HomeMy WebLinkAbout20132559.tiffSTATE OF COLORADO
John W. Hickenlooper, Governor
Karin McGowan
Interim Executive Director
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
Weld County Clerk & Recorder
1402 N 17th Ave
Greeley, CO 80631
September 3, 2013
Dear Sir or Madam:
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
(303) 692-3090
Colorado Department
of Public Health
and Environment
REceive0
SEP 0 5 2 �'
WELD CCU
CONSocWELD CCU
On September 6, 2013, the Air Pollution Control Division will publish a public notice for Carrizo Oil and
Gas, Inc. — Castor 2-36-31-9-29, 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-B 1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
3 /)
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
RJ"0
eca ?Lift I-PiN I
"to,
2013-2559
Colorado Department of Public Health and Environment
Air Pollution Control Division
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.)
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
NO,
VOC
CO
TANKS
001
---
30.5
---
Point
See "Notes to Permit Holder' 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 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.
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
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
TANKS
001
48" Cimarron Enclosed Flare
VOC, HAPS
PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates shall be maintained by the owner or operator
AIRS ID: 123/9AC3/001
Page 2 of 7
Colorado Department of Public Health and Environment
Air Pollution Control Division
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
Process Parameter
Annual
ii
TANKS
001
Crude oil throughput
49,640
bbl/year
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
9. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the
subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.)
(State only enforceable)
10. 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. This source is subject to the odor requirements of Regulation No.
2. (State only enforceable)
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 owner or operator shall follow the most recent 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. No compliance requirements under this section.
ADDITIONAL REQUIREMENTS
14. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3,
Part A, II.C)
a. Annually by April 30t 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
AIRS ID: 123/9AC3/001 Page 3 of 7
Colorado Department of Public Health and Environment
Air Pollution Control Division
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
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.
15. 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
16. 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.
17. 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 IILG. 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.
18. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the owner or operator 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 owner or operator or owner or operator's agents. It is valid
only for the equipment and operations or activity specifically identified on the permit.
19. 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.
20. 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
AIRS ID: 123/9AC3/001 Page 4 of 7
Colorado Department of Public Health and Environment
Air Pollution Control Division
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 owner or operator, or the Division revokes a permit, the
owner or operator or owner or operator of a source may request a hearing before the AQCC
for review of the Division's action.
21. 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.
22. 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:
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Carrizo Oil & Gas, Inc.
AIRS ID: 123/9AC3/001 Page 5 of 7
Colorado Department of Public Health and Environment
Air Pollution Control Division
Notes to Permit Holder at the time of this permit issuance:
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 owner or operator 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 complete 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 owner or operator 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/airregs/100102agcccommonprovisionsreq. 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.
AIRS
Point
Pollutant
CAS #
BIN
Uncontrolled
lb/yr
Reportable?
Controlled
lb/yr
001
Benzene
71432
A
27600
yes
1380
Toluene
108883
C
23728
yes
1186
Ethylbenzene
100414
C
2184
yes
109
Xylenes
1130207
C
6801
yes
340
n -Hexane
110543
C
137503
yes
6875
2,2,4-
Trimethylpentane
540841
C
8290
yes
415
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Emission Factors
Uncontrolled
lb/bbl
Emission Factors
Controlled
lb/bbl
Source
VOC
24.58
1.23
TANKS
71432
Benzene
.556
.0278
TANKS
108883
Toluene
.478
.0239
TANKS
100414
Ethylbenzene
.044
.0022
TANKS
1130207
Xylenes
.137
.0069
TANKS
110543
n -Hexane
2.77
.1385
TANKS
540841
2'2'4
Trimethylpentane
.167
.0084
TANKS
Note: The controlled emissions factors for point 001 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
AIRS ID: 123/9AC3/001
Page 6 of 7
Colorado Department of Public Health and Environment
Air Pollution Control Division
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
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, HAPS
NANSR
Synthetic Minor Source of: VOC, HAPS
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:
hllp://ecfi-.apoacccss.govi
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
I 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/oiloaspermitting.html
AIRS ID: 123/9AC3/001 Page 7 of 7
Construction Permit Application
Preliminary Analysis Summary
Section 1 —Applicant Information
Company Name:
Carrizo Oil & Gas, Inc.
Permit Number
13WE1042
Source Location:
NWNE, Section 36, T9N, R59W
Equipment Description:
Four 400 bbl crude oil storage tanks
AIRS ID:
123-9AC3-001
Date:
12 March 2013
Review Engineer:
Kirk Bear
Control Engineer:
Christopher Laplante .
Section 2 — Action Completed
X
Initial Approval
Modification
APEN Required/Permit Exempt
Final Approval
Transfer of Ownership
APEN Exempt/Permit Exempt
* If tank is a true minor source at a true minor facility, it may be granted "Final Approval" without first
being issued an Initial Approval permit
*Grandfathered exemption is for any tanks in service prior to December 30, 2002
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?
11 April 2013
Section 4 — Source Description
AIRS Point
Equipment Description
001
Four 400 bbl crude oil storage tanks
Is this a portable source?
Yes
X
No
Is this location in a non -attainment area for any criteria
pollutant?
X
Yes
No
If "yes", for what pollutant?
Milo
CO
X
Ozone
Is this location in an attainment maintenance area for
any criteria pollutant?
Yes
X
No
If "yes", for what pollutant?
(Note: These pollutants are subject to minor source
RACT per Regulation 3, Part B, Section III.D.2)
PKo
CO
Ozone
Is this source located in the 8 -hour ozone non -
attainment region? (Note: If "yes" the provisions of
Regulation 7, Sections XII and XVII.C may apply)
X
Yes
No
Page 1
Section 5— Emission Estimate Information
AIRS Point
Emission Factor Source
001
E&P Tanks.
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
001
49,640 bbl per year
Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory)
AIRS Point
Process Consumption/Throughput/Production
Data Year
001 I 49,640 bbl per year
2012
Basis for Permitted Emissions (Permit Limits)
AIRS Point
Process Consumption/Throughput/Production
001
49,640 bbl per year
Does this source use a control device?
X
Yes
No.
AIRS Point
Process
Control Device Description
% Reduction
Granted
Granted
001
01
Combustor
95
Section 6 — Emission Summary (tons per year)
Point
NO„
VOC
CO
Single HAP
Total HAP
PTE:
001
--
610
--
68.8
103.1
Uncontrolled point
source emission rate:
001
--
610
--
68.8
103.1
Controlled point
source emission rate:
001
--
30.5
--
3.4
5.2
Total Permitted
001
--
30.5
--
3.4 5.2
Section 7 — Non -Criteria / Hazardous Air Pollutants
Pollutant
CAS #
BIN
Uncontrolled
Emission Rate
(Ib/yr)
Are the
emissions
reportable?
Controlled Emission
Rate (lEmi
benzene
71432
A
+ 27600
yes
1380
n -hexane
110543
C
137503
yes
6875
ethylbenzene
100414
C
2184
yes
109
toulene
108883
C
23728
yes
1186
xylene
1330207
C
6801
yes
340
2,2,4 trimethylpentane
540841
C
8290
yes
415
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
standard?
Yes I X
No
Page 2
If "yes", complete the information listed below
AIRS Point
Process
Pollutant
Regulatory Basis
Test Method
001
01
Section 9 — Source Classification
Is this a new previously un-permitted source?
X
Yes
No
What is this facility classification?
True
Minor
X
Synthetic
Minor
Major
Classification relates to what programs?
X
Title V
X
PSD
X
NA NSR
MACT
Is this a modification to an existing permit?
Yes
X
No
If "yes" what kind of modification?
Minor
Synthetic
Minor
Major
Section 10 — Public Comment
Does this permit require public comment per CAQCC Regulation 3?
X
Yes
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.ii (subject to MACT)?
Yes
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
Air Quality Standards (NAAQS)?
If "yes", for which pollutants? Why?
Yes X No
AIRS Point
Section 12 —Regulatory Review
Regulation 1.- Particulate, Smoke, Carbon: Monoxideand Sulfur Dioxide
001
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 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 ^ .
001
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
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.
Page 3
Regulation 3 - APENs, Construction Permits. Operatin Permits, PSD
001
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 ton per year or more of any individual criteria pollutant (pollutants are not summed)
for which the area is in non -attainment.
(Applicant is required to file an APEN since emissions exceed two tons per year
VOC)
001
Part B - Construction Permit Exemptions
Applicant is required to obtain a permit since uncontrolled VOC emissions from this
facility are greater than the 5.0 TPY threshold (Reg. 3, Part B, Section II.D.3.a)
001
R
Regulation 6 - New Source Performance Standards
--
NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84.
Is this source greater than 19,800 gallons (471 bbl)? Yes
Is this source subject to NSPS Kb? No, 60.110b(d)(4)
Regulation 7 — Volatile Organic Com.ounds
001
XII. VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS
Tank is crude oil, Regulation 7 does not apply.
Regulation 8 — Hazardous Air Pollutants
001
MACT EEEE: Organic Liquids Distribution
This source is not subject to MACT EEEE because it is located at a "production field
facility" as defined in 40 CFR 63.761 (located upstream of the natural gas processing
plant).
001
MACT HH
This source is not subject to MACT HH because it is not located at a major source of HAP.
Section 13 — Aerometric Information Retrieval System Coding Information
Point
Process
Process
Description
Emission
Factor
Pollutant /
CAS #
Fugitive
(Y/N)
Emission Factor Source
Control
(%)
' 001
01
E&P crude oil
Storage Tanks
24.58 lb/bbl
VOC
No
E&P Tanks
95
.556 lb/bbl
benzene
71432
No
E&P Tanks
95
2.77 lb/bbl
n -hexane
110543
No
E&P Tanks
95
.044 lb/bbl
e benzene
100414
No
E&P Tanks
95
.478 lb/bbl
toulene
108883
No
E&P Tanks
95
.137 lb/bbl
xylene
1330207
No
E&P Tanks
95
.167 lb/bbl
2'2'4 TMP
540841
No
E&P Tanks
95
SCC
40400311 — Fixed
Roof Tank,
Condensate, working+breathing+flashing losses
Section 14 -- Miscellaneous Application Notes
AIRS Point
001 Crude Oil Storage Tanks
Conversion from lb/bbl to lb/1000 gal - ((lb/bbl e.f.) * 1000) / 42
Page 4
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO: 13WE1043
Issuance 1
DATE ISSUED:
ISSUED TO: Carrizo Oil and Gas, Inc.
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the Castor 2-36-31-9-29, located in the NWNE of Section 36,
Township 9N, Range 59W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
SEPARATOR
002
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, bV 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, 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
AIRS ID: 123/9AC3/002 Page 1 of 8
Wellhead Version 2012-1
Colorado Department of Public Health and Environment
Air Pollution Control Division
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
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 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.)
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
Equipment ID
AIRS
Point
Tons per Year
Emission Type
NO,
VOC
CO
SEPARATOR
002
1.1
18.7
5.8
Point
See "Notes to Permit Holde #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 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.)
AIRS ID: 123/9AC3/002 Page 2 of 8
Colorado Department of Public Health and Environment
Air Pollution Control Division
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
SEPARATOR
002
Separator controlled by a 25' flare stack
VOC, HAPs
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
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
SEPARATOR
002
Natural gas flaring
19.0 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 this point, 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.)
AIRS ID: 123/9AC3/002 Page 3 of 8
Colorado Department of Public Health and Environment
Air Pollution Control Division
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
15. The operator shall complete an initial site specific extended gas analysis of the natural gas
produced at this site in order to verify the VOC, benzene, toluene, ethyl benzene, xylenes, n -
hexane, and 2,2,4-trimethylpentane 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. Results of site -specific sampling and analysis
shall be submitted to the Division as part of the self -certification and used to demonstrate
compliance with the emissions factors chosen for this emissions point.
16. 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
17. 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
18. 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, orwhenevera 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.
19. 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
AIRS ID: 123/9AC3/002 Page 4 of 8
Colorado Department of Public Health and Environment
Air Pollution Control Division
20. 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.
21. 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.
22. 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.
23. 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.
24. 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.
25. 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.
26. 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.
AIRS ID: 123/9AC3/002 Page 5 of 8
Colorado Department of Public Health and Environment
Air Pollution Control Division
By:
Kirk Bear
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Carrizo Oil and Gas, Inc.
AIRS ID: 123/9AC3/002 Page 6 of 8
Colorado Department of 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:
httq://www.cdphe.state.co. us/req ulations/airreqs/100102agcccommonprovisionsreq. 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.
AIRS
Point
Pollutant
CAS #
BIN
Uncontrolled
Reportable?
(lb/yr) (Ib/yr)
Controlled
002
benzene
71432
A
2795
yes
147
n -hexane
110543
C
15442
yes
812
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Emission
Factors
Uncontrolled
Emission
Factors
Controlled
Source
VOC
174.6
lb/MMBtu
8.7
Ib/MMBtu
mass balance
CO
0.37
lb/MMBtu
0.37
lb/MMBtu
AP -42
NOx
.068
lb/MMBtu
.068
lb/MMBtu147
AP 42
71432
benzene
Ib/MMscf
7.35
lb/MMscf812
mass balance
110543
n -hexane
Ib/MMscf
40.6
Ib/MMscf
mass balance
Note: The uncontrolled VOC and HAP emissions for this point were calculated using the 15 March
2013 analysis of a gas sample collected from the Castor 2-36-11-9-69 well pad. The
controlled VOC and HAP emissions factors for point 002 are based on the flare control
efficiency of 95%.
AIRS ID: 123/9AC3/002
Page 7 of 8
Colorado Department of Public Health and Environment
Air Pollution Control Division
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
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, HAPs
NANSR
Synthetic Minor Source of: VOC, HAPs
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://ecfr.gpoaccess.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 )OCXXXX
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/apioilqaspermitting.html
AIRS ID: 123/9AC3/002
Page 8 of 8
Construction Permit Application
Preliminary Analysis Summary
Section 1 — Applicant Information
Company Name:
Carrizo Gas and Oil, Inc.
Permit Number:
13WE1043
Source Location:
NWNE, Section 36, T9N, R59W
AIRS ID:
123/9AC3/002: Separator controlled by a 25' flare stack.
Date:
2 May 2013
Review Engineer:
Kirk Bear
Control Engineer:
Christopher Laplante
Section 2 — Action Completed
X
Initial Approval
i Modification
APEN Required/Permit Exempt
CP1
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?
11 April 2013
Section 4 — Source Description
AIRS Point
Equipment Description
002
Separator
Is this a portable source?
Yes
X
No
Is this location in a non -attainment area for any criteria
pollutant?
X
Yes
No
. If "yes", for what pollutant?
PM,°
CO
X
Ozone
Is this location in an attainment maintenance area for
any criteria pollutant?
Yes
X
No
If "yes", for what pollutant?
(Note: These pollutants are subject to minor source
RACT per Regulation 3, Part B, Section 111.O.2)
PM,o
CO
Ozone
Is this source located in the 8 -hour ozone non -
attainment region? (Note: If "yes" the provisions of
Re ulation 7, Sections XII and XVII.C may apply)
X
Yes
No
Page 1
Section 5 — Emission Estimate Information
AIRS Point
Emission Factor Source
Separator
AP -42 and mass balance
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
Separator
19 MM scf/yr
Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory)
AIRS Point
Process Consumption/Throughput/Production
Data Year
Separator
19 MM scf/yr
2012
Basis for Permitted Emissions (Permit Limits)
AIRS Point
Process Consumption/Throughput/Production
Separator
19 MM scf/yr
Does this point use a control device?
X
Yes
No
AIRS Point
Process
Control Device Description
% Reduction Granted
Separator
1
Flare with a 25' stack
95
Section 6 - Emission Summa ry (tons per year)
Point l
NO),VOC
CO
SOx
PM10
Single
HAP
Total
HAP
PTE:
002
1.1
374.2
5.8
---
---
7.7
9.1
Controlled point
source emission rate:
002
'1.1
18.7
5.8
---
---
.4
.5
TOTAL PERMITTED
(TPY)
002
1.1
18.7
5.8
---
---
.4
.5
Section 7 — Non -Criteria / Hazardous Air Pollutants
Pollutant
CAS #
BIN
Uncontrolled
Emission Rate
(Ib/yr)
Are the
emissions
reportable?
Controlled Emission
Rate (Ib/yr)
Separator - Point 002
benzene
71432
A 2795
yes
147
n -hexane
110543
C
15442
yes
812
Note: Regulation 3, Part A, Section lI.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
No
Will testing be required to show compliance with any emission rate or regulatory
standard?
Yes
X
If "yes', complete the information listed below
AIRS Point
Process
Pollutant
Regulatory Basis
Test Method
Page 2
Section 9 — Source Classification
Is this a new previously un-permitted source?
002
YES
X
NO
What is this point classification?
True Minor
Synthetic Minor
X
Major
What is this facility classification?
True
Minor
X
Synthetic
Minor
Major
Classification relates to what programs?
X
Title V
X
PSD
X
NA NSR
MACT
Is this a modification to an existing permit'
Yes
X
No
If "yes" what kind of modification?
Minor
Synthetic
Minor
Major
Section 10 — Public Comment
Does this permit require public comment per CAQCC Regulation 3?
X
Yes
No
If "yes", for which pollutants? Why? VOC
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)?
X
Yes
No
Section 11 — Modeling
Is modeling required to demonstrate compliance with National Ambient
Air Quality Standards (NAAQS)?
If "yes", for which pollutants? Why?
Yes
X
No
AIRS Point
Section 12 — Regulatory Review
Requlateti;1 - Partic[tlar'e'Smoke, Carbon Monoxide and Sulfur Dioxrde%t
002
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
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.
'�,�'" Requlation2cdor_` ,.
002
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
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.
Page 3
Regulation 3 - APENs, Construction Permits, Operating Permits, PSD
002
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 ton per year or more of any individual criteria pollutant (pollutants are not summed)
for which the area is in non -attainment.
(Applicant is required to file an APEN since emissions exceed one ton per year
VOC)
002
Part B — Construction Permit Exemptions
Applicant is required to obtain a permit since uncontrolled VOC emissions from this
facility are greater than the 5.0 TPY threshold (Reg. 3, Part B, Section II.D.3.a)
Regulation 6 - New Source Performance Standards`
002
None
Regulation 7 — Volatile Organic Compounds
002
XII VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS
OPERATIONS
This point is located in the 8 -hr ozone control area; therefore, this point is subject
to Section XII of this regulation.
XVII STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS
This facility is an oil and gas operation that operates equipment subject to Section
XVII of this regulation.
Regulation 8 — Hazardous Air Pollutants
002
None
Section 13 — Aerometric Information Retrieval System Coding Information
Point
Process
Process Description
Emission
Factor
Pollutant/
CAS #
Fugitive
(Y/N)
Emission Factor
Source
Control
o
(/o)
002
01
Separator
174.6
lb/MMBtu
VOC
No
Mass Balance
95
0.068
lb/MMBtu
N0x
No
AP -42,
Table 13.5-1
NA
0.37
lb/MMBtu
CO
No
AP -42,
Table 13.5-1
NA
147 lb/MMscf
benzene
No
Mass Balance
95
812 lb/MMscf
n -hexane
No
Mass Balance
95
SCC
31000205 -Flares
Page 4
Section 14 — Miscellaneous Application Notes
AIRS Point
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/Ib-mol) at 60F and 1
atmosphere
002
Separator
enerated from the separator are:
Uncontrolled tpy
Controlled tpy
NOx
1.1
NA
CO
5.8
NA
VOC
374.2
18.7
benzene
2795 lb
147 lb
n -hexane
15442 lb
812 lb
An extended gas analysis was provided in the application dated 12/12/2012. The gas analysis was
performed less than a year from 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
Produced Natural Gas Venting/Flaring Preliminary Analysis
Division Information
Engineer:
Kirk Bear
Control Engineer:
Christopher Laplante
Review Date:
05/02/2013
Application Date:
12/12/2012
Facility Information
Permit No.
13WE1043
AIRs
County #
Facility #
9AC3
002
SEPARATOR
Carrizo Oil and Gas, Inc.
Castor 2-36-31-9-29
NWNE Section 36, T9N, R59W
123 Weld
Point #
Facility Equipment ID
Colorado Department of Public Health and Environment
Air Pollution Control Division
Attainment Status
PM10
Attainment
PM2.5
Attainment
SOx
Attainment
NOx
Nonattainmen
VOC
Nonattainmen
CO
Attainment
Potentially Located within EAC - determine attainment status of NC
Company Name:
Source Name:
Source Location:
SIC:
211111
4916
Elevation (feet)
x
New Permit
(CPI)
Modification
(Issuance #)
APEN
Required/Permit
Exempt
Transfer of
Ownership
APEN
Exempt/Permit
Fxemnt
Notes
Equipment Description
This source vents natural gas from:
Emissions from this source are:
a well head separator
routed to an open -flame flare
Natural gas venting from a well head separator. Emissions from this source are routed to an open -
flame flare.
Emission Calculation Method
EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3)
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
Throughput (0)
MW
19 MMscf/yr
29.290 Ib/lb-mol
2168.9 scf/hr
0.000 MMscf/d
1.61 MMscf/mo
mole %
MW
Ibxllbmol
mass fraction
E
Ib/hr
Ib/yr
tpy
Helium
0
4.0026
0.000
0.000
Helium
0.0
0
0.00
CO2
2.27
44.01
0.999
0.034
CO2
5.7
50083
25.04
N2
0.58
28.013
0.162
0.006
N2
0.9
8145
4.07
methane
54.8054
16.041
8.791
0.300
methane
50.3
440727
220.36
ethane
14.7003
30.063
4.419
0.151
ethane
25.3
221551
110.78
propane
15.0427
44.092
6.6326
0.226
propane
38.0
332506
166.25
isobutane
1.7001
58.118
0.9881
0.034
isobutane
5.7
49534
24.77
n -butane
6.1632
58.118
3.5819
0.122
n -butane
20.5
179569
89.78
isopentane
1.2194
72.114
0.8794
0.030
isopentane
5.0
44084
22.04
n -pentane
1.6464
72.114
1.18/3
0.041
n -pentane
6.8
59521
29./5
cyclopentane
0.1496
70.13
0.1049
0.004
cyclopentane
0.6
5260
2.63
n -Hexane
0.3571
.86.18
0.3077
0.011
n -Hexane
1.8
15428
7.71
cyclohexane
0.0924
84.16
0.0778
0.003
cyclohexane
0.4
3898
1.95
Other hexanes
0.6237
86.18
0.5375
0.018
Other hexanes
3.1
26946
13.47
heptanes
0.2876
100.21
0.2882
0.010
heptanes
1.6
14448
7.22
methylcyclohexane
0.0623
98.19
0.0612
0.002
methylcyclohexane
0.4
3067
1.53
224-TMP
0.0002
114.23
0.0002
0.000
224-TMP
0.0
11
0.01
Benzene
0.0713
78.12
0.0557
0.002
Benzene
0.3
2792
1.40
Toluene
0.0377
92.15
0.0347
0.001
Toluene
0.2
1742
0.87
Ethylbenzene
0.0043
106.17
0.0046
0.000
Ethylbenzene
0.0
229
0.11
Xylenes
0.0078
106.17
0.0083
0.000
Xylenes
0.0
415
0.21
Produced Natural Gas Venting/Flaring Preliminary Analysis
1C8+ Heavies I
0.14361 116.8011 0.1677 0.006 1C8+ Heavies
VOC mass fraction:
29.290
Notes
Mole %. MW, and mass fractions from Castor 2-25 gas analysis.
Emissions are based on 1008 hours of operation per year,
Colorado Department of Public Health and Environment
Air Pollution Control Division
1.0 1 8408
0.5093 Total VOC Emissions (Uncontrolled)
annual limit assuming 95% control
monthly limit assuming 95% control (lb/mo.)
4.20
373.9
18.7
3175.8
Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment
Air Pollution Control Division
Emissions Summary
1.00
tpy NOX
Uncontrolled/PTE
5,44
tpy CO
373.929
tpy VOC
Controlled
18.696
tpy VOC
Uncontrolled
Total (Ib/yr)
Bin
Scenario A
Reportable?
Controlled
Total (Ib/yr)
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2792
A
Yes
140
Toluene
1742
C
Yes
87
Ethylbenzene
229
C
No
11
Xylenes
415
C
No
21
n -hexane
15428
C
Yes
771
224-TMP
11
C
No
1
Regulatory Applicability
AQCC Regulation 1
This source is subject to the opacity requirements for flares in Section Il.A.5:'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.'
AQCC Regulation 2 _
Section I.A applies to all emission sources. "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 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."
Part A:
An APEN is required for this source because uncontrolled VOC emissions
exceed one ton per year in a nonattainment area for ozone.
Part B:
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.
This source is subject to Section III.D.2 (Minor Source RACT) because it is
located in a nonattainment area. RACT for this source has been determined
to be the use of a flare to control emissions.
Is public comment
required?
Public Comment Required
Facility Status
This facility is a synthetic minor source of VOC/HAP for Title V applicability.
This facility is a synthetic minor source of VOC/HAP for PSD/NSR applicability.
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