyde 0.027 0.011 0.00836 0.00334 AP 42, Table 3.2-2 Acrolein 0.017 0.007 0.00514 0.00206 AP 42, Table 3.2-2 1Conversion from g/hp-hr to lb/MMBtu made using a BSFC of 7100 Btu/hp-hr 2Controlled emission factors are based on control efficiencies using the oxidation catalyst: CO and formaldehyde—93%; VOC, acetaldehyde, and acrolein—60% 3. Monitoring Plan In order to monitor compliance with the annual emission and fuel consumption limits, the source will be required to monitor fuel consumption and calculate emissions on a monthly basis. The heat content of the natural gas used to fuel these engines is required to be determined semiannually in order to calculate emissions using recorded natural gas consumption. In addition, quarterly monitoring using a portable analyzer will be required to monitor compliance with the NOx and CO annual emission limits and emission rates. 123/0057 Page 39 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit To ensure proper operation of the control equipment, monitoring of the catalyst inlet temperature (daily) and catalyst differential pressure (monthly) is required. The catalyst inlet temperature must be maintained within the recommended range for lean burn engines and the differential pressure must be maintained within 2 inches of water column from the value recorded during the most current portable analyzer test that demonstrated compliance with the annual emission limits. Compliance with the opacity limits is presumed, in absence of credible evidence to the contrary, since only natural gas is permitted for use as fuel in these engines. 4. Compliance Status The Division completed a full compliance evaluation at the facility on August 31 , 2016. According to the inspection report, engines EU-38 and EU-39 were in compliance with Construction Permit 01WE0763 E0763 and applicable air pollution control regulations. F. EU-34R: One (1) Waukesha L7042 GSI, 4SRB natural gas fired internal combustion engine, rated at 1232 HP (manufacturers' maximum), Serial No. 250451, equipped with an Air-Fuel-Ratio controller and a Non Selective Catalytic Reduction system (AIRS point 025) 1. Applicable Requirements: Colorado Construction Permit 07WE0366 was issued for this unit on August 28, 2007 as initial approval. A self-certification package was received by the Division on April 1, 2008 demonstrating compliance with the initial approval construction permit under the provisions of Regulation No. 3, Part B, Section III.G.2 but a final approval construction permit has not been issued. Under the provisions of Regulation No. 3, Part C, Section V.A.3, the Division will not issue a final approval construction permit and is allowing the initial approval construction permit to continue in full force and effect. The applicable requirements of Construction Permit 07WE0366 have been incorporated into the operating permit as follows, with emission factors revised according to the application received on December 5, 2018: • (Condition 1) Visible emissions shall not exceed twenty percent (20%) during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. EPA Method 9 shall be used to measure opacity. (Reference: Regulation No. 1 , Section II.A.1 & 4) This condition has been included in the operating permit. The EPA Method 9 requirement has been replaced with language specifying that compliance with the opacity limit shall be presumed, in absence of credible evidence to the contrary, since only natural gas is permitted for use as fuel in this engine. This condition has been modified to include all of the operating scenarios applicable to the Section I I.A.4 30% standard. • (Condition 3) Emissions of air pollutants shall not exceed the following limitations. Compliance with the synthetic minor status of this facility shall be 123/0057 Page 40 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit determined by recording the facility's annual permitted criteria pollutant emissions, from each emission unit, on a rolling twelve (12) month total. The permit holder shall calculate monthly emissions and keep a compliance record on site, or at a local field office with site responsibility, for Division review. (Reference: Regulation No.3, Part B, Section II.A.4) o NOx — 23.8 tons/yr, 4041 .0 lb/month o VOC — 1.8 tons/yr, 302.4 lb/month o CO — 35.7 tons/yr, 6062.4 lb/month The monthly emission limits have not been included in the operating permit, as these were only required for the first twelve months of operation. The annual emission limitations (calculated on a rolling 12-month total), associated compliance monitoring, and recordkeeping requirements have been included in the operating permit. • (Condition 4) This source shall be limited to a maximum consumption rate as listed below and all other activities, operational rates and numbers of equipment as stated in the application. Monthly records of the actual consumption rate shall be maintained by the applicant and made available to the Division for inspection upon request. Compliance with the yearly consumption limits shall be determined on a rolling twelve (12) month total. (Reference: Regulation No. 3, Part B, Section II.A.4) o Consumption of natural gas as fuel shall not exceed 7.4 MMscf/month and 87.4 MMscf/year. The monthly fuel consumption limit has not been included in the operating permit since this was only required for the first twelve months of operation. The yearly fuel consumption limit and associated monitoring and record keeping requirements have been included in the operating permit. • (Condition 5) A source compliance test shall be conducted to measure the emission rate(s) for Oxides of Nitrogen and Carbon Monoxide, using EPA approved methods. (Reference Regulation No. 3, Part B, Section III.G.3) This condition has been satisfied with testing performed on February 5, 2008 that demonstrated compliance with the permitted NOx and CO emissions rates. Therefore, this condition has not been included in the operating permit. • (Condition 6) This engine shall be equipped with a NSCR system capable of reducing uncontrolled emissions as follows. Operating parameters of the control equipment are identified in the operating and maintenance plan for this engine and shall replace the control efficiency requirement in the final permit. (Reference: Regulation No. 3, Part B, Section IV.E) o NOx: at least 85% o CO: at least 67% 123/0057 Page 41 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit o VOC: at least 50% o Formaldehyde: at least 76% The requirement to meet pollutant specific control efficiencies has not been included in the operating permit. Permitted emission limits are based on these control efficiencies and uncontrolled emission factors provided by the source. Required monitoring of operating parameters associated with the control device has been included in the operating permit. • (Condition 7) Within 180 days after commencement of operation, the applicant shall adopt and follow the operating and maintenance plan and recordkeeping format as specified in Attachment B, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. (Reference: Regulation No. 3, Part B, Section III.G.7) Operation and maintenance requirements, parameter monitoring, and recordkeeping requirements have been directly incorporated into the operating permit in order to monitor compliance with emission limitations and other requirements for this engine. • (Condition 8) The applicant shall follow the most current operating and maintenance plan and recordkeeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. (Reference: Regulation No. 3, Part B, Section III.G.7) Operation and maintenance requirements, parameter monitoring, and recordkeeping requirements have been directly incorporated into the operating permit in order to monitor compliance with emission limitations and other requirements for this engine. • (Condition 10) This source shall be subject to the requirements of Regulation No. 7, Section XVI. For rich burn reciprocating internal combustion engines, a non-selective catalyst reduction and an air fuel controller shall be required. The emission control equipment required by this section XVI.B shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The applicable requirements of Regulation No. 7, Part E, Section I.B (previously Section XVI.B) have been included in the operating permit. • (Condition 11) This source is subject to the requirements of Regulation No. 8, Part E, Section III, Subpart ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines and Section I, Subpart A: General Provisions, including, but not limited to, the following: o Reduce formaldehyde by 76% or more; or limit the concentration of formaldehyde in the engine exhaust to 350 ppbvd or less at 15% O2. 123/0057 Page 42 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit o Operating limitations related to catalyst inlet temperature and pressure drop. o Operate and maintain the stationary RICE in a manner consistent with good air pollution control practices for minimizing emissions. The applicable requirements of 40 CFR 63 Subpart ZZZZ (RICE MACT) and 40 CFR 63 Subpart A (General Provisions) have been included in the operating permit. • (Condition 13) This emission unit may supersede the EU-34 Waukesha L-7042 GSI engine at this site, (123/0057/013). If this emission unit is removed, the Division shall be notified by letter, requesting the cancellation of this engine operating under permit 97WE0180. The EU-34R unit has replaced the original EU-34 unit permitted under 97WE0180. A cancellation for the original unit was received by the Division on April 20, 2011 . This condition has not been included in the operating permit. Although not specifically identified in Colorado Construction Permit 07WE0366, this engine is subject to the following applicable requirements: • Colorado Regulation No. 7, Part E, Section II.A.6 (previously Section XVI.D.6) contains requirements (effective January 14, 2017) for combustion process adjustments for combustion equipment. Applicability is based on uncontrolled actual NOx emissions being greater than five tons per year. The requirements of Colorado Regulation No. 7, Part E, Section II.A.6 have been included in the operating permit. 2. Emission Factors Emission limits from the current construction permit have been incorporated into the operating permit. These emission limits are based on manufacturer emission factors for NOx, CO, and VOC provided in the original application. These emission factors, as well as the emission factor for formaldehyde, the most abundant HAP emitted during operation of the engine, are shown in the table below. The construction permit emission factors are in units of g/hp-hr; these have been converted to lb/MMBtu for the operating permit according to Division policy. All other emissions (criteria and HAP) were calculated based on emission factors from AP-42, Table 3.2-3. Emission Factors for EU-34R Pollutant Uncontrolled Controlled Uncontrolled Controlled Source (g/hp-hr)' (g/hp-hr) (Ib/MMBtu)2 (lb/MMBtu)3 NOx 13.0 1.95 3.37 0.519 Manuf. CO 9.0 2.97 2.33 0.778 Manuf. VOC 0.30 0.15 0.078 0.039 Manuf. Formaldehyde 0.0707 0.017 0.0184 0.004 AP 42, (Table 3.2-3) 1Uncontrolled emission factors from the manufacturer were provided in g/hp-hr. 123/0057 Page 43 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit 'Conversion from g/hp-hr to lb/MMBtu was made using a BSFC of 8500 Btu/hp-hr for uncontrolled emission factors. 3Controlled emission factors are based on control efficiencies using the NSCR system, as provided by the catalyst manufacturer(NOx-85%; CO -67%; VOC- 50%; Formaldehyde — 76%). These factors were originally converted from g/hp-hr to lb/MMBtu using a BSFC of 7600 Btu/hp-hr, creating inconsistencies between fuel use and emission limits. Controlled emission factors have been revised to the ones shown above, converted using a BSFC of 8500 Btu/hp-hr. NOx and CO were converted using controlled emission factors that were rounded up to 2.0 and 3.0 g/hp-hr, respectively. 'Formaldehyde emission factor began as AP-42 (0.0205 lb/MMBtu), was converted to 0.0707 g/hp-hr using a BSFC of 7600 Btu/hp-hr, and then was converted to 0.0183 lb/MMBtu using a BSFC of 8500 Btu/hp-hr. 3. Monitoring Plan In order to monitor compliance with the annual emission and fuel consumption limits, the source will be required to monitor fuel consumption and calculate emissions on a monthly basis. The heat content of the natural gas used to fuel this engine is required to be determined semiannually in order to calculate emissions using recorded natural gas consumption. In addition, quarterly monitoring using a portable analyzer will be required to monitor compliance with the NOx and CO annual emission limits and emission rates. To ensure proper operation of the control equipment, monitoring of the catalyst inlet temperature (daily) and catalyst differential pressure (monthly) is required. The catalyst inlet temperature must be maintained within the recommended range for rich burn engines and the differential pressure must be maintained within 2 inches of water column from the value recorded during the most current portable analyzer test that demonstrated compliance with the annual emission limits. These control equipment parameters are monitored under the Compliance Assurance Monitoring requirements of 40 CFR Part 64. Compliance with the opacity limits is presumed, in absence of credible evidence to the contrary, since only natural gas is permitted for use as fuel in these engines. 4. Compliance Status The Division completed a full compliance evaluation at the facility on August 31 , 2016. According to the inspection report, engine EU-34R was in compliance with Construction Permit 07WE0366 and applicable air pollution control regulations. G. EU-103: One (1) Caterpillar G3616 LE, 4SLB natural gas fired internal combustion engine, site rated at 4262 HP, Serial No. BLB00452, equipped with an oxidation catalyst and AFR control (AIRS point 026) 1. Applicable requirements: Colorado Construction Permit 07WE0798 was issued for this unit on June 20, 2008 as initial approval. A final approval construction permit was issued on October 4, 2011 that increased the permitted annual fuel use and permitted annual emissions. The applicable requirements of Construction Permit 07WE0798 have been included in the operating permit as follows: • (Condition 2) Emissions of air pollutants shall not exceed the following limitations. Compliance with the synthetic minor status of this facility shall be 123/0057 Page 44 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling (12) month total. The permit holder shall calculate monthly emissions and keep a compliance record on site, or at a local field office with site responsibility, for Division review. (Reference: Regulation No. 3, Part B, Section II.A.4) o NOx — 30.4 tons/yr; VOC — 19.1 tons/yr; CO — 7.6 tons/yr The annual emission limitations (calculated on a rolling 12-month total), associated compliance monitoring, and recordkeeping requirements have been included in the operating permit. • (Condition 3) This engine shall be equipped with an oxidation catalyst and air- fuel ratio control. The oxidation catalyst shall be capable of reducing uncontrolled emissions of volatile organic compounds and carbon monoxide from the unit to the emission levels listed in Condition 2, above. Operating parameters of the control equipment are identified in the operation and maintenance plan. (Reference: Regulation No.3, Part B, Section III.E.) Permitted emission limits have been established based on control with an oxidation catalyst and parameter monitoring requirements for the control equipment, from the operation and maintenance plan, have been directly incorporated into the operating permit. Therefore, this condition has not been included in the operating permit. • (Condition 4) This source shall be limited to the following maximum consumption, processing and/or operational rates as listed below. Compliance with the yearly consumption limit shall be determined on a rolling twelve (12) month total. The permit holder shall calculate monthly consumption of natural gas and keep a compliance record on site or at a local field office with site responsibility, for Division review. (Reference: Regulation 3, Part B, II.A.4) o Consumption of natural gas — 269.30 MMscf/yr The limit on natural gas consumption and the associated monitoring and recordkeeping requirements have been included in the operating permit. • (Condition 6) Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1 , Section II.A.1. & 4.) This condition has been included in the operating permit and has been modified to include all of the operating scenarios applicable to the Section II.A.4 30% standard. Compliance with this opacity condition will be presumed, in absence of credible evidence to the contrary, whenever natural gas is used as fuel. • (Condition 8) This equipment is subject to the control requirements for stationary and portable engines in the 8-hour ozone control area under 123/0057 Page 45 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit Regulation No. 7, Section XVI.B.2. For lean burn reciprocating internal combustion engines, an oxidation catalyst shall be required. The applicable requirements of Colorado Regulation No. 7, Part E, Section I.B (previously Section XVI.B) have been included in the operating permit. • (Condition 9) This source is subject to the requirements of Regulation No. 8, Part E, Section III, Subpart ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines and Regulation No. 8, Part E, Section I, Subpart A: General Provisions, including, but not limited to, the following: o Reduce CO emissions by 93 percent or more; or limit concentration of formaldehyde in the stationary RICE exhaust to 14 ppmvd or less at 15 percent O2 o Operating limitations related to pressure drop across the catalyst and catalyst inlet temperature The applicable requirements of 40 CFR 63 Subpart ZZZZ and Subpart A (as adopted in Regulation No. 8) have been included in the operating permit. • (Condition 10) Upon startup of this point, the applicant shall follow the operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. (Reference: Regulation No. 3, Part B, Section III.G.7.) Operation and maintenance requirements, parameter monitoring, and recordkeeping requirements have been directly incorporated into the operating permit in order to monitor compliance with emission limitations and other requirements for this engine. • (Condition 11) This engine is subject to the periodic testing requirements of 40 C.F.R Part 63, Subpart ZZZZ. The applicable periodic testing requirements of 40 CFR 63, Subpart ZZZZ have been included in the operating permit. • (Condition 12) This engine is subject to the periodic testing requirements as specified in the operating and maintenance (O&M) plan as approved by the Division. Revisions to your O&M plan are subject to Division approval. Replacements of this unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A. Periodic testing has been included in the operating permit in the form of quarterly portable analyzer testing requirements which are used to monitor compliance with NOx and CO emission limitations. Additional portable analyzer testing is required within seven days of replacement of an engine under the Alternative Operating Scenario included in Section I, Condition 2. 123/0057 Page 46 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit Although not specifically identified in Colorado Construction Permit 07WE0798, this engine is subject to the following applicable requirements: • 40 CFR 60 Subpart JJJJ: The applicability of NSPS JJJJ was not included in the construction permit conditions but identified in the notes to permit holder since Colorado has not adopted this rule. The applicable provisions of NSPS JJJJ have been included in the operating permit per federal requirements. • Colorado Regulation No. 7, Part E, Section II.A.6 (previously Section XVI.D.6) contains requirements (effective January 14, 2017) for combustion process adjustments for combustion equipment. Applicability is based on uncontrolled actual NOx emissions being greater than five tons per year. The requirements of Colorado Regulation No. 7, Part E, Section II.A.6 have been included in the operating permit. 2. Emission Factors Emission limits from the current construction permit have been incorporated into the operating permit. These emission limits are based on manufacturer emission factors for NOx, CO, and VOC provided in the original application. These emission factors, as well as the emission factor for formaldehyde, the most abundant HAP emitted during operation of the engine, are shown in the table below. The construction permit emission factors are in units of g/hp-hr; these have been converted to lb/MMBtu for the operating permit according to Division policy. All other emissions (criteria and HAP) were calculated based on emission factors from AP-42, Table 3.2-3. Fuel use limits for this engine were revised during the issuance of the final approval permit to be based on a BSFC of 7243 Btu/hp-hr, resulting in an increase in fuel use and emission limits. However, emission factors were still converted from g/hp-hr to lb/MMBtu using a BSFC of 6867 Btu/hp-hr as specified in the initial issuance of 07WE0798. Using the lower BSFC for emission factor conversion results in slightly more conservative emission factors for use when calculating actual emissions. Emission Factors for EU-103 Pollutant Uncontrolled Controlled Uncontrolled Controlled Source (g/hp-hr) (g/hp-hr) (lb/MMBtu)1 (Ib/MMBtu)',z NOx 0.70 0.70 0.225 0.225 Manuf. CO 2.51 0.176 0.806 0.056 Manuf. VOC 0.61 0.439 0.196 0.141 Manuf. Formaldehyde 0.40 0.096 0.128 0.031 Manuf. 'Conversion from g/hp-hr to lb/MMBtu was made using a BSFC of 6867 Btu/hp-hr 2Controlled emission factors are based on control efficiencies using the oxidation catalyst system: CO 93%; VOC — 28%; Formaldehyde — 76% 3. Monitoring Plan In order to monitor compliance with the annual emission and fuel consumption limits, the source will be required to monitor fuel consumption and calculate emissions on a monthly basis. The heat content of the natural gas used to fuel this 123/0057 Page 47 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit engine is required to be determined semiannually in order to calculate emissions using recorded natural gas consumption. In addition, quarterly monitoring using a portable analyzer will be required to monitor compliance with the NOx and CO annual emission limits and emission rates. To ensure proper operation of the control equipment, monitoring of the catalyst inlet temperature (daily) and catalyst differential pressure (monthly) is required. The catalyst inlet temperature must be maintained within the recommended range for lean burn engines and the differential pressure must be maintained within 2 inches of water column from the value recorded during the most current portable analyzer test that demonstrated compliance with the annual emission limits. These control equipment parameters are monitored under the Compliance Assurance Monitoring requirements of 40 CFR Part 64. Compliance with the opacity limits is presumed, in absence of credible evidence to the contrary, since only natural gas is permitted for use as fuel in these engines. 4. Compliance Status The Division completed a full compliance evaluation at the facility on August 31 , 2016. According to the inspection report, engine EU-103 was in compliance with Construction Permit 07WE0798 and applicable air pollution control regulations. H. EU-104: One (1) Caterpillar G3616 LE, 4SLB natural gas fired internal combustion engine, site rated at 4735 HP, Serial No. BLB00539, equipped with an oxidation catalyst and Air-Fuel-Ratio control (AIRS point 028) 1. Applicable Requirements: Colorado Construction Permit 10WE1071 was issued for this engine on September 26, 2011 as Initial Approval. A Final Approval to Operate letter was issued on July 8, 2015. The applicable requirements of Construction Permit 10WE1071 have been included in the operating permit as follows: • (Condition 6) Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). Compliance with the annual limits shall be determined on a rolling (12) month total. The permit holder shall calculate monthly emissions and keep a compliance record on site, or at a local field office with site responsibility for Division review. (Reference: Regulation No. 3, Part B, Section II.A.4) o NOx - 32.0 tons/yr; CO - 8.0 tons/yr; VOC — 19.2 tons/yr The annual emission limitations (calculated on a rolling 12-month total), associated compliance monitoring, and recordkeeping requirements have been included in the operating permit. • (Condition 7) This engine shall be equipped with an oxidation catalyst and air- fuel ratio control. This emissions control system shall be capable of reducing uncontrolled emissions of volatile organic compounds and carbon monoxide 123/0057 Page 48 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit from the unit to the emission levels listed in Condition 6, above. Operating parameters of the control equipment are identified in the operation and maintenance plan. (Reference: Regulation No.3, Part B, Section III.E.) Permitted emission limits have been established based on control with an oxidation catalyst and parameter monitoring requirements for the control equipment, from the operation and maintenance plan, have been directly incorporated into the operating permit. Therefore, this condition has not been included in the operating permit. • (Condition 8) This source shall be limited to the following maximum consumption, processing and/or operational rates as listed below. Compliance with the yearly consumption limits shall be determined on a rolling twelve (12) month total. The permit holder shall calculate monthly consumption of natural gas and keep a compliance record on site or at a local field office with site responsibility, for Division review (Reference: Regulation 3, Part B, II.A.4) o Consumption of natural gas — 278.87 MMscf/yr The limit on natural gas consumption and the associated monitoring and recordkeeping requirements have been included in the operating permit. The consumption limit has been rounded up to 278.9 MMscf/yr. • (Condition 10) Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1 , Section II.A.1. & 4.) This condition has been included in the operating permit and has been modified to include all of the operating scenarios applicable to the Section II.A.4 30% standard. Compliance with this opacity condition will be presumed, in absence of credible evidence to the contrary, whenever natural gas is used as fuel. • (Condition 12) This equipment is subject to the control requirements for stationary and portable engines in the 8-hour ozone control area under Regulation No. 7, Section XVI.B.2. For lean burn reciprocating internal combustion engines, an oxidation catalyst shall be required. The applicable requirements of Colorado Regulation No. 7, Part E, Section I.B (previously Section XVI.B) have been included in the operating permit. • (Condition 13) This source is subject to the requirements of Regulation No. 8, Part E, Section III, Subpart ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines and Regulation No. 8, Part E, Section I, Subpart A: General Provisions, including, but not limited to, the following: o Reduce CO emissions by 93 percent or more; or limit concentration of formaldehyde in the stationary RICE exhaust to 14 ppmvd or less at 15 percent O2 123/0057 Page 49 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit o Operating limitations related to pressure drop across the catalyst and catalyst inlet temperature The applicable requirements of 40 CFR 63 Subpart ZZZZ and Subpart A (as adopted in Regulation No. 8) have been included in the operating permit. • (Condition 14) Upon startup of this point, the applicant shall follow the operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. (Reference: Regulation No. 3, Part B, Section III.G.7.) Operation and maintenance requirements, parameter monitoring, and recordkeeping requirements have been directly incorporated into the operating permit in order to monitor compliance with emission limitations and other requirements for this engine. • (Condition 15) A source initial compliance test shall be conducted on emissions point 028 to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emissions limits contained in this permit. o Oxides of Nitrogen, Carbon Monoxide, and Formaldehyde There is no limit for formaldehyde or individual HAP contained in this permit. An initial compliance test was conducted on November 11 , 2011 that demonstrated compliance with the emission limits for NOx and CO in this permit, as well as the limits for NSPS JJJJ. Formaldehyde results were below the level estimated in the permit application. This requirement has not been included in the operating permit. • (Condition 16) This engine is subject to the periodic testing requirements of 40 C.F.R Part 63, Subpart ZZZZ. The applicable periodic testing requirements of 40 CFR 63, Subpart ZZZZ have been included in the operating permit. • (Condition 17) This engine is subject to the periodic testing requirements as specified in the operating and maintenance (O&M) plan as approved by the Division. Revisions to your O&M plan are subject to Division approval. Replacements of this unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A. Periodic testing has been included in the operating permit in the form of quarterly portable analyzer testing requirements which are used to monitor compliance with NOx and CO emission limitations. Additional portable analyzer testing is required within seven days of replacement of an engine under the Alternative Operating Scenario included in Section I, Condition 2. • (Condition 19) Emissions from this point shall be released from an unobstructed vertical stack with a minimum height of 52.8 feet above ground level. 123/0057 Page 50 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit The stack height requirement has been included in the operating permit. • (Condition 20) This facility shall be completely enclosed by a fence line and posted with no trespassing signs that preclude public access to this site as described in the modeling analysis for this facility. This requirement is imposed as a result of the modeled ambient air NOx impacts that result from the emissions from this source. (Reference: Regulation No. 3, Part B, Section III.B.5) The requirement for the facility to be completely enclosed by a fence line to preclude public access has been included in the operating permit. Although not specifically identified in Colorado Construction Permit 10WE1071, this engine is subject to the following applicable requirements: • 40 CFR 60 Subpart JJJJ: The applicability of NSPS JJJJ was not included in the construction permit conditions but identified in the notes to permit holder since Colorado has not adopted this rule. The applicable provisions of NSPS JJJJ have been included in the operating permit per federal requirements. • Colorado Regulation No. 7, Part E, Section II.A.6 (previously Section XVI.D.6) contains requirements (effective January 14, 2017) for combustion process adjustments for combustion equipment. Applicability is based on uncontrolled actual NOx emissions being greater than five tons per year. The requirements of Colorado Regulation No. 7, Part E, Section II.A.6 have been included in the operating permit. 2. Emission Factors Emission limits from the current construction permit have been incorporated into the operating permit. These emission limits are based on manufacturer emission factors for NOx, CO, and VOC provided in the original application. These emission factors, as well as the emission factor for formaldehyde, the most abundant HAP emitted during operation of the engine, are shown in the table below. The construction permit emission factors are in units of g/hp-hr; these have been converted to lb/MMBtu for the operating permit according to Division policy. All other emissions (criteria and HAP) were calculated based on emission factors from AP-42, Table 3.2-3. Emission Factors for EU-104 Pollutant Uncontrolled Controlled Uncontrolled Controlled Source (g/hp-hr) (g/hp-hr) (lb/MMBtu)1 (Ib/MMBtu)',z NOx 0.70 0.70 0.229 0.229 Manuf. CO 2.51 0.176 0.820 0.057 Manuf. VOC 0.60 0.420 0.196 0.137 Manuf. Formaldehyde 0.40 0.096 0.131 0.031 Manuf. 'Conversion from g/hp-hr to lb/MMBtu was made using a BSFC of 6750 Btu/hp-hr 2Controlled emission factors are based on control efficiencies using the oxidation catalyst system: CO —93%; VOC - 30%; Formaldehyde -76% 3. Monitoring Plan 123/0057 Page 51 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit In order to monitor compliance with the annual emission and fuel consumption limits, the source will be required to monitor fuel consumption and calculate emissions on a monthly basis. The heat content of the natural gas used to fuel this engine is required to be determined semiannually in order to calculate emissions using recorded natural gas consumption. In addition, quarterly monitoring using a portable analyzer will be required to monitor compliance with the NOx and CO annual emission limits and emission rates. To ensure proper operation of the control equipment, monitoring of the catalyst inlet temperature (daily) and catalyst differential pressure (monthly) is required. The catalyst inlet temperature must be maintained within the recommended range for lean burn engines and the differential pressure must be maintained within 2 inches of water column from the value recorded during the most current portable analyzer test that demonstrated compliance with the annual emission limits. These control equipment parameters are monitored under the Compliance Assurance Monitoring requirements of 40 CFR Part 64. Compliance with the opacity limits is presumed, in absence of credible evidence to the contrary, since only natural gas is permitted for use as fuel in these engines. 4. Compliance Status The Division completed a full compliance evaluation at the facility on August 31 , 2016. According to the inspection report, Kerr-McGee failed to submit a revised APEN for EU-104 no later than 30 days before the existing APEN expired but no enforcement was recommended. The Division found that EU-104 was in compliance with all other requirements of Construction Permit 10WE1071 and applicable air pollution control regulations. I. F-4: One (1) John Zink 65' air assisted process flare used to control emissions from process equipment blowdowns associated with maintenance activities, compressor blowdowns, and venting such as for pressure relief valves or plant shutdowns. Serial No. 9148687 (AIRS point 070) 1. Applicable Requirements: Colorado Construction Permit 14WE0142 was issued for this process flare on July 9, 2015 as Initial Approval. A Final Approval to Operate letter was issued on January 27, 2016. The applicable requirements of Construction Permit 14WE0142 have been included in the operating permit as follows: • (Condition 4) As part of the self-certification process, the operator shall install a flow meter on the inlet to emissions unit F-4. The flowmeter shall be capable of continuously measuring and recording the flowrate of the combined gas streams routed to the flare for combustion. A flow meter has been installed for unit F-4 according the requirements of the condition above; therefore this condition has not been included in the operating permit, however the requirement to monitor the inlet volume of the combined gas streams to the flare using a flow meter has been included. 123/0057 Page 52 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit • (Condition 7) Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). Compliance with the annual limits shall be determined on a rolling (12) month total. The permit holder shall calculate monthly emissions and keep a compliance record on site, or at a local field office with site responsibility for Division review. (Reference: Regulation No. 3, Part B, Section II.A.4) o NOx — 8.5 tons/yr and 1444 lb/month o CO — 17.0 tons/yr and 2888 lb/nnonth o VOC — 12.7 tons/yr and 2158 lb/month o PM2.5— 0.3 tons/yr and 51 lb/month The annual emission limitations (calculated on a rolling 12-month total), associated compliance monitoring, and recordkeeping requirements have been included in the operating permit. Monthly limits have not been included since these are only required for the first twelve months of operation. PM2.5 emission limits have not been included in the operating permit since these are below APEN reporting levels of Colorado Regulation No. 3, Part A, Section I I.B.3.a. • (Condition 8) Emissions from maintenance activities and purge gas shall be collected and controlled by a flare in order to reduce the emissions of volatile organic compounds to the level listed in this section, above. Operating parameters of the flare are identified in the operation and maintenance plan for this unit. Flare combustion efficiency shall be a minimum of 98%. (Reference: Regulation No.3, Part B, Section III.E.) The requirement to route maintenance activities and purge gas to the flare has been included in the operating permit. The combustion efficiency and the requirement to collect and control emissions from maintenance activities and purge gas are incorporated through the permit limits and associated monitoring of the flare's operating parameters. • (Condition 9) This source shall be limited to the following maximum processing rates as listed below. Compliance with the yearly throughput limits shall be determined on a rolling twelve (12) month total. The permit holder shall calculate monthly consumption of natural gas and keep a compliance record on site or at a local field office with site responsibility, for Division review. (Reference: Regulation 3, Part B, II.A.4) o Natural gas combustion (Process and Purge gas) — 78.4 MMscf/yr and 6.7 MMscf/month The annual limit on natural gas consumption for the flare has been included in the operating permit, along with the associated compliance monitoring and recordkeeping requirements. The monthly consumption limit has not been included in the operating permit since this was only required for the first twelve months of operation. 123/0057 Page 53 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit • (Condition 10) The operator shall continuously monitor the process and upset flare to ensure the presence of a pilot flame. The requirement to continuously monitor the presence of a pilot flame in the flare has been included in the operating permit. • (Condition 11) The operator shall continuously monitor and record the total volumetric flow rate of the gas stream being routed to the flare. By the end of each month, the total volumetric flow for the previous months' data shall be calculated, and a new twelve-month total shall be calculated and recorded based on the previous twelve months' data. The requirement to continuously monitor the volumetric flow rate of the process and purge gas stream routed to the flare has been included in the operating permit. The pilot gas rate will be monitored based on the maximum design rate of the pilot and the hours of operation. Flow rates are required to be recorded on a monthly basis and throughput calculated on a twelve month rolling total to monitor compliance with the annual limitation. • (Condition 13) Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1 , Section II.A.1. & 4.) The opacity requirements of Reg. 1 Sections II.A.1 & 4 do not apply to process flares. Language in Section II.A.1 states "Except as provided for in paragraphs 2 through 6 below..." and Section II.A.5 gives a 30% opacity requirement for flares that is applicable at all times. Therefore, these requirements have not been included in the operating permit. The Section II.A.5 opacity requirement of 30% has been included in the operating permit. Compliance with this condition will be presumed, absent credible evidence to the contrary, based on the more stringent requirement for no visible emissions specified in Condition 15 below. • (Condition 15) The Division has determined this flare shall comply with the New Source Performance Standards requirements of Subpart A Section §60.18, General Control Device and Work Practice Requirements, including, but not limited to, the following: The Division has used the requirements of §60.18 as a model to establish periodic monitoring for this flare. The requirement to follow 40 CFR §60.18 for the design, construction, operation, and maintenance of the flare was included in this construction permit in accordance with the provisions of Colorado Regulation No. 3, Part B, Section III.E, which allows the Division to include any such terms and conditions which it deems necessary for the proposed project or activity to qualify for the permit. This flare is not subject to any applicable NSPS provisions of 40 CFR Part 60 that include these requirements for the flare. The operation and maintenance requirements of this condition have been 123/0057 Page 54 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit maintained for the flare, while specific compliance demonstration methods have been revised to comport with monitoring already required by the source. o Flares shall be designed for and operated with no visible emissions as determined by the methods specified in §60.18(f). (§60.18(c)(1)) A monitoring scheme has been included in the operating permit to determine a frequency of monitoring for 40 CFR §60.18(c)(1), requiring that the flare be operated with no visible emissions, since no frequency is stated in the rule. The monitoring included requires visual emissions observations to be performed daily, with a full Method 22 observation to be conducted whenever visual emissions are present during the initial observation. o Flares shall be operated with a flame present at all times, as determined by the methods specified in §60.18(f). (§60.18(c)(2)) Section 60.18(f) requires a thermocouple or equivalent device to monitor the presence of a flame, but does not give a monitoring frequency. This language has been revised to specify that the pilot flame must be monitored continuously, the device shall be equipped with an alarm to indicate no ignition of the flame, and records shall be kept of all pilot flame outages. o Flare specifications on heat content and maximum exit velocity per §60.18(c)(3) and §60.18(c)(5). 40 CFR §60.18(c)(3) states that "An owner/operator has the choice of adhering to either the heat content specifications in paragraph (c)(3)(ii) of this section and the maximum tip velocity specifications in paragraph (c)(4) of this section, or adhering to the requirements in paragraph (c)(3)(i) of this section", however, since the exit velocity specifications of (c)(4) apply only to steam-assisted and non-assisted flares, and the requirements of (c)(3)(i) specify that the flare be non-assisted, the requirements of (c)(3) are not compatible with an air-assisted flare. Therefore, only the requirements of 40 CFR §60.18 applicable to air- assisted flares have been included in the operating permit, although they may not comport with section (c)(3). These include section (c)(3)(ii) for heat content of gases routed to the flare and section (c)(5) for maximum exit velocity. The provisions of §60.18(c)(3)(i) were included in the construction permit, but these provisions are for a non-assisted flare, and so were not included in the operating permit since the permitted flare is air-assisted. o 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. (§60.18(c)(3)(ii)) 123/0057 Page 55 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit The heat content requirement of gases routed to the flare in §60.18(c)(3)(ii) references §60.18(f)(3) for the determination of the heat content. This reference has been changed to the ongoing heat content monitoring required for calculation of monthly emissions from the flare, which is to be determined using ASTM methods or equivalent, if approved in advance by the Division. o Air-assisted flares shall be designed and operated with an exit velocity less than the velocity, Vmax, as determined by the method specified in paragraph (f)(6). (§60.18(c)(5)) This requirement has been included in the operating permit, as well as the method for calculating exit velocity as specified in §60.18(f)(4). In order to monitor compliance with this requirement, the source will be required to calculate the maximum exit velocity of the flare monthly, based on actual operating conditions, and compare it to the limit specified by §60.18(f)(6). o Flares used to comply with this section shall be steam-assisted, air- assisted, or nonassisted. (§60.18(c)(6)) The permitted flare is an air-assisted flare; therefore, this condition is unnecessary and has not been included in the operating permit. o The flare shall be monitored to ensure it is operated and maintained in conformance with its design. (§60.18(d)) Record keeping requirements, including manufacturer operation and maintenance requirements and maintenance performed on the flare, have been included in the operating permit to monitor compliance with this condition. o Flares used to comply with provisions of this subpart shall be operated at all times when emissions may be vented to them. (§60.18(e)) This requirement has been included in the operating permit. o Method 22 of appendix A to this part shall be used to determine the compliance of flares with the visible emission provisions of this subpart. The observation period is 2 hours and shall be used according to Method 22. (§60.18(f)(1)) The requirement to use Method 22 to monitor for visual emissions has been included in the operating permit. A visible emissions observation has been required daily, with a full two hour observation required whenever visible emissions are present during the daily observation. o 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. (§60.18(f)(2)) This requirement has been included in the operating permit. 123/0057 Page 56 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit o The net heating value of the gas being combusted in a flare shall be calculated using the equation of §60.18(f)(3). The reference for the determination of heat content has been changed to the ongoing heat content monitoring required for emissions calculations. o The actual exit velocity of a flare shall be determined by dividing the volumetric flowrate (in units of standard temperature and pressure), as determined by Reference Methods 2, 2A, 2C, or 2D as appropriate; by the unobstructed (free) cross sectional area of the flare tip. (§60.18(f)(4)) This requirement has been included in the operating perrnit. o Determination of maximum permitted velocity, Vmax, for flares complying with paragraph (c)(4)(iii). (§60.18(f)(5)) §60.18(c)(4)(iii) is for steam-assisted and non-assisted flares. Since this is an air-assisted flare, this condition has not been included in the operating perrnit. o Determination of maximum permitted velocity for air-assisted flares (§60.18(f)(6)) The requirement to calculate the maximum permitted exit velocity according to §60.18(f)(6) has been included in the operating permit. • (Condition 16) This facility is located in an ozone non-attainment or attainment- maintenance area and subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. RACT requirements are met by controlling process emissions by combustion using an open flare. This requirement has not been included in the operating permit. RACT applies to minor sources located in non-attainment and attainment/maintenance areas. The uncontrolled potential to ernit of the process, maintenance, and other various emissions that are vented to this flare is above the major source level as defined in Colorado Regulation No. 3, Part B, Section I.B.25. The specific emission rates for each source of gases vented to this flare have not been analyzed or defined. This flare would potentially serve as a way that RACT is met rather than a source that is subject to RACT. • (Condition 17) Upon startup of these points, the applicant shall follow the operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. (Reference: Regulation No. 3, Part B, Section III.G.7.) Operation and maintenance requirements, parameter monitoring, and recordkeeping requirements have been directly incorporated into the operating permit in order to monitor compliance with emission limitations and other requirements for this flare. The requirement to calculate emissions using a 123/0057 Page 57 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit mass balance approach, as specified in the O&M plan, has been directly incorporated into the operating permit. • (Condition 18) The owner or operator shall demonstrate compliance with Condition 13 using EPA Method 9 to measure opacity from the flare per Condition 15. (Reference: Regulation No. 1, Section II.A.5). This condition was included under the initial testing requirements for the flare. A Method 9 opacity determination was performed as part of the self-certification process and the results have been submitted to the Division. This condition has not been included in the operating permit. • (Condition 19) The owner or operator shall sample the gas routed to the flare to determine the heat content on a semi-annual basis. Periodic sampling has been required for determination of heat content as well as VOC content for calculation of emissions using a mass balance approach. The frequency for the sampling of process/purge gas streams routed to the flare has been revised from semi-annually to quarterly, since analyses for these gases received by the Division have demonstrated significant variation in VOC and heat content, and emissions vented to this flare can come from a wide variety of sources. Although not specifically identified in Colorado Construction Permit 14WE0142, this flare is subject to the following applicable requirements: • Colorado Regulation No. 1, Section II.A.5 — Opacity emissions from a smokeless flare or other flare for the combustion of waste gases shall not exceed 30% for a period aggregating more than six minutes in any sixty consecutive minutes. 2. Emission Factors Emissions from the flare include uncombusted emissions of VOC that were routed through the flare and NOx and CO emissions from combustion. VOC emissions were estimated using a mass balance approach based on a plant inlet gas analysis and the requested throughput. An emission factor of 16,163 lb/MMscf was developed for the permitted VOC limit based on this approach, however, emissions are required to be calculated using a mass balance approach according to the requirements of the O&M plan, and not according to this emission factor. NOx and CO emissions were developed using a total heat content value based on the requested throughput of the process, purge, and pilot gas, the estimated heat contents of these streams and the following emission factors from the Texas Commission on Environmental Quality: Pollutant Lb/MMBtu NOx 0.138 123/0057 Page 58 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit CO 0.275 For air assisted flare with high Btu content (>1000 Btu/scf) 3. Monitoring Plan Monitoring has been included in the operating permit to yield data sufficient to calculate VOC emissions based on a mass balance approach. Process and purge gas volumes routed through the flare are monitored continuously and recorded monthly. Site specific extended gas analyses are required to be conducted quarterly to determine the molar fractions of VOC constituents for calculation of emissions using the recorded monthly throughput. The heat content of the streams routed to the flare are required to be determined quarterly for calculation of NOx and CO emissions using the given emission factors and the flare throughput. Monitoring of flare operation includes daily requirements for visual emissions observations and monthly determination of the maximum exit velocity of the flare for comparison to the standard, continuous monitoring of the flare pilot light using a thermocouple or equivalent device to ensure a flame is present at all times that emissions are routed to the flare, and quarterly heat content analyses for comparison to the minimum required for proper combustion. 4. Compliance Status The Division completed a full compliance evaluation at the facility on August 31 , 2016. According to the inspection report, the self-certification package for 14WE0142 was received two days after the 180 day deadline but no enforcement was recommended for this infraction. The Division found that F-4 was in compliance with all other requirements of Construction Permit 14WE0142 and applicable air pollution control regulations. VI. 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 123/0057 Page 59 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit issuance date, the first monitoring period and compliance period may be short (i.e. less than 6 months and less than 1 year). • Revised the Responsible Official and Facility Contact information to reflect the most recent information received by the Division. • Inserted language concerning postmarked dates for report submittals to reflect the Division's current standard language. Section I — General Activities and Summary • Revised Condition 1 .1 to include a current description of facility operations, including additional gas plants that are now a part of the single stationary source, and to specify the current attainment status of the area in which the facility operates. • Revised Condition 1 .3 to include references to construction permits incorporated into the operating permit and to remove those that have been cancelled. • Revised Condition 1 .4 to specify the current State-only enforceable conditions. • Condition 1 .5 was removed from the permit. Information about other operating permits associated with this facility for purposes of determining the applicability of PSD and NANSR regulations has been included in Condition 3 of this section. • Updated Condition 2 to include the current version of the engine Alternative Operating Scenario (10/12/12, with revisions according to the Reg. 6, Part B revisions adopted on March 21, 2013). Revised Table 1 : Internal Combustion Engine Information for the AOS to include descriptions of engines currently permitted at the facility. • Revised Condition 3 to specify the current status of the facility pertaining to PSD and NANSR regulations and other permits associated with the determination of this status. • Condition 5 was added to specify the units at this facility that are subject to the Compliance Assurance Monitoring (CAM) requirements of 40 CFR Part 64. • Condition 6 (Summary of Emission Units) was revised to specify the current emission units regulated by this operating permit. Units that have ceased operation and whose permits have been cancelled have been removed from the table. Section II — Specific Permit Terms • Condition 1 (former Condition 2) for compressor engine EU-33 (AIRS point 004): o Compressor engines EU-36 and EU-37 have been removed from the permit (See Section IV: Modifications Requested by Source) 123/0057 Page 60 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit o Revisions were made in the summary table for unit EU-33 to coincide with the modifications detailed in the items below. o The emission limits for unit EU-33 were divided into two separate conditions (Conditions 1 .1 and 1 .2) since the current portable monitoring language for operating permits has provisions in the emission limitations section for NOx and CO that are not applicable to PM, PMio, or VOC. The language specifying emission calculation methods has been revised to the current standard language. o The 30% opacity standard of Colorado Regulation No. 1, Section I I.A.4, applicable during certain operational activities, has been added to the operating permit (Condition 1.6) since this is a standard opacity requirement in permits for sources with the potential for opacity emissions. o The condition requiring compliance tests for initial compliance demonstration with NOx and CO permit limits has been removed since tests were completed in May 1999 that demonstrated compliance with permitted limits. o Condition 1 .7 was added to the operating permit to incorporate the applicable requirements of Colorado Regulation No. 7, Part E, Sections I and II (previous Section XVI). Sections I.A and I.B require catalyst controls for engines greater than 500 horsepower operating in the 8-hour Ozone Control Area. Section I.D.6 contains combustion process adjustment requirements that became effective on January 14, 2017. o Condition 1 .8 was added to include the general provisions requirements of Regulation No. 7, Part D, Section II (previous Section XVII.B), since this engine is subject to the requirements of Part E, Section I.D.3.b.(i) (previous Section XVII.E.3.b.(i)), but these have been streamlined out of the operating permit in favor of the Part E, Section I.A and B requirements. (See Colorado Regulation No. 7 in Section III: Applicable Requirements, above.) o Condition 1 .9 was added to include the 2008 consent decree requirement to have an oxidation catalyst for carbon monoxide control, as well as to include standard operating permit monitoring requirements for lean burn engines. The catalyst control requirement for EU-33 was first permitted in the February 9, 2017 issuance of 11WE730-1. Former Condition 2.8 (operation and maintenance) was revised to be more consistent with recently issued permits and included with Condition 1 .9 as a condition covering the operation, maintenance, and parameter monitoring for the engine and catalyst. • Former Condition 3 for compressor engine EU-35 (AIRS point 007) has been removed from the operating permit. This unit has been permanently shut down and the point and construction permit have been cancelled with a notice received on July 10, 2015. 123/0057 Page 61 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit • Condition 2 (former Condition 6) for Fugitive Equipment Leaks (AIRS points 011 and 018): o The provisions of Colorado Reg. 7, Part D, Section I.G (previous Section XII.G) have been included in the operating permit. These provisions require the application of the LDAR program of NSPS OOOO for natural gas processing plants located in the 8-hour Ozone Control Area, unless subject to the LDAR program provided at 40 CFR 60, Subpart OOOOa. The general provision of Part D, Section I.C.1.b (previous Section XII.C.1 .b) has also been included. o The applicable provisions of 40 CFR Part 63 Subpart HH were included in the operating permit. The source has not specifically determined that VHAP concentration can be reasonably expected never to exceed 10.0 percent by weight, per 63.772(a)(1), and recent submittals have indicated streams containing VHAP concentration above 10% by weight. The applicable provisions of MACT HH for the Fort Lupton facility currently only include periodic reporting requirements for sources subject to the LDAR provisions of NSPS OOOO. (See Section III: Applicable Requirements, above) • Condition 3 (former Condition 1) for compressor engine EU-32 (AIRS point 030): o All references for unit EU-31 (AIRS point 013) have been removed from this condition. This unit has been permanently shut down and the point has been cancelled with a notice received on July 10, 2015. o Removed all references to engine EU-34. This unit was permanently removed from the facility on September 28, 2007. o Revisions were made in the summary table for unit EU-32 to coincide with the modifications detailed in the items below. o The emission limits for EU-32 were divided into two separate conditions (Conditions 3.1 and 3.2) since the current portable monitoring language for operating permits has provisions in the emission limitations section for NOx and CO that are not applicable to PM, PM1o, or VOC. The language specifying emission calculation methods has been revised to the current standard language. o The 30% opacity standard of Colorado Regulation No. 1, Section I I.A.4, applicable during certain operational activities, has been added to the operating permit (Condition 4.6) since this is a standard opacity requirement in permits for sources with the potential for opacity emissions. o The condition requiring compliance tests for initial compliance demonstration with NOx and CO permit limits has been removed since 123/0057 Page 62 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit tests were completed in May 1999 that demonstrated compliance with permitted limits. o Condition 3.7 was added to the operating permit to incorporate the applicable requirements of Colorado Regulation No. 7, Part E, Sections I and II (previous Section XVI). Sections I.A and I.B require catalyst controls for engines greater than 500 horsepower operating in the 8-hour Ozone Control Area. Section I.D.6 contains combustion process adjustment requirements that became effective on January 14, 2017. o Former Condition 1 .7 (control device monitoring requirements) and Condition 1 .9 (Operation and Maintenance requirements) have been combined into one condition that includes operation, maintenance and monitoring requirements for the engine and associated catalyst. Monitoring requirements have been revised to reference those required in Condition 3.9 (MACT ZZZZ) and to include standard monitoring language for engines in operating permits. o The applicable requirements of 40 CFR 63 Subpart ZZZZ (RICE MACT) and 40 CFR 63 Subpart A (General Provisions) have been added to the operating permit for this engine. (See Section III: Applicable Requirements, above) o The applicable requirements of 40 CFR Part 64, Compliance Assurance Monitoring, have been added to the operating permit for this engine. (See Section III: Applicable Requirements, above) Section IV — Provisions Common to Multiple Units This Section was added to consolidate provisions that are common to multiple emission units. Section V — Permit Shield • The permit shield for 40 CFR 60, Subpart KKK was removed since this facility is now classified as a natural gas processing plant. Section VI — General Permit Conditions • Updated the general permit conditions to the current version (8/28/2018) Appendices • Updated Appendices B and C (Monitoring and Permit Deviation Reports and Compliance Certification Reports) to the newest versions (8/20/2014). • EPA's mailing address was revised (Appendix D). • Cleared the list of modifications from Appendix F related to the previous issuance. 123/0057 Page 63 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit • Added appendices for CAM requirements for subject units and to include the Engine AOS Applicability Reports. VII. Streamlining of Applicable Requirements Oxidation Catalyst Control Requirements — Reg. 7, Part E, Section I.D.3.b Engines EU-33, EU-38, and EU-39: Colorado Regulation No. 7, Part E, Section I.D.3.b contains a requirement to install an oxidation catalyst for lean burn reciprocating internal combustion engines with a manufacturer's design rate greater than 500 horsepower. This requirement is a state-wide, state-only enforceable requirement that applies to engines constructed or modified before February 1 , 2009. Regulation No. 7, Part E, Sections I.A and I.B require the installation of oxidation catalysts for all lean burn engines with a manufacturer's design rate greater than 500 horsepower located in the 8-hour Ozone Control Area. This requirement is both state and federally enforceable and applies to all engines in the ozone control area (both new and existing). For engines that are subject to both requirements, the Division considers that the Section I.D.3.b requirement can be streamlined for the Section I.A and I.B requirement since these provisions contain the same substantial requirements and the Section I.A and I.B requirement is both state and federally enforceable. Recordkeeping Requirements less than five years The following recordkeeping requirements have record retention periods that are less than required for sources subject to operating permit requirements and therefore have been streamlined out of the operating permit for the Section IV, Condition 22.b recordkeeping provisions which require records of all monitoring data and support information to be retained for a period of at least five years: • 40 CFR 60 Subpart OOOOa, §60.5421a(b)(2): When each leak is detected ... information must be recorded in a log and shall be kept for 2 years in a readily available location...(Only with respect to the requirement that records be kept for 2 years) • Colorado Regulation No. 7, Part D, Section III.E.2.c: Records of maintenance of pneumatic controllers shall be maintained for a minimum of three years and readily made available to the Division upon request. Pneumatic Controllers - Req. 7, Part D, Section III.C.1 and III.C.3 Colorado Regulation No. 7, Part D, Section III.C contains requirements for emission reductions for natural gas-actuated pneumatic controllers. Applicable requirements are determined based on whether the source is located in the 8-hour Ozone Control Area and the date of installation. The provisions of Section III.C.1 are applicable to all continuous bleed controllers in the 8- hour Ozone Control Area located from the wellhead to the natural gas processing plant. These provisions require pneumatic controllers placed in service on or after February 1 , 2009 to emit natural gas emissions in an amount equal to or less than a low bleed pneumatic controller and replacement or retrofitting of high bleed pneumatic controllers in 123/0057 Page 64 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit service prior to February 1 , 2009 so that emissions are reduced to an amount equal to or less than a low bleed controller by May 1, 2009. The provisions of Section III.C.2 are applicable to all continuous bleed controllers in the 8- hour Ozone Control Area located at natural gas processing plants. They require pneumatic controllers placed in service on or after January 1, 2018 to have a natural gas bleed rate of zero and replacement or retrofitting of controllers with a bleed rate greater than zero, in service prior to January 1, 2018, so that the pneumatic controller has a natural gas bleed rate of zero by May 1 , 2018. The provisions of Section III.C.3 are applicable statewide to all controllers placed in service on or after May 1 , 2014 and are state-only enforceable. They require the use of no-bleed pneumatic controllers where on-site electrical grid power is being used and the use of a no-bleed controller is technically and economically feasible, or the use of controllers with emissions less than or equal to a low-bleed pneumatic controller if the above conditions are not met. Section III.C.3 also requires all high-bleed controllers in service prior to May 1 , 2014 to be replaced or retrofitted with controllers that have natural gas emissions at or below a low-bleed controller by May 1 , 2015. A high-bleed pneumatic controller is defined in Section III.B as having a continuous bleed rate in excess of six standard cubic feet per hour of natural gas to the atmosphere. A low-bleed controller emits less than or equal to six standard cubic feet per hour. Sections III.C.1 and III.C.3 each have provisions to allow for the continued use of high- bleed pneumatic controllers when they remain in service due to safety and/or process concerns. Section III.C.2 has similar provisions for pneumatic controllers at natural gas plants with a bleed rate greater than zero. Pneumatic controllers that remain in service with emissions above the specified standards are subject to specific monitoring requirements in Section III.D and recordkeeping requirements in Section III.E which are associated with the applicable categories of Section III.C. Pneumatic controllers at natural gas processing plants located in the 8-hour Ozone Control Area are technically subject to the requirements in Sections III.C.1 , III.C.2, and III.C.3, as well as the associated monitoring requirements of Section III.D and recordkeeping requirements of Section III.E. Since the requirements of Section III.C.2 for pneumatic controllers at natural gas processing plants located in the 8-hour Ozone Control Area are the most stringent (zero bleed), are essentially redundant with and/or supersede the requirements of Section III.C.1 and III.C.3 (in regard to standards, exceptions, monitoring, and recordkeeping), and are both state and federally enforceable, the requirements of Sections III.C.1 and III.C.3 and the associated monitoring and record keeping have been streamlined out of the operating permit. In addition, the recordkeeping requirement of Section III.E.2.c, requiring maintenance records to be retained for three years, has been streamlined for the general (five year) operating permit recordkeeping requirements in Section III, Condition 22.b. 123/0057 Page 65 of 71 VIII. Facility Emissions Criteria pollutants: AIRS Facility Uncontrolled (tons/yr) Controlled, Potential to Emit(tons/yr) Point ID Description NOx VOC CO PM10 PM2.5 SO2 NOx VOC CO PM10 PM2.5 SO2 004 EU-33 Fairbanks Morse MEP-12, 2046HP 90.2 17.9 43.1 3.8 3.8 0.04 90.2 17.9 18.1 3.8 3.8 0.04 017 EU-101 Waukesha L7042GS1, 1478 HP 144.0 2.7 117.0 0.6 0.6 0.02 11.2 2.7 11.2 0.6 0.6 0.02 018 F001 Ft Lupton fugitives 200.6 26.9 020 EU-38 Caterpillar 3612 TALE, 3550 HP 24.0 18.9 85.7 1.1 1.1 0.07 24.0 7.5 6.0 1.1 1.1 0.07 020 EU-39 Caterpillar 3612 TALE, 3550 HP 24.0 18.9 85.7 1.1 1.1 0.07 24.0 7.5 6.0 1.1 1.1 0.07 025 EU-34R Waukesha L7042GS1, 1232 HP 154.7 3.6 107.1 0.9 0.9 0.03 23.8 1.8 35.7 0.9 0.9 0.03 026 EU-103 Caterpillar 3616, 4262 HP 30.4 26.5 108.9 1.4 1.4 0.08 30.4 19.1 7.6 1.4 1.4 0.08 028 EU-104 Caterpillar 3616, 4735 HP 32.0 27.4 114.8 1.4 1.4 0.08 32.0 19.2 8.0 1.4 1.4 0.08 030 EU-32 Waukesha L7042, 1232 HP 147.4 9.2 257.9 0.3 0.3 0.02 23.0 9.2 50.6 0.3 0.3 0.02 070 F-4 Air-assisted process flare 0.0 633.6 0.0 0.0 0.0 0.0 8.5 12.7 17.0 0.3 0.3 0.03 Fort Lupton Permitted Sources Total 646.7 959.3 920.2 10.6 10.6 0.41 267.1 124.5 160.2 10.9 10.9 0.44 038 S001 Ajax DPC-540LE, 514 HP 11.6 5.8 11.6 1.1 1.1 0.01 11.6 5.8 11.6 1.1 1.1 0.01 039 S002 Ajax DPC-540LE, 514 HP 11.6 5.8 11.6 1.1 1.1 0.01 11.6 5.8 11.6 1.1 1.1 0.01 040 S003 Ajax DPC-540LE, 514 HP 11.6 5.8 11.6 1.1 1.1 0.01 11.6 5.8 11.6 1.1 1.1 0.01 041 S004 Ajax DPC-540LE, 514 HP 11.6 5.8 11.6 1.1 1.1 0.01 11.6 5.8 11.6 1.1 1.1 0.01 042 S007 Platte Valley Fugitives 289.6 46.7 043 S009 NGL Amine unit 105.8 6.5 1.1 5.5 0.8 044 S012 Ajax DPC 2803LE, 550 HP 16.8 6.7 20.1 1.2 1.2 0.01 16.8 6.7 20.1 1.2 1.2 0.01 045 S013 Amine unit heater, 10.7 MMBtu/hr 6.8 0.4 5.7 0.5 0.5 0.04 6.8 0.4 5.7 0.5 0.5 0.04 047 S015 Ajax DPC 2803LE, 550 HP 10.6 5.3 10.6 0.9 0.9 0.01 10.6 5.3 10.6 0.9 0.9 0.01 048 S016 Ajax DPC 2803LE, 550 HP 10.6 5.3 10.6 0.9 0.9 0.01 10.6 5.3 10.6 0.9 0.9 0.01 049 S017 Ajax DPC 2803LE, 550 HP 10.6 5.3 10.6 0.9 0.9 0.01 10.6 5.3 10.6 0.9 0.9 0.01 050 S018 Caterpillar G3516 TALE, 980 HP 20.4 6.3 17.2 0.3 0.3 0.02 20.4 1.6 1.7 0.3 0.3 0.02 051 S019 Caterpillar G3516 TALE, 980 HP 20.4 6.3 17.2 0.3 0.3 0.02 20.4 1.6 1.7 0.3 0.3 0.02 052 S020 Solar Centaur 40 turbine, 4700 HP 49.0 10.2 35.5 1.1 1.1 0.0 49.0 10.2 35.5 1.1 1.1 0.0 00123/0057 Page 66 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit AIRS Facility Uncontrolled (tons/yr) Controlled, Potential to Emit(tons/yr) Point ID Description NOx VOC CO PMio PM2.5 SO2 NOx VOC CO PMio PM2.5 SO2 053 S021 Flare Industries air-assisted flare 1589.2 5.6 31.8 25.4 0.04 046 S014 Hot oil heater, 32.0 MMBtu/hr 14.2 0.7 11.9 1.0 1.0 0.08 14.2 0.7 11.9 1.0 1.0 0.08 073 �� TL Natural Gasoline Truck Loadout 118.6 5.6 5.9 7.4 0.3 0.3 0.0 Platte Valley Permitted Sources Total 205.8 2172.9 185.8 11.5 11.5 0.24 223.5 145.8 193.1 11.8 11.8 1.08 APEN and/or Permit exempt units 023 EU-411 Detroit Diesel KC750KWI, 1088HP 2.6 0.07 0.4 0.2 0.2 2.6 0.07 0.4 0.2 0.2 029 GEN21 Caterpillar C18 DITA, 900 HP 2.9 0.0 0.2 0.02 0.02 0.0 2.9 0.0 0.2 0.02 0.02 0.0 054 PLV PLC Mitsubishi 4G64S4M, 80 HP 0.1 0.0 6.1 0.1 0.0 6.1 Gen'2 NA S0221 John Deere diesel gen,115HP 0.9 0.1 0.2 0.07 0.07 0.06 0.9 0.1 0.2 0.07 0.07 0.06 APEN/Permit Exempt Totals 6.5 0.17 6.9 0.29 0.29 0.06 6.5 0.2 6.9 0.29 0.29 0.06 Fort Lupton/Platte Valley Totals 859.0 3132.4 1112.9 22.39 22.39 0.71 497.1 270.5 360.2 22.99 22.99 1.58 'PTE for emergency generators without permit limitations is based on 500 hr/yr operation, per EPA guidance memo on calculating potential to emit for emergency generators (written by OAQPS Director John Seitz, September 6, 1995) 2Potential criteria pollutant emissions for PLV PLC GEN are based on propane firing. 123/0057 Page 67 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit HAPs: HAP Controlled Emissions (Ib/yr) Potential to Emit (Ib/yr) AIRS Facility Point ID Benzene Toluene Ebentzene Xylene Hexane aldehyde n- Form- Acrolein aldehyde Butadiene hv Methanol TMP Total 004 EU-33 257.3 7321.2 1031.9 1029.2 328.9 9968.5 017 EU-101 99.0 1799.9 164.8 174.8 41.5 191.7 2471.7 018 F001 425 593 284 407 1577 1963 566 5815 020 EU-38 245.1 1919.7 454.0 738.3 552.0 3909.1 020 EU-39 245.1 1919.7 454.0 738.3 552.0 3909.1 025 EU-34R 145.0 403 241.4 257.0 60.8 280.8 1388 026 EU-103 300.1 8333.1 1389.7 2260.4 675.9 12959.2 028 EU-104 310.8 8778.8 1439.1 2340.7 700.0 13569.4 030 EU-32 213.9 1597.9 175.8 60.8 44.3 204.6 2297.3 070 F-4 77.1 77.6 3.5 26.9 2077.2 2262.3 Fort Lupton Totals 1217.3 670.6 287.5 433.9 4755.3 32073.3 5350.7 7599.5 146.6 5448.9 566 58549.6 038 S001 88 2491 351 350 112 3392 039 S002 88 2491 351 350 112 3392 040 S003 88 2491 351 350 112 3392 041 S004 88 2491 351 350 112 3392 042 S007 5375.7 5375.7 5375.7 5375.7 9255.9 5375.7 36134.4 043 S009 81 14 5 100 044 S012 93 2660 375 374 119 3621 045 S013 242 10 252 047 S015 76 2156 304 303 97 2936 048 S016 76 2156 304 303 97 2936 123/0057 Page 68 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit Potential to Emit (Ib/yr) AIRS Facility Paint ID Benzene Toluene Ethyl Xylene n Form Acrolein Acet- 1,3- Methanol 2'2'4- Total benzene Hexane aldehyde aldehyde Butadiene TMP 049 S017 76 2156 304 303 97 2936 050 S018 77 1276 90 146 174 1763 051 S019 77 1276 90 146 174 1763 052 S020 43 11 21 236 13 324 053 S021 118.2 76.9 46.3 123.4 588.1 952.9 046 S014 495 21 516 073 N G-TL-01 25 5 195 4 229 Platte Valley Totals 6272.9 5514.6 5433 5520.1 10935 21911 2871 2988 0 1206 5379.7 68031.3 APEN and/or Permit Exempt Units 023 EU-411 2.8 1.0 0.7 0.3 029 GEN21 2.1 0.8 0.5 0.2 054 PLV PLC 0.5 23.1 2.2 3.7 1.1 Genset12 NA S0221 0.4 0.2 0.1 0.5 0.3 APEN/Permit 5.3 2.0 0 1.3 0.5 24.1 2.2 4.0 0 1.1 0 40.5 Exempt Totals Fort Lupton/Platte 7495.5 6187.2 5720.5 5955.3 15690.8 54008.4 8223.9 10591.5 146.6 6656 5945.7 126621.4 Valley Totals 1PTE for emergency generators without permit limitations is based on 500 hr/yr operation, per EPA guidance memo on calculating potential to emit for emergency generators (written by OAQPS Director John Seitz, September 6, 1995) 2Potential HAP emissions for PLV PLC GEN are based on natural gas firing. 123/0057 Page 69 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit HAP Uncontrolled Emissions (lb/yr): AIRS Facility Uncontrolled Emissions (Ib/yr) Point ID Benzene Toluene Ethyl Xylene n- Form Acrolein Acet 1,3 Methanol 2'2'4 Total benzene Hexane aldehyde aldehyde Butadiene TMP 004 EU-33 257.3 7321.2 1031.9 1029.2 328.9 9968.5 017 EU-101 99.0 7199.7 164.8 174.8 41.5 191.7 7679.8 018 F001 3565 5507 2108 3468 14244 12337 4378 45607 020 EU-38 245.1 27423.8 1134.9 1845.9 552.0 31201.7 020 EU-39 245.1 27423.8 1134.9 1845.9 552.0 31201.7 025 EU-34R 145.0 1679 241.4 257.0 60.8 280.8 2664 026 EU-103 300.1 34721.4 1389.7 2260.4 675.9 39347.5 028 EU-104 310.8 36578.5 1439.1 2340.7 700.0 41369.1 030 EU-32 213.9 1597.9 175.8 60.8 44.3 204.6 2297.3 070 F-4 3852.5 3880.7 173.6 1346.7 103862 113115.5 Fort Lupton Totals 8132.7 9387.7 2281.6 4814.7 119207.1 143945.3 6712.5 9814.7 146.6 15631.2 4378 324452.1 038 S001 88 2491 351 350 112 3392 039 S002 88 2491 351 350 112 3392 040 S003 88 2491 351 350 112 3392 041 S004 88 2491 351 350 112 3392 042 S007 30932 30932 30932 30932 60369 30932 215029 043 S009 8076 1403 475 9954 044 S012 93 2660 375 374 119 3621 045 S013 242 10 252 047 S015 76 2156 304 303 97 2936 048 S016 76 2156 304 303 97 2936 049 S017 76 2156 304 303 97 2936 050 S018 77 5103 358 583 174 6295 051 S019 77 5103 358 583 174 6295 052 S020 43 11 21 236 13 324 123/0057 Page 70 of 71 Kerr-McGee Gathering, LLC — Fort Lupton Gas Plant Operating Permit No. 95OPWE013 Technical Review Document— Renewal 1 Operating Permit Uncontrolled Emissions (Ib/yr) AIRS Facility Point ID Benzene Toluene Ethyl Xylene n- Form Acrolein Acet- 1,3- Methanol 2,2,4- Total benzene Hexane aldehyde aldehyde Butadiene TMP 053 S021 5908.6 3843.9 2316.3 6171.8 29403.8 47644.4 046 S014 495 21 516 073 NG-TL-01 505 108 3898 82 4593 Platte Valley Totals 46094.6 36329.9 33259.3 37124.8 95036.8 29565 3407 3862 0 1206 31014 316899.4 APEN and/or Permit Exempt 023 EU-411 2.8 1.0 0.7 0.3 029 GEN21 2.1 0.8 0.5 0.2 054 PLV PLC 0.5 23.1 2.2 3.7 1.1 Genset12 NA S0221 0.4 0.2 0.1 0.5 0.3 APEN/Permit 5.3 2.0 0.0 1.3 0.5 24.1 2.2 4.0 0.0 1.1 0.0 Exempt Totals Fort Lupton/Platte 54232.6 45719.6 35540.9 41940.8 214244.4 173534.4 10121.7 13680.7 146.6 16838.3 35392 641392 Valley Totals 'PTE for emergency generators without permit limitations is based on 500 hr/yr operation, per EPA guidance memo on calculating potential to emit for emergency generators (written by OAQPS Director John Seitz, September 6, 1995) 2Potential HAP emissions for PLV PLC GEN are based on natural gas firing. 123/0057 Page 71 of 71 TECHNICAL REVIEW DOCUMENT For DRAFT RENEWAL OF OPERATING PERMIT 95OPWE013 Kerr-McGee Gathering LLC — Fort Lupton Complex — Platte Valley plant Weld County Source ID 123-0057 Issued: DATE Operating Permit Engineer: Joshua Jones Operating Permit Supervisor review: Blue Parish Field Services Unit review: Craig Giesecke 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 Ft Lupton Gas Processing Complex. The previous Operating Permit for this facility, 99OPWE207, was issued on October 1 , 1999 and expired on October 1 , 2004. 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. The provisions of Operating Permit 99OPWE207 for the Platte Valley Gas Plant are being incorporated into Operating Permit 95OPWE013. Details on modifications submitted by the source since the latest issuance of this permit can be found in Section IV: Modifications Requested by the Source, below. 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 September 30, 2003, comments on the draft permit submitted on [date], previous inspection reports and various email correspondence, as well as telephone conversations with the applicant. 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 https://www.colorado.dov/cdphe/title-v-operating-permits. 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 123/0057 Page 1 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit without applying for a revision to this permit or for an additional or revised construction permit. II. Description of Source Description of the single stationary source that is the Fort Lupton Gas Processing Complex is found in the Fort Lupton TRD. Emissions summaries and details for the facility are included in the Fort Lupton TRD. Ill. Applicable Requirements 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: Point 043 (S009) for VOC Point 073 (NG-TL-01) for VOC All other emission units at this facility are not subject to the CAM provisions since they either have pre-control emissions below the major source threshold, are uncontrolled, are not subject to an emission limitation or standard for the applicable regulated air pollutant, or are only subject to an emission limitation or standard that is exempt under §64.2(b)(1)). Hazardous Air Pollutants (HAPs) The Platte Valley Gas Plant is considered a major source of HAP with a potential to emit, considering controls, of more than 10 tons per year of any hazardous air pollutant (formaldehyde). Applicability for specific subparts of 40 CFR Part 63 for National Emissions Standards for Hazardous Air Pollutants is found below. RACT — Colorado Regulation No. 7, Part A, Section II.C.2 NG-TL-01: This natural gasoline liquids loadout is an existing source located in an ozone non-attainment or attainment-maintenance area with a potential to emit of 100 tons per year or more of VOC, before add-on controls, and is therefore subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 7, Part A, Section II.C.1.a, per Section II.C.1.a.(i) and (ii). RACT for this source shall be utilizing submerged fill during loadout of natural gasoline to truck tanks and routing emissions from the natural gasoline loadout to an enclosed flare. The SIP RACT requirements of Reg. 7, Part E, Section II.A for combustion equipment have been included in the operating permit. These are discussed in the Regulation No. 7 section below. 40 CFR 60 Subpart Dc 123/0057 Page 2 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit 5013 (point 045) and S014 (point 046) meet the applicability requirements of this rule. NSPS Dc applies to each steam generating unit (a device that combusts any fuel and produces steam or heats water or heats any heat transfer medium, per §60.41c) for which construction, modification, or reconstruction commenced after June 9, 1989, and that has a heat input capacity greater than or equal to 10 MMBtu/hr and less than or equal to 100 MMBtu/hr, per §60.40c(a). The applicable requirements of NSPS Dc for these units have been included in the operating permit. The requirement to maintain records required by this subpart for two years following the date of the record (§60.48c(i)) has been streamlined for the operating permit recordkeeping requirements of Section IV, Condition 22.b. 40 CFR 60 Subpart GG Turbine S020 commenced construction after October 3, 1977 and has a peak heat input rate equal to or greater than 10 MMBtu/hr; it is therefore subject to the requirements of NSPS GG per §60.633(a) and (b). Applicable requirements include a NOx emission limit based on the manufacturer's rated heat rate at the manufacturer's rated peak load and the option to comply with either a SO2 emission limit or a limit on sulfur content in the turbine fuel. 40 CFR Part 60 Subpart KKK — Standards of Performance for Equipment Leaks of VOC From Onshore Natural Gas Processing Plants for Which Construction, Reconstruction, or Modification Commenced After January 20, 1984, and on or Before August 23, 2011 This facility was constructed after January 20, 1984 and on or before August 23, 2011 and meets the definition of a natural gas processing plant found in §60.631 . It is therefore subject to the provisions of this subpart per §60.630(a)(1), (3), and §60.630(b). The Platte Valley facility is also subject to the requirements of Colorado Regulation No. 7, Part D, Section I.G, which requires that natural gas processing plants located in the 8- Hour Ozone Control Area apply the leak detection and repair (LDAR) program of NSPS OOOO beginning January 1 , 2019, regardless of the date of construction, unless subject to the LDAR program provided at 40 CFR 60, Subpart OOOOa. In a response to an information request, received on October 18, 2019, Ker-McGee indicated that all plants at the Fort Lupton Complex had elected to comply with the requirements of NSPS OOOOa. The Division received a notification from Kerr-McGee on May 1 , 2019 stating that all process units at the Fort Lupton Complex have become "affected facilities" under Subpart OOOOa, based on the requirements of Colorado Regulation No. 7, and that the date of construction was considered to be January 1 , 2019. The LDAR programs of NSPS OOOO and NSPS 0000a represent more stringent programs in terms of lower leak threshold definitions, more frequent monitoring, and instrument monitoring of connectors (not required in NSPS KKK). Since the requirements of NSPS KKK are less stringent and otherwise duplicative with NSPS OOOO/OOOOa, the provisions of NSPS KKK have been streamlined out of the operating permit in favor of the requirements of NSPS OOOOa. The Division has included the equipment leak standards of NSPS 0000a as applicable to the Fort Lupton and Platte Valley gas plants in the operating permit, since these requirements are equivalent to 123/0057 Page 3 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit those of NSPS OOOO, except that the provisions of NSPS 0000a also apply to GHG (methane). 40 CFR Part 60 Subpart JJJJ PLV PLC GEN (point 054): In a response to an information request, received December 19, 2017, Kerr-McGee specified that this engine was manufactured after January 1, 2009. It commenced construction after June 12, 2006, and is therefore subject to the requirements of this subpart per §60.4230(a)(4)(iv). It must meet the emission limitations of Table 1 of this subpart for emergency engines between 25 and 130 HP per §60.4233(d). 40 CFR 60 Subpart OOOO — Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution for which Construction, Modification or Reconstruction Commenced After August 23, 2011, and on or before September 18, 2015 The fugitive emissions at the Platte Valley Gas Plant are not subject to the requirements of Subpart OOOO based on federal applicability as prescribed in the rule, however, Colorado Regulation No. 7, Part D, Section I.G requires the application of the leak detection and repair (LDAR) program as provided in 40 CFR Part 60, Subpart OOOO, for natural gas processing plants located in the 8-hour Ozone Control Area, regardless of the date of construction of the facility, unless subject to the requirements of NSPS OOOOa. Sources must comply with these requirements beginning January 1 , 2019, per Part D, Section I.G.3. Section Part D, Section I.G also states that gas plants shall comply with the general provisions requirement of Part D, Section I.C.1 .b. The requirements of Reg. 7, Part D, Section I.G are both state and federally enforceable. In a response to an information request, received on October 18, 2019, Ker-McGee indicated that all plants at the Fort Lupton Complex had elected to comply with the requirements of NSPS OOOOa. The Division received a notification from Kerr-McGee on May 1 , 2019 stating that all process units at the Fort Lupton Complex have become "affected facilities" under Subpart OOOOa, based on the requirements of Colorado Regulation No. 7, and that the date of construction was considered to be January 1 , 2019. The Division has included the equipment leak standards of NSPS 0000a as applicable to the Fort Lupton and Platte Valley gas plants in the operating permit, since these requirements are equivalent to those of NSPS OOOO, except that the provisions of NSPS 0000a also apply to GHG (methane). 40 CFR 60 Subpart 0000a — Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After September 18, 2015 In a response to an information request, received on October 18, 2019, Ker-McGee indicated that all plants at the Fort Lupton Complex had elected to comply with the requirements of NSPS OOOOa. The Division received a notification from Kerr-McGee on May 1 , 2019 stating that all process units at the Fort Lupton Complex have become "affected facilities" under Subpart OOOOa, based on the requirements of Colorado Regulation No. 7, and that the date of construction was considered to be January 1 , 2019. The Division has included the equipment leak standards of NSPS 0000a as 123/0057 Page 4 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit applicable to the Fort Lupton and Platte Valley gas plants in the operating permit, since these requirements are equivalent to those of NSPS OOOO, except that the provisions of NSPS 0000a also apply to GHG (methane). 40 CFR 63 Subpart HH — National Emissions Standards for Hazardous Air Pollutant from Oil and Natural Gas Production Facilities The Platte Valley facility is a natural gas processing plant, as defined in 40 CFR §63.761 , therefore HAP emissions from all HAP emission units are aggregated for major source determination. This source is classified as a major source of HAP for Subpart HH, per the definition in 40 CFR §63.761 . The group of all ancillary equipment intended to operate in volatile hazardous air pollutant (VHAP) service (as defined in §63.761) is an affected source for natural gas plants per §63.760(b)(1)(iii). "In VHAP service" is defined as a piece of equipment that contains or contacts a fluid having a VHAP concentration equal to or greater than 10 percent by weight as determined according to the provisions of §63.772(a), which specifies "Each piece of ancillary equipment and compressors are presumed to be in VHAP service or in wet gas service unless an owner or operator demonstrates that the piece of equipment is not in VHAP service or in wet gas service." Since it has not been specifically determined that there are no streams at the Platte Valley gas plant that contain VHAP concentrations at greater than or equal to 10 percent, the provisions for equipment leak standards are applicable to this facility. Additionally, a natural gas liquids analysis for permitting of the natural gasoline loadout indicated the stream had 10.3% VHAP by weight, indicating there are streams in VHAP service at the plant. §63.769(b) provides an exemption for the equipment leak standards of Subpart HH for ancillary equipment and compressors subject to and controlled under the requirements of 40 CFR 60 Subpart OOOO. Since the requirements for equipment leaks of Subpart 0000a have been included in the operating permit as applicable to the Platte Valley facility (see 40 CFR 60 Subpart OOOO, above), the equipment leak standards for ancillary equipment of Subpart HH have not been included in the operating permit. Ancillary equipment complying with the requirements of NSPS OOOO must still submit the periodic reports specified in §63.775(e), per §63.769(b). 40 CFR Part 63 Subpart YYYY — National Emission Standards for Hazardous Air Pollutants for Stationary Combustion Turbines Turbine S020 is an affected source for Subpart YYYY per §63.6090(a) since it is located at a major source of HAP emissions and is classified as an existing stationary combustion turbine per §63.6090(a)(1), however, existing stationary combustion turbines in all subcategories do not have to meet the requirements of Subpart YYYY and of Subpart A of this part, per §63.6090(b)(4). 40 CFR Part 63 Subpart ZZZZ — National Emissions Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines S001- S004, S012, S015-S017: These engines are classified as existing (commenced construction before December 19, 2002) two stroke lean-burn (2SLB) RICE site rated at 123/0057 Page 5 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit more than 500 HP at a major source of HAP emissions and therefore do not have to meet the requirements of Subpart ZZZZ or of Subpart A per §63.6590(b)(3) and (b)(3)(i). 5018 and 5019: Both of these engines were permanently replaced, using an Alternative Operating Scenario (AOS), with engines that originally commenced construction after December 19, 2002. They are therefore classified as new 4SLB RICE site rated at more than 500 HP and are subject to the emissions and operating limitations of Tables 2a and 2b of Subpart ZZZZ per §63.6600(b). PLV PLC GEN: This is an 80 HP spark ignition engine powering a generator for the PLC system. It commenced construction in 2012 at a major source of HAP emissions and therefore is considered a new stationary RICE, per §63.6590(a)(2)(ii). New 4SLB engines less than 250 HP located at a major source of HAP must meet the requirements of this subpart by meeting the requirements of 40 CFR Part 60 Subpart JJJJ, per §63.6590(c)(3). S022: This is a 115 HP emergency compression ignition engine used to provide power to a back-up air compressor. It commenced construction in 2005 at a major source of HAP emissions, and therefore is considered existing per §63.6590(a)(1)(ii). This engine must comply with the work/management practices of Table 2c, Item 1 , per §63.6602. 40 CFR Part 63 Subpart DDDDD — National Emissions Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters S013 and S014: The amine unit heater and hot oil heater are considered existing affected sources under subpart DDDDD since they commenced construction before June 4, 2010. These units are in the units designed to burn gas 1 fuels subcategory, as defined in §63.7575, and therefore only have work practice standards requiring tune-ups and a one- time energy assessment related to the existing affected boilers and process heaters at the facility. In addition, all process heaters, as defined in §63.7575, located at a major source of HAP are affected sources under this rule, as specified in §63.7485. This includes the process heaters described in the insignificant activity list in Appendix A of the operating permit, which have heat inputs of less than 5 MMBtu/hr. Colorado Regulation No. 1 S013, S014, and S020: The amine unit heater, hot oil heater, and compressor turbine are subject to the Section III.A.1.b requirement for particulate matter (PM) from fuel burning equipment with a heat input rate greater than 1 MMBtu/hr but less than or equal to 500 MMBtu/hr, which provides a PM emission limit based on the design fuel input rate of the equipment. Compliance with this limit will be presumed, in the absence of credible evidence to the contrary, since only natural gas is permitted to be used as fuel in these units. S022: This diesel fired emergency engine is subject to the Regulation No.1 , Section VI.B requirements for new sources of sulfur dioxide emissions. New sources are defined as those not having been issued an emission permit before the August 11 , 1977 effective 123/0057 Page 6 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit date of the amended regulation. Section VI.B.4.b.(i) contains a limit on SO2 emissions of 0.8 pounds per million BTU of oil heat input for oil-fired units with a heat input rate of less than 250 MMBtu/hr. Compliance with this requirement will be presumed, in absence of credible evidence to the contrary, since only diesel fuel is permitted to be used as fuel in this engine. S020: The compressor turbine is subject to the Section VI.B.4.c.(i) limitation of 0.8 lb of SO2 per million Btu of heat input for combustion turbines with a heat input of less than 250 MMBtu/hr which had not been issued an emission permit prior to August 11, 1977. The averaging time for this limit is a three-hour rolling average per Section VI.B.2. Compliance with this limit will be presumed, in the absence of credible evidence to the contrary, since only natural gas is permitted to be used as fuel in these units. Colorado Regulation No. 6 S013, S014, and S020: The amine unit heater, hot oil heater, and compressor turbine are subject to Regulation No. 6, Part B, Section II state-only standards for new fuel burning equipment constructed , reconstructed, or modified after January 30, 1979. Section II.C.2 includes a limit on particulate matter emissions based on the design fuel input rate and Section II.C.3 includes a limit on particulate matter opacity greater than 20%. The Section II.C.2 requirements have been streamlined out of the permit for the Reg. 1 Section III.A.1 .b requirements (See Section VII: Streamlining of Applicable Requirements, below). S020: The compressor turbine is subject to the Part B, Section II.D.3.a limitation of 0.8 lb of SO2 per million Btu of heat input for combustion turbines with a heat input of less than 250 MMBtu/hr. The Section II.D.3.a requirement has been streamlined out of the permit for the Reg. 1 Section VI.B.4.c.(i) requirement (See Section VII: Streamlining of Applicable Requirements, below). Colorado Regulation No. 7 A revised Regulation No. 7, which has been reorganized from the previous version and revised to include requirements related to the serious nonattainment area designation for the Denver Metro North Front Range and revisions to several Colorado Revised Statutes, was published in the Colorado Register on January 25, 2020 and became effective on February 14, 2020. Part E, Section I.A through I.D — Engines Part E, Sections I.A and I.B, contain requirements for Control of Emissions from Engines in the 8-hour Ozone Control Area. Section I.A contains applicability provisions which specify that any stationary or portable engine with a manufacturer's design rate greater than 500 horsepower operating in the 8-hour Ozone Control Area shall employ air pollution control technology. The Platte Valley facility has obtained an exemption from these control requirements for the Ajax DPC 540 LE and Ajax DPC 2803LE engines (units S001-S004, S012, and S015-S017) according to Part E, Section I.C.4, demonstrating that retrofit technology for lean burn engines cannot be installed at a cost less than $5000 per ton of VOC reduction. A request for this exemption was received by 123/0057 Page 7 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit the Division on April 4, 2005 and granted in a letter sent by the Division dated April 15, 2005. Part E, Section I.D.3.b includes a state-wide, state-only requirement to install oxidation catalysts on existing (constructed or modified before February 1, 2009) lean burn engines with a design rate of greater than 500 horsepower by July 1 , 2010. Section I.D.3.b.(ii) contains a provision for an exemption if the owner or operator demonstrates that retrofit technology cannot be installed at a cost of less than $5000 per ton of VOC reduction. Though a request for an exemption under Section I.D.3.b.(ii) was never submitted, the Division considers the exemption granted under Section I.C.4 to be a valid demonstration of the criteria required for an exemption under Section I.D.3.b.(ii). Therefore, units S001- S004, S012, and S015-S017 are exempt from the provisions of this section. The Caterpillar engines at this facility (units S018-5019) are subject to Part E, Section I.B.2 requirement to install oxidation catalysts for lean burn engines greater than 500 horsepower that commence operation in the 8-hour Ozone Control Area on or after June 1 , 2004. Units S018 and S019 are also subject to the (State Only) requirement to install oxidation catalysts per Part E, Section I.D.3.b.(i). Since Section I.B.2 is both state and federally enforceable, the Section I.D.3.b.(i) control requirement has been streamlined out of the operating permit (See Section VII: Streamlining of Applicable Requirements, below). Part E, Section I.D.2 contains provisions for new, modified, and relocated engines applicable to units S018 and S019 that include emission performance standards based on engine size and construction or relocation date. The exemption afforded theses engines, in what was previously Section XVII.B.5, due to the fact that they are subject to emissions control requirements in 40 CFR 63 Subpart ZZZZ, has been removed with the revisions to Reg. 7 effective February 14, 2020. Therefore, these requirements have been included in the operating permit. Part E, Section II.A — Combustion Equipment Part E, Section II.A contains requirements for stationary and portable combustion equipment that existed at a major source of NOx(greater than or equal to 100 tpy) as of June 3, 2016, or that existed at a major source of NOx (greater than or equal to 50 tpy) as of the date of reclassification of the ozone nonattainment area to serious (January 27, 2020), which are located in the 8-hour Ozone Control Area. Section II.A.4 contains equipment specific NOx emission limits. Compliance demonstration requirements for these limits are found in Section II.A.5. Section II.A.2 includes exemptions to the requirements of Section II.A.4, II.A.5, and the associated recordkeeping and reporting requirements of Sections II.A.7 and II.A.8. Section II.A.2.e contains an exemption for natural gas-fired internal combustion engines that are subject to an emission control requirement in Section I.A or I.B, though there are no emission limits applicable to natural gas-fired internal combustion engines in Section II.A.4. Engines S018 and S019 are subject to the emission control requirements of Section I.A or I.B. The compression ignition electric generator engines at the Platte Valley plant have actual uncontrolled emissions below APEN reporting levels, and so meet the exemption of Section II.A.2.d for stationary combustion equipment with total uncontrolled actual emissions less than five tons per year of NOx. 123/0057 Page 8 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit The Platte Valley combustion turbine (S020) is subject to the emission limit of Part E, Section II.A.4.b.(i), which requires compliance with the NOx emission limits of 40 CFR 60 Subpart GG. Applicability of this section is dependent on the annual capacity factor (as defined in II.A.3.c) and the annual uncontrolled actual emissions, as specified in the exemptions of Section I I.A.2. Compliance determination for this limit is required by October 1 , 2021 and is based on performance testing. Section II.A.5.c.(ii)(A) specifies that an owner or operator that has used and continues to use performance testing to demonstrate compliance with the NSPS GG limit may use those performance testing procedures to satisfy the testing requirements of Section II.A.5.c.(ii). The Platte Valley turbine passed initial compliance testing for the NSPS GG limit in March 2002. NSPS GG does not require periodic testing for compliance with the NOx limit but quarterly portable analyzer testing has been included in the operating permit for continued compliance monitoring. Therefore, the additional testing requirements of Section II.A.5.c.(ii)(B)(1) have not been included in the operating permit. Section II.A.6 applies to combustion equipment (boilers, process heaters, duct burners, stationary combustion turbines, and stationary internal combustion engines) that have uncontrolled actual NOx emissions equal to or greater than five tons per year and that existed at a major source of NOx as of June 3, 2016, or that existed at a major source of NOx (greater than or equal to 50 tpy) as of the date of reclassification of the ozone nonattainment area to serious (January 27, 2020). Dryers, furnaces and ceramic kilns are also included in the emission units subject due to the nonattainment area reclassification. The following units are potentially subject to the combustion process adjustment requirements of Section I I.A.6: S001-S004, S012, S013, S014, S015-S017, S018-S019, and S020. Since applicability is based on uncontrolled actual emissions, individual unit applicability may vary from year to year. A note has been included in the operating permit that references the potential for changing unit applicability to this rule. Recordkeeping requirements for the combustion process adjustment provisions are included in Section Section II.A.7.f. Section I I.A.7.f.(iii) allows an owner or operator to comply with the applicable recordkeeping requirements related to combustion process adjustments conducted as part of a NSPS or MACT requirement. A note has been added to this provision to specify that records must be retained for five years according to the Title V recordkeeping requirements of Section VI, Condition 22.b, since NSPS and MACT recordkeeping requirements often allow a record retention time of less than five years. Part D, Section I — Volatile Organic Compound Emissions from Oil and Gas Operations Part D Section I applies to oil and gas operations that collect, store, or handle hydrocarbon liquids or produced water in the 8-hour Ozone Control Area. The following requirements represent revisions to Regulation No. 7 adopted to include RACT requirements based on EPA's control technique guidelines (CTGs) for the oil and gas industry. These requirements are applicable to sources in the 8-hour ozone nonattainment area and became effective on December 30, 2017. S007 — Fugitive Equipment Leaks: This facility is subject to Part D, Section I.G for natural gas processing gas plants located in the 8-hour Ozone Control Area. Section I.G.1 requires the application of the leak detection and repair (LDAR) program as provided in 40 CFR Part 60, Subpart OOOO, regardless of the date of construction of the facility, unless subject to the LDAR program provided at 40 CFR 60 Subpart OOOOa. Sources 123/0057 Page 9 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit constructed before January 1 , 2018 must comply with these requirements beginning January 1, 2019, per Section I.G.3. Section I.G also states that gas plants shall comply with the general provisions requirement of Section I.C.1.b, as well as the requirements of Section I.J for compressors and Section I.K for pneumatic pumps. The Platte Valley plant does not have any centrifugal compressors. Reciprocating compressors are subject to Section I.J.2, which requires control of VOC emissions through periodic rod packing replacements (based on hours of operation or calendar months) or through the collection and routing of VOC emissions to a process. Section I.K requires natural gas-driven diaphragm pneumatic pumps at natural gas processing plants to have a VOC emission rate of zero. Centrifugal compressors, reciprocating compressors and natural gas-driven pneumatic pumps are also subject to the definitions in Section I.B and the requirements of Sections I.C.1 .c through I.C.1 .e if they are using a control device to comply with specified requirements. Part D, Section III — Pneumatic Controllers This facility is technically subject to all the natural gas-driven pneumatic controller requirements of Section III.C, however, the more recently adopted requirements of Section III.C.2, for pneumatic controllers at gas plants located in the 8-hour Ozone Control Area, supersede and/or are redundant with the requirements of Sections III.C.1 and III.C.3. The provisions of Sections III.C.1 and III.C.3, and the associated monitoring and recordkeeping requirements in Sections III.D and III.E, have been streamlined out of the operating permit (See Section VII: Streamlining of Applicable Requirements, below). The provisions of Section III.C.2 and the associated monitoring and recordkeeping in Sections III.D and III.E have been included in the operating permit. In addition, the recordkeeping requirements of Section III.E.2.c, requiring records of pneumatic controller maintenance to be maintained for three years, has been streamlined for the five year recordkeeping requirement applicable to Title V sources in the General Conditions (Section VI Condition 22). IV. Modifications Requested by the Source This section includes information about modifications requested by the source for emission units that have previously been incorporated into the operating permit as well as requests from the source to incorporate construction permits and construction permit modifications issued since the most recent revision to the operating permit. Details on modifications for emission units previously incorporated into the operating permit are in this section. Details on construction permit conditions for emissions units that are being incorporated into the operating permit with this issuance are found in Section V: Emission Units. A. Description of Permit Modification Requests All applications received before March 1, 2011 were submitted by the previous owner, Encana Oil and Gas USA Inc. A minor modification application was received on August 22, 2002 that requested the inclusion of the provisions of Construction Permit 01 WE0290 for the Solar Turbine (S020, AIRS point 052). The Division agrees that this application can be processed 123/0057 Page 10 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit as a minor modification. See Section V: Emission Sources for details on this construction permit and how it has been incorporated into the operating permit. An application was received on September 30, 2002 for the transfer of ownership of all points included in Operating Permit 99OPWE207 from North American Resources Company to Encana Oil and Gas USA. This application was for Title V purposes. The original transfer of ownership application was received on July 8, 2002. This transfer of ownership for Title V purposes was never effected in the operating permit and is now superseded by the transfer of ownership to Kerr-McGee Gathering received on April 27, 2011 . A minor modification application was received on November 14, 2002 that requested the option to use individual fuel meters on certain natural gas burning equipment (engines and heaters) to measure fuel consumption. Fuel consumption had previously been based on a fuel allocation procedure using a central facility fuel meter and the operating hours and design fuel consumption rate of the individual units. The modification requested the continued use of the fuel allocation procedure for units without individual meters. This application also requested a change in the language for Btu content monitoring of natural gas that specified the Btu content shall be based on the "dry, high" heating value of the fuel. The Btu content monitoring language included in the operating permit specifies that the Btu content be based on the higher heating value of the fuel. In a response to an information request, received on March 27, 2017, Kerr-McGee indicated that all engines are now monitored using individual fuel meters and that the fuel allocation procedures are no longer necessary or desired. The renewal application, received on September 30, 2003, requested the following modifications: • Inclusion of the requirements of permit 02WE0927 (Unit 5021, AIRS point 053) for a Flare Industries air-assisted flare and the deletion of the requirements for unit S008 - Flare Industries Model 250 flare (CP# 93WE157-8, AIRS ID 123- 0319-008). This was requested as a minor modification. • Inclusion of the requirements of permit 01 WE0290 for a 4700 HP Solar turbine, previously submitted to the Division on August 22, 2002. • Inclusion of the modification application submitted to the Division on November 14, 2002 regarding the use of fuel meters for individual units. • Revision of the facility description to remove references to specific engine function, for permit flexibility. • Revision in fugitive emissions calculations to set the inlet gas analyses frequency to strictly annual, without provisions for more frequent analysis. • Additions to the Permit Shield for sections of 40 CFR 60, Subpart GG that are considered not applicable to the Solar turbine. A minor modification application was received on April 30, 2004 that requested an increase in the NOx and fuel consumption limits for units S001-S004 (Ajax DPC 123/0057 Page 11 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit 540LE engines) since fuel meters recently installed indicated that the engines use more fuel than previously thought. No increase in CO or VOC emissions was requested since permit limits for these pollutants are much more conservative. This application was never acted upon by the Division before the transfer of ownership to Kerr-McGee, and Kerr-McGee has requested to rescind the application in a response to an information request, received on March 27, 2017. A minor modification application was received on May 26, 2004 that requested the removal of the VOC testing program of Appendix G. This testing program was applicable to the fugitive emissions requirements of S007 and was closely aligned with the leak detection and repair (LDAR) requirements of NSPS KKK. The VOC testing program has been removed. The LDAR requirements of NSPS KKK are still applicable, but have been streamlined out of the operating permit in favor of the more stringent requirements of NSPS OOOOa. An email was received April 5, 2005 that requested the addition of oxidation catalyst controls to the unit descriptions for engines S018 and S019. No controlled emission limits were requested. An application was received on July 21 , 2005 that requested the addition of a 115 HP engine for a back-up air compressor (S022). An APEN submitted with this application requested 1000 hours per year operation and a NOx emission limit of 1.9 tons per year. This engine was assigned permit number 07WE0089 but the construction permit was never issued by the Division. Kerr-McGee anticipates that this engine will be APEN exempt per Colorado Regulation No. 3, Part A, Section II.D.1.a since uncontrolled actual emissions are expected to be less than de minimis levels of one ton per year. An APEN and permit cancellation notice for this engine was received on December 26, 2017. Kerr-McGee is required to maintain records of actual emissions to verify the engine is exempt from APEN reporting. This engine is subject to the requirements of 40 CFR Part 63 Subpart ZZZZ as indicated in Section III: Applicable Requirements. A minor modification application was received on October 28, 2005 that requested an increase in the VOC emission limit for fugitive emissions (S007) from 19.0 to 24.0 tons per year. This application was found to be insufficient upon review; specifically, no differentiation was made between the VOC content of gas and liquid streams used in the analysis and emission were found to be significantly underestimated. This application has been superseded by the application received on December 26, 2017. A minor modification application was received on June 13, 2006 that requested replacement of turbine engine S020 with a like kind model and the addition of the alternative operating scenarios for engine replacement for turbines and reciprocating engines. Current alternative operating scenarios for turbines and reciprocating engines have been included in the operating permit. Details on the incorporation of turbine S020 can be found in Section V: Emission Sources, below. An application was received on June 29, 2007 that requested the following modifications: the revision of permit language to allow for the fuel allocation procedure to be used to monitor fuel consumption when data from an individual fuel meter is not 123/0057 Page 12 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit reliable, the deletion of the requirements for the Elastec Smart Ash incinerator unit since this unit was removed from the facility, and the addition of VOC emissions associated with the NGL amine sweetening unit. The change in language for fuel consumption monitoring and the deletion of the incinerator requirements were requested to be processed as minor modifications and the Division agrees that these can be processed as such. The modification to revise the fuel monitoring language will not be effected in the operating permit since Kerr-McGee indicated in a response to an information request, received on March 27, 2017, that all engines are now monitored using individual fuel meters and that the fuel allocation procedures are no longer necessary or desired. The addition of VOC emissions to the NGL amine unit was submitted as a significant modification and would be required to be processed as such since it represented a significant increase in VOC emissions. This modification for the NGL amine unit was never acted upon by the Division and has subsequently been superseded by the modification received on June 12, 2014. An application was received on April 27, 2011 , requesting transfer of ownership of all points at the Platte Valley facility from Encana Oil and Gas USA to Kerr-McGee Gathering LLC. A modification application was received on June 12, 2014 to incorporate the provisions of construction permit 12WE1277 for the NGL amine sweetening unit (S009) and modified construction permit 02WE0927 for the plant process flare (S021). See Section V: Emission Sources for details on these construction permits and how they were incorporated into the operating permit. An application was received on December 26, 2017 that requested a change in the emissions calculation method and an increase in the emission limit for fugitive emissions at the Platte Valley plant (S007, AIRS point 042). This application has been superseded by the one received on October 24, 2019. See Section IV.B: Revisions to Previously Incorporated Sources, below. An application was received on December 26, 2017 that requested emission controls be applied to the limits for CO and VOC, as well as to the calculation of emissions of formaldehyde, acetaldehyde, and acrolein for compressor engines S018 and S019 (AIRS points 050, 051). See Section IV.B: Revisions to Previously Incorporated Sources, below. A modification application was received on August 3, 2018 to incorporate the provisions of Construction Permit 17WE0053 for the pressurized natural gas liquids loading operations (NG-TL-01, AIRS point 073) at the Platte Valley plant. Details on the incorporated provisions of this construction permit can be found in Section V: Emission Sources, below. An application for a modification was received on August 27, 2018, that requested to revise the emission limits for the Platte Valley process flare (S021 , AIRS point 053). Details of this modification request can be found in Section V: Emission Sources, below. An application was received on October 24, 2019 that requested a change in the emission limit for fugitive emissions at the Platte Valley plant (S007, AIRS point 042) 123/0057 Page 13 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit based on the use of control efficiencies associated with the leak detection and repair program of NSPS OOOOa. See Section IV.B: Revisions to Previously Incorporated Sources, below. An application was received on January 8, 2020 requesting a revision of the NOx emission factor for compressor engines S018 and S019 (AIRS points 050 and 051). See Section IV.B: Revisions to Previously Incorporated Sources, below. B. Revisions to Previously Incorporated Sources The following modifications have been requested for sources previously incorporated into this operating permit. 1. Modification to the Emissions Calculation Methodology and Increase in Permit Limits for S007: Fugitive Emissions from Equipment Leaks (AIRS point 042) — Received October 24, 2019 Fugitive emissions at Platte Valley were previously calculated using screening range emission factors from Table 2-8 of EPA's Protocol for Equipment Leak Emission Estimates (document EPA-453/R-95-017, Nov 1995, hereafter identified as the leaks document), which provides different emission factors for emissions calculations depending on whether components are detected to be leaking or not (leak rate is 10,000 ppmv or greater). The EPA document does not specify a monitoring frequency for detection of leaks or a method to determine how to apply these factors when using this estimation method on an ongoing basis. The previous operating permit also did not contain language sufficient to explain how to determine which set of emission factors to use, based on periodic leak detection monitoring, when calculating emissions for a twelve month rolling limit. The Platte Valley plant is subject to the quarterly leak detection and repair (LDAR) requirements of 40 CFR 60 (NSPS) Subpart KKK, however, instrument monitoring of connectors under Subpart KKK that would reveal a quantified leak rate is not required. The plant is also currently subject to the LDAR requirements of 40 CFR 60 Subpart OOOO, as required by Colorado Regulation No. 7, Part D, Section I.G.1 , and the provisions of 40 CFR 60 Subpart 0000a have been included in the operating permit as applicable requirements. The requirements of NSPS KKK have been streamlined out of the operating permit in favor of the more stringent requirements of NSPS OOOOa. (See Section III: Applicable Requirements, 40 CFR 60 Subpart KKK, above.) Application Received on December 26, 2017 (superseded) This application revised the emission calculation method to use the average emission factors of Table 2-4 from the equipment leaks document, which don't require determination of a quantified leak threshold for use. This change would align the emissions calculation method with 12-month rolling total emissions calculation requirements and with that of other fugitive emissions sources at the Fort Lupton Complex. Control efficiencies from Table 5-3 of the equipment leaks document were approved for use in calculating fugitive emissions: 70% - gas valves, 61% - light liquid valves, 45% light liquid pumps. These control efficiencies are applicable for LDAR programs with quarterly monitoring with a leak definition of 123/0057 Page 14 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit 10,000 ppmv (equivalent to NSPS KKK). This change in emissions calculation method resulted in a requested fugitive emissions limit of 104.8 tons/yr. This is an increase of 85.8 tons/yr over the previous limit. Subsequent to the submittal of this application, Platte Valley became subject to the equipment leak provisions of NSPS OOOO through the requirements of Regulation No. 7, Part D, Section I.G and has submitted an application to use control efficiencies based on voluntary compliance with the NSPS 0000a LDAR program. This application has been superseded by one received on October 24, 2019. Application Received on October 24, 2019 The calculation method for fugitive emissions in this application also uses the average emission factors of Table 2-4 from the equipment leaks document. These emission factors (in kg/component-hr, converted to lb/cornponent-hr) are given in terms of Total Organic Compounds and are multiplied by the number of components of each type (e.g. Pump Seals) and the VOC weight fraction of the stream as determined in the most recent analysis. Emissions by component type are summed to calculate total emissions, assuming 8760 hours per year of operation. Control efficiencies requested for this application — 96% for gas valves, 95% for light liquid valves, 88% for light liquid pumps, and 81% for connectors in all services — have been designated on the APEN for fugitive emissions as applicable to sources with an LDAR program conducted according to the requirements of NSPS OOOO or OOOOa. These control efficiencies are originally from Table 5-3 of the equipment leaks document and designated as applicable to LDAR programs conducted according to the requirements of the hazardous organic NESHAP equipment leak negotiated regulation (40 CFR 63 Subpart H or MACT H). The equipment-specific leak definitions and monitoring frequency of MACT H are substantially similar to those of NSPS OOOO/OOOOa. The table below contains the component counts used to develop the permit limits. Component Count' Component Gas Service Light Liquids Heavy Liquids Connectors 12,903 10,498 3,107 Flanges 3,657 2,847 432 Pump Seals 0 61 13 Valves 6,076 3,189 441 Other 292 82 20 Open-Ended Lines 0 0 0 Total 22,928 16,677 4,013 'Component count estimates are based on 2018 Platte Valley component count x 130%. The following streams and associated weight percentages of VOC and HAP were used to develop the emission limits: Composition(wt%)1 123/0057 Page 15 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit Representative Fluid VOC Benzene Toluene Ethyl- Xylene n-Hexane 224-TMP Benzene Inlet Gas 25 4.0 4.0 4.0 4.0 8.0 4.0 Fuel Gas or Residue Gas 9 1.0 1.0 1.0 1.0 1.0 1.0 NGL or O+ 100 4.0 4.0 4.0 4.0 8.0 4.0 Heavy Oil or Light Oil 100 4.0 4.0 4.0 4.0 8.0 4.0 1Concentrations given represent conservatively high estimates based on liquids and gas analyses provided as part of the 12/24/2017 application, sampled in 2017 and 2018. This change in emissions calculation method results in a new fugitive emissions limit of 46.7 tons/yr. This is an increase 27.7 tons/yr over the previous limit. This change does not affect any previous applicability determinations for the Platte Valley facility. Fugitive emissions do not count toward applicability determinations in the definition of major source for non-listed sources for Title V requirements in Regulation No. 3, Part A, Section I.B.25 or for PSD/NSR requirements in Reg.3, Part D, Section II.A.25. Additionally, since the Denver Metro/North Front Range area became non-attainment for ozone, neither the previous owner, Encana, nor Kerr-McGee has undergone non-attainment new source review for a major modification for VOC at the Platte Valley/Fort Lupton Complex facility, in which fugitive emissions would have been considered. 2. Modification to permit oxidation catalyst emission controls for engines S018 (AIRS point 050) and S019 (AIRS point 051) — Received December 26, 2017; Modification to revise emission factor for NOx — Received on January 8, 2020 These engines originally had oxidation catalysts installed in early 2005 as required by Colorado Regulation No. 7, Part E, Sections I.A and I.B, however, no modification to the construction or operating permits was requested to obtain emission limits representing these controls. The application received December 26, 2017 requested these emission controls be applied to the limits for CO and VOC, as well as to the calculation of emissions of formaldehyde, acetaldehyde, and acrolein. The application received on January 8, 2020 requested a revised NOx emission factor based on portable analyzer tests performed for these engines. The requested emission factor is 0.530 lb/MMBtu. This request was approved as this emission factor still represents a conservative emission factor compared to previous information provided on a manufacturer spec sheet. No change in the permitted annual NOx emission limit was requested as part of this application. Requested emission limits are based on uncontrolled emission factors for CO and VOC that were included in the previous operating permit and the NOx emission factor requested in the January 8, 2020 application. The emission factor for CO was developed from stack tests conducted in 1998. The VOC emission factor is from the January 1995 version of AP-42. The natural gas heat content used to estimate emissions was increased to 1100 Btu/scf (from 1020). 123/0057 Page 16 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit The requested emission factors and the revised potential to emit based on the oxidation catalyst controls are shown in the table below. Emission Factors and PTE for EU-290 (S018) and EU-289 (S019) Pollutant Uncontrolled Controlled Uncontrolled Controlled Source PTE3 (g/hp-hr) (g/hp-hr) (lb/MMBtu)1 (lb/MMBtu)2 (tpy) NOx --- --- 0.530 0.530 99OPWE207/ 20.4 stack test CO --- --- 0.492 0.049 99OPWE207/ 1.70 stack test VOC --- --- 0.18 0.045 AP-42 Table 1.6 3.2-2 Formalde 0.25 0.063 0.073 0.018 Manufacturer 0.64 -hyde Acetalde- AP-42 Table 0.00836 0.002 0.07 hyde 3.2-2 Acrolein --- --- 0.00514 0.001 AP-42 Table 0.05 3.2-2 1Conversion from g/hp-hr to lb/MMBtu was made using a BSFC of 7532 Btu/hp-hr 2Controlled emission factors are based on control efficiencies using the oxidation catalysts: CO—90%; VOC, Formaldehyde, Acetaldehyde and Acrolein—75% 3PTE is calculated using the permitted fuel consumption of 63.4 MMscf/yr and a fuel heating value of 1100 Btu/scf(preciously 1020 Btu/scf) C. The source's requested modifications were addressed as follows: Modifications for incorporation of construction permits issued for emission units at this facility since the latest revision to this operating permit are included in Section V: Emission Units, below. All references to the owner of the facility have been changed to Kerr-McGee Gathering according to the transfer of ownership package received on April 27, 2011 . Page Following Cover Page • The designated Responsible Official was revised according to a response to comments received on September 27, 2018. The permit contact was revised per comments received on December 2, 2019. These comments designated Mr. Miguel DeHerrera, Director of Midstream Operations, as the new Responsible Official, and Mark Losowski, HSE Representative, as the new permit contact. A previous request to change the Responsible Official, received on September 29, 2017, designated Mr. Craig Collins, Senior Vice President and Chief Operating Officer, as the Responsible Official, and Mr. Mathew Berghorn as a Duly Authorized Representatives of the Company, who is delegated the authority to sign environmental permits and/or compliance reports on behalf of the Company. Section I — General Activities and Summary • Condition 1 .3: Removed CP references for cancelled units (93WE157-8, 95WE683) and added CP references for units added (01WE0290, 02WE0927, 12WE1277, 17WE0053, 12WE1206.XP) 123/0057 Page 17 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit • Updated Condition 2 to include the current version of the natural gas engine Alternative Operating Scenario (AOS) (10/12/12), as well as to add the current AOS for turbine replacement. Revised Table 1: Internal Combustion Engine Information for the AOS to include descriptions of engines currently permitted at the facility. • Condition 6 — Summary of Emission Units o Removed descriptions for the following units since these have been permanently shut down at this facility: S008 and 5010. (See notes under Section III — Specific Permit Terms, below) o Inserted descriptions of the following units that have been added since the previous issuance: S020, S021, and NG-TL-01 . o Revised the description for the amine unit S009. Section III — Specific Permit Terms • Section III, Condition 1 (former Condition 1 of 99OPWE207) for Ajax compressor engines S001-S004 (AIRS points 038-041) o In draft permit comments received on November 9, 2017 Kerr-McGee requested the emission factors for CO and VOC be revised to be consistent with the emission and fuel use limits for these engines (CO — 0.514 lb/MMBtu, VOC - 0.257 lb/MMBtu). Emission limits, fuel consumption limits, and emission factors for construction permits 93WE157-1 to 93WE157-4 were originally based on manufacturer specifications for larger Ajax engines (600 and 800 HP) that were intended to be installed, but when the final approval construction permit was issued the emission factors were back-calculated to match the original emission and fuel use limits for the 600 HP engines with the smaller horsepower of the engines that were actually installed. In the initial operating permit the emission factors in the construction permits for CO and VOC were replaced with AP-42 factors. In draft permit comments received on December 9, 2019, Kerr-McGee requested that the emission factors for CO and VOC be revised again to those from the initial issuance of 99OPWE207. The current version of these emission factors, from AP-42 Table 3.2-1, updated in July 2000, have been included in the operating permit. • Section III, Condition 2 (former Condition 2 of 99OPWE207) for fugitive equipment leaks, S007 (AIRS point 042) o The emission calculation methodology and emission limits have been revised according to the application received on December 26, 2017. See Section IV.B: Revisions to Previously Incorporated Sources, above. o The requirement to follow the VOC testing program of Appendix G has been removed from the operating permit per the modification request received on May 26, 2004. This program was predominantly redundant 123/0057 Page 18 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit with the LDAR requirements of NSPS KKK and its removal was not considered a significant reduction in monitoring since the requirements of NSPS KKK still apply. In addition, the more stringent requirements of NSPS 0000a now apply (See 40 CFR 60 Subpart OOOOa, in Section III: Applicable Requirements, above). o Per Kerr-McGee's comments on draft permit conditions, received November 9, 2017, removed language requiring a component hard count be conducted every five years since additions and deletions of component counts are maintained through compliance demonstration for the LDAR program of NSPS OOOOa. • Former Condition 3 for the Flare Industries16" flare (S008, CP# 93WE157-8) has been removed from the operating permit. This point was cancelled with the issuance of construction permit 02WE0927 for a replacement flare. • Section III, Condition 3 (former Condition 4 of 99OPWE207) for S009 — NGL Amine Treating Unit (AIRS point 043) has been replaced with the requirements of Construction Permit 12WE1277. This unit was originally considered permit exempt but was later determined to have VOC emissions above permitting levels. The permit exemption (95WE409.XP) was cancelled upon issuance of 12WE1277. See Section V: Emission Sources, below. • Section III, Condition 4 (former Condition 6 of 99OPWE207) for Ajax compressor engine S012 (AIRS points 044) o In draft permit comments received on November 9, 2017 Kerr-McGee requested the emission factors for NOx, CO and VOC be revised to be consistent with the emission and fuel use limits for these engines (NOx- 0.697 lb/MMBtu, CO - 0.834 lb/MMBtu, VOC - 0.278 lb/MMBtu). Emission limits, fuel consumption limits, and emission factors for construction permit 97WE0722 were based on manufacturer specifications for Superior 694 HP engines that were intended to be installed. The Ajax engines were installed instead, and when final approval for the construction permit was completed through the issuance of the initial operating permit the original emission and fuel consumption limits remained but the emission factors were revised. The NOx emission factor included in the initial operating permit was ostensibly based on stack tests, but aligned with manufacturer emission factors submitted for equivalent Ajax engines permitted in 1997; CO and VOC emission factors were from AP-42. In draft permit comments received on December 9, 2019, Kerr-McGee requested that all emission factors be revised again to those from the initial issuance of 99OPWE207. The NOx emission factor was returned to that of the initial OP issuance. The current version of the CO and VOC emission factors, from AP-42 Table 3.2-1, updated in July 2000, have been included in the operating permit. • Former Condition 5 for the Elastec Smart Ash Incinerator (S010, CP# 95WE683) has been removed from the operating permit. A cancellation notice 123/0057 Page 19 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit was received for this unit on May 29, 2007 and removal from the operating permit was requested in the June 29, 2007 modification application. • Section III, Condition 6 (former Condition 9 of 99OPWE207) for Ajax compressor engines S015-S017 (AIRS points 047, 048, 049) o In draft permit comments received on November 9, 2017 Kerr-McGee requested the emission factors for CO and VOC be revised to be consistent with the emission and fuel use limits for these engines (CO — 0.543 lb/MMBtu, VOC - 0.271 lb/MMBtu). These were the original emission factors used to develop the emission limits in construction permits 97WE0725, 97WE0726, and 97WE0727. In draft permit comments received on December 9, 2019, Kerr-McGee requested that the emission factors for CO and VOC be revised again to those from the initial issuance of 99OPWE207. The current version of these emission factors, from AP-42 Table 3.2-1, updated in July 2000, have been included in the operating permit. • Section III, Condition 7 (former Condition 10 of 99OPWE207) for Caterpillar G3516 compressor engines S018 and S019 (AIRS point 050, 051) o The NOx emission factor was revised according to the application received on January 8, 2020. Emission limits for these engines were revised according to the application received on December 26, 2017, with permitted CO and VOC limits based on oxidation catalyst control. See Section IV.B: Revisions to Previously Incorporated Sources, above. • Provisions for the systems control generator, PLV PLC GEN, and the diesel generator powering a back-up air compressor, S022, were included in Section III, Condition 12 for insignificant units subject to NSPS/MACT requirements. Section V — Permit Shield • Included a permit shield item for 40 CFR 60 Subpart GG, §60.334(a), for turbine S020 (AIRS point 020) related to water injection for NOx control. The source does not use water injection but uses lean premixed combustion for NOx control. This permit shield was requested in the minor modification received on August 22, 2002 and also in the renewal application received September 30, 2003. Appendices • The list of insignificant activities was updated according to the most recent application. V. Emission Sources The applicable requirements of construction permits issued for emission units at this facility since the latest revision to this operating permit have been incorporated as follows: A. Conditions Not Included in the Unit-Specific Conditions of the Operating Permit 123/0057 Page 20 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit 1. Applicable Requirements: Conditions, which are common to various construction permits but which have not been included in the unit-specific conditions of the operating permit, have been listed in Section V.A of the Fort Lupton Technical Review Document. They have been consolidated there to avoid repetition in the permit specific sections. Any conditions from construction permits not discussed in the permit specific sections below are represented there. Any conditions specified in Section V.A of the Fort Lupton Technical Review Document that are still applicable to specific units or permits have been repeated in the permit specific sections to which they apply. B. S009: One (1) Natural Gas Liquids (NGL) amine sweetening unit, design capacity of 15,000 BBL/day. The amine solution is a specific formulated amine consisting of any combination of MEA, DEA, TEA, MDEA, and DGA. This system includes a NGL/amine contactor, a flash tank, a natural gas fired regeneration reboiler rated at 10.7 MMBtu/hr (AIRS point 045) and two (2) electric amine recirculation pumps with a total design capacity of 100 gallons per minute. Still vent and flash tank emissions are routed to a recuperative thermal oxidizer. During thermal oxidizer downtime flash tank emissions are routed to the process flare (AIRS point 053) and still vent emissions are routed to the atmosphere. Thermal oxidizer burner is rated at 5.0 MMBtu/hr. (AIRS point 043) This unit was first placed in service in 1995 but was considered permit exempt, however, basic requirements were included in the initial operating permit (APEN reporting, opacity, O&M requirements, in Section II, Condition 4). An application for a modification to the operating permit, received on June 29, 2007, included an APEN for this unit and requested a significant modification to include a VOC emission limit of 60.1 tons per year. This application was never processed by the Division. 1. Applicable Requirements: Colorado Construction Permit 12WE1277 was originally issued for this unit on June 10, 2013 as initial approval. Self-certification has been completed for this permit and a Final Approval to Operate letter was issued on June 2, 2014. The applicable requirements of Construction Permit 12WE1277 have been incorporated into the operating permit as follows: • (Condition 4) Emissions of air pollutants shall not exceed the following limitations. Compliance with the annual limits shall be determined on a rolling twelve (12) month total. The permit holder shall calculate emissions each month and keep a compliance record on site, or at a local field office with site responsibility, for Division review. After the first twelve months of operation after issuance of this permit, compliance with only the annual limitation is required. (Reference: Regulation No. 3, Part B, Section II.A.4) o NOx — 6.5 tons/yr; 1111 lb/month o VOC — 1.1 tons/yr; 187 lb/month o CO — 5.5 tons/yr; 934 lb/month The monthly emission limits have not been included in the operating permit, as these were only required for the first twelve months after permit issuance. The 123/0057 Page 21 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit annual emission limitations (calculated on a rolling 12-month total), associated compliance monitoring, and recordkeeping requirements have been included in the operating permit. • (Condition 5) Compliance with the emissions limits in this permit shall be demonstrated by running the ProMax model on a monthly basis using the most recent amine unit inlet extended gas analysis and recorded operational values (including gas throughput, lean amine recirculation rate, lean amine concentration and other operational values specified in the O&M Plan). Recorded operational values, except for gas throughput, shall be averaged on a monthly basis for input into ProMax. The requirement to run the ProMax model monthly using recorded operational parameters for demonstration of compliance with the VOC limit of the permit has not been included in the operating permit. In comments on a draft permit received on November 9, 2017, Kerr-McGee requested to use the pounds per hour results of their semi-annual compliance tests, multiplied by the hours of operation, to calculate actual emissions. The Division has agreed to allow the use of compliance test results to calculate actual emissions, but will require emission factors to be developed based on actual NGL throughput and waste and supplemental gases routed to the thermal oxidizer, so that emissions calculated based on these factors are more representative of actual processing rates instead of the processing rates of the amine unit at the time of testing. Emission factors are required to be developed for VOC in terms of lb/BBL of NGL processed and NOx and CO in terms of lb/MMscf of gas routed to the thermal oxidizer. • (Condition 6) The natural gas liquids amine sweetening unit shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Reference: Regulation No. 3, Part B, Section III.E) o Recuperative thermal oxidizer The requirement to operate the recuperative thermal oxidizer in order to reduce emissions to the established permit limits has been included in the operating permit. • (Condition 7) 100% of emissions that result from the flash tank associated with this amine unit shall be recycled to the thermal oxidizer as fuel. The requirement to route flash tank emissions to the thermal oxidizer as fuel has been included in the operating permit but without the 100% stipulation since this would create automatic non-compliance during thermal oxidizer downtime. The permit states that flash gas emissions are routed to the process flare during thermal oxidizer downtime. Still vent emissions are routed to the atmosphere during thermal oxidizer downtime. • (Condition 8) This source shall be limited to the following maximum processing rates, as listed below. Monthly records of actual natural gas liquids processing 123/0057 Page 22 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit rates and waste gas and supplemental fuel combustion shall be maintained by the owner or operator and made available to the Division for inspection upon request. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. After the first twelve months of operation after issuance of this operating permit, compliance with only the annual limitations is required. (Reference: Regulation No. 3, Part B, Section II.A.4) o Natural gas liquids throughput: 5,475,000 BBL/yr; 456,000 BBL/month o Combustion of waste gas and supplemental fuel: 301 .4 MMscf/yr; 25.6 MMscf/month The monthly processing limits have not been included in the operating permit, as these were only required for the first twelve months after permit issuance. The annual processing limits, associated compliance monitoring, and recordkeeping requirements have been included in the operating permit. • (Condition 9) This unit shall be limited to the maximum lean amine recirculation pump rate of 100 gallons per minute. The lean amine recirculation rate shall be monitored and recorded daily in a log maintained on site and made available to the Division for inspection upon request. (Reference: Regulation No. 3, Part B, II.A.4) The limit on lean amine recirculation rate, associated compliance monitoring, and record keeping have been included in the operating permit. • (Condition 11) Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.1 . & 4.) This condition has been modified to include all of the operating scenarios applicable to the Section II.A.4 30% standard. A qualitative visual emissions observation will be required daily to monitor compliance with the opacity requirements, with a follow up Reference Method 9 reading if visual emissions are observed. • (Condition 13) This amine unit is subject to the New Source Performance Standards requirements of Regulation No. 6, Part A, Subpart LLL, Standards of Performance for Onshore Natural Gas Processing: SO2 Emissions. The requirements of this NSPS are related to recordkeeping that demonstrates the facility is under the emission threshold for applicability for the standards (<2 long tons per day H25 in the acid gas). The applicable requirements of NSPS Subpart LLL have been included in the operating permit. • (Condition 14) The operator shall continuously monitor with a flow meter the following amine unit emission streams. By the end of each month, the total flow for the previous months' data shall be calculated, and a new twelve-month 123/0057 Page 23 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit total shall be calculated and recorded based on the previous twelve months' data. o Total acid gas volume routed to the thermal oxidizer. o Total supplemental fuel volume routed to the thermal oxidizer. o Total flash tank off gas volume from each amine unit flash tank. The requirement to monitor acid gas, supplemental fuel, and flash tank off gas volume with flow meters on a rolling twelve month total has been included in the operating permit for compliance monitoring for the process rate limits of Condition 8. • (Condition 15) The concentration of amine (MEA, DEA, TEA,MDEA and/or DGA plus piperazine) in the lean amine stream shall not exceed 45 weight percent on a monthly average basis. Records of the concentration of amine in the lean amine stream shall be kept according to the operating and maintenance plan for this point and shall be made available to the Division for inspection upon request (Colorado Regulation No. 3, Part A, II). The limit on amine concentration in the lean amine stream, associated compliance monitoring, and record keeping have been included in the operating permit. • (Condition 16) The concentration of amine in the lean amine stream shall be measured and recorded on a weekly basis. The concentration of amine is defined as the combined weight percent of all amine solutions and piperazine in the lean amine stream. Records of these operating parameters shall be made available to the Division for inspection upon request. (Colorado Regulation No. 3, Part A, II) The requirement to measure and record the concentration of amine in the lean amine stream weekly has been included in the operating permit along with the recordkeeping requirements and the definition for amine concentration. • (Condition 17) Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. (Reference: Regulation No. 3, Part B, Section III.G.7.) The applicable requirements from the O&M plan, including process parameter monitoring (lean amine circulation rate, inlet NGL temperature and pressure, volume of gas processed), control device monitoring (combustion temperature), operation and maintenance according to manufacturer recommendations, and recordkeeping requirements have been directly incorporated into the operating permit. • (Condition 18) The operating temperature of the thermal oxidizer used to control emissions from this dehydration unit shall be greater than 1400 °F, or 123/0057 Page 24 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit the temperature established during the most recent stack test of the equipment that was approved by the Division, at all times that any amine unit still vent emissions are routed to the thermal oxidizer in order to meet the emission limits in this permit. The reference to a dehydration unit was in error. The requirement to monitor and maintain the temperature of the thermal oxidizer at 1400 °F, or the temperature established during the most recent Division approved stack test, at all times that amine unit emissions are vented to the thermal oxidizer, has been included in the operating permit. The established thermal oxidizer operating temperature is required to be monitored continuously and maintained in order to apply the control efficiency to uncontrolled emissions from the amine unit. • (Condition 19) The owner or operator shall complete the initial inlet natural gas liquids analysis testing required by this permit and submit the results to the Division as part of the self-certification process to ensure compliance with emissions limits. (Reference: Regulation No. 3, Part B, Section III.E.) The initial inlet natural gas liquids analysis has been completed as part of the self-certification process, therefore, this condition has not been included in the operating permit. Ongoing natural gas liquids analyses have been required semi-annually. • (Condition 20) A source initial compliance test shall be conducted on emissions point 043 to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emissions limits specified in Condition 4 in this permit. The operator shall also demonstrate the thermal oxidizer achieves a minimum destruction and removal efficiency of 99.0% for VOC. o NOx, CO, VOC, HAPs (BTEX and n-Hexane) The initial compliance test has been completed as part of the self-certification process and the results were submitted to the Division on December 5, 2013. The test demonstrated compliance with all emission limits. Therefore, this requirement has not been included in the operating permit. Periodic testing is required by Condition 21. • (Condition 21) The operator shall measure the emission rate(s) for the pollutants listed below at least once every six months in order to demonstrate compliance with the emissions limits contained in this permit. Periodic testing shall be conducted at a minimum of at least thirty (30) days apart. The operator shall also demonstrate the thermal oxidizer achieves a minimum destruction and removal efficiency of 99.0% for VOC. o NOx, CO, VOC, HAPs (BTEX and n-Hexane) The requirement to conduct periodic testing has been included in the operating permit. The Division had requested that Kerr-McGee use EPA Method 320 of 40 CFR Part 63, Appendix A for testing of VOC emissions. This is due to 123/0057 Page 25 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit inconsistencies in testing performed on the amine unit with methods that are currently being used (Method 25A for total hydrocarbons and Method 18 for BTEX and n-Hexane and for Methane and Ethane to determine non-methane non-ethane hydrocarbons). These inconsistencies have included recorded methane and ethane levels being higher than total hydrocarbon levels and HAP levels (individual and total) being higher than VOC levels. Kerr-McGee indicated, in a response to an information request received on October 18, 2019, that in order to do a Method 320 test a stack extension would have to be added to the top of the thermal oxidizer to get the flow measurement above the flame front in the stack, but the thermal oxidizer's support structure and support legs cannot support a stack extension as it would be unsafe. Therefore, no specific testing requirement has been included in the operating permit. • (Condition 22) The operator shall sample the inlet natural gas liquids to the amine unit on an annual basis to determine the concentration of hydrogen sulfide (H2S) in the liquids stream. The sample results shall be monitored to demonstrate that this amine unit qualifies for the exemption from the Standards of Performance for Onshore Natural Gas Processing: SO2 Emissions (§60.640(b)). The testing required by Condition 23 may be used for this demonstration. The requirement to sample inlet natural gas liquids for H2S concentration and to use these results to demonstrate that the exemption of §60.640(b) is valid for the amine unit has been included in the operating permit. • (Condition 23) The owner or operator shall complete an extended liquids analysis prior to the inlet of the amine unit on an annual basis. Results of the sour liquids analysis shall be used to calculate emissions of criteria pollutants and hazardous air pollutants per this permit. The requirement to perform an extended natural gas liquids analysis has been included in the operating permit. This analysis has not been required to be used for emissions calculations purposes since emissions will be based on the results of the periodic performance tests going forward. The frequency of extended natural gas liquids analyses has been revised to semi-annually. • (Condition 24) This permit replaces the following permits, which are cancelled upon issuance of this permit. O 95WE409.XP, exemption is cancelled upon issuance of this permit This requirement has not been included in the operating permit since it was completed with the issuance of the construction permit. 2. Emission Factors VOC emissions for this amine unit were developed based on the ProMax simulation model and estimated supplemental fuel necessary to achieve a heat content of 300 Btu/scf for combustion in the thermal oxidizer. NOx and CO emissions are based on the heat content of the amine unit outlet streams as 123/0057 Page 26 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit predicted by the ProMax model and emissions factors from AP-42, Table 1 .4-1 for natural gas combustion in external combustion sources. NOx, CO, and VOC emissions will be required to be determined based on the results of the periodic compliance tests going forward. 3. Monitoring Plan Periodic parameter monitoring for the amine unit has been required in the operating permit including semi-annual extended inlet natural gas liquids analyses, as well as daily monitoring of the lean amine circulation rate, inlet temperature and pressure, and flash tank temperature and pressure. Amine concentrations are required to be monitored weekly for comparison to the limit. Total volumes of acid gas, flash tank off gas, supplemental fuel, and thermal oxidizer burner fuel are required to be continuously monitored using flow meters and used for calculation of NOx and CO emissions. Semi-annual extended natural gas liquids analyses have been required for all streams routed to the thermal oxidizer for calculation of uncontrolled VOC emissions for periods when gases are routed to the thermal oxidizer but it is not operating or doesn't meet the minimum temperature requirement. The thermal oxidizer combustion temperature is monitored every hour using a thermocouple for comparison to the temperature established during the latest stack test which demonstrated compliance with emission limits. Semi-annual stack tests have been established in Construction Permit 12WE1277 for monitoring of compliance with emission limits. Emission factors based on the results of these stack tests will be required to be developed and used to calculate actual emissions monthly. A qualitative visual emissions observation is required to be conducted daily, with a follow up Method 9 observation to be performed when visible emission are observed, to monitor compliance with opacity requirements. 4. Compliance Status The Division completed a full compliance evaluation at the facility on August 31 , 2016. According to the inspection report, amine unit S009 was in compliance with Construction Permit 12WE1277 and applicable air pollution control regulations. C. S020: One (1) Solar Centaur 40, natural gas fired internal combustion turbine engine, nominally rated at 4700 HP, design rated at 37.9 MMBtu/hr, Serial No. DCC0208. This unit powers a natural gas compressor. (AIRS point 052) 1. Applicable Requirements: Colorado Construction Permit 01WE0290 was originally issued on August 7, 2001 as Initial Approval. The source has demonstrated compliance under the provisions of Regulation No. 3, Part B, Section III.G.2 for initial approval construction permit 01WE0290 but has not yet received a final approval construction permit. Under the provisions of Regulation No. 3, Part C, Section V.A.3., the Division will not issue a final approval 123/0057 Page 27 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit construction permit and is allowing the initial approval construction permit to continue in full force and effect. The appropriate applicable requirements of the initial approval construction permit have been directly incorporated into this operating permit as follows: • (Condition 1) Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Opacity shall be measured by EPA Method 9. (Reference: Regulation 1, Section II.A.1.& 4.) The above opacity requirements have been included in the operating permit. The EPA Method 9 requirement has been replaced with language specifying that compliance with the opacity limits shall be presumed, in absence of credible evidence to the contrary, since only natural gas is permitted for use as fuel in this turbine engine. • (Condition 3) Emissions of air pollutants shall not exceed the following limitations. Compliance with the annual limits shall be determined on a rolling (12) month total. The permit holder shall calculate monthly emissions and keep a compliance record on site for Division review: (Reference: Regulation 3, Part B, III.A.4). o NOx - 49.0 tons/yr and 8162.7 Ib/mo; o CO — 35.5 tons/yr and 5917.3 Ib/mo; o VOC - 10.2 tons/yr and 1692.4 lb/mo The monthly emission limits have not been included in the operating permit, as these were only required for the first twelve months of operation. The annual emission limitations (calculated on a rolling 12-month total), associated compliance monitoring, and recordkeeping requirements have been included in the operating permit. • (Condition 4) This source shall be limited to a maximum consumption rate as listed below and all other activities, operational rates and numbers of equipment as stated in the application. Monthly records of the actual consumption rate shall be maintained by the applicant and made available to the Division for inspection upon request. Compliance with the yearly consumption limits shall be determined on a rolling twelve (12) month total. (Reference: Regulation 3, Part B,III.A.4) o Consumption of natural gas as fuel shall not exceed 26,666,666.7 scf per month and 320 MMscf/yr The monthly fuel consumption limit has not been included in the operating permit since this was only required for the first twelve months of operation. The yearly fuel consumption limit and associated monitoring and recordkeeping requirements have been included in the operating permit. 123/0057 Page 28 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit • (Condition 5) This source is subject to New Source Performance Standards requirements of Regulation No. 6, Part A, Subpart GG, Standards of Performance for Stationary Gas Turbines including, but not limited to the following: o Sulfur content of the fuel gas shall not exceed 0.8%; or monitoring of sulfur content shall be (by the "Length of Stain Tube") in accordance with federal NSPS ' 60.334. o Exhaust gases shall not contain nitrogen oxides exceeding 157.5 ppmVd (at 15% oxygen and ISO conditions) o NSPS General Provisions of 40 CFR 60.11 , 60.12, and 60.7. The applicable provisions of 40 CFR 60 Subpart GG and Subpart A (General Provisions) have been included in the operating permit. Monitoring of sulfur content by the "Length of Stain Tube" is no longer a provision of NSPS GG so this option has not been included. The sulfur content monitoring requirements of 60.334(h)(3)(i) and (ii) have been included in the operating permit. The exhaust gas NOx concentration limit is based on the equation in §60.333(a)(2) and a manufacturer's rated heat rate at peak load of 13.72 kJIW- hr (9702 Btu/hp-hr). • (Condition 6) A source compliance test shall be conducted to measure the emission rate(s) for the pollutants listed below. o Oxides of Nitrogen and Carbon Monoxide using EPA approved methods A compliance test was conducted for this unit on March 6, 2002 that demonstrated compliance with the permitted NOx and CO limits; therefore, this condition has not been included in the operating permit. Although not specifically identified in Colorado Construction Permit 01WE0290, this turbine is subject to the following applicable requirements: • Colorado Regulation No. 1 o Section III.A.1 .b: Particulate matter limitation for fuel burning equipment with design heat inputs greater than 1 MMBtu/hr but less than or equal to 500 MMBtu/hr. Particulate matter emissions shall not exceed 0.5 x (FI)-°.26 lb/MMBtu where Fl = fuel input in MMBtu/hr. o Section VI.B.4.c.(i): Limitation of 0.8 lb of SO2 per million Btu of heat input for combustion turbines with a heat input of less than 250 MMBtu/hr which had not been issued an emission permit prior to August 11, 1977. • Colorado Regulation No.6 o Part B, Section II.C.2: Particulate matter limitation for fuel burning equipment with design heat inputs greater than 1 MMBtu/hr but less than 123/0057 Page 29 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit or equal to 250 MMBtu/hr. Particulate matter emissions shall not exceed 0.5 x (FI)-°.26 lb/MMBtu where Fl = fuel input in MMBtu/hr. This requirement has been streamlined for the equivalent Regulation 1 , Section III.A.1 .b requirement; see Section VII: Streamlining of Applicable Requirements, in the Fort Lupton TRD. o Part B, Section II.C.3: Emissions of particulate matter shall not exceed 20% opacity o Part B, Section II.D.3.a: Limitation of 0.8 lb of SO2 per million Btu of heat input for combustion turbines with a heat input of less than 250 MMBtu/hr. This requirement has been streamlined for the equivalent Regulation No. 1 , Section VI.B.4.c.(i) requirement; see Section VII: Streamlining of Applicable Requirements, in the Fort Lupton TRD. • Colorado Regulation No. 7, Part E, Section II.A.6 (previously Section XVI.D.6) contains requirements (effective January 14, 2017) for combustion process adjustments for combustion equipment. Applicability is based on uncontrolled actual NOx emissions being greater than five tons per year. The requirements of Colorado Regulation No. 7, Part E, Section II.A.6 have been included in the operating permit. 2. Emission Factors Emission limits from the current construction permit have been incorporated into the operating permit. These emission limits are based on manufacturer emission factors for NOx, CO, and VOC provided in the original application. Emission factors for HAPs were taken from AP-42, Tables 3.1-2a and 3.1-3. This unit has a brake specific fuel consumption factor of 8059.9 Btu/HP-hr. 3. Monitoring Plan In order to monitor compliance with the annual emission and fuel consumption limits, the source will be required to monitor fuel consumption and calculate emissions on a monthly basis. The heat content of the natural gas used to fuel this turbine is required to be determined semiannually in order to calculate emissions using recorded natural gas consumption. Fuel consumption is monitored using a fuel meter. In addition, quarterly monitoring using a portable analyzer will be required to monitor compliance with the NOx and CO annual emission limits and emission rates. 4. Compliance Status The Division completed a full compliance evaluation at the facility on August 31 , 2016. According to the inspection report, turbine S020 was in compliance with Construction Permit 01WE0290 and applicable air pollution control regulations. D. S021: One (1) Flare Industries Air Assisted Flare. This emission unit is used for flaring of process gas. (AIRS point 053) 123/0057 Page 30 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit An application for a modification was received on August 27, 2018, that requested to revise the emission limits for the Platte Valley process flare. NOx and CO emissions were estimated using emission factors from AP-42, Chapter 13.5 for industrial flares. VOC emissions were estimated with a mass balance approach, using the VOC content determined from flare gas analyses and the permitted throughput to calculate VOC mass emissions. The new requested VOC limit is 31.8 tons per year, resulting in an increase of 30.7 tons per year. This change to the Platte Valley flare VOC emission limit has been done to more accurately quantify emissions from the flare. The Division considers that the newly permitted emission rate has been the emission rate for the flare since its original permitting and initial operation. A review of permitting actions for the flare determined that this change in emissions estimate would not have changed any previous applicability determinations for PSD/NANSR review. Original permitting and construction of the flare was done by the previous owner, Encana, in late 2002. The area in which the plant is located was in attainment for all pollutants at the time and the Platte Valley plant was not a major source for PSD. A throughput and emissions increase for the flare was permitted by Kerr-McGee in December 2013. Based on the current requested emissions and throughput rate the VOC emissions increase at the time would have been 17.5 tons/yr (current 31.8 tons/yr _ 103.4 MMscf/yr = 0.308 ton/MMscf; previous increase of 57.0 MMscf/yr equates to 17.5 tons/yr). Since this increase, as well as the current requested emission limit, is below the significance level for VOC and this throughput increase was not considered to be a part of any other project, no change in NANSR applicability from the project was warranted. Any increase in actual VOC emissions resulting from the December 2013 permitted throughput increase would have to be considered in any netting analysis done for any NANSR application where the actual emissions increase is within the contemporaneous period (five years prior to the date that the increase from the NANSR project would occur). 1. Applicable Requirements: Colorado Construction permit 02WE0927 was originally issued on November 21 , 2002 as Initial Approval. A modification was issued on December 2, 2013 to increase the process gas throughput as well as NOx and CO emissions. Self-certification has been completed for this permit and a Final Approval to Operate letter was issued on May 18, 2015. The applicable requirements of Construction Permit 02WE0927 have been incorporated into the operating permit as follows: • (Condition 5) Emissions of air pollutants shall not exceed the following limitations. Compliance with the annual limits shall be determined on a rolling twelve (12) month total. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. (Reference: Regulation No. 3, Part B, Section II.A.4) o NOx — 11 .3 ton/yr, 1920 lb/nnonth o CO — 22.5 tons/yr, 3823 lb/month 123/0057 Page 31 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit o VOC - 1.1 ton/yr, 187 lb/month The monthly emission limits have not been included in the operating permit since these were only required for the first twelve months of operation after permit issuance. The annual emission limitations (calculated on a rolling twelve-month total), associated compliance monitoring, and recordkeeping requirements have been included in the operating permit. VOC emissions monitoring and calculation requirements have been revised to comport with Condition 19 (see below). This method requires emissions to be calculated based on a mass balance approach using a periodic extended gas analyses that determines the VOC content of the streams routed to the flare, along with actual stream flow data. The emission limits for this flare have been revised according to the application received on August 27, 2018, as follows: o NOx — 5.6 tons/yr o CO — 25.4 tons/yr o VOC — 31 .8 tons/yr • (Condition 6) This source shall be limited to the following maximum processing rates as listed below. The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. (Reference: Regulation 3, Part B, II.A.4) o Process and purge gas — 102.6 MMscf/yr, 8.7 MMscf/month o Pilot gas — 0.77 MMscf/yr, 0.07 MMscf/rnonth The monthly throughput limits have not been included in the operating permit, since these were only required for the first twelve months of operation after permit issuance. The annual throughput limitations (calculated on a rolling twelve-month total), associated compliance monitoring, and recordkeeping have been included in the operating permit. The maximum process, purge, and pilot gas throughput limits have been revised according to the application received on August 27, 2018, as follows: o Process, Purge and Pilot gas — 103.4 MMscf/yr • (Condition 9) Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1 , Section II.A.1. & 4.) The opacity requirements of Reg. 1 Sections II.A.1 & 4 do not apply to process flares. Language in Section II.A.1 states "Except as provided for in paragraphs 123/0057 Page 32 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit 2 through 6 below..." and Section II.A.5 gives a 30% opacity requirement for flares that is applicable at all times. Therefore, these requirements have not been included in the operating permit. • (Condition 10) 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. (Reference: Regulation No. 1, Section II.A.5.) The opacity requirements of Reg. 1 , Section II.A.5 have been included in the operating permit. A one-time Method 9 opacity reading was performed as part of the self-certification process to demonstrate compliance with this condition. Compliance with this condition will be presumed, absent credible evidence to the contrary, based on the more stringent requirement for no visible emissions specified in Condition 14 below. • (Condition 12) The flare shall comply with the requirements in 40 CFR 60.18 for good engineering practices for a flare. No requirements in 40 CFR 60.18 are specifically designated as good engineering practices. The applicable requirements of 40 CFR 60.18 have been included in the operating permit, as indicated below. • (Condition 13) The operator shall continuously monitor and record the daily total volume of the process gas and purge gas streams being routed to the flare. By the end of each month, the total flow for the previous months' data shall be calculated, and a new twelve-month total shall be calculated and recorded based on the previous twelve months' data. The requirement to continuously monitor and record the daily volume of process and purge gas routed to the flare and to use this in the rolling twelve month total for compliance demonstration purposes has been included in the operating permit. • (Condition 14) The owner or operator shall design, construct, operate and maintain the flare according to the requirements set out in 40 CFR §60.18, including, but not limited to, the following: The Division has used the requirements of §60.18 as a model to establish periodic monitoring for this flare. The requirement to follow 40 CFR §60.18 for the design, construction, operation, and maintenance of the flare was included in this construction permit in accordance with the provisions of Colorado Regulation No. 3, Part B, Section III.E, which allows the Division to include any such terms and conditions which it deems necessary for the proposed project or activity to qualify for the permit. This flare is not subject to any applicable NSPS provisions of 40 CFR Part 60 that include these requirements for the flare. The operation and maintenance requirements of this condition have been maintained for the flare, while specific compliance demonstration methods have been revised to comport with monitoring already required by the source. 123/0057 Page 33 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit o The flare shall be designed and operated with no visible emissions as determined by 40 CFR §60.18(f), except for periods not to exceed a total of 5 minutes during any 2 consecutive hours. (§60.18(c)(1)) A monitoring scheme has been included in the operating permit to determine a frequency of monitoring for 40 CFR §60.18(c)(1), requiring that the flare be operated with no visible emissions, since no frequency is stated in the rule. The monitoring included requires visual emissions observations to be performed daily, with a full Method 22 observation to be conducted whenever visual emissions are present during the initial observation. o A flame shall be present at all times when emissions are vented to this flare, as determined by 40 CFR §60.18(f). (§60.18(c)(2)) Section 60.18(f) requires a thermocouple or equivalent device to monitor the presence of a flame, but does not give a monitoring frequency. This language has been revised to specify that the pilot flame must be monitored continuously, the device shall be equipped with an alarm to indicate no ignition of the flame, and records shall be kept of all pilot flame outages. o Flare specifications on heat content and maximum exit velocity per §60.18(c)(3) and §60.18(c)(5). 40 CFR §60.18(c)(3) states that "An owner/operator has the choice of adhering to either the heat content specifications in paragraph (c)(3)(ii) of this section and the maximum tip velocity specifications in paragraph (c)(4) of this section, or adhering to the requirements in paragraph (c)(3)(i) of this section", however, since the tip velocity specifications of (c)(4) apply only to steam-assisted and non-assisted flares, and the requirements of (c)(3)(i) specify that the flare be non-assisted, the requirements of (c)(3) are not compatible with an air-assisted flare. Therefore, only the requirements of 40 CFR §60.18 applicable to air- assisted flares have been included in the operating permit, although they may not comport with section (c)(3). These include section (c)(3)(ii) for heat content of gases routed to the flare and section (c)(5) for maximum tip velocity. The heat content requirement of gases routed to the flare in §60.18(c)(3)(ii) references §60.18(f)(3) for the determination of the heat content. This reference has been changed to the ongoing heat content monitoring required for calculation of monthly emissions from the flare, which is to be determined using ASTM methods or equivalent, if approved in advance by the Division. The §60.18(c)(5) requirement that flares be designed and operated with an exit velocity less that the velocity, Vmax, as determined by the method specified in paragraph §60.18(f)(6), has been included in the operating permit, as well as the method for calculating exit velocity as 123/0057 Page 34 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit specified in §60.18(f)(4). In order to monitor compliance with this requirement, the source will be required to calculate the maximum exit velocity of the flare monthly, based on actual operating conditions, and compare it to the limit specified by §60.18(f)(6). o The flare shall be monitored to ensure it is operated and maintained in conformance with its design, as specified in §60.18(d). Record keeping requirements, including manufacturer operation and maintenance requirements and maintenance performed on the flare, have been included in the operating permit to monitor compliance with this condition. • (Condition 15) This flare shall be operated at all times when emissions are vented to this flare. This condition has been included in the operating permit with the flare operation requirements of 40 CFR §60.18, since this requirement is included in those provisions. The language has been modified to state that the flare shall be operated at all times when emissions "may be" vented to it, as opposed to when emissions "are" vented to it, according to the original provision. • (Condition 16) Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) The most recent O&M plan for this flare was submitted on July 30, 2013. Requirements in this plan included calculating emissions according to permit requirements, monitoring of process gas throughput, monitoring of the pilot flame, maintaining records and following operation and maintenance plans according to manufacturer recommendations. All of these requirements, except the specific requirement to follow manufacturer's recommendations, were already included in the construction permit. This condition was not included in the operating permit since monitoring included in the O&M plan has been directly incorporated into the operating permit. • (Condition 17) The owner or operator shall complete the initial gas sample of the gas routed to the flare to determine the concentration of Hydrogen Sulfide, VOC, Benzene, Toluene, Ethylbenzene, Xylene and n-Hexane contents, and heat value in the gas stream. The owner or operator shall submit the results as part of the self-certification process to ensure compliance with emission limits. This requirement has not been included in the operating permit since it was completed as part of the self-certification process and there are no ongoing requirements for this condition. Periodic gas analyses have been included in the operating permit to calculate actual emissions for monitoring of compliance with the annual emission limits. 123/0057 Page 35 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit • (Condition 18) The owner or operator shall demonstrate compliance with Condition 9 using EPA Method 9 to measure opacity from the flare. (Reference: Regulation No. 1 , Section II.A.5). This requirement was included in the initial testing requirements for the construction permit and was completed as part of the self-certification process. Therefore, this requirement has not been included in the operating permit. • (Condition 19) On an annual basis, the operator shall complete a site specific extended gas analysis of the natural gas produced at this site that is routed to the flare in order to verify the content of VOC, Benzene, Toluene, Ethylbenzene, Xylene and n-Hexane contents (weight fraction) of this emission stream used in the permit application. Results of testing shall be used to determine site-specific emission factors using Division approved methods. The method for calculating VOC emissions (and HAP for APEN reporting purposes) for the flare for monitoring of compliance with the annual emissions limits has been revised to comport with this condition. This new method uses actual process data from flare streams to verify VOC content and calculate emissions based on a mass balance approach. VOC emissions will now be calculated using the molar fractions of VOC constituents determined from periodic analyses of the gas stream routed to the flare, the recorded volume of gases consumed in the flare, and a conversion factor of 379.3 scf/lb-mol (based on standard ambient conditions of 60°F and 14.7 psi). Periodic sampling has been required for determination of heat content for calculations of NOx and CO emissions, as well as VOC content for calculation of emissions using a mass balance approach. The frequency for the sampling of gas streams routed to the flare has been revised from semi-annually to quarterly, since analyses for these gases received by the Division have demonstrated significant variation in VOC and heat content, and emissions vented to this flare can come from a wide variety of sources. No specific requirement to develop emission factors based on the gas analyses has been included in the operating permit, but the source must use data from the most recent gas analysis to calculate VOC and HAP emissions. 2. Emission Factors NOx and CO emissions limits for the Platte Valley flare were based on emission factors from the Texas Commission on Environmental quality, for flares with high Btu content. Emission limits for NOx and CO are now based on emission factors from AP-42, Section 13.5 for industrial flares, as requested in the application received on August 27, 2018. VOC emission limits in 02W E0927 (modification 1 , issued 12/2/2013) were based on an AP-42, Section 13.5 emission factor for total hydrocarbons (THC), with an assumed 10% VOC content for the flare gas. This VOC factor represented controlled emissions. No estimate of uncontrolled VOC emissions had previously been performed for this flare. With this issuance of the operating permit, actual VOC emissions from the flare will be calculated using a mass balance approach, based on quarterly analyses of the gas streams routed to the flare and monthly 123/0057 Page 36 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit recorded flare gas throughput. This method will result in a revised VOC emission rate each quarter, based on the most recent analysis of the VOC content of the flare inlet streams. 3. Monitoring Plan Monitoring has been included in the operating permit to yield data sufficient to calculate VOC emissions based on a mass balance approach. Process and purge gas volumes routed through the flare are monitored continuously and recorded monthly. Site specific extended gas analyses are required to be conducted quarterly to determine the molar fractions of VOC constituents for calculation of emissions using the recorded monthly throughput. The heat content of the streams routed to the flare are required to be determined quarterly for calculation of NOx and CO emissions using the given emission factors and the flare throughput. Monitoring of flare operation includes daily requirements for visual emissions observations and monthly determination of the maximum exit velocity of the flare for comparison to the standard, continuous monitoring of the flare pilot light using a thermocouple or equivalent device to ensure a flame is present at all times that emissions are routed to the flare, and quarterly heat content analyses for comparison to the minimum required for proper combustion. 4. Compliance Status The Division completed a full compliance evaluation at the facility on August 31 , 2016. According to the inspection report, flare S021 was in compliance with Construction Permit 02WE0927 and applicable air pollution control regulations. E. NG-TL-01: One (1) Loadout of pressurized natural gasoline liquids to atmospheric tank truck, controlled by an enclosed flare (AIRS point 073) This natural gasoline loadout is an existing source that was discovered by Kerr- McGee during a self-audit to be subject to APEN reporting and construction permitting requirements and reported to the Division through the voluntary self-disclosure process. Kerr-McGee did not identify when this loadout operation began, but construction and operation of this loadout likely occurred with the initial construction of the plant in 1993 by North American Resources Company. 1. Applicable Requirements: Colorado Construction Permit 17WE0053 was issued for the natural gas liquids loading rack as an initial approval permit on December 11, 2017. A Final Approval to Operate letter was issued for this source on June 19, 2018. The appropriate applicable requirements of Construction Permit 17WE0053 have been incorporated as follows: • (Condition 1) You must notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. (Regulation Number 3, Part B, Section III.G.1) 123/0057 Page 37 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit A Notice of Startup for this source was received by the Division on December 20, 2017. This condition has not been included in the operating permit. • (Condition 2) Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. (Regulation Number 3, Part B, Section III.G.2) Compliance with the conditions in the initial approval construction permit have been demonstrated and a Final Approval to Operate letter was issued on June 19, 2018. This condition has not been included in the operating permit. • (Condition 3) This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) This condition is not applicable since this emission source has already been constructed, is currently in operation and no physical modification to the source has been approved with the issuance of this construction permit. This condition has not been included in the operating permit. • (Condition 4) The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) The initial compliance testing and sampling required in the initial issuance of this permit has been completed. The self-certification process has been completed and the final approval to operate letter has been issued. This condition has not been included in the operating permit. • (Condition 5) The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. A final approval to operate letter has been issued for this source. This condition has not been included in the operating permit. • (Condition 6) Emissions of air pollutants shall not exceed the following limitations. The owner or operator shall calculate monthly emissions based on the calendar month. During the first twelve (12) months after issuance of this permit, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months after permit issuance, compliance with only the annual limitation is required. Compliance with the annual limits, 123/0057 Page 38 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. (Reference: Regulation No. 3, Part B, Section II.A.4) o NOx — 5.6 tons per year and 947 pounds per month o CO — 7.4 tons per year and 1,263 pounds per month o VOC — 5.9 tons per year and 1,007 pounds per month The annual emission limitations (calculated on a rolling 12-month total), associated compliance monitoring, and recordkeeping requirements have been included in the operating permit. The monthly emission limitations have not been included in the operating permit since these were only applicable for the first 12 months after issuance of Construction Permit 17WE0057. • (Condition 7) The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) o NG-TL-01 (AIRS point 073): Enclosed flare for control of VOC and HAP The requirement to operate and maintain the natural gasoline liquids loadout with an enclosed flare has been included in the operating permit. • (Condition 8) This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. The owner or operator shall calculate monthly process rates based on the calendar month. During the first twelve (12) months after issuance of this permit, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months after permit issuance, compliance with only the annual limitation is required. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. (Reference: Regulation 3, Part B, II.A.4) o Natural gasoline liquids loaded —456,250 barrels per year and 38,750 barrels per month The annual process limitation (calculated on a rolling 12-month total), associated compliance monitoring, and recordkeeping requirements has been included in the operating permit. The monthly process limitation has not been included in the operating permit since this was only applicable for the first 12 months after issuance of Construction Permit 17WE0057. 123/0057 Page 39 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit • (Condition 9) Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation No. 1 , Section II.A.1 . & 4.) The enclosed combustion device for the loadout is not subject to Part D, Section I.C.1.d (previous Section XII) of Regulation No. 7, which is applicable to atmospheric condensate tank and compressor control requirements. Section XVII.B.1 .c does not exist. The applicable visible emissions requirements of Colorado Regulation No. 1 have been included in the operating permit. • (Condition 12) This source is an existing source located in an ozone non- attainment or attainment-maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 7,II.C.1 .a. RACT for this source shall be utilizing submerged fill during loadout of natural gasoline to truck tanks and routing emissions from the natural gasoline loadout to an enclosed flare. (Reference: Regulation 7, 11.0.1.a(i)) The requirements to utilize submerged fill loading and route emissions from the loadout to an enclosed combustion device have been included in the operating permit. • (Condition 13) The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): o Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. o All compartment hatches at the facility (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. This condition has not been included in the operating permit, per source's comments on the pre-public comment draft, since the NGL tanks are pressurized tanks and do not have thief hatches. o The owner or operator shall inspect onsite loading equipment during loading operations to monitor compliance with above conditions. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. The operating procedures to minimize leakage of VOCs to the atmosphere have been included in the operating permit. • (Condition 14) All natural gasoline liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of 123/0057 Page 40 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit volatile organic compounds to the atmosphere to the maximum extent practicable. The requirement design, operate, and maintain the loadout so as to minimize leakage of VOCs to the atmosphere has been included in the operating permit. • (Condition 15) Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) Operation and maintenance requirements, parameter monitoring, and recordkeeping requirements have been directly incorporated into the operating permit in order to monitor compliance with emission limitations and other requirements for this source. The requirement to follow the O&M plan has not been included in the operating permit. • (Condition 16) The owner or operator of a loadout that is controlled shall: o Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. o Include devices to prevent the release of vapor from vapor recovery hoses not in use. o Use operating procedures to ensure that natural gasoline liquid cannot be transferred unless the vapor collection equipment is in use. o Operate all recovery and disposal equipment at a back pressure less than the pressure relief valve setting of transport vehicles. o Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs shall be set to release at a pressure that will ensure flashing, working and breathing losses are routed to the control device under normal operating conditions. This provision has been revised to remove the reference to working and breathing losses and replace it with a reference to loading losses, to more accurately characterize the emissions from this source. • Document annual inspections of PRD with an indication of status, a description of any problems found, and their resolution. The above operational requirements for the enclosed combustion device have been included in the operating permit. Any modifications have been indicated above. • (Condition 17) A source initial compliance test shall be conducted on this emissions point to measure the emission rate(s) for the pollutants listed below 123/0057 Page 41 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit in order to demonstrate compliance with the emissions limits specified in this permit. The natural gasoline liquids throughput and pressure of the natural gasoline storage tank shall be measured and recorded during this test. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time (Reference: Common Provisions Section II.C and Regulation No. 3, Part B., Section III.G.3) o Oxides of Nitrogen using EPA approved methods; Volatile Organic Compounds using EPA Reference Method 18 and 25A; and Carbon Monoxide using EPA approved methods. An initial compliance test was conducted for this unit on April 18-19, 2018, which demonstrated compliance with the emission limits. This condition has not been included in the operating permit. • (Condition 18) A revised Air Pollutant Emission Notice (APEN) shall be filed according to the requirements of Regulation No. 3, Part A, Section II.C The APEN reporting requirements are included in Section IV (General Conditions), Condition 22.e of the operating permit. 2. Emission Factors: VOC emissions for the tank truck loadout of pressurized natural gasoline liquids were developed using Bryan Research and Engineering's ProMax simulation model, based on a sample analysis of natural gasoline liquids (sampled on December 23, 2015). NOx and CO emissions were estimated based on the maximum design heat input to the enclosed combustion device (ECD), the design rate of supplemental and pilot gas fuel supplied to the ECD, and lb/MMBtu emission factors provided by the ECD manufacturer. Emission factors provided in the construction permit are in units of lb/barrel of natural gasoline liquids loaded, however actual emissions calculations for purposes of monitoring compliance with emission limits are required to be calculated using the ProMax model and the results of ongoing parameter monitoring to account for actual operating conditions over time. 3. Monitoring Plan: Actual VOC emissions will be calculated monthly using the ProMax simulation model and inputs based on periodic parameter monitoring, including: monthly natural gasoline liquids throughput, semi-annual natural gasoline liquids composition and physical properties analyses, and monthly bulk temperature and pressure of natural gasoline liquids loaded. The energy (Btu) content of flashing and loading loss streams sent to the flare will be determined from the outputs of 123/0057 Page 42 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit the ProMax model runs. Monitoring for proper operation of the enclosed combustion device (ECD) includes daily visible emissions observations and verification that the pilot light is operating for each loadout event, since the ECD only operates when liquids are being loaded. 4. Compliance Status: Kerr-McGee submitted information for self-certification of compliance with the permit terms of the initial issuance of Construction Permit 17WE0053. A final approval to operate letter was issued on June 19, 2018. The Division completed a full compliance evaluation at the facility on July 12, 2018. According to the inspection report, natural gasoline liquids loadout NG-TL-01 was in compliance with Construction Permit 17WE0053 and applicable air pollution control regulations. VI. 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). • Revised the Responsible Official and Facility Contact information to reflect the most recent information received by the Division. • Inserted language concerning postmarked dates for report submittals to reflect the Division's current standard language. Section I — General Activities and Summary • Updates to general activities and source summary are included in the Fort Lupton TRD. Section III — Specific Permit Terms 123/0057 Page 43 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit • Section III, Condition 1 (former Condition 1 of 99OPWE207) for compressor engines S001 - S004 (AIRS points 038-041) o Revisions were made in the summary table for units S001-S004 to coincide with the modifications detailed in the items below. o The emission limits for units S001-S004 were divided into two separate conditions (Conditions 1 .1 and 1 .2) since the current portable monitoring language for operating permits has provisions in the emission limitations section for NOx and CO that are not applicable to VOC. The language specifying emission calculation methods has been revised to the current standard language. Emission factors for CO and VOC, originally from the January 1995 version of AP-42 Chapter 3, have been updated to the current emission factors found in the July 2000 version. o The reference to ASTM method D1945 for determining the Btu content of the natural gas (Condition 1 .4) has been revised to specify that an appropriate ASTM method be used. o Condition 1 .6 (former Condition 1.4): The 30% opacity standard of Colorado Regulation No. 1, Section II.A.4, applicable during certain operational activities, has been added to the operating permit since this is a standard opacity requirement in permits for sources with the potential for opacity emissions. o Condition 1 .8: The applicable requirements of Colorado Regulation No. 7, Part E, Section II.A.6 for combustion process adjustments were added to the operating permit. These requirements became effective on January 14, 2017. • Section III, Condition 2 (former Condition 2 of 99OPWE207) for fugitive equipment leaks, S007 (AIRS point 042) o The gas analysis requirements have been revised to specify that semi- annual analyses of all gas and liquid streams used to develop permit emissions must be performed. o The provisions of Colorado Reg. 7, Part D, Section I.G have been included in the operating permit. These provisions require the application of the LDAR program of NSPS OOOO for natural gas processing plants located in the 8-hour Ozone Control Area, beginning January 1, 2019, unless subject to the LDAR program provided at 40 CFR 60, Subpart OOOOa. The general provision of Part D, Section I.C.1 .b has also been included. o The provisions of NSPS 0000a were included in the operating permit according to the applicability of Reg. 7, Part D, Section I.G, and the response to an information request received on October 18, 2019. o The provisions of 40 CFR Part 63 Subpart HH were included in the operating permit. The source has not specifically determined that VHAP 123/0057 Page 44 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit concentration can be reasonably expected never to exceed 10.0 percent by weight, per 63.772(a)(1), and recent submittals have indicated streams containing VHAP concentration above 10% by weight. • Section III, Condition 4 (former Condition 6 of 99OPWE207) for compressor engine S012 (AIRS ID 044) o Revisions were made in the summary table for unit 5012 to coincide with the modifications detailed in the items below. o The emission limits for units S012 were divided into two separate conditions (Conditions 4.1 and 4.2) since the current portable monitoring language for operating permits has provisions in the emission limitations section for NOx and CO that are not applicable to VOC. The language specifying emission calculation methods has been revised to the current standard language. Emission factors for CO and VOC, originally from the January 1995 version of AP-42 Chapter 3, have been updated to the current emission factors found in the July 2000 version. o Condition 4.4 (former Condition 6.5): The reference to ASTM method D1945 for determining the Btu content of the natural gas has been revised to specify that an appropriate ASTM method be used. o Condition 4.6 (former Condition 6.4): The 30% opacity standard of Colorado Regulation No. 1, Section II.A.4, applicable during certain operational activities, has been added to the operating permit since this is a standard opacity requirement in permits for sources with the potential for opacity emissions. o Condition 4.8: The applicable requirements of Colorado Regulation No. 7, Part E, Section II.A.6 for combustion process adjustments were added to the operating permit. These requirements became effective on January 14, 2017. • Section III, Condition 5 (former Condition 7 of 99OPWE207) for the Perry Gas Processors, Inc. amine unit heater S013 (AIRS point 045) o The manufacturer of this heater was changed from Born, Inc. to Perry Gas Processors, Inc. per a response from an information request received by Kerr-McGee on May 3, 2017. The discrepancy between the manufacturer of the unit located at the facility and the manufacturer listed in the original operating and construction permits is unclear. o Revisions were made in the summary table for unit S013 to coincide with the modifications detailed in the items below. o NOx and CO emission factors were changed to Ib/MMBtu values (by dividing by 1020 Btu/scf per AP-42, Table 1.4-1 , footnote a) and Btu content monitoring was added for emissions calculation purposes, according to the Division's standard Title V monitoring for process heaters. 123/0057 Page 45 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit o Condition 5.5 (former Condition 7.4): The 30% opacity standard of Colorado Regulation No. 1, Section II.A.4, applicable during certain operational activities, has been added to the operating permit since this is a standard opacity requirement in permits for sources with the potential for opacity emissions. The Colorado Regulation No. 6, Part B, Section II.C.3 state-only 20% opacity limit for particulate matter from new fuel burning equipment of was also added since this is an applicable requirement. o Condition 5.6: The Colorado Regulation No. 1 , Section III.A.1 .b PM standard for fuel burning equipment was added to the operating permit since this is an applicable requirement. Compliance will be presumed, absent credible evidence to the contrary, since only natural gas is permitted to be used as fuel in the heater. o Condition 5.7: A statement of applicability to 40 CFR 63 Subpart DDDDD was added to the operating permit. MACT DDDDD requirements are included in a common reference in Section IV, Condition 8. o Condition 5.8: A statement of applicability to 40 CFR 63 Subpart A, General Provisions, was added to the operating permit. 40 CFR Part 63 General Provisions requirements are included in a common reference in Section IV, Condition 11 . o Condition 5.11: The applicable requirements of Colorado Regulation No. 7, Part E, Section II.A.6 for combustion process adjustments were added to the operating permit. These requirements became effective on January 14, 2017. o Condition 5.12 (former Condition 7.5): This condition was revised to be the same as the standard operating and maintenance condition that was included in the original Fort Lupton permit, which allows for internal operating and maintenance standards based on manufacturer's recommendations and good air pollution control practices. • Section III, Condition 6 (former Condition 9 of 99OPWE207) for compressor engines S015-S017 (AIRS points 047-049) o Revisions were made in the summary table for units S015-S017 to coincide with the modifications detailed in the items below. o The emission limits for these units were divided into two separate conditions (Conditions 6.1 and 6.2) since the current portable monitoring language for operating permits has provisions in the emission limitations section for NOx and CO that are not applicable to VOC. The language specifying emission calculation methods has been revised to the current standard language. Emission factors for CO and VOC, originally from the January 1995 version of AP-42 Chapter 3, have been updated to the current emission factors found in the July 2000 version. 123/0057 Page 46 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit o Condition 6.4 (former Condition 9.5): The reference to ASTM method D1945 for determining the Btu content of the natural gas has been revised to specify that an appropriate ASTM method be used. o Condition 6.6 (former Condition 9.4): The 30% opacity standard of Colorado Regulation No. 1, Section II.A.4, applicable during certain operational activities, has been added to the operating permit since this is a standard opacity requirement in permits for sources with the potential for opacity emissions. o Condition 6.8: The applicable requirements of Colorado Regulation No. 7, Part E, Section II.A.6 for combustion process adjustments were added to the operating permit. These requirements became effective on January 14, 2017. • Section III, Condition 7 (former Condition 10 of 99OPWE207) for compressor engines 5018-S019 (AIRS points 050-051) These engines were both permanently replaced using an Alternative Operating Scenario; S018 in December of 2008 and S019 in January of 2009. o Revisions were made in the summary table for units S018-S019 to coincide with the modifications detailed in the items below. o The emission limits for these units were divided into two separate conditions (Conditions 7.1 and 7.2) since the current portable monitoring language for operating permits has provisions in the emission limitations section for NOx and CO that are not applicable to VOC. The language specifying emission calculation methods has been revised to the current standard language. The emission factors and limits for CO and VOC have been revised to reflect the addition of oxidation catalyst controls for these engines. o Condition 7.4 (former Condition 10.5): The reference to ASTM method D1945 for determining the Btu content of the natural gas has been revised to specify that an appropriate ASTM method be used. o Condition 7.6 (former Condition 10.4): The 30% opacity standard of Colorado Regulation No. 1, Section II.A.4, applicable during certain operational activities, has been added to the operating permit since this is a standard opacity requirement in permits for sources with the potential for opacity emissions. o Condition 7.7 was added to the operating permit to incorporate the applicable requirements of Colorado Regulation No. 7, Part E, Section I (previous Section XVI). Sections I.A and I.B require catalyst controls for engines greater than 500 horsepower operating in the 8-hour Ozone Control Area. Section II.A.6 contains combustion process adjustment requirements that became effective on January 14, 2017. 123/0057 Page 47 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit o Provisions were added for oxidation catalyst parameter monitoring since these engines are now permitted with controls. o Added the applicable requirements of 40 CFR Part 60 Subpart ZZZZ and Subpart A, since both AOS replacement engines are subject to this rule. • Former Condition 8 of 99OPWE207 for the Born hot oil heater S014 (AIRS point 046) has been moved to Section III, Condition 12, since the provisions for this heater will be removed when the replacement heater is incorporated into the operating permit. Construction Permit 15WE1394 was issued on March 23, 2017 for a 30.0 MMBtu/hr heater that will replace 5014. The construction of this heater has been delayed by Kerr-McGee and an extension to the expiration of Construction Permit 15WE1394 has been issued by the Division. Kerr- McGee now has until March 23, 2020 to begin construction of the replacement heater. Section IV — Provisions Common to Multiple Units This Section was added to consolidate provisions that are common to multiple emission units. Section V — Permit Shield • Updated the Regulation No. 3 citation for the permit shield. • Removed the permit shield citation for the amine unit S009 exemption from construction permitting requirements. This unit was issued a construction permit with criteria pollutant emission limits on June 10, 2013. • Removed the permit shield citation for the facility-wide exemption from Prevention of Significant Deterioration (PSD) requirements. This source is now considered a major stationary source for PSD for CO, and a major stationary source for Non-Attainment New Source Review (NANSR) for NOx and VOC. Section IV — General Permit Conditions • Updated the general permit conditions to the current version (5/22/2012) Appendices • Updated Appendices B and C (Monitoring and Permit Deviation Reports and Compliance Certification Reports) to the newest versions (2/20/2007). • EPA's mailing address was revised (Appendix D). • Cleared the list of modifications from Appendix F related to the previous issuance. • Added appendices for CAM requirements for subject units and to include the Engine AOS Applicability Reports. 123/0057 Page 48 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit VII. Streamlining of Applicable Requirements Oxidation Catalyst Control Requirements — Reg. 7, Part E, Section I.D.3.b Engines 5018 and 5019: Colorado Regulation No. 7, Part E, Section I.D.3.b contains a requirement to install an oxidation catalyst for lean burn reciprocating internal combustion engines with a manufacturer's design rate greater than 500 horsepower. This requirement is a state-wide, state-only enforceable requirement that applies to engines constructed or modified before February 1 , 2009. Regulation No. 7, Part E, Sections I.A and I.B require the installation of oxidation catalysts for all lean burn engines with a manufacturer's design rate greater than 500 horsepower located in the 8-hour Ozone Control Area. This requirement is both state and federally enforceable and applies to all engines in the ozone control area (both new and existing). For engines that are subject to both requirements, the Division considers that the Section I.D.3.b requirement can be streamlined for the Section I.A and I.B requirement since these provisions contain the same substantial requirements and the Section I.A and I.B requirement is both state and federally enforceable. PM for Fuel Burning Equipment — Reg. 6, Part B, Section II.C.2 S013, S014, S020: Colorado Regulation No. 1 (Section III.A.1 .b) and Regulation No. 6 (Part B, Section II.C.2) contain the same particulate matter emission requirements for fuel burning equipment: emissions of particulate matter shall not exceed 0.5(FI)-°.26 where Fl = fuel input in MMBtu/hr. The Regulation No. 6, Part B requirement is a state-only requirement. Regulation No. 6, Part B, Section I.A, adopts, by reference, the 40 CFR Part 60 Subpart A general provisions. According to 40 CFR §60.8(c) in the general provisions, emissions in excess of the emission limit shall not be considered a violation during periods of startup, shutdown, and malfunction, unless otherwise specified in the applicable standard. Therefore, the Division considers that the Regulation No. 6, Part B particulate matter requirements do not apply during periods of startup, shutdown, and malfunction. The Regulation No. 1 requirements are therefore more stringent than the Regulation No. 6 requirements, and the Regulation No. 6 requirements have been streamlined out of the permit. SO2 for combustion turbines — Req.6, Part B, Section II.D.3.a S020: Colorado Regulation No. 1 (Section VI.B.4.c.(i)) and Regulation No. 6 (Part B, Section II.D.3.a) contain the same SO2 requirements for combustion turbines: emissions of SO2 shall not exceed 0.8 lb/MMBtu. As described for the Reg. 11 Reg. 6 PM standards above, the Division considers the Reg. 1 standard to be more stringent, since the Reg. 6 standards do not apply during periods of startup, shutdown, and malfunction. Therefore, the Reg. 6 standard has been streamlined out of the permit. Recordkeeping Requirements less than five years The following recordkeeping requirements have record retention periods that are less than required for sources subject to operating permit requirements and therefore have been streamlined out of the operating permit for the Section III, Condition 22.b recordkeeping provisions which require records of all monitoring data and support information to be retained for a period of at least five years: 123/0057 Page 49 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit 40 CFR 60 Subpart Dc, §60.48c(i): All records required under this section shall be maintained by the owner or operator of the affected facility for a period of two years following the date of such record. (Only the requirement that records be maintained for two years) 40 CFR 60 Subpart OOOOa, §60.5421a(b)(2): When each leak is detected ... information must be recorded in a log and shall be kept for 2 years in a readily available location...(Only with respect to the requirement that records be kept for 2 years) Colorado Regulation No. 7, Part D, Section III.E.2.c: Records of maintenance of pneumatic controllers shall be maintained for a minimum of three years and readily made available to the Division upon request. Pneumatic Controllers - Reg. 7, Part D, Section III.C.1 and III.C.3 Colorado Regulation No. 7, Part D, Section III.C contains requirements for emission reductions for natural gas-actuated pneumatic controllers. Applicable requirements are determined based on whether the source is located in the 8-hour Ozone Control Area and the date of installation. The provisions of Section III.C.1 are applicable to all continuous bleed controllers in the 8- hour Ozone Control Area located from the wellhead to the natural gas processing plant. These provisions require pneumatic controllers placed in service on or after February 1 , 2009 to emit natural gas emissions in an amount equal to or less than a low bleed pneumatic controller and replacement or retrofitting of high bleed pneumatic controllers in service prior to February 1 , 2009 so that emissions are reduced to an amount equal to or less than a low bleed controller by May 1, 2009. The provisions of Section III.C.2 are applicable to all continuous bleed controllers in the 8- hour Ozone Control Area located at natural gas processing plants. They require pneumatic controllers placed in service on or after January 1, 2018 to have a natural gas bleed rate of zero and replacement or retrofitting of controllers with a bleed rate greater than zero, in service prior to January 1, 2018, so that the pneumatic controller has a natural gas bleed rate of zero by May 1 , 2018. The provisions of Section III.C.3 are applicable statewide to all controllers placed in service on or after May 1 , 2014 and are state-only enforceable. They require the use of no-bleed pneumatic controllers where on-site electrical grid power is being used and the use of a no-bleed controller is technically and economically feasible, or the use of controllers with emissions less than or equal to a low-bleed pneumatic controller if the above conditions are not met. Section III.C.3 also requires all high-bleed controllers in service prior to May 1 , 2014 to be replaced or retrofitted with controllers that have natural gas emissions at or below a low-bleed controller by May 1 , 2015. A high-bleed pneumatic controller is defined in Section III.B as having a continuous bleed rate in excess of six standard cubic feet per hour of natural gas to the atmosphere. A low-bleed controller emits less than or equal to six standard cubic feet per hour. Sections III.C.1 and III.C.3 each have provisions to allow for the continued use of high- bleed pneumatic controllers when they remain in service due to safety and/or process 123/0057 Page 50 of 51 Kerr-McGee— Ft Lupton Gas Processing Complex Operating Permit No. 95OPWE013 Technical Review Document— Renewal Operating Permit concerns. Section III.C.2 has similar provisions for pneumatic controllers at natural gas plants with a bleed rate greater than zero. Pneumatic controllers that remain in service with emissions above the specified standards are subject to specific monitoring requirements in Section III.D and recordkeeping requirements in Section III.E which are associated with the applicable categories of Section III.C. Pneumatic controllers at natural gas processing plants located in the 8-hour Ozone Control Area are technically subject to the requirements in Sections III.C.1 , III.C.2, and III.C.3, as well as the associated monitoring requirements of Section III.D and recordkeeping requirements of Section III.E. Since the requirements of Section III.C.2 for pneumatic controllers at natural gas processing plants located in the 8-hour Ozone Control Area are the most stringent (zero bleed), are essentially redundant with and/or supersede the requirements of Section III.C.1 and III.C.3 (in regard to standards, exceptions, monitoring, and recordkeeping), and are both state and federally enforceable, the requirements of Sections III.C.1 and III.C.3 and the associated monitoring and record keeping have been streamlined out of the operating permit. In addition, the recordkeeping requirement of Section III.E.2.c, requiring maintenance records to be retained for three years, has been streamlined for the general (five year) operating permit recordkeeping requirements in Section III, Condition 22.b. 123/0057 Page 51 of 51 Hello