AIR QUALITY DIVISION (2024)

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AIR QUALITY DIVISION

Environmental Programs Department

Southern Ute Indian Tribe

PO Box 737 MS#84

Ignacio, CO 81137

Phone 970-563-4705

http://www.southernute-nsn.gov/environmental-programs/air-quality

July 15, 2025

Ms. Julie Best

Environmental Specialist

SIMCOE, LLC

1199 Main Ave, Suite 101

Durango, CO 81301

RE: Part 70 Operating Permit – Permit Renewal

Title V Permit # V-SUIT-0022-2024.00

SIMCOE, LLC

Florida River Central Delivery Point

Ms. Best,

The Southern Ute Indian Tribe Air Quality Division (AQD) has completed its review of SIMCOE,

LLC’s (SIMCOE) request to renew a Title V Permit to Operate, pursuant to the Title V Operating

Permit Program at 40 CFR Part 70, for the Florida River Central Delivery Point.

Based on the information submitted in SIMCOE’s application, the AQD hereby issues the enclosed Title

V Permit to Operate. The final permit will become effective on July 15, 2025.

A 30-day public comment period was held from April 18, 2025, to May 18, 2025. The AQD received no

comments from SIMCOE during this time and no comments were received from the public, affected

states, or tribes.

A 45-day Administrative Review period at EPA Region 8 was held from May 27, 2025, to July 11,

2025. No comments were received from EPA Region 8 during this review period.

Pursuant to RAC §2-109(8), within 60 days after the final permit has been issued, the applicant, any person

who participated in the public comment process and is aggrieved by the action, 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 Southern Ute Indian Tribe/State of Colorado Environmental

Commission’s Reservation Air Code (RAC) and the Commission’s Procedural Rules. Additionally, the

regulations at RAC §2-109(7) specify that any person may petition the EPA Administrator within 60 days

after the expiration of the Administrator’s 45-day review period to make an objection that the permit

would not be in compliance with applicable requirements. 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 you have any questions concerning the enclosed permit, please feel free to contact me.

Sincerely,

Mark Lamoreaux

Air Quality Scientist II - Permitting

Southern Ute Indian Tribe

(970) 563-2273

mlamoreaux@southernute-nsn.gov

Cc: US EPA Region 8 - r8airpermitting@epa.gov

Southern Ute Indian Tribe

Air Quality Division

Title V Operating Permit

Southern Ute Indian Tribe

Environmental Programs Department

Air Quality Division

71 Mike Frost Way

Ignacio, Colorado 81137

AIR POLLUTION CONTROL

TITLE V PERMIT TO OPERATE

In accordance with the provisions of Title V of the Clean Air Act (42 U.S.C. 7661-7661f) and Part

1, Article II of the Southern Ute Indian Tribe/State of Colorado Environmental Commission’s

Reservation Air Code (RAC) and applicable rules and regulations,

SIMCOE, LLC

Florida River Central Delivery Point

is authorized to operate air emission units and to conduct other air pollutant emitting activities in

accordance with the conditions listed in this permit.

This source is authorized to operate at the following location:

Southern Ute Indian Reservation

Section 25, T34N, R9W

La Plata County, Colorado

Terms not otherwise defined in this permit have the meaning assigned to them in the referenced

regulations. All terms and conditions of the permit are enforceable by the Tribe and citizens under

the Clean Air Act.

Daniel Powers, Air Quality Division Head

Environmental Programs Department

Southern Ute Indian Tribe

AIR POLLUTION CONTROL

TITLE V PERMIT TO OPERATE

SIMCOE, LLC

Florida River Central Delivery Point

SUIT Account Identification Code: 2-006

Permit Number: V-SUIT-0022-2024.00

[Replaces Permit No.: V-SUIT-0022-2019.01]

Issue Date:

Revised Date:

Expiration Date:

July 15, 2025

N/A

July 15, 2030

The SUIT account identification code and permit number cited above should be referenced in future

correspondence regarding this facility.

Permit Issuance History

DATE

TYPE OF

ACTION

DESCRIPTION OF ACTION

PERMIT NUMBER

June 2001

Permit Issued

Initial Part 71 Permit Issued

# V-SU-0022-00.00

October 4, 2010

Permit Issued

1st Part 71 Renewal Permit Issued

# V-SU-0022-05.00

October 2011

Permit

Revision

Minor Revision

# V-SU-000022-2005.01

August 2014

Permit Issued

November 2, 2015

Permit

Revision

Minor Revision

# V-SUIT-0022-2014.01

May 22, 2020

Permit Issued

1st Part 70 Renewal Permit Issued

# V-SUIT-0022-2019.00

December 30, 2020

Permit

Revision

Administrative Revision

Change of ownership from BP

America Production Company to

SIMCOE, LLC.

# V-SUIT-0022-2019.01

July 15, 2025

Permit Issued

2nd Part 70 Permit Renewal

# V-SUIT-0022-2024.00

Initial Part 70 Permit Issued

 Replaces EPA-issued permit:

V-SU-000022-2005.01



# V-SUIT-0022-2014.00

Table of Contents

Abbreviations and Acronyms ................................................................................................................................. 3

Section I – Source Information and Emission Unit Identification ............................................................................ 6

Source Information ..........................................................................................................................................6

Source Emission Points ....................................................................................................................................7

Section II – General Requirements ......................................................................................................................... 8

Title V Administrative Requirements ...............................................................................................................8

1.1.

Annual Fee Payment [RAC 2-110(1)(h) and RAC 2-118] ........................................................................ 8

1.2.

Compliance Requirements .................................................................................................................. 11

1.3.

Duty to Provide and Supplement Information [RAC 2-110(7)(e), 2-106(5), and 2-124] ....................12

1.4.

Submissions [RAC 2-105] .....................................................................................................................13

1.5.

Severability Clause [RAC 1-106 and RAC 2-110(1)(f)] .........................................................................13

1.6.

Permit Actions [RAC 2-110(3)] ............................................................................................................ 13

1.7.

Administrative Permit Revision [RAC 2-111(2)] .................................................................................14

1.8.

Minor Permit Revisions [RAC 2-111(3)] ..............................................................................................14

1.9.

Significant Permit Revisions [RAC 2-111(4)] .......................................................................................15

1.10.

Permit Reopenings, Revocations and Reissuances, and Terminations [RAC 2-112] .........................15

1.11.

Property Rights [RAC 2-110(3)(e)] .......................................................................................................16

1.12.

Inspection and Entry [RAC 2-110(9)(b)] ..............................................................................................16

1.13.

[Reserved] ............................................................................................................................................17

1.14.

Permit Transfers [RAC 2-113] ..............................................................................................................17

1.15.

Off-Permit Changes [RAC 2-116(2)]..................................................................................................... 17

1.16.

Permit Expiration and Renewal ..........................................................................................................18

Facility-Wide Requirements...........................................................................................................................19

2.1.

General Recordkeeping Requirements [RAC 2-110(6)] ...................................................................... 19

2.2.

General Reporting Requirements .......................................................................................................19

2.3.

Alternative Operating Scenarios [RAC 2-110(8)] ................................................................................21

2.4.

Permit Shield [RAC 2-110(10)(c)].........................................................................................................23

2.5.

Stratospheric Ozone and Climate Protection [40 CFR Part 82] ..........................................................23

Section III – Site Specific Permit Terms ................................................................................................................ 24

New Source Performance Standards (NSPS) and 40 CFR Part 60 ..................................................................24

1.1.

40 CFR Part 60, Subpart GG – Standards of Performance for Stationary Gas Turbines [40 CFR

60.330 – 60.335. RAC 3-102] .............................................................................................................................. 24

National Emission Standards for Hazardous Air Pollutants (NESHAP) and 40 CFR Part 63 ...........................33

2.1.

40 CFR Part 63, Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil

and Natural Gas Production Facilities [40 CFR 63.760 – 63.779 and RAC 4-103] ............................................. 33

Reserved – Tribal Minor New Source Review ................................................................................................33

Reserved – Prevention of Significant Deterioration Requirements ............................................................... 33

Reserved – Consent Decree Requirements ....................................................................................................33

Reserved – Compliance Assurance Monitoring (CAM) Requirements ...........................................................33

Enhanced Monitoring, Recordkeeping, and Reporting..................................................................................34

Section IV – Appendix .......................................................................................................................................... 35

Inspection Information ..................................................................................................................................35

1.1.

Driving Directions: ...............................................................................................................................35

1.2.

Global Positioning System (GPS): .......................................................................................................35

1.3.

Safety Considerations: ........................................................................................................................35

Abbreviations and Acronyms

4SLB

4SRB

AFS

AQD

bbl

BACT

CAA

CAM

CEMS

CFR

CMS

COMS

CO2

dscf

dscm

EPA

gal

GPM

H 2S

HAP

lbs

MACT

MMBtu

MMSCFD

NESHAP

NMHC

NOx

NSPS

NSR

PM10

ppbvd

ppm

ppmvd

PSD

PTE

psi

psia

RAC

RICE

RMP

scf

scfm

SO2

SUIT

tpy

Tribe

Four-Stroke Lean-Burn

Four-Stroke Rich-Burn

Air Facility System database

Southern Ute Indian Tribe’s Air Quality Division

Barrels

Best Available Control Technology

Clean Air Act [42 U.S.C. Section 7401 et seq.]

Compliance Assurance Monitoring

Continuous Emission Monitoring System

Code of Federal Regulations

Continuous Monitoring System (includes COMS, CEMS and diluent monitoring)

Continuous Opacity Monitoring System

Carbon monoxide

Carbon dioxide

Dry standard cubic foot

Dry standard cubic meter

United States Environmental Protection Agency

Gallon

Gallons per minute

Hydrogen sulfide

Hazardous Air Pollutant

Hour

Identification Number

Kilogram

Pounds

Maximum Achievable Control Technology

Megagram

Million British Thermal Units

Million standard cubic feet per day

Month

National Emission Standards for Hazardous Air Pollutants

Non-methane hydrocarbons

Nitrogen Oxides

New Source Performance Standard

New Source Review

Negative logarithm of effective hydrogen ion concentration (acidity)

Particulate Matter

Particulate matter less than 10 microns in diameter

Parts per billion by volume, dry

Parts per million

Parts per million by volume, dry

Prevention of Significant Deterioration

Potential to Emit

Pounds per square inch

Pounds per square inch absolute

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

Air Code

Reciprocating Internal Combustion Engine

Risk Management Plan

Standard cubic feet

Standard cubic feet per minute

Spark Ignition

Sulfur Dioxide

Southern Ute Indian Tribe

Ton(s) Per Year

Southern Ute Indian Tribe

US EPA

VOC

United States Environmental Protection Agency

Volatile Organic Compounds

Table of Figures

Table 1 - Emission Units................................................................................................................. 7

Table 2 - Insignificant Emission Units ........................................................................................... 8

Section I – Source Information and Emission Unit Identification

Source Information

Owner Name:

SIMCOE, LLC

Facility Name:

Florida River Central Delivery Point

Facility Location:

Section 25, T34N, R9W

Latitude:

37.156305 °N

Longitude:

State:

-107.780520 °W

Colorado

County:

La Plata

Responsible Official:

Area Manager, Midstream

SIC Code:

1311

ICIS Identification Number:

SU00000008067U0025

EPA Facility Registry ID:

110056281367

Other Clean Air Act Permits

None

Process Description:

The Florida River CDP processes coal bed methane gas to reduce the carbon dioxide and water

content to within pipeline specifications and compress this gas for delivery into interstate

pipeline systems. The CDP has four (4) medium pressure gas inlets and five (5) low pressure gas

inlets. Current plant throughput averages 210 million standard cubic feet per day (MMscfd) with

plant process capacity around 400 MMscfd.

Low pressure gas enters the plant through an inlet separator to remove free liquids after which it

is compressed from 25 to 275 psig. Initial compression of low-pressure gas is done by two (2)

electric driven, glycol/fin fanned cooled screw compressors and two (2) electric driven

reciprocating compressors. The low-pressure gas is then commingled with medium pressure gas

and sent to the dehydration (Tri-ethylene Glycol, TEG) units, to remove water vapor from the

gas.

Gas from medium pressure inlets enters the plant at 275 psig. Three (3) inlets go directly to the

amine (Methyl-diethanolamine, MDEA) units to remove carbon dioxide and is then comingled

with the low-pressure gas and sent to the dehydration units, to remove water vapor from the gas.

Two (2) inlets are not sent to the amine units or dehydration units since the gas has been

previously dried.

The carbon dioxide and water vapor from the amine units and dehydration units are vented to the

atmosphere. All gas is then compressed to 700 psig and sent to El Paso, Transwestern, or

Northwest Pipeline for transport to market via interstate pipeline.

Gas fired heaters and a waste heat recovery unit are utilized to heat Ethylene Glycol (EG) which

is used as the heat medium to regenerate lean MDEA from carbon dioxide saturated (rich)

MDEA and for heating some tanks in the plant. The dehydration units are fired on natural gas to

evaporate water from rich TEG. Final compression consists of three (3) electric driven

centrifugal compressors and two (2) natural gas fired Solar Centaur turbine driven centrifugal

compressors. The flare system disposes of an average of about 0.026 MMscfd but is designed to

handle the full inlet for a very brief period in emergency or plant upset situations.

Source Emission Points

Table 1 - Emission Units

Emission

Unit ID

Control

Equipment

Description

Solar Centaur H T5500 Natural Gas Fired Simple Cycle Turbine

37 MMBtu/hr

T-1

Serial No.

HC90781

Install Date:

1995

Solar Centaur H T5700 Natural Gas Fired Simple Cycle Turbine

39 MMBtu/hr

T-2

Serial No.

HC93D50

Install Date:

Serial No.

421

Install Date:

None

05/30/1989

Amine Unit Natural Gas Fired Regenerator Heater

44.0 MMBtu/hr

AH-2

Serial No.

2440

Install Date:

None

1980

Zecco Multipoint Ground Flare, 3 Stage Flare System with 90 Burners, 4

MMBtu/hr Pilot, 400 MMscf/d

Plant Flare

Serial No.

N/A

Install Date:

Serial No.

N/A

Install Date:

Serial No.

N/A

Install Date:

None

N/A

Tri-ethylene Glycol (TEG) Dehydration Still and Flash Tank Vent

180 MMscf/d

Dehy3

None

01/2004

Tri-ethylene Glycol (TEG) Dehydration Still and Flash Tank Vent

90 MMscf/d

Dehy1

None

08/1999

Amine Unit Natural Gas Fired Regenerator Heater

44.5 MMBtu/hr

AH-1

None

N/A

None

Table 2 - Insignificant Emission Units

Emission Unit

Amount

Description

Size

Units

AV-1

AV-2

AV-2a

IEU1

IEU3

IEU4

IEU5

IEU6

IEU8

N/A

Amine Unit #1 Vent

Amine Unit #2 Vent

Amine #2 Flash Tank

Dehy Reboiler #1a

Dehy Reboiler #1b

Dehy Reboiler #3a

Dehy Reboiler #3b

Process Fugitive Emissions

Gasoline Tank

MDEA Tank

EG Tank

TEG Tank

TEG Tanks

Diesel Fuel Tank

Diesel Tank

Waste Oil Tank

Lube Oil Tank

Oily Water Tank

Lube Oil Tanks

Compressor Lube Oil Drain and Sump

Lube Oil Tanks

Treated Water Tank

Well Water Tank

Produced Water Tank

Water Breakout Tanks

Dehy Water Collection Tanks

Evaporative Cooler Fresh Water Tanks

Evaporative Cooler Fresh Water Tank

Recycle Oil (Bunkered)

Maintenance Building Heaters

Office Heaters

140

N/A

2.5

2.14

N/A

500

250

300

1,500

100

300

100

300

210

100

550

500

238

250

100

4,000

400

3,000

1,260

12.8

0.175

0.120

0.117

0.080

0.061

MMscf/d

N/A

MMBtu/hr

N/A

gal

bbl

gal

bbl

gal

bbl

gal

bbl

gal

bbl

gal

bbl

MMBtu/hr

Section II – General Requirements

Title V Administrative Requirements

1.1. Annual Fee Payment [RAC 2-110(1)(h) and RAC 2-118]

1.1.1. An annual operating permit emission fee shall be paid to the Tribe by the

permittee.

[RAC 2-118(2)]

1.1.2. The permittee shall pay the annual permit fee each year no later than April 1 st for

the preceding calendar year.

[RAC 2-118(2)]

1.1.3. Fee payments shall be remitted in the form of a money order, bank draft, certified

check, corporate check, or electronic funds transfer payable to the Southern Ute

Indian Tribe and sent or delivered by the United States Postal Service c/o

Environmental Programs Department Part 70 Program, P.O. Box 737 MS #84,

Ignacio, Colorado 81137; or by common carrier (such as UPS or FedEx) c/o

Environmental Programs Department Part 70 Program, 398 Ouray Drive, Ignacio,

Colorado 81137.

[RAC 2-118(4)(a)]

1.1.4. The permittee shall send an updated fee calculation worksheet submitted annually

by the same deadline as required for fee payment to the address listed in the

Submissions section of this permit.

[RAC 2-118]

1.1.5. The permittee shall submit the initial fee calculation work sheet using the most

recent form provided by the Tribe.

[RAC 2-118(2)(c)]

1.1.6. Basis for calculating annual fee:

1.1.6.1.

Subtotal annual fees shall be calculated by multiplying the applicable

emission fee set pursuant to RAC §2-119(1) of this code times the total

tons of actual emissions for each fee pollutant. In lieu of actual emissions,

annual fees may be calculated based on the potential to emit for each fee

pollutant. Emissions of any regulated air pollutant that already are

included in the fee calculation under a category of regulated pollutant,

such as a federally listed hazardous air pollutant that is already accounted

for as a VOC or as PM10, shall be counted only once in determining the

source’s actual emissions.

[RAC 2-119(2)(a)]

1.1.6.1.1.

“Actual emissions” means the actual rate of emissions in tpy of

any fee pollutant (for fee calculation) emitted from a Title V

source over the preceding calendar year or any other period

determined by the Tribe to be more representative of normal

operation and consistent with the fee schedule adopted by the Tribe

and approved by the Administrator. Actual emissions shall be

calculated using each emissions units actual operating hours,

production rates, in-place control equipment, and types of

materials processed, stored, or combusted during the preceding

calendar year or other period used for this calculation.

[RAC 1-103(2)]

1.1.6.1.2.

Actual emissions shall be computed using compliance methods

required by the permit.

[RAC 2-118(1)(b)]

1.1.6.1.3.

If actual emissions cannot be determined using the compliance

methods in the permit, the permittee shall use other federally

recognized procedures.

[RAC 2-118(1)(b)]

1.1.6.2.

The total annual fee submitted shall be the greater of the applicable

minimum fee or the sum of subtotal annual fees for all fee pollutants

emitted from the source.

[RAC 2-119(2)(b)]

[Explanatory note: The applicable emission fee amount and applicable minimum fee (if necessary)

are revised each calendar year to account for inflation, and they are available from AQD prior to

the start of each calendar year.]

1.1.6.3.

The permittee shall exclude the following emissions from the calculation

of fees:

1.1.6.3.1.

The amount of actual emissions of any one fee pollutant that the

source emits in excess of 4,000 tpy.

1.1.6.3.2.

Any emissions that come from insignificant activities not required

in a permit application pursuant to RAC §2-106(4).

[RAC 1-103(2)(c)]

1.1.7. Annual fee calculation worksheets shall be certified as to truth, accuracy, and

completeness by a responsible official.

[RAC 2-105 and RAC 2-118(2)(c)]

1.1.8. Failure of the permittee to pay fees by the due date shall subject the permittee to

assessment of penalties and interest in accordance with RAC §2-118(6).

[RAC 2-118(6)]

1.1.9. When notified by the Tribe of underpayment of fees, the permittee shall remit full

payment within 30 days of receipt of an invoice from the Tribe.

[RAC 2-119(3)(b)]

1.1.10. A permittee who thinks a Tribe assessed fee is in error and who wishes to

challenge such fee shall provide a written explanation of the alleged error to the

Tribe along with full payment of the assessed fee.

[RAC 2-119(3)(c)]

1.2. Compliance Requirements

1.2.1. Compliance with the Permit

1.2.1.1.

The permittee must comply with all conditions of this part 70 permit. Any

permit noncompliance with federally enforceable or Commission-only

permit conditions constitutes a violation of the RAC and Clean Air Act

and is grounds for enforcement action; for permit termination, revocation

and reissuance, or revision; or for denial of a permit renewal application.

[RAC 2-110(3)(a)]

1.2.1.2.

It shall not be a defense for a permittee in an enforcement action that it

would have been necessary to halt or reduce the permitted activity in order

to maintain compliance with the conditions of this permit.

[RAC 2-110(3)(b)]

1.2.1.3.

All terms and conditions of this permit which are required under the Clean

Air Act or under any of its applicable requirements, including any

provisions designed to limit a source’s potential to emit, are enforceable

by the Administrator and citizens under the Clean Air Act, except terms

and conditions the permit specifically designates as not being federally

enforceable under the Clean Air Act that are not required under the Clean

Air Act or under any of its applicable requirements. Terms and conditions

so designated are not subject to the requirements of RAC §§2-108, 2-111,

2-112, other than those contained in this paragraph.

[RAC 2-110(3)(f)]

1.2.1.4.

This permit, or the filing or approval of a compliance plan, does not

relieve any person from civil or criminal liability for failure to comply

with the provisions of the RAC and the Clean Air Act, applicable

regulations thereunder, and any other applicable law or regulation.

[RAC 2-110(3)(g)]

1.2.1.5.

For the purpose of submitting compliance certifications in accordance

with the Compliance Certifications condition below of this permit, or

establishing whether or not a person has violated or is in violation of any

requirement of this permit, nothing shall preclude the use, including the

exclusive use, of any credible evidence or information, relevant to whether

a source would have been in compliance with applicable requirements if

the appropriate performance or compliance test or procedure had been

performed.

[Section 113(a) and 113(e)(1) of the Act, 40 CFR §§51.212, 52.12, 52.33, 60.11(g), and 61.12]

1.2.2. Compliance Certifications

1.2.2.1.

The permittee shall submit to the Tribe and the Administrator an annual

certification of compliance which shall certify the source’s compliance

status with all permit terms and conditions and all applicable requirements

relevant to the source, including those related to emission limitations,

standards, or work practices. The compliance certification shall be

certified as to truth, accuracy, and completeness by a responsible official

consistent with RAC §2-110(9)(a). The certification of compliance shall

be submitted annually by April 1st and shall cover the preceding calendar

year in which the certification of compliance is due, except that the first

annual certification of compliance will cover the period from the issuance

date of this permit through December 31st of the same year.

[RAC 2-110(9)(c)]

1.2.3. Compliance Schedule

1.2.3.1.

For applicable requirements with which the source is in compliance, the

source will continue to comply with such requirements.

[RAC 2-106(4)(l)(ii)]

1.2.3.2.

For applicable requirements that will become effective during the permit

term, the source shall meet such requirements on a timely basis.

[RAC 2-106(4)(l)(iii)]

1.3. Duty to Provide and Supplement Information [RAC 2-110(7)(e), 2-106(5), and 2124]

1.3.1. The permittee shall furnish to the Tribe, within the period specified by the Tribe,

any information that the Tribe request in writing to determine whether cause

exists for reopening and revising, revoking, and reissuing, or terminating the

permit, or to determine compliance with the permit. Upon request, the permittee

shall also furnish to the Tribe copies of records that are required to be kept by the

permit, including information claimed to be confidential. Information claimed to

be confidential must be accompanied by a claim of confidentiality according to

the provisions of RAC 2-124.

[RAC 2-110(7)(e) and RAC 2-124]

1.3.2. The permittee, upon becoming aware that any relevant facts were omitted or

incorrect information was submitted in the permit application or in a supplemental

submittal, shall promptly submit such supplementary facts or corrected

information. In addition, a permittee shall provide additional information as

necessary to address any requirements that become applicable after the date a

complete application is filed, but prior to release of a draft permit.

[RAC 2-106(5)]

1.4. Submissions [RAC 2-105]

1.4.1. Any application, form, report, compliance certification, or other document

submitted by the permittee under this permit shall contain a certification by a

responsible official of truth, accuracy, and completeness. This certification shall

state that, based on information and belief formed after reasonable inquiry, the

statements and information in the document are true, accurate, and complete.

[Explanatory Note: The Tribe has developed a reporting form “CTAC” for certifying

truth, accuracy and completeness of part 70 submissions. The form may be found on the

AQD’s website (http://www.southernute-nsn.gov/environmental-programs/air-quality).]

1.4.2. Except where otherwise noted, any documents required to be submitted under this

permit, including reports, test data, monitoring data, notifications, compliance

certifications, fee calculation worksheets, and applications for renewals and

permit modifications shall be submitted:

1.5. Severability Clause [RAC 1-106 and RAC 2-110(1)(f)]

by email at: airquality@southernute-nsn.gov

or by United States Postal Service:

Part 70 Program

Environmental Programs Department

Air Quality Division

P.O. Box 737 MS #84

Ignacio, Colorado 81137

or by Common Carrier:

Part 70 Program

Environmental Programs Department

Air Quality Division

398 Ouray Drive

Ignacio, CO 81137

The provisions of this permit are severable, and in the event of any challenge to any portion

of this permit, or if any provision is held invalid, the remaining permit conditions shall

remain valid and in force.

1.6. Permit Actions [RAC 2-110(3)]

1.6.1. This permit may be modified, reopened and revised, revoked and reissued, or

terminated for cause.

[RAC 2-110(3)(c)]

1.6.2. The filing by the permittee of a request for a permit revision, reissuance, or

termination, or of a notification of planned changes or anticipated noncompliance

shall not stay any permit condition.

[RAC 2-110(3)(d)]

1.7. Administrative Permit Revision [RAC 2-111(2)]

1.7.1. The permittee may submit an application for an administrative permit revision as

defined in RAC §1-103.

[RAC 2-111(2)(a)]

1.7.2. The permittee may implement an administrative permit revision immediately

upon submittal of the request for the administrative revision.

[RAC 2-111(2)(c)]

[Note to permittee: If the provisions allowing for an administrative permit revision do not apply,

please contact the Air Quality Division for a determination of similarity prior to submitting your

request for an administrative permit revision.]

1.8. Minor Permit Revisions [RAC 2-111(3)]

1.8.1. The permittee may submit an application for a minor permit revision as defined in

RAC §1-103.

1.8.2. An application requesting the use of minor permit revision procedures shall meet

the requirements of RAC §2-106(4) and shall include the following:

1.8.2.1.

A description of the change, the emissions resulting from the change, and

any new applicable requirements that will apply if the change occurs;

1.8.2.2.

If changes are requested to the permit language, the permittee’s suggested

draft permit changes;

1.8.2.3.

Certification by a responsible official, consistent with RAC §2-105, that

the proposed revision meets the criteria for use of minor permit revision

procedures and a request that such procedures be used; and

1.8.2.4.

Completed forms for the Tribe to use to notify the Administrator and

affected programs as required under RAC §2-108.

1.8.2.5.

If the requested permit revision would affect existing compliance plans or

schedules, related progress reports, or certification of compliance

requirements, and an outline of such effects.

[RAC 2-111(3)(a)]

1.8.3. The permittee shall not submit multiple minor permit revision applications that

may conceal a larger revision that would not constitute a minor permit revision.

[RAC 2-111(3)(b)]

1.8.4. The permittee may make the change proposed in its minor permit revision

application immediately after it files such application, provided, however, for

sources that have previously utilized this provision during the term of the permit

and, on two or more occasions have failed to file a complete application, may

thereafter make the change only after the application is deemed complete. After

the permittee makes the change and until the Tribe takes any of the actions

specified in the following subsection, the permittee must comply with both the

applicable requirements governing the change and the proposed permit terms and

conditions. During this period, the permittee need not comply with the existing

permit terms and conditions it seeks to modify. If the permittee fails to comply

with its proposed permit terms and conditions during this period, however, the

existing permit terms and conditions it seeks to modify may be enforced against

it. The filing of a minor permit revision application does not authorize

construction or modification of a source under the NSR preconstruction permit

program. It is the permittee’s responsibility to determine if a preconstruction

permit is required prior to commencing construction, modification, or

reconstruction.

[RAC 2-111(3)(e)]

1.8.5. The permit shield under RAC §2-110(10) does not extend to minor permit

revisions.

[RAC 2-110(10)(d)]

1.9. Significant Permit Revisions [RAC 2-111(4)]

1.9.1. The permittee must request the use of significant permit revision procedures as

defined in RAC §1-103.

1.9.2. Significant permit revisions shall meet all requirements of the RAC for permit

issuance and renewal, including those for applications, review by the

Administrator and affected programs, and public participation.

[RAC 2-111(4), 2-109, and 2-106(3)]

1.10.

Permit Reopenings, Revocations and Reissuances, and Terminations [RAC 2112]

1.10.1. The permit may be reopened and revised for any of the reasons listed in the

paragraphs below. Alternatively, the permit may be revoked and reissued for the

reasons listed in the paragraphs below:

1.10.1.1.

Additional requirements under the Clean Air Act become applicable to a

major source with a remaining permit term of 3 or more years, provided

that the Tribe shall revise such permits to incorporate such additional

requirements no later than 18 months after promulgation of such

requirements, and no such reopening is required if the effective date of the

requirement is later than the permit expiration date unless the original

permit or any of its terms or conditions have been extended past the permit

expiration date pursuant to RAC §2-104(2)(b)(iii);

1.10.1.2.

Additional requirements (including excess emissions requirements)

become applicable to an affected source under the acid rain program.

Upon approval by the Administrator, excess emissions offset plans shall

be deemed to be incorporated into the permit;

1.10.1.3.

The Tribe or the Administrator determines that the permit contains a

material mistake or that inaccurate statements were made in establishing

the terms or conditions of the permit; or

1.10.1.4.

The Tribe or the Administrator determines that the permit must be revised

or revoked and reissued to assure compliance with applicable

requirements.

1.10.2. The permit may be terminated for any of the reasons listed below:

1.11.

1.10.2.1.

The permittee fails to meet the requirements of an approved compliance

plan;

1.10.2.2.

The permittee has been in significant or repetitious noncompliance with

the operating permit terms or conditions;

1.10.2.3.

The permittee has exhibited a history of willful disregard for

environmental laws of any tribal or state authority, or of the United States;

1.10.2.4.

The permittee has knowingly misrepresented a material fact in any

application, record, report, plan, or other document filed or required to be

maintained under the permit;

1.10.2.5.

The permittee falsifies, tampers with, or renders inaccurate any monitoring

device or method required to be maintained under the permit;

1.10.2.6.

The permittee fails to pay fees required under RAC§§2-118 and 2-119; or

1.10.2.7.

The Administrator has found that cause exists to terminate the permit.

Property Rights [RAC 2-110(3)(e)]

This permit does not convey any property rights of any sort, or any exclusive privilege.

1.12.

Inspection and Entry [RAC 2-110(9)(b)]

Upon presentation of credentials and other documents as may be required by law, the

permittee shall allow authorized representatives of the Tribe or other authorized

representative to perform the following:

1.12.1. Enter upon the permittee’s premises where a source is located or emissionsrelated activity is conducted, or where records must be kept under the conditions

of the permit;

1.12.2. Have access to and copy, at reasonable times, any records that must be kept under

the conditions of the permit;

1.12.3. Inspect at reasonable times any facilities, equipment (including monitoring and air

pollution control equipment), practices, or operations regulated or required under

the permit; and

1.12.4. As authorized by the Clean Air Act, sample or monitor at reasonable times

substances or parameters for the purpose of assuring compliance with the permit

or applicable requirements.

1.13.

[Reserved]

1.14.

Permit Transfers [RAC 2-113]

1.14.1. This permit shall not be transferable, by operation of law or otherwise, from one

location to another or from one source to another, except that a permit may be

transferred from one location to another in the case of a portable source that has

notified the Tribe in advance of the transfer, pursuant to the RAC. A permit for a

source may be transferred from one person to another if the Tribe finds that the

transferee is capable of operating the source in compliance with the permit. This

transfer must be accomplished through an administrative permit revision in

accordance with the Administrative Permit Revisions section of this permit.

1.15.

Off-Permit Changes [RAC 2-116(2)]

1.15.1. The permittee is allowed to make, without a permit revision, certain changes that

are not addressed or prohibited by this permit provided that the following

requirements are met:

1.15.1.1.

Each such change meets all applicable requirements and shall not violate

any existing permit term or condition;

1.15.1.2.

Such changes are not subject to any requirements under title IV of the

Clean Air Act and are not modifications under title I of the Clean Air Act;

1.15.1.3.

Such changes are not subject to permit revision procedures under RAC §2111; and

1.15.1.4.

The permittee provides contemporaneous written notice to the Tribe and

the Administrator of each such change, except for changes that qualify as

insignificant activities. Such notice shall state when the change occurred

and shall describe the change, any resulting emissions change, pollutants

emitted, and any applicable requirement that would apply as a result of the

change.

[RAC 2-116(2)(a)]

1.15.2. The permit shield does not apply to changes made under this provision.

[RAC 2-110(10)(d)]

1.15.3. The permittee shall keep a record describing changes made at the source that

result in emissions of any regulated air pollutant subject to an applicable

requirement, but not otherwise regulated under the permit, and the emissions

resulting from those changes.

[RAC 2-116(2)(b)]

1.15.4. A copy of each off-permit change notification shall be made available to the Tribe

upon request.

[RAC 2-110(6)]

1.16.

Permit Expiration and Renewal

[RAC §§2-104(3), 2-106(2)(b), 2-107(7)(a), 2-107(7)(b), 2-110(1)(a), and 2-106(3)]

1.16.1. This permit shall expire five years from the issuance date of this permit.

[RAC 2-110(1)(a)]

1.16.2. Expiration of this permit terminates the permittee’s right to operate unless a

timely and complete permit renewal application has been submitted at least 6

months but not more than 18 months prior to the date of expiration of this permit.

[RAC 2-107(7)(b)]

1.16.3. If the permittee submits a timely and complete permit application for renewal,

consistent with RAC §2-106 but the Tribe has failed to issue or disapprove a

renewal permit before the end of the permit term, then the permit shall not expire

and all its terms and conditions shall remain in effect until the renewal permit has

been issued or disapproved.

[RAC 2-104(2)(b)]

1.16.4. The ability to operate under this permit shall cease if (1) the Tribe takes final

action to issue the permittee a renewal permit or deny the permittee a permit or

(2) the permittee fails to submit by the deadline specified in writing by the Tribe

any additional information identified as being needed to process the application.

[RAC 2-104(3)]

1.16.5. Renewal of this permit is subject to the same procedures, including those for

public participation and affected program and EPA review, as those that apply to

initial permit issuance.

[RAC 2-107(7)(a)]

1.16.6. The application for renewal shall include the current permit number, description

of permit revisions and off permit changes that occurred during the permit term,

any applicable requirements that were promulgated and not incorporated into the

permit during the permit term, and other information required by the application

form.

[RAC 2-106(4)(e)(ix)]

Facility-Wide Requirements

Conditions in this section of the permit apply to all emissions units located at the facility, including

any units not specifically listed in Table 1 or Table 2 of the Source Emission Points section of this

permit.

[RAC 2-110(1)(d)]

2.1. General Recordkeeping Requirements [RAC 2-110(6)]

The permittee shall comply with the following generally applicable recordkeeping

requirements:

2.1.1. If the permittee determines that his or her stationary source that emits (or has the

potential to emit, without federally recognized controls) one or more hazardous

air pollutants is not subject to a relevant standard or other requirement established

under 40 CFR part 63, the permittee shall keep a record of the applicability

determination, for a period of five years after the determination, or until the

source changes its operations to become an affected source, whichever comes

first. Each of these records shall be made available to the Tribe upon request. The

record of the applicability determination shall include an analysis (or other

information) that demonstrates why the permittee believes the source is

unaffected (e.g., because the source is an area source).

[40 CFR 63.10(b)(3)]

2.1.2. Records shall be kept of off permit changes made, as required by the Off Permit

Changes section of this permit.

2.2. General Reporting Requirements

2.2.1. The permittee shall submit to the Tribe all reports of any required monitoring

under this permit semiannually, by April 1 and October 1 of each year. The

report due on April 1 shall cover the July 1 - December 31 reporting period of the

previous calendar year. The report due on October 1 shall cover the January 1 June 30 reporting period of the current calendar year. All instances of deviations

from permit requirements shall be clearly identified in such reports. All required

reports shall be certified by a responsible official consistent with the Submissions

section of this permit.

[RAC 2-110(7)(a)]

2.2.2. “Deviation” means any situation in which an emissions unit fails to meet a permit

term or condition. A deviation is not always a violation. A deviation can be

determined by observation or through review of data obtained from any testing,

monitoring, or recordkeeping established in accordance with RAC 2-110(5) and

(6). For a situation lasting more than 24 hours which constitutes a deviation, each

24 hour period is considered a separate deviation. Included in the meaning of

deviation are any of the following:

2.2.2.1.

A situation where emissions exceed an emission limitation or standard;

2.2.2.2.

A situation where process or emissions control device parameter values

indicate that an emission limitation or standard has not been met; or

2.2.2.3.

A situation in which observations or data collected demonstrate

noncompliance with an emission limitation or standard or any work

practice or operating condition required by the permit.

2.2.2.4.

A situation in which an exceedance or an excursion, as defined in 40 CFR

Part 64 occurs.

[RAC 1-103(21)]

2.2.3. The permittee shall promptly report to the Tribe deviations from permit

requirements, (including emergencies), including the date, time, duration, and the

probable cause of such deviations, the quantity and pollutant type of excess

emissions resulting from the deviation, and any preventative, mitigation, or

corrective actions or measures taken. Prompt deviation reports shall be submitted

to the following email address: airquality@southernute-nsn.gov

2.2.4.

“Prompt” is defined as follows:

2.2.4.1.

Where the underlying applicable requirement contains a definition of

“prompt” or otherwise specifies a time frame for reporting deviations, that

definition or time frame shall govern.

2.2.4.2.

Where the underlying applicable requirement fails to address the time

frame for reporting deviations, reports of deviations will be submitted

based on the following schedule:

2.2.4.2.1.

For emissions of a hazardous air pollutant or a toxic air pollutant

(as identified in the applicable regulation) that continue for more

than an hour in excess of permit requirements, the report must be

made by email, telephone, verbal, or facsimile communication by

the close of business the next working day, upon discovery of the

occurrence, and in writing within 10 working days from the

occurrence;

2.2.4.2.2.

For emissions of any regulated air pollutant, excluding those listed

in RAC §2-110(7)(b)(i), that continue for more than 2 hours in

excess of permit requirements, the report must be made by email,

telephone, verbal, or facsimile communication by the close of

business the next working day, upon discovery of the occurrence,

and in writing within 10 working days from the occurrence;

2.2.4.2.3.

For all other deviations from permit requirements, the report shall

be contained in the report submitted with the semi-annual

monitoring report.

[RAC 2-110(7)(b)]

2.3. Alternative Operating Scenarios [RAC 2-110(8)]

2.3.1. Replacement of an existing engine or turbine identified in this permit shall be

allowed as an off-permit change pursuant to the Off Permit Changes provisions of

this permit provided all of the following conditions are met:

2.3.1.1.

The engine or turbine replacement is not subject to any requirements

under Title IV of the Clean Air Act and is not a modification under Title I

of the Clean Air Act;

2.3.1.2.

The replacement engine or turbine is of the same make, model,

horsepower rating, and configured to operate in the same manner as the

engine or turbine being replaced.

2.3.1.3.

The replacement engine or turbine meets all applicable requirements

identified in this permit that apply to the existing engine or turbine being

replaced.

2.3.1.4.

All applicable requirements that apply to the replacement engine or

turbine are already included in the permit. Replacement of an existing

engine or turbine identified in this permit with a new, modified, or

reconstructed engine must utilize a Minor Permit Revision as specified in

RAC 2-111(3) or a Significant Permit Revision as specified in RAC 2111(4) to incorporate any new applicable requirements. The applicable

requirements include, but may not be limited to:

2.3.1.4.1.

Standards of Performance for Stationary Compression Ignition

Internal Combustion at 40 CFR Part 60, Subpart IIII;

2.3.1.4.2.

Standards of Performance for Stationary Spark Ignition Internal

Combustion Engines at 40 CFR Part 60, Subpart JJJJ;

2.3.1.4.3.

National Emission Standard for Hazardous Air Pollutants for

Stationary Reciprocating Internal Combustion Engines at 40 CFR

Part 63, Subpart ZZZZ;

2.3.1.4.4.

Standards of Performance for Stationary Gas Turbines at 40 CFR

Part 60, Subpart GG;

2.3.1.4.5.

Standards of Performance for Stationary Combustion Turbines at

40 CFR Part 60, Subpart KKKK;

2.3.1.4.6.

National Emission Standard for Hazardous Air Pollutants for

Stationary Combustion Turbines at 40 CFR Part 63, Subpart

YYYY;

2.3.1.4.7.

Requirements established in a permit or permits issued pursuant to

the Federal Minor New Source Review Program in Indian Country

at 40 CFR Part 49;

2.3.1.4.8.

Requirements established in a permit or permits issued pursuant to

the Prevention of Significant Deterioration of Air Quality Program

at 40 CFR Part 52; or

2.3.1.4.9.

Requirements established in any promulgated Federal

Implementation Plan that may apply to engines located on the

Southern Ute Indian Reservation.

2.3.2. The permittee shall provide contemporaneous written notice to the Tribe and the

Administrator of any replacement of an existing engine or turbine identified in

this permit. Such notice shall state when the replacement occurred and shall

describe the replacement and any applicable requirement that would apply as a

result of the replacement.

2.3.3. The permittee shall keep a record of the engine or turbine replacement.

2.3.4. The use of a backup thermal oxidizer with equivalent capacity and emission

destruction efficiency and configured to operate in the same manner as the

primary thermal oxidizer shall be an allowed alternative operating scenario under

this permit provided that the following conditions are met:

2.3.4.1.

Any emission limits, requirements, testing or other provisions that apply to

the primary thermal oxidizer shall also apply to the backup thermal

oxidizer except that an annual performance test shall only be conducted on

the backup thermal oxidizer if the unit operates for more than 500 hours in

any calendar year.

2.3.4.2.

At no time shall the backup thermal oxidizer operate at the same time the

primary thermal oxidizer is operating except periods of transition between

the primary and backup thermal oxidizers. Transition events shall be

documented, last no more than 30 minutes in duration, and will be

reported as excess emission events.

2.4. Permit Shield [RAC 2-110(10)(c)]

Nothing in this permit shall alter or affect the following:

2.4.1. The provisions of Section 303 of the Clean Air Act, 42 U.S.C. §7603 concerning

emergency powers, including the respective authorities of the Administrator under

those sections;

2.4.2. The liability of a permittee for any violation of applicable requirements prior to or

at the time of permit issuance;

2.4.3. The applicable requirements of the acid rain program consistent with section

408(a) of the Act; or

2.4.4. The ability of the Administrator respectively to obtain information from a source

pursuant to Section 114 of the Clean Air Act, 42 U.S.C. §7414.

2.5. Stratospheric Ozone and Climate Protection [40 CFR Part 82]

The permittee shall comply with the standards for recycling and emissions reduction

pursuant to 40 CFR Part 82, Subpart F:

2.5.1. Persons opening appliances for maintenance, service, repair, or disposal must

comply with the required practices pursuant to 40 CFR §82.156.

2.5.2. Equipment used during the maintenance, service, repair, or disposal of appliances

must comply with the standards for recycling and recovery equipment pursuant to

40 CFR §82.158.

2.5.3. Persons performing maintenance, service, repair, or disposal of appliances must

be certified by an approved technician certification program pursuant to 40 CFR

§82.161.

Section III – Site Specific Permit Terms

New Source Performance Standards (NSPS) and 40 CFR Part 60

1.1. 40 CFR Part 60, Subpart GG – Standards of Performance for Stationary Gas

Turbines [40 CFR 60.330 – 60.335. RAC 3-102]

This facility is subject to the requirements of 40 CFR Part 60, subparts A and GG.

Notwithstanding conditions in this permit, you shall comply with all applicable

requirements of 40 CFR Part 60, subparts A and GG.

[40 CFR 60.1]

1.1.1.

Affected Sources

1.1.1.1.

The following emission units are considered affected sources under 40

CFR Part 60, Subpart GG:

T-1 – Solar Centaur H T5500 Natural Gas-Fired Simple Cycle Turbine, 37

MMBtu/hr

T-2 – Solar Centaur H T5700 Natural Gas-Fired Simple Cycle Turbine, 39

MMBtu/hr

[40 CFR 60.330]

1.1.2.

Standard for Nitrogen Oxides

1.1.2.1.

Emission

Unit

Pollutant

No owner or operator subject to the provisions of this subpart shall cause

to be discharged into the atmosphere from any stationary gas turbine, any

gases which contain nitrogen oxides in excess of:

Emission Standard

𝑆𝑇𝐷 = 0.0150

T-1

NOx

Regulatory

Reference

(14.4)

+ 0 = 173 𝑝𝑝𝑚

𝑌

Where:

STD = allowable ISO corrected (if required as given in

§60.335(b)(1)) NOx emission concentration (percent by

volume at 15 percent oxygen and on a dry basis),

Y = 12.5

40 CFR 60.332(a)(2)

Manufacturer's rated heat rate at manufacturer's rated peak

load (kilojoules per watt hour), or actual measured heat rate

based on lower heating value of fuel as measured at actual

peak load for the facility. The value of Y shall not exceed

14.4 kilojoules per watt hour, and

F=0

NOx emission allowance for fuel-bound nitrogen as defined

in paragraph 40 CFR 60.332(a)(4).

(14.4)

𝑆𝑇𝐷 = 0.0150

+ 0 = 170 𝑝𝑝𝑚

𝑌

Where:

STD = allowable ISO corrected (if required as given in

§60.335(b)(1)) NOx emission concentration (percent by

volume at 15 percent oxygen and on a dry basis),

T-2

NOx

Y = 12.7

Manufacturer's rated heat rate at manufacturer's rated peak

load (kilojoules per watt hour), or actual measured heat rate

based on lower heating value of fuel as measured at actual

peak load for the facility. The value of Y shall not exceed

14.4 kilojoules per watt hour, and

40 CFR 60.332(a)(2)

F=0

NOx emission allowance for fuel-bound nitrogen as defined

in paragraph 40 CFR 60.332(a)(4).

1.1.2.2.

1.1.3.

Stationary gas turbines with a heat input greater than or equal to 10.7

gigajoules per hour (10 MMBtu/hr) when fired with natural gas are exempt

from the NOx emission standard when being fired with an emergency fuel.

For the purpose of this requirement, the term “emergency fuel” means “a

fuel fired by a gas turbine only during circumstances, such as natural gas

curtailment or breakdown of delivery system, that makes it impossible to

fire natural gas in the gas turbine.”

[40 CFR 60.331(r) & 60.332]

Standard for Sulfur Dioxide

Every owner or operator subject to this subpart shall comply with the following

condition:

1.1.3.1.

1.1.4.

No owner or operator subject to the provisions of this subpart shall burn in

any stationary gas turbine any fuel which contains total sulfur in excess of

0.8 percent by weight (8000 ppmw).

[40 CFR 60.333]

Monitoring of Operations

1.1.4.1.

The owner or operator of any stationary gas turbine subject to this subpart:

1.1.4.2.

The permittee may continue to monitor for nitrogen and sulfur content

using the custom fuel monitoring schedule (CFMS) approved by EPA in a

letter dated December 2, 1996, and described in the subparagraphs below:

1.1.4.2.1.

Fuel Nitrogen Monitoring Protocol

1.1.4.2.1.1.

Monitoring of fuel nitrogen content shall not be required

while natural gas is the only fuel fired in the turbine.

1.1.4.2.1.2.

Monitoring of fuel nitrogen content shall be determined

daily while firing a fuel other than pipeline-quality natural

gas or while firing an emergency fuel as defined in 40 CFR

60.331(r).

1.1.4.2.1.3.

Should a nitrogen analysis, required for any other reason

other than firing an emergency fuel, demonstrate

noncompliance with the emission standard for NOx

contained in 40 CFR 60.332, the permittee shall

immediately notify EPA Region 8 and the Tribe of the

excess emissions and nitrogen monitoring shall be

conducted daily during the interim period while the custom

fuel monitoring schedule is being re-examined by EPA

Region 8 and the Tribe.

1.1.4.2.2.

Fuel Sulfur Monitoring Protocol

1.1.4.2.2.1.

Analysis for fuel sulfur content of the natural gas shall be

conducted using the appropriate methods specified in 40

CFR.335(b)(10)(ii); or for Phase I sampling the permittee’s

GC monitoring system may be used; and under Phase II

and III, the “length of stain tube” method is approved as an

alternative fuel sulfur test method, providing that the Gas

Processors Association procedures (GPA Standard 237786) are followed and 100% pipeline quality natural gas is

the only fuel fired in the gas turbines.

1.1.4.2.2.1.1.

Phase

III

The sampling and analysis frequency of fuel sulfur

allowed under the custom fuel monitoring schedule

is as follows:

Frequency

Daily

Quarterly

Semi-Annually

Technique

El Paso GC Data

Length of Stain Tube

Period

6 Months

18 Months

2 years

1.1.4.2.2.1.2.

If, during the period of each phase, the monitoring

required above shows little variability in the fuel

sulfur content and demonstrates compliance with

the emission limits for SO2 contained in 40 CFR

60.333, the permittee may then proceed to the next

sampling phase with written notices to EPA Region

8 and the Tribe.

1.1.4.2.2.1.3.

Monitoring of fuel sulfur content shall be

determined daily while firing an emergency fuel as

defined in 40 CFR 60.331(r).

1.1.4.2.2.1.4.

Should sulfur analysis, required for any reason other

than for firing an emergency fuel, demonstrate

noncompliance with the emission standard for SO 2

contained in 40 CFR 60.333, the permittee shall

immediately notify EPA Region 8 and the Tribe of

the excess emissions and sulfur monitoring shall be

conducted daily during the interim period while the

custom fuel monitoring schedule is being reexamined by EPA Region 8 and the Tribe.

1.1.4.2.3.

After the initial 4-year term of the custom fuel monitoring

schedule, the permittee will continue using the same monitoring

requirements as stipulated in Phase III of the schedule in this

section of this permit. EPA Region 8 may choose to terminate the

custom fuel monitoring schedule and require the permittee to

reapply for a custom fuel monitoring schedule. Termination of the

custom fuel monitoring schedule will require that the permittee

monitor as required by 40 CFR 60.3334(h)(1) through (3).

1.1.4.2.4.

If there is a change in fuel supply, the permittee must immediately

notify the EPA Region 8 and the Tribe of such change for reexamination of this custom fuel monitoring schedule. A change in

fuel quality, fuel makeup, or fuel supplier shall be considered as a

change in fuel supply. Sulfur and nitrogen monitoring shall be

conducted daily during the interim period when this custom fuel

monitoring schedule is being re-examined.

1.1.4.2.5.

All analyses required by this custom fuel monitoring schedule shall

be performed by a laboratory using the approved test methods,

except for Phase I testing using the permittee’s GC Phase II and III

using the length of the stain tube. The permittee may request that

EPA Region 8 allow for the substitution of any analytical method

for another method specified in this custom fuel monitoring

schedule. Any substitution will require the written approval of

EPA Region 8.

1.1.4.2.6.

1.1.4.3.

EPA Region 8 and the Tribe may request that an audit of the fuel

sampling program be conducted at any time during the life of this

custom fuel monitoring schedule. This audit shall consist of daily

sampling of fuel gas for either nitrogen content, sulfur content, or

both. The length of this audit shall be no less than 2 weeks. If

noncompliance values are found in nitrogen content, sulfur

content, or both; daily monitoring shall be conducted during the

interim period while the custom fuel schedule is being re-examined

by EPA Region 8 and the Tribe.

[40 CFR 60.334]

The owner or operator of any affected facilities shall measure NOx

emissions at each affected facility at least once every calendar quarter to

show compliance with the requirements of 40 CFR 60.332(a)(2). To meet

this requirement, the permittee shall measure the NOX emissions from

each turbine subject to this subpart using a portable analyzer and the

monitoring protocol approved by EPA, or by the monitoring protocols

approved by EPA as outlined in 40 CFR 60 Appendix A.

1.1.4.3.1.

You may conduct a performance test as specified in this permit to

satisfy the requirement of quarterly portable analyzer

measurements.

1.1.4.3.2.

Monitoring shall begin in the first calendar quarter following EPA

notification to the applicant of the approval of the monitoring

protocol.

1.1.4.3.3.

If the affected facility is inoperable for 1,500 hours or more in any

calendar quarter, the permittee is exempt from conducting NO X

monitoring for the emissions unit for that quarter only.

1.1.4.3.4.

If the affected facility is inoperable for 3,000 hours or more in any

semi-annual period, the permittee is exempt from conducting NOx

monitoring for the emission unit for that semi-annual period only.

1.1.4.3.5.

Monitoring may not occur within 30 days of the previous

monitoring measurements.

1.1.4.3.6.

For any one turbine, if the results of four (4) consecutive quarterly

portable analyzer measurements are less than 75% of the NOx

emission limit for the turbine, you may reduce the frequency of

subsequent monitoring from quarterly to semi-annual. If results

from semi-annual portable analyzer measurements are greater than

75% of the emission limit, the monitoring frequency shall change

back to quarterly.

1.1.4.4.

The permittee shall not perform tuning or make any adjustments to turbine

settings, processes or operational parameters immediately prior to the

measurements or during measurements. Any such tuning or adjustments

may result in a determination that the result is invalid.

[RAC 2-110(5)(b)]

[Note: the issuance of this permit does not reset the monitoring frequency for the affected facilities subject to 40 CFR

Part 60, Subpart GG (i.e. if it has been demonstrated that the turbines are not emitting NOx in an amount greater

than 75% of the emission limit for four consecutive quarterly tests, and the monitoring frequency has been reduced to

semi-annual, you may continue on the semi-annual schedule)]

1.1.5.

Test Methods and Procedures

1.1.5.1.

The owner or operator shall conduct the performance tests required in

§60.8, using either:

1.1.5.1.1.

EPA Method 20,

1.1.5.1.2.

ASTM D6522-00 (incorporated by reference, see §60.17), or

1.1.5.1.3.

EPA Method 7E and either EPA Method 3 or 3A in appendix A to

this part, to determine NOx and diluent concentration.

1.1.5.1.4.

Sampling traverse points are to be selected following Method 20 or

Method 1, (non-particulate procedures) and sampled for equal time

intervals. The sampling shall be performed with a traversing

single-hole probe or, if feasible, with a stationary multi-hole probe

that samples each of the points sequentially. Alternatively, a multihole probe designed and documented to sample equal volumes

from each hole may be used to sample simultaneously at the

required points.

1.1.5.1.5.

Notwithstanding the above provision, the owner or operator may

test at fewer points than are specified in Method 1 or Method 20 if

the following conditions are met:

1.1.5.1.5.1.

1.1.5.1.5.1.1.

You may perform a stratification test for NO X and diluent

pursuant to:

The procedures specified in section 6.5.6.1(a)

through (e) appendix A to part 75 of 40 CFR.

1.1.5.1.5.2.

1.1.5.2.

Once the stratification sampling is completed, the owner or

operator may use the following alternative sample point

selection criteria for the performance test:

1.1.5.1.5.2.1.

If each of the individual traverse point NOx

concentrations, normalized to 15 percent O2, is

within 10 percent of the mean normalized

concentration for all traverse points, then you may

use 3 points (located either 16.7, 50.0, and 83.3

percent of the way across the stack or duct, or, for

circular stacks or ducts greater than 2.4 meters (7.8

feet) in diameter, at 0.4, 1.2, and 2.0 meters from

the wall). The 3 points shall be located along the

measurement line that exhibited the highest average

normalized NOx concentration during the

stratification test; or

1.1.5.1.5.2.2.

If each of the individual traverse point NOx

concentrations, normalized to 15 percent O2, is

within 5 percent of the mean normalized

concentration for all traverse points, then you may

sample at a single point, located at least 1 meter

from the stack wall or at the stack centroid.

The owner or operator shall determine compliance with the applicable

nitrogen oxides emission limitation in §60.332 and shall meet the

performance test requirements of §60.8 as follows:

1.1.5.2.1.

For each run of the performance test, the mean nitrogen oxides

emission concentration (NOXo) corrected to 15 percent O2 shall be

corrected to ISO standard conditions using the following equation.

Notwithstanding this requirement, use of the ISO correction

equation is optional for: Lean premix stationary combustion

turbines; units used in association with heat recovery steam

generators (HRSG) equipped with duct burners; and units equipped

with add-on emission control devices:

𝑵𝑶𝑿 = (𝑵𝑶𝑿𝒐 )(𝑷𝒓 /𝑷𝒐 )𝟎.𝟓 𝒆𝟏𝟗(𝑯𝒐 𝟎.𝟎𝟎𝟔𝟑𝟑) (𝟐𝟖𝟖 °K/ 𝑻𝒂 )𝟏.𝟓𝟑

Where:

NOX = emission concentration of NOX at 15 percent O2 and ISO

standard ambient conditions, ppm by volume, dry basis,

NOXo = mean observed NOX concentration, ppm by volume, dry

basis, at 15 percent O2,

Pr = reference combustor inlet absolute pressure at 101.3 kilopascals

ambient pressure. Alternatively, you may use 760 mm Hg (29.92 in

Hg),

Po = observed combustor inlet absolute pressure at test, mm Hg.

Alternatively, you may use the barometric pressure for the date of

the test,

Ho = observed humidity of ambient air, g H2O/g air,

e = transcendental constant, 2.718, and

Ta = ambient temperature, °K.

1.1.5.2.2.

1.1.5.3.

1.1.6.

The 3-run performance test required by §60.8 must be performed

within 5 percent at 30, 50, 75, and 90-to-100 percent of peak load

or at four evenly-spaced load points in the normal operating range

of the gas turbine, including the minimum point in the operating

range and 90-to-100 percent of peak load, or at the highest

achievable load point if 90-to-100 percent of peak load cannot be

physically achieved in practice. If the turbine combusts both oil

and gas as primary or backup fuels, separate performance testing is

required for each fuel. Notwithstanding these requirements,

performance testing is not required for any emergency fuel (as

defined in §60.331).

[40 CFR 60.335]

The initial performance test required by §60.8 must be conducted within

60 days after achieving the maximum production rate at which the

affected facility will be operated, but not later than 180 days after initial

startup of the affected facility.

[40 CFR 60.8]

Recordkeeping Requirements

1.1.6.1.

You must comply with the following recordkeeping requirements:

1.1.6.1.1.

You shall maintain records of the occurrence and duration of any

startup, shutdown, or malfunction in the operation of an affected

facility; any malfunction of the air pollution control equipment; or

any periods during which a continuous monitoring system or

monitoring device is inoperative.

1.1.6.1.2.

1.1.6.2.

You shall maintain a file of information required by the Subpart

GG conditions of this permit.

You must comply with the following recordkeeping requirements when

firing an emergency fuel:

1.1.6.2.1.

Monitoring of fuel sulfur content shall be recorded daily while

firing an emergency fuel as defined in 40 CFR 60.331(r).

1.1.6.2.2.

Monitoring of fuel nitrogen content shall be recorded daily while

firing a fuel other than pipeline-quality natural gas or while firing

an emergency fuel as defined in 40 CFR 60.331(r).

1.1.6.3.

You must keep records of all required monitoring. The records shall

include the following:

1.1.6.3.1.

The date, place, and time of sampling or measurements;

1.1.6.3.2.

The date(s) analyses were performed;

1.1.6.3.3.

The company or entity that performed the analyses.

1.1.6.3.4.

The analytical techniques or methods used;

1.1.6.3.5.

The results of such analyses; and

1.1.6.3.6.

The operating conditions as existing at the time of sampling or

measurement.

1.1.6.4.

You must keep a record of the number of hours an affected facility is

inoperable and document the reason(s) why it was inoperable.

1.1.6.5.

You must retain records of all required monitoring data and support

information, sample analyses, fuel supplier, fuel quality, and fuel make-up

pertinent to the custom fuel monitoring schedule for a period of at least 5

years from the date of the monitoring sample, measurement, report, or

application. These records shall be made available upon request by the

Tribe and the EPA. Support information includes all calibration and

maintenance records, all original strip-chart recordings for continuous

monitoring instrumentation, and copies of all reports required by this

permit.

[RAC 2-110(6)]

1.1.7.

Reporting Requirements

1.1.7.1.

You shall submit to the Tribe and the EPA a written report of the results of

any initial performance test(s) required in this section.

[RAC 2-110(7) and 40 CFR 60.8]

National Emission Standards for Hazardous Air Pollutants (NESHAP) and 40 CFR

Part 63

2.1. 40 CFR Part 63, Subpart HH - National Emission Standards for Hazardous Air

Pollutants From Oil and Natural Gas Production Facilities [40 CFR 63.760 – 63.779

and RAC 4-103]

The permittee is the owner or operator of a glycol dehydration unit that is exempt from

the standards of 40 CFR §63.764(d). The permittee shall retain each determination used

to demonstrate that the actual average benzene emissions from each dehydrator are below

0.90 megagram per year.

[40 CFR 63.764(e)(1), 63.772(b), and 63.774(d)(1)]

2.1.1. The permittee must obtain an extended wet gas analysis of the inlet gas stream at

least once per calendar year. The gas sample shall be taken at a point prior to

where the gas enters the dehydration system contact tower. The analysis shall

include the gas temperature and pressure at which the sample was taken. The gas

analysis results and corresponding temperature and pressure documented during

collection of the gas sample must be used to determine the actual average benzene

emissions annually, in accordance with §63.772(b)(2)(i) or (ii). If electing to

make this demonstration according §63.772(b)(2)(i), using the GRI-GLYCalc TM

model, the permittee shall perform each model run using a single gas analysis and

the corresponding temperature and pressure documented during collection of the

gas sample. The permittee may elect to average the results of multiple GRIGLYCalcTM model runs in determining actual average benzene emissions

annually, if multiple gas samples are collected within a 12-month period.

[RAC 2-110(5)(b)]

Reserved – Tribal Minor New Source Review

Reserved – Prevention of Significant Deterioration Requirements

Reserved – Consent Decree Requirements

Reserved – Compliance Assurance Monitoring (CAM) Requirements

Enhanced Monitoring, Recordkeeping, and Reporting

7.1. Any documents required to be submitted under this Title V operating permit,

including but not limited to, reports, test data, monitoring data, notifications,

compliance certifications, fee calculation worksheets, and applications for renewals

and permit modifications shall be submitted to the Tribe:

by email at: airqualty@southernute-nsn.gov

or by United States Postal Service:

or by Common Carrier:

Part 70 Program

Environmental Programs Department

Air Quality Division

P.O. Box 737 MS #84

Ignacio, Colorado 81137

Part 70 Program

Environmental Programs Department

Air Quality Division

398 Ouray Drive

Ignacio, CO 81137

Section IV – Appendix

Inspection Information

1.1. Driving Directions:

From the City of Durango, Colorado, go east on Highway 172 to County Road 307. Then

go south on County Road 307 for approximately 2.8 miles. Then go east into the facility

1.2. Global Positioning System (GPS):

Latitude: 37.156305 °N

Longitude: -107.780520 °W

1.3. Safety Considerations:

SIMCOE recommends all visitors to the Florida River Central Delivery Point wear a hard

hat, safety glasses, safety footwear, hearing protection, and fire-retardant clothing.

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.