                            	OMB No. 2060-0336,
   	Approval Expires 05/31/2019
   
 Federal Operating Permit Program (40 CFR Part 71)
 INITIAL COMPLIANCE PLAN AND COMPLIANCE CERTIFICATION (I-COMP)

SECTION A - COMPLIANCE STATUS AND COMPLIANCE PLAN
   Complete this section for each unique combination of applicable requirements and emissions units at the facility. List all compliance methods (monitoring, recordkeeping and reporting) you used to determine compliance with the applicable requirement described above.  Indicate your compliance status at this time for this requirement and compliance methods and check "YES" or "NO" to the follow-up question.     
   
   Emission Unit ID(s): EU-1  -  New 4SLB >500 HP at a Major Source of HAPs
   
   Applicable Requirement (Describe and Cite)
   
   40 CFR 63, Subpart ZZZZ  -  National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines
   
   Emission Limitations:
   
   §63.6600(b)
   Table 2a  -  point 2
   a. Reduce CO emissions by 93 percent or more; or
   b. Limit concentration of formaldehyde in the stationary RICE exhaust to 14 ppmvd or less at 15 percent O2
   
   General Requirements:
   
   §63.6595(b)(2)
   Any stationary RICE for which construction or reconstruction is commenced before your area source becomes a major source of HAP must be in compliance with the provisions of this subpart that are applicable to RICE located at major sources within 3 years after your area source becomes a major source of HAP.
   
   §63.6605
   (a) You must be in compliance with the emission limitations, operating limitations, and other requirements in this subpart that apply to you at all times.
   (b) At all times you must operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require you to make any further efforts to reduce emissions if levels required by this standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source.
   
   Compliance Requirements:
   
   §63.6600(b)
   Table 2b point 1: 
   a. maintain your catalyst so that the pressure drop across the catalyst does not change by more than 2 inches of water at 100 percent load plus or minus 10 percent from the pressure drop across the catalyst that was measured during the initial performance test; and 
   b. maintain the temperature of your stationary RICE exhaust so that the catalyst inlet temperature is greater than or equal to 450 °F and less than or equal to 1350 °F.
   
   §63.6610
   If you own or operate a stationary RICE with a site rating of more than 500 brake HP located at a major source of HAP emissions you are subject to the requirements of this section.
   (a) You must conduct the initial performance test or other initial compliance demonstrations in Table 4 to this subpart that apply to you within 180 days after the compliance date that is specified for your stationary RICE in § 63.6595 and according to the provisions in § 63.7(a)(2).
   
   §63.6615
   Table 3: Conduct subsequent performance tests semiannually.
   
   §63.6620
   Table 4: conduct testing per Points 1 or 3
   
   §63.6625
   (b) If you are required to install a continuous parameter monitoring system (CPMS) as specified in Table 5 of this subpart, you must install, operate, and maintain each CPMS according to the requirements in paragraphs (b)(1) through (6) of this section. For an affected source that is complying with the emission limitations and operating limitations on March 9, 2011, the requirements in paragraph (b) of this section are applicable September 6, 2011.
   (1) You must prepare a site-specific monitoring plan that addresses the monitoring system design, data collection, and the quality assurance and quality control elements outlined in paragraphs (b)(1)(i) through (v) of this section and in § 63.8(d). As specified in § 63.8(f)(4), you may request approval of monitoring system quality assurance and quality control procedures alternative to those specified in paragraphs (b)(1) through (5) of this section in your site-specific monitoring plan.
   (i) The performance criteria and design specifications for the monitoring system equipment, including the sample interface, detector signal analyzer, and data acquisition and calculations;
   (ii)Sampling interface (e.g., thermocouple) location such that the monitoring system will provide representative measurements;
   (iii)Equipment performance evaluations, system accuracy audits, or other audit procedures;
   (iv) Ongoing operation and maintenance procedures in accordance with provisions in § 63.8(c)(1)(ii) and (c)(3); and
   (v) Ongoing reporting and recordkeeping procedures in accordance with provisions in § 63.10(c), (e)(1), and (e)(2)(i).
   (2) You must install, operate, and maintain each CPMS in continuous operation according to the procedures in your site-specific monitoring plan.
   (3) The CPMS must collect data at least once every 15 minutes (see also § 63.6635).
   (4) For a CPMS for measuring temperature range, the temperature sensor must have a minimum tolerance of 2.8 degrees Celsius (5 degrees Fahrenheit) or 1 percent of the measurement range, whichever is larger.
   (5) You must conduct the CPMS equipment performance evaluation, system accuracy audits, or other audit procedures specified in your site-specific monitoring plan at least annually.
   (6) You must conduct a performance evaluation of each CPMS in accordance with your site-specific monitoring plan.
   
   §63.6630
   (a) You must demonstrate initial compliance with each emission limitation, operating limitation, and other requirement that applies to you according to Table 5 of this subpart.
   (b) During the initial performance test, you must establish each operating limitation in Tables 1b and 2b of this subpart that applies to you.
   (c) You must submit the Notification of Compliance Status containing the results of the initial compliance demonstration according to the requirements in § 63.6645.
   
   Table 5 Point 9
   i. The average formaldehyde concentration, corrected to 15 percent O2, dry basis, from the three test runs is less than or equal to the formaldehyde emission limitation; and
   ii. You have installed a CPMS to continuously monitor catalyst inlet temperature according to the requirements in § 63.6625(b); and
   iii. You have recorded the catalyst pressure drop and catalyst inlet temperature during the initial performance test.
   
   §63.6635
   (a) If you must comply with emission and operating limitations, you must monitor and collect data according to this section.
   (b) Except for monitor malfunctions, associated repairs, required performance evaluations, and required quality assurance or control activities, you must monitor continuously at all times that the stationary RICE is operating. A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions.
   (c) You may not use data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities in data averages and calculations used to report emission or operating levels. You must, however, use all the valid data collected during all other periods.
   
   §63.6640
   (a) You must demonstrate continuous compliance with each emission limitation, operating limitation, and other requirements in Tables 1a and 1b, Tables 2a and 2b, Table 2c, and Table 2d to this subpart that apply to you according to methods specified in Table 6 to this subpart.
   (b) You must report each instance in which you did not meet each emission limitation or operating limitation in Tables 1a and 1b, Tables 2a and 2b, Table 2c, and Table 2d to this subpart that apply to you. These instances are deviations from the emission and operating limitations in this subpart. These deviations must be reported according to the requirements in § 63.6650. If you change your catalyst, you must reestablish the values of the operating parameters measured during the initial performance test. When you reestablish the values of your operating parameters, you must also conduct a performance test to demonstrate that you are meeting the required emission limitation applicable to your stationary RICE.
   (e) You must also report each instance in which you did not meet the requirements in Table 8 to this subpart that apply to you. If you own or operate a new or reconstructed stationary RICE with a site rating of less than or equal to 500 brake HP located at a major source of HAP emissions (except new or reconstructed 4SLB engines greater than or equal to 250 and less than or equal to 500 brake HP), a new or reconstructed stationary RICE located at an area source of HAP emissions, or any of the following RICE with a site rating of more than 500 brake HP located at a major source of HAP emissions, you do not need to comply with the requirements in Table 8 to this subpart: An existing 2SLB stationary RICE, an existing 4SLB stationary RICE, an existing emergency stationary RICE, an existing limited use stationary RICE, or an existing stationary RICE which fires landfill gas or digester gas equivalent to 10 percent or more of the gross heat input on an annual basis. If you own or operate any of the following RICE with a site rating of more than 500 brake HP located at a major source of HAP emissions, you do not need to comply with the requirements in Table 8 to this subpart, except for the initial notification requirements: a new or reconstructed stationary RICE that combusts landfill gas or digester gas equivalent to 10 percent or more of the gross heat input on an annual basis, a new or reconstructed emergency stationary RICE, or a new or reconstructed limited use stationary RICE.
   
   Notification Requirements: 
   
   §63.6645
   (a) You must submit all of the notifications in §§ 63.7(b) and (c), 63.8(e), (f)(4) and (f)(6), 63.9(b) through (e), and (g) and (h) that apply to you by the dates specified
   
   Reporting Requirements:
   §63.6650
   (a) You must submit each report in Table 7 of this subpart that applies to you.
   
   Recordkeeping Requirements:
   §63.6655
   (a) If you must comply with the emission and operating limitations, you must keep the records described in paragraphs (a)(1) through (a)(5), (b)(1) through (b)(3) and (c) of this section.
   (1) A copy of each notification and report that you submitted to comply with this subpart, including all documentation supporting any Initial Notification or Notification of Compliance Status that you submitted, according to the requirement in § 63.10(b)(2)(xiv).
   (2) Records of the occurrence and duration of each malfunction of operation (i.e., process equipment) or the air pollution control and monitoring equipment.
   (3) Records of performance tests and performance evaluations as required in § 63.10(b)(2)(viii).
   (4) Records of all required maintenance performed on the air pollution control and monitoring equipment.
   (5) Records of actions taken during periods of malfunction to minimize emissions in accordance with § 63.6605(b), including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation.
   (b) For each CEMS or CPMS, you must keep the records listed in paragraphs (b)(1) through (3) of this section.
   (1) Records described in § 63.10(b)(2)(vi) through (xi).
   (2) Previous (i.e., superseded) versions of the performance evaluation plan as required in § 63.8(d)(3).
   (3) Requests for alternatives to the relative accuracy test for CEMS or CPMS as required in § 63.8(f)(6)(i), if applicable.
   (d) You must keep the records required in Table 6 of this subpart to show continuous compliance with each emission or operating limitation that applies to you.
   
   §63.6660
   (c) You must keep each record readily accessible in hard copy or electronic form for at least 5 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record, according to § 63.10(b)(1).
   
   Compliance Methods for the Above (Description and Citation):
   
   Targa will install an oxidation catalyst to control the emissions of either CO or formaldehyde
   
   
   Compliance Status:
   
   _X_ In Compliance:  Will you continue to comply up to permit issuance?  _X__ Yes    ____No
   
   ___ Not In Compliance: Will you be in compliance at permit issuance?  ___Yes    ___No    
   
   ___ Future-Effective Requirement:  Do you expect to meet this on a timely basis? ____Yes  ____No
   
   
         
 SCHEDULE OF COMPLIANCE
      
   
   Complete this section if you answered "NO" to any of the questions in section A.  Also, complete this section if required to submit a schedule of compliance by an applicable requirement. Please attach copies of any judicial consent decrees or administrative orders for this requirement.       
   
   Unit(s)____________________ Requirement_____________________________________________
   
   Reason for Noncompliance.   Briefly explain reason for noncompliance at time of permit issuance or that future-effective requirement will not be met on a timely basis:
   
   
   Narrative Description of how Source Compliance Will be Achieved.   Briefly explain your plan for achieving compliance: 
   
   
   Schedule of Compliance.   Provide a schedule of remedial measures, including an enforceable sequence of actions with milestones, leading to compliance, including a date for final compliance.
   
   
   
   	Remedial Measure or Action
                                         
                              Date to be Achieved
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
         
   
    
   
   


C.  SCHEDULE FOR SUBMISSION OF PROGRESS REPORTS

   Only complete this section if you are required to submit one or more schedules of compliance in section B or if an applicable requirement requires submittal of a progress report.  If a schedule of compliance is required, your progress report should start within 6 months of application submittal and subsequently, no less than every six months.  One progress report may include information on multiple schedules of compliance.
   
   Contents of Progress Report (describe):  
   
   
   First Report____/____/___  Frequency of Submittal_______________
   
   Contents of Progress Report (describe):
   
   
   First Report____/____/___  Frequency of Submittal_______________
   
   
   
   
   D.  SCHEDULE FOR SUBMISSION OF COMPLIANCE CERTIFICATIONS
   
   
   This section must be completed once by every source.  Indicate when you would prefer to submit compliance certifications during the term of your permit (at least once per year).
     
   Frequency of submittal______________________ Beginning____/____/____ 
      
      
      
 COMPLIANCE WITH ENHANCED MONITORING & COMPLIANCE CERTIFICATION REQUIREMENTS
    
   
   This section must be completed once by every source.  To certify compliance with these, you must be able to certify compliance for every applicable requirement related to monitoring and compliance certification at every unit.
   
   Enhanced Monitoring Requirements:           ____ In Compliance      ____ Not In Compliance 
   
   Compliance Certification Requirements:      ____ In Compliance      ____ Not In Compliance 
                                         
                             INSTRUCTIONS FOR I-COMP
               INITIAL COMPLIANCE PLAN AND COMPLIANCE CERTIFICATION
   
   Section A (Compliance Status and Compliance Plan)
   
   Description of Applicable Requirement:  Complete Section A for each unique combination of applicable requirements (emission limitations, standards or other similar requirements of federal rules, SIP, TIP, FIP, or federally-enforceable permits) that apply to particular emissions units. You will likely have to complete this section numerous times to include all requirements at all emission units.  
   
   The emissions unit ID(s) should be the ones defined in section I of form GIS.  If the requirement, including compliance method, applies in the same way to multiple emission units, you may list multiple units for a particular requirement.
   
   The descriptions here should be detailed to the individual requirement level, rather than the standard level (if a MACT applies to you, describe each requirement of the MACT, rather than just a citation to the MACT as a whole). If the requirement imposes a particular numerical limit or range, include that in your description.
   
   Citations to the requirements should unambiguously identify the requirement to the lowest level necessary. 
   
   Compliance Methods:  List all compliance methods (monitoring, recordkeeping and reporting) you used to determine compliance with the applicable requirement described above.  Such methods may be required by the applicable requirements or performed for other reasons.  List all compliance methods required by applicable requirements, whether you used them to determine compliance or not.
   
   To describe monitoring, indicate the monitoring device, the equipment, process, or pollutant monitored, averaging time, frequency, and a citation or cross-reference to the requirement.  To describe recordkeeping, describe the records kept, the frequency of collection, and include a citation or cross-reference to the requirement.  Please indicate whether monitoring data, results, or other records kept for compliance purposes may be kept on-site rather than reported.  To describe reporting requirements, describe what is reported, when it is reported, and cite or cross-reference the requirement.
   
   The citation or cross-reference here must unambiguously identify the requirement to the lowest level necessary. 
   
   Note that Compliance Assurance Monitoring (CAM) under part 64 is also an applicable requirement that may impose compliance methods for title V sources and require the submittal of a CAM plan with this application.  Also note that periodic monitoring (which may be monitoring or recordkeeping designed to serve as monitoring) under part 71 may be required in certain limited circumstances: when there is no monitoring required, monitoring is required but there is no frequency specified, or only a one-time test is required.  You may propose periodic monitoring in your application, but the permitting authority will make the final decision. If you wish to propose periodic monitoring, please do so in an attachment that clearly identifies the requirements, the units they apply to, and what you propose for periodic monitoring.
   
   Compliance Status:  For each requirement and associated compliance methods described above, indicate whether you are in compliance, not in compliance, or it is a future-effective requirement (only check one). This is with respect to your compliance status at the time of application submittal.  You should consider all available information or knowledge that you have when evaluating your compliance status, including reference test methods and other compliance requirements that are required directly by a statute, regulation, or permit and "credible evidence" (e.g., non-reference test methods and other information "readily available" to you and already being utilized by you).  For each compliance status indication, you must answer "YES" or "NO" as to your expectations for continuing (or future) compliance.  If you answer "NO" to any of these questions, you will have to complete the schedule of compliance section (section B).
   
   Section B (Schedule of Compliance)
   
   Complete this section if you answered "NO" to any of the questions in section A.  Regardless of how you answered the questions in section A, complete this section if required to have a schedule of compliance by an applicable requirement, or if a judicial consent decree or administrative order includes a schedule of compliance.  
   
   Identify the applicable requirement using the same information you used in section A.  Provide a brief explanation of the reason for noncompliance (either now or in the future). [e.g., "do not have control device required as BACT."]  Next, provide a brief description of what the schedule of compliance is trying to achieve.  Then in the table provided, include a detailed schedule of remedial measures, including an enforceable sequence of actions with milestones, leading to compliance with the applicable requirement.  This schedule shall resemble and be at least as stringent as that contained in any judicial consent decree or administrative order to which the source is subject.  Any such schedule of compliance must be supplemental to, and not sanction noncompliance with, the applicable requirements on which it is based.  For each remedial measure, provide the date by which the action will be completed.  This schedule or one approved by the permitting authority will be included in the permit.  
   
   Lastly, attach a copy of any judicial consent decrees or administrative orders for which you are providing a schedule of compliance.
   
   Section C (Schedule for Submission of Progress Reports)
   
   If you must submit one or more schedules of compliance (specified in section B), or if an applicable requirement requires submittal of a progress report, complete this section.  Progress reports describe your progress in meeting the milestone dates for the remedial measures required by the schedule of compliance.  Progress reports must be submitted at least every 6 months, but specific applicable requirements may require them more frequently.  One progress report may include information on one or more schedules of compliance.  Describe the contents of the progress report, including the date that your facility will begin submitting them and the frequency they will be submitted.
   
   Section D (Schedule for Submission of Compliance Certifications)
   
   All applicants must complete this section.  Compliance certifications must be submitted at least every year unless the applicable requirement or EPA requires them more frequently.  Provide the date when the first compliance certification will be sent.
   
   Section E (Compliance Status for Enhanced Monitoring and Compliance Certification)
   
   All applicants must complete this section.  The completion of this section does not satisfy the requirement for the responsible official to submit a certification of truth, accuracy, and completeness (instead, this is met by completing form CTAC and submitting it with the other forms you send to EPA).  
   
   To certify compliance with "Enhanced Monitoring," you must be in compliance at all emission units with CAM and "Periodic Monitoring" [required by 40 CFR 71.6(a)(3)(i)(B)], if they apply.  "Compliance Certification Requirements" include requirements for compliance certification in title V applications and permits, and possibly through applicable requirements (e.g., certain MACT standards).  If you have fully completed sections A - E of this form, you will be in compliance with the compliance certification requirement for applications.  If you do not have a title V permit at this time, you can assume you are in compliance with the compliance certification requirements for permits and with periodic monitoring requirements.  If you indicate you are "not in compliance" with either of these requirements, attach an explanation.
   
                                       END
