TECHNICAL REVIEW DOCUMENT For DRAFT RENEWAL OF … · Vanguard Operating, LLC – Bailey Compressor Station Operating Permit No. 09OPGA339 Technical Review Document – Renewal Operating

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TECHNICAL REVIEW DOCUMENT For

DRAFT RENEWAL OF OPERATING PERMIT 09OPGA339

Vanguard Operating, LLC – Bailey Compressor Station Garfield County

Source ID 045-1477

February 2018 – Date

Operating Permit Engineer: Elie Schuchardt Operating Permit Supervisor review: Blue Parish Field Services Unit review: Dida Osborne

I. PURPOSE

This document establishes the basis for decisions made regarding the applicable requirements, emission factors, monitoring plan and compliance status of emission units covered by the renewed Operating Permit for the Bailey Compressor Station. The previous Operating Permit for this facility was issued on 6/1/2012, was last revised on 2/9/2017 and expired on 6/1/2017. However, since a timely and complete renewal application was submitted, under Colorado Regulation No. 3, Part C, Section IV.C all of the terms and conditions of the existing permit shall not expire until the renewal operating permit is issued and any previously extended permit shield continues in full force and operation.

Prior to submittal of the renewal application, the source submitted an application on 3/2/2015 (via email) requesting that the permit be modified to require annual sampling of the dehydration inlet gas sample, as emissions of BTEX are minimal and well below all thresholds in the tiered sampling approach set forth in the 6/1/2012 issuance of the operating permit. Since this modification involves a reduction in monitoring frequency, the modification must be processed as a significant modification as required by Colorado Regulation No. 3, Part C, Section I.A.7.c. A significant modification is processed under the same procedures as a renewal, i.e. it must go through a 30-day public comment period and EPA 45-day review period. Therefore, since the renewal application has been submitted the Division is incorporating the modification with the renewal.

This document is designed for reference during the review of the proposed permit by the EPA, the public, and other interested parties. The conclusions made in this report are based on information provided in the original application submitted on 5/31/2016, comments on the draft permit submitted on 9/18/2018, previous inspection reports and various email correspondence, as well as telephone conversations with the applicant. Please note that copies of the Technical Review Document for the original permit and any Technical Review Documents associated with subsequent modifications of the original Operating Permit may be found in the Division files as well as on the Division website at http://www.colorado.gov/cdphe/airTitleV. This narrative is intended only as an adjunct for the reviewer and has no legal standing.

Vanguard Operating, LLC – Bailey Compressor Station Operating Permit No. 09OPGA339 Technical Review Document – Renewal Operating Permit

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Any revisions made to the underlying construction permits associated with this facility made in conjunction with the processing of this operating permit application have been reviewed in accordance with the requirements of Regulation No. 3, Part B, Construction Permits, and have been found to meet all applicable substantive and procedural requirements. This operating permit incorporates and shall be considered to be a combined construction/operating permit for any such revision, and the permittee shall be allowed to operate under the revised conditions upon issuance of this operating permit without applying for a revision to this permit or for an additional or revised construction permit.

II. DESCRIPTION OF SOURCE

The Bailey Compressor Station is a natural gas compression facility as defined under Standard Industrial Classification 1311. The facility gathers gas from surrounding well sites via a gathering pipeline system. The gas undergoes a physical separation process in the inlet separator, which separates the gas from the liquids. The liquids go to the five (5) on-site storage tanks (AIRS 006) and is subsequently loaded into trucks (AIRS 009). The gas then goes to the compression stage (AIRS 001, 004, 012) where it is compressed from field pressure to approximately 1000 psi. The compressed gas then goes through the four (4) TEG dehydration units (AIRS 005, 010, 011, 014) to remove water to meet pipeline specifications. The dehydrated gas is then routed to the sales gas pipeline.

Emission control devices include: six (6) oxidation catalyst beds for each compressor engine, four (4) condensers to aid in the control of the each TEG dehydration unit still vent, one (1) vapor recovery unit (VRU) to recompress and recycle emissions from the condensate storage tanks and TEG dehydration units to the plant inlet, and one (1) facility flare (AIRS 008) used to combust emissions from the condensate storage tanks and TEG dehydration units during periods of VRU downtime.

The facility is located approximately 5 miles south of Silt in Garfield County on Alta Mesa Road. The area in which the plant operates is designated as attainment for all criteria pollutants.

There are no affected states within 50 miles of the plant. The following Federal Class I designated area is within 100 kilometers of the plant: Black Canyon of the Gunnison National Park, West Elk Wilderness Area, Flattops Wilderness Area, Eagles Nest Wilderness Area and Maroon Bells – Snowmass Wilderness Area.

Emissions (in tons/yr) at the facility are as follows:

AIRS ID Facility ID Source Controlled Emissions (tons/year)

NOx CO VOC Reportable

HAP

001 ENG01 Compressor Engine 24.77 8.88 17.34 2.28






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005 TEG01 TEG Dehydration Unit -- -- 4.44 1.54

006 TNK01-05 Condensate Storage Tanks -- -- 10.63 0.37

008 FLARE Facility Flare 2.56 5.10 -- --

009 LOADING Condensate Truck Loading -- -- 3.15 --





Total Permitted Facility Emissions (tons/year) 184.30 70.06 157.82 23.58

2015 Actual Facility Emissions (tons/year) 166.37 69.30 142.23 21.23

III. APPLICABLE REQUIREMENTS

Prevention of Significant Deterioration (PSD)

This facility is located in an area designated attainment for all pollutants. Based on the information provided by the applicant, this source is categorized as a minor stationary source for PSD as of the issue date of this permit. Any future modification which is major by itself (Potential to Emit of ≥ 250 TPY) for any pollutant listed in Regulation No. 3, Part D, Section II.A.44 for which the area is in attainment or attainment/maintenance may result in the application of the PSD review requirements.

Accidental Release Program – 112(r)

Section 112(r) of the Clean Air Act mandates a new federal focus on the prevention of chemical accidents. Sources subject to these provisions must develop and implement risk management programs that include hazard assessment, a prevention program, and an emergency response program. They must prepare and implement a Risk Management Plan (RMP) as specified in the Rule.

Based on the information provided by the applicant, the Bailey Compressor Station is not subject to the provisions of the Accidental Release Prevention Program (Section 112(r) of the Federal Clean Air Act).

Compliance Assurance Monitoring (CAM)

The following emission points at this facility use a control device to achieve compliance with an emission limitation or standard to which they are subject and have pre-control emissions that exceed or are equivalent to the major source threshold. They are therefore subject to the provisions of the CAM program as set forth in 40 CFR Part 64 as adopted by reference into Colorado Regulation No. 3, Part C, Section XIV:

AIRS ID 004 (ENG03/04/05) – Caterpillar G3616 TALE Compressor Engines (4,890 HP) for CO

AIRS ID 005 (TEG01) – TEG Dehydration Unit (40 MMSCFD) for VOC and HAP

AIRS ID 006 (TNK01-05) – Condensate Storage Tanks (400 bbl each) for VOC


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AIRS ID 012 (ENG06) – Caterpillar G3616 TALE Compressor Engine (4,890 HP) for CO


It should be noted that HAP limitations were included in the operating permit for the Bailey Compressor Station. These limitations are only in place to demonstrate applicability of the area source MACT HH requirements (see discussion below), and to ensure the facility remains exempt from the major source requirements of MACT DDDDD (see discussion below). The Bailey Compressor Station is classified as a “production field facility”, pursuant to MACT HH and MACT DDDDD, and, as such, the area source applicability depends only on HAP emissions from dehydration units and condensate storage tanks. As of this permit issuance on XX/XX/XXXX, the Bailey Compressor Station is an area source of HAP for the purposes of MACT HH and is subject to area source requirements. Because MACT DDDDD applies only to major sources of HAP, the Bailey Compressor Station is not subject to this subpart as an area source of HAP. To ensure major source requirements in MACT HH or MACT DDDDD are not inadvertently triggered, HAP limitations were included in the operating permit. However, these limitations are meant to apply to the dehydration units and condensate storage tanks only, as these are the only two sources of HAP emissions that must be aggregated for area source determination at production field facilities, pursuant to MACT HH and MACT DDDDD. As such, no other equipment is subject to these HAP limitations. Therefore, the engines, although producing HAP emissions in excess of the CAM applicability thresholds, are not subject to CAM for HAP limitations because the HAP limitations in this permit are not applicable to the engines. However, the dehydration units, which emit both individual and total HAP in excess of the major source applicability thresholds and must comply with the HAP limitations, are subject to CAM for these limitations.

Engines ENG01/02/03/04/05/06 are also subject to 40 CFR Part 63 Subpart ZZZZ, which sets forth CO and formaldehyde limitations. All engines have the potential to emit formaldehyde in excess of the major source threshold of 10 tons/year, and engines ENG03/04/05/06 have the potential to emit CO in excess of the major source threshold of 100 tons/year. However, pursuant to §64.2(b)(1)(i), “emission limitations or standards proposed by the Administrator after November 15, 1990 pursuant to section 111 or 112 of the Act” are exempt from CAM requirements. Subpart ZZZZ was proposed under the provisions of Section 112 after the effective date of the CAM rule, and, as such, all limitations set forth therein are not subject to CAM pursuant to §64.2(b)(1)(i). However, because engines ENG03/04/05/06 are subject to the CO emission limitation set forth in the Title V permit, which is not exempted under CAM, these engines are subject to the CAM provisions for this CO limitation only. As noted above, HAP limitations, which would include formaldehyde, were included in the operating permit. However, these HAP limitations are for the purposes of area source applicability under MACT HH. As the area source designation under MACT HH does not include HAP contributions from


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engines, the engines are not subject to this emission limitation and are therefore not subject to a qualifying limitation for HAP.

The remaining permitted points at the Bailey Compressor Station are NOT subject to CAM per the following justifications:

AIRS ID 001 (ENG01/02) – Caterpillar G3612 TALE engines exempt due to pre-control emissions below major source thresholds (see above for formaldehyde rationale).

AIRS ID 008 (FLARE) – Flare exempt due to pre-control emissions below major source thresholds

AIRS ID 009 (LOADING) – Condensate truck loading exempt due to pre-control emissions below major source thresholds

It should be noted that the flare is a permitted point at the Bailey Compressor Station. The flare itself has emissions of NOx and CO well below the major source thresholds for CAM applicability, and therefore does not require a separate CAM plan for itself. However, because the TEG dehydration units and condensate storage tanks use this flare as a control device, the flare is subject to the monitoring requirements of CAM to ensure proper air pollution control for the dehydration units and tanks.

Hazardous Air Pollutants (HAPs)

The Bailey Compressor Station has the potential to emit in excess of the major source threshold of 10 tons/year for a single HAP (formaldehyde). As such, this facility is considered to be a major source of Hazardous Air Pollutants (HAP). Reportable HAP emissions for this facility are summarized in the following table:

Pollutant

Controlled Emissions

Actual Emissions

tons/year tons/year

Acetaldehyde 3.32 3.27

Acrolein 2.04 2.02

Methanol 0.99 --

Formaldehyde 10.39 10.27

n-Hexane 1.01 0.22

2,2,4-TMP 0.02 --

Benzene 1.93 2.10

Toluene 2.98 2.92

Ethyl benzene 0.13 0.06

Xylenes 0.78 0.38

Facility Total 23.58 21.23

It should be noted that synthetic minor HAP limitations were included in the operating permit. For the purposes of MACT HH (see discussion below), the Bailey Compressor


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Station is an area source of HAP, since this designation depends only on HAP emissions from the dehydration units and condensate storage tanks. As such, limitations were included in the operating permit for the dehydration units and condensate storage tanks only to ensure that major source requirements under MACT HH are not triggered and the facility may continue to comply with the area source requirements for dehydration units under MACT HH.

Source Determination

With this permit action, the Division revisited the source determination in regards to the natural gas operations in the area surrounding the Bailey Compressor Station to verify that the proper pollutant emitting activities are included in this permit as part of the facility. The applicant did not identify any other pollutant emitting activities in the vicinity of the Bailey Compressor Station on that are dependent upon the facility to maintain operations. The Division considers the current determination for this facility to be accurate, and the proper pollutant emitting activities are included in this permit.

40 CFR Part 63 Subpart ZZZZ NESHAP – National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines

This section addresses the final version of Subpart ZZZZ, last updated in the Federal Register on 2/27/2014. For the purposes of the Bailey Compressor Station, this subpart applies to all compressor engines.

Affected facilities under this subpart include both area and major sources of HAP. A major source of HAP is defined in §63.2 as “any stationary source or group of stationary sources located within a contiguous area and under common control that emits or has the potential to emit considering controls, in the aggregate, 10 tons per year or more of any hazardous air pollutant or 25 tons per year or more of any combination of hazardous air pollutants”. Section §63.6675 of subpart ZZZZ lists four exceptions to this definition:

1. Emissions from any oil or gas exploration or production well (with its associated equipment (as defined in this section)) and emissions from any pipeline compressor station or pump station shall not be aggregated with emissions from other similar units, to determine whether such emission points or stations are major sources, even when emission points are in a contiguous area or under common control

Based on the facility plot plan, there are no exploration or production wells associated with the Bailey Compressor Station, nor are there any other facilities in close proximity that could potentially be considered to be on the same surface site. Therefore, this clarification is not applicable to the major source determination.

2. For oil and gas production facilities, emissions from processes, operations, or equipment that are not part of the same oil and gas production facility, as defined in §63.1271 of subpart HHH of this part, shall not be aggregated;


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Pursuant to the first exception of this subpart, no aggregation of processes, operations or equipment that were not part of the Bailey Compressor Station was undertaken.

3. For production field facilities, only HAP emissions from glycol dehydration units, storage vessel with the potential for flash emissions, combustion turbines and reciprocating internal combustion engines shall be aggregated for a major source determination

Production field facilities, as defined in §63.6675, are “oil and gas production facilities located prior to the point of custody transfer”. Custody transfer for this subpart ZZZZ is defined as “the transfer of hydrocarbon liquids or natural gas: After processing and/or treatment in the producing operations, or from storage vessels or automatic transfer facilities or other such equipment, including product loading racks, to pipelines or any other forms of transportation. For the purposes of this subpart, the point at which such liquids or natural gas enters a natural gas processing plant is a point of custody transfer.” The Bailey Compressor Station is located upstream of the Meeker Natural Gas Processing Plant and is therefore, by definition, prior to the point of custody transfer. As such, only HAP emissions from the glycol dehydration units, storage vessels and reciprocating internal combustion engines were aggregated for the purposes of major source determination.

4. Emissions from processes, operations, and equipment that are not part of the same natural gas transmission and storage facility, as defined in §63.1271 of subpart HHH of this part, shall not be aggregated


The aggregation of the specified emission units in exception 3 above results in potential to emit values that exceed the major source threshold of 10 tons/year for individual HAP emissions of formaldehyde (see HAP summary table in section above). As such, the Bailey Compressor Station is considered a major source for the purposes of Subpart ZZZZ.

Affected engines under this subpart include existing, new or reconstructed engines. Pursuant to §63.6590(a)(1)(i), “For stationary RICE with a site rating of more than 500 brake horsepower (HP) located at a major source of HAP emissions, a stationary RICE is existing if you commenced construction or reconstruction of the stationary RICE before December 19, 2002.” Commenced construction dates for the engines at the Bailey Compressor Station were reported on the most recent APENs (received 11/26/2014) as follows:

AIRS ID Facility

Identifier Site-Rated

Horsepower Commenced Construction Date

(per 11/26/2014 APENs) Subpart ZZZZ Designation

001 ENG01 3,665 7/2008 New

001 ENG02 3,665 7/2008 New


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004 ENG03 4,890 11/2008 New

004 ENG04 4,890 4/2009 New

004 ENG05 4,890 6/2010 New

012 ENG06 4,890 3/2011 New

Based on the “commenced construction” dates in the preceding table, all engines at the Bailey Compressor Station are considered “new” engines, pursuant to Subpart ZZZZ. Therefore, each engine is subject to the Subpart ZZZZ requirements for new engines greater than 500 HP at a major source of HAP.

Please refer to Section V of this document for a more detailed discussion on the incorporation of the requirements of Subpart ZZZZ into the operating permit.

40 CFR Part 63 Subpart HH – National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities

This section addresses the final version of Subpart HH, last updated in the Federal Register on 8/16/2012. For the purposes of the Bailey Compressor Station, this subpart applies to the TEG dehydration units.

Affected facilities under this subpart include both area and major sources of HAP. A major source of HAP is defined in §63.2 as “any stationary source or group of stationary sources located within a contiguous area and under common control that emits or has the potential to emit considering controls, in the aggregate, 10 tons per year or more of any hazardous air pollutant or 25 tons per year or more of any combination of hazardous air pollutants”. Section §63.761 of subpart HH lists three (3) clarifications to this definition:

1. Emissions from any oil or gas exploration or production well (with its associated equipment (as defined in this section)) and emissions from any pipeline compressor station or pump station shall not be aggregated with emissions from other similar units, to determine whether such emission points or stations are major sources, even when emission points are in a contiguous area or under common control

Pursuant to the “facility” definition set forth in §63.761, “for the purpose of a major source determination, facility (including a building, structure, or installation) means oil and natural gas production and processing equipment that is located within the boundaries of an individual surface site as defined in this section”. “Surface site” is defined in §63.761 as “any combination of one or more graded pad sites, gravel pad sites, foundations, platforms, or the immediate physical location upon which equipment is physically affixed.” Based on the facility plot plan, there are no exploration or production wells associated with the Bailey Compressor Station, nor are there any other facilities in close proximity that could potentially be considered to be on the same surface site. Therefore, this clarification is not applicable to the major source determination.

2. Emissions from processes, operations, or equipment that are not part of the same facility, as defined in this section, shall not be aggregated


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3. For facilities that are production field facilities, only HAP emissions from glycol dehydration units and storage vessels shall be aggregated for a major source determination. For facilities that are not production field facilities, HAP emissions from all HAP emission units shall be aggregated for a major source determination

Production field facilities are defined in §63.761 as “facilities located prior to the point of custody transfer”. Custody transfer is defined in this subpart as “the transfer of hydrocarbon liquids or natural gas: after processing and/or treatment in the producing operations, or from storage vessels or automatic transfer facilities or other such equipment, including product loading racks, to pipelines or any other forms of transportation. For the purposes of this subpart, the point at which such liquids or natural gas enters a natural gas processing plant is a point of custody transfer”. The Bailey Compressor Station is located upstream of the Meeker Natural Gas Processing Plant and is therefore, by definition, prior to the point of custody transfer. As such, only HAP emissions from the glycol dehydration units and storage tank battery were considered in the determination of source status for the purposes of Subpart HH.

Pursuant to the definition of major source set forth in §62.3 and the clarifications in §63.761, the HAP emissions from this facility are below the major source thresholds of 10 tons/year individual and 25 tons/year total HAP. Therefore, for the purposes of subpart HH, the Bailey Compressor Station is considered to be an area source of HAP. Area sources under Subpart HH are subject to only TEG dehydration unit requirements per §63.760(b)(2). Therefore, fugitive emission and storage tank requirements set forth in this subpart were not included the operating permit.

Each TEG dehydration unit meets the Benzene Exemption set forth in Subpart HH §63.764 (e)(1)(ii). The sole requirement applicable to these dehydration units under Subpart HH is the maintenance of records validating that the actual average benzene emissions are below 0.9 megagrams per year (1,984 lb/year).

Please refer to Section V of this document for a more detailed discussion on the incorporation of the requirements of subpart HH into the operating permit.

40 CFR Part 60 Subpart JJJJ – Standards of Performance for Stationary Spark Ignition Internal Combustion Engines

This section addresses the final version of Subpart JJJJ, last updated in the Federal Register on 8/30/2016. For the purposes of the Bailey Compressor Station, this subpart applies to each compressor engines except ENG02.

Affected engines for owners/operators under this subpart, pursuant to §60.4230(a)(4)(i), include those that “commence construction after June 12, 2006, where the stationary SI ICE are manufactured…on or after July 1, 2007, for engines with a maximum engine power greater than or equal to 500 HP (except lean burn engines with a maximum engine power greater than or equal to 500 HP and less than 1,350 HP.)” For the


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purposes of subpart JJJJ, “the date that construction commences is the date the engine is ordered by the owner or operator” (§60.4230(a)). The date of manufacture for each engine, obtained from the most recent APENs submitted (received on 11/26/2014) are summarized in the table below:

AIRS ID

Facility Identifier

Site-Rated Horsepower

Commenced Construction Date (per 11/26/2014 APENs)

Date of Manufacture (per 11/26/2014 APENs)

Subpart JJJJ Applicability

001 ENG01 3,665 7/2008 9/21/2007 Yes

001 ENG02 3,665 7/2008 4/27/2007 No

004 ENG03 4,890 11/2008 9/24/2007 Yes

004 ENG04 4,890 4/2009 12/30/2008 Yes

004 ENG05 4,890 6/2010 12/23/2008 Yes

012 ENG06 4,890 3/2011 2/6/2009 Yes

All engines except ENG02 commenced construction after 6/12/2006 and were manufactured after 7/1/2007, thereby fulfilling the applicability criteria in §60.4230(a)(4)(i). These engines are therefore subject to Subpart JJJJ. However, engine ENG02 does not fulfill the second part of the applicability criteria, because it was manufactured prior to the 7/1/2007 applicability date. As such, ENG02 is not subject to Subpart JJJJ.

Please refer to Section V of this document for a more detailed discussion on the incorporation of the requirements of Subpart JJJJ into the operating permit.

Colorado Regulation No. 7 Section XVII – Statewide Controls for Oil and Gas Operations and Natural Gas-Fired Reciprocating Internal Combustion Engines

This section addresses the final version of Colorado Regulation No. 7 Section XVII, last updated 12/30/2017. For the purposes of the Bailey Compressor Station, this section applies to oil and gas operations and RICE located within the state of Colorado.

Requirements applicable to the Bailey Compressor Station are as follows:

Section XVII.B – General provisions, including good engineering and air pollution control practices

Section XVII.C – Storage Tank Requirements, addressing VOC and hydrocarbon emission reductions, audio, visual and olfactory (AVO) inspections, approved instrument monitoring methods (AIMM) and the storage tank emission management (STEM) plan

Section XVII.D – Dehydration unit requirements, addressing VOC and hydrocarbon emission reductions

Section XVII.F – LDAR requirements for fugitive emissions, including periodic approved instrument monitoring methods (AIMM) and repair, remonitoring, recordkeeping and reporting requirements


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Colorado Regulation No. 7 Section XVIII – Natural Gas-Actuated Pneumatic Controllers Associated with Oil and Gas Operations

This section addresses the final version of Colorado Regulation No. 7 Section XVII, last updated 12/30/2017. For the purposes of the Bailey Compressor Station, this section applies to natural gas actuated pneumatic controllers.

Section XVIII.C – Natural gas actuated pneumatic controller design requirements, including utilizing low-bleed or no-bleed controllers unless high-bleed is otherwise required for safety purposes

Section XVIII.D – Monitoring requirements, including tagging high-bleed pneumatic controllers and performing monthly inspections

Section XVIII.E – Recordkeeping requirements, including a log of all controllers and maintenance performed

Non-Applicable Regulations

40 CFR Part 63 Subpart DDDDD – This subpart sets forth the National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial and Institutional Boilers and Process Heaters. Pursuant to the major source definition in Subpart DDDDD §63.7575, “for…facilities that are production field facilities, only HAP emissions from glycol dehydration units and storage vessels with the potential for flash emissions shall be aggregated for a major source determination. For facilities that are not production field facilities, HAP emissions from all HAP emission units shall be aggregated for a major source determination.” Production field facilities are, pursuant to Subpart ZZZZ §63.6675 and Subpart HH §63.761, “facilities located prior to the point of custody transfer”. Custody transfer is further defined in these subparts as “the transfer of hydrocarbon liquids or natural gas: after processing and/or treatment in the producing operations, or from storage vessels or automatic transfer facilities or other such equipment, including product loading racks, to pipelines or any other forms of transportation. For the purposes of this subpart, the point at which such liquids or natural gas enters a natural gas processing plant is a point of custody transfer”. The Bailey Compressor Station is located upstream of the Meeker Natural Gas Processing Plant and is therefore, by definition, prior to the point of custody transfer. As such, only HAP emissions from the glycol dehydration units and storage tank battery were considered in the determination of source status for the purposes of Subpart DDDDD. Emissions of from the glycol dehydration units and storage tank battery combined are not in excess of the major source threshold for HAP of 10 tons/year individual HAP and 25 tons/year total HAP. As such, the Bailey Compressor Station is not considered to be a major source of HAP for the purposes of Subpart DDDDD. Therefore, the dehydration unit reboilers and tank heaters at the Bailey Compressor Station are not subject to this rule, which is applicable only to major sources of HAP, pursuant to §63.7485. To ensure the major source thresholds, and, by extension, Subpart DDDDD applicability, is not inadvertently triggered, synthetic minor HAP limits were


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included in the operating permit for both the dehydration units and condensate storage tanks.

MACT Subpart JJJJJJ – Subpart JJJJJJ applies to Industrial, Commercial and Institutional Boilers located at area sources of HAP. The Bailey Compressor Station operates natural gas fired heaters as reboilers to provide sufficient heat to regenerate the TEG from the dehydration units, and tank heaters to prevent tank contents from freezing during winter months. Pursuant to §63.11193, a major source of HAP for the purposes of this subpart is defined to be any source with emissions of a single HAP in excess of 10 tons/year or total facility HAP in excess of 25 tons/year (§63.2. It should be noted that, unlike Subpart DDDDD above, there are no clarifications to the §63.2 definition of major source). The Bailey Compressor Station produces formaldehyde emissions that are greater than the 10 tons/year threshold. As such, this facility is considered to be a major source of HAP for the purposes of Subpart JJJJJJ and is not subject to the area source requirements of this Subpart.

40 CFR Part 60 Subpart Kb – This subpart sets for the Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction or Modification Commenced After July 23, 1984. For the purposes of Subpart Kb, “the affected facility to which this subpart applies is each storage vessel with a capacity greater than or equal to 75 cubic meters (m3) that is used to store volatile organic liquids (VOL) for which construction, reconstruction, or modification is commenced after July 23, 1984.” All condensate storage tanks at the Bailey Compressor Station have a design capacity of 400 bbl, which is below the 75 m3 (~472 bbl) applicability threshold. Therefore, the condensate storage tanks at the Bailey Compressor Station are not subject to Subpart Kb.

40 CFR Part 60 Subpart KKK – This subpart sets forth the Standards of Performance for Equipment Leaks of VOC from Onshore Natural Gas Processing Plants for Which Construction, Reconstruction or Modification Commenced After January 20, 1984 and on or Before August 23, 2011. For the purposes of Subpart KKK, a natural gas processing plant is defined as “any processing site engaged in the extraction of natural gas liquids from field gas, fractionation of mixed natural gas liquids to natural gas products, or both” The Bailey Compressor Station does not extract or fractionate natural gas liquids. As such, this facility is not subject to Subpart KKK.

40 CFR Part 60 Subpart OOOO – This subpart sets forth the Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution for which Construction, Modification or Reconstruction Commended after August 23, 2011 and on or before September 18, 2015. Affected facilities under this subpart include gas well facilities, centrifugal compressors, reciprocating compressors, pneumatic controllers, storage vessels, process units, sweetening units, and hydraulic fracturing sites. The Bailey Compressor Station is not a gas well or hydraulic fracturing facility, and does not contain any centrifugal compressors or sweetening units. All reciprocating compressors (and


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the associated engines) were constructed prior to the August 23, 2011 applicability date (see table of manufacture dates for NSPS JJJJ applicability, above). The condensate storage tanks and process units (TEG dehydration units TEG01-04) commenced operation pursuant to the following table:

AIRS ID

Facility Identifier

Startup Date (per 5/31/2016 Renewal App)

Subpart OOOO Applicability

005 TEG01 7/16/2008 No

006 TNK01-05 7/16/2008 No

010 TEG02 11/17/2008 No

011 TEG03 5/5/2009 No

014 TEG04 5/10/2011 No

It can be assumed that construction on each of these units was commenced prior to the startup dates listed in the preceding table. Because each date listed is prior to the August 23, 2011 applicability date of NSPS OOOO, none of these units are subject to the requirements of NSPS OOOO. The Bailey Compressor Station does have natural gas pneumatic controllers, however, pursuant to NSPS OOOO §60.5365, the pneumatic controller requirements are applicable to only those continuous bleed controllers with a bleed rate greater than 6 SCFH. Per the 5/31/2016 Title V renewal application, there are 6 continuous bleed pneumatic controllers with a bleed rate of 2.1 SCFH located at the Bailey Compressor Station. Because the bleed rate is less than the 6 SCFH threshold set forth in NSPS OOOO, none of the continuous bleed pneumatic controllers are subject to this subpart. Based on this analysis, the Bailey Compressor Station is not an affected facility under NSPS OOOO.

Colorado Regulation No. 7, Section XVII.E – This section of Colorado Regulation No. 7 sets forth requirements for new, modified, existing and relocated natural gas fired reciprocating internal combustion engines. Colorado Regulation No. 7, Section XVII.B.5 sets forth the following exemption: “…internal combustion engines that are subject to an emissions control requirement in a federal maximum achievable control technology (“MACT”) standard under 40 CFR Part 63, a Best Available Control Technology (“BACT”) limit, or a New Source Performance Standard (“NSPS”) under 40 CFR Part 60 are not subject to Section XVII., except for the leak detection and repair requirements in Section XVII.F.” Each engine at the Bailey Compressor Station is subject to the numerical emissions standards for formaldehyde and CO set forth in 40 CFR Part 63 Subpart ZZZZ. Additionally, all engines except ENG02 are subject to the numerical limitations for NOx, CO and VOC set forth in 40 CFR Part 60 Subpart JJJJ. These numerical limitations and reductions in specific pollutant emissions fulfill the “emissions control requirement” required by the exemption in Colorado Regulation No. 7, Section XVII.B.5. As such, these engines are not subject to the engine requirements in Colorado Regulation No. 7, Section XVII.E.

It should be noted that in the previous issuance of the operating permit on 6/1/2012, the Section XVII.E requirements were included for ENG02 only.


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Although this engine was subject to the numerical requirements under MACT Subpart ZZZZ, those requirements did not become enforceable until January 13, 2014, which was after the initial permit issuance. Until that time, ENG02 was not subject to an emissions control requirement set forth in a MACT or NSPS, as this engine is also not subject to the requirements of NSPS JJJJ (see above discussion). As such, the applicable Colorado Regulation No. 7, Section XVII.E requirements were included for ENG02, which would apply from the initial permit issuance on 6/1/2012 until the requirements of MACT ZZZZ became applicable. Based on the 2017 inspection report for the Bailey Compressor Station, ENG02 is now fully compliant with the requirements of Subpart ZZZZ, which includes a numerical emissions limitation for CO and formaldehyde. As such, this engine now meets the Colorado Regulation No. 7, Section XVII.B.5 exemption, and is no longer subject to the Section XVII.E requirements. These requirements were therefore removed from the operating permit.

IV. MODIFICATIONS REQUESTED BY THE SOURCE

The renewal application received on 5/31/2016 requested the following modifications:

Cancel the fugitive emissions point 007, since emissions were reduced to below the APEN reporting threshold when using the reduced emission factors from EPA’s Protocol for Equipment Leak Estimates (EPA-453/R-95-017, Table 2-8), pursuant to Colorado Regulation No. 7, Section XVII.F.2.

o It should be noted that this request was processed in the administrative permit revision issued on 2/9/2017.

Modify the frequency of the dehydration units’ extended gas analysis sampling from the tiered approach set forth by the 6/1/2012 issuance of the operating permit to annual. This was originally requested in the 3/2/2015 significant modification, and is addressed below.

The significant modification received on 3/2/2015 (via email) requested the following modification:

Update the frequency of the dehydration units’ extended gas analysis sampling required by the 6/1/2012 issuance of the operating permit from a tiered approach to annual sampling.

In the 6/1/2012 issuance of the operating permit, initial quarterly sampling is required to demonstrate the benzene, ethylbenzene, toluene and xylene (BTEX) concentrations are below the thresholds for each BTEX constituent. Once four consecutive quarterly samples have been collected that demonstrate BTEX content is less than the listed thresholds, the sampling frequency decreases to semi-annual. This frequency is further reduced to annual if the two semi-annual samples indicate the BTEX composition is below the listed thresholds. The source submitted several extended gas analyses identifying the “worst case” BTEX expected at the Bailey Compressor Station. These samples indicate that the BTEX levels expected are below the thresholds set forth in the tiered sampling approach, when evaluated on a mole basis. In addition, it should be


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noted that these dehydration units have been historically operated well below their permitted limits (i.e., 2015 actual emissions of VOC were 0.2 tons/year; each unit is permitted at 4.4 tons/year). As such, actual emissions of HAP have been consistently below the de minimis APEN reporting threshold of 250 lb/year. This modification was incorporated in its entirety with the XX/XX/XXXX issuance of the operating permit.

It should be noted that this modification was submitted under the minor modification provisions of Colorado Regulation No. 3, Part C, Section X. The Division has determined that a “significant change” in regards to monitoring (Section X.A.2) includes instances in which monitoring frequency is relaxed. Because the tiered sampling approach requires both quarterly and semi-annual sampling, this request to for annual sampling was determined to be a reduction in monitoring frequency. As such, this request was instead processed as a significant modification, pursuant to Colorado Regulation No. 3, Part C, Section I.A.7.c. Because a significant modification is processed under the same procedures as a renewal, i.e. it must go through a 30-day public comment period and EPA 45-day review period, this significant modification was incorporated into the renewal of this operating permit.

The source review comments received on 9/18/2018 (via email) requested the following modifications:

Update the contact information for the responsible official (RO).

Remove the requirement to monitor the dehydration units’ reboiler operating temperature and pressure, as these parameters are not required inputs for the GLYCalc model emission estimation.

Both of these requests were incorporated into the operating permit in their entirety.

Updates to Appendices

Appendix A

o Replaced facility plot plan with the plot plan received with the renewal application on 5/31/2016

o Updated insignificant activities list with the information provided in the 5/31/2016 renewal application

It should be noted that the 5/31/2016 list of insignificant activities included both fugitive equipment leaks and gas-driven pneumatic devices. Pursuant to Colorado Regulation No. 3, Part C, Section II.E, paragraph 2, insignificant activity exemptions cannot apply if “a source would avoid any specific federal or state applicable requirement, including, but not limited to, New Source Performance Standards, Regulation Number 7, Prevention of Significant Deterioration (Section VI., Part D of this Regulation Number 3), nonattainment New Source Review requirements (Section V. Part D of this Regulation Number 3), Title III, National Emission Standards for Hazardous Air Pollutants, Title V, and Colorado


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Maximum Achievable Control Technology or Generally Available Control Technology.” Fugitive equipment leaks and pneumatic controllers located at compressor stations are affected facilities subject to the applicable requirements of Colorado Regulation No. 7 Section XVII.F and Section XVIII. As such, these activities cannot be classified as insignificant under Colorado Regulation No. 3, Part C, Section II.E. The fugitive equipment leaks and gas-driven pneumatic controllers were therefore not included in the insignificant activities list in Appendix A of the operating permit. It should be noted that the applicable requirements of Colorado Regulation No. 7, Section XVII.F for fugitive emissions and Section XVIII for natural gas driven pneumatic controllers were included in the operating permit.

V. OTHER MODIFICATIONS

In addition to the source requested modifications, the Division has included changes to make the permit more consistent with recently issued permits, include comments made by EPA on other Operating Permits, as well as correct errors or omissions identified during inspections and/or discrepancies identified during review of this renewal. These changes are as follows:

Page Following Cover Page

Revised Submittal Deadlines based on permit issuance date of XX/XX/XXXX.

Modified the language concerning postmarked dates for report submittals to reflect the Division’s current standard language.

Section I – General Activities and Summary

Updated source description in Condition 1.1 to include AIRS ID’s for each point and a summary of emission control units for clarity.

Updated source description in Condition 1.1 to identify the Eagles Nest Wilderness Area as a Federal Class I designated area within 100 km of the Bailey Compressor Station.

Updated state-only enforceable regulation list (Condition 1.4) to include the general requirements of Colorado Regulation No. 7, Section XVII.B, the fugitive emissions requirements of Section XVII.F and the pneumatic controller requirements of Section XVIII.

Updated AOS language to the most current Division standard (ver. 10/12/12); revised Reg 7, MACT and NSPS references

Updated PSD language in Condition 3 to reflect the most current Colorado Regulation No. 3 references.

Updated CAM language in Condition 5 to identify units subject to CAM and reference the applicable CAM condition in the permit body.

Section II – Specific Permit Terms


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Condition 1 – ENG01 - 02 (AIRS 001): Two (2) Caterpillar G3612 Compressor Engines, Rated at 3,665 HP & ENG03 - 06 (AIRS 004): Four (4) Caterpillar G3616 Compressor Engines, Rated at 4,890 HP

Condition 1.1 – NOx & CO Limitations & Compliance Monitoring

o Added clarification that the heat content used in the emission calculation should be that of the most recent heat content analysis

o Added requirement to maintain records of the monthly emission calculations to be made available to the Division upon request

o Relocated the portable monitoring requirement to its own condition to more specifically address the requirements

Condition 1.2 - VOC Emission Limitations & Compliance Monitoring

o Added clarification that the heat content used in the emission calculation should be that of the most recent heat content analysis

o Added requirement to maintain records of the monthly emission calculations to be made available to the Division upon request

Condition 1.4 – Natural Gas Heat Content

o Added requirement to maintain records of the heat content verification to be made available to the Division upon request.

o Note that the natural gas heat content used to determine the emission limitations and emission factors for these engines was 1059 Btu/SCF.

Condition 1.5 – Hours of Operation

o Created condition to more specifically address hours of operation monitoring for clarity, including the time frame in which hours readings must be taken relative to the facility-wide fuel gas meter reading.

Condition 1.6 – Opacity

o Updated condition format to current Division-standard. It should be noted that the content of this condition was not altered.

Condition 1.7 – Portable Monitoring

o Added reference condition requiring quarterly portable monitoring. This requirement was included in the summary table to clarify that portable monitoring is required for these engines

Condition 1.9 – 40 CFR Part 60, Subpart JJJJ NSPS

o Updated heading language to the most current Division-standard format, noting the most recent version of NSPS JJJJ adopted (8/30/2016) on


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which the regulatory language included in the permit is based and the fact that Colorado Regulation No. 6 has not yet adopted NSPS JJJJ.

o Updated emission limitation table to include the July 1, 2010 manufacture date standards. Although currently there are no engines at the Bailey Compressor Station that are subject to these limitations, they were included in the permit so that a permit modification is not required to insert them, should an alternative operating scenario (AOS) be executed in which the replacement engine is subject to the July 1, 2010 standards

o Added exemption from compliance with the CO emission limitation in Table 1, pursuant to NSPS JJJJ Table 1, footnote b, for lean burn engines that are otherwise required to comply with the emissions standards of MACT ZZZZ Table 2a. As all engines at the Bailey Compressor Station are new, lean burn engines required to comply with MACT ZZZZ Table 2a, this exemption was included in the operating permit.

o Added clarification to VOC emission calculation, pursuant to NSPS JJJJ Table 1 Footnote d, that formaldehyde should not be included when determining compliance with the VOC standard

o Added reference to testing procedures in §60.4244 since these engines must conduct performance testing in accordance with this section

Condition 1.10 – 40 CFR Part 60, Subpart A

o Updated to include the following applicable sections:

Notification and Recordkeeping (§60.7)

Compliance with standards and maintenance requirements (§60.11)

General notification and reporting requirements (§60.19)

Condition 1.11 – 40 CFR Part 63, Subpart ZZZZ

o Updated heading language to the most current Division-standard format, noting the most recent version of MACT ZZZZ adopted (2/27/2014) on which the regulatory language included in the permit is based, and highlighting the fact that Colorado Regulation No. 8 has not yet adopted MACT ZZZZ revisions later than 3/10/2010 as state-enforceable.

o Reformatted condition to align more closely with the order of conditions established in MACT ZZZZ for clarity.

o Removed applicability condition (§60.6595(a)(1)). This applicability condition was required in the previous issuance of the operating permit on 6/1/2012 since ENG06 hadn’t yet been constructed and the requirements of Subpart ZZZZ were not effective until January 13, 2014. However, since the applicability date has passed and ENG06 was constructed and, per


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the 2017 inspection report, is operating in compliance with Subpart ZZZZ, this applicability requirement was removed.

o Removed initial performance test requirements of §63.6610. Per the 2017 inspection report, the initial performance tests were completed on 12/9-10/2008 for ENG01, 02 and 03, 5/27/2009 for ENG04, 7/27/2010 for ENG05 and 6/7/2011 for ENG06. All engines achieved passing results. As such, these initial requirements have been met and are no longer required to be in the operating permit.

o Removed the specific performance testing requirements of Subpart ZZZZ Table 4 and instead included the requirement to conduct periodic performance tests (§63.6615) and referenced the full performance testing requirements in §63.6620, which include Subpart ZZZZ Table 4. This reference encompasses all applicable testing requirements within the rule, not just those in Table 4. This was done to clarify that the source is subject to all applicable performance testing requirements, not just those listed in Table 4, and brevity as the full testing requirements of Subpart ZZZZ are substantial.

o Included requirement to install, operate and maintain a CPMS to continuously monitor catalyst inlet temperature (§63.6625(b)). This requirement was not explicitly included in the 6/1/2012 issuance of the operating permit.

Per the 2017 inspection report, all engines at the Bailey Compressor Station are equipped with a CPMS

o Included requirements for monitoring, collecting data and excluding malfunction data for the purposes of continuous compliance demonstration (§63.6635). These requirements were not included in the 6/1/2012 issuance of the operating permit, but are applicable to the Bailey Compressor Station.

o Removed initial compliance demonstration requirements of §63.6630. Per the 2017 inspection report, the initial performance tests were completed on 12/9-10/2008 for ENG01, 02 and 03, 5/27/2009 for ENG04, 7/27/2010 for ENG05 and 6/7/2011 for ENG06. All engines achieved passing results. As such, these initial requirements have been met and are no longer required to be in the operating permit.

o Updated all Subpart ZZZZ Table 6 references to Item 7.a instead of Item 8.a. Item 7.a refers to engines that use an oxidation catalyst to comply with the formaldehyde emission limitations. Item 8.a refers to engines that do not use an oxidation catalyst. Because the engines at the Bailey Compressor Station all utilize an oxidation catalyst, the correct reference is Table 6, Item 7.a.

o Included additional applicable continuous compliance demonstration requirements as follows:


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Requirement to report instances in which the emission and/or operating limitations were not met (§63.6640(b)).

Allowance to deviate from emission or operating limitations during engine burn-in (§63.6640(d))

Requirement to report instances in which the general requirements of Subpart A are not satisfied (§63.6640(e))

These requirements were not included in the 6/1/2012 issuance of the operating permit, but are applicable to the Bailey Compressor Station.

o Included applicable notification requirement to submit notification of intent to conduct performance testing (§63.6645(g)). This requirement was not included in the 6/1/2012 issuance of the operating permit, but is applicable to the Bailey Compressor Station.

o Removed reporting requirements of Table 7 and included instead a reference to Table 7 along with all applicable conditions in §63.6650 that Table 7 points to, including compliance reports requirements (§63.6650(b) and (c)), deviation reporting (§63.6650(d) and (e)) and Title V semi-annual reporting (§63.6650(f)).

o Removed requirement to keep records of maintenance conducted on the engine to demonstrate compliance with a maintenance plan (§63.6655(e)). This requirement is applicable to existing stationary RICE only. All engines at the Bailey Compressor Station are classified as “new” under Subpart ZZZZ (see Section III above). As such, this condition is not applicable to the engines at the Bailey Compressor Station.

o Added recordkeeping requirements of §63.6655, including copies of notifications, records of malfunctions, performance tests, maintenance, efforts made to minimize the duration of malfunctions, CPMS requirements under the general provisions of Subpart A and records used to demonstrate continuous compliance with Table 6 of Subpart ZZZZ. These requirements were not included in the 6/1/2012 issuance of the operating permit, but are applicable to the Bailey Compressor Station.

o Added requirements dictating the form and length of recordkeeping (§63.6660). These requirements were not included in the 6/1/2012 issuance of the operating permit, but are applicable to the Bailey Compressor Station.

PREVIOUS Condition 1.11 – Colorado Regulation No. 7 Requirements for ENG02

o Since the 6/1/2012 issuance of the operating permit, ENG02 became subject to the emission reduction requirements of MACT ZZZZ (1/13/2014). As such, this engine now qualifies for the Colorado Regulation No. 7, Section XVII.B.5 exemption from complying with Section XVII if the engine is otherwise subject to an emission control


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requirement under a federal MACT. As such, the state-only enforceable requirements of Section XVII.E were removed from the operating permit. This determination is addressed in Section III.

Condition 2 – TEG01 - 04 (AIRS 005, 010, 011 & 014): Four (4) TEG Dehydration Units, Rated at 40 MMSCFD

Condition 2.1 - VOC Emission Limitations & Compliance Monitoring

o Restructured condition to specifically address VOC emission limitations and compliance monitoring. Created new requirement to specifically address the required parametric monitoring and averaging for the various temperatures and pressures.

o Added equation to be used when calculating compliance with the VOC and HAP emission limitations based on the GLYCalc output.

It should be noted that emissions from the still vent and flash gas are either routed to a vapor recovery unit (VRU) or to a flare (during VRU downtime). When the VRU is operating, a control efficiency of 100% is assumed. Therefore, no emissions are generated when this control device is utilized. Still vent and flash gas emissions are only present during periods of VRU downtime, when emissions are routed to a flare with a 95% control efficiency. Therefore, the calculation included in the operating permit addresses emissions generated during VRU downtime only, since there are no emissions to atmosphere during VRU operation. The GLYCalc output includes both flash gas and still vent emissions combined, to which a control efficiency of 95% for the flare is applied. The controlled hourly emissions output from GLYCalc is then multiplied by the hours of VRU downtime to obtain total monthly emissions from the dehydration units.

o Removed short term VOC limitation for dehydration unit TEG04. Short term limitations are required for new units until a 12 month rolling total can be established. At the time of the initial permit draft, TEG04 had not yet completed a full 12 months of operation. Because this dehydration unit has been in operation since 2011, a 12 month rolling total has since been established, and, as such, all monthly limitations were removed from this condition.

o Added requirement to maintain records of calculations, to be made available to the Division upon request

o Included requirement to calculate HAP emissions for the purposes of APEN reporting, and also to demonstrate the area source applicability under MACT HH, as required by Condition 6.

Condition 2.2 – Gas Throughput Limitations & Compliance Monitoring


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o Removed short term throughput limitation for dehydration unit TEG04. Short term limitations are required for new units until a 12 month rolling total can be established. At the time of the initial permit draft, TEG04 had not yet completed a full 12 months of operation. Because this dehydration unit has been in operation since 2011, a 12 month rolling total has since been established and, as such, all monthly limitations were removed from this condition.

o Added clarification to use an average daily gas throughput, obtained from the daily calculations averaged over each month, in the GLYCalc model run to monitor compliance with the VOC and HAP limitations.

Condition 2.3 – Lean Glycol Circulation Rate

o Moved requirement from previous Condition 2.1 to perform monthly averaging on the lean glycol circulation rate to this condition. This was done to group all requirements related to each monitored parameter into a single condition for clarity and ease of reference.

Condition 2.4 – Extended Gas Analysis

o Updated frequency to annual and removed tiered frequency requirements, pursuant to the significant modification received 3/2/2015. This modification is addressed in Section IV.

Condition 2.5 – GLYCalc Input Parameters

o Created this condition to specifically address the temperature and pressure parameters to be monitored and input into the monthly GLYCalc run, previously addressed in Condition 2.1. This was done to group all requirements related to each monitored parameter into a single condition for clarity and ease of reference.

o Removed requirement to monitor the reboiler operating temperature and pressure. These parameters are not required inputs to the GLYCalc model and do not affect emission calculations in any way, as noted in source correspondence received 9/18/2018.


o Removed requirement to track days of dehydration unit operation. All calculations are performed on an hourly or monthly basis, therefore eliminating the need for this monitoring requirement.

o Updated frequency of monitoring to daily. Daily monitoring is required to comply with the daily calculation of natural gas throughput to each dehydration unit, as required in Condition 2.2.

Condition 2.7 – Control Device Requirements

o Restructured requirement to specifically address the flash gas and still vent emissions routing, since they are significantly different.


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It should be noted that the flash gas emissions are primarily routed to the dehydration unit reboilers as fuel gas. However, in instances where the fuel gas requirements are being met and excess flash gas exists, a pressure regulating valve opens to route the flash gas emissions through the condensate storage tanks to either a VRU (if operating) or to a flare (if the VRU is not operating). As required by Colorado Construction Permit 07GA0569, it shall be assumed, for the purposes of compliance demonstration, that ALL flash gas is routed through the condensate storage tanks and to either the VRU or flare. This assumption is conservative in that no credit for the destruction of flash gas emissions in the reboilers is taken.

o Added requirement to limit and monitor condenser outlet temperature to 150°F, pursuant to the renewal application submitted on 5/31/2016. The condenser is used to first cool and condense some BTEX emissions vaporized in the dehydration still, thereby reducing still vent emissions. This condenser is included in the GLYCalc runs from the 3/4/2010 construction permit application used to determine the VOC emission limitations in Colorado Construction Permit 07GA0569. Because the temperature at which the condenser operates directly affects the efficacy of the condenser, the condenser outlet temperature shall be monitored to ensure that it does not exceed the value (150°F) at which the dehydration unit was permitted at. A monitoring frequency of weekly was chosen, based on the most current Division-standard operating and maintenance (O&M) plan for dehydration units located at facilities that have controlled potential VOC emissions in excess of 80 tons/year.

Condition 2.8 – Compliance Assurance Monitoring (CAM)

o Created reference condition for the specific CAM requirements set forth in the operating permit, indicating the limitations to which CAM applies for clarity.

Condition 2.9 – Statewide Controls for Oil and Gas Operations (State-Only Enforceable)

o Since the date of the previous operating permit issuance, new requirements for dehydration units were promulgated under Colorado Regulation No. 7, Section XVII. The requirements of this regulation were added as follows:

It should be noted that the exemption for dehydration units under Section XVII.B.5 does NOT apply to the dehydration units at the Bailey Compressor Station. This exemption states that “Glycol natural gas dehydrators…that are subject to an emissions control requirement in a federal maximum achievable control technology (“MACT”) standard under 40 CFR Part 63, a Best Available Control Technology (“BACT”) limit, or a New Source Performance Standard (“NSPS”) under 40 CFR Part 60 are not subject to Section XVII., except for the leak detection and repair


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requirements in Section XVII.F.” Although each dehydration unit is subject to MACT HH, it falls under the benzene exemption, which is not considered to be a qualifying “emissions control requirement” pursuant to the Section XVII.B.5 exemption, because the benzene exemption only excludes the dehydration unit from complying with most of MACT HH, and is therefore not an “emissions control requirement”. As such, these dehydration units are subject to the requirements of Colorado Regulation No. 7, Section XVII.D.

It should be noted that the Colorado Regulation No. 7, Section XVII language has been supplemented with additional recordkeeping requirements for the purposes of demonstrating compliance with Section XVII, pursuant to Colorado Regulation No. 3, Part C, Section V.C.5.b. This additional language is indicated in the operating permit by bold and italicized text to indicate that the requirement is not explicitly stated in Colorado Regulation No. 7 and was added to address monitoring gaps and clarify methods of compliance.

Section XVII.D.1 – Requirement to reduce uncontrolled actual emissions of VOCs from the dehydration unit by 90% using air pollution control equipment.

Supplemented condition with statement that compliance is presumed provided the control device requirements for the flare, VRU and condenser, as well as the Colorado Regulation No. 7 Section XVII.B general requirements are met.

Section XVII.D.2 – The requirements of Section XVII.D.1 are applicable where actual uncontrolled emissions of VOC from each dehydrator are greater than 2 tons/year or the sum of actual uncontrolled emissions of VOC from all dehydrators at a facility exceed 15 tons/year.

Section XVII.D.3 – Requirement to reduce uncontrolled actual emissions of hydrocarbons from the dehydration unit by 95%.

Supplemented condition with statement that compliance is presumed provided the control device requirements for the flare, VRU and condenser, as well as the Colorado Regulation No. 7 Section XVII.B general requirements are met.

It should be noted that the combustion device associated with these dehydration units was permitted in 2007, prior to the 5/1/2014 applicability date for the 98% destruction efficiency manufacturers’ guarantee requirement for combustion devices. In addition, as of the date of this permit issuance, there are no buildings or areas for designated outdoor activities located within 1,320 feet of the Bailey


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Compressor Station. Therefore, the 98% destruction efficiency manufacturers’ guarantee requirement for combustion devices is not applicable at this time. However, the requirement was included in the permit in the event that a qualifying building or area for designated outdoor activity is constructed.

Section XVII.D.4 – The requirements of Section XVII.D.3 are applicable to natural gas dehydrators constructed before 5/1/2015 with uncontrolled actual emissions equal to or greater than 6 tons/year or 2 tons/year if the dehydration unit is located within 1,320 feet of a building or outside activity area. Recordkeeping requirements not specifically addressed in the regulation were added to ensure proper calculation of actual uncontrolled emissions from dehydration units and to specifically address the compliance timeline for dehydration units that become subject to the requirements of Colorado Regulation No. 7 Section XVII.D based on these calculations.

As of the date of this permit issuance, there are no buildings or areas for designated outdoor activities located within 1,320 feet of the Bailey Compressor Station. Therefore, the applicability threshold for Section XVII.D.3 is 6 tons/year, not 2 tons/year. However, this requirement was included in the permit in the event that a qualifying building or area for designated outdoor activity is constructed.

Condition 2.10 – 40 CFR Part 63, Subpart HH MACT

o Added affirmative defense provision (§63.762(a)), which was updated in the Federal Register on 8/16/2012, subsequent to the 6/1/2012 permit issuance.

Condition 2.11 – 40 CFR Part 63, Subpart A MACT

o Created condition to address the applicable general requirements for MACT rules. Because these dehydration units are subject to MACT HH, they are subject to the MACT general provisions, including:

Prohibited activities and circumvention (§63.4)

Recordkeeping and reporting requirements (§63.10)

Condition 3 – TNK01 - 05 (AIRS 006): Five (5) Condensate Storage Tanks, 400 bbl Each This condition was updated to refer to five tanks, instead of seven. Per source correspondence received 3/13/2018, only five tanks have been constructed and there are no plans to install the permitted 6th or 7th tank, as allowed under Colorado


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Construction Permit 07GA0569. As such, all references to the 6th and 7th tank have been removed from the operating permit.

Condition 3.1 – VOC Emission Limitations & Compliance Monitoring

o Restructured condition to specifically reference each parameter required as an input to E&P TANKS.

o Added equation to be used when calculating compliance with the VOC and HAP emission limitations based on the E&P TANKS output.

It should be noted that emissions from the condensate storage tanks are either routed to a vapor recovery unit (VRU) or to a flare (during VRU downtime). When the VRU is operating, a control efficiency of 100% is assumed. Therefore, no emissions are generated when this control device is utilized. Emissions from the condensate storage tanks are only present during periods of VRU downtime, when emissions are routed to a flare with a 95% control efficiency. Therefore, the calculation included in the operating permit addresses emissions generated during VRU downtime only, since there are no emissions to atmosphere during VRU operation. The E&P TANKS output includes all working, breathing and flashing emissions combined, to which a control efficiency of 95% for the flare is applied. The controlled hourly emissions output from E&P TANKS is then multiplied by the hours of VRU downtime to obtain total monthly emissions from the condensate storage tanks.

Pursuant to Colorado Construction Permit 07GA0569, flash gas emissions from the dehydration unit are routed to the VRU and flare through the tank venting system. Although these emissions are piped to the tanks, they are accounted for in the dehydration unit VOC emission limitation, not the condensate tank battery emission limitation. Thus, the condensate tank battery emission limitation is based solely on emissions generated from the tanks, including working, breathing and flashing losses.

o Included requirement to calculate HAP emissions for the purposes of APEN reporting, and also to demonstrate the area source applicability under MACT HH, as required by Condition 6.

Condition 3.2 – Condensate Throughput Limitations & Compliance Monitoring

o Updated condition to indicate that throughput is measured using sales or haul tickets, as indicated in the 2017 inspection report and source correspondence received 3/13/2018.

Condition 3.4 – E&P TANKS Input Parameters

o Updated RVP/API requirements to reflect actual procedures used in the field, pursuant to source correspondence received for the Bailey


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Compressor Station renewal process on 3/13/2018. API gravity is measured during each truck loading event and used to calculate an RVP. This methodology was reflected in the permit.

Condition 3.5 – Control System Requirements

o Added requirement to monitor periods of VRU downtime. This parameter is necessary to monitor compliance with the annual VOC and HAP limitations for the condensate tank battery, as VOC emissions are only generated during periods of VRU downtime, when emissions are routed to the flare (95% control efficiency).

o Added reference to the operating requirements for the flare when it is used as a control device for the condensate storage tanks, mirroring a similar requirement in the dehydration unit condition.

o Added requirement to operate the VRU at all times when emissions are routed to it, mirroring the similar requirement in the dehydration unit condition.

Condition 3.6 – Compliance Assurance Monitoring (CAM)

o Created reference condition for the specific CAM requirements set forth in the operating permit, indicating the limitations to which CAM applies for clarity.


o Since the date of the previous operating permit issuance, new requirements for storage tanks were promulgated under Colorado Regulation No. 7, Section XVII. The requirements of this regulation were added as follows:

It should be noted that the Colorado Regulation No. 7, Section XVII language has been supplemented with additional recordkeeping requirements for the purposes of demonstrating compliance with Section XVII, pursuant to Colorado Regulation No. 3, Part C, Section V.C.5.b. This additional language is indicated in the operating permit by bold and italicized text to indicate that the requirement is not explicitly stated in Colorado Regulation No. 7 and was added to address monitoring gaps and clarify methods of compliance.

Section XVII.C.1.a – Requirement to install and operate air pollution control equipment with an average control efficiency of 95% for VOC.

Supplemented condition with statement that compliance is presumed provided the control device requirements for the flare and VRU, emission minimization techniques, and the


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Colorado Regulation No. 7 Section XVII.B general requirements are met.

Section XVII.C.1.b – Requirement to install and operate air pollution control equipment with an average control efficiency of 95% for hydrocarbons.

Supplemented condition with statement that compliance is presumed provided the control device requirements for the flare and VRU, emission minimization techniques, and the Colorado Regulation No. 7 Section XVII.B general requirements are met.

Section XVII.C.1.d – Requirement to conduct audio, visual and olfactory (AVO) inspections on tank battery and associated separators and control equipment.

Section XVII.C.1.e – Exemption from AVO inspections in instances where it is unsafe to monitor equipment

Section XVII.C.2.a – Requirement to operate without normally venting hydrocarbons from thief hatches and pressure relief devices, and a clarification of what is included in the term “venting”.

Supplemented condition indicating that compliance is presumed as long as hydrocarbon venting did not occur during normal operations pursuant to the recordkeeping requirements of Section XVII.C.3.

Section XVII.C.2.b – Requirement to develop, certify, implement and maintain the Storage Tank Emission Management System (STEM) plan, which must include control technologies, monitoring practices, operational practices, procedures for evaluating emission performance from tanks, and approved instrument monitoring methods (AIMM). A schedule to implement AIMM is included in this condition.

Supplemented condition with additional monitoring to determine if and when a storage tank battery becomes subject to a higher inspection frequency and a schedule of the implementation of that new frequency. Additional requirement to periodically review and update STEM plan.

Section XVII.C.3 – Requirement to maintain records of STEM, deviations from STEM, including time periods where the air pollution control equipment is not operating, corrective actions taken, and a list of equipment that AVO inspections were not performed on due to safety hazards.

Condition 4 – LOADING (AIRS 009): Condensate Truck Loadout


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It should be noted that as of this permit issuance on XX/XX/XXXX, the condensate truck loadout does not produce emissions above APEN thresholds. In email correspondence dated 2/1/2017, the source requested that this point be retained in the operating permit, despite being permit and APEN exempt pursuant to Colorado Regulation No. 3, Part A, Section II.D and Part B, Section II.D. As such, language was included to provide for an event in which APEN reporting is triggered.

Condition 4.1 – VOC Emission Limitations & Compliance Monitoring

o Restructured condition to split the requirement to submit an APEN when loading emissions exceed the APEN reporting threshold from the VOC emission calculation for clarity.

Condition 4.2 – Condensate Throughput Limitations & Compliance Monitoring

o Updated condition to indicate that throughput is measured using sales or haul tickets, as indicated in the 2017 inspection report and source correspondence received 3/13/2018.

Condition 5 – FLARE (AIRS 008): Facility Flare (Enclosed Combustion Device)

Condition 5.1 – NOx & CO Emission Limitations & Compliance Monitoring

o Restructured condition to specifically address parameters required to calculate emissions of NOx and CO, including the emission factors, gas throughput, hours of flare operation, and heat content.

Condition 5.2 – Gas Throughput Limitations & Compliance Monitoring

o Restructured condition to individually address each of the emission streams routed to the flare. Provided calculations to determine the amount of waste gas from the dehydration units and condensate storage tanks, based off of the most recent GLYCalc and TANKS model runs for these units. Noted that the amount of monthly pilot gas consumed shall be based on the pilot rating provided by the manufacturer, per source correspondence received 3/13/2018.

Condition 5.3 – Natural Gas Heat Content

o Added requirement to annually verify the heat content of the natural gas used as pilot gas in the flare. The heat content of the pilot gas is required to determine the pilot gas contribution to NOx and CO emissions.


o Updated condition to require daily monitoring of flare operation, to be consistent with the required daily monitoring of VRU operation, as required in Condition 2.6. Since the flare serves as a backup control device to the VRU, the monitoring of operating hours should be on the


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same frequency to ensure the correct routing of emissions is captured for the purposes of compliance demonstration with the NOx and CO limitations for the flare and the VOC limitations for the dehydration units and condensate storage tanks.

o Added requirement to maintain records of hours of flare operation to be made available to the Division upon request.

Condition 5.5 – Opacity

o Split Method 22 and 9 compliance requirements into separate control device requirements condition for clarity. Referenced that compliance with the opacity requirements is presumed, provided the Method 22 and 9 requirements are met.

Condition 5.6 – Control Device Requirements

o Created separate condition to address specific flare requirements, including operating the flare at all times that emissions are routed to it, operate the flare with a continuous pilot light and to conduct EPA Method 22 and 9 observations to determine compliance with the applicable opacity limitations.

o Moved requirement that the flare be operated at all times when emissions are routed to it from the dehydration unit and condensate tank conditions to this new condition to avoid redundancy.

o Updated visible emissions monitoring requirement to require daily visible emissions monitoring (pursuant to the compliance demonstration indicated in the 2017 inspection report), Method 22 observations in the event emissions are observed (pursuant to the information received in the 5/31/2016 Title V renewal application, and Method 9 observations in the event the visible emissions reading from Method 22 lasts longer than 1 minute in a 15 minute period (as required by the previous issuance of this operating permit.

o Added requirement to maintain a copy of the EPA Method 9 certification for the qualified observer to be made available to the Division upon request.


o Created condition to identify and reference all applicable requirements to the flare under Colorado Regulation No. 7, Section XVII, including:

Reference to the requirements located in the facility-wide condition to observe good air pollution control practices (Section XVII.B.1.b and XVII.B.2.a), since this combustion device is used to comply with the various requirements of Colorado Regulation No. 7, Section XVII.


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Requirement to install an enclosed combustion device (Section XVII.B.2.b)

Requirement to install an auto-igniter (Section XVII.B.2.d)

Reference to the requirement located in the TEG dehydration unit condition to maintain a manufacturer’s guarantee of 98% destruction efficiency (Section XVII.D.3), since this combustion device controls emissions from dehydration units subject to Colorado Regulation No. 7, Section XVII.D.

As noted in the TEG dehydration condition above, the dehydration units at the Bailey Compressor Station are located more than 1,320 feet from a building or designated area for outdoor activities. As such, the requirement to maintain records of the 98% manufacturer’s guarantee are not applicable at the time of this permit issuance. However, these requirements were included to provide for an event in which a building or qualifying outdoor area is constructed within the 1,320 feet threshold.

Reference to the requirements located in the condensate storage tank condition to conduct visual inspections of the air pollution control equipment and associated piping (Section XVII.C.1.d.(ii) – (v)), since this combustion device controls emissions from condensate tanks subject to Colorado Regulation No. 7, Section XVII.C.

Condition 6 – HAP Emission Limitations for the TEG Dehydration Units (AIRS 005, 010, 011, 014) and Condensate Storage Tanks (AIRS 006) It should be noted that this is a new permit condition that was not included in the 6/1/2012 issuance of the operating permit. The purpose of this condition is to ensure the source is tracking HAP to demonstrate that the facility is accurately designated as an area source of HAP for the purposes of MACT HH. Because this facility is an area source, it is subject to area source requirements under MACT HH. If facility-wide HAP emissions exceed the major source thresholds of 10 tons/year individual HAP and 25 tons/year total HAP, different requirements are triggered under MACT HH. Pursuant to MACT HH, major or area source status for production field facilities shall be calculated from HAP emissions from the glycol dehydration units and storage vessels only. The Bailey Compressor Station, by definition, is classified as a production field facility (see discussion in Section III of this document). Therefore, the HAP emission limitations set forth in this condition are applicable to only the TEG dehydration units TEG01-04 and the condensate storage tanks TNK01-05.

Condition 6.1.1 – This condition requires HAP emissions to be calculated on a monthly basis for any HAP above the de-minimis reporting threshold of 250 lb/year. The HAP calculation methodology is the exact same as the VOC


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calculation methods set forth in the dehydration unit and condensate tank battery point-specific conditions.

Condition 6.1.2 – This condition requires the monthly calculation of individual HAP emitted from the TEG dehydration units and condensate tank battery to be used in a rolling twelve month total to determine compliance with the 8 tons/year individual HAP limitation.

Condition 6.1.3 – This condition requires the monthly calculation of total HAP emitted from the TEG dehydration units and condensate tank battery to be used in a rolling twelve month total to determine compliance with the 20 tons/year individual HAP limitation.

It should be noted that the limit of 8 and 20 tons/year allows for insignificant activities associated with the dehydration unit and storage vessels to be emitted without exceeding the major source threshold of 10 and 25 tons/year. If the 8 or 20 tons/year limit is exceeded, a higher limit of up to 10 and/or 25 tons/year may be requested, however, the source will then be required to track insignificant activities associated with the dehydration unit and storage vessels to ensure these activities do not exceed the major source threshold for the purposes of MACT HH.

Condition 7 – Facility Wide Requirements

Condition 7.3 - Statewide Requirements for Oil and Gas Operations

Since the date of the previous operating permit issuance, new requirements for compressor stations were promulgated under Colorado Regulation No. 7, Section XVII. The requirements of this regulation were added as follows:

It should be noted that the Colorado Regulation No. 7, Section XVII language has been supplemented with additional recordkeeping requirements for the purposes of demonstrating compliance with Section XVII, pursuant to Colorado Regulation No. 3, Part C, Section V.C.5.b. This additional language is indicated in the operating permit by bold and italicized text.

o Section XVII.B – General Requirements (State-Only Enforceable)

Section XVII.B.1.a – Requirement to minimize leakage of VOCs from intermediary hydrocarbon processing operations

Section XVII.B.1.b – Requirement to apply good engineering and air pollution control practices at all times

Section XVII.B.2.a – Requirement to operate and maintain air pollution control equipment pursuant to manufacturer specification and to ensure such equipment is designed to handle reasonable foreseeable fluctuations in operation

Section XVII.B.3.a – Requirement to cap open-ended lines at compressor stations or to monitor them in accordance with the


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Section XVII.F LDAR requirements. Supplemented condition with recordkeeping requirements in order to demonstrate compliance with Section XVII.B.3.a.

Section XVII.B.3.c – Requirement to replace rod packing at regular intervals for reciprocating compressors and maintain records of this replacement. Supplemented condition with recordkeeping requirements in order to demonstrate compliance with Section XVII.B.3.c.

o Section XVII.F – LDAR Requirements (State-Only Enforceable)

Section XVII.F.2 – Option to use Table 2-8 of the 1995 EPA Protocol for Equipment Leak Emission Estimates for the purposes of evaluating the applicability of component fugitive emissions to Colorado Regulation No. 3

Section XVII.F.3 – Requirement to implement approved instrument monitoring methods (AIMM) and perform this monitoring on a mandated schedule. For the purposes of Section XVII.F, AIMM is defined to be EPA Method 21 or IR camera

Section XVII.F.5 – Provision to refrain from monitoring points defined as difficult, unsafe or inaccessible

Section XVII.F.6 – Division-approved methods to detect leaks, including EPA Method 21 and IR camera monitoring

Section XVII.F.7 – Required timeline for leak repair efforts (within 5 working days) and remonitoring (within 15 working days of repair)

Section XVII.F.8 – Recordkeeping requirements, including the date of inspection, a list of leaking components and the method used to determine leakage, a list of the delayed repair components, the repair efforts, remonitoring date and list of components designated as difficult, unsafe or inaccessible

It should be noted that the Colorado Regulation No. 7, Section XVII.F.8 record retention requirement of 2 years was streamlined out of the operating permit for the more stringent, federally-enforceable records retention period of 5 years, as required by operating permits.

Section XVII.F.9 – Reporting requirements for submittals prior to January 1, 2018, including the annual report submittal, including the number of facilities inspected, total number of inspections, number of leaks identified, number of leaks repaired, number of leaks placed on the delayed repair list and certification by the responsible official


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Section XVII.F.10 – Reporting requirements beginning in 2019, including the quantity of facilities inspected, the frequency tier of those facilities, number and type of leaks identified, number of leaks repaired, number of leaks on the delayed repair list, records of the review required delayed repairs and certification by the responsible official

o Section XVIII – Natural Gas Actuated Pneumatic Controllers Requirements (State-Only Enforceable)

It should be noted that although there are federally enforceable requirements in Section XVIII, all requirements from Section XVIII included in the operating permit are State-Only Enforceable, as the Bailey Compressor Station is not located in the 8-Hour Ozone Control Area. Therefore, all Section XVIII requirements were denoted as “State-Only Enforceable” in the operating permit.

Section XVIII.C.3.a. – Pneumatic controllers placed into service on or after 5/1/2014 must utilize no-bleed pneumatic controllers or self-contained pneumatic controllers if onsite electrical power is available. If onsite electrical power is not available and no-bleed pneumatics are not technically feasible, pneumatic controllers shall be low-bleed or intermittent controllers.

Although this facility was constructed prior to 5/1/2014 and therefore all associated pneumatic controllers should have existed prior to this date, installation of these controllers may become necessary in the future to allow for better process control or to address safety issues. These installations may not be significant enough to trigger a permit modification (either construction or operating). As such, this condition was included in the operating permit to capture the obligation of the source to comply with Section XVIII, regardless of when the controller was installed and whether or not a permit modification resulted.

Section XVIII.C.3.c. – High bleed pneumatic controllers that must remain in service shall comply with the monitoring requirements of XVIII.D and recordkeeping requirements by XVIII.E. For high bleed controllers in service before 5/1/2014, to owner must have submitted justification by 3/1/2015. For high bleed controllers installed after 5/1/2014, a justification for the high bleed controller to be installed for safety or process purposes must be submitted 30 days prior to installation

Section XVIII.D – Monitoring requirements, including tagging each high bleed pneumatic controller and inspecting/maintaining these controllers monthly.


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Section XVIII.E – Recordkeeping requirements, including maintaining a log of total pneumatic controllers and maintenance performed, and retaining these records for a period of 5 years.

It should be noted that the Colorado Regulation No. 7, Section XVIII.E.2.c record retention requirement of 3 years was streamlined out of the operating permit for the more stringent, federally-enforceable records retention period of 5 years, as required by operating permits.

Condition 8 – Portable Monitoring Requirements

Updated portable monitoring language to the most current Division standard (ver. 6/26/2014)

Condition 9 – Compliance Assurance Monitoring Requirements

Created condition to address Compliance Assurance Monitoring (CAM) for all affected units using the most current Division standard (ver. 4/16/2009)

Section III – Permit Shield

Updated the Reg 3 Citation for the permit shield

Section IV – General Permit Conditions

Updated the general permit conditions to the current Division standard (ver. 3/13/2018)

Appendices

Appendix A – Updated insignificant activities list to indicate which insignificant activities require monitoring and recordkeeping pursuant to Colorado Regulation No. 3, Part C, Section II.E.

Appendix B – Updated to the most current Division standard (ver. 8/20/2014)

Appendix C – Updated to the most current Division standard (ver. 8/20/2014)

Appendix D – Updated addresses to the most current Division standard (ver. 2/5/2014)

Appendix F – Cleared the list of modifications from table related to the previous issuance

Appendix G – Updated Applicability Report to current Division standard (ver. 10/12/2012, citation updates from 8/20/2014)

Appendix H – Created Appendix H to include CAM plans for the engines and dehydration units, pursuant to the 5/31/2016 renewal application (refer to Section III above for the affected units).

VI. INSIGNIFICANT ACTIVITIES


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The following list of insignificant activities was provided by the source in the renewal application submitted on 5/31/2016 to assist in the understanding of the facility layout. The insignificant activities are categorized below pursuant to the applicable exemption:

*Colorado Regulation No. 3, Part C, Section II.E.3.a: Individual emission points in nonattainment areas having uncontrolled actual emissions of any criteria pollutant (as defined in Section I.B.17. of Part A of this Regulation Number 3) of less than one ton per year and individual emission points in attainment or attainment/maintenance areas having uncontrolled actual emissions of any criteria pollutant of less than two tons per year, and each individual emission point with uncontrolled actual emissions of lead less than one hundred pounds per year, regardless of where the source is located.

Emergency Shutdown Vent (ESD)

*Colorado Regulation No. 3, Part C, Section II.E.3.k: Each individual piece of fuel burning equipment, other than smokehouse generators and internal combustion engines, that uses gaseous fuel, and that has a design rate less than or equal to five million British thermal units per hour.

Three (3) 1.28 MMBtu/hr Reboilers (RB01, 03, 04)

One (1) 0.942 MMBtu/hr Reboiler (RB02)

Five (5) 0.75 MMBtu/hr Tank Heaters (HT01-05)

*Colorado Regulation No. 3, Part C, Section II.E.3.n: Chemical storage tanks or containers that hold less than five hundred gallons, that have an annual average throughput less than twenty-five gallons per day, and are not associated with either oil and gas production wastewater or commercial facilities that accept oil production wastewater for processing.

*Colorado Regulation No. 3, Part C, Section II.E.3.mm: Chemical storage areas where chemicals are stored in closed containers, and where total storage capacity does not exceed five thousand gallons. This exemption applies solely to storage of such chemicals. This exemption does not apply to transfer of chemicals from, to, or between such containers.

*Colorado Regulation No. 3, Part C, Section II.E.3.uu: Oil production wastewater (produced water tanks), containing less than one percent by volume annual average crude oil, except for commercial facilities that accept oil production wastewater for processing.

Colorado Regulation No. 3, Part C, Section II.E.3.aaa: Storage tanks of capacity less than forty thousand gallons of lubricating oils or waste lubricating oils.

Colorado Regulation No. 3, Part C, Section II.E.3.ggg: Each individual piece of fuel burning equipment that uses gaseous fuel, and that has a design rate less than or equal to ten million British thermal units per hour, and that is used solely for heating buildings for personal comfort.

VII. PERMIT SHIELD


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The source requested a permit shield for the following regulations in the renewal application submitted on 5/31/2016. Each request was reviewed and the shield was either granted or denied pursuant to the reasoning outlined in this section.

The following requests for permit shield were granted pursuant to the justification given:

o Colorado Regulation No. 1 Section III.A.1.b – for engines only

Colorado Regulation No. 1 Section III.A.1.b sets the particulate matter standards for fuel burning equipment. Engines, pursuant to the Colorado Common Provisions Regulation, are not considered fuel burning equipment and are therefore not subject to the Colorado Regulation No. 1 PM standards. As such, the permit shield for these requirements for the engines only has been granted.

The following requests for permit shield were denied pursuant to the justification given:

o 40 CFR Part 63 Subpart HH Major Source Requirements

At the time of permit issuance on XX/XX/XXXX, the Bailey Compressor Station is considered to be an area source under MACT HH, and is therefore exempt from major source requirements. The Division will not apply permit shields to regulations that could potentially become applicable during the permit term due to changes that frequently occur at oil and natural gas facilities (e.g., modifications that increase emissions above major source HAP levels can trigger major MACT requirements, modifications or reconstructions can trigger NSPS requirements, etc.). As such, the permit shield for MACT HH was denied.

o 40 CFR Part 60 Subpart OOOO

At the time of permit issuance on XX/XX/XXXX, the Bailey Compressor Station has not constructed, modified or reconstructed any piece of equipment during the applicability timeframe of NSPS OOOO (8/23/2011-9/18/2015) and is therefore not currently subject to this regulation. The Division will not apply permit shields to regulations that could potentially become applicable during the permit term due to changes that frequently occur at oil and natural gas facilities (e.g., modifications that increase emissions above major source HAP levels can trigger major MACT requirements, modifications or reconstructions can trigger NSPS requirements, etc.). As such, the permit shield for NSPS OOOO was denied.

In addition to the permit shields requested in the 5/31/2016 renewal application, the permit shields granted in the 6/1/2012 permit issuance were revisited and revised as follows:


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The following permit shields were removed from the operating permit, pursuant to the justification given:

o Colorado Regulation No. 3, Part D – PSD/NANSR Requirements

At the time of permit issuance on XX/XX/XXXX, the Bailey Compressor Station Potential to Emit (PTE) is less than the major stationary source threshold of 250 tons/year for the purposes of PSD. In addition, the Bailey Compressor Station is not located in an area designated as non-attainment for any criteria pollutant. As such, the PSD and NANSR requirements do not apply to the Bailey Compressor Station at this time. However, future construction or modifications could trigger PSD requirements if these changes result in a sufficient increase in emissions. Because the permit shield is intended to apply to regulations that could never be applicable to the facility, the permit shield for Colorado Regulation No. 3, Part D was removed from the operating permit.

o Colorado Regulation No. 7, Section XVIII – Pneumatic Controller Requirements

Pursuant to the 5/31/2016 renewal application, the Bailey Compressor Station operates natural gas driven pneumatic controllers that are subject to Colorado Regulation No. 7, Section XVIII. These requirements were included in the operating permit (Section V above). As such, this permit shield was removed from the operating permit.

The following permit shield justifications were updated as follows:

o Colorado Regulation No. 7, Sections III, IV and VI – Storage of Petroleum Liquids and VOC

These sections set forth applicable requirements for the storage of petroleum liquid. The intent of this rule was to regulate loading facilities and to capture storage tanks not otherwise subject to storage requirements of Colorado Regulation No. 7 (i.e., not controlled pursuant to Section XII and XVII). The Bailey Compressor Station is not considered to be a “loading facility”. Furthermore, the condensate storage tanks at the Bailey Compressor Station are subject to Section XVII.B and XVII.C. As such, this facility is otherwise regulated and is therefore not subject to Colorado Regulation No. 7, Sections III, IV and VI.

o Colorado Regulation No. 7, Section VII – Crude Oil

This section sets forth applicable requirements of crude oil handling storage. The Bailey Compressor Station does not store crude oil and does not utilize any tanks in excess of 40,000 gallons (~952 bbl). As such, this facility is not subject to Colorado Regulation No. 7, Section VII.


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o Colorado Regulation No. 7, Section VIII – Petroleum Refining

This section sets forth applicable requirements of crude oil processing and refining. The Bailey Compressor Station does not handle crude oil and is not considered a “refinery”. As such, this facility is not subject to Colorado Regulation No. 7, Section VIII.

VIII. STREAMLINING OF APPLICABLE REQUIREMENTS

This section addresses the conditions streamlined from this permit:

Colorado Regulation No. 7, Section XVII.C.1.d.(v)

The Colorado Regulation No. 7 Section XVII.C.1.d.(v) requirement to inspect the flare controlling condensate storage tanks not more frequently than every 7 days, but at least every 31 days, was streamlined out of the operating permit with respect to the inspection frequency only. Pursuant to the current Division-standard operating and maintenance (O&M) plan for condensate storage tanks located at facilities with permitted VOC emissions greater than or equal to 80 tons/year, the enclosed combustion device shall be inspected daily for visible emissions. Because the Bailey Compressor Station is permitted to emit VOC in excess of 80 tons/year (Section IX of this document), the inspection frequency requirement for visible flare emissions was increased to daily. As such, the Colorado Regulation No. 7, Section XVII.C.1.d.(v) frequency requirement was streamlined from the operating permit, in favor of daily monitoring.

Colorado Regulation No. 7, Section XVII.A.2

The Colorado Regulation No. 7 Section XVII.A.2 definition of Approved Instrument Monitoring Methods (AIMM) was streamlined out of the operating permit with respect to other Division-approved alternatives ONLY. EPA Method 21 is the required method to comply with the AIMM inspections necessary to monitor compliance with the capture requirements of Colorado Regulation No. 7, Section XVII.C.2.a. Because the AIMM definition is a state-only requirement, and EPA Method 21 is federally accepted, the AIMM definition was partially streamlined from the operating permit.

Colorado Regulation No. 7, Section XVII.C.3, Section XVII.F.8 and Section XVIII.E.2.c

The Colorado Regulation No. 7 Section XVII.C.3 requirement to retain records of storage tank parameters for 2 years, the Section XVII.F.8 requirement to retain records of LDAR inspection results for 2 years, and the Section XVIII.E.2.c requirement to retain records of gas driven pneumatic controller maintenance for 3 years have been streamlined out of the operating permit in favor of the federally-enforceable Colorado Regulation No. 3 record retention requirement of five years for operating permits. Because the five year period is more stringent and Colorado Regulation No. 3 is federally enforceable, the state-only enforceable records retention requirement of Sections XVII.C.3, XVII.F.8 and


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XVIII.E.2.c were streamlined out in favor of the five year requirement from Colorado Regulation No. 3, Part C, Section V.C.6.b.


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IX. FACILITY-WIDE EMISSION SUMMARY

AIRS ID Facility ID Source

Controlled Emissions (tons/year) Uncontrolled Emissions (tons/year)

NOx CO VOC Reportable

HAP NOx CO VOC

Reportable HAP

001 ENG01 Compressor Engine 24.77 8.88 17.34 2.28 24.77 88.83 34.68 15.89





005 TEG01 TEG Dehydration Unit -- -- 4.44 1.54 -- -- 136.46 47.35

006 TNK01-05 Condensate Storage Tanks -- -- 10.63 0.37 -- -- 327.01 11.34

008 FLARE Facility Flare 2.56 5.10 -- -- 2.56 5.10 -- --

009 LOADING Condensate Truck Loading -- -- 3.15 -- -- -- 3.15 --





Total Permitted Facility Emissions (tons/year) 184.30 70.06 157.82 23.58 184.30 654.96 1128.58 317.95


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Uncontrolled HAP Emissions (Reportable)


Calculated Reportable HAP Uncontrolled Emissions (tons/year)

Acetaldehyde Acrolein Methanol Formaldehyde n-

Hexane 2,2,4-TMP

Benzene Toluene Ethyl

benzene Xylenes

001 ENG01 Compressor Engine 0.91 0.56 0.27 14.16 -- -- -- -- -- --


004 ENG03 Compressor Engine 1.21 0.74 0.36 18.89 0.16 -- -- -- -- --



005 TEG01 TEG Dehydration Unit -- -- -- -- 3.42 -- 14.60 22.48 0.98 5.87

006 TNK01-05 Condensate Storage Tanks -- -- -- -- 7.40 0.49 1.13 1.71 -- 0.61

008 FLARE Facility Flare -- -- -- -- -- -- -- -- -- --

009 LOADING Condensate Truck Loading -- -- -- -- -- -- -- -- -- --





Total Permitted Facility Emissions (tons/year) 6.64 4.08 1.98 103.86 21.73 0.49 59.53 91.64 3.91 24.08


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Controlled HAP Emissions (Reportable)


Calculated Reportable HAP Controlled Emissions (tons/year)

Acetaldehyde Acrolein Methanol Formaldehyde n-

Hexane 2,2,4-TMP

Benzene Toluene Ethyl

benzene Xylenes







006 TNK01-05 Condensate Storage Tanks -- -- -- -- 0.24 0.02 0.04 0.06 -- 0.02

008 FLARE Facility Flare -- -- -- -- -- -- -- -- -- --

009 LOADING Condensate Truck Loading -- -- -- -- -- -- -- -- -- --





Total Permitted Facility Emissions (tons/year) 3.32 2.04 0.99 10.39 1.01 0.02 1.93 2.98 0.13 0.78

2015 Actual Facility Emissions (tons/year) 3.267 2.015 -- 10.27 0.22 -- 2.097 2.92 0.06 0.38


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Information Relied Upon

Facility ID Information Source

ENG01 APEN rec'd 11/26/2014; mfg. EF's for NOx, CO, VOC; uncontrolled HAP EF's from AP-42 Table 3.2-2; mfg. CE for NOx, CO, VOC, CH2O; 50% CE for HAP





TEG01 APEN rec'd 11/26/2014; composition based on 5/2/2007 sample, emissions based on 3/18/2009 GLYCalc run, both submitted with 3/4/2010 CP 07GA0569 application

TNK01-05 APEN rec'd 11/26/2014; composition based on 6/22/2006 sample, emissions based on 5/21/2007 E&P TANKS run, both submitted with 6/28/2007 CP 07GA0569 application

FLARE APEN rec'd 11/26/2014; TCEQ EF's for NOx, CO; based on calculation submitted with 3/4/2010 CP 07GA0569 application

LOADING APEN rec'd 6/20/2007; emissions based on AP-42 Chapter 5.2, Eqn. (1); based on calculation submitted with 5/31/2016 renewal application



