RMRVAMC Initial Title V Operating Permit Application.pdf

CONSTRUCTION PERMIT

Permit number: 14AD0765 Issuance 4

Date issued: July 13, 2022

Issued to: Veterans Affairs Medical Center

Facility Name: Eastern Colorado Health Care System

Plant AIRS ID: 001-2090

Physical Location: 13611 E. Colfax Avenue, Aurora

County: Adams

General Description: Hospital facility

Equipment or activity subject to this permit:

Facility Equipment ID

AIRS

Point

Description

6-BFT-1

6-BFT-2

6-BFT-3

6-BFT-4

001 Four dual fuel-fire boilers:

Make: Cleaver Brooks Model: 4WI-LN SNs: T3789-1-1, T3786-1-2, T3786-1-3, & T3786-1-4 Design Rated at 28.16 MMBTU per hour each Fuels Allowed: Natural gas & #2 Diesel

EGEN -1

EGEN -2

EGEN -3

EGEN -4

002 Four diesel fuel-fire emergency generators:

Make: Caterpillar Model: AA/3516C SNs: DD500444, DD500447, DD500445, DD500446 Design Rate: 3,273 hp each Relocation Year: 2013 NSPS: Subpart IIII, Tier 4I/Alt NOx

Point 002: This engine may be replaced with another engine per the temporary engine replacement provision or with another Caterpillar engine model AA/3516C per the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A.

THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25- 7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE

FOLLOWING SPECIFIC TERMS AND CONDITIONS:

REQUIREMENTS TO SELF-CERTIFY FOR FINAL APPROVAL

1. This construction permit represents final permit approval to operate emission point 001.

Therefore, it is not necessary to self-certify. (Regulation Number 3, Part B, III.G.5).

2. Point 002: Within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever is later, the operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Reference: Regulation Number 3, Part B, III.G.2.)

3. Points 001, 002: The owner or operator must revise and update the operating and maintenance

(O&M) plan, along with a recordkeeping format, that outlines how the applicant will maintain compliance on an ongoing basis with the requirements of this permit. Compliance with the O&M plan must commence at startup. Within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever is later, the owner or operator must submit the O&M plan to the Division. Failure to submit an acceptable operating and maintenance plan could result in the revocation of the permit. Note that the Division may modify the monitoring requirements as part of the Title V Operating Permit if this facility is subject to Title V permitting (Reference: Regulation Number 3, Part B, III.G.7.).

EMISSION LIMITATIONS AND RECORDS

4. Emissions of air pollutants must not exceed the following limitations (as calculated using the emission factors* included in the Notes to Permit Holder section of this permit Annual records of the actual emission rates must be maintained by the applicant and made available to the Division for inspection upon request. (Reference: Regulation Number 3, Part B, Section II.A.4)

Annual Limits:

Facility Equipment ID

AIRS

Point

Tons Per Year 1. Emission Type TSP PM10 PM2.5 SO2 NOx VOC CO Pb

As listed above

001 1.5 1.5 1.5 -- 19.9 1.4 16.6 -- Point

002 -- -- -- -- 19.6 -- 4.5 --

Facility Total 1.5 1.5 1.5 -- 39.5 1.4 21.1 --

* Note: See “Notes to Permit Holder” for information on emission factors and methods used to calculate limits.

Compliance with the annual limits must be determined on a rolling twelve (12) month total. By the end of each month, a new twelve-month total is calculated based on the previous twelve months’ data. The permit holder must calculate actual emissions each month and keep a compliance record on-site or at a local field office with site responsibility for Division review.

The owner or operator must use the emission factors found in “Notes to Permit Holder” to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions.

5. The particulate emission control measures listed on the attached page (as approved by the Division) must be applied to the particulate emission producing sources as required by Regulation Number 1, Section III.D.1.b.

AIRS Point Unit/Stack Control Device Pollutants Controlled

As listed above 001 Boilers Low-NOx burners (LBNs) NOx

PROCESS LIMITATIONS AND RECORDS

6. This source must be limited to the following maximum consumption, processing, and/or operational rates as listed below. Annual records of the actual process rate must be maintained by the applicant and made available to the Division for inspection upon request. (Reference:

Regulation 3, Part B, II.A.4)

Process/Consumption Limits

AIRS

Point

Process Parameter Annual Limit

As listed above

Natural gas consumption 394.73 MMscf per year*

#2 Fuel oil consumption 16,350 gallons per year**

002 Diesel fuel consumption 85,590 gallons per year**

* Based on fuel’s heat value of 1,000 BTU scf ** Based on fuel’s heat value of 139,000 BTU per gallon

Compliance with the yearly process limits must be determined on a rolling twelve (12) month total. By the end of each month, a new twelve-month total is calculated based on the previous twelve months’ data. The permit holder must calculate monthly process rates and keep a compliance record on-site or at a local field office with site responsibility, for Division review

STATE AND FEDERAL REGULATORY REQUIREMENTS

7. Visible emissions must not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions must not exceed 30% opacity for more than six minutes in any sixty consecutive minutes.

Opacity must be determined using EPA Method 9. (Reference: Regulation Number 1, Section II.A.1.

& 4.)

8. This source is subject to the odor requirements of Regulation Number 2 (State only enforceable).

9. Point 001: This source is subject to the New Source Performance Standards requirements of Regulation Number 6, Part A, Subpart Dc, Standards of Performance for Small Industrial- Commercial-Institutional Steam Generating Units including, but not limited to, the following:

[The requirements below reflect the rule language of 40 CFR Part 60 Subpart Dc published in the Federal Register on 2/16/12. However, if revisions to this Subpart are published at a later date, the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 60, Subpart Dc.].

a. Reporting and recordkeeping requirements. (Reference: §60.48c)

b. No owner or operator of an affected facility that combusts oil shall combust oil in the affected facility that contains greater than 0.5 weight percent sulfur. (Reference:

§60.42c(d))

c. No owner or operator of an affected facility that combusts distillate oil and has a heat input capacity of 8.7 MW (30 MMBtu/h) or greater shall cause to be discharged into the atmosphere from that affected facility any gases that exhibit greater than 20 percent opacity (6-minute average), except for one 6-minute period per hour of not more than 27 percent opacity. (Reference: §60.43c(c))

d. Distillate oil means fuel oil that complies with the specifications for fuel oil numbers 1 or 2, diesel fuel oil numbers 1 or 2, kerosene, biodiesel, or biodiesel blends. (Reference:

§60.41c)

e. Fuel supplier certification records shall be kept for each delivery of distillate fuel oil to be used in the boiler. Fuel supplier certification shall include the name of the oil supplier, the type of oil, and the maximum sulfur content of the oil. (Reference: §60.42c(h), §60.48c(f))

f. The owner or operator of each affected facility subject to the SO2 emission limits and fuel oil sulfur limits under §60.42c shall submit reports to the Division. The reporting period for the reports required under this subpart is six months. All reports shall be submitted to the

Division, shall be postmarked by the 30th day following the end of the reporting period, and shall include: (Reference: §60.48c(d), §60.48c(j))

(1) Calendar dates covered in the reporting period;

(2) Records of fuel supplier certifications; and

(3) A certified statement signed by the owner or operator of the affected facility that the records of fuel supplier certifications submitted represent all the fuel combusted during the reporting period.

10. Point 002: This source is subject to the New Source Performance Standards (NSPS) requirements of Regulation Number 6, Part A, Subpart IIII, Standards of Performance for Stationary Compression Ignition Internal Combustion Engines (CI ICE) including, but not limited to, the following:

[The requirements below reflect the rule language of 40 CFR Part 60 Subpart IIII published in the Federal Register on 1/30/2013. However, if revisions to this Subpart are published at a later date, the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 60, Subpart IIII.]

a. Emissions of Nitrogen Oxides shall not exceed 0.50 grams per horsepower-hour.

b. Emissions of Non-Methane Hydrocarbons shall not exceed 0.30 grams per horsepower-hour.

c. Emissions of Carbon Monoxide shall not exceed 2.6 grams per horsepower hour.

d. Emissions of Particulate Matter shall not exceed 0.07 grams per horsepower hour.

e. All fuel purchased shall meet the following specifications:

(1) Sulfur content shall not exceed 15 ppm.

(2) Have a minimum cetane index of 40 or

Have a maximum aromatic compound content of 35% by volume.

Compliance shall be demonstrated by maintaining copies of the fuel specifications provided by the supplier on-site or in a readily accessible location and made available to the Division for inspection upon request.

f. All engines and control devices must be installed, configured, operated, and maintained according to the specifications and instructions provided by the engine manufacturer.

g. If the engine is equipped with a diesel particulate filter, the filter must be installed with a backpressure monitor that notifies the owner or operator when the high backpressure limit of the engine is approached. Records shall be kept of any corrective action taken after the backpressure monitor has notified the owner or operator that the high backpressure limit is approached.

11. The owner or operator of this facility is subject to the following requirements of Regulation Number 6, Part A, Subpart A, General Provisions (40CFR part 60, Subpart A).

a. At all times, including periods of start-up, shutdown, and malfunction, the facility, and control equipment shall, to the extent practicable, be maintained and operated in a manner consistent with good air pollution control practices for minimizing emissions. Determination of whether or not acceptable operating and maintenance procedures are being used will be based on information available to the Division, which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. (Reference: Regulation Number 6, Part A. General Provisions from 40 CFR 60.11)

b. No article, machine, equipment, or process shall be used to conceal an emission that would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard that is based on the concentration of a pollutant in the gases discharged to the atmosphere. (§ 60.12)

12. This source is located in an ozone non-attainment or attainment-maintenance area and subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2: RACT for this source was determined to be compliant with the requirements of NSPS Subpart Dc and Subpart III in conditions 9, 10 and 11 above.

OPERATING & MAINTENANCE REQUIREMENTS

13. The owner or operator must develop an operating and maintenance (O&M) plan, along with a recordkeeping format, that outlines how the applicant will maintain compliance on an ongoing basis with the requirements of this permit. Compliance with the O&M plan must commence at startup. Within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever is later, the owner or operator must submit the O&M plan to the Division. Failure to submit an acceptable operating and maintenance plan could result in the revocation of the permit. Note that the Division may modify the monitoring requirements as part of the Title V Operating Permit if this facility is subject to Title V permitting (Reference:

Regulation Number 3, Part B, III.G.7.).

COMPLIANCE TESTING AND SAMPLING

Initial Testing Requirements

14. Within 180 days of a startup, the owner or operator must demonstrate compliance with the visible emission limit above using EPA Method 9 to measure opacity from the boilers and emergency generators’ stacks. This measurement must consist of a minimum of twenty-four consecutive readings taken at fifteen-second intervals over six minutes. (Reference: Regulation Number 1, Section II.A.1 & 4)

Periodic Testing Requirements

15. Point 002: Replacements of this unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A.

ADDITIONAL REQUIREMENTS

16. All previous versions of this permit are canceled upon issuance of this permit.

17. The permit number must be marked on the subject equipment for ease of identification. (Reference:

Regulation Number 3, Part B, III.E.) (State only enforceable)

18. A Revised Air Pollutant Emission Notice (APEN) must be filed (Reference: Reg. 3, Part A, II.C):

a. By April 30 of the year following a significant increase in emissions. A significant increase in emissions is defined as follows:

For any criteria pollutant:

For sources emitting less than 100 tons per year, a change in actual emissions of five tons per year or more, above the level reported on the last APEN submitted; or

For VOC sources in the Denver Metro ozone attainment-maintenance area emitting less than 100 tons of VOC per year, a change in actual emissions of one ton per year or more or five percent, whichever is greater, above the level reported on the last APEN submitted; or

For any non-criteria reportable pollutant:

If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division.

b. Whenever there is a change in the owner or operator of any facility, process, activity; or

c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or

d. Whenever a permit limitation must be modified; or

e. No later than 30 days before the existing APEN expires.

19. This source is subject to the provisions of Regulation Number 3, Part C, Operating Permits (Title V of the 1990 Federal Clean Air Act Amendments). The provisions of this construction permit must be incorporated into the operating permit. The application for the modification to the Operating Permit is due within one year of the issuance of this permit.

GENERAL TERMS AND CONDITIONS:

20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the Division as provided in Regulation Number 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee.

21. If this permit specifically states that final approval has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or the operation of this source. Final approval of the permit must be secured from the Division in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and Regulation Number 3, Part B, Section III.G. Final approval cannot be granted until the operation or activity commences and has been verified by the Division as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final approval.

Details for obtaining final approval to operate are located in the Requirements to Self-Certify for Final Approval section of this permit.

22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the applicant and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the applicant or applicant's agents. It is valid only for the equipment and operations or activity specifically identified on the permit.

By:

Sunday A. Fadeyi, P. E.

Permit Engineer

Permit History:

Issuance Date Description

Issuance 1 October 28, 2014 Initial Approval was issued to RK Medical, Inc.

Issuance 2 August 19, 2019 Initial Approval issued to /veterans Affairs Medical Center. Transfer of ownership from RK Medical, Inc.

Issuance 3 June 2, 2022 Addition of four (4) emergency diesel engines to the existing boilers;

Initial Approval permit reissued to Veterans Affairs Medical Center.

Issuance 4 July 13, 2023 Correction to issuance 3; Correction to revise engine EGEN-1 serial number from “ADD500444” to “DD500444”

Notes to Permit Holder (as of the date of permit issuance):

1) The production or raw material processing limits and emission limits contained in this permit are based on the production/processing rates requested in the permit application. These limits may be revised upon request of the permittee providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and application form must be submitted with a request for a permit revision.

2) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The permittee must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See https://www.colorado.gov/pacific/cdphe/aqcc-regs.

3) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations

AIRS Point Pollutant CAS Controlled Emission Rate

001 Hexane 110-54-3 711 lbs. per year

4) The emission levels contained in this permit are based on the following controlled emission factors:

Point 001 – Boilers combusting natural gas fuel:

CAS Pollutant Emission Factors Source of Emission Factors

------ TSP 7.6000 lbs. per MMscf AP-42

------ PM10 7.6000 lbs. per MMscf AP-42

------ PM2.5 7.6000 lbs. per MMscf AP-42

------ NOx 100.0000 lbs. per MMscf AP-42

------ VOC 5.5000 lbs. per MMscf AP-42

------ CO 84.000 lbs. per MMscf AP-42

Point 001 – Boilers combusting #2 fuel oil:

CAS Pollutant Emission Factors Applied Source of Emission Factors

------ NOx 20.000 lbs. per 1000-gallons AP-42 https://www.colorado.gov/pacific/cdphe/aqcc-regs

------ VOC 34.000 lbs. per 1000-gallons AP-42

Point 002 – Diesel fuel-fired emergency generators:

CAS Pollutant Emission Factors Source of Emission Factors

-------- NOx 450.730 lbs. per 1000-gallons AP-42

------- CO 103.572 lbs. per 1000-gallons AP-42

5) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150.

6) This facility is classified as follows:

Applicable Requirement Status

Operating Permit Major source: NOx, Minor source: PM, VOC, CO

PSD Minor source: PM, NOx, VOC, CO

NANSR Major source: NOx, Minor source: PM, VOC, CO

7) The full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the following website:

http://ecfr.gpoaccess.gov/

Part 60: Standards of Performance for New Stationary Sources

NSPS 60.40c-60.48c Subpart Dc

NSPS 60.4200-60.4219 Subpart IIII

Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories

MACT 63.6580-63.6675 Subpart ZZZZ

8) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation Number 3, Part A, Section VI.B.)

9) Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the Division to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S.

10) Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Division on grounds set forth in the Colorado Air Pollution Prevention and Control Act and regulations of the AQCC including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the applicant, or the Division revokes a permit, the applicant or owner or operator of a source may request a hearing before the AQCC for http://ecfr.gpoaccess.gov/ review of the Division’s action.

11) Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollutant Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate.

12) Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S.

ATTACHMENT A:

ALTERNATIVE OPERATING SCENARIOS

STATIONARY (CI) ENGINE

October 1, 2011

The current AOS requirements have been included as per below. AOS requirements can change based on new/modified regulations or changes to the facility status. The permittee must comply with the appropriate AOS requirements contained in the most recently issued version of PS-Memo 98-06, available on the Division's website, which may be different than the requirements below.

2. Alternative Operating Scenarios

The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of Stationary (CI) engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility- Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS, and the owner or operator shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit.

2.1 Engine Replacement

The following AOS is incorporated into this permit to deal with an engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. “Temporary” is defined as in the same service for 90 operating days or less, in any 12 months.

“Permanent” is defined as in the same service for more than 90 operating days in any 12 months. The 90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90-day total. The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit.

All replacement engines are subject to all federally applicable and state-only requirements set forth in this permit (including monitoring and record keeping.

The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 60 days. Results of all tests shall be kept on-site for five

(5) years and made available to the Division upon request.

The owner or operator shall maintain a log on-site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and the serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and the serial number of the replacement engine.

2.1.1 The owner or operator may temporarily replace an existing engine that is covered by this permit with a different engine without modifying this permit; so long as the temporary replacement engine complies with all permit limitations and other requirements applicable to the existing engine. Calculation of emissions from the temporary replacement engine shall be made as outlined in section 2.1.3.

2.1.2 An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model, serial number, and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement engine and an analysis of any new applicable requirements for the replacement engine as required by Condition 2.2. This submittal shall be accompanied by a certification from the Responsible Official indicating that “based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate, and complete”.

This AOS cannot be used for permanent engine replacement of a grandfathered or permit-exempt engine or an engine that is not subject to emission limits.

The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division concerning any permanent engine replacement.

2.1.3 Compliance of the replacement engine with the applicable emission limitations of the original engine shall be monitored by one of the following methods:

1) Manufacturer-certified emission factors showing compliance.

2) Stack tests of the same make and model showing compliance. This would only be considered if the test was done under similar conditions to Colorado (i.e. at altitude).

3) Stack tests on the engine.

2.2 Applicable Regulations for Permanent Engine Replacements

2.2.1 NSPS for stationary compression-ignition internal combustion engines: 40 CFR

Part 60, Subpart IIII

A permanent replacement engine that is ordered after July 11, 2005, and manufactured after April 1, 2006, or is modified or reconstructed after July 11, 2005, is subject to the requirements of 40 CFR Part 60, Subpart IIII. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in any request for a permanent engine replacement.

Note that under the provisions of Regulation No. 6. Part B, section I.B. the Relocation of a source from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the date of manufacture for purposes of determining the applicability of NSPS IIII requirements).

2.2.2. MACT for Stationary Reciprocating Internal Combustion Engines: 40 CFR Part 63, Subpart ZZZZ.

Any permanent replacement engine located at either an area or major source is subject to the requirements of 40 CFR Part 63, Subpart ZZZZ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in any request for a permanent engine replacement.

2.3 Additional Sources

The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not a “routine replacement” of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for the addition of new emission points for any site; an engine that is being installed as an entirely new emission point and not as part of an AOS-approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process before installation.

October 31, 2023