Response to EPA Order on Kerr-McGee Source Determination/Aggregation

The files provided below comprise the Division's July 14, 2010 response to the October 8, 2009 Environmental Protection Agency (EPA) Order on the Title V renewal permit for the Kerr-McGee Frederick Station. This response includes a cover letter, the response document itself, and a series of attachments. The focus of the response is on the issues associated with the source determination for the Frederick Station, though many of the concepts discussed in the response apply more broadly to source aggregation questions for oil and gas facilities in Colorado.

• Colorado Department of Public Health and Environment (CDPHE) Response Cover Letter to Environmental Protection Agency (EPA)
• Colorado Department of Public Health and Environment (CDPHE) Response Document to Environmental Protection Agency (EPA)

• Attachment 1:
  • Environmental Protection Agency (EPA) Order Anadarko Frederick Station
• Attachment 2:
  • Air Pollution Control Division (APCD) Addendum to Frederick Technical Review Document (TRD)
• Attachment 3:
  • McCarthy Memo Re: Source Determinations for Oil and Gas
• Attachment 4:
  • Texas Guidance on Definition of Site
• Attachment 5:
  • Oklahoma Air Permitting Collocated Facilities
• Attachment 6:
  • Louisiana Contiguous for Oil & Gas Production Facilities
• Attachment 7:
  • Wyoming PowerPoint Presentation
• Attachment 8:
  • Request for Information to Anadarko Petroleum Re: Frederick Compressor Station
• Attachment 9:
  • Frederick Response-Noble Energy's Letter Request for Information
• Attachment 10:
  • Frederick Response EnCana Oil & Gas Letter Request for Information
• Attachment 11:
  • Frederick Response DCP Midstream Letter Request for Information
• Attachment 12:
  • Kerr-McGee Response Letter to Colorado Department of Public Health and Environment (CDPHE) Questions
• Attachment 13:
  • EnCana Oil & Gas Response to Air Pollution Control Division (APCD) Information Request
• Attachment 14:
  • DCP Midstream Response to Air Pollution Control Division (APCD) Information Request
• Attachment 15:
  • Noble Energy's Response to Air Pollution Control Division (APCD) Information Request
• Attachment 16:
  • Alaska BP Prudhoe Bay Unit (PBU) Statement of Basis
• Attachment 17:
  • Alaska Prudhoe Bay Environmental Protection Agency (EPA) Order Denying Petition
• Attachment 18:
  • Bracken Email to M. Burgett
• Attachment 19:
  • Wattenberg System Map
    • Note: this is a scaled down version of the full map, which is 46 by 38 inches and more than 17 megabytes in file size.
    • If you would like a CD containing the full-sized map please e-mail comments.apcd@state.co.us