HomeMy WebLinkAbout20140412.tiff STATE OF COLORADO
John W.Hickenlooper,Governor
Larry Wolk, MD,MSPH /F \
Executive Director and Chief Medical Officer i,5 .90
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Dedicated to protecting and improving the health and environment of the people of Colorado ,
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4300 Cherry Creek Dr.S. Laboratory Services Division 1876
Denve
r,Colorado 80246-1530 8100 Lowry Blvd.
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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
Weld County Clerk& Recorder
1402 N 17th Ave
Greeley, CO 80631 RECEIVED
January 31, 2014 FEB 0 7 2014
WELD COUNTY
COMMISSION'Rc
Dear Sir or Madam:
On February 4,2014, the Air Pollution Control Division will publish a public notice for Carrizo Oil & Gas,
Inc.—Sievers 1-3-7-62, 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-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
7ubllc-1 1C,' CL I._ 'RL 2014-0412
• 194 1�-I ' 2-t� ly
STATE OF COLORADO
John W.Hickenlooper, Governor
Larry Wolk, MD,MSPH /oF [of-.
,
Executive Director and Chief Medical Officer He
Dedicated to rotectin and improving the health and environment of the people of Colorado
o
P 9 P 9 P P .\' �> *
4300 Cherry Creek Dr. S. Laboratory Services Division \11 t
Denver,Colorado 80246-1530 8100 Lowry Blvd. �e�s�
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. — Sievers 1-3-7-62—Weld County
Released To: The Greeley Tribune
On: January 31, 2014
Published: February 4,2014
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: Sievers 1-3-7-62
wellpad
SESE Section 3,T7N, R62W
Weld County
The proposed project or activity is as follows: The applicant is operating a well site with a separator.
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):
• permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.I.a
(25 tpy in a non-attainment area and/or 50 tpy in an attainment area)
• 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 13 W E2721 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:
Rebecca Vasil
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B 1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
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' . STATE OF COLORADO
h�%FOR
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT �
AIR POLLUTION CONTROL DIVISION t�^ °i
TELEPHONE: (303)692-3150 ls�..
.IB76
CONSTRUCTION PERMIT
PERMIT NO: 13WE2721
Issuance 1
DATE ISSUED:
ISSUED TO: Carrizo Oil & Gas, Inc
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the Sievers 1-3-7-62, located in the SESE of Section 3,
Township 7N, Range 62W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS
Equipment Point Description
ID
SEPARATOR 003 Separator controlled by a 25' 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 Air Pollution Control Division(the Division)no later than fifteen
days after issuance of this permit, by submitting a Notice of Startup form to the
Division. The Notice of Startup form may be downloaded online at
www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of
the permitted source is a violation of Air Quality Control Commission(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 in this permit shall be demonstrated to the Division. It is the owner or
operator'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, III.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; (Hi) does not complete construction within a reasonable time of the
AIRS ID: 123/9BE2 Page 1 of 7
Wellhead Version 2012-1
IPol
De en f Public Health and Environment
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 following information for all permitted equipment except fugitive emissions from
equipment leaks shall be provided to the Division within fifteen (15) days after issuance of
permit.
• manufacturer
• model number
• serial number
This information shall be included with the Notice of Startup submitted for the equipment.
(Reference: Regulation No. 3, Part B, III.E.)
6. 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
7. 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 Emission Type
Equipment ID Point NO, VOC CO
SEPARATOR 003 3.23 45.78 17.56 Point
See "Notes to Permit Holder#4"for information on emission factors and methods used to calculate
limits.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)from
each emission unit, on a rolling twelve (12) month total. By the end of each month a new
twelve-month total shall be calculated based on the previous twelve months' data. The
permit holder shall calculate emissions each month 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 permitted emission units, requiring an APEN, at this facility.
8. 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 Pollutants
Control Device
Equipment ID Point Controlled
SEPARATOR 003 Separator controlled by a 25' flare stack VOC, HAPs
AIRS ID: 123/9BE2 Page 2 of 7
olo Deb �'�ment f Public Health and Environment
Air Pollution Control Division
PROCESS LIMITATIONS AND RECORDS
9. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the 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 003 Natural gas flaring 64.7 MMSCF/yr
The owner or operator shall calculate monthly process rates based on the calendar month.
Compliance with the annual 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 throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. 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)
11. 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.)
12. 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.)
13. These sources are subject to the odor requirements of Regulation No. 2. (State only
enforceable)
OPERATING & MAINTENANCE REQUIREMENTS
14. 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
15. The owner or operator shall demonstrate compliance with Condition 11 using EPA Method 9
to measure opacity from the flare. (Reference: Regulation No. 1, Section II.A.5).
Periodic Testing Requirements
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
AIRS ID: 123/9BE2 Page 3 of 7
of De en f Public Health and Environment
Air Pollution Control Division
(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 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
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.
AIRS ID: 123/9BE2 Page 4 of 7
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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.
By:
Rebecca Vasil
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Carrozo Oil & Gas, Inc.
AIRS ID: 123/9BE2 Page 5 of 7
D • oi..j . De en f Public Health and Environment
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.colorado.qovics/Satellite?c=-Document C&childpagename=CDPHE-
Main%2FDocument C%2FCBONAddLinkView&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
Emission Are the Controlled
AIRS Rate emissions Emission
Point Pollutant CAS# BIN (lb/yr) reportable? Rate(lb/yr)
Benzene 71432 A 8580 Yes 420
Toluene 108883 C 6260 Yes 320
003
Xylene 1330207 C 1300 Yes 60
n-Hexane 110543 C 51820 Yes 2600
5) The emission levels contained in this permit are based on the following emission factors:
Emission Emission
CAS# Pollutant Factors Factors Source
Uncontrolled Controlled
NOx 0.068 0.068 AP-42
lb/MMBtu lb/MMBtu _
CO 0.37 AP-42
0.37 lb/MMBtu lb/MMBtu
VOC 28304.79 1415.15 Engineering
lb/mmscf lb/mmscf Calculation
71432 Benzene 132.93 6.49 Engineering
lb/mmscf lb/mmscf Calculation
108883 Toluene 96.76 4.95 Engineering
lb/mmscf lb/mmscf Calculation
1330207 Xylene 20.17 0.927 Engineering
lb/mmscf lb/mmscf Calculation
110543 n-hexane 801.31 40.19 Engineering
lb/mmscf lb/mmscf Calculation
AIRS ID: 123/96E2 Page 6 of 7
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"' 'Dolo^a De ment f Public Health and Environment
Air Pollution Control Division
Note: The uncontrolled VOC and HAP emissions for this point were calculated using the August 5,
2013 analysis of a gas sample collected from the Sievers 1-3-7-62 well. The controlled VOC
and HAP emissions factors for point 003 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 of:
VOC
NANSR Synthetic Minor Source of:
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:
htip: ectr.epoaccess.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 ZZZZ—Subpart MMMMM
MACT 63.8980-End Subpart NNNNN—Subpart XX(XXX
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:
www colorado.qov/cdphe/oilgaspermits
AIRS ID: 123/9BE2 Page 7 of 7
Construction Permit Application
Preliminary Analysis Summary
Section 1 —Applicant Information
Company Name: Carrizo Oil &Gas, Inc.
Permit Number: 13WE2721
Source Location: SESE Section 3 T7N R62W, Weld County (non-attainment)
Equipment Description: Plant flare with a minimum combustion efficiency of 95%.
AIRS ID: 123-9BE2-003
Date: November 5`h 2013
Review Engineer: Rebecca Vasil
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? 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? September 5`h 2013
Section 4—Source Description
AIRS Point Equipment Description
003 Separator controlled by a 40' flare stack. Flare has a minimum combustion
efficiency of 95%.
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)
Page 1
Section 5—Emission Estimate Information
AIRS Point Emission Factor Source
003 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(PTE)
AIRS Point Process Consumption/Throughput/Production
003 64.7 mmscf/yr
Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory)
AIRS Point Process Consumption/Throughput/Production Data Year
003 64.7 mmscf/yr 2013
Basis for Permitted Emissions (Permit Limits)
AIRS Point Process Consumption/Throughput/Production
003 64.7 mmscf/yr
Does this facility use control devices? X Yes No
AIRS Point Process Control Device Description % Reduction Granted
003 of Flare 95
Section 6—Emission Summary(tons per year)
Point NO„ VOC CO SOx PM10 Single Total
HAP HAP
PTE: 003 3.23 915.66 17.56 --- --- 25'91 33.98
(n-hexane)
Uncontrolled point 25.91
source emission rate: 003 3.23 915.66 17.56 --- --- 33.98
(n-hexane)
Controlled point 003 3.23 45.78 17.56 --- --- 1.30 1 7
source emission rate: (n-hexane)
Section 7—Non-Criteria/ Hazardous Air Pollutants
Uncontrolled Arethe Controlled Emission
Pollutant CAS# BIN Emission Rate emissions Ibl r
(Iblyr) reportable? Rate( y )
Point 003
Benzene 71432 A 8,580 Yes 420
Toluene 108883 C 6,260 Yes 320
Xylene 1330207 C 1,300 Yes 60
n-Hexane 110543 C 51,820 Yes 2,600
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 X Yes No
standard?
If"yes", complete the information listed below
AIRS Point Process Pollutant Regulatory Basis Test Method
Page 2
003 of VOC, State only requirement • Site-specific gas
HAPS analysis
Section 9—Source Classification
What is this facility classification? True X Synthetic Major
Minor Minor
Classification relates to what programs? X Title V PSD X NA NSR X 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? X Yes No
If"yes", for which pollutants?Why? VOC, HAPs
For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)? X Yes 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 Yes X No
Air Quality Standards (NAAQS)?
If"yes", for which pollutants?Why? NOx emissions are less than 40 TPY.
AIRS Point Section 12— Regulatory Review
Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide
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
003 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.
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
003 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
003 Criteria Pollutants: Applicant is required to file an APEN since emissions
exceed 1 ton per year VOC
Part B—Construction Permit Exemptions
003 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 II.D.3.a)
Regulation 6 - New Source Performance Standards
003 None
Regulation 7—Volatile Organic Compounds
003 None
Regulation 8— Hazardous Air Pollutants
Page 3
003 I None
Section 13—Aerometric Information Retrieval System Coding Information
Emission Pollutant/ Fugitive Emission Factor Control
Point Process Process Description Factor CAS# (Y/N) Source (%)
28304.7913 VOC No Engineering 95
Ib/MMscf Calculation
0.068 NOx No AP-42' NA
lb/MMBtu Table 13.5-1
0.37 CO No AP-42, NA
Ib/MMBtu Table 13.5-1
01 Flare 132.93 Benzene No Engineering 95
003 Ib/MMscf Calculation
96.76 Toluene No Engineering 95
Ib/MMscf Calculation
20.17 Engineering
• Ib/MMscf Xylene No Calculation 95
801.31 n-hexane No Engineering 95
Ib/MMscf Calculation
SCC 31000206-Flares
Page 4
Section 14—Miscellaneous Application Notes
AIRS Point 003 Flare
Emissions were calculated using VOC wt fraction.
(scf/hr) *(Ib/Ib-mol) * (% fraction from sales gas analysis)/(379.4 scf/lb-mol) = lb/hr* (hr/yr)/2000 lb/T) =
TPY
VOC = (915.66 TPY *2000 Ib/T) /(64.7 mmscf/yr = 28304.7913 lb/mmscf
NOx and CO (from AP-42, Chapter 13, Table 13.5-1 (NOx = 0.068 Ib/mmbtu, CO = 0.37 lb/mmbtu)
SO2 emissions based on AP-42 Table 1.4-2 (SO2 = 0.00037 lb/MMBtu)
PM10 and PM2.5 based on AP-42 Table 13.5-2 (PM10 and PM2.5=40 ug/l)
Emission factors for HAPS are:
Benzene = (8580 Ib/yr)/64.7 mmscf/yr= 132.93 lb/mmscf
Toluene = (6260 Ib/yr)/64.7 mmscf/yr= 96.76 lb/mmscf
Xylene= (1300 Ib/yr)/64.7mmscf/yr=20.17lb/mmscf
n-hexane= (51820 Ib/yr)/64.7 mmscf/yr= 801.31 lb/mmscf
Emissions generated from the flare are:
Uncontrolled Total (Ib/yr) Controlled Total (lb/yr)
NOx 6,460 6,460
VOC 1,831,320 91,560
CO 35,120 35,120
Benzene 8,580 420
Toluene 6,260 320
Xylene 1,300 60
n-hexane 51,820 2,600
An extended gas analysis was provided in the application dated 08/05/2013. The gas analysis was
perfomed less than a year of submittal. An updated extended gas analysis will not be required because:
-an extended gas analysis was performed within a year of this submittal and included with this package
Page 5
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