HomeMy WebLinkAbout20133317.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
Weld County Clerk & Recorder
1402 N 17th Ave
Greeley, CO 80631
November 22, 2013
Dear Sir or Madam:
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
(303) 692-3090
PECEIVEP
WELD igei�hlTY
COMMLa"' L) NETS
Colorado Department
of Public Health
and Environment
On November 26, 2013, the Air Pollution Control Division will publish a public notice for Carrizo Oil and
Gas, Inc. — Jones 18-14-10-59, 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,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
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2013-3317
STATE OF COLORADO
John W. Hickenlooper, Governor
Larry Wolk, MD, MSPH
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
www.colorado.gov/cdphe
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
(303) 692-3090
Website Title: Carrizo Oil and Gas, Inc. —Jones 18-14-10-59 — Weld County
Released To: The Greeley Tribune
On: November 22, 2013
Published: November 26, 2013
PUBLIC NOTICE OF A PROPOSED PROJECT
OR ACTIVITY WARRANTING PUBLIC COMMENT
Colorado Department
of Public Health
and Environment
Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado
Air Pollution Control Division for the following source of air pollution:
Applicant: Carrizo Oil and Gas, Inc.
Facility: Jones 18-14-10-59
crude oil production site
Lot 14, Section 18, T10N, R59W
Weld County
The proposed project or activity is as follows: The applicant proposes a well flare with a requested throughput of
36 MMscf of separator vapors per year.
The Division has determined that this permitting action is subject to public comment per Colorado Regulation No.
3, Part B, Section III.C due to the following reason(s):
• permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a
(25 tpy in a non -attainment area and/or 50 tpy in an attainment area)
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 13 WE1222 have been filed
with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the
Division's website at www.colorado.gov/cdphe/AirPublicNotices
The Division hereby solicits submission of public comment from any interested person concerning the ability of
the proposed project or activity to comply with the applicable standards and regulations of the Commission. The
Division will receive and consider written public comments for thirty calendar days after the date of this Notice.
Any such comment must be submitted in writing to the following addressee:
Kirk Bear
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-Bl
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO:
DATE ISSUED:
ISSUED TO:
13WE1222
Carrizo Oil and Gas, Inc.
Issuance 1
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the Jones 18-14-10-59, located in Lot 14 of Section 18,
Township 10N, 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
005
Separator controlled by a 25' flare stack. Flare has a
minimum combustion efficiency of 95%. The flare is not
enclosed.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR
QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED
IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen
days after issuance of this permit, by submitting a Notice of Startup form to the
Division. The Notice of Startup form may be downloaded online at
www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of
the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No.
3, Part B, Section III.G.1 and can result in the revocation of the permit.
2. Within one hundred and eighty days (180) after issuance of this permit, compliance with the
conditions contained in this permit shall be demonstrated to the Division. It is the owner or
operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate
compliance within 180 days may result in revocation of the permit. (Reference: Regulation
No. 3, Part B, 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: 123-9AE4-005 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 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.)
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Reference: Regulation No. 3, Part B, Section III.E.)
5. The following information for all permitted equipment shall be provided to the Division within
fifteen (15) days after issuance of permit.
• manufacturer
• model number
• serial number
This information shall be included with the Notice of Startup submitted for the equipment.
(Reference: Regulation No. 3, Part B, III.E.)
6. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission Type
NO,VOC
CO
SEPARATOR
005
2.2
42.6
11.7
Point
See "Notes to Permit Holde #4' for information on emission factors and methods used to calculate
limits.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from
each emission unit, on a rolling twelve (12) month total. By the end of each month a new
twelve-month total shall be calculated based on the previous twelve months' data. The
permit holder shall calculate emissions each month and keep a compliance record on site or
at a local field office with site responsibility, for Division review. This rolling twelve-month
total shall apply to all permitted emission units, requiring an APEN, at this facility.
8. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
AIRS ID: 123-9AE4.005 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
005
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
005
Natural gas flaring
36.0 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.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
AIRS ID: 123-9AE4-005 Page 3 of 8
Colorado Department of Public Health and Environment
Air Pollution Control Division
15. The owner or operator shall demonstrate compliance with Condition 11 using EPA Method
9 to measure opacity from the flare. (Reference: Regulation No. 1, Section II.A.5).
Periodic Testing Requirements
16. On an annual basis, the operator shall complete a site specific extended gas analysis of the
natural gas produced at this site that is routed to the flare in order to verify the VOC content
(weight fraction) of this emission stream used in the permit application. Results of testing
shall be used to determine site -specific emission factors using Division approved methods.
ADDITIONAL REQUIREMENTS
17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3,
Part A, II.C)
a. Annually whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of
five (5) tons per year or more, above the level reported on the last APEN; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above
the level reported on the last APEN submitted to the Division.
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
c. Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
18. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit)
shall apply to this source at any such time that this source becomes major solely by virtue of
a relaxation in any permit condition. Any relaxation that increases the potential to emit
above the applicable Federal program threshold will require a full review of the source as
though construction had not yet commenced on the source. The source shall not exceed
the Federal program threshold until a permit is granted. (Regulation No. 3 Part D).
GENERAL TERMS AND CONDITIONS
19. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
20. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide "final" authority for this activity or operation of this source. Final authorization of
the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
AIRS ID: 123-9AE4-005 Page 4 of 8
Colorado Department of Public Health and Environment
Air Pollution Control Division
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.
21. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the applicant and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the applicant or applicant's agents. It is valid only for the
equipment and operations or activity specifically identified on the permit.
22. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
23. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ad initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the applicant, or the Division revokes a permit, the applicant
or owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Kirk Bear
Permit Engineer
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Carrizo Oil and Gas, Inc.
AIRS ID: 123-9AE4-005
Page 5 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:
http://www.cdphe.state.co.us/requlations/a irregs/100102agcccom monprovisionsreq.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?
Controlled
005
benzene
71432
A
10901
yes
545
n -hexane
110543
C
56598
yes
2830
toulene
108883
C
7755
yes
388
ethyl benzene
100414
C
1059
yes
53
xylene
1330207
C
1321
yes
66
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
27.0
lb/MMBtu
1.3
lb/MMBtu
mass balance
CO
0.37
lb/MMBtu
0.37
lb/MMBtu
AP -42
NOx
.068
lb/MMBtu
.068
lb/MMBtu302.8
AP 42
71432
benzene
lb/MMscf
15.1
lb/MMscf1572.2
mass balance
110543
n -hexane
lb/MMscf
78.6
lb/MMscf215.4
mass balance
108883
toulene
lb/MMscf
10.8
lb/MMscf
mass balance
100414
ethyl
benzene
29.41
lb/MMscf
1.5
lb/MMscf
mass balance
AIRS ID: 123-9AE4-005
Page 6 of 8
Colorado Department of Public Health and Environment
Air Pollution Control Division
CAS #
Pollutant
Emission
Factors
Uncontrolled
Emission
Factors
Controlled
Source
1330207
xylene
36.7
lb/MMscf
1.8
lb/MMscf
mass balance
Note: The uncontrolled VOC and HAP emissions for this point were calculated using the 29 October
2012 analysis of a gas sample collected from the Jones 18-14-10-59 well pad. The controlled
VOC and HAP emissions factors for point 005 are based on the flare control efficiency of
95%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this
permit is valid for a term of five years from the date it was received by the Division. A revised APEN
shall be submitted no later than 30 days before the five-year term expires. Please refer to the most
recent annual fee invoice to determine the APEN expiration date for each emissions point associated
with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-
3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, HAPs
PSD
Synthetic Minor Source of: VOC
MACT NH
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.>;poaccess.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 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
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:
httpliwym.cdphe.state.co.us/apioilqaspermitting.html
AIRS ID: 123-9AE4-005
Page 7 of 8
Colorado Department of Public Health and Environment
Air Pollution Control Division
AIRS ID: 123-9AE4-005 Page 8 of 8
Construction Permit Application
Preliminary Analysis Summary
Section 1 — Applicant Information
Company Name:
Carrizo Gas and Oil, Inc.
Permit Number:
13WE1222
Source Location:
Lot 14, Section 18, T10N, R59W
AIRS ID:
123-9AE4-005: Separator controlled by a 25' flare stack.
Date:
23 May 2013
Review Engineer:
Kirk Bear
Control Engineer:
Christopher Laplante
2 — Action Completed
X
Initial Approval
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?
t
I 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
I
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? 14 January 2013
Section 4 — Source Description
AIRS Point
Equipment Description
005
Separator
Is this a portable source?
Yes
X
No
Is this location in a non -attainment area for any criteria
pollutant?
Yes
X
No
If "yes", for what pollutant?
PM,0
CO
Ozone
Is this location in an attainment maintenance area for
an criteria ollutant?
Yes
X
No
If "yes", for what pollutant?
(Note: These pollutants are subject to minor source
RACT er Regulation 3, Part B, Section III.D.2)
PM10
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)
Yes
X I 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
36.0 MM scf/yr
Basis for Actual Emissions Reported During this APEN Filing (Reported to inventory)
AIRS Point
Process Consumption/ThroughputlProduction
Data Year
Separator
36.0 MM scf/yr
2013
Basis for Permitted Emissions (Permit Limits)
AIRS Point
Process Consumption/Throughput/Production
Separator
36.0 MM scf/yr
Does this point use a control device?
X
Yes
No
AIRS Point
Process
Control Device Description
% Reduction Granted
Separator
I
Flare with a 25' stack
95
Section 6 — Emission Summary
(tons per year)
Point
NO„
VOC
CO
SOx
PM10
Single
HAP
Total
HAP
PTE:
005
2.2
852.5
11.7
---
---
28.3
38.8
Controlled point
source emission rate:
005
2.2
42.6
11.7
---
---
1.4
1.9
TOTAL PERMITTED
(TPY)
005
2.2
42.6
11.7
---
---
1.4
1.9
Section 7 — Non -Criteria / Hazardous Air Pollutants
Pollutant
CAS #
BIN
Uncontrolled
Emission Rate
(Iblyr)
Are Me
emissions
reportable?
Controlled Emission
Rate (lb/yr)
Separator - Point 005
benzene
71432
A
10901
yes
545
n -hexane
110543
C
56598
yes
2830
toulene
108883
C
7755
yes
388
ethyl benzene
100414
C
1059
yes
53
xylene
1330207
C
1321
yes
66
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
X
No
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?
005
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
NA NSR
X
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?
Yes
No
If "yes", for which pollutants? Why? VOC
For Reg. 3, Part B, 1II.C.1.a (emissions increase > 25/50 tpy)?
X
Yes
No
For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)?
Yes
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 Monoxide and Sulfur Dioxide
005
Section 1I.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
005
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
005
Part A-APEN Requirements
Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for:
each individual emission point in an attainment area with uncontrolled actual emissions of
two tons per year or more of any individual criteria pollutant (pollutants are not summed)
for which the area is in attainment.
(Applicant is required to file an APEN since emissions exceed two tons per year
VOC)
005
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
005
None
Regulation 7 — Volatile Organic Compounds
005
Xli VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS
OPERATIONS
This point is not located in the 8 -hr ozone control area; therefore, this point is not
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
005
None
Section 13 — Aerometric Information Retrieval System Coding Information
Point
Process
Process Description
Emission
Factor
Pollutant /
CAS #
Fugitive
(Y/N)
Emission Factor
Source
Control
(0/0)
005
01
Separator
27.0
lb/MMBtu
VOC
No
Mass Balance
95
0.068
lb/MMBtu
NOx
No
AP -42,
Table 13.5-1
NA
0.37
Ib/MMBtu
CO
No
AP -42,
Table 13.5-1
NA
302.8
Ib/MMscf
benzene
No
Mass Balance
95
1572.2
Ib/MMscf
n -hexane
No
Mass Balance
95
215.4
Ib/MMscf
toulene
No
Mass Balance
95
29.4
lb/MMscf
ethyl
benzene
No
Mass Balance
95
36.7
Ib/MMscf
xylene
No
Mass Balance
95
SCC
31000205 -Flares
Page 4
Section 14 — Miscellaneous Application Notes
AIRS Point
005
Separator
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/lb-mol) at 60F and 1
atmosphere
Emissions generated from the separator are:
An extended gas analysis was provided in the application dated 1/14/2013. 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:
05/23/2013
Application Date:
01/14/2013
Facility Information
Permit No.
13WE1222
AI Rs
County #
Facility #
123 Weld
Point #
9AE4
005
SEPARATOR
Carrizo Oil and Gas, Inc.
Jones 18-14-10-59
Lot 14, Section 18, T10N, R59W
Facility Equipment ID
Company Name:
Source Name:
Colorado Department of Public Health and Environment
Air Pollution Control Division
Attainment Status
PM10
Attainment
PM2,5
Attainment
SOx
Attainment
NOx
Attainment
VOC
Attainment
CO
Attainment
Source Location:
SIC:
211111
5394
Elevation (feet)
x
New Permit
(CP1)
Modification
(Issuance #)
APEN
Required/Permit
Exempt
Transfer of
Ownership
Notes
APEN
Exempt/Permit
Exempt
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
36.00 MMscf/yr 4109.6 scf/hr
31.480 Ib/Ib-mol 0.099 MMscf/d
3.06 MMscf/mo
mole %
MW
lbx/ibmol
mass fraction
E
lb/hr
Iblyr
tp,
Helium
0.01
4.0026
0.000
0.000
Helium
0.0
38
0.02
CO2
2.73
44.01
1.201
0.038
CO2
13.0
114124
57.06
N2
0.73
28.013
0.204
0.006
N2
2.2
19424
9.71
methane
53.004
16.041
8.502
0.270
methane
92.2
807613
403.81
ethane
11.9505
30.063
3.593
0.114
ethane
39.0
341257
170.63
propane
14.8574
44.092
6.5509
0.208
propane
71.0
622251
311.13
isobutane
1.8085
58.118
1.0511
0.033
isobutane
11.4
99837
49.92
n -butane
7.1278
58.118
4.1425
0,132
n -butane
44.9
393496
196.74
isopentane
1.6537
72.114
1.1925
0.038
isopentane
12.9
113276
56.64
n -pentane
2.4423
72.114
1.!61'2
0.056
n -pentane
19.1
16/295
83.65
cyclopentane
0.2783
70.13
0.1952
0.006
cyclopentane
2.1
18539
9.27
n -Hexane
0.6914
86.18
0.5958
0.019
n -Hexane
6.5
56598
28.30
cyclohexane
0.1902
84.16
0.1601
0.005
cyclohexane
1.7
15205
7.60
Otherhexanes
1.1584
86.18
0.9983
0.032
Otherhexanes
10.8
94826
47.41
heptanes
0.6443
100.21
0.6457
0.021
heptanes
7.0
61329
30.66
methyicyclohexane
0.1343
98.19
0.1319
0.004
methylcyciohexane
1.4
12526
6.26
224-TMP
0.0003
114.23
0.0003
0.000
224-TMP
0.0
33
0.02
Benzene
0.1469
78.12
0.1148
0.004
Benzene
1.2
10901
5.45
Toluene
0.0886
92.15
0.0816
0.003
Toluene
0.9
7755
3.88
Ethylbenzene
0.0105
106.17
0.0111
0.000 Ethylbenzene
0.1
1059
0.53
Xylenes
0.0131
106.17
0.0139
0.000 �Xylenes
0.2
1321
0.66
Produced Natural Gas Venting/Flaring Preliminary Analysis
Colorado Department of Public Health and Environment
Air Pollution Control Division
IC8+ Heavies I 0.28191 117 6101 0.3315 I 0.011 1C8+ Heavies 1 3.6 I 31492
VOC mess fraction:
31.480
Notes
Mole %, MW, and mass fractions from Jones 18-14-10-59 gas analysis.
Emissions are based on 1008 hours of operation per year.
0.5711 Total VOC Emissions (Uncontrolled)
annual limit assuming 95% control
monthly limit assuming 95% control (1b/mo.)
15.75
853.9
42.7
7252.0
Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment
Air Pollution Control Division
Emissions Summary
1.90
tpy NOX
Uncontrolled/PTE
10,32
tpy CO
853.864
tpy VOC
Controlled
42.693
tpy VOC
Uncontrolled
Total (lb/yr)
Bin
Scenario A
Reportable?
Controlled
Total (lb/yr)
Benzene
10901
A
Yes
545
Toluene
7755
C
Yes
388
Ethylbenzene
1059
C
Yes
53
Xylenes
1321
C
Yes
66
n -hexane
56598
C
Yes
2830
224-TMP
33
C
No
2
Regulatory Applicability
AQCC Regulation 1,
This source is subject to the opacity requirements for flares in Section II.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,"
la ion 3
Part A:
An APEN is required for this source because uncontrolled VOC emissions
exceed two tons per year in an attainment area.
Part B:
A permit is required for this source because uncontrolled VOC emissions from
this facility exceed five tons per year in an attainment area.
This source is not subject to Section III.D.2 (Minor Source RACT) because it
is not located in a nonattainment area.
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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Section 02 — Re
Section 01 — Administrative Information
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713-328-1060
Fax Number:
Patricia.Moden@crzo.net
E-mail Address:
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