HomeMy WebLinkAbout20181451.tiffCOLO:RA.D0
Department of Public
Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Steve Moreno
Weld County - Clerk to the Board
1150 0 St
PO Box 758
Greeley, CO 80632
May 1, 2018
Dear Sir or Madam:
RECEIVED
MAY 0 3 2018
WELD COUNTY
COMMISSIONERS
On May 3, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for Nutri-
Turf, LLC. A copy of this public notice and the public comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning -of the public notice period. Please send any comment,regarding this public notice to
the address below_
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
430OCherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
John W. Hiaenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
Bubl►e, IRS► cc: PLCMM tTP) \NL (TT),
05_04 -IS pW (EIVCH/TM]CK)
_O5-03-18
2018-1451
Air Pollution Control Division
Notice Of A Proposed Renewal Title V Operating Permit
Warranting Public Comment
Website Title: Nutri-Turf, LLC. - Nutri-Turf, LLC. - Weld County
Notice Period Begins: May 3, 2018
NOTICE is hereby given that an application to renew an Operating Permit has been submitted to the
Colorado Air Pollution Control Division, 4300 Cherry Creek Drive South, Denver, Colorado 80246-1530, for
the following source of air pollution:
Applicant:. Nutri-Turf, LLC.
43308 Weld County Road #15
Fort Collins, CO 80524
Facility: Nutri-Turf, LLC.
43308 Weld County Road #15
Fort Collins, CO 80524
r
Nutri-Turf, LLC. has applied to renew the Operating Permit for the Nutri-Turf, LLC. in Weld County, CO. The
facility processes brewery wastewater via land application to irrigate various crops for sale. There were no
significant changes to the permit as a result of this renewal. There were no changes to emissions of
regulated pollutants as a result of this renewal. A copy of the application, including supplemental
information, the Division's analysis, and a draft of the Renewal Operating Permit 98OPWE204 have been
filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are
available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices.
The Division has made a preliminary determination of approval of the application. Based on the informatioi
submitted by the applicant, the Division has prepared the draft renewal operating permit for approval-. Andy
interested person may contact Nicholas Dummer of the Division at 303-692-3125 to obtain additional
information. Any interested person may submit written comments to the Division concerning 1) the
sufficiency of the preliminary analysis, 2) whether the permit application should be approved or denied, 3)
the ability of the proposed activity to comply with applicable requirements, 4) the air quality impacts of,
alternatives to, and control technology required on the source or modification, and 5) any other appropriate
air quality considerations. Any interested person may submit a written request to the Division for a public
comment hearing before -the Colorado Air Quality Control Commission (Commission) to receive comments
regarding the concerns listed above as well as the sufficiency of the preliminary analysis and whether the
Division should approve or deny the permit application. If requested, the hearing will be held before the
Commission within 60 days of its receipt of the request for a hearing unless a longer time period is agreed
upon by the Division and the applicant. The hearing request must: 1) identify the individual or group
requesting the hearing, 2) state his or her address and phone number, and 3) state the reason(s) for the
request, the manner in which the person is affected I;y the proceedings, and an explanation of why the
person's interests are not already adequately represented. The Division will receive and consider the
written public comments and requests for any hearing for thirty calendar days after the date of this Notice.
COLOR DO'
Hat4ttr Gnatnsowatt
Colorado Department
of Public Health
and Environment
OPERATING PERMIT
Nutri-Turf, LLC.
First Issued: October 1, 1999
Renewed: DRAFT
AIR POLLUTION CONTROL DIVISION
COLORADO OPERATING PERMIT
FACILITY NAME: Nutri-Turf, LLC. OPERATING PERMIT NUMBER
FACILITY ID: 123/0497
RENEWED: DRAFT
EXPIRATION DATE: DRAFT
MODIFICATIONS: See Appendix F of Permit
98OPWE204
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 LOCATIONS:
Nutri-Turf, LLC. Nutri-Turf, LLC.
43308 Weld County Road #15
Fort Collins, CO 80524
43308 Weld County Road #15
Fort Collins, CO 80524
INFORMATION RELIED UPON
Operating Permit Renewal Applications Received: May 30, 2017
And Additional Information Received: August 5, 2015, February 2, 2017
Nature of Business: Production of Crops for Sale
Primary SIC: 0191 (Auxiliary of Anheuser Busch Co., SIC 2082)
RESPONSIBLE OFFICIAL
Name: Eugene Bocis
Title: General Manager
Phone: (970) 490-4500
FACILITY CONTACT PERSON
Name:
Title:
Phone:
Aaron Mortensen
ES Manager
(970) 490-4635
SUBMITTAL DEADLINES -
First Semi -Annual Monitoring Penod October 1, 2010'- December 3 2010
Sem
i
-Semi Annual MonitoringPeriods Janu 1- June`.30,.1, December q �' July 311 . ,
Monitoring Reports: Due February 1 2011 & August 1, 2011 &subsequent years
Subsequent Annual Compliance Periods: January 1 = December 31
Annual Compliance'Certification. Due February 1,.'2011 & 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 - Generall Activities and Summary
1. Permitted Activities
2. Alternative Operating Scenarios (AOS)
3. Non -Attainment New Source Review (NANSR) and Prevention of Significant Deterioration
(PSD)
4. Accidental Release Prevention Program (112(r))
5. Compliance Assurance Monitoring (CAM)
6. Summary of Emission Units
SECTION II - Specific Permit Terms
1. P201 — AREA 20 — Land Application of Wastewater
2. 40 CFR Part 63, Subpart CCCCCC —National Emission Standards for Hazardous Air. Pollutants
for Source Category: Gasoline Dispensing Facilities
1
1
1
2
2
2
3
4
4
7
SECTION III - Permit Shield 9
1. Specific Non -Applicable Requirements 9
2. General Conditions 9
3. Stream -lined -Conditions 10
SECTION IV - General Permit Conditions (ver 5/22/2012) )L1
A. Appendix A - Inspection Information 24
A.I. Directions to Plant: 24
A.II. Safety Equipment Required: 34
A.III. Facility Plot Plan: 24
A.N. List of Insignificant Activities. 24
B. Appendix B — Reporting Requirements and Definitions 27
B.I. Appendix B — Monitoring and Permit Deviation Report - Part I 31
B.II. Appendix B — Monitoring and Permit Deviation Report -. Part II 32
B.III. Appendix B — Monitoring and Permit Deviation Report - Part III 34
C. Appendix C — Required Format for Annual Compliance Certification Reports 35
D. Appendix D — Notification Addresses 37
D.I. Air Pollution!Control Division 37
D.II. United States Environmental Protection Agency 37
E. Appendix E — Permit Acronyms 38
F. Appendix F — Permit Modifications
40
Air Pollution Control Division
Colorado Operating Permit
Permit 98OPWE204
1. Permitted Activities
1.1
Nutri-Turf, LLC.
Page 1
SECTION I - General Activities and Summary
The Nutri-Turf, LLC. (herein, Source) facility is an auxiliary operation of the Anhueser-Busch
Companies, LLC., Fort Collins Brewery (operates under Operating Permit 95OPLR064). A portion of
the brewery wastewater is piped to the. Source for land application. The land is irrigated with'wastewater
via center pivots; soil bacteria break down soluble organics in the wastewater into usable nutrients for
planted vegetation to grow. The Source grows and sells a variety of crops, including brome grass,
alfalfa, other grasses, wheat; and corn.
The facility is located at 43308 Weld County Road #15, Fort Collins, Colorado, Weld County. This
facility is located in an area classified as attainment for all pollutants except ozone. It is classified as
non -attainment for the 8 -hr ozone standard and is part of the 8 -hr Ozone Control Area as defined in
Regulation No. 7, Section II.A.1 .
7
Wyoming is an affected state within 50 miles of the plant. There are two Federal Class I designated
areas within 100 kilometers of the facility: Rocky Mountain National Park and Rawah Wilderness area.
1.2 Until such time as this permit expires or is modified or revoked, the Source is allowed to discharge air
pollutants from this facility in accordance with the requirements, limitations, and conditions of this
permit. '.
1.3 The Operating Permit incorporates the applicable requirements contained in the underlying construction
permits, and does not affect those applicable requirements, except as modified during review of the
application or as modified subsequent to permit issuance using the modification procedures found in
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: N/A — the applicable requirements are incorporated directly into this Operating
Permit through a combined Colorado Construction Permit/Operating Permit procedure.
1.4 All conditions in this permit are enforceable by the United States Environmental Protection Agency
(EPA), Colorado Air Pollution Control Division (hereinafter Division) and its agents, and citizens unless
otherwise specified. State -only enforceable conditions are: Permit Condition Number(s): Section IV,
Conditions 3.g _(last paragraph), 14 & 18.
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 (AOS)
2.1 There are no AOS associated with permitted activities at the facility.
Operating Permit 98OPWE204 First Issued: October 1, 1999
Renewed: DRAFT
Air. Pollution Control Division
Colorado Operating Permit
Permit 98OPWE204
Nutri-Turf, LLC.
Page 2
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 (PTE) of volatile
organic compounds (VOC) or oxides of nitrogen (NOx) is greater than (>) 100 tons per year (tpy)).
Future modifications at this facility resulting in a significant net emissions increase (see Colorado
Regulation No. 3, Part D, Sections II.A.27 and 44) for VOC or NOx or a modification which is major by
itself (PTE > 100 tpy of either VOC or NON) may result in the application of the NANSR review
requirements.
3.2 This facility is categorized as a PSD major stationary source (PTE > 250 tpy). for NOx and SO2. Future,
modifications at this facility resulting in a significant net emissions increase (see Colorado Regulation
No. 3, Part D, Sections II.A.27 and 44) or a modification which is major by itself (PTE > 250 tpy) for
any pollutant listed in Colorado 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 Anhueser-Busch Companies, LLC., Fort Collins Brewery, operating under Operating Permit
95OPLR064, is associated with this facility for the purposes,of determining applicability of PSD
regulations.
4. Accidental Release Prevention Program (112(r))
4.1 Based on the information provided by the Source, this facility is not subject to the provisions of the
Accidental Release Prevention Program in Section 112(r) of the Federal Clean Air Act (CAA).
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: NiA — there is no add-on control equipment at the facility.
•
Operating Permit 98OPWE204 First Issued: October 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit 98OPWE204
6. Summary of Emission Units
6.1 The emissions units regulated by this permit are the following:
Nutri-Turf, LLC.
Page 3
Emission Unit
AIRS
Facility
Description
Pollution Control
ID
Stack ID
Land Application
001
P201
Land application of wastewater
Microbial and
vegetative destruction
Table 1 — Nutri-Turf Emission Unit Summary
Operating Permit 98OPWE204 First Issued: October 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit 98OPWE204
Nutri-Turf, LLC.
Page
4
1. P201 - AREA
20 — Land
SECTION II - Specific Permit Terms
Application of Wastewater
Permit
Monitoring
Parameter
Condition
Limitation
Compliance Emission'
p
Number
Factor
Method
Interval
Land Application
Wastewater Volume
1.1
1,625 x 106 gallons / year
Recordkeeping
Monthly
Recordkeeping
Monthly
VOC Emissions
1.2
236.0 tons / year
4.5% Evaporation Rate
Water Sampling
Every 8 Days
Calculation
Annually
VOC Sampling and
Testing
1 3
Sampling and Testing
Every 8 Days
Recordkeeping
Ongoing
BACT
1.4
Distillation and Land
See Condition 1.4
Application
RACT
1.5
Distillation and Land
See Condition 1.5
Application
Table 2 — P201 Emissions and Requirements Summary
The following applicable
requirements
are incorporated directly into this Operating
Permit through a combined
Colorado Construction
Permit/Operating
Permit procedure, in accordance with
Section I, Condition 1.3.
1.1 Land application
of wastewater
must not exceed 1,625 x 106 gallons
per year.
1.1.1 Calibrated
flow
meters shall be used to measure the daily volume
of wastewater applied to the
land
at the facility.
As a backup system, the Source shall track
the daily volume of wastewater
volume
leaving
the brewery to the Source. The Source must
keep records of the daily flow
volumes
and use
them to calculate monthly total volumes.
Compliance
with
the annual land application volume shall
be determined on a rolling twelve-
month
total. By
the end of each month, a new twelve-month
total shall be calculated using the
previous
twelve
-months' data.
1.1.2 The
flow meters
required in this condition must be calibrated
at least once per calendar year.
Annual
calibrations
must occur at least 90 days apart.
1.1.3 Records
of daily
wastewater volumes, monthly calculations,
and annual flow meter calibrations
shall
be maintained
and made available for Division inspection
upon request.
1.2 VOC emissions
must not
exceed 236.0 tons per year.
1.2.1 Compliancewith
the annual limitation shall be determined
on a rolling twelve-month total. By
the
end of each
month, a new twelve-month total shall be calculated
using the previous twelv
-
months'
data.
VOC emissions shall be calculated on monthly
basis, as follows:
Operating Permit 98OPWE204
First Issued: October 1, 199
Renewed: 'DRAFT
I
1.3.2
Air Pollution Control Division
Colorado Operating Permit
Permit 98OPWE204
Nutri-Turf, LLC.
Page 5
lb lb gal lb emitted
Emissions [—I-
-ayVOC Concentration [gal] * Throughput [dal * 0.045 Llb applied
Daily emissions as calculated in the equation above will be aggregated to calculate total
monthly emissions.
1.2.2 For the purposes of emission calculations, as shown in the final term in the equation above, the
Source shall calculate emissions assuming that 4.5% by weight of VOC applied to the landfarm
is emitted into the atmosphere.
1.2.3 The throughput shall be monitored as described in Condition 1.1.
1.2.4 The VOC concentration shall be monitored as described in Condition 1.3. Note that the results
of the VOC concentration testing shall be used as representative of all daily VOC
concentrations for use in the above calculation until the subsequent sampling and testing event
at which time the new VOC concentration as determined by the sampling and testing in
Condition 1.3 will be used.
1.2.5 Records of daily and; monthly calculations shall be maintained and made available for Division
inspection upon request.
1.3 VOC concentration for use in the above equation shall be monitored via sampling and testing as follows:
1.3.1 At least once every eight (8) days, the Source shall conduct sampling of the VOC (ethanol)
content of the wastewater at the outlet of the brewery to determine the VOC concentration in
the wastewater in units of pounds per gallon for use in the calculation in Condition 1.3. In the
event that more than one wastewater sample is collected and analyzed during each eight day
period, the Source will use the highest recorded concentration to calculate emissions, unless
otherwise approved by the Division.
1.3.1.1 The Source must keep a rolling twenty -four -month average of VOC content in the
wastewater. By the end of each month, a new twenty -four -month total shall be
calculated using the previous twenty -four -months' data.
1.3.1.2 The Source must calculate the standard deviation of the VOC content using the
results of each sampling and testing event.
1.3.1.3 In the event that any individual test result exceeds two standard deviations of the
average VOC concentration in the wastewater, the Source shall investigate the cause
of the excursion and make note of the findings in a log.
Records of wastewater sampling, and analyses, average and standard deviation calculations,
standard deviation excursions, sampling and testing protocols, and written Division approval of
the protocols shall be maintained for Division inspection upon request.
1.4 This emission unit is subject to the PSD Best Available Control Technology Requirements for the
control of VOC emissions, as follows:
Operating Permit 98OPWE204 First Issued: October 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit 98OPWE204
Nutri-Turf, LLC.
Page 6
1.4.1 Distillation for recovery of ethanol and microbial vegetative destruction through land
application for the purpose of growing crops represents BACT for treatment of brewery
wastewater. Requirements for distillation are set forth in the Anhueser-Busch Companies,
LLC., Fort Collins Brewery Title V Operating Permit 95OPLR064.
1.4.2 The Source shall operate the equipment so as to minimize misting, including placing nozzles as
low to the ground as possible, and using equipment with appropriate orifice size and splash
plate configuration. Compliance with this condition shall be presumed provided the equipment
is operated and maintained in accordance with manufacturer's recommendations and good
engineering practices.
1.4.3 The areas where wastewater is applied shall be areas which are covered with vegetation at all
times when wastewater is applied, except as required following tilling and seeding for crop
rotation and field work, per standard agricultural practices. The Source must maintain records
when wastewater is applied in areas without vegetation and the reason for the application of the
wastewater in those areas. These records must be made available for Division inspection upon
request.
1.5 This emission unit is subject to Colorado Regulation No. 7, Section V. Disposal of Volatile Organic
Compounds, as follows:
1.5.1 The Source may not dispose of VOCs by evaporation or spillage unless Reasonably Available
Control Technology (RACT) is utilized (Colorado Regulation No. 7, Section V.A.). RACT for
this Source has is the distillation for recovery of ethanol and microbial and vegetative
destruction through land application for the purpose of growing crops for treatment of brewery
wastewater. Requirements for distillation are set forth in the Anhueser-Busch Companies,
LLC., Fort Collins Brewery Title V Operating Permit 95OPLR064.
1.5.2 CompEance with this Condition shall be monitored by following the requirements of Condition
1.4.
Operating Permit 98OP'WE204
First Issued: October 1, 1999
Renewed: DRAF
Air Pollution Control Division
Colorado Operating Permit
Permit 98OPWE204
Nutri-Turf, LLC.
Page 7
2. 40 CFR Part 63, Subpart CCCCCC — National Emission Standards for Hazardous Air Pollutants
for Source Category: Gasoline Dispensing Facilities
The 560 gallon gasoline tank is subject to 40 CFR Part 63, Subpart CCCCCC — National Emission
Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities. The
requirements of this Subpart pertain to establishing standard emission limitations and management
practices for HAP emitting from the loading of gasoline storage tanks at gasoline dispensing facilities
(40 CFR Part 63, §63.11110). Specifically, the facility is subject to the following requirements:
The requirements below reflect the current rule language as of the revisions to 40 CFR Part 63 Subpart
CCCCCC published in the Federal Register on January 24, 2011. However, if revisions to this Subpart
are published at a later date, the Source shall be subject to the requirements contained in- the revised
version of 40 CFR Part 63, Subpart CCCCCC:
These requirements have not been adopted into Colorado Regulation No. 8, Part E as of the date of this
permit issuance, and therefore are not state -enforceable. In the event that these requirements are
adopted into Colorado Regulations, they will become state -enforceable.
2.1 The Source shall, upon request by the Administrator, demonstrate that the monthly throughput is less
than the 10,000 gallon threshold level., As specified in §63.11112(d), recordkeeping to document
monthly throughput must begin on January 10, 2008. Records required under this condition shall be kept
for a period of 5 years (40 CFR Part 63, §63.11111(e)).
22 . Monthly throughput is the total volume of gasoline loaded into, or dispensed from, all the gasoline
storage tanks located at a single affected gasoline dispensing facility (GDF) (40 CFR Part 63,
§63.11111(h)).
2.3
If the Source's total throughput of gasoline exceeds 10,000 gallons per month, the Source shall remain
subject to the requirementsfor sources above the threshold, even if the Source throughput later falls
below the applicable throughput threshold (40 CFR Part 63, §63.11111(i)).
2.4 The emission sources to which this subpart applies. are gasoline storage tanks and associated equipment
components in vapor or liquid gasoline service at new, reconstructed, or existing GDF that meet the
criteria specified in §63.11111. Pressure/Vacuum vents_ on gasoline storage tanks and the equipment
necessary to unload product from cargo tanks into the storage tanks at GDF are covered emission
sources. The equipment used for the refueling of motor vehicles is not covered by Subpart CCCCCC (40
CFR Part 63, §63.11112(a)).
2.5 The Source shall comply with the standards in Subpart CCCCCC no later than January 10, 2011 (40
CFR Part 63, §63.11113(b)).
2.6 The Source shall, at all times, operated and maintain any affected source, including associated air
pollution control equipment and monitoring equipment, in a manner consistent with safety and good air
pollution control practices for minimizing emissions. Determination of whether such operation and
maintenance"procedures are being used willbebased on information available to the Administrator
which may include, but is not limited to, monitoring results, review of operation and maintenance
Operating Permit 98OPWE204 First Issued: October 1, 1999
Renewed: GRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit 98OPWE204
Nutri-Turf, LLC.
Page 8
procedures, review of operation and maintenance records, and inspection of the source (40 CFR Part 63,
§63.11115(a)).
2.7 The Source shall not allow gasoline to be handled in a manner that would result in vapor releases to the
atmosphere for extended periods of time. Measures to be taken,include, but are not limited to, the
following (40 CFR Part 63, §6311116(a)):
2.7.1 Minimize gasoline spills (40 CFR Part 63, §63.11116(a)(1));
2.7.2 Clean up spills as expeditiously as practicable (40 CFR Part 63, §63.11116(a)(2));
2.7.3 Cover all open gasoline containers and all gasoline storage tank fill -pipes with a gasketed seal
when not in'use (40 CFR Part 63, §63.11116(a)(3)); -
2.7.4 Minimize gasoline sent to open waste collection systems that collect and transport gasoline to
reclamation and recycling devices, such as oil/water separators (40 CFR Part 63,
§63.11116(a)(4)).
2.8 The Source is not required to submit notifications or reports as specified in §63.11125, §63.11126, or
Subpart A of 40 CFR Part 63, but shall have records available within 24 hours of a request by the
Administrator to document the gasoline throughput (40 CFR Part 63, §63.11116(b)).
2.9 Portable gasoline containers that meet the requirements of 40 CFR Part 59, Subpart F, are considered
acceptable for compliance with §63.11116(a)(3) (40 CFR Part 63, §63.11116(d)).
2.10 GDF covered under Subpart CCCCCC are subject to 40 CFR Part 63, Subpart A, General Provisions.
These requirements include but are not limited to (40 CFR Part 63, §63.11130):
2.10.1 Prohibited activities and circumvention (§63.4); and
2.10.2 Compliance with operation & maintenance (§63.6(e)).
Operating Permit 98OPWE204 First Issued: October 1, 1999
Renewed: ;DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit 98OPWE204
SECTION III - Permit Shield
Nutri-Turf, LLC.
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
Page 9
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 &
Number
Applicable Requirement .
.
Justification
Facility Wide
40 CFR Part 60, Subpart Kb, Standards of Performance
for VOL Storage Vessels (except for 60.116b(b), as
adopted by reference in Colorado Regulation No. 6, Part
A
Storage vessels with design capacity greater than
40,000 gallons storing a liquid with a true vapor
pressure less than 3.5 kPa (0.5 psi) are exempt from
Subpart Kb, except for recordkeeping requirements
2. General Conditions
Compliance with this Operating Permit shall be deemed compliance with all applicable requirements
specifically identified in the permit and other requirements specifically identified in the permit as not
applicable to the source. This permit shield shall not alter or affect the following:
2.1 The provisions of §§ 25-7-112 and 25-7-113, C.R.S., or § 303 of the federal act, concerning enforcement
in cases of emergency;
2.2 The liability of an owner or operator of a source for any violation of applicable requirements prior to or
at the time of permit issuance;
2.3 The applicable requirements of the federal Acid Rain Program, consistent with § 408(a) of the federal
act;
2.4 The ability of the Air Pollution Control Division to obtain information from a source pursuant to §25-7-
111(2)(I), C.R.S., or the ability of the Administrator to obtain information pursuant to § 114 of the
federal act;
2.5 The ability of the Air Pollution Control Division to reopen the Operating Permit for cause pursuant to
Regulation No. 3, Part C, § XIII.
2.6 Sources are not shielded from terms and conditions that become applicable to the source subsequent to
permit issuance.
Operating Permit 98OPWE204
First Issued: October 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit 98OPWE204
3.— Stream -lined Conditions
Nutri-Turf, LLC.
Page 10
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.
Emission Unit
Description &
Number
Applicable Requirement
-
Justification
N/A
Operating Permit 98OPWE204 First Issued: October 1, 1999
Renewed DRAFj T
Air Pollution Control Division
Colorado Operating Permit
Permit 98OPWE204
SECTION IV - General Permit Conditions (ver 3/3/2018)
1. Administrative Changes
Nutri-Turf, LLC.
Page 11
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® 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., II.B., B.C., II.E., ELF., ILL 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 98OPWE204 First Issued: October 1, 1999
Renewed: !DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit 98OPWE204
Nutri-Turf, LLC.
Page 12
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 theiDivision:
(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
bry 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(ss);
(iii) Safe access to sampling platform(s); and
(iv) Utilities for sampling and testing equipment.
Each performance test shall consist of at least three separate runs using the applicable test method. Each run shall be
conducted for the time and under the conditions specified in the applicable standard. For the purpose of determining
compliance with an applicable standard, the arithmetic mean of results of at least three runs shall apply. In the event
that a sample is accidentally lost or conditions occur in which one of the runs must be discontinued because of forced
shutdown_ failure of an irreplaceable portion of the sample train, extreme meteorological conditions, or other
circumstances beyond the owner or operator's control, compliance may, upon the Division's approval, be determined
using the arithmetic mean of the results of the two other runs.
Nothing in this section shall abrogate the Division's authority to conduct its own performance test(s) if so warranted.
Operating Permit 98OPWE204 First Issued: October 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit 98OPWE204
Nutri-Turf, LLC.
Page 13
• 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;
All reasonably possible steps were taken to minimize the impact of the excess emissions on ambient air
quality;
(v)
(vi) All emissions monitoring systems were kept in operation (if at all possible);
(vii) The owner or operator's actions during the period of excess emissions were documented by properly
signed, contemporaneous operating logs or other relevant evidence;
(viii) The excess emissions were not part of a recurring pattern indicative of inadequate design, operation, or
maintenance;
(ix) At all times, the facility was operated in a manner consistent with good practices for minimizing emissions.
This section is intended solely to be a factor in determining whether an affirmative defense is available to
an owner or operator, and shall not constitute an additional applicable requirement; and
(x) During the period of excess emissions, there were no exceedances of the relevant ambient air quality
standards established in the Commissions' Regulations that could be attributed to the emitting source.
The owner or operator of the facility experiencing excess emissions during a malfunction shall notify the division
verbally as soon as possible, but no later than noon of the Division's next working day, and shall submit written
notification following the initial occurrence of the excess emissions by the end of the source's next reporting period.
The notification shall address the criteria set forth above.
The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief.
The Affirmative Defense Provision does not apply to failures to meet federally promulgated performance standards
or emission limits, including, but not limited to, new source performance standards and national emission standards
for hazardous air pollutants. The affirmative defense provision does not apply to state implementation plan (sip)
limits or permit limits that have been set taking into account potential emissions during malfunctions, including, but
not necessarily limited to, certain limits with 30 -day or longer averaging times, limits that indicate they apply during
malfunctions, and limits that indicate they apply at all times or without exception.
e. Circumvention Clause
Operating Permit 98OPWE204 First Issued: October 1, 1999
Renewed: DRAFT]
Air Pollution Control Division
Colorado Operating Permit
Permit 98OPWE204
Nutri-Turf, LLC.
g.
Page 14
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.
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 r 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.
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 98OPWE204 First Issued: October 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit 98OPWE204
Nutri-Turf, LLC.
Page 15
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.
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 98OPWE204 First Issued: October 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit 98OPWE204
g.
Nutri-Turf, LLC.
Page 16
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,
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 pennittee 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 revisionshall 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 permktee 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 permiee shall pay a permit processing fee in accordance with the provisions of C.R.S. § 25-7-114.7. If the
Division estimates that processing of the permit will take more than 30 hours, it will notify the permittee of its
estimate of what the actual charges may be prior to commencing any work exceeding the 30 hour limit.
Operating Permit 98OP'WE204 First Issued: October 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit 98OPWE204.
Nutri-Turf, LLC,
Page 17
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, § lII.D.1.
The permittee shall employ such control measures and operating procedures as are necessary to minimize fugitive particulate
emissions into the atmosphere, in accordance with the provisions of Regulation No. 1, § III.D.1.
10. Inspection and Entry
Regulation No. 3, 5 CCR 1001-5, Part C, $ V.C.16.b.
Upon presentation of credentials and other documents as may be required by law, the permittee shall allow the Air Pollution
Control Division, or any authorized representative, to perform the following:
a. enter upon the permittee's premises where an Operating Permit source is located, or emissions -related activity is
conducted, or where records must be kept under the terms of the permit;
b. have access to, and copy, at reasonable times, any records that must be kept under the conditions of the permit;
c. inspect at reasonable times any facilities, equipment (including monitoring and air pollution control equipment),
practices, or operations regulated or required under the Operating Permit;
d. sample or monitor at reasonable times, for the purposes of assuring compliance with the Operating Permit or
applicable requirements, any substances or parameters.
11. Minor. Permit Modifications
Regulation No. 3, 5 CCR 1001-5, Part C, §§ X. & XI.
The permittee shall submit an application for a minor permit modification before making the change requested in the
application. The permit shield shall not extend to minor permit modifications.
12. New Source Review
Regulation No. 3, 5 CCR 1001-5, Part B —
The permittee shall not commence construction or modification of a source required to be reviewed under the New Source
Review provisions of Regulation No. 3, Part B, without first receiving a construction permit.
13. No Property Rights Conveyed
Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.11.d.
This permit does not convey any property rights of any sort, or any exclusive privilege.
14. Odor
Regulation No. 2, 5 CCR 1001-4, Part A
As a matter of state law only, the permittee shall comply with the provisions of Regulation No. 2 concerning odorous
emissions.
15. Off -Permit Changes to the Source
Regulation No. 3, 5 CCR 1001-5, Part C, § XII.B.
'Operating Permit 98OPWE204 First Issued: October 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit 98OPWE204
Nutri-Turf, LLC.
Page 18
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., H.
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 1001-17
The permittee shall comply with the provisions of Regulation No. 15 concerning emissions of ozone depleting compounds.
Sections I., II.C., 11.D., M. 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, § E.D.
Portable Source permittees shall notify the Air Pollution Control Division at least 10 days in advance of each change in
location.
21. Prompt Deviation Reporting
Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.7.b.
The permittee shall promptly report any deviation from permit requirements, including those attributable to malfunction
conditions as defined in the permit, the probable cause of such deviations, and any corrective actions or preventive measures
taken.
"Prompt" is defined as follows:
a. Any definition of "prompt" or a specific timeframe for reporting deviations provided in an underlying applicable
requirement as identified in this permit; or
Operating Permit 98OPWE204 First Issued: October 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit 98OPWE204
Nutri-Turf, LLC.
Page 19
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, & H. Part C, V.C.6., V.C.7.
a. Unless otherwise provided in the source specific conditions.of this Operating Permit, the permittee shall maintain
compliance monitoring records that include the following information:
(I) date, place as defined in the Operating Permit, and time of sampling or measurements;
(ii) date(s) on which analyses were performed;
(iii) the company or entity that performed the analysis;
(iv) the analytical techniques or methods used;
(v) the results of such analysis; and
(vi) the operating conditions at the time of sampling or measurement.
b. The permittee shall retain records of all required monitoring data and support information for a period of at least five
(5) years from the date of the monitoring sample, measurement, report or application. Support information, for this
purpose, includes all calibration and maintenance records and all original strip -chart recordings for continuous
monitoring instrumentation, and copies of all reports required by the Operating Permit. With prior approval of the
Air Pollution Control Division, the permittee may maintain any of the above records in a computerized form.
c. Permittees must retain records of all required monitoring data and support information for the most recent twelve
(12) month period, as well as compliance certifications for the past five (5) years on -site at all times. A permittee
shall make available for the Air Pollution Control Division's review all other records of required monitoring data
and support information required to be retained by the permittee upon 48 hours advance notice by the Division.
d. The permittee shall submit to the Air Pollution Control Division all reports of any required monitoring at least every
six (6) months, unless an applicable requirement, the compliance assurance monitoring rule, or the Division requires
Operating Permit 98OPWE204 First Issued: October 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit 98OPWE204
Nutri-Turf, LLC.
Page 20
submission on a more frequent basis. All instances of deviations from any permit requirements must be clearly
identified in such reports.
e. The permittee shall file an Air Pollutant Emissions Notice ("APEN") prior to constructing, modifying, or altering
any facility, process, activity which constitutes a stationary source from which air pollutants are or are to be emitted,
unless such source is exempt from the APEN filing requirements of Regulation No. 3, Part A, § II.D. A revised
APEN shall be filed annually whenever a significant change in emissions, as defined in Regulation No. 3, Part A, §
II.C.2., occurs; whenever there is a change in owner or operator of any facility, process, or activity; whenever new
control equipment is installed; whenever a different type of control equipment replaces an existing type of control
equipment; whenever a permit limitation must be modified; or before the APEN expires. An APEN is valid for a
period of five years. The five-year period recommences when a revised APEN is received by the Air Pollution
Control Division. Revised APENs shall be submitted no later than 30 days before the five-year term expires.
Permittees submitting revised APENs to inform the Division of a change in actual emission rates must do so by
April 30 of the following year. Where a permit revision is required, the revised APEN must be filed along with a
request for permit revision. APENs for changes in control equipment must be submitted before the change occurs.
Annual fees are based on the most recent APEN on file with the Division.
23. Reopenings for Cause
Regulation No. 3, 5 CCR 1001-5, Part C, $ XIII.
a. The Air Pollution Control Division shall reopen, revise, and reissue Operating Permits; permit reopenings and
reissuance shall be processed using the procedures set forth in Regulation No. 3, Part C, § III., except that
proceedings to reopen and reissue permits affect only those parts of the permit for which cause to reopen exists.
b. The Division shall reopen a permit whenever additional applicable requirements become applicable to a major
source with a remaining permit term of three or more years, unless the effective date of the requirements is later than
the date on which the permit expires, or unless a general permit is obtained to address the new requirements;
whenever additional requirements (including excess emissions requirements) become applicable to an affected
source under the acid rain program; whenever the Division determines the permit contains a material mistake or that
inaccurate statements were made in establishing the emissions standards or other terms or conditions of the permit;
or whenever the Division determines that the permit must be revised or revoked to assure compliance with an
applicable requirement.
c. The Division shall provide 30 days' advance notice to the permittee of its intent to reopen the permit, except that a
shorter notice may be provided in the case of an emergency.
d. The permit shield shall extend to those parts of the permit that have been changed pursuant to the reopening and
reissuance procedure.
24. Section 502(b)(10) Changes
Regulation No. 3, 5 CCR 1001-5, Part C, $ )(B.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.
25. Severability Clause
Regulation No. 3, 5. CCR 1001-5, Part C, & V.C.10.
In the event of a challenge to any portion of the permit, all emissions limits, specific and general conditions, monitoring,
record keeping and reporting requirements of the permit, except those being challenged, remain valid and enforceable.
26. Significant Permit Modifications
Operating Permit 98OPWE204 First Issued: October 1,_1999
Renewed: ?DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit 98OPWE204
Nutri-Turf, LLC.
Page 21
Regulation No. 3, 5 CCR 1001-5, Part C,
The permittee shall not make a significant modification required to be reviewed under Regulation No. 3, Part B
("Construction Permit" requirements) without first receiving a construction permit. The permittee shall submit a complete
Operating Permit application or application for an Operating Permit revision for any new or modified source within twelve
months of commencing operation, to the address listed in Item 1 in Appendix D of this permit. If the permittee chooses to use
the "Combined Construction/Operating Permit" application procedures of Regulation No. 3, Part C, then the Operating
Permit must be received prior to commencing construction of the new or modified source.
27. Special Provisions Concerning the Acid Rain Program
Regulation No. 3, 5 CCR 1001-5, Part C, $$ V.C.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.
28. Transfer or Assignment of Ownership
Regulation No. 3, 5 CCR 1001-5, Part C,
No transfer or assignment of ownership of the Operating Permit source will be effective unless the prospective owner or
operator applies to the Air Pollution Control Division on Division -supplied Administrative Permit Amendment forms, for
reissuance of the existing Operating Permit. No administrative permit shall be complete until a written agreement containing
a specific date for transfer of permit, responsibility, coverage, and liability between the permittee and the prospective owner
or operator has been submitted to the Division.
29. Volatile Organic Compounds
Regulation No. 7, 5 CCR 1001-9, && III & V.
a. The requirements in paragraphs a, b and e apply to sources located in an ozone non -attainment area or the Denver 1 -
hour ozone attainment/maintenance area. The requirements in paragraphs c and d apply statewide.
b. 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.
c. Detectable vapor loss shall be determined visually, by touch, by presence of odor, or using a portable hydrocarbon
analyzer. When an analyzer is used, detectable vapor loss means a VOC concentration exceeding 10,000 ppm.
Testing shall be conducted as in Regulation No. 7, Section VBI.C.3.
d. 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.
e. The permittee shall not dispose of volatile organic compounds by evaporation or spillage unless Reasonably
Available Control Technology (RACT) is utilized.
f. No owner or operator of a bulk gasoline terminal, bulk gasoline plant, or gasoline dispensing facility as defined in
Colorado Regulation No. 7, Section VI, shall permit gasoline to be intentionally spilled, discarded in sewers, stored
in open containers, or disposed of in any other manner that would result in evaporation.
Operating Permit 98OPWE204 First Issued: October 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit 98OPWE204
g.
Nutri-Turf, LLC.
Page 22
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.
30. Wood Stoves and Wood burning Appliances
Regulation No. 4, 5 CCR 1001-6
The permittee shall comply with the provisions of Regulation No. 4 concerning the advertisement, sale, installation, and use
of wood stoves and wood burning appliances.
J
Operating Permit 98OPWE204 First Issued: October 1, 1999
Renewed DRAFT
Air Pollution Control Division
Colorado Operating Permit
Appendices
Operating Permit Appendices
Appendix A — Inspection Information
Appendix B — Monitoring and Permit Deviation Report
Appendix C — Compliance Certification Report
Appendix D — Notification Addresses
Appendix E — Permit Acronyms
Appendix F —Permit Modifications
Page 23
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 98OPWE204 First Issued: October 1, 1999
Renewed: DRAF1]
Air Pollution Control Division
Colorado Operating Permit
Ins s ection Information
Appendix A
Pa•e24
A. Appendix A - Inspection Information
A.I. Directions to Plant:
Going north on I-25 through Fort Collins, take County Road 50 East to County Road 15 and go
north on County Road 15
A.II. Safety Equipment Required:
Eye Protectk)n; Hard Hat; Hearing Protection
A.III. Facility Plot Plan:
The attached Figure (following page) shows the plot plan as submitted in the May 30, 2017 Title V
Operating Permit Application.
A.IV. List of Insignificant Activities:
The following list of insignificant activities was provided by the source to assist in the understanding
of the facility layout. Since there is no requirement to update such a list, activities may have changed
since the last filing.
For insignificant activities marked with an asterisk (*) the owner or operator must maintain
sufficient recordkeeping to verify that the exemption applies (i.e., annual throughput is less than
400,000 gallons). Such records shall be made available for Division review upon request (Colorado
Regulation No. 3, Part C, Section ILE).
A.IV.1. Space Heaters (Colorado Regulation No. 3, Part C, Section II.E.3.ggg.)
A.IV.2. *560 gallon gasoline tank (Section II.E.3.a.) Note that this tank issubject to the
requirements of 40 CFR Part 63, Subpart CCCCCC — National Emission Standards for
Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities, as
described in Section II, Condition 2
A.IV.3. 560 gallon diesel tank (Section II.E.3.fff.)
A.IV.4. *Miscellaneous lube oil storage (Section II.E.3.aaa.)
A.IV.5. Parts washer (aqueous cleaner) (Section II.E.3.mmm.)
A.IV.6. Hot water heaters (Section II.E.3.k.)
A.IV.7. Air conditioning/ventilation (Section II.E.3.tt.)
Operating Permit 98OP'WE204 First Issued: October 1, 1949
Renewed: DRAIj_JTl
Air Pollution Control Division
Colorado Operating Permit
Inspection Information
A.IV.8. Air compressor (Section II.E.3.qq.)
A.IV.9. Welding operations (Section II.E.3.r.)
A.IV.10. Sewer vents (Section II.E.3.c.)
Appendix A
Page 25
A.IV.11. Field cultivating and harvest (Section II.E.3.g.)
A.IV.12. Aerosol can usage (Section II.E.3.u.)
A.IV.13. Adhesive usage (Section II.E.3.y.)
A.IV.14. Fugitive emissions from landscaping (Section II.E.3.cc.)
A.IV.15. Architectural painting and surface preparation (Section II.E.3.nn.)
A.IV.16: Janitorial activities (Section II.E.3.pp)
A.IV.17. Office emissions - cleaning, copying, restrooms (Section II.E.3.tt)
A.IV.18. Pesticide/fumigant/herbicide use (Section II.E.3.ttt.)
A.IV.19. Basins for storm water runoff prevention (Section II.E.3.yyy.)
A.IV.20. *Air pollution emission units, operations or activities with emissions less than the
appropriate de minimis reporting level (Section II.E.3.a.)
Operating Permit 98OPWE204 First Issued: October 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Inspection Information
Appendix A
Page 26
Operating, Permit 98OPWE204
First Issued: October 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Compliance Certification Report
B. Appendix B — Reporting Requirements and Definitions
Appendix B
Page 27
Please note that, pursuant to 113(c)(2) of the federal Clean Air Act, any person who knowingly:
(A) Makes any false material statement, representation, or certification in, or omits material information from,
or knowingly alters, conceals, or fails to file or maintain any notice, application, record, report, plan, or
other document required pursuant to the Act to be either filed or maintained (whether with respect to the
requirements imposed by the Administrator or by a State);
(B) Fails to notify or report as required under the Act; or
(C) Falsifies, tampers with, renders inaccurate, or fails to install any monitoring device or method required to
be maintained or followed under the Act shall, upon conviction, be punished by a fine pursuant to title 18
of the United States Code, or by imprisonment for not more than 2 years, or both. If a conviction of any
person under this paragraph is for a violation committed after a first conviction of such person under this
paragraph, the maximum punishment shall be doubled with respect to both the fine and imprisonment.
The Source must comply with all conditions of this operating permit. Any permit noncompliance
constitutes a violation of the Act and is grounds for enforcement action; for permit termination,
revocation and reissuance, or modification; or for denial of a permit renewal application.
The Part 70 Operating Permit program requires three types of reports to be filed for all permits. All
required reports must be certified by a responsible official.
Report #1: Monitoring Deviation Report (due at least every six months)
For purposes of this operating permit, the Division is requiring that the monitoring reports are due
every six months unless otherwise noted in the permit. All instances of deviations from permit
monitoring requirements must be clearly identified in such reports.
For purposes of this operating permit, monitoring means any condition determined by observation, by
data from any monitoring protocol, or by any other monitoring which is required by the permit as well
as the recordkeeping associated with that monitoring. This would include, for example, fuel use or
process rate monitoring, fuel analyses, and operational or control device parameter monitoring.
Report #2: Permit Deviation Report (must be reported "promptly")
In addition to the monitoring requirements set forth in the permits as discussed above, each and every
requirement of the permit is subject to deviation reporting. The reports must address deviations from
permit requirements, including those attributable to malfunctions as defined in this Appendix, the
probable cause of such deviations, and any corrective actions or preventive measures taken. All
deviations from any term or condition of the permit are required to be summarized or referenced in the
annual compliance certification.
Operating Permit 98OPWE204 First Issued: October 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Compliance Certification Report
Appendix B
Page 28
For purposes of -this operating permit, "malfunction" shall refer to both emergency conditions and
malfunctions. Additional discussion on these conditions is provided later in this Appendix.
For purposes of this operating permit, the Division is requiring that the permit deviation reports are due
as set forth in General Condition 21. Where the underlying applicable requirement contains a definition
of prompt or otherwise specifies a time frame for reporting deviations, that definition or time frame shall.
govern. For example, quarterly Excess Emission Reports required by an NSPS or Regulation No. 1,
Section IV.
In addition to the monitoring deviations discussed above, included in the meaning of deviation for the
purposes of this -operating permit are any of the following:
(1)
(2)
(3)
A situation where emissions exceed an emission limitation or standard contained in the permit;
A situation where process or control device parameter values demonstrate that an emission
limitation or standard contained in the permit has not been met;
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:
2 = Process:
3 = Monitor:
4 = Test:
5 = Maintenance:
6 = Record:
7 = Report:
8 = CAM:
= 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
A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the
Compliance Assurance Monitoring (CAM) Rule) has occurred.
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 Ceftifications are intended to state the compliance status of each requirement of the permit
over the certification period. They must be based, at a minimum, on the testing and monitoring
methods specified in the permit that were conducted during the relevant time period. In addition, if the
Operating Permit 98OPWE204 First Issued: October 1, 1999 •
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Compliance Certification Report
Appendix B
Page 29
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.
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 98OPWE204 First Issued: October 1, 1999
Renewed. 3DRAFT
Air Pollution Control Division
Colorado Operating Permit
Compliance Certification Report
Startup, Shutdown, Malfunctions and Emergencies,
Appendix B
Page 30
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 98OP'WE204 First Issued: October 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Compliance Certification Report
B.I. Appendix B — Monitoring and Permit Deviation Report - Part I
Appendix B
Page 31
B.I.1. Following is the required format for the Monitoring and Permit Deviation report to be
submitted to the Division as set forth in General Condition 21. The Table below must be
completed for all equipment or processes for which specific Operating Permit terms exist.
B.I.2. Part II of this Appendix B shows the format and information the Division will require for
describing periods of monitoring and permit deviations, or malfunction or emergency
conditions as indicated in the Table below. One Part II Form must be completed for each
Deviation. Previously submitted reports (e.g. EER's or malfunctions) may be referenced
and the form need not be filled out in its entirety.
FACILITY NAME: Nutri-Turf, LLC.
OPERATING PERMIT NO: 98OPWE204
REPORTING PERIOD: (see first page of the permit for specific reporting period and dates)
Emission Unit
Facility ID
Deviations noted
During Period?'
Unit Description During Period.
Deviation Code 2
Malfunction/Emergency
Condition Reported
YES
NO
YES
NO
P201
Land Application
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:
-
2 = Process:
3 = Monitor:
4 = Test:
5 = Maintenance:
6 = Record:
7 = Report:
8=CAM:
9 = 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
A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the
Compliance Assurance Monitoring (CAM) Rule) has occurred.
When the deviation is not covered by any of the above categories
Operating Permit 98OPWE204 First Issued: October 1, 1999
Renewed: DRAFT
Air Pollution Control L vision
Colorado Operating Permit
Compliance Certification Report
.B.II. Appendix B — Monitoring and Permit Deviation. Report - Part II
FACILITY NAME: Nuiri-Turf, LLC.
OPERATING PERMIT NO: 98OPWE204
REPORTING PERIOD:
Is the deviation being claimed as an:
Appendix EB
Page 32
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 98OPWE204
First Issued: October 1, 1999
Renewed: DRAFTJ
Air Pollution Control Division
Colorado Operating Permit
Compliance Certification Report
EXAMPLE
FACILITY NAME: U.S.S. Enterprise
OPERATING PERMIT NO: 64OPZZXXX
REPORTING PERIOD: 1/1/2369 - 6/30/2369
Appendix B
Page 33
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:
Holodeck generator with nanobot-repaired filtration system — Unit TNG
Operating Permit Condition Number Citation
Section II, Condition 3.1 - Opacity Limitation
Explanation of Period of Deviation
Tribbles in the console
Duration
START- 1730 4/10/2369
END- 1800 4/10/2369
Action Taken to Correct the Problem
Transported Tribbles to Klingon vessel.
Measures Taken to Prevent Reoccurrence of the Problem
Permanent ban of Tribbles as pets. Increased structural integrity of console.
(
Dates of Malfunction/Emergencies Reported (if applicable)
5/30/2369 to J.L. Picard, APCD
Deviation Code Division Code QA:
Operating Permit 98OPWE204
First Issued: October 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Compliance Certification Report
Appendix B
Page 34
B.III. Appendix B — Monitoring and Permit Deviation Report - Part III
REPORT CERTIFICATION
SOURCE NAME: Nutii-Turf, LLC.
FACILITY IDENTIFICATION NUMBER: 123-0497
PERMIT NUMBER: 98OPWE204
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 punished in accordance with the provisions of Sub -Section 25-7122.1,
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 98OPWE204 First Issued: October 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Notification Addresses
Appendix C
Page 35
C. Appendix C — Required Format for Annual Compliance Certification
Reports
Following is the format for the Compliance Certification report to be submitted to the Division and the U.S. EPA
annually based on the effective date of the permit. The Table below must be completed for all equipment or
processes for which specific Operating Permit terms exist.
FACILITY NAME: Nutri-Turf, LLC.
OPERATING PERMIT NO: 98OPWE204
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.
Emission Unit
Facility ID •
Deviations
Reported'
Unit Description Permit.
Monitoring
Method per
Was compliance
continuous or
intermittent.
Previous
Current
YES
NO
YES
NO
P201
Land Application
-
General Conditions
Insignificant Activities'
' If deviations were noted in a previous deviation report , put an "X" under "previous". If deviations were noted in the current deviation
report (i.e. for the last six months of the annual reporting period), put an "X" under "current". Mark both columns if both apply.
2 Note whether the method(s) used to determine the compliance status with each term and condition was the method(s) specified in the
permit. If it was not, mark "no" and attach additional information/explanation.
3 Note whether the compliance status with of each term and condition provided was continuous or intermittent. "Intermittent
Compliance" can mean either that noncompliance has occurred or that the owner or operator has data sufficient to certify compliance
only on an intermittent basis. Certification of intermittent compliance therefore does not necessarily mean that any noncompliance has
occurred. -
NOTE:
The Periodic Monitoring requirements of the Operating Permit program rule are intended to provide assurance that even in the absence
of a continuous system of monitoring the Title V source can demonstrate whether it has operated in continuous compliance for the
Operating Permit 98OPWE204
First Issued: October 1, 1999
Renewed: DRA=FTI
Air Pollution Control Division
Colorado Operating Permit
Notification Addresses
Appendix C
Page 36
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.
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 riot . in compliance with all the
requirements of section 112(r).
1. A Risk Management Plan will be has been submitted to the appropriate
authority and/or the designated central location by the required date.
III. Certification
All information for the Annual Compliance Certification must be certified by a responsible official as defined in
Colorado Regulation No. 3, Part A, Section I.B. This signed certification document must be packaged with the
documents being submitted.
I have reviewed this certification in its entirety and, based on information and belief formed after
reasonable inquiry, I certify that the statements and information contained in this certification are true,
accurate and complete.
Please note that the Colorado Statutes state that any person who knowingly, as defined in § 18-1-501(6),
C.R.S., makes any false material statement, representation, or certification in this document is guilty of a
misdemeanor and may be punished in accordance with the provisions of § 25-7 122.1, C.R.S.
Printed or Typed Name Title
Signature Date Signed
NOTE: All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental Protection
Agency at the addresses listed in Appendix D of this Permit.
Operating Permit 98OPWE204 First Issued: October 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Notification Addresses
Appendix D
Page 37
D. Appendix D — Notification Addresses
D.I. Air Pollution Control Division
Colorado Department of Public Health and Environment
Air Pollution Control Division
Operating Permits Unit
APCD-SS-B 1
4300 Cherry Creek Drive S.
Denver, CO 80246-1530
ATTN: Matt Burgett
D.II. United States Environmental Protection Agency
Compliance Notifications:
Office of Enforcement, Compliance and Environmental Justice
Mail Code 8ENF-AT
U.S. Environmental Protection Agency, Region VIII
1595 Wynkoop Street
Denver, CO 80202-1129
502(b)(10) Changes, Off Permit Changes:
Office of Partnerships and Regulatory Assistance
Mail Code 8P -AR
U.S. Environmental Protection Agency, Region VIII
1595 Wynkoop Street
Denver, CO 80202-1129
Operating Permit 98OPWE204 First Issued: October 1, 1999
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit Acronyms
Appendix F
Page 38
E. Appendix E — Permit Acronyms
Listed Alphabetically:
AIRS - Aerometric Information Retrieval System
AP -42 - EPA Document Compiling Air Pollutant Emission Factors
APEN - Air Pollution Emission Notice (State of Colorado)
APCD - Air Pollution Control Division (State of Colorado)
ASTM - American Society for Testing and Materials
BACT - Best Available Control Technology
BTU - British Thermal Unit
CAA - Clean Air Act (CAAA = Clean Air Act Amendments)
CCR - Colorado Code of Regulations
CEM - Continuous Emissions Monitor
CF - Cubic Feet (SCF = Standard Cubic Feet)
CFR - Code of Federal Regulations
CO - Carbon Monoxide
COM - Continuous Opacity Monitor
CRS - Colorado Revised Statute
EF - Emission Factor
EPA - Environmental Protection Agency
FI - Fuel Input Rate in MMBtu/hr
FR - Federal Register
G - Grams
Gal - Gallon
GPM - Gallons per Minute
HAPs - Hazardous Air Pollutants
HP - Horsepower
HP -HR - Horsepower Hour (G/HP-HR = Grams per Horsepower Hour)
LAER - Lowest Achievable Emission Rate
LBS - Pounds
M - Thousand
MM - Million
MMscf _ Million Standard Cubic Feet
MMscfd - Million Standard Cubic Feet per Day
N/A or NA - Not Applicable
NOx - Nitrogen Oxides
NESHAP - National Emission Standards for Hazardous Air Pollutants
NSPS - New Source Performance Standards
P - Process Weight Rate, in Tons/Hr
PE - Particulate Emissions
PM - Particulate Matter
PMto - Particulate Matter Under 10 Microns
PSD - Prevention of Significant Deterioration
PTE - Potential To Emit
Operating Permit 98OPWE204
First Issued: October 1, 1999 '
Renewed: DRAE:T
Air Pollution Control Division
Colorado Operating Permit
Permit Acronyms
Appendix E
Page 39
RACT
SCC -
SCF -
SIC -
SO2 -
TPY -
TSP -
VOC -
Reasonably Available Control Technology.
Source Classification Code
Standard. Cubic Feet
Standard Industrial Classification
Sulfur Dioxide
Tons Per Year
Total Suspended•Particulate
Volatile Organic Compounds
Operating Permit 98OPWE204
First Issued: October 1, 1999
Renewed:DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit Modifications
Appendix K
Page 40
F. Appendix F — Permit Modifications
DATE OF
REVISION
TYPE OF
REVISION
SECTION NUMBER,
CONDITION NUMBER
DESCRIPTION OF REVISION
9
s
1
Operating Permit 98OPWE204
First Issued: October 1, 1999
Renewed: DRAFT
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
OPERATING PERMIT RENEWAL SUMMARY
PERMIT NUMBER: 98OPWE204
APPLICANT: Nutri-Turf, LLC.
REVIEW ENGINEER: Nicholas Dummer
AIRS ID #: 123/0497 DATE: April 30, 2018
SOURCE DESCRIPTION
Nutri-Turf, LLC.. has applied for renewal of their Operating Permit issued for their facility located at 43308 Weld County
Road, Fort Collins, CO 80524. The facility processes wastewater from the Anheuser Busch Brewery via land application to
irrigate crops for production and sale. The facility is classified under SIC 0191. The facility is classified as non -attainment'
for ozone and is part of the 8 -hr Ozone Control Area.
There is only one Operating Permit associated with this facility. However, it is considered collocated with respect to
emissions from the Anheuser Busch Brewery.
This source is categorized as a Non -Attainment New Source Review (NANSR) major stationary source and a major
stationary source with respect to Prevention of Significant Deterioration (PSD) requirements. Wyoming is an affected state
within 50 miles of this facOity. Rocky Mountain National Park and Rawah National Wilderness Area are Federal Class I
designated areas within WO km of this facility. The emission units covered under this permit are not subject to the
Accidental Release provisions of section 112(r) of the Federal Clean Air Act. In addition, none of the emission units at this
facility are subject to the Compliance Assurance Monitoring (CAM) requirements in 40 CFR Part 64.
FACILITY EMISSION SUMMARY
ll,,,;,
Nutri=Turf
_ Brewery
Pollutant
PTE
Actual
PTE
Actual
• NO.
-
- '
544
47.5
CO
-
-
100
4.0
VOC
236.0
87.0
215
115.7
SO2
-
-
1410
0.3
PM
-
-
193
7.4
PM10
-
-
193
4.3
PM2.5
-
-
193
7.8
EMISSION SOURCES
No changes were made to the emission sources. Requirements associated with MACT CCCCCC were added for a
gasoline tank on site.
ALTERNATIVE OPERATING SCENARIOS
No changes were made to the alternative operations scenarios.
INSIGNIFICANTACTIVITIES
No changes were made to the list of insignificant activities.
- PERMIT SHIELD
No changes were made to the permit shield.
TECHNICAL REVIEW DOCUMENT
For
;DRAFT RENEWAL OF OPERATING PERMIT 98OPWE204
Nutri-Turf, LLC.
Weld County
Source ID 123/0497
February 2018 — Date'
Operating Permit Engineer:
Operating Permit Supervisor review:
Field Services Unit review:
I. Purpose
Nicholas Dummer
Matt Burgett
Dave Huber
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 Nutri-Turf, LLC. facility (herein,
Source). The previous Operating Permit for this facility was issued on June 1, 2013
and expired on June 1, 2018., 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.
Prior to submittal of the renewal application, the source submitted a minor modification
application on August 5, 2015 which requested changes to flow monitoring
requirements. Detailed discussion of thesemodifications are outlined in Section IV of
this TRD.
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 original application submitted on May 30,
2017, commentson the draft permit submitted on [d]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 www.colorado.gov/cdphe/airTitleV. This narrative is
intended only as an adjunct for the reviewer and has no legal standing.
Any revisions made to the underlying construction permits associated with this facility.
made in conjunction with the processing bf 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
123/0497 Page 1 of 5
Nutri-Turf, LLC.
Operating Permit No. 98OPWE204
Technical Review Document — Renewal 3 Operating Permit
this operating permit without applying for a revision to this permit or for an additional or
revised construction permit.
II. Description of Source
The Nutri-Turf, LLC. (herein, Source) facility is an auxiliary operation of the Anhueser-
Busch Companies, LLC., Fort Collins Brewery (operates under Operating Permit
95OPLR064). A portion of the brewery wastewater is piped to the Source for land
application. The land is irrigated with wastewater via center pivots; soil bacteria break
down soluble organics in the wastewater into usable nutrients for planted vegetation to
grow. The Source grows and sells a variety of crops, including brome grass, alfalfa,
other grasses, wheat, and corn.
The facility is located at 43308 Weld County Road #15, Fort Collins, Colorado, Weld
County. This facility is located in an area classified as attainment for all pollutants
except ozone. It is classified as non -attainment for the 8 -hr ozone standard and is part
of the 8 -hr Ozone Control Area as defined in Regulation No. 7, Section II.A.1.
Wyoming is an affected state within 50 miles of the plant. There are two Federal Class
I designated areas within 100 kilometers of the facility: Rocky Mountain National Park
and Rawah Wilderness area.
This facility is categorized as a NANSR major stationary source (potential to emit
(PTE) of volatile organic compounds (VOC) or oxides of nitrogen (NOx) is greater than
(>) 100 tons per year (tpy)). Future modifications at this facility resulting in a
significant net emissions increase (see Colorado Regulation No. 3, Part D, Sections
II.A.27 and 44) for VOC or NOx or a modification which is major by itself (PTE > 100
tpy of either VOC or NOx) may result in the application of the NANSR review
requirements.
This facility is categorized as a PSD major stationary source (PTE > 250 tpy) for NOx
and SO2. Future modifications at this facility resulting in a significant net emissions
increase (see Colorado Regulation No. 3, Part D, Sections II.A.27 and 44) or a
modification which is major by itself (PTE > 250 tpy) for any pollutant listed in
Colorado 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.
Potential and actual emissions (from most recent APENs) from the Nutri-Turf facility
and the collocated Anhueser-Busch Companies, LLC., Fort Collins Brewery are as
follows (note that the actual emissions are taken,from the most recently submitted
APENS from the facilities):
Nutri-Turf
Brewery
Pollutant
PTE
Actual
PTE
Actual
NOx
544
47.5
CO
100
4.0
VOC
236.0
87.0
215
115.7
SO2
1410
0.3
123/0497
Page 2 of 5
Nutri-Turf, LLC.
Operating Permit No. 98OPWE204
Technical Review Document — Renewal 3 Operating Permit
PM
-
-
193
7.4
PMio
- _
-
193
'4.3
PM2.5
-
-
193
7.8
Ill. Applicable Requirements
Accidental Release Program — 112(r)
Section 112(r) of the Clean Air Act mandates a new federal focus on the prevention of
chemical accidents. Sources subject to these provisions must develop and implement
risk management programs that include hazard assessment, a prevention program,
and an emergency response program. They must prepare and implement a Risk
Management Plan (RMP) as specified in the Rule
Based on the information provided by the Source, this facility is not subject to the
provisions of Section 112(r) of the Federal Clean Air Act.
Hazardous Air .Pollutants (HAP)
The facility is a true minor Source of HAP. There are no emissions of HAP at the
facility.
Colorado Regulation No. 7, Section XIX — Control of Emissions from Specific Major
Sources of VOC and/or NOx in the 8 -hour Ozone Control Area
The Source was required to submit a RACT analysis for the land application of
brewery wastewater no later than December 31, 2017 in accordance with the
requirements of Section XIX.B. At the time of issuance of this Operating Permit, the
Source successfully completed this requirement. In the event that the Division requires
additional RACT for the facility, a modification to this Operating Permit will be
necessary; however, at this time this requirement was omitted from the Operating
Permit as the one-time requirement has been fulfilled by the Source.
IV. Modifications Requested by the Source
Since the previous issuance of the Operating Permit, the Source requested the
following modifications:
Section II — Specific Permit Terms
• The Source requested changes to Condition 1.1 monitoring of wastewater to
the facility. Instead of the primary monitoring flow meter being_ the meter leaving
the brewery, the facility requested that the primary meter be the one entering
the landfarm. This modification was accepted and addressed in the updated
Condition 1 language. These. changes are discussed in greater detail in Section
V of this TRD..
V. Other Modifications
123/0497 Page 3 of 5
Nutri-Turf, LLC.
Operating Permit No. 98OPWE204
Technical Review Document — Renewal 3 Operating Permit
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).
• Modified the language concerning postmarked dates for report submittals to
reflect the Division's current standard language. _
Section I — General Activities and Summary
• Revised the formatting in Section I to reflect current Division Operating Permit
formats. The numbering was slightly altered, but there were no notable
changes to this Section.
Section II — Specific Permit Terms
• Condition 1 was reworked for clarity of applicable requirements. The numbering
schema was updated for clarity and individual sub -paragraphs were given their
own sub -conditions.
• Condition 1.1 was updated to reflect the Source's modification request to use
the wastewater applied as the primary flow measurement instead of the
wastewater leaving the brewery.
• Condition 1.1 was updated to require recordkeeping of annual flow meter
calibrations, as appropriate.
• Condition 1.2 was updated to include the calculation methodology. The
sampling requirement was moved to a separate condition. The calculation
requirement was updated to clarify that the results of once -per -8 -day sampling
would be used until a subsequent sampling event.
• Condition 1.3 was added to address the sampling and.testing requirements for
the facility. .
The requirement to use the highest recorded concentration for each 8 -day
sampling period was added to the permit to prevent cherry -picking data. The
Source is permitted to request that a test result be omitted pending Division
123/0497 Page 4 of 5
Nutri-Turf, LLC.
Operating Permit No. 98OPWE204
Technical Review Document — Renewal 3 Operating Permit
approval. This was added in the event that the Source discovers an issue with
a test that may have resulted in atypical results. Additionally, the requirement to
maintain 24 -month rolling total VOC concentrations and standard deviation
calculations was added. In the event that a sampling and testing result exceeds
two standard deviations from the average, the Source is required to investigate
the cause of the excursion. This requirement aims to\provide the Division with
data to better understand VOC emissions due to variability in operations.
• Conditions 1.4 and 1.5 for BACT and RACT were updated for clarity, but there
were no changes to the requirements.'
• Added Condition 2 to the Operating Permit which includes the requirements for
the gasoline tank in the insignificant activities list. These requirements include
general best practices for minimizing emissions to the atmosphere of VOCs.
The tank must be fitted with a gasketed seal.
Section III — Permit Shield
• There were no changes to the permit shield.
Section V — General Permit Conditions
• The general permit conditions were updated to the) most recent version
(3/3/2018)
Appendices
• The formatting of the Appendices was updated for consistency and clarity:
• The insignificant activities list was updated to reflect the Colorado Regulation
No. 3, Part C, Section II.E. requirements to maintaimrecords of certain
insignificant activities to verify that they ought to remain on the list, as
appropriate. A cross-reference was added for the gasoline tank which points at
the MACT CCCCCC requirements as discussed above.
123/0497 < Page 5 of 5
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
OPERATING PERMIT RENEWAL SUMMARY
PERMIT NUMBER: 98OPWE204
APPLICANT: Nutri-Turf, LLC.
REVIEW ENGINEER: Nicholas Dummer
AIRS ID #: 123/0497 DATE: April 30, 2018
SOURCE DESCRIPTION
Nutri-Turf, LLC.. has applied for renewal of their Operating Permit issued for their facility located at 43308 Weld County
Road, Fort Collins, CO 80524. The facility processes wastewater from the Anheuser Busch Brewery via land application to
irrigate crops for production and sale. The facility is classified under SIC 0191. The facility is classified as non -attainment
for ozone and is part of the 8 -hr Ozone Control Area.
There is only one Operating Permit associated with this facility. However, it is considered collocated with respect to
emissions from the Anheuser Busch Brewery.
This source is categorized as a Non -Attainment New Source Review (NANSR) major stationary source and a major
stationary source with respect to Prevention of Significant Deterioration (PSD) requirements. Wyoming is an affected state
within 50 miles of this facility. Rocky Mountain National,Park and Rawah National Wilderness Area are Federal Class I
designated areas within 100 km of this facility. The emission units covered under this permit are not subject to the
Accidental Release provisions of section 112(r) of the Federal Clean Air Act. In addition, none of the emission units at this
facility are subject to the Compliance Assurance Monitoring (CAM) requirements in 40 CFR Part 64.
FACILITY EMISSION SUMMARY
Nutri-Turf
Brewery
Pollutant
PTE
Actual
PTE
Actual
NO.
-
-
544
47.5
CO
-
-
100 -
4.0
VOC
236.0
87.0
215
115.7
SO2
-
-
1410
0.3
PM
-
-
193
7.4
PM1p
-
-
193
4.3
PM2.5
-
-
193
7.8
EMISSION SOURCES
No changes were made to the emission sources. Requirements associated with MACT CCCCCC were added for a
gasoline tank on site.
ALTERNATIVE OPERATING SCENARIOS
No changes were made to the alternative operations scenarios.
INSIGNIFICANT ACTIVITIES
No changes were made to the list of insignificant activities.
PERMIT SHIELD
No changes were made to the permit shield.
„Q c
ONE OF fl -e. ANI-tELIS-84.19CH COMPANIES
May 22, 2017
Mr. Nicholas Demmer
Colorado Department of Public Health and Environment
Air Pollution Control Division
4300 Cheery Creek Drive
Denver, CO 80246
RE: Nutri-Turf, LLC — Title V Renewal
Mr. Drummer:
2351 Busch Drive
Fort Collins, CO 80524
970-490-4500
Busch Agricultural Resources, LLC's Nutri-Turf, LLC facility is pleased to submit this Title V
Permit renewal application. The facility is a major stationary source and currently operates
under Title V Operating Permit #98OPWE204. In accordance with Colorado Regulation No, 3,
Part C, Section IILB.6, an application for renewal of an operating permit is due at least twelve
months, but no more than 18 months, prior to, the expiration of the operating permit; An
administratively complete application received on or before the due date entitles the source to
an application shield under the provisions of Colorado Regulation No. 3, Part C, Section II.B.
The permit renewal is due on or before June 1, 2017.
Colorado Regulation No. 3, Part C, Section 1113.6 requires the following information be
included in the renewal application:
1. Cover letter signed by the Company's Responsible Official
O No changes are being requested for the operating permit except as identified
below.
2. Colorado Form 2000-800 signed by the Responsible Official
• All required forms are attached, including Form 2000-800 which is signed by the
Responsible Official.
3. A copy of any materials incorporated by reference must be included with the renewal
application, unless currently on file with CDPHE.
m No rew materials are being incorporated by reference.
4. Greenhouse Gas (GHG) emissions statement
O The facility is minor (<100,000 TPY of CO2e) for GHGs.
ONE OF THE AAIH'EuSER-&,SCH COMPANIES
2351 Busch Drive
Fort Collins, CO 80524
970-490-4500
5. Revise list of insignificant activities as necessary
® The facility has not made any changes. Thus, there are not changes to the list of
insignificant activities.
6. Compliance Assurance Monitoring Applicability
o The CAM requirements as outlined in Code of Federal Regulations, Title 40, Part
64 (40 CFR 64) apply to individual sources at Part 70 facilities which use air
pollution control equipment to achieve compliance and have pre -control potential
to emit greater than major source levels. The facility does not utilize air pollution
control equipment. Thus, CAM does not apply.
7. Requested Changes
O The facility is requesting only one minor change to Section II Item 1.1. The
change is noted below:
1.1 Disposal of wastewater shall not exceed 1,625 x 106 gallons per year.
Compliance with the annual limit shall be determined on a rolling 12 -month total.
By the end of each month a new twelve-month total is calculated using the
previous twelve months' data.
Flow meters shall be used to measure the amount of wastewater entering the
landfarm from the brewery. As a backup system, the brewery shall track
outgoing wastewater amounts. Flowmeters shall be calibrated annually.
The permittee shall maintain records of the monthly amounts of wastewater sent
to the land application site, and the calculated rolling 12 -month total. These
records shall be made available to the Division for inspection upon request.
As required, the facility is submitting the original plus three copies of this application.
Thank you for your consideration. Please feel free to contact Aaron Mortensen at (970)
490-4635 if you have any questions or require additional information.
Since
Eug ne '„ ocis
Gen-: anager
NUTRI-TURF, LLC
PLOT PLAN
NUTRI-TURF, LLC
CDPHE TITLEV RENEWAL FORM
N° TRITURF-FORTCO LINS, CO
SW 1/4 SEC. 10
SEC 20
WELL SEC. 1>
am #4
WELD CUNEY R0.90
SEC. 21
U WELL:#6
,SEC 15
SEC27
SW I/4 SEC 14
SEC 26
Filtration Basin Wildlife Habitat
Collection Pond ni North Weld County
Water District
Center Pivot 4,.• ,, 134 WC,7
Dry Land Area ,,,,.,,°5.466 <,, Lysimeter
Buildings & Tanks Well
NUTRI-TURF, LLC
CDPHE TITLE V RENEWAL FORM
Operating Permit Application
Colorado Department of Public Health and Environment
Air Pollution Control Division
Facility name and Name
FACILITY IDENTIFICATION
SEE INSTRUCTIONS ON REVERSE SIDE
mailing address Street or Route
City, State, Zip Code
2. Facility location
Street Address
(No P.O. Box) City,County, Zip Code
3. Parent corporation Name
4. Responsible
Street or Route
City, State, Zip Code
Country (if not U.S.)
Name
official Title
Nutri-Turf, LLC.
43308 Weld County Road #15
Fort Collins, CO 80524
43308 Weld County Road #15
Fort Collins, CO 80524
Busch Agricultural Resources, LLC
One Busch Place (202-6)
St. Louis, MO 63118
FORM 2000-100
Rev 0G-95
Telephone
5. Permit contact person Name
Title
(If Different than 4) Telephone
Eugene Bocis
General Manager
970-490-4500
Aaron Mortensen
ES Manager
970-490-4635
6. Facility SIC code:
7. Facility identification code: CO 1230497_
0191
8. Federal Tax I: D. Number:
9. Primary activity of the operating establishment:
Land application of wastewater from Anheuser-Busch's Fort Collins Brewery
10. Type of operating permit New Modified X Renewal
I I. Is the facility located in a "nonattainment" area: XYes No
I f "Yes" check the designated "icon -attainment" pollutant(s):
Carbon Monoxide X Ozone PM 10
Other (specify)
12. List all (Federal and sate) 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 pennit. For a Modified Operating Permit, do not complete this item.
Operating Permit Number = 98OPWE204
- Operatinu Permit Application
Colorado Department of Public Health and Environment
Air Pollution Control Division
FACILITY PLOT PLAN
FORM 2000-101
Rev 06-95
Facility Name: Facility Identification Code: CO
• The operating permit must be prepared and submitted on forms stipplied 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
infonnation 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?
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 X No
List the name(s) of any neighboring state(s) within a 50 mile radius of your facility:
Wyoming
Yes X No
Operating Permit Application
Colorado Department of Public Health and Environment
Air Pollution Control Division
SOURCE AND SITE DESCRIPTIONS
FORM 2000-102
Rev 06-95
Facility Name: Nutrl-Turf, LLC. Facility Identification Code: CO 1230497
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 willmot consider or act upon your application unless each form used has been entirely completed. Completion of the
information in the shaded area of this form is optional. Use "NA" where necessary to identify an information request that does not apply and is not'
in the optional shaded area.
1. Briefly describe the existing Unit(s) to be permitted: Attach copies of Form 2000-700 as needed to provide the information. Process
flowsheets or line diagrams showing major features and locations of air pollution control equipment can be most effective in showing the
location and relationships of the units. Providing mass flowrates/balances at critical points on the diagrams is very helpful when developing
an understanding of the processes involved.
This facility is an auxiliary operation of the Anheuser-Busch, Inc., Fort Collins Brewery. A portion of the
Brewery wastewater is piped to this site for land application. The land is irrigated through center pivots with
wastewater so that soil bacteria can break down the soluble organics and the vegetation can utilize the water
and the nutrients. The Production of brome grass, alfalfa, other grasses, wheat, and corn is sold.
2. Site Location and Description (Include instructions needed to drive to remote sites not identifed by street addresses)
The facility is located or Weld County Road #15
3. Safety Equipment
Identify safety equipment required for performing an inspection of the facility:
Protection
X Hard Hat
X Safety shoes
Hearing Protection
Gloves
Other, specify no jewellery
Operniins Permit Application SOURCE DESCRIPTION -INSIGNIFICANT ACTIVITIES
Colorado Department of Public Health and Environment
• Air Pollution Control Division
FORM 2000-102B
Rev 06-95
Facility Name: Mari -Turf, I.1 C. Facility ldentitication Code: CO 123O497
'NOTE: The operating pennit 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 fotnt 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.
X (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).
X 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.
X Chemical storage tanks or containers that hold less than 500 gallons, and which have a daily throughput less than 25 gallons.
x 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. -
' X 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)
X 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.
X 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.
X Storage tanks meeting all of the following criteria:•
(i) annual throughput is less than 400,000 gallons; and_ -
(ii) the liquid stored is one of the following:
(A) diesel fuels 1-D, 2-D, or 4-D;.
(B) fuel oils #1 through #6;
(C) gas turbine fuels 1-GT through 4-GT;
(D) an oil/water mixture with a vapor pressure lower than that of diesel fuel (Reid vapor pressure of .025 PSIA).
Each individual piece of fuel burning equipment which uses gaseous fuel, and which has a design rate less than or equal to 10 million
Btu per hour, and which is used solely for heating buildings for personal comfort.
Stationary Internal Combustion Engines which:
(i) power portable drilling rigs; or
(ii) are emergency power generators which operate no more than 250 hours per year; or
(iii) have actual emissions less than five tons per year or rated horsepower of less than 50.
Surface mining activities which mine 70,000 tons or fewer of product material per year. A fugitive dust control plan is required for such
sources. Crushers, screens and other processing equipment activities are not included in this exemption.
Air pollution emission units, operations or activities with emissions less than the appropriate de minimis reporting level.
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
Colorado Department of Health
Air Pollution Control Division
Facility Name: Nutri-Turf, LLC
ADMINISTRATION
TABULATION OF PERMIT APPLICATION FORMS " FORM 2000-800
09-94
Facility Identification Code: CO 1230497
This application contains the following forms:
lip, Form 2000-100. 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 Fort
This application contains the following forms (one
form for each facility boiler, printing operation, etc.):
Form 2000-200. Stack Identification
0
Form 2000-300, Boiler or Furnace Operation '
O
Form 2000-301. Storage Tanks
0
Fonn 2000-302, Internal Combustion Engine
0
Form 2000-303, Incineration
Form 2000-304, Printing Operations
0
Fonts 2000-305, Painting and Coating Operations
0
Form 2000-306, Miscellaneous Processes
0
Fonn 2000-307, Glycol Dehydration Unit
0
III. AIR POLLUTION CONTROL
SYSTEM
Total Number
of This Form
This application contains the following forms:
Forst 2000-400, Miscellaneous
0
Form 2000-401, Condensers
0
Fonn 2000-402, Adsorbers
0
Form 2000-403, Catalytic or Thermal Oxidation
0
Form 2000-404. Cyclones/Settling Chambers
0
Form 2000-405, Electrostatic Precipitators
0
Fonn 2000-406, Wet Collection Systems
0
Form 2000-407. Baghouses/Fabric Filters
0
IV. COMPLIANCE
DEMONSTRATION
Total Number
of This Form
This application contains the following forms lone
for each facility boiler. printing operation. etc.):
Fonn 2000-500. Compliance Certification - Monitoring and Reporting
0
Form 2000-501. Continuous Emission Monitoring
0
Fonn 2000-502. Periodic Emission Monitoring Using Portable Monitors
0
Form 2000-503. Control System Parameters or Operation Parameters of a Process
0
Form 1000-504, Monitoring Maintenance Procedur_s
0
Fort 2000-505, Stack Testing
0
Form 2000-506, Fuel Sampling and Analysis
0
Form '2000-507, Recordkeeping
0
Form 2000-508, Other Methods
0
92
V. EMISSION SUMMARY AN@
COMPLIANCE CERTIFICATION
This application contains the following forms
quantifying emissions, cenifying compliance with
applicable requirements, and developing a
compliance plan
Total Number
of This Form
Form 2000-600, Emission Unit Hazardous Air Pollutants
Form 2000-601, Emission Unit Criteria Air Pollutants
Form 2000-602, Facility Hazardous Air Pollutants
Form 2000-603, Facility Criteria Air Pollutants
0
0
0
Form 2000-604, Applicable Requirements and Status of Emission Unit
Fonts 2000-605, Permit Shield Protection Identification
0
0
Fonn 2000-606, Emission Unit Compliance Plan - Commitments and Schedule
Form 2000-607, Plant -Wide Applicable Requirements
0
0
Form 2000-608, Plant -Wide Compliance Plan - Commitments and Schedule
0
0
VI. SIGNATURE OF RESPONSIBLE OFFICIAL - FEDERAL/STATE CONDITIONS
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 containedin this application are true, accurate and coniplete.
B. CERTIFICATION OF FACILITY COMPLIANCE STATUS - FEDERAL/STATE CONDITIONS (check one box only)
1 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 followingemissions unit(s):
(lisiall 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 ehe provisions of § 25-
7 122.1, C.R.S.
Printed or Typed Name
Eugene Bocis
ignature
Title
General Manager
Date Signe
/7
93
Operating Permit Application
Colorado Department of Health
Air Pollution Control Division
Facility Name: Nutri-Turf, LLC.
CERTIFICATION FOR STATE -ONLY CONDITIONS FORM 2000-800
09-94
Facility Identification Code: CO 1230497
VI. SIGNATURE OF RESPONSIBLE OFFICIAL - STATE ONLY.CONDITiONS
A. STATEMENT OF COMPLETENESS .
1 have reviewed'this application in its entirety and, based on -information and belief formed
and information contained in this application are true, accurate and complete.
B. CERTIFICATION OF FACILITY COMPLIANCE STATUS -FOR STATE -ONLY CONDITIONS
- 1 I certify. that the facility described in this air pollution permit application is fully
I certify that the facility described in this air pollution permit application is fully
for the following emissions unit(s):
after reasonable inquiry, I certify that the statements
(check one box only)
in compliance with all applicable requirements.
in compliance with all applicable requirements, except
material statement, representation, or certification
be punished in accordance with the provisions of § 25-
(list all noncomplying units)
WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false
in, or omits material information from this application is guilty of a misdemeanor and may
7 122.1, C.R.S.
Printed or Typed Name
Eugene Bocis
Title
General Manager
Signature
Date Signed
6/aa _
•
SEND ALL MATERIALS TO:
COLORADO DEPARTMENT OF HEALTH
APCD-SS-B I
4300 CHERRY CREEK DRIVE SOUTH
DENVER, CO 80246-1530
94
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