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HomeMy WebLinkAbout20140748.tiff STATE OF COLORADO John W.Hickenlooper,Governor Larry Wolk,MD,MSPH . nozo Executive Director and Chief Medical Officer e; Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr.S. Laboratory Services Division •'8 • Denver,Colorado 80246-1530 8100 Lowry Blvd. Phone(303)692.2000 Denver,Colorado 80230-6928 Colorado Department Located in Glendale,Colorado (303)692-3090 of Public Health www.colorado.gov/edphe and Environment Weld County—Clerk to the Board 1150 O Street PO Box 758 Greeley,CO 80632 March 6, 2014 Dear Sir or Madam: On March 9,2014,the Air Pollution Control Division will publish a public notice for Carrizo Oil&Gas, Inc. —Speaker 1-27-31-8-61, 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 RECEIVED Denver, Colorado 80246-1530 Attention: Clara Gonzales " Regards, • COMMISSIONERS 2014 I ( G_k.cty Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure (-FWDltt..)7 fie. . i L ,?IA)f kit 3•aW• I`i 3 I1•l4 2014-0748 STATE OF COLORADO John W.Hickenlooper,Governor Larry Wolk,MD,MSPH coy'coto Executive Director and Chief Medical Officer Nr. Dedicated to protecting and improving the health and environment of the people of Colorado x 4300 Cherry Creek Dr.S. Laboratory Services Division • Denver,Colorado 80246-1530 8100 Lowry Blvd. rare Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department Located in Glendale,Colorado (303)692-3090 of Public Health www.colorado.gov/cdphe and Environment Website Title: Carrizo Oil &Gas, Inc.—Speaker 1-27-31-8-61 —Weld County Released To: The Greeley Tribune On: March 6,2014 Published: March 9, 2014 PUBLIC NOTICE OF A PROPOSED PROJECT OR ACTIVITY WARRANTING PUBLIC COMMENT Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Carrizo Oil&Gas, Inc. Facility: Speaker 1-27-31-8-61 oil and gas exploration and production site NNWNE, Section 27,T8N, R61 W Weld County,Colorado) Weld County The proposed project or activity is as follows: The operator proposes to obtain a permit allowing the operation of a flare to combust well-gas. Permitted throughput of well gas is 16.3 MMscf/year The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application,the Division's analysis,and a draft of Construction Permit 13WE2798 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at www.colorado.gov/cdphe/AirPublicNotices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such comment must be submitted in writing to the following addressee: Christian Lesniak Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B I Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us DRAFT STATE OF COLORADO etc, COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT IT- A IR POLLUTION CONTROL DIVISION TELEPHONE:(303)692-3150 •1876 CONSTRUCTION PERMIT PERMIT NO: 13WE2798 Issuance 1 DATE ISSUED: ISSUED TO: Carrizo Oil & Gas, Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Crude oil and natural gas exploration and production facility, known as Speaker 1-27-31-8- 61, located in the NWNE of Section 27,Township 8 North, Range 61 West, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID SEPARATOR 006 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 at 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/d own loadforms.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 AIRS ID: 123/9715 Page 1 of 8 Condensate Tank Version 2009-1 DRAFTColorado Department of Public Health and Environment Air Pollution Control Division application associated with this permit;(ii)discontinues construction for a period of eighteen months or more; (Hi) 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.) 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. 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 AIRS Tons per Year Equipment ID Point NO, VOC CO Emission Type SEPARATOR 006 -- 12.41 4.61 Point See "Notes to Permit Holder#4"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. 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 AIRS Control Device Pollutants Equipment ID Point Controlled SEPARATOR 006 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 natural gas 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) AIRS ID: 123/9715 Page 2 of 8 DRA FTColorado Department of Public Health and Environment Air Pollution Control Division Process/Consumption Limits Facility AIRS Process Parameter Annual Limit Equipment ID Point SEPARATOR 006 Natural gas flaring 16.3 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 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. 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.). 11. These sources are subject to the odor requirements of Regulation No. 2. (State only enforceable) OPERATING & MAINTENANCE REQUIREMENTS 12. 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 13. 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). 14. The operator shall complete an initial site specific extended gas analysis of the natural gas produced at this site in order to verify the VOC, benzene,toluene,ethylbenzene,xylenes,n- hexane,and 2,2,4-trimethylpentane 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. Periodic Testing Requirements 15. The owner or operator shall demonstrate compliance with Condition 10 using EPA Method 9 to measure opacity from the flare on an annual basis, in any year during which the flare is AIRS ID: 123/9715 Page 3 of 8 DRAFTColorado Department of Public Health and Environment Air Pollution Control Division in operation. The term of the year shall begin on the date of issuance of the permit. (Reference: Regulation No. 1, Section II.A.5). 16. On an annual basis,the operator shall complete a site specific extended gas analysis of the natural gas produced at this site that is routed to the flare in order to verify the VOC 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. 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 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 AIRS ID: 123/9715 Page 4 of 8 DRAFTColorado Department of Public Health and Environment Air Pollution Control Division 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 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. P )� By: /ILL ,47....ay Christian Lesniak Permit Engineer Air Pollution Control Division Permit History AIRS ID: 123/9715 Page 5 of 8 DRAFTColorado Department of Public Health and Environment Air Pollution Control Division Issuance Date Description Issuance 1 This Issuance Newly permitted process flare at a new synthetic minor source facility. Notes to Permit Holder: 1) 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 shall 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 No.3, Part A, Section VI.B.) 2) 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. 3) 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.colorado.gov/cs/Satellite?c=Document C&childpagename=CDPHE- Main%2FDocument C%2FC8ONAddLinkView&cid=1251599389641&paciename=CBONWrapper 4) 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. Uncontrolled Are the Controlled AIRS Pollutant CAS# BIN Emission Rate emissions Emission Point (Ib/yr) reportable? Rate(Ib/yr) Benzene 71432 A 1280 Yes 64 006 Toluene 108883 C 1100 Yes 55 n-Hexane 110543 C 8782 Yes 439 5) The emission levels contained in this permit are based on the following emission factors: - Point 006: CAS# Pollutant Weight Fraction Emission Factors Emission Factors Source of Gas(%) Uncontrolled Controlled NOx --- 0.068 lb/MMBtu 0.068 AP-42 lb/MMBtu CO --- 0.37 0.37 AP-42 lb/MMBtu lb/MMBtu VOC 42.55 30452.76 1522.64 Engineering Ib/MMSCF lb/mmscf Calculation 71432 Benzene 0.1097 78.32 3.916 Engineering lb/MMSCF Ib/mmscf Calculation AIRS ID: 123/9715 Page 6 of 8 DRAFTColorado Department of Public Health and Environment Air Pollution Control Division CAS# Pollutant Weight Fraction Emission Factors Emission Factors Source of Gas(%) Uncontrolled Controlled 108883 Toluene 0.0943 67.34 3.367 Engineering lb/MMSCF lb/mmscf Calculation 110543 n-hexane 0.7527 537.54 26.877 Engineering lb/MMSCF lb/mmscf Calculation Note: The uncontrolled VOC and HAP emissions for this point were calculated using the December 19, 2011 analysis of a gas sample collected from the Speaker 1-27-31-8-61 well. The controlled VOC and HAP emissions factors for point 006 are based on the flare control efficiency of 95%. 6) 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. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic minor Source: VOC NANSR Synthetic Minor Source: VOC MACT HH Area Source Requirements: Not Applicable 8) 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 AIRS ID: 123/9715 Page 7 of 8 DRAFTColorado Department of Public Health and Environment Air Pollution Control Division 9) 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/oiloaspermittino.htm I AIRS ID: 123/9715 Page 8 of 8 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Carrizo Oil&Gas, Inc. Permit Number: 13WE2798 Source Location: NNWNE Section 27,T8N, R61 W Equipment Description Plant flare with a minimum combustion efficiency of 95%. AIRS ID: 123-9715-006 Date: 1/3/2014 Review Engineer: Christian Lesniak Control Engineer: Stefanie Rucker 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? X Yes 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? On what date was this application complete? 10/03/2013 Section 4—Source Description AIRS Point Equipment Description 006 Plant flare used to control gas stream during maintenance events.Flare has a minimum combustion efficiency of 95%. The flare is open. Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria x Yes No pollutant? If"yes",for what pollutant? PM10 CO X Ozone Is this location in an attainment maintenance area for Yes X No any criteria pollutant? If"yes", for what pollutant? (Note: These pollutants are subject to minor source PKo CO Ozone RACT per Regulation 3, Part B, Section III.D.2) Is this source located in the 8-hour ozone non- attainment region? (Note: If"yes"the provisions of X Yes No Regulation 7, Sections XII and XVII.C may apply) Page 1 Section 5—Emission Estimate Information AIRS Point Emission Factor Source 006 AP-42, Table 13.5-1 for NOx and CO. Mass balance for VOC. Did the applicant provide actual process data for the emission inventory? X Yes No Basis for Potential to Emit(PTEI AIRS Point Process Consumption/Throughput/Production 006 16.3 MMCF/yr Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 006 16.3 MMCF/yr 2013 Basis for Permitted Emissions(Permit Limits) AIRS Point Process Consumption/Throughput/Production 006 16.3 MMCF/yr Does this facility use control devices? X Yes No AIRS Point Process Control Device Description % Reduction Granted 006 01 Flare 95 Section 6—Emission Summary(tons per year) Point NO VOC CO SOx PM10 Single HAP Total HAP PTE: 006 0.85 248.19 4.61 --- --- 4.39 (n-hexane) 5.9 Uncontrolled point 006 0.85 248.19 4.61 — -- 4.39 (n-hexane) 5.9 source emission rate: Controlled point 006 0.85 12.41 4.61 --- --- 0.22 (n-hexane) 0.3 source emission rate: Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled Are Controlled Emission Pollutant CAS# BIN Emission Rate .miser (Ibyr) reportable? Rate(Ibtyr) Benzene 71432 A 1280 Yes 64 Toluene 108883 C 1100 Yes 55 n-Hexane 110543 C 8782 Yes 439 Note: Regulation 3, Part A, Section lI.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 X Yes No standard? If"yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method 006 01 VOC, State only requirement Site specific gas HAPS analysis Page 2 Section 9—Source Classification Is this a new previously un-permitted X Yes No source? What is this facility classification? True X Synthetic Major Minor Minor Classification relates to what X Title V X PSD NA NSR MACT programs? 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? Yes X No If"yes",for which pollutants?Why? For Reg. 3, Part B, III.C.1.a (controlled emissions increase>25/50 Yes X No tpy)? 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)? Yes X No Section 11 —Modeling Is modeling required to demonstrate compliance with National Ambient Yes X No Air Quality Standards (NAAQS)? If"yes", for which pollutants?Why? NOx emissions are less than 40 TPY. AIRS Point Section 12 Re ulato Review } . 4i .iE u'np._ aii`.;. 9 . • SIAM tt Section ll.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, 006 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 ,:i�{{��y consecutive minutes. yy++;;yy �4i� 14:5 AF�sti'.x,._.i� • C 's'+ tor „ -.4-a Section I.A-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 006 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. Re `;'�'e' ".: raittudf_IQnBrtllits PertfilCs PSb Part A-APEN Requirements Criteria Pollutants: For criteria pollutants,Air Pollutant Emission Notices are required for: each individual emission point in an attainment area with uncontrolled actual emissions of 006 two tons per year or more of any individual criteria pollutant(pollutants are not summed)for which the area is attainment. (Applicant is required to file an APEN since emissions from production exceed 2 tons per year VOC) Part B—Construction Permit Exemptions 006 Applicant is required to file a permit since uncontrolled VOC emissions are greater than the 2.0 TPY threshold(Reg. 3, Part B, Section ILD.3.a) _Regulation 6—New Source Performance Standards 006 None Page 3 , 11t-Noiatile.famit11C'. +r;, c • t.f. t".. mol.67ert 006 None 1 _EAErlt+rA1f'P rte- 006 None Section 13—Aerometric Information Retrieval System Coding Information Point Process Process Description Emission Pollutant/ Fugitive Emission Factor Control Factor CAS# (Y/N) Source (%) 30452.76 Engineering lb/MMscf VOC No Calculation 95 0.068 AP-42, lb/MMBtu NOx No Table 13.5-1 NA 0.37 AP-42, 01 Flare lb/MMBtu CO No Table 13.5-1 NA 006 78'32 Benzene No Engineering 95 lb/MMSCF Calculation 67.34 Toluene No Engineering 95 lb/MMSCF Calculation 537.54 n-hexane No Engineering 95 lb/MMSCF Calculation 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). 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