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Home My WebLink About20140082.tiff STATE OF COLORADO John W.Hickenlooper,Governor Larry Wolk,MD,MSPH °F °p�oy Executive Director and Chief Medical Officer '(o to; Dedicated to protecting and improving the health and environment of the people of Colorado % Y a 4300 Cherry Creek Dr.S. Laboratory Services Division ta • Denver,Colorado 80246-1530 8100 Lowry Blvd. Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department Located in Glendale,Colorado (303)692-3090 of Public Health www.colorado.gov/cdphe and Environment Weld County Clerk& Recorder 1402 N 17th Ave Greeley, CO 80631 RECEIVED January 2, 2014 JAN - 7 .2014 WELD COUNTY COMMIS ' o =:_: S Dear Sir or Madam: On January 6, 2014, the Air Pollution Control Division will publish a public notice for Cheyenne Plains Gas Pipeline Company, LLC—Cheyenne Plains Compressor Station, in the The Greeley Tribune. 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 date the public notice is published. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health & Environment APCD-SS-B 1 4300 Cherry Creek Drive South Denver,Colorado 80246-1530 Attention: Clara Gonzales Regards, l ''l v J Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 1 Icb l� 2014-0082 ( 6I ►ti NOTICE OF A PROPOSED RENEWAL TITLE V OPERATING PERMIT WARRANTING PUBLIC COMMENT Website Title: Cheyenne Plains Gas Pipeline Company, LLC Cheyenne Plains Compressor Station—Weld County NOTICE is hereby given that an Operating Permit application to renew an Operating Permit has been submitted to the Colorado Air Pollution Control Division,4300 Cherry Creek Drive South, Denver, Colorado 80246-1530, for the following source of air pollution: Applicant: Cheyenne Plains Gas Pipeline Company, LLC P.O. Box 1087 Colorado Springs, CO 80944 Facility: Cheyenne Plains Compressor Station Section 5, TI IN, R66W Approx 4 miles north of Rockport Cheyenne Plains Gas Pipeline Company, LLC has applied for a Renewal Operating Permit for the Cheyenne Plains Compressor Station in Weld County, CO. This facility is a natural gas compressor station. A copy of the application, including supplemental information, the Division's analysis, and a draft of the Renewal Operating Permit 05OPWE281 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at www.coloradoqov//cdphe/AirPublicNotices. Based on the information submitted by the applicant,the Division has prepared the draft renewal operating permit for approval. Any interested person may contact Blue Parish of the Division at 303-692-3194 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. RELEASED TO: The Greeley Tribune on PUBLISHED: January 6, 2014 January 2, 2014 ctfl:: - o s�,ye NuM � 1876� � Colorado Department of Public Health and Environment OPERATING PERMIT Cheyenne Plains Gas Pipeline Company, LLC Cheyenne Plains Compressor Station First Issued: October 1 , 2007 Renewed: DRAFT AIR POLLUTION CONTROL DIVISION COLORADO OPERATING PERMIT FACILITY NAME: Cheyenne Plains OPERATING PERMIT NUMBER Compressor Station FACILITY ID: 123/0051 05OPWE281 RENEWED: DRAFT EXPIRATION DATE: DRAFT MODIFICATIONS: See Appendix F of Permit Issued in accordance with the provisions of Colorado Air Pollution Prevention and Control Act, 25-7-101 et seq. and applicable rules and regulations. ISSUED TO: PLANT SITE LOCATION: Cheyenne Plains Gas Pipeline Company, LLC Cheyenne Plains Compressor Station P.O. Box 1087 Section 5, TI IN, R66W (—4 miles North of Rockport) Colorado Springs, CO 80944 Weld County INFORMATION RELIED UPON Operating Permit Renewal Application Received: October 3, 2011 And Additional Information Received: On various dates during the permit drafting period Nature of Business: Natural Gas Transmission Primary SIC: 4922 RESPONSIBLE OFFICIAL FACILITY CONTACT PERSON Name: Matt Mask Name: Leslie Nolting Title: Director—Operations Title: Specialist—EHS Senior II Phone: (719) 329-5637 Phone: (719) 520-4652 SUBMITTAL DEADLINES — First Semi-Annual Monitoring Period: TBD Based on Issuance Date Subsequent Semi-Annual Monitoring Periods: (keep consistent with calendar quarters) Semi-Annual Monitoring Reports: TBD Based on Issuance Date First Annual Compliance Period: TBD Based on Issuance Date Subsequent Annual Compliance Periods: (keep consistent with calendar quarters) Annual Compliance Certification: TBD Based on Issuance Date Note that the Semi-Annual Monitoring Reports and Annual Compliance report must be received at the Division office by 5:00 p.m. on the due date. Postmarked dates will not be accepted for the purposes of determining the timely receipt of those reports. TABLE OF CONTENTS: SECTION I - General Activities and Summary 1 1. Permitted Activities 1 2. Alternative Operating Scenarios for Turbines—version 1/23/2013 2 3. Alternative Operating Scenarios for Engines—version 10/12/2013 9 4. Prevention of Significant Deterioration (PSD) 10 5. Accidental Release Prevention Program (112(r)) 10 6. Compliance Assurance Monitoring (CAM) 10 7. Summary of Emission Units 12 SECTION II - Specific Permit Terms 13 1. Three Solar Taurus 70-10302S Combustion Turbines 13 2. H-8701 and H-8702: Heatec, Natural Gas Fired Hot Oil Heaters, Each Rated at 43.79 mmBtu/hr 20 3. Flare Stack (FL-8921) and CO2 Vent (ST-8931): CO2 Treatment Plant — Glycol Dehydrator and Amine Unit, Each Rated at 300 mmSCF/day 29 4. EG-6141- Caterpillar, Model No. 3516B LE, Emergency Generator Rated at 1557 hp 43 5. Portable Monitoring (10/12/12 version) 45 6. H-8721 —Two Maxon, Model Tube-o-Flame, Reboiler Burners Rated at 3.8 MMBtu/hr each (Total of 7.6 MMBtu/hr) 46 SECTION III -Permit Shield 48 1. Specific Non-Applicable Requirements 48 2. General Conditions 48 3. Stream-lined Conditions 48 SECTION IV- General Permit Conditions (ver 5/22/2012) 50 1. Administrative Changes 50 2. Certification Requirements 50 3. Common Provisions 50 4. Compliance Requirements 54 5. Emergency Provisions 55 6. Emission Controls for Asbestos 55 7. Emissions Trading, Marketable Permits, Economic Incentives 55 8. Fee Payment 55 9. Fugitive Particulate Emissions 56 10. Inspection and Entry 56 11. Minor Permit Modifications 56 12. New Source Review 56 13. No Property Rights Conveyed 56 14. Odor 56 15. Off-Permit Changes to the Source 57 16. Opacity 57 17. Open Burning 57 18. Ozone Depleting Compounds 57 19. Permit Expiration and Renewal 57 20. Portable Sources 57 21. Prompt Deviation Reporting 57 22. Record Keeping and Reporting Requirements 58 TABLE OF CONTENTS: 23. Reopenings for Cause 59 24. Section 502(b)(10) Changes 59 25. Severability Clause 60 26. Significant Permit Modifications 60 27. Special Provisions Concerning the Acid Rain Program 60 28. Transfer or Assignment of Ownership 60 29. Volatile Organic Compounds 60 30. Wood Stoves and Wood burning Appliances 61 APPENDIX A- Inspection Information 63 1. Directions to Plant: 63 2. Safety Equipment Required: 63 3. Facility Plot Plan: 63 4. List of Insignificant Activities. 63 APPENDIX B 65 Reporting Requirements and Definitions 65 Monitoring and Permit Deviation Report- Part I 69 Monitoring and Permit Deviation Report - Part II 71 Monitoring and Permit Deviation Report - Part III 73 APPENDIX C 74 Required Format for Annual Compliance Certification Reports 74 APPENDIX D 77 Notification Addresses 77 APPENDIX E 78 Permit Acronyms 78 APPENDIX F 80 Permit Modifications 80 Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 1 SECTION I - General Activities and Summary 1. Permitted Activities 1.1 The facility is a natural gas compression facility as defined under Standard Industrial Classification 4922. This facility is a mainline compressor station. Its main function is to compress and transmit natural gas from the Wyoming area east into Kansas. This is achieved by using three (3) natural gas fired combustion turbines driving natural gas compressors. The facility also includes a CO2 Treatment Plant, which consists of a triethylene glycol dehydrator and amine treatment unit. Emissions from the glycol dehydrator still (regenerator) vent and flash tank and emissions from the amine unit flash tank are routed to a flare to reduce VOC emissions. The amine unit regenerator vent is equipped with a SulfaTreat H2S control system to reduce H2S emissions. There are also two (2) 43.79 mmBtu/hr natural gas fired heaters associated with the amine unit and an emergency generator that are included in Section II of the permit as significant emission units. The Cheyenne Plains Compressor Station was constructed in 2004 at the site of an existing mainline compressor station (Cheyenne Station), whose main function is to compress and transmit natural gas from the Wyoming area to the Colorado Front Range area. As such the two facilities are considered a single source for purposes of Prevention of Significant Deterioration (PSD) review requirements and Title V permitting requirements. Equipment associated with the Cheyenne Compressor Station is addressed in a separate Title V operating permit (95OPWE090). The facility is located 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. 1.2 Until such time as this permit expires or is modified or revoked, the permiUee is allowed to discharge air pollutants from this facility in accordance with the requirements, limitations, and conditions of this permit. 1.3 The Operating Permit incorporates the applicable requirements contained in the underlying construction permits, and does not affect those applicable requirements, except as modified during review of the application or as modified subsequent to permit issuance using the modification procedures found in Regulation No. 3, Part C. These Part C procedures meet all applicable substantive New Source Review requirements of Part B. Any revisions made using the provisions of Regulation No. 3, Part C shall become new applicable requirements for purposes of this Operating Permit and shall survive reissuance. This permit incorporates the applicable requirements (except as noted in Section II) from the following construction permits: 03WE0910, 03WE0913, 03WE0916 and 04WE1390. 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 - Conditions 3.g (last paragraph), 14 & 18 (as noted). Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit # 05OPWE281 Page 2 1.5 All information gathered pursuant to the requirements of this permit is subject to the Recordkeeping and Reporting requirements listed under Condition 22 of the General Conditions in Section IV of this permit. Either electronic or hard copy records are acceptable. 2. Alternative Operating Scenarios for Turbines—version 1/23/2013 2.1 Routine Turbine Component Replacements The following physical or operational changes to the turbines in this permit are not considered a modification for purposes of NSPS GG, major stationary source NSR/PSD, or Regulation No. 3, Part B. Note that the component replacement provisions apply ONLY to those turbines subject to NSPS GG. Neither pre-GG turbines nor post GG turbines (i.e. KKKK turbines) can use those provisions. In the event that EPA promulgates amendments to Subparts GG and/or KKKK that further define or alter the definition of component replacements that will not trigger modifications, the provisions of those rules shall supersede the component replacement provisions listed below. 2.1.1 Replacement of stator blades, turbine nozzles, turbine buckets, fuel nozzles, combustion chambers, seals, and shaft packings, provided that they are of the same design as the original. 2.1.2 Changes in the type or grade of fuel used, if the original gas turbine installation, fuel nozzles, etc. were designed for its use. 2.1.3 An increase in the hours of operation (unless limited by a permit condition) 2.1.4 Variations in operating loads within the engine design specification. 2.1.5 Any physical change constituting routine maintenance, repair, or replacement. Turbines undergoing any of the above changes are subject to all federally applicable and state-only requirements set forth in this permit(including monitoring and record keeping), and shall be subject to any shield afforded by this permit. If replacement of any of the components listed in (1) or(5) above results in a change in serial number for the turbine, a letter explaining the action as well as a revised APEN and appropriate filing fee shall be submitted to the Division within 30 days of the replacement. Note that the repair or replacement of components must be of genuinely the same design. Except in accordance with the Alternate Operating Scenario set forth below, the Division does not consider that this allows for the entire replacement(or reconstruction) of an existing turbine with an identical new one or one similar in design or function. Rather,the Division considers the repair or replacements to encompass the repair or replacement of components at a turbine with the same (or functionally similar) components. 2.2 Alternative Operating Scenarios The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of combustion turbines and turbine components has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility-Alternative Operating Scenarios, Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE28I Page 3 Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any turbine or turbine component replacement performed in accordance with this AOS, and the permittee shall be allowed to perform such turbine or turbine component replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.2.1 General Requirements for Turbine Replacements The following AOS is incorporated into this permit in order to deal with a turbine breakdown or periodic routine maintenance and repair of an existing onsite turbine that requires the use of a temporary or permanent replacement turbine. The definitions of"Temporary" and "Permanent" for each permitted unit are defined in Condition 2.2.7. The compliance demonstrations required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit. All replacement turbines are subject to all federally applicable and state-only requirements set forth in this permit (including monitoring and record keeping), and shall be subject to any shield afforded by this permit. The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with the NSPS requirements. Results of all tests shall be kept on site for five (5) years and made available to the Division upon request. 2.2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The permittee may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The permittee shall measure nitrogen oxide (NO,i) and carbon monoxide (CO) emissions in the exhaust from the replacement turbine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement turbine. All portable analyzer testing required by this permit shall be conducted using the most current version of the Division's Portable Analyzer Monitoring Protocol as found on the Division's Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 4 website. Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year(whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year(8760), whichever applies. For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp- hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement turbine will be subject to, the results of the test shall be converted to the appropriate units as described in the above-mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NO,,and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the turbine is in compliance with both the NOx and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NO,, or CO emission limitations, the turbine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NO,, and CO emission limitations or until the turbine is taken offline. 2.2.3 Recordkeeping Requirements for Turbine Replacements The permittee shall maintain a log on-site to contemporaneously record the start and stop date of any turbine replacement, the manufacturer and serial number of the turbine(s) that are replaced during the term of this permit, and the manufacturer and serial number of the replacement turbine. 2.2.4 Specific Requirements for Temporary Replacements The permittee may temporarily replace an existing turbine covered by this permit as specified in Condition 2.2.7 with the exact make and model turbine without modifying this permit so long as the replacement turbine complies with the emission limitations and other requirements applicable to the original turbine as well as any new applicable requirements for the replacement turbine. Measurement of emissions from the temporary replacement turbine shall be made as set forth in Condition 2.2.2. The permittee may temporarily replace a grandfathered or permit exempt turbine or a turbine that is not subject to emission limits without modifying this permit. In this circumstance, potential annual emissions of NOx and CO from the temporary replacement turbine must be less than or equal to the potential annual emissions of NOx and CO from the original grandfathered or permit Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 5 exempt turbine or for the turbine that is not subject to emission limits, as determined by applying appropriate emission factors (e.g. AP-42 or manufacturer's emission factors). 2.2.5 Specific Requirements for Permanent Replacements The permittee may permanently replace an existing turbine covered by this permit as specified in Condition 2.2.7 with the exact make and model turbine without modifying this permit so long as the replacement turbine complies with the emission limitations and other requirements applicable to the original turbine as well as any new applicable requirements for the replacement turbine. Measurement of emissions from the temporary replacement turbine shall be made as set forth in Condition 2.2.2. This AOS cannot be used for permanent turbine replacement of a grandfathered or permit exempt turbine or a turbine that is not subject to emission limits. This AOS cannot be used in areas designated as non-attainment or attainment/maintenance for VOC, CO,NOx SO2 and PMio. The AOS cannot be used for the permanent replacement of an entire turbine at any source that is an existing major stationary source for a regulated NSR Pollutant unless the existing turbine has federally enforceable emission limits that are below the significance levels in Reg 3, Part D, II.A.42. This AOS cannot be used for the permanent replacement of an entire turbine at any source where: (1) the facility-wide potential to emit of CO2e is equal to or greater than 100,000 tpy of CO2e, and (2) the originally permitted turbine does not have a CO2e emission limit below 75,000 tpy CO2e. In the absence of a numerical CO2e limit, the PTE of CO2e should be based on 8760 hours per year of operation and emission factors from AP-42 Chapter 3.1, 40 CFR Part 75, and/or other factors approved by the Division. Nothing in this AOS shall preclude the Division from taking an action, based on any permanent turbine replacement(s), for circumvention of any state or federal PSD/NANSR requirement. Additionally, in the event that any permanent turbine replacement(s) constitute(s) a circumvention of applicable PSD/NANSR requirements, nothing in this AOS shall excuse the permittee from complying with PSD/NANSR and applicable permitting requirements. 2.2.5.1 Turbines Relocated into Colorado from Outside of Colorado Note that under the provisions of Regulation No. 6, Part B, Section I.B., as referenced in Part A, the following turbines that are exempt from federal NSPS requirements based on dates of construction, reconstruction or relocation that occurred outside of the State of Colorado will become subject to NSPS requirements after relocation into the State as follows: a. Replacement Units Previously Exempt from NSPS GG This condition applies to units that originally commenced construction outside of Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 6 Colorado prior to October 3, 1977 and have not been reconstructed or modified after October 3, 1977. If these units were previously installed within the State of Colorado during the applicability dates of NSPS Subpart GG (October 3, 1977 — February 18, 2005), they will be subject to Subpart GG upon relocation into the State of Colorado. The applicable requirements of Subpart GG shall be determined based on the date on which the unit was previously installed within the State of Colorado. If these units were not previously installed within the State of Colorado during the applicability dates of NSPS Subpart GG, they will be subject to the requirements for new units under Subpart KKKK upon commencement of construction in Colorado. b. Units Subject to NSPS Subpart GG This condition applies to units that originally commenced construction outside of Colorado after October 3, 1977 but prior to February 18, 2005 and have not been reconstructed or modified after February 18, 2005. These units will remain subject to NSPS Subpart GG upon relocation into Colorado, and the applicable requirements under Subpart GG shall not be changed or re-determined based on the date of relocation into Colorado. c. Units subject to NSPS Subpart KKKK This condition applies to units that originally commenced construction outside of Colorado after February 18, 2005. These units will remain subject to NSPS Subpart KKKK upon relocation into Colorado, and the applicable requirements under Subpart KKKK shall not be changed or re-determined based on the date of relocation into Colorado. 2.2.5.2 Air Pollutant Emission Notice (APEN) Submittals An APEN that includes the specific manufacturer, model, and serial number of any permanent replacement turbine shall be filed with the Division for the permanent replacement turbine within 14 calendar days of commencing operation of the replacement turbine. The APEN shall be accompanied by the appropriate APEN filing fee and a cover letter explaining that the permittee is exercising an alternative operating scenario and is installing a permanent replacement turbine. The permittee shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent turbine replacement. The owner or operator shall include, with the APEN, a regulatory applicability analysis to address the requirements of the replacement unit. At a minimum, the applicability analysis shall include: Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 7 • An analysis of any requirements applicable to the replacement turbine that differ from those applicable to the permitted unit. Applicable requirements include, but are not limited to, Federal NSPS, MACT and/or Colorado Air Quality Control Commission regulations. For example, if an original unit that qualifies as a reconstructed gas turbine subject to an NSPS KKKK NO. limit of 150 ppm is replaced with a Subpart KKKK unit that has not been modified or reconstructed, the NOx limit of the replacement unit will be 42 ppm. The analysis should also address any testing, monitoring, recordkeeping and reporting differences between the original and replacement units. • The applicability determination shall list the most recent date that the turbine was modified or reconstructed as per the definitions in 40 CFR §§60.2 and 60.14. If the turbine has never been modified or reconstructed, the applicability determination shall include a statement to verify that no modifications or reconstructions have occurred. • The applicability determination shall also list the most recent date that the turbine was overhauled, and an explanation of whether the overhaul qualifies or does not qualify as a modification or reconstruction. Supporting documentation, including cost estimates shall be submitted for those that do not qualify as reconstructions. • The applicability analysis must be certified by either 1) for Operating Permits, a Responsible Official as defined in Colorado Regulation No. 3, Part A, Section I.B.38, or 2) for Construction and General Permits, the person legally authorized to act on behalf of the source. This signed certification document must be packaged with the documents being submitted. The certification shall include the following statement: I have reviewed this certification in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this certification are true, accurate and complete. 2.2.6 Additional Sources The replacement of an existing turbine with a new turbine is viewed by the Division as the installation of a new emissions unit, not"routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site; a turbine that is being installed as an entirely new emission point and not as part of an AOS-approved replacement of an existing onsite turbine has to go through the appropriate Construction/Operating permitting process prior to installation. 2.2.7 Allowable Replacements Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 8 Table 1 —Turbine Replacements Allowed by the AOS— Units Relocated from Outside the State of Colorado Permitted Turbine Allowable Replacements' Point Applicable NSPS Make/Model Requirement Status/Type Restrictions Units that predate NSPS Subpart GG but were previously installed within the CP CG-7101 state of Colorado during the Temporary replacement units may operate up to CP CG-7201 Subpart GG applicability 90 days in any 12 month period2 CP CG-7301 period(Oct 4, 1977—Feb 18, Permanent replacement units may operate more 2005) than 90 days in any 12 month period' Subpart GG Solar Taurus -OR- Natural Gas Fired Units subject to Subpart GO Turbines,Model Temporary replacement units may operate up to No.70-10302S z 270 days in any 12 month period All Others Permanent replacement units: not allowed(new permit or modification required) Note I: Replacement unit must be of the same make and model as the permitted unit Note 2: The temporary replacement period is the total number of operating days that the replacement unit may operate in the same service. If the temporary replacement turbine operates only part of a day,that day counts toward the total. Temporary replacement units shall comply with all requirements in Conditions 2.2.1,2.2.2 and 2.2.3,and with the specific requirements for temporary replacements in Condition 2.2.4. Note 3: Permanent replacement units shall comply with all requirements in Conditions 2.2.1,2.2.2 and 2.2.3,and with the specific requirements for permanent replacements in Condition 2.2.5. Table 2—Turbine Replacements Allowed by the AOS —Units Relocated from Within the State of Colorado Permitted Turbine Allowable Replacements' Point Applicable NSPS Make/Model Requirement Status/Type Restrictions CP CG-7101 Temporary replacement units may operate up to CP CG-7201 90 days in any 12 month period2 Units subject to Subpart GG CP CG-7301 Permanent replacement units may operate more than 90 days in any 12 month period' Subpart GG Solar Taurus Temporary replacement units may operate up to Natural Gas Fired 270 days in any 12 month period2 All Others Turbines,Model Permanent replacement units: not allowed(new No.70.10302S permit or modification required) Note 1: Replacement unit must be of the same make and model as the permitted unit Note 2: The temporary replacement period is the total number of operating days that the replacement unit may operate in the same service. If the temporary replacement turbine operates only part of a day,that day counts toward the total. Temporary replacement units shall comply with all requirements in Conditions 2.2.1,2.2.2 and 2.2.3,and with the specific requirements for temporary replacements in Condition 2.2.4. Note 3: Permanent replacement units shall comply with all requirements in Conditions 2.2.1,2.2.2 and 2.2.3,and with the specific requirements for permanent replacements in Condition 2.2.5. Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit # 05OPWE281 Page 9 3. Alternative Operating Scenarios for Engines—version 10/12/2013 The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility-Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS, and the permittee shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. The following AOS contains the provisions for temporary replacements of engines that are not subject to emission limits and periodic monitoring requirements. 3.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with a compressor or other engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month period. "Permanent" is defined as in the same service for more than 90 operating days in any 12 month period. The 90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90-day total. The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit. All replacement engines are subject to all federally applicable and state-only requirements set forth in this permit (including monitoring and record keeping), and shall be subject to any shield afforded by this permit. The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5) years and made available to the Division upon request. The permittee shall maintain a log on-site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. 3.1.1 The permittee may temporarily replace a grandfathered or permit exempt engine or an engine that is not subject to emission limits without modifying this permit. In this circumstance, potential annual emissions of NO„ and CO from the temporary replacement engine must be less than or equal to the potential annual emissions of NQ and CO from the original grandfathered or permit exempt engine or for the engine that is not subject to emission limits, as determined by applying appropriate emission factors (e.g. AP-42 or manufacturer's emission factors). Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 10 3.2 Additional Sources The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not"routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site; an engine that is being installed as an entirely new emission point and not as part of an AOS- approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. Table 1 Internal Combustion Engine Information For AOS Emission Replacement Engine Periodic Subject to Point Monitoring CAM? CP EG- Caterpillar,Model No.3516B LE,4-Cycle Lean 6141 Burn Natural Gas-Fired Internal Combustion N/A No Engine,rated at 1557 hp and 10.95 mmBtu/hr. 4. Prevention of Significant Deterioration (PSD) 4.1 This facility is located in an area designated attainment for all pollutants. It is categorized as a major stationary source (Potential to Emit> 250 Tons/Year for NOx, CO and VOC). Future modifications at this facility resulting in a significant net emissions increase (see Reg 3, Part D, Sections II.A.26 and 42) for any pollutant as listed in Regulation No. 3, Part D, Section II.A.42 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.42) may result in the application of the PSD review requirements. 4.2 The following Operating Permits are associated with this facility for purposes of determining applicability of Prevention of Significant Deterioration regulations: 95OPWE090 (Cheyenne Compressor Station) 5. Accidental Release Prevention Program (112(r)) 5.1 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). 6. Compliance Assurance Monitoring (CAM) 6.1 The following emission points at this facility use a control device to achieve compliance with an emission limitation or standard to which they are subject and have pre-control emissions that exceed or are equivalent to the major source threshold. They are therefore subject to the provisions of the CAM program as set forth in 40 CFR Part 64, as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV: The glycol dehydrator is not subject to CAM since at the time the CAM plan was required the Title V permit specified a continuous compliance determination method (40 CFR Part 64 § 64.2(b)(1)(vi), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 11 All other units at the facility either have uncontrolled emissions below CAM applicability thresholds, or do not use devices considered to be control devices for the purposes of CAM applicability. • Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 12 7. Summary of Emission Units 7.1 The emissions units regulated by this permit are the following: Facility AIRS ID Description Startup Date Pollution Control ID Device CP CG- Solar Taurus Natural Gas Fired Turbine,Model No. 70-10302S, 7101 Engine Serial No.OCH 10-B8166.The turbine is rated at 9,816 hp and 71.42 mmBtu/hr. Package Skid Serial Number TC04639. December Dry Low NO, 015 15,2004 Combustion Sy stem CP CG- Engine Taurus Natural Gas Fired Turbine,Model No. 70-10302S, 7201 Engine Serial No.OHL09-84243.The turbine is rated at 9,816 hp and 71.42 mmBtu/hr.Package Skid Serial Number TC04638. Solar Taurus Natural Gas Fired Turbine,Model No.70- 10302S, CP CG- 024 Engine Serial No.OCHI0-B0020.0-B0020.The turbine is rated at 9,816 hp October 29, Dry Low NO, 7301 and 71.42 mmBtu/hr.Package Skid Serial Number TC05362. 2004 Combustion System Heatec,Model No. VHC1-16010-40-G, Serial No.04-074- H-8701 151,Natural Gas Fired Hot Oil Heater,Rated at 43.79 mmBtu/hr. This heater is part of the amine treatment unit Janu 30, 018 2005 Low NO,Burners Heatec,Model No. VHC1-16010-40-G, Serial No.04-074- 1-1-8702 152,Natural Gas Fired Hot Oil Heater, Rated at 43.79 mmBtu/hr. This heater is part of the amine treatment unit Flare Vent: Emissions from the triethylene glycol dehydrator regenerator(still)vent and flash tank and the amine unit flash tank FL-8921 022 are routed to the flare.The glycol dehydrator and amine unit are January 30, Air-Assisted, each rated at 300 mmSCF/day.The flare is rated at 13.54 2005 Elevated Flare mmBtu/hr. ST-8931 021 Amine Unit Regenerator(CO2)Vent.Amine unit is rated at January 30, SulfaTreat H2S 300 mmSCF/day. 2005 Control System Caterpillar,Model No. 3516B LE,Serial No.CTW00511,4- CP EG- Cycle Lean Burn Natural Gas-Fired Internal Combustion December 6141 023 Engine,rated at 1557 hp and 10.95 mmBtu/hr.This engine is 2004 None used to drive an emergency generator. Maxon Tube-o-Flame Natural Gas Fired Reboiler burners, associated with the glycol dehydrator listed under Facility ID FL- January 30, H-8721 025 8921. The unit consists of two burners with a rating of 3.8 2005 None MMBtu/hr or each burner. SN: H8721-101387 Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 13 SECTION II - Specific Permit Terms 1. Three Solar Taurus 70-10302S Combustion Turbines CG-7101, S/N OCH10-B8166 (Package Skid Serial Number TC04639) CG-7101, S/N OHL09-B4243 (Package Skid Serial Number TC04638) CG-7101, S/N OCHI0-B0020 (Package Skid Serial Number TC05362) Unless Otherwise S?ecitied Limitations Apply to Each Turbine Permit Limitation Compliance Monitoring Condition Emission Parameter Number Factor Method Interval BACT 1.1 See Condition 1.1 Requirements CG-7101 &7201: 24.5 ppmvd at 15% O2,except as provided for below: CG-7301: 15 ppmvd at 15%O2,except Recordkeeping as provided for below: See and Calculation Monthly All Turbines:NO„ 1.2Condition -20°F<T<0°F:42 ppmvd at 15%O2 12 Portable Flue Gas Quarterly T<-20°F: 120 ppmvd at 15%O2 All limits on a 1-hr average Analyzer CG-7101 & 7201: 31.6 tons/yr each CG-7301: 20.1 tons/yr CG-7101 & 7201:48.8 ppmvd at 15% O2,except as provided for below: CG-7301: 25 ppmvd at 15%O2,except Recordkeeping as provided for below: See and Calculation Monthly All Turbines: Condition CO 1.2 -20°F<T<0°F: 100 ppmvd at 15%O2 1.2 Portable Flue Gas Quarterly T<-20°F: 150 ppmvd at 15%O2 All limits on a 1-hr average Analyzer CG-7101 & 7201: 38.5 tons/yr each CG-7301: 20.9 tons/yr All Turbines: 3 ppmvd at 15%O2,except as provided for below: See Condition 1.2.1 -20°F<T<0°F: 5 ppmvd at 15%O2 VOC 1.2 T<-20°F: 8 ppmvd at 15%O2 All limits on a I-hr average See Recordkeeping 11.3 tons/year each Condition and Calculation Monthly 1.2.2 Natural Gas 13 661.5 MMscf/year - Recordkeeping Monthly Consumption 150 ppmvd @ 15%O2 OR Use of Fuel Only Pipeline Which Contains Less than 0.8 Weight% - Quality Natural Sulfur Gas is Used as SO2 1.4 Fuel Restriction Fuel 0.8 Ibs/MMBtu Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit ft 05OPWE281 Page 14 Permit Limitation Compliance Monitoring Condition Emission Parameter Number Factor Method Interval Only Pipeline 0.165 lbs/MMBtu Fuel Restriction Quality Natural Gas is Used as PM Fuel 1.5 2.10 tons/year each 6.6 x 10'3 Recordkeeping Monthly Ibs/MMBtu and Calculation 6.6 PM,0 2.10 tons/year each x Recordkeeping 10-3 Monthly lbs/MMBtu and Calculation Heat Content ASTM Methods 1.6 or In-Line Gas Semi-Annual of Natural Gas Chromatograph Not to Exceed 20%Except as Provided for Below Only Pipeline For Startup-Not to Exceed 30%, for a Quality Natural Opacity 1.7 Fuel Restriction Period or Periods Aggregating More Gas is Used as Than Six(6)Minutes in any 60 Fuel consecutive Minutes NSPS General 1.8 See Condition 1.8 Provisions 1.1 Each turbine is subject to the requirements of the Prevention of Significant Deterioration (PSD) Program. Best Available Control Technology (BACT) shall be applied for control of Nitrogen Oxides (NO,,), Carbon Monoxide (CO) and Volatile Organic Compounds (VOC). BACT has been determined to be as follows: 1.1.1 BACT for NO,, has been determined to be SoLoNOX (dry low NOx (DLN)) combustion technology for turbine CG-7101 and CG-7201 and SoLoNOX II (DLN) combustion technology for turbine CG-7301 with emission limits as identified in Condition 1.2.1.1 (Colorado Construction Permits 03WE0910 and 04WE1390). 1.1.2 BACT for CO has been determined to be good combustion practices with emission limits as identified in Condition 1.2.1.2 (Colorado Construction Permits 03WE0910 and 04WE1390). 1.1.3 BACT for VOC has been determined to be good combustion practices and use of pipeline quality natural gas as fuel with emission limits as identified in Condition 1.2.1.3 (Colorado Construction Permits 03WE0910 and 04WE1390). 1.2 Nitrogen Oxide (NO,,), Carbon Monoxide (CO) and Volatile Organic Compound (VOC) emissions from this turbine are subject to the following requirements: 1.2.1 For purposes of BACT NO„, CO and VOC are subject to the following limitations (Colorado Construction Permits 03WE0910 and 04WE1390). All limitations are at 15%O2, on a 1-hr average Operating Permit 05OPWE281 First Issued: October I, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 15 1.2.1.1 Except as provided for below, NO, emissions from turbines CG-7101and CG-7201 shall not exceed 24.5 ppmvd and NO, emissions from turbine CG-7301 shall not exceed 15 ppmvd. a. When the ambient temperature is less than 0 ° F but greater than or equal to—20 ° F, NO,emissions shall not exceed 42 ppmvd. b. When the ambient temperature is less than—20 °F,NO,emissions shall not exceed 120 ppmvd. 1.2.1.2 Except as provided for below, CO emissions from turbines CG-7101 and CG-7201 shall not exceed 48.8 ppmvd and CO emissions from turbine CG-7301 shall not exceed 25 ppmvd. a. When the ambient temperature is less than 0 ° F but greater than or equal to—20 ° F, CO emissions shall not exceed 100 ppmvd. b. When the ambient temperature is less than—20 ° F, CO emissions shall not exceed 150 ppmvd. 1.2.1.3 Except as provided for below, VOC emissions shall not exceed 3 ppmvd. a. When the ambient temperature is less than 0 ° F but greater than or equal to—20 ° F, VOC emissions shall not exceed 5 ppmvd. b. When the ambient temperature is less than—20 °F, VOC emissions shall not exceed 8 ppmvd. 1.2.1.4 The source shall monitor the number of hours that each turbine operates when the ambient temperature meets the criteria in Conditions 1.2.1.1a& 1.2.1.1b, 1.2.1.2a & 1.2.1.2b and 1.2.1.3a & 1.2.1.3b above. The hours meter on the 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. Portable monitoring shall be conducted quarterly in accordance with the requirements in Condition 5 to monitor compliance with the NO, and CO BACT limits. At least annually, such portable monitoring shall be conducted at the temperatures specified in Conditions 1.2.1.1a & 1.2.1.1b and 1.2.1.2a& 1.2.1.2b above, unless ambient conditions or extended periods at those temperatures are not sufficient to conduct the monitoring. In the event that it is not feasible to conduct a portable monitoring test at the temperatures specified in Conditions 1.2.1.1a & 1.2.1.lb and 1.2.1.2a& 1.2.1.2b, due to ambient conditions or insufficient time, a written explanation shall be submitted with the annual compliance certification describing the reasons that portable monitoring was not conducted. In the absence of credible evidence to the contrary, compliance with the VOC BACT limit is presumed provided that the natural gas used as fuel meets the requirements in Condition 1.4.1. 1.2.2 NON, CO and VOC emissions shall not exceed the annual emission limitations stated above (Colorado Construction Permits 03WE0910 and 04WE1390 as modified under the provisions of Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 16 Section I, Condition 1.3, to revise the CO emissions as indicated on the APEN received on March 30, 2007). Compliance with the emission limitations shall be monitored as follows: 1.2.2.1 Except as provided below, the emission factors listed in the table below(from the manufacturer) have been approved by the Division and shall be used to calculate emissions from the turbines as follows: NO„ CO VOC T> 0 °F: T> 0 °F: T> 0°F: CG-7101 & CG-7201: CG-7101 & CG-7201: 0.035 lb/mmBtu 0.098 lb/mmBtu 0.119 lb/mmBtu -20 ° F <T < 0 ° F: CG-7301: 0.060 CG-7301: 0.061 0.070 lb/mmBtu lb/mmBtu lb/mmBtu T< -20 °F: -20 ° F <T < 0 ° F: -20 °F < T< 0 ° F: 0.105 lb/mmBtu 0.177 lb/mmBtu 0.257 lb/mmBtu T < -20 °F: T < -20 ° F: 0.504 lb/mmBtu 0.384 lb/mmBtu Monthly emissions shall be calculated by the end of the subsequent month for each turbine using the above emission factors, the monthly natural gas consumption and the lower heating value of the gas, as specified in Condition 1.6, in the equation below: Tons _ ibs MMscn MMBtuI ton Month = EF(MMBtu) x Fuel Use(Monthl x Fuel Heat Content(MMscfl x (z000 lb) Monthly emissions from each turbine shall be used in a twelve-month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months' data. 1.2.2.2 Portable Monitoring shall be conducted quarterly in accordance with the requirements in Condition 5 to monitor compliance with the NO„ and CO emission limitations. Note that the second to the last paragraph in Condition 5 (apply for a permit modification within 60 days if the portable analyzer test indicates that the emission rates/factors are greater than the emission rates/factors identified in the permit) does not apply to these emission units. 1.3 Natural gas consumption for each turbine shall not exceed the limitations stated above (Colorado Construction Permits 03WE0910 and 04WE1390). Natural gas consumption shall be recorded monthly using each turbine's fuel meter. Monthly natural gas consumption shall be used in a twelve month Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE28I Page 17 rolling total to monitor compliance with the annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months data. 1.4 Sulfur Dioxide (SO2) emissions shall not exceed the following limitations: 1.4.1 Each turbine shall meet one of the following requirements: 1.4.1.1 Sulfur Dioxide (SO2) emissions from the turbine shall not exceed 150 ppmvd at 15% O2, OR 1.4.1.2 No fuel, which contains sulfur in excess of 0.8 percent by weight, shall be used in this combustion turbine (Colorado Construction Permits 03WE0910 and 04WE1390 and 40 CFR Part 60 Subpart GG §§ 60.333(a) & (b), as adopted by reference in Colorado Regulation No. 6, Part A). In the absence of credible evidence to the contrary, compliance with the above requirements is presumed since only pipeline quality natural gas is permitted to be used as fuel in these turbines. The permittee shall maintain records demonstrating that the natural gas burned meets the definition of pipeline quality natural gas as defined in 40 CFR Part 72 (0.5 grains or less of total sulfur per 100 standard cubic feet). The demonstration shall be made using the gas quality characteristics in a current, valid purchase contract, tariff sheet or transportation contract for the gaseous fuel. These records shall be made available to the Division upon request. 1.4.2 Sulfur Dioxide (SO2) emissions from each turbine shall not exceed 0.8 lbs/MMBtu, on a 3-hr rolling average (Colorado Regulation No. 1, Section VI.B.4.c.(i) and V1.B.2). In the absence of credible evidence to the contrary, compliance with the SO2 limitations is presumed since only pipeline quality natural gas is permitted to be used as fuel in these turbines. 1.5 Particulate Matter Emissions (PM and PM 1o) shall not exceed the following limitations: 1.5.1 Particulate Matter (PM) emissions from each turbine shall not exceed the above limitations (Colorado Regulation No. 1, Section III.A.1). In the absence of credible evidence to the contrary, compliance with the particulate matter emission limit is presumed since only pipeline quality natural gas is permitted to be used as fuel in these turbines. The numeric PM standard was determined using the design heat input of each turbine (71.42 MMBtu/hr) in the following equation: PE = 0.5 x (FI)-°26 where: PE =particulate standard in lbs/MMBtu Fl = fuel input in MMBtu/hr 1.5.2 PM and PMio emissions shall not exceed the annual emission limitations stated above (Colorado Construction Permits 03WE0910 and 04WE1390). Compliance with the emission limitations shall be monitored as follows: Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE28I Page 18 Monthly emissions shall be calculated by the end of the subsequent month for each turbine using the emission factors specified in the table above, the monthly natural gas consumption and the lower heating value of the gas, as specified in Condition 1.6, in the equation below: Tons _ Ibs MMsc'' ton ll Month — EF(M MMBtuMBtuj1 X Fuel Use(Monthl x Fuel Heat Content(MMscf) x (z000 lb1 Monthly emissions from each turbine shall be used in a twelve-month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months' data. 1.6 The Btu content of the natural gas used to fuel these turbines shall be verified semi-annually using the appropriate ASTM Methods or equivalent, if approved in advance by the Division. In lieu of collecting a sample, the Btu content of the natural gas may be determined using the in-line gas chromatograph to determine the gas composition and the appropriate ASTM Methods or equivalent, if approved in advance by the Division, to calculate the Btu content. The Btu content of the gas shall be calculated for January and July, using the average composition of the gas as determined by the in-line gas chromatograph for those months. The Btu content of the natural gas shall be based on the lower heating value of the fuel. If sampling is conducted, calculations of monthly emissions shall be made using the heat content derived from the most recent required analysis. If the gas chromatograph data is used, calculations of monthly emissions for January through June shall be made using the January average Btu content and calculations of monthly emissions for July through December shall be made using the July average Btu content. 1.7 Each turbine is subject to the following opacity requirements: 1.7.1 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section A.II.1). 1.7.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from start-up which is in excess of 30%opacity for a period or periods aggregating more than six (6) minutes in any sixty (60) consecutive minutes (Colorado Regulation No. 1, Section II.A.4). In the absence of credible evidence to the contrary, compliance with the above opacity requirements shall be presumed since only pipeline quality natural gas is permitted to be used as fuel for these turbines. 1.8 Each turbine is subject to the NSPS Subpart A, General Provisions requirements (Colorado Regulation No. 6, Part A, Federal 40 CFR 60.1 through 60.19). Specifically, these units are subject to the following: 1.8.1 No owner or operator subject to the provisions of this part shall build, erect, install, or use any article, machine, equipment or process, the use of which conceals an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit # 05OPWE281 Page 19 limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gases discharged to the atmosphere. (40 CFR § 60.12) 1.8.2 Records of startups, shutdowns, and malfunctions shall be maintained, as required under 40 CFR § 60.7. 1.8.3 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. (40 CFR § 60.11(d)). Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit # 05OPWE281 Page 20 2. H-8701 and H-8702: Heatec, Natural Gas Fired Hot Oil Heaters, Each Rated at 43.79 mmBtu/hr Unless Otherwise Specified Limitations Apply to Each Heater Permit Limitation Compliance Monitoring Condition Emission Factor Parameter Number Method Interval BACT Requirements 2.1 See Condition 2.1 0.045 lb/MMBtu,on a 1-hr Portable Flue Gas Annually NO, 2 2 average Analyzer 0.045 Ib/M vIBtu 8.9 tons/year each Recordkeeping& Monthly Calculation 0.037 lb/MMBtu,on a 1-hr Portable Flue Gas Annually CO 2 2 average Analyzer 0.037 lb/MMBtu Recordkeeping& Monthly 7.3 tons/year each Calculation 0.016 lb/MMBtu,on a 1-hr See Condition 2.2.1 average VOC 2.2 0.016 lb/MMBtu '"Recordkeeping& 3.15 tons/year each Calculation Monthly Natural Gas 2.3 416.8 MMscf/year Recordkeeping Monthly Consumption Only Natural PM 2.4 0.185 lb/MMBtu Fuel Restriction Gas is Used as Fuel NSPS General 2.5 See Condition 2.5 Provisions ASTM Methods or Heat Content of 2.6 In-Line Gas Semi-Annual Natural Gas Chromatograph Not to Exceed 20%Except as Provided for Below For Startup-Not to Only Natural Opacity 23 Exceed 30%,for ' _.°`'` `^ Fuel Restriction Gas is Used as a Period or Periods Fuel Aggregating More than Six(6)Minutes in any 60 Consecutive Minutes MACT Subpart DDDDD 2.8 See Condition 2.8 Requirements No Rain Caps or Other Stack Requirements 2.9 Obstructions are Allowed Certification Annually on the Exhaust Stacks for these Heaters Hours of Operation 2.10 Recordkeeping Monthly Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 21 2.1 Each heater is subject to the requirements of the Prevention of Significant Deterioration (PSD) Program. Best Available Control Technology (BACT) shall be applied for control of Nitrogen Oxides (NON), Carbon Monoxide (CO) and Volatile Organic Compounds (VOC). BACT has been determined to be as follows: 2.1.1 BACT for NON has been determined to be low NOx burners with emission limits as identified in Condition 2.2.1.1 (Colorado Construction Permit 03WE0913). 2.1.2 BACT for CO has been determined to be good combustion practices with emission limits as identified in Condition 2.2.1.2 (Colorado Construction Permit 03WE0913). 2.1.3 BACT for VOC has been determined to be good combustion practices with emission limits as identified in Condition 2.2.1.3 (Colorado Construction Permit 03WE0913). 2.2 Nitrogen Oxide(NOx), Carbon Monoxide (CO) and Volatile Organic Compound (VOC) emissions from each heater are subject to the following requirements: 2.2.1 For purposes of BACT NOx, CO and VOC are subject to the following limitations (Colorado Construction Permit 03WE0913): 2.2.1.1 NOx emissions shall not exceed 0.045 lb/MMBtu, on a 1-hour average. 2.2.1.2 CO emissions shall not exceed 0.037 lb/MMBtu, on a 1-hour average. 2.2.1.3 VOC emissions shall not exceed 0.016 lb/MMBtu, on a 1-hour average. Compliance with the NON and CO emission limitations shall be monitored by conducting portable monitoring annually in accordance with the requirements in Condition 5. In the absence of credible evidence to the contrary compliance with the VOC BACT limits is presumed since only pipeline quality natural gas is permitted to be used as fuel in these heaters. 2.2.2 NON, CO and VOC emissions from each heater shall not exceed the annual emission limitations stated above (Colorado Construction Permit 03WE0913) Monthly emissions from each heater shall be calculated by the end of the subsequent month using the above emission factors (from the manufacturer), the monthly fuel consumption and the lower heating value of the fuel, as specified in Condition 2.6, in the equation below: Tons _ lbs \ x Fuel Use("se/ x Fuel Heat Content MMBfu\ x \.(( tan \1 Month — EF\MMBtu) \Month MMscfJ 2000 lb / Monthly emissions from each heater shall be used in a twelve-month rolling total to monitor compliance with the annual limitation. Each month a new twelve month total shall be calculated using the previous twelve months' data. 2.3 Natural gas consumption from each heater shall not exceed the limitations stated above (Colorado Construction Permit 03WE0913, as modified under the provisions of Section I, Condition 1.3, to allow for use of a combined fuel meter instead of individual fuel meters for the hot oil heaters). Natural gas Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit # 05OPWE281 Page 22 consumed in each heater shall be recorded monthly, as required by 40 CFR Part 60 Subpart Dc § 60.48c(g), as adopted by reference in Colorado Regulation No. 6, Part A. Natural gas use shall be recorded monthly using the fuel meter associated with the two heaters and the supplemental flare fuel, and allocation of fuel used by each heater shall be made using the equation shown below. Monthly natural gas use for each heater shall be used in a twelve month rolling total to monitor compliance with the annual limitation. Each month, a new twelve month total shall be calculated using the previous twelve months data. (MMscf\ _ f(MMscf\ 1/MMscf\ Hours OperationH X \Month)H — Month/Total — Month Flare L\ Hours 0perationH8701+H8702 Where: frvIMscf\ Month ill = Fuel use for Heater H-8701 or H-8702,as applicable (MMscf\ = Total fuel use recorded at the fuel meter \Month/Toni (MMscf\ Fuel use recorded at the flare supplemental fuel meter,as required by Condition \Month)Flare 3.12 Hours Operations = Hours of operation for Heater H-8701 or H-8702,as applicable, as required by Condition 2.10 Hours OpeartionHe70i.H8702 = Hours of operation for H-8701 &H-8702 combined 2.4 Particulate matter emissions from each heater shall not exceed the above limitations (Colorado Regulation No. 1, Section 1I1.A.1). In the absence of credible evidence to the contrary, compliance with the particulate matter emission limit is presumed since only pipeline quality natural gas is permitted to be used as fuel in these heaters. The numeric PM standard was determined using the design heat input of each heater (45 MMBtu/hr) in the following equation: PE= 0.5 x (FI)-0.26 where: PE=particulate standard in lbs/MMBtu FI = fuel input in MMBtu/hr 2.5 Each heater is subject to the NSPS Subpart A, General Provisions requirements (Colorado Regulation No. 6, Part A, Federal 40 CFR 60.1 through 60.19). Specifically, these units are subject to the following: 2.5.1 No owner or operator subject to the provisions of this part shall build, erect, install, or use any article, machine, equipment or process, the use of which conceals an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gases discharged to the atmosphere. (40 CFR § 60.12) 2.5.2 Records of startups, shutdowns, and malfunctions shall be maintained, as required under 40 CFR § 60.7. Operating Permit 05OPWE281 First Issued: October I, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 23 2.5.3 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. (40 CFR § 60.11(d)). 2.6 The Btu content of the natural gas used to fuel these heaters shall be verified semi-annually using the appropriate ASTM Methods or equivalent, if approved in advance by the Division. In lieu of collecting a sample, the Btu content of the natural gas may be determined using the in-line gas chromatograph to determine the gas composition and the appropriate ASTM Methods or equivalent, if approved in advance by the Division, to calculate the Btu content. The Btu content of the gas shall be calculated for October and April, using the average composition of the gas as determined by the in-line gas chromatograph for those months. The Btu content of the natural gas shall be based on the lower heating value of the fuel. If sampling is conducted, calculations of monthly emissions shall be made using the heat content derived from the most recent required analysis. If the gas chromatograph data is used, calculations of monthly emissions for October through March shall be made using the October average Btu content and calculations of monthly emissions for April through September shall be made using the April average Btu content. 2.7 Each heater is subject to the following opacity requirements: 2.7.1 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section A.II.1). 2.7.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from start-up which is in excess of 30%opacity for a period or periods aggregating more than six (6) minutes in any sixty (60) consecutive minutes (Colorado Regulation No. 1, Section II.A.4). In the absence of credible evidence to the contrary, compliance with the above opacity requirements shall be presumed since only natural gas is permitted to be used as fuel for these heaters. 2.8 These heaters are subject to the requirements in 40 CFR Part 63 Subpart DDDDD, "National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters", including, but not limited to, the following: The requirements below reflect the current rule language as of the revisions to 40 CFR Part 63 Subpart DDDDD published in the Federal Register on January 31, 2013. However, if revisions to this Subpart are published at a later date, the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 63, Subpart DDDDD. Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit # 05OPWE281 Page 24 When do I have to comply with this subpart? (¢63.7495) 2.8.1 If you have an existing boiler or process heater, you must comply with this subpart no later than January 31, 2016, except as provided in 40 CFR 63.6(i) (§63.7435(b)). 2.8.2 You must meet the notification requirements in Condition 2.8.12 according to the schedule in Conditions 2.8.13 and 2.8.14 and in subpart A of 40 CFR Part 63. Some of the notifications must be submitted before you are required to comply with the emission limits and work practice standards in this subpart(§63.7495(d)). What emission limitations, work practice standards, and operating limits must I meet? (,¢63.7500) 2.8.3 You must meet the requirements in Conditions 2.8.3.1 through 2.8.3.3. You must meet these requirements at all times the affected unit is operating (§63.7500(a)). Boilers and process heaters in the units designed to burn gas 1 fuels subcategory are not subject to the emission limits in Tables 1 and 2 or 11 through 13 to this subpart, or the operating limits in Table 4 of Subpart DDDDD (§63.7500(e)). The work practice standards in Table 3 that apply to these heaters are: 2.8.3.1 A new or existing boiler or process heater without a continuous oxygen trim system and with heat input capacity of 10 million Btu per hour or greater: Conduct a tune-up of the boiler or process heater annually as specified in § 63.7540. (40 CFR Part 63 Subpart DDDDD, Table 3, item 3). 2.8.3.2 An existing boiler or process heater located at a major source facility, not including limited use units: Must have a one-time energy assessment performed by a qualified energy assessor. An energy assessment completed on or after January 1, 2008, that meets or is amended to meet the energy assessment requirements in this table, satisfies the energy assessment requirement. A facility that operates under an energy management program compatible with ISO 50001 that includes the affected units also satisfies the energy assessment requirement(§63.7500(a)(1) & Subpart DDDDD, Table 3, item 4). The energy assessment must include the following with extent of the evaluation for items a. to e. appropriate for the on-site technical hours listed in the definition of Energy Assesment in § 63.7575: a. A visual inspection of the boiler or process heater system. b. An evaluation of operating characteristics of the boiler or process heater systems, specifications of energy using systems, operating and maintenance procedures, and unusual operating constraints. c. An inventory of major energy use systems consuming energy from affected boilers and process heaters and which are under the control of the boiler/process heater owner/operator. d. A review of available architectural and engineering plans, facility operation and maintenance procedures and logs, and fuel usage Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 25 e. A review of the facility's energy management practices and provide recommendations for improvements consistent with the definition of energy management practices, if identified. f. A list of cost-effective energy conservation measures that are within the facility's control. g. A list of the energy savings potential of the energy conservation measures identified. h. A comprehensive report detailing the ways to improve efficiency, the cost of specific improvements, benefits, and the time frame for recouping those investments. 2.8.3.3 At all times, you must operate and maintain any affected source including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator that may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source (§63.7500(a)(3)). What are my initial compliance requirements and by what date must 1 conduct them? (,¢63.7510) 2.8.4 You must complete an initial tune-up by following the procedures described in §63.7540(a)(10)(i) through (vi) no later than the compliance date specified in Condition 2.8.1, except as specified in Condition 2.8.5. You must complete the one-time energy assessment specified in Condition 2.8.3.2 no later than the compliance date specified in Condition 2.8.1, except as specified in Condition 2.8.5. 2.8.5 For existing affected sources that have not operated between the effective date of the rule [April 1, 2013] and the compliance date that is specified in Condition 2.8.1, you must complete an initial tune-up by following the procedures described in § 63.7540(a)(10)(i)through (vi) no later than 30 days after the re-start of the affected source and, if applicable, complete the one-time energy assessment specified in Condition 2.8.3.2, no later than the compliance date specified in Condition 2.8.1. When must 1 conduct subsequent tune-ups? ( '63.7515) 2.8.6 You must conduct an annual performance tune-up according to 40 CFR 63.7540(a)(10), (11), or (12), respectively. Each annual tune-up specified in 40 CFR 63.7540(a)(10) must be no more than 13 months after the previous tune-up. (§63.7515(d)). 2.8.7 For affected sources that have not operated since the previous compliance demonstration and more than one year has passed since the previous compliance demonstration, you must complete a subsequent tune-up by following the procedures described in 40 CFR 63.7540(a)(10)(i) Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 26 through (vi) and the schedule described in 40 CFR 63.7540(a)(13) for units that are not operating at the time of their scheduled tune-up (§63.7515(g)). How do I demonstrate initial compliance with the work practice standards? (§63.7530) 2.8.8 You must submit a signed statement in the Notification of Compliance Status report that indicates that you conducted a tune-up of the unit (§63.7530(d)). 2.8.9 You must include with the Notification of Compliance Status a signed certification that the energy assessment was completed according to Condition 2.8.3.2 and is an accurate depiction of your facility at the time of the assessment(§63.7530(e)). 2.8.10 You must submit the Notification of Compliance Status containing the results of the initial compliance demonstration according to the requirements in Condition 2.8.14 (§63.7530(f)). How do I demonstrate continuous compliance with the work practice standards? (§63.7540) 2.8.11 You must demonstrate continuous compliance with the work practice standards in Condition 2.8.3 according to the following methods: 2.8.11.1 You must conduct an annual tune-up of the boiler or process heater to demonstrate continuous compliance as specified in 40 CFR §§63.7540(a)(10)(i) through (vi) (§63.7540(a)(10)). 2.8.11.2 If the unit is not operating on the required date for a tune-up, the tune-up must be conducted within 30 calendar days of startup (§63.75401(a)(13)). Notification, Reports, and Records 2.8.12 You must submit to the Administrator the initial notification (§ 63.9(b)) and the notification of compliance status (§ 63.9(h)) by the dates specified. (§ 63.7545(a)) 2.8.13 As specified in § 63.9(b)(2), if you startup your affected source before January 31, 2013, you must submit an Initial Notification not later than 120 days after January 31, 2013 (§63.7545(b)). 2.8.14 If you are required to conduct an initial compliance demonstration as specified in § 63.7530, you must submit a Notification of Compliance Status according to § 63.9(h)(2)(ii). For the initial compliance demonstration for each boiler or process heater, you must submit the Notification of Compliance Status, including all performance test results and fuel analyses, before the close of business on the 60th day following the completion of all performance test and/or other initial compliance demonstrations for all boiler or process heaters at the facility according to § 63.10(d)(2). The Notification of Compliance Status must only contain the information specified 40 CFR 63.7545(e)(1) and (8) (§63.7545(e)). 2.8.15 You must submit annual compliance reports as follows (§63.7550(b)): 2.8.15.1 The first compliance report must cover the period beginning on the compliance date Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 27 that is specified in Condition 2.8.1 and ending on July 31 or January 31, whichever date is the first date that occurs at least one year after the compliance date that is specified in Condition 2.8.1. 2.8.15.2 The first annual compliance report must be postmarked or submitted no later than January 31. 2.8.15.3 Subsequent annual compliance reports must cover the applicable 1-year period from January 1 to December 31. 2.8.15.4 Subsequent annual compliance reports must be postmarked or submitted no later than January 31. 2.8.16 A compliance report must contain the information specified in §63.7550(c)(5)(i) through (iv) and (xiv) (§63.7550(c)). 2.8.17 You must keep the following records: 2.8.17.1 A copy of each notification and report that you submitted to comply with this subpart, including all documentation supporting any Initial Notification or Notification of Compliance Status or compliance report that you submitted, according to the requirements in § 63.10(b)(2)(xiv) (§63.7555(a)(1)). 2.8.17.2 Records of performance tests, fuel analyses, or other compliance demonstrations and performance evaluations as required in § 63.10(b)(2)(viii) (§63.7555(a)(2)). 2.8.17.3 Your records must be in a form suitable and readily available for expeditious review, according to § 63.10(6)(1) (§63.7560(a)). 2.8.17.4 As specified in § 63.10(b)(1),you must keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record (§63.7560(b)). 2.8.17.5 You must keep each record on site, or they must be accessible from on site (for example, through a computer network), for at least 2 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record, according to § 63.10(b)(1). You can keep the records off site for the remaining 3 years (§63.7560(c)). What parts of the General Proyisions apply to me? (§63.7565) 2.8.18 Table 10 of 40 CFR Part 63 Subpart DDDDD shows which parts of the General Provisions in §§ 63.1 through 63.15 apply to you. (§ 63.7565) These requirements include but are not limited to the following: 2.8.18.1 Prohibited activities in § 63.4. 2.8.18.2 Notification requirements in § 63.9. 2.9 No rain caps or other obstructions are allowed on the exhaust stacks for these heaters (Colorado Construction Permit 03WE0913). Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit # 05OPWE281 Page 28 2.10 Hours of operation for the each heater shall be monitored and recorded monthly in a log that is available to the Division upon request. The hours of operation shall be used to calculate monthly fuel consumption for each heater as required by Condition 2.3 (Colorado Construction Permit 03WE0913, as modified under the provisions of Section I, Condition 1.3, to allow for use of a combined fuel meter instead of individual fuel meters for the hot oil heaters). Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit # 05OPWE281 Page 29 3. Flare Stack (FL-8921) and CO2 Vent(ST-8931): CO2 Treatment Plant—Glycol Dehydrator and Amine Unit, Each Rated at 300 mmSCF/day. Permit Limitation Compliance Monitoring Condition Emission Factor Parameter Number Method Interval t, �' See Condition 4.I BACT Requirements ..- 4.1 `',4),-4„ s*�r4k��Y Opacity—Applies to 3.2 Not to exceed 30% �^z See Condition 3.2 the Flare Only .. NO, 7.4 tons/year 1.7 lbs/hr Recordkeeping& Monthly 3.3 Calculation CO 39.42 tons/year 9 lbs/hr VOC—Flare Stack 5.8 tons/year VOC-CO2 Stack 11.8 tons/year See Condition Parametric Daily H2S—CO2 Stack 3.4 5.0 tons/year 3.4 Benzene—Glycol 0.90 tons/year Dehydrator Extended Gas Analysis ASTM Methods Quarterly Natural Gas Processed 3.5 109,500 MMscf/year Flow Meter Monthly The glycol dehydrator and Operating 3 6 amine treatment unit shall See Condition 3.6 Requirements be operated together at all ,?°3a., times e Hours of Operation 3.7 • Recordkeeping I Monthly MACT Subpart HHH 3 s Benzene emissions less , ".r. See Condition 3.8 Requirements than 1,984lbs/year MACT General 1 ` 3.9 See Condition 3.9 Provisions " ' Visible Emission Visible Emissions Monthly Requirements Observations Temperature A Flame Shall be Present - Sensor or Flame at all times that the Flare is } Detection Device Continuously Flare Requirements 3.10 Operated ,_, with Alarm Flare Specifications—Btu -_' Certification Annually Content of Gas&Velocity Flare Shall be Operating at all Times that the Certification Annually Dehydrator is Operated SulfaTreat H2S Control 3 I I H2S Emissions Shall Be See Condition 3.11 System Reduced by 75% Supplemental Fuel 3.12 Recordkeeping Monthly Consumed in the Flare 3.1 The CO2 Treatment Plant is subject to the requirements of the Prevention of Significant Deterioration (PSD) Program. Best Available Control Technology (BACT) shall be applied for control Volatile Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit # 05OPWE281 Page 30 Organic Compounds (VOC). BACT has been determined to be use of an elevated flare to reduce VOC emissions from the glycol dehydrator regenerator (still) vent and flash tank and the amine unit flash tank by 98 % (Colorado Construction Permit 03WE0916). In the absence of credible evidence to the contrary, compliance with the 98% control efficiency requirement is met provided the requirements in Conditions 3.6, 3.8, 3.9 and 3.10 are met. 3.2 No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes (Colorado Construction Permit 03WE0916 and Colorado Regulation No. 1, Section II.A.5). This opacity requirement applies to the flare only. In the absence of credible evidence to the contrary, compliance with this opacity requirement is presumed provided the requirements in Condition 3.10.4 are met. 3.3 NO,,and CO emissions from the flare shall not exceed the limitation stated above (Colorado Construction Permit 03WE0916). Monthly emissions of NO„and CO shall be calculated by the end of the subsequent month using the above emission factors (from the manufacturer) and the number of hours the flare is operated in the following equation: Tons (Ibs (( ton Month = EF x Flare hours of operation(Mouhoursrn) x hr/ \z000 lb/ A twelve month rolling total of emissions will be maintained to monitor compliance with the annual emission limitations. Each month, a new twelve month total shall be calculated using the previous twelve months data. 3.4 VOC and H2S emissions from the flare vent and the CO2 vent and benzene emissions from the glycol dehydrator shall not exceed the limitations stated above (Colorado Construction Permit 03WE0916). Compliance with the VOC, benzene and H2S emission limitations shall be monitored as follows: 3.4.1 For the dehydration unit: VOC and HAP emissions shall be calculated monthly using the Gas Research Institute's GLYCaIc Model, Version 4.0 or higher, as follows: Monthly averages of the following monitored values shall be determined for use as inputs to the GLYCaIc Model. Values of parameters shall be representative of the unit's operation during the month. Parameter Monitoring Frequency Flash Tank Temperature Flash Tank Pressure Wet Gas Inlet Temperature Daily Wet Gas Inlet Pressure Stripping Gas Rate Triethylene Glycol Recirculation Rate Operating Permit 05OPWE28I First Issued: October I, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 31 The GLYCaIc model shall also use following inputs: the most recent extended gas analysis results (inlet gas to the dehydrator) as specified in Condition 3.4.4, the hours of operation for the flare as specified in Condition 3.10.5, the hours of operation for the dehydration unit as specified in Condition 3.7 and the average daily gas throughput value calculated as specified in 3.5. A 98% control efficiency for the flare may be applied to uncontrolled emissions predicted by the model (GLYCaIc) for the dehydrator, for those hours that the flare was in operation, provided that the requirements of Conditions 3.8, 3.9 and 3.10 are met. 3.4.2 For the amine unit, VOC, HAP and H2S emissions shall be calculated monthly using the ProMax model, as follows: Monthly averages of the following monitored values shall be determined for use as inputs to the ProMax Model. Values of parameters shall be representative of the unit's operation during the month. Parameter Monitoring Frequency Inlet Gas Temperature Inlet Gas Pressure Daily Stripping Gas Rate Lean Amine Recirculation Rate The ProMax model shall also use following inputs: the most recent extended gas analysis results (inlet gas to the amine unit) as specified in Condition 3.4.4, the hours of operation for the flare as specified in Condition 3.10.5,the hours of operation for the SulfaTreat system as specified by Condition 3.11, the hours of operation for the amine unit as specified in Condition 3.7 and the average daily gas throughput value calculated as specified in 3.5. A 75%control efficiency for the SulfaTreat system may be applied to uncontrolled H2S emissions predicted by the model (ProMax) for the amine unit, for those hours that the SulfaTreat system was in operation, provided that the requirements of Condition 3.11 are met. A 98%control efficiency for the flare may be applied to uncontrolled VOC and HAP emissions predicted by the model (ProMax) for the flash tank emissions from the amine unit, for those hours that the flare was in operation, provided that the requirements of Conditions 3.8, 3.9 and 3.10 are met. 3.4.3 Monthly calculation of emissions shall be conducted by the end of the subsequent month. Monthly emissions shall be used in a twelve month rolling total of VOC, benzene and H2S to monitor compliance with the annual emission limitation. Each month, a new twelve month total shall be calculated using the previous twelve months data. Records of calculations shall be kept in a log to be made available to the Division upon request. Monthly calculations are not required when the dehydration unit and amine unit did not operate during the month. Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit # 05OPWE281 Page 32 3.4.4 An extended natural gas analysis of inlet gas to the amine unit and the glycol dehydrator shall be conducted quarterly, using ASTM methods or equivalent. Frequency of extended gas analyses shall move to semi-annually after the first year, then to annually after the second year if the BTEX concentrations remain consistently below the established values identified in the table below. Frequency will revert back to quarterly if any of the BTEX constituents exceed the listed values. The first quarterly sample shall be taken three months after the sample that indicated that a BTEX constituent exceeded the parameters in the above table was taken. Required analyses shall be conducted not less than one month apart. Constituent Value Criteria Benzene 30 At or below Toluene 30 At or below Ethylbenzene 0 Not to exceed Xylene 0 Not to exceed 3.5 The quantity of natural gas processed by the CO2 Treatment Plant shall not exceed the limitation listed above (Colorado Construction Permit 03WE0916). The natural gas processed through the CO2 Treatment Plant shall be monitored using a flow meter and recorded monthly in a log that is available to the Division upon request. Monthly natural gas processed shall be used in a twelve month rolling total to monitor compliance with the annual limitation. Each month, a new twelve month total shall be calculated using the previous twelve months data. An average daily gas throughput rate shall be determined as follows: Average Daily Gas Throughput = Gas Throughput MMscfx Month xzanr5 month Hrs Operation day This average daily gas throughput rate shall be used in the monthly GLYCaIc and ProMax runs and emission calculations required by Conditions 3.4.1 and 3.4.2. 3.6 The glycol dehydrator and the amine unit shall operate together as a unit at all times. At no time shall the glycol dehydrator be operated without the amine unit also operating and at no time shall the amine unit be operated without the glycol dehydrator. 3.7 Hours of operation for the dehydration unit and the amine unit shall be monitored and recorded monthly in a log that is available to the Division upon request. The hours of operation shall be used to calculate monthly emissions as required by Conditions 3.4.1 and 3.4.2. 3.8 The glycol dehydrator is subject to the National Emission Standards for Hazardous Air Pollutants of Regulation No. 8, Part E, Subpart HHH (40 CFR Part 63, Subpart HHH), for Natural Gas Transmission and Storage Facilities, including, but not limited to, the following: The requirements below reflect the current rule language as of the revisions to 40 CFR Part 60 Subpart HHH published in the Federal Register on August 16, 2012. However, if revisions to this Subpart are published at a later date, the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 60, Subpart HHH. Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 33 Note that the compliance date for the glycol dehydrator is the startup date (January 30, 2005) as specified in 40 CFR Part 63 Subpart HHH § 63.1270(d)(2). Affirmative defense for violations of emission standards during malfunction 3.8.1 The provisions set forth in this subpart(Condition 3.8) shall apply at all times. 3.8.2 In response to an action to enforce the standards set forth in Subpart HHH, you may assert an affirmative defense to a claim for civil penalties for violations of such standards that are caused by malfunction, as defined at § 63.2. Appropriate penalties may be assessed; however, if you fail to meet your burden of proving all of the requirements in the affirmative defense, the affirmative defense shall not be available for claims for injunctive relief(§ 63.1272(d)). 3.8.3 To establish the affirmative defense in any action to enforce such a standard, you must timely meet the reporting requirements in § 63.1272(d)(2). The affirmative defense must satisfy the requirements of§ 63.1272(d)(1). (§ 63.1272(d)(2)). General Standards 3.8.4 All reports required under this subpart shall be sent to the Administrator at the appropriate address listed in §63.13. Reports may be submitted on electronic media (40 CFR Part 63 Subpart HHH § 63.1274(b)). 3.8.5 In all cases where the provisions of this subpart require an owner or operator to repair leaks by a specified time after the leak is detected, it is a violation of this standard to fail to take action to repair the leak(s) within the specified time. If action is taken to repair the leak(s) within the specified time, failure of that action to successfully repair the leak(s) is not a violation of this standard. However, if the repairs are unsuccessful, a leak is detected and the owner or operator shall take further action as required by the applicable provisions of this subpart (40 CFR Part 63 Subpart HHH § 63.1274(g)). 3.8.6 At all times the owner or operator must operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source(§63.1274(h)). Glycol Dehydrator Unit Process Vent Standards 3.8.7 The owner or operator shall connect the process vent to a control device or a combination of control devices through a closed-vent system and the outlet benzene emissions from the control device(s) shall be less than 0.90 megagrams per year (1,984 Ibs/yr). The closed-vent system shall be designed and operated in accordance with the requirements of§63.1281(c) (Conditions 3.8.9 through 3.8.11). The control device(s) shall be designed and operated in accordance with the Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit # 05OPWE281 Page 34 requirements of§63.1281(d) (Conditions 3.8.12 and 3.8.13), except that the performance requirements specified in §63.1281(d)(1)(i) and (ii) do not apply (40 CFR Part 63 Subpart HHH § 63.1275(b)(1)(ii)). Benzene emissions from the glycol dehydrator are limited to less than 1,984 pounds per year of benzene as specified in Condition 3.4 of this permit. 3.8.8 One or more safety devices that vent directly to the atmosphere may be used on the air emission control equipment installed to comply with paragraph (b)(1) (Condition 3.8.7) of this section (40 CFR Part 63 Subpart HHH § 1275(b)(2)). Control Equipment Requirements Compliance with paragraphs (c) and (d) of this section (Conditions 3.8.9 through 3.8.13)will be determined by review of the records required by § 63.1284, the reports required by § 63.1285, by review of performance test results, and by inspections (40 CFR Part 63 Subpart HHH § 63.1281(a)). Closed-vent system requirements 3.8.9 The closed-vent system shall route all gases, vapors, and fumes emitted from the material in an emissions unit to a control device that meets the requirements specified in paragraph (d) of this section (Conditions 3.8.12 through 3.8.13) (40 CFR Part 63 Subpart HHH § 63.1281(c)(1)). 3.8.10 The closed-vent system shall be designed and operated with no detectable emissions (40 CFR Part 63 Subpart HHH § 63.1281(c)(2)). 3.8.11 If the closed-vent system contains one or more bypass devices that could be used to divert all or a portion of the gases, vapors, or fumes from entering the control device, the owner or operator shall meet the requirements specified in paragraphs (c)(3)(i) and (c)(3)(ii) of this section (Conditions 3.8.11.1 and 3.8.11.2) (40 CFR Part 63 Subpart HHH § 63.1281(c)(3)). 3.8.11.1 For each bypass device, except as provided for in paragraph (c)(3)(ii) of this section (Condition 3.8.11.2), the owner or operator shall either(40 CFR Part 63 Subpart HHH § 63.1281(c)(3)(i)): a. At the inlet to the bypass device that could divert the stream away from the control device to the atmosphere, properly install, calibrate, maintain, and operate a flow indicator that is capable of taking periodic readings and sounding an alarm when the bypass device is open such that the stream is being, or could be, diverted away from the control device to the atmosphere; or b. Secure the bypass device valve installed at the inlet to the bypass device in the non-diverting position using a car-seal or a lock-and-key type configuration. 3.8.11.2 Low leg drains, high point bleeds, analyzer vents, open-ended valves or lines, and safety devices are not subject to the requirements of paragraph (c)(3)(i) of this section (Condition 3.8.11.1) (40 CFR Part 63 Subpart HHH § 63.1281(c)(3)(ii)). Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 35 Control device requirements. 3.8.12 The flare shall be designed and operated in accordance with the requirement of§ 63.1 1(b), which are specified in Condition 3.10 (40 CFR Part 63 Subpart HHH § 63.1281(d)(1)(iii)). 3.8.13 Each control device used to comply with this subpart shall be operating at all times when gases, vapors, and fumes are vented from the emissions unit or units through the closed-vent system to the control device, as required under §63.1275. An owner or operator may vent more than one unit to a control device used to comply with this subpart(40 CFR Part 63 Subpart HHH § 63.1281(d)(4)(i)). Test Methods, Compliance Procedures, and Compliance Demonstrations No detectable emissions test procedure. (40 CFR Part 63 Subpart HHH § 63.1282(b)) 3.8.14 The procedure shall be conducted in accordance with Method 21, 40 CFR part 60, appendix A (40 CFR Part 63 Subpart HHH § 63.1282(b)(1)). 3.8.15 The detection instrument shall meet the performance criteria of Method 21,40 CFR part 60, appendix A, except the instrument response factor criteria in section 3.1.2(a) of Method 21 shall be for the average composition of the fluid, and not for each individual organic compound in the stream (40 CFR Part 63 Subpart HHH § 63.1282(b)(2)). 3.8.16 The detection instrument shall be calibrated before use on each day of its use by the procedures specified in Method 21, 40 CFR part 60, appendix A (40 CFR Part 63 Subpart HHH § 63.1282(6)(3)). 3.8.17 Calibration gases shall be as follows (40 CFR Part 63 Subpart HHH § 63.1281(b)(4)): 3.8.17.1 Zero air (less than 10 parts per million by volume hydrocarbon in air); and 3.8.17.2 A mixture of methane in air at a methane concentration of less than 10,000 parts per million by volume. 3.8.18 An owner or operator may choose to adjust or not adjust the detection instrument readings to account for the background organic concentration level. If an owner or operator chooses to adjust the instrument readings for the background level,the background level value must be determined according to the procedures in Method 21 of 40 CFR part 60, appendix A (40 CFR Part 63 Subpart HHH § 63.1282(6)(5)). 3.8.19 Except as provided in paragraph (b)(6)(ii) of this section (Condition 3.8.20), the detection instrument shall meet the performance criteria of Method 21 of 40 CFR part 60, appendix A, except the instrument response factor criteria in section 3.1.2(a) of Method 21 shall be for the average composition of the process fluid not each individual volatile organic compound in the stream. For process streams that contain nitrogen, air, or other inerts which are not organic HAP or VOC, the average stream response factor shall be calculated on an inert-free basis (40 CFR Part 63 Subpart HHH § 63.1282(b)(6)(i)). Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 36 3.8.20 If no instrument is available at the facility that will meet the performance criteria specified in paragraph (b)(6)(i) of this section (Condition 3.8.19), the instrument readings may be adjusted by multiplying by the average response factor of the process fluid, calculated on an inert-free basis as described in paragraph (b)(6)(i) of this section (Condition 3.8.19) (40 CFR Part 63 Subpart HHH § 63.1282(b)(6)(ii)). 3.8.21 An owner or operator must determine if a potential leak interface operates with no detectable emissions using the applicable procedure specified in paragraph (b)(7)(i) or(b)(7)(ii) of this section (Conditions 3.8.21.1 or 3.8.21.2) (40 CFR Part 63 Subpart HHH § 63.1282(6)(7)). 3.8.21.1 If an owner or operator chooses not to adjust the detection instrument readings for the background organic concentration level, then the maximum organic concentration value measured by the detection instrument is compared directly to the applicable value for the potential leak interface as specified in paragraph (b)(8) of this section (Condition 3.8.22) (40 CFR Part 63 Subpart HHH § 63.1282(b)(7)(i)). 3.8.21.2 If an owner or operator chooses to adjust the detection instrument readings for the background organic concentration level, the value of the arithmetic difference between the maximum organic concentration value measured by the instrument and the background organic concentration value as determined in paragraph (b)(5) of this section (condition 3.8.18) is compared with the applicable value for the potential leak interface as specified in paragraph (b)(8) of this section (Condition 3.8.22) (40 CFR Part 63 Subpart HHH § 63.1282(b)(7)(ii)). 3.8.22 A potential leak interface is determined to operate with no detectable organic emissions if the organic concentration value determined in paragraph (b)(7) (Condition 3.8.21) is less than 500 parts per million by volume (40 CFR Part 63 Subpart HHH § 63.1282(b)(8)). Control device performance test procedures 3.8.23 A flare that is designed and operated in accordance with the provisions of 40 CFR Part 63 Subpart A § 63.11(b) shall be exempt from the control device performance test procedures in 40 CFR Part 63 Subpart HHH § 63.1283(d), except for the following (40 CFR Part 63 Subpart HHH § 63.1282(d)(1)(i)): 3.8.24 An owner or operator shall design and operate each flare in accordance with the requirements specified in §63.11(b) and the compliance determination shall be conducted using Method 22 of 40 CFR part 60, appendix A, to determine visible emissions. (40 CFR Part 63 Subpart HHH § 63.1282(d)(2)). Inspection and Monitoring Requirements Closed vent system inspection and monitoring requirements 3.8.25 For each closed-vent system required to comply with this section, the owner or operator shall comply with the requirements of paragraphs (c)(2) through (7) (Conditions 3.8.26 through 3.8.31) of this section (40 CFR Part 63 Subpart HHH § 63.1283(c)(1)). Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 37 3.8.26 Except as provided in paragraphs (c)(5) and (6) of this section (Conditions 3.8.29 and 3.8.30), each closed-vent system shall be inspected according to the procedures and schedule specified in paragraphs (c)(2)(i) and (ii) of this section (Conditions 3.8.26.1 and 3.8.26.2) and each bypass device shall be inspected according to the procedures of(c)(2)(iii) of this section (Condition 3.8.26.3) (40 CFR Part 63 Subpart HHH § 63.1283(c)(2)). 3.8.26.1 For each closed-vent system joints, seams, or other connections that are permanently or semi-permanently sealed (e.g., a welded joint between two sections of hard piping or a bolted or gasketed ducting flange),the owner or operator shall (40 CFR Part 63 Subpart HHH § 63.1283(c)(2)(i)): a. Conduct annual visual inspections for defects that could result in air emissions. Defects include, but are not limited to, visible cracks, holes, or gaps in piping; loose connections; or broken or missing caps or other closure devices. The owner or operator shall monitor a component or connection using the procedures specified in §63.1282(b) (Conditions 3.8.14 through 3.8.22) to demonstrate that it operates with no detectable emissions following any time the component or connection is repaired or replaced or the connection is unsealed. Inspection results shall be submitted in the Periodic Report as specified in §63.1285(e)(2)(iii). 3.8.26.2 For closed-vent system components other than those specified in paragraph (c)(2)(i) of this section (Condition 3.8.26.1), the owner or operator shall (40 CFR Part 63 Subpart HHH § 63.1283(c)(2)(ii)): a. Conduct an initial inspection according to the procedures specified in §63.1282(b) (Conditions 3.8.14 through 3.8.22) to demonstrate that the closed-vent system operates with no detectable emissions. Inspection results shall be submitted with the Notification of Compliance Status Report as specified in §63.1285(d)(1) or (2). b. Conduct annual inspections according to the procedures specified in §63.1282(b) (conditions 3.8.14 through 3.8.22)to demonstrate that the components or connections operate with no detectable emissions. Inspection results shall be submitted in the Periodic Report as specified in §63.1285(e)(2)(iii). c. Conduct annual visual inspections for defects that could result in air emissions. Defects include, but are not limited to, visible cracks, holes, or gaps in ductwork; loose connections; or broken or missing caps or other closure devices. Inspection results shall be submitted in the Periodic Report as specified in §63.1285(e)(2)(iii). 3.8.26.3 For each bypass device, except as provided for in §63.1281(c)(3)(ii) (Condition 3.8.11.2), the owner or operator shall either (40 CFR Part 63 Subpart HHH § 63.1283(c)(2)(iii)): a. At the inlet to the bypass device that could divert the steam away from the control device to the atmosphere, set the flow indicator to take a reading at least once every 15 minutes; or Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 38 b. If the bypass device valve installed at the inlet to the bypass device is secured in the non-diverting position using a car-seal or a lock-and-key type configuration, visually inspect the seal or closure mechanism at least once every month to verify that the valve is maintained in the non-diverting position and the vent stream is not diverted through the bypass device. 3.8.27 In the event that a leak or defect is detected, the owner or operator shall repair the leak or defect as soon as practicable, except as provided in paragraph (c)(4) of this section (Condition 3.8.28) (40 CFR Part 63 Subpart HHH § 63.1283(c)(3)). 3.8.27.1 A first attempt at repair shall be made no later than 5 calendar days after the leak is detected. 3.8.27.2 Repair shall be completed no later than 15 calendar days after the leak is detected. 3.8.28 Delay of repair of a closed-vent system for which leaks or defects have been detected is allowed if the repair is technically infeasible without a shutdown, as defined in §63.1271, or if the owner or operator determines that emissions resulting from immediate repair would be greater than the fugitive emissions likely to result from delay of repair. Repair of such equipment shall be completed by the end of the next shutdown (40 CFR Part 63 Subpart HHH § 63.1283(c)(4)). 3.8.29 Any parts of the closed-vent system or cover that are designated, as described in paragraphs (c)(5) (i) and (H) of this section (Conditions 3.8.29.1 and 3.8.29.2), as unsafe to inspect are exempt from the inspection requirements of paragraphs (c)(2) (i) and (ii) of this section (Conditions 3.8.26.1 and 3.8.26.2) if(40 CFR Part 63 Subpart HHH § 63.1283(c)(5)): 3.8.29.1 The owner or operator determines that the equipment is unsafe to inspect because inspecting personnel would be exposed to an imminent or potential danger as a consequence of complying with paragraph (c)(2)(i) or(ii) of this section (Conditions 3.8.26.1 and 3.8.26.2); and 3.8.29.2 The owner or operator has a written plan that requires inspection of the equipment as frequently as practicable during safe-to-inspect times. 3.8.30 Any parts of the closed-vent system or cover that are designated, as described in paragraphs (c)(6) (i) and (H) of this section (conditions 3.8.30.1 and 3.8.30.2), as difficult to inspect are exempt from the inspection requirements of paragraphs (c)(2) (i) and (ii) of this section (Conditions 3.8.26.1 and 3.8.26.2) if(40 CFR Part 63 Subpart HHH § 63.1283(c)(6)): 3.8.30.1 The owner or operator determines that the equipment cannot be inspected without elevating the inspecting personnel more than 2 meters above a support surface; and 3.8.30.2 The owner or operator has a written plan that requires inspection of the equipment at least once every 5 years. 3.8.31 Records shall be maintained as specified in §63.1284(b)(5) through (8) (40 CFR Part 63 Subpart HHH § 63.1283(c)(7)). Control device monitoring requirements Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 39 3.8.32 The owner or operator shall install and operate a continuous parameter monitoring system in accordance with the requirements of paragraphs (d)(3), (d)(6) and (d)(7) of this section (Conditions 3.8.33 through 3.8.36). The continuous parameter monitoring system must meet the following specifications and requirements (40 CFR Part 63 Subpart HHH § 63.1283(d)(1)): 3.8.32.1 Each continuous parameter monitoring system shall measure data values at least once every hour and record either(40 CFR Part 63 Subpart HHH § 63.1283(d)(1)(i)): a. Each measured data value 3.8.32.2 A site-specific monitoring plan must be prepared that addresses the monitoring system design, data collection, and the quality assurance and quality control elements outlined in 40 CFR Part 63 §63.1282(d)(1)(ii) and in § 63.8(d). Each CPMS must be installed, calibrated, operated, and maintained in accordance with the procedures in your approved site-specific monitoring plan. Using the process described in § 63.8(f)(4), you may request approval of monitoring system quality assurance and quality control procedures alternative to those specified in paragraphs (d)(1)(ii)(A) through (E) of this section in your site-specific monitoring plan. (40 CFR Part 63 Subpart HHH § 63.1283(d)(I)(ii)). 3.8.32.3 The owner or operator must conduct the CPMS equipment performance checks, system accuracy audits, or other audit procedures specified in the site-specific monitoring plan at least once every 12 months. (40 CFR Part 63 Subpart HHH § 63.1283(d)(1)(iii)). 3.8.32.4 The owner or operator must conduct a performance evaluation of each CPMS in accordance with the site-specific monitoring plan. (40 CFR Part 63 Subpart HHH § 63.1283(d)(1)(iv)). 3.8.33 The owner or operator shall install, calibrate, operate, and maintain a device equipped with a continuous recorder to measure the values of operating parameters appropriate for the control device as specified in either paragraph (d)(3)(i), (d)(3)(ii), or (d)(3)(iii) of this section (Condition 3.8.33.1) (40 CFR Part 63 Subpart HHH § 63.1283(d)(3)(i)). 3.8.33.1 A continuous monitoring system that measures the following operating parameters as applicable (40 CFR Part 63 Subpart HHH § 63.1283(d)(3)(i)): a. For a flare, a heat sensing monitoring device equipped with a continuous recorder that indicates the continuous ignition of the pilot flame (40 CFR Part 63 Subpart HHH § 63.1283(d)(3)(i) (C)). 3.8.34 An excursion for a given control device is determined to have occurred when the monitoring data or lack of monitoring data result in any one of the criteria specified in paragraphs (d)(6)(i) through (d)(6)(iv) of this section (Conditions 3.8.34.1 and 3.8.34.2) being met. When multiple operating parameters are monitored for the same control device and during the same operating day, and more than one of these operating parameters meets an excursion criterion specified in paragraphs (d)(6)(i) through (d)(6)(iv) of this section (Conditions 3.8.34.1 and 3.8.34.2), then a single excursion is determined to have occurred for the control device for that operating day (40 CFR Part 63 Subpart HHH § 63.1283(d)(6)). Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit # 05OPWE281 Page 40 3.8.34.1 An excursion occurs when the monitoring data are not available for at least 75 percent of the operating hours in a day (40 CFR Part 63 Subpart HHH § 63.1283(d)(6)(iii)). Note that this requirement applies to the data monitored for the flare as required by Condition 3.8.32. 3.8.34.2 If the closed-vent system contains one or more bypass devices that could be used to divert all or a portion of the gases, vapors, or fumes from entering the control device, an excursion occurs when (40 CFR Part 63 Subpart HHH § 63.1283(d)(3)(iv)): a. For each bypass line subject to §63.1281(c)(3)(i)(A) (Condition 3.8.11.1a the flow indicator indicates that flow has been detected and that the stream has been diverted away from the control device to the atmosphere. b. For each bypass line subject to §63.1281(c)(3)(i)(B) (Condition 3.8.11.1b), if the seal or closure mechanism has been broken, the bypass line valve position has changed, the key for the lock-and-key type lock has been checked out, or the car- seal has broken. 3.8.35 For each excursion, the owner or operator shall be deemed to have failed to have applied control in a manner that achieves the required operating parameter limits. Failure to achieve the required operating parameter limits is a violation of this standard. (40 CFR Part 63 Subpart HHH § 63.1283(d)(7)). 3.8.36 Nothing in paragraphs (d)(1)through (d)(8) of this section (Conditions 3.8.32 through 3.8.35) shall be construed to allow or excuse a monitoring parameter excursion caused by any activity that violates other applicable provisions of this subpart (40 CFR Part 63 Subpart HHH § 63.1283(d)(9)). Recordkeeping and Reporting Requirements 3.8.37 Records shall be kept as required by 40 CFR Part 63 Subpart HHH § 63.1284(a), (b), (c) and (e). 3.8.38 Reports shall be submitted as required by 40 CFR Part 63 Subpart HHH § 63.1285. 3.8.39 The owner or operator shall maintain records of the occurrence and duration of each malfunction of operation ( i.e., process equipment) or the air pollution control equipment and monitoring equipment. The owner or operator shall maintain records of actions taken during periods of malfunction to minimize emissions in accordance with § 63.1274(h) (Conditions 3.8.1 through 3.8.3), including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation (§ 63.1284(f)). 3.9 The glycol dehydrator is subject to the General Provisions in Regulation No. 8, Part E, Section I (40 CFR Part 63, Subpart A), as specified in 40 CFR Part 63 Subpart HHH § 63.1274(a). These requirements include, but are not limited to the following: 3.9.1 Prohibited activities and circumvention in § 63.4. 3.9.2 Performance test requirements in § 63.7 except for § 63.7(e)(1) Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 41 3.9.3 Monitoring requirements in § 63.8. 3.9.4 Notification requirements in § 63.9. 3.9.5 Recordkeeping requirements in § 63.10. 3.10 The flare is subject to the following requirements from 40 CFR Part 63 Subpart A § 63.11(b): 3.10.1 Owners or operators using flares to comply with the provisions of this part shall monitor these control devices to assure that they are operated and maintained in conformance with their designs (40 CFR Part 63 Subpart A § 63.11(b)(1)). 3.10.2 Flares shall be steam-assisted, air-assisted, or non-assisted (40 CFR Part 63 Subpart A § 63.11(b)(2)). 3.10.3 Flares shall be operated at all times when emissions may be vented to them(40 CFR Part 63 Subpart A § 63.11(6)(3)). 3.10.4 Flares shall be designed for and operated with no visible emissions, except for periods not to exceed a total of 5 minutes during any 2 consecutive hours. Test Method 22 in appendix A of part 60 of this chapter shall be used to determine the compliance of flares with the visible emission provisions of this part. The observation period is 2 hours and shall be used according to Method 22. (40 CFR Part 63 Subpart A § 63.11(6)(4)) Compliance with the visible emission requirements shall be monitored by conducting a visible emission observation monthly when the flare is operating. Monthly observations shall last a minimum of five minutes. If no visible emissions are present during this observation, in the absence of credible evidence to the contrary, the flare will be considered in compliance with the above visible emissions requirement. If visible emissions are present during the monthly reading, a two (2) hour observation shall be conducted in accordance with Method 22 to determine if the flare is in compliance with the above visible emissions requirement. If visible emissions are present for five minutes or less (total) during the two-hour observation, then the flare shall be deemed in compliance. If visible emissions are present for more than five minutes (total) during the two-hour observation, then the flare shall be deemed out of compliance with the above visible emissions requirement. Subject to the provisions of C.R.S. § 25-7-123.1 and in the absence of credible evidence to the contrary, exceedance of the visible emission requirement shall be considered to exist from the time a Method 22 reading is taken that shows the flare is out of compliance (as defined above) until a Method 22 reading is taken that shows the flare is in compliance (as defined above). 3.10.5 Flares shall be operated with a flame present at all times. The presence of a flare pilot flame shall be monitored using a thermocouple or any other equivalent device to detect the presence of a flame (40 CFR Part 63 Subpart A § 63.11(b)(5))). The device must meet the specific requirements specified in Conditions 3.8.32 and 3.8.33. Records of the times and duration of all periods of pilot flame outages, and estimated emissions shall be maintained and made available Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 42 to the Division upon request. Estimated emissions shall be used as specified in Condition 3.4.1 to monitor compliance with the VOC and benzene emission limitation in Condition 3.4. 3.10.6 Flares shall be used only with the net heating value of the gas being combusted being 11.2 MJ/scm (300 Btu/scf) or greater if the flare is steam-assisted or air-assisted; or with the net heating value of the gas being combusted being 7.45 MJ/scm (200 Btu/scf) or greater if the flare is nonassisted (40 CFR Part 63 Subpart A § 63.11(b)(6)(ii)). The net heating value of the gas being combusted shall be calculated using the equation specified in 40 CFR Part 63 Subpart A § 63.11(b)(6)(ii). 3.10.7 Air-assisted flares shall be designed and operated with an exit velocity less than the velocity, Vmax, as determined by 40 CFR Part 63 Subpart A § 63.11(b)(8) (40 CFR Part 63 Subpart A § 63.11(b)(8)). The actual exit velocity of a flare shall be determined by dividing by the volumetric flow rate of gas being combusted (in units of emission standard temperature and pressure), as determined by Test Method 2, 2A, 2C, or 2D in appendix A to 40 CFR part 60 of this chapter, as appropriate, by the unobstructed (free) cross-sectional area of the flare tip (40 CFR Part 63 Subpart A § 63.11(b)(7)(i)). 3.10.8 The permittee shall maintain records from the September 2005 performance test indicating compliance with the requirements of Conditions 3.10.6 and 3.10.7. The results of the monitoring required under 3.10.4 shall be used to assess compliance with the requirements in Conditions 3.10.6 and 3.10.7. 3.11 Emissions from the amine unit regenerator(still) vent shall be routed through a closed vent system to the Sulfa Treat H2S control system prior to being emitted. The SulfaTreat H2S control system shall be operated and maintained to reduce H2S emissions from the amine unit regenerator(still) vent by 75%or greater(Colorado Construction Permit 03WE0916). The outlet H2S concentration shall be continuously monitored in order to determine when the SulfaTreat material must be replaced. The permittee shall keep records from the manufacturer which indicate the H2S outlet concentration level that requires replacement of the SulfaTreat material. In the absence of credible evidence to the contrary, compliance with the 75% reduction requirement shall be presumed provided the SulfaTreat unit and associated H2S monitoring system are operated and maintained in accordance with manufacturer's recommendations and good engineering practices. Records of the times and duration of all periods the SulfaTreat unit was not operating and estimated emissions shall be maintained and made available to the Division upon request. Estimated emissions shall be used as specified in Condition 3.4.2 to monitor compliance with the 1-125 emission limitations in Condition 3.4. 3.12 Supplemental fuel consumed in the flare shall be monitored and recorded monthly in a log that is available to the Division upon request. The amount of supplemental fuel consumed shall be used to calculate monthly monthly fuel consumption for each heater as required by Condition 2.3 (Colorado Construction Permit 03WE0913, as modified under the provisions of Section 1, Condition 1.3, to allow for use of a combined fuel meter instead of individual fuel meters for the hot oil heaters). Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit # 05OPWE281 Page 43 4. EG-6141- Caterpillar, Model No. 351613 LE, Emergency Generator Rated at 1557 hp Permit Limitation Compliance Monitoring Condition Emission Factor Parameter Number Method Interval NO, 1 g/hp-hr Recordkeeping&4.1 Annually CO 3.04 g/hp-hr Calculation Hours of Operation 4.2 Recordkeeping Annually Only Natural Opacity 4.3 Not to exceed 20% Fuel Restriction Gas is Used as Fuel MACT Subpart ZZZZ Requirements— "` 4.4 . See Condition 4.4 : ,., rprw Exemptions for ;;. t„ Emergency Engines 4.1 The emission factors listed above have been approved by the Division and shall be used to calculate emissions from the emergency generator (from the manufacturer). Annual emissions of Nitrogen Oxide (NO,0 and Carbon Monoxide (CO) emissions for purposes of APEN reporting and payment of annual fees shall be determined using the above emission factors, the maximum horsepower(1557 hp) and the hours of operation (as required by Condition 4.2)the following equation: Tons (/ hr lb Year = EF \hp-hr� x hours of operation(yr) x Max HPx (453.6O x ( ton 1z000 ton) 4.2 Hours of operation shall be monitored annually and recorded in a log to be made available to the Division upon request. For each operational period, the log shall note whether the engine was operated for purposes of: (1) maintenance checks and readiness testing, (2) emergency operation, or(3) non- emergency operation. Recorded data shall be used to calculate emissions as required by Condition 4.1, and to monitor the engine's exemption status under 40 CFR Part 63 Subpart ZZZZ as required by Condition 4.4.1. Note that if annual hours of operation exceed 250 hours in any year, the engine is no longer exempt from the permitting requirements in Colorado Regulation No. 3, as per Part B Section II.D.1.c.(ii). Note also that if annual hours of operation exceed 250 hours per year in any year, the exemption from the requirement to install controls under Colorado Regulation No. 7, Section XVII.E.3.b.(ii) is no longer applicable (based on the approval letter provided by the Division dated December 21, 2009). In the event that hours of operation exceed 250 hours per year,the permittee shall submit an application to revise this permit within 30 days in order to include the appropriate applicable requirements. 4.3 No owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section II.A.1). In the absence of credible evidence to the contrary, compliance with the above opacity requirements shall be presumed since only natural gas is used permitted to be as fuel in this engine. The permittee shall maintain records that verify that only natural gas is used as fuel in this engine. Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 44 4.4 This engine qualifies as a new emergency stationary RICE greater than 500 hp located at a major source. As such, this engine is only subject to the initial notification requirements the National Emissions Standards for Hazardous Air Pollutants requirements of Regulation No. 8, Part E, Subpart ZZZZ (40 CFR Part 63, Subpart ZZZZ), for Stationary Reciprocating Internal Combustion Engines. The requirements below reflect the current rule language as of the revisions to 40 CFR Part 63 Subpart ZZZZ published in the Federal Register on January 30, 2013. However, if revisions to this Subpart are published at a later date, the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 63 Subpart ZZZZ. These requirements have not been adopted into Colorado Regulation No. 8, Part E as of the date of this permit issuance [DATE], and are therefore not state-enforceable. In the event that these requirements are adopted into Colorado Regulations, they will become state-enforceable. 4.4.1 If you own or operate an emergency stationary RICE, you must operate the emergency stationary RICE according to the requirements in Conditions 4.4.1.1 through 4.4.1.3. In order for the engine to be considered an emergency stationary RICE under this subpart, any operation other than emergency operation, maintenance and testing, emergency demand response, and operation in non-emergency situations for 50 hours per year, as described in Condition 4.4.1.3, is prohibited. If you do not operate the engine according to the requirements in Conditions 4.4.1.1 through 4.4.1.3, the engine will not be considered an emergency engine under this subpart and must meet all requirements for non-emergency engines (§63.6640(f)). 4.4.1.1 There is no time limit on the use of emergency stationary RICE in emergency situations. 4.4.1.2 You may operate your emergency stationary RICE for any combination of the purposes specified in Condition 4.4.1.2.a below for a maximum of 100 hours per calendar year. Any operation for non-emergency situations as allowed by 4.4.1.3 counts as part of the 100 hours per calendar year allowed by this Condition 4.4.1.2. a. Emergency stationary RICE may be operated for maintenance checks and readiness testing, provided that the tests are recommended by federal, state or local government, the manufacturer, the vendor, the regional transmission organization or equivalent balancing authority and transmission operator, or the insurance company associated with the engine. The owner or operator may petition the Administrator for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the owner or operator maintains records indicating that federal, state, or local standards require maintenance and testing of emergency RICE beyond 100 hours per calendar year. 4.4.1.3 Emergency stationary RICE located at major sources of HAP may be operated for up to 50 hours per calendar year in non-emergency situations. The 50 hours of operation in non-emergency situations are counted as part of the 100 hours per calendar year for maintenance and testing and emergency demand response provided in Condition 4.4.1.2. The 50 hours per year for non-emergency situations cannot be used for peak Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 45 shaving or non-emergency demand response, or to generate income for a facility to supply power to an electric grid or otherwise supply power as part of a financial arrangement with another entity. The records maintained as required by Condition 4.2 shall be used to monitor the hours and type of operation for this emergency engine. 5. Portable Monitoring (10/12/12 version) Emission measurements of nitrogen oxides (NQ) and carbon monoxide (CO) shall be conducted quarterly using a portable flue gas analyzer. At least one calendar month shall separate the quarterly tests. Note that if the engine is operated for less than 100 hrs in any quarterly period, then the portable monitoring requirements do not apply. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's website at: http://www.colorado.gov/cs/Satellite/CDPHE-AP/CBON/1251596520270 Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual or short term emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year(8760), whichever applies. If the portable analyzer results indicate compliance with both the NOx and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOx and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOx or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOx and CO emission limitations or until the engine is taken offline. For comparison with the emission rates/factors, the emission rates/factors determined by the portable analyzer tests and approved by the Division shall be converted to the same units as the emission rates/factors in the permit. If the portable analyzer tests shows that either the NOx or CO emission rates/factors are greater than the relevant ones set forth in the permit, and in the absence of subsequent testing results to the contrary (as approved by the Division),the permittee shall apply for a modification to this permit to reflect, at a minimum, the higher emission rate/factor within 60 days of the completion of the test. Results of all tests conducted shall be kept on site and made available to the Division upon request. Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 46 6. H-8721 —Two Maxon, Model Tube-o-Flame, Reboiler Burners Rated at 3.8 MMBtu/hr each (Total of 7.6 MMBtu/hr) Permit Limitation Compliance Monitoring Condition Emission Factor Parameter Number Method Interval NO„ 0.12 lb/MMBtu Recordkeeping& 6.1 Calculation Annually CO 0.147 lb/MMBtu Hours of Operation 6.2 Recordkeeping Annual Not to exceed 20%Except as Provided for Below For Startup-Not to Only Natural Opacity 63 Exceed 30%,for Fuel Restriction Gas is Used as a Period or Periods Fuel Aggregating More than Six(6)Minutes in any 60 Consecutive Minutes Particulate Matter Only Natural (PM) 6.4 0.30 lb/M3/Mtu Fuel Restriction Gas is Used as Fuel Note that this emission unit is exempt from the construction permit requirements in Regulation No. 3,Part B. 6.1 The emission factors listed above have been approved by the Division and shall be used to calculate emissions from the reboiler burners (from the manufacturer). Annual emissions of Nitrogen Oxide (NOx) and Carbon Monoxide (CO) emissions for purposes of APEN reporting and payment of annual fees shall be determined using the above emission factors, the maximum rating for both burners combined (7.6 MMBtu/hr) and the hours of operation (as required by Condition 4.2)the following equation: Tons lb hr MMBtu lb ton = EF(MMBtu) x hours of operation(yr) x Rating( hr ) x Year 453.6 g) x (2000 ton) 6.2 Hours of operation shall be monitored annually and recorded in a log to be made available to the Division upon request. Recorded data shall be used to calculate emissions as required by Condition 6.1. 6.3 The reboiler burners are subject to the following opacity requirements: 6.3.1 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant which is in excess of 20%opacity (Colorado Regulation No. I, Section A.II.1). 6.3.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from start-up which is in excess of 30% opacity for a period or periods aggregating more than six (6) minutes in any sixty (60) consecutive minutes (Colorado Regulation No. 1, Section II.A.4). Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 47 In the absence of credible evidence to the contrary, compliance with the above opacity requirements shall be presumed since only natural gas is used permitted to be as fuel in these burners. The permittee shall maintain records that verify that only natural gas is used as fuel in these burners. 6.4 Particulate Matter (PM) emissions from the reboiler burners shall not exceed the above limitation (Colorado Regulation No. 1, Section III.A.1.b). In the absence of credible evidence to the contrary, compliance with the particulate matter emission limits is presumed since only natural gas and is permitted to be used as fuel for the boiler and process heaters. The permittee shall maintain records that verify that only natural gas is used as fuel in the boiler and process heaters. Note that the numeric PM standard for the reboiler burners was determined using the design heat input rate for the unit(7.6 MMBtu/hr) in the following equation: PE= 0.5 x (FI)-°26 where: PE = particulate standard in lb/MMBtu FI = fuel input in MMBtu/hr Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 48 SECTION III - Permit Shield Regulation No. 3, 5 CCR 1001-5, Part C, §§ I.A.4, V.D. & XIII.B; § 25-7-I14.4(3)(a), C.R.S. 1. Specific Non-Applicable Requirements Based on the information available to the Division and supplied by the applicant, the following parameters and requirements have been specifically identified as non-applicable to the facility to which this permit has been issued. This shield does not protect the source from any violations that occurred prior to or at the time of permit issuance. In addition, this shield does not protect the source from any violations that occur as a result of any modifications or reconstruction on which construction commenced prior to permit issuance. The source did not specifically identify and justify any non-applicable requirements to be included in the permit shield. 2. General Conditions Compliance with this Operating Permit shall be deemed compliance with all applicable requirements specifically identified in the permit and other requirements specifically identified in the permit as not applicable to the source. This permit shield shall not alter or affect the following: 2.1 The provisions of§§ 25-7-112 and 25-7-113, C.R.S., or § 303 of the federal act, concerning enforcement in cases of emergency; 2.2 The liability of an owner or operator of a source for any violation of applicable requirements prior to or at the time of permit issuance; 2.3 The applicable requirements of the federal Acid Rain Program, consistent with § 408(a) of the federal act; 2.4 The ability of the Air Pollution Control Division to obtain information from a source pursuant to §25-7- 111(2)(I), C.R.S., or the ability of the Administrator to obtain information pursuant to § 114 of the federal act; 2.5 The ability of the Air Pollution Control Division to reopen the Operating Permit for cause pursuant to Regulation No. 3, Part C, § XIII. 2.6 Sources are not shielded from terms and conditions that become applicable to the source subsequent to permit issuance. 3. Stream-lined Conditions The following applicable requirements have been subsumed within this operating permit using the pertinent streamlining procedures approved by the U.S. EPA. For purposes of the permit shield, compliance with the listed permit conditions will also serve as a compliance demonstration for purposes of the associated subsumed requirements. Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 49 Permit Condition Streamlined (Subsumed) Requirements Section II, 40 CFR Part 60 Subpart GG § 60.332(6) (as adopted by reference in Regulation Condition 1.2.1.1 No. 6, Part A, Subpart GG) [Nitrogen Oxide emissions shall not exceed 189.5 ppmvd at 15% oxygen and ISO standard day conditions] Section II, 40 CFR Part 60 Subpart GG § 60.334(h)(3), as adopted by reference in Colorado Condition 1.4.1 Regulation No. 6, Part A [source shall monitor the sulfur content of the fuel] Section II, Colorado Regulation No. 6, Part B, Section II.C.2 [particulate matter emissions Conditions 1.5.1 shall not exceed 0.5(FI)"°16 lbs/MMBtu] —State Only Requirement and 2.4 and 6.4 Section II, Colorado Regulation No. 6, Part B, Section II.C.3 [opacity of emissions shall not Conditions 1.7 exceed 20%] — State Only Requirement and 2.7 and 6.3 Section II, Colorado Regulation No. 6, Part B, Section II.D.3.a [SO2 emissions shall not Condition 1.4.2 exceed 0.8 lbs/MMBtu] -State Only Requirement Section II, Regulation No. 6, Part B, Section I [general provisions] - State-only Conditions 1.8 Requirement and 2.5 Section IV, 40 CFR Part 60 Subpart Dc § 60.48c(i) [retain records for 2 yrs] Conditions 22.6 and c Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 50 SECTION IV- General Permit Conditions (ver 5/22/2012) 1. Administrative Changes Regulation No.3,5 CCR 1001-5,Part A, § 11I. 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.I. 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,§§ 111.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.,11.B.,11.C.,II.E.,II.F.,11.1,and 11.J a. To Control Emissions Leaving Colorado When emissions generated from sources in Colorado cross the State boundary line,such emissions shall not cause the air quality standards of the receiving State to be exceeded,provided reciprocal action is taken by the receiving State. Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 51 b. Emission Monitoring Requirements The Division may require owners or operators of stationary air pollution sources to install,maintain,and use instrumentation to monitor and record emission data as a basis for periodic reports to the Division. c. Performance Testing The owner or operator of any air pollution source shall, upon request of the Division,conduct performance test(s) and furnish the Division a written report of the results of such test(s) in order to determine compliance with applicable emission control regulations. Performance test(s)shall be conducted and the data reduced in accordance with the applicable reference test methods unless the Division: (i) specifies or approves, in specific cases,the use of a test method with minor changes in methodology; (ii) approves the use of an equivalent method; (iii) approves the use of an alternative method the results of which the Division has determined to be adequate for indicating where a specific source is in compliance;or (iv) waives the requirement for performance test(s)because the owner or operator of a source has demonstrated by other means to the Division's satisfaction that the affected facility is in compliance with the standard. Nothing in this paragraph shall be construed to abrogate the Commission's or Division's authority to require testing under the Colorado Revised Statutes,Title 25,Article 7,and pursuant to regulations promulgated by the Commission. Compliance test(s)shall be conducted under such conditions as the Division shall specify to the plant operator based on representative performance of the affected facility.The owner or operator shall make available to the Division such records as may be necessary to determine the conditions of the performance test(s).Operations during period of startup, shutdown,and malfunction shall not constitute representative conditions of performance test(s)unless otherwise specified in the applicable standard. The owner or operator of an affected facility shall provide the Division thirty days prior notice of the performance test to afford the Division the opportunity to have an observer present.The Division may waive the thirty day notice requirement provided that arrangements satisfactory to the Division are made for earlier testing. The owner or operator of an affected facility shall provide,or cause to be provided,performance testing facilities as follows: (i) Sampling ports adequate for test methods applicable to such facility; (ii) Safe sampling platform(s); (iii) Safe access to sampling platform(s); and (iv) Utilities for sampling and testing equipment. Each performance test shall consist of at least three separate runs using the applicable test method. Each run shall be conducted for the time and under the conditions specified in the applicable standard.For the purpose of determining compliance with an applicable standard,the arithmetic mean of results of at least three runs shall apply. In the event that a sample is accidentally lost or conditions occur in which one of the runs must be discontinued because of forced shutdown,failure of an irreplaceable portion of the sample train,extreme meteorological conditions,or other circumstances beyond the owner or operator's control,compliance may, upon the Division's approval,be determined using the arithmetic mean of the results of the two other runs. Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 52 Nothing in this section shall abrogate the Division's authority to conduct its own performance test(s)if so warranted. d. Affirmative Defense Provision for Excess Emissions during Malfunctions An affirmative defense to a claim of violation under these regulations is provided to owners and operators for civil penalty actions for excess emissions during periods of malfunction. To establish the affirmative defense and to be relieved of a civil penalty in any action to enforce an applicable requirement,the owner or operator of the facility must meet the notification requirements below in a timely manner and prove by a preponderance of evidence that: (i) The excess emissions were caused by a sudden, unavoidable breakdown of equipment,or a sudden, unavoidable failure of a process to operate in the normal or usual manner, beyond the reasonable control of the owner or operator; (ii) The excess emissions did not stem from any activity or event that could have reasonably been foreseen and avoided,or planned for,and could not have been avoided by better operation and maintenance practices; (iii) Repairs were made as expeditiously as possible when the applicable emission limitations were being exceeded; (iv) The amount and duration of the excess emissions(including any bypass)were minimized to the maximum extent practicable during periods of such emissions; (�) All reasonably possible steps were taken to minimize the impact of the excess emissions on ambient air quality; (vi) All emissions monitoring systems were kept in operation(if at all possible); (vii) The owner or operator's actions during the period of excess emissions were documented by properly signed,contemporaneous operating logs or other relevant evidence; (viii) The excess emissions were not part of a recurring pattern indicative of inadequate design,operation,or maintenance; (ix) At all times,the facility was operated in a manner consistent with good practices for minimizing emissions. This section is intended solely to be a factor in determining whether an affirmative defense is available to an owner or operator,and shall not constitute an additional applicable requirement;and (x) During the period of excess emissions,there were no exceedances of the relevant ambient air quality standards established in the Commissions' Regulations that could be attributed to the emitting source. The owner or operator of the facility experiencing excess emissions during a malfunction shall notify the division verbally as soon as possible,but no later than noon of the Division's next working day,and shall submit written notification following the initial occurrence of the excess emissions by the end of the source's next reporting period. The notification shall address the criteria set forth above. The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief. The Affirmative Defense Provision does not apply to failures to meet federally promulgated performance standards or emission limits, including,but not limited to,new source performance standards and national emission standards for hazardous air pollutants.The affirmative defense provision does not apply to state implementation plan(sip) limits or permit limits that have been set taking into account potential emissions during malfunctions,including,but not necessarily limited to,certain limits with 30-day or longer averaging times, limits that indicate they apply during malfunctions,and limits that indicate they apply at all times or without exception. Operating Permit 05OPWE281 First Issued: October I, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 53 e. Circumvention Clause A person shall not build,erect,install,or use any article,machine,equipment,condition,or any contrivance,the use of which,without resulting in a reduction in the total release of air pollutants to the atmosphere,reduces or conceals an emission which would otherwise constitute a violation of this regulation.No person shall circumvent this regulation by using more openings than is considered normal practice by the industry or activity in question. f. Compliance Certifications For the purpose of submitting compliance certifications or establishing whether or not a person has violated or is in violation of any standard in the Colorado State Implementation Plan,nothing in the Colorado State Implementation Plan shall preclude the use, including the exclusive use,of any credible evidence or information,relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed.Evidence that has the effect of making any relevant standard or permit term more stringent shall not be credible for proving a violation of the standard or permit term. When compliance or non-compliance is demonstrated by a test or procedure provided by permit or other applicable requirement,the owner or operator shall be presumed to be in compliance or non-compliance unless other relevant credible evidence overcomes that presumption. g. Affirmative Defense Provision for Excess Emissions During Startup and Shutdown An affirmative defense is provided to owners and operators for civil penalty actions for excess emissions during periods of startup and shutdown.To establish the affirmative defense and to be relieved of a civil penalty in any action to enforce an applicable requirement,the owner or operator of the facility must meet the notification requirements below in a timely manner and prove by a preponderance of the evidence that: (i) The periods of excess emissions that occurred during startup and shutdown were short and infrequent and could not have been prevented through careful planning and design; (ii) The excess emissions were not part of a recurring pattern indicative of inadequate design,operation or maintenance; (iii) If the excess emissions were caused by a bypass(an intentional diversion of control equipment),then the bypass was unavoidable to prevent loss of life,personal injury,or severe property damage; (iv) The frequency and duration of operation in startup and shutdown periods were minimized to the maximum extent practicable; (v) All possible steps were taken to minimize the impact of excess emissions on ambient air quality; (vi) All emissions monitoring systems were kept in operation(if at all possible); (vii) The owner or operator's actions during the period of excess emissions were documented by properly signed,contemporaneous operating logs or other relevant evidence;and, (viii) At all times,the facility was operated in a manner consistent with good practices for minimizing emissions. This subparagraph is intended solely to be a factor in determining whether an affirmative defense is available to an owner or operator,and shall not constitute an additional applicable requirement. The owner or operator of the facility experiencing excess emissions during startup and shutdown shall notify the Division verbally as soon as possible,but no later than two(2)hours after the start of the next working day, and shall submit written quarterly notification following the initial occurrence of the excess emissions. The notification shall address the criteria set forth above. The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief. Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 54 The Affirmative Defense Provision does not apply to State Implementation Plan provisions or other requirements that derive from new source performance standards or national emissions standards for hazardous air pollutants,or any other federally enforceable performance standard or emission limit with an averaging time greater than twenty- four hours. In addition,an affirmative defense cannot be used by a single source or small group of sources where the excess emissions have the potential to cause an exceedance of the ambient air quality standards or Prevention of Significant Deterioration(PSD)increments. In making any determination whether a source established an affirmative defense,the Division shall consider the information within the notification required above and any other information the Division deems necessary,which may include,but is not limited to,physical inspection of the facility and review of documentation pertaining to the maintenance and operation of process and air pollution control equipment. 4. Compliance Requirements Regulation No.3, 5 CCR 1001-5,Part C, §§III.C.9.,V.C.11.& 16.d. and § 25-7-122.1(2),C.R.S. a. The permittee must comply with all conditions of the Operating Permit. Any permit noncompliance relating to federally-enforceable terms or conditions constitutes a violation of the federal act,as well as the state act and Regulation No. 3. Any permit noncompliance relating to state-only terms or conditions constitutes a violation of the state act and Regulation No. 3, shall be enforceable pursuant to state law,and shall not be enforceable by citizens under§ 304 of the federal act. Any such violation of the federal act,the state act or regulations implementing either statute is grounds for enforcement action,for permit termination,revocation and reissuance or modification or for denial of a permit renewal application. b. It shall not be a defense for a permittee in an enforcement action or a consideration in favor of a permittee in a permit termination,revocation or modification action or action denying a permit renewal application that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of the permit. c. The permit may be modified,revoked,reopened, and reissued,or terminated for cause. The filing of any request by the permittee for a permit modification,revocation and reissuance,or termination,or any notification of planned changes or anticipated noncompliance does not stay any permit condition,except as provided in §§X. and XI.of Regulation No.3,Part C. d. The permittee shall furnish to the Air Pollution Control Division,within a reasonable time as specified by the Division,any information that the Division may request in writing to determine whether cause exists for modifying, revoking and reissuing,or terminating the permit or to determine compliance with the permit. Upon request,the permittee shall also furnish to the Division copies of records required to be kept by the permittee, including information claimed to be confidential. Any information subject to a claim of confidentiality shall be specifically identified and submitted separately from information not subject to the claim. e. Any schedule for compliance for applicable requirements with which the source is not in compliance at the time of permit issuance shall be supplemental,and shall not sanction noncompliance with,the applicable requirements on which it is based. f For any compliance schedule for applicable requirements with which the source is not in compliance at the time of permit issuance,the permittee shall submit,at least every 6 months unless a more frequent period is specified in the applicable requirement or by the Air Pollution Control Division,progress reports which contain the following: (i) dates for achieving the activities,milestones,or compliance required in the schedule for compliance,and dates when such activities,milestones,or compliance were achieved;and (ii) an explanation of why any dates in the schedule of compliance were not or will not be met,and any preventive or corrective measures adopted. Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 55 g. The permittee shall not knowingly falsify,tamper with,or render inaccurate any monitoring device or method required to be maintained or followed under the terms and conditions of the Operating Permit. 5. Emergency Provisions Regulation No.3,5 CCR 1001-5,Part C, &VILE 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 9I st 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. Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit # 05OPWE28I Page 56 c. The permittee shall pay an APEN fee in accordance with the provisions of C.R.S. § 25-7-114.1(6)for each APEN or revised APEN filed. 9. Fugitive Particulate Emissions Regulation No. 1,5 CCR 1001-3, & III.D.1. The permittee shall employ such control measures and operating procedures as are necessary to minimize fugitive particulate emissions into the atmosphere, in accordance with the provisions of Regulation No. 1, § III.D.1. 10. Inspection and Entry Regulation No.3,5 CCR 1001-5,Part C, &V.C.16.b. Upon presentation of credentials and other documents as may be required by law,the permittee shall allow the Air Pollution Control Division,or any authorized representative,to perform the following: a. enter upon the permittee's premises where an Operating Permit source is located,or emissions-related activity is conducted,or where records must be kept under the terms of the permit; b. have access to, and copy,at reasonable times,any records that must be kept under the conditions of the permit; c. inspect at reasonable times any facilities,equipment(including monitoring and air pollution control equipment), practices,or operations regulated or required under the Operating Permit; d. sample or monitor at reasonable times,for the purposes of assuring compliance with the Operating Permit or applicable requirements,any substances or parameters. 11. Minor Permit Modifications Regulation No. 3, 5 CCR 1001-5,Part C, §§ X. &XI. The permittee shall submit an application for a minor permit modification before making the change requested in the application. The permit shield shall not extend to minor permit modifications. 12. New Source Review Regulation No. 3, 5 CCR 1001-5,Part B 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. Operating Permit 05OPWE281 First Issued: October I, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 57 15. Off-Permit Changes to the Source Regulation No.3,5 CCR 1001-5,Part C, § XII.B. The permittee shall record any off-permit change to the source that causes the emissions of a regulated pollutant subject to an applicable requirement,but not otherwise regulated under the permit,and the emissions resulting from the change, including any other data necessary to show compliance with applicable ambient air quality standards. The permittee shall provide contemporaneous notification to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. The permit shield shall not apply to any off-permit change. 16. Opacity Regulation No. 1,5 CCR 1001-3, §§ I.,II. The permittee shall comply with the opacity emissions limitation set forth in Regulation No. 1, §§ I.-II. 17. Open Burning Regulation No. 9,5 CCR 1001-11 The permittee shall obtain a permit from the Division for any regulated open burning activities in accordance with provisions of Regulation No.9. 18. Ozone Depleting Compounds Regulation No. 15, 5 CCR 1001-17 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: Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT • Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 58 a. Any definition of"prompt"or a specific timeframe for reporting deviations provided in an underlying applicable requirement as identified in this permit;or b. Where the underlying applicable requirement fails to address the time frame for reporting deviations,reports of deviations will be submitted based on the following schedule: (i) For emissions of a hazardous air pollutant or a toxic air pollutant(as identified in the applicable regulation) that continue for more than an hour in excess of permit requirements,the report shall be made within 24 hours of the occurrence; (ii) For emissions of any regulated air pollutant,excluding a hazardous air pollutant or a toxic air pollutant that continue for more than two hours in excess of permit requirements,the report shall be made within 48 hours;and (iii) For all other deviations from permit requirements,the report shall be submitted every six(6)months, except as otherwise specified by the Division in the permit in accordance with paragraph 22.d. below. c. If any of the conditions in paragraphs b.i or b.ii above are met,the source shall notify the Division by telephone (303-692-3155)or facsimile(303-782-0278)based on the timetables listed above. [Explanatory note: Notification by telephone or facsimile must specify that this notification is a deviation report for an Operating Permit.] A written notice,certified consistent with General Condition 2.a.above(Certification Requirements),shall be submitted within 10 working days of the occurrence. All deviations reported under this section shall also be identified in the 6-month report required above. "Prompt reporting"does not constitute an exception to the requirements of"Emergency Provisions" for the purpose of avoiding enforcement actions. 22. Record Keeping and Reporting Requirements Regulation No.3,5 CCR 1001-5,Part A, 6 II.; Part C, &5 V.C.6.,V.C.7. a. Unless otherwise provided in the source specific conditions of this Operating Permit,the permittee shall maintain compliance monitoring records that include the following information: (i) date,place as defined in the Operating Permit,and time of sampling or measurements; (ii) date(s)on which analyses were performed; (iii) the company or entity that performed the analysis; (iv) the analytical techniques or methods used; (v) the results of such analysis;and (vi) the operating conditions at the time of sampling or measurement. b. The permittee shall retain records of all required monitoring data and support information for a period of at least five (5)years from the date of the monitoring sample,measurement,report or application. Support information, for this purpose,includes all calibration and maintenance records and all original strip-chart recordings for continuous monitoring instrumentation,and copies of all reports required by the Operating Permit. With prior approval of the Air Pollution Control Division,the permittee may maintain any of the above records in a computerized form. c. Permittees must retain records of all required monitoring data and support information for the most recent twelve (12)month period,as well as compliance certifications for the past five(5)years on-site at all times. A permittee shall make available for the Air Pollution Control Division's review all other records of required monitoring data and support information required to be retained by the permittee upon 48 hours advance notice by the Division. Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 59 d. The permittee shall submit to the Air Pollution Control Division all reports of any required monitoring at least every six(6)months,unless an applicable requirement,the compliance assurance monitoring rule,or the Division requires submission on a more frequent basis. All instances of deviations from any permit requirements must be clearly identified in such reports. e. The permittee shall file an Air Pollutant Emissions Notice("APEN")prior to constructing,modifying,or altering any facility,process,activity which constitutes a stationary source from which air pollutants are or are to be emitted, unless such source is exempt from the APEN filing requirements of Regulation No. 3,Part A, § II.D. 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(6)(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. Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 60 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 Regulation No.3,5 CCR 1001-5,Part C, & 1II.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 I in Appendix D of this permit. If the permittee chooses to use the "Combined Construction/Operating Permit" application procedures of Regulation No.3,Part C,then the Operating Permit must be received prior to commencing construction of the new or modified source. 27. Special Provisions Concerning the Acid Rain Program Regulation No. 3,5 CCR 1001-5,Part C, &&V.C.1.b.&8 a. Where an applicable requirement of the federal act is more stringent than an applicable requirement of regulations promulgated under Title IV of the federal act,40 Code of Federal Regulations(CFR)Part 72,both provisions shall be incorporated into the permit and shall be federally enforceable. b. Emissions exceeding any allowances that the source lawfully holds under Title IV of the federal act or the regulations promulgated thereunder,40 CFR Part 72,are expressly prohibited. 28. Transfer or Assignment of Ownership Regulation No. 3, 5 CCR 1001-5,Part C, No transfer or assignment of ownership of the Operating Permit source will be effective unless the prospective owner or operator applies to the Air Pollution Control Division on Division-supplied Administrative Permit Amendment forms, for reissuance of the existing Operating Permit. No administrative permit shall be complete until a written agreement containing a specific date for transfer of permit,responsibility,coverage,and liability between the permittee and the prospective owner or operator has been submitted to the Division. 29. Volatile Organic Compounds Regulation No. 7, 5 CCR 1001-9, && III&V. 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 Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Cheyenne Plains Gas Pipeline Company, LLC Colorado Operating Permit Cheyenne Plains Compressor Station Permit# 05OPWE281 Page 61 • 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. 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 05OPWE281 First Issued: October 1, 2007 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 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix A Inspection Information Page 63 APPENDIX A-Inspection Information 1. Directions to Plant: From I-25 take exit 293 through the town of Carr, Colorado to Rockport, Colorado. The Cheyenne Plains Compressor Station is located approximately four(4) miles north of Rockport in Weld County on Highway 85. 2. Safety Equipment Required: Eye Protection Hard Hat Safety Shoes Hearing Protection Fire Retardant Clothing (i.e. NOMEX®) 3. Facility Plot Plan: The attached figure shows the plot plan as submitted on April 20, 2005 with additional information used to support the processing of the Title V renewal permit for the Cheyenne Compressor Station (95OPWE090). 4. List of Insignificant Activities: The following list of insignificant activities was provided by the source to assist in the understanding of the facility layout. Since there is no requirement to update such a list, activities may have changed since the last filing. The asterisk (*) denotes an insignificant activity source category based on the size of the activity, emissions levels from the activity or the production rate of the activity. The owner or operator of individual emission points in insignificant activity source categories marked with an asterisk (*) must maintain sufficient record keeping verifying that the exemption applies. Such records shall be made available for Division review upon request. (Colorado Regulation No. 3, Part C, Section II.E). Insignificant activities and/or sources of emissions identified by the permittee are as follows: Units with emissions less than APEN de minims—criteria pollutants (Reg 3, Part C.II.E.3.b)* Emergency shutdowns (VOC emissions <2 tons/yr) Fugitive VOC emissions from Equipment leaks (VOC emissions <2 tons/yr) Compressor blowdowns (VOC emissions <2 tons/yr) Turbine startups (VOC emissions <2 tons/yr) Fuel (gaseous) burning equipment< 5 mmBtu/hr(Reg 3, Part C.II.E.3.k)* Utility heater, 5 mmBtu/hr Operating Permit 05OPWE28I First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix A Inspection Information Page 64 ai • !....;0)-;11:1 6 I i I• t O zN Figure t Facility Plot Plan ,s1.;11;rii„ 10i o3v `r; Cheyenne Plains Compressor Station ?G�, s,� G ,; iil beg4li.4 Jyl r�%% I. H r v yM ...L...-r,. ��-..71 y y. LJ '/ t 11,,, rG '{•Iii ' i 1 1 ii! ! i I ,.) 1:1 t trrrett7n to i r u 11.dI I t R p jt i'-"tt ;' 111 4 i ;�li_is-,_.i) I . • ...IL ,I..:..:,_. t:,--;Ili :1.;�{I��r- j r; I 1 l I I i :T` '' i II:r I t o :.. 4it 11.; • - I i .4 Iii+ :I a 'II I • .. Y (rN 17 I ". Iii '�..'0.18l_IL. 4, I,,1 ; s , j { i i ; . I i 1 " ;r i II, i j • ,._yr11 y'i I 11 I , . r i r 'i i� I -I. i( I• ' I 1 ,d ••••e•�N.l.( ,I.I. i • I I I.; r i i A A.•.;;;11 • • ;i li j ..I ' is • r yn �. y i t ' L ii 1 {1.'• 1. C fG I ! . ,sse! . i 1 !, k: ,j; i .I I r• , .;l. . .- I yy ., • ~! -III N:a.y I i l Ili ;�.j ` , : R t I , i ;s '. �, +* ii i • • a 1 Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 65 APPENDIX B Reporting Requirements and Definitions with codes ver 2/20/07 Please note that, pursuant to 113(c)(2) of the federal Clean Air Act, any person who knowingly: (A) makes any false material statement, representation, or certification in, or omits material information from, or knowingly alters, conceals, or fails to file or maintain any notice, application, record, report, plan, or other document required pursuant to the Act to be either filed or maintained (whether with respect to the requirements imposed by the Administrator or by a State); (B) fails to notify or report as required under the Act; or (C) falsifies,tampers with, renders inaccurate, or fails to install any monitoring device or method required to be maintained or followed under the Act shall, upon conviction, be punished by a fine pursuant to title 18 of the United States Code, or by imprisonment for not more than 2 years, or both. If a conviction of any person under this paragraph is for a violation committed after a first conviction of such person under this paragraph, the maximum punishment shall be doubled with respect to both the fine and imprisonment. The permittee must comply with all conditions of this operating permit. Any permit noncompliance constitutes a violation of the Act and is grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application. The Part 70 Operating Permit program requires three types of reports to be filed for all permits. All required reports must be certified by a responsible official. Report#1: Monitoring Deviation Report (due at least every six months) For purposes of this operating permit, the Division is requiring that the monitoring reports are due every six months unless otherwise noted in the permit. All instances of deviations from permit monitoring requirements must be clearly identified in such reports. For purposes of this operating permit, monitoring means any condition determined by observation, by data from any monitoring protocol, or by any other monitoring which is required by the permit as well as the recordkeeping associated with that monitoring. This would include, for example, fuel use or process rate monitoring, fuel analyses, and operational or control device parameter monitoring. Report#2: Permit Deviation Report (must be reported "promptly") In addition to the monitoring requirements set forth in the permits as discussed above, each and every requirement of the permit is subject to deviation reporting. The reports must address deviations from permit requirements, including those attributable to malfunctions as defined in this Appendix, the probable cause of Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 66 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. I, Section IV. In addition to the monitoring deviations discussed above, included in the meaning of deviation for the purposes of this operating permit are any of the following: (1) A situation where emissions exceed an emission limitation or standard contained in the permit; (2) A situation where process or control device parameter values demonstrate that an emission limitation or standard contained in the permit has not been met; (3) A situation in which observations or data collected demonstrates noncompliance with an emission limitation or standard or any work practice or operating condition required by the permit; or, (4) A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred. (only if the emission point is subject to CAM) For reporting purposes, the Division has combined the Monitoring Deviation Report with the Permit Deviation Report. All deviations shall be reported using the following codes: 1 = Standard: When the requirement is an emission limit or standard 2 = Process: When the requirement is a production/process limit 3 =Monitor: When the requirement is monitoring 4 =Test: When the requirement is testing 5=Maintenance: When required maintenance is not performed 6 = Record: When the requirement is recordkeeping 7 = Report: When the requirement is reporting 8=CAM: A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred. 9=Other: When the deviation is not covered by any of the above categories Report#3: Compliance Certification (annually, as defined in the permit) Submission of compliance certifications with terms and conditions in the permit, including emission limitations, standards, or work practices, is required not less than annually. Compliance Certifications are intended to state the compliance status of each requirement of the permit over the certification period. They must be based, at a minimum, on the testing and monitoring methods specified in the Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 67 permit that were conducted during the relevant time period. In addition, if the owner or operator knows of other material information (i.e. information beyond required monitoring that has been specifically assessed in relation to how the information potentially affects compliance status), that information must be identified and addressed in the compliance certification. The compliance certification must include the following: • The identification of each term or condition of the permit that is the basis of the certification; • Whether or not the method(s) used by the owner or operator for determining the compliance status with each permit term and condition during the certification period was the method(s) specified in the permit. Such methods and other means shall include, at a minimum, the methods and means required in the permit. If necessary, the owner or operator also shall identify any other material information that must be included in the certification to comply with section 113(c)(2) of the Federal Clean Air Act, which prohibits knowingly making a false certification or omitting material information; • The status of compliance with the terms and conditions of the permit, and whether compliance was continuous or intermittent. The certification shall identify each deviation and take it into account in the compliance certification. Note that not all deviations are considered violations.' • Such other facts as the Division may require, consistent with the applicable requirements to which the source is subject, to determine the compliance status of the source. The Certification shall also identify as possible exceptions to compliance any periods during which compliance is required and in which an excursion or exceedance as defined under 40 CFR Part 64 (the Compliance Assurance Monitoring(CAM) Rule) has occurred. (only for emission points subject to CAM) Note the requirement that the certification shall identify each deviation and take it into account in the compliance certification. Previously submitted deviation reports, including the deviation report submitted at the time of the annual certification, may be referenced in the compliance certification. For example, given the various emissions limitations and monitoring requirements to which a source may be subject, a deviation from one requirement may not be a deviation under another requirement which recognizes an exception and/or special circumstances relating to that same event. Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 68 Startup, Shutdown, Malfunctions and Emergencies Understanding the application of Startup, Shutdown, Malfunctions and Emergency Provisions, is very important in both the deviation reports and the annual compliance certifications. Startup, Shutdown, and Malfunctions Please note that exceedances of some New Source Performance Standards (NSPS) and Maximum Achievable Control Technology (MACT) standards that occur during Startup, Shutdown or Malfunctions may not be considered to be non-compliance since emission limits or standards often do not apply unless specifically stated in the NSPS. Such exceedances must, however, be reported as excess emissions per the NSPS/MACT rules and would still be noted in the deviation report. In regard to compliance certifications, the permittee should be confident of the information related to those deviations when making compliance determinations since they are subject to Division review. The concepts of Startup, Shutdown and Malfunctions also exist for Best Available Control Technology (BACT) sources, but are not applied in the same fashion as for NSPS and MACT sources. Emergency Provisions Under the Emergency provisions of Part 70 certain operational conditions may act as an affirmative defense against enforcement action if they are properly reported. DEFINITIONS Malfunction (NSPS) means any sudden, infrequent, and not reasonably preventable failure of air pollution control equipment, process equipment, or a process to operate in a normal or usual manner. Failures that are caused in part by poor maintenance or careless operation are not malfunctions. Malfunction (SIP) means any sudden and unavoidable failure of air pollution control equipment or process equipment or unintended failure of a process to operate in a normal or usual manner. Failures that are primarily caused by poor maintenance, careless operation, or any other preventable upset condition or preventable equipment breakdown shall not be considered malfunctions. Emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed a technology-based emission limitation under the permit, due to unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by improperly designed equipment, lack of preventative maintenance, careless or improper operation, or operator error. Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 69 Monitoring and Permit Deviation Report- Part I 1. Following is the required format for the Monitoring and Permit Deviation report to be submitted to the Division as set forth in General Condition 21. The Table below must be completed for all equipment or processes for which specific Operating Permit terms exist. 2. Part II of this Appendix B shows the format and information the Division will require for describing periods of monitoring and permit deviations, or malfunction or emergency conditions as indicated in the Table below. One Part II Form must be completed for each Deviation. Previously submitted reports (e.g. EER's or malfunctions) may be referenced and the form need not be filled out in its entirety. FACILITY NAME: Cheyenne Plains Gas Pipeline Company, LLC—Cheyenne Plains Compressor Station OPERATING PERMIT NO: 05OPWE281 REPORTING PERIOD: (see first page of the permit for specific reporting period and dates) Malfunction/Emergenc Deviations noted During Period?' Deviation Code'' y Condition Reported Operating Permit Unit During Period? ID Unit Description YES NO ',Aritin YES NO CP CG-7101 Solar Taurus Natural Gas Fired Turbine, Model No. 70-10302S,Engine Serial No. OCH 10-88166.The turbine is rated at 9,816 hp and 71.42 mmBtu/hr. Package Skid Serial Number TC04639. CP CG-7201 Solar Taurus Natural Gas Fired Turbine, Model No.70-10302S,Engine Serial No. OHL09-B4243.The turbine is rated at 9,816 hp and 71.42 mmBtu/hr.Package Skid Serial Number TC04638. CP CG-7301 Solar Taurus Natural Gas Fired Turbine, Model No. 70- 10302S,Engine Serial No. OCH 10-B0020.The turbine is rated at 9,816 hp and 71.42 mmBtu/hr.Package Skid Serial Number TC05362. H-8701 Heatec,Model No.VHCI-16010-40-G, Serial No.04-074-151,Natural Gas Fired Hot Oil Heater,Rated at 43.79 mmBtu/hr. This heater is part of the amine treatment unit H-8702 Heatec,Model No.VHCI-16010-40-G, Serial No.04-074-152,Natural Gas Fired Hot Oil Heater,Rated at 43.79 mmBtu/hr. This heater is part of the amine treatment unit Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 70 Deviations noted 2 Malfunction/Emergenc During Period?� Deviation Codey Condition Reported During Period? Operating Permit Unit ID Unit Description YES NO YES NO FL-8921 Flare Vent:Emissions from the glycol dehydrator regenerator(still)vent and flash tank and the amine unit flash tank are routed to the flare.The glycol dehydrator and amine unit are each rated at 300 mmSCF/day.The flare is rated at 13.54 mmBtu/hr. ST-8931 Amine Unit Regenerator(CO2)Vent.Amine unit is rated at 300 mmSCF/day. CP EG-6141 Caterpillar,Model No.3516B LE,Serial No. CTW00511,4-Cycle Lean Burn Natural Gas-Fired Internal Combustion Engine,rated at 1557 hp and 10.95 mmBtu/hr.This engine is used to drive an emergency generator. H-8721 Two Maxon,Model Tube-o-Flame,Reboiler Burners Rated at 3.8 MMBtu/hr each(Total of 7.6 MMBtu/hr) General Conditions Insignificant Activities I See previous discussion regarding what is considered to be a deviation. Determination of whether or not a deviation has occurred shall be based on a reasonable inquiry using readily available information. 2 Use the following entries,as appropriate 1 = Standard: When the requirement is an emission limit or standard 2 =Process: When the requirement is a production/process limit 3 =Monitor: When the requirement is monitoring 4=Test: When the requirement is testing 5= Maintenance: When required maintenance is not performed 6 = Record: When the requirement is recordkeeping 7 = Report: When the requirement is reporting 8=CAM: A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred. 9=Other: When the deviation is not covered by any of the above categories Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 71 Monitoring and Permit Deviation Report - Part II FACILITY NAME: Cheyenne Plains Gas Pipeline Company, LLC—Cheyenne Plains Compressor Station OPERATING PERMIT NO: 05OPWE281 REPORTING PERIOD: Is the deviation being claimed as an: Emergency Malfunction N/A (For NSPS/MACT) Did the deviation occur during: Startup Shutdown Malfunction Normal Operation OPERATING PERMIT UNIT IDENTIFICATION: Operating Permit Condition Number Citation Explanation of Period of Deviation Duration (start/stop date &time) Action Taken to Correct the Problem Measures Taken to Prevent a Reoccurrence of the Problem Dates of Malfunctions/Emergencies Reported (if applicable) Deviation Code Division Code QA: SEE EXAMPLE ON THE NEXT PAGE Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 72 EXAMPLE FACILITY NAME: Acme Corp. OPERATING PERMIT NO: 96OPZZXXX REPORTING PERIOD: 1/1/04 - 6/30/06 Is the deviation being claimed as an: Emergency Malfunction XX N/A (For NSPS/MACT) Did the deviation occur during: Startup Shutdown Malfunction Normal Operation OPERATING PERMIT UNIT IDENTIFICATION: Asphalt Plant with a Scrubber for Particulate Control - Unit XXX Operating Permit Condition Number Citation Section II, Condition 3.1 - Opacity Limitation Explanation of Period of Deviation Slurry Line Feed Plugged Duration START- 1730 4/10/06 END- 1800 4/10/06 Action Taken to Correct the Problem Line Blown Out Measures Taken to Prevent Reoccurrence of the Problem Replaced Line Filter Dates of Malfunction/Emergencies Reported (if applicable) 5/30/06 to Alan Smithee, APCD Deviation Code Division Code QA: Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 73 Monitoring and Permit Deviation Report - Part III REPORT CERTIFICATION SOURCE NAME: Cheyenne Plains Gas Pipeline Company, LLC—Cheyenne Plains Compressor Station FACILITY IDENTIFICATION NUMBER: 123/0051 PERMIT NUMBER: 05OPWE281 REPORTING PERIOD: (see first page of the permit for specific reporting period and dates) All information for the Title V Semi-Annual Deviation Reports must be certified by a responsible official as defined in Colorado Regulation No. 3, Part A, Section I.B.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 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix C Compliance Certification Report Page 74 APPENDIX C Required Format for Annual Compliance Certification Reports Following is the format for the Compliance Certification report to be submitted to the Division and the U.S. EPA annually based on the effective date of the permit. The Table below must be completed for all equipment or processes for which specific Operating Permit terms exist. FACILITY NAME: Cheyenne Plains Gas Pipeline Company, LLC—Cheyenne Plains Compressor Station OPERATING PERMIT NO: 05OPWE28l REPORTING PERIOD: I. Facility Status _During the entire reporting period, this source was in compliance with ALL terms and conditions contained in the Permit, each term and condition of which is identified and included by this reference. The method(s) used to determine compliance is/are the method(s) specified in the Permit. With the possible exception of the deviations identified in the table below, this source was in compliance with all terms and conditions contained in the Permit, each term and condition of which is identified and included by this reference, during the entire reporting period. The method used to determine compliance for each term and condition is the method specified in the Permit, unless otherwise indicated and described in the deviation report(s). Note that not all deviations are considered violations. Monitoring Was compliance Operating Deviations Reported' Method per continuous or Permit Unit Unit Description permit?2 Intermittent?' ID Previous I Current YES I NO Continuous I Intermittent CP CG- Solar Taurus Natural Gas Fired 7101 Turbine,Model No.70.103025, Engine Serial No.OCH 10-B8166. The turbine is rated at 9,816 hp and 71.42 mmBtu/hr. Package Skid Serial Number TC04639. CP CG- Solar Taurus Natural Gas Fired 7201 Turbine,Model No.70-10302S, Engine Serial No.OHL09-B4243. The turbine is rated at 9,816 hp and 71.42 mmBtu/hr.Package Skid Serial Number TC04638. CP CG- Solar Taurus Natural Gas Fired 7301 Turbine,Model No.70- 10302S, Engine Serial No.OCHI0-B0020. The turbine is rated at 9,816 hp and 71.42 mmBtu/hr.Package Skid Serial Number TC05362. Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix C Compliance Certification Report Page 75 Monitoring Was compliance Operating Deviations Reported' Method per continuous or Permit Unit Unit Description Permit?2 Intermittent?3 ID Previous I Current YES I NO Continuous I Intermittent H-8701 Heatec,Model No.VHCI-16010- 40-G,Serial No.04-074.151, Natural Gas Fired Hot Oil Heater, Rated at 43.79 mmBtu/hr.This heater is part of the amine treatment unit H-8702 Heatec,Model No.VHC I-16010- 40-G,Serial No.04-074-152, Natural Gas Fired Hot Oil Heater, Rated at 43.79 mmBtu/hr.This heater is part of the amine treatment unit FL-8921 Flare Vent:Emissions from the glycol dehydrator regenerator(still) vent and flash tank and the amine unit flash tank are routed to the flare.The glycol dehydrator and amine unit are each rated at 300 mmSCF/day.The flare is rated at 13.54 mmBtu/hr. ST-8931 Amine Unit Regenerator(CO2) Vent.Amine unit is rated at 300 mmSCF/day. • CP EG- Caterpillar,Model No. 3516B LE, 6141 Serial No.CTW00511,4-Cycle Lean Bum Natural Gas-Fired Internal Combustion Engine,rated at 1557 hp and 10.95 mmBtu/hr. This engine is used to drive an emergency generator. H-8721 Two Maxon,Model Tube-o-Flame, Reboiler Burners Rated at 3.8 MMBtu/hr each(Total of 7.6 MMBtu/hr) General Conditions Insignificant Activities If deviations were noted in a previous deviation report,put an"X"under"previous". If deviations were noted in the current deviation report(i.e.for the last six months of the annual reporting period),put an"X"under"current". Mark both columns if both apply. 2 Note whether the method(s)used to determine the compliance status with each term and condition was the method(s)specified in the permit. If it was not,mark "no"and attach additional information/explanation. 3 Note whether the compliance status with each term and condition provided was continuous or intermittent. "Intermittent Compliance"can mean either that noncompliance has occurred or that the owner or operator has data sufficient to certify compliance only on an intermittent basis. Certification of intermittent compliance therefore does not necessarily mean that any noncompliance has occurred. NOTE: Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix C Compliance Certification Report Page 76 The Periodic Monitoring requirements of the Operating Permit program rule are intended to provide assurance that even in the absence of a continuous system of monitoring the Title V source can demonstrate whether it has operated in continuous compliance for the duration of the reporting period. Therefore,if a source I)conducts all of the monitoring and recordkeeping required in its permit,even if such activities are done periodically and not continuously,and if 2)such monitoring and recordkeeping does not indicate non-compliance,and if 3)the Responsible Official is not aware of any credible evidence that indicates non-compliance,then the Responsible Official can certify that the emission point(s) in question were in continuous compliance during the applicable time period. 4 Compliance status for these sources shall be based on a reasonable inquiry using readily available information. II. Status for Accidental Release Prevention Program: A. This facility is subject is not subject to the provisions of the Accidental Release Prevention Program (Section 112(r) of the Federal Clean Air Act) B. If subject: The facility is is not in compliance with all the requirements of section 112(O. 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 05OPWE28I First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix D Notification Addresses Page 77 APPENDIX D Notification Addresses 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-T U.S. Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver, Colorado 80202-1129 Permit Modifications, Off Permit Changes: Office of Partnerships and Regulatory Assistance Air and Radiation Programs, 8P-AR U.S. Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver, Colorado 80202-1129 Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix E Permit Acronyms Page 78 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 PMio - Particulate Matter Under 10 Microns Operating Permit 05OPWE28I First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix E Permit Acronyms Page 79 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 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix G Appendix G Title Page 80 • APPENDIX F Permit Modifications DATE OF TYPE OF SECTION NUMBER, DESCRIPTION OF REVISION REVISION REVISION CONDITION NUMBER Operating Permit 05OPWE281 First Issued: October 1, 2007 Renewed: DRAFT TECHNICAL REVIEW DOCUMENT For DRAFT RENEWAL/MODIFICATION OF OPERATING PERMIT 05OPWE281 Cheyenne Plains Gas Pipeline Company, LLC — Cheyenne Plains Compressor Station Weld County Source ID 1230051 December 2013 Operating Permit Engineer: Blue Parish Operating Permit Supervisor review: Matthew Burgett Field Services Unit review: Jennifer Mattox I. Purpose This document establishes the basis for decisions made regarding the applicable requirements, emission factors, monitoring plan and compliance status of emission units covered by the renewed Operating Permit for the Cheyenne Plains Compressor Station. The previous Operating Permit for this facility was issued on October 1 , 2007, and expired on October 1, 2012. 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. Following the submittal of the renewal application, the source submitted an application on May 1, 2013 requesting that the permit be modified to allow natural gas consumption for heaters H-8701 and H-8702 to be monitored using the master fuel meter and allocation calculations instead of individual meters on each heater. This document is designed for reference during the review of the proposed permit by the EPA, the public, and other interested parties. The conclusions made in this report are based on information provided in the original application submitted on October 3, 2011, the minor modification application submitted on May 1, 2013, comments on the draft permit submitted on December 18, 2013, previous inspection reports and various email correspondence, as well as telephone conversations with the applicant. Please note that copies of the Technical Review Document for the original permit and any Technical Review Documents associated with subsequent modifications of the original Operating Permit may be found in the Division files as well as on the Division website at www.colorado.qov/cdphe/airTitleV. This narrative is intended only as an adjunct for the reviewer and has no legal standing. Any revisions made to the underlying construction permits associated with this facility made in conjunction with the processing of this operating permit application have been reviewed in accordance with the requirements of Regulation No. 3, Part B, Construction Permits, and have been found to meet all applicable substantive and procedural requirements. This operating permit incorporates and shall be considered to be a combined construction/operating permit for any such revision, and the 123/0051 Page 1 of 17 Cheyenne Plains Gas Pipeline Company, LLC Operating Permit No. 05OPWE281 Technical Review Document—Renewal 1 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. II. Description of Source The facility is a natural gas compression facility as defined under Standard Industrial Classification 4922. This facility is a mainline compressor station. Its main function is to compress and transmit natural gas from the Wyoming area east into Kansas. This is achieved by using three (3) natural gas fired combustion turbines driving natural gas compressors. The facility also includes a CO2 Treatment Plant, which consists of a triethylene glycol dehydrator and amine treatment unit. Emissions from the glycol dehydrator still (regenerator) vent and flash tank and emissions from the amine unit flash tank are routed to a flare to reduce VOC emissions. The amine unit regenerator vent is equipped with a SulfaTreat H2S control system to reduce H2S emissions. There are also two (2) 45 mmBtu/hr natural gas fired heaters associated with the amine unit and an emergency generator that are included in Section II of the permit as significant emission units. The Cheyenne Plains Compressor Station was constructed in 2004 at the site of an existing mainline compressor station (Cheyenne Station), whose main function is to compress and transmit natural gas from Wyoming to the Colorado Front Range area. As such the two facilities are considered a single source for purposes of Prevention of Significant Deterioration (PSD) review requirements and Title V permitting requirements. Equipment associated with the Cheyenne Compressor Station is addressed in a separate Title V operating permit (95OPWE090). The facility is located 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. This facility is located in an area designated attainment for all pollutants'. It is categorized as a major stationary source (Potential to Emit ≥ 250 Tons/Year for NON, CO and VOC). Future modifications at this facility resulting in a significant net emissions increase (see Reg 3, Part D, Sections II.A.26 and 42) for any pollutant as listed in Regulation No. 3, Part D, Section II.A.42 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.42) may result in the application of the PSD review requirements. The summary of emissions that was presented in the Technical Review Document (TRD) for the previous permit issuance has been modified to update potential to emit by adding the Dehydrator Reboiler Burners, which were previously listed as an insignificant activity. All other emissions listed remain unchanged from the previous TRD. Emissions for the Dehydrator Reboiler Burners are based on manufacturer ' This source is located in the portion of Weld County that is not included in the 8-hour ozone control area. 123/0051 Page 2 of 17 Cheyenne Plains Gas Pipeline Company, LLC Operating Permit No. 05OPWE281 Technical Review Document—Renewal 1 emission factors for NOx and CO, and AP-42 Chapter 1.4 (7/1998) for all other pollutants. Potential to emit is shown in the table below: Facility Wide Emissions (95OPWE090 and 05OPWE281) Potential to Emit Pollutant 95OPWE090 05OPWE281 Facility PM1 35.23 11.96 47.19 PM101 35.23 11.96 47.19 SO21 1.33 3.44 4.77 NOx 624.3 112.52 736.82 CO 262.8 158.11 420.91 VOC 291.3 58.37 349.67 HAPs 60.7 14.14 74.8 'Emissions for each emission unit are typically below the APEN de minimis level, so emission limits have generally not been included in the construction permits and/or Title V permit. 05OPWE281 Emissions Potential to Emit Emission Unit PM PM1a SO2 NOx CO VOC HAPs Turbine CP CG-7101 2.1 2.1 1.06 31.6 38.5 11.3 See Table Turbine CP CG-7201 2.1 2.1 1.06 31.6 38.5 11.3 on Turbine CP CG-7301 2.1 2.1 1.06 20.1 20.9 11.3 Page 17 Hot Oil Heater H-8701 1.58 1.58 0.13 8.9 7.3 3.15 Hot Oil Heater H-8701 1.58 1.58 0.13 8.9 7.3 3.15 Flare Vent FL-8921 2.25 2.25 7.0 39.42 5.8 Amine Unit Regenerator(CO2) 11,8 Vent ST-8931 Emergency Generator CP EG- 0.43 1.30 0.37 6141 Dehydrator Reboiler Burners H- 0.25 0.25 3.99 4.89 0.2 8721 TOTAL 11.96 11.96 3.44 112.52 158.11 58.37 14.14 Ill. Applicable Requirements Accidental Release Program — 112(r) Section 112(r) of the Clean Air Act mandates a new federal focus on the prevention of chemical accidents. Sources subject to these provisions must develop and implement 123/0051 Page 3 of 17 Cheyenne Plains Gas Pipeline Company, LLC Operating Permit No. 05OPWE281 Technical Review Document—Renewal 1 risk management programs that include hazard assessment, a prevention program, and an emergency response program. They must prepare and implement a Risk Management Plan (RMP) as specified in the rule. Based on the information provided by the applicant, this facility is not subject to the provisions of the Accidental Release Prevention Program (Section 112(r) of the Federal Clean Air Act). Compliance Assurance Monitoring (CAM) 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. In the technical review document (TRD) for the initial issuance of this permit (issued October 1, 2007), the Division indicated that CAM did not apply to the following emission units/limits: • Engine EG-6141 (emergency generator engine). The engine does not have a control device. • Turbines CG-7101, CG-7201 & CG-7301. Although the turbines are equipped with dry low NOx (DLN) combustion systems to reduce NOx emissions, DLN is considered to be inherent process equipment and is therefore not considered to be a control device as defined in 40 CFR Part 64 § 64.1. • Heaters H-8701 & H-8702. Although the heaters are equipped with low NO, burners (LNB), LNB is considered to be inherent process equipment and is therefore not considered to be a control device as defined in 40 CFR Part 64 § 64.1. • Amine Unit Regenerator CO2 Vent (ST-8931). This unit is routed to a SulfaTreat system to reduce H2S emissions. However, uncontrolled H2S emissions are 19.7 tons per year and are therefore less than the major source level, so CAM does not apply. • Flare Vent (FL-8921) — benzene emissions. The benzene limit associated with this unit is a MACT standard from Subpart HHH, and MACT limits are exempt from CAM as per 40 CFR Part 64 § 64.2(b)(1)(i). • Flare Vent (FL-8921) —VOC emissions. The original TRD determined that the VOC emission limits associated with the flare vent were subject to CAM, but because the post-control limit (5.74 tons per year VOC) is less than the major source threshold (100 tons per year), CAM would not apply until the first renewal of the permit. No changes have occurred to engine EG-6141, Turbines CG-7101, CG-7201, CG- 7301, Heaters H-8701 & H-8702, the CO2 Vent or the Flare Vent that would affect the CAM determinations made above, except as follows: 123/0051 Page 4 of 17 Cheyenne Plains Gas Pipeline Company, LLC Operating Permit No. 05OPWE281 Technical Review Document—Renewal 1 • As part of this first renewal permit, the Division is reconsidering CAM applicability for the Flare Vent VOC emissions limit. Because the initial Title V permit included a continuous compliance determination method for the flare (continuous monitoring for the presence of a flame, as required by 40 CFR Part 63 Subpart HHH), the VOC emission limit is exempt from CAM as per §64.1(b)(1)(vi). There are no other emission units under this permit that use a control device to achieve compliance with an emission limit and have potential pre-control emissions greater than major source levels. Hazardous Air Pollutants (HAPs) Potential to Emit of total HAPs for both the Cheyenne Plains Compressor Station (05OPWE281) and the Cheyenne Station (95OPWE090) combined is above the major source threshold of 25 tpy. 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, 1.6.44). Source Determination With this permit action, the Division revisited the source determination in regards to the natural gas operations in the area surrounding the Cheyenne Plains Compressor Station to verify that the proper pollutant emitting activities are included in this permit as part of the Cheyenne Plains Compressor Station. In an email dated September 6, 2013, the applicant did not identify any other pollutant emitting activities in the vicinity of the Cheyenne Plains Compressor Station that are dependent upon the Cheyenne Plains Compressor Station to maintain operations. The Division considers the current determination for this facility to be accurate, and the proper pollutant emitting activities are included in this permit. 40 CFR 63 Subpart YYYY - National Emission Standards for Hazardous Air Pollutants for Stationary Combustion Turbines Each turbine is considered to be a "new" turbine (commenced construction after January 14, 2003) under Subpart YYYY. However, §63.6095(d) notes that standards for new or reconstructed gas-fired lean premix and diffusion flame turbines are stayed until EPA takes final action to require compliance, and only initial notification requirements apply. An initial notification was submitted for turbines CG-7101 and CG- 7201 on June 15, 2005 and an initial notification was submitted for turbine CG-7301 on April 4, 2006. Therefore, no Subpart YYYY requirements are included in this renewal permit. 123/0051 Page 5 of 17 Cheyenne Plains Gas Pipeline Company, LLC Operating Permit No. 05OPWE281 Technical Review Document—Renewal 1 40 CFR Part 63 Subpart ZZZZ—National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines EG-6141 is a new emergency engine greater than 500 hp located at a major source of HAP. As such, it is exempt from all requirements under Subpart ZZZZ except for initial reporting requirements (§ 63.6590(b)(1)(i)). The initial notification for this unit was submitted on December 13, 2004. On January 30, 2013, EPA published changes to Subpart ZZZZ in the Federal Register as a final rule to include a limit on the number of hours that this type of emergency engine may operate in certain scenarios in order to qualify as an engine subject to limited requirements. Prior to this date, the rule had no time limit on the use of emergency engines for routine testing and maintenance. The Division is modifying the existing permit requirement to track hours of operation so that it also tracks the type of operation in order to qualify as an emergency engine under Subpart Z777. Note that the Subpart ZZZZ requirements for this unit are not currently state enforceable, since the version of Subpart 7777 that is currently adopted into Colorado Reg No. 8 states that new emergency engines are not subject to any requirements except for the submittal of an initial notification. 40 CFR Part 60 Subpart JJJJ—Standards of Performance for Stationary Spark Ignition Internal Combustion Engines Subpart JJJJ applies to stationary spark ignition engines that commenced construction, reconstruction or modification after June 12, 2006 and were manufactured after specific dates. EG-6141 started up in 2004 and has not been reconstructed or modified; Subpart JJJJ does not apply. Colorado Regulation No. 7, Section XVII Requirements for Engines On December 12, 2008, the Colorado Air Quality Control Commission (AQCC) adopted revisions to Colorado Regulation No. 7 to include state-wide requirements for existing (constructed or modified before February 1, 2009) internal combustion engines greater than 500 hp. These requirements are set forth in Reg 7, Section XVII.E.3. Specifically these engines are required to install oxidation catalysts per Section XVII.E.3.b.(i). However, Section XVI1.3.b.(ii) specifies that sources that could demonstrate that the retrofit cost was more than $ 5,000/ton were exempt from the requirements, provided the demonstration was submitted by August 1, 2009. The source requested an exemption from the control requirements from these engines and the Division granted the exemption in a letter dated December 21, 2009, contingent upon engine operation not exceeding 250 hours per year. 40 CFR Part 63 Subpart DDDDD - National Emission Standards for Hazardous Air Pollutants for Maior Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters The previous issuance of the operating permit included a requirement to submit an application under 112(j) (Case-by-Case MACT) for the hot oil heaters by a deadline yet to be determined by EPA. The 112(j) application was required under the MACT Hammer provisions because, at the time, EPA had vacated the Boiler MACT. Since 123/0051 Page 6 of 17 Cheyenne Plains Gas Pipeline Company, LLC Operating Permit No. 05OPWE281 Technical Review Document—Renewal 1 that time, EPA has finalized a major source boiler MACT rule (published in the federal register on January 1, 2013, and effective April 1, 2013) and the 112(j) application is no longer required. The major source boiler MACT defines existing boilers and process heaters as those that have commenced construction or reconstruction on or before June 10, 2010. The two hot oil heaters qualify as an existing affected source in the subcategory: units designed to burn gas 1 fuels. Only work practice standards apply to this subcategory: annual tune ups and an initial energy assessment. The reboiler burners associated with the glycol dehydrator are also considered to be process heaters under the definition of Subpart DDDDD. However, the reboiler burners qualify for exemption from Subpart DDDDD under §63.7491(h): Any boiler or process heater that is part of the affected source subject to another subpart of this part. The reboiler burners are part of the glycol dehydrator, which is an affected source under 40 CFR Subpart HHH. 40 CFR Part 60Subpart GG—Standards of Performance for Stationary Gas Turbines Each of the three turbines included in this permit are subject to Subpart GG (stationary gas turbines with greater than 10 MMBtu/hr that commenced construction, modification or reconstruction after October 3, 1977 and before February 8, 2005. The applicable requirements were included in the initial operating permit (note that some of the Subpart GG requirements were streamlined out in favor of more stringent requirements; see the TRD for the initial operating permit issuance for details). 40 CFR Part 63 Subpart HH—National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities Subpart HH applies to facilities that process, upgrade, or store natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category. This source is in the transmission and storage source category, and is therefore subject to Subpart HHH instead of HH. 40 CFR Part 63 Subpart HHH—National Emission Standards for Hazardous Air Pollutants From Natural Gas Transmission and Storage Facilities The dehydrator is subject to control requirements under Subpart HHH, as described in the TRD for the initial operating permit issuance. The source complies with the option to control to 0.90 Mg/year of benzene (§63.1275(b)(1)(ii)) by routing emissions through a closed vent system to a flare. The applicable HHH requirements were included in the initial operating permit. Since that permit was issued, EPA published revisions to Subpart HHH in the Federal Register on August 16, 2012 as a final rule. Changes in the rule that are applicable to this source are: (1) the addition of a requirement to prepare a site-specific monitoring requirement for the flare, and (2) the replacement of the Startup Shutdown Malfunction (SSM) provisions with the Affirmative Defense Provisions. Note that due to the removal of the SSM provision, the standards now apply at all times and deviations during SSM must be recorded and reported. The updated rule language is included in the renewal permit. 123/0051 Page 7 of 17 Cheyenne Plains Gas Pipeline Company, LLC Operating Permit No. 05OPWE281 Technical Review Document—Renewal 1 Note that the Division also removed Condition 3.9.26.1.a, which required the initial closed vent system inspection and submittal of results in the Notification of Compliance Status (NOCS) report. This was an initial one-time only requirement, and the NOCS was received by the Division on July 28, 2005. Also, the Division removed the requirements from §1283(d)(1)(i)(B), which require averages to be calculated from control device monitoring data. Since the only monitored data is the presence or absence of a flame, the Division considers only §1283(d)(1)(i)(A) to be applicable (the requirement to record each measured value). Colorado Regulation No. 7, Section XVII Requirements for Glycol Dehydrators Colorado Regulation No. 7, Section XVII.D includes state-wide requirements for glycol dehydrators with actual uncontrolled VOC emissions greater than 15 tons per year. However, these requirements do not apply to glycol dehydrators located at natural gas storage facilities. Therefore, Section XVII.D requirements do not apply to the dehydrator at Cheyenne Plains Compressor Station. Subpart LLL—Standards of Performance for SO2 Emissions From Onshore Natural Gas Processing for Which Construction, Reconstruction, or Modification Commenced After January 20, 1984, and on or Before August 23, 2011 The amine unit was previously determined to be an affected unit under this rule, but was exempt from control requirements based on the facility's design capacity. However, the Subpart LLL applies only to onshore natural gas processing plants. Since this facility is not a gas processing plant, the requirement to maintain records demonstrating the exemption under Subpart LLL will be removed from the renewal permit. In previous permitting actions when Subpart LLL was determined to apply, there was no information within Subpart LLL that provided clarification on whether "Onshore Natural Gas Processing" included natural gas processes located at facilities other than natural gas processing plants. When NSPS Subpart OOOO was proposed on August 23, 2011, the preamble for that rule clarified that Subpart LLL was only applicable to natural gas processing plants (reference 76 FR 52741 & 52754). 40 CFR Part 60 Subpart OOOO - Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution Subpart OOOO addresses gas wells, compressors, pneumatic controllers, storage vessels, equipment leaks associated with process units, and some sweetening units. Subpart OOOO applies to affected facilities that commenced construction, modification or reconstruction after August 23, 2011. All equipment at Cheyenne Plains Compressor Station was constructed prior to this applicability date and has not since been reconstructed or modified. Additionally, the following equipment does not qualify as an affected facility under Subpart OOOO, regardless of construction/modification/relocation date for the following reasons: 123/0051 Page 8 of 17 Cheyenne Plains Gas Pipeline Company, LLC Operating Permit No. 05OPWE281 Technical Review Document—Renewal 1 • Compressors are only affected facilities if they are located between the wellhead and the natural gas transmission and storage segment. Since this facility is a natural gas storage facility, all compressors do not qualify as affected facilities. • Pneumatic controllers > 6 scfs are only affected facilities if they are located between the wellhead and the natural gas transmission and storage segment. Other pneumatic controllers are only affected facilities if they are located at a natural gas processing plant. Since this facility is a natural gas storage facility, all pneumatic controllers do not qualify as affected facilities. • Sweetening units (e.g., amine units) are only affected facilities if they are located at natural gas processing plants. Since this facility is not a natural gas processing plant, the amine unit is not an affected facility. • Equipment leaks associated with process units (i.e., fugitive components) are only affected facilities if they are located at natural gas processing plants. Since this facility is not a natural gas processing plant, the amine unit is not an affected facility. • Note that there are no storage vessels associated with this permit, either as permitted emission units or as insignificant activities. 40 CFR Part 60 Subpart KKK - Standards of Performance for Equipment Leaks of VOC From Onshore Natural Gas Processing Plants Subpart KKK does not apply to the Cheyenne Plains Compressor Station because it is not a natural gas processing plant. 40 CFR Part 60 Subpart Kb - Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984 As per § 60.110b(d)(4), Subpart Kb does not apply to vessels with a design capacity less than or equal to 1,589.874 m3 (approximately 10,000 bbl) used for petroleum or condensate stored, processed, or treated prior to custody transfer. There are no such tanks associated with this permit. 40 CFR Part 63 Subpart EEEE — National Emission Standards for Hazardous Air Pollutants: Organic Liquids Distribution (Non-Gasoline) Under §63.2334(c)(2), organic liquid distribution operations do not include activities and equipment at natural gas transmission and storage facilities; therefore, Subpart EEEE requirements do not apply. Portable Monitoring Requirements The previously issued version of the operating permit required quarterly portable monitoring for NO. and CO emissions from the turbines. The requirement used the Division's standard portable monitoring language, except that the following additional language was included: 123/0051 Page 9 of 17 Cheyenne Plains Gas Pipeline Company, LLC Operating Permit No. 05OPWE281 Technical Review Document—Renewal 1 Note that the second to the last paragraph in Condition 5 (apply for a permit modification within 60 days if the portable analyzer test indicates that the emission rates/factors are greater than the emission rates/factors identified in the permit) does not apply to these emission units. This requirement was included because these turbines are subject to BACT limits for NO. and CO, and the emission factors specified in the permit are associated with the original BACT determination. This additional language will also be included in the renewal permit. IV. Emissions from the Amine Unit The previously issued permit included provisions for calculating emissions from the amine unit using the AMINECaIc modeling software. Since the original issuance of the permit, the Division has discovered that this modeling software may under predict emissions by a significant amount. Therefore, the renewal permit will require emission calculations to be performed using ProMax instead. V. Modifications Requested by the Source In their modification application submitted on May 1, 2013, the source requested that the permit be revised to allow natural gas consumption for heaters H-8701 and H- 8702 to be monitored using the master fuel meter and allocation calculations instead of individual meters on each heater. In their application, the source indicated that this modification met the requirements for a minor permit modification and requested that the minor permit modification procedures in Colorado Regulation No. 3, Part C, Section X be used. Colorado Regulation No. 3, Part C, Section X.A identifies those modifications that can be processed under the minor permit modification procedures. Specifically, minor permit modifications "are not otherwise required by the Division to be processed as a significant modification" (Colorado Regulation No. 3, Part C, Section X.A.6). The requested minor modification involves only a change to the method of fuel monitoring. The Division frequently allows fuel monitoring based on a single fuel meter and an allocation procedure and therefore does not consider this to be a significant change to monitoring procedures that would otherwise be disqualified as a minor modification under Part C, Section X. Therefore, the Division determined that this modification can be processed as a minor modification. This minor modification is being incorporated into this renewal permit. The renewal application received on October 3, 2011 requested the following modifications: • Revise the stipulated passing criteria value in Condition 3.5.1 (note this is Condition 3.4.1 in the renewal permit) for the Amine unit. The permit required an AMINECaIc model to be run to determine actual emissions whenever an average monthly monitored value fails the stipulated passing criteria. The permit allowed the use of default emission factors when monitored values meet the stipulated passing criteria. The permit included a stipulated passing criteria 123/0051 Page 10 of 17 Cheyenne Plains Gas Pipeline Company, LLC Operating Permit No. 05OPWE281 Technical Review Document—Renewal 1 of at or above 100 °F for amine unit inlet gas temperature; the applicant requested this value be lowered to 75 °F in the renewal application. The applicant requested this change because the actual inlet gas temperature readings to the amine unit have consistently averaged around 80 °F, and AMINECaIc runs using actual values show VOC and HAP emissions to be consistently low. Note that this modification will no longer be necessary as the renewal permit will now include a requirement to calculate amine emissions using ProMax on a monthly basis using actual monitored values. The stipulated passing criteria for process parameters is no longer included in the permit. Note also that the requirements for running the GLYCaIc model for the dehydrator have been updated to be similar to the structure of the ProMax modeling requirements. • Change the total heat input rate for the two burners associated with the dehydrator reboiler to 7.6 MMBtu/hr. The reboiler was previously specified to be 4.97 MMBtu/hr (for both burners combined), and was therefore listed as an insignificant activity in the permit. To correct the error, the applicant included an APEN for the reboiler with the renewal application. Note that the corrected total rating of the reboiler is still below 10 MMBtu/hr and is therefore still exempt from construction permitting thresholds as per Reg 3, Part B, Section I.D.1.e. The unit no longer qualifies as an insignificant activity, but the only applicable requirements are the opacity requirements of Regulations No. 1 and No. 6, the particulate matter standards of Regulations No. 1 and No. 6, and the requirement to submit an APEN and pay annual fees. The Reg 6 opacity requirements will be streamlined out in favor of the Reg 1 requirements, and the Reg 6 particulate standard will be streamlined out in favor of the Reg 1 standard. This streamlining is done in exactly the same manner as was done for the hot oil heaters under the original permit issuance. Note that the TRD for the original permit issuance includes an extensive discussion of opacity and particulate matter streamlining. Note also that the Division is including the 30% Reg 1 opacity standard only during startup (Section II.A.4). Based on engineering judgment the Division considers that building a new fire, cleaning of fire boxes and soot blowing does not apply to the operation of reboiler burners. In addition, these burners do not have add-on control devices, so adjustment or occasional cleaning of control devices do not apply. Process modifications may apply, however, based on engineering judgment, the Division believes that such activities would be unlikely to occur for longer than six minutes. Therefore, the 30% opacity requirement has been included in the operating permit for startup of this unit. As discussed in Section III, the Boiler MACT Subpart DDDDD requirements do not apply to the reboiler burners. • The applicant requested the removal of Conditions 3.11.6 and 3.11.7 and stated that the performance tests completed in September 2005 satisfied the requirements and therefore they are no longer needed in the permit. 123/0051 Page 11 of 17 Cheyenne Plains Gas Pipeline Company, LLC Operating Permit No. 05OPWE281 Technical Review Document—Renewal 1 Note that Conditions 3.11.6 and 3.11.7 (3.10.6 and 3.10.7 in the renewal permit) are flare requirements under 40 CFR 63 Subpart A related to the minimum heat value of the gas combusted and minimum exit velocity (§§ 63.11(b)(6)(ii) and 63.11(b)(7)(i), respectively). These requirements are not related only to the initial design/construction of the flare; they also specify that the flare be operated/used in accordance with the specified requirements, and so the Division considers these requirements to be ongoing. Instead of removing these requirements, the Division is adding a new condition 3.10.8 which will allow the owner or operator to use data from other existing monitoring requirements to show ongoing compliance with Subpart A requirements for the flare. Specifically, the visible emission observations for the flare will be used to as a method to monitor whether the flare is being operated properly. Additionally, the source should maintain records from the 2005 performance test to specify that the flare was designed and constructed in accordance with the requirements. • The applicant noted that the serial numbers of each of the three turbines be changed to reflect the serial number of the turbine package skid. The Division considers the replacement of an engine within an existing turbine package skid to be an action subject to pre-construction permitting requirements under Regulation No. 3, Part B (and in some cases, Part D), and therefore does not consider the listing of only the package skid serial number to be appropriate. Note that the replacement of certain components are not necessarily subject to permitting action, even if the replacement results in the change of a serial number for the engine (in this situation the owner or operator should submit an APEN with the serial number change and an explanatory cover letter— see PS Memo 98-07B for further details at www.colorado.qov/cdphe/psmemos). The Division will note the package serial numbers in the permit but will not remove the engine serial numbers. The engine serial numbers listed for 7101 and 7301 are being updated in this renewal since the owner or operator replaced the gas generators on these units which resulted in new serial numbers (as specified in a letter to the Division received on December 16, 2010). • The applicant noted that the facility name has changed from Cheyenne Plains Gas Pipeline Company to Cheyenne Plains Gas Pipeline Company, LLC. This name change request was included on the APEN submitted for the glycol reboiler mentioned above, and specified for the entire facility on an APEN received on December 18, 2013. • In addition to the changes noted above, the applicant requested corrections to the directions to the plant (Appendix A of the permit). The applicant notified the Division of a change to permit contact information in a letter dated July 25, 2012. The source submitted comments for the draft permit (received on December 18, 2013) requesting the following additional changes: (1) update the facility contact info, (2) 123/0051 Page 12 of 17 Cheyenne Plains Gas Pipeline Company, LLC Operating Permit No. 05OPWE281 Technical Review Document—Renewal 1 • Include standard AOS language for engine and turbine replacements Note that this facility is a major stationary source for purposes of PSD, and as per Division policy, the permanent replacement provisions of the AOS are not allowed unless the replaced units have emission limits or PTE below PSD significance thresholds. Each turbine already has permit limits below significance thresholds for NON, SO2, VOC, SO2, PM and PM10. The PTE for CO2e for each turbine is also less than the value at which greenhouse gases would be subject to regulation (75,000 tons per year), based on a CO2 emission factor from AP-42 of 110 lb/MMBtu (Table 3.1-2a, 4/2000), a rating of 71.42 MMBtu/hr and 8760 hours/year operation. Therefore, the Division is including the standard language for temporary and permanent replacements under the AOS. The engine driving the emergency generator is not subject to permit limits under Colorado Reg 3, Part B, and is only included in Section II of the permit because of recordkeeping requirements under 40 CFR 63 Subpart 7777. As per Division policy, the permanent replacement provisions of the AOS are not allowed for units that do not have emission limits. Therefore, the Division will only include temporary replacement AOS provisions. • Correct the serial numbers on the turbines and the heat rating for the hot oil heaters and correct other typographical errors • Change the references from ambient temperature to turbine inlet temperature with respect to the alternative low-temperature BACT limits for NON. The manufacturer specification sheet used to establish the alternative limits specifies ambient temperatures, not turbine inlet temperatures. This change will not be included in the renewal; changes to the basis of a BACT limit would require further evaluation of emission increases. • Correct the reference to a "transient pilot" with respect to monitoring hours of operation because the turbines use a variable pilot, not a transient pilot. The source's requested modifications were addressed as follows: Page Following Cover Page • Updated facility contact information Section I — General Activities and Summary • Added the reboiler burners to the list of emission units in Condition 6. • Updated the serial numbers for turbines 7101 and 7201 and added package skid serial numbers for all three turbines in the list of emission units in Condition 6. Corrected hot oil heater ratings. • Added the standard language for turbine replacement AOS (both temporary and permanent) and for engine replacement AOS (temporary only) 123/0051 Page 13 of 17 Cheyenne Plains Gas Pipeline Company, LLC Operating Permit No. 05OPWE281 Technical Review Document—Renewal 1 Section II — Specific Permit Terms • Hot Oil Heater Fuel Monitoring — updated the fuel monitoring requirement to include a calculation for allocating fuel use to each heater. Because the fuel meter monitors the total fuel used by both heaters as well as supplemental fuel feed to the flare, the calculation involves removing the flare consumption from the total, and then allocating the remaining fuel according to hours of operation for each heater (note the heaters have the same size rating). The permit also includes new conditions requiring monitoring the hours of operation for each heater and the amount of fuel used as supplemental feed to the flare; these parameters are required as inputs to the allocation calculation. • Reboiler Burners: added a new condition 6 to address these units. The only applicable requirements are APEN submittals and emission reporting, and Reg 1/6 opacity requirements and Reg 1/6 particulate matter standards (Reg 6 will be streamlined out in favor of Reg 1 for both opacity and PM). • Added Condition 3.10.8 to address compliance monitoring methods for the flare operation requirements of 40 CFR 63 Subpart A • Updated the serial numbers for turbines 7101 and 7201 and added package skid serial numbers for all three turbines. Corrected hot oil heater ratings. • Removed reference to "transient" when referring to the pilot for purposes of monitoring hours of operation for the turbines. Section III — Permit Shield • Added the reboiler burners to the list of streamlined requirements where Reg 6 opacity and particulate matter is streamlined out in favor of Reg 1. Appendices • Appendix A: revised the drive-to directions for the facility. Removed the dehydrator reboiler from the list of insignificant activities. Updated the rating for the utility heater based on correspondence received September 6, 2013. • Appendices B/C: Added the reboiler burners to the reporting formats. Updated the serial numbers for turbines 7101 and 7201 and added package skid serial numbers for all three turbines VI. Other Modifications In addition to the source requested modifications, the Division has included changes to make the permit more consistent with recently issued permits, include comments made by EPA on other Operating Permits, as well as correct errors or omissions identified during inspections and/or discrepancies identified during review of this renewal. These changes are as follows: 123/0051 Page 14 of 17 Cheyenne Plains Gas Pipeline Company, LLC Operating Permit No. 05OPWE281 Technical Review Document—Renewal 1 Page Following Cover Page • It should be noted that the monitoring and compliance periods and report and certification due dates are shown as examples. The appropriate monitoring and compliance periods and report and certification due dates will be filled in after permit issuance and will be based on permit issuance date. Note that the source may request to keep the same monitoring and compliance periods and report and certification due dates as were provided in the original permit. However, it should be noted that with this option, depending on the permit issuance date, the first monitoring period and compliance period may be short (i.e. less than 6 months and less than 1 year). Section I — General Activities and Summary • Revised the language in Condition 1.4 include current conditions that are state- only enforceable. • The applicant submitted APENs on March 20, 2012 to renew the 5-year APEN term. In these APENs, points 015 and 016 (CG-7101 and CG-7201) were grouped on a single APEN and points 018 and 019 (H-8701 and H-702) were grouped on a single APEN. The Division processed these APENs by effectively moving point 016 into point 015 and moving point 019 into point 018. The renewed permit reflects these changes. Section II — Specific Permit Terms • Removed the requirement to submit a 112(j) application for the hot oil heaters and replaced the condition with the applicable requirements of the new major source boiler MACT rule. See Section III for further details. • Updated the Subpart HHH rule to include EPA's latest changes and removed the initial inspection requirement that has been completed. See Section III for further discussion on Subpart HHH rule changes. • Added requirements for the emergency engine related to January 30, 2013 changes to 40 CFR Part 63, Subpart ZZZZ. The source will now track the type of operation as well as the number of hours to monitor the exemption status for emergency engines under the modified federal rule. Added the limitations from the offramp determination for control requirements under Reg 7, Section XVII (the Division granted the offramp provided the engine is operated less than 250 hours per year in a letter dated December 21, 2009). • Updated the portable monitoring condition language to the most current standard version. Section IV— General Permit Conditions • Updated the general permit conditions to the current version (5/22/2012) 123/0051 Page 15 of 17 Cheyenne Plains Gas Pipeline Company, LLC Operating Permit No. 05OPWE281 Technical Review Document—Renewal 1 Appendix A • Updated the insignificant activity list to note that certain categories of equipment are exempt based on the size of the activity, emissions levels from the activity or the production rate of the activity. The owner or operator of must maintain sufficient record keeping verifying that the exemption applies. 123/0051 Page 16 of 17 �a m m O 0 N in el O1 0 .ai t o O O o N O1 O O O -I 0) I— , ) ulalofy O o = a o aa)) -o co co auexaH-u m en - off o O en U c O O O O O .4 o I c Ia�IPIN o 0 0 m O O O 0 a) i- 117_2 w u louey;aw o c o — o N N. N co E dial.tin o a o w o p n. A U a) D aualAX o 0 Ni 0 c d 0 O O O o m 0. a a auanlol o o o o in ID N 0 m U N 7 O O O O _I o M w 7_ CY rq U. H apAgaplewaoi N N o o N 0 N a) tm o O O O o o o `o auazuaglAy;3 O O O 0 m O O O a 0 m c auazuag OOOOr-- 0 0 o 00 rn o N CO o O O O O N O 00 co m N c LU apAgaple;a3y o O O O 0 E d a O O o o a 0 a) in 5 to J — c J co N c co o m ° a a E c c d ro 2 c o U N a' c VI .c O 2 v m y ru a N '≥ O. a) J a ain = O U m a o O r0 •Vl O a) O O N. E O 0a N V) T m C) ❑ — N Cl- N O M w U)• Z r r i r N ' F.U) 3 Co 2 2 c '≥ o �a € 7) < O O d O O cc m N � a0! 2 0 0 2 a) 0 c U 0 o` c c rn— _ _ ro c m m o C C o c C D a) c -o w aft . E a O O z c le a) t Taa, c y o a) a c > - o o a) E - E a o m M U a J f- I- 1 2 ❑ ¢ F W ❑ F c S . N COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION OPERATING PERMIT RENEWAL SUMMARY PERMIT NUMBER: 05OPWE281 AIRS ID#: 1230051 DATE: December 24, 2013 APPLICANT: Cheyenne Plains Gas Pipeline Company, LLC—Cheyenne Plains Compressor Station REVIEW ENGINEER: Blue Parish SOURCE DESCRIPTION Cheyenne Plains Gas Pipeline Company, LLC has applied for renewal of their Operating Permit issued for the Cycenne Plains Compressor Station located in Section 5, T11 N, R66W, north of Rockport in Weld County. The facility is a natural gas compression facility as defined under Standard Industrial Classification 4922. This facility is a mainline compressor station. Its main function is to compress and transmit natural gas from the Wyoming area east into Kansas. This is achieved by using three(3) natural gas fired combustion turbines driving natural gas compressors. The facility also includes a CO2 Treatment Plant,which consists of a triethylene glycol dehydrator and amine treatment unit. Emissions from the glycol dehydrator still (regenerator)vent and flash tank and emissions from the amine unit flash tank are routed to a flare to reduce VOC emissions. The amine unit regenerator vent is equipped with a SulfaTreat H2S control system to reduce H2S emissions. There are also two (2)45 mmBtu/hr natural gas fired heaters associated with the amine unit and an emergency generator. There are two 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. This facility is located in an area designated attainment for all pollutants. It is categorized as a major stationary source (Potential to Emit≥250 Tons/Year for NOx, CO and VOC). Future modifications at this facility resulting in a significant net emissions increase(see Reg 3, Part D, Sections II.A.26 and 42)for any pollutant as listed in Regulation No. 3, Part D, Section II.A.42 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.42) may result in the application of the PSD review requirements. The following Operating Permits are associated with this facility for purposes of determining applicability of Prevention of Significant Deterioration regulations: 95OPWE090 (Cheyenne Compressor Station). 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, Also, 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 Potential to Emit Pollutant 95OPWE090 05OPWE281 Facility PM' 35.23 11.96 47.19 PM101 35.23 11.96 47.19 S021 1.33 3.44 4.77 NOx 624.3 112.52 736.82 CO 262.8 158.11 420.91 VOC 291.3 58.37 349.67 HAPs 60.7 14.14 74.8 'Emissions for each emission unit are typically below the APEN de minimis level, so emission limits have generally not been included in the construction permits and/or Title V permit. 05OPWE281 Emissions Potential to Emit Emission Unit PM PM10 SO2 NO, CO VOC HAPs Turbine CP CG-7101 2.1 2.1 1.06 31.6 38.5 11.3 Turbine CP CG-7201 2.1 2.1 1.06 31.6 38.5 11.3 Turbine CP CG-7301 2.1 2.1 1.06 20.1 20.9 11.3 Hot Oil Heater H-8701 1.58 1.58 0.13 8.9 7.3 3.15 Hot Oil Heater H-8701 1.58 1.58 0.13 8.9 7.3 3.15 Flare Vent FL-8921 2.25 2.25 7.0 39.42 5.8 Amine Unit Regenerator(CO2) 11.8 Vent ST-8931 Emergency Generator CP EG-6141 0.43 1.30 0.37 Dehydrator Reboiler Burners H- 0.25 0.25 3.99 4.89 0.2 8721 TOTAL 11.96 11.96 3.44 112.52 158.11 58.37 14.14 The following discussion identifies the changes that were made in the renewal permit. EMISSION SOURCES • Revised monitoring for the Amine unit to use require PROMAX modeling runs instead of AmineCALC • Corrected the rating of the burners associated with the dehydrator reboiler, removed the burners from the list of insignificant activities and added them to the list of significant emission units, and added the applicable opacity, PM and APEN reporting requirements • Updated the flare monitoring requirements to allow visible emissions monitoring requirements to be used to monitor compliance with 40 CFR Part 63 Subpart A requirements • Updated the monitoring for the hot oil heater fuel use to allow for use of a combined fuel meter • Made minor corrections throughout to serial numbers and unit ratings. • Added requirements for the emergency engine related to January 30, 2013 changes to 40 CFR Part 63, Subpart ZZZZ • Updated the Subpart HHH rule to include EPA's latest changes and removed the initial inspection requirement that has been completed. • Removed the requirement to submit a 112(j) application for the hot oil heaters and replaced the condition with the applicable requirements of the new major source boiler MACT rule ALTERNATIVE OPERATING SCENARIOS (AOS) • Added Division's standard AOS language to allow for temporary and permanent replacement of turbines • Added Division's standard AOS language to allow for temporary replacement of emergency generator engine INSIGNIFICANT ACTIVITIES • Removed the dehydrator reboiler burner from the list and added it as an emission source as described above. PERMIT SHIELD • Added the reboiler burners to the list of streamlined requirements where Reg 6 opacity and particulate matter is streamlined out in favor of Reg 1. Cheyenne Mains Gas Pipeline Company,LLC IBCEIT[1D Two North Nevada Avenue *..� 1 v+' Colorado Springs,W 80903 ' 3 N11 ! 719 473 2300 pcD f September 30, 2011 S. 2t.orV' {1 Via UPS Overnight 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 Plains Compressor Station, #05OPWE281 Dear Ms. Parish: Cheyenne Plains Gas Pipeline Company, L.L.C. (hereinafter referred to as Cheyenne Plains) is submitting the renewal application for the Cheyenne Plains Compressor Station Title V Operating Permit. This renewal application is comprised of the following components: • Cover letter, Title V forms and signed certification • Attachment 1: Regulatory Review • Attachment 2: Updated Glycol Dehydrator APEN and supporting emission calculations • Attachment 3: Greenhouse gas (GHG) emission estimates A federal and state air regulatory review is provided in Attachment 1 of this application. This covers current and proposed air regulatory requirements potentially applicable to this facility and how Cheyenne Plains is complying with those requirements. The following changes are being requested during the Cheyenne Plains Title V renewal period: 1. Revise AMINECaIc inlet gas temperature The inlet gas temperature monitoring parameter to the amine unit needs to be revised. The current inlet gas temperature parameter value in the permit is 100 degrees F and the criteria are specified as "At or Above". Cheyenne Plains would like to revise the inlet gas temperature monitoring parameter to 75 degree F and maintain the criteria as "At or Above". The monthly inlet gas temperature readings to the amine unit seem to consistently average around 80 degrees F and the VOC and HAP emissions are consistently low. Based on the significant amount of data collected to date showing consistently low emissions, it is requested in this renewal application that the inlet gas temperature parametric criteria be lowered to 75 degree F to be more representative of the amine unit's actual operation. 2. Monthly AmineCalc Modeling During our internal reasonable inquiry process as part of this Title V renewal application, it was discovered that some AmineCalc monthly modeling runs had not yet been completed in accordance with Condition 3.5.3 of the permit. These runs have since been completed and are up to date through the end of August 2011. Glycol dehydrator reboiler—change heat rate to 3.8 mmbtulhour each During our internal review as part of the Cheyenne Plains Title V renewal process, it was discovered that the glycol dehydrator reboiler currently is not appropriately represented in the Title V permit. The maximum heat input for the reboiler currently specified in the Title V permit is 4.97 MMBtu/hr (2.485 MMBtu for each burner), and the current Title V permit therefore considers the dehydrator reboiler to be an insignificant contributor to air pollution pursuant to the provisions of Regulation 3, Part CII.E.3.k (fuel burning equipment with design rate s 5 MMBtu/hr.). During the recent site visit and records review, Cheyenne Plains discovered that the actual combined design rate of the two burners is 7.6 MMBtu/hr (3.8 MMBtu/hr for each burner). To correct this error, Cheyenne Plains hereby is submitting as Attachment 2 an Air Pollution Emission Notice (APEN) with supporting emission calculations, and Cheyenne Plains requests that the APEN fee of $152.90 be included as part of the Cheyenne Plains Title V renewal processing fee. Remove flare stack testing requirements Please remove Specific Condition 3.11.6 and 3.11.7. The flare performance tests were completed in September 2005 and these tests are no longer needed in the Cheyenne Plains Title V permit. Serial numbers of three turbines Please note the serial number change request for the following units. These serial numbers are taken off the package skid for each combustion turbine unit at the facility • Revise Serial Number CP CG-7101 to TCO4639 • Revise Serial Number CP CG-7201 to TCO4638 • Revise Serial Number CP CG-7301 to TCO5362 These serial number revisions reflect the Company's understanding that the serial number of the turbine package most accurately identifies the permitted source. Greenhouse Gas Emission Estimates Since GHG is now considered a pollutant under the Clean Air Act, Cheyenne Plains is also providing greenhouse gas (GHG) potential to emit (PTE) emission estimates for combustion sources regulated under 40 CFR 98, Subpart C (Subpart C). The PTE This design heat rate is based on lower heating value (LHV) estimates are based on the methodology specified in the Mandatory GHG Reporting Rule in Subpart C. and maximum annual operation of the combustion sources(i.e.,8,760 hours/year).. The GHG emission estimates are provided in Attachment 3 of this application. Based on the estimated GHG emissions for the combustion sources, the Cheyenne Plains facility would be considered an existing Title V major source of GHG emissions as per the major source thresholds in the Prevention of Significant Deterioration and Title V Greenhouse Gas Tailoring Rule which became effective on August 2, 2010. Cheyenne Plains is complying with the federal applicable GHG Mandatory Reporting Rule requirements. However, since the GHG reporting rule under 40 CFR 98 is currently not included in the definition of applicable requirement under 40 CFR 70.2 and 71.2, it is not listed as a new applicable requirement in this application. Company Name Change The current company name (Cheyenne Plains Gas Pipeline Company) and address also needs to be updated as a minor administrative change within the permit. It is requested that the name and address be changed to the following: Cheyenne Plains Gas Pipeline Company, L.L.C. 2 North Nevada Avenue, Colorado Springs, Colorado 80903 Revise directions to the plant Please revise the directions to the plant in Appendix A with the following driving directions: "From 1-25 take exit 293 through the town of Carr, Colorado to Rockport, CO. The Cheyenne Plains Compressor Station is located approximately four (4) miles north of Rockport in Weld County on Highway 85." Change in permit contact person Please note the change in the permit contact person from Sandra D. Miller to Jim Tangeman. In addition, note the change in the permit contact person's phone number. 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. If you have any additional questions, please contact Jim Tangeman at 719 520-4769. Sincerely, Matthew J. Mask Director, Rocky Mountain Division El Paso Western Pipelines CC: File: \PWED_CIG\COLORADO\Cheyenne)AIR\Title V\Permits and Renewals Dan Schnee, Legal Gary Stuart, Cheyenne Curtis Smith, Cheyenne (Station Files) Barry Schatz, Safety& Sustainability Operating Permit Application FACILITY IDENTIFICATION FORM 2000-100 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name and Name Cheyenne Plains Compressor Station mailing address Street or Route 2 North Nevada Avenue City, State, Zip Colorado Springs, CO 80903 Code 2. Facility location Street Address Section 5,T11N, R66W (No P.O. Box) City, County, Zip Approx.4 miles north of Rockport, Weld County Code 3. Parent corporation Name Cheyenne Plains Gas Pipeline Company, L.L.C. Street or Route 2 North Nevada Avenue City, State, Zip Colorado Springs, CO 80903 Code Country(if not U.S.) 4. Responsible Name Matt Mask official Title Director, Rocky Mountain Division Telephone (719) 329-5637 5. Permit contact person Name James G.Tangeman Title Supervisor,Environmental (If Different than 4) Telephone 719-5204769 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 New I Modified X Renewal 11. Is the facility located in a "nonattainment"area: I I Yes X No If"Yes", check the designated "non-attainment" pollutant(s): I Carbon Monoxide I Ozone I I PM10 I I Other(specify) 12. List all (Federal and State) air pollution permits (including grandfathered units), plan approvals and exemptions issued to this facility. List the number, date and what unit/process is covered by each permit. For a Modified Operating Permit, do not complete this item. Operating Permit#05OPWE281,#03WE0910,#04WE1390,#03WE0913,#03WE0916. • Alternate RIO: Matthew J. Mask, Director, Rocky Mountain Division,719-329-5637 Operating Permit Application TABULATION OF PERMIT APPLICATION FORMS FORM 2000-800 Colorado Department of Health 09-94 Air Pollution Control Division Facility Name:Chevenne Plains Compressor Station Facility Identification Code: CO1230051 1. ADMINISTRATION This application contains the following forms: x Form 2000-100,Facility Identification Fi Form 2000-101,Facility Plot Plan Forms 2000-102,-102A,and-1028,Source and Site Descriptions II. EMISSIONS SOURCE Total Number DESCRIPTION of This Form This application contains the following forms fl Form 2000-200,Stack Identification (one form for each facility boiler,printing I I Form 2000-300,Boiler or Furnace Operation [I Form 2000-301,Storage Tanks I I Form 2000-302,Internal Combustion Engine Form 2000-303,Incineration Ia Form 2000-304,Printing Operations I Form 2000-305,Painting and Coating Operations I1 Form 2000-306,Miscellaneous Processes [1 Form 2000-307,Glycol Dehydration Unit III. AIR POLLUTION CONTROL Total Number SYSTEM of This Form This application contains the following forms: Form 2000-400,Miscellaneous I I Form 2000-401,Condensers II 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 Total Number DEMONSTRATION of This Form This application contains the following forms .. Form 2000-500,Compliance Certification-Monitoring and Reporting (one for each facility boiler,printing operation, Form 2000-501,Continuous Emission Monitoring Form 2000-502,Periodic Emission Monitoring Using Portable Monitors .. Form 2000-503,Control System Parameters or Operation Parameters of a Process i 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 Total Number COMPLIANCE CERTIFICATION of This Form This application contains the following forms Form 2000-600,Emission Unit Hazardous Air Pollutants quantifying emissions,certifying compliance with applicable requirements,and developing a compliance plan I] Form 2000-601,Emission Unit Criteria Air Pollutants Form 2000-602,Facility Hazardous Air Pollutants iJ Form 2000-603,Facility Criteria Air Pollutants Form 2000-604,Applicable Requirements and Status of Emission Unit 1 f Form 2000-605,Permit Shield Protection Identification I Form 2000-606,Emission Unit Compliance Plan-Commitments and Schedule it Form 2000-607,Plant-Wide Applicable Requirements I1 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. X 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): See cover letter accompanying this application . (list all non-complying units) WARNING: Any person who knowingly, as defined in § 18-1-501(6),C.R.S., makes any false material statement, representation, or certification in, or omits material information from this application is guilty of a misdemeanor and may be punished in accordance with the provisions of§ 25-7 122.1, C.R.S. Printed or Typed Name Title: Matt J. Mask Director, Rocky Mountain Division Signature Date Signed ','Y1' rs}� 9/3v/null Operating Permit Application CERTIFICATION FOR STATE-ONLY CONDITIONS FORM 2000-800 Colorado Department of Health 09-94 Air Pollution Control Division Facility OO12y NaName: Cheyenne Plains Compressor Station Facility Identification Code: 1 VI. SIGNATURE OF RESPONSIBLE OFFICIAL - STATE ONLY CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and,based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this application are true,accurate and complete. B. CERTIFICATION OF FACILITY COMPLIANCE STATUS FOR STATE-ONLY CONDITIONS (check one box only) ❑ I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements. X 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): See cover letter accompanying this application . (list all non-complying units) WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false material statement, representation, or certification in, or omits material information from this application is guilty of a _misdemeanor and may be punished in accordance with the provisions of§ 25-7 122.1, C.R.S. Printed or Typed Name Title: Matt J. Mask Director, Rocky Mountain Division Signature: Date Signed SEND ALL MATERIALS TO: COLORADO DEPARTMENT OF HEALTH APCD-SS-B1 4300 CHERRY CREEK DRIVE SOUTH DENVER, CO 80246-1530 Attachment 1 Regulatory Review APPLICABLE REQUIREMENTS The Cheyenne Plains Compressor Station is located in Weld County, Colorado which is designated as an attainment area for all criteria pollutants. The Cheyenne Plains Compressor Station is considered major source for Title V under Regulation 3, Part C for NOx, CO, VOC, and HAPs. Colorado Regulations The State of Colorado has established regulations limiting the amount of PM and SO2 a source may emit to the atmosphere. It has also set opacity limitations. Colorado has adopted and incorporated by reference numerous regulations of Title 40 of the CFR, including New Source Performance Standards (NSPS) (40 CFR Part 60),National Emission Standards for Hazardous Air Pollutants (NESHAPs) (40 CFR Part 61), and National Emission Standards for Hazardous Air Pollutants for Source Categories (MACT Standards) (40 CFR Part 63). Compliance with applicable Colorado Regulations is described here. Regulation No. 1, Section II.A.1 and II.A.4,and Regulation 6 Part B §II.C.2 Visible emissions are limited to 20%opacity during normal operation. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. The specific activities under which the 30% opacity standard applies are: building a new fire, cleaning of fire boxes, soot blowing, startup, any process modification, or adjustment or occasional cleaning of control equipment. Building a new fire, cleaning of fire boxes and soot-blowing activities are not conducted at the facility. In addition, turbines at the facility do not have add-on control devices, so adjustment or occasional cleaning of control devices do not apply to these turbines. Process modifications may apply to the turbines,however, such activities would be unlikely to occur for longer than six minutes.Therefore, the 30%opacity requirement would apply for startup of these units. Compliance is presumed based on the sole use of natural gas as fuel. Regulation No. 1, Section II.C Open burning is prohibited without a permit. Open burning activities are not conducted at the facility. Regulation No. 1, Section III.A and Regulation 6, Part B Per Regulation 1, Section III.A, for fuel burning equipment with designed heat inputs greater than lx106 BTU per hour, but less than or equal to 500 x 106 British thermal units (Btu)per hour, the following equation will be used to determine the allowable particulate emission limitation. PE=0.5(FI)-o.26 Where: PE=Particulate Emission in pounds per million British thermal units (Ib/MMBtu)heat input. Fl = Fuel Input in MMBtu/hr. Regulation 6, Part B limits particulate emissions for fuel burning equipment to <0.5 MMBtu/hr for equipment less than 1 MMBtu/hr. For equipment constructed, reconstructed, or modified after January 30, 1979, emissions of particulate matter are limited emission rate calculated using the equation above. Compliance with these limitations is presumed since only pipeline quality natural gas is permitted to be used as fuel. Regulation No. 1, §VI.B.2. This regulation limits sulfur dioxide emissions from new combustion turbine<250 MMBtu/hr (constructed or modified after August 11, 1977)to 0.8 lb S02/MMBtu. SO2 limits for sources other than combustion turbines constructed or modified after August 11, 1977 to 2 tons per day. The averaging time for all new source emissions standards for SO2 shall be three hours,and any three-hour rolling average of emission rates which exceeds these standards is a violation of this regulation. Compliance with these limitations is presumed since only pipeline quality natural gas is permitted to be used as fuel. Regulation No. 2 Section 1 Emissions of detectable odorous air contaminants must be minimized. Cheyenne Plains does not anticipate that activities at this facility are significant sources of odorous air emissions. Regulation 3, Part A, Section 2.A Air Pollutant Emission Notices(APENs)are required prior to any construction, modification, or alteration of the facility for any source with uncontrolled actual emissions of greater than or equal to 2 tons per year(tpy)of any criteria pollutant in an attainment area, or greater than the deminimis level of HAPs. This application includes an APEN for the glycol dehydrator reboiler, which was initially indicated as APEN exempt. APEN renewals are submitted every 5 years as required. Regulation 3, Part A, Section VI.C Annual emission fees are required to be paid within 60 days of receipt of the invoice from CDPHE. Annual fees are paid for this facility as required. Regulation 6, Part A This regulation generally adopts New Source Performance Standards (NSPS) contained in 40 CFR Part 60 by reference. The applicability of individual NSPS is discussed in the next section on Federal Regulations. Regulation 8, Part E This regulation generally adopts 40 CFR 63 (National Emission Standards for Hazardous Air Pollutants, or NESHAP for source categories)by reference. The applicability of individual NSPS is discussed in the next section on Federal Regulations. Federal Regulations STANDARDS OF PERFORMANCE FOR NEW STATIONARY SOURCES (NSPS) 40 CFR 60 Subpart GG The turbines are subject to Standards of performance for Stationary Gas Turbines, including, but not limited to the following : • NOx limits shall not exceed 189.5 ppmvd at 15% O2 and ISO conditions • SO2 emissions not to exceed 150 ppmvd at 15% O2 or sulfur content offuel not to exceed 0.8 % by weight(§ 60.333(a) and (b)) The NOx BACT limits imposed by the permit are more stringent than the NSPS limit; compliance with these limits is presumed. Compliance with the SO2 limit is demonstrated by maintaining a copy of the FERC tariff at the facility: 40 CFR 60 Subpart OOOO Please note that NSPS Subpart OOOO addressing volatile organic compound(VOC) and sulfur dioxide emissions from natural gas processing plants will be reviewed for applicability upon final issuance by the EPA for the Cheyenne Plains Gas Pipeline Station. National Emission Standards for Hazardous Air Pollutants (NESHAP) 40 CFR 63 Subpart HUH The glycol dehydration unit is subject to NESHAPs for Source Category: Natural Gas Transmission and Storage, 40 CFR. Part 63, Subparts HHH. 40 CFR 63 Subpart DDDDD The effective date of the NSPS Subpart DDDDD Boilers and Process Heaters MACT has been stayed by the EPA. Upon the expiration for the stay the affected boilers and process heaters at the facility will follow the recommended tune-up requirements per the regulation. 40 CFR 63 Subpart YYYY The final rule for combustion turbines was signed on August 29, 2003 and was published in the Federal Register on March 5, 2004. The turbines are considered "new"turbines (commenced construction after January 14, 2003) and are subject to the MACT. However, in the August 18, 2004 version of the Federal Register, the EPA issued a stay for gas-fired lean premix and diffusion flame turbines. Therefore, the "new"turbines at this facility are only subject to the initial notification requirements and need not comply with any other requirement of 40 CFR Part 63 Subpart YYYY until EPA takes final action to require compliance and publishes a document in the Federal Register. An initial notification was submitted for turbines CG-7101 and CG-7201 on June 15, 2005 and an initial notification was submitted for turbine CG-7301 on April 14, 2006. 40 CFR 63 Subpart ZZZZ The emergency generator is the only engine, associated with the Cheyenne Plains equipment subject to the RICE MACT. This unit is subject to the maintenance plan requirement with an effective date in October, 2013. Cheyenne Plains will comply with this requirement upon its effective date if the emergency generator is still in place at the facility. 40 CFR 63 Subpart EEEE Subpart EEEE (Organic liquids distribution -non-gasoline) applies to major sources of HAP that own or operate an organic liquid distribution facility except those at oil and natural gas transmission facilities(as defined in Subpart HH) or natural gas transmission and storage facilities (as defined in Subpart HHH). The Cheyenne Plains facility is subject to Subpart HHH, therefore,this NESHAPS does no t apply. 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W F •5 iG c . 0 0O Q W to ❑ ❑ 0 ❑ W (nh _ vy _ _ en en Dehydrator Reboiler Emissions Calculations Cheyenne Plains Compressor Ratio Fuel Usage: Heat Input: 7.6 MMBtu/hr 2 fire tubes @ 3.8 MMBtu/hr each Fuel Heat Value(LHV): 925 Btu/scf Nominal Hourly Fuel Usage: 8216.2 scf/hr Heat Input/Fuel LHV Annual Fuel Usage: 72.0 MMscf/yr Assumes 8760 hrs/yr operation Emission Calculations(Criteria Pollutants) AnrielearriirMP-741.Wit. WI"Wan PM 7.6 lb/MMscf AP-42 Table 1.4-2(7/98)' 0.062 0.27 502 0.6 lb/MMscf AP-42 Table 1.4-2(7/98) 0.005 0.02 NOx 0.12 lb/MMBtu Mfg.Information" 0.91 3.99 CO 0.147 Ib/MMBtu Mfg.Information" 1.12 4.89 VOC 5.5 lb/MMscf AP-42 Table 1.4-2(7/98) 0.045 0.20 'All Particulate emisslonsare assumed to be less than 2.5 microns In diameter(i.e.,PM2.5) "Based on emission estimate provided by Maxon(manufacturer of the fire tube burners) Emission Calculations(Hazardous Air Pollutants) o <l)2(�r '��,' ., - rl Kr. 7 '"' E',t Benzene 2.10E-03 lb/MMscf AP-42 Table 1.4-3(7/98) 0.000 0.151 0.0001 A 50 No Formaldehyde 7.50E-02 lb/MMscf AP-42 Table 1.4-3(7/98) 0.001 5.398 0.0027 A 50 No n-Hexane 1.80E+00 lb/MMscf _AP-42 Table 1.4-3(7/98) 0.015 129.553 0.0648 C 1000 No Toluene 3.40E-03 lb/MMscf AP-42 Table 1.4-3(7/98) 0.000 0.245 0.0001 C 1000 No Attachment 3 Greenhouse Gas Emission Estimates 5R.4g5§t§ i' 1= ,.� ,...,;.., § 8 !\§)'414"7"5 ■1 b |;^'4'4§14;. ! ||!■;| " d . p: !\\§!!!!s| 191$$,,, |§§§!!!!! 1111!,!;!| | ` 1` ||, � /\\ / ;;||||m |r l;MMMM"4`■ |# « Si {g 1.,,,..., . i| |,.,:„:: | ! ' - , ( |! |!|;/i!°�5 | |l |Z!!;|!!;! { 1 ' . : ! . .1 bill i 'ri ! 8252! 62 4 q/ / i { | f !!!.! 11 ! , i | ! 1 iI1H* ! | ! ° ' ` ° . i !§§ | ! . §) I!Ye 21 ,!{ }()|)E § A IOWA 4 , \\ I ! \ }\jj§ §§I § ;fig\ I �\ i I i v �0� i\pi )� r `'-1/ 5 OC o1 �z� w 1 �` i i i i i ��.�� ill STATE OF COLORADO Bill Ritter,Jr.,Governor pp cdzo Ned Calonge, M.D.,Interim Executive Director {xrxQ.To,, Dedicated to protecting and improving the health and environment of the people of Colorado \.�, "(C(''"--''`.jj�J o; 4300 Cherry Creek Dr.S. Laboratory Services Division "�:/1 Denver,Colorado 80246-1530 8100 Lowry Blvd. *ism Phone(303)692-2000 Denver,Colorado 80230-6928 TDD Line(303)691-7700 (303)692-3090 Colorado Department Located in Glendale,Colorado of Public Health http://www.cdphe.state.co,us and Environment December 21, 2009 Mr. Vincent Brindley El Paso Pipeline Corporation PO Box 1087 Colorado Springs, CO 80944 Re: El Paso Pipeline Reciprocating Internal Combustion Engines at Cheyenne Plains Compressor Station- Request for Exemption under Regulation No. 7, Section XVII.E.3 Dear Mr. Brindley: • The Air Pollution Control Division (the Division) has reviewed your letter dated July 30, 2009 and subsequent email dated December 7, 2009 concerning your request for an exemption from the volatile organic compounds (VOC) control requirements of Regulation No. 7, Section XVII for a number of natural gas-fired lean-burn Reciprocating Internal Combustion Engines (RICE) providing gas compression. The exemption request indicates that all thirty-nine (39) RICE are lean-burn technology, thus Regulation No. 7, Section XVII.E.3.b applies and states the following: XVII.E.3.b. Lean Burn Reciprocating Internal Combustion Engines XVII.E.3.b.(i) Except as provided in Section XVII.E.3.b.(ii), all lean burn reciprocating internal combustion engines with a manufacturer's nameplate'design rate greater than 500 horsepower shall install and operate an oxidation catalyst by July 1, 2010. A lean burn reciprocating internal combustion engine is one with a normal exhaust oxygen concentration of 2% by volume, or greater. XVII.E.3.b.(ii)Any lean burn reciprocating internal combustion engine constructed or modified before February 1, 2009, for which the owner or operator demonstrates 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 (this value shall be adjusted for future applications according to the current day consumer price index) is exempt complying with Section XVII.E.3.b.(i). Installation costs and the best information available for determining control efficiency shall be considered in determining such costs. In order to qualify for such exemption, the owner or operator must submit an application making such a demonstration, together with all supporting documents, to the Division by August 1, 2009. In the exemption request demonstration, El Paso provided cost analysis, along with supplier quotes, indicating that all thirty-nine (39) engines exceeded the $5,000 control cost threshold. _ Cheyenne Mains Gas Pipeline Company,LLC CN 5 Two North Nevada Avenue ,v Colorado Springs,CO 80903 IS �6 719.473.2300 December 15, 2010 S'Irt Via UPS- Overnight Mr. Jim King Colorado Department of Public Health and Environment Air Pollution Control Division Operating Permits Unit, APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Cheyenne Plains Compressor Station Units CP CG-7101 and CP CG-7301, Gas Generator Exchanges. (Operating Permit# 05OPWE281) Dear Mr. King: The gas generator on the units on Cheyenne Plains Units CP CG-7101 and CP CG-7301 were replaced as part of Cheyenne Plain's (CHP) routine repair and maintenance program. This replacement was a like kind exchange. The replacement gas generator units have the same emission levels as the units they replaced. The changeout will result in no net emissions increase. The serial number for the new gas generator on unit CP CG-7101 is #OCH-10-68166; the old unit had serial # 0251 B. The serial number for the new gas generator on unit CP CG-7301 is #OCH-10-B0020; the old unit had serial # 0286B. CHP is requesting that the serial numbers be updated on the Title V permit. To verify that the new gas generators meet permitted emission limits CHP performed portable emission tests on the units. Both units meet permitted emission limits. Copies of the test results are attached for your review. If you have any questions about the gas generator exchange you can contact me at (719) 329-5641. Sincerely, —B anniSclak Barry Schatz Principal Environmental Scientist Pipelines West- Environmental CC: S.D. Miller/ File: ENVS: CO — Cheyenne Plains — Title V V.L. Brindley J.B. Christian A el paso COLORADO INTERSTATE GAS CO. Portable Emissions Testing Form July 1 to Sept 30, 2010 Cheyenne Plains 05OPWE281 cc 1 C` CG -1I0 Mike Meyer 17-Aug-10 17-Aug-10 17-Aug-10 BARO.PRESS.("Hg): 24.12 10:33 AM 10:43 AM 10:54 AM ENGINE LOAD(BHP): 6024 ECOM J2KN SIN: 1277 FUEL USE(SCFH): 60,339 j: 90 91 91 HEAT VALUE(BTU/SCF): 966 3.5 I AVERAGE HP: 6024 GAS ANALYZER CALIBRATION DATA Repent. flue . , I I • ,... ' Interference Checks (natant 0.0 0.0 0.0 , 1.00 O210.1 10.2 • 20.9 21.0 21.0 1.00 0 0 0 ' 1.00 140 25 25.9 CO.. m..:.. .,, I 50.5 50.5 50.6 0 1.00 0 0 0 1.00 N O2 mi..,,26.5 25 ` NO'VP CO ppm-,. 50.3 50.3 50.2 0.2 0 130 0 0 0 � i - 130 CO 25.4 25 50.3 50 49 1.00 EMISSION MEASUREMENT DATA 1 I .1 02% 15.92 a43 NO ppm 3.13 ,iib NO2 ppm NOx ppm @ 15%02 5 24.5 NOx lbs/mmBTU 0.02 0.098 NO„TPY 4.52 31.6 CO ppm @ 15%02 2 48.8 COIbsImmBTU o.00 0.12 ICO TPY 1.07 38.5 FUEL DATA 6t`C MSCF/D 1448.14 MSCFMR 60,339 CF/HP/FIR 10.02 BTUMP/HR 9673 Form A Linearity Check Data Sheet npany: Cheyenne Plains Facility: Cheyenne Plains Date: August 17, 2010 Source Tested: CG 1 Analyst: Mike Meyer Analyzer Manufacture/Model#: ECOM J2KN Analyzer Serial#: 1277 LINEARITY CHECK Calibration Gas Analyzer Analyzer Analyzer Analyzer Absolute Percent Linearity Concentration Response Response Response Response Difference of Valid Pollutant (Indicate Unit) ppm NO ppm NO2 ppm CO %Or (Indicate Unit) Span (Yes or No) Zero 0 ppm 0 l , 0 ppm 0.00% YES NO Mid 25 p• 25.9 i 0.9 ppm 1.78% YES Span 50.5 ppm 50.5 0 0 ppm 0.00% YES Zero 0 ppm 0 0 ppm 0.00% YES NO2 Mid 26.5 ppm 25 1.5 ppm 2.98°/ YES Qf� 50.3 ppm 0.2 50.3 0 0 ppm 0.00% YES Zero 0 ppm i 0 0 ppm 0.00% YES CO Mid 25.4 ppm 25 0.4 ppm 0.80% YES Span 50.3 ppm 50 _ 0.3 ppm 0.60% YES I Zero 0.0 % 0 0 % 0.00% YES �f Mid 10.1 % 10.2 0.1 % 0.48% YES O2 Span 20.9 % _.. i , . _, 21 0.1 % 0.48% YES Form B Stability Check Data Sheet Date: August 17, 2010 Facility: Cheyenne Plains Analyst: Mike Meyer Source Tested: CG 1 Analyzer Manufacture/Model#: ECOM J2KN Analyzer Serial#: 1277 Pollutant: NO Span Gas Concentration (ppm): 50.5 STABILITY CHECK Elapsed Elapsed Elapsed Time Analyzer Time Analyzer Time Analyzer (Minutes) Response (Continued) Response (Continued) Response 0 0 16 51.2 32 1 48.3 17 51.2 33 2 49.2 18 51.2 34 3 49.5 19 51.3 35 4 49.8 20 51.3 36 5 50.6 21 51.3 37 6 50.7 22 38 7 50.8 23 39 8 50.8 24 40 9 50.9 25 41 10 51 26 42 11 51 27 43 12 51.1 28 44 13 51.1 29 45 14 51.1 30 46 15 51.1 31 47 For 30-minute Stability Check Period: Maximun Concentration (ppm): 51.3 Minimum Concentration (ppm): 50.6 For 15-minute Stability Check Period: Maximun Concentration (ppm): 51.3 Minimum Concentration (ppm): 50.6 Maximum Deviation = 100*(Max. Conc. -Min.Conc.)/Span Gas Conc. = 1.4% percent Stability Time(minutes): 15 Form B Stability Check Data Sheet Date: August 17, 2010 Facility: Cheyenne Plains Analyst: Mike Meyer Source Tested: CG 1 Analyzer Manufacture/Model#: ECOM J2KN Analyzer Serial#: 1277 Pollutant: NO, Span Gas Concentration(ppm): 50.3 STABILITY CHECK Elapsed Elapsed Elapsed Elapsed Time Analyzer Time Analyzer Time Analyzer Time Analyzer (Minutes) Response (Continued) Response (Continued) Response (Continued) Response 0 0 16 52.7 32 54.4 48 55.3 1 38.6 17 52.9 33 54.5 49 55.4 2 42.4 18 53 34 54.5 50 55.5 3 43.8 19 53.2 35 54.6 51 55.5 4 44.6 20 53.3 36 54.7 52 55.5 5 0 21 53.4 37 54.7 53 55.6 6 50.7 22 53.5 38 54.8 54 55.6 7 51 23 53.5 39 54.8 55 55.6 8 51.3 24 53.7 40 54.9 56 55.7 9 51.5 25 53.8 41 55 57 55.7 10 51.6 26 53.9 42 55 58 55.8 11 51.9 27 54 43 55.1 59 55.8 12 52.1 28 54 44 55.1 60 55.8 13 52.3 29 54.2 45 55.1 61 55.8 14 52.4 30 54.2 46 55.2 62 15 52.6 31 54.3 47 55.3 63 For 30-minute Stability Check Period: Maximun Concentration(ppm): 55.8 Minimum Concentration(ppm): 54.3 For 15-minute Stability Check Period: Maximun Concentration(ppm): 55.8 Minimum Concentration(ppm): 54.3 Maximum Deviation=100*(Max.Conc. -Min. Conc.)/Span Gas Conc.= 3.0% percent Stability Time(minutes): 30 Form B Stability Check Data Sheet Date: August 17, 2010 Facility: Cheyenne Plains Analyst: Mike Meyer Source Tested: CG 1 Analyzer Manufacture/Model#: ECOM J2KN Analyzer Serial#: 1277 Pollutant: CO Span Gas Concentration (ppm): 50.3 STABILITY CHECK Elapsed Elapsed Elapsed Time Analyzer Time Analyzer Time Analyzer (Minutes) Response (Continued) Response (Continued) Response 0 0 16 50 32 1 55 17 50 33 2 56 18 50 34 3 57 19 50 35 4 58 20 50 36 5 50 21 50 37 6 50 22 38 7 50 23 39 8 50 24 40 9 50 25 41 10 50 26 42 11 49 27 43 12 50 28 44 13 50 29 45 14 50 30 46 15 50 31 47 For 30-minute Stability Check Period: Maximun Concentration (ppm): 50 Minimum Concentration (ppm): 49 For 15-minute Stability Check Period: Maximun Concentration (ppm): 50 Minimum Concentration (ppm): 49 Maximum Deviation = 100* (Max. Conc. -Min. Conc.)/Span Gas Conc.= 2.0% percent Stability Time (minutes): 15 Form C Calibration Error Check Data Sheet Company: Cheyenne Plains Facility: Cheyenne Plains Source Tested: CG 1 Date: August 17, 2010 Analyst: Mike Meyer Analyzer Manufacturer/Model#: ECOM J2KN Analyzer Serial#: 1277 PRETEST CALIBRATION ERROR CHECK A B [A-B] [A-B]/SGa100 Pump Flow Analyzer Calibration Gas Absolute Precent Calibration Reponse Rate Reading Concentration Difference of Valid Time (Indicate Units) (Indicate Units) (Indicate Units) (Indicate Units) Span (Yes/No) (Minutes) Zero 3.51/min 0 ppm 0 ppm 0 ppm 0.00% YES 1.00 NO Span 3.51/min 50.5 ppm 50.5 ppm 0 ppm 0.00% YES 1.00 Zero 3.51/min 0 ppm 0 ppm 0 ppm 0.00% YES 1.00 NO2 Span 3.51/min 50.3 ppm 50.3 ppm 0 ppm 0.00% YES 1.50 Zero 3.51/min 0 ppm 0 ppm 0 ppm 0.00% YES 1.00 CO Span 3.51/min 50 ppm 50.3 ppm 0.3 ppm 0.60% YES 1.00 Zero 3.5 1/min 0 % 0% 0 % 0.00% YES 1.00 O2 Span 3.511min 21 % 21 % 0.1 % 0.48% YES 1.00 1 Pretest Calibration NO Cell Temperature(°F): I 90 SG = Span Gas POST TEST CALIBRATION ERROR CHECK A B [A-B] [A-B]/SG"100 Interference Check Average of Pump Pre It Post NO CO Flow Analyzer Calibration Gas Absolute Precent Calibration Test Analyzer Monitor Monitor Rate Reading Concentration Difference of Valid Readings Response Response (indicate Units) (Indicate Units) (Indicate Units) (Indicate Units) Span (Yes/No) (Indicate Units) (ppm) (ppm) Zero 3.51/min 0 ppm 0 ppm 0 ppm 0.00% YES 0 NO Span 3.51/min 50.6 ppm 50.5 ppm 0.1 ppm 0.20% YES - 50.55 L 0 Zero 3.51/min 0 ppm 0 ppm 0 ppm 0.00% YES- 0 NO2 Span 3.51/min 50.2 ppm 50.3 ppm 0.1 ppm 0.20% YES 50.25 0.2 0 Zero 3.5 Ilmin 0 ppm 0 ppm 0 ppm 0.00% YES 0 CO Span 3.51/min 49 ppm 50.3 ppm 1.3 ppm 2.58% YES 49.5 ( Zero 3.5 I/min 0 % 0 % 0 % 0.00% YES 0 I + O2 Span 3.51/min 21 % 20.9 % 0.1 % 048% YES 21 Postest Calibration NO Cell Temperature(°F) 91 CO Interference Response(Ico%); 0.00% NO Interference Response(INo%): 0.09% SG = Span Gas Form D - 2 Combustion Turbine Test Results Company: Cheyenne Plains Facility:Cheyenne Plains Source Tested: CO 1 Date:August 17,2010 Source Manufacturer/Model It: Solar I 70.10302S Site Rated Horsepower: 9616 Source Serial It:0251B Type of Emission Control: SOLOND5 Analyst: Mike Meyer Analyzer Manufacturer/Model#: ECOM J2KN Analyzer Serial#: 1277 OPeratino Conditions: Source operating at 90%of greater of site-rated horsepower during testi Yesio NO Suction/ Engine Specific Discharge Turbine Ts Engine Gas Engine Fuel Fuel Heat Fuel Pressures Temperature Engine, Throughput Consumption Content Consumption Engine Tested (Indicate units) (5F) RPM (Indicate Units) Indicate units)- (mulct) Igtump-hrl' Horsepower 840 I 1324 1351 1123480 264.00 mmscfld 60,339 msmhr 966 9673 6024 'As reported by the Manufacture Test Results Test Stan Time: 10:33:00 AM NO Cell Temperature PF)after Its leg.,]minutes)of the test: 90°F Test End Time: 10:54:00 AM NO Cell Temperature l'F)after 2/3(e.g.,14 minutes)of the test: 91 °F NOX(NO+NO2 Average Average Tested NO conned Tested NO2, red NOsconeaed Tested Tested Tested ppm Allowable Allowable Allowable NO ppm PPm NO2 PPm PPm ppm gm/hp-hr TPY l@us O2) gmlhp-hr TPY PPm @10502 3 3 1 1 4 0.018 4.52 5 0.098 31.60 24.5 02 CO Average Average Tested 02 corrected Tested CO corrected Tested Tested Tested ppm Allowable Allowable Allowable Or% % CO ppm ppm gmlhp-hr TPV 1@15X021 gmlhp-hr TPY ppm @15%0, 15.92 15.84 2 2 0.004 1.07 2 0.119 38.50 48.8 I certify to the best or my knowledge the test results are accurate and representative of the emissions from this source.e Mike D Meyer Print Name Signature A el paso COLORADO INTERSTATE GAS CO. Portable Emissions Testing Form July 1 to Sept 30,2010 Cheyenne Plains �.:J�t,,_; 05OPWE2B1 cc 3 CP 4.4-730 •a,: 1 ,, Mike Meyer 17-Aug-10 17-Aug-10 17-Aug-10 BARO.PRESS.("119): 24.07 12:31am 12:42am 12:52am ENGINE LOAD(BHP): 6353 ECOM J2KN SIN: 1277 FUEL USE(SCFH): 78,339 98 97 98 HEAT VALUE(BTU/SCF): 966 35 I AVERAGE HP: 6353 GAS ANALYZER CALIBRATION DATA Reponse 4 +ii;'. ''.+. Interference Checks",C (Mlnptes) 0.0 0.0 0.0 1.00 0210.1 10.1 20.9 21.0 21.0 1.00 0 0 0.1 1.00 NO 25 25.9 50.6 50.5 50.6 ' 0 1.00 9 0 0 ; 1.00 NO2 2t5 25 , ' NO ppm- CO ppoi°' 1 ' _ „ 1 50.3 50.3 50.5 0.1 0 1.50 0 0 0 i 1.00 CO 25.4 25 1 50.3 50 50 ( 1.00 EMISSION MEASUREMENT DATA Oil NO ppm 6.24 c'1 NO2 ppm z 61 ;i NOx ppm 15%02 10 15 I NOx lbslmmBTU 0.037 0.060 NO,TPY 12.11 20.1 CO ppm 15%02 0 25 COIbsJmmBTU 0.000 0.061 I CO TPY 0.04 20.9 FUEL DATA MSCF/D '1880.14 MSCFMR 78,339 CFMPMR 12.33 BTUMPMR 11911 Form A Linearity Check Data Sheet ..ompany: Cheyenne Plains Facility: Cheyenne Plains Date: August 17, 2010 Source Tested: CG 3 Analyst: Mike Meyer Analyzer Manufacture/Model#: ECOM J2KN Analyzer Serial#: 1277 LINEARITY CHECK Calibration Gas Analyzer Analyzer Analyzer Analyzer Absolute Percent Linearity Concentration Response Response Response Response Difference of Valid Pollutant (Indicate Unit) ppm NO ppm NO2 ppm CO %O2 (Indicate Unit) Span (Yes or No) N Zero 0 ppm 0 0 ppm 0.00% YES Mid 25 ppm 25.9 0.9 ppm 1.78% YES n 50.5 ppm 50.5 0 0 ppm 0.00% YES Zero N�2 �� 0 ppm 0 0 ppm 1.5 ppm 0.00% YES. Mld 26.5 ppm 25 2.98% YES 50.3 ppm 0.1 50.3 0 0 ppm 0.00% YES C O Zero 0 ppm 0 0 ppm 0.00% YES Mid 25.4 ppm 25 0.4 ppm 0.80% YES Q� 50.3 ppm 50 0.3 ppm 0.60% YES Zero 0.0 % ! 0 0 % 0.00% YES O�fL Mid 10.1 % _ 10.1 0 % 0.00% YES Span 20.9 % l . , 21 0.1 % 0.48% YES Form B Stability Check Data Sheet Date: August 17, 2010 Facility: Cheyenne Plains Analyst: Mike Meyer Source Tested: CG 3 Analyzer Manufacture/Model#: ECOM J2KN Analyzer Serial#: 1277 Pollutant: NO Span Gas Concentration (ppm): 50.5 STABILITY CHECK Elapsed Elapsed Elapsed Time Analyzer Time Analyzer Time Analyzer (Minutes) Response (Continued) Response (Continued) Response 0 0 16 51.2 32 1 48.3 17 51.2 33 2 49.2 18 51.2 34 3 49.5 19 51.3 35 4 49.8 20 51.3 36 5 50.6 21 51.3 37 6 50.7 22 38 7 50.8 23 39 8 50.8 24 40 9 50.9 25 41 10 51 26 42 11 51 27 43 12 51.1 28 44 13 51.1 29 45 14 51.1 30 46 15 51.1 31 47 For 30-minute Stability Check Period: Maximun Concentration (ppm): 51.3 Minimum Concentration (ppm): 50.6 For 15-minute Stability Check Period: Maximun Concentration (ppm): 51.3 Minimum Concentration (ppm): 50.6 Maximum Deviation = 100*(Max.Conc. - Min. Conc.)/Span Gas Conc. = 1.4% percent Stability Time(minutes): 15 Form B Stability Check Data Sheet Date: August 17, 2010 Facility: Cheyenne Plains Analyst: Mike Meyer Source Tested: CG 3 Analyzer Manufacture/Model#: ECOM J2KN Analyzer Serial#: 1277 Pollutant: NO, Span Gas Concentration(ppm): 50.3 STABILITY CHECK Elapsed Elapsed Elapsed Elapsed Time Analyzer Time Analyzer Time Analyzer Time Analyzer (Minutes) Response (Continued) Response (Continued) Response (Continued) Response 0 0 16 52.7 32 54.4 48 55.3 1 38.6 17 52.9 33 54.5 49 55.4 2 42.4 18 53 34 54.5 50 55.5 3 43.8 19 53.2 35 54.6 51 55.5 4 44.6 20 53.3 36 54.7 52 55.5 5 0 21 53.4 37 54.7 53 55.6 6 50.7 22 53.5 38 54.8 54 55.6 7 51 23 53.5 39 54.8 55 55.6 8 51.3 24 53.7 40 54.9 56 55.7 9 51.5 25 53.8 41 55 57 55.7 10 51.6 26 53.9 42 55 58 55.8 11 51.9 27 54 43 55.1 59 55.8 12 52.1 28 54 44 55.1 60 55.8 13 52.3 29 54.2 45 55.1 61 55.8 14 52.4 30 54.2 46 55.2 62 15 52.6 31 54.3 47 55.3 63 For 30-minute Stability Check Period: Maximun Concentration(ppm): 55.8 Minimum Concentration(ppm): 54.3 For 15-minute Stability Check Period: Maximun Concentration(ppm): 55.8 Minimum Concentration(ppm): 54.3 51.7 Maximum Deviation=100*(Max.Conc.-Min.Conc.)/Span Gas Conc.= 3.0% percent Stability Time(minutes): 30 Form B Stability Check Data Sheet Date: August 17, 2010 Facility: Cheyenne Plains Analyst: Mike Meyer Source Tested: CG 3 Analyzer Manufacture/Model#: ECOM J2KN Analyzer Serial#: 1277 Pollutant: CO Span Gas Concentration (ppm): 50.3 STABILITY CHECK Elapsed Elapsed Elapsed Time Analyzer Time Analyzer Time Analyzer (Minutes) Response (Continued) Response (Continued) Response 0 0 16 50 32 1 55 17 50 33 2 56 18 50 34 3 57 19 50 35 4 58 20 50 36 5 50 21 50 37 6 50 22 38 7 50 23 39 8 50 24 40 9 50 25 41 10 50 26 42 11 49 27 43 12 50 28 44 13 50 29 45 14 50 30 46 15 50 31 47 For 30-minute Stability Check Period: Maximun Concentration (ppm): 50 Minimum Concentration (ppm): 49 For 15-minute Stability Check Period: Maximun Concentration (ppm): 50 Minimum Concentration (ppm): 49 Maximum Deviation = 100*(Max. Conc. -Min.Conc.)/Span Gas Conc. = 2.0% percent Stability Time(minutes): 15 Form C Calibration Error Check Data Sheet Company: Cheyenne Plains Facility: Cheyenne Plains Source Tested: CG 3 Date: August 17, 2010 Analyst: Mike Meyer Analyzer Manufacturer/Model#: ECOM J2KN Analyzer Serial#: 1277 PRETEST CALIBRATION ERROR CHECK A B [A-B] , [A-B]/SGa100 Pump Flow Analyzer Calibration Gas Absolute PreceM Calibration Reponse Rate Reading Concentration Difference of Valid Time (Indicate Units) (Indicate Units) (Indicate Units) (Indicate Units) Span (Yes/No) (Minutes) Zero 3.5 i/min 0 ppm 0 ppm 0 ppm 0.00% YES 1.00 NO Span 3.51/min 50.5 ppm 50.5 ppm 0 ppm 0.00% _ YES 1.00 NO2 S Zero 3.511min 0 ppm 0 ppm 0 ppm 0.00% YES 1.00 pan 3.51/min 50.3 ppm 50.3 ppm 0 ppm 0.00% YES 1.50 Zero 3.51/min 0 ppm 0 ppm 0 ppm 0.00% YES 1.00 CO Span 3.5 undo 50 ppm 50.3 ppm 0.3 ppm 0.60% YES 1.00 Zero 3.5 Ilmin 0 % 0% 0 % 0.00% YES 1.00 72 Span 3.5 umin 21 % 21 % 0.1 % 048% YES 1.00 I Pretest Calibration NO Cell Temperature(°F): I 98 SG = Span Gas POST TEST CALIBRATION ERROR CHECK A B [A-B] [A-B]/SGa100 Interference Check Average of Pump Pre B Post NO CO Flow Analyzer Calibration Gas Absolute Precent Calibration Test Analyzer Monitor Monitor Rate Reading Concentration Difference of Valid Readings Response Response (Indicate Units) (Indicate Units) (Indicate Units) (Indicate Units) Span (Yes/No) (Indicate Units) (ppm) (ppm) Zero 3.51/min 0.1 ppm 0 ppm 0.1 ppm 0.20% YES 005 a'Yv - , NO Span 3.51/min 50.6 ppm 50.5 ppm 0,1 ppm 0.20% YES 50.55 0 Zero 3.51/min 0 ppm 0 ppm 0 ppm_ 0.00% - YES 0 't; NO2 Span 3.5 umin 50.5 ppm 50.3 ppm 0.2 ppm 0.40% YES 50.4 0.1 0 Zero 3.5 I/min 0 ppm 0 ppm 0 ppm 0.00% YES 0 CO Span 3.51/min 50 ppm 50.3 ppm 0.3 ppm 0.60% YES 50 Zero 3.5 1/min 0% 0 % 0 % 0.00% YES 0 02 Span 3.5 I/min 21 % 20.9 % 0.1 % 0.48% YES 21 Postest Calibration NO Cell Temperature(°F) 98 CO Interference Response(Ico%)_ 0.00% NO Interference Response(INO,%a): 0.06% SG = Span Gas Form D - 2 Combustion Turbine Test Results Company: Cheyenne Plains Facility:Cheyenne Plains Source Tested: CG 3 Date: August 17,2010 Source Manufacturer/Model#: Solar I 70-103025 Site Rated Horsepower: 9816 Source Serial#: 0286B Type of Emission Control: SOLoNOx 2 Analyst: Mike Meyer Analyzer Manufacturer/Model#: ECOM J2KN Analyzer Serial#: 1277 Operating Conditions: • Source operating at 90%of greater or site-rated horsepower during test?Yes/No NO Suction/ Engine Specific Discharge Turbine T, Engine Gas Engine Fuel Fuel Heat Fuel Pressures Temperature Engine Throughput Consumption Content Consumption Engine Tested (Indicate Units) (5F) RPM (Indicate units) (Indicate Units) (Mu/c1S IStu/hpdkrli Horsepower 0 I 0 1042 1111164 264.00 mmsd/d 78,339 mscfmr 966 11911 6353 'As reported by the Manufacture Test Results Test Start Time: 12:31am NO Cell Temperature fF)after'/s le.g.,7 minutes)of the test: 98 °F Test End Time: 12:52am NO Cell Temperature OF)after 2/3(e.g.:14 minutes)of the test: 97 °F NOX(NO+NO2 Avenge Average Tested NO,,,,,a.d Tested NO2,e„ema NO,mnened Tested Tested Tested ppm Allowable Allowable Allowable NO ppm ppm NO2 ppm ppm ppm gm/hp-hr TPY (®is Oa) gmlhp-hr TPY ppm dg ta%O2 6 6 3 3 9 0.037 12.11 10 0.060 20.10 15 O2 CO Average Average Tested O2 corrected Tested CO ew.se.d Tested Tested Tested ppm Allowable Allowable Allowable 0t% % CO ppm ppm gm/hp-hr TPY l®15%02) gMhp-hr TPY ppm@tS%0s 15.70 15.63 0 0 0.000 0.04 0 0.061 20.90 25 I certify to the best or my knowledge the test results are accurate end representative of emissions from this source. �'- 5:27-- —.: Mike D Meyer Print Name Signature • P/7Colorado Interstate Gas Company, L.L.C. a Kinder Morgan company July 25, 2012 Sent via FedEx#7985 5836 5852 Colorado Department of Public Health and Environment Attn.: Mr. Matt Burgett APCD-SS-Bl 4300 Cherry Creek Drive South _ Denver, CO 80246 Subject: Change of Permit Contact Colorado Interstate Gas Company, LLC. Cheyenne Plains Compressor Station Operating Permit#95OPWE281 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 Plains Compressor Station operating permit 95OPWE281. A permit renewal was submitted on September 30, 2011. This form replaces the form submitted on 9/30/11. If you have any questions regarding this request, please contact Dawn Meyers of Kinder Morgan at dawn meyers@kindermorgan.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. ,yrelm,20e_ 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 Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name and Name Cheyenne Plains 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 Gelerade�n Cktyytmtt e Plr Ae CrQ5. 7t.lxo 4.tgrThr, u �L Street or Route 370 Van Gordon Street / City, State,Zip Code Lakewood, CO 80228 Country(if not U.S.) 4. Responsible Name Matt Mask official Title Director— Operations Telephone (719) 329-5637 5. Permit contact person Name Dawn Meyers Title Specialist—ENS Lead (If Different than 4) Telephone (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): 0 Carbon Monoxide ❑ Ozone 0 PM10 0 Other(specify) 12. List all(Federal and State)air pollution permits(including grandfathered units),plan approvals and exemptions issued to this facility.List the number,date and what unit/process is covered by each permit. For a Modified Operating Permit, do not complete this item. 05OPWE281 4- roAec'iroAf2d Co✓r'tc&✓1 Vlz &040; ( 'D DS q4/2O)2 Parish, Blue M. From: Meyers, Dawn [Dawn—Meyers@kindermorgan.com] ent: Friday, September 28, 2012 4:25 PM o: Parish, Blue M. • Subject: RE: Colorado APCD - Name Change Request Blue, my apologizes, I didn't receive your e-mail either. IT is supposedly working on a solution to allow emails from the CDPHE through our filter. In the meantime, if you don't receive an e-mail response back from me within 1 business day that I have at least received your email please call. It seems that if you delete the signature block the emails go right through....(definitely not a long term solution but will work until our IT dept gets this corrected). You are absolutely correct, I messed up the form. Cheyenne Plains is still owned by Cheyenne Plains Gas Pipeline Company. There has been no change of owner,just an overwhelmed air compliance engineer who messed up the form! From: Parish, Blue M. [mailto:Blue.Parish@dphe.state.co.us] Sent: Friday, September 28, 2012 12:17 PM - To: Meyers, Dawn Subject: RE: Colorado APCD - Name Change Request Hi Dawn, I had previously sent you an email regarding Cheyenne Plains that I assume was also blocked. I received a Form 2000-100 for this facility back in August that identifies you as the new contact person, but this form notes the owner as CIG, LLC. The current permit is issued to Cheyenne Plains Gas Pipeline Company. I wasn't sure if an :tual ownership transfer occurred or if the CIG listed on the form was in error. Thanks Blue Parish 303-692-3194 From: Meyers, Dawn [mailto:Dawn Meyers@kindermorgan.com] Sent: Friday, September 28, 2012 11:25 AM To: Rusher, Paul; Tangeman, James G (Jim); Bieda, David J Cc: Joyce, Jackie E.; Parish, Blue M.; Taylor, Timothy A. Subject: RE: Colorado APCD - Name Change Request Paul, thank you for forwarding this as I did not receive your original e-mail. Our IT dept is working on the issue of blocked e-mails due to the CDPHE signature block and hopefully it will be resolved shortly. We have 2 air quality engineers within Kinder Morgan that are responsible for air compliance work in Colorado. I will be your contact for the following facilities: Colorado Interstate Gas Company, LLC—Cheyenne, Greasewood, Kit Carson, Springfield, Cheyenne Plains Gas Pipeline Company, LLC-- Cheyenne, and Wyoming Interstate Company, LLC—Snake River ')avid Bieda will be your point of contact for the remaining facilities. We will both review the attached list and resolve any APEN issues. t Thank you Dawn From: Rusher, Paul [mailto:Paul.Rusher@dphe.state.co.us] (! Sent: Friday, September 28, 2012 7:55 AM To: Tangeman, James G (Jim); Meyers, Dawn; Bieda, David J Cc: Joyce, Jackie E.; Parish, Blue M.; Taylor, Timothy A. Subject: Colorado APCD - Name Change Request *This email was originally sent on 09/12/2012. I have been informed by Jackie Joyce that you may not have received this message due to links included in our signature blocks. I have removed these items from my signature block. To Whom it May Concern, The Colorado Air Pollution Control Division has recently been notified of Colorado Interstate Gas Company's name change to Colorado Interstate Gas Company, LLC. I have attached a listing of all emissions points owned by Colorado Interstate Gas Company.This list includes emissions points that have been determined to be APEN exempt as well as cancelled/inactive points; these points are highlighted in red. Please review this list for accuracy and let me know if you find any discrepancies with your records.The purpose of reviewing this list is so that I can accurately define your APEN requirements for your name change request. Jackie Joyce has notified Colorado Interstate Gas Company that the Division requires the submission of one APEN per facility (with at least one active/reportable emissions source) in order to effectuate a name change. Please confirm that ALL active emissions sources under Colorado Interstate Gas Company will be owned by Colorado Interstate Gas Company, LLC (in other words, you will not be retaining some sources under the ownership of Colorado Interstate Gas Company while some move under the ownership of Colorado Interstate Gas Company, LLC). If these are separate company entities and the emissions sources are split between them, this will be considered and ownership transfer. I currently have a name change APEN for the Flank Compressor Station (received 08/31/2012). You will also need to fill out the Permit Application Form,found here. Please fill this form out completely, up through Section 9, and submit it with the rest of the required APENs. Your name change request will not be processed until all required APENs have been received by the Division. Please let me know if you have any questions. Paul Rusher - - Permit Reviewer Stationary Sources Program • Air Pollution Control Division Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South Denver, CO 80246-1530 303-692-2285 (office), 303-782-0278 (fax) • • C � MAY - 12613 Cheyenne Plains Gas Pipeline Company,LLC April 30, 2013 Sent Via Fed Ex— Tracking#7996 3980 7681 Colorado Department of Public Health and Environment Air Pollution Control Division -Operating Permit Unit APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 ATTN: Matt Burgett Subject: Cheyenne Plains Gas Pipeline Company, LLC Cheyenne Plains Compressor Station,Title V Operating Permit#05OPWE281 Minor Permit Modification Request Dear Mr. Burgett Cheyenne Plains Gas Pipeline Company, LLC (CHP), hereby requests a minor permit modification in accordance with Regulation Number 3, Part C, X., Minor Permit Modification Procedures, of Title V Permit #05OPWE281, Section II, Provision 2.3 as follows: 2.3 Natural gas consumption from each heater shall not exceed the limitations stated above (Colorado Construction Permit 03WE0913). Natural gas consumed in each heater shall be recorded monthly, as required by 40 CFR Part 60 Subpart Dc '60.48c(g), as adopted by reference in Colorado Regulation No. 6, Part A. Natural gas use shall be recorded monthly.-using the fuel meter for each h atcr. Monthly natural gas use for each heater shall be used in a twelve month rolling total to monitor compliance with the annual limitation. Each month, a new twelve month total shall be calculated using the previous twelve months data. CHP currently records the natural gas usage monthly utilizing the master fuel meter and allocation calculations. CHP would like to continue to record fuel utilizing the allocation method. Please call me at (303) 914-7837 if you have any questions or if you need additional information. Sincerely, (� A_ Y1 U ' � �y Y ,i'ncus K. Dawn Meyers Matt Mask Pipeline Engineer— Senior Responsible Official Enclosures cc: Curtis Smith Rich Prouty Matt Mask Station File File 370 Van Gordon Street • Lakewood, CO 80228-8304 • (303) 989-1740 7/5/13 State.co.us E ecutiee Branch Mail-Cheyenne Plains Compressor Station-Additional Information Request c '%`' 1S, STATE O F (Ssot COLORADO N dT6_' Cheyenne Plains Compressor Station - Additional Information Request Parish -CDPHE, Blue <blue.parish@state.co.us> Fri, Jul 5, 2013 at 11:52 AM To: Dawn Meyers <dawn_meyers@kindemlorgan.com> Hi Dawn, I'm basically finished drafting the renewal permit, and now I'm looking for the following information: 1. ProMax model run at permit limits, as well as any requests you may have about changing the permit so that it does not rely on AMINECaIc (as we discussed previously on the phone). 2. Can you please confirm the size of the utility bumer listed in the insignificant activity list? There are older APENs that (I believe) are associated with this unit and list the size as anything from 1 to 16 MMBtu/hr. 3. Please provide a list of all E&P sites (well pads), compressor stations and gas plants owned or operated by Cheyenne Plains Gas Pipeline Company LLC or subsidiaries that are located a quarter mile or less from the Cheyenne Plains Compressor Station. For these sites please provide the facility name, AIRS ID (if previously assigned by the Division) and the distance of the site to the Cheyenne Plains Compressor Station If you determine that an identified site will not be wholly dependent on the Cheyenne Plains Compressor Station please explain why the site is not. Note you do not need to list the Cheyenne Station here. 4. Please provide a list of all E&P sites (well pads), compressor stations and gas plants owned or operated by Cheyenne Plains Gas Pipeline Company LLC or subsidiaries that are located more than a quarter mile from the Cheyenne Plains Compressor Station that are wholly dependent on the operation of the Cheyenne Plains Compressor Station to be able to maintain the identified site operations. For the sites identified please provide the facility name, AIRS ID (if previously assigned by the Division) and the distance of the site to the Cheyenne Plains Compressor Station. 5. Is there a serial number for the reboiler burner on the dehydrator? This question is specific to just the bumer(s) only, and not the dehydrator itself. Please let me know if you have any questions relating to this info request. I also wanted to alert you to the following: • Subpart HHH now requires you to have site-specific monitoring plan for the flare. This change in the rule was made when they got rid of the SSM plans and added affirmative defense. This plan requirement will be in the renewal permit, although there is no requirement to submit it to the Division to have it reviewed/approved. • Subpart DDDDD applies to the hot oil heaters, as I'm sure you're aware. However, we have determined that dehy reboiler bumers are not subject to DDDDD if they are part of dehys that are subject to HHH (the exemption is in §63.7491(h). I have not seen this determination tested anywhere yet (EPA no longer comments on our renewal TVs unless they are petitioned), so you may want to consider it carefully. Thanks and have a good holiday weekend. Blue Parish Air Quality Engineer Stationary Sources Program Air Pollution Control Division Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South Denver, CO 80246-1530 https://mai I.g oog Ie.corn/mail/u/0/?ui=2&ilr 16fdf6552f&uewcpt&search=sent&th=l3faff718ff5d0a7 1/2 7/5/13 State.co.us becutlhe Branch Mail-Cheyenne Plains Compressor Station-Additional Information Request 303-692-3194 I blue.parish@state.co.us https://mail.g cog le.coMmail/u/0/?ui=2&ilr 16fdf6552f&viev=pt&search=sent&1h=13faff718ff5d0a7 212 10/1/13 State.co.us Executive Branch Mail-RE:Cheyenne Plains Compressor Station-Additional Information Request 1�,c k STATE OF V' COLORADO IAib RE: Cheyenne Plains Compressor Station - Additional Information Request Meyers, Dawn <Dawn_Meyers@kindermorgan.com> Fri, Sep 6, 2013 at 9:39 AM To: "Parish - CDPHE, Blue" <blue.parish@state.co.us> Blue, my apologizes, I thought I had responded to this but clearly have not! See below: From: Parish - CDPHE, Blue [mailto:blue.parish@state.co.us] Sent: Tuesday, September 03, 2013 4:15 PM To: Meyers, Dawn Subject: Fwd: Cheyenne Plains Compressor Station - Additional Information Request Hi Dawn, Just checking up on the status of the following request. If you need more time, just let me know. Thanks Blue Parish Air Quality Engineer Stationary Sources Program Air Pollution Control Division Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South • Denver, CO 80246-1530 303-692-3194 I blue.parish@state.co.us -- Forwarded message -- From: Parish -CDPHE, Blue <blue.parish@state.co.us> Date: Fri, Jul 5, 2013 at 11:52 AM Subject: Cheyenne Plains Compressor Station -Additional Information Request To: Dawn Meyers <dawn_meyers@kindermorgan.com> Hi Dawn, I'm basically finished drafting the renewal permit, and now I'm looking for the following information: https://mail.g cog le.convmail/u/0/?ui=2&ile16fdf6552f&iemppt&q=dawn_meyers%40kindermorgan.com&qs=hue&search=query&th=140f3ed5b866705d 1/3 10/1/13 State.co.us E)ecuti'e Branch Mail-RE:Cheyenne Plains Compressor Station-Additional Information Request 1. ProMax model run at permit limits, as well as any requests you may have about changing the permit so that it does not rely on AMINECalc (as we discussed previously on the phone). This one is a bit confusing. As the plant has not operated for the last 1 1/2 years, we don't have a good inlet analysis to use and don't have a process engineer that has all the correct inputs for when it is operating. We attempted a run and have lower emissions than currently permitted (which may not be our max, see attached). Could we leave the emission limits as it is currently permitted and remove the requirement to run AmineCalc based on the table, just state that we need to run ProMax monthly when the plant is operating to obtain actual emissions for the rolling 12 month total? We have found with our Treating Business unit that ProMax is generally a more conservative and accurate estimation tool. As the gas stream is richer(which it is not in this case), there is a larger difference between AmineCalc estimated emissions and ProMax. 2. Can you please confirm the size of the utility burner listed in the insignificant activity list? There are older APENs that (I believe) are associated with this unit and list the size as anything from 1 to 16 MMBtu/hr. It is 5 MMBTU/hr max. 3. Please provide a list of all E&P sites (well pads), compressor stations and gas plants owned or operated by Cheyenne Plains Gas Pipeline Company LLC or subsidiaries that are located a quarter mile or less from the Cheyenne Plains Compressor Station. For these sites please provide the facility name, AIRS ID (if previously assigned by the Division) and the distance of the site to the Cheyenne Plains Compressor Station If you determine that an identified site will not be wholly dependent on the Cheyenne Plains Compressor Station please explain why the site is not. Note you do not need to list the Cheyenne Station here. There is nothing within a '/< mile of Cheyenne Plains other than the CIG/WIC Cheyenne Station 4. Please provide a list of all E&P sites (well pads), compressor stations and gas plants owned or operated by Cheyenne Plains Gas Pipeline Company LLC or subsidiaries that are located more than a quarter mile from the Cheyenne Plains Compressor Station that are wholly dependent on the operation of the Cheyenne Plains Compressor Station to be able to maintain the identified site operations. For the sites identified please provide the facility name, AIRS ID (if previously assigned by the Division) and the distance of the site to the Cheyenne Plains Compressor Station. We don't have any facilities that are wholly dependent on the operation of Cheyenne Plains to maintain their operations. 5. Is there a serial number for the reboiler burner on the dehydrator? This question is specific to just the bumer(s) only, and not the dehydrator itself. the Dehy reboiler serial #is H8721-101387 Please let me know if you have any questions relating to this info request. I also wanted to alert you to the following: • Subpart HHH now requires you to have site-specific monitoring plan for the flare. This change in the rule was made when they got rid of the SSM plans and added affirmative defense. This plan requirement will be in the renewal permit, although there is no requirement to submit it to the Division to have it reviewed/approved. • Subpart DDDDD applies to the hot oil heaters, as I'm sure you're aware. However, we have determined that dehy reboiler burners are not subject to DDDDD if they are part of dehys that are subject to HHH (the exemption is in §63.7491(h). I have not seen this determination tested anywhere yet (EPA no longer comments on our renewal TVs unless they are petitioned), so you may want to consider it carefully. Thanks and have a good holiday weekend. Blue Parish Air Quality Engineer Stationary Sources Program Air Pollution Control Division Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South Denver, CO 80246-1530 303-692-3194 j blue.parish@state.co.us https://mail.goog le.com/mail/u/0/?ui=2& 16fdf6557f&uew=pt&q=dawn_meyers%40kindermorg an.com&gs=true&search=query&th=140f3ed5b866705d 2/3 10/1/13 State.co.us Exacutiye Branch Mail-RE:Cheyenne Plains Compressor Station-Additional Information Request c Cheyenne basin amine8-06-13.xls 729K https://mail.goog le.comrnail/W0/?ui=2&ik=16fdf6552f&tiew=pt&q=dawn_meyers%40Idndermorgan.com&qs=true&search=query&th=140f3ed5b866705d 3/3 10/2/13 State.co.us Et=cutive Branch Mail-Re:Cheyenne Plains Compressor Station-Additional Information Request e (�1,� f •:V . �• �E STATE OF _ ' COLORADO Ixi4 Re: Cheyenne Plains Compressor Station - Additional Information Request Parish -CDPHE, Blue <blue.parish@state.co.us> Mon, Sep 9, 2013 at 8:55 AM To: "Meyers, Dawn" <Dawn_Meyers@kindermorgan.com> Thanks Dawn. I will update the draft to monthly ProMax runs, that solves our issues. The draft will go to internal review, then you will see a draft to review in a couple of weeks. Another thing has come up- I still cannot get the inventory to reflect the correct company name for all of the points. Point 025 (glycol reboiler)was entered under"Cheyenne Plains Gas Pipeline Company, LLC", but all other points under this permit remain as "Cheyenne Plains Gas Pipeline Co" I had requested that all the other points be changed to include the LLC, but the data entry people told me they cannot do this since APEN updates were submitted just last May that had the old company name again (without the LLC). To fix this problem (i.e., put all points under the LLC name), they need a new APEN that specifies the LLC name for the entire facility. You can use the general APEN form, and on the AIRS ID field list 123/0051, but leave the point number blank. Check off"Name Change" and leave the equipment-specific information blank. APEN forms For all future APEN submittals, be sure to include the LLC portion of the name, otherwise the points that do not have it will be transferred back to the old company name. I would also recommend that you submit a request to cancel the utility heater point since it is an APEN-exempt point. Reason is that we received several APENs for it in the early 2000's, and this causes us to create a point for it in the inventory (123/0051/020), and now it looks like it has an expired APEN to anyone querying the inventory. On the cancellation form (link below), there is an option to specify that the point is still active but APEN-exempt and you are choosing to no longer submit APENs for it. You can cite the following exemption from APEN reporting requirements for gas equipment less than or equal to 5 MMBtu/hr: Reg 3, Part A, II.D.1.k. APEN cancellation form Please address these submittals to me when you send them and I will make sure they get processed correctly. Give me a call if you have any questions. Thanks Blue Parish Air Quality Engineer Stationary Sources Program Air Pollution Control Division Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South Denver, CO 80246-1530 303-692-3194 I blue.parish@state.co.us On Fri, Sep 6, 2013 at 9:39 AM, Meyers, Dawn <Dawn_Meyers@kindermorgan.com> wrote: https://mail.g oog le.com/mail/u/0/?ui=2&ik=16fdf6552f&vievrpt&cat=Cheyenne Plains&search=cat&th=14103389c96fc470 1/3 10/2/13 State.co.us Fnerutise Branch Mail-Re:Cheyenne Plains Compressor Station-Additional Information Request Blue, my apologizes, I thought I had responded to this but clearly have not! See below: Front Parish - CDPHE, Blue [mailto:blue.parish@state.co.us] Sent: Tuesday, September 03, 2013 4:15 PM To: Meyers, Dawn Subject: Fwd: Cheyenne Plains Compressor Station - Additional Information Request Hi Dawn, Just checking up on the status of the following request. If you need more time, just let me know. Thanks Blue Parish Air Quality Engineer Stationary Sources Program Air Pollution Control Division Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South Denver, CO 80246-1530 303-692-3194 j blue.parish@state.co.us Forwarded message From: Parish -CDPHE, Blue <blue.parish@state.co.us> Date: Fri, Jul 5, 2013 at 11:52 AM Subject: Cheyenne Plains Compressor Station -Additional Information Request To: Dawn Meyers <dawn_meyers@kindermorgan.com> Hi Dawn, I'm basically finished drafting the renewal permit, and now I'm looking for the following information: 1. ProMax model run at permit limits, as well as any requests you may have about changing the permit so that it does not rely on AMINECaIc (as we discussed previously on the phone). This one is a bit confusing. As the plant has not operated for the last 1 % years, we don't have a good inlet analysis to use and don't have a process engineer that has all the correct inputs for when it is operating. We- attempted a run and have lower emissions than currently permitted (which may not be our max, see attached). Could we leave the emission limits as it is currently permitted and remove the requirement to run AmineCalc based on the table, just state that we need to run ProMax monthly when the plant is operating to obtain actual emissions for the rolling 12 month total? We have found with our Treating Business unit that ProMax is generally a more conservative and https://mail.goog le.corrimail/u/0/?ui=2&ilr16fdf6552f&ue' pt&cat=Cheyenne Plains&search=cat&th=14103389c96fc470 2/3 10/2/13 State.co.us Executi'a Branch Mail-Re:Cheyenne Plains Compressor Station-Additional Information Request accurate estimation tool. As the gas stream is richer(which it is not in this case), there is a larger difference between AmineCalc estimated emissions and ProMax. 2. Can you please confirm the size of the utility burner listed in the insignificant activity list? There are older APENs that (I believe) are associated with this unit and list the size as anything from 1 to 16 MMBtu/hr. It is 5 MMBTU/hr max. 3. Please provide a list of all E&P sites (well pads), compressor stations and gas plants owned or operated by Cheyenne Plains Gas Pipeline Company LLC or subsidiaries that are located a quarter mile or less from the Cheyenne Plains Compressor Station. For these sites please provide the facility name, AIRS ID (if previously assigned by the Division) and the distance of the site to the Cheyenne Plains Compressor Station If you determine that an identified site will not be wholly dependent on the Cheyenne Plains Compressor Station please explain why the site is not. Note you do not need to list the Cheyenne Station here. There is nothing within a 1/4 mile of Cheyenne Plains other than the CIG/WIC Cheyenne Station 4. Please provide a list of all E&P sites (well pads), compressor stations and gas plants owned or operated by Cheyenne Plains Gas Pipeline Company LLC or subsidiaries that are located more than a quarter mile from the Cheyenne Plains Compressor Station that are wholly dependent on the operation of the Cheyenne Plains Compressor Station to be able to maintain the identified site operations. For the sites identified please provide the facility name, AIRS ID (if previously assigned by the Division) and the distance of the site to the Cheyenne Plains Compressor Station. We don't have any facilities that are wholly dependent on the operation of Cheyenne Plains to maintain their operations. 5. Is there a serial number for the reboiler burner on the dehydrator? This question is specific to just the bumer(s) only, and not the dehydrator itself. the Dehy reboiler serial #is H8721-101387 Please let me know if you have any questions relating to this info request. I also wanted to alert you to the following: • Subpart HHH now requires you to have site-specific monitoring plan for the flare. This change in the rule was made when they got rid of the SSM plans and added affirmative defense. This plan requirement will be in the renewal permit, although there is no requirement to submit it to the Division to have it reviewed/approved. • Subpart DDDDD applies to the hot oil heaters, as I'm sure you're aware. However, we have determined that dehy reboiler burners are not subject to DDDDD if they are part of dehys that are subject to HHH (the exemption is in §63.7491(h). I have not seen this determination tested anywhere yet (EPA no longer comments on our renewal TVs unless they are petitioned), so you may want to consider it carefully. Thanks and have a good holiday weekend. Blue Parish Air Quality Engineer Stationary Sources Program Air Pollution Control Division Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South Denver, CO 80246-1530 303-692-3194 I blue.parish@state.co.us https://mail.g oog le.com/mail/u/0/?ui=2&ik 16fdf6552f&ue pt8cat=Cheyenne Plains&search=cat&th=14103389c96fc470 3/3 � -o---'43 Cheyenne Plains Gas Pipeline Company,LLC December 16, 2013 Sent via Email & Fed Ex— Tracking#7974 1934 8964 Colorado Department of Public Health and Environment APCD-SS-B 1 Attn.: Ms. Blue Parish 4300 Cherry Creek Drive South Denver, CO 80246-1530 Subject: Cheyenne Plains Gas Pipeline Company, LLC Cheyenne Plains Compressor Station, Permit#05OPWE281 Comments on Draft Permit Dear Ms. Parish: Cheyenne Plains Gas Pipeline Company, LLC. has reviewed the draft operating permit received on November 13, 2013. We have the following comments/requested changes: Page 2 of Document(Facility/Permit Information Page) • Facility Contact will change to the following: Leslie Nolting Specialist, EHS Senior II (719) 520-4652 • Cheyenne Plains requests that the semi-annual and annual certification periods remain consistent with calendar quarters. Section I • Provision 2.1 - Cheyenne Plains requests inclusion of the Division's Standard AOS language for both engine and turbine like kind replacements. • Provision 6.1 — Please make the following corrections: o CP CG-7101 Engine Serial No. is OCH10-B8166, Package Skid SN is TC04639 CP CG-7201 Engine Serial No. is OHL09-B4243, Package Skid SN is TC04638 o CP CG-7301 Engine Serial No. is OHC10-60020, Package Skid SN is TC05362; o H-8701 & H-8702— Hot oil heaters are each 43.79 mmBtu/hr Section II • Permit Page 4, Provision 1, Table with NOx annual limit incorrectly references CG-7101 & 7210. It should be CG-7101 & 7201. • Permit Page 6, Provision 1.2.1, Cheyenne Plains requests changing all references from ambient temperature to turbine inlet temperature (T1), as SoLoNOx operations and emissions guarantees are based on T1 rather than ambient temperature. • Permit Page 6, Provision 1.2.1.4 — Cheyenne Plains requests removal of the word "transient" prior to pilot on line 3 of this provision. The turbines have a variable pilot. 370 Van Gordon Street • Lakewood, CO 80228 • (303) 989-1740 Cheyenne Plains Title V Permit#05OPWE281 Draft Permit Comments December 16, 2013 Page 2 of 2 We have updated the Air Pollution Emission Notice (APEN) to reflect the correct ownership of the facility, Cheyenne Plains Gas Pipeline Company, LLC and to reflect the change in contact information and address. If you have any questions or require additional information, please contact me at (303) 914- 7837 or dawn_meyers@kindermorgan.com Sincerely, Dawn R. Meyers Senior Pipeline Engineer Enclosures cc: Curtis Smith Station File File STATE OF COLORADO John W.Hickenlooper,Governor Larry Wolk,MD,MSPH .orico<o�. Executive Director and Chief Medical Officer Fe, Dedicated to protecting and improving the health and environment of the people of Colorado (* > �� w% 4300 Cherry Creek Dr.S. _Ian Denver,Colorado 80246-1530 --- Phone(303)692-2000 Colorado Department Located in Glendale,Colorado of Public Health www.colorado.gov/cdphe and Environment December 24, 2013 Ms. Dawn Meyers Specialist— EHS Lead Cheyenne Plains Gas Pipeline Company, LLC PO Box 1087 Colorado Springs, CO 80944 SUBJECT: Response to Comments on Draft Renewal Operating Permit for the Cheyenne Plains Gas Pipeline Company, LLC —Cheyenne Plains Compressor Station Dear Ms. Meyers: The Division received your comments and requested changes for the draft permit on December 18, 2013. I am incorporating all of the requests as received with the exception of the request to change the basis for the alternative low-temperature NOx BACT limits from ambient temperature to turbine inlet temperature. Based on a review of the Division files, the basis used for the BACT determination was confirmed to be ambient temperature (see attached manufacture specification). A change in the temperature basis would be considered a modification and would need additional evaluation to determine changes in emissions and other factors that were relied upon in the original analysis. The Division will continue with processing this renewal permit; the next step will be the public notice period. Please contact me at (303) 692-3194 or blue.parishastate.co.us if you have any questions. Sincerely, "If ti Blue Parish Operating Permit Unit Stationary Sources Program Air Pollution Control Division Cc: Leslie Nolting (via email) Enclosures Solar Turbinescic allearerF ra r Cur4pav Product Information Letter - • SoLoNOx Products — Emissions in Non-SoLoNOx Modes Leslie Witherspoon Solar Turbines Incorporated PURPOSE bine engine models are controlled to increase (So- pilot fuel from approximately 3 to 10% of the total Solar's dry-low NOx emissions SoNOx) have been developed to fuel flow to improve flame stability. Without this provide systems o the low- increase in pilot fuel at temperatures below 0°F, est emissions possible during normal operating conditions. In order to optimize the performance the engines may exhibit combustor rumble since of operation may be near the lean stability limit. the turbine, the combustion and fuel systems are designed to reduce NOx, CO and unburned For permitting purposes, customers have used hydrocarbons (UHC) without penalizing stability the New Source Performance Standard (NSPS) or transient capabilities. At very low load and cold levels, 40 CFR 60, subpart GG for a conservative temperature extremes, the SoLoNOx system NOx emission estimate at ambient temperatures must be controlled differently in order to assure below 0 °F. Table 4 herein summarizes NSPS stable operation. These required adjustments to NOx emission levels for Solar's equipment. the engine controls at extreme conditions cause emissions to increase. Emission warranty limita- In some cases, either the customer or regulatory tions are, therefore, imposed for load (50 to agency desires a "less conservative° estimate of 100%) and for cold ambient temperatures (>0°F). actual emissions for when the turbine is not oper- ating The purpose of this PIL is to provide emissions in SoLoNOx mode. For such instances, the estimates ars for e NOx, PIC and UHC at these off- following actual emission estimates are provided. design conditions. "Expected" emissions are extrapolated from San 9Diego factory tests and may vary at these ex- COLD AMBIENT EMISSIONS ESTIMATES treme temperatures and as a result of variations in other parameters such as fuel composition, Solar's standard temperature range warranty for fuel quality, etc. Emission warranties cannot be SoLoNOx engines is >0°F. At ambient tempera- offered for ambient temperatures below 0°F. tures below 0°F, the unit is no longer in SoLoNOx mode and emissions are expected to be higher For SoLoNOx engine models, except for Cen- than when operating in SoLoNOx mode. At ambi- tour 40 and 90, expected emissions (ppm ent temperatures below 0°F, many of Solar's tur- corrected to 15 /° as a function of ambient temperature are given in Table 1. Table 1. Expected Emissions below 0`F(except for Centaur 40 and Mars 90) Ambient Fuel System - Fuel NOx, ppm CO, ppm UHC,ppm 0°F to-20°F Gas only(50 to 100% load) Gas 42 100 50 Gas 72 100 50 Dual fuel (80 to 100% load) Liquid 120 150 75 Below-20°F Gas only (50 to 100% load) Gas 120 150 75 Gas 120 150 75 Dual fuel (80 to 100% load) Liquid 120 150 75 PIL 167 1 9 January 2003 Caterpillar: Confidential Green Solar Turbines Incorporated Product Information Letteri167 For Centaur 40 and Mars 90 engine models, EMISSIONS ESTIMATES AT LESS expected emissions (ppm corrected to 15% O2) THAN 50% LOAD as a function of ambient temperature are given in At operating loads <50%, SoLoNOx engines are Table 2. controlled to increase stability and transient re- Some regulatory agencies in states with colder sponse capability. The control steps that are re- winter climates (primarily Alaska and Wyoming) quired affect emissions in two ways: 1) pilot fuel have started to ask about cold ambient tempera- flow is increased, increasing NO, emissions, and ture restrictions and corresponding emissions 2) airflow through the combustor is increased, below 0°F. In all cases to date, the regulatory increasing CO emissions. Note that 50% load is agency did not require a certain emission level to an approximation and that engine controls are be met, but merely asked what emissions are triggered either by power output for single-shaft expected so that emissions could be appropri- engines or gas producer speed for two-shaft en- • ately estimated for annual emissions inventory gines. purposes and NSR applicability issues. For permitting purposes, Solar has historically Some customers have used the permitting strat- recommended the use of New Source Perform- egy of installing digital thermometers to record ance Standard (NSPS) levels, 40 CFR 60, sub- ambient temperature. The amount of time is re- pad GG for conservative NOx emission estimates corded that the ambient temperature falls below outside the typical load range warranty. (Table 4 • • 0°F. The amount of time below 0°F is then used herein summarizes NSPS NOx emission levels with the emission estimates shown above to es- timateSolar's"actual"emissions. In some cases, either the customer or regulatory agency desires a "less conservative° estimate of For customers who wish to permit at a single emission rate over all temperatures, inlet air heat- actual emissions for when the turbine is not oper- ng can be used to raise the engine inlet air tern- actual emission, 20%, are estimated based on a sting in SoLoNOx mode. For such instances, the perature (T1) above 0°F. With inlet air heating to combination of empirical calculations and the Um- keep T1 above 0 °F, standard emission warranty ited test data available. Table 3 provides esti- levels may be offered. Table 2. Expected Emissions below 0`F for Centaur 40 and Mars 90 Engines ppm m pm Ambient` Fuel System Fuel NOx, pp CO,, UHC, Gas only (50 to 100% load) Gas 120 150 75 Centaur 40 and Mars 90 Below 0°F Dual fuel (80 to 100% load) Gas or 120 150 75 Centaur 40 Liquid (Dual fuel not applicable for Mars 90) • Table 3. Estimated Emissions Engine Load NOx, ppm CO, ppm UHC, PPM Less than 50% 70 2200 300 Idle 50 3500 500 PIL 167 2 9 January 2003 Caterpillar: Confidential Green Solar Turbines Incorporated Product Information Letter 167 Table 4. NSPS Limits(NOx,ppmv @ 15% Oz) Gas Fuel Liquid Fuel >1/3 Power >1/3 Power Product Gas Fuel to Grid Liquid Fuel° to Grid • Titan 130-19500 GSC 209° 105° 205 102 CS/MD 214° 210 Mars 100-15000 GSC 209° 105° 207 104 CS/MD 203° 201 Mars 90-13000 GSC • 205° 197 CS/MD 199° 193 Taurus 70-10300 GSC 212° 210 • CS/MD 207° 201 Taurus 60-7300, -7800 GSC 190°/193° 188/191 CS/MD 190°/193° 188/191 Mercury 50 EXEMPT Centaur 50-6200, -6100 GSC 184` 183 CS/MD 180` 177 Centaur 40-4700 GSC • 182° 179 CS/MD 1670 165 Saturn 20-1600 GSC 156` 155 CS/MD 150° 150 a SoLoN0x,water Injection, or add-on control is required to meet NSPS ° Fuel bound nitrogen content assumed to be <0.015%by volume ` Conventional turbine meets NSPS mates of NOR, CO, and UHC emissions when natural gas. At ambient temperatures below - operating below 50% load and above -20°F. The 20°F, the NO, emission estimate is 120 ppmv for estimated emissions can be assumed to vary loads <50%. For liquid fuel operation below B0% linearly as load is decreased from just below 50% load, emissions documentation is in progress. load to idle. The above values apply for any product for gas only or dual fuel systems using pipeline quality Solar Turbines Incorporated 9330 Sky Park Court San Diego, CA 92123-5398 Caterpillar is a registered trademark of Caterpillar Inc. Solar, Titan,Mars, Taurus,Mercury, Centaur, Saturn, SoLoNOx, and Turbotronic are trademarks of Solar Turbines Incorporated. Specifications subject to change without notice.Printed in U.S.A. ©2003 Solar Turbines Incorporated. All rights reserved. PIL 167 3 9 January 2003 Caterpillar: Confidential Green Hello