Air Pollution Control (2020)

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Air Pollution Control

Title V Permit to Operate

Statement of Basis for Permit No V-SUIT-0054-2020.00

March 2, 2021

Red Cedar Gathering Company

Midway Compressor Station

Southern Ute Indian Reservation

La Plata County, Colorado

1. Facility Information

a. Location

The Midway Compressor Station (Midway), owned and operated by Red Cedar Gathering Company (Red

Cedar), is located within the exterior boundary of the Southern Ute Indian Reservation. The exact location

is Section 23, T33N, R7W, in La Plata County, at latitude North 37.09240 and longitude West 107.57650.

The mailing address is:

Red Cedar Gathering Company

Midway Compressor Station

125 Mercado Street; Suite 201

Durango, CO 81301

b. Contacts

Facility Contact:

Kyle Hunderman

Environmental Compliance Specialist II – Air Quality

Red Cedar Gathering Company

125 Mercado Street; Suite 201

Durango, CO 81301

(970) 764-6921

Responsible Official:

Coy Bryant

President and Chief Operating Officer

Red Cedar Gathering Company

125 Mercado Street; Suite 201

Durango, CO 81301

(970) 764-6900

c. Description of Operations

The Midway Compressor Station receives coal-bed methane gas gathered from nearby sources and

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

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

the transportation from the supplying gas wells. Separator overhead gas is fed to one of up to ten

compressor engines from a common suction header. The compressors discharge gas to a common

discharge that feeds to scrubbers. The scrubbers separate and collect liquids that may have formed

during compression. The compressed gas is then fed to a dehydration unit. Tri-ethylene glycol (TEG) is

circulated counter-currently and absorbs water in the wet gas. Rich glycol is circulated to a reboiler,

where moisture is driven to the atmosphere by heating the glycol. Dry gas exits the contactors and is

directed to the sales line, where it is metered and exits the facility. The gas processing capacity of the

facility is approximately 60 MMscf/day with ten compressor engines operating.

There are currently nine natural gas-fired 4-stroke lean-burn 1340 horsepower Caterpillar G2516LE

compressor engines and one natural gas-fired 4-stroke lean burn 1380 horsepower Caterpillar G3516J

compressor engine operating at the facility. The nine units have a site rating of 1251 horsepower and the

one unit has a site rating of 1380 horsepower. The facility also contains one Tri-ethylene glycol

dehydration unit with two 30 MMscfd contact towers and one 0.75 MMBtu/hr reboiler burner.

Additional facility equipment includes: ten 500 gallon lubricating oil storage tanks, ten 500 gallon used

oil storage tanks, four 500 gallon ethylene glycol storage tanks, three 500 gallon used oil storage tanks,

one 400 barrel used oil tank, one 60 barrel dehy still vent tank, one 0.750 MMBtu/hr TEG reboiler

heater, one 0.325 MMBtu/hr used oil storage tank heater, one 0.008 MMBtu/hr catalytic heater, and one

0.004 MMBtu/hr catalytic heater. Each of the Caterpillar compressor engines is equipped with either a

NOx sensor or O2 sensor as part of the air fuel controller system (AFRC) and an oxidation catalytic

converter to reduce emissions in the exhaust stream. A continuous parameter monitoring system

(CPMS) is used to record the catalyst inlet temperature of each engine to ensure that the inlet

temperature remains between 450° F and 1350° F. The CPMS continuously monitors the catalyst inlet

temperature and reduces the data to a 4-hour rolling average. The CPMS also logs the shutdown times

and events and displays the unit process and fuel flows for each engine. The pressure drop across the

catalyst is manually recorded at least once a month. Facility data is recorded in accordance with

applicable parts of Section §63.6640.

d. List of All Units and Emission-Generating Activities

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

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

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

Table 1 – Emission Units

Red Cedar Gathering Company, Midway Compressor Station

Emission

Unit ID

Control

Equipment

Description

Caterpillar G3516LE (4SLB SI) Natural Gas-Fired Compressor Engine

1,340 Nameplate Rated HP

Serial No.

WPW-02226

Install Date:

3/13/2019

Serial No.

WPW00724

Install Date:

8/20/2019

Serial No.

WPW00178

Install Date:

6/4/2019

Serial No.

WPW00235

Install Date:

5/8/2015

Serial No.

WPW00939

Install Date:

10/11/2016

Serial No.

WPW01778

Install Date:

11/19/2019

Serial No.

WPW01905

Install Date:

4/23/2019

Serial No.

WPW00938

Install Date:

7/16/2019

Caterpillar G3516LE (4SLB SI) Natural Gas-Fired Compressor Engine

1,340 Nameplate Rated HP

Serial No.

4EK-00507

Install Date:

12/3/2019

Caterpillar G3516J (4SLB SI) Natural Gas-Fired Compressor Engine

1,380 Nameplate Rated HP

E10

Serial No.

N6W0059

Install Date:

9/20/2018

Oxidation Catalyst

and AFRC

(*Enforceable)

Oxidation Catalyst

and AFRC

(*Not Enforceable)

Oxidation Catalyst

and AFRC

(*Enforceable)

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

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

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

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

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

[RAC 2-106(4)(f); RAC 1-103(36) and (37)]. However, the application may not omit information needed

to determine the applicability of, or to impose, any applicable requirement, or to calculate the fee

[RAC 2-106(4)(f)]. Units that qualify as “insignificant” for the purposes of the Part 70 application are in

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

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

insignificant. The application provided calculations for heater/reboiler emissions based on EPA’s AP-42

emission factors. Red Cedar provided sufficient information, including EPA Tanks 4.0.9d calculations, to

verify any emissions from liquids in the tanks were insignificant. This data supports Red Cedar’s claim

that these units qualify as insignificant.

Table 2 – Insignificant Emission Units

Red Cedar Gathering Company, Midway Compressor Station

Emission

Unit ID

TK-501

TK-502

TK-503→512

TK-513→522

TK-523→526

TK-527

TK-528→530

RB1

H-101

H-102

H-103

FUG

C10

Amount

Description

Size

Units

N/A

Tri-Ethylene Glycol (TEG) Dehydrator

MMscfd

Used Oil Tank

Dehy Still Vent Tank

Lubricating Oil Storage Tank

Used Oil Storage Tank

Ethylene Glycol (EG) Storage Tank

TEG Storage Tank

Used Oil Storage Tank

TEG Reboiler Heater

Used Oil Storage Tank Heater

Catalytic Heater

Fugitive Emissions

Ariel JGT/4 Compressor Unit – Serial Number: F-56746

400

500

0.75

0.325

0.008

0.004

N/A

bbl

gal

MMBtu/hr

N/A

e. Facility Construction and/or Permitting History

The Midway Compressor Station (previously Spring Creek Compressor Station) became a major CAA

Title V Source, as defined in 40 CFR 70.2, on February 25, 2010 when the sixth compressor engine began

operation. A Part 71 Federal Operating Permit Application was received by the U.S. Environmental

Protection Agency (EPA) on December 23, 2010. An amendment to the application was received by the

EPA on January 12, 2012. A Tribal Operating Permit Application was submitted for the facility in March

of 2013.

On May 1, 2014 Samson Resources Company (previous owner) and EPA entered into Consent

Agreement Final Order (CAFO) #CAA-08-2013-0015. The emission limits in the CAFO provided

enforceable recognition of the air-to-fuel ratio (AFR) control systems installed on each of the nine (9)

engines operating at the facility at that time. Although Midway remains a major source subject to Title V,

the enforceable emission limits in the CAFO reduce the emissions NOX emissions at the facility to

synthetic minor levels with respect to the Prevention of Significant Deterioration (PSD) permit program at

40 CFR Part 52.

On March 11, 2015, EPA issued Samson Resources Company synthetic minor new source review permit

# SMNSR-SU-000053-2013.001 to maintain, beyond the expiration date of the CAFO, Spring Creek’s

status as a synthetic minor source of NOx emissions with respect to the Prevention of Significant

Deterioration (PSD) permit program. On May 30, 2018, Red Cedar requested EPA terminate permit #

SMNSR-SU-00053-2017.002. EPA granted that request on July 25, 2018 and the permit was terminated.

On July 15, 2015, an initial Part 70 operating permit, V-SUIT-0054-2015.00, was issued to Samson

Resources Company. Two administrative permit revisions were completed to reflect change of ownership

from Samson Resources Company to Red Willow Production Company to the current owner, Red Cedar

Gathering Company. On May 13, 2019, a significant permit revision was completed to reflect the

addition of emission unit E10. A minor permit revision was completed on July 1, 2019 after a like kind

engine swing occurred on emission unit E1. Although the engine is a like kind engine, the engine’s

manufacture date made the engine subject to new requirements. An administrative permit revision was

completed on November 1, 2019 to correct emission standards. On March 2, 2021, a Part 70 renewal

permit, V-SUIT-0054-2020.00, was issued.

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 Midway Compressor Station was listed by Red Cedar in Forms “GIS”, “PTE”, and the

various forms “EMISS” of the Part 70 operating permit renewal application. Table 3 shows PTE data

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

Table 3 - Potential to Emit

Red Cedar Gathering Company, Midway Compressor Station

Regulated Air Pollutants

in tpy

Emission

Unit ID

Largest

Single HAP

(CH2O)

GHGS

(CO2e mtpy)

NOX

VOC

SO2

PM10

Lead

Total

HAPs

24.2

6.9

0.0

0.4

22.7

0.0

4.0

3.3

6,363.1

24.2

6.9

0.0

0.4

22.7

0.0

4.0

3.3

6,363.1

24.2

6.9

0.0

0.4

22.7

0.0

4.0

3.3

6,363.1

24.2

6.9

0.0

0.4

22.7

0.0

4.0

3.3

6,363.1

24.2

6.9

0.0

0.4

22.7

0.0

4.0

3.3

6,363.1

24.2

6.9

0.0

0.4

22.7

0.0

4.0

3.3

6,363.1

24.2

6.9

0.0

0.4

22.7

0.0

4.0

3.3

6,363.1

24.2

6.9

0.0

0.4

22.7

0.0

4.0

3.3

6,363.1

24.2

6.9

0.0

0.4

22.7

0.0

4.0

3.3

6,363.1

E10

Total IEUs

6.7

0.5

16.9

0.5

0.0

0.5

0.0

37.8

0.4

0.0

6.4

0.3

5.6

0.0

7,202.5

Total

225.0

79.5

0.0

4.6

242.5

0.0

42.7

35.3

71,450.9

6,980.5

2. Tribal Authority

Midway Compressor Station is located within the exterior boundaries of the Southern Ute Indian

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

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

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

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

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

manner as a state” for the purposes of issuing CAA Title V, Part 70 operating permits. The EPA

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

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

Part 1 of the Reservation Air Code. Therefore, the Southern Ute Indian Tribe is the appropriate

governmental entity to issue the Title V permit to this facility.

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

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

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

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

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

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

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

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

subparts of the new source performance standards (NSPS) and national emission standards for hazardous

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

These NSPS and NESHAP subparts generally apply to oil and gas operations within the exterior

boundaries of the Southern Ute Indian Reservation and were adopted, unchanged, into the Reservation Air

Code as Parts 2 and 3.

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

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

Managing Air Emissions From True Minor Sources In Indian Country In The Oil And Natural Gas

Production And Natural Gas Processing Segments Of The Oil And Natural Gas Sector” listed at 40 CFR

§49.101 – 105 or the “Federal Minor New Source Review Program In Indian Country” listed at 40 CFR

§49.151 – 164.

3. Applicable Requirements

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

(CFR) at Title 40. Note that this discussion does not include the full spectrum of potentially applicable

regulations and is not intended to represent official applicability determinations. These discussions are

based on the information provided by Red Cedar in its Part 70 permit renewal application and are only

intended to present the information certified to be true and accurate by the Responsible Official of this

facility.

Prevention of Significant Deterioration (PSD) - 40 CFR 52.21

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

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

existing stationary source. A new stationary source, or a modification to an existing minor stationary

source, is major if the proposed project has the potential to emit any pollutant regulated under the CAA

in amounts equal to or exceeding specified major source thresholds, which are 100 tpy for 28 listed

industrial source categories and 250 tpy for all other sources. PSD also applies to modifications at

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

levels for each pollutant are defined in the PSD regulations at 40 CFR 52.21. A modification is a

physical change or change in the method of operation.

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

this source is 250 tpy for criteria pollutants. On March 11, 2015, EPA issued Samson Resources Company

a synthetic minor new source review permit # SMNSR-SU-000053-2013.001 to create legally and

practically enforceable reductions of NOx emissions to establish Midway as a synthetic minor source of

NOx emissions with respect to PSD. The synthetic minor permit was terminated on July 25, 2019 as the

emission limits exceed the equipment’s potential. The potential to emit of regulated pollutants at this

facility are currently below the major source threshold of 250 tpy. Therefore, the requirements of PSD

do not apply at this time.

New Source Performance Standards (NSPS)

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

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

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

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

The Midway Compressor Station is subject to 40 CFR Part 60, Subpart JJJJ and Subpart OOOOa.

Therefore, the General Provisions of Part 60 apply as specified in the relevant subparts.

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

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

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

modification, or reconstruction after June 9, 1989.

According to Red Cedar, there are no steam generating units with a maximum design heat input

capacity between 10 and 100 MMBtu/hr at the Midway Compressor Station. Therefore, Subpart

Dc does not apply.

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

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

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

According to Red Cedar, there are no stationary gas turbines located at the Midway Compressor

Station. Therefore, Subpart GG does not apply.

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

which Construction, Reconstruction, or Modification Commenced After June 11, 1973, and Prior to May

19, 1978. This rule applies to storage vessels for petroleum liquids with a storage capacity greater than

40,000 gallons. 40 CFR Part 60, Subpart K does not apply to storage vessels for petroleum or condensate

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

According to Red Cedar, the Midway Compressor Station has no storage vessels that were

constructed 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

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

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

420,000 gallons used for petroleum or condensate stored, processed, or treated prior to custody transfer.

According to Red Cedar, the Midway Compressor Station has no storage vessels that were

constructed between May 18, 1978 and June 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. This rule applies to storage vessels with a capacity greater than or equal

to 75 cubic meters (~472 bbl).

According to Red Cedar, the Midway Compressor Station has no storage vessels for Volatile

Organic Liquid that were constructed after July 23, 1984, with a capacity greater than or equal to

75m3 or with a vapor pressure at or above 15kPa. Therefore, Subpart Kb does not apply to this

facility.

40 CFR Part 60, Subpart KKK: Standards of Performance for Equipment Leaks of VOC from Onshore

Natural Gas Processing Plants for which construction, reconstruction, or modification commenced after

January 20, 1984, and on or before August 23, 2011. This rule applies to compressors and other

equipment at onshore natural gas processing facilities. As defined in this subpart, a natural gas processing

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

fractionation of mixed NGLs to natural gas products, or both. NGLs are defined as the hydrocarbons,

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

According to Red Cedar, the Midway Compressor Station does not extract natural gas liquids from

field gas or fractionate mixed natural gas liquids to natural gas products, and thus does not meet

the definition of a natural gas processing plant under this subpart. Therefore, Subpart KKK does

not apply.

40 CFR Part 60, Subpart LLL: Standards of Performance for SO2 emissions from Onshore Natural Gas

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

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

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

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

recovery units are defined as process devices that recover sulfur from the acid gas (consisting of H2S and

CO2) removed by a sweetening unit.

According to Red Cedar, the Midway Compressor Station has no sweetening or sulfur recovery

units. Therefore, Subpart LLL does not apply.

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

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

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

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

manufactured on or after specified manufacture trigger dates. The manufacture trigger dates are based on

the engine type, fuel used, and maximum engine horsepower.

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

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

Red Cedar provided the following information:

Table 4 - NSPS Subpart JJJJ Applicability Determination

Red Cedar Gathering Company, Midway Compressor Station

Subpart JJJJ

Trigger Date

for

ApplicabilityManufactured

on or after

Subject to

Subpart

JJJJ?

Unit

Serial No

Unit Description

Fuel

NameplateRated

Horsepower

Commence

Construction,

Modification, or

Reconstruction

Date

WPW-02226

Caterpillar G3516LE 4SLB

Compressor Engine

Natural

Gas

1,340

5/18/2008

1/1/2008

Yes

WPW00724

Caterpillar G3516LE 4SLB

Compressor Engine

Natural

Gas

1,340

2/5/2007

1/1/2008

4EK-00507

Caterpillar G3516LE 4SLB

Compressor Engine

Natural

Gas

1,340

6/1/1995

1/1/2008

WPW00178

Caterpillar G3516LE 4SLB

Compressor Engine

Natural

Gas

1,340

5/22/2006

1/1/2008

WPW00235

Caterpillar G3516LE 4SLB

Compressor Engine

Natural

Gas

1,340

6/30/2006

1/1/2008

WPW00939

Caterpillar G3516LE 4SLB

Compressor Engine

Natural

Gas

1,340

5/31/2007

1/1/2008

WPW01778

Caterpillar G3516LE 4SLB

Compressor Engine

Natural

Gas

1,340

10/30/2007

1/1/2008

WPW01905

Caterpillar G3516LE 4SLB

Compressor Engine

Natural

Gas

1,340

12/19/2007

1/1/2008

WPW00938

Caterpillar G3516LE 4SLB

Compressor Engine

Natural

Gas

1,340

5/16/2007

1/1/2008

E10

N6W0059

Caterpillar G3516J 4SLB

Compressor Engine

Natural

Gas

1,380

3/28/2018

7/1/2007

Yes

According to Red Cedar, Emission units E2, E3, E4, E5, E6, E7, E8, and E9 are four-stroke leanburn SI-ICE with a nameplate rated hp greater than 500 but less than 1,350, manufactured prior to

the specified January 1, 2008 trigger date for this engine category, and therefore have no

applicable requirements under the subpart. Therefore, the requirements of Subpart JJJJ do not

apply to emission units E2, E3, E4, E5, E6, E7, E8, or E9.

Emission unit E1 is a four-stroke lean burn SI-ICE with a nameplate hp greater than 500 but less

than 1, 350 and was manufactured after the specified January 1, 2008 trigger date. Emission unit

E10 is a four-stroke lean burn SI-ICE with a nameplate HP greater than 500 and was manufactured

after July 1, 2007 trigger date. Therefore, the requirements of Subpart JJJJ apply to unit E1

and E10.

Should Red Cedar propose to install any replacement engine that is subject to Subpart JJJJ for

unit(s) E2, E3, E4, E5, E6, E7, E8, or E9, Red Cedar will not be allowed to use the off permit

changes provision, and will be required to submit a minor permit revision application to

incorporate Subpart JJJJ requirements into the permit.

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

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

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

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

equal to or greater than 10.7 gigajoules (10 MMBtu) per hour.

According to Red Cedar, there are no stationary gas turbines located at Midway Compressor

Station. 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. Affected facilities under this subpart include gas wells,

compressors, pneumatic controllers, storage vessels, process unit equipment, and sweetening units. The

effective date for this subpart is October 15, 2012.

According to Red Cedar, the Midway Compressor Station is not a natural gas processing plant and

does not have gas wells, storage vessels, continuous-bleed pneumatic devices, or compressors that

have been constructed, modified, or reconstructed after August 23, 2011, and on or before

September 18, 2015. Therefore, Subpart OOOO does not apply.

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

This subpart establishes emission standards and compliance schedules for the control of methane, VOC,

and SO2 emissions from affected facilities that commence construction, modification or reconstruction

after September 18, 2015. Affected facilities and equipment under this subpart include wells,

compressors, storage vessels, process unit equipment, sweetening units, pneumatic pumps and pneumatic

controllers.

According to Red Cedar, the Midway Compressor Station is not a natural gas processing plant and

does not have gas wells, storage vessels, or continuous-bleed pneumatic devices that have been

constructed, modified, or reconstructed after September 18, 2015. However, the addition of

emission unit E10 triggered requirements for that compressor (assembly of the Arial compressor

(emission unit C10) was finished on June 5, 2018)) and for the collection of fugitive emissions

components at a compressor station. Therefore, the requirements of Subpart OOOOa apply.

National Emission Standards for Hazardous Air Pollutants (NESHAP)

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

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

the CAA. The general provisions under subpart A apply to sources that are subject to the specific

subparts of Part 63.

As explained below, the Midway Compressor Station is subject to 40 CFR Part 63 Subparts HH and

ZZZZ. Therefore, the General Provisions of Part 63 apply as specified in the relevant subparts.

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, 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.

Throughput Exemption

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

through (a)(1)(iii), is less than 18,400 standard cubic meters per day are exempt from the requirements of

this subpart.

Source Aggregation

Major source, as used in this subpart, has the same meaning as in §63.2, except that:

Emissions from any oil and gas production well with its associated equipment and emissions from

any pipeline compressor station or pump station shall not be aggregated with emissions from other

similar units.

Emissions from processes, operations, or equipment that are not part of the same facility shall not

be aggregated.

For facilities that are production field facilities, only HAP emissions from glycol dehydration units

and storage vessels shall be aggregated for a major source determination.

Facility

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

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

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

limited to: well sites, satellite tank batteries, central tank batteries, a compressor station that transports

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

Production Field Facility

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

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

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

custody transfer is the inlet to the plant.

Natural Gas Processing Plant

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

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

combination of both. A treating plant or gas plant that does not engage in these activities is considered to

be a production field facility.

Major Source Determination for Production Field Facilities

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

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

to the major source thresholds.

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

aggregated.

Major Source Glycol Dehydrator Applicabilities

For facilities that are determined to be major HAP sources, each glycol dehydration unit is subject to the

glycol dehydration unit process vent standards of 40 CFR 63.765 for small or large dehydration units,

defined, as follows, in 40 CFR 63.760:

Small Glycol Dehydration Unit: a glycol dehydration unit, located at a major source of HAP, with an

actual annual average natural gas flowrate less than 85 thousand standard cubic meters per day or actual

annual average benzene emissions less than 0.90 Mg/yr, determined according to §63.772(b).

Large Glycol Dehydration Unit: a glycol dehydration unit, located at a major source of HAP, with an

actual annual average natural gas flowrate equal to or greater than 85 thousand standard cubic meters per

day and actual annual average benzene emissions equal to or greater than 0.90 Mg/yr, determined

according to §63.772(b). A glycol dehydration unit complying with the 0.9 Mg/yr control option under

§63.765(b)(1)(ii) is considered to be a large dehydrator.

Area Source Applicability

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

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

This subpart requires different emission reduction requirements for glycol dehydration units found at oil

and gas production facilities based on their geographical location.

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

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

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

pump rate optimized or operators must document that uncontrolled annual actual benzene emissions are

less than 0.9 megagrams (1,984 lbs.).

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

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

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

year thereafter, using gas composition data measured during the preceding 12 months.

Applicability of Subpart HH to the Midway Compressor Station

According to Red Cedar, the Midway Compressor Station total HAP emissions from glycol

dehydrators and storage vessels are below major source thresholds. Furthermore, with respect to

area source requirements, uncontrolled actual annual average benzene emissions from the TEG

dehydration units at the facility are less than 0.9 megagrams. Per 40 CFR 63.764(e)(1)(ii),

dehydration unit D10 is exempt from the 40 CFR 63.764(d) general requirements for area sources.

Therefore, Red Cedar must maintain records as specified in 63.774(d)(1).

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

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

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

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

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

According to Red Cedar, the Midway Compressor Station is not part of the natural gas

transmission and storage source category. 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) at

major and area sources of HAPs.

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

Summary of Applicability to Engines at Major HAP Sources

Major HAP Sources

Engine Type

Horse Power Rating

New / Existing

Applicability Trigger Date

SI ICE – All1

≥ 500 HP

New

On or After:

12/19/2002

SI ICE – 4SRB

> 500 HP

Existing

Before:

12/19/2002

SI ICE – All1

≤ 500 HP

New

On or After:

6/12/2006

SI ICE – All

≤ 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 – All

≤ 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

Applicability of 40 CFR 63, Subpart ZZZZ to the Midway Compressor Station:

Fuel

Site Rated

Commenced

Construction or

Reconstruction Date

Subject to

Subpart

ZZZZ?

Caterpillar G3516LE 4SLB

Compressor Engine

Natural

Gas

1,251

5/18/2008

Yes

Caterpillar G3516LE 4SLB

Compressor Engine

Caterpillar G3516LE 4SLB

Compressor Engine

Caterpillar G3516LE 4SLB

Compressor Engine

Caterpillar G3516LE 4SLB

Compressor Engine

Caterpillar G3516LE 4SLB

Compressor Engine

Caterpillar G3516LE 4SLB

Compressor Engine

Caterpillar G3516LE 4SLB

Compressor Engine

Caterpillar G3516LE 4SLB

Compressor Engine

Natural

Gas

Natural

Gas

Natural

Gas

Natural

Gas

Natural

Gas

Natural

Gas

Natural

Gas

Natural

Gas

1,251

2/5/2007

Yes

1,251

6/1/1995

1,251

5/22/2006

Yes

1,251

6/30/2006

Yes

1,251

5/31/2007

Yes

1,251

10/30/2007

Yes

1,251

12/19/2007

Yes

1,251

5/16/2007

Yes

Caterpillar G3516J 4SLB

Compressor Engine

Natural

Gas

1,380

3/28/2018

Yes

Unit

Serial

Number

Unit Description

WPW-02226

WPW00724

4EK-00507

WPW00178

WPW00235

WPW00939

WPW01778

WPW01905

WPW00938

E10

N6W0059

According to Red Cedar, Midway is a major source as defined in §63.6675 of Subpart ZZZZ.

Unit E3 is a four-stroke lean-burn (4SLB) stationary RICE >500 site-rated hp that commenced

construction before December 19, 2002 and is therefore considered an existing 4SLB stationary

RICE. In accordance with §63.6590(b)(3)(ii), existing 4SLB stationary RICE with a site rating of

more than 500 brake hp located at a major source of HAP do not have to meet the requirements of

this subpart and of subpart A of part 63. Units E1, E2, and E4 through E10 are four-stroke leanburn (4SLB) stationary RICE > 500 site-rated hp that commenced constructed after December 19,

2002. As a result of this construction date, the units are considered new 4SLB stationary RICE.

Therefore, Units E1, E2, E4, E5, E6, E7, E8, E9, and E10 are subject to the requirements for

new non-emergency 4SLB SI RICE >500 hp located at a major source of HAPs.

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

Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and

Process Heaters. This rule establishes national emission limitations and operating limitations for HAPs

emitted from new and existing industrial boilers, institutional boilers, commercial boilers, and process

heaters that are located at major sources of HAPs. Boilers or process heaters that combust natural gas for

fuel or have a maximum designed heat input capacity less than 10 MMBtu/hr are subject to work practice

standards in lieu of emission limits. For the purposes of this subpart, an affected unit is an existing unit if

it was constructed prior to June 4, 2010.

According to Red Cedar, the Midway Compressor Station has no industrial, commercial, or

institutional boilers as defined in this subpart. 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 by 40 CFR 63.11237, and are located at area

sources of HAPs, as defined by 40 CFR 63.2, except as specified in 40 CFR 63.11195. For the purposes

of this subpart, an affected unit is an existing unit if it was constructed prior to June 4, 2010.

According to Red Cedar, there are no industrial, institutional, or commercial boilers at Midway

Compressor Station. Therefore, Subpart JJJJJJ does not apply.

Compliance Assurance Monitoring (CAM) Rule

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

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

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

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

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

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

apply to any of the following emission limitations or standards:

(i)

(ii)

(iii)

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;

(iv)

(v)

(vi)

Emissions limitations or standards or other applicable requirements that apply solely

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

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

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

of this chapter;

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

compliance determination method, as defined in §64.1.”

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

an applicable permit condition, which:

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

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

and

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

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

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

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

source.

According to Red Cedar, the Midway Compressor Station has no units with potential emissions

equal to or greater than the major source thresholds for an applicable regulated pollutant.

Therefore, CAM does not apply.

Chemical Accident Prevention Program

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

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

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

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

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

presented under §68.115. §68.115(b)(l) and (2)(i) indicate that toxic and flammable substances in a

mixture do not need to be considered when determining whether more than a threshold quantity is present

at a stationary source if the concentration of the substance is below one percent by weight of the mixture.

§68.115(b)(2)(iii) indicates that prior to entry into a natural gas processing plant, regulated substances in

naturally occurring hydrocarbon mixtures need not be considered when determining whether more than a

threshold quantity is present at a stationary source. Naturally occurring hydrocarbon mixtures include

condensate, field gas, and produced water.

According to Red Cedar, the Midway Compressor Station does not have regulated substances

above the threshold quantities in this rule. Therefore, the facility is not subject to the

requirement to develop and submit a risk management plan.

Stratospheric Ozone and Climate Protection

40 CFR Part 82, Subpart F: Air Conditioning Units. According to Red Cedar, no maintenance, service,

repair or disposal of any equipment containing Class I or Class II refrigerants chlorofluorocarbons

(CFCs)) occurs at Midway Compressor Station. However, if Red Cedar were to engage in any of the afore

mentioned activities 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 Red Cedar, there are no halon fire

extinguishers at Midway Compressor Station. However, should Red Cedar obtain any halon fire

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

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

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

Part 82 and submit an application for a modification to this Title V permit.

Mandatory Greenhouse Gas Reporting

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

emission thresholds to calculate, monitor, and report greenhouse gas emissions. The requirements of 40

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

however, need not be included in a tribal-issued part 70 permit because those requirements are not

included in the definition of “applicable requirement” in either 40 CFR part 70 or RAC 1-103(11).

Although the rule is not an applicable requirement under 40 CFR Part 70 or the RAC, the source is not

relieved from the requirement to comply with the rule separately from compliance with its Part 70

operating permit. It is the responsibility of each source to determine whether Part 98 is applicable and to

comply, if necessary.

4. Public Participation

a. Public Notice

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

public comment.

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

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

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

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

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

your name and address:

by United State Postal Service to:

by any other delivery service to:

Part 70 Permitting Contact

Southern Ute Indian Tribe

Environmental Programs Division

Part 70 Program

PO Box 737 MS #84

Ignacio, Colorado 81137

Part 70 Permitting Contact

Southern Ute Indian Tribe

Environmental Programs Division

Part 70 Program

398 Ouray Drive

Ignacio, Colorado 81137

Public notice for the draft permit was published in the Durango Herald on November 4, 2020 and in the

Southern Ute Drum on November 6, 2020 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 Program webpage at

www.southernute-nsn.gov/environmental-programs/air-quality/air-permitting/, and at:

Southern Ute Indian Tribe

Environmental Programs Division

Air Quality Program

71 Mike Frost Way

Ignacio, Colorado 81137

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

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

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

operating permit during the public comment period. The Tribe has considered and addressed comments

in making a final decision on the permit. The Tribe keeps a record of the commenters and of the issues

raised during the public participation process.

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

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

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

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

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

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

available reference material.

c. Opportunity to Request a Hearing

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

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

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

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

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

the draft permit.

d. Public Petitions to the Administrator

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

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

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

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

be based only on objections to the permit that were raised with reasonable specificity during the public

comment period unless the petitioner demonstrates that it was impracticable to raise such objections

within such period, or unless the grounds for such objections arose after such period. If the administrator

objects to a permit as a result of this petition, the Tribe shall not issue the permit until the Administrator’s

objection has been resolved, except that a petition for review does not stay the effectiveness of a permit or

its requirements if the permit was issued after the end of the 45-day review period and before the

Administrator’s objection.

e. Appeal of Permits

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

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

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

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

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

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

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

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

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

f. Notice to Affected States/Tribes

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

The following entities will be notified:

•

State of Colorado, Department of Public Health and Environment

State of New Mexico, Environment Department

Ute Mountain Ute Tribe, Environmental Programs Department

Navajo Tribe, Navajo Nation EPA

Jicarilla Tribe, Environmental Protection Office

National Park Service, Air Resources Division, Denver, CO

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

Region

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