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 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
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REGION 8
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1595 Wynkoop Street
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Denver, CO  80202-1129
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Phone (800) 227-8917
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www.epa.gov/region8
Ref: 8ARD-PM

Mr. Danny Powers
Air Quality Program Manager
Southern Ute Indian Tribe Environmental Programs 
P.O. Box 737, Mail Slot #84
Ignacio, Colorado  81137-0737
Via email: dpowers@southernute-nsn.gov

Re:	Arkoma Operations, Ignacio Gas Treating Plant, Permit # SMNSR-SU-000052-2021.004,  Proposed Synthetic Minor New Source Review Permit

Dear Mr. Powers:

The U.S. Environmental Protection Agency Region 8 is proposing to issue a revised synthetic Tribal Minor New Source Review (MNSR) permit for the existing previously owned by Catamount Energy Partners, LLC's (Catamount) and currently owned by Arkoma Operations (Arkoma), Ignacio Gas Treating Plant (Ignacio) on the Southern Ute Indian Reservation. As requested by Arkoma, this permit would incorporate several changes. Arkoma requested permit revisions that would modify the existing monitoring and recordkeeping requirements to allow the facility to operate with permit conditions more consistent with other similar true minor sources. 

The requested revisions do not result in an increase in allowable emissions. In the proposed permit, EPA has included some additional conditions to ensure enforceability of the requested revisions. The proposed permit reflects changes to emission calculation requirements, control and operational requirements and monitoring and recordkeeping requirements for the triethylene glycol (TEG) dehydration systems. Also, the proposed permit reflects changes to control, operation, monitoring and maintenance requirements for the 4-stroke lean-burn (4SLB) compressor engines. Lastly, the proposed permit reflects the recent termination of a consent decree (Civil Action No. 12.cv.02584.REB.KLM) which the facility historically operated under. On May 3, 2021, Catamount filed a change in ownership (Form OWN) for the Ignacio Plant to Arkoma Operations, LLC (Arkoma) which has also been reflected in the proposed permit.

A public comment period for the proposed permit will begin on July 22, 2021, and end on August 21, 2021.

The proposed permit and supporting documentation are available in the electronic docket at Regulations.gov (Docket ID #EPA-R08-OAR-2021-0515), and we ask that you please assist members of the public who contact you with instructions on how to access the material available for public review until the end of the public comment period. Comments may be submitted via email to R8AirPermitting@epa.gov, or through https://www.regulations.gov (Docket ID #EPA-R08-OAR-2021-0515). In addition, we have provided copies of the bulletin board public notice announcement and 


would appreciate it if you could post this announcement in prominent locations in your area. All of these documents will also be available for review in electronic format on our website at: https://www.epa.gov/caa-permitting/caa-permit-public-comment-opportunities-region-8. 

If you have any questions concerning the enclosed proposed permit or technical support documents, please contact Lohitaksha (Lo.) Rao, of my staff, at (303) 312-6241 or at rao.lohitaksha@epa.gov.   
                                          
                                       Sincerely,
                                                
                                      Carl Daly
                                      Acting Director
                                      Air and Radiation Division
                                      
                                      
Enclosures



