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Home My WebLink About20160521.tiff 44, COPHE COLORADO Co Department of Public M* Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150O St PO Box 758 RECEIVED Greeley, CO 80632 January 26, 2016 JAN 2 9 2016 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On January 27, 2016, the Air Pollution Control Division will begin a 30-day public notice period for Carrizo Oil Et Gas, Inc. - Timbro Ranch 3 Multi-Pad. 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. Thepacket must be available forpublic inspection for aperiod of thirty (30) days from g P Y the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Ft Environment APCD-SS-B1 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 —P , 2016-0521 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe ,k, ,;:,`� C ws Ql John W. Hickenlooper,Governor ! Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer .� I '-*.ta76,",/ CDPHE Air Pollution Control Division CO s Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Carrizo Oil Et Gas, Inc. - Timbro Ranch 3 Multi-Pad - Weld County Notice Period Begins: January 27, 2016 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 Et Gas, Inc. Facility: Timbro Ranch 3 Multi-Pad Oil and Gas Exploration and Production Facility Lot 2 of Section 3, Township 9N, Range 59W Weld County The proposed project or activity is as follows: Operator is requesting permit coverage for three (3) low pressure separators, crude oil truck loadout, and twelve (12) crude oil storage vessels at a new synthetic minor oil and gas exploration and production facility. 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 15WE1219, 15WE1221 and 15WE1223 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 https://www.colorado.gov/pacific/cdphe/air- permit-public-notices 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: Harrison Slaughter Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd®state.co.us 1 I A CO L011400 „t VVV txw�n�.�cnxwas:.� nwmrr�;:�n,�.r, II A STATE OF COLORADO oCp COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT <4;A. AIR POLLUTION CONTROL DIVISION y r }NI TELEPHONE: (303)692-3150 #A ,►i" '4'1876+i CONSTRUCTION PERMIT PERMIT NO: 15WE1219 Issuance 1 DATE ISSUED:ISSUED TO: Carrizo Oil & Gas, Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas exploration and production facility, known as the Timbro Ranch 3 Multi-pad, located in Lot 2 of Section 3, Township 9N, Range 59W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Three (3) separators controlled by an open flare during gas SEPARATOR 001 pipeline downtime and maintenance. Flare has a minimum combustion efficiency of 95%. 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 of the latter of commencement of operation or issuance of this permit, by submittinq a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at https://www.colorado.gov/pacific/cdphe/other-air- permitting-notices. 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) of the latter of commencement of operation or 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, III.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 AIRS ID: 123/9E17 Page 1 of 9 Wellhead Version 2012-1 D olo De en f Pu and Airblic PollutionHealth ControlEnvironment Division on which such construction or activity was scheduled to commence as set forth in the permit 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 of the latter of commencement of operation or issuance of this 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 AIRS Tons per Year Equipment ID Point NO, VOC CO Emission Type SEPARATOR 001 2.8 36.8 15.3 Point See "Notes to Permit Holder #4" for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. Compliance with the 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. AIRS ID: 123/9E17 Page 2 of 9 ;E I doo A,, De - ent f Public Health and Environment Air Pollution Control Division 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.) Facility AIRS Pollutants Control Device Equipment ID Point Controlled SEPARATOR 001 Open Flare VOC and 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 AIRS Process Parameter Annual Limit Equipment ID Point SEPARATOR 001 Natural gas flaring 55.1 MMSCF The owner or operator shall monitor 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. 10. The owner or operator shall continuously monitor and record the volumetric flow rate of natural gas vented from the separators using a flow meter. The flow meter shall continuously measure flow rate and record total volumetric flow vented from each separator. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 11. 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) 12. These sources are subject to the odor requirements of Regulation No. 2. (State only enforceable) 13. The open flare covered by this permit has been approved as an alternative emissions control device under Regulation Number 7, Section XVII.B.2.e. The open flare must have no visible emissions during normal operations and be designed so that an observer can, by means of visual observation from the outside of the open flare, or by other convenient means approved by the Division, determine whether it is operating properly. This open flare must be equipped with an operational auto-igniter according to the following schedule: AIRS ID: 12319E17 Page 3 of 9 Dolo De ent f Public PollutionHealthand Control DivisionEnvironment • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto-igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto-igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 14. The separators covered by this permit are subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98%for hydrocarbons. OPERATING & MAINTENANCE REQUIREMENTS 15. 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 16. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, I I.C) a. Annually by April 30th 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 volatile organic compounds (VOC) and nitrogen oxides sources (NO,) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or AIRS ID: 123/9E17 Page 4 of 9 olo De - ent ,f Public Health and Environment Air Pollution Control Division For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 18. Federal regulatory program requirements (i.e. PSD, NANSR) 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 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 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 AIRS ID: 12319E17 Page 5 of 9 olo De en f PubD lic PollutionHealth Controland DivisionEnvironment 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: Harrison Slaughter Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Carrizo Oil & Gas, Inc. Permit for three(3) separators controlled by one (1) open flare at a new synthetic minor exploration and production facility. AIRS ID: 123/9E17 Page 6 of 9 010 „ De ent ,f 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: https://www.colorado.gov/pacific/cdphe/aqcc-reqs 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. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Point Pollutant CAS# BIN (Ib/yr) reportable? Rate(Ib/yr) Benzene 71432 A 3,846 Yes 193 Toluene 108883 C 3,074 Yes 154 Ethylbenzene 100414 C 198 No 10 001 Xylenes 1130207 C 604 Yes 31 n-Hexane 110543 C 25,670 Yes 1,284 2,2,4- 540841 C 495 Yes 25 Trimethylpentane 5) The emission levels contained in this permit are based on the following emission factors: Mole Emission Emission Fraction Factors Factors CAS# Pollutant of Gas Uncontrolled Controlled Source (%) (lb/MMscf) (lb/MMscf) NOx --- 101.7 101.7 AP-42, Table 13.5-1 CO --- 553.4 553.4 AP-42, Table 13.5-1 VOC 19.03 26,639.46 1,331.97 Engineering Calculation 71432 Benzene 0.0334 69.74 3.48 Engineering Calculation 108883 Toluene 0.0228 55.75 2.78 Engineering Calculation AIRS ID: 123/9E17 Page 7 of 9 olo De en f PubD lic PollutionHealth Controland DivisionEnvironment Mole Emission Emission Fraction Factors Factors CAS# Pollutant of Gas Uncontrolled Controlled Source (%) (Ib/MMscf) (lb/MMscf) 100414 Ethylbenzene 0.0013 3.58 1.79x10-' Engineering Calculation 1330207 Xylenes 0.004 10.95 5.47x10"' Engineering Calculation 110543 n-hexane 0.2026 465.53 23.27 Engineering Calculation 540841 2,2,4-TMP 0.0028 8.97 4.48x10-' Engineering Calculation Note: The uncontrolled VOC and HAP emissions for this point were calculated using the June 12, 201 analyses of a gas samples collected from the Timbro Ranch 3 Multi-pad 1-34-10- 59, 2-34-10-59, and 2-3-9-59 wells. The controlled VOC and HAP 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 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 Status Requirement Operating Permit Synthetic Minor Source of: VOC, n-Hexane, and Total HAPs PSD Synthetic Minor Source of: VOC, n-Hexane, and Total HAPs 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 7777—Subpart MMMMM AIRS ID: 123/9E17 Page 8 of 9 a alolo : De '� entPublic Health and Environment Air Pollution Control Division MACT 63.8980-End Subpart NNNNN-Subpart X)O(XXX 9) A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification AIRS ID: 12319E17 Page 9 of 9 Division Information Engineer: Harrison Slaughter Control Engineer: Chris Laplante Review Date: 12/16/2015 Application Date: 08/14/2015 Facility Identifiers Permit No. 15WE1219 Potentially located in ozone nonattainment area AIRs County# 123 'Weld Facility# 9E17 Facility Type: exploration and production facility ❑Located in the 8-hour non-attainment area? 0 True Minor 0 Synthetic Minor for: I✓ VOC r NOx r CO Administrative Information Company Name: Carrizo Oil &Gas, Inc. Source Name: Timbro Ranch 3 Multi-pad Source Location: Lot 2 of Section 3, Township 9N, Range 59W SIC: 1311 Address 1: Carrizo Oil&Gas, Inc. Mailing Address 2: 500 Dallas,Suite 2300 Address ty,State Zip: Houston,TX, 77002 Name: Patricia Whitenight Person To Phone: 713-328-1036 Contact Fax: 713-328-1060 Email: patricia.whitenight@crzo.net 'Requested Action Self Certification Required? Yes Issuance Number: 1 Source De scription: tion: Oil and gas exploration and production facility known as the Timbro Ranch 3 Multi-pad, located in the Lot 2 of Section 3,Township 9N, Range 59W,Weld County,Colorado. Point Name Type Control Action Newly 001 Separator Separator Venting Flare reported source Three(3)separators controlled by one open flare during maintenance and sales line downtime.Flare has a 001 minimum control efficiency of 95%. Equipment Description This source vents natural gas from: a well head separator Emissions from this source are: routed to a flare Natural gas venting from a well head separator.Emissions from this source are routed to a flare. Calculations 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(O) 55.14375 MMscf/yr 36762.5 sd/hr MW 25.95 IbAb-mol 0.8823 MMscf/d mole% MW Ibxllbmol mass fraction lb/hr lb/yr tpy Helium 0.00 4.0026 0.000 0.000 0.01 21.08 0.01 CO2 2.59 44.01 1.139 0.044 110.44 165662.09 82.83 N2 0.90 28.013 0.253 0.010 24.53 36792.36 18.40 methane 63.98 16.041 10.263 0.395 995.51 1493261.97 746.63 ethane 13.48 30.063 4.052 0.156 393.02 589534.44 294.77 propane 11.43 44.092 5.039 0.194 488.77 733157.35 366.58 isobutane 1.12 58.118 0.650 0.025 63.06 94583.91 47.29 n-butane 3.81 58.118 2.215 0.085 214.83 322238.52 161.12 isopentane 0.69 72.114 0.497 0.019 48.18 72264.26 36.13 n-pentane 0.92 72.114 0.663 0.026 64.36 96537.10 48.27 cydopentane 0.08 70.13 0.054 0.002 5.26 7886.80 3.94 n-Hexane 0.20 86.18 0.175 0.007 16.94 25404.60 12.70 cydohexane 0.05 84.16 0.045 0.002 4.33 6499.81 3.25 Other hexanes 0.35 86.18 0.303 0.012 29.37 44060.82 22.03 heptanes 0.18 100.21 0.178 0.007 17.30 25949.60 12.97 methylcydohexane 0.04 98.19 0.042 0.002 4.11 6158.52 3.08 224-TMP 0.00 114.23 0.003 0.000 0.31 469.34 0.23 Benzene 0.03 78.12 0.026 0.001 2.53 3799.27 1.90 Toluene 0.02 92.15 0.021 0.001 2.04 3057.60 1.53 Ethylbenzene 0.00 106.17 0.001 0.000 0.13 195.78 0.10 Xylenes 0.00 106.17 0.004 0.000 0.41 611.35 0.31 C8+Heavies 0.10 120.000 0.115 0.004 11.17 16758.23 8.38 VOC mass frad 0.387 Total VOC(Uncontrolled) 729.82 VOC Mot% 19.03 Notes Mole%,MW,and mass fractions reflect a weighted average of three site specific gas analyses from the Timbro Ranch 3 Multi-pad. The samples were taken from the 1-34-10-59,2-34-10-59,and 2-3-9-59 wells on 06/16/2015. Emissions are based on 1500 hours of operation per year. A molecular weight of 120 was used for C8+heavies. 15WE1.219.CP1.xlsm Three(3)separators controlled by one open flare during maintenance and sales line downtime.Flare has a 001 minimum control efficiency of 95%. Flaring Information Equipment Description Flare to combust separator gas during gas pipeline downtime and maintenance. Manufacturer TBD Model TBD Serial Number TBD Gas Heating Value 1495.7 Btu/scf Throughput 82478.50688 MMBtu/yr VRU Information Equipment Description Not applicable Make TBD Model TBD Requested Control N/A Annual Bypass Tim N/A Backup Flare Overall Control 95.00% Combustion emission factor source: AP-42:Chapter 13.5 0.07 Ilb NOX/MMBtu 0.37 IIb CO/MMBtu Emissions Summary Table Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 26470 Ib/MMscf 1323.48 lb/MMscf 729.8 tpy 36.5 tpy Gas Analysis Nox 0.07 Ib/MMBTU 0.07 lb/MMBTU 2.8 tpy 2.8 tpy AP-42 CO 0.37 Ib/MMBTU 0.37 Ib/MMBTU 15.3 tpy 15.3 tpy AP-42 Benzene 68.90 lb/MMscf 3.44 lb/MMscf 3799 lb/yr 190 lb/yr Gas Analysis n-Hexane 460.70 Ib/MMscf 23.0349 lb/MMscf 25405 lb/yr 1270 lb/yr Gas Analysis Toluene 55.448 lb/MMscf 2.7724 lb/MMscf 3058 lb/yr 153 lb/yr Gas Analysis Xylenes 11.087 lb/MMscf 0.5543 lb/MMscf 611 lb/yr 31 lb/yr Gas Analysis Ethylbenzene 3.550 lb/MMscf 0.1775 lb/MMscf 196 lb/yr 10 lb/yr Gas Analysis 2,2,4-TMP 8.511 lb/MMscf 0.4256 lb/MMscf 469 lb/yr 23 lb/yr Gas Analysis 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." AQCC Regulation 7 Was the well newly constructed,hydraulically fractured,or recompleted on or after August 1,2014? yes This separator is subject to Reg 7,Section XVII.G.and control requirements of Reg 7,Section XVII.B.2 Notes: ... 1. The VOC emissions calculated above are slightly less than the values calculated by the operator.This is simply a result of r oudning differences in the calculation. Since the operator's result is slightly more conservative than the result I calculated,I am comfortable using their results for the VOC permit limits. 2. The HAP emission factors and resulting emissions calculated above were determined using a weighted average of the mol%from three separate site specific gas analyses.These values do not match with the values calculated by the operator.The operator expressed that they calculated the total HAPs based on a weighted average of HAP weight%in the gas stream of each of the three site specific samples. It was determined that the weighted ave rage weight%of HAPs was 0.90%. Using this value along with the displacement equation from the EPA Emission Inventory Improvement Program Publication:Volume II, Chapter 10,the total HAPs were calculated to be 33,885.75 lb/year. The following equation was utilized: lb/yr HAPs=vol gas to flare(882.3Mscfd)*1000 scf/Mscf*lday/24hr*Ibmol gas/379 scf gas*25.95 lb gas/Ibmol gas*0.90/100 I bVOC/Ibgas*1500hr/year 3.A ratio of individual HAP to total HAP was calculated for each HAP pollutant in the three site specific samples provided. A weighted average of the ratios was calculated and utilized to determine the individual HAP emissions associated with this source. The following equation was used in the determination: Individual HAP Emissions(lb/year)=(33,885.75Ib/year)*[(Individual HAP/Total HAP)] For example,the weighted average ratio for benzene to total HAPs was determined to be 0.113454.Using the above equation the toluene emissions were determined as follow: Benzene emissions(Ib/yr)=(33,885.75 lb/yr)*(0.113454)=3,844 lb/year. 15WE1219.CP1.xlsm Three(3)separators controlled by one open flare during maintenance and sales line downtime.Flare has a 001 minimum control efficiency of 95%. The individual HAP emissions using this calculation results in more conservative values than displayed in the table above.As a result,the values calculated by the operator will be used for permitting purposes. Below is a table that summarizes the emissions and emission factors for individual HAPs found in the permit: Average ratio of Emission individual HAP to Factors Uncontrolled Emissions Controlled Emissions Controlled EF Pollutant Total HAP (lb/MMscf) (lb/year) (lb/year) (Ib/MMscf) Benzene 0.11349 69.739 3,846 192 3.487 Toluene 0.090714 55.744 3,074 154 2.787 Ethylbenzene 0.005835 3.586 198 10 0.179 Xylenes 0.017821 10.951 604 30 0.548 n-Hexane 0.757543 465.509 25,670 1283 23.275 2,2,4-TMP 0.014597 8.970 495 25 0.448 Notes Continued: 4. Even though this source is subject to Regulation 7 Section XVII.G.,the source requested that an open flare be permitted as an alternative emission control device per Regulation Number 7,Section XVII.B.2.e. The open flare at this site was approved for the following reasons: (i)The emissions from the separator are normally routed to the gas pipeline.The open flare is used during maintenance and scenarios when the gas pipeline is unavailable.The operator is only requesting to permit 1,500 hrs of operation. (ii)The open flare will be able to control 95%of the hydrocarbon emissions and has a manufacturer's design guarantee of 98%control for hydrocarbons. (iii)The permitted open flare will operate with no visible emissions,is equipped with an autoigniter,and is capable of complying with requirements of Section XVII.B. (iv)The operator expressed that approximately 10 enclosed combustors would be required to handle the throughput as compared to one open flare. Based on the above reasons,I felt it was reasonable to permit the open flare as an alternative control device per Regulation Number 7,Section XVII.B.2.e and in accordance with PS Memo 15-03 Section 2.3. 5.The NOx and CO emissions contained in the permit were converted from units of lb/MMBtu to lb/MMscf using the APEN reported gas heating value of 1495.7 MMBtu/MMscf. For example NOx was converted as follows: (0.068 lb/MMBtur(1495.7 MMBtu/MMscf)=101.7 lb/MMscf. The CO emission factor was calculated as follows: (0.37 lb/MMBtu)•(1495.7 MMBtu/MMscf)=553.4 lb/MMscf. 6.The operator expressed that a flow meter had been installed at this facility to meter the gas vented from the separators. 7.The operator was provided with a draft permit to review prior to public comment.The operator reviewed the draft and expressed that there were three separators at the facility rather than two.As a result,the source description was updated to reflect three(3)separators rather than two. • 15WE1219.CP1.xlsm • AIRS(County/Plant) 123/9E17 Permit No. 15WE1219 Date 12/16/2015 Controlled Controlled Actual Requested NCRP= Uncontrolled Emission Emissions Emissions Ctrl. reportable Point# SCC Pollutant or CAS Factor Emisison Factor Source (tpy)• (tpy)* PTE(tpy)' Eff% ? • 001 31000205 VOC 26639.46 lb/MMscf Gas Analysis 36.8 734.5 95% Yes 001 31000205 NOx 0.068Ib/MMBTL1AP-42 2.8 2.8 0% Yes 001 31000205 CO 0.37 lb/MMBTLAP-42 15.3 15.3 0% Yes 001 31000205 Benzene 69.74 lb/MMscf Gas Analysis 193 3846 95% Yes 001 31000205 n-Hexane 465.53 lb/MMscf Gas Analysis 1284 25670 95% Yes 001 31000205 Toluene 55.75 lb/MMscf Gas Analysis 154 3074 95% Yes 001 31000205 Ethylbenzene 3.58 lb/MMscf Gas Analysis 10 198 95% No 001 31000205 Xylenes 10.95 lb/MMscf Gas Analysis 31 604 95% Yes 001 31000205 2,2,4-TMP 8.97 lb/MMscf Gas Analysis 25 495 95% Yes "HAP emissions are represented with units of lbs/year STATE OF COLORADO of �a , COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT �� AIR POLLUTION CONTROL DIVISION yam, } . TELEPHONE: (303)692-3150 rr .*t„ '+ 4-1170`. CONSTRUCTION PERMIT PERMIT NO: 15WE1221 Issuance 1 DATE ISSUED: ISSUED TO: Carrizo Oil & Gas, Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas exploration and production facility, known as the Timbro Ranch 3 Multi-pad, located in Lot 2 of Section 3, Township 9N, Range 59W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID LOAD 002 Truck loadout of crude oil. Emissions from the loadout are not controlled. 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 of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at https://www.colorado.gov/pacific/cdphe/other-air- permitting-notices. 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) of the latter of commencement of operation or 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, III.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 AIRS ID: 123/9E17 Page 1 of 8 Condensate Loadout TM Version 2012-1 Co do p e o Publ Airic PoHealthllution Controland DivisionEnvironment on which such construction or activity was scheduled to commence as set forth in the permit 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, I I I.F.4.) 4. 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 5. 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 AIRS Tons per Year Emission Type Equipment ID Point NO. VOC CO LOAD 002 -- 9.5 -- 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. PROCESS LIMITATIONS AND RECORDS 6. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Process Parameter Annual Limit Equipment ID Point LOAD 002 Crude oil loading 187,246 BBL AIRS ID: 123/9E17 Page 2 of 8 Co do P `p r e o Public Health and Environment I Air Pollution Control Division The owner or operator shall monitor 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. 7. Crude oil loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III.E) STATE AND FEDERAL REGULATORY REQUIREMENTS 8. 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 I I.A.I. &4.) 9. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 10. The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. b. All compartment hatches at the facility (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. The owner or operator shall inspect onsite loading equipment during loading operations to monitor compliance with above conditions. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. 11. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. OPERATING & MAINTENANCE REQUIREMENTS 12. This source is not required to follow a Division-approved operating and maintenance plan. COMPLIANCE TESTING AND SAMPLING 13. This source is not required to comply with any testing and sampling requirements. AIRS ID: 123/9E17 Page 3 of 8 Co do p e o Pu and Airblic PollutionHealth Control DivisionEnvironment 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 30th 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 volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or 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) 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 AIRS ID: 123/9E17 Page 4 of 8 Co A do I p e o Public Health and Environment I Air Pollution Control Division 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. 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 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 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: Harrison Slaughter Permit Engineer AIRS ID: 123/9E17 Page 5 of 8 Co do p e o Pu and Airblic PollutionHealth Control DivisionEnvironment Permit History Issuance Date Description Issuance 1 This Issuance Issued to Carrizo Oil &Gas, Inc. Permit for crude oil truck loadout at a new synthetic minor oil and gas exploration and production facility. AIRS ID: 123/9E17 Page 6 of 8 CoA. do 9, p e o 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: https://www.colorado.gov/pacific/cdphe/aqcc-regs 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. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Point Pollutant CAS# BIN (lb/yr) reportable? Rate(lb/yr) n-Hexane 110543 C 1,701 Yes N/A Benzene 71432 A 277 Yes N/A Toluene 108883 C 264 Yes N/A 002 Ethylbenzene 100414 C 41 No N/A Xylenes 1330207 C 92 No N/A 2,2,4-TMP 540841 C 44 No N/A 5) The emission levels contained in this permit are based on the following emission factors: Emission Factors - Uncontrolled CAS Pollutant lb/BBL loaded Source VOC 0.101 AP-42 110543 n-Hexane 9.08x10-' Mass Balance 71432 Benzene 1.47x10-' Mass Balance 108883 Toluene 1.41x10-' Mass Balance The uncontrolled VOC emission factor was calculated using AP-42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L= 12.46*S*P*M/T S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 3.4 psia AIRS ID: 123/9E17 Page 7 of 8 Co do p e o PubD lic PollutionHealth Controland DivisionEnvironment M (vapor molecular weight) =50 Ib/Ib-mol T(temperature of liquid loaded)= 530°R The uncontrolled non-criteria reportable air pollutant(NCRP)emission factors were calculated by multiplying the loadout VOC emission factor by the ratio of the NCRP emission factors to the VOC emission factor determined for the crude oil tanks at the facility: (NCRP NCRP LoadoutEF = (VOC LoadoutEF)* a VOC TnknkEFEF 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 Status Requirement Operating Permit Synthetic Minor Source of: VOC, n-Hexane, and Total HAPs PSD Synthetic Minor Source of: VOC, n-Hexane, and Total HAPs 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 7777-Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart)OOOOO( 9) A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification AIRS ID: 12319E17 Page 8 of 8 Division Information Engineer: Harrison Slaughter Control Engineer: Chris Laplante Review Date: 12/17/2015 Application Date: 08/14/2015 Facility Identifiers Permit No. 15WE1221 Potentially located in ozone nonattainment area AIRs County# 123 'Weld Facility# 9E17 Facility Type: exploration and production facility ❑Located in the 8-hour non-attainment area? O True Minor Synthetic Minor for: I✓ VOC r N0x r CO Administrative Information Company Name: Carrizo Oil &Gas, Inc. Source Name: Timbro Ranch 3 Multi-pad Source Location: Lot 2 of Section 3, Township 9N, Range 59W SIC: 1311 Address 1: Carrizo Oil&Gas, Inc. Mailing Address 2: 500 Dalas,Suite 2300 Address ty,State Zip: Houston,TX,77002 Name: Patricia Whitenight • Person To Phone: 713-328-1036 Contact Fax: 713-328-1060 Email: patricia.whitenight@crzo.net 'Requested Action Self Certification Required? Yes Issuance Number: 1 Source Description: Oil and gas exploration and production facility known as the Timbro Ranch 3 Multi-pad, located in the Lot 2 of Section 3,Township 9N, Range 59W,Weld.County,Colorado. Point Name Type Control Action Newly 002 LOAD Loadout None reported source 002 Hydrocarbon Loadout to Tanker Trucks The table of inputs below enables you to calculate the loading loss emissions factor"L". Calculations If you choose to use a state default emissions factor,you may enter is directly into cell B14 L=12.46*S*P*M/T(AP-42:Chapter 5.2,Equation 1) in units lb/1,000 gallons which will overwrite L=loading losses in lb per 1000 gallons loaded Factor Meaning Value Units Source S Saturation Factor 0.6 AP-42 AP-42 Table 7.1-2 (true vapor pressure at 70°F P True Vapor Pressure 3.4 psia and RVP= 5) Molecular Weight of AP-42 Table 7.1-2(MW at RVP=5) M Vapors 50 lb/lb-mole T Liquid Temperature 530 deg. R Field Data L 2.40 lb/10^3 gal 1.01E-01 lb/bbl Annual requested Throughput 187246 BBL/yr 7864332 gal/yr Annual requested VOC emissions 18858 lb/yr 9.43 tpy Control: None Efficiency: 0.00% NCRPs Component Mass Fraction If the operator provides HAP speciation from a stable"sales oil" Benzene 0.0147 analysis,enter the mass fraction from this data. Alternatively,if n-hexane 0.0902 the operator modeled a pressurized oil to develop a site specific emissions factor,enter the modeled mass fraction for the Toluene 0.0140 Xylenes 0.0048 Ethylbenzene 0.0021 2,2,4-TMP 0.0023 Ratio of HAP to VOC emission factors developed for crude oil tanks at the facility. (See additional Source: explanation in notes below) Emissions Summary Table Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 0.1007 lb/bbl 9.43 tpy 9.43 tpy AP-42 Benzene 0.001476 lb/bbl 276.5 lb/yr 276.5 lb/yr AP-42 n-Hexane 0.009080 lb/bbl 1700.2 lb/yr 1700.2 lb/yr AP-42 Toluene 0.001408 lb/bbl 263.6 lb/yr 263.6 lb/yr AP-42 Xylenes 0.000487 lb/bbl 91.3'lb/yr 91.3 lb/yr AP-42 Ethylbenzene 0.000216 lb/bbl 40.4 lb/yr 40.4 lb/yr AP-43 2,2,4-TMP 0.000231 lb/bbl 43.3 lb/yr 43.3 lb/yr AP-44 Regulatory Review 'Regulation 1 -.Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide 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.) !Regulation 2—Odor 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. !Regulation 3-APEN and Permitting Requirements Is this site considered an exploration and production location (e.g.well pad)? Yes If yes, review the following two exemptions for applicability: Does the operator unload less than 10,000 gallons(238 BBLs)per day of crude oil on an annual average basis? No If yes,this emissions point is categorically exempt from permit requirements per Regulation 3,Part B,Section II.D.1.I Does this operator unload less than 6,750 bbls per year of condensate via splash fill or 16,308 bbls per year of condensate via submerged fill procedure? No If yes,this emissions point is categorically exempt from permit requirements per Regulation 3,Part B,Section II.D.1.1 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 attainment. (Applicant is required to file an APEN since emissions exceed than 2 tons per year VOC) 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) Part B, III.D.2 -RACT requirements for new or modified minor sources This section of Regulation 3 requires RACT for new or modified minor sources located in nonattainment or attainment/maintenance areas.This source is not located in the 8-hour ozone nonattainment area, or the 1- hour ozone area. Since source is in attainment, RACT is not required. However, operator is using 0.6 saturation factor, which does satisfy RACT requirements. 'Regulation 6-New Source Performance Standards No applicable subpart. This facility is not a bulk gasoline terminal. 'Regulation 7-Volatile Organic Compounds No sections apply. Per Regulation 7, Section VI.C, a terminal is defined as a petroleum liquid storage and distribution facility that has a daily average throughput of more than 76,000 liters of gasoline (20,000 gallons), which is loaded directly into transport vehicles. This facility is neither a terminal, nor a bulk plant per definitions in Reg 7, Section VI.C. !Regulation 8—Hazardous Air Pollutants MACT EEEE: Not subject because minor source of HAPs It should also be noted that this source would not be subject because it is located at a production field facility and thus exempt per 40CFR 63.2334(c)(1). Additional Notes: 1. The uncontrolled non-criteria reportable air pollutant(NCRP)emission factors were calculated by multiplying the loadout VOC emission factor by the ratio of NCRP emission factors to VOC emission factors determined for the crude oil tanks at the facility.The following equation demonstrates the calculation: NCRP Loadout EF=(Loadout VOC EF)*[(NCRP Tank EF)/(VOC Tank EF)] The emission factors for the crude oil tanks at this facility used for this calculation may be referenced in permit #15WE1223. 2. The operator was provided with a draft permit to review prior to public comment.The operator reviewed the draft and expressed they did not have any comments. • AIRS(County/Plant)123/9E17 Permit No. 15WE1221 Date 12/17/2015 Controlled Controlled Actual Requested NCRP= Uncontrolled Emission Emissions Emissions Ctrl. reportable Point# SCC Pollutant or CAS Factor Emisison Factor Source (tpy)` (tpy)* PTE(tpy)* Eff% ? 002 40600132 VOC 2.398 lb/1000 9 a AP-42 N/A 9.4 9.4 0% Yes 002 40600132 Benzene 0.035 lb/1000 ga AP-42 N/A 276.5 276.5 0% Yes 002 40600132 n-Hexane 0.216 lb/1000 ga AP-42 N/A 1700.2 1700.2 0% Yes 002 40600132 Toluene 0.034 lb/1000 ga AP-42 N/A 263.6 263.6 0% Yes 002 40600132 Ethylbenzene 0.005 lb/1000 ga AP-43 N/A 40.4 40.4 0% No 002 40600132 Xylenes 0.012 lb/1000 ga AP-42 N/A 91.3 91.3 0% No 002 40600132 2,2,4-TMP 0.0055 lb/1000 ga AP-42 N/A 43.3 43.3 0% No `New Source-no actual emissions "VOC is represented in tpy.while the HAPs are represented in lbs/year C D P H E Construction Permit CO 1Air Pollution Control Division Permit number: 15WE 1223 Issuance: 1 Date issued: Issued to: Carrizo Oil Et Gas, Inc. Facility Name: Timbro Ranch 3 Multi-pad Plant AIRS ID: 123/9E17 Physical Location: Lot 2 SEC 3 T9N R59W County: Weld County General Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Point Equipment Description Description ID TANKS 004 Twelve (12) 400 barrel fixed roof storage Enclosed Flares vessels used to store crude oil. 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 this specific 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 of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting- notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or 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. A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.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 Storage Tank Version Svn Minor 2015-1 Page 1 of 7 after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction 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. (Regulation Number 3, Part B, Section 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. (Regulation Number 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. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NO. VOC CO Type TANKS 004 --- --- 13.1 --- Point Note: 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 not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility-wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility.' Compliance with the annual limits, for both criteria and hazardous air pollutants, 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 actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility AIRS Control Device Pollutants Equipment ID Point Controlled TANKS 004 Two(2) Enclosed Flares (SN: TBD) VOC and HAP 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 and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits f =D.LIE 'COLORADO CO f Mr Pollution Control Division Detranneo f Heatin&E nvQemmsnt Page 2 of 7 Facility AIRS Process Parameter Annual Limit Equipment ID Point TANKS 004 Crude Oil Throughput 187,246 The owner or operator shall monitor 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 STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A)when applicable. 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed, have no visible emissions during normal operations, and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating property. This flare must be equipped with an operational auto-igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto-igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto-igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shalt install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 14. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING ft MAINTENANCE REQUIREMENTS 15. Upon startup of this point, the owner or operator shall follow the most recent operating and maintenance (OEM) 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 the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) � COP HE COLORADO CO Air Pollution Control Division ear ,uhl fle Page 3 of 7 COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th 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 volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or 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. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 19. Federal regulatory program requirements (i.e. PSD, NANSR) 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 Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 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 Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. '21H. COLORADO CO j Air Pollution Control Division D.purmerd cr ,biz I lealtn s ameQcmnC Page 4 of 7 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 Number 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 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. 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 owner or operator, or the Division revokes a permit, the 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. By: Harrison Slaughter Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Carrizo Oil ft Gas Inc. Permit for crude oil storage tanks at a new synthetic minor oil and gas well production facility. ` COPE COLORADO CO tr, Air Pollution Control Division 9:._l le E Page 5 of 7 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. (Regulation Number 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: https://www.colorado.gov/pacific/cdphe/aqcc-regs 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 Uncontrolled Controlled Point Pollutant CAS# Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 7,665 384 Toluene 108883 7,311 366 Ethylbenzene 100414 1,120 56 004 Xylenes 1130207 2,526 127 n-Hexane 110543 47,093 2,355 2'2'4- 540841 1,200 60 Trimethylpentane Note All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year(lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 004: Uncontrolled Controlled CAS# Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl V0C 2.79 1.39x10-1 EaP Tank 71432 Benzene 4.09x10-` 2.04x10-3 EEtP Tank 108883 Toluene 3.9x10` 1.95x1O' E&tP Tank 100414 Ethylbenzene 5.98x10-3 2.99x10-4 EaP Tank 1330207 Xytene 1.34x1O` 6.7x10"4 EaP Tank 110543 n-Hexane 2.51x10-' 1.25x10-` EaP Tank 540841 Trimethylpentane 6.41x10-3 3.2x10-4 EaP Tank A CDPHE COLORADO co �� Air Pollution Control Division Dement leattry Emaronn ent Page 6 of 7 Note: The controlled emissions factors for this point are based on the enclosed 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 Status Requirement Operating Permit Synthetic Minor Source of: VOC, n-Hexane, Et Total HAPs PSD Synthetic Minor Source of: VOC, n-Hexane, a Total HAPs MACT HH Major Source Requirements: Not Applicable 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 XXXXXX 4 coil: COLORADO Ir C©coil: Air Pollution Control Division ,ew :. w f �c ,-,__:; 4,, F, Page 7 of 7 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Carrizo Oil &Gas, Inc. Permit Number: 15WE1223 Source Name: Timbro Ranch 3 Multi-pad Source Location: Lot 2 of Section 3,Township 9N, Range 59W Equipment Description: Twelve(12)above ground 400 bbl atmospheric crude oil storage tanks AIRS ID: 123-9E17 Date: 12/16/2015 Review Engineer: Harrison Slaughter Control Engineer: Chris Laplante Section 2—Action Completed Grandfathered Modification APEN Required/Permit Exempt X 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? November 11, 2015 Section 4—Source Description AIRS Point Equipment Description 004 Twelve(12)above ground 400 bbl atmospheric crude oil storage tanks Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria Yes X No pollutant? If"yes", for what pollutant? N/A PM,o N/A CO N/A Ozone Is this location in an attainment maintenance area for Yes X No any criteria pollutant? If"yes", for what pollutant? (Note: These pollutants are subject to minor source N/A PKo N/A CO N/A Ozone RACT per Regulation 3, Part B, Section III.D.2) Is this source located in the 8-hour ozone non- attainment region?(Note: If"yes"the provisions of Yes X No • Regulation 7, Sections XII and XVII.C may apply) Page 1 Section 5—Emission Estimate Information AIRS Point Emission Factor Source Source calculated site-specific emission factors using a weighted average of the 004 results from three E&P Tank simulations that utilized extended natural gas liquid analysis from the three wells at the site. Please see Section 14 for additional details. Did the applicant provide actual process data for the emission inventory? Yes X No Basis for Potential to Emit(PTEI AIRS Point Process Consumption/Throughput/Production 004 187,246 BBL per year Basis for Actual Emissions Reported During this APEN Filing(Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 004 187,246 BBL per year 2015 Basis for Permitted Emissions(Permit Limits) AIRS Point Process Consumption/Throughput/Production 004 187,246 BBL per year Does this source use a control device? X Yes No AIRS Point Process Control Device Description % Reduction Granted 004 01 Two(2) Enclosed Flares 95 Section 6—Emission Summary(tons per year) Point NO. VOC CO Single HAP Total HAP PTE: 004 0.33 261.1 1.81 23'6 33.5 (n-Hexane) Uncontrolled point 004 0.33 261.1 1.81 23.6 33.5 source emission rate: (n-Hexane) Controlled point 004 0.33 13.1 1.81 1'2 1.7 source emission rate: (n-Hexane) Total APEN Reported 1.2 emissions: 004 0.33 13.1 1.81 (n-Hexane) 1.7 Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled Are the Controlled Emission Pollutant CAS# BIN Emission Rate emissions (ibtyr) reportable? Rate(lb/yr) Benzene 71432 A 7,665 Yes 384 n-Hexane 110543 C 47,093 Yes 2,355 Toluene 108883 C 7,311 Yes 366 Ethylbenzene 100414 C 1,120 Yes 56 Xylenes 1130207 C 2,526 Yes 127 2,2,4-Trimethylpentane 540841 C 1,200 Yes 60 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. Page 2 Section 8—Testing Requirements Will testing be required to show compliance with any emission rate or regulatory Yes X No standard? If"yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method Section 9—Source Classification Is this a new previously un-permitted X Yes No source? What is this facility classification? True X Synthetic Major Minor Minor Classification relates to what X Title V X PSD NA NSR MACT programs? Is this a modification to an existing permit? Yes X No If"yes"what kind of modification? N/A Minor N/A Synthetic N/A Major Minor 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)? X Yes No For Reg. 3, Part B, III.C.1.c.ii (subject to MACT)? Yes X 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 Yes X No Air Quality Standards (NAAQS)? If"yes", for which pollutants?Why? AIRS Point Section 12—Regulatory Review Regulation 1 -Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide 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, 004 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 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 004 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 Part A-APEN Requirements Criteria Pollutants: For criteria pollutants,Air Pollutant Emission Notices are required for: 004 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 attainment. (Applicant is required to file an APEN since emissions exceed 2 tons per year VOC) Part B—Construction Permit Exemptions 004 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 NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84. Is this source greater than 19,800 gallons(471 bbl)? No Is this source subject to NSPS Kb?No WHY? NSPS Kb does not apply to storage vessels that have a capacity less than 471 004 bbls. Each of the storage tanks at this facility has a capacity of 400 bbls. Additionally, §60.110b(d)(4)states that NSPS Kb does not apply to"Vessels with a design capacity less than or equal to 1,589.874 m3(10,000 bbls) used for petroleum or condensate stored, processed, or treated prior to custody transfer. Since these vessels are located at a point prior to custody transfer and have a design capacity less than 10,000 bbls, this exemption also applies. NSPS OOOO: Tanks with the potential to emission equal to or greater than 6 TPY. Are uncontrolled VOC emissions greater than 6 TPY?Yes Are controlled emissions greater than 6 TPY? No(operator is requesting permit limit of 004 13.1 tpy—see details below) Source is not subject to NSPS OOOO requirements. Since NSPS OOOO is based on an individual vessel basis,the calculation to determine VOC emissions per vessel is as follows: (13.1 tpy VOC)/(12 storage vessels)= 1.1 tpy VOC per vessel. This is below the NSPS threshold of 6 tpy VOC. This further asserts that NSPS OOOO is not applicable. Regulation 7—Volatile Organic Compounds XII.VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS (Applicant is not subject to the emission control requirements for condensate tanks since it is located in an attainment area.) 004 XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS (Applicant is currently subject to this since actual uncontrolled emissions are greater than 6 tpy of VOC.) Regulation 8—Hazardous Air Pollutants —MACT EEEE: Organic Liquids Distribution 004 • This source is not subject to MACT EEEE because it is not located at a major source of HAP. MACT HH 004 • 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 Process Emission Pollutant/ Fugitive Control Point Process Description Factor CAS# (Y/N) Emission Factor Source (oho) Twelve(12) 66.42 004 01 400bb1 E&P lb/1000 gal VOC No E&P Tank 95 Condensate throughput Page 4 f Storage Tanks 9.74x10-' Benzene/ lb/1000 gal 71432 No E&P Tank 95 throughput 5.97 n-Hexane/ lb/1000 gal No E&P Tank 95 throughput 110543 9.29x10' Toluene/ lb/1000 gal 108883 No E&P Tank 95 throughput 1.42x10' Ethylbenzene lb/1000 gal / 00414 No E&P Tank 95 throughput 3.19x10-' Xylene/ lb/1000 gal No E&P Tank 95 throughput 1130207 1.52x10-' lb/1000 gal 2,2,4-TMP/ No E&P Tank 95 throughput 540841 SCC 40400312—Fixed Roof Tank, Crude Oil,working+breathing+flashing losses Page 5 Section 14—Miscellaneous Application Notes AIRS Point 004 Twelve(12)above ground 400 bbl atmospheric crude oil storage tanks A permit will be issued because the uncontrolled VOC emissions of the source are greater than 2 TPY (APEN threshold)the uncontrolled VOC emissions associated with the facility are greater than 5 TPY (permit threshold). The operator used site specific emission factors. These factors were determined through the use E&P Tank 2.0 and an extended natural gas liquid analysis for three wells at the facility. The dates for the extended natural gas liquid analysis for the three wells on location are as follow: • Timbro 1-34-10-59: June 12,2015 • Timbro 2-34-10-59: June 12, 2015 • Timbro 2-3-9-59: June 12, 2015 The source then utilized the projected annual production of each of the three wells in addition to the emission factors determined through use of E&P Tank 2.0 calculations to determine a weighted average emission factor for the facility. The calculation is as follows: Given Information: Well Projected Annual %of Total VOC EF(from E&P Production (bbls/yr) Production Tank 2.0) lbs/bbl Timbro 1-34-10-59* 68,540 36.6 3.354 Timbro 2-34-10-59* 65,658 35.1 1.586 Timbro 2-3-9-59* 53,048 28.3 3.546 *Projected annual production determined by: First 30 days production*0.4*1.2*12 Calculation: VOC EF =(3.354 lbs/bbl*0.366) +(1.586 lbs/bbl *0.351)+(3.546 lbs/bbl*0.283)=2.79 lbs/bbl A similar calculation was utilized to determine the emission factor for the HAPs. Below is a table summarizing the emission factors determined through E&P Tanks: Benzene EF Toluene EF Ethylbenzene Xylenes EF n-Hexane 2'2'4 MP EF Well (lb/bbl) (lb/bbl) EF(lb/bbl) (lb/bbl) EF(lb/bbl) (Ib bbl) Timbro 0.04368 0.0426 0.00636 0.01707 0.2823 0.00919 1-34-10-59 Timbro 0.02315 0.02208 0.00338 0.008499 0.1472 0.001 2-34-10-59 Timbro 0.05942 0.05546 0.008709 0.01504 0.3409 0.0095 2-3-9-59 The overall emission factors(lb/bbl)calculated for each pollutant are as follow: VOC Benzene Toluene Ethylbenzene Xylenes n-Hexane 2,2,4-TMP 2.79 4.09 x 10"2 3.90x10"2 5.98x10-' 1.34x10"2 2.51x10-1 6.41x10-3 These emission factors have been converted to lb/1000 bbls and are represented above in Section 13 of this PA. Page 6 NOx and CO Emission Calculations: The NOx and CO emissions were calculated through the following methodology: Process Description Process Limits: 01 Tank Vapor Volume to 1.47 MMscf/year flare from flash, working and breathing losses 02 Pilot gas volume to 2.92 MMscf/year flare The tank vapor volume to the flare as a result of flash, working and breathing losses was determined by multiplying the gas oil ratio (GOR), determined for each of the three wells at the location, by the annual crude oil throughput from each of the three wells. The resulting worst case scenario (highest vapor rate per day)was used as the basis for calculating the NOx and CO emissions. The GOR determined for each well serves as a correlation, and is integral to the determination of the annual vent gas throughput. The GOR for each well was obtained from the E&P Tank calculations conducted for each well at the location. The equation for the calculation may be referenced below: 1year Vapor Rate = (GORweii1 * (Crude Oil Throughputweu) U65days) The information provided in the application is as follows: Well GOR(scf/bbl) Crude Oil Throughput (bbls/year) Timbro 1-34-10-59* 21.51 68,540 Timbro 2-34-10-59* 9.45 65,658 Timbro 2-3-9-59* 20.72 53,048 Calculations: • Timbro 1-34-10-59 21.51 scf\ 68,540 bbl 1 year 4,039scf Vapor Rate = ( * _ \ bbl / \ year 365 days day • Timbro 2-34-10-59 9.45scf 65,658 bbl 1 year _ 1,700scf Vapor Rate = ( l r bbl 1 \ year 365 days day • Timbro 2-3-9-59 20.72 scf\ 53,048 bbl 1 year _ 3011scf Vapor Rate = ( *r bbl ) \ year 365 days day The annual tank vapor volume to flare(process 01)was determined using the worst case vapor rate as determined above. The vapor rate associated with the Timbro 1-34-10-59 well resulted in the highest daily vapor rate and was used in the calculation. The total annual process limit for the pilot gas volume (process 02) is based on the design rate of the continuous pilot light. The maximum annual limit was determined through the summation of the tank vapor volume and the pilot gas volume routed to the flare. Page 7 The NOx and CO emissions are based on the following emission factors: Emission Factors Pollutant Uncontrolled Source lb/MMBtu NOx 0.068 AP-42: Chapter 13.5 CO 0.370 AP-42 Chapter 13.5 Note: The calculation of the NOx and CO emissions take into account separate heating values for the tank vapor volume and pilot gas volume sent to the flare. The heating value for the tank vapor is based on a worst case scenario(i.e. highest heating value from extended natural gas liquid analysis). The emissions resulting from the independent processes are calculated separately using the appropriate heating value, and the results are summed to obtain the emission levels. The heating values utilized in the calculation of the emission levels are as follow: Process Description Heating Value 01 Tank Vapor 3,688 Btu/scf 02 Pilot gas 1,496 Btu/scf NOx emissions calculation: 1.47MMscf 1.0x106scf 3688 Btu 1MMBtu 0.0681b 1ton yr * MMscf * scf *1.0x106 Btu* Btu *20001bs_— 0.184 tpy 2.92MMscf 1.0x106scf 1496 Btu 1MMBtu 0.0681b 1ton yr * MMscf * scf * 1.0x106 Btu* Btu *20001bs_— 0.149 tpy NOx Total Emissions=0.184 tpy+0.149 tpy= 0.33 tpy CO emissions calculation: 1.47MMscf 1.0x106scf 3688 Btu 1MMBtu 0.371b iton* * _ yr * MMscf * scf * 1.0x106 Btu Btu 20001bs— 1.0 tpy 2.92MMscf 1.0x106scf 1496 Btu 1MMBtu 0.371b iton* yr * MMscf * scf * 1.0x106 Btu Btu * _ 0.81 tpy 20001bs— CO Total Emissions= 1.0 tpy+0.81 tpy= 1.81 tpy NOx and CO emissions are not above the 2 tpy APEN reporting threshold for the attainment area.As a result, a permit limit will not be included for these pollutants. Additional Notes: 1.The operator was provided with a draft permit to review prior to public comment. They reviewed the draft and expressed that the condensate tanks were controlled by two(2) enclosed flares rather than just one. As a result,the permit and PA were updated to reflect the use of two(2)enclosed flares to control the condensate tanks at the facility. Page 8 Z v 2 O u co u O ¢ G .2'. C c W v1 V O^ q ❑ . � - R C V▪▪ J /� T f!1 f71 A N; L U >>� G •\ c 3 o G Ca v o` 5. > ar v s...., G ea tt 1 0 tt . c c a e _ e o = r°o u ev a - 2 ✓ • m u c i3. ^ o .2 u c .-17:7 E•N g° -v.4 y �+ a a ma c' • o CI —I a. • o u u C/ a c� U a� c d v` c i z z w ° a 'v y 44 3 8 c o a o F = 7 �. t: u c 42 C 40 c g G r.. T O 1.4 C. = v bL ;C V G o. —Q A a ,O 'C C.1 F-•- .o O c u O U .�^ _'�. ^ p ° c°o o It. L e x N Q — h +' E s °' c .3 C/� o c. is .II E = C -O V.E > ' ".O .� O v '> u T u 2 r.+ C G 6A._ ❑. ❑ v v O _ o �=' 4, u 7.: M O. Q .co-. C C I o• u _ = i. C 4.C .o. Ur C.L. u C d U O Q P." 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