HomeMy WebLinkAbout20130867.tiffSTATE OF COLORADO
John W. Hickenlooper, Governor
Christopher E. Urbina, MD, MPH
Executive Director and Chief Medical Officer
Dedicated to protecting and improving the health and environment of the people of Colorado
4300 Cherry Creek Dr. S. Laboratory Services Division
Denver, Colorado 80246-1530 8100 Lowry Blvd.
Phone (303) 692-2000 Denver, Colorado 80230-69281.RECEIVED.
Located in Glendale, Colorado (303) 692-3090
http://www.Cdphe.state.co.us
APR a k StJ13
March 29, 2013 WELD COUNT'? _.
Weld County Clerk & Recorder COMMISSIONER
1402 N 17th Ave
Greeley, CO 80631
Dear Sir or Madam:
Colorado Department
of Public Health
and Environment
On April 3, 2013, the Air Pollution Control Division will publish a public notice for Carrizo Oil & Gas, Inc. —
Pergamos 8-41-7-60, in the The Greeley Tribune. A copy of this public notice and the public comment packet are
enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public
copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet
must be available for public inspection for a period of thirty (30) days from the date the public notice is published.
Please send any comment regarding this public notice to the address below.
Colorado Dept. of Public Health & Environment
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Ellen Evans
Regards,
Ellen Evans
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
743
CC- f t ►- `/'T
2013-0867
Stephanie Chaousy
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-Bl
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO: 12WE2815
DATE ISSUED:
ISSUED TO:
Carrizo Oil & Gas, Inc.
Issuance 1
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Natural gas production facility, known as Pergamos 8-41-7-60, located in the NENE of
Section 8, Township 7 North, Range 60 West, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment ID
AIRS
Point
Description
SEPARATOR
005
Separator controlled by a flare stack. Flare has a minimum
combustion efficiency of 95%. The flare is not enclosed.
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 AUTHORIZATION
1. YOU MUST notify the APCD no later than fifteen days after issuance of this permit or
activity by submitting a Notice of Startup (NOS) form to the APCD. The Notice of Startup
(NOS) form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html.
Failure to notify the APCD of startup of the permitted source is a violation of AQCC
Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit.
2. Within one hundred and eighty days (180) after issuance of this permit, compliance with the
conditions contained on this permit shall be demonstrated to the Division. It is the permittee's
responsibility to self -certify compliance with the conditions. Failure to demonstrate
compliance within 180 days may result in revocation of the permit. (Reference: Regulation
No. 3, Part B, II.G.2).
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction for a period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
estimated completion date. The Division may grant extensions of the deadline per
Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.)
AIRS ID: 123/9A32 Page 1 of 7
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4. The operator shall 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 No. 3, Part B, Section III.E.)
5. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
blic Health and Environment
Air Pollution Control Division
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission Type
yp
NO„
VOC
CO
SEPARATOR
005
0.9
11.3
4.9
Point
See "Notes to Permit Holder #4" for information on emission factors and methods used to calculate
limits.
Compliance with the synthetic minor status of this facility shall be determined by recording
the facility's annual criteria pollutant emissions, from each emission unit, on a rolling (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 shall calculate monthly emissions and keep
a compliance record on site or at a local field office with site responsibility, for Division
review. This rolling twelve-month total shall apply to all emission units, requiring an APEN, at
this facility.
7. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
SEPARATOR
005
Open flare
VOC
PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum consumption, processing and/or
operational rates as listed below. Monthly records of the actual crude oil throughput shall 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
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
SEPARATOR
005
Natural gas flaring
18.6 MMSCF/yr
Compliance with the yearly natural gas throughput limits shall be determined on a rolling
twelve (12) month total. By the end of each month a new twelve-month total is calculated
AIRS ID: 123/9A32
Page 2 of 7
P*blic Health and Environment
Air Pollution Control Division
based on the previous twelve months' data. The permit holder shall calculate monthly
natural gas throughput and keep a compliance record on site or at a local field office with site
responsibility, for Division review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
9. The permit number and AIRS ID number shall be marked on the subject equipment for ease
of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable)
10. Visible emissions shall 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 shall not exceed 30% opacity for more than six minutes in any
sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.1. & 4.)
11. No owner or operator of a smokeless flare or other flare for the combustion of waste
gases shall allow or cause emissions into the atmosphere of any air pollutant which is in
excess of 30% opacity for a period or periods aggregating more than six minutes in any
sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.5.).
12. These sources are subject to the odor requirements of Regulation No. 2. (State only
enforceable)
OPERATING & MAINTENANCE REQUIREMENTS
13. Upon startup of these points, the applicant shall follow the operating and maintenance (O&M)
plan and record keeping format approved by the Division, in order to demonstrate compliance
on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are
subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B,
Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
14. The operator shall complete an initial site specific extended gas analysis of the natural gas
produced at this site that is routed to the open flame flare in order to verify the VOC,
benzene, toluene, ethylbenzene, xylenes, n -hexane content (weight fraction) of this emission
stream used in the permit application. Results of testing shall be used to determine site -
specific emission factors using Division approved methods. Results of site -specific sampling
and analysis shall be submitted to the Division as part of the self -certification and used to
demonstrate compliance with the emissions factors chosen for this emissions point.
For example, the benzene emission factor shall be calculated according to the following
equation using the benzene weight fraction and the natural gas's average molecular weight
determined in the site -specific gas analysis:
2b,Laat's .71,424,3,
Pawl iey,SPy"yA 'A+Sb_u^r 73'm7, .
15. The owner or operator shall demonstrate compliance with Condition 10 using EPA Method 9
to measure opacity from the flare. (Reference: Regulation No. 1, Section II.A.5).
Periodic Testing Requirements
16. The owner or operator shall sample the gas routed to the flare to determine the heat content
on an annual basis
AIRS ID: 123/9A32 Page 3 of 7
P Health and Environment
Air Pollution Control Division
ADDITIONAL REQUIREMENTS
17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3,
Part A, II.C)
a. Annually whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of
five (5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOx per year, a change
in annual actual emissions of one (1) ton per year or more or five percent, whichever
is greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of
five percent or 50 tons per year or more, whichever is less, 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, or
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.
18. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall
apply to this source at any such time that this source becomes major solely by virtue of a
relaxation in any permit condition. Any relaxation that increases the potential to emit above
the applicable Federal program threshold will require a full review of the source as though
construction had not yet commenced on the source. The source shall not exceed the
Federal program threshold until a permit is granted. (Regulation No. 3 Part D).
GENERAL TERMS AND CONDITIONS
19. 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 APCD as provided in AQCC
Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
20. If this permit specifically states that final authorization 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 operation of this source. Final authorization of
the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD 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
AIRS ID: 12319A32 Page 4 of 7
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written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self -Certify for Final Authorization
section of this permit.
21. 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.
22. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
23. 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 shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (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 review of the
Division's action.
24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
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.
25. 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.
blic Health and Environment
Air Pollution Control Division
By:
Stephanie Chaousy, PE
Permit Engineer
Air Pollution Control Division
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Facility -wide permit for: (1) process flare. New
synthetic minor source facility.
AIRS ID: 123/9A32
Page 5 of 7
oloray, DepiAm tif... P blic Health and Erivironment
Air Pollution Control Division
Notes to Permit Holder:
1) The production or raw material processing limits and emission limits contained in this permit are based on
the consumption 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 shall 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 of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See:
http://www. cdphe. state.co.us/requlations/airregs/100102 aacccom m onprovisionsrea. pdf.
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 #
BIN
Uncontrolled
Emission
Rate
(Ib/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (Ib/yr)
005
Benzene
71432
A
1802
Yes
90
Toluene
108883
C
1429
Yes
71
Ethylbenzene
100414
C
182
No
9
Xylenes
1130207
C
537
No
27
n -Hexane
110543
C
10375
Yes
519
4) The emission levels contained in this permit are based on the following emission factors:
Point 003:
CAS #
Pollutant
Weight
Fraction of
Gas (%)
Emission
Factors
Uncontrolled
Emission Factors
Controlled
Source
NOx
_
0.068
Ib/MMBtu
0.068 lb/MMBtu
AP -42
CO
---
0.37 lb/MMBtu
0.37 lb/MMBtu
AP -42
VOC
36.64
24325.3720
lb/MMSCF
1216.27
lb/mmscf
Engineering
Calculation
71432
Benzene
0.146
96.8770
Ib/MMSCF
4.8439 lb/mmscf
Engineering
Calculation
108883
Toluene
0.116
76'8322
lb/MMSCF
3.8416 lb/mmscf
Engineering
Calculation
100414
Ethyl benzene
0.015
9'8046
lb/MMSCF
0.4902 lb/mmscf
Engineering
Calculation
1330207
Xylenes
0.0431.4427
28.8536
1b/MMSCF
lb/mmscf
Engineering
Calculation
110543
n -hexane
0.84
557.7824
lb/MMSCF
27.8891 lb/mmscf
Engineering
Calculation
AIRS ID: 123/9A32
Page 6 of 7
mitblic Health and Environment
Air Pollution Control Division
Note: The uncontrolled VOC and HAP emissions for this point were calculated using the August 22,
2012 analysis of a gas sample collected from the Pergamos 8-41 well. The controlled VOC
and HAP emissions factors for point 005 are based on the flare control efficiency of 95%.
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 shall 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
Synthetic minor Source:
VOC
NANSR
Synthetic Minor Source:
VOC
MACT HH
Area Source Requirements: Not Applicable
7) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at
the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A — Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A — Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A — Subpart Z
MACT
63.600-63.1199
Subpart AA — Subpart DDD
MACT
63.1200-63.1439
Subpart EEE — Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ — Subpart YYYY
MACT
63.6580-63.8830
Subpart 7777 - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN — Subpart XXXXXX
8) An Oil and Gas Industry Construction Permit Self -Certification Form is included with this permit packet.
Please use this form to complete the self -certification requirements as specified in the permit conditions.
Further guidance on self -certification can be found on our website at:
http://www.cdphe.state.co.us/ap/oilgaspermittina.html
AIRS ID: 123/9A32
Page 7 of 7
Construction Permit Application
Preliminary Analysis Summary
Section 1 — Applicant Information
Company Name:
Carrizo Oil & Gas, Inc.
Permit Number:
12WE2815
Source Location:
NENE S8, T7N, R60W, Weld County (non -attainment)
Equipment Description
Plant flare with a minimum combustion efficiency of 95%.
AIRS ID:
123-9A32-005
Date:
February 14, 2013
Review Engineer:
Stephanie Chaousy, P.E.
Control Engineer:
Chris Laplante
Section 2 — Action Completed
Grandfathered
Modification
APEN Required/Permit Exempt
X
CP1
Transfer of Ownership
APEN Exempt/Permit Exempt
*If tank is a true minor source at a true minor facility, it shall be granted "Final Approval"
Section 3 — Applicant Completeness Review
Was the correct APEN submitted for this source type?
X
Yes
No
Is the APEN signed with an original signature?
X
Yes
No
Was the APEN filled out completely?
X
Yes
No
Did the applicant submit all required paperwork?
Yes
X
No
Did the applicant provide ample information to determine emission rates?
X
Yes
No
If you answered "no" to any of the above, when did you mail an
Information Request letter to the source?
Please see Section 14
On what date was this application complete?
September 24, 2012
Section 4 — Source Description
AIRS Point
Equipment Description
005
Plant flare used to control gas stream. Flare has a minimum combustion efficiency
of 95%. The flare is enclosed.
Is this a portable source?
Yes
X
No
Is this location in a non -attainment area for any criteria
pollutant?
X
Yes
No
If "yes", for what pollutant?
PM,()
CO
X
Ozone
Is this location in an attainment maintenance area for
an criteria ollutant?
Yes
X
No
If "yes", for what pollutant?
(Note: These pollutants are subject to minor source
RACT per Re ulation 3, Part B, Section IIl.D.2)
PM10
CO
Ozone
Is this source located in the 8 -hour ozone non -
attainment region? (Note: If "yes" the provisions of
Regulation 7, Sections XII and XVI1.C may apply)
X
Yes
No
Page 1
Section 5 — Emission Estimate Information
AIRS Point
Emission Factor Source
005
AP -42, Table 13.5-1 for NOx and CO. Mass balance for VOC. Please see Section 14
for calculations.
Did the applicant provide actual process data for the emission inventory?
X
Yes
No
Basis for Potential to Emit (PTE)
AIRS Point
Process Consumption/Throughput/Production
005
18.6 MMCF/yr
Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory)
AIRS Point
Process Consumption/Throughput/Production
Data Year
005
18.6M MCF/yr
2012
Basis for Permitted Emissions (Permit Limits)
AIRS Point
Process Consumption/Throughput/Production
005
18.6 MMCF/yr
Does this facility use control devices?
X
Yes
No
AIRS Point
Process
Control Device Description
% Reduction
Granted
005
01
Flare
95
Section 6 — Emission Summary (tons per year)
Point
NO,
VOC
CO
SOx
PM10
Single HAP
Total
HAP
PTE:
005
0.9
226.2
4.9
---
---
5.2 (n -hexane)
7.2
Uncontrolled point
source emission rate:
005
0.9
226.2
4.9
---
---
5.2 (n -hexane)
7.2
Controlled point
source emission rate:
005
0.9
11.3
4.9
---
--
0.26 (n -hexane)
0.4
Section 7 — Non -Criteria / Hazardous Air Pollutants
Pollutant
CAS #
BIN
Uncontrolled
Emission Rate
tlb/yr}
Are the
ssio sEmission
reportable?
Controlled
Rate (Ibty)
Benzene
71432
A
1802
Yes
90
Toluene
108883
C
1429
Yes
71
Ethylbenzene
100414
C
182
No
9
Xylenes
1330207
C
537
No
27
n -Hexane
110543
C
10375
Yes
519
Note: Regulation 3, Part A, Section II.B.3.b APEN emission reporting requirements for non -criteria air
pollutants are based on potential emissions without credit for reductions achieved by control
devices used by the operator.
Section 8 —Testing Requirements
Will testing be required to show compliance with any emission rate or regulatory
standard?
X
Yes
No
If "yes", complete the information listed below
AIRS Point
Process
Pollutant
Regulatory Basis
Test Method
Page 2
005
01
VOC,
HAPS
State only requirement
Site specific gas
analysis
Section 9 - Source Classification
Is this a new previously un-permitted
source?
X
Yes
No
What is this point classification?
True
Minor
X
Synthetic
Minor
Major
What is this facility classification?
True
Minor
X
Synthetic
Minor
Major
Classification relates to what
programs?
X
Title V
PSD
X
NA NSR
MACT
Is this a modification to an existing permit?
Yes
X
No
If "yes" what kind of modification?
Minor
Synthetic Minor
Major
Section 10 — Public Comment
Does this permit require public comment per CAQCC Regulation 3?
X
Yes
No
If "yes", for which pollutants? Why?
For Reg. 3, Part B, III.C.1.a (controlled emissions increase > 25/50
tpy)?
Yes
X
No
For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)?
Yes
X
No
For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)?
X
Yes
No
Section 11 —Modeling
Is modeling required to demonstrate compliance with National Ambient
Air Quality Standards (NAAQS)?
If "yes", for which pollutants? Why?
NOx emissions are less than 40 TPY.
Yes
X
No
AIRS Point
Section 12 — Regulatory Review
°= . =
Regulatioh 1 - Paitiic alate, Smoke, Carbon Morroxideland SuifttraDioxide tat=
005
Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator
of a source shall allow or cause the emission into the atmosphere of any air pollutant which
is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings
taken at 15 -second intervals for six minutes. The approved reference test method for
visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July,
1992)) in all subsections of Section II. A and B of this regulation.
Section II.A.5 - Smokeless Flare or Flares for the Combustion of Waste Gases No owner
or operator of a smokeless flare or other flare for the combustion of waste gases shall
allow or cause emissions into the atmosphere of any air pollutant which is in excess of
30% opacity for a period or periods aggregating more than six minutes in any sixty
consecutive minutes.
Requlation_2._Odor° =-.
005
Section LA - No person, wherever located, shall cause or allow the emission of odorous air
contaminants from any single source such as to result in detectable odors which are
measured in excess of the following limits: For areas used predominantly for residential or
commercial purposes it is a violation if odors are detected after the odorous air has been
diluted with seven (7) or more volumes of odor free air.
Page 3
'Regulation3=>APENs, Construction Permits, -Operating. Permits, PSD=-='
005
Part A-APEN Requirements
Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for:
each individual emission point in a non -attainment area with uncontrolled actual emissions
of one ton per year or more of any individual criteria pollutant (pollutants are not summed)
for which the area is non -attainment.
(Applicant is required to file an APEN since emissions from production exceed 1 ton
per year VOC)
005
Part B — Construction Permit Exemptions
Applicant is required to file a permit since uncontrolled VOC emissions are greater
than the 20 TPY threshold (Reg. 3, Part B, Section 11.D.2.a)
.,v
Reaulation t- New Source Performance Standards, =
005
None
Regulation 7„,,,Volatile—Organic Compounds'
005-
None
.r
-Regulation 8 =Hazardous Air_Pollutants r.
005
None
Section 13—Aerometric Information
Retrieval System Coding Information
Point
Process
Process Description
Emission
Factor
Pollutant/
CAS #
Fugitive
(Y/N)
Emission Factor
Source
Control
(%)
005
01
Flare
-
24325.3720
Ib/MMSCF
VOC
No
Engineering
Calculation
95
0.068
lb/MMBtu
NOx
-
No
AP -42,
Table 13.5-1
NA
0.37
lb/MMBtu
CO
No
AP -42,
Table 13.5-1
NA
96.8770
lb/MMSCF
Benzene
No
Engineering
Calculation
95
76.8322
lb/MMSCF
Toluene
No
• Engineering
Calculation
95
9.8046
lb/MMSCF
Ethylbenzene
No
Engineering
Calculation
95
28.8536
Ib/MMSCF
X lenes
y
No
Engineering
Calculation
95
557.7824
Ib/MMSCF
n -hexane
No
Engineering
Calculation
95
SCC
31000205 -Flares
Section 14 —Miscellaneous Application Notes
AIRS Point
005
Process flare
A permit will be issued because the uncontrolled VOC emissions are greater than 2 TPY (permit
threshold).
The operator provided revised calculations via email on 2/14/13. The PA and APENS were updated
accordingly.
Site -specific uncontrolled emission factors calculated from the separator spreadsheet:
VOC 24325.3720 lb/MMscf natural gas vented
Benzene 96.8770 lb/MMscf natural gas vented
Toluene 76.8322 lb/MMscf natural gas vented
Ethylbenzene 9.8046 lb/MMscf natural gas vented
Xylenes 28.8536 lb/MMscf natural gas vented
n -Hexane 557.7824 lb/MMscf natural gas vented
Page 4
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