### United States Environmental Protection Agency
Region 8

Air Program

1595 Wynkoop Street
Denver, Colorado 80202

AIR POLLUTION CONTROL

TITLE V PERMIT TO OPERATE

In accordance with the provisions of title V of the Clean Air Act and 40 CFR Part 71 and applicable

rules and regulations,

Public Service Company of Colorado Tiffany Compressor Station

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

accordance with the pennit conditions listed in this pennit.

This source is authorized to operate at the following location:

Section 3, Township 32N, Range 6W

on the Southern Ute Indian Reservation

Tenns not otherwise defined in this penn it have the meaning assigned to them in the referenced regulations. All tenns and conditions of the pennit are enforceable by EPA and citizens under the Clean

Air Act.

Deborah Lebow Aal, Acting Director

Air Program

US EPA Region 8

### PAGE LEFT INTENTIONALLY BLANKAIR POLLUTION CONTROL

TITLE V PERMIT TO OPERATE Public Service Company of Colorado Tiffany Compressor Station

Permit Number: V-SU-00023-2010.00 Issue Date: Ma y 9, 2011 Replaces Permit No.: V-SU-0023-05.02 Effective Dat e: May 18, 2011 Expiration Date: May 18, 2016

The permit number cited above should be referenced in future correspondence regarding this facility.

Permit Action History

DATE OF

ACTION TYPE OF

ACTION SECTION

NUMBER, DESCRIPTION OF ACTION

November 2000 Initial Permit Issued Permit #V-SU-0 023-00.00

December 2005 1 st Renewal Permit

Issued Permit #V-SU-0023-05.00 (two modifications) Permit #V-SU-0023-05.01 (minor modification) Permit #V-SU-0023-05.02 (administrative amendm ent)
May 2011 2 nd Renewal Permit

Issued Permit #V-SU-00023-2010.00i TABLE OF CONTENTS

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

................................................... ....................................... ii

LIST OF TABLES ....................................

................................................... ........................................... iii

I. Source Information and Emission Unit Identifica tion .............................................. ....................... 1

A. General Source Information ....................

................................................... ................................... 1

B. Source Emission Points ........................

................................................... ....................................... 2

II. Facility-Wide Requirements ...................

................................................... ........................................ 4 A. General Recordkeeping Requirements ............

................................................... .......................... 4 B. Alternative Operating Scenarios ...............

................................................... ................................. 4 C. Stratospheric Ozone and Climate Protection ....

................................................... ....................... 5

D. Permit Shield .................................

................................................... ............................................... 5

III. Part 71 Administrative Requirements .........

................................................... ................................ 6 A. Annual Fee Payment ............................

................................................... ....................................... 6 B. Annual Emissions Inventory.....................

................................................... .................................. 8 C. Compliance Requirements .......................

................................................... ................................... 9 D. Duty to Provide and Supplement Information ....

................................................... ................... 10

E. Submissions ...................................

................................................... ............................................. 11 F. Severability Clause............................

................................................... ......................................... 11

G. Permit Actions ................................

................................................... ........................................... 11

H. Administrative Permit Amendments ..............

................................................... ......................... 11

I. Minor Permit Modifications ....................

................................................... .................................. 12 J. Group Processing of Minor Permit Modifications

................................................... .................. 14 K. Significant Permit Modifications ..............

................................................... ............................... 15 L. Reopening for Cause ...........................

................................................... ...................................... 15 M. Property Rights ...............................

................................................... .......................................... 16 N. Inspection and Entry ..........................

................................................... ....................................... 16 O. Emergency Provisions ..........................

................................................... ..................................... 16 P. Transfer of Ownership or Operation ............

................................................... ........................... 17 Q. Off Permit Changes ............................

................................................... ....................................... 17 R. Permit Expiration and Renewal .................

................................................... .............................. 20

IV. Appendices to the Part 71 Permit ..............

................................................... .................................. 21 A. Inspection Information ........................

................................................... ..................................... 21ii

Abbreviations and Acronyms

AR Acid Rain ARP Acid Rain Program

bbls Barrels BACT Best Available Control Technology CAA Clean Air Act [42 U.S.C. Section 7401 et seq.] CAM Compliance Assurance Monitoring CEMS Continuous Emission Monitoring System CFR Code of Federal Regulations

CH 2 O Formaldehyde CMS Continuous Monitoring System (includes COMS, C EMS, and diluents monitoring) COMS Continuous Opacity Monitoring System

CO Carbon monoxide

CO 2 Carbon dioxide DAHS Data Acquisition and Handling System dscf Dry standard cubic foot dscm Dry standard cubic meter EIP Economic Incentives Programs EPA Environmental Protection Agency FGD Flue gas desulfurization gal gallon GPM Gallons per minute

H 2 S Hydrogen Sulfide

HAP Hazardous Air Pollutant

hr hour

Id. Identification number kg kilogram lb pound MACT Maximum Achievable Control Technology

MVAC Motor Vehicle Air Conditioner Mg Megagram

MMBtu Million British Thermal Units

mo Month

NESHAP National Emission Standards for Hazardous A ir Pollutants NMHC Non-methane hydrocarbons

NO

x Nitrogen oxides

NSPS New Source Performance Standard

NSR New Source Review pH Negative logarithm of effective hydrogen ion co ncentration (acidity)

PM Particulate Matter

PM 10 Particulate Matter less than 10 microns in diamet er ppm Parts per million PSD Prevention of Significant Deterioration

PTE Potential to emit psi Pounds per square inch psia pounds per square inch absolute RICE Reciprocating internal combustion engine RMP Risk Management Plan scfm Standard cubic feet per minute SNAP Significant New Alternatives Program

SO 2 Sulfur Dioxide tpy Tons per year US EPA United States Environmental Protection Agen cy VOC Volatile Organic Compoundsiii 

### LIST OF TABLES

Table 1. Emission Units................................................................................. ......2 Table 2. Insignificant Emission Units .................................... ...................................31



### I. Source Information and Emission Unit Identifica tion

I.A. General Source Information

Parent Company Name: Public Service Company of Colorado

Plant Name: Tiffany Compressor Station

Plant Location: Section 4, T32N, R6W 1213 County Road 330, Ignacio, Colorado

Region: 8

State: Colorado

County: La Plata

Reservation: Southern Ute Indian Reservation

Tribe: Southern Ute Indian Tribe

Responsible Official: Vice President System Design, Operation, and Main tenance

SIC Code: 4922

AFS Plant Identification Number: 08-067-00158

Other Clean Air Act Permits: There are no other Federal CAA permits, such as m inor NSR or PSD issued to this facility.2

Description of Process:

The Tiffany Compressor Station conditions natural g as to pipeline quality for delivery to PSCo customers. The facility compresses natural gas usi ng three compression engines and removes water from the gas stream (dehydration) with three trieth ylene glycol (TEG) dehydrators. The natural gas is then odorized and delivered into a PSCo pipeline th at provides natural gas to Pagosa Springs, the San Luis Valley, and other PSCo mountain customers. Th is source is classified as a natural gas transmissi on facility defined under Standard Industrial Classifi cation 4922. The facility does not extract natural gas liquids (NGLs) from field gas, nor fractionate mixe d NGL to natural gas products.

Air pollutant emissions are primarily from three in ternal combustion engines which drive the compressors, and from the three TEG dehydration uni ts. All engines are White Superior model 8G825 4-cycle engines, fired only on natural gas, site ra ted at 660 horsepower (hp) each, and exhaust individually to the atmosphere. Dehydrator units D 001, D002 and D003 have the potential to emit VOCs and HAPs, including benzene, toluene, xylene a nd n-hexane from their still vents.

I.B. Source Emission Points

The following table identifies and describes each e missions unit, such as process units and control

devices.

Table 1 - Emission Units Public Service Company of Colorado Tiffany Compressor Station

Emission Unit

Id. Description Control Equipment

E001

E002

E003 Three White Superior model 8G825 Compressor

Engines, 660 bhp, natural gas fired

serial no. 21086, installed 11/15/74 serial no. 268139, installed 1/1/77 serial no. 274239, installed 1/1/80 None

None

None

D001

D002

D003 Two 0.58 mmscf/hr Triethylene Glycol Dehydrators,

manufactured by Production Equipment Corporation

contactor tower serial number: 1006, installed 197 4 contactor tower serial number: 1065, installed 197 4

One 0.17 mmscf/hr Triethylene Glycol Dehydrator, manufactured by J. W. Williams

contactor tower serial number: 997, installed 2003 None

None

None3

The following table identifies and describes the in significant activities/emission units at the source

.

Table 2 - Insignificant Emission Units Public Service Company of Colorado Tiffany Compressor Station

Description

2 - Glycol reboiler burners for units D001 and D002 , rated at 0.625

mmBtu/hr

Glycol reboiler burner for unit D003, rated at 0.35 mmBtu/hr

2 – 500 gallon triethylene glycol above ground stor age tanks

1,057 gallon ethylene glycol coastal 50 coolant abo ve ground tank

35 kW Generac emergency generator

5 – separator radiant heaters, rated at 0.025 mmBtu /hr (total)

1,100 gallon oil tank

560 gallon used oil underground tank

2,000 gallon water/oil tank

Elastec Inc. Smart Ash Burner

Two window-mounted air conditioning units4



### II. Facility-Wide Requirements

Conditions in this section of the permit apply to a ll emissions units located at the facility, including any units not specifically listed in Tabl e 1 and Table 2 of Section I.B.

[40 CFR 71.6(a)(1)]

II.A. General Recordkeeping Requirements [40 CFR 71.6(a)(3)(ii) and 63.10(b)(3)]

The permittee shall comply with the following gener ally applicable recordkeeping requirements:

1. If the permittee determines that his or her station ary source that emits (or has the potential to emit, without considering controls) one or more HAPs is not subject to a relevant standard or other requirement established under 40 CFR part 63, the permittee shall keep a record of the applicability determination on site at the Operations Center for a period of five years after the determination, or until the so urce changes its operations to become an affected source, whichever comes first. The record of the applicability determination shall include an analysis (or other information) th at demonstrates why the permittee believes the source is unaffected (e.g., because th e source is an area source). The analysis (or other information) shall be sufficiently detail ed to allow the Administrator to make a finding about the source’s applicability status wit h regard to the relevant standard or other requirement. If relevant, the analysis shall be pe rformed in accordance with requirements established in subparts of 40 CFR part 63 for this purpose for particular categories of stationary sources. If relevant, the analysis shou ld be performed in accordance with EPA guidance materials published to assist sources in m aking applicability determinations under section 112, if any.

2. Records shall be kept, as required by Section III.Q . of this permit, of off permit changes that are made in accordance with the approved Alter native Operating Scenarios in

Section II.B.

II.B. Alternative Operating Scenarios [40 CFR 71.6(a)(9)]

Engine Replacement/Overhaul

1. Replacement of an existing permitted engine with an engine of the same make, model, horsepower rating, and configured to operate in the same manner as the engine being replaced, and which satisfies all of the provisions for off permit changes, including the provisions specific to engine replacement, shall be considered an allowed alternative operating scenario under this permit.

2. Any emission limits, requirements, control technolo gies, or provisions that apply to engines that are replaced under this Alternative Op erating Scenarios section shall also apply to the replacement engines. A replacement en gine shall be considered a new unit and thus subject to any initial compliance testing and all other conditions applicable to the engine.5

3. Replacement of an existing permitted engine with an engine subject to 40 CFR part 60, subpart IIII is not an allowed alte rnative operating scenario.

4. Replacement of an existing permitted engine with an engine subject to 40 CFR part 60, subpart JJJJ is not an allowed alte rnative operating scenario.

5. Replacement of an existing permitted engine not sub ject to 40 CFR part 63, subpart ZZZZ with an engine subject to 40 CFR part 63, subp art ZZZZ is not an allowed alternative operating scenario.

[Explanatory Note: This section was included to al low for off permit replacement of engines that may have existing federally enforceable limits . For replacement engines which trigger new applicable requirements (i.e., NSPS, NESHAP, etc.), the minor permit modification process shall be utilized to maintain the permitted emission limi ts of the replaced engine and incorporate the new applicable requirements.]

II.C. Stratospheric Ozone and Climate Protection [40 CFR part 82]

The permittee shall comply with the standards for r ecycling and emissions reduction pursuant to 40 CFR part 82, subpart F:

1. Persons opening appliances for maintenance, serv ice, repair, or disposal must comply with the required practices pursuant to 40 CFR §82. 156.

2. Equipment used during the maintenance, service, repair, or disposal of appliances must comply with the standards for recycling and recover y equipment pursuant to 40 CFR §82.158.

3. Persons performing maintenance, service, repair, or disposal of appliances must be certified by an approved technician certification p rogram pursuant to 40 CFR §82.161.

II.D. Permit Shield [40 CFR 71.6(f)(3)]

Nothing in this permit shall alter or affect the fo llowing:

1. The liability of a permittee for any violation of a pplicable requirements prior to or at the time of permit issuance;

2. The ability of EPA to obtain information from a sou rce pursuant to section 114 of the CAA; or

3. The provisions of section 303 of the CAA (emergency orders), including the authority of

EPA under that section.6



### III. Part 71 Administrative Requirements

III.A. Annual Fee Payment [40 CFR 71.6(a)(7) and 40 CFR 71.9]

1. The permittee shall pay an annual permit fee in acc ordance with the procedures outlined

below. [40 CFR 71.9(a)]

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

.

[40 CFR 71.9(h)]

3. The fee payment shall be in United States currency and shall be paid by money order, bank draft, certified check, corporate check, or electro nic funds transfer payable to the order of the U.S. Environmental Protection Agency. [40 CFR 71.9(k)(1)]

4. The permittee shall send fee payment and a complete d fee filing form to

For regular U.S. postal service mail For non-U.S. Postal Service Express mail (FedEx, Airborne, DHL, and UPS) U.S. Environmental Protection Agency U.S. Bank FOIA and Miscellaneous Payments Government Lockbox 979078

Cincinnati Finance Center U.S. EPA FOIA & Misc. P ayments
P.O. Box 979078 1005 Convention Plaza St. Louis, MO 63197-9000 SL-MO-C2-GL St. Louis, MO 63101

[40 CFR 71.9(k)(2)]

[Explanatory note: The fee filing form “FF” may be found on EPA website at: http://www.epa.gov/air/oaqps/permits/p71forms.html ]

5. The permittee shall send an updated fee calculation worksheet form and a photocopy of each fee payment check (or other confirmation of ac tual fee paid) submitted annually by the same deadline as required for fee payment to th e address listed in Section III.E. of this permit. [40 CFR 71.9(h)(1)]

[Explanatory note: The fee calculation worksheet fo rm “FEE” may be found on EPA website at: http://www.epa.gov/air/oaqps/permits/p71forms.html ]7

6. Basis for calculating annual fee:

(a) The annual emissions fee shall be calculated by mul tiplying the total tons of actual emissions of all “regulated pollutants (for fee cal culation)” emitted from the source by the presumptive emissions fee (in dollars/ton) i n effect at the time of

calculation. [40 CFR 71.9(c)(1)]

(i) “Actual emissions” means the actual rate of emissio ns, in tpy, of any regulated pollutant (for fee calculation) emitted f rom a part 71 source over the preceding calendar year. Actual emissions shal l be calculated using each emissions unit’s actual operating hours, produ ction rates, in-place control equipment, and types of materials processed , stored, or combusted during the preceding calendar year. [40 CFR 71.9(c)(6)]

(ii) Actual emissions shall be computed using methods re quired by the permit for determining compliance, such as monitoring or s ource testing data.

[40 CFR 71.9(h)(3)]

(iii) If actual emissions cannot be determined using the compliance methods in the permit, the permittee shall use other federally recognized procedures.

[40 CFR 71.9(e)(2)]

[Explanatory note: The presumptive fee amount is re vised each calendar year to account for inflation, and it is available from EPA prior to th e start of each calendar year.]

(b) The permittee shall exclude the following emissions from the calculation of fees:

(i) The amount of actual emissions of each regulated po llutant (for fee calculation) that the source emits in excess of 4,0 00 tpy;

[40 CFR 71.9(c)(5)(i)]

(ii) Actual emissions of any regulated pollutant (for fe e calculation) already included in the fee calculation; and [40 CFR 71.9(c)(5)(ii)]

(iii) The quantity of actual emissions (for fee calculati on) of insignificant activities [defined in §71.5(c)(11)(i)] or of insig nificant emissions levels from emissions units identified in the permittee’s application pursuant to §71.5(c)(11)(ii). [40 CFR 71.9(c)(5)(iii)]8

7. Fee calculation worksheets shall be certified as to truth, accuracy, and completeness by a responsible official.

[Explanatory note: The fee calculation worksheet fo rm “FEE” already incorporates a section to help permittees meet this responsibility.] [40 CFR 71.9(h)(2)]

8. The permittee shall retain fee calculation workshee ts and other emissions-related data used to determine fee payment for 5 years following subm ittal of fee payment. [Emissionrelated data include, for example, emissions-relate d forms provided by EPA and used by the permittee for fee calculation purposes, emissio ns-related spreadsheets, and emissionsrelated data, such as records of emissions monitori ng data and related support information required to be kept in accordance with § 71.6(a)(3)(ii).] [40 CFR 71.9(i)]

9. Failure of the permittee to pay fees in a timely ma nner shall subject the permittee to assessment of penalties and interest in accordance with §71.9(l). [40 CFR 71.9(l)]

10. When notified by EPA of underpayment of fees, the p ermittee shall remit full payment within 30 days of receipt of notification. [40 CFR 71.9(j)(2)]

11. A permittee who thinks an EPA assessed fee is in er ror, and who wishes to challenge such fee, shall provide a written explanation of the all eged error to EPA along with full payment of the EPA assessed fee. [40 CFR 71.9(j)(3)]

III.B. Annual Emissions Inventory [40 CFR 71.9(h)(1) and (2)]

The permittee shall submit an annual emissions repo rt of its actual emissions for both criteria pollutants and regulated HAPs for this facility for the preceding calendar year for fee assessment purposes. The annual emissions report shall be cer tified by a responsible official and shall be submitted each year to EPA by April 1 st

.

The annual emissions report shall be submitted to E PA at the address listed in Section III.E. of this permit.

[Explanatory note: An annual emissions report, requ ired at the same time as the fee calculation worksheet by § 71.9(h), has been incorporated into the fee calcula tion worksheet form “FEE” as a convenience to permittees.]9

III.C. Compliance Requirements [40 CFR 71.6(a)(6)(i) and (ii), sections 113(a) and 113(e)(1) of the Act, and 40 CFR 51.212, 52.12, 52.33, 60.11( g), and 61.12]

1. Compliance with the Permit

(a) The permittee must comply with all conditions of th is part 71 permit. Any permit noncompliance constitutes a violation of the CAA an d is grounds for enforcement action; for permit termination, revocation and reis suance, or modification; or for denial of a permit renewal application. [40 CFR 71.6(a)(6)(i)]

(b) It shall not be a defense for a permittee in an enf orcement action that it would have been necessary to halt or reduce the permitted acti vity in order to maintain compliance with the conditions of this permit. [40 CFR 71.6(a)(6)(ii)]

(c) For the purpose of submitting compliance certificat ions in accordance with Section III.C.3. of this permit, or establishing whether or not a person has violated or is in violation of any requirement of this permit, nothin g shall preclude the use, including the exclusive use, of any credible eviden ce or information, relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or p rocedure had been performed.

[Section 113(a) and 113(e)(1) of the Act, 40 CFR 51 .212, 52.12, 52.33, 60.11(g), and 61.12]

2. Compliance Schedule

(a) For applicable requirements with which the source i s in compliance, the source will continue to comply with such requirements. [40 CFR 71.5(c)(8)(iii)(A)]

(b) For applicable requirements that will become effect ive during the permit term, the source will meet such requirements on a timely basi s. [40 CFR 71.5(c)(8)(iii)(B)]

3. Compliance Certifications

(a) The permittee shall submit to EPA a certification o f compliance with permit terms and conditions, including emission limitations, sta ndards, or work practices annually each year no later than April 1 st . The compliance certification due on April 1, 2012 shall cover the period from March 1, 2011 through December 31, 2011. Thereafter, each compliance cer tification shall cover the period for the previous calendar year. The complia nce certification shall be certified as to truth, accuracy, and completeness b y a responsible official consistent with §71.5(d). [40 CFR 71.6(c)(5)]10

(b) The certification shall include the following:

(i) Identification of each permit term or condition tha t is the basis of the certification; (ii) The identification of the method(s) or other means used for determining the compliance status of each term and condition during the certification period, and whether such methods or other means pro vide continuous or

intermittent data. Such methods and other means sh all include, at a minimum, the methods and means required in this per mit. If necessary, the permittee also shall identify any other material in formation that must be included in the certification to comply with secti on 113(c)(2) of the CAA, which prohibits knowingly making a false certificat ion or omitting material information; (iii) The status of compliance with the terms and conditi ons of the permit for the period covered by the certification based on the me thod or means designated in (ii) above. The certification shall identify each deviation and take it into account in the compliance certificatio n; (iv) Such other facts as the EPA may require to determin e the compliance status of the source; and (v) Whether compliance with each permit term was contin uous or intermittent.

[40 CFR 71.6(c)(5)(iii)]

[Explanatory note: To help part 71 permittees meet reporting responsibilities, EPA has developed a reporting form for annual compliance certificatio ns. The form may be found on EPA website

at: http://www.epa.gov/air/oaqps/permits/p71forms.html ]

III.D. Duty to Provide and Supplement Information [40 CFR 71.6(a)(6)(v), 71.5(a)(3), and 71.5(b)]

1. The permittee shall furnish to EPA, within a reason able time, any information that EPA may request in writing to determine whether cause e xists for modifying, revoking, and reissuing, or terminating the permit, or to determi ne compliance with the permit. Upon request, the permittee shall also furnish to the EP A copies of records that are required to be kept pursuant to the terms of the permit, includ ing information claimed to be

confidential. Information claimed to be confidenti al must be accompanied by a claim of confidentiality according to the provisions of 40 C FR part 2, subpart B.

[40 CFR 71.6(a)(6)(v) and 71.5(a)(3)]

2. The permittee, upon becoming aware that any relevan t facts were omitted or incorrect information was submitted in the permit application , shall promptly submit such supplementary facts or corrected information. In a ddition, a permittee shall provide additional information as necessary to address any requirements that become applicable after the date a complete application is filed, but prior to release of a draft permit.11 [40 CFR 71.5(b)]

III.E. Submissions [40 CFR 71.5(d), 71.6(c)(1) and 71.9(h)(2)]

1. Any document (application form, report, compliance certification, etc.) required to be submitted under this permit shall be certified by a responsible official as to truth, accuracy, and completeness. Such certifications shall state that based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete.

[Explanatory note: EPA has developed a reporting f orm “CTAC” for certifying truth, accuracy, and completeness of part 71 submissions. The form may be found on EPA website at: http://www.epa.gov/air/oaqps/permits/p71forms.html ]

2. Any documents required to be submitted under this p ermit, including reports, test data, monitoring data, notifications, compliance certific ations, fee calculation worksheets, and applications for renewals and permit modifications shall be submitted to:

Part 71 Permit Contact Air Program, 8P-AR U.S. Environmental Protection Agency, 1595 Wynkoop Street Denver, Colorado 80202-1129

III.F. Severability Clause [40 CFR 71.6(a)(5)]

The provisions of this permit are severable, and in the event of any challenge to any portion of this permit, or if any portion is held invalid, the rema ining permit conditions shall remain valid and in

force.

III.G. Permit Actions [40 CFR 71.6(a)(6)(iii)]

This permit may be modified, revoked, reopened, and reissued, or terminated for cause. The filing of a request by the permittee for a permit modifica tion, revocation and reissuance, or termination, or of a notification of planned changes or anticipa ted noncompliance does not stay any permit

condition.

III.H. Administrative Permit Amendments [40 CFR 71.7(d)]

1. The permittee may request the use of administrative permit amendment procedures for a permit revision that:

(a) Corrects typographical errors;

(b) Identifies a change in the name, address, or phone number of any person identified in the permit, or provides a similar minor administ rative change at the source;12

(c) Requires more frequent monitoring or reporting by t he permittee;

(d) Allows for a change in ownership or operational con trol of a source where the EPA determines that no other change in the permit is ne cessary, provided that a written agreement containing a specific date for transfer o f permit responsibility, coverage, and liability between the current and new permittee has been submitted to the EPA;

(e) Incorporates into the part 71 permit the requiremen ts from preconstruction review permits authorized under an EPA-approved program, p rovided that such a program meets procedural requirements substantially equival ent to the requirements of §71.7 and §71.8 that would be applicable to the cha nge if it were subject to review as a permit modification, and compliance requiremen ts substantially equivalent to those contained in §71.6; or

(f) Incorporates any other type of change which EPA has determined to be similar to those listed above in subparagraphs (a) through (e) above.

[Note to permittee: If subparagraphs (a) through (e ) above do not apply, please contact EPA for a determination of similarity prior to submitting you r request for an administrative permit amendment under this provision.]

III.I. Minor Permit Modifications [40 CFR 71.7(e)(1)]

1. The permittee may request the use of minor permit m odification procedures only for those

modifications that:

(a) Do not violate any applicable requirement;

(b) Do not involve significant changes to existing moni toring, reporting, or recordkeeping requirements in the permit;

(c) Do not require or change a case-by-case determinati on of an emission limitation or other standard, or a source-specific determination for temporary sources of ambient impacts, or a visibility or increment analysis;

(d) Do not seek to establish or change a permit term or condition for which there is no corresponding underlying applicable requirement and that the source has assumed to avoid an applicable requirement to which the sou rce would otherwise be subject.

Such terms and conditions include:

(i) A federally enforceable emissions cap assumed to av oid classification as a modification under any provision of title I; and (ii) An alternative emissions limit approved pursuant to regulations promulgated under section 112(i)(5) of the CAA;13

(e) Are not modifications under any provision of title I of the CAA; and

(f) Are not required to be processed as a significant m odification.

[40 CFR 71.7(e)(1)(i)(A)]

2. Notwithstanding the list of changes ineligible for minor permit modification procedures in paragraph 1, above, minor permit modification proce dures may be used for permit modifications involving the use of economic incenti ves, marketable permits, emissions trading, and other similar approaches, to the exten t that such minor permit modification procedures are explicitly provided for in an applic able implementation plan or in applicable requirements promulgated by EPA. [40 CFR 71.7(e)(1)(i)(B)]

3. An application requesting the use of minor permit m odification procedures shall meet the requirements of §71.5(c) and shall include the foll owing:

(a) A description of the change, the emissions resultin g from the change, and any new applicable requirements that will apply if the chan ge occurs;

(b) The source's suggested draft permit;

(c) Certification by a responsible official, consistent with §71.5(d), that the proposed modification meets the criteria for use of minor pe rmit modification procedures and a request that such procedures be used; and

(d) Completed forms for the permitting authority to use to notify affected states as required under §71.8. [40 CFR 71.7(e)(1)(ii)]

4. The source may make the change proposed in its mino r permit modification application immediately after it files such application. After the source makes the change allowed by the preceding sentence, and until the permitting au thority takes any of the actions authorized by §71.7(e)(1)(iv)(A) through (C), the s ource must comply with both the applicable requirements governing the change and th e proposed permit terms and conditions. During this time period, the source ne ed not comply with the existing permit terms and conditions it seeks to modify. However, if the source fails to comply with its proposed permit terms and conditions during this ti me period, the existing permit terms and conditions it seeks to modify may be enforced a gainst it. [40 CFR 71.7(e)(1)(v)]

5. The permit shield under §71.6(f) may not extend to minor permit modifications.

[40 CFR 71.7(e)(1)(vi)].14

III.J. Group Processing of Minor Permit Modificati ons [40 CFR 71.7(e)(2)]

1. Group processing of modifications by EPA may be use d only for those permit

modifications:

(a) That meet the criteria for minor permit modificatio n procedures under Section III.I., of this permit; and

(b) That collectively are below the threshold level of 10% of the emissions allowed by the permit for the emissions unit for which the cha nge is requested, 20% of the applicable definition of major source in §71.2, or 5 tpy, whichever is

least. [40 CFR 71.7(e)(2)(i)]

2. An application requesting the use of group processi ng procedures shall be submitted to EPA, shall meet the requirements of §71.5(c), and s hall include the following:

(a) A description of the change, the emissions resultin g from the change, and any new applicable requirements that will apply if the chan ge occurs;

(b) The source's suggested draft permit;

(c) Certification by a responsible official, consistent with §71.5(d), that the proposed modification meets the criteria for use of group pr ocessing procedures and a request that such procedures be used;

(d) A list of the source's other pending applications a waiting group processing, and a determination of whether the requested modification , aggregated with these other applications, equals or exceeds the threshold set u nder section 1.(b) above; and (e) Completed forms for the permitting authority to use to notify affected states as required under §71.8. [40 CFR 71.7(e)(2)(ii)]

3. The source may make the change proposed in its mino r permit modification application immediately after it files such application. After the source makes the change allowed by the preceding sentence, and until the permitting au thority takes any of the actions authorized by §71.7(e)(1)(iv)(A) through (C), the s ource must comply with both the applicable requirements governing the change and th e proposed permit terms and conditions. During this time period, the source ne ed not comply with the existing permit terms and conditions it seeks to modify. However, if the source fails to comply with its proposed permit terms and conditions during this ti me period, the existing permit terms and conditions it seeks to modify may be enforced a gainst it. [40 CFR 71.7(e)(2)(v)]

4. The permit shield under §71.6(f) may not extend to group processing of minor permit

modifications.15 [40 CFR 71.7(e)(2)(vi)]

III.K. Significant Permit Modifications [40 CFR 71.7(e)(3)]

1. The permittee must request the use of significant p ermit modification procedures for those

modifications that:

(a) Do not qualify as minor permit modifications or as administrative amendments;

(b) Are significant changes in existing monitoring perm it terms or conditions; or

(c) Are relaxations of reporting or recordkeeping permi t terms or conditions.

[40 CFR 71.7(e)(3)(i)]

2. Nothing herein shall be construed to preclude the p ermittee from making changes consistent with part 71 that would render existing permit compliance terms and conditions

irrelevant. [40 CFR 71.7(e)(3)(i)]

3. Permittees must meet all requirements of part 71 fo r applications, public participation, and review by affected states and tribes for significan t permit modifications. For the application to be determined complete, the permitte e must supply all information that is required by §71.5(c) for permit issuance and renewa l, but only that information that is related to the proposed change. [40 CFR 71.7(e)(3)(ii), 71.8(d), and 71.5(a)(2)]

III.L. Reopening for Cause [40 CFR 71.7(f)]

The permit may be reopened and revised prior to exp iration under any of the following

circumstances:

1. Additional applicable requirements under the Act be come applicable to a major part 71 source with a remaining permit term of 3 or more ye ars. Such a reopening shall be completed not later than 18 months after promulgati on of the applicable requirement. No such reopening is required if the effective date of the requirement is later than the date on which the permit is due to expire, unless the origi nal permit or any of its terms and conditions have been extended pursuant to §71.7 (c) (3);

2. Additional requirements (including excess emissions requirements) become applicable to an affected source under the acid rain program. Up on approval by the Administrator, excess emissions offset plans shall be deemed to be incorporated into the permit;

3. EPA determines that the permit contains a material mistake or that inaccurate statements were made in establishing the emissions standards o r other terms or conditions of the permit; or16

4. EPA determines that the permit must be revised or r evoked to assure compliance with the applicable requirements.

III.M. Property Rights [40 CFR 71.6(a)(6)(iv)]

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

III.N. Inspection and Entry [40 CFR 71.6(c)(2)]

Upon presentation of credentials and other document s as may be required by law, the permittee shall allow EPA or an authorized representative to perform the following:

1. Enter upon the permittee’s premises where a part 71 source is located, or emissions-related activity is conducted, or where records must be kep t under the conditions of the permit;

2. Have access to and copy, at reasonable times, any r ecords that must be kept under the conditions of the permit;

3. Inspect at reasonable times any facilities, equipme nt (including monitoring and air pollution control equipment), practices, or operati ons regulated or required under the permit; and

4. As authorized by the CAA, sample or monitor at reas onable times substances or parameters for the purpose of assuring compliance w ith the permit or applicable requirements.

III.O. Emergency Provisions [40 CFR 71.6(g)]

1. In addition to any emergency or upset provision con tained in any applicable requirement, the permittee may seek to establish that noncomplia nce with a technology-based emission limitation under this permit was due to an emergenc y. To do so, the permittee shall demonstrate the affirmative defense of emergency th rough properly signed contemporaneous operating logs, or other relevant e vidence that:

(a) An emergency occurred and that the permittee can id entify the cause(s) of the

emergency;

(b) The permitted facility was at the time being proper ly operated;

(c) During the period of the emergency the permittee to ok all reasonable steps to

minimize levels of emissions that exceeded the emis sions standards, or other requirements in this permit; and

(d) The permittee submitted notice of the emergency to EPA within 2 working days of

the time when emission limitations were exceeded du e to the emergency. This17 notice must contain a description of the emergency, any steps taken to mitigate emissions, and corrective actions taken. This noti ce fulfills the requirements for prompt notification of deviations.

2. In any enforcement proceeding, the permittee attemp ting to establish the occurrence of an emergency has the burden of proof.

3. An “emergency” means any situation arising from sud den and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal opera tion, and that causes the source to exceed a technology-based emission limitation under the permit due to unavoidable increases in emissions attributable to the emergenc y. An emergency shall not include noncompliance to the extent caused by improperly de signed equipment, lack of preventive maintenance, careless or improper operation, or ope rator error.

III.P. Transfer of Ownership or Operation [40 CFR 71.7(d)(1)(iv)]

A change in ownership or operational control of thi s facility may be treated as an administrative permit amendment if the EPA determines no other cha nge in this permit is necessary and provided that a written agreement containing a specific date for transfer of permit responsibility, coverage, and liability between the current and new permittee has been submitted to EPA.

III.Q. Off Permit Changes [40 CFR 71.6(a)(12) and 71.6(a)(3)(ii)]

The permittee is allowed to make certain changes wi thout a permit revision, provided that the following requirements are met:

1. Each change is not addressed or prohibited by this permit;

2. Each change shall meet with all applicable requirem ents and shall not violate any existing permit term or condition;

3. Changes under this provision may not include change s subject to any requirement of 40 CFR parts 72 through 78 or modifications under a ny provision of title I of the CAA;

4. The permittee must provide contemporaneous written notice to EPA of each change, except for changes that qualify as insignificant ac tivities under §71.5(c)(11). The written notice must describe each change, the date of the c hange, any change in emissions, pollutants emitted, and any applicable requirements that would apply as a result of the change;

5. The permit shield does not apply to changes made un der this provision; and

6. The permittee must keep a record describing all cha nges that result in emissions of any regulated air pollutant subject to any applicable r equirement not otherwise regulated under this permit, and the emissions resulting from those changes.18

7. For replacement of an existing permitted compressor engine with an engine of the same make, model, horsepower rating, and configured to o perate in the same manner as the engine being replaced, in addition to satisfying al l other provisions for off permit changes, the permittee shall satisfy the following provision s:

(a) The replacement engine employs air emissions contro l devices, monitoring, record keeping and reporting that are equivalent to those employed by the engine being replaced;

(b) The replacement of the existing engine does not con stitute a major modification or major new source as defined in Federal PSD regulati ons (40 CFR 52.21);

(c) No new applicable requirements, as defined in 40 CF R 71.2, are triggered by the replacement; and

(d) The following information is provided in a written notice to EPA in addition to the standard information listed above for contemporaneo us written notices for off permit changes:

(i) Make, model number, serial number, horsepower ratin g and configuration of the existing engine and the replacement engine; (ii) Manufacture date, commence construction date (per t he definition in 40 CFR 60.2, 60.4230(a) and 63.2), installation dat e, and start-up date of the replacement engine; (iii) If applicable, documentation of the cost to rebuild a replacement engine versus the cost to purchase a new engine in order t o support claims that an engine is not “reconstructed,” as defined in 40 CFR 60.15 and 40 CFR 63.2; (iv) 40 CFR part 60, subpart IIII (CI Engine NSPS) non-a pplicability documentation as appropriate; (v) 40 CFR part 60, subpart JJJJ (SI Engine SNPS) non-a pplicability documentation as appropriate; (vi) 40 CFR part 63, subpart ZZZZ (RICE MACT) non-applic ability documentation for major

sources, as appropriate; (vii) 40 CFR part 63, subpart ZZZZ (RICE MACT) non-applic ability

documentation for area

sources, as appropriate; (viii) Documentation to demonstrate that the replacement d oes not constitute a major new source or major modification, as defined in Federal PSD rules (40 CFR 52.21), as follows:

A. If the replacement will not constitute a "physical change or change in the method of operation" as described in §52.21( b), an explanation of how that conclusion was reached shal l be provided.19 B. If the replacement will constitute a "physical chan ge or change in the method of operation" as described §52.21(b), th e following information shall be provided:

(1) If the existing source is a "major stationary sourc e" as defined in §52.21(b): For each "regulated NSR poll utant" as defined in §52.21(b), a demonstration (including al l calculations) that the replacement will not be a "m ajor modification" as defined in §52.21(b). A modificat ion is major only if it causes a "significant emissions in crease" as defined in §52.21(b), and also causes a "significan t net emissions increase" as defined in §52.21(b).

The “Applicability Procedures” of §52.21(a)(2) shal l be used to calculate whether or not there will be a signifi cant emissions increase. If there will be a significant emissions increase, then calculations shall be provided to de monstrate there will not be a significant net emissions incre ase. These

latter calculations shall include all sourcewide contemporaneous and creditable emission increases a nd decreases, as defined in §52.21(b), summed with the PTE of the replacement unit(s).

If netting is used to demonstrate that the replacem ent will not constitute a "major modification," verification shall be provided that the replacement unit(s) employ emissi on controls at least equivalent in control effectivene ss to those employed by the unit(s) being replaced.

PTE of replacement unit(s) shall be determined base d on the definition of PTE in §52.21(b). For each "regulate d NSR pollutant" for which the PTE is not "significant,"

calculations used to reach that conclusion shall be provided.

(2) If the existing source is not a "major stationary s ource" as defined in §52.21(b): For each "regulated NSR poll utant," a demonstration (including all calculations) that the replacement unit(s), by itself, will not constitute a "major stationary source" as defined in §52.21(b).

8. The notice shall be kept on site and made available to EPA on request, in accordance with the general recordkeeping provision of this permit.

9. Submittal of the written notice required above shal l not constitute a waiver, exemption, or shield from applicability of any applicable standar d or PSD permitting requirements under20

40 CFR 52.21 that would be triggered by the replace ment of any one engine, or by replacement of multiple engines.

III.R. Permit Expiration and Renewal [40 CFR 71.5(a)(1)(iii), 71.5(a)(2), 71.5(c)(5), 71.6(a)(11), 71.7(b), 71.7(c)(1), and 71.7(c)(3)]

1. This permit shall expire upon the earlier occurrenc e of the following events:

(a) Five (5) years elapses from the date of issuance; o r

(b) The source is issued a part 70 or part 71 permit un der an EPA approved or delegated permit program. [40 CFR 71.6(a)(11)]

2. Expiration of this permit terminates the permittee’ s right to operate unless a timely and complete permit renewal application has been submit ted at least 6 months but not more than 18 months prior to the date of expiration of t his permit. [40 CFR 71.5(a)(1)(iii)]

3. If the permittee submits a timely and complete perm it application for renewal, consistent with §71.5(a)(2), but EPA has failed to issue or de ny the renewal permit, then all the terms and conditions of the permit, including any permit shield granted pursuant to §71.6(f) shall remain in effect until the renewal permit has been issued or denied. [40 CFR 71.7(c)(3)]

4. The permittee’s failure to have a part 71 permit is not a violation of this part until EPA takes final action on the permit renewal applicatio n. This protection shall cease to apply if, subsequent to the completeness determination, t he permittee fails to submit any additional information identified as being needed t o process the application by the deadline specified in writing by EPA. [40 CFR 71.7(b)]

5. Renewal of this permit is subject to the same proce dural requirements that apply to initial permit issuance, including those for public partici pation, affected State, and tribal review.

[40 CFR 71.7(c)(1)]

6. The application for renewal shall include the curre nt permit number, description of permit revisions and off permit changes that occurred duri ng the permit term, any applicable requirements that were promulgated and not incorpor ated into the permit during the permit term, and other information required by the applica tion form.

[40 CFR 71.5(a)(2) and 71.5(c)(5)]21



### IV. Appendices to the Part 71 Permit

IV.A. Inspection Information

1. Directions to Tiffany Compressor Facility

From Bayfield, Colorado, travel south on Buck Highw ay/County Road 521 to Ignacio, then south on State Highway 151 past mile marker 9 to County Road 330. Travel approximately 1 mile east on County Road 330 to Tif fany Compressor Station.

2. Location of the Tiffany Compressor Facility

Latitude: 37°, 2.999’ North Longitude: 107°, 30.707’ West

3. Safety Considerations

All visitors to the facility are expected to adher e to Tiffany Compressor Station safety policies. Policies of particular concern are those regarding the Personal Protective Equipment (PPE) and performance of Hot Work. As po sted at the entrance to the station, Tiffany Compressor Station requires persons enterin g the site to wear a hard hat, safety glasses, safety toe footwear, hearing protection, a nd fire retardant clothing. Tiffany Compressor Station also requires a permit (issued b y authorized Tiffany Compressor Station employees) prior to the performance of any hot work at the station.