Department of Environmental Quality 

To protect, conserve and enhance the quality of Wyoming's 

environment for the benefit of current and future generations. 

Matthew H. Mead, Governor John Carra, Director 

Mr. Jim Andersen 

Vice President 

Garco Energy LLC 

160 West Canyon Crest Road 

Alpine, UT 84004 

Dear Mr. Andersen: 

March 20, 2012 

Permit No. MD-11913 

The Division of Air Quality of the Wyoming Department of Environmental Quality has completed final 

review of Garco Energy LLC's application to modify the Douglas Refinery with the authorization of one 

(I) 25.2 MMBtu/hr Lummus hot oil heater, increase the crude oil throughput to 5,000 barrels per day 

(bpd), installation of one (I) 190 hp Cummins Fire Power Model CFP7E-F20 fire pump diesel engine and 

one (I) 11.9 bbl diesel fuel storage tank, putting a naphta splitter back into service, and updating the 

facility emissions. The Douglas Refinery is located at 2070 Highway 59, in the NEI/4 of Section 9, 

T35N, R70W, approximately nineteen (19) miles north-northeast of Douglas, in Converse County, 

Wyoming. 

Following this agency's proposed approval of the request as published February 15, 2012 and in 

accordance with Chapter 6, Section 2(m) of the Wyoming Air Quality Standards and Regulations, the 

public was afforded a 30-day period in which to submit comments concerning the proposed modification, 

and an opportunity for a public hearing. Comments have been received and were considered for the final 

permit. Therefore, on the basis of the information provided to us, approval to modify the Douglas 

Refinery as described in the application is hereby granted pursuant to Chapter 6, Section 2 of the 

regulations with the following conditions: 

I. That authorized representatives of the Division of Air Quality be given permission to enter and 

inspect any propetty, premise or place on or at which an air pollution source is located or is being 

constructed or installed for the purpose of investigating actual or potential sources of air pollution 

and for determining compliance or non-compliance with any rules, standards, permits or orders. 

2. That all substantive commitments and descriptions set forth in the application for this permit, 

unless superseded by a specific condition of this permit, arc incorporated herein by this reference 

and are enforceable as conditions of this permit. 

3. That a permit to operate, in accordance with Chapter 6, Section 2(a)(iii) of the WAQSR, ts 

required after a 120 day start-up period in order to operate this facility. 

4. That all notifications, reports and correspondences associated with this permit shall be submitted 

to the Stationary Source Compliance Program Manager, Air Quality Division, 122 West 2511' 

Street, Cheyenne, WY 82002 and a copy shall be submitted to the District Engineer, Air Quality 

Division, !52 North Durbin Street, Suite I 00, Casper, WY 8260 I. 

Hersehler Building · 122 West 25th Street · Cheyenne, WY 82002 · http://deq.state.wy.us 

ADMIN/OUTREACH ABANDONED MINES AIR QUALITY 

(307) 777-7758 (307) 777-6145 (307} ?Tl-7391 

F~'\X 777-7682 FAX 777-0402 FAX 777-~)fi'lfi 

INDUSTRIAL SITING 

(307) 777-7369 

FAX T/7-f/'1':\7 

LAND QUALITY SOLID & HAZ. WASTE 

(30'1) 777-7756 (307) 777-7752 

FAX 77"1-f>Rh4 FAX 777-S<!7.'\ 

WATER QUALITY 

(307) 777-7781 

FAX 777-C.Q?'>. 

~~ (,~) 
Garco Energy LLC 

Air Quality Permit MD-11913 

Page 2 

5. That written notification of the actual date of initial start-up for each source is required fiHeen 

( 15) days after start-up in accordance with Chapter 6, Section 2(i)(ii) of the WAQSR. For the 

Cummins Fire Power Model CFP7E-F20 fire pump engine, the notification shall be submitted on 

a complete Engine Installation/Removal form. The form can be downloaded from the Air Quality 

website b.tJp://deq.state.wv.us/agd or obtained from the Air Quality Division. 

6. That upon shutdown and removal of an engine from the facility, written notification is required 

within fifteen (15) days of removal. Such notification shall be submitted on a complete Engine 

Installation/Removal form. 

7. That the date of commencement of construction shall be reported to the Administrator within 

thirty (30) days of commencement. In accordance with Chapter 6, Section 2(h) of the WAQSR, 

approval to construct or modify shall become invalid if construction is not commenced within 

twenty-four (24) months after receipt of such approval or if construction is discontinued for a 

period of twenty-four (24) months or more. The Administrator may extend the period based on 

satisfactory justification of the requested extension. 

8. The 25.2 MMBtu/hr Lummis hot oil heater shall be tested for NO, and CO emissions within 

ninety (90) days of permit issuance. Testing shall follow EPA rcf'crence methods or a portable 

analyzer following the State of Wyoming's Portable Analyzer Protocol. A test protocol shall be 

submitted to this office for review and approval prior to testing. Results shall be submitted to this 

Division within forty-five (45) days of completion. 

9. That emissions from the 25.2 MMBtu/hr Lummis hot oil heater shall be limited as follows: 

Source NO, co 

Jb/MMBtu lb/hr tpy lb/MMBtu lb/hr tpy 

25.2 MMBtu/hr Lummis hot oil heater 0.025 0.6 2.8 0.04 1.0 4.5 

I 0. The Cummins Fire Power Model CFP7E-F20 fire pump engine shall be limited to 500 operating 

hours per year. The engine shall be equipped with a non-resettable hour meter, and the hours of 

operation shall be recorded and maintained f(Jr a period of five (5) years and shall be made 

available to the Division upon request. 

II. Garco Energy LLC shall maintain documentation that the Cummins Fire Power Model CFP7EF20 fire pump engine is EPA Tier 3 certified. The documentation shall be made available upon 

request. 

12. Garco Energy LLC shall comply with all applicable requirements of 40 CFR pa!i 60, subpart Jill 

for the Cummins Fire Power Model CFP7E-F20 fire pump engine. 

13. Garco Energy LLC shall comply with all applicable requirements of 40 CFR part 63, subpart 

ZZZZ for the Cummins Fire Power Model CFP7E-F20 fire pump engine. 
Garco Energy LLC 

Air Quality Permit MD-11913 

Page 3 

14. Garco Energy LLC shall follow the testing requirements as follows for the 25.2 MMBtu/hr 

Lummis hot oil heater: 

1. That at least once every two (2) years, the 25.2 MMBtu/hr Lummus hot oil heater shall be 

tested for NO, and CO to determine if the heater is operating within the emission limits 

specified in this permit. Testing shall be conducted using EPA Reference Methods or a 

portable analyzer, following the State of Wyoming's Portable Analyzer Protocol. A 

written report of the results is to be submitted to the Division within forty-five (45) days 

of completion. Notification of the test date shall be provided to the Division fifteen ( 15) 

days prior to testing. The testing frequency may be revised without administratively 

amending the permit, but shall be approved by the Division prior to implementation. 

ii. The Air Quality Division shall be notified within twenty-four (24) hours of the heater 

where the testing/monitoring required by (i) of this condition shows operation outside the 

permitted emission limits. By no later than seven (7) calendar days of such 

testing/monitoring event, the owner or operator shall repair and retest/monitor the 

affected heater to demonstrate that the heater has been returned to operation within the 

permitted emission limits. Compliance with this permit condition regarding repair and 

retesting/monitoring shall not be deemed to limit the authority of the Air Quality Division 

to cite the owner or operator for an exceedance of the permitted emission limits for any 

testing/monitoring required by (i) of this condition which shows noncompliance. 

15. Garco Energy LLC shall comply with one (I) of the following two (2) emission limits for the two 

(2) Born charge heaters and 25.2 MMBtu/hr Lummis hot oil heater: 

a. The S02 emissions for each of the two (2) Born charge heaters and 25.2 MMBtu/hr 

Lummis hot oil heater shall be limited to 20 ppmv (dry basis, corrected to zero percent 

(0%) excess air), as determined hourly on a 3-hour rolling average basis; and to 8 ppmv 

(dry basis, corrected to zero percent (0 %) excess air), as determined daily on a 365 

successive day rolling average basis. 

or: 

b. The l-1 2S content of the fuel gas for the two (2) Born charge heaters and 25.2 MMBtu/hr 

Lummis hot oil heater shall be limited to 162 ppmv, as determined hourly on a 3-hour 

rolling average basis; and 60 ppmv, as determined daily on a 365 successive calendar day 

rolling average basis. 

16. Garco Energy LLC shall follow the fuel gas monitor requirements of WAQSR Chapter 5, Section 

3, subpart Ja §60.1 07a. 

17. Vapors fi·om the two (2) truck loadout racks (North and South) shall be routed to the TCI 1200 

llare. Records shall be maintained, noting periods during the truck loadout operations when the 

llarc is not operational. 

18. Garco Energy LLC shall operate the Sunn 96 llare only to combust process upset gases fi·om 

pressure relief valves discharges or other emergency situations. 
Garco Energy LLC 

Air Quality Permit MDHII913 

Page 4 

I 9. The flares shall be designed, constructed, operated and maintained to be smokeless, per Chapter 

5, Section 2(m) of the WAQSR, with no visible emissions except for periods not to exceed a total 

of five (5) minutes during any two (2) consecutive hours as determined by 40 CFR part 60, 

appendix A, Method 22. 

20. Garco Energy LLC shall comply with 40 CFR part 60, §60. I 8 for the TCI I 200 flare. 

2 I. Garco Energy LLC shall comply with all applicable requirements of §60. I 03a of W AQSR 

Chapter 5 Section 3, subpart Ja for the flare management plan. 

22. Garco Energy LLC shall comply with all applicable requirements of 40 CFR part 60, subpart Kb 

for storage tanks T-1 07, T I 08, and T20 I. 

23. Garco Energy LLC shall comply with all applicable requirements of 40 CFR part 60, subpart De 

for the 25.2 MMBtu/hr Lummis heater. 

24. Gareo Energy LLC shall comply with all applicable requirements of W AQSR Chapter 5 Section 

3, subpart Ja. 

25. Garco Energy LLC shall comply with all applicable requirements of 40 CFR part 60, subpart 

GGGa and maintain a Leak Detection and Repair (LDAR) program at the Douglas Refinery. 

26. Garco Energy LLC shall comply with all applicable requirements of 40 CFR part 60, subpart 

QQQ for the oil/water separator. 

27. The authorization to operate the two (2) 7.0 MMBtu/hr Born crude charge heaters shall expire on 

July I, 2013. 

28. That shut-down notifications shall be submitted to the Division within fifteen (I 5) days of shutdown of the two (2) 7.0 MMBtu/hr Born crude charge heaters. 

29. The two (2) Cooper GMV -6 refrigeration compressor cng1nes cannot be operated unless 

authorized by an appropriate permit modification. 

30. All records shall be kept for a period of flve (5) years and made available to the Division upon 

request. 

3 l. Effective upon permit issuance, this permit shall supersede Air Quality Permits MD-1389 and 

MD-l389A, and Air Quality Waivers wv-7076 and wv-12637 for the Douglas Reflnery. 

It must be noted that this approval does not relieve you of your obligation to comply with all applicable 

county, state, and federal standards, regulations or ordinances. Special attention must be given to Chapter 

6, Section 2 of the Wyoming Air Quality Standards and Regulations, which details the requirements for 

compliance with conditions 3, 5, and 7. Any appeal of this permit as a final action of the Department 

must be made to the Environmental Quality Council within sixty (60) days of permit issuance per Section 

16, Chapter!, General Rules of Practice and Procedure, Department of Environmental Quality. 
Ga rco Energy LLC 

Air Qua li ty Permit MD-11913 

Page 5 

If we may be of further assistance to you, please feel free to contact th is office. 

Sincerely, 

2~a.D~ Steven A. Dietrich 

Administrator 

Air Quality Division 

cc: Chris Hanify 

irector 

ept. of Environmental Quality 

Kristi Unzicker, Manager Environmental and Marine Compliance 

Genesis Energy, L.P., 91 9 Milam, Suite-.2 1 00, Houston, TX 77002 
I 

I 

Garco Energy LLC 

Air Quality Permit MD-11913 

Page6 

ID Source 

F-550 25.2 MMBtulhr Lummus hot oil heater 

HI 7.0 MMBtulhr Born crude charge heater 

H2 7.0 MMBtulhr Born crude charge heater 

Cummins Fire Power Model CFP7E-F20 1 

T-107 Naphtha storage tank 

T-108 Crude oil storage tank 

T-Ill Naphtha storage tank 

T-!12 Naphtha storage tank 

T-201 Crude storage tank 

T-202 Diesel storage tank 

T-203 Diesel storage tank 

T-204 Diesel storage tank 

T-205 VGO storage tank 

T-206 Process water storage tank 

T-207 Storm water tank 

T-208 Fire water tank 

Fire pump engine diesel fuel storage tank 

Fugitives 

Truck loading 

F-960 TCI 1200 flare 2 

S-96 Sunn 96 emergency flare 3 

Box cooler 

Total Facility Emissions 

Table 1: Douglas Refinery Facility Emissions 

NO, co 

lblhr tpy lblhr tpy 

0.6 2.8 LO 4.5 

L1 4.6 OA LS 

' Ll 4.6 OA LS 

I LO 03 0.5 0.1 

- - - -

- - - - - - - -

- I - - -

- - - -

- - - -

- - - -

- - - -

- - - -

- - - -

I - - I - -

- - - -

I - - I - -

- - I - I -

- - I - -

1.4 2.6 0.4 0.6 

105.0 26.3 26.3 6.6 

- - I - -

110.2 41.2 29 15.4 

.. 

voc HAP 

lblhr tpy lblhr tpy 

0.1 0.6 

<0.1 0.2 - -

<0.1 0.2 - -

<0.1 <0.! - -

0.1 OA - -

0.! 0.5 - -

- - - -

- - - -

0.1 0.5 - -

<0.1 0.1 - -

<0.1 0.1 - -

<0.1 <0.1 - -

<0.1 <0.1 - -

- - - -

- - - -

- - - -

- - - -

9.1 39.9 - -

Controlled with TCl 1200 flare 

0.1 0.2 - -

15.0 3.8 - -

<0.1 <0.1 <0.01 <0.01 

24.6 46.5 <0.01 <0.01 

Emissions based on 500 hours of annual operation Emissions based on 3,650 annual hours of truck loadout operations 3 Emissions assuming 500 annual hours of operation of pilot flame 

so, 

lb/hr tpy 

0.1 0.2 

<0.1 0.1 

<0.1 0.1 

- -

- -

- I -

- -

I - -

- I -

- -

- -

- -

I - -

I - -

- -

- -

- -

- -

- -

- -

- - ' 

- -

0.1 0.4