Air Pollution Control (2022)
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Air Pollution Control
Title V Permit to Operate
Statement of Basis for Permit No. V-SUIT-0023-2022.00
February 12, 2024
Public Service Company of Colorado
Tiffany Compressor Station
Southern Ute Indian Reservation
La Plata County, Colorado
1. Facility Information
a. Location
The Tiffany Compressor Station, owned and operated by Public Service Company of Colorado
(PSCo), is located within the exterior boundary of the Southern Ute Indian Reservation. The exact location
is Section 4, T32N, R6W, in La Plata County, at latitude North 37.05054 and longitude West -107.5121694.
The mailing address is:
Public Service Company of Colorado
Tiffany Compressor Station
1800 Larimer Street, Suite 1300
Denver, CO 80202
b. Contacts
Facility Contact:
Chad Campbell
Manager, Air and Water Compliance
Public Service Company of Colorado
1800 Larimer Street, Suite 1300
Denver, CO 80202
303-294-2177
Responsible Official:
Jeffery West
Senior Director, Environmental Services
Public Service Company of Colorado
1800 Larimer St
Denver, CO 80202
303-571-2762
c. Description of Operations
The Tiffany Compressor Station conditions natural gas to pipeline quality for delivery to Xcel Energy,
PSCo customers. The facility compresses natural gas using three compressor engines and removes water
from the gas stream using three dehydrators. The gas is then odorized and delivered into a PSCo pipeline
that provides gas to Pagosa Springs, the San Luis Valley, and the PSCo mountain customers. This facility
is classified as a natural gas transmission facility defined under Standard Industrial Classification 4922.
The primary source of emissions are from the facility’s three natural gas-fired four-stroke rich-burn (4SRB)
spark ignition (SI) compressor engines, and three triethylene glycol (TEG) dehydrators.
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d. List of All Units and Emission-Generating Activities
PSCo 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
PSCo, Tiffany Compressor Station
Emission
Unit ID
Control
Equipment
Description
3 – White Superior 8G-825 (4SRB SI) Compressor Engines, 800 name plate rated hp
E001
Serial No.
21086
Install Date:
11/15/1974
E002
Serial No.
286139
Install Date:
01/01/1977
E003
Serial No.
274239
Install Date:
01/01/1980
None
2 – Triethylene Glycol (TEG) Dehydration Unit, 14 MMscf/day
D001
Serial No.
N/A
Install Date:
01/01/1974
D002
Serial No.
N/A
Install Date:
01/01/1974
1 – Triethylene Glycol (TEG) Dehydration Unit, 10 MMscf/day
D003
Serial No.
N/A
Install Date:
None
None
01/01/2003
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
[RAC 2-106(4)(f); RAC 1-103(36) and (37)]. However, the application may not omit information needed
to determine the applicability of, or to impose, any applicable requirement, or to calculate the fee
[RAC 2-106(4)(f)]. 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.
PSCo stated in its Part 70 permit renewal application that the emission units in Table 2, below, are
insignificant. The application provided calculations for the emergency generator, heaters and reboilers,
fugitive emissions, and smart ash burner based on a combination of manufacturer’s specifications, EPA’s
AP-42 emission factors, and EPA WebFIRE emission factors. This data supports PSCo’s claim that these
units qualify as insignificant.
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Table 2 – Insignificant Emission Units
PSCo, Tiffany Compressor Station
Emission
Unit ID
Amount
Description
Size
Units
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
E006
N/A
N/A
2
2
1
1
1
1
1
1
1
5
2
Glycol Reboiler Burners for D001 and D002
Plastic Triethylene Glycol Above Ground Storage Tank
Oil Tank
Underground Used Oil Tank
Water / Oil Tank
Elastec Inc. Smart Ash Burner
Glycol Reboiler Burner for D003
Ethylene Glycol Coastal 50 Coolant Above Ground Tank
Generac Emergency Generator, (4SRB) 374 site rated hp
Separator Radiant Heaters
Window Mounted Air Conditioner
0.625
500
1,100
560
2,000
N/A
0.35
1,057
250
0.025
N/A
MMBtu/hr
gal
gal
gal
gal
N/A
MMBtu/hr
gal
KW
MMBtu/hr
N/A
e. Facility Construction and/or Permitting History
The Tiffany Compressor Station commenced operation in 1974 with one engine (E001) and two TEG
dehydrators (D001 and D002). Engine units E002 and E003 were added in 1977 and 1980, respectively.
A third dehydrator (D003) was added in 2003. EPA issued the initial Title V operating permit, #V-SU0023-00.00, on November 22, 2000. The facility’s first renewal permit was issued on December 6, 2005
as permit #V-SU-0023-05.00. That permit was twice modified and issued as permit #V-SU-0023.05.02.
The facility’s second renewal permit, #V-SU-0023-2010.00 was issued May 9, 2011 with an effective date
of May 18, 2011. AQD issued the Title V operating permit, #V-SUIT-0023-2013.00, on September 13,
2013. AQD issued a renewal permit, #V-SUIT-0023-2018.00 on August 17, 2018. On November 30, 2021,
a minor permit revision was completed for the replacement of the three dehydration units, with a single
dehydration unit. The modification was not completed, and this renewal permit reflects current operations
at the Tiffany Compressor Station. On February 12, 2024, the AQD issued renewal permit V-SUIT-00232022.00. No pre-construction permits have been issued to this facility.
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 Tiffany Compressor Station was listed by PSCo in Forms “GIS”, “PTE”, and the various forms
“EMISS” of the Part 70 operating permit application. Table 3 shows PTE data broken down by each
individual emission unit, as well as the total facility-wide PTE.
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Emission
Unit ID
Table 3 - Potential to Emit
PSCo, Tiffany Compressor Station
Regulated Air Pollutants1,2,3
in tpy (uncontrolled)
NOx
VOC
SO2
PM10
CO
Lead
Total
HAPs
Largest
Single HAP
GHGs
(CO2e mtpy)
E001
86.0
2.9
0.0
0.2
66
0.0
0.7
0.46
2936
E002
86.0
2.9
0.0
0.2
66
0.0
0.7
0.46
2936
E003
86.0
2.9
0.0
0.2
66
0.0
0.7
0.46
2936
D001
0.0
0.12
0.0
0.0
0.0
0.0
0.005
0.01
4830
D002
0.0
0.12
0.0
0.0
0.0
0.0
0.005
0.01
4830
D003
0.0
0.05
0.0
0.0
0.0
0.0
0.002
0.01
1659
Total IEUs
1.0
.1
0.0
0.1
1.1
0.0
0.0
0.0
1006
259.0
9.1
0.0
0.7
199.1
0.0
2.1
1.41
21,133
2. Tribal Authority
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 # 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).
Title V Operating Permitting Program: On March 2, 2012, 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 Operating Permitting Program (Program). In
concert with that Program approval, 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. EPA promulgated its approval of the Tribe’s
applications on March 15, 2012 (77 FR 15267).
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 and national emission standards for hazardous air
pollutants 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
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§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. Note that this discussion does not include the full spectrum of potentially applicable
regulations and is not intended to represent official applicability determinations. These discussions are
based on the information provided by PSCo 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.
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)
10
Nitrogen Oxides (NOx)
10
Sulfur Dioxide (SO2)
10
Volatile Organic Compounds (VOC)
5
PM10
5
PM2.5
3
Lead
0.1
Fluorides
1
Sulfuric Acid Mist
2
Hydrogen Sulfide (H2S)
2
Total Reduced Sulfur (including H2S)
2
Reduced Sulfur Compounds (including H2S)
2
Municipal Waste Combustor Emissions
10
Municipal Solid Waste Landfill Emissions
10
(measured as nonmethane organic compounds)
Starting August 30, 2011, all minor modifications at existing major NSR sources, requests for synthetic
minor limitations, and the transferring of synthetic minor limits from Part 71 permits into minor NSR
permits became subject to the TMNSR rule. All true minor sources and minor modifications at existing
major sources constructed after August 30, 2011 were required to submit a registration form within 90 days
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of beginning operation and obtain a permit if a general permit was available for that source category. No
general permit was available for sources in the oil and gas sector constructed or modified between August
30, 2011 and October 2, 2016 and these sources were only required to register with EPA.
On May 12, 2016, EPA finalized a Federal Implementation Plan (FIP) for true minor oil and gas sources in
Indian County. Beginning on October 3, 2016, all new and modified true minor oil and gas sources are
required to register with the EPA to obtain coverage under the FIP. Owners/operators also have the option
of apply to EPA for a source-specific permit instead of complying with the FIP, or EPA may determine that
a source-specific permit is necessary due to local or reservation-specific air quality concerns.
Future modifications at the Tiffany Compressor Station 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 a “major” stationary source or “major” modification of an
existing stationary source. A new stationary source, or a modification to an existing minor stationary
source, is major if the proposed project has the potential to emit of any criteria pollutant regulated under
the CAA in amounts equal to or exceeding specified major source thresholds, which are 100 tpy for 28
listed industrial source categories 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. A modification is a physical change
or change in the method of operation.
The Tiffany Compressor Station does not belong to any of the 28 source categories. Therefore, the potential
to emit threshold for determining PSD applicability for this source is 250 tons per year for criteria pollutants.
Stack test data used to calculate PTE NOx emissions for units E001, E002, and E003 show the facility has
the PTE NOx in amounts that exceed the 250 tpy PSD applicability thresholds and is therefore categorized
as major stationary source for PSD permitting purposes. According to PSCo, the addition of engine unit
E003 in 1980 caused the facility to become a major stationary source for PSD permitting. The installation
of emission unit E003 pre-dates the major source baseline date for NOx of February 8, 1988 under 40 CFR
§52.21(b)(14)(i). Therefore, PSD applies to the facility but there have been no major modifications at the
facility that have increased the NOx PTE in amounts meeting the significance threshold for major PSD
sources of 40 tpy. The GHG emissions at the Tiffany Compressor Station are not “subject to regulation”
as defined in RAC 1-103(65). Therefore, PSD regulations do not apply at this time.
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.
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As explained below, the Tiffany Compressor Station is not subject to any specific subparts under
40 CFR Part 60. Therefore, the General Provisions of Part 60 do not apply.
40 CFR Part 60, Subpart Dc: Standards of Performance for Small Industrial-CommercialInstitutional 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 PSCo, the Tiffany Compressor Station has no steam generating units with a maximum
design heat input capacity of 100 MMBtu/hr or less, but greater than or equal to 10 MMBtu/hr at
the 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 PSCo, the Tiffany Compressor Station has no tanks with a storage capacity greater
than 40,000 gallons. 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
June 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 PSCo, the Tiffany Compressor Station has no tanks with a storage capacity greater
than 40,000 gallons. 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. This rule applies to storage vessels with a capacity greater than or equal
to 75 cubic meters (~472bbl or 19,813 gal).
According to PSCo, the Tiffany Compressor Station has no tanks with a capacity greater than 75 m3
(~472bbl or 19,813 gal) that are used to store volatile organic liquids. 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.
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According to PSCo, there are no stationary gas turbines located at the Tiffany Compressor Station.
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 PSCo, the Tiffany Compressor Station 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 SO2 emissions from Onshore Natural
Gas Processing for which construction, reconstruction, or modification commenced after January 20, 1984,
and on or before August 23, 2011. 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 H2S and CO2)
removed by a sweetening unit.
According to PSCo, the Tiffany Compressor Station 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 rule applies to owners and operators of stationary compression ignition
internal combustion that commence construction, reconstruction, or modification after July 11, 2005.
According to PSCo, there are no stationary compression ignition internal combustion engines
located at the Tiffany Compression Station. 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)).
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PSCo provided the following information:
Table 4 - NSPS Subpart JJJJ Applicability Determination
PSCo, Tiffany Compressor Station
Trigger Date
for
ApplicabilityManufactured
on or after
Unit
Serial No
Unit Description
Fuel
Maximum
HP
Manufacture Date
Commenced
Construction
Date
E001
21086
White Superior 8G-825
4SRB Compressor Engine
Natural
Gas
800
Manufactured Prior
to July 1, 2007
Prior to
6/12/2006
07/01/07
E002
268139
White Superior 8G-825
4SRB Compressor Engine
Natural
Gas
800
Manufactured Prior
to July 1, 2007
Prior to
6/12/2006
07/01/07
E003
274239
White Superior 8G-825
4SRB Compressor Engine
Natural
Gas
800
Manufactured Prior
to July 1, 2007
Prior to
6/12/2006
07/01/07
E006
3013106462
Generac SG250 4SRB
Emergency Generator
Engine
Natural
Gas
374
Manufactured After
January 1, 2009
After
6/12/2006
01/01/09
According to PSCo, E001, E002, and E003 were manufactured prior to July 1, 2007 (trigger date
for engines with maximum engine power greater than or equal to 500 hp). The engines have not
been reconstructed or modified (as defined in §60.15) since June 12, 2006. Therefore, the
requirements of Subpart JJJJ do not apply. However, emission unit E006 was manufactured
after January 1, 2009 (the trigger date for emergency engines with a maximum engine power greater
than 25 hp). Therefore, the requirements of Subpart JJJJ do apply.
Should PSCo propose to install a replacement engine for E001, E002 and E003, that is subject to
Subpart JJJJ, PSCo will not be allowed to use the off-permit changes provision and will be required
to submit a minor permit modification application to incorporate Subpart JJJJ requirements into the
permit.
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. Affected facilities under this subpart include gas
wells, compressors, pneumatic controllers, storage vessels, process unit equipment, and sweetening units.
According to information provided by PSCo, the Tiffany Compressor Station does not have any
affected facilities as defined at 40 CFR §60.5365 that were constructed, reconstructed, or modified
after August 23, 2011. Therefore, Subpart OOOO does not apply.
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 VOC
and SO2 emissions from affected facilities that commence construction, modification or reconstruction after
9
September 18, 2015. Affected facilities and equipment under this subpart include wells, compressors,
storage vessels, process unit equipment, sweetening units, pneumatic pumps and pneumatic controllers.
According to information provided by PSCo, the Tiffany Compressor Station does not have any
affected facilities under the rule that commenced construction after September 18, 2015. Therefore,
Subpart OOOOa does not apply.
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, the Tiffany Compressor Station is subject to 40 CFR Part 63, Subpart ZZZZ.
Therefore, the General Provisions of Part 63 apply as specified in the relevant subpart.
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 major or area 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. For the purpose of this subpart, natural gas enters the
transmission and storage category after the natural gas processing plant, when present. Affected units for
this subpart are outlined for area and major sources at §63.670(b).
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 are exempt from the requirements of
this subpart.
Source Aggregation
Major source, as used in this subpart, has the same meaning as in §63.2, except that:
1)
Emissions from any oil and gas production well with its associated equipment and emissions from
any pipeline compressor station or pump station shall not be aggregated with emissions from other
similar units.
2)
Emissions from processes, operations, or equipment that are not part of the same facility 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 with the potential for flash emissions shall be aggregated for a major source
determination.
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 compressor station 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.
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 also applies 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.
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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 the Tiffany Compressor Station
According to PSCo, the Tiffany Compressor Station is a natural gas transmission facility and not a
natural gas production facility. Therefore, Subpart HH does not apply.
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 PSCo, the Tiffany Compressor Station’s potential HAP emissions are below the major
source thresholds. 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. This rule establishes national
emission limitations and operating limitations for HAPs emitted from stationary spark ignition internal
combustion engines (SI ICE) and stationary compression ignition internal combustion engines (CI ICE).
For the purposes of this standard, construction or reconstruction is as defined in §63.2.
Engine Type
Summary of Applicability to Engines at Major HAP Sources
Major HAP Sources
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
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Engine Type
Summary of Applicability to Engines at Area Hap Sources
Area HAP Sources
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
Table 5 - Applicability of 40 CFR 63, Subpart ZZZZ to the Tiffany Compressor Station:
Unit
Serial
Number
E001
21086
E002
268139
E003
274239
E006
3013106462
Fuel
Site Rated
BHP
Commenced Construction,
Reconstruction, or
Modification Date
Natural Gas
658
Prior to 06/12/2006
Natural Gas
658
Prior to 06/12/2006
Natural Gas
658
Prior to 06/12/2006
Natural Gas
374
After 06/12/2006
Unit Description
White Superior 8G-825 4SRB
Compressor Engine
White Superior 8G-825 4SRB
Compressor Engine
White Superior 8G-825 4SRB
Compressor Engine
Generac SG250 4SRB
Emergency Generator Engine
According to PSCo, the Tiffany Compressor Station is an area source as defined in subpart ZZZZ.
Units E001, E002 and E003 are considered existing non-emergency non-black start spark ignition
(SI) four-stroke rich-burn (4SRB) stationary RICE greater than 500 hp that commenced construction
prior to June 12, 2006. The units have not been reconstructed and are located on a pipeline segment
that meets the criteria necessary to qualify the units as remote stationary RICE. According to 40
CFR 63.6595(a)(1), 40 CFR 63.6603, 40 CFR 63.6625(e), and Table 2d of Subpart ZZZZ, Units
E001, E002 and E003, and must comply with the applicable emission limitations, operating
limitations, and other requirements of Subpart ZZZZ.
Unit E006 is considered an existing emergency no-black start SI 4SRB stationary RICE that
commenced construction after June 12, 2006. The unit has not been reconstructed. Therefore, Unit
E006 is not subject to the requirements of Subpart ZZZZ.
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 operating limitations 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 information provided by PSCo, the Tiffany Compressor Station is not a major source
as defined in this subpart. Therefore, Subpart DDDDD does not apply.
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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 that are fueled by coal, biomass, or oil and are located at area sources of
HAPs. For the purposes of this subpart, an affected unit is an existing unit if it was constructed prior to
June 4, 2010.
According to PSCo, all emission sources at the Tiffany Compressor Station use only natural gas as
a fuel and are exempt from this rule (in accordance with §63.11195). Therefore, Subpart 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:
1)
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);
Ҥ64.2(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.”
Ҥ64.1: 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.”
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2)
The unit uses a control device to achieve compliance with any such limit or standard; and
3)
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 PSCo, the CAM rule does not apply to any of the units at the Tiffany Compressor
Station as no emission unit located at the facility meets any of the three CAM applicability criteria.
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. §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.
§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.
According to PSCo, the Tiffany Compressor Station does not have regulated substances above the
threshold quantities in this rule. Therefore, the facility 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 PSCo there are two air
conditioning units at the Tiffany Compressor Station that contain Class I or Class II refrigerants
(chlorofluorocarbons (CFCs)). Therefore, Tiffany Compressor Station 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 information provided by PSCo,
there are no halon fire extinguishers at the Tiffany Compressor Station. However, should PSCo 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, PSCo would be required to comply with 40
CFR Part 82 and submit an application for a modification to this Title V permit.
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Mandatory Greenhouse Gas Reporting
40 CFR Part 98: 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 tribalissued 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 was published in the Durango Herald and Southern Ute Drum on November 11, 2023
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, this 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/government/departments/epd/air-quality/, and at:
Southern Ute Indian Tribe
Environmental Programs Department
16
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 to the Part 70 Permit Contact at the address listed above. 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 believes any condition of the draft permit was inappropriate should
have raised all reasonably ascertainable issues and submitted 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 address
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.
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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 the
RAC 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
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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.