HomeMy WebLinkAboutSVCS Air Permit 13GA2428
AIRS ID: 045/2325 Page 1 of 18
NGEngine Version 2012-1
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO: 13GA2428
Issuance 1
DATE ISSUED: January 28, 2014
ISSUED TO: Rocky Mountain Natural Gas, LLC
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the Spring Valley Compressor Station, located in NWNE
Section 3, Township 7S, Range 88W, in Garfield County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment ID
AIRS
Point Description
849 001
One (1) Waukesha, Model P 9390 GSI, Serial Number
5283701783, natural gas-fired, naturally aspirated, 4SRB
reciprocating internal combustion engine, site rated at 1970
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.
850 002
One (1) Waukesha, Model P 9390 GSI, Serial Number
5283701802, natural gas-fired, naturally aspirated, 4SRB
reciprocating internal combustion engine, site rated at 1970
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.
G-100 003
One (1) Generac, Model SG 300, Serial Number 2117900,
natural gas-fired, naturally aspirated, 4SRB reciprocating
internal combustion engine, site rated at 454 horsepower at
2300 RPM. This engine shall be equipped with a non-
selective catalytic reduction (NSCR) system and air-fuel ratio
control. This emission unit is used as an emergency backup
generator
EL 005 Equipment leaks (fugitive VOCs) from a natural gas
compressor station.
Colorado Department of Public Health and Environment
Air Pollution Control Division
AIRS ID: 045/2325 Page 2 of 18
Points 001 and 002: These engines may be replaced with another engine in accordance
with the temporary engine replacement provision or with another Waukesha P 9390 GSI
engine in accordance with the permanent replacement provision of the Alternate Operating
Scenario (AOS), included in this permit as Attachment A.
Point 003: These engines may be replaced with another engine in accordance with the
temporary engine replacement provision or with another Generac SG 300 engine in
accordance with the permanent replacement provision of the Alternate Operating Scenario
(AOS), included in this permit as Attachment A.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO
AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS
INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than
fifteen days 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; (ii) discontinues construction for a period
of eighteen months or more; (iii) does not complete construction within a reasonable
time of the estimated completion date. The Division may grant extensions of the
deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B,
III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self-certification process.
(Reference: Regulation No. 3, Part B, Section III.E.)
5. The following information shall be provided to the Division within fifteen (15) days after
commencement of operation.
manufacture date
construction date
order date
date of relocation into Colorado
This information shall be included with the Notice of Startup submitted for the equipment.
(Reference: Regulation No. 3, Part B, III.E.)
Colorado Department of Public Health and Environment
Air Pollution Control Division
AIRS ID: 045/2325 Page 3 of 18
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
Equipment ID
AIRS
Point
Pounds per Month Emission Type NOx VOC CO
849 001 2262 2262 4847 Point
850 002 2262 2262 4847 Point
G-100 003 522 522 1117 Point
EL 005 --- 1836 --- Fugitives
(Note: Monthly limits are based on a 31-day month.)
The owner or operator shall calculate monthly emissions based on the calendar month.
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year Emission Type NOx VOC CO
849 001 13.3 13.3 28.5 Point
850 002 13.3 13.3 28.5 Point
G-100 003 3.1 3.1 6.6 Point
EL 005 --- 10.8 --- Fugitives
See “Notes to Permit Holder” for information on emission factors and methods used to calculate
limits.
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 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.)
Colorado Department of Public Health and Environment
Air Pollution Control Division
AIRS ID: 045/2325 Page 4 of 18
Facility
Equipment
ID
AIRS
Point Control Device Pollutants
Controlled
849 001 Non-selective catalytic reduction (NSCR) system
and air/fuel ratio controller NOx and CO
850 002 Non-selective catalytic reduction (NSCR) system
and air/fuel ratio controller NOx and CO
G-100 003 Non-selective catalytic reduction (NSCR) system
and air/fuel ratio controller NOx and CO
9. Point 005: The operator shall calculate actual emissions from this emissions point
based on representative component counts for the facility with the most recent gas and
liquids analyses, 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.
PROCESS LIMITATIONS AND RECORDS
10. 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
Equipment
ID
AIRS
Point Process Parameter Annual
Limit
Monthly Limit
(31 days)
849 001 Consumption of natural gas as a fuel 142.9
MMscf/yr
12.1
MMscf/month
850 002 Consumption of natural gas as a fuel 142.9
MMscf/yr
12.1
MMscf/month
G-100 003 Consumption of natural gas as a fuel 34.5
MMscf/yr
2.9
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.
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.
STATE AND FEDERAL REGULATORY REQUIREMENTS
11. 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)
Colorado Department of Public Health and Environment
Air Pollution Control Division
AIRS ID: 045/2325 Page 5 of 18
12. 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.)
13. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
OPERATING & MAINTENANCE REQUIREMENTS
14. Points 001-003: 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.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
15. Points 001-003: A source initial compliance test shall be conducted on emissions
points 001, 002 and 003 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.
Volatile Organic Compounds using EPA approved methods.
Formaldehyde
16. Point 005: Within one hundred and eighty days (180) after commencement of
operation, the owner or operator shall complete the initial extended gas analysis of gas
samples and extended natural gas liquids analysis of liquids that are representative of
volatile organic compound (VOC) and hazardous air pollutants (HAP) that may be
released as fugitive emissions. This extended gas and liquids analyses shall be used in
the compliance demonstration as required in the Emission Limits and Records section of
this permit. The operator shall submit the results of the gas and liquids analyses and
emission calculations to the Division as part of the self-certification process to ensure
compliance with emissions limits.
17. Point 005: 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
Colorado Department of Public Health and Environment
Air Pollution Control Division
AIRS ID: 045/2325 Page 6 of 18
results to the Division as part of the self-certification process to ensure compliance with
emissions limits.
Periodic Testing Requirements
18. Points 001-003: These engines are 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.
19. Point 005: On an annual basis, the owner or operator shall complete an extended gas
analysis of gas samples and an extended natural gas liquids analysis of liquids that are
representative of volatile organic compounds (VOC) and hazardous air pollutants (HAP)
that may be released as fugitive emissions. This extended gas and liquids analyses
shall be used in the compliance demonstration as required in the Emission Limits and
Records section of this permit.
ADDITIONAL REQUIREMENTS
20. 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. Points 001-003: 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.
Colorado Department of Public Health and Environment
Air Pollution Control Division
AIRS ID: 045/2325 Page 7 of 18
21. 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).
GENERAL TERMS AND CONDITIONS:
22. 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.
23. 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.
24. 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.
25. 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.
26. Each and every condition of this permit is a material part hereof and is not severable.
Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire
permit and upon such occurrence, this permit shall be deemed denied ab initio. This
permit may be revoked at any time prior to self-certification and final authorization by the
Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality
Control Act and regulations of the Air Quality Control Commission (AQCC), including
failure to meet any express term or condition of the permit. If the Division denies a
permit, conditions imposed upon a permit are contested by the owner or operator, or the
Division revokes a permit, the owner or operator of a source may request a hearing
before the AQCC for review of the Division’s action.
27. 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
Colorado Department of Public Health and Environment
Air Pollution Control Division
AIRS ID: 045/2325 Page 8 of 18
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
28. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution
Prevention and Control Act or the regulations of the AQCC may result in administrative,
civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121
(injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S.
By:
Stephanie Chaousy, PE
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Rocky Mountain Natural Gas, LLC.
Newly permitted compressor station with three
reciprocating internal combustion engines and
associated fugitives. Synthetic minor facility.
Colorado Department of Public Health and Environment
Air Pollution Control Division
AIRS ID: 045/2325 Page 9 of 18
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these
fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of
receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference:
Regulation No. 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN)
and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written notice
to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions
Regulation. See:
http://www.cdphe.state.co.us/regulations/airregs/100102aqcccommonprovisionsreg.pdf.
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis
of the specific compounds emitted if the source(s) operate at the permitted limitations.
AIRS
Point
Pollutant CAS # BIN
Uncontrolled
Emission
Rate
(lb/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (lb/yr)
001
Formaldehyde 50000 A 1902 Yes 1902
Methanol 67561 C 437 No 437
Acetaldehyde 75070 A 399 Yes 399
Acrolein 107028 A 376 Yes 376
Benzene 71432 A 226 Yes 226
1,3-Butadiene 106990 A 95 Yes 95
Toluene 108883 C 80 No 80
002
Formaldehyde 50000 A 1902 Yes 1902
Methanol 67561 C 437 No 437
Acetaldehyde 75070 A 399 Yes 399
Acrolein 107028 A 376 Yes 376
Benzene 71432 A 226 Yes 226
1,3-Butadiene 106990 A 95 Yes 95
Toluene 108883 C 80 No 80
003
Formaldehyde 50000 A 707 Yes 707
Methanol 67561 C 106 No 106
Acetaldehyde 75070 A 96 Yes 96
Colorado Department of Public Health and Environment
Air Pollution Control Division
AIRS ID: 045/2325 Page 10 of 18
Acrolein 107028 A 91 Yes 91
Benzene 71432 A 55 Yes 55
1,3-Butadiene 106990 A 23 No 23
Toluene 108883 C 19 No 19
005
Benzene 71432 A 195 Yes 195
Toluene 108883 C 222 No 222
Ethylbenzene 100414 C 6 No 6
Xylenes 1330207 C 72 No 72
n-Hexane 110543 C 1318 Yes 1318
5) The emission levels contained in this permit are based on the following emission factors:
Points 001 and 002:
Emission Factors -
Uncontrolled
Emission Factors –
Controlled
CAS Pollutant lb/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr
NOx 3.4622 13 0.1864 0.7
CO 2.3969 9 0.3995 1.5
VOC 0.1864 0.7 0.1864 0.7
50000 Formaldehyde 0.0133 0.05 0.0133 0.05
67561 Methanol 0.0031 0.0115 0.0031 0.0115
75070 Acetaldehyde 0.0028 0.0105 0.0028 0.0105
107028 Acrolein 0.0026 0.0099 0.0026 0.0099
71432 Benzene 0.0016 0.0059 0.0016 0.0059
106990 1,3-Butadiene 0.0007 0.0025 0.0007 0.0025
108883 Toluene 0.0006 0.0021 0.0006 0.0021
Emission factors are based on a Brake-Specific Fuel Consumption Factor of 8278 Btu/hp-hr, a
site-rated horsepower value of 1970, and a fuel heat value of 1000 Btu/scf.
Emission Factor Sources:
CAS Pollutant Uncontrolled EFSource Controlled EF Source
NOx Manufacturer Manufacturer
CO Manufacturer Manufacturer
VOC Regulation Regulation
50000 Formaldehyde Manufacturer Manufacturer
Point 003:
Emission Factors -
Uncontrolled
Emission Factors –
Controlled
CAS Pollutant lb/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr
NOx 2.27 8.9333 0.1779 0.7
CO 3.72 14.6396 0.3812 1.5
VOC 0.1779 0.7 0.1779 0.7
50000 Formaldehyde 0.0205 0.0807 0.0205 0.0807
67561 Methanol 0.0031 0.0120 0.0031 0.0120
75070 Acetaldehyde 0.0028 0.0110 0.0028 0.0110
107028 Acrolein 0.0026 0.0104 0.0026 0.0104
Colorado Department of Public Health and Environment
Air Pollution Control Division
AIRS ID: 045/2325 Page 11 of 18
Emission Factors -
Uncontrolled
Emission Factors –
Controlled
CAS Pollutant lb/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr
71432 Benzene 0.0016 0.0062 0.0016 0.0062
106990 1,3-Butadiene 0.0007 0.0026 0.0007 0.0026
108883 Toluene 0.0006 0.0022 0.0006 0.0022
Emission factors are based on a Brake-Specific Fuel Consumption Factor of 8676 Btu/hp-hr, a
site-rated horsepower value of 454, and a fuel heat value of 1000 Btu/scf.
Emission Factor Sources:
CAS Pollutant Uncontrolled EFSource Controlled EF Source
NOx AP-42, Table 3.2-3 AP-42, Table 3.2-3
CO AP-42, Table 3.2-3 AP-42, Table 3.2-3
VOC Regulation Regulation
50000 Formaldehyde AP-42 AP-42, Table 3.2-3
Point 005:
Component Gas Service Heavy Oil Light Oil Water/Oil
Service
Connectors 1400 0 380 0
Flanges 240 0 25 0
Open-ended Lines 40 0 2 0
Pump Seals 0 0 2 0
Valves 275 0 70 0
Other* 200 0 65 0
VOC Content (wt.
fraction) 0.1114 1 0.9491 1
Benzene Content (wt.
fraction) 0.0006 0 0.0104 0
Toluene Content (wt.
fraction) 0.0007 0 0.0117 0
Ethylbenzene (wt.
fraction) 0 0 0.0004 0
Xylenes Content (wt.
fraction) 0.0003 0 0.0035 0
n-hexane Content (wt.
fraction) 0.0022 0 0.0784 0
*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 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
Colorado Department of Public Health and Environment
Air Pollution Control Division
AIRS ID: 045/2325 Page 12 of 18
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 and liquids analyses.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the
most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division at
(303)-692-3150.
7) Points 001-003: These engines are 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.gov/ttn/atw/area/arearules.html Points 001-003:
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/fr18ja08.pdf
8) This facility is classified as follows:
Applicable
Requirement Status
Operating Permit Synthetic Minor Source of:
NOx, CO
PSD Synthetic Minor Source of:
NOx, CO
MACT ZZZZ Area Source Requirements: Applicable
NSPS JJJJ Applicable
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
Colorado Department of Public Health and Environment
Air Pollution Control Division
AIRS ID: 045/2325 Page 13 of 18
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:
www.colorado.gov/cdphe/oilgaspermits
Colorado Department of Public Health and Environment
Air Pollution Control Division
AIRS ID: 045/2325 Page 14 of 18
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.
Colorado Department of Public Health and Environment
Air Pollution Control Division
AIRS ID: 045/2325 Page 15 of 18
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.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 (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.
Colorado Department of Public Health and Environment
Air Pollution Control Division
AIRS ID: 045/2325 Page 16 of 18
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
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.D.2
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.
Colorado Department of Public Health and Environment
Air Pollution Control Division
AIRS ID: 045/2325 Page 17 of 18
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:
Max Engine HP Construction or
Relocation Date
Emission Standards in G/hp-hr
NOX CO VOC
100<Hp<500 January 1, 2008 2.0 4.0 1.0
January 1, 2011 1.0 2.0 0.7
500<Hp July 1, 2007 2.0 4.0 1.0
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, § I.B (which is referenced in Part 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
Colorado Department of Public Health and Environment
Air Pollution Control Division
AIRS ID: 045/2325 Page 18 of 18
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.