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Address Info: 1150 O Street, P.O. Box 758, Greeley, CO 80632 | Phone:
(970) 400-4225
| Fax: (970) 336-7233 | Email:
egesick@weld.gov
| Official: Esther Gesick -
Clerk to the Board
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20160846.tiff
Aik CDPHE COLORADO IA CO Department of Public ., Health ft Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 0 St PO Box58 Greeley, CO 80632 RECEIVED March 2, 2016 MAR I4 2016 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On March 9, 2016, the Air Pollution Control Division will begin a 30-day public notice period for Carrizo Oil i:t Gas, Inc. - Castor 36 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. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, ./.44.#4.,,, ‘17-1(-1.2i Clara r Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure -P IL R` -J ULu3 2016-0846 3 ) q / a.o i ci C C R(07-O41-3/q 4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe I i/r r,�os, John W. Hickenlooper,Governor i Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer (-': \,,,, ,,,_;,,,:_ii5?)/ CDPHE Air Pollution Control Division CO , , Notice of a Proposed Project or Activity Warranting Public M` Comment Website Title: Carrizo Oil Et Gas, Inc. - Castor 36 Multi-pad - Weld County Notice Period Begins: March 9, 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 a Gas, Inc. Facility: Castor 36 Multi-pad Oil and gas exploration and production facility NWNE Sect. 36, T9N, R59W Weld County The proposed project or activity is as follows: Three (3) new vapor recovery towers (VRTs) at an existing well pad site routing vapors to an enclosed flare. 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): • 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 15WE1215 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: Betsy Gillard Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us _...... _. _.. COLORADO O 1 I , STATE OF COLORADO of c., •LO- • • • D - • -T' •F P = C HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION *. TELEPHONE: (303)692-3150 * f CONSTRUCTION PERMIT PERMIT NO: 15WE1215 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 Castor 36 Multi-Pad, located in the NWNE Sect. 36 T9N R59W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID VRTs 011 Three (3) vapor recovery towers (VRTs), routing vapors to an enclosed flare. Flare has a minimum control 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 after commencement of operation or issuance of this permit, whichever comes later, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, 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 on which such construction or activity was scheduled to commence as set forth in the AIRS ID: 123/9AC3 Page 1 of 8 • pa enT ealth and Environment llution Control Division permit applicDolor i pe 'sconstruction 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 operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO VOC CO Emission Type VRTs 011 14.0 3.4 Point $ee Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 7. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit(Reference: Regulation No.3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID VRTs 011 Enclosed Flare(s) VOC, HAPs • PROCESS LIMITATIONS AND RECORDS AIRS ID: 123/9AC3 Page 2 of 8 olor.` Depa en . P •li Health and Environment it Pollution Control Division 8. This source s- it - t - -wi m pr- -ing 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. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Equipment Point Process Parameter Annual Limit ID VRTs 011 Crude Oil throughput 78,691 barrels Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 10. Visible emissions shall not exceed twenty percent(20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. &4.) 11. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 12. The flare(s) covered by this permit is subject to Regulation No. 7, Section XVII.B General Provisions (State only enforceable). These requirements include, but are not limited to: • XVII.B.2.b If a 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 combustion device, or by other means approved by the Division, determine whether it is operating properly. • XVII.B.2.d Auto-igniters: All combustion devices used to control emissions of hydrocarbons must be equipped with and operate an auto-igniter as follows: • XVII.B.2.d.(i) All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto-igniter upon installation of the combustion device. • XVII.B.2.d.(ii) 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. AIRS ID: 123/9AC3 Page 3 of 8 olor epa en i ealth and Environment it Pollution Control Division 13. All separation nt -p par nd VRTs, covered by this permit is 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 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to'Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. The owner or operator shall demonstrate compliance with opacity standards, using EPA Method 22 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 (1) minute in any fifteen (15) minute period during normal operation. (Reference: Regulation No. 7, Section XVII.A.II) ADDITIONAL REQUIREMENTS 16. 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 (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 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 AIRS ID: 123/9AC3 Page 4 of 8 olorl Depa en - P •li Health and Environment A it Pollution Control Division c. When; cr --en - ed, o - -never 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. 17. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 18. 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. 19. 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. 20. 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. 21. 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. 22. 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. AIRS ID: 123/9AC3 Page 5 of 8 olor pa en • •li ealth and Environment it Pollution Control Division 23. Section 25-7- a), S es ur.: ired 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. 24. 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: Betsy Gillard Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Carrizo Oil & Gas, LLC New vapor recovery towers(VRTs) at exiting synthetic minor facility AIRS ID: 123/9AC3 Page 6 of 8 olor Depa en P Ii Health and Environment it Pollution Control Division Notes to Permit Holder me o e a . 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: htto://www.colorado.aov/cs/Satellite?c=Document C&childoaaename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper 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 Rate Point Pollutant CAS# (Ib/yr) reportable? (Ib/yr) Benzene 71432 11374 Yes 569 n-Hexane 110543 60294 Yes 3015 Toluene 108883 9182 Yes 459 011 Ethylbenzene 100414 875 Yes 44 Xylenes 1330207 2411 Yes 121 2,2,4-TMP 540841 3511 Yes 176 5) The emission levels contained in this permit are based on the following emission factors: Point 011: Emission Emission Pollutant Factors Factors Source Uncontrolled Controlled lb/bbl Lb/bbl NOx 0.068 0.068 AP-42 (Ib/MMBTU) CO 0.37 0.37 AP-42 (Ib/MMBTU) VOC 7.14 0.36 E&P Tanks Benzene 0.145 0.007 E&P Tanks Toluene 0.117 0.006 E&P Tanks Ethylbenzene 0.011 0.001 E&P Tanks AIRS ID: 123/9AC3 Page 7 of 8 en Ii ealth and Environment it Pollution Control Division DRAirxnePa Pollutant Factors Factors Source Uncontrolled Controlled Ib/bbl Lb/bbl Xylenes 0.031 0.002 E&P Tanks n-hexane 0.766 0.038 E&P Tanks 2,2,4-TMP 0.045 0.002 E&P Tanks Note: Controlled emission factors are based on a 95%control efficiency. 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: VOCs,total HAPs, Benzene,Toluene,and n-Hexane NANSR Synthetic MinorSource of: VOCs 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.aDoaccess.aov/ 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 XXXXX( 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/aacific/cdahe/air-permit-self-certification. AIRS ID: 123/9AC3 Page 8 of 8 Colorado Air Permitting Project Project Details Review engineer: BetsySillardr': Package#: 338442 Received Date: 10/1/2015 -, - Review Start Date: 2/5/2016 . Section 01-Facility Information Company Name: Carrizo Oil.&Gas,ine.' '-- County AIRS ID: 123 Plant AIRS ID: 9AC3 Facility Name: Cast©r 36 Mtdt-past,:, Physical Address/Location: NWNESect 361'9N;R53W Type of Facility: atf"" What industry segment? Of•` ak,,,, &hlProce ng r;'''t 4 Is this facility located in a NAAQS non-attainment area? ''Yes _;:;: If yes,for what pollutant? ❑Carbon Monoxide(CO) ❑Particulate Matter(PM) 2Ozone(NOx&VOC) Section 02-Emissions Units In Permit Application Emissions Self Cert AIRs Point# Emissions Source Type Permit# Issuance# Action Engineering Remarks Control? Required? 00i:- irrudeO UfS ,i tk;:,„ , , .13WE1042 3 „ t ad anon, 010 ; /r tI _ . �� . .,, • GP02 GIB 1' ^ek fxoi.ftii€rre T' : 'P !3 011ta 15WE1215 .1 .k __ % 0 ce '' r .gtFOV % z p '' - /r/rip ;,: 2 � .. .. ryp � ; c a .;;1 ,y,,. . ;, r ^a\„\.: 3 a<�'.. % -. ✓i' `,,N xy r',wi5E3'/ .,.,‘,A c:••„.„ . ., ,, _ \ ,t lit �� �7 A � s Section 03-Description of Project Reduction-of crude piithroughput for permit 13W E1042.Additioo.of 3 VRTs(15WE1215);and;a gas;lift:engi ne under GP02. . Section 04-Public Comment Requirments Is Public Comment Required? -i io '-'- . "W If yes,why?' IjRsb� fl, ,,. *" Section 05-Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required?2 If yes,for what pollutants? ... , Colorado Air Permitting Project If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If es,ex.lain what •ro:rams and which ••Ilutants here: • f Is this stationary source a major source? If yes,explain what programs and which pollutants here: Condensate Storage Tank(s)Emissions Inventory Issuance Date:December 30,2015 Section 01-Adminstrative Information Facility AIRs ID: CS 0 County Plant Point Section 02-Equipment Description Details Detailed Emissions Unit Three(3)Vapctrwecoevery,Tavrers(VRT3) Description: ?-- • Emission Control Device teed 46'anclwed coaWestor(6N:10246)*Ortorf6Eant pilotligh Description: Requested Overall VOC&HAP Control Efficiency%: '....-. .... . Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Storage Tank(s) Actual Condensate Throughput= - 51.325;Barrels(bbl)per year Actual Condensate Throughput While Emissions Controls Operating= 52,325,'. Requested Permit Limit Throughput= 78,691 Barrels(bbl)per year Potential to Emit(PTE)Condensate Throughput= 78,91,Barrels(bbl)per year Secondary Emissions-Combustion Device(s) Heat content of waste gas= Btu/scf 7.4 7400000 94.03870837 Volume of waste gas emitted per BBL of liquids produced= scf/bbl Actual heat content of waste gas routed to combustion device= 0 MMBTU per year Request heat content of waste gas routed to combustion device= 0 MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= 18,510 MMBTU per year section 04-Emissions Factors&Methodologies Will this storage tank emit flash emissions? Condensate Storage Tanks Control Device Uncontrolled E.F. Controlled E.F. Uncontrolled E.F. Uncontrolled Pollutant (lbs/bbl (Ibs/bbl (Ibs/MMBtu E.F.(Ibs/bbl Emissions Factor Source Citation Condensate Condensate waste heat Condensate Throughput) Throughput) combusted) Throughput) SNS. 1 ill 0.0000 PM2.5 :44:V ' 24 _ .- 0.0000 • ��G1 A 40k 04 0,ot% 0.0000 !J:21111 rAss, �1 . \.X X 0.37 + 0.0000 0.145 0007 0.11?" 0.006 0.011 0.001 MINIM 0.031 0.002 -- IIMMinTr. .. 0.766 0.045 - 0.002 , section 05-Emissions Inventory Potential to Emit Requested Permit Limits Actual Emissions Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) PM10 0.0 0.0 0.0 0.0 0.0 PM2.5 0.0 0.0 0.0 0.0 0.0 NOx 0.6 0.0 0.0 0.0 0.0 VOC 280.9 280.9 14.0 183.2 9.2 CO 3.4 0.0 0.0 0.0 0.0 Potential to Emit Requested Permit Limits Actual Emissions Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) Benzene 5.7E+00 5.7E+00 2.9E-01 3.7E+00 1.9E-01 Toluene 4.6E+00 4.6E+00 2.3E-01 3.0E+00 1.5E-01 Ethylbenzene 4.4E-01 4.4E-01 2.2E-02 2.8E-01 1.4E-02 Xylene 1.2E+00 1.2E+00 6.0E-02 7.9E-01 3.9E-02 n-Hexane 3.01E+01 3.0E+01 L5E+00 2.0E+01 9.8E-01 224 TMP 1.8E+00 1.8E+00 8.8E-02 1.1E+00 5.7E-02 Section 06-Regulatory Summary Analysis Regulation 7,Section XII.C,D,E,F Storage tank is subject to Regulation 7,Section XII,as provided bel Regulation 7,Section XII.G,C Storage Tank is not subject to Regulation 7,Section XII.G Regulation 7,Section XVII.B,C.1,C.3 Storage tank is subject to Regulation 7,Section XVII,B,C1&C.3,a Regulation 7,Section XVII.C.2 Storage tank is subject to Regulation 7,Section XVII.C2,as provide Regulation 6,Part A,NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulationb,Part A,NSPS Subpart 0000 Storage Tank is not subject to NSPS 0000 Regulation 8,Part E,MACT Subpart HH Storage Tank is not subject to MACT HH-If the tank is subject to a (See regulatory applicability worksheet for detailed analysis) 1 of 2 K:\PA\2015\15WE1215.CP1.xlsm • Condensate Storage Tank(s)Emissions Inventory Issuance Date:December 30,2015 ;action 07-Initial and Periodic Samoan and Testine Reouirements Does the company use the state default emissions factors to estimate emissions? If yes,are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? If yes,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company use a site specific emisions factor to estimate emissions? MN if yes and If there are flash emissions,are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted?This sample should be considered representative which generally means site-specific and collected within one year of the application received date.However,if the facility has not been modified(e.g.,no new wells brought on-line),then it may be appropriate to use an older site-specific sample. If no,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company request a control device efficiency greater than 95%for a flare or combustion device? • tf yes,the permit will contain and inital compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling ds� . 3x,9 .. _ Section 09-inventory SCC Cathie and Emissions Factor= Uncontrolled Emissions AIRS Point if Process* SCC Code Pollutant Factor Control%Units 011 01 PM10 0.00 0 lb/1,000 gallons condensate throughput PM2.5 0.00 0 lb/1,000 gallons condensatethrouthput NOx 0.00 0 lb/1,000 gallons condensate throughput VOC 170.0 95 lb/1,000 gallons condensate throughput CO 0.00 0 lb/1,000 gallons condensate throughput Benzene 3.45 95 lb/1,000 gallons condensate throughput Toluene 2.79 95 Ib/1,000 gallons condensate throughput Ethylbenzene 0.26 95 Ib/1,000 gallons condensate throughput Xylene 0.73 95 lb/1,000 gallons condensate throughput n-Hexane 18.24 95 Ib/1,000 gallons condensate throughput 224 TM' 1.06 95 lb/1,000 gallons condensate throughput 2 of 2 K:\PA\2015\15WE1215.CP1.xlsm • 4' p. G e i E e a C - Corm orm _ _` ,E--., -200 Fir Pollutant Enm«ssionNot_ce (APEN) and ,.< Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged on additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re-submittal. There may be a more specific APEN for your source (e.g. paint booths, mining operations, engines, etc.). A list of specialty APENs is available on the Air Pollution Control Division (APCDI website at www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: AIRS ID Number: 1 23 /9AC3/ ( , r! ., Section 1 - Administrative Information Company Name': CarriZo Oil & Gas, Inc. Site Name: Castor 36 Multi-pad Site Location Site Location: NWNE Sec. 36, T9N, R59W County: Weld NAICS or SIC Code: 211111 Mailing Address: (Include Zip Code) 500 Dallas, Suite 2300 Houston, TX 77002 Permit Contact: Patricia Whitenight Phone Number: 713-328-1036 Portable Source Home Base: E-Mail Address: Patricia.Whitenight@crzo.net 'Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. .a.;97937144° /•.C1-.` COI.3F 1.D Permit Number: AIRS ID Number: 123 /9AC3/ Section 2- Requested Action O NEW permit OR newly-reported emission source (check one below) ❑✓ STATIONARY source ❑ PORTABLE source -OR- ❑ MODIFICATION to existing permit (check eoch box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership2 ❑ Other(describe below) -OR- • APEN submittal for update only (Please note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally-enforceable limit on Potential To Emit (PTE) ❑ APEN submittal for permit exempt/grandfathered source Additional Info Et Notes: 2 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Three VRTs Manufacturer: Diverse Model No.: VRTCAR0001 Serial No.: 0000, 0001 , 0002 Company equipment Identification No. (optional): VRTs For existing sources, operation began on: 2015 For new, modified, or reconstructed sources the projected start-up date is: (] Check this box if operating hours are 8,76O hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day days/week weeks/year Seasonal use percentage: Dec-Feb: 25 Mar-May: 25 June-Aug: 25 Sept-Nov: 25 o,c. ., �, Permit Number: AIRS ID Number: 1 23 /9AC3/ Section 4 - Processing/Manufacturing Information Er Material Use ❑ Check box if this information is not applicable to source or process From what year is the actual annual amounr? 2015 Design Process Actual Annual Requested Annual Description Rate Amount Permit Limit3 (Specify Units) (Specify Units) (Specify Units) Material Consumption: Crude Oil 78,691 Finished Product(s): 3Requested values will become permit limitations. Requested limit(s)should consider future process growth. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) -103.9212/40.71382 ❑ Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Operator Discharge Height p Temp. Flow Rate Velocity • Stack ID No. Above Ground Level • (`F) (ACFM) (ft/sec) (Feet) Two Combustors Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Downward ❑ Upward with obstructing raincap ❑ Horizontal ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): • kG� Permit Number: AIRS ID Number: 1 23 /9AC3i Section 6 - Combustion Equipment Et Fuel Consumption Information Check box if this information is not applicable to the source (e.g. there is no fuel-burning equipment associated with this emission source) Design Input Rate Actual Annual Fuel Use Requested Annual Permit Limit3 (MMBTU/hr) (Specify Units) (Specify Units) From what year is the actual annual fuel use data? Indicate the type of fuel used': ❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/SCF) ❑ Field Natural Gas Heating value: BTU/SCF ❑ Ultra Low Sulfur Diesel (assumed fuel heating value of 138,000 BTU/gallon) ❑ Propane (assumed fuel heating value of 2,300 BTUISCF) ❑ Coal Heating value: BTU/lb Ash Content: Sulfur Content: ❑ Other(describe): Heating value (give units): 3 Requested values will become permit limitations. Requested limit(s)should consider future process growth. a If fuel heating value is different than the listed assumed value, please provide this information in the "Other" field. Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Control Equipment Description Overall Control Efficiency (%reduction in emissions) TSP (PM). PMI° PM2.s SOx NOx CO VOC Enclosed Combustors 95% Other: \?z' co r.C i. Permit Number: AIRS ID Number: 1 23 /9AC3/ Section 7 (continued) From what year is the following reported actual annual emissions data? 2015 Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Emission Uncontrolled Requested Annual Permit Factor Actual Annual Emissions 3 Pollutant Emission Emission Limit(s) Factor Source (Specify Units) (AP-42,Mfg. Uncontrolled Controlled5 Uncontrolled Controlled etc) (Tons/year) (Tons/year) (Tons/year) (Tons/year) TSP (PM) PM10 PMz.5 SO, NO„ CO VOC 7.14 lb/bbl E&P Tanks 280.8 14.0 Other: 3 Requested values will become permit limitations. Requested limit(s)should consider future process growth. 5Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Section 8 - Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteria pollutants (e.g. HAP- hazardous air pollutant) equal to or greater than 250 lbs/year? © Yes ❑ No If yes, use the following table to report the non-criteria pollutant (HAP) emissions from source: Uncontrolled Uncontrolled Controlled CAS Overall Emission Emission Factor Actual Actual Number Chemical Name Control Factor Source Emissions Emissions Efficiency (specify units) (AP-42,Mfg. etc) (lbs/year) (lbs/year) Benzene 95% 1.45E-01 lb/bbl Mass Balance 5.69 0.28 n-Hexane 95% 7.66E-01 lb/bbl Mass Balance 30.15 1.51 Toluene 95% 1,17E-01 lb/bbl Mass Balance 4.59 0.23 Ethylbenzene 95% 1.11E-02 lb/bbl Mass Balance 0.44 0.02 Xylenes• 95% 3.06E-02 lb/bbl Mass Balance 1.21 0.06 2,2,4 TMP 95% 4.46E-02 lb/bbl Mass Balance '1.76 0.09 'Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Permit Number: AIRS ID Number: 1 23 /9AC3/ Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. , (--• - , , . . • ,7 ,, . ,. �� " �' 1plc, I IV ,. i,nature of Legally Authorized P rson (not a vendor or consultant) Date Patricia Whitenight Air Quality Program Administrator Name (please print) Title Check the appropriate box to request a copy of the: ❑ Engineer's Preliminary Analysis conducted ❑ Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 to: For more information or assistance call: Colorado Department of Public Health and Environment Small Business Assistance Program Air Pollution Control Division (303) 692-3175 or (303) 692-3148 APCD-SS-B1 4300 Cherry Creek Drive South Or visit the APCD website at: Denver, CO 80246-1530 www.colorado.gov/pacific/cdphe/air-permits Telephone: (303) 692-3150 6 I ice`„
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