HomeMy WebLinkAbout20163255.tiffCOLORADO
Department 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
October 7, 2016
Dear Sir or Madam:
RECEIVED
OCT 1 7 2016
WELD COUNTY
COMMISSIONERS
On October 13, 2016, the Air Pollution Control Division will begin a 30 -day public notice period for
Colorado Interstate Gas Company - Cheyenne Compressor Station. A copy of this public notice and
the public comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: 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.cotorado.gov/cdphe
��f7� 1 i L John W. Hickentooper, Governor ; Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
`` cc,PLC mm(yP) NLC Pa,)
Pt )C ER/C1-1/3m CK)
1,0/09/Ico IO/ (Cl/ 1 Co
2016-3255
Air Pollution Control Division
Notice Of A Proposed Renewal Title V Operating Permit
Warranting Public Comment
Website Title: Colorado Interstate Gas Company - Cheyenne Compressor Station - Weld County
Notice Period Begins: October 13, 2016
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: Colorado Interstate Gas Company
370 Van Gordon St
Lakewood, CO 80228
Facility: Cheyenne Compressor Station
Section 5, T11N, R66W
Weld County
Colorado
Colorado Interstate Gas Company has applied to renew the Operating Permit for the Cheyenne Compressor
Station in Weld County, CO. This facility is a mainline compressor station. There has been no modification.
There has been no change in emissions. A copy of the application, including supplemental information, the
Division's analysis, and a draft of the Renewal Operating Permit 95OPWE090 have been filed with the Weld
County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's
website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. The Division has made a
preliminary determination of approval of the application. Based on the information submitted by the
applicant, the Division has prepared the draft renewal operating permit for approval. Any interested person
may contact Thang Nghiem of the Division at (303) 692-3256 to obtain additional information. Any interested
person may submit written comments to the Division concerning 1) the sufficiency of the preliminary
analysis, 2) whether the permit application should be approved or denied, 3) the ability of the proposed
activity to comply with applicable requirements, 4) the air quality impacts of, alternatives to, and control
technology required on the source or modification, and 5) any other appropriate air quality considerations.
Any interested person may submit a written request to the Division for a public comment hearing before the
Colorado Air Quality Control Commission (Commission) to receive comments regarding the concerns listed
above as well as the sufficiency of the preliminary analysis and whether the Division should approve or deny
the permit application. If requested, the hearing will be held before the Commission within 60 days of its
receipt of the request for a hearing unless a longer time period is agreed upon by the Division and the
applicant. The hearing request must: 1) identify the individual or group requesting the hearing, 2) state his
or her address and phone number, and 3) state the reason(s) for the request, the manner in which the
person is affected by the proceedings, and an explanation of why the person's interests are not already
adequately represented. The Division will receive and consider the written public comments and requests
for any hearing for thirty calendar days after the date of this Notice.
COLORADO
Colorado Department
of Public Health
and Environment
OPERATING PERMIT
Cheyenne Compressor Station
First Issued: September 1, 1998
Renewed: DRAFT
AIR POLLUTION CONTROL DIVISION
COLORADO OPERATING PERMIT
FACILITY NAME:
FACILITY ID:
RENEWED:
EXPIRATION DATE:
MODIFICATIONS:
Cheyenne
Compressor Station
1230051
DRAFT
DRAFT
See Appendix F of Permit
OPERATING PERMIT NUMBER
95OPWE090
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:
Colorado Interstate Gas Company
P.O. Box 1087
Colorado Spring, CO 80944
INFORMATION RELIED UPON
Operating Permit Renewal Application
Received:
And Additional Information Received:
PLANT SITE LOCATION:
Section 5, Ti 1N, R66W (-j 4 miles North of Rockport)
Weld County
February 18, 2010
March 14, March 29, and October 3 - 2016
Nature of Business: Natural Gas Transmission
Primary SIC: 4922
RESPONSIBLE OFFICIAL (PRIMARY) FACILITY CONTACT PERSON
Name:
Title:
Phone:
Matt Mask
Director of Operations
(719) 329-5637
RESPONSIBLE OFFICIAL (SECONDARY)
Name:
Title:
Phone:
Ken Grubb
VP of Operations
(713) 369-8763
Name:
Title:
Phone:
Susan Riebe
Air Permitting and Compliance Engineer
(303) 914-4597
SUBMITTAL DEADLINES
Semi -Annual Monitoring Periods: DRAFT
Semi -Annual Monitoring Report: DRAFT
First Annual Compliance Period: DRAFT
Subsequent Annual Compliance Periods: DRAFT
Annual Compliance Certification: DRAFT
Note that the Semi -Annual Monitoring Reports and Annual Compliance Certifications 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/certifications.
TABLE OF CONTENTS:
SECTION I - General Activities and Summary 1
1. Permitted Activities 1
2. Alternative Operating Scenarios 2
3. Prevention of Significant Deterioration (PSD) 2
4. Accidental Release Prevention Program (112(r)) 2
5. Compliance Assurance Monitoring (CAM) 2
6. Summary of Emission Units 3
SECTION II - Specific Permit Terms 4
1. CG -1/S001, CG -2/S002, CG -3/S003 and CG -4/S004: Cooper 2 -Cycle Clean Burn ICEs, S/N:
48534, 48533, 48532 and 48531 4
2. WIC CG -1/S006 and WIC CG -2/S007: Cooper 2 -Cycle Clean Burn ICEs, S/N: 48867 and
48868 6
3. WIC CG -7301: Cooper 2 Cycle Clean Burn ICE, S/N: 46291 8
4. WIC CG -7401: Cooper 2 Cycle Clean Burn ICE, S/N: 48468 10
5. CG -7501/S008: Caterpillar, 4 -Cycle Low NOx ICE, Equipped with Oxidation Catalyst S/N:
4ZS00310 12
6. CG -7601/S009: Solar Taurus 60-7800S, Combustion Turbine, S/N: 1255T 16
7. CG -7701/S010: Caterpillar, 4 -Cycle Low NOx ICE, Equipped with Oxidation Catalyst S/N:
BEN00254 22
8. Portable Monitoring (06/26/2014 version) 25
9. Reciprocating Internal Combustion Engine (RICE) MACT Requirements 26
SECTION III - Permit Shield 34
1. Specific Non -Applicable Requirements 34
2. General Conditions 34
3. Streamlined Conditions 35
SECTION IV - General Permit Conditions 36
1. Administrative Changes 36
2. Certification Requirements 36
3. Common Provisions 36
4. Compliance Requirements 40
5. Emergency Provisions 40
6. Emission Controls for Asbestos 41
7. Emissions Trading, Marketable Permits, Economic Incentives 41
8. Fee Payment 41
9. Fugitive Particulate Emissions 41
10. Inspection and Entry 42
11. Minor Permit Modifications 42
12. New Source Review 42
13. No Property Rights Conveyed 42
14. Odor 42
15. Off -Permit Changes to the Source 42
16. Opacity 43
17. Open Burning 43
18. Ozone Depleting Compounds 43
19. Permit Expiration and Renewal 43
TABLE OF CONTENTS:
20. Portable Sources 43
21. Prompt Deviation Reporting 43
22. Record Keeping and Reporting Requirements 44
23. Reopenings for Cause 45
24. Section 502(b)(10) Changes 45
25. Severability Clause 45
26. Significant Permit Modifications 45
27. Special Provisions Concerning the Acid Rain Program 46
28. Transfer or Assignment of Ownership 46
29. Volatile Organic Compounds 46
30. Wood Stoves and Wood burning Appliances 47
APPENDIX A - Inspection Information 1
Directions to Plant: 1
Safety Equipment Required: 1
Facility Plot Plan. 1
List of Insignificant Activities: 1
APPENDIX B 1
Reporting Requirements and Defmitions 1
Monitoring and Permit Deviation Report - Part I 5
Monitoring and Permit Deviation Report - Part II 6
Monitoring and Permit Deviation Report - Part III 8
APPENDIX C 1
Required Format for Annual Compliance Certification Reports 1
APPENDIX D 1
Notification Addresses - February 5, 2014 Version 1
APPENDIX E 1
Permit Acronyms 1
APPENDIX F 1
Permit Modifications 1
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 1
SECTION I - General Activities and Summary
1. Permitted Activities
1.1 This facility is a mainline compressor station. Its main function is to compress and transmit
natural gas from the Wyoming area to the Front Range area located in Colorado. This is
achieved by using eight (8) internal combustion engine driven horizontal compressors.
In the summer of 2003 construction commenced on an additional internal combustion engine and
turbine, both driving compressors as part of the Front Range Expansion Project (FREP). The
FREP supplies gas to the Colorado Front Range and a power plant in Colorado Springs.
In the summer of 2004, construction commenced on the Cheyenne Plains Project (CPP), this
additional expansion is to support a new pipeline transporting gas east into Kansas. The CPP
equipment is addressed in a separate Title V operating permit (05OPWE281) issued on April 1,
2014.
The facility is located approximately 4 miles north of Rockport in Weld County on Highway 85.
The area in which the plant operates is designated as attainment for all criteria pollutants. There
are two affected states within 50 miles of the plant: Wyoming and Nebraska. The following
Federal Class I designated area is within 100 kilometers of the plant: Rocky Mountain National
Park & Rawah Wilderness.
1.2 Until such time as this peiniit expires or is modified or revoked, the permittee is allowed to
discharge air pollutants from this facility in accordance with the requirements, limitations, and
conditions of this permit.
1.3 This Operating Permit incorporates the applicable requirements contained in the underlying
construction permits, and does not affect those applicable requirements, except as modified
during review of the application or as modified subsequent to permit issuance using the
modification procedures found in Regulation No. 3, Part C. These Part C procedures meet all
applicable substantive New Source Review requirements of Part B. Any revisions made using
the provisions of Regulation No. 3, Part C shall become new applicable requirements for
purposes of this operating permit and shall survive reissuance. This peiuiit incorporates the
applicable requirements (except as noted in Section II) from the following construction permits:
11WE 631-1, 11WE 631-2, 11WE631-3, 11WE 631-4, 13WE536-1, 13WE526-2, 97WE0032,
98WE0030, 03WE0184, 03WE0185 and 03WE0912.
1.4 All conditions in this permit are enforceable by US Environmental Protection Agency, Colorado
Air Pollution Control Division (hereinafter Division) and its agents, and citizens unless
otherwise specified. State -only enforceable conditions are: Permit Condition Number(s):
Section IV - 14 and 18 (as noted).
1.5 All information gathered pursuant to the requirements of this permit is subject to the
Recordkeeping and Reporting requirements listed under Condition 22 of the General Conditions
in Section IV of this permit. Either electronic or hard copy records are acceptable.
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 2
2. Alternative Operating Scenarios
2.1 The permittee shall be allowed to make the following changes to its method of operation without
applying for a revision of this permit.
2.1.1 No separate operating scenarios have been specified.
3. Prevention of Significant Deterioration (PSD)
3.1 This facility is located in an area designated attainment for all pollutants. It is categorized as a
major stationary source (Potential to Emit > 250 tons per year for NOx, CO and VOC). Future
modifications at this facility resulting in a significant net emissions increase (see Regulation No.
3, Part D, Section II.A.27 and 44) for any pollutant as listed in Regulation No. 3, Part D, Section
II.A.44 or a modification which is major by itself (i.e. a Potential to Emit of > 250 TPY of any
pollutant listed in Regulation No. 3, Part D, Section II.A.44) may result in the application of the
PSD review requirements.
3.2 The following Operating Permits are associated with this facility for purposes of determining
applicability of Prevention of Significant Deterioration regulations: 05OPWE281 (Cheyenne
Plains Gas Pipeline Company).
4. Accidental Release Prevention Program (112(r))
4.1 Based on the information provided by the applicant, the facility is not subject to the provisions of
the Accidental Release Prevention Program (section 112(r) of the Federal Clean Air Act).
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:
None.
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 3
6. Summary of Emission Units
6.1 The emissions units regulated by this permit are the following:
Emission Unit
Number/Facility
Equipment ID
AIRS
Stack
Number
Stack ID
Description
Pollution
Control
Device
E001/
CIG CG -1
001
S001
Cooper 2 -cycle Clean Burn Internal Combustion Engine, Model
GMVH-12, S/N: 48534, 7250 Btu/hp-hr, 2700 hp, natural gas fired.
None
E002/
CIG CG -2
001
S002
Cooper 2 -cycle Clean Burn Internal Combustion Engine, Model
GMVH-12, S/N: 48533, 7250 Btu/hp-hr, 2700 hp, natural gas fired.
None
E003/
CIG CG -3
001
S003
Cooper 2 -cycle Clean Burn Internal Combustion Engine, Model
GMVH-12, S/N: 48532, 7250 Btu/hp-hr, 2700 hp, natural gas fired.
None
E004/
CIG CG -4
001
S004
Cooper 2 -cycle Clean Burn Internal Combustion Engine, Model
GMVH-12, S/N: 48531, 7250 Btu/hp-hr, 2700 hp, natural gas fired.
None
E005/
WIC CG -1
007
S006
Cooper 2 -cycle Clean Burn Internal Combustion Engine, Model
GMVH-12, S/N: 48867, 6799.2 Btu/hp-hr, 2700 hp, natural gas fired.
None
E006/
WIC CG -2
008
S007
Cooper 2 -cycle Clean Burn Internal Combustion Engine, Model
GMVH-12, S/N: 48868, 6799.2 Btu/hp-hr, 2700 hp, natural gas fired.
None
E-7301/
WIC CG -7301
011
5011
Cooper 2 -cycle Clean Burn Internal Combustion Engine, Model
GMVH-12C2, S/N: 46291, 6950 Btu/hp-hr, 2700 hp, natural gas fired.
None
E-7401/
WIC CG -7401
012
S012
Cooper 2 -cycle Clean Burn Internal Combustion Engine, Model
GMVH-12C2, S/N: 48468, 6975 Btu/hp-hr, 2700 hp, natural gas fired.
None
E008/
FR CG -7501
013
S008
Caterpillar 4 -Cycle Lean Burn Internal Combustion Engine, Model
No. 3606 TALE, S/N: 4ZS00310, natural gas fired. The engine is
rated at 1,775 hp and 13 mmBtu/hr.
Oxidation
Catalyst
E009/
FR CG -7601
014
S009
Solar Taurus Natural Gas Fired Turbine, Model No. 60-7800S, S/N:
1255T, natural gas fired turbine. The turbine is rated at 6,536 hp and
58 mmBtu/hr.
Dry Low NOx
Combustion
System
(SoLoNOx II)
E010/
FR CG -7701
017
S010
One (1) Caterpillar 4 -cycle Lean Burn, Model No. G3608 TALE, S/N:
BEN00254, natural gas fired internal combustion engine. The engine
is rated at 2,443 hp and 16.47 mmBtu/hr.
Oxidation
Catalyst
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 4
SECTION II - Specific Permit Terms
1. CG -1/S001, CG -2/S002, CG -3/S003 and CG -4/S004: Cooper 2 -Cycle Clean Burn ICEs, S/N:
48534, 48533, 48532 and 48531
Parameter
Permit
Condition
Number
Limitations for each engine
Short Term Long Term
Compliance
Emission
Factor
Monitoring
Method Interval
NOx
.,te 'Y
82.1 tpy
0.96 lb/MMBtu
Recordkeeping &
Calculation,
Monthly
CO
1.1
26.3 tpy
0.31 lb/MMBtu
Portable Flue Gas
Each
VOC
36.2 tpy
0.42 lb/MMBtu
Analyzer
Calendar
Quarter
Natural gas
consumption
1.2
181.3 MMscf/yr
Recordkeeping
Monthly
Heat Content
1.3
' „
ASTM Methods or
in -Line Gas
Chromatograph
Semi -Annual
Opacity
1.4
Not to exceed 20%
Fuel Restriction
Only Natural
Gas is Used
as Fuel
1.1
Emissions of Nitrogen Oxide, Carbon Monoxide and Volatile Organic Compound emissions
from each engine shall not exceed the limitations stated above (Colorado Construction Permits
11WE631-1 through 4, as modified under the provisions of Section I, Condition 1.3 to remove
the construction permit short-term emission limits). Compliance with the emission limitations
shall be monitored as follows:
Except as provided below, the emission factors listed above (from the manufacturer,
converted to lb/MMBtu based on an engine heat rate of 7,250 Btu/hp-hr) have been
approved by the Division and shall be used to calculate emissions from these engines
as follows:
Monthly emissions shall be calculated for each engine by the end of the subsequent
month using the above emission factors, the monthly fuel consumption and the lower
heating value of the fuel, as specified in Condition 1.3, in the equation below:
tons/month = JEF (lbs/MMBtu)1 x [Fuel Use (MMscf/month)1 x [Heat Content of Fuel (MMBtu/MMscfl
2000 lbs/ton
A twelve-month rolling total of emissions from each engine shall be maintained to
monitor compliance with the annual limitation. Each month a new twelve month total
shall be calculated using the previous twelve months' data.
If a reference method test is conducted under the provisions of Condition 1.1.2, and
the results of the testing show that either the NOx or CO emission rates/factors are
greater than the emission rates/factors listed above, the permittee shall apply for a
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 5
modification to this permit to reflect, at a minimum, the higher emission rates/factors
within 60 days of the completion of the reference method test.
1.1.2 Portable Monitoring shall be conducted each calendar quarter in accordance with the
requirements in Condition 8.
1.2 Natural gas use for each engine shall not exceed the annual limitation stated above (Colorado
Construction Permits 11WE631-1 through 4, as modified under the provisions of Section I,
Condition 1.3 to remove the short-term fuel use limits). Natural gas use shall be recorded
monthly using the facility natural gas meter. Natural gas consumption for each engine shall be
allocated according to size, hours of operation and other records as necessary and recorded in a
log to be made available to the Division upon request. A twelve month rolling total shall be
maintained for each engine to monitor compliance with the annual limitation. Each month, a
new twelve month total shall be calculated using the previous twelve months data.
1.3 The Btu content of the natural gas used to fuel these engines shall be verified semi-annually
using the appropriate ASTM Methods or equivalent, if approved in advance by the Division. In
lieu of collecting a sample, the Btu content of the natural gas may be determined using the in -line
gas chromatograph to determine the gas composition and ASTM Method 3588 to calculate the
Btu content. The Btu content of the gas shall be calculated using the average composition of the
gas over the semi-annual period and assuming the composition of C6+ constituents is as follows:
50% C6, 25% C7 and 25% Cg. The Btu content of the natural gas shall be based on the lower
heating value of the fuel. Calculations of monthly emissions shall be made using the heat
content derived from the most recent required analysis.
1.4 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air
pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section A.II.1). The
opacity standard applies to each engine. In the absence of credible evidence to the contrary,
compliance with the 20% opacity limit shall be presumed since only natural gas is pei witted to
be used as fuel for these engines. The permittee shall maintain records that verify that only
natural gas is used as fuel.
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 6
2. WIC CG -1/S006 and WIC CG -2/S007: Cooper 2 -Cycle Clean Burn ICEs, S/N: 48867 and 48868
Parameter
Permit
Condition
Number
Limitations for each engine
Short Term Long Term
Compliance
Emission Factor
Monitoring
Method Interval
NOx
CO
VOC
2.1
N/A
82.1 tpy
1.02 lb/MMBtu
Recordkeeping &
Calculation
Monthly
N/A
26.3 tpy
0.33 lb/MMBtu
N/A
36.2 tpy
0.45 lb/MMBtu
Portable Flue Gas
Analyzer
Each
Calendar
Quarter
Natural gas
consumption
Heat Content
2.2
2.3
Opacity
2.4
170 MMscf/yr
Not to exceed 20%
Recordkeeping
ASTM Methods
or In -Line Gas
Chromatograph
Monthly
Semi -Annual
Fuel Restriction
Only Natural
Gas is Used
as Fuel
2.1 Nitrogen Oxide, Carbon Monoxide and Volatile Organic Compound emissions from each
engine shall not exceed the limitations stated above (Colorado Construction Permits 13WE536-
1, 2, as modified under the provisions of Section I, Condition 1.3 to remove the short-term
emission limits). Compliance with the emission limitations shall be monitored as follows:
2.1.1 Except as provided below, the emission factors listed above (from the manufacturer,
converted to lb/MMBtu based on an engine heat rate of 6799.2 Btu/hp-hr) have been
approved by the Division and shall be used to calculate emissions from these engines
as follows:
Monthly emissions shall be calculated for each engine by the end of the subsequent
month using the above emission factors, the monthly natural gas consumption and the
lower heating value of the fuel, as specified in Condition 2.3, in the equation below:
tons/month = JEF (1bs/MMBtu)1 x [Fuel Use (MMscf/month)1 x [Heat Content of Fuel (MMBtu/MMscffl
2000 lbs/ton
A twelve-month rolling total of emissions from each engine shall be maintained to
monitor compliance with the annual limitation. Each month a new twelve month total
shall be calculated using the previous twelve months' data.
If a reference method test is conducted under the provisions of Condition 2.1.2, and
the results of the testing show that either the NOx or CO emission rates/factors are
greater than the emission rates/factors listed above, the permittee shall apply for a
modification to this permit to reflect, at a minimum, the higher emission rates/factors
within 60 days of the completion of the reference method test.
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 7
2.1.2 Portable Monitoring shall be conducted each calendar quarter in accordance with the
requirements in Condition 8.
2.2 Natural gas use for each engine shall not exceed the annual limitations stated above (Colorado
Construction Permits 13WE536-1, 2, as modified under the provisions of Section I, Condition
1.3 to remove the short-term fuel use limits). Natural gas use shall be recorded monthly using
the facility fuel meter. Natural gas consumption for each engine shall be allocated according to
size, hours of operation and other records as necessary and recorded in a log to be made available
to the Division upon request. A twelve month rolling total shall be maintained for each engine
to monitor compliance with the annual limitation. Each month, a new twelve month total shall
be calculated using the previous twelve months data.
2.3 The Btu content of the natural gas used to fuel these engines shall be verified semi-annually
using the appropriate ASTM Methods or equivalent, if approved in advance by the Division. In
lieu of collecting a sample, the Btu content of the natural gas may be determined using the in -line
gas chromatograph to determine the gas composition and ASTM Method 3588 to calculate the
Btu content. The Btu content of the gas shall be calculated using the average composition of the
gas over the semi-annual period and assuming the composition of C6+ constituents is as follows:
50% C6, 25% C7 and 25% C8. The Btu content of the natural gas shall be based on the lower
heating value of the fuel. Calculations of monthly emissions shall be made using the heat
content derived from the most recent required analysis.
2.4 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air
pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section A.II.1). The
opacity standard applies to each engine. In the absence of credible evidence to the contrary,
compliance with the 20% opacity limit shall be presumed since only natural gas is permitted to
be used as fuel for these engines. The permittee shall maintain records that verify that only
natural gas is used as fuel.
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 8
3. WIC CG -7301: Cooper 2 Cycle Clean Burn ICE, S/N: 46291
Parameter
Permit
Condition
Number
Limitations
Short Term Long Term
Compliance
Emission Factor
Monitoring
Method Interval
NOx
CO
VOC
3.1
39.5 tpy
0.48 lb/MMBtu
Recordkeeping
& Calculation
Monthly
39.0 tpy
0.48 lb/MMBtu
30.0 tpy
0.36 lb/MMBtu
Portable Flue
Gas Analyzer
Each Calendar
Quarter
Natural gas
consumption
3.2
Heat Content
3.3
Opacity
3.4
173.8 MMscf/yr
Not to exceed 20%
Recordkeeping •
ASTM Methods
or in -Line Gas
Chromatograph
Fuel Restriction
Monthly
Semi -Annual
Only Natural
Gas is Used as
Fuel
3.1 Emissions of Nitrogen Oxide, Carbon Monoxide and Volatile Organic Compound emissions
shall not exceed the limitations stated above (Colorado Construction Permit 97WE0032, as
modified under the provisions of Section I, Condition 1.3 to remove the short-term emission
limits). Compliance with the emission limitations shall be monitored as follows:
3.1.1 Except as provided below, the emission factors listed above (from the manufacturer,
converted to lb/MMBtu based on an engine heat rate of 6,950 Btu/hp-hr) have been
approved by the Division and shall be used to calculate emissions from this engine as
follows:
Monthly emissions shall be calculated by the end of the subsequent month using the
above emission factors, the monthly fuel consumption and the lower heating value of
the fuel, as specified in Condition 3.3, in the equation below:
tons/month = [EF (lbs/MMBtu)l x [Fuel Use (MMscf/month)l x (Heat Content of Fuel (MMBtu/MMscf)1
2000 lbs/ton
A twelve-month rolling total of emissions shall be maintained to monitor compliance
with the annual limitation. Each month a new twelve month total shall be calculated
using the previous twelve months' data.
If a reference method test is conducted under the provisions of Condition 3.1.2, and
the results of the testing show that either the NOx or CO emission rates/factors are
greater than the emission rates/factors listed above, the peirrtittee shall apply for a
modification to this permit to reflect, at a minimum, the higher emission rates/factors
within 60 days of the completion of the reference method test.
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 9
3.1.2 Portable Monitoring shall be conducted each calendar quarter in accordance with the
requirements in Condition 8.
3.2 Natural gas use for this engine shall not exceed the annual limitation stated above (Colorado
Construction Permit 97WE0032, as modified under the provisions of Section I, Condition 1.3 to
remove the short -tent' fuel use limit). Natural gas use shall be recorded monthly using the
facility fuel meter. Natural gas consumption for each engine shall be allocated according to size,
hours of operation and other records as necessary and recorded in a log to be made available to
the Division upon request. A twelve month rolling total shall be maintained to monitor
compliance with the annual limitation. Each month, a new twelve month total shall be calculated
using the previous twelve months data.
3.3 The Btu content of the natural gas used to fuel this engine shall be verified semi-annually using
the appropriate ASTM Methods or equivalent, if approved in advance by the Division. In lieu of
collecting a sample, the Btu content of the natural gas may be determined using the in -line gas
chromatograph to determine the gas composition and ASTM Method 3588 to calculate the Btu
content. The Btu content of the gas shall be calculated using the average composition of the gas
over the semi-annual period and assuming the composition of C6+ constituents is as follows:
50% C6, 25% C7 and 25% Cg. The Btu content of the natural gas shall be based on the lower
heating value of the fuel. Calculations of monthly emissions shall be made using the heat
content derived from the most recent required analysis.
3.4 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air
pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section A.II.1). In the
absence of credible evidence to the contrary, compliance with the 20% opacity limit shall be
presumed since only natural gas is permitted to be used as fuel for this engine. The permittee
shall maintain records that verify that only natural gas is used as fuel.
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 10
4. WIC CG -7401: Cooper 2 Cycle Clean Burn ICE, S/N: 48468
Parameter
Permit
Condition
Number
Limitations
Short Term Long Term
Compliance
Emission
Factor
Monitoring
Method Interval
NOx
4.1
CO
VOC
39.5 tpy
0.47 lb/MMBtu
Recordkeeping
& Calculation
Portable Flue
Gas Analyzer
Monthly
39.0 tpy
0.47 lb/MMBtu
30.0 tpy
0.36 lb/MMBtu
Portable Flue
Gas Analyzer
Each
Calendar
Quarter
Natural gas
consumption
4.2
Heat Content
Opacity
4.3
4.4
175.5 MMscf/yr
Not to exceed 20%
Recordkeeping
Monthly
ASTM
Methods or In -
Line Gas
Chromatograph
Fuel Restriction
Semi -Annual
Only Natural
Gas is Used
as Fuel
4.1 Emissions of Nitrogen Oxide, Carbon Monoxide and Volatile Organic Compound emissions
shall not exceed the limitations stated above (Colorado Construction Permit 98WE0030, as
modified under the provisions of Section I, Condition 1.3 to remove the short term emission
limits). Compliance with the emission limitations shall be monitored as follows:
4.1.1 Except as provided below, the emission factors listed above (from the manufacturer,
converted to lb/MMBtu based on an engine heat rate of 6,975 Btu/hp-hr) have been
approved by the Division and shall be used to calculate emissions from this engine as
follows:
Monthly emissions shall be calculated by the end of the subsequent month using the
above emission factors, the monthly fuel consumption and the lower heating value of
the fuel, as specified in Condition 4.3, in the equation below:
tons/month = JEF (lbs/MMBtu)l x [Fuel Use (MMscf/month)1 x [Heat Content of Fuel (MMBtu/MMscf)l
2000 lbs/ton
A twelve-month rolling total of emissions shall be maintained to monitor compliance
with the annual limitation. Each month a new twelve month total shall be calculated
using the previous twelve months' data.
If a reference method test is conducted under the provisions of Condition 4.1.2, and
the results of the testing show that either the NOx or CO emission rates/factors are
greater than the emission rates/factors listed above, the permittee shall apply for a
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 11
modification to this permit to reflect, at a minimum, the higher emission rates/factors
within 60 days of the completion of the reference method test.
4.1.2 Portable Monitoring shall be conducted each calendar quarter in accordance with the
requirements in Condition 8.
4.2 Natural gas use for this engine shall not exceed the annual limitation stated above (Colorado
Construction Permit 98WE0030, as modified under the provisions of Section I, Condition 1.3 to
remove the short term fuel use limit). Natural gas use shall be recorded monthly using the facility
fuel meter. Natural gas consumption for each engine shall be allocated according to size, hours
of operation and other records as necessary and recorded in a log to be made available to the
Division upon request. A twelve month rolling total shall be maintained to monitor compliance
with the annual limitation. Each month, a new twelve month total shall be calculated using the
previous twelve months data.
4.3 The Btu content of the natural gas used to fuel this engine shall be verified semi-annually using
the appropriate ASTM Methods or equivalent, if approved in advance by the Division. In lieu of
collecting a sample, the Btu content of the natural gas may be deteiliiined using the in -line gas
chromatograph to determine the gas composition and ASTM Method 3588 to calculate the Btu
content. The Btu content of the gas shall be calculated using the average composition of the gas
over the semi-annual period and assuming the composition of C6+ constituents is as follows:
50% C6, 25% C7 and 25% Cg. The Btu content of the natural gas shall be based on the lower
heating value of the fuel. Calculations of monthly emissions shall be made using the heat
content derived from the most recent required analysis.
4.4 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air
pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section A.II.1). In the
absence of credible evidence to the contrary, compliance with the 20% opacity limit shall be
presumed since only natural gas is permitted to be used as fuel for this engine. The permittee
shall maintain records that verify that only natural gas is used as fuel.
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 12
5. CG -7501/S008: Caterpillar, 4 -Cycle Low NOx ICE, Equipped with Oxidation Catalyst S/N:
4ZS00310
Parameter
Permit
Condition
Number
Limitations
Short Term Long Term
Compliance
Emission Factor
Monitoring
Method Interval
BACT
Requirements
NOx
CO
VOC
5.1
5.2
0.27 lb/MMBtu, on a 1 -hr average
N/A I 14.3 tons/yr
0.27 lb/MMBtu
See Condition 5.1
Recordkeeping &
Calculation
Monthly
0.07 lb/MMBtu, on a 1 -hr average
N/A I 3.7 tons/yr
0.07 lb/MMBtu
0.10 lb/MMBtu, on a 1 -hr average
N/A
5.3 tons/yr
0.10 lb/MMBtu
Portable Flue Gas
Analyzer
Each
Calendar
Quarter
Formaldehyde
5.3
N/A
2.72 tons/yr
0.13 lb/MMBtu
Recordkeeping &
Calculation
Monthly
Natural gas
consumption
5.4
Heat Content
5.5
Opacity
5.6
N/A
112 MMscf/yr
Not to exceed 20%
RICE MACT
Requirements
5.7
MACT
General
Provisions
5.8
Emission Limitation: Reduce CO
Emissions by 93%
Operating Limitations: 1.) Maintain
catalyst so that the pressure drop does
not change by more than 2" of H2O at
100% load plus or minus 10% from
pressure drop measured during the
initial performance test. AND
2.) Maintain the RICE so that the
inlet temperature to the catalyst is
greater than or equal to 450 ° F and
less than or equal to 1350 ° F.
Recordkeeping
Monthly
ASTM Methods
or In -Line Gas
Chromatograph
Semi -Annual
Fuel Restriction
Only Natural
Gas is Used
as Fuel
See Condition 5.7
See Condition 5.8
5.1 This engine is subject to the requirements of the Prevention of Significant Deterioration (PSD)
Program. Best Available Control Technology (BACT) shall be applied for control of Nitrogen
Oxides (NOx), Carbon Monoxide (CO) and Volatile Organic Compounds (VOC). BACT has
been determined to be as follows:
Operating Permit Number: 95OPWE090
First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 13
5.1.1 BACT for NOx has been determined to be lean bum combustion technology with
emission limits as identified in Condition 5.2.1.1 (Colorado Construction Permit
03WE0184).
5.1.2 BACT for CO has been determined to be an oxidation catalyst with emission limits as
identified in Condition 5.2.1.2 (Colorado Construction Permit 03WE0184).
5.1.3 BACT for VOC has been determined to be an oxidation catalyst with emission limits
as identified in Condition 5.2.1.3 (Colorado Construction Permit 03WE0185).
5.2 Nitrogen Oxide (NOx), Carbon Monoxide (CO) and Volatile Organic Compound (VOC)
emissions from this engine are subject to the following requirements:
5.2.1 For purposes of BACT NON, CO and VOC are subject to the following limitations
(Colorado Construction Permit 03WE0184):
5.2.1.1 NOx emissions shall not exceed 0.27 lb/MMBtu, on a 1 -hour average.
5.2.1.2 CO emissions shall not exceed 0.07 lb/MMBtu, on a 1 -hour average.
5.2.1.3 VOC emissions shall not exceed 0.10 lb/MMBtu, on a 1 -hour average.
Portable monitoring shall be conducted each calendar quarter in accordance with the
requirements in Condition 8 to monitor compliance with the NON and CO BACT
limits.
In the absence of credible evidence to the contrary compliance with the VOC BACT
limits is presumed provided therequirements in Conditions 5.7 and 5.8 are met.
5.2.2 NON, CO and VOC emissions shall not exceed the annual emission limitations stated
above (Colorado Construction Permit 03WE0184) Compliance with the emission
limitations shall be monitored as follows:
5.2.2.1 Except as provided below, the emission factors listed above (from the
manufacturer, converted to lb/MMBtu based on an engine heat rate of
6,620 Btu/hp-hr) have been approved by the Division and shall be used to
calculate emissions from this engine as follows:
Monthly emissions shall be calculated by the end of the subsequent month
using the above emission factors, the monthly fuel consumption and the
lower heating value of the fuel, as specified in Condition 5.5, in the
equation below:
tons/mo = f EF (lbs/MMBtu)] x [Fuel Use (MMscf/mo)] x [Heat Content of Fuel (MMBtu/MMscf)1
2000 lbs/ton
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 14
A twelve-month rolling total of emissions shall be maintained to monitor
compliance with the annual limitation. Each month a new twelve month
total shall be calculated using the previous twelve months' data.
5.2.2.2 Portable Monitoring shall be conducted each calendar quarter in
accordance with the requirements in Condition 8.
Note that the second to the last paragraph in Condition 8 (apply for a
permit modification within 60 days if the EPA Reference Test indicates
that the emission rates/factors are greater than the emission rates/factors
identified in the permit) does not apply to this emission unit.
5.3 Formaldehyde emissions shall not exceed the limitations stated above (Colorado Construction
Permit 03WE0184). Monthly emissions from the engine shall be calculated by the end of the
subsequent month using the above emission factors (from the manufacturer, converted to
lb/MMBtu based on an engine heat rate of 6,620 Btu/hp-hr), the monthly fuel consumption and
the lower heating value of the fuel, as specified in Condition 5.5, in the following equation:
tons/month = JEF (lbs/MMBtu)l x [Fuel Use (MMscf/month)1 x [Heat Content of Fuel (MMBtu/MMscfl [
2000 lbs/ton
Note that a control efficiency of 60% may be applied to the above equation provided the requirements in Condition 5.7
have been met.
A twelve-month rolling total of emissions shall be maintained to monitor compliance with the
annual limitation. Each month a new twelve month total shall be calculated using the previous
twelve months' data.
5.4 Natural gas use shall not exceed the limitations stated above (Colorado Construction Pei nut
03WE0184). Natural gas use shall be recorded monthly using the facility fuel meter. Natural
gas consumption for each engine shall be allocated according to size, hours of operation and
other records as necessary and recorded in a log to be made available to the Division upon
request. A twelve month rolling total shall be maintained to monitor compliance with the annual
limitation. Each month, a new twelve month total shall be calculated using the previous twelve
months data.
5.5 The Btu content of the natural gas used to fuel this engine shall be verified semi-annually using
the appropriate ASTM Methods or equivalent, if approved in advance by the Division. In lieu of
collecting a sample, the Btu content of the natural gas may be determined using the in -line gas
chromatograph to determine the gas composition and ASTM Method 3588 to calculate the Btu
content. The Btu content of the gas shall be calculated using the average composition of the gas
over the semi-annual period and assuming the composition of C6+ constituents is as follows:
50% C6, 25% C7 and 25% C8. The Btu content of the natural gas shall be based on the lower
heating value of the fuel. Calculations of monthly emissions shall be made using the heat
content derived from the most recent required analysis.
5.6 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air
pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section A.II.1). In the
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 15
absence of credible evidence to the contrary, compliance with the 20% opacity limit shall be
presumed since only natural gas is permitted to be used as fuel for this engine. The permittee
shall maintain records that verify that only natural gas is used as fuel.
5.7 This engine is subject to the requirements in 40 CFR Part 63 Subpart ZZZZ, "National Emission
Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion
Engines", as adopted by reference in Colorado Regulation No. 8, Part E, Section III, as specified
in Condition 9 of this permit.
Note that the compliance date for this engine is August 16, 2004 as specified in 40 CFR Part 63
Subpart ZZZZ § 63.6595(a)(2).
5.8 This engine is subject to the requirements in 40 CFR Part 63 Subpart A "General Provisions", as
adopted by reference in Colorado Regulation No. 8, Part E, Section I as specified in 40 CFR Part
63 Subpart ZZZZ § 63.6665. These requirements include, but are not limited to the following:
5.8.1 Prohibited activities and circumvention in § 63.4.
5.8.2 Operation and maintenance requirements in § 63.6(e)(1).
5.8.3 Startup, shutdown and malfunction plan requirements in § 63.6(e)(3).
5.8.4 Performance test requirements in § 63.7.
5.8.5 Monitoring requirements in § 63.8.
5.8.6 Notification requirements in § 63.9.
5.8.7 Recordkeeping requirements in § 63.10.
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 16
6. CG -76011S009: Solar Taurus 60-7800S, Combustion Turbine, S/N: 1255T
Parameter
Permit
Condition
Number
Limitations for each engine
Short Term Long Term
Compliance
Emission
Factor
Monitoring
Method Interval
BACT
Requirements
6.1.
NOx
6.2
CO
VOC
15 ppmvd at 15% O2, except as provided
for below:
-20°F<T<0°F:42ppmvdat 15%O2
T < -20 ° F: 120 ppmvd at 15% O2
All limits on a 1 -hr average
1.46 tons/mo ' 17.2 tons/yr
25 ppmvd at 15% O2, except as provided
for below:
-20°F<T<0°F: 100ppmvdat 15%O2
T < -20 ° F: 150 ppmvd at 15% O2
All limits on a 1 -hr average
1.54 tons/mo 18.1 tons/yr
3 ppmvd at 15% O2, except as provided
for below:
-20°F<T<0°F:5ppmvd at15%O2
T < -20 ° F: 8 ppmvd at 15% O2
All limits on a 1 -hr average
Natural gas
consumption
6.3
43.6 MMscf/mo
513.7 MMscf/yr
SO2
6.4.
150 ppmvd @ 15% O2 OR Use of Fuel
Which Contains Less than 0.8 Weight %
Sulfur
0.8 lbs/MMBtu
PM
6.5.
Heat Content
6.6
Opacity
6.7.
NSPS General
Provisions
6.8.
See Condition
6.2.
0.174 lbs/MMBtu
Not to Exceed 20% Except as Provided
for Below
For Startup - Not to Exceed 30%, for a
Period or Periods Aggregating More than
Six (6) Minutes in any 60 Consecutive
Minutes
See Condition 6.1.
Recordkeeping &
Calculation
Monthly
Portable Flue Gas
Analyzer
Each
Calendar
Quarter
See Condition 6.2.1.
Recordkeeping
Monthly
Fuel Restriction
Whenever
Pipeline
Quality
Natural Gas
is Used as
Fuel
ASTM Methods
or In -Line Gas
Chromatograph
Fuel Restriction
Semi -Annual
Whenever
Pipeline
Quality
Natural Gas
is Used as
Fuel
See Condition 6.8.
6.1 This turbine is subject to the requirements of the Prevention of Significant Deterioration (PSD)
Program. Best Available Control Technology (BACT) shall be applied for control of Nitrogen
Oxides (NOx), Carbon Monoxide (CO) and Volatile Organic Compounds (VOC). BACT has
been determined to be as follows:
Operating Permit Number: 95OPWE090
First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Peiiiut # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 17
6.1.1 BACT for NOx has been determined to be SoLoNOx II (dry low NOx (DLN))
combustion technology with emission limits as identified in Condition 6.2.1.1
(Colorado Construction Permit 03WE0185).
6.1.2 BACT for CO has been determined to be good combustion practices with emission
limits as identified in Condition 6.2.1.2 (Colorado Construction Permit 03WE0185).
6.1.3 BACT for VOC has been determined to be good combustion practices and use of
pipeline quality natural gas as fuel with emission limits as identified in Condition
6.2.1.3 (Colorado Construction Permit 03WE0185).
6.2 Nitrogen Oxide (NOx), Carbon Monoxide (CO) and Volatile Organic Compound (VOC)
emissions from this turbine are subject to the following requirements:
6.2.1 For purposes of BACT NOx, CO and VOC are subject to the following limitations
(Colorado Construction Permit 03WE0185). All limitations are at 15% O2, on a 1 -hr
average:
6.2.1.1 Except as provided for below, NOx emissions shall not exceed 15 ppmvd
a. When the ambient temperature is less than 0° F but greater than or
equal to —20° F, NOx emissions shall not exceed 42 ppmvd.
b. When the ambient temperature is less than —20° F, NOx emissions
shall not exceed 120 ppmvd.
6.2.1.2 Except as provided for below, CO emissions shall not exceed 25 ppmvd.
a. When the ambient temperature is less than 0° F but greater than or
equal to —20° F, CO emissions shall not exceed 100 ppmvd.
b. When the ambient temperature is less than —20° F, CO emissions shall
not exceed 150 ppmvd.
6.2.1.3 Except as provided for below, VOC emissions shall not exceed 3 ppmvd.
a. When the ambient temperature is less than 0° F but greater than or
equal to —20° F, VOC emissions shall not exceed 5 ppmvd.
b. When the ambient temperature is less than —20° F, VOC emissions
shall not exceed 8 ppmvd.
6.2.1.4 The source shall monitor and keep records of the number of hours that the
turbine operates when the ambient temperature meets the criteria in
Conditions 6.2.1.1.a & b, 6.2.1.2.a & b and 6.2.1.3.a & b above. Hours of
turbine operation when ambient temperatures are below 0° F and below —
20° F shall be monitored and recorded.
Portable monitoring shall be conducted each calendar quarter in accordance with the
requirements in Condition 8 to monitor compliance with the NOx and CO BACT
limits. At least annually, such portable monitoring shall be conducted at the
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Peiinit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 18
temperatures specified in Conditions 6.2.1.1.a & b and 6.2.1.2.a & b above, unless
ambient conditions or extended periods at those temperatures are not sufficient to
conduct the monitoring. In the event that it is not feasible to conduct a portable
monitoring test at the temperatures specified in Conditions 6.2.1.1.a & b and 6.2.1.2.a
& b, due to ambient conditions or insufficient time, a written explanation shall be
submitted with the annual compliance certification describing the reasons that
portable monitoring was not conducted.
In the absence of credible evidence to the contrary, compliance with the VOC BACT
limit is presumed whenever pipeline quality natural gas is used as fuel and good
combustion practices are applied.
6.2.2 NOx and CO emissions shall not exceed the monthly and annual emission limitations
stated above (Colorado Construction Permit 03WE0185). Compliance with the
emission limitations shall be monitored as follows:
6.2.2.1 Except as provided below, the emission factors listed in the table below
(from the manufacturer, converted to lb/MMBtu based on the design heat
input rate of 58 MMBtu/hr) have been approved by the Division and shall
be used to calculate emissions from this turbine as follows:
NOx
CO
T>0°F:
0.063 lb/mmBtu
-20°F<T<0°F:
0.177 lb/mmBtu
T< -20°F:
0.504 lb/mmBtu
T>0°F:
0.064 lb/mmBtu
-20°F<T<0°F:
0.257 lb/mmBtu
T< -20°F:
0.384 lb/mmBtu
Monthly emissions shall be calculated by the end of the subsequent month
using the above emission factors, the monthly fuel consumption and the
lower heating value of the fuel, as specified in Condition 6.6, in the
equation below:
tons/mo = [EF (lbs/MMBtu)1 x [Fuel Use (MMscf/mo)1 x [Heat Content of Fuel (MMBtu/MMscf)1
2000 lbs/ton
Compliance with the monthly emission limits shall be monitored by
comparing the calculated monthly emissions with the monthly emission
limitations. A twelve-month rolling total of emissions shall be maintained
to monitor compliance with the annual limitation. Each month a new
twelve month total shall be calculated using the previous twelve months'
data.
6.2.2.2 Portable Monitoring shall be conducted each calendar quarter in
accordance with the requirements in Condition 8.
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed. DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 19
Note that the second to the last paragraph in Condition 8 (apply for a
permit modification within 60 days if the EPA Reference Test indicates
that the emission rates/factors are greater than the emission rates/factors
identified in the permit) does not apply to this emission unit.
6.3 Natural gas use for the turbine shall not exceed the limitations stated above (Colorado
Construction Permits 03WE0185). Natural gas use shall be recorded monthly using the turbine's
fuel meter.
Compliance with the monthly natural gas use limit shall be monitored by comparing the recorded
monthly fuel use with the monthly fuel use limitation. A twelve month rolling total shall be
maintained to monitor compliance with the annual limitation. Each month, a new twelve month
total shall be calculated using the previous twelve months data.
6.4 Sulfur Dioxide (SO2) emissions shall not exceed the following limitations:
6.4.1 The turbine shall meet one of the following requirements:
6.4.1.1 Sulfur Dioxide (SO2) emissions from the turbine shall not exceed 150
ppmvd at 15% O2,
OR
6.4.1.2 No fuel, which contains sulfur in excess of 0.8 percent by weight, shall be
used in this combustion turbine (Colorado Construction Permit 03WE0185
and 40 CFR Part 60 Subpart GG §§ 60.333(a) & (b), as adopted by
reference in Colorado Regulation No. 6, Part A).
In the absence of credible evidence to the contrary, compliance with the above
requirements is presumed when pipeline quality natural gas is used as fuel. The
permittee shall maintain records demonstrating that the natural gas burned meets the
definition of pipeline quality natural gas as defined in 40 CFR Part 72 (0.5 grains or
less of total sulfur per 100 standard cubic feet). The demonstration shall be made
using the gas quality characteristics in a current, valid purchase contract, tariff sheet
or transportation contract for the gaseous fuel. These records shall be made available
to the Division upon request.
6.4.2 Sulfur Dioxide (SO2) emissions from the turbine shall not exceed 0.8 lbs/MMBtu, on
a 3 -hr rolling average (Colorado Regulation No. 1, Section VI.B.4.c.(i) and VI.B.2).
In the absence of credible evidence to the contrary, compliance with the SO2
limitations is presumed whenever pipeline quality natural gas is used as fuel in this
turbine.
6.5 Particulate Matter (PM) emissions from the turbine shall not exceed the above limitations
(Colorado Regulation No. 1, Section III.A.1). In the absence of credible evidence to the
contrary, compliance with the particulate matter emission limit is presumed whenever pipeline
quality natural gas is used as fuel in the turbine.
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 20
The numeric PM standard was deteiiiuned using the design heat input for the turbine (58
MMBtu/hr) in the following equation:
PE = 0.5 x (FI)-°.26' where: PE = particulate standard in lbs/mmBtu
FI = fuel input in mmBtu/hr
6.6 The Btu content of the natural gas used to fuel this turbine shall be verified semi-annually using
the appropriate ASTM Methods or equivalent, if approved in advance by the Division. In lieu of
collecting a sample, the Btu content of the natural gas may be determined using the in -line gas
chromatograph to determine the gas composition and ASTM Method 3588 to calculate the Btu
content. The Btu content of the gas shall be calculated using the average composition of the gas
over the semi-annual period and assuming the composition of C6+ constituents is as follows:
50% C6, 25% C7 and 25% Cg. The Btu content of the natural gas shall be based on the lower
heating value of the fuel. Calculations of monthly emissions shall be made using the heat
content derived from the most recent required analysis.
6.7 The turbine is subject to the following opacity requirements:
6.7.1 No owner or operator of a source shall allow or cause to be emitted into the
atmosphere any air pollutant which is in excess of 20% opacity (Colorado Regulation
No. 1, Section A.II.1),
6.7.2 No owner or operator of a source shall allow or cause to be emitted into the
atmosphere any air pollutant resulting from start-up which is in excess of 30%
opacity for a period or periods aggregating more than six (6) minutes in any sixty (60)
consecutive minutes (Colorado Regulation No. 1, Section II.A.4).
In the absence of credible evidence to the contrary, compliance with the above opacity
requirements shall be presumed whenever pipeline quality natural gas is used as fuel for this
turbine.
6.8 This turbine is subject to the NSPS Subpart A, General Provisions requirements (Colorado
Regulation No. 6, Part A, Federal 40 CFR 60.1 through 60.19). Specifically, this unit is subject
to the following:
6.8.1 No article, machine, equipment or process shall be used to conceal an emission which
would otherwise constitute a violation of an applicable standard. Such concealment
includes, but is not limited to, the use of gaseous diluents to achieve compliance with
an opacity standard or with a standard which is based on the concentration of a
pollutant in the gasses discharged to the atmosphere. (40 CFR § 60.12)
6.8.2 Records of startups, shutdowns, and malfunctions shall be maintained, as required
under 40 CFR § 60.7.
6.8.3 At all times, including periods of startup, shutdown, and malfunction, owners and
operators shall, to the extent practicable, maintain and operate any affected facility
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 21
including associated air pollution control equipment in a manner consistent with good
air pollution control practice for minimizing emissions. Determination of whether
acceptable operating and maintenance procedures are being used will be based on
information available to the Administrator which may include, but is not limited to,
monitoring results, opacity observations, review of operating and maintenance
procedures, and inspection of the source. (40 CFR § 60.11(d))
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 22
7. CG -7701/S010: Caterpillar, 4 -Cycle Low NOx ICE, Equipped with Oxidation Catalyst S/N:
BEN00254
Parameter
Permit
Condition
Number
Limitations
Short Term Long Term
Compliance
Emission Factor
Monitoring
Method Interval
BACT
Requirements
7.1.
NOx
CO
VOC
7.2
0.27 lb/MMBtu, on a 1 -hr average
1.8 tons/mo I 21.2 tons/yr
0.07 lb/MMBtu, on a 1 -hr average
0.44 tons/mo I 5.2 tons/yr
0.10 lb/MMBtu, on a 1 -hr average
0.27 lb/MMBtu
0.07 lb/MMBtu
See Condition 7.1.
0.63 tons/mo
7.4 tons/yr
0.10 lb/MMBtu
Recordkeeping &
Calculation
Portable Flue Gas
Analyzer
Monthly
Each
Calendar
Quarter
Formaldehyde
7.3.
0.32 tons/mo
3.8 tons/yr
0.13 lb/MMBtu
Recordkeeping &
Calculation
Monthly
Natural gas
consumption
7.4
13.3 MMscf/mo
157 MMscf/yr
Recordkeeping
Monthly
Heat Content
7.5
Opacity
7.6
Not to exceed 20%
RICE MACT
Requirements
7.7.
MACT
General
Provisions
7.8.
Emission Limitation: Reduce CO
Emissions by 93%
Operating Limitations: 1.) Maintain
catalyst so that the pressure drop does
not change by more than 2" of H2O at
100% load plus or minus 10% from
pressure drop measured during the
initial performance test. AND
2.) Maintain the RICE so that the
inlet temperature to the catalyst is
greater than or equal to 450 ° F and
less than or equal to 1350 ° F.
ASTM Methods
or In -Line Gas
Chromatograph
Semi -Annual
Fuel Restriction
Only Natural
Gas is Used
as Fuel
See Condition 7.7.
See Condition 7.8.
7.1 This engine is subject to the requirements of the Prevention of Significant Deterioration (PSD)
Program. Best Available Control Technology (BACT) shall be applied for control of Nitrogen
Oxides (NOx), Carbon Monoxide (CO) and Volatile Organic Compounds (VOC). BACT has
been deteiituned to be as follows:
Operating Permit Number: 95OPWE090
First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 23
7.1.1 BACT for NOx has been determined to be lean bum combustion technology with
emission limits as identified in Condition 7.2.1.1 (Colorado Construction Permit
03WE0912).
7.1.2 BACT for CO has been determined to be an oxidation catalyst with emission limits as
identified in Condition 7.2.1.2 (Colorado Construction Permit 03WE0912).
7.1.3 BACT for VOC has been determined to be an oxidation catalyst with emission limits
as identified in Condition 7.2.1.3 (Colorado Construction Petinit 03WE0912).
7.2 Nitrogen Oxide (NOx), Carbon Monoxide (CO) and Volatile Organic Compound (VOC)
emissions from this engine are subject to the following requirements:
7.2.1 For purposes of BACT NOx, CO and VOC are subject to the following limitations
(Colorado Construction Permit 03WE0912):
7.2.1.1 NOx emissions shall not exceed 0.27 lb/MMBtu, on a 1 -hour average.
7.2.1.2 CO emissions shall not exceed 0.07 lb/MMBtu, on a 1 -hour average.
7.2.1.3 VOC emissions shall not exceed 0.10 lb/MMBtu, on a 1 -hour average.
Portable monitoring shall be conducted Each Calendar Quarter in accordance with the
requirements in Condition 8 to monitor compliance with the NOx and CO BACT
limits.
In the absence of credible evidence to the contrary compliance with the VOC BACT
limits is presumed provided the requirements in Conditions 7.7 and 7.8 are met.
7.2.2 NOx, CO and VOC emissions shall not exceed the monthly and annual emission
limitations stated above (Colorado Construction Permit 03WE0912) Compliance with
the emission limitations shall be monitored as follows:
7.2.2.1 Except as provided below, the emission factors listed above (from the
manufacturer, converted to lb/MMBtu based on an engine heat rate of
6,581 Btu/hp-hr) have been approved by the Division and shall be used to
calculate emissions from this engine as follows:
Monthly emissions shall be calculated by the end of the subsequent month
using the above emission factors, the monthly fuel consumption and the
lower heating value of the fuel, as specified in Condition 7.5, in the
equation below:
tons/mo = IEF (lbs/MMBtu)] x [Fuel Use (MMscf/mo)1 x [Heat Content of Fuel (MMBtu/MMscf)l
2000 lbs/ton
Compliance with the monthly emission limits shall be monitored by
comparing the calculated monthly emissions with the monthly emission
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 24
limitations. A twelve-month rolling total of emissions shall be maintained
to monitor compliance with the annual limitation. Each month a new
twelve month total shall be calculated using the previous twelve months'
data.
7.2.2.2 Portable Monitoring shall be conducted each calendar quarter in
accordance with the requirements in Condition 8.
Note that the second to the last paragraph in Condition 8 (apply for a
permit modification within 60 days if the EPA Reference Test indicates
that the emission rates/factors are greater than the emission rates/factors
identified in the permit) does not apply to this emission unit.
7.3 Formaldehyde emissions shall not exceed the limitations stated above (Colorado Construction
Permit 03WE0912). Monthly emissions from the engine shall be calculated by the end of the
subsequent month using the above emission factors (from the manufacturer, converted to
lb/MMBtu based on an engine heat rate of 6,581 Btu/hp-hr), the monthly fuel consumption and
the lower heating value of the fuel, as specified in Condition 7.5, in the following equation:
tons/month = jEF (lbs/MMBtu)1 x [Fuel Use (MMscf/month)l x [Heat Content of Fuel (MMBtu/MMscf) l
2000 lbs/ton
Note that a control efficiency of 60% may be applied to the above equation provided the requirements in Condition 6.8
have been met.
Compliance with the monthly emission limits shall be monitored by comparing the calculated
monthly emissions with the monthly emission limitations. A twelve-month rolling total of
emissions shall be maintained to monitor compliance with the annual limitation. Each month a
new twelve month total shall be calculated using the previous twelve months' data.
7.4 Natural gas use shall not exceed the limitations stated above (Colorado Construction Permit
03WE0912). Natural gas use shall be recorded monthly using the facility fuel meter. Natural
gas consumption for each engine shall be allocated according to size, hours of operation and
other records as necessary and recorded in a log to be made available to the Division upon
request.
Compliance with the monthly natural gas use limit shall be monitored by comparing the
allocated monthly fuel use with the monthly natural gas use limitation. A twelve month rolling
total shall be maintained to monitor compliance with the annual limitation. Each month, a new
twelve month total shall be calculated using the previous twelve months data.
7.5 The Btu content of the natural gas used to fuel this engine shall be verified semi-annually using
the appropriate ASTM Methods or equivalent, if approved in advance by the Division. In lieu of
collecting a sample, the Btu content of the natural gas may be determined using the in -line gas
chromatograph to determine the gas composition and ASTM Method 3588 to calculate the Btu
content. The Btu content of the gas shall be calculated using the average composition of the gas
over the semi-annual period and assuming the composition of C6+ constituents is as follows:
50% C6, 25% C7 and 25% Cg. The Btu content of the natural gas shall be based on the lower
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 25
heating value of the fuel. Calculations of monthly emissions shall be made using the heat
content derived from the most recent required analysis.
7.6 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air
pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section A.II.1). In the
absence of credible evidence to the contrary, compliance with the 20% opacity limit shall be
presumed since only natural gas is permitted to be used as fuel for this engine. The permittee
shall maintain records that verify that only natural gas is used as fuel.
7.7 This engine is subject to the requirements in 40 CFR Part 63 Subpart ZZZZ, "National Emission
Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion
Engines", as adopted by reference in Colorado Regulation No. 8, Part E, Section III, as specified
in Condition 9 of this permit.
Note that the compliance date for this engine is the startup date (December 15, 2004) as specified
in 40 CFR Part 63 Subpart ZZZZ § 63.6595(a)(3).
7.8 This engine is subject to the requirements in 40 CFR part 63 Subpart A "General Provisions", as
adopted by reference in Colorado Regulation No. 8, Part E, Section I as specified in 40 CFR Part
63 Subpart ZZZZ § 63.6665. These requirements include, but are not limited to the following:
7.8.1 Prohibited activities and circumvention in § 63.4.
7.8.2 Operation and maintenance requirements in § 63.6(e)(1).
7.8.3 Startup, shutdown and malfunction plan requirements in § 63.6(e)(3).
7.8.4 Performance test requirements in § 63.7.
7.8.5 Monitoring requirements in § 63.8.
7.8.6 Notification requirements in § 63.9.
7.8.7 Recordkeeping requirements in § 63.10.
8. Portable Monitoring (06/26/2014 version)
Emission measurements of nitrogen oxides (NOx) and carbon monoxide (CO) shall be conducted
quarterly using a portable flue gas analyzer. At least one calendar month shall separate the quarterly
tests. Note that if a unit is operated for less than 100 hrs in any quarterly period, then the portable
monitoring requirements do not apply.
For the purposes of this condition, quarterly shall mean calendar quarter.
All portable analyzer testing required by this permit shall be conducted using the Division's Portable
Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's website at:
https: //www. colorado. gov/pacific/cdphe/portable-analyzer-monitoring-protocol
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 26
Results of the portable flue gas analyzer tests shall be used to monitor the compliance status of a unit.
For comparison with an annual or short term emission limit, the results of the tests shall be converted to
a lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever applies) in
order to monitor compliance. If a source is not limited in its hours of operation the test results will be
multiplied by the maximum number of hours in the month or year (8760), whichever applies.
If the portable analyzer results indicate compliance with both the NOx and CO emission limitations, in
the absence of credible evidence to the contrary, the source may certify that the engine is in compliance
with both the NOx and CO emission limitations for the relevant time period.
Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if
the portable analyzer results fail to demonstrate compliance with either the NOx or CO emission
limitations, the engine will be considered to be out of compliance from the date of the portable analyzer
test until a portable analyzer test indicates compliance with both the NOx and CO emission limitations
or until the engine is taken offline.
For comparison with the emission rates/factors, the emission rates/factors determined by the portable
analyzer tests and approved by the Division shall be converted to the same units as the emission
rates/factors in the permit. If the portable analyzer tests shows that either the NOx or CO emission
rates/factors are greater than the relevant ones set forth in the permit, and in the absence of subsequent
testing results to the contrary (as approved by the Division), the permittee shall apply for a modification
to this permit to reflect, at a minimum, the higher emission rate/factor within 60 days of the completion
of the test.
Results of all tests conducted shall be kept on site and made available to the Division upon request.
9. Reciprocating Internal Combustion Engine (RICE) MACT Requirements.
"National Emission Standards for Stationary Reciprocating Internal Combustion Engines" in 40 CFR
Part 63 Subpart ZZZZ, as adopted by reference in Colorado Regulation No. 8, Part E, Section III,
requirements, include but are not limited to the following:
9.1 General Requirements:
9.1.1 This unit must be in compliance with the emission limitations and operating
limitations in Conditions 9.2 and 9.3 at all times, except during periods of startup,
shutdown and malfunction (40 CFR Part 63 Subpart ZZZZ § 63.6605(a)).
9.1.2 This unit, including air pollution control and monitoring equipment, shall be operated
and maintained in a manner consistent with good air pollution control practices for
minimizing emissions at all time, including during startup, shutdown and malfunction
(40 CFR Part 63 Subpart ZZZZ § 63.6605(b)).
9.2 Emission Limitations: Carbon Monoxide (CO) emissions from this engine must be reduced by
93 percent or more (40 CFR Part 63 Subpart ZZZZ § 63.6600(b), Table 2a, item 2).
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 27
9.3 Operating Limitations: This unit is subject to the following operating limitations (40 CFR Part 63
Subpart ZZZZ § 63.6600(b), Table 2b, iteml):
9.3.1 The catalyst must be maintained so that the pressure drop across the catalyst does not
change by more than two inches of water at 100 percent load plus or minus ten
percent from the pressure drop across the catalyst that was measured during the initial
performance test; and
9.3.2 The temperature of the stationary RICE exhaust shall be maintained so that the
catalyst inlet temperature is greater than or equal to 450 ° F and less than or equal to
1350 ° F.
9.4 Initial Testing and Compliance Requirements: An initial performance test shall be conducted
within 180 days of the compliance date to measure the O2 and CO at the inlet and outlet of the
control device using a portable CO and O2 analyzer in accordance with the requirements in
ASTM D6522-00 (incorporated by reference, see § 63.14). The CO concentration must be at
15% O2 on a dry basis. Measurements to determine O2 must be made at the same time as the
measurements for CO concentration (40 CFR Part 63 Subpart ZZZZ § 63.6610(a), Table 4, item
1).
9.5 Subsequent Performance Test Requirements: Subsequent performance tests shall be conducted
semi-annually. After compliance has been demonstrated for two consecutive tests, the frequency
of semi-annual tests may be reduced to annually. If the results of any subsequent annual
performance test indicates the stationary RICE is not in compliance with the CO emission
limitations, or you deviate from any of your operating limitations, you must resume semi-annual
performance tests (40 CFR Part 63 Subpart ZZZZ § 63.6615, Table 3, item 1).
9.6 Performance Tests and Other Procedures: Each of the performance tests conducted under
Conditions 9.4 and 9.5 are subject to the following requirements:
9.6.1 Each performance test must be conducted according to the requirements in §
63.7(e)(1) and under the conditions specified in Condition 9.4. The test must be
conducted at any load condition plus or minus 10 percent of 100 percent load (40
CFR Part 63 Subpart ZZZZ § 63.6620(b)).
9.6.2 You may not conduct performance tests during periods of startup, shutdown, or
malfunction, as specified in § 63.7(e)(1) (40 CFR Part 63 Subpart ZZZZ §
63.6620(c)).
9.6.3 You must conduct three separate test runs for each performance test required in
Conditions 9.4 and 9.5 as specified in § 63.7(e)(3). Each test run must last at least 1
hour (40 CFR Part 63 Subpart ZZZZ § 63.6620(d)).
9.6.4 You must use the equation below to determine compliance with the percent reduction
requirements (40 CFR Part 63 Subpart ZZZZ § 63.6620(e)(1)).
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 28
C; Cax100=R
C,
Where:
C, = concentration of CO at the control device inlet
Co = concentration of CO at the control device outlet, and
R = percent reduction of CO emissions.
9.6.5 You must normalize the carbon monoxide (CO) concentrations at the inlet and outlet
of the control device to a dry basis and to 15 percent oxygen, or an equivalent percent
of carbon dioxide (CO2). If pollutant concentrations are to be corrected to 15 percent
oxygen and CO2 concentration is measured in lieu of oxygen concentration, a CO2
correction factor is needed. Calculate the CO2 correction factor in accordance with
the requirements in §§ 63.6620(e)(2)(i) and (ii)) (40 CFR Part 63 Subpart ZZZZ §
63.6620(e)(2)).
9.6.6 The engine percent load during a performance test must be determined by
documenting the calculations, assumptions, and measurement devices used to
measure or estimate the percent load in a specific application. A written report of the
average percent load determination must be included in the notification of compliance
status. The following information must be included in the written report: the engine
model number, the engine manufacturer, the year of purchase, the manufacturer's
site -rated brake horsepower, the ambient temperature, pressure, and humidity during
the performance test, and all assumptions that were made to estimate or calculate
percent load during the performance test must be clearly explained. If measurement
devices such as flow meters, kilowatt meters, beta analyzers, stain gauges, etc. are
used, the model number of the measurement device, and an estimate of its accuracy in
percentage of true value must be provided (40 CFR Part 63 Subpart ZZZZ §
63.6620(i)).
9.7 Monitoring, Installation, Operation and Maintenance Requirements: You must install, maintain
and operate a continuous parametric monitoring system (CPMS) to continuously monitor the
catalyst inlet temperature in accordance with the requirements in § 63.8 (40 CFR Part 63 Subpart
ZZZZ § 63.6625(b), Table 5, item 1).
9.8 Demonstrate Initial Compliance with Emissions and Operating Limitations: Initial compliance
shall be demonstrated as follows:
9.8.1 The average reduction of emissions of CO determined from the initial performance
test achieves the required CO percent reduction and a CPMS to continuously monitor
catalyst inlet temperature has been installed in accordance with the requirements in
Condition 9.7 (40 CFR Part 63 Subpart ZZZZ §§ 63.6630(a), Table 5, items 1.i and
ii).
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 29
9.8.2 You have recorded the catalyst pressure drop and catalyst inlet temperature during the
initial performance test (40 CFR Part 63 Subpart ZZZZ § 63.6630(b), Table 5, item
1.u1).
9.8.3 You must submit the Notification of Compliance status containing the results of the
initial compliance demonstration according to the requirements in Condition 9.11.4
(40 CFR Part 63 Subpart ZZZZ § 63.6630(c)).
9.9 Monitoring and Collecting Data for Continuous Compliance: Data must be monitored and
collected in accordance with the following (40 CFR Part 63 Subpart ZZZZ § 63.6635(a)):
9.9.1 Except for monitor malfunctions, associated repairs, and required quality assurance or
control activities (including, as applicable, calibration checks and required zero and
span adjustments), you must monitor continuously at all times that the stationary
RICE is operating (40 CFR Part 63 Subpart ZZZZ § 63.6635(b)).
9.9.2 You may not use data recorded during monitoring malfunctions, associated repairs,
and required quality assurance or control activities in data averages and calculations
used to report emission or operating levels. You must however, use all the valid data
collected during all other periods (40 CFR Part 63 Subpart ZZZZ § 63.6635(c)).
9.10 Demonstrating Continuous Compliance with the Emission and Operating Limitations:
Continuous compliance with the emission and operating limitations shall be determined as
follows:
9.10.1 You must demonstrate continuous compliance with each emission and operating
limitation in Conditions 9.2 and 9.3 as follows:
9.10.1.1 Conducting subsequent performance tests as specified in Condition 9.5
and demonstrating the required CO reduction (40 CFR Part 63 Subpart
ZZZZ § 63.6640(a), Table 6, item 1.i).
9.10.1.2 Collecting the catalyst inlet temperature data according to Condition 9.7
and reducing these data to 4 -hour rolling averages and maintaining the 4 -
hour rolling averages within the operating limitations for the catalyst inlet
temperature (40 CFR Part 63 Subpart ZZZZ § 63.6640(a), Table 6, items
1.ii thru iv).
9.10.1.3 Measuring the pressure drop across the catalyst once per month and
demonstrating that the pressure drop across the catalyst is within the
operating limitation established during the initial performance test (40
CFR Part 63 Subpart ZZZZ § 63.6640(a), Table 6, item 1.v).
9.10.2 You must report each instance in which you did not meet each emission limitation or
operating limitation in Conditions 9.2 and 9.3. These instances are deviations from
the emission and operating limitations in Conditions 9.2 and 9.3. These deviations
must be reported according to the requirements in Conditions 9.12.3 and 9.12.4. If
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 30
you change your catalyst, you must reestablish the values of the operating parameters
measured during the initial performance test. When you reestablish the values of
your operating parameters, you must also conduct a performance test to demonstrate
that you are meeting the required emission limitation applicable to your stationary
RICE (40 CFR Part 63 Subpart ZZZZ § 63.6640(b)).
9.10.3 You must also report each instance in which you did not meet the requirements in
Table 8 of 40 CFR Part ZZZZ (40 CFR Part 63 Subpart ZZZZ § 63.6640(e)).
Table 8 is the list of provisions in 40 CFR Part 63 Subpart A (general provisions) that
apply to stationary RICE. The general provisions for each engine are indicated in
Section II, Conditions 5.9 (E008) and 7.9 (E010).
9.11 What Notifications to Submit and When:
9.11.1 You must submit all of the notifications in §§ 63.7(b) and (c), 63.8(e), (f)(4), and
(f)(6), 63.9(b) through (e), and (g) and (h) that apply to you by the dates specified (40
CFR Part 63 Subpart ZZZZ § 63.6645(a)).
9.11.2 As specified in § 63.9(b)(2), if you start up your stationary RICE before the effective
date of 40 CFR Part 63 Subpart ZZZZ, you must submit an Initial Notification not
later than December 13, 2004 (40 CFR Part 63 Subpart ZZZZ § 63.6645(b)).
9.11.3 If you are required to conduct a performance test, you must submit a Notification of
Intent to conduct a performance test at least 60 days before the performance test is
scheduled to begin as required in § 63.7(b)(1) (40 CFR Part 63 Subpart ZZZZ §
63.6645(e)).
9.11.4 If you are required to conduct a performance test or other initial compliance
demonstration as specified in Conditions 9.4 and 9.8, you must submit the
Notification of Compliance Status before the close of the business on the 30th day
following the completion of the initial compliance demonstration (40 CFR Part 63
Subpart ZZZZ § 63.6645(h)(1)).
9.12 What Reports to Submit and When:
Compliance Reports
9.12.1 Unless the Division has approved a different schedule for submission of reports under
§ 63.10(a), you must submit Compliance Reports in accordance with the following
requirements:
9.12.1.1 The first Compliance report must cover the period beginning on the
compliance date that is specified for your affected source in §63.6595 and
ending on June 30 or December 31, whichever date is the first date
following the end of the first calendar half after the compliance date that is
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 31
specified for your source in § 63.6595 (40 CFR Part 63 Subpart ZZZZ §
63.6650(b)(1)).
9.12.1.2 The first Compliance report must be postmarked or delivered no later than
July 31 or January 31, whichever date follows the end of the first calendar
half after the compliance date that is specified for your affected source in
§63.6595. (40 CFR Part 63 Subpart ZZZZ § 63.6650(b)(2)).
9.12.1.3 Each subsequent Compliance report must cover the semiannual reporting
period from January 1 through June 30 or the semiannual reporting period
from July 1 through December 31 (40 CFR Part 63 Subpart ZZZZ §
63.6650(b)(3)).
9.12.1.4 Each subsequent Compliance report must be postmarked or delivered no
later than July 31 or January 31, whichever date is the first date following
the end of the semiannual reporting period (40 CFR Part 63 Subpart ZZZZ
§ 63.6650(b)(4)).
9.12.1.5 For each stationary RICE that is subject to pemlitting regulations pursuant
to 40 CFR part 70 or 71, and if the permitting authority has established
dates for submitting semiannual reports pursuant to 40 CFR 70.6
(a)(3)(iii)(A) or 40 CFR 71.6 (a)(3)(iii)(A), you may submit the first and
subsequent Compliance reports according to the dates the permitting
authority has established instead of according to the dates in paragraphs
(b)(1) through (4) of this section (40 CFR Part 63 Subpart ZZZZ §
63.6650(b)(5)).
9.12.2 The Compliance Reports must include the information in §§ 63.6650(c)(1) thru (6)
(40 CFR Part 63 Subpart ZZZZ § 63.6650(c)).
9.12.3 For each deviation from any emission or operating limitation that occurs for a
stationary RICE where you are using a CMS to comply with the emission and
operating limitations in this subpart you must include information in §§ 63.6650(c)(1)
thru (4) and (e)(1) thru (12) (40 CFR Part 63 Subpart ZZZZ § 63.6650(e)).
9.12.4 Each affected source that has obtained a title V operating permit pursuant to 40 CFR
part 70 or 71 must report all deviations as defined in this subpart in the semiannual
monitoring report required by 40 CFR 70.6 (a)(3)(iii)(A) or 40 CFR
71.6(a)(3)(iii)(A). If an affected source submits a Compliance report pursuant to
Condition 9.12 along with, or as part of, the semiannual monitoring report required by
40 CFR 70.6(a)(3)(iii)(A) or 40 CFR 71.6(a)(3)(iii)(A), and the Compliance report
includes all required information conceming deviations from any emission or
operating limitation in this subpart, submission of the Compliance report shall be
deemed to satisfy any obligation to report the same deviations in the semiannual
monitoring report. However, submission of a Compliance report shall not otherwise
affect any obligation the affected source may have to report deviations from permit
requirements to the permit authority (40 CFR Part 63 Subpart ZZZZ § 63.6650(f)).
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 32
9.13 What Records to Keep:
9.13.1 A copy of each notification and report that you submitted to comply with this
Condition 9, including all documentation supporting any Initial Notification or
Notification of Compliance Status that you submitted, according to the requirement in
§63.10(b)(2)(xiv) (40 CFR Part 63 Subpart ZZZZ § 63.6655(a)(1)).
9.13.2 Records of the occurrence and duration of each malfunction of operation (i.e., process
equipment) or the air pollution control and monitoring equipment. (40 CFR Part 63
Subpart ZZZZ § 63.6655(a)(2)).
9.13.3 Records of performance tests and performance evaluations as required in
§63.10(b)(2)(viii) (40 CFR Part 63 Subpart ZZZZ § 63.6655(a)(3)).
9.13.4 Records of all required maintenance performed on the air pollution control and
monitoring equipment (40 CFR Part 63 Subpart ZZZZ § 63.6655(a)(4)).
9.13.5 Records of actions taken during periods of malfunction to minimize emissions in
accordance with §63.6605(b), including corrective actions to restore malfunctioning
process and air pollution control and monitoring equipment to its normal or usual
manner of operation (40 CFR Part 63 Subpart ZZZZ § 63.6655(a)(5)).
9.13.6 For each CPMS you must keep the following requirements (40 CFR Part 63 Subpart
ZZZZ §§ 63.6655(b)(1) thru (3)):
9.13.6.1 Records described in § 63.10(b)(2)(vi) through (xi).
9.13.6.2 Previous (i.e., superseded) versions of the performance evaluation plan as
required in § 63.8(d)(3).
9.13.6.3 Requests for alternatives to the relative accuracy test for CEMS or CPMS
as required in § 63.8(f)(6)(i), if applicable.
9.13.7 You must keep the records required in Condition 9.10.1 to show continuous
compliance with each emission or operating limitation that applies to you (40 CFR
Part 63 Subpart ZZZZ § 63.6655(d)).
9.14 Form and Length of Recordkeeping:
9.14.1 Your records must be in a form suitable and readily available for expeditious review
according to § 63.10(b)(1) (40 CFR Part 63 Subpart ZZZZ § 63.6660(a)).
9.14.2 As specified in § 63.10(b)(1), you must keep each record for 5 years following the
date of each occurrence, measurement, maintenance, corrective action, report, or
record (40 CFR Part 63 Subpart ZZZZ § 63.6660(b)).
9.14.3 You must keep each record readily accessible in hard copy or electronic form on -site
for at least 5 years after the date of each occurrence, measurement, maintenance,
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 33
corrective action, report, or record, according to § 63.10(b)(1) (40 CFR Part 63
Subpart ZZZZ § 63.6660(c)).
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Peinut # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 34
SECTION III - Permit Shield
Regulation No. 3, 5 CCR 1001-5, Part C, $$ I.A.4, V.D., & XIII.B and § 25-7-114.4(3)(a), C.R.S.
1. Specific Non -Applicable Requirements
Based upon 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 modification or reconstruction on which construction commenced
prior to permit issuance.
Emission Unit
Description &
Number
Non -Applicable Requirement
Justification
All
Regulation No. 1, Section III - Particulate Emissions
Emission units do not fall under the regulated
categories for Particulate Emissions.
All
Regulation No. 1, Section IV - Continuous Monitoring
Requirements for New or Existing Sources
Emission units do not fall under the source
categories required to perform continuous
monitoring.
All
Regulation No. 3, Part D, Section V — Non -attainment
areas
Facility is not located in a non -attainment area for
any pollutant.
All
Regulation No. 6, Part A, - Federal Source Performance
Standards, Subpart A - General Provisions
Emission units are not affected sources.
All
Regulation No. 6, Part A - Federal New Source
Performance Standards, Subpart K, Ka, Kb - Storage
Vessels for Petroleum Liquids
No emission units commenced construction after
June 11, 1973 that met the applicability provisions
of the standards.
All
Regulation No. 6, Part A - Federal New Source
Performance Standards, Subpart KKK - Equipment leaks
of VOC from Onshore Natural Gas Processing Plants
Emission units are not affected sources.
All
Regulation No. 6, Part A - Federal New Source
Performance Standards, Subpart LLL - SO2 Emissions
from Onshore Natural Gas Processing Plants
Emission units are not affected sources.
All
Regulation No. 8, Part A - NESHAPS, 40 CFR Part 61,
Subpart J - Equipment Leaks of Benzene
Emissions are less than 10 weight percent benzene.
All
Regulation No. 8, Part A - NESHAPS, 40 CFR Part 61,
Subpart V - Equipment Leaks (VHAP)
Emissions are less than 10 weight percent volatile
hazardous air pollutants.
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;
Operating Permit Number: 95OPWE090
First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 35
2.2 The liability of an owner or operator of a source for any violation of applicable requirements
prior to or at the time of permit issuance;
2.3 The applicable requirements of the federal Acid Rain Program, consistent with § 408(a) of the
federal act;
2.4 The ability of the Air Pollution Control Division to obtain information from a source pursuant to
§ 25-7-111(2)(I), C.R.S., or the ability of the Administrator to obtain information pursuant to §
114 of the federal act;
2.5 The ability of the Air Pollution Control Division to reopen the Operating Permit for cause
pursuant to Regulation No. 3, Part C, § XIII.
2.6 Sources are not shielded from terms and conditions that become applicable to the source
subsequent to permit issuance.
3. Streamlined Conditions
The following applicable requirements have been subsumed within this operating permit using the
pertinent streamlining procedures approved by the U.S. EPA. For purposes of the permit shield,
compliance with the listed peiuiit conditions will also serve as a compliance demonstration for purposes
of the associated subsumed requirements.
Permit Condition
Streamlined (Subsumed) Requirements
Section II, Condition
6.2.1.1
40 CFR Part 60 Subpart GG § 60.332(b) (as adopted by reference in Regulation No. 6, Part
A, Subpart GG) [Nitrogen Oxide emissions shall not exceed 172.8 ppmvd at 15% oxygen
and ISO standard day conditions]
Section II, Condition 6.4.1
40 CFR Part 60 Subpart GG § 60.334(h)(3), as adopted by reference in Colorado Regulation
No. 6, Part A [source shall monitor the sulfur content of the fuel]
Section II, Condition 6.5
Colorado Regulation No. 6, Part B, Section II.C.2 [particulate matter emissions shall not
exceed 0.5(FI)-°.26 lbs/MMBtu] — State Only Requirement
Section II, Condition 6.7
Colorado Regulation No. 6, Part B, Section II.C.3 [opacity of emissions shall not exceed
20%] — State Only Requirement
Section II, Condition 6.4.2
Colorado Regulation No. 6, Part B, Section II.D.3.a [SO2 emissions shall not exceed 0.8
lbs/MMBtu] — State Only Requirement
Operating Permit Number: 95OPWE090
First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Peisnit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 36
SECTION IV - General Permit Conditions ver. 5/22/12
1. Administrative Changes
Regulation No. 3, 5 CCR 1001-5, Part A, § III.
The permittee shall submit an application for an administrative permit amendment to the Division for those permit changes
that are described in Regulation No. 3, Part A, § I.B.1. The permittee may immediately make the change upon submission of
the application to the Division.
2. Certification Requirements
Regulation No. 3, 5 CCR 1001-5, Part C, §§ III.B.9., V.C.16.a.& e. and V.C.17.
a. Any application, report, document and compliance certification submitted to the Air Pollution Control Division
pursuant to Regulation No. 3 or the Operating Permit shall contain a certification by a responsible official of the
truth, accuracy and completeness of such form, report or certification stating that, based on information and belief
formed after reasonable inquiry, the statements and information in the document are true, accurate and complete.
b. All compliance certifications for terms and conditions in the Operating Permit shall be submitted to the Air Pollution
Control Division at least annually unless a more frequent period is specified in the applicable requirement or by the
Division in the Operating Permit.
c. Compliance certifications shall contain:
(i) the identification of each permit term and condition that is the basis of the certification;
(ii) the compliance status of the source;
(iii) whether compliance was continuous or intermittent;
(iv) method(s) used for determining the compliance status of the source, currently and over the reporting
period; and
(v) such other facts as the Air Pollution Control Division may require to determine the compliance status of the
source.
d. All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental
Protection Agency at the addresses listed in Appendix D of this Permit.
e. If the permittee is required to develop and register a risk management plan pursuant to § 112(r) of the federal act, the
permittee shall certify its compliance with that requirement; the Operating Permit shall not incorporate the contents
of the risk management plan as a permit term or condition.
3. Common Provisions
Common Provisions Regulation, 5 CCR 1001-2 §§ ILA., ILB., ILC., ILE., ILF., II.I, and ILJ
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 Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 37
b. Emission Monitoring Requirements
The Division may require owners or operators of stationary air pollution sources to install, maintain, and use
instrumentation to monitor and record emission data as a basis for periodic reports to the Division.
c. Performance Testing
The owner or operator of any air pollution source shall, upon request of the Division, conduct performance test(s)
and furnish the Division a written report of the results of such test(s) in order to determine compliance with
applicable emission control regulations.
Performance test(s) shall be conducted and the data reduced in accordance with the applicable reference test
methods unless the Division:
(i) specifies or approves, in specific cases, the use of a test method with minor changes in methodology;
(ii) approves the use of an equivalent method;
(iii) approves the use of an alternative method the results of which the Division has determined to be adequate
for indicating where a specific source is in compliance; or
(iv) waives the requirement for performance test(s) because the owner or operator of a source has demonstrated
by other means to the Division's satisfaction that the affected facility is in compliance with the standard.
Nothing in this paragraph shall be construed to abrogate the Commission's or Division's authority to
require testing under the Colorado Revised Statutes, Title 25, Article 7, and pursuant to regulations
promulgated by the Commission.
Compliance test(s) shall be conducted under such conditions as the Division shall specify to the plant operator based
on representative performance of the affected facility. The owner or operator shall make available to the Division
such records as may be necessary to determine the conditions of the performance test(s). Operations during period of
startup, shutdown, and malfunction shall not constitute representative conditions of performance test(s) unless
otherwise specified in the applicable standard.
The owner or operator of an affected facility shall provide the Division thirty days prior notice of the performance test to
afford the Division the opportunity to have an observer present. The Division may waive the thirty day notice
requirement provided that arrangements satisfactory to the Division are made for earlier testing.
The owner or operator of an affected facility shall provide, or cause to be provided, performance testing facilities as follows:
(i) Sampling ports adequate for test methods applicable to such facility;
(ii) Safe sampling platform(s);
(iii) Safe access to sampling platform(s); and
(iv) Utilities for sampling and testing equipment.
Each performance test shall consist of at least three separate runs using the applicable test method. Each run shall be
conducted for the time and under the conditions specified in the applicable standard. For the purpose of determining
compliance with an applicable standard, the arithmetic mean of results of at least three runs shall apply. In the event
that a sample is accidentally lost or conditions occur in which one of the runs must be discontinued because of
forced shutdown, failure of an irreplaceable portion of the sample train, extreme meteorological conditions, or other
circumstances beyond the owner or operator's control, compliance may, upon the Division's approval, be
determined using the arithmetic mean of the results of the two other runs.
Nothing in this section shall abrogate the Division's authority to conduct its own performance test(s) if so warranted.
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 38
d. Affirmative Defense Provision for Excess Emissions during Malfunctions
An affirmative defense to a claim of violation under these regulations is provided to owners and operators for civil
penalty actions for excess emissions during periods of malfunction. To establish the affirmative defense and to be
relieved of a civil penalty in any action to enforce an applicable requirement, the owner or operator of the facility
must meet the notification requirements below in a timely manner and prove by a preponderance of evidence that:
(i) The excess emissions were caused by a sudden, unavoidable breakdown of equipment, or a sudden,
unavoidable failure of a process to operate in the normal or usual manner, beyond the reasonable control of
the owner or operator;
(ii) The excess emissions did not stem from any activity or event that could have reasonably been foreseen and
avoided, or planned for, and could not have been avoided by better operation and maintenance practices;
(iii) Repairs were made as expeditiously as possible when the applicable emission limitations were being
exceeded;
(iv) The amount and duration of the excess emissions (including any bypass) were minimized to the maximum
extent practicable during periods of such emissions;
(v) All reasonably possible steps were taken to minimize the impact of the excess emissions on ambient air
quality;
(vi) All emissions monitoring systems were kept in operation (if at all possible);
(vii) The owner or operator's actions during the period of excess emissions were documented by properly
signed, contemporaneous operating logs or other relevant evidence;
(viii) The excess emissions were not part of a recurring pattern indicative of inadequate design, operation, or
maintenance;
(ix) At all times, the facility was operated in a manner consistent with good practices for minimizing emissions.
This section is intended solely to be a factor in determining whether an affirmative defense is available to
an owner or operator, and shall not constitute an additional applicable requirement; and
(x) During the period of excess emissions, there were no exceedances of the relevant ambient air quality
standards established in the Commissions' Regulations that could be attributed to the emitting source.
The owner or operator of the facility experiencing excess emissions during a malfunction shall notify the division
verbally as soon as possible, but no later than noon of the Division's next working day, and shall submit written
notification following the initial occurrence of the excess emissions by the end of the source's next reporting period.
The notification shall address the criteria set forth above.
The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief.
The Affirmative Defense Provision does not apply to failures to meet federally promulgated performance standards
or emission limits, including, but not limited to, new source performance standards and national emission standards
for hazardous air pollutants. The affirmative defense provision does not apply to state implementation plan (sip)
limits or permit limits that have been set taking into account potential emissions during malfunctions, including, but
not necessarily limited to, certain limits with 30 -day or longer averaging times, limits that indicate they apply during
malfunctions, and limits that indicate they apply at all times or without exception.
e. Circumvention Clause
A person shall not build, erect, install, or use any article, machine, equipment, condition, or any contrivance, the use
of which, without resulting in a reduction in the total release of air pollutants to the atmosphere, reduces or conceals
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 39
an emission which would otherwise constitute a violation of this regulation. No person shall circumvent this
regulation by using more openings than is considered normal practice by the industry or activity in question.
f. Compliance Certifications
g.
For the purpose of submitting compliance certifications or establishing whether or not a person has violated or is in
violation of any standard in the Colorado State Implementation Plan, nothing in the Colorado State Implementation
Plan shall preclude the use, including the exclusive use, of any credible evidence or information, relevant to whether
a source would have been in compliance with applicable requirements if the appropriate performance or compliance
test or procedure had been performed. Evidence that has the effect of making any relevant standard or permit term
more stringent shall not be credible for proving a violation of the standard or permit term.
When compliance or non-compliance is demonstrated by a test or procedure provided by permit or other applicable
requirement, the owner or operator shall be presumed to be in compliance or non-compliance unless other relevant
credible evidence overcomes that presumption.
Affirmative Defense Provision for Excess Emissions During Startup and Shutdown
An affirmative defense is provided to owners and operators for civil penalty actions for excess emissions during
periods of startup and shutdown. To establish the affirmative defense and to be relieved of a civil penalty in any
action to enforce an applicable requirement, the owner or operator of the facility must meet the notification
requirements below in a timely manner and prove by a preponderance of the evidence that:
(i)
The periods of excess emissions that occurred during startup and shutdown were short and infrequent and
could not have been prevented through careful planning and design;
(ii) The excess emissions were not part of a recurring pattern indicative of inadequate design, operation or
maintenance;
(iii) If the excess emissions were caused by a bypass (an intentional diversion of control equipment), then the
bypass was unavoidable to prevent loss of life, personal injury, or severe property damage;
(iv) The frequency and duration of operation in startup and shutdown periods were minimized to the maximum
extent practicable;
(v) All possible steps were taken to minimize the impact of excess emissions on ambient air quality;
(vi) All emissions monitoring systems were kept in operation (if at all possible);
(vii) The owner or operator's actions during the period of excess emissions were documented by properly
signed, contemporaneous operating logs or other relevant evidence; and,
(viii) At all times, the facility was operated in a manner consistent with good practices for minimizing emissions.
This subparagraph is intended solely to be a factor in determining whether an affirmative defense is
available to an owner or operator, and shall not constitute an additional applicable requirement.
The owner or operator of the facility experiencing excess emissions during startup and shutdown shall notify the
Division verbally as soon as possible, but no later than two (2) hours after the start of the next working day, and shall
submit written quarterly notification following the initial occurrence of the excess emissions. The notification shall
address the criteria set forth above.
The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief.
The Affirmative Defense Provision does not apply to State Implementation Plan provisions or other requirements
that derive from new source performance standards or national emissions standards for hazardous air pollutants, or
any other federally enforceable performance standard or emission limit with an averaging time greater than twenty -
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 40
four hours. In addition, an affirmative defense cannot be used by a single source or small group of sources where
the excess emissions have the potential to cause an exceedance of the ambient air quality standards or Prevention of
Significant Deterioration (PSD) increments.
In making any determination whether a source established an affirmative defense, the Division shall consider the
information within the notification required above and any other information the Division deems necessary, which
may include, but is not limited to, physical inspection of the facility and review of documentation pertaining to the
maintenance and operation of process and air pollution control equipment.
4. Compliance Requirements
Regulation No. 3, 5 CCR 1001-5, Part C, §§ III.C.9., V.C.11. & 16.d. and § 25-7-122.1(2), C.R.S.
a. The permittee must comply with all conditions of the Operating Permit. Any permit noncompliance relating to
federally -enforceable terms or conditions constitutes a violation of the federal act, as well as the state act and
Regulation No. 3. Any permit noncompliance relating to state -only terms or conditions constitutes a violation of the
state act and Regulation No. 3, shall be enforceable pursuant to state law, and shall not be enforceable by citizens
under § 304 of the federal act. Any such violation of the federal act, the state act or regulations implementing either
statute is grounds for enforcement action, for permit termination, revocation and reissuance or modification or for
denial of a permit renewal application.
b. It shall not be a defense for a permittee in an enforcement action or a consideration in favor of a permittee in a
permit termination, revocation or modification action or action denying a permit renewal application that it would
have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of
the permit.
c. The permit may be modified, revoked, reopened, and reissued, or terminated for cause. The filing of any request by
the permittee for a permit modification, revocation and reissuance, or termination, or any notification of planned
changes or anticipated noncompliance does not stay any permit condition, except as provided in §§ X. and XI. of
Regulation No. 3, Part C.
d. The permittee shall furnish to the Air Pollution Control Division, within a reasonable time as specified by the
Division, any information that the Division may request in writing to determine whether cause exists for modifying,
revoking and reissuing, or terminating the permit or to determine compliance with the permit. Upon request, the
permittee shall also furnish to the Division copies of records required to be kept by the permittee, including
information claimed to be confidential. Any information subject to a claim of confidentiality shall be specifically
identified and submitted separately from information not subject to the claim.
e. Any schedule for compliance for applicable requirements with which the source is not in compliance at the time of
permit issuance shall be supplemental, and shall not sanction noncompliance with, the applicable requirements on
which it is based.
f. For any compliance schedule for applicable requirements with which the source is not in compliance at the time of
permit issuance, the permittee shall submit, at least every 6 months unless a more frequent period is specified in the
applicable requirement or by the Air Pollution Control Division, progress reports which contain the following:
g.
(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.
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
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 41
Regulation No. 3, 5 CCR 1001-5, Part C, § VII.E
An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the
source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that
causes the source to exceed the technology -based emission limitation under the permit due to unavoidable increases in
emissions attributable to the emergency. "Emergency" does not include noncompliance to the extent caused by improperly
designed equipment, lack of preventative maintenance, careless or improper operation, or operator error. An emergency
constitutes an affirmative defense to an enforcement action brought for noncompliance with a technology -based emission
limitation if the permittee demonstrates, through properly signed, contemporaneous operating logs, or other relevant evidence
that:
a. An emergency occurred and that the permittee can identify the cause(s) of the emergency;
b. the permitted facility was at the time being properly operated;
c. during the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that
exceeded the emission standards, or other requirements in the permit; and
d. the permittee submitted oral notice of the emergency to the Air Pollution Control Division no later than noon of the
next working day following the emergency, and followed by written notice within one month of the time when
emissions limitations were exceeded due to the emergency. This notice must contain a description of the
emergency, any steps taken to mitigate emissions, and corrective actions taken.
This emergency provision is in addition to any emergency or malfunction provision contained in any applicable requirement.
6. Emission Controls for Asbestos
Regulation No. 8, 5 CCR 1001-10, Part B
The permittee shall not conduct any asbestos abatement activities except in accordance with the provisions of Regulation No.
8, Part B, "asbestos control."
7. Emissions Trading, Marketable Permits, Economic Incentives
Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.13.
No permit revision shall be required under any approved economic incentives, marketable permits, emissions trading and
other similar programs or processes for changes that are specifically provided for in the permit.
8. Fee Payment
C.R.S $§ 25-7-114.1(6) and 25-7-114.7
a. The permittee shall pay an annual emissions fee in accordance with the provisions of C.R.S. § 25-7-114.7. A 1%
per month late payment fee shall be assessed against any invoice amounts not paid in full on the 91st day after the
date of invoice, unless a permittee has filed a timely protest to the invoice amount.
b. The permittee shall pay a permit processing fee in accordance with the provisions of C.R.S. § 25-7-114.7. If the
Division estimates that processing of the permit will take more than 30 hours, it will notify the permittee of its
estimate of what the actual charges may be prior to commencing any work exceeding the 30 hour limit.
c. The permittee shall pay an APEN fee in accordance with the provisions of C.R.S. § 25-7-114.1(6) for each APEN or
revised APEN filed.
9. Fugitive Particulate Emissions
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 42
Regulation No. 1, 5 CCR 1001-3, § III.D.1.
The permittee shall employ such control measures and operating procedures as are necessary to minimize fugitive particulate
emissions into the atmosphere, in accordance with the provisions of Regulation No. 1, § III.D.1.
10. Inspection and Entry
Regulation No. 3, 5 CCR 1001-5, Part C, $ V.C.16.b.
Upon presentation of credentials and other documents as may be required by law, the permittee shall allow the Air Pollution
Control Division, or any authorized representative, to perform the following:
a. Enter upon the permittee's premises where an Operating Permit source is located, or emissions -related activity is
conducted, or where records must be kept under the terms of the permit;
b. have access to, and copy, at reasonable times, any records that must be kept under the conditions of the permit;
c. inspect at reasonable times any facilities, equipment (including monitoring and air pollution control equipment),
practices, or operations regulated or required under the Operating Permit;
d. sample or monitor at reasonable times, for the purposes of assuring compliance with the Operating Permit or
applicable requirements, any substances or parameters.
11. Minor Permit Modifications
Regulation No. 3, 5 CCR 1001-5, Part C, §§ X. & XI.
The permittee shall submit an application for a minor permit modification before making the change requested in the
application. The permit shield shall not extend to minor permit modifications.
12. New Source Review
Regulation No. 3, 5 CCR 1001-5, Part B
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.
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
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 43
contemporaneous notification to the Air Pollution Control Division and to the Environmental Protection Agency at the
addresses listed in Appendix D of this Permit. The permit shield shall not apply to any off -permit change.
16. Opacity
Regulation No. 1, 5 CCR 1001-3, §§ I., II.
The permittee shall comply with the opacity emissions limitation set forth in Regulation No. 1, §§ I.- II.
17. Open Burning
Regulation No. 9, 5 CCR 1001-11.
The permittee shall obtain a permit from the Division for any regulated open burning activities in accordance with provisions
of Regulation No. 9.
18. Ozone Depleting Compounds
Regulation No. 15, 5 CCR 1001-17.
The permittee shall comply with the provisions of Regulation No. 15 concerning emissions of ozone depleting compounds.
Sections I., II.C., II.D., III. IV., and V. of Regulation No. 15 shall be enforced as a matter of state law only.
19. Permit Expiration and Renewal
Regulation No. 3, 5 CCR 1001-5, Part C, §§ III.B.6., IV.C., V.C.2.
a. The permit term shall be five (5) years. The permit shall expire at the end of its term. Permit expiration terminates
the permittee's right to operate unless a timely and complete renewal application is submitted.
b. Applications for renewal shall be submitted at least twelve months, but not more than 18 months, prior to the
expiration of the Operating Permit. An application for permit renewal may address only those portions of the permit
that require revision, supplementing, or deletion, incorporating the remaining permit terms by reference from the
previous permit. A copy of any materials incorporated by reference must be included with the application.
20. Portable Sources
Regulation No. 3, 5 CCR 1001-5, Part C, § II.D.
Portable Source permittees shall notify the Air Pollution Control Division at least 10 days in advance of each change in
location.
21. Prompt Deviation Reporting
Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.7.b.
The permittee shall promptly report any deviation from permit requirements, including those attributable to malfunction
conditions as defined in the permit, the probable cause of such deviations, and any corrective actions or preventive measures
taken.
"Prompt" is defined as follows:
a. Any definition of "prompt" or a specific timeframe for reporting deviations provided in an underlying applicable
requirement as identified in this permit; or
b. Where the underlying applicable requirement fails to address the time frame for reporting deviations, reports of
deviations will be submitted based on the following schedule:
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 44
(i)
For emissions of a hazardous air pollutant or a toxic air pollutant (as identified in the applicable regulation)
that continue for more than an hour in excess of permit requirements, the report shall be made within 24
hours of the occurrence;
(ii) for emissions of any regulated air pollutant, excluding a hazardous air pollutant or a toxic air pollutant that
continue for more than two hours in excess of permit requirements, the report shall be made within 48
hours; and
(iii) for all other deviations from permit requirements, the report shall be submitted every six (6) months, except
as otherwise specified by the Division in the permit in accordance with paragraph 22.d. below.
c. If any of the conditions in paragraphs b.i or b.ii above are met, the source shall notify the Division by telephone
(303-692-3155) or facsimile (303-782-0278) based on the timetables listed above. [Explanatory note: Notification
by telephone or facsimile must specify that this notification is a deviation report for an Operating Permit.] A
written notice, certified consistent with General Condition 2.a. above (Certification Requirements), shall be
submitted within 10 working days of the occurrence. All deviations reported under this section shall also be
identified in the 6 -month report required above.
"Prompt reporting" does not constitute an exception to the requirements of "Emergency Provisions" for the purpose of
avoiding enforcement actions.
22. Record Keeping and Reporting Requirements
Regulation No. 3, 5 CCR 1001-5, Part A, $ II.; Part C, §§ V.C.6., V.C.7.
a. Unless otherwise provided in the source specific conditions of this Operating Permit, the permittee shall maintain
compliance monitoring records that include the following information:
(i) date, place as defined in the Operating Permit, and time of sampling or measurements;
(ii) date(s) on which analyses were performed;
(iii) the company or entity that performed the analysis;
(iv) the analytical techniques or methods used;
(v) the results of such analysis; and
(vi) the operating conditions at the time of sampling or measurement.
b. The permittee shall retain records of all required monitoring data and support information for a period of at least five
(5) years from the date of the monitoring sample, measurement, report or application. Support information, for this
purpose, includes all calibration and maintenance records and all original strip -chart recordings for continuous
monitoring instrumentation, and copies of all reports required by the Operating Permit. With prior approval of the
Air Pollution Control Division, the permittee may maintain any of the above records in a computerized form.
c. Permittees must retain records of all required monitoring data and support information for the most recent twelve
(12) month period, as well as compliance certifications for the past five (5) years on -site at all times. A permittee
shall make available for the Air Pollution Control Division's review all other records of required monitoring data
and support information required to be retained by the permittee upon 48 hours advance notice by the Division.
d. The permittee shall submit to the Air Pollution Control Division all reports of any required monitoring at least every
six (6) months, unless an applicable requirement, the compliance assurance monitoring rule, or the Division requires
submission on a more frequent basis. All instances of deviations from any permit requirements must be clearly
identified in such reports.
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 45
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, § XII.A.
The permittee shall provide a minimum 7 -day advance notification to the Air Pollution Control Division and to the
Environmental Protection Agency at the addresses listed in Appendix D of this Permit. The permittee shall attach a copy of
each such notice given to its Operating Permit.
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 Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 46
Regulation No. 3, 5 CCR 1001-5, Part C, § III.B.2.
The permittee shall not make a significant modification required to be reviewed under Regulation No. 3, Part B
("Construction Permit" requirements) without first receiving a construction permit. The permittee shall submit a complete
Operating Permit application or application for an Operating Permit revision for any new or modified source within twelve
months of commencing operation, to the address listed in Item 1 in Appendix D of this permit. If the permittee chooses to
use the "Combined Construction/Operating Permit" application procedures of Regulation No. 3, Part C, then the Operating
Permit must be received prior to commencing construction of the new or modified source.
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, § II.C.
No transfer or assignment of ownership of the Operating Permit source will be effective unless the prospective owner or
operator applies to the Air Pollution Control Division on Division -supplied Administrative Permit Amendment forms, for
reissuance of the existing Operating Permit. No administrative permit shall be complete until a written agreement containing
a specific date for transfer of permit, responsibility, coverage, and liability between the permittee and the prospective owner
or operator has been submitted to the Division.
29. Volatile Organic Compounds
Regulation No. 7, 5 CCR 1001-9, §$ III & V.
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.
a.
All storage tank gauging devices, anti -rotation devices, accesses, seals, hatches, roof drainage systems, support
structures, and pressure relief valves shall be maintained and operated to prevent detectable vapor loss except when
opened, actuated, or used for necessary and proper activities (e.g. maintenance). Such opening, actuation, or use
shall be limited so as to minimize vapor loss.
Detectable vapor loss shall be determined visually, by touch, by presence of odor, or using a portable hydrocarbon
analyzer. When an analyzer is used, detectable vapor loss means a VOC concentration exceeding 10,000 ppm.
Testing shall be conducted as in Regulation No. 7, Section VIII.C.3.
b. Except when otherwise provided by Regulation No. 7, all volatile organic compounds, excluding petroleum liquids,
transferred to any tank, container, or vehicle compartment with a capacity exceeding 212 liters (56 gallons), shall be
transferred using submerged or bottom filling equipment. For top loading, the fill tube shall reach within six inches
of the bottom of the tank compartment. For bottom -fill operations, the inlet shall be flush with the tank bottom.
c. The permittee shall not dispose of volatile organic compounds by evaporation or spillage unless Reasonably
Available Control Technology (RACT) is utilized.
d. No owner or operator of a bulk gasoline terminal, bulk gasoline plant, or gasoline dispensing facility as defined in
Colorado Regulation No. 7, 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 Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE090
Colorado Interstate Gas Company
Cheyenne Station
Page 47
e. Beer production and associated beer container storage and transfer operations involving volatile organic compounds
with a true vapor pressure of less than 1.5 PSIA actual conditions are exempt from the provisions of paragraph b,
above.
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.
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Appendices
OPERATING PERMIT APPENDICES
A - INSPECTION INFORMATION
B - MONITORING AND PERMIT DEVIATION REPORT
C - COMPLIANCE CERTIFICATION REPORT
D - NOTIFICATION ADDRESSES
E - PERMIT ACRONYMS
F - PERMIT MODIFICATIONS
*DISCLAIMER:
None of the information found in these Appendices shall be considered to be State or
Federally enforceable, except as otherwise provided in the permit, and is presented to
assist the source, permitting authority, inspectors, and citizens.
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Inspection Information
Appendix A
Page 1
APPENDIX A - Inspection Information
Directions to Plant:
Cheyenne Compressor Station is located approximately 4 miles north of Rockport in Weld County on
Highway 85.
Safety Equipment Required:
Eye Protection
Hard Hat
Safety Shoes
Hearing Protection
Facility Plot Plan:
Figure 1 (following page) shows the plot plan as submitted on April 20, 2005 to support the source's
Title V Renewal Operating Permit Application.
List of Insignificant Activities:
The following list of insignificant activities was provided by the source to assist in the understanding of
the facility layout. Since there is no requirement to update such a list, activities may have changed since
the last filing.
The asterisk (*) denotes an insignificant activity source category based on the size of the activity,
emissions levels from the activity or the production rate of the activity. The owner or operator of
individual emission points in insignificant activity source categories marked with an asterisk (*) must
maintain sufficient record keeping verifying that the exemption applies. Such records shall be made
available for Division review upon request. (Colorado Regulation No. 3, Part C, Section II.E)
Insignificant activities and/or sources of emissions as submitted in the application are as follows:
Each individual piece of fuel burning equipment that uses gaseous fuel, and that has a design rate less
than or equal to ten million British thermal units per hour, and that is used solely for heating buildings
for personal comfort (Reg 3, Part C.II.E.3.ggg)
Cleaver Brooks Natural Gas Boiler, rated at 8.4 MMBtu/hr
Cleaver Brooks Natural Gas Boiler, rated at 1.1 MMBtu/hr
Parker Heating Boiler, rated at 2.6 MMBtu/hr
*Individual emission points in attainment or attainment/maintenance areas having uncontrolled actual
emissions of any criteria pollutant of less than two tons per year (Reg 3, Part C.II.E.3.a)
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Inspection Information
Appendix A
Page 2
Cheyenne — CIG Fugitive VOC emissions from equipment leaks (formerly addressed in Colorado
Construction Permit 96WE039)
Cheyenne — CIG Venting of natural gas prior to engine overhaul
Cheyenne — CIG T-5 New Ambitrol storage 8,820 gal
Cheyenne — CIG T-10 Water well storage 65,800 gal
Cheyenne — CIG T-16 Domestic water storage 7,500 gal
Cheyenne — WIC T-2 Hydraulic oil storage 580 gal
Cheyenne — WIC T-4 Hydraulic oil storage 2,000 gal
Cheyenne — WIC T-5 Ambitrol storage 8,820 gal
Cheyenne — Front Range T-6406 Ambitrol storage 8,820 gal
Storage tanks of capacity less than forty thousand gallons of lubricating oils or waste lubricating oils
(Reg 3, Part C.II.E.3.aaa)
Cheyenne — CIG T-1 Lube oil day tank 150 gal
Cheyenne — CIG T-3 New oil storage 6,800 gal
Cheyenne — CIG T-4 New oil storage 2,000 gal
Cheyenne — CIG T-15 Waste liquid tank (oil, Ambitrol, water, scrubber dumps) 12,690 gal
Cheyenne — WIC T-1 Lube oil day tank 150 gal
Cheyenne — WIC T-3.1 New oil storage 8,000 gal
Cheyenne — WIC T-3.2 Used oil storage 2,000 gal
Cheyenne — WIC T-6 Waste liquid tank (oil, Ambitrol, water, scrubber dumps) 8,400 gal
Cheyenne — WIC T-7 Waste liquid tank (oil, Ambitrol, water) 500 gal
Cheyenne — Front Range T-6402 Waste liquid tank (oil, Ambitrol, water) 600 gal
Cheyenne — Front Range T -6404A New oil storage 8,400 gal
Cheyenne — Front Range T -6404B Used oil storage 1,930 gal
Cheyenne — Front Range T-6501 Lube oil day tank 180 gal
Stationary Internal Combustion Engines that are emergency power generators that operate no more than
two hundred fifty hours per year (Reg 3, Part C.II.E.3.nnn.(ii)); or have uncontrolled actual emissions
less than five tons per year (Reg 3, Part C.II.E.3.nnn.(iii))
CIG Emergency Generator Waukesha F2895 GSIU, rated at 607 hp
WIC Emergency Generator Cummins GTA 1710, rated at 600 hp
Front Range Emergency Generator Caterpillar G3412 CTA130LE, rated at 598 hp
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Inspection Information
Appendix A
Page 3
This Page Intentionally Left Blank
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
Appendix B
Page 1
APPENDIX B
Reporting Requirements and Definitions
with codes ver 8/20/2014
Please note that, pursuant to 113(c)(2) of the federal Clean Air Act, any person who knowingly:
(A) makes any false material statement, representation, or certification in, or omits material information
from, or knowingly alters, conceals, or fails to file or maintain any notice, application, record, report,
plan, or other document required pursuant to the Act to be either filed or maintained (whether with
respect to the requirements imposed by the Administrator or by a State);
(B) fails to notify or report as required under the Act; or
(C) falsifies, tampers with, renders inaccurate, or fails to install any monitoring device or method required to
be maintained or followed under the Act shall, upon conviction, be punished by a fine pursuant to title
18 of the United States Code, or by imprisonment for not more than 2 years, or both. If a conviction of
any person under this paragraph is for a violation committed after a first conviction of such person under
this paragraph, the maximum punishment shall be doubled with respect to both the fine and
imprisonment.
The permittee must comply with all conditions of this operating permit. Any permit noncompliance constitutes
a violation of the Act and is grounds for enforcement action; for permit termination, revocation and reissuance,
or modification; or for denial of a permit renewal application.
The Part 70 Operating Permit program requires three types of reports to be filed for all permits.
All required reports must be certified by a responsible official.
Report #1: Monitoring Deviation Report (due at least every six months)
For purposes of this operating permit, the Division is requiring that the monitoring reports are due every six
months unless otherwise noted in the permit. All instances of deviations from permit monitoring requirements
must be clearly identified in such reports.
For purposes of this operating permit, monitoring means any condition determined by observation, by data from
any monitoring protocol, or by any other monitoring which is required by the permit as well as the
recordkeeping associated with that monitoring. This would include, for example, fuel use or process rate
monitoring, fuel analyses, and operational or control device parameter monitoring.
Report #2: Permit Deviation Report (must be reported "promptly")
In addition to the monitoring requirements set forth in the permits as discussed above, each and every
requirement of the permit is subject to deviation reporting. The reports must address deviations from permit
requirements, including those attributable to upset conditions and malfunctions as defined in this Appendix, the
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
Appendix B
Page 2
probable cause of such deviations, and any corrective actions or preventive measures taken. All deviations from
any term or condition of the permit are required to be summarized or referenced in the annual compliance
certification.
For purposes of this operating permit, "malfunction" shall refer to both emergency conditions and malfunctions.
Additional discussion on these conditions is provided later in this Appendix.
For purposes of this operating permit, the Division is requiring that the permit deviation reports are due as set
forth in General Condition 21. Where the underlying applicable requirement contains a definition of prompt or
otherwise specifies a time frame for reporting deviations, that definition or time frame shall govern. For
example, quarterly Excess Emission Reports required by an NSPS or Regulation No. 1, Section IV.
In addition to the monitoring deviations discussed above, included in the meaning of deviation for the purposes
of this operating permit are any of the following:
(1) A situation where emissions exceed an emission limitation or standard contained in the permit;
(2) A situation where process or control device parameter values demonstrate that an emission limitation
or standard contained in the permit has not been met;
(3)
A situation in which observations or data collected demonstrates noncompliance with an emission
limitation or standard or any work practice or operating condition required by the permit; or,
(4) A situation in which an excursion or exceedance as defined in 40 CFR 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:
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 40 CFR 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.
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
Appendix B
Page 3
Compliance Certifications are intended to state the compliance status of each requirement of the permit over the
certification period. They must be based, at a minimum, on the testing and monitoring methods specified in the
permit that were conducted during the relevant time period. In addition, if the owner or operator knows of other
material information (i.e. information beyond required monitoring that has been specifically assessed in relation
to how the information potentially affects compliance status), that information must be identified and addressed
in the compliance certification. The compliance certification must include the following:
• The identification of each term or condition of the permit that is the basis of the certification;
• 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.1
• Such other facts as the Division may require, consistent with the applicable requirements to
which the source is subject, to determine the compliance status of the source.
The Certification shall also identify as possible exceptions to compliance any periods during which compliance
is required and in which an excursion or exceedance as defined under 40CFR Part 64 (the Compliance
Assurance Monitoring (CAM) Rule) has occurred. (only for emission points subject to CAM)
Note the requirement that the certification shall identify each deviation and take it into account in the
compliance certification. Previously submitted deviation reports, including the deviation report submitted at the
time of the annual certification, may be referenced in the compliance certification.
1 For example, given the various emissions limitations and monitoring requirements to which a source may be
subject, a deviation from one requirement may not be a deviation under another requirement which recognizes
an exception and/or special circumstances relating to that same event.
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed. DRAFT
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
Appendix B
Page 4
Startup, Shutdown, Malfunctions and Emergencies
Understanding the application of Startup, Shutdown, Malfunctions and Emergency Provisions, is very important
in both the deviation reports and the annual compliance certifications.
Startup, Shutdown, and Malfunctions
Please note that exceedances of some New Source Performance Standards (NSPS) and Maximum Achievable
Control Technology (MACT) standards that occur during Startup, Shutdown or Malfunctions may not be
considered to be non-compliance since emission limits or standards often do not apply unless specifically stated
in the NSPS. Such exceedances must, however, be reported as excess emissions per the NSPS/MACT rules and
would still be noted in the deviation report. In regard to compliance certifications, the permittee should be
confident of the information related to those deviations when making compliance determinations since they are
subject to Division review. The concepts of Startup, Shutdown and Malfunctions also exist for Best Available
Control Technology (BACT) sources, but are not applied in the same fashion as for NSPS and MACT sources.
Emergency Provisions
Under the Emergency provisions of Part 70 certain operational conditions may act as an affiuniative 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 Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 5
Monitoring and Permit Deviation Report - Part I
1. Following is the required format for the Monitoring and Permit Deviation report to be submitted to the
Divisionon a semi-annual basis unless otherwise noted in the permit. The Table below must be
completed for all equipment or processes for which specific Operating Permit terms exist.
2. Part II of this Appendix B shows the format and information the Division will require for describing
periods of monitoring and permit deviations, or upset or emergency conditions as indicated in the Table
below. One Part II Form must be completed for each Deviation. Previously submitted reports (e.g.
EERs or malfunctions) may be referenced and the form need not be filled out in its entirety.
FACILITY NAME: Colorado Interstate Gas Company — Cheyenne Compressor Station
OPERATING PERMIT NO: 95OPWE090
REPORTING PERIOD: (see first page of the permit for specific reporting period and dates)
Operating
Permit Unit
ID
Unit Description
Deviations Noted
During Period?'
Deviation
Code2
Upset/Emergency
Condition Reported
During Period?
YES
NO
YES
NO
E001
Cooper ICE, S/N 48534. CIG CG -1
E002
Cooper ICE, S/N 48533. CIG CG -2
E003
Cooper ICE, S/N 48532. CIG CG -3
E004
Cooper ICE, S/N 48531. CIG CG -4
E005
Cooper ICE, S/N 48867. WIC CG -1
E006
Cooper ICE, S/N 48868. WIC CG -1
E-7301
Cooper ICE, S/N 46291. WIC CG -7301
E-7401
Cooper ICE, S/N 48468. WIC CG -7401
E008
Caterpillar ICE, S/N 4ZS00310. FR CG -7501
E009
Solar Combustion Turbine, S/N 1255T. FR CG -7601.
E010
Caterpillar ICE, S/N BEN00254. FR/CP CG -7701
General Conditions
Insignificant Activities
See previous discussion regarding what is considered to be a deviation. Determination of whether or not a deviation as occurre
shall be based on a reasonable inquiry using readily available information.
2Use the following entries as appropriate:
1 = Standard: When the requirement is an emission limit or standard
2 = Process: When the requirement is a production/process limit
3 = Monitor: When the requirement is monitoring
4 = Test: When the requirement is testing
5 = Maintenance: When required maintenance is not performed
6 = Record: When the requirement is recordkeeping
7 = Report: When the requirement is reporting
8 = CAM: A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the Compliance Assurance
Monitoring (CAM) Rule) has occurred.
9 = Other: When the deviation is not covered by any of the above categories
Operating Permit Number: 95OPWE090
First Issued: 9/1/98
Renewed: DRAFT
•
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
Appendix B
Page 6
Monitoring and Permit Deviation Report - Part II
FACILITY NAME: Colorado Interstate Gas Company — Cheyenne Compressor Station
OPERATING PERMIT NO: 95OPWE090
REPORTING PERIOD:
Is the deviation being claimed as an: Emergency Upset N/A
(For NSPS/MACT) Did the deviation occur during Startup Shutdown Malfunction
Normal Operation
OPERATING PERMIT UNIT IDENTIFICATION:
Operating Permit Condition Number Citation
Explanation of Period of Deviation
Duration (start/stop date & time)
Action Taken to Correct the Problem
Measures Taken to Prevent a Reoccurrence of the Problem
Dates of Upsets/Emergencies Reported (if applicable)
Deviation Code (for Division Use Only) Division Code QA
SEE EXAMPLE ON THE NEXT PAGE
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
Appendix B
Page 7
EXAMPLE
FACILITY NAME: Acme Corp.
OPERATING PERMIT NO: 96OPZZXXX
REPORTING PERIOD: 1/1/96 - 6/30/96
Is the deviation being claimed as an: Emergency Malfunction XX N/A
(For NSPS/MACT) Did the deviation occur during: Startup Shutdown Malfunction
Normal Operation
OPERATING PERMIT UNIT IDENTIFICATION:
Asphalt Plant with a Scrubber for Particulate Control - Unit XXX
Operating Permit Condition Number Citation
Section II, Condition 3.1 - Opacity Limitation
Explanation of Period of Deviation
Slurry Line Feed Plugged
Duration
START- 1730 4/10/96
END- 1800 4/10/96
Action Taken to Correct the Problem
Line Blown Out
Measures Taken to Prevent Reoccurrence of the Problem
Replaced Line Filter
Dates of Upsets/Emergencies Reported (if applicable)
4/10/96 to S. Busch, APCD
Deviation Code (for Division Use Only)
Division Code QA
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
Appendix B
Page 8
Monitoring and Permit Deviation Report - Part III
REPORT CERTIFICATION
SOURCE NAME: Colorado Interstate Gas Company — Cheyenne Compressor Station
FACILITY IDENTIFICATION NUMBER: 1230051
PERMIT NUMBER: 95OPWE090
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.38. This signed certification document must be
packaged with the documents being submitted.
STATEMENT OF COMPLETENESS
I have reviewed the information being submitted in its entirety and, based on information and belief
formed after reasonable inquiry, I certify that the statements and information contained in this submittal
are true, accurate and complete.
Please note that the Colorado Statutes state that any person who knowingly, as defined in Sub -Section 18-
1-501(6), C.R.S., makes any false material statement, representation, or certification in this document is
guilty of a misdemeanor and may be punished in accordance with the provisions of Sub -Section 25-7
122.1, C.R.S.
Printed or Typed Name Title
Signature of Responsible Official Date Signed
Note: Deviation reports shall be submitted to the Division at the address given in Appendix D of this permit. No copies need be sent
to the U.S. EPA
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Compliance Certification Report
Appendix C
Page 1
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: Colorado Interstate Gas Company — Cheyenne Compressor Station
OPERATING PERMIT NO: 95OPWE090
REPORTING PERIOD:
I. Facility Status
During the entire reporting period, this source was in compliance with ALL terms and conditions contained
in the Permit, each term and condition of which is identified and included by this reference. The method(s)
used to determine compliance is/are the method(s) specified in the Permit.
With the possible exception of the deviations identified in the table below, this source was in compliance
with all terms and conditions contained in the Permit, each term and condition of which is identified and
included by this reference, during the entire reporting period. The method used to determine compliance for
each term and condition is the method specified in the Permit, unless otherwise indicated and described in the
deviation report(s). Note that not all deviations are considered violations.
Operating
Permit Unit
ID
Unit Description
Deviations
Reported'
Monitoring
Method per
Permit?2
Was compliance '
continuous or
intermittent?3
Was Data
Continuous?4
Previous
Current
YES
NO
Continuous
intermittent
YES
NO
E001
Cooper ICE, S/N 48534. CIG CG -1
E002
Cooper ICE, S/N 48533. CIG CG -2
E003
Cooper ICE, S/N 48532. CIG CG -3
E004
Cooper ICE, S/N 48531. CIG CG -4
E005
Cooper ICE, S/N 48867. WIC CG -1
E006
Cooper ICE, S/N 48868. WIC CG -1
E-7301
Cooper ICE, S/N 46291. WIC CG -
7301
E-7401
Cooper ICE, S/N 48468. WIC CG -
7401
E008
Caterpillar ICE, S/N 4Z500310. FR
CG -7501
E009
Solar Combustion Turbine, S/N
1255T. FR CG -7601.
E010
Caterpillar ICE,S/N BEN00254.
FR/CP CG -7701
Operating Permit Number: 95OPWE090
First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Compliance Certification Report
Appendix C
Page 2
Operating
Permit Unit
ID
Unit Description
Deviations
Reported'
Monitoring
Method per
Permit?2
Was compliance
continuous or
intermittent?3
Was Data
Continuous?4
Previous
I Current
YES
NO
Continuous
'Intermittent
YES
NO
General Conditions
Insignificant Activities 5
If deviations were noted in the previous deviation report (i.e. for the first six months of the annual reporting period), 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.
The Periodic Monitoring requirement 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 has operated in continuous compliance for the duration of the reporting
period. Therefore, if a source 1) conducts all of the monitoring and recordkeeping required in its permit, even if such a activities are
done periodically and not continuously, and if 2) such monitoring and recordkeeping does not indicate non-compliance, and if 3) the
Responsible Official is not aware of any credible evidence that indicates non-compliance, then the Responsible Official can certify
that the emission point(s) in question were in continuous compliance during the applicable time period.
4 Note whether the method(s) used to determine the compliance status with each term and condition provided continuous or
intermittent data.
s Compliance status for these sources shall be based on a reasonable inquiry using readily available information.
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Compliance Certification Report
Appendix C
Page 3
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
section 112(r).
is is not in compliance with all the requirements of
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.38. 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 Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Notification Addresses
Appendix D
Page 1
APPENDIX D
Notification Addresses - February 5, 2014 Version
1. 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
2. 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 Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit Acronyms
Appendix E
Page 1
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
PM10 - Particulate Matter Under 10 Microns
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit Acronyms
Appendix E
Page 2
PPM Parts Per Million
PPMV Parts Per Million, by Volume
PPMVD Parts Per Million, by Volume, Dry
PSD - Prevention of Significant Deterioration
PTE - Potential To Emit
RACT - Reasonably Available Control Technology
SCC - Source Classification Code
SCF - Standard Cubic Feet
SIC - Standard Industrial Classification
SO2 - Sulfur Dioxide
TPY - Tons Per Year
TSP - Total Suspended Particulate
VOC - Volatile Organic Compounds
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Permit Modifications
Appendix F
Page 1
APPENDIX F
Permit Modifications
DATE OF
REVISION
TYPE OF
REVISION
SECTION
NUMBER,
CONDITION
NUMBER
DESCRIPTION OF REVISION
Operating Permit Number: 95OPWE090 First Issued: 9/1/98
Renewed: 3/1/06
TECHNICAL REVIEW DOCUMENT
For
RENEWAL #2 OF OPERATING PERMIT 95OPWE090
Colorado Interstate Gas Company — Cheyenne Compressor Station
Weld County
Source ID 1230051
September - 2016
Operating Permit Engineer:
Operating Permit Supervisor review:
Field Services Unit review:
I. Purpose
Thang Nghiem
Blue Parish
Jennifer Morse
This document will establish 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 proposed for this site. The original Operating
Permit was issued September 1, 1998. The first Operating Permit renewal was issued
March 1, 2006. The expiration date for the first renewal was March 1, 2011. However,
since a timely and complete renewal application was submitted, under Colorado
Regulation No. 3, Part C, Section IV.C all of the terms and conditions of the existing
permit shall not expire until the renewal operating permit is issued and any previously
extended permit shield continues in full force and operation. This document is designed
for reference during the review of the proposed permit by the EPA, the public, and other
interested parties. The conclusions made in this report are based on information
provided in the renewal application submitted February 18, 2010, additional technical
information submitted April 22, 2016, comments on the draft permit and technical review
document received on DRAFT, comments received during the public comment period
(DRAFT), previous inspection reports and various e-mail 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
httlos://www.colorado.gov/cdphe/title-v-operatinq-permits.
Any revisions made to the underlying construction permits associated with this facility
made in conjunction with the processing of this operating permit application have been
reviewed in accordance with the requirements of Regulation No. 3, Part B, Construction
Permits, and have been found to meet all applicable substantive and procedural
requirements. This operating permit incorporates and shall be considered to be a
combined construction/operating permit for any such revision, and the permittee shall
be allowed to operate under the revised conditions upon issuance of this operating
permit without applying for a revision to this permit or for an additional or revised
construction permit.
Page 1
II. Description of Source
This facility is a mainline compressor station. Its main function is to compress and
transmit natural gas from the Wyoming area to the Front Range area located in
Colorado. This is achieved by using eight (8) internal combustion engine driven
horizontal compressors.
In the summer of 2003 construction commenced on an additional internal combustion
engine and turbine, both driving compressors as part of the Front Range Expansion
Project (FREP). The FREP supplies gas to the Colorado Front Range and a power
plant in Colorado Springs.
In the summer of 2004, construction commenced on the Cheyenne Plains Project
(CPP), this additional expansion is to support a new pipeline transporting gas east into
Kansas. The CPP equipment is addressed in a separate Title V operating permit
(05OPWE281) issued on April 1, 2014.
The facility is located approximately 4 miles north of Rockport in Weld County on
Highway 85. The area in which the plant operates is designated as attainment for all
criteria pollutants. There are two affected states within 50 miles of the plant: Wyoming
and Nebraska. The following Federal Class I designated area is within 100 kilometers
of the plant: Rocky Mountain National Park.
Based on the information available to the Division and provided by the applicant, no
modifications have been made to the equipment identified in the current Title V permit
since the previous issuance.
Prevention of Significant Deterioration (PSD)
This facility is located in an area designated attainment for all pollutants. It is
categorized as a major stationary source (Potential to Emit > 250 tons per year for NOx,
CO and VOC). Future modifications at this facility resulting in a significant net
emissions increase (see Regulation No. 3, Part D, Section II.A.27 and 44) for any
pollutant as listed in Regulation No. 3, Part D, Section II.A.44 or a modification which is
major by itself (i.e. a Potential to Emit of > 250 TPY of any pollutant listed in Regulation
No. 3, Part D, Section II.A.44) may result in the application of the PSD review
requirements.
Accidental Release Program — 112(r)
Based on the information provided by the applicant, the facility is not subject to the
provisions of the Accidental Release Prevention Program (section 112(r) of the Federal
Clean Air Act).
Greenhouse Gases
The potential -to -emit of greenhouse gas (GHG) emissions from this facility is greater
than 100,000 TPY CO2e. Future modifications greater than 75,000 tons per year CO2e
may be subject to regulation (Regulation No. 3, Part A, I.B.44).
Page 2
Hazardous Air Pollutants (HAPs)
This facility is considered a major source for hazardous air pollutants as it has a
potential to emit total HAPs of over 25 tons per year.
Facility Wide Emissions
There are two operating permits (95OPWE090 and 05OPWE281) associated with this
facility. The table below demonstrates facility wide emissions.
Pollutant
Potential to Emit (tons/yr)
95OPWE090
05OPWE281
Facility
NOx
624.3
106.6
730.9
CO
262.8
172.1
434.9
VOC
291.3
58.9
350.2
HAPS
60.7
14.1
74.8
*Notes: These numbers are transferred over from the TRD associated with the first renewal of this
operating permit since there are no changes to this renewal application.
95OPWE090 Emissions
Emission Unit
Potential to Emit
(tons/yr)
Actual Emissions
(tons/yr)
HAPs
NOx
CO
VOC
NOx
CO
VOC
Engine - E001 (CIG CG -1)
82.1
26.3
36.2
See Table on
Page 12
Engine - E002 (CIG CG -2)
82.1
26.3
36.2
Engine - E003 (CIG CG -3)
82.1
26.3
36.2
Engine - E004 (CIG CG -4)
82.1
26.3
36.2
Engine - E005 (WIC CG -1)
82.1
26.3
36.2
Engine - E006 (WIC CG -2)
82.1
26.3
36.2
Engine - E-7301 (WIC CG -7301)
39.5
39
30
Engine - E-7401 (WIC CG -7401)
39.5
39
30
Engine - E008 (FR CG -7501)
14.3
3.7
5.3
Turbine - E009 (FR CG -7601)
17.2
18.1
1.4
Engine — E010 (FR CG -7701)
21.2
5.2
7.4
Total
624.3
262.8
291.3
96.4
64.1
43.4
60.7
*Notes: PTE numbers are transferred over from the TRD associated with the first renewal of this
operating permit since there are no changes to this renewal application. Actual emissions are obtained
from the 2015 Emissions Inventory.
The breakdown of HAP emissions by emission unit and individual HAP is provided on
page 11 of this document. As indicated in the footnotes for the table on page 11, the
HAP PTE was determined as follows: for the engines in the current Title V permit it is
based on design rate, permitted annual hours of operation (or 8760 hrs/yr) and the most
conservative emission factor from AP -42 or HAPCalc 2.0, for the new engines it is
based on the permitted emissions for formaldehyde and AP -42 emission factors for the
Page 3
other pollutants and for the FREP turbine, HAP emissions are based on AP -42 emission
factors, design rate and 8760 hrs/yr of operation.
Ill. Applicable Requirements
MACT Requirements
Natural Gas Transmission and Storage MACT (40 CFR Part 63 Subpart HHH)
The most current version of 40 CFR Part 63 Subpart HHH §63.1270 Applicability and
designation of affected source (77 FR 49584, Aug. 16, 2012) still only applies to glycol
dehydrators. There is no glycol dehydrator associated with the equipment addressed in
the current Title V permit and in this renewal therefore this facility is not subject to
Subpart HHH.
RICE MACT (40 CFR Part 63 Subpart ZZZZ)
The final rule for RICE was published in the Federal Register on February 27, 2014.
The requirements in the Operating Permit reflect the most current rule language
published in the Federal Register on February 27, 2014. The eight Cooper engines in
the current Title V permit are 2 -cycle clean burn engines. In accordance with the
provisions in 40 CFR Part 63 Subpart ZZZZ § 63.6590(b)(3)(i), existing (commenced
construction or reconstruction prior to December 19, 2002) 2 -stroke lean burn engines
do not have to meet the requirements in 40 CFR Part 63 Subparts A and ZZZZ,
including the initial notification requirements. The Division considers that the clean burn
engines meet the definition of lean burn engines in 40 CFR Part 63 Subpart ZZZZ §
63.6675.
The Front Range Expansion Project (FREP) and Cheyenne Plains Project (CPP)
engines (both 4 -stroke lean burn engines) were constructed after December 19, 2002
and therefore the RICE MACT requirements apply to these engines. The appropriate
requirements from the RICE MACT will be included in the renewal permit.
RICE MACT for Emergency Generators
Three natural gas fired emergency generators were identified at this facility, two of
which as existing emergency engines that commenced construction prior to December
19, 2002:
• Unit EG-1: CIG Waukesha F2895 GSIU S/N 319934, 607 HP, manufactured in
1982
• Unit EG-6101: WIC Cummins GTA1710, S/N 41500012, 600 HP, manufactured
in 1982
A third emergency generator is identified as a new emergency engine with
manufactured date of 2003:
• Unit EG-3003: Front Range Caterpillar G3412 CTA 130LE, S/N CTP00313, 598
HP
Page 4
Units EG-1 and EG-6101 do not have to meet the requirements of subpart ZZZZ and of
subpart A, including initial notification requirements per 40 CFR Part 60 Subpart ZZZZ
§63.6590(b)(3)(iii). Unit EG-3003 does not have to meet the requirements of subpart
ZZZZ and of subpart A except for the initial notification requirements of §63.6645(f) per
Subpart ZZZZ §63.6590(b)(1)(i).
According to 40 CFR Part 60 Subpart ZZZZ §63.6665, all three emergency engines are
not subject to any of the requirements of the General Provisions specified in Table 8 of
Subpart ZZZZ for the following reasons:
• Unit EG-1 and unit EG-6101 : an existing emergency stationary RICE with a site
rating of more than 500 brake HP located at a major source of HAP emissions
• Unit EG-3003: a new emergency stationary RICE with a site rating of more than
500 brake HP located at a major source of HAP emissions.
However, unit EG-3003 being a new emergency stationary RICE is subject to the initial
notification requirements, which were satisfied upon construction commencement. For
the aforementioned reasons, the emergency generators will not be subject to MACT
ZZZZ and will be covered in the Insignificant Activities List.
Industrial, Commercial and Institutional Boilers and Process Heaters MACT (40 CFR
Part 63 Subpart DDDDD)
The final rule for industrial, commercial and institutional boilers and process heaters
was published in the Federal Register on November 20, 2015 and was last published in
the Federal Register on November 20, 2015. The provisions in 40 CFR Part 63 Subpart
DDDDD no longer exempts existing (constructed before January 13, 2003) small
gaseous fired units (< 10 mmBtu/hr) from the requirements in 40 CFR Part 63 Subpart A
(as specified in Table 10 to Subpart DDDDD) and Subpart DDDDD.
Based on information provided by facility, the two Cleaver Brooks natural gas boilers
and a Parker heating boiler identified in the Insignificant Activities List do not meet the
definition of a boiler in 40 CFR Part 63 Subpart DDDDD (the boilers use a glycol -water
mixture instead of water). These boilers also do not meet the definition of a process
heater since they primarily provide space heat. Therefore, the industrial, commercial
and institutional boilers and process heaters MACT requirements do not apply to the
equipment in the current Title V permit.
Combustion Turbine MACT (40 CFR Part 63 Subpart YYYY)
The final rule for combustion turbines was published in the Federal Register on April 20,
2006. The combustion turbine commenced construction prior to January 14, 2003 (a
purchase order was issued on September 26, 2002). Therefore, in accordance with the
provisions in 40 CFR Part 63 Subpart YYYY § 63.6090(a)(1), the combustion turbine
does not have to meet the requirements in 40 CFR Part 63 Subparts A and YYYY,
including the initial notification requirements.
Page 5
Standards of Performance for Stationary Spark Ignition Internal Combustion Engines
(40 CFR Part 60 Subpart JJJJ).
This subpart applies to owners and operators of stationary SI ICE that commence
construction after June 12, 2006, where the stationary SI ICE are manufactured on or
after July 1, 2007, for engines with a maximum engine power greater than or equal to
500 HP (40 CFR Part 60 Subpart JJJJ §60.4230(a)(4)(i)). All engines at this facility
commenced construction before June 12, 2006 and therefore are not subject to this
subpart.
Colorado Regulation No. 7 Control of Ozone via Ozone Precursors and Control of
Hydrocarbons via Oil and Gas Emissions
The eight Cooper 2 -cycle lean burn engines at the facility are exempt from the
requirements of installing and operating an oxidation catalyst by July 1, 2010 as the
owner or operator demonstrated to the Division that retrofit technology cannot be
installed at a cost of less than $ 5,000 per ton of volatile organic compound emission
reduction (Colorado Regulation No. 7, Section XVII.E.3.b.(ii)). The Division approved
the exemption on a letter dated December 21, 2009.
The two Caterpillar 4 -cycle lean burn engines equipped with oxidation catalysts are not
subject to Colorado Regulation No. 7 as these engines are already subject to a BACT
per Colorado Regulation No. 7, Section XVII.B.5.
Three emergency generators in the Insignificant Activities List will be subject to the
requirements of Colorado Reg. 7 Part XVII.E - Control of emissions from new, modified,
existing, and relocated natural gas fired reciprocating internal combustion engines if
they have operation hours or actual uncontrolled emissions exceeding the categorical
exemption thresholds (250 operation hours or 5 tons/year) listed in Colorado Regulation
Number 3, Part B.II.D.1.c (Colorado Regulation No. 7, Section XVII.E.1 - State Only
Enforceable). These engines will have exceeded 5 tons/year at respectively 554, 560,
and 562 operation hours.
Compliance Assurance Monitoring (CAM) Requirements
CAM applies to any emission unit that is subject to an emission limitation, uses a control
device to achieve compliance with that emission limitation and has potential pre -control
emissions greater than major source levels.
The eight Cooper engines are not equipped with any control devices.
The combustion turbine is equipped with a dry low NOx (DLN) combustion system to
reduce NOx emissions. However, DLN is not considered a control device as defined in
40 CFR Part 64 § 64.1, as adopted by reference in Colorado Regulation No. 3, Part C,
Section XIV, since DLN is considered inherent process equipment. Therefore, CAM
does not apply to the new turbine.
Page 6
The two Caterpillar engines are equipped with oxidation catalysts to reduce CO and
formaldehyde emissions. However, uncontrolled emissions of CO and formaldehyde
are 59 tons/year and 9.44 tons/year (CPP engine) and 42.8 tons/year and 6 tons/year
(FREP engine), respectively, which are below the major source levels of 100 tons/year
for criteria pollutants and 10 tons/yr of HAPs. Therefore, the CAM requirements do not
apply to the new engines.
There has been no equipment added as of the time of this TRD being edited for the
purposes of second renewal application (March 14, 2016), therefore CAM does not
apply to any of the equipment included in the renewal Title V permit.
APEN Requirements for Equipment in Insignificant Activities List
Insignificant Activities List for this facility includes three natural gas boilers. All of which
have design rates of less than 10 MMBtu/hour (8.4 MMBtu/hour, 1.1 MMBtu/hour and
2.6 MMBtu/hour). According to information provided by the facility, these units are used
for providing building heat and therefore are exempt from APEN requirements according
to Colorado Regulation No. 3, Part A, Section II.D.1.ggg.
The three emergency generators identified in the Insignificant Activities List will exceed
the APEN thresholds of 2 tons/year of criteria pollutants in an attainment area and will
need to submit an APEN if they exceed the following operation hours:
Emergency Generator Make
Operation Hours
CIG Waukesha F2895 GSIU, rated at 607 hp
221
WIC Cummins GTA1710, rated at 600 hp
224
Front Range Caterpillar G3412 CTA130LE, rated at 598 hp
225
*Note: emission factors used to calculate these operation hours are from AP -42 Table 3.2-2 for Natural
Gas Fired Engines.
Construction Permitting Requirements for Equipment in Insignificant Activities List
The three emergency generators are categorically exempted from construction permit
requirements (Reg 3, Part B.II.D.1.c) and operating permit requirements (Reg 3, Part
C.II.E.3.nnn) under the conditions that they do not operate more than 250 hours per
year or they have uncontrolled actual emissions less than 5 tons/year. At the following
operation hours, these emergency generators will have exceeded the 5 tons/year
threshold for this above exemption and the facility will be required to obtain a
construction permit, or modify the operating permit to include these engines:
Emergency Generator Make
Operation Hours
CIG Waukesha F2895 GSIU, rated at 607 hp
554
WIC Cummins GTA1710, rated at 600 hp
560
Front Range Caterpillar G3412 CTA130LE, rated at 598 hp
562
`Note: emission factors used to calculate these operation hours are from AP -42 Table 3.2-2 for Natural
Gas Fired Engines.
Page 7
IV. Discussion of Modifications Made
Source Requested Modifications
The source submitted their renewal application #2 on February 18, 2010. This request
and other subsequent requests were addressed as follows:
Page following cover page
CIG requested in their July 25, 2012 letter that an updated permit contact person be
identified in the permit. The Division will grant this request.
Streamlining of Applicable Requirements
No changes are being made in this renewal.
Other Modifications
In addition to the modifications requested by the source, 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.
The Division has made the following revisions, based on recent internal permit
processing decisions and EPA comments, to the Cheyenne Renewal Operating Permit
with the source's requested modifications. These changes are as follows:
Section I — General Activities and Summary
• Added "4 -cycle Lean Burn" to the Caterpillar engine in last item of the Summary
of Emission Units table (6.1).
• Minor language changes were made to Condition 3.1 to more appropriately
reflect the status of the source with respect to PSD.
Section II — Specific Permit Terms
• "Fuel" has been changed to "Natural Gas" throughout the permit to reflect that
only natural gas can be used as fuel.
• Updated Portable Monitoring language in Condition 8 to 06/26/2014 version.
• Removed Conditions 9.10.3 and 9.10.4 - startup, shutdown and malfunction
language (formerly 40 CFR Part 63 Subpart ZZZZ § 63.6640(c) & (d)) because it
has been removed from the rule.
• Updated CFR reference in Condition 9.11.4.
• Removed Startup, Shutdown and Malfunction Report section (Condition 9.12.5)
because these requirements are removed from the rule.
Page 8
• Updated and added language to Condition 9.13 to reflect most recent MACT
ZZZZ updates (9.13.2, 9.13.4, and 9.13.5).
• Updated 9.14.3 to reflect a change that records must be kept on -site for at least 5
years instead of the previous 2 years on -site and 3 years off -site.
• Updated "shall keep monitor" to "shall monitor and keep records" in condition
6.2.1.4
• Removed one time condition to comply with monthly emission limits for one year
following issuance of revised CP (Conditions 6.2.2.1, 6.3, 7.2.2, 7.3, and 7.4)
Section III — Permit Shield
• Change Condition 1. "Specific Conditions" to "Specific Non -applicable
Requirements".
Section IV — General Permit Conditions
• Updated General Permit Conditions to 05/22/2012 version.
Appendices
• Updated Insignificant Activities List in Appendix A with categorical exemptions
under Colorado Regulation No. 3, Part C as follows:
o Reg 3, Part C.II.E.3.ggg - Each individual piece of fuel burning equipment that
uses gaseous fuel, and that has a design rate less than or equal to ten million
British thermal units per hour, and that is used solely for heating buildings for
personal comfort:
■ Cleaver Brooks Natural Gas Boiler, rated at 8.4 MMBtu/hr
■ Cleaver Brooks Natural Gas Boiler, rated at 1.1 MMBtu/hr
■ Parker Heating Boiler, rated at 2.6 MMBtu/hr
o Reg 3, Part C.II.E.3.a - *Individual emission points in attainment or
attainment/maintenance areas having uncontrolled actual emissions of any
criteria pollutant of less than two tons per year:
■ Cheyenne — CIG Fugitive VOC emissions from equipment leaks
(formerly addressed in Colorado Construction Permit 96WE039)
■ Cheyenne — CIG Venting of natural gas prior to engine overhaul
■ Cheyenne — CIG T-5 New Ambitrol storage 8,820 gal
■ Cheyenne — CIG T-10 Water well storage 65,800 gal
■ Cheyenne — CIG T-16 Domestic water storage 7,500 gal
■ Cheyenne — WIC T-2 Hydraulic oil storage 580 gal
■ Cheyenne — WIC T-4 Hydraulic oil storage 2,000 gal
■ Cheyenne — WIC T-5 Ambitrol storage 8,820 gal
Page 9
• Cheyenne — Front Range T-6406 Ambitrol storage 8,820 gal
o Reg 3, Part C.II.E.3.aaa - Storage tanks of capacity less than forty thousand
gallons of lubricating oils or waste lubricating oils:
• Cheyenne — CIG T-1 Lube oil day tank 150 gal
• Cheyenne — CIG T-3 New oil storage 6,800 gal
• Cheyenne — CIG T-4 New oil storage 2,000 gal
• Cheyenne — CIG T-15 Waste liquid tank (oil, Ambitrol, water, scrubber
dumps) 12,690 gal
• Cheyenne — WIC T-1 Lube oil day tank 150 gal
• Cheyenne — WIC T-3.1 New oil storage 8,000 gal
• Cheyenne — WIC T-3.2 Used oil storage 2,000 gal
• Cheyenne — WIC T-6 Waste liquid tank (oil, Ambitrol, water, scrubber
dumps) 8,400 gal
• Cheyenne — WIC T-7 Waste liquid tank (oil, Ambitrol, water) 500 gal
• Cheyenne — Front Range T-6402 Waste liquid tank (oil, Ambitrol,
water) 600 gal
• Cheyenne — Front Range T -6404A New oil storage 8,400 gal
• Cheyenne — Front Range T -6404B Used oil storage 1,930 gal
• Cheyenne — Front Range T-6501 Lube oil day tank 180 gal
o Reg 3, Part C.II.E.3.nnn.(ii) & (iii) - Stationary Internal Combustion Engines
that are emergency power generators that operate no more than two hundred
fifty hours per year; or have uncontrolled actual emissions less than five tons
per year:
• CIG Emergency Generator Waukesha F2895 GSIU, rated at 607 hp
• WIC Emergency Generator Cummins GTA1710, rated at 600 hp
• Front Range Emergency Generator Caterpillar G3412 CTA130LE,
rated at 598 hp
• Appendix B and C were replaced with Division's current standard versions.
• Notification addresses in Appendix D were updated.
• Updated unit for Fl — Fuel Input Rate to MMBtu/hr in Appendix E.
Page 10
HAPs Per Division Analysis (95OPWE090)
Unit
HAP Emissions (tons/yr)
acetaldehyde acrolein benzene toluene 2,2,4- xylene formaldehyde
trimethylpentane
n -hexane methanol total
E001 - E004
2.66
2.67
0.69
0.33
0.29
18.93
0.33
0.85
26.75
E005 & E006
1.25
1.25
0.34
0.15
0.14
8.88
0.15
0.40
12.56
E-7301
0.64
0.64
0.17
0.08
0.07
4.54
0.08
0.20
6.42
E-7401
0.64
0.64
0.17
0.08
0.07
4.55
0.08
0.20
6.43
E008 (engine)
0.43
0.26
0.02
0.02
0.01
2.72
3.46
E009 (turbine)
0.01
0.03
0.02
0:18
0.24
E010 (engine)
0.60
0.37
0.03
0.03
0.01
3.81
4.85
Total
6.23
5.83
1.42
0.72
0.57
0.04
43.61
0.64
1.65
60.71
Engine emissions are based on most conservative emission factor (from AP -42 and HAPCalc 2.0, for 2 -cycle lean burn engines and/or 2 -cycle lean/clean burn) for each pollutant.
Emission from 6008, E009 and 6010 are from the preliminary analysis for the CPP and FREP PSD permit.
Fugitive VOC emissions are below APEN de minimis and since facility is major for HAPS without them, they are not included in the table.
This table has been transferred over from the TRD associated with the first renewal of this operating permit.
Page 11
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
OPERATING PERMIT RENEWAL SUMMARY
PERMIT NUMBER: 95OPWE090
AIRS ID #: 123/0051 DATE: October 05, 2016
APPLICANT: Colorado Interstate Gas Company - Cheyenne Compressor Station
REVIEW ENGINEER: Thang Nghiem
SOURCE DESCRIPTION
Colorado Interstate Gas Company - Cheyenne Compressor Station has applied for renewal of their Operating Permit
issued for their facility located at Section 5, T11 N, R66W, in Weld County. The facility operates ten (10) natural gas fired
internal combustion engine -driven horizontal compressors and one (1) natural gas fired turbine and is classified under SIC
4922. The facility is located in the north area of Weld County and the area is classified as attainment for all pollutants.
There are two Operating Permits associated with this facility. The second Operating Permit is 05OPWE281 issued on April
1, 2014.
This source is categorized as a major stationary source and a minor stationary source with respect to Prevention of
Significant Deterioration (PSD) requirements. There are two affected states within 50 miles of this facility: Wyoming and
Nebraska. Rocky Mountain National Park and Rawah Wilderness are Federal Class I designated areas within 100 km of
this facility. There is no Federal Class II designated area within 100 km of the 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
Criteria Pollutants
Emission Unit
Potential to Emit
(tons/yr)
Actual Emissions
(tons/yr)
NOx
CO
VOC
NOx
CO
VOC
Engine - E001 (CIG CG -1)
82.1
26.3
36.2
Engine - E002 (CIG CG -2)
82.1
26.3
36.2
Engine - E003 (CIG CG -3)
82.1
26.3
36.2
Engine - E004 (CIG CG -4)
82.1
26.3
36.2
Engine - E005 (WIC CG -1)
82.1
26.3
36.2
Engine - E006 (WIC CG -2)
82.1
26.3
36.2
Engine - E-7301 (WIC CG -7301)
39.5
39
30
Engine - E-7401 (WIC CG -7401)
39.5
39
30
Engine - E008 (FR CG -7501)
14.3
3.7
5.3
Turbine - E009 (FR CG -7601)
17.2
18.1
1.4
Engine — E010 (FR CG -7701)
21.2
5.2
7.4
Total
624.3
262.8
291.3
96.4
64.1
43.4
Hazardous Air Pollutants
Unit
HAP Emissions (tons/yr)
acetaldehyd acrol benzene toluene 2,2,4- xylene formalde n -hexane methanol total
e ein trimethyl hyde
pentane
E001 - E004
2.66
2.67
0.69
0.33
0.29
18.93
0.33
0.85
26.75
E005 & E006
1.25
1.25
0.34
0.15
0.14
8.88
0.15
0.40
12.56
E-7301
0.64
0.64
0.17
0.08
0.07
4.54
0.08
0.20
6.42
E-7401
0.64
0.64
0.17
0.08
0.07
4.55
0.08
0.20
6.43
E008 (engine)
0.43
0.26
0.02
0.02
0.01
2.72
3.46
E009 (turbine)
0.01
0.03
0.02
0.18
0.24
E010 (engine)
0.60
0.37
0.03
0.03
0.01
3.81
4.85
Total
6.23
5.83
1.42
0.72
0.57
0.04
43.61
0.64
1.65
60.71
EMISSION SOURCES
A full list of minor changes made to the renewal permit can be found in the Technical Review Document. No significant
changes were made to the permit.
ALTERNATIVE OPERATING SCENARIOS
No changes were made to the alternative operations scenarios.
INSIGNIFICANT ACTIVITIES
Changes to the list of insignificant activities can be found in the Technical Review Document.
PERMIT SHIELD
No changes were made to the permit shield section.
Colorado Interstate
Gas Company, L.L.C.
July 25, 2012
Sent via FedEx #7986 5836 5852
Colorado Department of Public Health and Environment
Attn.: Mr. Matt Burgett
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246
Subject: Change of Permit Contact
Colorado Interstate Gas Company, LLC.
Cheyenne Compressor Station
Operating Permit #95OPWE090
Dear Mr. Burgett:
Colorado Interstate Gas Company is submitting this letter as well as the enclosed form 2000-100 to
update the permit contact person for the Cheyenne Compressor Station operating permit 95OPWE090.
A permit renewal was submitted on February 12, 2010. This form replaces the form submitted on
2/12/10.
If you have any questions regarding this request, please contact Dawn Meyers of Kinder Morgan at
dawn me,,_-s@k:ind_rmcr_an.com or 303-914-7837.
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.
Matt J. Mask
Division Two Director, Western Region Natural Gas
cc: J.B. Christian
M.J. Mask
Dawn Meyers
File
370 Van Gordon Street • Lakewood, CO 80228-8304 • (303) 989-1740
Operating Permit Application
FACILITY IDENTIFICATION FORM
2000-100
Colorado Department of Public Health and Environment
Air Pollution Control Division
Rev 06-95
SEE INSTRUCTIONS ON REVERSE SIDE
1. Facility name and Name Cheyenne Compressor Station
mailing address
Street or Route 370 Van Gordon St
City, State, Zip Code Lakewood, CO 80228
2. Facility location Street Address Section 5, Township 11N, Range 66W
(No P.O. Box) City,County, Zip Code Weld County
3. Parent corporation Name
Street or Route
City, State, Zip Code
Country (if not U.S.)
Colorado Interstate Gas Company, LLC.
370 Van Gordon Street
Lakewood, CO 80228
4. Responsible Name
official Title
Telephone
Matt Mask
Director — Operations
(719) 329-5637
5. Permit contact person Name
Title
(If Different than 4) Telephone
Dawn Meyers
Specialist — EHS Lead
(303) 914-7837
6. Facility SIC code: 4922
7. Facility identification code: 1230051
8. Federal Tax I. D. Number:
9. Primary activity of the operating establishment: Natural Gas Transmission
10. Type of operating permit New
Modified X Renewal
11. Is the facility located in a "nonattainment" area: Yes X No
If "Yes", check the designated "non -attainment" pollutant(s):
❑ Carbon Monoxide ❑ Ozone
❑ PM10 ❑ Other (specify)
12. List all (Federal and State) air pollution permits (including grandfathered units), plan approvals and exemptions issued to
this facility. List the number, date and what unit/process is covered by each permit. For a Modified Operating Permit, do not
complete this item.
95OPWE090
e
February 12, 2010
Via UPS Overnight
Colorado
Interstate Gas
an El Paso company
Ms. Blue Parish
Operating Permits Unit
Colorado Department of Public Health & Environment
Air Pollution Control Division
4300 Cherry Creek Drive South, APCD-SSP-B1
Denver, CO 80246-1530
Operating Permit Renewal for Cheyenne Compressor Station, #95OPWE090
Dear Ms. Parish:
Colorado Interstate Gas Company (CIG) is submitting the renewal application for the
Cheyenne Compressor Station Title V Operating Permit.
No changes are being requested for the operating permit. A form 2000-100 is enclosed
indicating the primary Responsible Official. Also enclosed is a form 2000-800 signed by me
indicating the current compliance status of the Cheyenne Compressor Station facility.
As requested CIG has reviewed the current list of insignificant activities and updated the list,
a copy of the list is attached to this letter.
If you have any additional questions, please contact Vince Brindley at 719-520-4487.
Sincerely, g _
Matthew J. Mask
Director, Rocky Mountain Division
El Paso Western Pipelines
CC: File: \PWED_CIG\COLORADO\Cheyenne\AIR\Title V\Permits and Renewals
Sandra Miller, PWED
Dan Schnee, Legal
Gary Stuart, Cheyenne
Curtis Smith, Cheyenne (Station Files)
Colorado Interstate Gas
2 North Nevada Avenue Colorado Springs, Colorado 80903
PO Box 1087 Colorado Springs, Colorado 80944
tel 719.473.2300
Operating Permit Application FACILITY IDENTIFICATION
Colorado Department of Public Health and Environment
Air Pollution Control Division
SEE INSTRUCTIONS ON REVERSE SIDE
FORM 2000-100
Rev 06-95
1.
Facility name and Name
mailing address Street or Route
City, State, Zip
Code
Colorado Interstate Gas Company - Cheyenne
Compressor Station
P.O. Box 1087
Colorado Springs, CO 80944
2. Facility location
Street Address
(No P.O. Box) City, County, Zip
Code
Section 5, T11 N, R66W
Approx. 4 miles north of Rockport, Weld County
3. Parent corporation
4. Responsible
official
Name
Street or Route
City, State, Zip
Code
Country (if not
U.S.)
Name
Title
Telephone
Colorado Interstate Gas Company
2 North Nevada Avenue
Colorado Springs, CO 80903
Gary Stuart*
Manager, Cheyenne Area
970-897-3241
5. Permit contact person
(If Different than 4)
Name
Title
Telephone
Sandra D. Miller
Manager, Pipelines West Environmental
719-520-4350
6. Facility SIC code: 4922
7. Facility identification code: CO 1230051
8. Federal Tax I. D. Number: 840173305
9. Primary activity of the operating establishment: Natural Gas Storage and Transmission
10. Type of operating permit L New
C Modified X Renewal
11. Is the facility located in a "nonattainment" area: C Yes X No
If "Yes", check the designated "non -attainment" pollutant(s):
C Carbon Monoxide 1 Ozone C PM10 ❑ Other (specify)
12. List all (Federal and State) air pollution permits (including grandfathered units), plan approvals arcu exemptions
issued to this facility. List the number, date and what unit/process is covered by each permit. For a Nliodified Operating
Permit, do not complete this item.
Operating Permit #95OPWE090, 11WE631-1, 11WE631-2, 11WE631-3, 11WE631-4, 13WE536-1, 13WE526-2
97WE0032, 98WE0030, 03WE0184, 03WE0185 and 03WE0912.
• Alternate RIO: Matthew J. Mask, Director, Rocky Mountain Division, 719-Z29-5637
perating Permit Application
olorado Department of Health
it Pollution Control Division
acility Name: CIG Cheyenne Station
ADMINISTRATION
TABULATION OF PERMIT APPLICATION FORMS
FORM 2000-800
09-94
Facility Identification Code: CO1230051
This application contains the following forms:
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 Form
This application contains the following forms
(one form for each facility boiler. nrintine
Form 2000-200, Stack Identification
Form 2000-300, Boiler or Furnace Operation
Form 2000-301, Storage Tanks
Form 2000-302, Internal Combustion Engine
Form 2000-303, Incineration
Form 2000-304, Printing Operations
Form 2000-305, Painting and Coating Operations
Form 2000-306, Miscellaneous Processes
Form 2000-307, Glycol Dehydration Unit
III. AIR POLLUTION CONTROL
SYSTEM
Total Number
of This Form
This application contains the following forms:
Form 2000-400, Miscellaneous
Form 2000-401, Condensers
Form 2000-402, Adsorbers
Form 2000-403, Catalytic or Thermal Oxidation
Form 2000-404, Cyclones/Settling Chambers
Form 2000-405, Electrostatic Precipitators
Form 2000-406, Wet Collection Systems
▪ Form 2000-407, Baghouses/Fabric Filters
IV. COMPLIANCE
DEMONSTRATION
Total Number
of This Form
This application contains the following forms
(one for each facility boiler. nrintine
Form 2000-500, Compliance Certification - Monitoring and Reporting
Form 2000-501, Continuous Emission Monitoring
Form 2000-502, Periodic Emission Monitoring Using Portable Monitors
- Form 2000-503, Control System Parameters or Operation Parameters of a
Procwcc
Form 2000-504, Monitoring Maintenance Procedures
Form 2000-505, Stack Testing
Form 2000-506, Fuel Sampling and Analysis
Form 2000-507, Recordkeeping
Form 2000-508, Other Methods
V. EMISSION SUMMARY AND
COMPLIANCE CERTIFICATION
Total Number
of This Form
This application contains the following forms
quantifying emissions, certifying compliance
with applicable requirements, and developing a
compliance plan
= Form 2000-600, Emission Unit Hazardous Air Pollutants
= Form 2000-601, Emission Unit Criteria Air Pollutants
Form 2000-602, Facility Hazardous Air Pollutants •
S Form 2000-603, Facility Criteria Air Pollutants
Form 2000-604, Applicable Requirements and Status of Emission Unit
Form 2000-605, Permit Shield Protection Identification
Form 2000-606, Emission Unit Compliance Plan - Commitments and Schedule
Form 2000-607, Plant -Wide Applicable Requirements
= Form 2000-608, Plant -Wide Compliance Plan - Commitments and Schedule
VI. SIGNATURE OF RESPONSIBLE OFFICIAL - FEDERAL/STATE CONDITIONS
A. STATEMENT OF COMPLETENESS
I have reviewed this application in its entirety and, based on information and belief formed after reasonable inquiry, I certify
that the statements and information contained in this application are true, accurate and complete.
B. CERTIFICATION OF FACILITY COMPLIANCE STATUS - FEDERAL/STATE CONDITIONS (check
one box only)
I certify that the facility described in this air pollution permit application is fully in compliance with
all applicable requirements.
❑ I certify that the facility described in this air pollution permit application is fully in compliance with
all applicable requirements, except for the following emissions unit(s):
(list all non -complying units)
WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false material
statement, representation, or certification in, or omits material information from this application is guilty of
a misdemeanor and may be punished in accordance with the provisions of § 25-7 122.1, C.R.S.
Printed or Typed Name
Matt J. Mask
Title:
Director, Rocky Mountain Division
Signature i)
`,11v.i j
110
Date Signed
)perating Permit Application
:olorado Department of Health
dr Pollution Control Division
CERTIFICATION FOR STATE -ONLY CONDITIONS FORM 2000-800
09-94
-ility Name: CIG Cheyenne Station
Facility Identification Code: CO1230051
VI. SIGNATURE OF RESPONSIBLE OFFICIAL - STATE ONLY CONDITIONS
A. STATEMENT OF COMPLETENESS
I have reviewed this application in its entirety and, based on information and belief
that the statements and information contained in this application are true, accurate
B. CERTIFICATION OF FACILITY COMPLIANCE STATUS FOR
one box only)
X I certify that the facility described in this air pollution permit
all applicable requirements.
❑ I certify that the facility described in this air pollution permit
all applicable requirements, except for the following emissions
formed after reasonable inquiry, I certify
and complete.
STATE -ONLY CONDITIONS (check
application is fully in compliance with
application is fully in compliance with
unit(s):
C.R.S., makes any false material
from this application is guilty of
of § 25-7 122.1, C.R.S.
(list all non -complying units)
WARNING: Any person who knowingly, as defined in § 18-1-501(6),
statement, representation, or certification in, or omits material information
a misdemeanor and may be punished in accordance with the provisions
Printed or Typed Name
Matt J. Mask
Title:
Director, Rocky Mountain Division
Signature: 1
Date Signed
SEND ALL MATERIALS TO:
COLORADO DEPARTMENT OF HEALTH
APCD-SS-B 1
4300 CHERRY CREEK DRIVE SOUTH
DENVER, CO 80246-1530
Cheyenne Station Insignificant Sources: 2/2010
Cheyenne —CIG & WIC
Fugitive VOC emissions from equipment leaks (formerly addressed in Colorado Construction
Permit 96WE039
Venting of natural gas prior to engine overhaul
Natural gas boiler, Cleaver Brooks Model #CB-7OO-2OO, 8.4 MMBtu/hr
Natural gas boiler, Cleaver Brooks Model #L-75511, 1.1 MMBtu/hr
Emergency generators: 319934, 41500012
T-1 Lube oil day tank 150g
T-2 Hydraulic oil storage 580g
T-3 New oil storage 6,800g
T-4 Used oil storage 2,000g
T-5 New Ambitrol storage 8,820g
T-10 Water well storage 65,800g
T-15 Waste liquid tank 12,690g (oil, ambitrol, water, scrubber dumps)
T-16 Domestic Water storage 7,500g
(WIC)T-1 Lube oil day tank 150g
(WIC)T-3.1 New oil storage 8,000g
(WIC)T-3.2 Used oil storage 2,000g
(WIC)T-4 Hydraulic oil storage 2,000g
(WIC)T-5 Ambitrol storage 8,820g
(WIC)T-6 Waste liquid tank 8,400g (oil, ambitrol, water, scrubber dumps)
(WIC )T-7 Waste liquid tank 500g (oil, ambitrol, water)
Cheyenne —Front Range
Front Range Emergency Generator:
Make: Caterpillar #G3412CTA130LE, 598 bhp
Serial #: CTP00313
Parker Heating Boiler:
Mark# HE -6701, 2,600,000 BTU/hr
Serial #: 54831
Tanks:
T-6402 Waste liquid tank 600g (oil, ambitrol, water)
T -6404A New oil storage 8,400
T -6404B Used oil storage 1,930g
T-6406 Ambitrol storage 8,820g
T-6501 Lube oil day tank 180g
Various Cheyenne Station Locations:
Miscellaneous landscaping equipment
3/30/2016 State.co.us Executive Branch Mail - RE: CIG Cheyenne Operating Permit Renewal #2
STATE OF
COLORADO
Nghiem - CDPHE, Thang <thang.nghiem@state.co.us>
RE: CIG Cheyenne Operating Permit Renewal #2
Nolting, Leslie R <LeslieNolting@kindermorgan.com>
To: "Nghiem - CDPHE, Thang" <thang.nghiem@state.co.us>
Tue, Mar 29, 2016 at 6:11 PM
Hi Thang, your information is correct for David Bieda and myself. Dawn Meyers covers our western slope
facilities including CIG-Greasewood.
Please see attached information on the units you requested. There are some blanks that I am still gathering
information...thank you for your patience!
Regarding your question about the Cleaver Brooks and Parker Heating boilers, these units do not heat water
to make steam, they heat a glycol -water mixture to provide building heat. They do not meet the definition of
a boiler in 40 CFR 63 Subpart DDDDD and also do not meet the definition of a process heater since they
primarily provide space heat. We have similar units at our Latigo facility for which this same determination
applies.
Thank you and I will send the remaining information ASAP.
Leslie
From: Nghiem - CDPHE, Thang[mailto:thang.nghiem@state.co.us]
Sent: Tuesday, March 15, 2016 10:43 AM
[Quoted text hidden]
[Quoted text hidden]
g Cheyenne Insignificant Activities.xlsx
13K
https://m ai I.google.com/m ai I/u/1/?ui=2&ik=0c94807f4c&view=pt&search=i nbox&m sg=153c4dc30ee46263&si m 1= 153c4dc30ee46263 1/1
0
c
Ln
vN
n v
E .≥
U U
C a
c c
Lc:
L
U bi
U
Emission Factors
NOx CO VOC
100 lb/MMscf 84 Ib/MMscf 5.5 Ib/MMscf
100 lb/MMscf 84 lb/MMscf 5.5 lb/MMscf
100 lb/MMscf 84 Ib/MMscf 5.5 Ib/MMscf
JMfg Date
N N
O CO
01 O 01
ri N T --I
Fuel usage
a
- 4- w
U U U N U
N N N r" 01
CO
C C
.-
CC
L L L
\ \ \
a a a y 7 y
L L L O] CO m
N O co 2 2 2
VD 2 2 2
LO ti
N 00 .-i
Z
in
N M
rn o M M
01 O O Ln
moo c0in
in O_ N
TN
.7 U
v
0
0
2
a)
co
2
Waukesha F2895 GSIU
Cummins GTA1710
Caterpillar G3412 CTA130LE
Parker Heating Boiler
Cleaver Brooks CB -700-200
Cleaver Brooks CB -700-100
C
0
M .--I
00 ON .�
CO UP ,t->"...
6 LLJ ',/
W1
0
v
C
v
m
>
C
C0
E
v
O
C
0
a)
a
0
N
>
v
a O
47
aoo
L o
O
0cu
ro
L
°-
L
O
[O L
O O
O O
O O
00 .ot
J J
2
J J
bc
Eo
io io
c c
u w
u
m m
O O
rn m
ro
c C
0 0
c c
to
al al
Hro
CO Ca
H 7
7
0.1 Q1
7
Colorado Interstate.
Gas Company, L.L.C.
Kindc Moroan company
370 Van Gordon Street
Lakewood, CO 80228
303.914.4597
October 3, 2016
Thang Nghiem
Colorado Department of Public Health and Environment
Air Pollution Control Division - Operating Permit Unit
4300 Cherry Creek Drive South
Denver, CO 80246-1530
VIA Email
Subject: Colorado Interstate Gas Company - Cheyenne Compressor Station, FID: 1230051, OP: 95OPWE090
Comments on Draft Permit
Dear Mr. Nghiem,
We have reviewed the draft operating r permit, and as requested we are providing the following comments and
questions in advance of the identified deadline, October 6, 2016.
• Throughout the document the serial number for EOO2/CIG CG -2 is incorrectly identified as 48833. It
should be universally corrected to 48533.
• For the quarterly emission tests, we request authorization to use calendar quarters for emission testing
period to reduce risk of missing a test.
• The primary Responsible Official (RO) should be Matt Mask, Director of Operations, 719.329.5637.
Secondary RO should be Ken Grubb, VP of Operations, 713.369.8763. Can the RO be identified by title
first, and then by name, with the understanding that the authority for RO lies with the title, regardless of
who holds the position?
• The site manager is no longer Gary Stuart, but is now Brian Nave.
• Sections 1.4, 2.4, 3.4 require that "permittee shall maintain records that verify only natural gas is used as
fuel." Since we would have to modify the units to be able to burn anything other than natural gas,
request that this be revised to state that the equipment may not be modified to burn any fuel other than
natural gas without a permit revision.
• Section 6.2.1.4 states "The hours meter on the transient pilot shall be used to monitor and record the
number of hours the turbine runs when ambient temperatures are below 0 F. Hours of turbine operation
when the ambient temperatures are below -20 F shall be recorded manually." Request that we change
this to say that "Hours of turbine operation when ambient temperatures are below 0 F and below -20 F
shall be monitored and recorded." The removal of the language specifying manual recording will allow
flexibility for using either automated or manual recording. The pilot is a variable pilot which runs
continuously, therefore the pilot hours cannot be used for monitoring when temperatures are below zero.
• The permit requires preparing monthly calculations of monthly fuel use and emissions and 12 -month
running totals for several items of equipment. This condition creates significant record keeping and does
not add to compliance. If the equipment meets the permit limits during compliance testing, it cannot
exceed either the monthly emission limits or the 12 -month running totals. We request that these
requirements be eliminated.
• Section 9.10.3 references a startup, shutdown, and, malfunction plan. ZZZZ no longer requires SSM plans
as per 40 CFR 63.6665 Table 8 and we therefore request that reference to the plan be eliminated.
• In the Tech Review, page 3, it says "The criteria pollutant PTE for the engines and turbines are based on
Colorado Interstate Gas Company - Cheyenne Compressor Station, FID: 1230051 OP: 95OPWE090,
Comments on Draft Permit
Page 2 of 2
permitted emissions. Even though actual emissions are typically much less than permitted emissions, the
source usually reports permitted emissions as actual emissions." This is no longer the case; while in the
past the permitted emissions have been reported, we have recently been reporting actual emissions.
• Tech Review page 4, Natural Gas Transmission and Storage MACT Subpart HHH states, "The most current
version....still only applies to glycol dehydrators and condensate storage tanks." HHH applies to glycol
dehydrators only, so the phrase "and condensate storage tanks" should be removed.
• We request simplification of the "Summary of Emission Units" table, section 6.1. The first column shows
the Emission Unit Number and the Facility Equipment ID; the Facility Equipment ID is generally consistent
with that shown in the 2016 APENs. The third column shows a Facility Identifier and Stack ID; the stack
IDs shown (as the first entry in the cells in this column) are generally consistent with those in previously
submitted APENS. However, the Facility Identifier in the 3rd column is not always consistent with the
Facility Equipment; the Facility Identifier is unnecessary and causes confusion. Therefore we request that
the 3rd column be revised so that it provides only Stack IDs.
• We request three corrections in the "Summary of Emission Units" table, section 6.1: For WIC CG -7301
the correct Stack ID is 5011 and for WIC CG -7401 the correct Stack ID is S012. For E010, there is a typo
showing the unit name as "FR/CG-7701," and it should be "FR CG -7701." These corrections are consistent
with previously submitted APENs, including the most recent APEN submitted in 2016.
Pleasecontactmeat303.914.4597orbyemailatSusan_Riebe@kindermorgan.com ifyou haveanyquestionsorif
you need additional information.
Sincerely,
Susan Riebe
Sr. Engineer — Air Permitting and Compliance
COLORADO
Department of Public
Health Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
October 04, 2016
Susan Riebe
Colorado Interstate Gas Company, LLC
370 Van Gordon Street
Lakewood, CO 80228
RE: Response to CIG October 03, 2016 Response to Draft Operating Permit 95OPWE090
Dear Ms. Riebe:
The comments you provided on the draft revised Operating Permit 95OPWE090 and Technical
Review Document for your facility were received via e-mail on October 03, 2016. The Division has
reviewed and addressed your comments as follows:
Comment 1: Throughout the document the serial number for E002/CIG CG -2 is incorrectly
identified as 48833. It should be universally corrected to 48533.
Response 1: Serial numbers has been corrected per request.
Comment 2: For the quarterly emission tests, we request authorization to use calendar
quarters for emission testing period to reduce risk of missing a test.
Response 2: Language has been updated per request. Please notice additional language under
first paragraph of Portable Monitoring (Section II - Condition 8) defining "quarterly" as
"calendar quarter".
Comment 3: Responsible Official (RO) primary and secondary update.
Response 3: This information has been updated in the operating permit per request.
Comment 4: The site manager is no longer Gary Stuart, but is now Brian Nave.
Response 4: Site manager is not listed in the OP. No change has been made.
Comment 5: Sections 1.4, 2.4, 3.4 require',that "permittee shall maintain records that verify
only natural gas is used as fuel." Since we would have to modify the units to be able to burn
anything other than natural gas, request that this be revised to state that the equipment may
not be modified to burn any fuel other than natural gas without a permit revision.
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
John W. Hickenlooper, Governor Larry Wolk, MD, MPH, Executive Director and Chief Medical Officer
Response 5: The Division is unable to fulfill this request as this language has been deemed
appropriate and obligatory by previous EPA comments.
Comment 6: Request to update language in Section II - Condition 6.2.1.4 for monitoring and
recording of hours of turbine operation when ambient temperatures are below 0° F and below
-20° F.
Response 6: Section II - Condition 6.2.1.4 has been revised to read as "Hours of turbine
operation when ambient temperatures are below 0 F and below -20 F shall be monitored and
recorded." as per request.
Comment 7: Request to eliminate 12 -month running totals calculations for fuel use and
emissions
Response 7: Per PS Memo 97-03, the Division determined that the 12 -month running totals
calculations for fuel use and emissions requirement will need to be included in the operating
permit to easily determine compliance status.
Comment 8: Section 9.10.3 references a startup, shutdown, and malfunction plan. ZZZZ no
longer requires SSM plans as per 40 CFR 63.6665 Table 8 and we therefore request that
reference to the plan be eliminated.
Response 8: Condition 9.10.3 has been removed and the removal discussion was added to the
Technical Review Document.
Comment 9: Request to update permitted emissions to actual emissions in Tech Review
Document Emissions Table.
Response 9: Actual emissions data has been added to this table using the data from the
Division's 2015 Emissions Inventory, as reported by the source.
Comment 10: Tech Review page 4, Natural Gas Transmission and Storage MACT Subpart HHH
states, "The most current version....still only applies to glycol dehydrators and condensate
storage tanks." HHH applies to glycol dehydrators only, so the phrase "and condensate
storage tanks" should be removed.
Response 10: The phrase "and condensate storage tanks" has been removed from the
document as per request.
Comment 11: Request to remove Facility Identifier in the "Summary of Emission Units" table,
section 6.1 of the operating permit to avoid confusion.
Response 11: The "Summary of Emission Units" table in Section I - Condition 6.1 has been
updated as per request.
Comment 12: We request three corrections._ in the "Summary of emission Units" table, section
6.1: For WIC CG -7301 the correct Stack ID is 5011 arid for' WIC CG -7401 the correct Stack ID
is S012. For E010, there is a typo showing the'unit'name as'"FR/CG-7701," and it should be
"FR CG -7701."
Response 12: The "Summary of Emission Units" table in Section I - Condition 6.1 has been
updated as per request.
Page 2 of 3
The next step for this draft initial operating permit wilt be to put it out for a 30 -day Public
Comment Period. After that, the proposed permit wilt go to EPA Region VIII for a 45 -day review
period. 1'oo wilt receive separate letters containing information for the Public Comment Period
and EPA 45 -day review period.
We appreciate that you took the time to thoroughly review this draft. Please feel free to contact
me at (303) 692-3256 or thang.nghiem@state.co.us.
Sincerely,
Thang Nghiem
Operating Permit Unit
Stationary Sources Program
Air Pollution Control Division
Page 3 of 3
Hello