Air Pollution Control (2024)
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Air Pollution Control
Title V Permit to Operate
Statement of Basis for Permit No. V-SUIT-0028-2024.00
April 25, 2025
El Paso Natural Gas Company, LLC
Bondad Compressor Station
Southern Ute Indian Reservation
La Plata County, Colorado
1. Facility Information
a. Location
The Bondad Compressor Station (Bondad), owned and operated by El Paso Natural Gas Company, LLC
(El Paso), is located within the exterior boundary of the Southern Ute Indian Reservation. The exact location
is Section 13, T33N, R9W in La Plata County, at latitude North 37.097831 and longitude West
-107.769832. The mailing address is:
El Paso Natural Gas Company, LLC
Bondad Compressor Station
2 North Nevada Avenue
Colorado Springs, CO 80903
b. Contacts
Facility Contact:
Ken Distler
Senior EHS Engineer
El Paso Natural Gas Company, LLC
2 North Nevada Avenue
Colorado Springs, CO 80903
(719) 520-4328
Responsible Official:
Donald Perkins
Director - OPS
El Paso Natural Gas Company, LLC
2527 Foresight Circle
Grand Junction, CO 81505
(970) 208-1286
c. Description of Operations
The Bondad Compressor Station is a natural gas compression facility located within the exterior boundaries
of the Southern Ute Indian Reservation in southwestern Colorado. The Bondad Compressor Station receives
gas from a nearby processing plant. The gas enters the facility through inlet scrubbers which knock out
small quantities of water and pipeline liquids. The gas is then compressed by three (3) natural gas-fired
turbine compressors into the transmission pipeline.
The facility was constructed in December 1981 with the installation of two 2782-hp Solar Centaur natural
gas turbine-driven compressors and one natural gas reciprocating engine for auxiliary power generation
during purchase power outages. Emissions from the two original turbines were permitted by the Colorado
Department of Public Health and Environment. In 1992, a third regenerative-cycle turbine was added (Solar
Centaur T4000, 2786-hp). In 1994, the two original turbines were converted from simple cycle to
regenerative cycle. In 1997, increases to the NOx emission limits were incorporated into the permits for the
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original two turbines. Pursuant to a Compliance Order on Consent from the CDPHE, all three turbines were
replaced with simple-cycle Solar Centaur turbines. In 2004, units A‐01, A‐02, and B‐01 were replaced as
part of an expansion project.
d. List of all Units and Emission-Generating Activities
El Paso 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
El Paso Natural Gas Company, LLC – Bondad Compressor Station
Emission
Unit ID
Control
Equipment
Description
Solar Centaur 50-6202L Simple-Cycle Natural Gas-Fired Turbine 42.73 MMBtu/hr
A-01
Serial No.
CC80013
Install Date:
03/19/2004
A-02
Serial No.
CC80014
Install Date:
02/29/2004
N/A
Solar Centaur 50-6202LS Simple Cycle Natural Gas-Fired Turbine 42.73 MMBtu/hr
N/A
B-01
Serial No.
CC91308
Install Date:
04/28/2004
Waukesha F1197 GU (4SRB SI) Natural Gas-Fired Emergency Generator 235 Name
Plate Rated HP
A-AUX-01
Serial No.
360792
Install Date:
N/A
01/01/1981
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.
El Paso 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.
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Table 2 - Insignificant Emission Units
El Paso Natural Gas Company, LLC – Bondad Compressor Station
Emission
Amount
Description
Size
Unit ID
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
1
1
1
1
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Natural Gas-Fired Building Heater
Used Oil Tank
Lube Oil Storage Tank
Lube Oil Day Tank
Fugitive Component VOC Emissions
VOC Emissions from Unit Blowdowns
VOC Emissions from Expansion Gas
VOC Emissions from Station ESD
Miscellaneous Chemicals for Maintenance / Operation
Pig Receiver
Pig Launcher
0.25
107
210
34
N/A
N/A
N/A
N/A
<500
N/A
N/A
Units
MMBtu/hr
bbl
bbl
bbl
N/A
N/A
N/A
N/A
gal
N/A
N/A
e. Facility Construction and Permitting History
DATE
DESCRIPTION OF ACTION
PERMIT NUMBER
June 2001
Initial Part 71 Permit Issued
# V-SU-0028-00.00
October 2007
1st Part 71 Permit Renewal
# V-SU-0028-06.00
January 2008
Administrative Revision
# V-SU-0028-06.01
October 2009
Administrative Amendment
# V-SU-0028-06.02
January 31, 2014
Initial Part 70 Permit Issued
# V-SUIT-0028-2014.00
April 29, 2019
1st Renewal Permit Issued
# V-SUIT-0028-2019.00
September 23, 2024
Minor Revision
# V-SUIT-0028-2019.01
April 25, 2025
2nd Renewal Permit Issued
# V-SUIT-0028-2024.00
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 Bondad was listed by El Paso 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.
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Emission
Unit ID
Table 3 - Potential to Emit
El Paso Natural Gas Company, LLC – Bondad Compressor Station
Regulated Air Pollutants
in tpy
NOx
VOC
SO2
PM10
CO
Lead
Total
HAPs
A-01
A-02
B-01
A-AUX-01
Total IEU’s
92.20
92.20
32.20
2.80
0.11
0.65
0.65
0.99
0.06
1.70
0.64
0.64
0.64
0.00
0.00
1.24
1.24
1.24
0.01
0.01
22.80
22.80
45.00
5.10
0.09
0.00
0.00
0.00
0.00
0.00
0.19
0.19
0.19
0.02
0.03
Largest
Single
HAP
(CH2O)
0.13
0.13
0.13
0.01
0.00
TOTAL
219.51
4.05
1.92
3.74
95.79
0.00
0.62
0.40
GHGs
(CO2 e tpy)
21,897.10
21,897.10
21,897.10
61.90
3,654.00
69,407.20
2. Tribal Authority
El Paso’s Bondad 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.
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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 El Paso 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)
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)
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
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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 Bondad 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.
Bondad 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, Bondad is subject to specific subparts under 40 CFR part 60. Therefore, the
General Provisions of Part 60 do 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 El Paso, Bondad 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 El Paso, Bondad 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 at the facility. Therefore,
Subpart Dc does not apply.
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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 El Paso, Bondad does not have any storage vessels for petroleum liquids with a storage
capacity greater than 40,000 gallons 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 El Paso, Bondad does not have any storage vessels for petroleum liquids with a storage
capacity greater than 40,000 gallons 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 El Paso, all tanks storing volatile organic liquids at Bondad are less than 75 m 3 (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 El Paso, stationary gas turbines A-01, A-02, and B-01 have a heat input at peak load
greater than 10 MMBtu/hr that commenced construction after October 3, 1977. Therefore, Subpart
GG does 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 El Paso, Bondad 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
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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 El Paso, Bondad 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 El Paso, there are no stationary compression ignition (CI) internal combustion engines
(ICE) located at Bondad. 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)).
El Paso provided the following information:
Table 4 - NSPS Subpart JJJJ Applicability Determination
El Paso Natural Gas Company, LLC – Bondad Compressor Station
Unit
A-AUX-01
1
Serial
No.
Unit Description
360792
Waukesha F1197
GU (4SRB SI)
Emergency
Generator
Fuel
Maximum
HP
Manufacture
Date1
Commenced
Construction
Date
Subpart JJJJ
Trigger Date Manufactured
on or after
Natural
Gas
235
Prior to
06/12/2006
Prior to
06/12/2006
01/01/2009
According to Red Cedar, the engine has not been reconstructed or modified (as defined in §60.15) since June 12, 2006.
According to El Paso, emission unit A-AUX-01 was manufactured prior to January 1, 2009 (the
trigger date for emergency engines with a maximum engine power greater than 25 HP); and has not
been modified or reconstructed since June 12, 2006. Therefore, Subpart JJJJ does not apply.
Should El Paso propose to install a replacement engine for emission unit A-AUX-01 that is subject
to Subpart JJJJ, El Paso may not be allowed to use the off-permit changes provision and may be
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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 El Paso, the stationary gas turbines located at Bondad were constructed before
February 18, 2005, and have not been reconstructed or modified. 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 El Paso, Bondad 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 Affected facilities under this subpart include gas wells, compressors, pneumatic
controllers, pneumatic pumps, storage vessels, and the collection of fugitive emission components at well
sites and compressor stations.
According to El Paso, Bondad 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 Super-Emitter
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.
9
According to El Paso, Bondad 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, Bondad 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
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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 Bondad Compressor Station
According to El Paso, Bondad is a natural gas transmission compression station that is located
downstream of a processing plant. 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 El Paso, Bondad is considered an area source of HAPs. 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.
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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
1
SI ICE - All
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 Bondad Compressor Station:
Unit
Serial No.
Unit Description
Fuel
Site
Rated HP
Commenced Construction,
Reconstruction, or
Modification Date
A-AUX-01
360792
Waukesha F1197 GU
(4SRB SI) Emergency
Generator
Natural Gas
235
Prior to 06/12/2006
According to El Paso, Bondad is an area source of HAPs as defined in subpart ZZZZ. Emission unit
A-AUX-01 is an existing stationary emergency RICE that commenced construction before June 12,
2006, and has not been reconstructed or modified since this date. Therefore, Bondad Compressor
Station is subject to the applicable 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 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 El Paso, Bondad 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 §
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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 El Paso, Bondad 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:
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.”
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 El Paso’s application, there are no sources at Bondad that require control devices.
Therefore, CAM does not apply.
Chemical Accident Prevention Program
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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 El Paso’s application, Bondad does not have regulated substances above the threshold
quantities in this rule. Therefore, Bondad 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 El Paso’s application, there are no air
conditioning units at Bondad that contain Class I or Class II refrigerants (chlorofluorocarbons (CFCs)).
However, should El Paso obtain any air conditioning units at Bondad 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 El Paso’s application, there are no
halon fire extinguishers at Bondad. However, should El Paso 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, El Paso 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
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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
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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
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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.