HomeMy WebLinkAbout20130870.tiffSTATE OF COLORADO
John W. Hickenlooper, Governor
Christopher E. Urbina, MD, MPH
Executive Director and Chief Medical Officer
Dedicated to protecting and improving the health and environment of the people of Colorado
4300 Cherry Creek Dr. S.
Denver, Colorado 80246-1530
Phone (303) 692-2000
Located in Glendale, Colorado
http://www.cdphe.state.co.us
April 4, 2013
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
(303) 692-3090
Weld County Clerk & Recorder
1402 N 17th Ave
Greeley, CO 80631
Dear Sir or Madam:
RECEIVED
APR 1 0 Z013
WELD COUNTY.
COMMISSIONERS
Colorado Department
of Public Health
and Environment
On April 4, 2013, the Air Pollution Control Division will publish a public notice for Carrizo Oil & Gas, Inc. —
Bringelson Ranch 33-21-9-58, in the The Greeley 'Tribune. A copy of this public notice and the public comment
packet was mailed to the County on April 1, 2013. There was a revision made to the application so please provide
this permit instead of the one originally submitted.
Regards,
Stephanie Chaousy, PE
Permit Engineer
Stationary Sources Program
Air Pollution Control Division
Enclosure
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2013-0870
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO: 1 2WE2808
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 Bringelson Ranch 33-21-9-58, located in the NENW
of Section 33, Township 9 North, Range 58 West, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment ID
AIRS
Point
Description
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
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/downloadforms.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.
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).
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 fora period of eighteen
months or more; (iii) 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.)
AIRS ID: 123/9A31 Page 1 of 7
Condensate Tank Version 2009-1
blic Health and Environment
Air Pollution Control Division
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
Equipment ID
AIRS
Point
Tons per Year
Emission Type
NO,
VOC
CO
SEPARATOR
005
5.1
75.0
27.6
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.
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 I I.E.)
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
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
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
SEPARATOR
005
Natural gas flaring
99.5 MMSCF/yr
AIRS ID: 123/9A31
Page 2 of 7
Pablic 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. The owner or operator shall sample the gas routed to the flare to determine the heat content
on an annual basis
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: 123/9A31 Page 3 of 7
Public Health and Environment
Air Pollution Control Division
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
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
AIRS ID: 123/9A31 Page 4 of 7
P blic Health and Environment
Air Pollution Control Division
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:
Stephanie Chaousy, PE
Permit Engineer
Air Pollution Control Division
Permit Histor
Issuance
Date
Description
Issuance 1
This Issuance
Facility -wide permit for: (1) process flare. New
synthetic minor source facility.
AIRS ID: 123/9A31 Page 5 of 7
Wok Health and Environment
Air Pollution Control Division
Notes to Permit Holder:
1) 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.
2) 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/regulations/airreos/100102agcccom m on prOvisiOn sreq.pdf.
3) 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.
AIRS
Point
Pollutant
CAS #
BIN
Uncontrolled
Emission
Rate
(Ib/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (Ib/yr)
005
Benzene
71432
A
12039
Yes
602
Toluene
108883
C
9508
Yes
475
Ethylbenzene
100414
C
1589
Yes
79
Xylenes
1130207
C
3568
Yes
178
n -Hexane
110543
C
64979
Yes
3249
4) The emission levels contained in this permit are based on the following emission factors:
Point 005:
CAS #
Pollutant
Weight
Fraction of
Gas (%)
Emission
Factors
Uncontrolled
Emission Factors
Controlled
Source
NOx
_
0.068
lb/MMBtu
0.068 lb/MMBtu
AP -42
CO
---
0.37 lb/MMBtu
0.37 lb/MMBtu
AP -42
VOC
43.11
30158.3964
lb/MMSCF
1507.9198
lb/mmscf
Engineering
Calculation
71432
Benzene
0.173
120. 9932
lb/MMSCF
6.050 lb/mmscf
Engineering
Calculation
108883
Toluene
0.0137
95. 5540
lb/MMSCF
4.7777 lb/mmscf
Engineering
Calculation
100414
Ethylbenzene
0.023
15. 9675
lb/MMSCF
0.7984 lb/mmscf
Engineering
Calculation
1330207
Xylenes
0.051
35. 8569
lb/MMSCF
1.7928 lb/mmscf
Engineering
Calculation
110543
n -hexane
0.934
653.0579
Ib/MMSCF
32.6529 lb/mmscf
Engineering
Calculation
AIRS ID: 123/9A31
Page 6 of 7
Note:
Dry
olora;Dep^ m t ' blic Health and Environment
Air Pollution Control Division
WI. CV
The uncontrolled VOC and IHAP emissions for this point were calculated using the August 22,
2012 analysis of a gas sample collected from the Bringelson Ranch 33-21 well. The controlled
VOC and HAP emissions factors for point 005 are based on the flare control efficiency of 95%.
5) 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.
6) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic minor Source:
VOC, n -hexane, total HAPS
NANSR
Synthetic Minor Source:
VOC
MACT HH
Area Source Requirements: Not Applicable
7) 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.govi
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
SubpartA— SubpartKKKK
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
SubpartA — Subpart?
MACT
63.600-63.1199
Subpart M — 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
8) 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/oiloasperm ittinq. htm I
AIRS ID: 12319A31
Page 7 of 7
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