Scott, 

 

As a follow-up to our phone conversation this morning, I am providing a summary of the four instances where 

Colorado has allowed sources, under our existing NSR program, to use a time period that is different than the 

two years (i.e., 24 months) immediately preceding the proposed project to determine the source’s actual 

emissions baseline for NSR permitting purposes: 

 

Suncor Commerce City Refinery (West Plant) – Clean Fuels Project (to facilitate production of lower sulfur 

content fuels)

Application submitted in Jan 2004 (two-year period immediately preceding would have been 2002 and 2003) 

Two-year period approved by Colorado: 2001 and 2003

Reason: During 2002, Suncor performed a major plant turnaround/maintenance event at the refinery. Colorado 

determined that 2001 and 2003 were more representative of normal operation at the facility (netting exercise). 

 

Lamar Utilities Board (Arkansas River Power Authority) – Lamar Repowering Project (converted from natural 

gas to coal-fired boiler)

Application submitted in Dec 2004 (two-year period immediately preceding would have been approx. 2003 and 

2004) 

Two-year period approved by Colorado: 2001 and 2002

Reason: LUB had historically operated a natural gas fired boiler on site to generate electricity. When natural gas 

prices increased substantially in 2003 and 2004, it was no longer economical for LUB to operate this boiler. 

Summary of Instances Where Colorado Has Allowed a Different Two-Year Actuals Baseline

Hea, Roland C. 

to: 

Scott Jackson 

11/18/2011 12:13 PM 

Cc: 

"King, Kirsten L.", "Wojtach, Dena", Donald Law 

Hide Details 

From: "Hea, Roland C." <Roland.Hea@dphe.state.co.us> 

To: Scott Jackson/R8/USEPA/US@EPA 

Cc: "King, Kirsten L." <Kirsten.King@dphe.state.co.us>, "Wojtach, Dena" 

<Dena.Wojtach@dphe.state.co.us>, Donald Law/R8/USEPA/US@EPA 

History: This message has been replied to and forwarded. 

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Colorado determined that 2001 and 2002 were more representative of normal operation at the facility (PSD 

permit for some pollutants, netted out for NOx). 

 

EVRAZ Rocky Mountain Steel – Pueblo Steel Mill (steel production increase request)

Application submitted in March 2011 (two-year period immediately preceding would have been 2009 and 2010) 

Two-year period approved by Colorado: 2007 and 2008

Reason: Due to economic conditions, ERMS produced a lower amount of steel in 2009 than they had typically 

been producing since their new furnace had gone in to full operation, with demand picking back up in 2010. 

Colorado determined that 2007 and 2008 were more representative of normal operation at the facility (PSD 

permit). 

 

OXY – Conn Creek Compressor Station in Garfield County (modifications to plant to remedy compliance issues 

and facilitate production changes)

Application originally submitted in April 2010 but revised several times during processing (two-year period 

immediately preceding would have been approx. 2009 and 2010) 

Two-year period approved by Colorado: September 2007 through August 2009 

Reason: As a result of operational and compliance issues, OXY was required to shutdown two major pieces of 

process equipment at the plant, starting in September 2009. This equipment would normally run as part of the 

plant operations. Colorado determined that September 2007 through August 2009 was more representative of 

normal operation at the facility (netting exercise). 

Please let me know if you have any questions. 

 

Thanks, 

Roland 

 

Roland C. Hea, P.E.

Permitting Section Supervisor

Air Pollution Control Division

Colorado Department of Public Health and Environment

4300 Cherry Creek Drive South

Denver, Colorado 80246-1530

303-692-3252

303-782-0278 (Fax)

roland.hea@state.co.us

 

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