Air Pollution Control (2024)

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Air Pollution Control

Title V Permit to Operate

Statement of Basis for Permit No. V-SUIT-0046-2024.00

July 21, 2025

Red Cedar Gathering Company

Worford Ridge Compressor Station

Southern Ute Indian Reservation

La Plata County, Colorado

1. Facility Information

a. Location

The Worford Ridge Compressor Station (Worford Ridge), owned and operated by Red Cedar Gathering

Company (Red Cedar), is located within the exterior boundary of the Southern Ute Indian Reservation. The

exact location is Section 16, T33N, R8W in La Plata County, at latitude North 37.100880 and longitude

West -107.721620. The mailing address is:

Red Cedar Gathering Company

Worford Ridge Compressor Station

125 Mercado St., Suite 201

Durango, CO 81301

b. Contacts

Facility Contact:

Ethan Hinkley

Air Quality Compliance Manager

Red Cedar Gathering Company

125 Mercado St., Suite 201

Durango, CO 81301

(970) 764-6495

Responsible Official:

Coy Bryant

President – Chief Operating Officer

Red Cedar Gathering Company

125 Mercado St., Suite 201

Durango, CO 81301

(970) 764-6900

c. Description of Operations

According to Red Cedar, the Worford Ridge Compressor Station is a natural gas compression facility

located within the exterior boundaries of the Southern Ute Indian Reservation in Southwestern Colorado.

Worford Ridge receives coal-bed methane gas gathered from nearby sources and dehydrates and

compresses the natural gas to transmission pipeline specifications. Gas entering the facility from the field

is first fed to an inlet separator that gravimetrically removes water that may have formed/condensed during

transportation from the supplying gas wells. The water is transferred to a storage tank where it is stored

until removal from the facility. The pipelines are periodically cleaned using pigging operations in the

southwest corner of the facility. Separator overhead gas is fed to one of the four compressor engines from

a common suction header. The compressors discharge gas to a common discharge header that feeds to

scrubbers. The scrubbers separate and collect liquids that may have formed during compression. The

compressed gas is then fed to the dehydration unit. Tri-ethylene glycol is circulated counter-currently and

absorbs water from the saturated gas. Rich glycol is circulated to a reboiler, where moisture is driven to the

atmosphere by heating the glycol. Dry gas exits the contactors and is directed to the sales line, where it is

metered and exits the facility. The gas processing capacity of the facility is approximately 40 MMscf/d with

four compressor engines operating.

The primary source for emissions is from the facility’s four natural gas-fired, four-stroke lean-burn (4SLB)

spark ignition (SI) compressor engines, and one tri-ethylene glycol (TEG) dehydrator.

d. List of all Units and Emission-Generating Activities

Red Cedar provided the information contained in Tables 1 and 2 in its Part 70 permit renewal application.

Table 1 lists emission units and emission generating activities, including any air pollution control devices.

Emission units identified as “insignificant” emitting units (IEUs) are listed separately in Table 2.

Table 1 - Emission Units

Red Cedar Gathering Company – Worford Ridge Compressor Station

Emission

Control

Description

Unit ID

Equipment

Waukesha L5794LT (4SLB SI) Natural Gas-Fired Compressor Engine

1,449 Name Plate Rated HP

C-101

Serial No.

C-16160/1

Install Date:

06/15/2021

C-102

Serial No.

C-15809/1

Install Date:

11/06/2017

C-103

Serial No.

C-15966/1

Install Date:

11/25/2019

C-104

Serial No.

C-17235/1

Install Date:

07/09/2014

None

Tri-Ethylene Glycol (TEG) Dehydrator 40 (MMscf/day)

None

Serial No.

N/A

Install Date:

08/01/2006

The Southern Ute Indian Tribe/State of Colorado Environmental Commission’s Reservation Air Code

allows sources to separately list in the permit application units or activities that qualify as “insignificant”

based on potential emissions below 2 tpy for all regulated pollutants that are not listed as hazardous air

pollutants (HAPs) under Section 112(b) of the Clean Air Act (CAA) and below 1,000 lbs per year or the de

minimis level established under Section 112(g), whichever is lower, for HAP emissions. However, the

application may not omit information needed to determine the applicability of, or to impose, any applicable

requirement, or to calculate the fee. Units that qualify as “insignificant” for the purposes of the Part 70

application are in no way exempt from applicable requirements or any requirements of the Part 70 permit.

Red Cedar stated in its Part 70 permit renewal application the emission units in Table 2, below, are

insignificant. The application provided calculations for fugitive emissions, heaters, tanks based on a

combination of EPA’s Protocol for Equipment Leak Emission Estimates, Table 2-4, November 1995;

manufacturer’s specifications, EPA’s AP-42 emission factors, and EPA Tanks 4.0.9d emission model. This

data supports the source’s claim that these units qualify as insignificant.

Table 2 - Insignificant Emission Units

Red Cedar Gathering Company – Worford Ridge Compressor Station

Emission

Unit ID

Amount

Description

Size

Units

RB1

H-502

TK-502

TK-503

TK-504 - 507

TK-508, 509

TK-601

FUG

N/A

Natural Gas-Fired Regenerator Burner

Tank Heater

Used Oil Tank

Dehydrator Still Vent Tank

Lube Oil Storage Tank

Ethylene Glycol Storage Tank

Tri-ethylene Glycol (TEG) Storage Tank

Fugitive Emissions

0.75

0.12

21,000

2,520

500

N/A

MMBtu/hr

Gallons

N/A

e. Facility Construction and Permitting History

DATE

DESCRIPTION OF ACTION

PERMIT NUMBER

June 2007

Initial Part 71 Permit Issued

# V-SU-0046-07.00

January 2008

Administrative Amendment

# V-SU-0046-07.01

January 31, 2014

Initial Part 70 Permit Issued

# V-SUIT-0046-2014.00

May 18, 2015

Minor Permit Revision Issued

# V-SUIT-0046-2014.01

January 9, 2017

Administrative Permit Revision

# V-SUIT-0046-2014.02

December 19, 2017

Administrative Permit Revision

# V-SUIT-0046-2014.03

June 14, 2019

1st Part 70 Permit Renewal

# V-SUIT-0046-2019.00

July 21, 2025

2nd Part 70 Permit Renewal

# V-SUIT-0046-2024.00

f. Potential to Emit

Under RAC 1-103(51), potential to emit (PTE) is defined as the maximum capacity of a stationary source

to emit a pollutant under its physical and operational design. Any physical or operational limitation on the

capacity of the source to emit a pollutant, including air pollution control equipment and restrictions on hours

of operation or on the type or amount of material combusted, stored, or processed, shall be treated as part

of its design if the limitation, or the effect it would have on emissions, is federally enforceable.

The PTE for Worford Ridge was listed by Red Cedar in Forms “GIS”, “PTE”, and the various forms

“EMISS” of the Part 70 operating permit renewal application. Table 3 shows PTE data broken down by

each individual emission unit, as well as the total facility-wide PTE.

Emission

Unit ID

Table 3 - Potential to Emit

Red Cedar Gathering Company – Worford Ridge Compressor Station

Regulated Air Pollutants

in tpy

NOx

VOC

SO2

PM10

Lead

Total

HAPs

C-101

C-102

C-103

C-104

26.82

0.00

3.61

8.35

0.00

0.46

0.00

24.81

0.00

3.32

4.19

Largest

Single

HAP

(CH2O)

2.45

0.00

Total IEUs

0.40

0.00

0.40

0.00

0.10

0.00

3,765.57

TOTAL

107.68

22.79

0.00

1.84

99.64

0.00

17.48

9.80

33,165.71

GHGs

(CO2 e

tpy)

6,338.72

4,045.26

2. Tribal Authority

Red Cedar’s Worford Ridge Compressor Station is located within the exterior boundaries of the Southern

Ute Indian Reservation and is thus within Indian Country as defined at 18 U.S.C. §1151. On March 2, 2012,

the EPA determined that the Southern Ute Indian Tribe of the Southern Ute Indian Reservation had met the

requirements of 40 CFR §70.4(b) for full approval to administer its Clean Air Act Title V, Part 70 Permitting

Program (Program). In concert with that Program approval, the EPA also found that the Tribe met the

requirements of Section 301(d)(2) of the CAA and 40 CFR §49.6 for treatment “in the same manner as a

state” for the purposes of issuing CAA Title V, Part 70 operating permits. The EPA promulgated its

approval of the Tribe’s applications on March 15, 2012 (77 FR 15267). The requirements of the Clean Air

Act Title V, Part 70 Permitting Program (Program) have been incorporated at Article II, Part 1 of the

Reservation Air Code. Therefore, the Southern Ute Indian Tribe is the appropriate governmental entity to

issue the Title V permit to this facility.

The Reservation Air Code: The Reservation Air Code was adopted pursuant to the authority vested in the

Southern Ute Indian Tribe/State of Colorado Environmental Commission by (1) the Intergovernmental

Agreement Between the Southern Ute Indian Tribe and the State of Colorado Concerning Air Quality

Control on the Southern Ute Indian Reservation dated December 13, 1999, (2) tribal law (Resolution of the

Council of the Southern Ute Indian Tribe No. 00-09), (3) State law (C.R.S. § 24- 62-101), and (4) as

recognized in federal law (Act of October 18, 2004, Pub. L. No. 108-336, 118 Stat.1354).

NSPS and NESHAP Delegation: On September 6, 2013, the Southern Ute Indian Tribe received delegation

from the EPA to incorporate by reference into the Reservation Air Code and enforce certain subparts of the

new source performance standards (NSPS) and national emission standards for hazardous air pollutants

(NESHAP) under Sections 111 and 112 of the Clean Air Act, respectively (78 FR 40635). These NSPS and

NESHAP subparts generally apply to oil and gas operations within the exterior boundaries of the Southern

Ute Indian Reservation and were adopted, unchanged, into the Reservation Air Code as Parts 2 and 3.

Tribal Minor New Source Review Program: Minor sources of air pollution located within the Southern Ute

Indian Reservation exterior boundaries must comply with either the “Federal Implementation Plan for

Managing Air Emissions from True Minor Sources in Indian Country in the Oil and Natural Gas Production

and Natural Gas Processing Segments of the Oil and Natural Gas Sector” listed at 40 CFR §49.101 – 105

or the “Federal Minor New Source Review Program in Indian Country” listed at 40 CFR §49.151 – 164.

3. Applicable Requirements

The following discussion addresses a selection of the regulations from the Code of Federal Regulations

(CFR) at Title 40. These discussions are based on the information provided by Red Cedar in its Part 70

permit renewal application and are only intended to present the information certified to be true and accurate

by the Responsible Official of this facility. The following discussion does not include all potentially

applicable regulations and is not intended to represent official Tribe applicability determinations.

Tribal Minor New Source Review (TMNSR) – 40 CFR Part 49

EPA promulgated the federal rule “Review of New Sources and Modifications in Indian Country,”

otherwise known as the Tribal Minor New Source Review Rule (TMNSR), on July 1, 2011 (76 FR 38748).

The TMNSR rule applies to all new or modified industrial facilities in Indian country with a potential to

emit equal to or greater than the minor NSR thresholds, but less than the major source thresholds, which

are generally 100 to 250 tons per year (tpy). The minor NSR thresholds for attainment/unclassifiable areas

are displayed in the table below:

40 CFR 49.153 Minor NSR Thresholds

Minor NSR Thresholds for

Regulated NSR Pollutant

Attainment/Unclassifiable Areas in Tons Per

Year (TPY)

Carbon Monoxide (CO)

Nitrogen Oxides (NOx)

Sulfur Dioxide (SO2)

Volatile Organic Compounds (VOC)

PM10

PM2.5

Lead

0.1

Fluorides

Sulfuric Acid Mist

Hydrogen Sulfide (H2S)

Total Reduced Sulfur (including H2S)

Reduced Sulfur Compounds (including H2S)

Municipal Waste Combustor Emissions

Municipal Solid Waste Landfill Emissions

(measured as nonmethane organic compounds)

On June 11, 2024, the Southern Ute Indian Tribe received partial delegation of the Tribal Minor New Source

Review Program through the Agreement for Delegation of Partial Administrative Authority of Certain

Federal Clean Air Act Indian Country Programs to the Southern Ute Indian Tribe by the United States

Environmental Protection Agency. The two federal Clean Air Act (CAA) Programs are: (l) the Federal

Implementation Plan for Managing Air Emissions from True Minor Sources in Indian Country in the Oil

and Natural Gas Production and Oil and Natural Gas Processing Segments of the Oil and Natural Gas Sector

(FIP), 40 Code of Federal Regulations (C.F.R.) Part 49, Subpart C, Sections 49.101 through 49.105 and (2)

the Federal Minor New Source Review Program in Indian Country (MNSR), 40 C.F.R. Part 49, Subpart C,

Sections 49.151 through 49.164. Under the FIP, all new and modified true minor oil and gas sources are

required to register with the EPA to obtain coverage. Under the MNSR, minor sources and minor

modifications at an existing source are required to obtain a preconstruction permit prior to beginning

construction. The MNSR program provides a mechanism for a source to obtain authorization to construct

through a site-specific permit or to accept federally enforceable requirements to become a “synthetic minor”

source under NSR or the Title V permitting program. The program also includes general permits for six

source categories.

Future modifications at Worford Ridge will be subject to the TMNSR rule; however, no TMNSR permits

have been issued to this facility at this time.

Prevention of Significant Deterioration (PSD) - 40 CFR 52.21

PSD is a preconstruction review requirement of the CAA that applies to proposed projects that are

sufficiently large (in terms of emissions) to be considered a major stationary source or a major modification

of an existing stationary source as defined in 40 CFR §52.21 (b)(1)(i) and (b)(2)(i). A new stationary source

or a modification to an existing stationary source is major if the proposed project has the PTE any pollutant

regulated under the CAA in amounts equal to or exceeding specified major source thresholds, which are

100 tpy for 28 listed industrial sources (named source) and 250 tpy for all other sources. PSD also applies

to modifications at existing major sources that cause a “significant net emissions increase” at that source.

Significance levels for each pollutant are defined in the PSD regulations at 40 CFR §52.21 (b)(23). A

modification is a physical change or change in the method of operation.

Worford Ridge is not a PSD named source. Therefore, the PTE threshold for determining PSD applicability

for this source is 250 tpy for criteria pollutants. The PTE of regulated pollutants at this facility are currently

below major source thresholds, therefore, this site is not subject to the requirements of PSD.

New Source Performance Standards (NSPS)

40 CFR Part 60, Subpart A: General Provisions. This Subpart applies to the owner or operator of any

stationary source that contains an affected facility, the construction or modification of which is commenced

after the date of publication of any standard in Part 60. The general provisions under Subpart A apply to

sources that are subject to the specific subparts of Part 60.

As explained below, Worford Ridge is not subject to specific subparts under 40 CFR part 60.

Therefore, the General Provisions of Part 60 do not apply.

40 CFR Part 60, Subpart Db: Standards of Performance for Industrial-Commercial-Institutional Steam

Generating Units. This rule applies to steam generating units with a heat input capacity of greater than 100

MMBtu/hr and commenced construction, modification, or reconstruction after June 19, 1984.

According to Red Cedar, Worford Ridge has no steam generating units with a heat input capacity

greater than 100 MMBtu/hr at the facility. Therefore, Subpart Db does not apply.

40 CFR Part 60, Subpart Dc: Standards of Performance for Small Industrial-Commercial-Institutional

Steam Generating Units. This rule applies to steam generating units with a maximum design heat capacity

of 100 MMBtu/hr or less, but greater than or equal to 10 MMBtu/hr and commenced construction,

modification, or reconstruction after June 9, 1989.

According to Red Cedar, Worford Ridge has no steam generating units with a maximum heat input

capacity of 100 MMBtu/hr or less, but greater than or equal to 10 MMBtu/hr at the facility.

Therefore, Subpart Dc does not apply.

40 CFR Part 60, Subpart K: Standards of performance for Storage Vessels for Petroleum Liquids for which

Construction, Reconstruction, or Modification Commenced After June 11, 1973, and Prior to May 19, 1978.

This rule applies to storage vessels for petroleum liquids with a storage capacity greater than 40,000 gallons.

40 CFR Part 60, Subpart K does not apply to storage vessels for petroleum or condensate stored, processed,

and/or treated at a drilling and production facility prior to custody transfer.

According to Red Cedar, Worford Ridge has no storage vessels for petroleum liquids for which

construction, reconstruction, or modification commenced after June 11, 1973, and Prior to May 19,

1978. Therefore, Subpart K does not apply.

40 CFR Part 60, Subpart Ka: Standards of Performance for Storage Vessels for Petroleum Liquids for which

Construction, Reconstruction, or Modification Commenced After May 18, 1978, and Prior to

July 23, 1984. This rule applies to storage vessels for petroleum liquids with a storage capacity greater than

40,000 gallons. Subpart Ka does not apply to petroleum storage vessels with a capacity of less than 420,000

gallons used for petroleum or condensate stored, processed, or treated prior to custody transfer.

According to Red Cedar, Worford Ridge has no storage vessels for petroleum liquids for which

construction, reconstruction, or modification commenced after May 18, 1978, and prior to July 23,

1984. Therefore, Subpart Ka does not apply.

40 CFR Part 60, Subpart Kb: Standards of Performance for Volatile Organic Liquid Storage Vessels

(Including Petroleum Liquid Storage Vessels) for which Construction, Reconstruction, or Modification

Commenced After July 23, 1984, and On or Before October 4, 2023. This rule applies to storage vessels

with a capacity greater than or equal to 75 cubic meters (472 bbl).

According to Red Cedar, there are no tanks storing volatile organic liquids at Worford Ridge that

are less than 75 m3 (472 bbl or 19,813 gal). Therefore, Subpart Kb does not apply.

40 CFR Part 60, Subpart GG: Standards of Performance for Stationary Gas Turbines. This rule applies to

stationary gas turbines, with a heat input at peak load equal to or greater than 10.7 gigajoules per hour (10

MMBtu/hr), that commenced construction, modification, or reconstruction after October 3, 1977.

According to Red Cedar, there are no stationary gas turbines located at Worford Ridge. Therefore,

Subpart GG does not apply.

40 CFR Part 60, Subpart KKK: 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. This rule applies to compressors and other equipment

at onshore natural gas processing facilities. As defined in this subpart, a natural gas processing plant is any

processing site engaged in the extraction of natural gas liquids (NGLs) from field gas, fractionation of

mixed NGLs to natural gas products, or both. NGLs are defined as the hydrocarbons, such as ethane,

propane, butane, and pentane that are extracted from field gas.

According to Red Cedar, Worford Ridge does not extract natural gas liquids from field gas, nor does

it fractionate mixed NGLs to natural gas products, and thus does not meet the definition of a natural

gas processing plant under this subpart. Therefore, subpart KKK does not apply.

40 CFR Part 60, Subpart LLL: Standards of Performance for SO 2 Emissions from Onshore Natural Gas

Processing for which construction, reconstruction, or modification commenced after January 20, 1984, and

on or before August 23, 2011. This rule applies to sweetening units and sulfur recovery units at onshore

natural gas processing facilities. As defined in this subpart, sweetening units are process devices that

separate hydrogen sulfide (H2S) and carbon dioxide (CO2) from a sour natural gas stream. Sulfur recovery

units are defined as process devices that recover sulfur from the acid gas (consisting of H 2S and CO2)

removed by a sweetening unit.

According to Red Cedar, Worford Ridge does not perform sweetening or sulfur recovery at the

facility. Therefore, subpart LLL does not apply.

40 CFR Part 60, Subpart IIII: Standards of Performance for Stationary Compression Ignition Internal

Combustion Engines. This subpart establishes emission standards and compliance requirements for the

control of emissions from stationary combustion ignition (CI) internal combustion engines (ICE) that

commence construction (which for the purposes of this subpart is the date the engine is ordered by the

owner or operator) after July 11, 2005, and are manufactured as a certified National Fire Protection

Association (NFPA) fire pump engine after July 1, 2006, or are manufactured after April 1, 2006, and are

not fire pump engines.

According to Red Cedar, there are no stationary compression ignition (CI) internal combustion

engines (ICE) located at Worford Ridge. Therefore, Subpart IIII does not apply.

40 CFR Part 60, Subpart JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion

Engines. This subpart establishes emission standards and compliance requirements for the control of

emissions from stationary spark ignition (SI) internal combustion engines (ICE) that commenced

construction, modification, or reconstruction after June 12, 2006, where the SI ICE are manufactured on or

after specified manufacture trigger dates. The manufacture trigger dates are based on the engine type, fuel

used, and maximum engine horsepower.

For the purposes of this subpart, the date that construction commences is the date the engine is ordered by

the owner or operator (See 40 CFR 60.4230(a)).

Red Cedar provided the following information:

Table 4 - NSPS Subpart JJJJ Applicability Determination

Red Cedar Gathering Company – Worford Ridge Compressor Station

Unit

Serial No.

C-101

C-16160/1

C-102

C-15809/1

C-103

C-15966/1

C-104

C-17235/1

Unit Description

Waukesha

L5794LT 4SLB

Compressor Engine

Waukesha

L5794LT 4SLB

Compressor Engine

Waukesha

L5794LT 4SLB

Compressor Engine

Waukesha

L5794LT 4SLB

Compressor Engine

Trigger Date

for

Applicability Manufactured

on or after

Fuel

Maximum

Manufacture

Date1

Commenced

Construction

Date

Natural

Gas

1,449

11/01/2005

Prior to

06/12/2006

07/1/2007

Natural

Gas

1,449

08/01/2005

Prior to

06/12/2006

07/1/2007

Natural

Gas

1,449

08/01/2005

Prior to

06/12/2006

07/1/2007

Natural

Gas

1,449

01/16/2007

After

06/12/2006

07/1/2007

Per Red Cedar, these engines have not been modified or reconstructed (as defined in Part 60) since June 12, 2006

According to Red Cedar, emission units C-101, C-102, and C-103 commenced construction before

June 12, 2006. Emission unit C-104 commenced construction after June 12, 2006, but was

manufactured prior to July 1, 2007 (the trigger date for engines with a maximum engine power

greater than or equal to 500 HP), and therefore has no requirements under Subpart JJJJ. Additionally,

none of the engines have been reconstructed or modified (as defined in §60.15) since June 12, 2006.

Therefore, the requirements of Subpart JJJJ do not apply.

Should Red Cedar propose to install a replacement engine for unit C-101, C-102, C-103, and or C104 that is subject to Subpart JJJJ, Red Cedar may not be allowed to use the off-permit changes

provision and may be required to submit a minor permit modification application to incorporate

Subpart JJJJ requirements into the permit.

40 CFR Part 60, Subpart KKKK: Standards of Performance for Stationary Combustion Turbines. This

subpart establishes emission standards and compliance schedules for the control of emissions from

stationary combustion turbines that commenced construction, modification, or reconstruction after February

18, 2005. The rule applies to stationary combustion turbines with a heat input at peak load equal to or greater

than 10.7 gigajoules (10 MMBtu) per hour.

According to Red Cedar, there are no stationary combustion turbines located at Worford Ridge.

Therefore, Subpart KKKK does not apply.

40 CFR Part 60, Subpart OOOO: Standards of Performance for Crude Oil and Natural Gas Production,

Transmission, and Distribution. This subpart establishes emission standards and compliance schedules for

the control of VOC and SO2 emissions from affected facilities that commence construction, modification,

or reconstruction after August 23, 2011, and on or before September 18, 2015. Affected facilities under this

subpart include gas wells, compressors, pneumatic controllers, storage vessels, process unit equipment, and

sweetening units.

According to Red Cedar, Worford Ridge does not include any affected facilities that have been

constructed, modified, or reconstructed after August 23, 2011, and on or before September 18, 2015.

Therefore, Subpart OOOO does not apply. However, requirements of EPA’s Super-Emitter

Program will apply should they occur.

40 CFR Part 60, Subpart OOOOa: Standards of Performance for Crude Oil and Natural Gas Facilities. This

subpart establishes emission standards and compliance schedules for the control of the pollutant greenhouse

gases (GHG). The greenhouse gas standard in this subpart is in the form of a limitation on emissions of

methane from affected facilities in the crude oil and natural gas source category that commence

construction, modification, or reconstruction after September 18, 2015. This subpart also establishes

emission standards and compliance schedules for the control of volatile organic compounds (VOC) and

sulfur dioxide (SO2) emissions from affected facilities in the crude oil and natural gas source category that

commence construction, modification, or reconstruction after September 18, 2015, and on or before

December 6, 2022.

According to Red Cedar, Worford Ridge does not include any affected facilities that have been

constructed, modified, or reconstructed after September 18, 2015, and on or before December 6,

2022. Therefore, Subpart OOOOa does not apply. However, requirements of EPA’s SuperEmitter Program will apply should they occur.

40 CFR Part 60, Subpart OOOOb: Standards of Performance for Crude Oil and Natural Gas Facilities.

This subpart establishes emission standards and compliance schedules for the control of the pollutant

greenhouse gases (GHG). The greenhouse gas standard in this subpart is in the form of a limitation on

emissions of methane from affected facilities in the crude oil and natural gas source category that

commence construction, modification, or reconstruction after December 6, 2022. This subpart also

establishes emission standards and compliance schedules for the control of volatile organic compounds

(VOC) and sulfur dioxide (SO2) emissions from affected facilities in the crude oil and natural gas source

category that commence construction, modification, or reconstruction after December 6, 2022.

According to Red Cedar, Worford Ridge does not include any affected facilities that have been

constructed, modified, or reconstructed after December 6, 2022. Therefore, Subpart OOOOb does

not apply. However, requirements of EPA’s Super-Emitter Program will apply should they

occur.

National Emission Standards for Hazardous Air Pollutants (NESHAP)

40 CFR Part 63, Subpart A: General Provisions. This subpart contains national emissions standards for

HAPs that regulate specific categories of sources that emit one or more HAP regulated pollutants under the

CAA. The general provisions under Subpart A apply to sources that are subject to the specific subparts of

Part 63.

As explained below, Worford Ridge is subject to specific subparts under 40 CFR part 63. Therefore,

the General Provisions of Part 63 do apply.

40 CFR Part 63, Subpart HH: National Emission Standards for Hazardous Air Pollutants from Oil and

Natural Gas Production Facilities. This subpart applies to the owners and operators of affected units located

at natural gas production facilities that are area or major sources of HAPs, as defined by §63.761, and that

process, upgrade, or store natural gas prior to the point of custody transfer, or that process, upgrade, or store

natural gas prior to the point at which natural gas enters the natural gas transmission and storage source

category or is delivered to a final end user. The affected units are glycol dehydration units, storage vessels

and the group of ancillary equipment, and compressors intended to operate in volatile hazardous air

pollutant service, which are located at natural gas processing plants.

Facility

For the purpose of a major source determination, facility means oil and natural gas production and

processing equipment that is located within the boundaries of an individual surface site as defined in Subpart

HH. Examples of facilities in the oil and natural gas production category include, but are not limited to:

well sites, satellite tank batteries, central tank batteries, a Central Delivery Point that transports natural gas

to a natural gas processing plant, and natural gas processing plants.

Production Field Facility

Production field facilities are those located prior to the point of custody transfer. The definition of custody

transfer (40 CFR 63.761) means the point of transfer after the processing/treating in the producing

operation, except for the case of a natural gas processing plant, in which case the point of custody transfer

is the inlet to the plant.

Natural Gas Processing Plant

A natural gas processing plant is defined in 40 CFR 63.761 as any processing site engaged in the extraction

of NGLs from field gas, or the fractionation of mixed NGLs to natural gas products, or a combination of

both. A treating plant or gas plant that does not engage in these activities is considered to be a production

field facility.

Throughput Exemption

Those sources whose maximum natural gas throughput, as appropriately calculated per §63.760(a)(1)(i)

through (a)(1)(iii), is less than 18,400 standard cubic meters per day and a facility-wide actual annual

average hydrocarbon liquid throughput less than 39,700 liters per day are exempt from the requirements of

this subpart.

Major Source Determination for Production Field Facilities

The definition of major source in subpart HH (at 40 CFR 63.761) states, in part, that only emissions from

the dehydration units and storage vessels at production field facilities shall be aggregated when comparing

to the major source thresholds.

For facilities that are not production field facilities, HAP emissions from all HAP emission units shall be

aggregated.

Area Source Applicability

40 CFR Part 63, Subpart HH applies also to area sources of HAPs. An area source is a HAP source whose

total HAP emissions are less than 10 tpy of any single HAP or 25 tpy for all HAPs in aggregate. This subpart

requires different emission reduction requirements for glycol dehydration units found at oil and gas

production facilities based on their geographical location.

Units located in densely populated areas (determined by the Bureau of Census) and known as urbanized

areas with an added 2-mile offset and urban clusters of 10,000 people or more, are required to have emission

controls. Units located outside these areas will be required to have the glycol recirculation pump rate

optimized or operators must document that uncontrolled annual actual benzene emissions are less than 0.9

megagrams (1,984 lbs.).

Any source that determines that it is not a major source but has actual emissions of 5 tons per year of a

single HAP or 12.5 tons per year of a combination of HAP (i.e. 50 percent of the major source thresholds),

shall update its major source determination within 1 year of the prior determination and each year thereafter,

using gas composition data measured during the preceding 12 months.

Applicability of Subpart HH to Worford Ridge Compressor Station

According to Red Cedar, Worford Ridge is located prior to the point of custody transfer and is

therefore considered a production field facility and not a natural gas transmission or storage facility.

Potential HAP emissions from the glycol dehydration units and storage vessels at the facility are

less than the major source thresholds of 25 tpy total HAPS and 10 tpy of a single HAP. Therefore,

Worford Ridge is considered an area source of HAPs according to 40 CFR part 63, subpart HH.

Uncontrolled actual benzene emissions from the dehydration unit at the facility is less than 0.9

megagrams. Per 40 CFR 63.764(e)(1)(ii), the dehydration unit is exempt from the 40 CFR 63.764(d)

general standards for area sources. Therefore, only recordkeeping requirements apply to

Worford Ridge.

40 CFR Part 63, Subpart HHH: National Emission Standards for Hazardous Air Pollutants from Natural

Gas Transmission and Storage Facilities. This subpart applies to natural gas transmission and storage

facilities that transport or store natural gas prior to entering the pipeline to a local distribution company or

to a final end user, and that are a major source of hazardous air pollutant (HAP) emissions. Natural gas

transmission means the pipelines are used for long distance transport (excluding processing).

According to Red Cedar, Worford Ridge is a natural gas production facility and not a natural gas

transmission or storage facility. Therefore, Subpart HHH does not apply.

40 CFR Part 63, Subpart ZZZZ (RICE MACT): National Emission Standards for Hazardous Air Pollutants

for Stationary Reciprocating Internal Combustion Engines (RICE). This rule establishes national emission

limitations and operating limitations for HAPs emitted from stationary spark ignition reciprocating internal

combustion engines (SI RICE) and stationary compression ignition reciprocating internal combustion

engines (CI RICE).

For the purposes of this standard, construction or reconstruction is as defined in §63.2.

Summary of Applicability to Engines at Major HAP Sources

Major HAP Sources

Engine Type

Horse Power Rating

New / Existing

Applicability Trigger Date

SI ICE – All1

≥ 500 hp

New

On or After:

12/19/2002

SI ICE – 4SRB

> 500 hp

Existing

Before:

12/19/2002

SI ICE – All1

≤ 500 hp

New

On or After:

6/12/2006

SI ICE - All1

≤ 500 hp

Existing

Before:

6/12/2006

CI ICE - All2

≥ 500 hp

New

On or After:

12/19/2002

CI ICE – Non Emergency

> 500 hp

Existing

Before:

12/19/2002

CI ICE – All2

≤ 500 hp

New

On or After:

6/12/2006

CI ICE – All2

≤ 500 hp

Existing

Before:

6/12/2006

1. All includes emergency ICE, limited use ICE, ICE that burn land fill or digester gas, 4SLB, 2SLB, and 4SRB.

2. All includes emergency ICE and limited use ICE.

Summary of Applicability to Engines at Area Hap Sources

Area HAP Sources

Engine Type

Horse Power Rating

New / Existing

Applicability Trigger Date

SI ICE - All1

All hp

New

On or After:

6/12/2006

SI ICE - All1

All hp

Existing

Before:

6/12/2006

CI ICE - All2

All hp

New

On or After:

6/12/2006

CI ICE - All2

All hp

Existing

Before:

6/12/2006

1. All includes emergency ICE, limited use ICE, ICE that burn land fill or digester gas, 4SLB, 2SLB, and 4SRB.

2. All includes emergency ICE and limited use ICE.

Applicability of 40 CFR 63, Subpart ZZZZ to Worford Ridge Compressor Station:

Unit

Serial No.

C-101

C-16160/1

C-102

C-15809/1

C-103

C-15966/1

C-104

C-17235/1

Fuel

Site

Rated HP

Commenced Construction,

Reconstruction, or

Modification Date

Natural Gas

1,389

Prior to 06/12/2006

Natural Gas

1,389

Prior to 06/12/2006

Natural Gas

1,389

Prior to 06/12/2006

Natural Gas

1,389

After 06/12/2006

Unit Description

Waukesha L5794LT

4SLB Compressor Engine

Waukesha L5794LT

4SLB Compressor Engine

Waukesha L5794LT

4SLB Compressor Engine

Waukesha L5794LT

4SLB Compressor Engine

According to Red Cedar, Worford Ridge is an area source of HAPs as defined in subpart ZZZZ.

Emission units C-101, C-102, and C-103 commenced construction before June 12, 2006, and are

considered existing stationary RICE. Additionally, units C-101, C-102, and C-103 are not located

on gas pipelines and have 5 or fewer buildings intended for human occupancy and no buildings with

four or more stories within a 0.25-mile radius around the engines. Therefore, units C-101, C-102,

and C-103 are considered existing remote 4SLB stationary RICE and must meet the Subpart

ZZZZ requirements.

Emission unit C-104 is considered a new stationary RICE located at an area source of HAP. In

accordance with §63.6590(c)(1), C-104 must meet the requirements of Subpart ZZZZ by meeting

the requirements of 40 CFR Part 60, Subpart JJJJ. However, unit C-104 (a SI ICE with a maximum

engine power greater than or equal to 500 HP) was manufactured prior to July 1, 2007, and therefore

has no requirements under 40 CFR Part 60, Subpart JJJJ.

40 CFR Part 63, Subpart DDDDD (Boiler MACT): National Emission Standards for Hazardous Air

Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters. This

rule establishes national emission limitations and work practice standards for HAPs emitted from new and

existing industrial boilers, institutional boilers, commercial boilers, and process heaters that are located at

major sources of HAPs. Boilers or process heaters that combust natural gas for fuel or have a maximum

designed heat input capacity less than 10 MMBtu/hr are subject to work practice standards in lieu of

emission limits. For the purposes of this Subpart, an affected unit is an existing unit if it was constructed

prior to June 4, 2010.

According to Red Cedar, Worford Ridge is not a major source as defined in this subpart, or in 40

CFR Part 63, Subpart HH. Therefore, Subpart DDDDD does not apply.

40 CFR Part 63, Subpart JJJJJJ: National Emission Standards for Hazardous Air Pollutants for Area

Sources: Industrial, Commercial, and Institutional Boilers. This rule establishes national emission standards

and operating limitations for HAPs emitted from new and existing industrial boilers, institutional boilers,

and commercial boilers, as defined in §63.11237 and are located at area sources of HAPs, as defined in §

63.2, except as specified in §63.11195. For the purposes of this Subpart, an affected unit is an existing unit

if it was constructed prior to June 4, 2010.

According to Red Cedar, Worford Ridge does not have any coal, oil, or biomass boilers at the

facility. Therefore, JJJJJJ does not apply.

Compliance Assurance Monitoring (CAM) Rule

40 CFR Part 64: Compliance Assurance Monitoring Provisions. According to 40 CFR §64.2(a), the CAM

rule applies to each Pollutant Specific Emission Unit (PSEU) at a major source that is required to obtain a

Part 70 or Part 71 permit if the unit satisfies all of the following criteria:

The unit is subject to an emission limitation or standard for the applicable regulated air pollutant

other than an emissions limitation or standard that is exempt under §64.2(b)(1);

“§64.2(b)(1): Exempt emission limitations or standards. The requirements of this part shall not

apply to any of the following emission limitations or standards:

(i)

(ii)

(iii)

(iv)

(v)

(vi)

Emission limitations or standards proposed by the Administrator after November 15, 1990,

pursuant to Section 111 or 112 of the Act;

Stratospheric ozone protection requirements under Title VI of the Act;

Acid Rain Program requirements pursuant to Sections 404, 405, 406, 407(a), 407(b) or 410

of the Act;

Emissions limitations or standards or other applicable requirements that apply solely under

an emissions trading program approved or promulgated by the Administrator under the Act

that allows for trading emissions with a source or between sources;

An emissions cap that meets the requirements specified in §70.4(b)(12) or §71.6(a)(13)(iii)

of this chapter;

Emission limitations or standards for which a Part 70 or 71 permit specifies a continuous

compliance determination method, as defined in §64.1.”

“§64.1: Continuous compliance method means a method, specified by the applicable standard or

an applicable permit condition, which:

(1) Is used to determine compliance with an emission limitation or standard on a continuous basis,

consistent with the averaging period established for the emission limitation or standard; and

(2) Provides data either in units of the standard or correlated directly with the compliance limit.”

The unit uses a control device to achieve compliance with any such limit or standard; and

The unit has pre-control device emissions of the applicable regulated pollutant that are equal to or

greater than 100% of the amount, in tons per year, required for a source to be classified as a major

source.

According to Red Cedar’s application, Worford Ridge has no units with potential emissions equal

to or greater than the major source thresholds for an applicable regulated air pollutant. Therefore,

CAM does not apply.

Chemical Accident Prevention Program

40 CFR Part 68: Chemical Accident Prevention Provisions. This rule applies to stationary sources that

manufacture, process, use, store, or otherwise handle more than the threshold quantity of a regulated

substance in a process. Regulated substances include 77 toxic and 63 flammable substances which are

potentially present in the natural gas stream entering the facility and in the storage vessels located at the

facility. The quantity of a regulated substance in a process is determined according to the procedures

presented under §68.115. The regulations at §68.115(b)(l) and (2)(i) indicate that toxic and flammable

substances in a mixture do not need to be considered when determining whether more than a threshold

quantity is present at a stationary source if the concentration of the substance is below one percent by weight

of the mixture. The regulations at §68.115(b)(2)(iii) indicates that prior to entry into a natural gas processing

plant, regulated substances in naturally occurring hydrocarbon mixtures need not be considered when

determining whether more than a threshold quantity is present at a stationary source. Naturally occurring

hydrocarbon mixtures include condensate, field gas, and produced water.

Based on Red Cedar’s application, Worford Ridge does not have regulated substances above the

threshold quantities in this rule. Therefore, Worford Ridge is not subject to the requirement to

develop and submit a risk management plan.

Stratospheric Ozone and Climate Protection

40 CFR Part 82, Subpart F: Air Conditioning Units. According to Red Cedar’s application, there are no air

conditioning units at Worford Ridge that contain Class I or Class II refrigerants (chlorofluorocarbons

(CFCs)). However, should Red Cedar obtain any air conditioning units at Worford Ridge that contain Class

I or Class II refrigerants then it must comply with the standards of Part 82 Subpart F for recycling and

emissions reduction if they service, maintain, or repair the air conditioning units in any way or if they

dispose of the units.

40 CFR Part 82, Subpart H: Halon Fire Extinguishers. According to Red Cedar’s application, there are no

halon fire extinguishers at Worford Ridge. However, should Red Cedar obtain any halon fire extinguishers,

then it must comply with the standards of 40 CFR Part 82, Subpart H for halon emissions reduction, if it

services, maintains, tests, repairs, or disposes of equipment that contains halon or uses such equipment

during technician training. Specifically, Red Cedar would be required to comply with 40 CFR Part 82 and

submit an application for a modification to this Title V permit.

Mandatory Greenhouse Gas Reporting

40 CFR Part 98: Mandatory Greenhouse Gas Reporting. This rule requires sources above certain emission

thresholds to calculate, monitor, and report greenhouse gas emissions. The requirements of 40 CFR Part 98

and CAA §307(d)(1)(V), the CAA authority under which 40 CFR Part 98 was promulgated, however, need

not be included in a part 70 permit because those requirements are not included in the definition of

“applicable requirement” in either 40 CFR part 70 or RAC 1-103(11). Although the rule is not an applicable

requirement under 40 CFR Part 70 or the RAC, the source is not relieved from the requirement to comply

with the rule separately from compliance with its Part 70 operating permit. It is the responsibility of each

source to determine whether Part 98 is applicable and to comply, if necessary.

4. Public Participation

a. Public Notice

Per RAC §2-109, all Part 70 draft operating permits shall be publicly noticed and made available for public

comment. Public notice is given by publication in a newspaper of general circulation in the area where the

source is located or in a state publication designed to give general public notice, to persons on a mailing list

developed by the Tribe, including those who request in writing to be on the list, and by other means if

necessary to assure adequate notice to the affected public. If an interested person would like to be added to

the Tribe’s mailing list to be informed of future actions on permits issued by the Tribe, please send your

name and address:

by United State Postal Service to:

by any other delivery service to:

Part 70 Permitting Contact

Southern Ute Indian Tribe

Environmental Programs Department

PO Box 737 MS #84

Ignacio, Colorado 81137

Part 70 Permitting Contact

Southern Ute Indian Tribe

Environmental Programs Department

398 Ouray Drive

Ignacio, Colorado 81137

Public notice for the draft permit was published in the Durango Herald and the Southern Ute Drum on

February 7, 2025, in order to provide opportunity for public comment on the draft permit and the

opportunity to request a public hearing.

b. Opportunity for Comment

Members of the public were given an opportunity to review a copy of the draft permit prepared by the Tribe,

the application, the statement of basis for the draft permit, and all supporting materials for the draft permit.

Copies of these documents were on the Southern Ute Air Quality Division webpage at

https://www.southernute-nsn.gov/justice-and-regulatory/epd/air-quality/, and at:

Southern Ute Indian Tribe

Environmental Programs Department

Air Quality Division

71 Mike Frost Way

Ignacio, Colorado 81137

All documents were available for review at the Southern Ute Indian Tribe’s Environmental Programs

Department office Monday through Friday from 9:00 a.m. to 4:00 p.m. (excluding holidays).

Any interested person was given the opportunity to submit written comments on the draft Part 70 operating

permit during the public comment period. The Tribe has considered and addressed comments in making a

final decision on the permit. The Tribe keeps a record of the commenters and of the issues raised during the

public participation process.

Anyone, including the applicant, who believed any condition of the draft permit was inappropriate, could

raise all reasonably ascertainable issues and submit all arguments supporting his or her position by the close

of the public comment period. Any supporting materials submitted must have been included in full and may

not have been incorporated by reference, unless the material had already been submitted as part of the

administrative record in the same proceeding or consisted of Environmental Commission, tribal, state or

Federal statutes and regulations, EPA documents of general applicability, or other generally available

reference material.

c. Opportunity to Request a Hearing

A person may submit a written request for a public hearing to the Part 70 Permit Contact at the addresses

listed above, by stating the nature of the issues to be raised at the public hearing. Based on the number of

hearing requests received, the Tribe will hold a public hearing whenever it finds there is a significant degree

of public interest in a draft operating permit. The Tribe will provide public notice of the public hearing. If

a public hearing is held, any person may submit oral or written statements and data concerning the draft

permit.

d. Public Petitions to the Administrator

In the event the Administrator of the United States Environmental Protection Agency does not object to

issuance of the permit, on the basis that it would not be in compliance with applicable requirements, within

its 45-day review period, any person may then petition the Administrator within 60 days after the expiration

of the Administrator’s 45-day review period to make such objection. Any such petition must be based only

on objections to the permit that were raised with reasonable specificity during the public comment period

unless the petitioner demonstrates that it was impracticable to raise such objections within such period, or

unless the grounds for such objections arose after such period. If the administrator objects to a permit as a

result of this petition, the Tribe shall not issue the permit until the Administrator’s objection has been

resolved, except that a petition for review does not stay the effectiveness of a permit or its requirements if

the permit was issued after the end of the 45-day review period and before the Administrator’s objection.

e. Appeal of Permits

Within 60 days after the Tribe’s final permit action, an applicant, any person who filed comments on the

draft permit or participated in the public hearing, and any other person who could obtain judicial review of

that action under applicable law, may appeal to the Environmental Commission in accordance with RAC

2-109(8) and the Commission’s Procedural Rules.

Petitions for administrative review of final permit actions can be filed after the deadline designated by the

Commission only if they are based solely on grounds arising after the deadline for administrative review

has passed. Such petitions shall be filed no later than 60 days after the new grounds for review arise. If the

final permit action being challenged is the Tribe’s failure to take final action, a petition for administrative

review may be filed any time before the Tribe denies or issues the final permit.

f. Notice to Affected States/Tribes

As described in RAC § 2-109(3), public notice will be given by notifying all affected programs.

The following entities will be notified:



State of Colorado, Department of Public Health and Environment

State of New Mexico, Environment Department

Ute Mountain Ute Tribe, Environmental Programs Department

Navajo Tribe, Navajo Nation EPA

Jicarilla Tribe, Environmental Protection Office

National Park Service, Air Resources Division, Denver, CO

U.S. Department of Agriculture, United States Forest Service, Rocky Mountain

Region

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.