# Department of Environmental Quality To protect, conserve and enhance the quality ofWyoming's environment for the benefit ofcurrent 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

PermitNo. MD-11913

The Division ofAir Quality ofthe Wyoming Department of Environmental Quality has completed final review ofGarco Energy LLC's application to modify the Douglas Refinery with the authorization ofone (I) 25.2 MMBtu/hr Lummus hot oil heater, increase the crude oil throughput to 5,000 barrels per day (bpd), installation ofone (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 ofthe Division ofAir 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 ofinvestigating actual or potential sources ofair 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 That all substantive commitments and descriptions set forth in the application for this permit, unless superseded by a specific condition ofthis permit, arc incorporated herein by this reference and are enforceable as conditions ofthis permit. 3.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 I00, 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) ofthe 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 ofan engine from the facility, written notification is required within fifteen (15) days ofremoval. 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 ofcommencement. In accordance with Chapter 6, Section 2(h) ofthe 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 oftwenty-four (24) months or more. The Administrator may extend the period based on satisfactoryjustification ofthe 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 ofWyoming'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 ofcompletion. 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 I0. 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 of40 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 ZZZZfor 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 ifthe 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 ofthe results is to be submitted to the Division within forty-five (45) days ofcompletion. Notification ofthe 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) ofthis 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 ofthe Air Quality Division to cite the owner or operator for an exceedance ofthe permitted emission limits for any testing/monitoring required by (i) ofthis condition which shows noncompliance. 15. Garco Energy LLC shall comply with one (I) ofthe 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 ofthe 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 ofWAQSR Chapter 5, Section 3, subpart Ja §60.107a. 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 reliefvalves discharges or other emergency situations.Garco Energy LLC Air Quality Permit MDHII913 Page 4 I9. The flares shall be designed, constructed, operated and maintained to be smokeless, per Chapter 5, Section 2(m) ofthe WAQSR, with no visible emissions except for periods not to exceed atotal 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.I8 for the TCI I200 flare. 2I. Garco Energy LLC shall comply with all applicable requirements of §60.I03a of W AQSR Chapter 5 Section 3, subpart Ja for the flare management plan. 22. Garco Energy LLC shall comply with all applicable requirements of40 CFR part 60, subpart Kb for storage tanks T-107, TI08, and T20I. 23. Garco Energy LLC shall comply with all applicable requirements of40 CFR part 60, subpart De for the 25.2 MMBtu/hr Lummis heater. 24. Gareo Energy LLC shall comply with all applicable requirements ofW 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 ofshutdown ofthe 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. 3l. 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 ofyour obligation to comply with all applicable county, state, and federal standards, regulations or ordinances. Special attention must be given to Chapter 6, Section 2 ofthe Wyoming Air Quality Standards and Regulations, which details the requirements for compliance with conditions 3, 5, and 7. Any appeal ofthis permit as a final action ofthe Department must be made to the Environmental Quality Council within sixty (60) days ofpermit issuance per Section 16, Chapter!, General Rules ofPractice and Procedure, Department ofEnvironmental Quality.Garco Energy LLC Air Quality Permit MD-11913 Page 5 I fwe may be off urth erassistance to you, please f eel f r ee to contactthis office. Sincerel y,

# 2~a.D~ Steven A
.Dietrich Administra tor Air Quality Division cc: Chris Hanify irector ept. ofEn vironmentalQuality
Kristi Unzicker,Manager E nvironmentaland Marine Compliance Genesi s Energy, L.P., 91 9 Milam, Suite-.21 00, Houston,TX77002

## 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 watertank 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: DouglasRefinery FacilityEmissions 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

- - 

## - -



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- 

## - 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

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## - <0.1 <0.1

- - <0.1 <0.1 

## - -

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### - - 

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- - - -

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### - -



### - - - - 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 ofannual operation Emissions based on 3,650 annual hours oftruck loadout operations 3Emissions assuming 500 annual hours ofoperation ofpilot flame 

## so, lb/hr tpy 0.1 0.2 <0.1 0.1 <0.1 0.1

- 

### -

- -

- 

## I

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- - 0.1 0.4