Air Pollution Control (2020)

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Air Pollution Control

Title V Permit to Operate

Statement of Basis for Permit No. V-SUIT-0031-2020.00

June 14, 2021

Red Cedar Gathering Company

South Ignacio Central Delivery Point

Southern Ute Indian Reservation

La Plata County, Colorado

1. Facility Information

a. Location

The South Ignacio Central Delivery Point, 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 32, T33N R7W, in La Plata County, at latitude North 37.053917 and longitude West 107.625222. The mailing address is:

Red Cedar Gathering Company

South Ignacio Central Delivery Point

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 South Ignacio Central Delivery Point (South Ignacio) is owned and operated by Red Cedar Gathering

Company. The facility is located within the exterior boundaries of the Southern Ute Indian Reservation in

Section 32, Township 33, Range 7 West in La Plata County, Colorado.

The facility is comprised of equipment that dehydrates and compresses coal-bed methane gas from several

wells to transmission pipeline specifications. Gas entering the facility from the field is first fed to an inlet

separator that gravimetrically removes water that may have formed/condensed during transportation from

the supplying gas wells. Separator overhead gas is fed to one of the eight compressor engines from a

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

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

compressed gas is then fed to two dehydration units. Tri-ethylene glycol is circulated counter-currently

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

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

where it is metered and exits the facility. The gas processing capacity of the facility is approximately 70

MMscfd with eight compressor engines operating.

Process equipment installed at the facility consists of eight natural gas-fired reciprocating engines, two

triethylene glycol dehydration units equipped with reboiler burners. There are several insignificant

emission units at this facility including various storage tanks and heaters.

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.

Emission

Unit ID

Table 1 – Emission Units

Red Cedar Gathering Company, South Ignacio Central Delivery Point

Control

Equipment

Description

Waukesha L7044GSI (4SRB SI) Natural Gas-Fired Compressor Engine

1,680 Nameplate Rated HP

Serial No.

C-62071/1

Install Date:

7/14/2020

NSCR Catalyst

and AFRC

Waukesha L7042GL (4SLB SI) Natural Gas-Fired Compressor Engine

1,480 Nameplate Rated HP

Serial No.

C-12215/4

Install Date:

8/15/2018

Serial No.

403301

Install Date:

10/8/2008

Serial No.

C-12097/1

Install Date:

3/10/2008

AFRC

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

1,447 Nameplate Rated HP

Serial No.

C-15962/1

Install Date:

5/6/2019

Serial No.

C-16161/1

Install Date:

9/15/2016

Serial No.

C-15838/1

Install Date:

3/21/2018

Serial No.

C-15963/1

Install Date:

4/22/2020

Oxidation

Catalyst and

AFRC

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, South Ignacio Central Delivery Point

Emission Unit ID

Amount

Description

Size

Units

TK-501 → 502

TK-503

TK-504 → 511

TK-512 → 519

TK-520

TK-521 → 522

RB1

RB2

H-101 → 102

H-103

FUG

N/A

TEG Dehydrator

Used Oil Tanks

Dehydrator Still Vent Drain Tank

Lube Oil Storage Tanks

Used Oil Storage Tanks

Ethylene Glycol Storage Tank

TEG Storage Tanks

TEG Dehydrator Reboiler Heater (D1)

TEG Dehydrator Reboiler Heater (D2)

Used Oil Storage Tank Heaters

Catalytic Heater

Fugitive Emissions

500

1.75

0.75

0.325

0.008

N/A

MMscfd

bbl

gal

MMBtu/hr

N/A

e. Facility Construction and/or Permitting History

South Ignacio Central Delivery Point received its initial part 71 permit, #V-SU-0031-01.00, in April of

2004. This permit contained a federally enforceable 9.5 tpy facility-wide formaldehyde emissions cap to

prevent the source from triggering the major source requirements of the RICE MACT at 40 CFR Part 63,

Subpart ZZZZ, effective on August 16, 2004. In November 2005, the permit was modified to add three

new lean-burn compressor engines with oxidation catalysts under the existing formaldehyde cap. The

permit was modified again in July 2008 to authorize the installation of a new 40 MMscf/day dehydration

unit (emission unit D2) and create an enforceable benzene emission limit of 0.9 tpy benzene for each

dehydration unit (emission units D1 and D2), and a facility-wide HAP emission limit of 23 tpy, in order

for the facility to avoid triggering the area source MACT HH requirement for glycol dehydrators emitting

more than 1 tpy of benzene effective January 5, 2009, or triggering any major source MACT requirements

for the dehydrators or engines. All Part 71 established synthetic minor emission limits were created prior

to the trigger dates for MACT standards or the triggering of major NSR modification thresholds. On

August 10, 2009, EPA issued the first renewal permit for the facility (V-SU-0031-08.00).

In 2011 Samson Resources Company (the previous owner) submitted a synthetic minor permit application

for the facility under the Federal Minor New Source Review Program in Indian Country (76 FR 38748),

to transfer the enforceable emissions limitations established under the part 71 permit #V-SU-0031-08.00

to a minor new source review permit. On January 9, 2015 EPA issued the facility synthetic minor new

source review permit #SMNSR-SU-000031-2011.001. This permit did not authorize the construction of

any new emission sources or authorize any physical modifications to the facility or its operations. The

permit was revised three times and the current permit number is #SMNSR-SU-000031-2019.004

The site’s part 71 permit expired upon issuance of the initial Part 70 permit (V-SUIT-0031-2014.00). The

Part 70 permit had two administrative permit revisions on January 9, 2017 and December 19, 2017

respectively, for a transfer of ownership from Samson Resources Company to Red Willow Production

Company and then from Red Willow Production Company to Red Cedar Gathering Company. A Part 70

renewal permit, V-SUIT-0031-2020.00, was issued on June 14, 2021.

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 South Ignacio Delivery Point was listed by Red Cedar in Forms “GIS”, “PTE”, and the

various forms “EMISS” of the Part 70 operating permit renewal application and additional information.

Table 3 shows PTE data broken down by each individual emission unit, as well as the total facility-wide

PTE.

Emission

Unit ID

Table 3 - Potential to Emit

Red Cedar Gathering Company, South Ignacio Central Delivery Point

Regulated Air Pollutants

(tons per year)

Largest

Single

HAP

(CH2O)

NOX

VOC

SO2

PM10

Lead

Total

HAPs

40.3

5.8

0.0

1.1

56.5

0.0

1.9

1.2

9,225.0

19.4

12.9

0.0

0.4

34.9

0.0

3.1

2.2

7,772.2

19.4

12.9

0.0

0.4

34.9

0.0

3.1

2.2

7,772.2

19.4

12.9

0.0

0.4

34.9

0.0

3.1

2.2

7,772.2

28.1

2.3

0.0

0.5

24.9

0.0

3.3

2.5

8,497.6

28.1

2.3

0.0

0.5

24.9

0.0

3.3

2.5

8,497.6

28.1

2.3

0.0

0.5

24.9

0.0

3.3

2.5

8,497.6

28.1

2.3

0.0

0.5

24.9

0.0

3.3

2.5

8,497.6

IEUs

1.5

2.5

0.0

0.1

1.3

0.0

0.9

0.0

7,370.1

TOTAL

212.4

56.2

0.0

4.4

262.1

0.0

25.3

17.8

73,902.1

GHGs

(CO2e tpy)

2. Tribal Authority

South Ignacio Central Delivery Point 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.

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.

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

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

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

38748). The TMNSR rule applies to all new or modified industrial facilities in Indian country with a

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

thresholds, which are generally 100 to 250 tons per year (tpy). The minor NSR thresholds for

attainment/unclassifiable areas are displayed in the table below:

40 CFR 49.153 Minor NSR Thresholds

Regulated NSR Pollutant

Carbon Monoxide (CO)

Nitrogen Oxides (NOx)

Sulfur Dioxide (SO2)

Volatile Organic Compounds (VOC)

PM10

PM2.5

Lead

Fluorides

Sulfuric Acid Mist

Hydrogen Sulfide (H2S)

Total Reduced Sulfur (including H2S)

Reduced Sulfur Compounds (including H2S)

Municipal Waste Combustor Emissions

Municipal Solid Waste Landfill Emissions (measured as

nonmethane organic compounds)

Minor NSR Thresholds for Attainment/Unclassifiable

Areas in Tons Per Year (TPY)

0.1

Starting August 30, 2011 all minor modifications at existing major NSR sources, requests for synthetic

minor limitations, and the transferring of synthetic minor limits from Part 71 permits into minor NSR

permits became subject to the TMNSR rule. All existing true minor sources were required to register

with EPA by no later than March 1, 2013. All new minor sources constructed between August 30, 2011

and September 2, 2014 were required to submit a registration form within 90 days of beginning operation

and obtain a permit only if a general permit is available for that source category. All new true minor

sources not in the oil and natural gas sector, which intend to construct after September 2, 2014, are

required to apply for a preconstruction permit. After March 2, 2016, all minor modifications at major

sources and true minor sources in the oil and natural gas sector that intend to construct have to apply for

a preconstruction permit.

EPA issued South Ignacio Central Delivery Point synthetic minor new source review permit

#SMNSR-SU-000031-2011.001 to transfer legally and practically enforceable emission limits

previously established in the EPA-issued Part 71 permit. The permit was revised three times, and

the current permit number is #SMNSR-SU-000031-2019.004. The requirements of the new

source review permit have been incorporated into the Part 70 operating permit.

Prevention of Significant Deterioration (PSD) - 40 CFR 52.21

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

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

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

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

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

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

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

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

physical change or change in the method of operation.

South Ignacio Central Delivery Point does not belong to any of the 28 listed industrial source categories.

Therefore, the PTE threshold for determining PSD applicability for this source is 250 tpy for criteria

pollutants and 100,000 tpy for CO2e. According to Red Cedar, South Ignacio Central Delivery Point is a

synthetic minor source with respect to PSD for NOx and is a major source of CO. Therefore, this site is

subject to 40 CFR Part 52.

New Source Performance Standards (NSPS)

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

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

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

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

As explained below, the South Ignacio Central Delivery Point is not subject to any subparts of 40

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

40 CFR Part 60, Subpart Dc: Standards of Performance for Small Industrial-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, the South Ignacio Central Delivery Point has no steam generating units

with a maximum design heat input capacity of 100 MMBtu/hr or less, but greater than or equal to

10 MMBtu/hr at the facility. 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 South Ignacio Central

Delivery Point. 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, South Ignacio Central Delivery Point has no storage vessels for

petroleum liquids for which construction, reconstruction, or modification occurred after June 11,

1973 and prior to May 19, 1978. Therefore, Subpart K does not apply.

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

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

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

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

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

According to Red Cedar, there are no storage tanks for petroleum liquids at South Ignacio Central

Delivery Point which were constructed between May 18, 1978 and July 23, 1984. Therefore,

Subpart Ka does not apply.

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

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

Commenced After July 23, 1984. This rule applies to storage vessels with a capacity greater than or equal

to 75 cubic meters (472bbl, or 19,813 gal). The subpart does not apply to storage vessels with a capacity

greater than or equal to 151 cubic meters storing a liquid with a maximum true vapor pressure less than

3.5 kPa or with a capacity greater than or equal to 75 cubic meters but less than 151 cubic meters storing a

liquid with a maximum true vapor pressure less than 15.0 kPa.

According to Red Cedar, South Ignacio Central Delivery Point has no storage vessels for volatile

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

75 m3 (~19,800 GAL) or with a vapor pressure at or above 15 kPa. Therefore, Subpart Kb does

not apply.

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

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

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

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

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

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

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

According to Red Cedar, the South Ignacio Central Delivery Point does not extract natural gas

liquids from field gas or fractionate mixed natural gas liquids to natural gas products. 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 South Ignacio Central Delivery Point has no sweetening or sulfur

recovery units. Therefore, Subpart LLL does not apply.

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

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

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

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

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

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

not fire pump engines.

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

engines (ICE) located at South Ignacio Central Delivery Point. Therefore, Subpart IIII does not

apply.

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

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

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

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

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

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

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

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

NSPS Subpart JJJJ Applicability Determination

Red Cedar Gathering Company, South Ignacio Central Delivery Point

Unit

Serial No.

C-62071/1

C-12215/4

403301

C-12097/1

C-15962/1

C-16161/1

C-15838/1

C-15963/1

Unit Description

Waukesha L7044GSI SI

4SRB Compressor

Engine

Waukesha L7042GL SI

4SLB Compressor

Engine

Waukesha L7042GL SI

4SLB Compressor

Engine

Waukesha L7042GL SI

4SLB Compressor

Engine

Waukesha L5794LT SI

4SLB Compressor

Engine

Waukesha L5794LT SI

4SLB Compressor

Engine

Waukesha L5794LT SI

4SLB Compressor

Engine

Waukesha L5794LT SI

4SLB Compressor

Engine

Subject

NSPS

Subpart

JJJJ

Fuel

Maximum

Commence

Construction

Manufacture

Date

Trigger Date for

ApplicabilityManufactured

on or after

Natural

Gas

1,680

Prior to

6/12/2006

8/22/2005

7/1/2007

Natural

Gas

1,480

Prior to

6/12/2006

10/21/1996

7/1/2007

Natural

Gas

1,480

Prior to

6/12/2006

4/1/1991

7/1/2007

Natural

Gas

1,480

Prior to

6/12/2006

7/1/1996

7/1/2007

Natural

Gas

1,447

Prior to

6/12/2006

2/1/2006

7/1/2007

Natural

Gas

1,447

Prior to

6/12/2006

11/1/2005

7/1/2007

Natural

Gas

1,447

Prior to

6/12/2006

9/12/2005

7/1/2007

Natural

Gas

1,447

Prior to

6/12/2006

2/28/2006

7/1/2007

According to Red Cedar, South Ignacio Central Delivery Point is potentially subject to this subpart

as all engines at the site are stationary spark ignition internal combustion engines. However, Units

E1, E2, E3, E4, E5, E6, E7, and E8 were manufactured prior to July 1, 2007 (the trigger date for

engines with a maximum design horsepower ≥ 500). Therefore, Subpart JJJJ does not apply.

Should Red Cedar propose to install a replacement engine which is subject to Subpart JJJJ, 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 the South Ignacio Central

Delivery Point. 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.

According to Red Cedar, South Ignacio Central Delivery Point is not a natural gas processing

plant and does not include 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 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, South Ignacio Central Delivery Point is not a natural gas processing

plant and does not include gas wells, storage vessels, continuous bleed pneumatic devices, or

compressors that have been constructed, modified, or reconstructed after September 18, 2015.

Therefore, Subpart OOOOa does not apply.

National Emission Standards for Hazardous Air Pollutants (NESHAP)

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

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

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

subparts of Part 63.

As explained below, the South Ignacio Central Delivery Point 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, 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 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 South Ignacio Central Delivery Point

According to Red Cedar, the South Ignacio Central Delivery Point has affected sources under this

subpart, upgrades natural gas, is not located in an urbanized area or urban cluster, and is located

prior to the point of custody transfer (and therefore prior to the point at which natural gas leaves

the natural gas processing category and enters the natural gas transmission and storage category).

Because the facility is in the natural gas production category, only emissions from dehydration

units and storage vessels need to be aggregated when determining major source status.

Red Cedar determined that actual average benzene emissions from the TEG dehydration units at

the facility are less than 0.90 megagrams per year. Per 40 CFR 63.764(e)(1)(ii), South Ignacio is

exempt from the general standards of 40 CFR 63.764(d). Therefore, only the recordkeeping

requirements of 40 CFR 63.774(d)(1) apply to the facility.

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 South Ignacio Central Delivery Point is not a natural gas

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

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

Pollutants for Stationary Reciprocating Internal Combustion Engines. This rule establishes national

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

combustion engines (SI ICE) and stationary compression ignition internal combustion engines (CI ICE).

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

Summary of Applicability to Engines at Area Hap Sources

Area HAP Sources

Engine Type

Horse Power Rating

New / Existing

Applicability Trigger Date

SI ICE – All1

All HP

New

On or After:

6/12/2006

SI ICE – All

All HP

Existing

Before:

6/12/2006

CI ICE – All2

All HP

New

On or After:

6/12/2006

CI ICE – All

All HP

Existing

Before:

6/12/2006

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

2. All includes emergency ICE and limited use ICE

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 – All2

≤ 500 hp

New

On or After:

6/12/2006

CI ICE – All2

≤ 500 hp

Existing

Before:

6/12/2006

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

2. All includes emergency ICE and limited use ICE

Applicability of 40 CFR Part 63, Subpart ZZZZ to the South Ignacio Central Delivery Point

Unit

Serial

Number

C-62071/1

C-12215/4

403301

C-12097/1

C-15962/1

C-16161/1

C-15838/1

C-15963/1

Unit Description

Waukesha L7044GSI SI

4SRB Compressor Engine

Waukesha L7042GL SI

4SLB Compressor Engine

Waukesha L7042GL SI

4SLB Compressor Engine

Waukesha L7042GL SI

4SLB Compressor Engine

Waukesha L5794LT SI

4SLB Compressor Engine

Waukesha L5794LT SI

4SLB Compressor Engine

Waukesha L5794LT SI

4SLB Compressor Engine

Waukesha L5794LT SI

4SLB Compressor Engine

Fuel

Site Rated

Commenced

Construction or

Reconstruction Date

Subject to Major

Source Standards for

RICE

Natural Gas

1680

8/22/2005

Yes

Natural Gas

1337

10/21/1996

Natural Gas

1337

4/1/1991

Natural Gas

1337

7/1/1996

Natural Gas

1401

2/1/2006

Yes

Natural Gas

1401

11/1/2005

Yes

Natural Gas

1401

9/12/2005

Yes

Natural Gas

1401

2/28/2006

Yes

The South Ignacio Central Delivery Point is a major source of HAP. Unit E1 is a four-stroke richburn (4SRB) stationary RICE >500 hp constructed after December 19, 2002 and is subject to the

ZZZZ major source requirements. Units E2, E3, and E4 are four-stroke lean burn (4SLB)

stationary RICE > 500 hp constructed prior to December 19, 2002. In accordance with

§63.6590(b)(3)(ii), units E2, E3, and E4 are not subject to ZZZZ or 40 CFR Part 63, Subpart A.

Units E5, E6, E7, and E8 are 4SLB stationary RICE >500 hp constructed after December 19, 2002

and are subject to ZZZZ major source requirements. Therefore, Subpart ZZZZ applies.

40 CFR Part 63, Subpart DDDDD: National Emission Standards for Hazardous Air Pollutants for Major

Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters. This rule establishes

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

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

sources of HAPs, as defined by 40 CFR 63.7575. 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, there are no industrial, institutional, or commercial boilers at South

Ignacio Central Delivery Point. 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 South

Ignacio Central Delivery Point. 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)

(iv)

(v)

(vi)

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

pursuant to Section 111 or 112 of the Act;

Stratospheric ozone protection requirements under Title VI of the Act;

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

410 of the Act;

Emissions limitations or standards or other applicable requirements that apply solely

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

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

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

of this chapter;

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

compliance determination method, as defined in §64.1.”

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

an applicable permit condition, which:

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

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

and

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

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

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

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

source.

According to Red Cedar, there are no emission units at the facility with pre-control device

emissions of a regulated pollutant greater than the major source threshold. 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, South Ignacio Central Delivery Point has no substance listed by this

regulation that is stored on-site in quantities above the applicable threshold values set forth by the

regulation. 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, the facility does not

engage in the distribution or sale of controlled substances, and it does not produce, transform, destroy,

import, or export products containing controlled substances. If Red Cedar were to engage in any of the

aforementioned activities, it must comply with the standards of part 82, Subpart F for recycling and

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

of the units.

40 CFR Part 82, Subpart H: Halon Fire Extinguishers. According to Red Cedar, there are no halon fire

extinguishers at South Ignacio Central Delivery Point. 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 revision to this Title V permit.

Mandatory Greenhouse Gas Reporting

40 CFR Part 98: This rule requires sources above certain emission thresholds to calculate, monitor, and

report greenhouse gas emissions. The requirements of 40 CFR Part 98 and CAA §307(d)(1)(V), the CAA

authority under which 40 CFR Part 98 was promulgated, however, need not be included in a 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:

Southern Ute Indian Tribe

Environmental Programs Division

Part 70 Program

PO Box 737 MS #84

Ignacio, Colorado 81137

by any other delivery service to:

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 March 10, 2021 and the

Southern Ute Drum on March 12, 2021 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 available on the Southern Ute Air Quality Program webpage at

https://www.southernute-nsn.gov/justice-and-regulatory/epd/public-comments/, 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.

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.