HomeMy WebLinkAbout20162263.tiff(COLORADO
IDepartment of Public
Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
11500 St
PO Box 758
Greeley, CO 80632
July 11, 2016
Dear Sir or Madam:
On July 14, 2016, the Air Pollution Control Division will begin a 30 -day public notice period for Kerr-
McGee Oil and Gas Onshore LP - Central Oil Stabilization Facility. 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
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
John W. Hickenlooper, Governor Larry Wolk. MD, MSPH, Executive Director and Chief Medical Officer
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2016-2263
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Kerr-McGee Oil and Gas Onshore LP - Central Oil Stabilization Facility - Weld County
Notice Period Begins: July 14, 2016
Notice is hereby given that an application for a proposed project or activity has been submitted to the
Colorado Air Pollution Control Division for the following source of air pollution:
Applicant: Kerr-McGee Oil and Gas Onshore LP
Facility: Central Oil Stabilization Facility
Oil processing facility
Section 34 of T3N R65W
Weld County
The proposed project or activity is as follows: The applicant proposes to operate a Solar Taurus 60-7300S
turbine for power generation.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section
III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area)
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 13WE2977 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 hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Any such comment must be submitted in writing to the following addressee:
Andy Gruel
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
_ COLOR.a:)O
1
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
PERMIT NO:
DATE ISSUED:
ISSUED TO:
13WE2977
CONSTRUCTION PERMIT
Issuance 1
Kerr-McGee Oil and Gas Onshore LP
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the Central Oil Stabilization Facility, located in Section 34 of
Township 3N Range 65W in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
TUR-1
009
One (1) Solar, Model Centaur 60-7300S, Serial Number TBD,
natural-gas fired, combustion turbine rated at 80.1 MMBtu/hr (LVH)
based on 100% load and 0 degrees Fahrenheit ambient
temperature. This turbine is equipped with SoLoNOx technology.
This turbine may be rep aced with another Solar Centaur 60-7300S turbine in accordance with
the temporary turbine replacement provision or with another Solar Centaur 60-7300S turbine
in accordance with the permanent replacement provision of the Alternate Operating Scenario
(AOS), included in this permit as Attachment A.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR
QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED
IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen
days of the latter of commencement of operation or issuance of this permit, ty
submitting a Notice of Startup form to the Division. The Notice of Startup form may be
downloaded online at https://www.colorado.gov/pacific/cdphe/other-air-permitting-notices.
Failure to notify the Division of startup of the permitted source is a violation of Air Quality
Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the
revocation of the permit.
AIRS ID: 123-9B7D-009 Page 1 of 12
Turbine TM Version 2012-1
Public Health and Environment
Air Pollution Control Division
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit shall be
demonstrated to the Division. It is the owner or operator's responsibility to self -certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may
result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2).
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction fora period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
estimated completion date. The Division may grant extensions of the deadline per
Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Reference: Regulation No. 3, Part B, Section III.E.)
5. The following information shall be provided to the Division within fifteen (15) days of the
latter of commencement of operation or issuance of this permit.
• manufacturer
• model number
• serial number
This information shall be included with the Notice of Startup submitted for the equipment.
(Reference: Regulation No. 3, Part B, III.E.)
6. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission Type
NOx
VOC
CO
SO2
FM10
TUR-1
009
35.8
12.3
42.5
1.2
6.4
Point
See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Annual records of the actual emission rates shall be maintained by the owner or operator
and made available to the Division for inspection upon request.
PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum processing rates as listed below.
Annual records of the actual processing rate shall be maintained by the owner or operator
AIRS ID: 123-9B7D-009
Page 2of12
and made available to the Division for inspection upon request. (Reference: Regulation 3,
Part B, II.A.4)
Process/Consumption Limits
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
TUR-1
009
Consumption of natural gas as a
fuel
540 MMscf/yr
OT Public Health and Environment
Air Pollution Control Division
STATE AND FEDERAL REGULATORY REQUIREMENTS
9. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the
subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.)
(State only enforceable)
10. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of
the source. During periods of startup, process modification, or adjustment of control
equipment visible emissions shall not exceed 30% opacity for more than six minutes in any
sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections
XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1,
Section II.A.1. & 4.)
11. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable)
12. This source is subject to the Particulate Matter and Sulfur Dioxide Emission Regulations of
Regulation 1 including, but not limited to, the following:
a. No owner or operator shall cause or permit to be emitted into the atmosphere from
any fuel -burning equipment, particulate matter in the flue gases which exceeds the
following (Regulation 1, Section III.A.1):
(i) For fuel burning equipment with designed heat inputs greater than 1x106
BTU per hour, but less than or equal to 500x106 BTU per hour, the following
equation will be used to determine the allowable particulate emission
limitation.
PE=0.5(FI)"°26
Where:
PE = Particulate Emission in Pounds per million BTU heat input.
Fl = Fuel Input in Million BTU per hour.
b. Emissions of sulfur dioxide shall not emit sulfur dioxide in excess of the following
combustion turbine limitations. (Heat input rates shall be the manufacturer's
guaranteed maximum heat input rates).
New sources (Regulation 1, Section VI.B.4.c):
Combustion Turbines with a heat input of less than 250 Million BTU per hour:
0.8 pounds of sulfur dioxide per million BTU of heat input.
13. The turbine is subject to the New Source Performance Standards requirements of
Regulation No. 6, Part A, Subpart KKKK, Standards of Performance for Stationary
Combustion Turbines.
14. This source is subject to the New Source Performance Standards requirements of 40 CFR
Part 60, Subpart KKKK, Standards of Performance for Stationary Combustion Turbines
including, but not limited to, the following:
(i)
AIRS ID: 123-9B7D-009 Page 3 of 12
Public Health and Environment
Air Pollution Control Division
a. Emissions of NO shall not exceed the limits specified in §60.4320.
b. Compliance with the fuel sulfur content limit shall be presumed when burning natural
gas. The methods specified in 40 CFR Part 60 Subpart KKKK § 60.4365 shall be
used to demonstrate the natural gas meets the definition of natural gas.
c. Initial and subsequent performance tests in accordance with §60.4400 must be
performed to demonstrate continuous compliance.
In addition, the following requirements of Regulation 6, Part A, Subpart A, General
Provisions, apply.
d. At all times, including periods of start-up, shutdown, and malfunction, the facility and
control equipment shall, to the extent practicable, be maintained and operated in a
manner consistent with good air pollution control practices for minimizing emissions.
Determination of whether or not acceptable operating and maintenance procedures
are being used will be based on information available to the Division, which may
include, but is not limited to, monitoring results, opacity observations, review of
operating and maintenance procedures, and inspection of the source. (Reference:
Regulation 6, Part A. General Provisions from 40 CFR 60.11(d))
e. No article, machine, equipment or process shall be used to conceal an emission
which would otherwise constitute a violation of an applicable standard. Such
concealment includes, but is not limited to, the use of gaseous diluents to achieve
compliance with an opacity standard or with a standard which is based on the
concentration of a pollutant in the gases discharged to the atmosphere. (§60.12)
Written notification of construction and initial startup dates shall be submitted to the
Division as required under §60.7.
Records of startups, shutdowns, and malfunctions shall be maintained, as required
under §60.7.
h. Performance tests shall be conducted as required under §60.8.
g
OPERATING & MAINTENANCE REQUIREMENTS
15. This source is not required to follow a Division -approved operating and maintenance plan.
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
16. This turbine is subject to the initial testing requirements of 40 C.F.R. Part 60, Subpart KKKK
as referenced in this permit.
Periodic Testing Requirements
17. This turbine is subject to the periodic testing requirements of 40 C.F.R. Part 60, Subpart
KKKK as referenced in this permit.
18. The operator shall conduct quarterly portable analyzer monitoring of the turbine exhaust
outlet emissions of nitrogen oxides (NOx) and carbon monoxide (CO) to monitor compliance
with the emissions limits. After four (4) consecutive compliant quarterly tests, the frequency
may be reduced to annually. If any of the annual tests fail, the testing frequency shall return
to quarterly until four (4) consecutive compliant quarterly tests are achieved. Results of all
tests conducted shall be kept on site and made available to the Division upon request.
AIRS ID: 123-9B7D-009 Page 4 of 12
me°t OTl Public Health and Environment
Air Pollution Control Division
ADDITIONAL REQUIREMENTS
19. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3,
Part A, II.C)
a. Annually by April 30`h whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of
five (5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO„ per year, a
change in annual actual emissions of one (1) ton per year or more or five percent,
whichever is greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of
five percent or 50 tons per year or more, whichever is less, above the level reported
on the last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above
the level reported on the last APEN submitted to the Division.
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
c. Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
f. Within 14 calendar days of commencing operation of a permanent replacement
turbine under the alternative operating scenario outlined in this permit as Attachment
A. The APEN shall include the specific manufacturer, model and serial number and
horsepower of the permanent replacement turbine, the appropriate APEN filing fee
and a cover letter explaining that the owner or operator is exercising an alternative -
operating scenario and is installing a permanent replacement turbine. Submittal of
an updated APEN is also required for replacement of components if such
replacement results in a change of serial number.
GENERAL TERMS AND CONDITIONS
20. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
21. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide "final" authority for this activity or operation of this source. Final authorization of
the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
AIRS ID: 123-9B7D-009 Page 5 of 12
Coy do e, p,' " e o Public Health and Environment
Air Pollution Control Division
self -certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self -Certify for Final Authorization
section of this permit.
22. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the owner or operator and is conditioned upon conduct of the activity, or
construction, installation and operation of the source, in accordance with this information and
with representations made by the owner or operator or owner or operator's agents. It is valid
only for the equipment and operations or activity specifically identified on the permit.
23. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
24. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the owner or operator, or the Division revokes a permit, the
owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Andy Gruel, P.E.
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Kerr-McGee Oil and Gas Onshore LP.
New permit to allow full-time operation of turbine
which was previously granted APEN-exempt
status due to operation less than 250 hrs/yr.
AIRS ID: 123-9B7D-009
Page 6 of 12
of Public Health and Environment
Air Pollution Control Division
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees
will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of
the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3,
Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are based on
the consumption rates requested in the permit application. These limits may be revised upon request of
the owner or operator providing there is no exceedance of any specific emission control regulation or any
ambient air quality standard. A revised air pollution emission notice (APEN) and complete application
form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any
malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon
as possible, but no later than noon of the next working day, followed by written notice to the Division
addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See:
https://www.colorado.qov/pacific/cdphe/aqcc-reqs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis
of the specific compounds emitted if the source(s) operate at the permitted limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emission
Rate
(Ib/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (lb/yr)
009
Formaldehyde
50000
2022
Yes
N/A
Benzene
71432
9
No
N/A
5) The emission levels contained in this permit are based on the following emission factors:
Point 009:
CAS
Pollutant
Emission
lb/MMBtu
Factors - Uncontrolled
Source
NOx
0.099
Manufacturer
CO
0.121
Manufacturer
VOC
0.035
Manufacturer
SOx
0.00340
AP -42, Table 3.1-2a
PM10
0.0180
Manufacturer
50000
Formaldehyde
0.00288
EPA Memo "Revised HAP Emission
Factors for Stationary Combustion
Turbines" 8/22/03
71432
Benzene
0.000012
AP -42 Table 3.1-3
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this
permit is valid for a term of five years from the date it was received by the Division. A revised APEN
shall be submitted no later than 30 days before the five-year term expires. Please refer to the most
recent annual fee invoice to determine the APEN expiration date for each emissions point associated
with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-
3150.
AIRS ID: 123-9B7D-009
Page 7 of 12
7) This facility is classified as follows:
Public Health and Environment
Air Pollution Control Division
Applicable
Requirement
Status
Operating Permit
Minor Source
PSD and NANSR
Minor Source
MACT YYYY
Minor Source
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at
the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A — Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A — Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
SubpartA— SubpartZ
MACT
63.600-63.1199
Subpart AA — Subpart DDD
MACT
63.1200-63.1439
Subpart EEE — Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ — Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ — Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN — Subpart XXXXX(
9) A self certification form and guidance on how to self -certify compliance as required by this permit may
be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification
AIRS ID: 123-9B7D-009 Page 8 of 12
OT Public Health and Environment
Air Pollution Control Division
ATTACHMENT A:
ALTERNATIVE OPERATING SCENARIOS
TURBINES WITHOUT CONTINUOUS EMISSIONS MONITORING
August 16, 2011
1. Routine Turbine Component Replacements
The following physical or operational changes to the turbines in this permit are not considered a
modification for purposes of NSPS GG, major stationary source NSR/PSD, or Regulation No. 3,
Part B. Note that the component replacement provisions apply ONLY to those turbines subject to NSPS
GG. Neither pre-GG turbines nor post GG turbines (i.e. KKKK turbines) can use those provisions.
1) Replacement of stator blades, turbine nozzles, turbine buckets, fuel nozzles, combustion chambers,
seals, and shaft packings, provided that they are of the same design as the original.
2) Changes in the type or grade of fuel used, if the original gas turbine installation, fuel nozzles, etc. were
designed for its use.
3) An increase in the hours of operation (unless limited by a permit condition)
4) Variations in operating loads within the engine design specification.
5) Any physical change constituting routine maintenance, repair, or replacement.
Turbines undergoing any of the above changes are subject to all federally applicable and stateonly
requirements set forth in this permit (including monitoring and record keeping). If replacement of any of
the components listed in (1) or (5) above results in a change in serial number for the turbine, a letter
explaining the action as well as a revised APEN and appropriate filing fee shall be submitted to the
Division within 30 days of the replacement.
Note that the repair or replacement of components must be of genuinely the same design. Except in
accordance with the Alternate Operating Scenario set forth below, the Division does not consider that this
allows for the entire replacement (or reconstruction) of an existing turbine with an identical new one or one
similar in design or function. Rather, the Division considers the repair or replacements to encompass the
repair or replacement of components at a turbine with the same (or functionally similar) components.
2. Alternative Operating Scenarios
The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of
combustion turbines and turbine components has been reviewed in accordance with the requirements of
Regulation No. 3., Part A, Section IV.A, Operational Flexibility- Alternative Operating Scenarios,
Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source
New Source Review and Prevention of Significant Deterioration, and it has been found to meet all
applicable substantive and procedural requirements. This permit incorporates and shall be considered a
Construction Permit for any turbine or turbine component replacement performed in accordance with this
AOS, and the owner or operator shall be allowed to perform such turbine or turbine component
replacement without applying for a revision to this permit or obtaining a new Construction Permit.
2.1 Turbine Replacement
The following AOS is incorporated into this permit in order to deal with a turbine breakdown or
periodic routine maintenance and repair of an existing onsite turbine that requires the use of a
temporary replacement turbine. "Temporary" is defined as in the same service for 90 operating days
AIRS ID: 123-9B7D-009 Page 9 of 12
Public Health and Environment
Air Pollution Control Division
or less in any 12 month period. "Permanent" is defined as in the same service for more than 90
operating days in any 12 month period. The 90 days is the total number of days that the turbine is in
operation. If the turbine operates only part of a day, that day shall count as a single day towards the
90 -day total. The compliance demonstrations and any periodic monitoring required by this AOS are in
addition to any compliance demonstrations or periodic monitoring required by this permit.
Any permanent turbine replacement under this AOS shall result in the replacement turbine being
considered a new affected facility for purposes of NSPS and shall be subject to all applicable
requirements of that Subpart including, but not limited to, any required Performance Testing.
All replacement turbines are subject to all federally applicable and state -only requirements set forth in
this permit (including monitoring and record keeping).
The results of all tests and the associated calculations required by this AOS shall be submitted to the
Division within 30 calendar days of the test or within 60 days of the test if such testing is required to
demonstrate compliance with the NSPS requirements. Results of all tests shall be kept on site for
five (5) years and made available to the Division upon request.
The owner or operator shall maintain a log on -site and contemporaneously record the start and stop
date of any turbine replacement, the manufacturer, date of manufacture, model number, horsepower,
and serial number of the turbine (s) that are replaced during the term of this permit, and the
manufacturer, model number, horsepower, and serial number of the replacement turbine.
2.1.1 The owner or operator may temporarily replace an existing turbine that is covered by this permit
with a turbine that is the exact same make and model as the existing turbine without modifying
this permit, so long as the temporary replacement turbine complies with the emission limitations
for the existing permitted turbine and other requirements applicable to the original turbine.
Measurement of emissions from the temporary replacement turbine shall be made as set forth
in section 2.2.
2.1.2 The owner or operator may permanently replace the existing turbine that is covered by this
permit with a turbine that is the exact same make and model as the existing turbine without
modifying this permit so long as the permanent replacement turbine complies with the emission
limitations and other requirements applicable to the original turbine as well as any new
applicable requirements for the replacement turbine. Measurement of emissions from the
temporary replacement turbine shall be made as set forth in section 2.2.
2.1.3 An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and
serial number and horsepower of the permanent replacement turbine shall be filed with the
Division for the permanent replacement turbine within 14 calendar days of commencing
operation of the replacement turbine. The APEN shall be accompanied by the appropriate
APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative
operating scenario and is installing a permanent replacement turbine. This AOS cannot be
used for permanent turbine replacement of a grandfathered or permit exempt turbine or a
turbine that is not subject to emission limits. The owner or operator shall agree to pay fees
based on the normal permit processing rate for review of information submitted to the Division
in regard to any permanent turbine replacement.
2.2 Portable Analyzer Testing
Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping
Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss
streamlining the testing requirements.
AIRS ID: 123-9B7D-009 Page 10 of 12
4_:
artmel:, of Public Health and Environment
Air Pollution Control Division
245
SaP rw k.
Note that the testing required by this Condition may be used to satisfy the periodic testing requirements
specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer
testing, this test conducted under the AOS will serve as the quarterly test and an additional portable
analyzer test is not required for another three months).
The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required
by this Condition, if approved in advance by the Division.
The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the
exhaust from the replacement turbine using a portable flue gas analyzer within seven (7) calendar days of
commencing operation of the replacement turbine.
All portable analyzer testing required by this permit shall be conducted using the most current version of
the Division's Portable Analyzer Monitoring Protocol as found on the Division's website. Results of the
portable analyzer tests shall be used to monitor the compliance status of this unit.
For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the
tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or
year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation
the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever
applies.
For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or
concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement
turbine will be subject to, the results of the test shall be converted to the appropriate units as described in
the above -mentioned Portable Analyzer Monitoring Protocol document.
If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the
absence of credible evidence to the contrary, the source may certify that the turbine is in compliance with
both the NOX and CO emission limitations for the relevant time period.
Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if
the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission
limitations, the turbine will be considered to be out of compliance from the date of the portable analyzer
test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or
until the turbine is taken offline.
2.3 Applicable Regulations for Permanent Turbine Replacements
2.3.1 NSPS for Stationary Gas Turbines: 40 CFR 60, Subpart GG
§60.330 Applicability and designation of affected facility.
(a) The provisions of this subpart are applicable to the following affected facilities: All stationary gas
turbines with a heat input at peak load equal to or greater than 10.7 gigajoules (10 million Btu) per
hour. based on the lower heating value of the fuel fired.
(b) Any facility under paragraph (a) of this section which commences construction, modification, or
reconstruction after October 3, 1977, is subject to the requirements of this part except as provided
in paragraphs (e) and (j) of §60.332.
A Subpart GG applicability determination as well as an analysis of applicable Subpart GG
monitoring, recordkeeping, and reporting requirements for the permanent turbine replacement shall
be included in any request for a permanent turbine replacement
AIRS ID: 123-9B7D-009 Page 11 of 12
Public Health and Environment
Air Pollution Control Division
Note that under the provisions of Regulation No. 6. Part B, Section I.B. that Relocation of a source
from outside of the State of Colorado into the State of Colorado is considered to be a new source,
subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to
Colorado becomes equivalent to the commence construction date for purposes of determining the
applicability of NSPS GG requirements).
2.3.2 NSPS for Stationary Combustion Turbines: 40 CFR 60, Subpart KKKK
§60.4305 Does this subpart apply to my stationary combustion turbine?
(a) If you are the owner or operator of a stationary combustion turbine with a heat input at peak load
equal to or greater than 10.7 gigajoules (10 MMBtu) per hour, based on the higher heating value of
the fuel, which commenced construction, modification, or reconstruction after February 18, 2005,
your turbine is subject to this subpart. Only heat input to the combustion turbine should be included
when determining whether or not this subpart is applicable to your turbine. Any additional heat input
to associated heat recovery steam generators (HRSG) or duct burners should not be included when
determining your peak heat input. However, this subpart does apply to emissions from any
associated HRSG and duct burners.
(b) Stationary combustion turbines regulated under this subpart are exempt from the requirements
of subpart GG of this part. Heat recovery steam generators and duct burners regulated under this
subpart are exempted from the requirements of subparts Da, Db, and Dc of this part.
A Subpart KKKK applicability determination as well as an analysis of applicable Subpart KKKK
monitoring, recordkeeping, and reporting requirements for the permanent turbine replacement shall
be included in any request for a permanent turbine replacement
Note that under the provisions of Regulation No. 6. Part B, Section I.B. that Relocation of a source
from outside of the State of Colorado into the State of Colorado is considered to be a new source,
subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to
Colorado becomes equivalent to the commence construction date for purposes of determining the
applicability of NSPS KKKK requirements).
2.4 Additional Sources
The replacement of an existing turbine with a new turbine is viewed by the Division as the installation of a
new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an
advanced construction permit review. The AOS cannot be used for additional new emission points for any
site; a turbine that is being installed as an entirely new emission point and not as part of an AOS-approved
replacement of an existing onsite turbine has to go through the appropriate Construction/Operating
permitting process prior to installation
AIRS ID: 123-9B7D-009 Page 12 of 12
Construction Permit Application
Preliminary Analysis Summary
Section 1 — Applicant Information
Company Name:
Kerr-McGee Oil and Gas Onshore LP
Permit Number:
13WE2977
Source Location:
Central Oil Stabilization Facility — Section 34 T3N R65W, Weld County
Equipment Description:
Point 009: One (1) turbine for back-up power (make: Solar, model:
Taurus 60-7300S, sn: TBD).
AIRS ID:
123-9B7D-009
Date:
06/07/2016 (Application rec'd 6/8/15; delayed by login)
Review Engineer:
Andy Gruel
Control Engineer:
Stefanie Rucker
Section 2 — Action Completed
Grandfathered
Modification
APEN Required/Permit Exempt
X
CP1
Transfer of Ownership
APEN Exempt/Permit Exempt
Section 3 —Applicant Completeness Review
Was the correct APEN submitted for this source type?
X
Yes
No
Is the APEN signed with an original signature?
X
Yes
No
Was the APEN filled out completely?
Yes
X
No
Did the applicant submit all required paperwork?
X
Yes
No
Did the applicant provide ample information to determine emission rates?
X
Yes
No
If you answered "no' to any of the above, when did you mail an
Information Request letter to the source?
6/22/2016 — emailed to request
revised APEN to correct typo errors.
Received revised APEN 6/23/16.
Received NCRP form 6/28/16.
On what date was this application complete?
6/28/16
Section 4 — Source Description
AIRS Point
Equipment Description
009
Point 009: One (1) turbine for back-up power (make: Solar, model: Taurus 60-
7300S, sn: TBD). The turbine is fueled by field gas.
Is this a portable source?
Yes
X
No
Is this location in a non -attainment area for any criteria
pollutant?
X
Yes
No
If "yes", for what pollutant?
PKo
CO
X
Ozone
Is this location in an attainment maintenance area for
any criteria pollutant?
Yes
X
No
If "yes", for what pollutant?
(Note: These pollutants are subject to minor source
RACT per Regulation 3, Part B, Section III.D.2)
PM,o
CO
Ozone
Is this source located in the 8 -hour ozone non -
attainment region? (Note: If "yes" the provisions of
Regulation 7, Sections XII and XVII.C may apply)
x
Yes
No
Page 1
Section 5— Emission Estimate Information
AIRS Point
Emission Factor Source
009
PM, NOx, VOC, CO: Manufacturer
SOx: AP -42 3.1-2a
Did the applicant provide actual process data for the emission inventory?
Yes
X
No
Basis for Potential to Emit (PTEI
AIRS Point
Process Consumption/Throughput/Production
009
540 MMscf/yr
(80.1 MMBtu/hr * 8760 hr/yr / 1300 MMBtu/MMscf )
Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory)
AIRS Point
Process Consumption/Throughput/Production
Data Year
No actual emissions reported
Basis for Permitted Emissions (Permit Limitsi
AIRS Point
Process Consumption/Throughput/Production
009
540 MMscf/yr
Does this facility use control devices?
Yes
X
No
AIRS Point
Process
Control Device Description
% Reduction Granted
This emissions point is uncontrolled.
Section 6 — Emission Summary (tons per year)
Point
NO,
VOC
CO
SOx
PM10
Single HAP
Total
HAP
PTE:
009
34.75
12.29
42.47
1.19
6.32
1.01
(formaldehyde)
1.07
Uncontrolled point
source emission rate:
009
34.75
12.29
42.47
1.19
6.32
1.01
(formaldehyde)
1.074
Controlled point
source emission rate:
009
N/A — Point is uncontrolled
Section 7 — Non -Criteria / Hazardous Air Pollutants
Pollutant
CAS #
Uncontrolled
Emission Rate
(Ib/l r)
Are the
emissions
reportable?
Controlled Emission
Ib r
Rate ( Y )
Point 009 "TUR-1"
Formaldehyde
50000
2022
Yes
N/A
Note: Regulation 3, Part A, Section II.B.3.b APEN emission reporting requirements for non -criteria air
pollutants are based on potential emissions without credit for reductions achieved by control
devices used by the operator.
Section 8 —Testing Requirements
Will testing be required to show compliance with any emission rate or regulatory
standard?
X
Yes
No
If "yes", complete the information listed below
AIRS Point
Process
Pollutant
Regulatory Basis
Test Method
009
NSPS KKKK
Page 2
Section 9 — Source Classification
What is this facility classification?
X
True
Minor
Synthetic
Minor
Major
Classification relates to what programs?
X
Title V
PSD
X
NA NSR
MACT
Is this a modification to an existing permit?
Yes
X
No
If "yes" what kind of modification?
Minor
Synthetic
Minor
Major
Section 10 — Public Comment
Does this permit require public comment per CAQCC Regulation 3?
X
Yes
No
If "yes", for which pollutants? Why? VOC
For Reg. 3, Part B, III.C.1.a emissions increase > 25 tpy NOx in NAA
X
Yes
No
For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)?
Yes
No
For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)?
Yes
No
Section 11 — Modeling
Is modeling required to demonstrate compliance with National Ambient
Air Quality Standards (NAAQS)?
If "yes", for which pollutants? Why?
Yes
X
No
AIRS Point
Section 12 — Regulatory Review
Regulation 1 - Particulate Smoke Carbon Monoxide and Sulfur Dioxide
009
Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or
operator of a source shall allow or cause the emission into the atmosphere of any air
pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive
opacity readings taken at 15 -second intervals for six minutes. The approved reference test
method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix
A (July, 1992)) in all subsections of Section II. A and B of this regulation.
Regulation 2 — Odor
009
Section I.A - No person, wherever located, shall cause or allow the emission of odorous
air contaminants from any single source such as to result in detectable odors which are
measured in excess of the following limits: For areas used predominantly for residential or
commercial purposes it is a violation if odors are detected after the odorous air has been
diluted with seven (7) or more volumes of odor free air.
Regulation 3 - APENs, Construction Permits, Operating Permits, PSD
009
Part A-APEN Requirements
Applicant is required to file an APEN since emissions exceed 1 tons per year of criteria
pollutants.
009
Part B — Construction Permit Exemptions
Applicant is required to obtain a permit since criteria pollutant VOC emissions from this
facility are greater than the 2.0 TPY threshold (Reg. 3, Part B, Section II.D.3.a)
Regulation 6 - New Source Performance Standards
009
NSPS KKKK: This is a stationary source turbine with heat input greater than 10
MMBtu/hr. Therefore, Subpart KKKK is applicable. The operator must comply with the
following:
Standard §60.4320(a) -Table 1; [NOx emission standard]
§60.4320(a) -(b);
§60.4325;
§60.4333(a);
§60.4400(a) [ initial performance test as required by §60.8, annual NOx performance
testing];
]§60.4400(b): (b)(1), (b)(4), (b)(6)
Page 3
Regulation 7 — Volatile Organic Compounds
009
None
Regulation 8 — Hazardous Air Pollutants
009
None
Section 13—Aerometric Information Retrieval System Coding Information
Point
Process
Process Description
Emission
Factor
Pollutant /
CAS #
Fugitive
(Y/N)
Emission Factor
Source
Control
o
(/o)
009
01
Turbine for back-up
power generation
45.5
lb/MMscf
VOC
No
Manufacturer
0
128.7
lb/MMscf
NOx
No
Manufacturer
0
157.3
Ib/MMscf
CO
No
Manufacturer
0
4.42
lb/MMscf
SOx
No
AP -42 3.1-2a
0
23.4
Ib/MMscf
PM10
No
Manufacturer
0
3'744
Ib/MMscf
Formaldehyde
No
EPA Memo
0
SCC
2-01-002-01 Turbine for Electricity Generation, fueled by Natural Gas
Section 14 — Miscellaneous Application Notes
AIRS Point
009
Turbine ("TUR-1")
This point was previously issued an APEN-exempt/Permit-exempt letter due to operation less than 250 hours per
year. This application requests that the turbine be operated full-time.
In this application, an APEN is required because criteria pollutant emissions exceed 1 tpy in non -attainment area; a
permit is required because uncontrolled VOC emissions are projected to exceed 2 tpy in non -attainment area.
NOx, VOC, and CO emission factors were provided by the applicant based on a manufacturer's performance test run
May 19 2015. PM10/2.5 emission factors were based on a product information letter developed by the manufacturer
("PIL 171 Revision 3", dated 1 June 2012).
Formaldehyde emission factor was estimated from Table 16 of EPA document "Revised HAP Emission Factors for
Stationary Combustion Turbines, OAR -2002-0060". Emission factors for all other HAPs were estimated from AP -42
Table 3.1-3. Formaldehyde is the only HAP with emissions above reportable limits.
Emissions from the turbine are not controlled.
Page 4
2
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[Provide Facility Equipment ID to identify how this equipment is referenced within your organization.'
nested Action (check applicable request boxes)
Section 02 — Re
Section 01 —Administrative Information
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mitations. Requested level should consider process growth over the next five years.
2015-5-26 COSF Turbine APEN.doc
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FORM APCD-200
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Permit Number:
Section 05 — Emission Release Information (Attach a separate sheet with relevant information in the event of multiple releases; provide datum & either Lat/Long or UTM)
❑ Vertical with obstructing raincap
Direction of outlet (check one):
Exhaust Opening Shape & Size (check one):
Information
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Section 06 — Combustion E
Taurus 60-73005
Company equipmen
Section 07 — Emissions Inventory Information & Emission Control Information
Estimation
Method or
Emission Factor
Source
Manufacturer
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Please use the APCU Non -Criteria Reportable Air Pollutant Addendum form to report pollutants nut listed above.
Requested Permitted
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Uncontrolled
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Form Revision Date: A
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