HomeMy WebLinkAbout20140301.tiff EXHIBIT N
CONSTRUCTION APEN
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT 'e A i>
AIR POLLUTION CONTROL DIVISION ,+'1(0
TELEPHONE: (303) 692-3150 *1876,
1896,
CONSTRUCTION PERMIT
PERMIT NO: 1 2WE2117
Issuance 1
DATE ISSUED:
ISSUED TO: Sterling Energy Investments LLC
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the Centennial Gas Plant, located in SESW S25 T9N R61 W,
in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS Description
Equipment ID Point
One (1)Waukesha, Model L7044GSI, Serial Number To Be
Determined, natural gas-fired, turbo-charged, 4SRB
reciprocating internal combustion engine, site rated at 1680
C001 001 horsepower at 1200 RPM. This engine shall be equipped
with a non-selective catalytic reduction (NSCR) system and
air-fuel ratio control This emission unit is used for natural
gas compression.
One (1)Waukesha, Model L7044GS1, Serial Number To Be
Determined, natural gas-fired, turbo-charged, 4SRB
reciprocating internal combustion engine, site rated at 1680
C002 002 horsepower at 1200 RPM. This engine shall be equipped
with a non-selective catalytic reduction (NSCR) system and
air-fuel ratio control This emission unit is used for natural
gas compression.
One (1)Waukesha, Model L7044GS1, Serial Number To Be
Determined, natural gas-fired, turbo-charged, 4SRB
reciprocating internal combustion engine, site rated at 1680
G001 003 horsepower at 1200 RPM. This engine shall be equipped
with a non-selective catalytic reduction (NSCR) system and
air-fuel ratio control This emission unit is used for natural
gas compression.
AIRS ID: 123/9966 Page 1 of 28
NGEngine Version 2012-1
Colorado Department of Public Health and Environment
Air Pollution Control Division
Facility AIRS Description
Equipment ID Point
One (1)Waukesha, Model L7044GSI, Serial Number To Be
Determined, natural gas-fired, turbo-charged, 4SRB
reciprocating internal combustion engine, site rated at 1680
G002 004 horsepower at 1200 RPM. This engine shall be equipped
with a non-selective catalytic reduction (NSCR) system and
air-fuel ratio control This emission unit is used for natural
gas compression.
One (1) Caterpillar, Model G3306, Serial Number 07Y02221,
natural gas-fired, turbo-charged, 4SRB reciprocating internal
P001 005 combustion engine, site rated at 220 horsepower at 1800
RPM. This engine shall be equipped with a non-selective
catalytic reduction (NSCR) system and air-fuel ratio control
This emission unit is used for Propane compression.
One (1) Caterpillar, Model G3408TA, Serial Number TBD,
natural gas-fired, turbo-charged, 4SRB reciprocating internal
R001 006 combustion engine, site rated at 400 horsepower at 1800
RPM. This engine shall be equipped with a non-selective
catalytic reduction (NSCR) system and air-fuel ratio control
This emission unit is used for Propane compression.
One (1) Caterpillar, Model G3412, Serial Number TBD,
natural gas-fired, turbo-charged, 4SRB reciprocating internal
R002 007 combustion engine, site rated at 600 horsepower at 1800
RPM. This engine shall be equipped with a non-selective
catalytic reduction (NSCR) system and air-fuel ratio control
This emission unit is used for Propane compression.
One (1) Triethylene glycol (TEG), natural gas dehydration
DEHY001 008 unit (custom built) with a design capacity of 9.92 MMscf per
day. This unit is equipped with a flash tank, reboiler and still
vent. Emissions are routed to the thermal oxidizer.
Methyldiethanolamine (MDEA) natural gas sweetening
system for acid gas removal with a design capacity of 9.92
MMSCF per day(custom built). This emissions unit is
AMINE001 009 equipped with one (1) TBD amine recirculation pump. This
system includes a natural gas/amine contactor, a flash tank,
and a natural gas fired amine regeneration reboiler. All
emissions are routed to the thermal oxidizer.
FUG001 010 Equipment leaks (fugitive VOCs)from a Natural Gas
Processing Plant.
These engines may be replaced with another engine in accordance with the temporary
engine replacement provision or with another Waukesha L7044GSI, Caterpillar G3408,
Caterpillar G3412, or Caterpillar G3306 engine in accordance with the permanent
AIRS ID: 123/9966 Page 2 of 28
Colorado Department of Public Health and Environment
Air Pollution Control Division
replacement provision of the Alternate Operating Scenario (AOS), included in this permit as
Attachment A.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO
AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS
INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than
fifteen days after commencement of operation, by submitting a Notice of Startup
form to the Division. The Notice of Startup form may be downloaded online at
www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup
of the permitted source is a violation of Air Quality Control Commission (AQCC)
Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit.
2. Within one hundred and eighty days (180) after commencement of operation,
compliance with the conditions contained in this permit shall be demonstrated to the
Division. It is the owner or operator's responsibility to self-certify compliance with the
conditions. Failure to demonstrate compliance within 180 days may result in revocation
of the permit. (Reference: Regulation No. 3, Part B, III.G.2).
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source
within 18 months after either, the date of issuance of this construction permit or the date
on which such construction or activity was scheduled to commence as set forth in the
permit application associated with this permit; (H) discontinues construction for a period
of eighteen months or more; (Hi) does not complete construction within a reasonable
time of the estimated completion date. The Division may grant extensions of the
deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B,
III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self-certification process.
(Reference: Regulation No. 3, Part B, Section III.E.)
5. The following information shall be provided to the Division within fifteen (15) days after
commencement of operation.
• manufacture date
• construction date
• order date
• date of relocation into Colorado
• manufacturer
• model number
• serial number
This information shall be included with the Notice of Startup submitted for the equipment.
(Reference: Regulation No. 3, Part B, III.E.)
AIRS ID: 123/9966 Page 3 of 28
Colorado Department of Public Health and Environment
Air Pollution Control Division
6. The operator shall retain the permit final authorization letter issued by the Division after
completion of self-certification, with the most current construction permit. This
construction permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Monthly Limits:
Facility AIRS Pounds per Month
Equipment ID Point NO, VOC CO Emission Type
C001 001 827 357 827 Point
C002 002 827 357 827 Point
G001 003 827 357 827 Point
G002 004 827 357 827 Point
P001 005 109 40 108 Point
R001 006 198 85 196 Point
R002 007 298 108 294 Point
DEHY001 008 --- 109 --- Point
AMINE001 009 --- 88 --- Point
FUG001 010 --- 7577 --- Fugitive
(Note: Monthly limits are based on a 31-day month.)
The owner or operator shall calculate monthly emissions based on the calendar month.
Facility-wide emissions of each individual hazardous air pollutant shall be less than
1,359 lb/month.
Facility-wide emissions of total hazardous air pollutants shall be less than 3,398
lb/month.
Annual Limits:
Facility AIRS Tons per Year
Equipment ID Point Emission Type
NO, VOC CO
C001 001 4.9 2.1 4.9 Point
C002 002 4.9 2.1 4.9 Point
G001 003 4.9 2.1 4.9 Point
G002 004 4.9 2.1 4.9 Point
P001 005 0.6 0.2 0.6 Point
R001 006 1.2 0.5 1.2 Point
R002 007 1.7 0.6 1.7 Point
DEHY001 008 --- 0.6 --- Point
AIRS ID: 123/9966 Page 4 of 28
Colorado Department of Public Health and Environment
Air Pollution Control Division
AMINE001 009 --- 0.5 --- Point
FUG001 010 --- 44.6 --- Fugitive
See "Notes to Permit Holder"for information on emission factors and methods used to calculate
limits.
Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0
tpy.
Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
During the first twelve (12) months of operation, compliance with both the monthly and
annual emission limitations is required. After the first twelve (12) months of operation,
compliance with only the annual limitation is required.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)
from each emission unit, on a rolling twelve (12) month total. By the end of each month
a new twelve-month total shall be calculated based on the previous twelve months' data.
The permit holder shall calculate emissions each month and keep a compliance record
on site or at a local field office with site responsibility, for Division review. This rolling
twelve-month total shall apply to all permitted emission units, requiring an APEN, at this
facility.
8. The owner or operator shall track emissions from all insignificant activities at the facility
on an annual basis to demonstrate compliance with the facility emission limitations as
seen below. An inventory of each insignificant activity and associated emission
calculations shall be made available to the Division for inspection upon request. For the
purposes of this condition, insignificant activities shall be defined as any activity or
equipment, which emits any amount but does not require an Air Pollutant Emission
Notice (APEN).
Total emissions from the facility, including permitted emissions and insignificant
activities, shall not exceed:
• 100 tons per year of any criteria pollutant and/or
• 10 tons per year of a single hazardous air pollutant and/or
• 25 tons per year of total hazardous air pollutants (HAP).
9. Point 010: The operator shall calculate actual emissions from this emissions point based
on representative component counts for the facility with the most recent gas analysis, as
required in the Compliance Testing and Sampling section of this permit. The operator
shall maintain records of the results of component counts and sampling events used to
calculate actual emissions and the dates that these counts and events were completed.
These records shall be provided to the Division upon request.
10. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
Facility AIRS Pollutants
Equipment Point Control Device Controlled
ID
AIRS ID: 123/9966 Page 5 of 28
Colorado Department of Public Health and Environment
Air Pollution Control Division
C001 001 NSCR catalyst and air/fuel ratio controller NOx, CO, VOC
C002 002 NSCR catalyst and air/fuel ratio controller NOx, CO, VOC
G001 003 NSCR catalyst and air/fuel ratio controller NOx, CO, VOC
G002 004 NSCR catalyst and air/fuel ratio controller NOx, CO, VOC
P001 005 NSCR catalyst and air/fuel ratio controller NOx, CO
R001 006 NSCR catalyst and air/fuel ratio controller NOx, CO,VOC
R002 007 NSCR catalyst and air/fuel ratio controller NOx, CO, VOC
DEHY001 008 Thermal Oxidizer VOC, HAP's
AMINE001 009 Thermal Oxidizer VOC, HAP's
PROCESS LIMITATIONS AND RECORDS
11. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rate shall be maintained by the owner or
operator and made available to the Division for inspection upon request. (Reference:
Regulation 3, Part B, II.A.4)
Process/Consumption Limits
Facility AIRS Annual Monthly Limit
Equipment Point Process Parameter Limit (31 days)
ID
C001 001 Consumption of natural gas as a fuel 98.25 8.35
MMscf/yr MMscf/month
C002 002 Consumption of natural gas as a fuel 98.25 8.35
MMscf/yr MMscf/month
6001 003 Consumption of natural gas as a fuel 98.25 8.35
MMscf/yr MMscf/month
G002 004 Consumption of natural gas as a fuel 98.25 8.35
MMscf/yr MMscf/month
P001 005 Consumption of natural gas as a fuel 12.29 1.04
MMscf/yr MMscf/month
R001 006 Consumption of natural gas as a fuel 21.17 1.8
MMscf/yr MMscf/month
R002 007 Consumption of natural gas as a fuel 32.67 2.8
MMscf/yr MMscf/month
DEHY001 008 Throughput of natural gas 3620.8 307.6
MMscf/yr MMscf/month
AMINE001 009 Throughput of natural gas 3620.8 307.6
MMscf/yr MMscf/month
The owner or operator shall calculate monthly process rates based on the calendar
month.
During the first twelve (12) months of operation, compliance with both the monthly and
annual throughput limitations is required. After the first twelve (12) months of operation,
compliance with only the annual limitation is required.
AIRS ID: 123/9966 Page 6 of 28
Colorado Department of Public Health and Environment
Air Pollution Control Division
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on
the previous twelve months' data. The permit holder shall calculate throughput each
month and keep a compliance record on site or at a local field office with site
responsibility, for Division review.
12. Point 008: This unit shall be limited to the maximum lean glycol circulation rate of 2.5
gallons per minute. The lean glycol recirculation rate shall be recorded weekly in a log
maintained on site and made available to the Division for inspection upon request.
(Reference: Regulation No. 3, Part B, II.A.4)
STATE AND FEDERAL REGULATORY REQUIREMENTS
13. Point 008: The flare covered by this permit is subject to Regulation No. 7, Section
XVII.B General Provisions (State only enforceable). If a flare or other combustion device
is used to control emissions of volatile organic compounds to comply with Section XVII, it
shall be enclosed, have no visible emissions during normal operations, and be designed
so that an observer can, by means of visual observation from the outside of the enclosed
flare or combustion device, or by other convenient means approved by the Division,
determine whether it is operating properly. The operator shall comply with all applicable
requirements of Section XVII.
14. Point 008: This equipment is subject to the control requirements for glycol natural gas
dehydrators under Regulation No. 7, Section XVII.D (State only enforceable). Beginning
May 1, 2008, uncontrolled actual emissions of volatile organic compounds from the still
vent and vent from any gas-condensate-glycol (GCG) separator (flash separator or flash
tank), if present, shall be reduced by an average of at least 90 percent through the use
of air pollution control equipment.
This source shall comply with all applicable general provisions of Regulation 7, Section
XVII.
15. Point 009: This amine unit is subject to the New Source Performance Standards
requirements of Regulation No. 6, Part A, Subpart OOOO, Standards of Performance for
Crude Oil and Natural Gas Production, Transmission and Distribution including, but not
limited to, the following:
• §60.5365—Applicability and Designation of Affected Facilities
o §60.5365(g)(3) - Facilities that have a design capacity less than 2 long
tons per day (LT/D) of hydrogen sulfide (H2S) in the acid gas (expressed
as sulfur) are required to comply with recordkeeping and reporting
requirements specified in §60.5423(c) but are not required to comply with
§§60.5405 through 60.5407 and §§60.5410(g) and 60.5415(g).
• §60.647— Record keeping and reporting Requirements
o §60.5423(c) -To certify that a facility is exempt from the control requirements
of these standards, for each facility with a design capacity less that 2 LT/D of
H2 S in the acid gas (expressed as sulfur) you must keep, for the life of the
AIRS ID: 123/9966 Page 7 of 28
Colorado Department of Public Health and Environment
Air Pollution Control Division
facility, an analysis demonstrating that the facility's design capacity is less
than 2 LT/D of H2 S expressed as sulfur
16. Point 008: This source is subject to the requirements of 40 CFR, Part 63, Subpart HH -
National Emission Standards for Hazardous Air Pollutants for Source Categories from
Oil and Natural Gas Production Facilities including, but not limited to, the following:
• §63.764 - General Standards
o §63.764 (e)(1) -The owner or operator is exempt from the requirements of
paragraph (c)(1) and (d) of this section if the criteria listed in paragraph
(e)(1)(i) or (ii) of this section are met, except that the records of the
determination of these criteria must be maintained as required in
§63.774(d)(1).
• §63.764 (e)(1)(ii) — The actual average emissions of benzene from
the glycol dehydration unit process vent to the atmosphere are less
than 0.90 megagram per year, as determined by the procedures
specified in §63.772(b)(2) of this subpart.
• §63.772 - Test Methods, Compliance Procedures and Compliance
Demonstration
o §63.772(b) - Determination of glycol dehydration unit flowrate or benzene
emissions. The procedures of this paragraph shall be used by an owner or
operator to determine glycol dehydration unit natural gas flowrate or benzene
emissions to meet the criteria for an exemption from control requirements
under§63.764(e)(1).
• §63.772(b)(2) - The determination of actual average benzene
emissions from a glycol dehydration unit shall be made using the
procedures of either paragraph (b)(2)(i) or (b)(2)(ii) of this section.
Emissions shall be determined either uncontrolled, or with federally
enforceable controls in place.
• §63.772(b)(2)(i) — The owner or operator shall determine
actual average benzene emissions using the model GRI-
GLYCaIc TM , Version 3.0 or higher, and the procedures
presented in the associated GRI-GLYCaIc TM Technical
Reference Manual. Inputs to the model shall be representative
of actual operating conditions of the glycol dehydration unit
and may be determined using the procedures documented in
the Gas Research Institute (GRI) report entitled "Atmospheric
Rich/Lean Method for Determining Glycol Dehydrator
Emissions" (GRI-95/0368.1); or
• §63.772(b)(2)(ii) - The owner or operator shall determine an
average mass rate of benzene emissions in kilograms per
hour through direct measurement using the methods in
§63.772(a)(1)(i) or (ii), or an alternative method according to
§63.7(f). Annual emissions in kilograms per year shall be
determined by multiplying the mass rate by the number of
hours the unit is operated per year. This result shall be
converted to megagrams per year.
AIRS ID: 123/9966 Page 8 of 28
Colorado Department of Public Health and Environment
Air Pollution Control Division
• §63.774 - Recordkeeping Requirements
o §63.774 (d)(1) -An owner or operator of a glycol dehydration unit that meets
the exemption criteria in §63.764(e)(1)(i) or §63.764(e)(1)(ii) shall maintain
the records specified in paragraph (d)(1)(i) or paragraph (d)(1)(ii) of this
section, as appropriate, for that glycol dehydration unit.
• §63.774 (d)(1)(ii) - The actual average benzene emissions (in terms
of benzene emissions per year) as determined in accordance with
§63.772(b)(2).
17. The permit number and AIRS ID point number(e.g. 123/4567/890) shall be marked on
the subject equipment for ease of identification. (Reference: Regulation Number 3, Part
B, III.E.) (State only enforceable)
18. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation
of the source. During periods of startup, process modification, or adjustment of control
equipment visible emissions shall not exceed 30% opacity for more than six minutes in
any sixty consecutive minutes. Emission control devices subject to Regulation 7,
Sections XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation
No. 1, Section II.A.1. &4.)
19. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
20. Points 001-004, 007: This equipment is subject to the requirements for natural gas-fired
reciprocating internal combustion engines under Regulation No. 7, Section XVII.E.3
(State only enforceable). Any rich burn reciprocating internal combustion engine
constructed or modified before February 1, 2009 with a manufacturer's name plate
design rate greater than 500 horsepower shall install and operate both a non-selective
catalyst reduction and an air fuel controller by July 1, 2010. The operator shall operate
and maintain the air pollution control equipment to manufacturer specifications or
equivalent to the extent practicable and shall keep manufacturer specifications or
equivalent on file. Records of maintenance shall be kept on site or at a local field office
with site responsibility, for Division review.
Please note that replacements of this engine in accordance with the AOS in Attachment
A may be subject to this or other requirements in Regulation 7, Section XVII.E.
21. Points 001-004, 007: This equipment is subject to the control requirements for natural
gas-fired reciprocating internal combustion engines under Regulation No. 7, Section
XVII.E (State only enforceable). The owner or operator of any natural gas-fired
reciprocating internal combustion engine that is either constructed or relocated to the
state of Colorado from another state after the date listed in the table below shall operate
and maintain each engine according to the manufacturer's written instructions or
procedures to the extent practicable and consistent with technological limitations and
good engineering and maintenance practices over the entire life of the engine so that it
achieves the emission standards required in the table below:
Maximum Engine Construction or Emission Standard in g/hp-hr
HP Relocation Date NOx I CO I VOC
AIRS ID: 123/9966 Page 9 of 28
Colorado Department of Public Health and Environment
Air Pollution Control Division
<100HP Any N/A N/A N/A
≥100HP and January 1, 2008 2.0 4.0 1.0
<500HP January 1, 2011 1.0 2.0 0.7
≥S00HP July 1, 2007 2.0 4.0 1.0
July 1, 2010 1.0 2.0 0.7
22. Points 001-004, 007:This source is subject to the requirements of:
• Regulation No. 8, Part E , Subpart III.FFFF: National Emissions Standards
for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion
Engines (RICE) of 40 C.F.R. Part 63, Subpart ZZZZ, and
• Regulation No. 8, Part E, Subpart I.A, National Emission Standards for
Hazardous Air Pollutants for Source Categories: General Provisions, 40 CFR
Part 63
including, but not limited to, the following:
• Emission and Operating Limitations
o §63.6600(a) - If you own or operate an existing, new, or reconstructed spark
ignition 4SRB stationary RICE with a site rating of more than 500 brake HP
located at a major source of HAP emissions, you must comply with the
following emission limitations (Table 1 a, Subpart ZZZZ to Part 63):
• Reduce formaldehyde emissions by 76 percent or more, or
• Limit the concentration of formaldehyde in the stationary RICE
exhaust 350 ppbvd or less at 15 percent O2.
o §63.6600(a) - If you own or operate an existing, new, or reconstructed spark
ignition 4SRB stationary RICE with a site rating of more than 500 brake HP
located at a major source of HAP emissions, you must comply with the
following operating limitations (Table 1 b, Subpart ZZZZ to Part 63):
• Maintain your catalyst so that the pressure drop across the catalyst
does not change by more than 2 inches of water at 100 percent load
plus or minus 10 percent from the pressure drop across the catalyst
measured during the initial performance test; and
• Maintain the temperature of your stationary RICE exhaust so that the
catalyst inlet temperature is greater than or equal to 750 °F and less
than or equal to 1250 °F.
• General Compliance Requirements
o §63.6605(a) - You must be in compliance with the emission limitations and
operating limitations in this subpart that apply to you at all times, except
during periods of startup, shutdown, and malfunction.
o §63.6605(b) - If you must comply with emission limitations and operating
limitations, you must operate and maintain your stationary RICE, including air
pollution control and monitoring equipment, in a manner consistent with good
AIRS ID: 123/9966 Page 10 of 28
Colorado Department of Public Health and Environment
Air Pollution Control Division
air pollution control practices for minimizing emissions at all times, including
during startup, shutdown, and malfunction.
• Testing and Initial Compliance Requirements
o §63.6610(a) - You must conduct the initial performance test or other initial
compliance demonstrations in Table 4 to Subpart 777Z of Part 63 that apply
to you within 180 days after the compliance date that is specified for your
stationary RICE in §63.6595 and according to the provisions in §63.7(a)(2).
o §63.6615 - If you must comply with the emission limitations and operating
limitations, you must conduct subsequent performance tests semiannually (as
per Table 3 of Subpart ZZZZ to Part 63). After you have demonstrated
compliance for two consecutive tests, you may reduce the frequency of
subsequent performance tests to annually. If the results of any subsequent
annual performance test indicate the stationary RICE is not in compliance
with the CO or formaldehyde emission limitation, or you deviate from any of
your operating limitations, you must resume semiannual performance tests.
o §63.6625(a) - If you elect to install a GEMS as specified in Table 5 of this
subpart, you must install, operate, and maintain a CEMS to monitor CO and
either oxygen or CO2 at both the inlet and the outlet of the control device
according to the requirements in paragraphs 63.6625(a)(1) through
63.6625(4) of Subpart ZZZZ to Part 63.
o §63.6625(b) - If you are required to install a continuous parameter monitoring
system (CPMS) as specified in Table 5 of this subpart, you must install,
operate, and maintain each CPMS according to the requirements in §63.8.
o §63.6630(a) - You must demonstrate initial compliance with each emission
and operating limitation that applies to you according to Table 5 of Subpart
ZZZZ to Part 63.
o §63.6630(b) - During the initial performance test, you must establish each
operating limitation in Tables lb and 2b of Subpart ZZZZ to Part 63 that
applies to you.
o §63.6630(c) - You must submit the Notification of Compliance Status
containing the results of the initial compliance demonstration according to the
requirements in §63.6645.
• Continuous Compliance Requirements Delete this entire section if the engine is
not one of the following:
o §63.6635(b) - Except for monitor malfunctions, associated repairs, and
required quality assurance or control activities (including, as applicable,
calibration checks and required zero and span adjustments), you must
monitor continuously at all times that the stationary RICE is operating.
o §63.6635(c) - You may not use data recorded during monitoring
malfunctions, associated repairs, and required quality assurance or control
activities in data averages and calculations used to report emission or
operating levels. You must, however, use all the valid data collected during all
other periods.
AIRS ID: 123/9966 Page 11 of 28
Colorado Department of Public Health and Environment
Air Pollution Control Division
o §63.6640(a) - You must demonstrate continuous compliance with each
emission limitation and operating limitation in Tables la and lb and Tables
2a and 2b of subpart ZZZZ of Part 63 that apply to you according to methods
specified in Table 6 of Subpart ZZZZ of Part 63.
o §63.6640(b) - You must report each instance in which you did not meet each
emission limitation or operating limitation in Tables la and 1b and Tables 2a
and 2b of Subpart ZZZZ of Part 63 that apply to you. These instances are
deviations from the emission and operating limitations in this subpart. These
deviations must be reported according to the requirements in §63.6650. If you
change your catalyst, you must reestablish the values of the operating
parameters measured during the initial performance test. When you
reestablish the values of your operating parameters, you must also conduct a
performance test to demonstrate that you are meeting the required emission
limitation applicable to your stationary RICE.
o §63.6640(d) - Consistent with §§63.6(e) and 63.7(e)(1), deviations from the
emission or operating limitations that occur during a period of startup,
shutdown, or malfunction are not violations if you demonstrate to the
Administrator's satisfaction that you were operating in accordance with
§63.6(e)(1). For new, reconstructed, and rebuilt stationary RICE, deviations
from the emission or operating limitations that occur during the first 200 hours
of operation from engine startup (engine burn-in period) are not violations.
§63.6640(e) - You must also report each instance in which you did not meet
the requirements in Table 8 of Subpart ZZZZ to Part 63 that apply to you.
• Notifications, Reports and Records
o §63.6645(a) - If you own or operate a stationary RICE with a site rating of
more than 500 brake HP located at a major source of HAP emissions you
must submit all of the notifications in §§63.7(b) and (c), 63.8(e), (f)(4) and
(f)(6), 63.9(b) through (e), and (g) and (h) that apply to you by the dates
specified.
o §63.6645(f) - If you are required to submit an Initial Notification but are
otherwise not affected by the requirements of this subpart, in accordance with
§63.6590(b), your notification should include the information in §63.9(b)(2)(i)
through (v), and a statement that your stationary RICE has no additional
requirements and explain the basis of the exclusion (for example, that it
operates exclusively as an emergency stationary RICE if it has a site rating of
more than 500 brake HP located at a major source of HAP emissions).
o §63.6645(g) - If you are required to conduct a performance test, you must
submit a Notification of Intent to conduct a performance test at least 60 days
before the performance test is scheduled to begin as required in §63.7(b)(1).
o §63.6645(h) - If you are required to conduct a performance test or other initial
compliance demonstration as specified in Tables 4 and 5 of Subpart 7777 to
Part 63, you must submit a Notification of Compliance Status according to
§63.9(h)(2)(ii).
• §63.6645(h)(1) - For each initial compliance demonstration required in
Table 5 of Subpart ZZZZ to Part 63 that does not include a
performance test, you must submit the Notification of Compliance
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Colorado Department of Public Health and Environment
Air Pollution Control Division
Status before the close of business on the 30th day following the
completion of the initial compliance demonstration.
• §63.6645(h)(2) - For each initial compliance demonstration required in
Table 5 of Subpart 7777 to Part 63 that includes a performance test
conducted according to the requirements in Table 3 to this subpart,
you must submit the Notification of Compliance Status, including the
performance test results, before the close of business on the 60th day
following the completion of the performance test according to
§63.10(d)(2).
o §63.6650(a) - You must submit each report in Table 7 of Subpart ZZZZ to
Part 63 that applies to you.
o §63.6655(a) - If you must comply with the emission and operating limitations,
you must keep the records described in §63.6655(a)(1) through (a)(3),
§63.6655 (b)(1) through (b)(3) and §63.6655 (c).
o §63.6655(d) - You must keep the records required in Table 6 of Subpart
ZZZZ of Part 63 to show continuous compliance with each emission or
operating limitation that applies to you.
o §63.6660(a) - Your records must be in a form suitable and readily available
for expeditious review according to §63.10(b)(1).
o §63.6660(b) - 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.
o §63.6660(c) - You must keep each record readily accessible in hard copy or
electronic form on-site 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.
• Other Requirements and Information
o §63.6665 - Table 8 to this subpart shows which parts of the General
Provisions in §§63.1 through 63.15 apply to you.
OPERATING & MAINTENANCE REQUIREMENTS
23. Upon startup of these points, the owner or operator shall follow the most recent
operating and maintenance (O&M) plan and record keeping format approved by the
Division, in order to demonstrate compliance on an ongoing basis with the requirements
of this permit. Revisions to your O&M plan are subject to Division approval prior to
implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.)
24. Point 009: The inlet gas temperature and inlet gas pressure shall be measured and
recorded monthly.
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
25. Point 008 and 009: A source initial compliance test shall be conducted to measure the
emission rate(s) for the pollutants listed below in order to demonstrate compliance with
in this permit. The operator shall demonstrate the thermal oxidizer achieves a minimum
AIRS ID: 123/9966 Page 13 of 28
Colorado Department of Public Health and Environment
Air Pollution Control Division
destruction efficiency of 98.0% for VOC. The test protocol must be in accordance with
the requirements of the Air Pollution Control Division Compliance Test Manual and shall
be submitted to the Division for review and approval at least thirty (30) days prior to
testing. No compliance test shall be conducted without prior approval from the Division.
Any compliance test conducted to show compliance with a monthly or annual emission
limitation shall have the results projected up to the monthly or annual averaging time by
multiplying the test results by the allowable number of operating hours for that averaging
time (Reference: Regulation No. 3, Part B., Section III.G.3)
Volatile Organic Compounds using EPA approved methods.
Hazardous Air Pollutants using EPA approved methods.
26. Point 010: Within one hundred and eighty days (180) after commencement of operation,
the operator shall complete a hard count of components at the source and establish the
number of components that are operated in "heavy liquid service", "light liquid service",
"water/oil service" and "gas service". The operator shall submit the results to the
Division as part of the self-certification process to ensure compliance with emissions
limits.
27. Points 001-004, 007: A source initial compliance test shall be conducted on emissions
points to measure the emission rate(s) for the pollutants listed below in order to
demonstrate compliance with the emission limits in this permit. The test protocol must
be in accordance with the requirements of the Air Pollution Control Division Compliance
Test Manual and shall be submitted to the Division for review and approval at least thirty
(30) days prior to testing. No compliance test shall be conducted without prior approval
from the Division. Any compliance test conducted to show compliance with a monthly or
annual emission limitation shall have the results projected up to the monthly or annual
averaging time by multiplying the test results by the allowable number of operating hours
for that averaging time (Reference: Regulation No. 3, Part B., Section III.G.3)
Oxides of Nitrogen using EPA approved methods.
Carbon Monoxide using EPA approved methods.
Periodic Testing Requirements
28. Point 008: The owner or operator shall complete an extended wet gas analysis prior to
the inlet of the TEG dehydrator on an annual basis. Results of the wet gas analysis shall
be used to calculate emissions of criteria pollutants and hazardous air pollutants per this
permit and be provided to the Division upon request.
29. Point 009: The operator shall sample the inlet gas to the plant or the inlet gas to the
amine unit on an annual basis to determine the concentration of hydrogen sulfide (H2S)
in the gas stream. The sample results shall be monitored to demonstrate that this amine
unit qualifies for the exemption from the Standards of Performance for Onshore Natural
Gas Processing: SO2 Emissions (§60.5423(c)).
30. Points 001-004, 007: This engine is subject to the periodic testing requirements as
specified in the operating and maintenance (O&M) plan as approved by the Division.
Revisions to your O&M plan are subject to Division approval. Replacements of this unit
completed as Alternative Operating Scenarios may be subject to additional testing
requirements as specified in Attachment A.
AIRS ID: 123/9966 Page 14 of 28
Colorado Department of Public Health and Environment
Air Pollution Control Division
ADDITIONAL REQUIREMENTS
31. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation
No. 3, Part A, II.C)
a. Annually by April 30th whenever a significant increase in emissions occurs as
follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions
of five (5)tons per year or more, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions
of five percent or 50 tons per year or more, whichever is less, above the level
reported on the last APEN submitted; or
For any non-criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less,
above the level reported on the last APEN submitted to the Division.
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
c. Whenever new control equipment is installed, or whenever a different type of
control equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
f. Within 14 calendar days of commencing operation of a permanent replacement
engine under the alternative operating scenario outlined in this permit as
Attachment A. The APEN shall include the specific manufacturer, model and
serial number and horsepower of the permanent replacement engine, the
appropriate APEN filing fee and a cover letter explaining that the owner or
operator is exercising an alternative-operating scenario and is installing a
permanent replacement engine.
32. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit)
shall apply to this source at any such time that this source becomes major solely by
virtue of a relaxation in any permit condition. Any relaxation that increases the potential
to emit above the applicable Federal program threshold will require a full review of the
source as though construction had not yet commenced on the source. The source shall
not exceed the Federal program threshold until a permit is granted. (Regulation No. 3
Part D).
33. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil
and Natural Gas Production Facilities major stationary source requirements shall apply
to this stationary source at any such time that this stationary source becomes major
solely by virtue of a relaxation in any permit limitation and shall be subject to all
appropriate applicable requirements of Subpart HH. (Reference: Regulation No. 8, Part
E)
34. MACT Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines requirements shall apply to this
source at any such time that this source becomes major solely by virtue of a relaxation in
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Colorado Department of Public Health and Environment
Air Pollution Control Division
any permit limitation and shall be subject to all appropriate applicable requirements of
that Subpart on the date as stated in the rule as published in the Federal Register.
(Reference: Regulation No. 8, Part E)
GENERAL TERMS AND CONDITIONS:
35. This permit and any attachments must be retained and made available for inspection
upon request. The permit may be reissued to a new owner by the APCD as provided in
AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership
and the submittal of a revised APEN and the required fee.
36. If this permit specifically states that final authorization has been granted, then the
remainder of this condition is not applicable. Otherwise, the issuance of this construction
permit does not provide "final" authority for this activity or operation of this source. Final
authorization of the permit must be secured from the APCD in writing in accordance with
the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section
III.G. Final authorization cannot be granted until the operation or activity commences
and has been verified by the APCD as conforming in all respects with the conditions of
the permit. Once self-certification of all points has been reviewed and approved by the
Division, it will provide written documentation of such final authorization. Details for
obtaining final authorization to operate are located in the Requirements to Self-
Certify for Final Authorization section of this permit.
37. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the owner or operator and is conditioned upon conduct of the activity, or
construction, installation and operation of the source, in accordance with this information
and with representations made by the owner or operator or owner or operator's agents.
It is valid only for the equipment and operations or activity specifically identified on the
permit.
38. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with
the provisions of Section 25-7-114.5(7)(a), C.R.S.
39. Each and every condition of this permit is a material part hereof and is not severable.
Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire
permit and upon such occurrence, this permit shall be deemed denied ab initio. This
permit may be revoked at any time prior to self-certification and final authorization by the
Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality
Control Act and regulations of the Air Quality Control Commission (AQCC), including
failure to meet any express term or condition of the permit. If the Division denies a
permit, conditions imposed upon a permit are contested by the owner or operator, or the
Division revokes a permit, the owner or operator or owner or operator of a source may
request a hearing before the AQCC for review of the Division's action.
40. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
41. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution
Prevention and Control Act or the regulations of the AQCC may result in administrative,
AIRS ID: 123/9966 Page 16 of 28
Colorado Department of Public Health and Environment
Air Pollution Control Division
civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121
(injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S.
By:
....
Stuart Siffring
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Sterling Energy Investments LLC.
New Synthetic Minor Gas Plant.
AIRS ID: 123/9966 Page 17 of 28
Colorado Department of Public Health and Environment
Air Pollution Control Division
Notes to Permit Holder at the time of this permit issuance:
1) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN)
and complete application form must be submitted with a request for a permit revision.
2) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written notice
to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions
Regulation. See:
http://www.cdohe.state co.us/requlations/airregs/100102agcccommonprovisionsreq.pdf.
3) The following emissions of non-criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis
of the specific compounds emitted if the source(s) operate at the permitted limitations.
Uncontrolled Are the Controlled
AIRS Pollutant CAS# Emission
BIN Rate emissions Emission
Point (Ib/yr) reportable? Rate (lb/yr)
Formaldehyde 5000 A 2336 Yes 2336
Acetaldehyde 75070 A 318 Yes 318
001
Acrolein 107028 A 300 Yes 300
Benzene 71432 A 180 Yes 180
Formaldehyde 5000 A 2336 Yes 2336
Acetaldehyde 75070 A 318 Yes 318
002
Acrolein 107028 A 300 Yes 300
Benzene 71432 A 180 Yes 180
Formaldehyde 5000 A 2336 Yes 2336
Acetaldehyde 75070 A 318 Yes 318
003
Acrolein 107028 A 300 Yes 300
Benzene 71432 A 180 Yes 180
Formaldehyde 5000 A 2336 Yes 2336
Acetaldehyde 75070 A 318 Yes 318
004
Acrolein 107028 A 300 Yes 300
Benzene 71432 A 180 Yes 180
005 Formaldehyde 5000 A 292 Yes 292
Formaldehyde 5000 A 504 Yes 504
006 Acetaldehyde 75070 A 69 Yes 69
Acrolein 107028 A 65 Yes 65
AIRS ID: 123/9966 Page 18 of 28
Colorado Department of Public Health and Environment
Air Pollution Control Division
Formaldehyde 5000 A 777 Yes 777
Acetaldehyde 75070 A 106 Yes 106
007
Acrolein 107028 A 100 Yes 100
Benzene 71432 A 60 Yes 60
Benzene 71432 A 9490 Yes 95
008 Toluene 108883 C 5150 Yes 52
n-Hexane 110543 C 8850 Yes 89
Benzene 71432 A 13100 Yes 131
009 Toluene 108883 C 5550 Yes 56
n-Hexane 110543 C 1450 Yes 15
010 Benzene 71432 A 78 Yes 78
4) The emission levels contained in this permit are based on the following emission factors:
Points 001-004:
Emission Factors - Emission Factors—
Uncontrolled Controlled
CAS Pollutant lb/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr
NOx 3.78 13.3 0.095 0.30
CO 3.18 11.2 0.095 0.30
VOC 9.9E-2 0.35 3.6E-2 0.13
5000 Formaldehyde 2.05E-2 7.2E-2 2.05E-2 7.2E-2
75070 Acetaldehyde 2.7E-3 9.8E-3 2.7E-3 9.8E-3
107028 Acrolein 0.00263 9.2E-3 0.00263 9.2E-3
71432 Benzene 0.00158 5.5E-3 0.00158 5.5E-3
Emission factors are based on a Brake-Specific Fuel Consumption Factor of 7744 Btu/hp-hr, a
site-rated horsepower value of 1680, and a fuel heat value of 1160 Btu/scf.
Emission Factor Sources:
CAS Pollutant Uncontrolled EFSource Controlled EF
Source
NOx Manufacturer Manufacturer
CO Manufacturer Manufacturer
VOC Manufacturer Manufacturer
5000 Formaldehyde AP-42; Table 3.2-3 (7/2000); Natural Gas No Control
75070 Acetaldehyde AP-42; Table 3.2-3 (7/2000); Natural Gas No Control
107028 Acrolein AP-42; Table 3.2-3 (7/2000); Natural Gas No Control
71432 Benzene AP-42; Table 3.2-3 (7/2000); Natural Gas No Control
Point 005:
Emission Factors - Emission Factors—
Uncontrolled Controlled
CAS Pollutant lb/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr
NOx 6.93 23.07 9.0E-2 0.30
CO 0.47 1.6 8.91E-2 0.30
VOC 3.27E-2 0.12 3.27E-2 0.12
5000 Formaldehyde 2.05E-2 6.87E-2 2.05E-2 6.87E-2
AIRS ID: 123/9966 Page 19 of 28
Colorado Department of Public Health and Environment
Air Pollution Control Division
Emission factors are based on a Brake-Specific Fuel Consumption Factor of 7396 Btu/hp-hr, a site-
rated horsepower value of 220, and a fuel heat value of 1160 Btu/scf.
Emission Factor Sources:
CAS Pollutant Uncontrolled EFSource Controlled EF
Source
NOx Manufacturer Manufacturer
CO Manufacturer Manufacturer
VOC Manufacturer Manufacturer
5000 Formaldehyde AP-42; Table 3.2-3 (7/2000); Natural Gas No Control
Point 006:
Emission Factors - Emission Factors—
Uncontrolled Controlled
CAS Pollutant lb/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr
NOx 7.32 26.27 9.51E-2 0.30
CO 0.50 1.6 9.41E-2 0.30
VOC 3.46E-2 0.16 2.81E-2 0.13
5000 Formaldehyde 2.05E-2 6.51E-2 2.05E-2 6.51E-2
75070 Acetaldehyde 2.79E-3 8.86E-3 2.79E-3 8.86E-3
107028 Acrolein 0.00263 8.36E-3 0.00263 8.36E-3
Emission factors are based on a Brake-Specific Fuel Consumption Factor of 7008 Btu/hp-hr, a site-
rated horsepower value of 400, and a fuel heat value of 1160 Btu/scf.
Emission Factor Sources:
CAS Pollutant Uncontrolled EFSource Controlled EF
Source
NOx Manufacturer Manufacturer
CO Manufacturer Manufacturer
VOC Manufacturer Manufacturer
5000 Formaldehyde AP-42; Table 3.2-3 (7/2000); Natural Gas No Control
75070 Acetaldehyde AP-42; Table 3.2-3 (7/2000); Natural Gas No Control
107028 Acrolein AP-42; Table 3.2-3 (7/2000); Natural Gas No Control
Point 007:
Emission Factors- Emission Factors—
Uncontrol led Controlled
CAS Pollutant lb/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr
NOx 7.11 23.27 9.25E-2 0.30
CO 0.49 1.6 9.14E-2 0.30
VOC 3.36E-2 0.11 3.36E-2 0.11
5000 Formaldehyde 2.05E-2 0.067 2.05E-2 0.067
75070 Acetaldehyde 2.79E-3 9.12E-3 2.79E-3 9.12E-3
107028 Acrolein 0.00263 8.60E-3 0.00263 8.601E-3
71432 Benzene 0.00158 5.16E-3 0.00158 5.16E-3
Emission factors are based on a Brake-Specific Fuel Consumption Factor of 7210 Btu/hp-hr, a site-
rated horsepower value of 600, and a fuel heat value of 1160 Btu/scf.
Emission Factor Sources:
CAS Pollutant Uncontrolled EFSource Controlled EF
Source
NOx Manufacturer Manufacturer
CO Manufacturer Manufacturer
VOC Manufacturer Manufacturer
AIRS ID: 123/9966 Page 20 of 28
Colorado Department of Public Health and Environment
Air Pollution Control Division
CAS Pollutant Uncontrolled EFSource Controlled EF
Source
5000 Formaldehyde AP-42; Table 3.2-3 (7/2000); Natural Gas No Control
75070 Acetaldehyde AP-42; Table 3.2-3 (7/2000); Natural Gas No Control
107028 Acrolein AP-42; Table 3.2-3 (7/2000); Natural Gas No Control
71432 Benzene AP-42; Table 3.2-3 (7/2000); Natural Gas No Control
Point 008:
The emission levels contained in this permit are based on the following emission factors:
Emission Factors Emission Factors
CAS# Pollutant Uncontrolled Controlled Source
Ib/MMscf Natural Ib/MMscf Natural
Gas Throughput Gas Throughput
VOC 35.1 0.354 Promax
110543 n-Hexane 2.44 0.022 Promax
71432 Benzene 2.62 0.027 Promax
108883 Toluene 1.43 0.016 Promax
Note: The controlled emissions factors for point 009 are based on the thermal oxidizer control
efficiency of 99%.
Point 009:
The emission levels contained in this permit are based on the following emission factors:
Emission Factors Emission Factors
CAS# Pollutant Uncontrolled Controlled Source
lb/MMscf Natural lb/MMscf Natural
Gas Throughput Gas Throughput
VOC 28.47 0.287 Promax
71432 Benzene 3.618 0.0387 Promax
108883 Toluene 1.535 0.0166 Promax
Note: The controlled emissions factors for point 009 are based on the thermal oxidizer control
efficiency of 99%.
Point 010:
Component Gas Service Heavy Oil Light Oil ervi
S Water/Oil
Service
Connectors 1472 0 1844 0
Flanges 568 0 791 0
Open-ended Lines 62 0 87 0
Pump Seals 0 0 0 0 _
Valves 627 0 785 0
Other* 80 0 87 0
VOC Content(wt%) 33.8161903 100 100 100
Benzene Content(wt%) 8.73E-2 0 8.73E-2 0
Toluene Content(wt%) 4.08E-2 0 4.08E-2 0
Ethylbenzene(wt%) 3.05E-3 0 3.05E-3 0
Xylenes Content(wt%) 7.40E-3 0 7.40E-3 0
n-hexane Content(wt%) 0.495 0 0.495 0
AIRS ID: 123/9966 Page 21 of 28
Colorado Department of Public Health and Environment
Air Pollution Control Division
*Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms,
drains, dump arms, hatches, instrument meters, polish rods and vents
TOC Emission Factors(kg/hr-component):
Component Gas Service Heavy Oil Light Oil ervi
Servi Water/Oil
Service
Connectors 2.0E-04 7.5E-06 2.1E-04 1.1E-04
Flanges 3.9E-04 3.9E-07 1.1E-04 2.9E-06
Open-ended Lines 2.0E-03 1.4E-04 1.4E-03 2.5E-04
Pump Seals 2.4E-03 NA 1.3E-02 2.4E-05
Valves 4.5E-03 8.4E-06 2.5E-03 9.8E-05
Other 8.8E-03 3.2E-05 7.5E-03 1.4E-02
Source: EPA-453/R95-017
Compliance with emissions limits in this permit will be demonstrated by using the TOC emission
factors listed in the table above with representative component counts, multiplied by the VOC content
from the most recent gas analysis.
5) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice(APEN)associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the
most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division at
(303)-692-3150.
6) Points 001-004, 007: This engine is subject to 40 CFR, Part 60, Subpart JJJJ—Standards of
Performance for Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008
Federal Register posting — effective March 18, 2008). This rule has not yet been incorporated into
Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is
available on the EPA website at: http://www.epa.gov/ttn/atw/area/fr18ia08.pdf
7) Points 001-004, 007: This engine is subject to 40 CFR, Part 63, Subpart ZZZZ- National Emission
Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See
January 18, 2008 Federal Register posting - effective March 18, 2008). The January 18, 2008
amendments to include requirements for area sources and engines < 500 hp located at major
sources have not yet been incorporated into Colorado Air Quality Control Commission's Regulation
No. 8. A copy of the complete subpart is available on the EPA website at:
http://www.epa.gov/ttn/atw/area/fr18ja08.pdf Additional information regarding area source standards
can be found on the EPA website at: http://www.epa.qov/ttn/atw/area/arearules.html
8) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of:
NOx, CO, VOC
PSD Synthetic Minor Source of:
NOx, CO
MACT ZZZZ Area Source Requirements: Not Applicable
AIRS ID: 123/9966 Page 22 of 28
Colorado Department of Public Health and Environment
Air Pollution Control Division
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A—Subpart KKKK
NSPS Part 60,Appendixes Appendix A—Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT 63.1-63.599 Subpart A—Subpart Z
MACT 63.600-63.1199 Subpart AA—Subpart DDD
MACT 63.1200-63.1439 Subpart EEE—Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM
MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX
10) An Oil and Gas Industry Construction Permit Self-Certification Form is included with this permit
packet. Please use this form to complete the self-certification requirements as specified in the permit
conditions. Further guidance on self-certification can be found on our website at:
htto://wvvwcdphe.state.co.us/ap/oiloaspermittinghtml
AIRS ID: 123/9966 Page 23 of 28
Colorado Department of Public Health and Environment
Air Pollution Control Division
ATTACHMENT A:
ALTERNATIVE OPERATING SCENARIOS
RECIPROCATING INTERNAL COMBUSTION ENGINES
October 12, 2012
2. Alternative Operating Scenarios
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 owner
or operator shall be allowed to perform such engine replacement without applying for a revision to this
permit or obtaining a new Construction Permit.
2.1 Engine Replacement
The following AOS is incorporated into this permit in order to deal with a compressor engine breakdown
or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a
temporary or permanent replacement engine. "Temporary" is defined as in the same service for 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).
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 owner or operator 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. In addition to the log, the
owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make
them available to the Division upon request.
2.1.1 The owner or operator may temporarily replace an existing compressor engine that is subject to
the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and
horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying
this permit, so long as the temporary replacement engine complies with all permit limitations and other
requirements applicable to the existing engine. Measurement of emissions from the temporary
replacement engine shall be made as set forth in section 2.2.
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Colorado Department of Public Health and Environment
Air Pollution Control Division
2.1.2 The owner or operator may permanently replace the existing compressor engine with another
engine with the same manufacturer, model, and horsepower engines without modifying this permit so
long as the permanent replacement engine complies with all permit limitations and other requirements
applicable to the existing engine as well as any new applicable requirements for the replacement engine.
Measurement of emissions from the permanent replacement engine and compliance with the applicable
emission limitations shall be made as set forth in section 2.2.
An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial
number and horsepower of the permanent replacement engine shall be filed with the Division for the
permanent replacement engine within 14 calendar days of commencing operation of the replacement
engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that
the owner or operator is exercising an alternative operating scenario and is installing a permanent
replacement engine, and a copy of the relevant Applicability Reports for the replacement engine.
Example Applicability
Reports can be found at http://www.cdphe.state.co.us/ap/oilgaspermitting.html. This submittal shall be
accompanied by a certification from the Responsible Official indicating that"based on the information and
belief formed after reasonable inquiry, the statements and information included in the submittal are true,
accurate and complete".
This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine
or an engine that is not subject to emission limits.
The owner or operator shall agree to pay fees based on the normal permit processing rate for review of
information submitted to the Division in regard to any permanent engine replacement.
2.2 Portable Analyzer Testing
Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping
Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss
streamlining the testing requirements.
Note that the testing required by this Condition may be used to satisfy the periodic testing requirements
specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer
testing, this test conducted under the AOS will serve as the quarterly test and an additional portable
analyzer test is not required for another three months).
The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required
by this Condition, if approved in advance by the Division.
The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the
exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of
commencing operation of the replacement engine.
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 web site at:
http://www.colorado.qov/cs/Satellite/C DPH E-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 (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.
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Colorado Department of Public Health and Environment
Air Pollution Control Division
For comparison with a short-term limit that is either input based (Ib/mmBtu), output based (g/hp-hr) or
concentration based (ppmvd @ 15% 02) that the existing unit is currently subject to or the replacement
engine will be subject to, the results of the test shall be converted to the appropriate units as described in
the above-mentioned Portable Analyzer Monitoring Protocol document.
If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the
absence of credible evidence to the contrary, the source may certify that the engine is in compliance with
both the NOX and CO emission limitations for the relevant time period.
Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if
the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission
limitations, the engine will be considered to be out of compliance from the date of the portable analyzer
test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or
until the engine is taken offline.
2.3 Applicable Regulations for Permanent Engine Replacements
2.3.1 Reasonably Available Control Technology(RACT): Reg 3, Part B § II.D2
All permanent replacement engines that are located in an area that is classified as
attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT)
for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and
NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which
the area is in attainment/maintenance or nonattainment, except as follows:
In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of
emissions and to NOX and SO2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds
40 tons/yr.
For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating
internal combustion engines:
VOC: The emission limitations in NSPS JJJJ
CO: The emission limitations in NSPS JJJJ
NOX: The emission limitations in NSPS JJJJ
SO2: Use of natural gas as fuel
PM10: Use of natural gas as fuel
As defined in 40 CFR Part 60 Subparts GG (§60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains
20.0 grains or less of total sulfur per 100 standard cubic feet.
2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State-
Only conditions).
Control Requirements: Section XVI
Any permanent replacement engine located within the boundaries of an ozone nonattainment area is
subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified
below:
Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non-
selective catalyst and air fuel controller to reduce emission.
Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation
catalyst to reduce emissions.
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Colorado Department of Public Health and Environment
Air Pollution Control Division
The above emission control equipment shall be appropriately sized for the engine and shall be operated
and maintained according to manufacturer specifications.
The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2,
Emission Standards: Section XVII.E—State-only requirements
Any permanent engine that is either constructed or relocated to the state of Colorado from another state,
after the date listed in the table below shall operate and maintain each engine according to the
manufacturer's written instructions or procedures to the extent practicable and consistent with
technological limitations and good engineering and maintenance practices over the entire life of the
engine so that it achieves the emission standards required in the table below:
Construction or Emission Standards in G/hp-hr
Max Engine HP Relocation Date
NOx CO VOC
January 1, 2008 2.0 4.0 1.0
100<Hp<500 January 1, 2011 1.0 2.0 0.7
July 1, 2007 2.0 4.0 1.0
500<Hp
July 1, 2010 1.0 2.0 0.7
The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2.
2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ
A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater
than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp
except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for
lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements
of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting
requirements for the permanent engine replacement shall be included in the Applicability Reports
required under Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this
AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this
AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted
within the time frame specified in Condition 2.2.
Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from
outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to
the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes
equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ
requirements).
However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does,
any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ,
there will be an additional step added to the determination of the NSPS. Under the provisions of
Regulation No. 6, Part B, § LB (which is referenced in Pad A), any engine relocated from outside of the
State of Colorado into the State of Colorado is considered to be a new source, subject to the
requirements of NSPS JJJJ.
2.3.4 Reciprocating internal combustion engine(RICE) MACT: 40 CFR Part 63, Subpart ZZZZ
A permanent replacement engine located at either an area or major source is subject to the requirements
in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting
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Colorado Department of Public Health and Environment
Air Pollution Control Division
requirements for the permanent engine replacement shall be included in the Applicability Reports
required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this
AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under
Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time
frame specified in Condition 2.2.
2.4 Additional Sources
The replacement of an existing engine with a new engine is viewed by the Division as the installation of a
new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an
advanced construction permit review. The AOS cannot be used for additional new emission points for any
site; an engine that is being installed as an entirely new emission point and not as part of an AOS-
approved replacement of an existing onsite engine has to go through the appropriate
Construction/Operating permitting process prior to installation.
AIRS ID: 123/9966 Page 28 of 28
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