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Home My WebLink About20140442.tiff STATE OF COLORADO John W.Hickenlooper,Governor Karin McGowan ,.(F�O,� Interim Executive Director I 0 Dedicated to protecting and improving the health and environment of the people of Colorado * R ♦\ fi 4300 Cherry Creek Dr.S. Laboratory Services Division • Denver,Colorado 80246-1530 8100 Lowry Blvd. /876 Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department Located in Glendale,Colorado (303)692-3090 of Public Health hitp://www.cdpbe.state.co.us and Environment Weld County Clerk&Recorder 1402 N 17th Ave Greeley, CO 80631 February 10, 2014 Dear Sir or Madam: On February 13, 2014, the Air Pollution Control Division will publish a public notice for Carrizo Oil and Gas, Inc.—Debrine 21-44-8-61, in the The Greeley I rihune. 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: Clara Gonzales Regards, f 7'• Clara Gonzales RECEIVED Public Notice Coordinator Stationary Sources Program FEB 13 2014 Air Pollution Control Division Enclosure WELD COUNTY COMMISSIONERS Ji Cs -PL R L R'C 2014-0442 STATE OF COLORADO John W.Hickenlooper,Governor • Karin McGowan ,4,;(3 oz R\ Interim Executive Director � Dedicated to protecting and improving the health and environment of the people of Colorado , 4 ar 0 4300 Cherry Creek Dr.S. Laboratory Services Division re'� 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 http://www.cdphe.state.co.us and Environment Website Title: Carrizo Oil and Gas, Inc.—Debrine 21-44-8-61 — Weld County Released To: The Greeley Tribune On: February 10, 2014 Published: February 13, 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 and Gas, Inc. Facility: Debrine 21-44-8-61 Oil and natural gas exploration and production Section 21 of township 8 north, range 61 west Weld County The proposed project or activity is as follows: Oil and natural gas exploration and production facility The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section lI1.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 12WE2343 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: Michael Cleary Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-BI Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us T fi mr'.p: (Pr.' . Yt;{yep tG! L m W. in mgt.,Ss STATE OF COLORADO of COO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT wee .9g AIR POLLUTION CONTROL DIVISIONin lin! TELEPHONE: (303)692-3150 . "�w,,,di'`: *)876 CONSTRUCTION PERMIT PERMIT NO: 12WE2343 Issuance 1 DATE ISSUED: ISSUED TO: Carrizo Oil & Gas, Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural gas production facility, known as Debrine 21-44-8-61, located in the SESE of Section 21, 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 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 w.cri : stxe usiap/ciown!oadterms nimi. 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 AIRS ID: 123/99BA Page 1 of 7 Condensate Tank Version 2009-1 slora,A Dep m P lic Health and Environment D Air Pollution Control Division 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 Emission Type NO, VOC CO SEPARATOR 005 --- 5.9 2.9 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 AIRS Control Device Pollutants Equipment ID Point 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 AIRS Process Parameter Annual Limit Equipment ID Point SEPARATOR 005 Natural gas flaring 11.6 MMSCF/yr AIRS ID: 123/99BA Page 2 of 7 lora Dep .. m . P ho Health and Environment Air Pollution Control Division 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). Periodic Testing Requirements 14. 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 15. 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 AIRS ID: 123/99BA Page 3 of 7 lora Dep m P Airlic PollutionHealthand Control DivisionEnvironment D 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. 16. 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 17. 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. 18. 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 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. 19. 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. 20. 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. 21. 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 AIRS ID: 123/99BA Page 4 of 7 lora Dep m .•P - lic Health and Environment Air Pollution Control Division 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. 22. 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. 23. 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. By: < Michael Cleary Permit Engineer Air Pollution Control Division Permit History Issuance Date Description Issuance 1 This Issuance Newly permitted process flare at a new synthetic minor source facility. AIRS ID: 123199BA Page 5 of 7 lik tA Dep m P lic Health and Environment D Air Pollution Control Division 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.cdphe.state.co.us/requlations/airrecish 001 02aqcccom monprovisionsreq.pdf. 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 Emission Are the Controlled AIRS Rate emissions Emission Point Pollutant CAS# BIN (Ib/yr) reportable? Rate (Ib/yr) Benzene 71432 A 913 Yes 46 005 Toluene 108883 C 545 No 27 n-Hexane 110543 C 4901 Yes 245 5) The emission levels contained in this permit are based on the following emission factors: Point 005: Weight Emission Emission CAS# Pollutant Fraction of Factors Factors Source Gas (%) Uncontrolled Controlled 0.068 0.068 NOx "' lb/MMBtu Ib/MMBtu AP-42 CO 0.37 0.37 AP-42 lb/MMBtu lb/MMBtu VOC 34.61 20326.704 1016.34 Engineering Ib/MMSCF lb/mmscf Calculation 71432 Benzene 0.125 78.944 3.947 Engineering Ib/MMSCF lb/mmscf Calculation 108883 Toluene 0.748 47.169 2.358 Engineering lb/MMSCF lb/mmscf Calculation 110543 n-hexane 0.672 423.851 21.193 Engineering Ib/MMSCF lb/mmscf Calculation AIRS ID: 123/99BA Page 6 of 7 1..)lorac)hDep tm PP lic Health and Environment Air Pollution Control Division Note: The uncontrolled VOC and HAP emissions for this point were calculated using May 23,2012 analysis of a gas sample collected from the Debrine 21-44 well.The controlled VOC and HAP emissions factors for point 005 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: cctr_cpoacccs .go\ 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 ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX 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/oilgaspermittinq html AIRS ID: 123/99BA Page 7 of 7 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Carrizo Oil & Gas, Inc. Permit Number: 12WE2343 Source Name: Debrine 21-44-8-61 Source Location. SESE Section 21, T8N, R61W, Weld County (attainment) Equipment Description: Separator controlled by a 25'flare stack. Flare has a minimum combustion efficiency of 95%. The flare is not enclosed. AIRS ID: 123-99BA-005 Review Date: May 15, 2013 Review Engineer: Michael Cleary Draft Permit Location K:\PERMITS\2012\12WE2343.CP1 Section 2—Action Completed • X CP1 Modification APEN Required/Permit Exempt Final Approval Transfer of Ownership APEN Exempt/Permit Exempt 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? 07/30/2012 Section 4—Source Description AIRS Point Equipment Description 005 Separator controlled by a 25'flare stack. Flare has a minimum combustion efficiency of 95%. The flare is not enclosed. 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 PM10 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) Is this source located at an oil and gas exploration site? X Yes No Page 1 Is this source located at a facility that is considered a major source of hazardous air pollutant (HAP) Yes X No emissions? Will this equipment be operated in any NAAQS Yes X No nonattainment area? Section 5—Emission Estimate Information AIRS Point Emission Factor Source 005 Site-specific using VOC weight fraction (Refer to Section 14 for calculations) 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 005 11.6 MMsfc per year Basis for Permitted Emissions(Permit Limits) AIRS Point Process Consumption/Throughput/Production 005 11.6 MMsfc per year Does this source use a control device? Yes X No Section 6—Emission Summary(tons per year) Point NO, VOC CO Single HAP HAP PTE: 005 --- 117.3 --- 2.45(n-hexane) 3.27 Uncontrolled point 005 --- 117.3 -- 2.45(n-hexane) 3.27 source emission rate: Permitted point source 005 --- 5.9 --- 0.12 (n-hexane) 0.16 emission rate: Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled Are the Controlled Emission Pollutant CAS# BIN Emission Rate emission. r (iblyr) reportable? Rate(Ibl Y ) Benzene 71432 A 913 Yes 46 Toluene 108883 C 545 No 27 Ehtylbenzene 100414 C 52 No 3 Xylenes 1.1.30207 - C 130 Nq 6 n-hexane 110543 C_ 4901 Yes 245 224-TMP 71432 Note: Regulation"3, Part A, Section Il.B.3.b APEN emission'.reporting requirements for non=criteria air pollutants arebased on potential emissions without credit for reductions achieved by control ctevices used by the Operator. Section 8-Testing Requirements Will testing be required to show compliance with any emission rate orregulatory . ,,yes standard? Section 9-Source Classification Is this a new previously un-permitted source? X Yes No Page 2 What is this point classification? True X Synthetic Major Minor Minor What is this facility classification? True X Synthetic Major Minor Minor 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 Major Minor 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 (emissions increase> 25/50 tpy)? Yes No For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)? Yes No For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? Yes No Section 11 —Modeling Is modeling required to demonstrate compliance with National Ambient Yes X No Air Quality Standards (NAAQS)? AIRS Point Section 12—Regulatory Review Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of 005 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.) Regulation 2—Odor 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 005 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. Regulation 3 -APENs, Construction Permits, Operating Permits PSD 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 tons per year or more of any individual criteria pollutant(pollutants are not summed) 005 for which the area is non-attainment. (Applicant is required to file an APEN since emissions of VOC exceed 1 tons per year VOC) Part B—Construction Permit Exemptions Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 2.0 TPY threshold(Reg. 3, Part B, Section ll.D.3.a) Regulation 6- New Source Performance Standards 005 None Regulation 7—Volatile Organic Compounds 005 None • Regulation 8—Hazardous Air Pollutants 005 None Section 13—Aerometric Information Retrieval System Coding Information Process Pollutant/ Fugitive Emission Contro Point Process Description Emission Factor CAS# (Y/N) Factor Source (%) Page 3 20326.704 Ib/MMscf VOC No Engineering 95 Calculation 0.068 lb/MMBtu N0x No AP-42, NA Table 13.5-1 0.37 Ib/MMBtu CO No AP-42' NA Table 13.5-1 78.944 lb/MMscf Benzene No Engineering 95 Calculation 01 Separator 007 47.169 Ib/MMscf Toluene No Engineering 95 Calculation 4.482 Ib/MMscf Ethlybenzene No Engineering 95 Calculation 11.205 Ib/MMscf Xylenes No Engineering 95 Calculation 423.851 Ib/MMscf n-hexane No Engineering 95 Calculation SCC 31000106-Oil/Gas/Water Separation Section 14—Miscellaneous Application Notes AIRS Point 007 Separator A permit is required for this source because uncontrolled VOC emissions from this facility exceed two tons per year in a nonattainment area for ozone. Operator provided an extended gas analysis and emissions were calculated using EPA Emission Inventory Improvement Program Publication, Volume II, Chapter 10-Displacement equation (10.4-3) where: Ex= Q * MW*Xx/C Ex=emissions of pollutant x Q =Volumetric flow rate/volume of gas processed MW= Molecular weight of gas = SG of gas * MW of air Xx= mass fraction of x in gas C = molar volume of ideal gas (379 scf/lb-mol)at 60F and 1 atm Emission factors were calculated to be: VOC = 117.5 x 2000 + 11.6 mmscf/yr = 20326.704 lb/mmscf Benzene = 913 + 11.6 mmscf/yr = 78.944 lb/mmscf Toluene = 545 + 11.6 mmscf/yr = 47.169 lb/mmscf Ethylbenzene = 52 + 11.6 mmscf/yr = 4.482 lb/mmscf Xylenes = 130 + 11.6 mmscf/yr = 11.205 ,Ib/mmscf n-hexane = 4901 + 11.6 mmscf/yr = 423.851 Ib/mmscf 224-TMP = 3 + 11.6 mmscf/yr = 0.301 lb/mmscf The extended gas analysis provided in the application was dated 05/23/2012. The gas analysis was performed less than a year prior to submittal. 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