HomeMy WebLinkAbout20162946.tiffDepartment of Public
Health Et Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
11500 St
PO Box 758
Greeley, CO 80632
September 15, 2016
Dear Sir or Madam:
On September 22, 2016, the Air Pollution Control Division will begin a 30 -day public notice period for
Carrizo Oil Et Gas - Bringelson 8-20 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,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
John W. Hickenlooper, Governor
9/aco1(C
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
Larry Wolk, MD, MSPH, Executive Director and Chief Medical Office
cc- tPL C MM / TP)
pu_x £R ICH/3m /C)
19/ 9O
2016-2946
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Carrizo Oil Et Gas - Bringelson 8-20 Multi -pad - Weld County
Notice Period Begins: September 22, 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
Facility: Bringelson 8-20 Multi -pad
oil and gas well pad
Section 20, Township 9N, Range 58W
Weld County
The proposed project or activity is as follows: The applicant proposes to construct a new oil and gas
exploration and production facility including crude oil tanks and gas/liquid separators.
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 14WE1387 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:
Kira Gillette
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
COLOR ADO
1
Division Information
Engineer:
Kira Gillette
Control Engineer:
Roland Hea, P.E.
Review Date:
02/26/2015
Application Date:
08/18/2014
Facility Identifiers
Permit No.
14WE1387
AIRs
County #
123 Weld
Facility #
9D1C
Facility Type:
exploration and production facility
❑ Located in the 8 -hour non -attainment area?
Administrative Information
Potentially located in ozone nonattainment area
O True Minor
Synthetic Minor for:
f VOC i NOx rCO
Company Name:
Carrizo Oil & Gas, Inc.
Source Name:
Bringelson 8-20 Multi -pad
Source Location:
SIC:
NWSW Section 20, Township 9N, Range 58W
211111
Mailing
Address
Address 1:
Address 2:
ty, State Zip:
Carrizo Oil & Gas, Inc.
500 Dallas, Ste 2300
Houston, TX 77002
Person To
Contact
Name:
Phone:
Fax:
Email:
Patricia Moden
713-328-1036
713-328-1060
patricia.moden@crzo.net
Requested Action
Self Certification Required?
Issuance Number:
Source Description:
Yes
1
Oil and gas exploration and production facility known as the Bringelson 8-20 Multi -pad, located in the NWSW
Section 20, Township 9N, Range 58W, Weld County, Colorado.
Point
Name
Type
Control
Action
001
Tanks
Oil Tanks
Flare
Newly
reported
source
Nineteen (19) above ground atmospheric crude oil storage tanks (400bb1 total); controlled
001 by enclosed flare with minimum control efficiency of 95%.
Calculations
Requsted Throughput
301788
bbl
Control
Flare
Efficiency
95.00%I
Flare
AP -42 combustion emission factors:
parameter weighted avg worst case units worst case
Flare rating 2.98 2.98 MMBtu/hr n/a
Flared gas HV 3230 3789.22 Btu/scf 9-20
Pilot gas HV 1452.7 1514.2 Btu/scf 10-20
GOR 15.77 27.34 scf/bbl 9-20
Pilot gas volume 4000 4000 scf/day n/a
NOx 0.068 lb/MMBtu
CO 0.37 lb/MMBtu
Emissions Summary Table
#vessels Ctrl Emiss per vessel
19 2.8 tpy VOC
Pollutant
Unc. Emission Factor
Uncontrolled Emissions
Controlled Emissions
Source
Ctrld. Emis
NOx
3.64E-03 lb/bbl
0.5 tpy
0.55 tpy
Engineering C
3.64E-03
VOC
7.1 lb/bbl
1071.3 tpy
53.6 tpy
E&P TANK
3.55E-01
CO
2.14E-02 lb/bbl
3.2 tpy
3.2 tpy
Engineering C
2.14E-02
Benzene
7.04E-03 lb/bbl
2125 lb/yr
106 lb/yr
E&P TANK
3.52E-04
Toluene
5.62E-03 lb/bbl
1696 lb/yr
85 lb/yr
E&P TANK
2.81E-04
EB
7.47E-04 lb/bbl
225 lb/yr
11 lb/yr
E&P TANK
3.74E-05
Xylenes
2.16E-03 lb/bbl
652 lb/yr
33 lb/yr
E&P TANK
1.08E-04
n -Hexane
5.37E-02 lb/bbl
16206 lb/yr
810 lb/yr
E&P TANK
2.69E-03
224-TMP
3.81 E-03 lb/bbl
1150 lb/yr
57 lb/yr
E&P TANK
1.91E-04
Regulatory Review
Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall
allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This
standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The
approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60,
Appendix A (July, 1992)) in all subsections of Section II. A and B of this regulation.
Section II.A.5 - Smokeless Flare or Flares for the Combustion of Waste Gases No owner or operator of a
smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the
atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more
than six minutes in any sixty consecutive minutes.
Regulation 2 — Odor
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 6 -'New Source Performance Standards
NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84.
This source is not subject because each tank is less than 19,800 gallons (471 bbl)
NSPS OOOO: for storage vessels in the natural gas production, transmission, and processing
segments.
This source is not subject because each tank emits less than 6 tpy VOC.
Regulation 7`- Volatile Organic Compounds
XII. VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS
ion Factor
lb/bbl
lb/bbl
lb/bbl
lb/bbl
lb/bbl
lb/bbl
lb/bbl
lb/bbl
lb/bbl
(Applicant is not subject to the emission control requirements for condensate tanks since it is
located in an attainment area.)
XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS...
(Applicant is subject to this since actual uncontrolled emissions are greater than 20 tpy of VOC.)
14WE1387
Construction Permit
Air Pollution Control Division
Permit number:
Date issued:
Issued to:
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General Description:
Issuance: 1
Carrizo Oil Et Gas, Inc.
Bringelson 8-20 Multi -pad
123/9D1 C
NWSW Section 20, Township 9N, Range 58W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
TANKS
001
Nineteen (19) fixed roof storage vessels
(400bb1 total), used to store crude oil
Enclosed Flare
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 the
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 Syr: Minor 2015-1
Page 1 of 7
ssuanc of this construction permit or the date on which such
onst on .cti"` sche:' -d 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
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NOX
VOC
CO
TANKS
001
---
---
53.6
3.2
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
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
TANKS
001
Enclosed Flare with minimum control
efficiency of 95%
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.)
COLORADO
Air Pollution Control Division
Page 2 of 7
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
TANKS
001
Crude Oil throughput
301,788 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 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 source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
11. 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, as defined under Regulation
Number 7, XVII.A.16; 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 properly. 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.
12. 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 shall 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.
13. 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 Et MAINTENANCE REQUIREMENTS
14. Upon startup of these points, 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.)
COLORADO
Air Pollution Control Division
Page 3 of 7
Initial Testing Requirements
15. 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, XVII.B.2. and XVII.A.16)
Periodic Testing Requirements
16. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
17. 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.
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 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.
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 -
COLORADO
Aix Pollution Control Division
Page 4 of 7
C Regu g Lion Number 3, Part B, Section III.G. Final authorization
cannot-ti`e goperat . nor 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.
23. 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.
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:
Kira Gillette
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Initial approval permit for new crude oil storage
tanks, issued to Carrizo Oil Et Gas, Inc.
COLORADO
Air Pollution Control Division
Page 5 of 7
No
th- = this - ` it 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
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
001
Benzene
71432
2125
106
Toluene
108883
1696
85
Ethylbenzene
100414
225
11
Xylenes
1330207
652
33
n -Hexane
110543
16,206
810
2,2,4-
Trimethylpentane
540841
1150
57
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 001:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
CO
2.14E-02
2.14E-02
Source
V0C
7.1
3.55E-01
Source
71432
Benzene
7.04E-03
3.52E-04
Source
108883
Toluene
5.62E-03
2.81E-04
Source
1330207
Xylene
2.16E-03
1.08E-04
Source
110543
n -Hexane
5.37E-02
2.69E-03
Source
540841
2,2,4-
Trimethylpentane
3.81 E-03
1.91E-04
Source
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%.
COLORADO
Air Pollution Control Division
Page 6 of 7
6) I +a e h R.S., 5 14.1, e h Air Pollutant Emission Notice (APEN) associated with
permi va • • a ive ya 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 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.
8) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of:
VOC, n -Hexane
NANSR
Synthetic Minor Source of:
VOC
MACT HH
Major Source Requirements: Not Applicable
Area Source Requirements: Not Applicable
9) 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
COLORADO
AirPollution Control Division
Page 7 of 7
Division Information
Engineer:
Kira Gillette
Control Engineer:
Stefanie Rucker
Review Date:
02/26/2015
Application Date:
08/18/2014
Facility Identifiers
Permit No.
14WE1390
AIRS
County #
123 Weld
Facility #
9D1C
Facility Type:
exploration and production facility
❑ Located in the 8 -hour non -attainment area?
Administrative Information
Potentially located in ozone nonattainment area
O True Minor
Synthetic Minor for:
VOC r NOx r CO
Company Name:
Carrizo Oil & Gas, Inc.
Source Name:
Bringelson 8-20 Multi -pad
Source Location:
SIC:
NWSW Section 20, Township 9N, Range 58W
211111
Mailing
Address
Address 1:
Address 2:
ty, State Zip:
Carrizo Oil & Gas, Inc.
500 Dallas, Ste 2300
Houston, TX 77002
Person To
Contact
Name:
Phone:
Fax:
Email:
Patricia Moden
713-328-1036
713-328-1060
patricia.moden@crzo.net
Requested Action
Self Certification Required?
Issuance Number:
Yes
1
Source Description:
Oil and gas exploration and production facility known as the Bringelson 8-20 Multi -pad, located in the NWSW
Section 20, Township 9N, Range 58W, Weld County, Colorado.
Point
Name
Type
Control
Action
004
Separator
Separator Venting
Flare
Newly
reported
source
Five gas/liquid separator controlled by one open flare during pipeline downtime. Flare
004 has a 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. Primarily, emissions from this source are routed to pipeline through closed loop
system. When the pipeline is down, emissions are routed to a flare (open flare). Although the flare is designed for 98% efficiency and
the closed loop has no emissions, Carrizo is accepting the conservative assumption of a constant 95% control efficiency for this
source.
There is one separator per well, and five wells included in this application.
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
Requested hydrocarbon liquid throughput
Ratio of requested natural gas venting to hydrocarbon liquid throughput
days/yr operation at requested 600hrs/yr
requested MMscf/day
25 days/yr
1.596 MMscf/d
Throughput (Q)
MW
39.9
MMscf/yr
lb/lb-mol
4554.79452
0.10931507
scf/hr
MMscf/d
25.68
301788 bbl/yr
132.2 scf/bbl
pollutant
Wt % (Ib)c/Ibgas)
lb/hr
lb/yr
tpy
Weighted avg
of 5 wells
8-20
9-20
10-20
11-20
12-20
Sample date
6/13/14
6/13/14
6/13/14
6/18/14
6/18/14
Helium
0.000
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
CO2
4.101
4.11
4.05
4.01
4.15
4.21
12.66
110877.85
55.44
N2
1.022
1.07
1.03
0.77
1.08
1.17
3.15
27619.57
13.81
methane
40.168
40.9097
40.0117
36.3507
41.2028
42.6331
123.97
1085944.27
542.97
ethane
15.643
15.4270
15.5107
16.3979
15.5430
15.3446
48.28
422913.02
211.46
propane
19.619
19.2561
19.6471
21.2609
19.2749
18.5394
60.55
530415.64
265.21
isobutane
2.526
2.4829
2.5468
2.7454
2.4741
2.3570
7.80
68289.71
34.14
n -butane
8.583
8.4504
8.6770
9.3143
8.3744
8.0161
26.49
232036.65
116.02
isopentane
1.939
1.9120
1.9707
2.1083
1.8809
1.8042
5.99
52431.70
26.22
n -pentane
2.505
2.4480
2.5506
2.7284
2.4224
2.3510
7.73
67717.59
33.86
cyclopentane
0.188
0.2042
0.1847
0.2250
0.1634
0.1639
0.58
5090.83
2.55
n -Hexane
0.670
0.6580
0.6863
0.7332
0.6397
0.6242
2.07
18106.25
9.05
cyclohexane
0.171
0.1747
0.1733
0.1911
0.1579
0.1549
0.53
4615.31
2.31
Other hexanes
1.189
1.1688
1.2176
1.2952
1.1415
1.1067
3.67
32136.61
16.07
heptanes
0.735
0.7395
0.7658
0.8064
0.6859
0.6646
2.27
19871.75
9.94
methylcyclohexane
0.173
0.1799
0.1785
0.1944
0.1583
0.1497
0.53
4673.21
2.34
224-TMP
0.000
0.0004
0.0004
0.0009
0.0004
0.0004
0.00
13.38
0.01
Benzene
0.084
0.0868
0.0780
0.0977
0.0779
0.0788
0.26
2259.63
1.13
Toluene
0.070
0.0745
0.0658
0.0802
0.0632
0.0653
0.21
1881.97
0.94
Ethylbenzene
0.010
0.0121
0.0087
0.0123
0.0080
0.0094
0.03
270.78
0.14
Xylenes
0.024
0.0288
0.0181
0.0333
0.0179
0.0216
0.07
638.36
0.32
C8+ Heavies
0.569
0.5956
0.6146
0.6297
0.4712
0.5241
1.75
15372.41
7.69
Total VOC (Uncontr
39.054
38.473
39.384
42.457
38.012
36.631
120.528
1.056E+06
527.9
Total VOC (Controlled)
6.0
52791.1
26.4
Notes
Mole %, MW, and mass fractions from Bringelson 8-20 Multi -pad gas analysis collected for 5 wells in June, 2014, analyzed by
Empact EAS.
Emissions are based on 8760 hours of operation per year.
14WE1390.CP1.xlsm
Five gas/liquid separator controlled by one open flare during pipeline downtime. Flare
004 has a minimum control efficiency of 95%.
Flaring Information
Equipment Description [Projected Annual]
Flare to combust low-pressure separator gas Site Gas (Mcf) VOC% HV (Btu/scf)
Manufacturer
(not provided)
Model
Serial Number
Gas Heating Value
1452.673955
Btu/scf
Throughput
57961.69079
MMBtu/yr
VRU Information
Equipment Description
Facility is not using a VRU to control this point
Make
Model
Requested Control Efficiency
Annual Bypass Time
Backup
Overall Control
95.00%
Combustion emission factor sourcE
0.068 IIb NOX/MMBtu
Emissions Summary Table
AP -42: Chapter 13.5
0.37 Ilb CO/MMBtu
8-20 114435 38.473 1441.6
9-20 139457 39.384 1456
10-20 110769 42.457 1514.2
11-20 124172 38.012 1434.3
12-20 93786 36.631 1412.9
average 116523.8 38.9913 1451.8
weighted average 39.0537 1452.674
total 582619
pollutant mass fraction
VOC 3.91E-01
b 8.36E-04
t 6.96E-04
e 1.00E-04
x 2.36E-04
n -C6 6.70E-03
Emission Factors
Emissions
Pollutant
Uncontrolled
Controlled
Units
lncontrollec
Controlled
Units
Source
Reportable?
VOC
2.646E+04
1.323E+03
lb/MMscf
527.9
26.4
tpy
Gas Analysis
yes
NOx
9 878E+01
9.878E+01
lb/MMscf
2.0
2.0
tpy
AP -42
no
CO
5.375E+02
5.375E+02
lb/MMscf
10.7
10.7
tpy
AP -42
yes
NOx
0.068
0.068
lb/MMBtu
2.0
2.0
tpy
AP -42
no
CO
0.37
0.37
lb/MMBtu
10.7
10.7
tpy
AP -42
yes
Benzene
5.663E+01
2.832E+00
lb/MMscf
2260
113
lb/yr
Gas Analysis
yes
n -Hexane
4.538E+02
2.269E+01
lb/MMscf
18106
905
lb/yr
Gas Analysis
yes
Toluene
4.717E+01
2.358E+00
lb/MMscf
1882
94
lb/yr
Gas Analysis
yes
Xylenes
1.600E+01
8.000E-01
lb/MMscf
638
32
lb/yr
Gas Analysis
yes
Ethylbenzene
6.786E+00
3.393E-01
Ib/MMscf
271
14
lb/yr
Gas Analysis
yes
2,2,4-Trimethylpenta
3.354E-01
1.677E-02
lb/MMscf
13
1
lb/yr
Gas Analysis
no
Notes:
1) Applicant provided 26464 lb/MMscf for VOC uncontrolled EF. This is slightly different, but more conservative than the EF calculated above.
The discrepancy is no more than small rounding differences. As it is quite similar but more conservative, the applicant's EF will be used in the
permit.
2) Applicant provided emissions estimates for HAP emissions that are only slightly different from those calculated above, no more than small
rounding differences. The more conservative of the value calculated above and the value from the applicant will be used in the permit.
3) Applicant requested not to use CO & NOx combustion emission factors in the same terms as the permit process limit (lb/MMscf). Applicant
feels the lb/MMscf emission factors do not appropriately represent the contribution of the pilot light gas, and requested that the emission
factors in the permit be listed in the same units as they are listed in AP -42. The Emissions Summary Table above shows the emissions
calculated from each set of emission factors for NOx and CO are the same (teal & purple text above).
14 WE 1390.CP1.xlsm
Five gas/liquid separator controlled by one open flare during pipeline downtime. Flare
004 has a minimum control efficiency of 95%.
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?
no
This separator is not subject to Reg 7 Section XVII.G
Although this application was submitted over a year before PS Memo 15-03 was published, the applicant provided an Alternative
Emissions Control form justifying the use of the open flare. The AEC form and follow up email with further explanation is included in
the PDF of this PA saved as the electronic record of this permit action.
14 W E1390.CP1.xlsm
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO:
14WE1390
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 Bringelson 8-20 Multi -pad,
located in the NWSW Section 20, Township 9N, Range 58W, Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
Separator
004
Five well head separators controlled by one open 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 issuance of this permit, by submittinq a Notice of Startup form to
the Division. The Notice of Startup form may be downloaded online at
www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup
of the permitted source is a violation of Air Quality Control Commission (AQCC)
Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit.
2. Within one hundred and eighty days (180) after issuance of this permit, compliance with
the conditions contained in this permit shall be demonstrated to the Division. It is the
owner or operator's responsibility to self -certify compliance with the conditions. Failure to
demonstrate compliance within 180 days may result in revocation of the permit.
(Reference: Regulation No. 3, Part B, 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: 123/9D1C Page 1 of 9
olor
Depa Health and Environment
it Pollution Control Division
permit applic peisconconstruction 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. Within fifteen (15) days after issuance of permit the operator shall provide to the Division
the following information about each separator that is subject to 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. Within one hundred and eighty days (180) after issuance of this permit, the operator
shall install a flow meter to monitor and record volumetric flow rate of natural gas vented
from each separator covered by this permit. Until the flow meter is installed, the operator
shall monitor and record condensate/crude produced through the separator and estimate
the gas flow rate based on standard cubic feet (scf) per barrel (bbl) of 132.2 scf/bbl
estimated from the permit application.
7. 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
8. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission Type
NO x
VOC
CO
Separator
004
2.0
26.4
10.7
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.
AIRS ID: 123/9D1C
Page 2 of 9
li g -Health and Environment
it Pollution Control Division
The permit hof,c t '' io _ onth Ikeep 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.
9. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
Separator
004
Emissions from the separators are routed to the
pipeline through a closed loop, or to an open flare
during pipeline downtime.
VOC, HAP
PROCESS LIMITATIONS AND RECORDS
10. 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. (Reference:
Regulation 3, Part B, II.A.4)
Process/Consumption Limits
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
Separator
004
Natural Gas Venting
39.9 MMSCF
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.
11. Upon installation of the flow meter(s), the owner or operator shall continuously monitor
and record the volumetric flow rate of natural gas vented from each separator using the
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 contained in this
permit and to calculate emissions as described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
12. The permit number and ten digit AIRS ID number assigned by the Division (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)
13. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
14. 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
AIRS ID: 123/9D1C Page 3 of 9
excess of 300/ ergating i re than six minutes in any
sixty consecutive minutes. (Regulation Number 1, Section II.A.5.)
Health and Environment
it Pollution Control Division
OPERATING & MAINTENANCE REQUIREMENTS
15. 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
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, Section 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: (Reference: Regulation
No. 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 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 or Title V Operating Permit)
shall apply to this source at any such time that this source becomes major solely by
AIRS ID: 123/9D1C Page 4 of 9
li Health and Environment
it Pollution Control Division
virtue of a rel.•itiaglaxa at 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
20. This permit and any attachments must be retained and made available for inspection
upon request. The permit may be reissued to a new owner by the APCD as provided in
AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership
and the submittal of a revised APEN and the required fee.
21. If this permit specifically states that final authorization has been granted, then the
remainder of this condition is not applicable. Otherwise, the issuance of this construction
permit does not provide "final" authority for this activity or operation of this source. Final
authorization of the permit must be secured from the APCD in writing in accordance with
the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section
III.G. Final authorization cannot be granted until the operation or activity commences
and has been verified by the APCD as conforming in all respects with the conditions of
the permit. Once self -certification of all points has been reviewed and approved by the
Division, it will provide written documentation of such final authorization. Details for
obtaining final authorization to operate are located in the Requirements to Self -
Certify for Final Authorization section of this permit.
22. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the 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.
AIRS ID: 123/9D1C Page 5 of 9
olor-=Depa en .li Health and Environment
it Pollution Control Division
26. Violation of t , o Re of a ;_ sions raF e 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:
Kira Gillette
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Initial approval permit for new separator, issued
to Carrizo Oil & Gas, Inc.
AIRS ID: 123/9D1C Page 6 of 9
Health and Environment
it 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 owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN)
and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written notice
to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: http://www.colorado.gov/cs/Satellite?c=Document C&childpaqename=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.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(Ib/yr)
004
Benzene
71432
2260
113
Toluene
108883
1882
94
Ethylbenzene
100414
271
14
Xylenes
1130207
638
32
n -Hexane
110543
18125
906
2,2,4-
Trimethylpentane
540841
14
1
AIRS ID: 123/9D1C
Page 7 of 9
5) The emission level
Point 004:
Health and Environment
it Pollution Control Division
ission factors:
CAS #
Pollutant
Uncontrolled
Emission
Factors
Controlled
Emission
Factors
Emission
Factor
Units
Source
NOx
0.068
0.068
lb/MMBtu
AP -42
CO
0.37
0.37
lb/MMBtu
AP -42
VOC
2.646E+04
1.323E+03
lb/MMscf
Source (gas analysis)
71432
Benzene
5.663E+01
2.832E+00
lb/MMscf
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108883
Toluene
4.717E+01
2.358E+00
Ib/MMscf
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100414
Ethylbenzene
6.786E+00
3.393E-01
lb/MMscf
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1330207
Xylene
1.600E+01
8.000E-01
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110543
n -Hexane
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Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the
most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division at
(303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of:
VOC, n -Hexane
NANSR
Synthetic Minor Source of:
VOC
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
AIRS ID: 123/9D1C
Page 8 of 9
MACT
63.14 *5
S
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li Health and Environment
it Pollution Control Division
MACT
63.6580-63.8830
Subpart ZZZZ — Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN — Subpart XXXXXX
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: 123/9D1 C Page 9 of 9
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9/23/2015 State.co.us Executive Branch Mail - Carrizo Bringelson 8-20: 98% efficiency request
STATE OF
COLORADO
Gillette - CDPHE, Kira <kira.gillette@state.co.us>
Carrizo Bringelson 8-20: 98% efficiency request
EEE <ashley.campsie@eeeng.net> Mon, Sep 21, 2015 at 3:11 PM
To: "Gillette - CDPHE, Kira" <kira.gillette@state.co.us>, Patricia Whitenight <Patricia.Whitenight@crzo.net>
Cc: Stefanie Rucker - CDPHE <stefanie.rucker@state.co.us>
Kira,
Please find attached a revised spreadsheet using actual data highest 12 months times 1.1 for the oil and
water tanks. In addition, since the pipeline is pretty consistent for this site we have reduced the requested
amount of gas being flared. We changed the control efficiency back to 95% for the combustor. Although it is
fully capable of 98% Carrizo does not want to spend the time and money associated with periodic stack tests
and monitoring the agency will require.
All three sources; the oil tanks, water tanks, and oil loadout are all controlled by a single enclosed flare
(combustor). There were two but one has been moved to another site. Also note, since the original
submittal a GP -02 application was submitted for a VRU. Carrizo is still working through the operations of the
unit and does not know if it will remain onsite. As such, no reduction in tank/loadout emissions have been
requested for the VRU at this time.
Please red -line the APENs and forms as appropriate. If you prefer us to submit updated APENs, just let me
know.
Thanks,
Ashley
From: Gillette - CDPHE, Kira [mailto:kira.gillette@state.co.us]
Sent: Friday, September 18, 2015 7:44 AM
To: Patricia Moden <patricia.moden@crzo.net>; Ashley Campsie <ashley.campsie@eeeng.net>
Cc: Stefanie Rucker - CDPHE <stefanie.rucker@state.co.us>
Subject: Carrizo Bringelson 8-20: 98% efficiency request
[Quoted text hidden]
Bringelson 8-20 Multi-Pad_Calcs_PTE_rev3.pdf
107K
https://mai I.google.com/mail/u/0/?ui=2&i k= bdd6ca9821 &view=pt&search=i nbox&msg=14ff1 bfba383e727&sim l=14ff1 bfba383e727 1/1
9/28/2015 State.co.us Executive Branch Mail - Carrizo Bringelson 8-20: 98% efficiency request
STATE OF
COLORADO
Gillette - CDPHE, Kira <kira.gillette@state.co.us>
Carrizo Bringelson 8-20: 98% efficiency request
EEE <ashley.campsie@eeeng.net>
To: "Gillette - CDPHE, Kira" <kira.gillette@state.co.us>
Cc: Patricia Whitenight <Patricia.Whitenight@crzo.net>
Kira,
Fri, Sep 25, 2015 at 3:09 PM
Almost but not quite, please see my changes below. The highest 12 month total wasn't until 2015 so I
updated the 2014 actual numbers below. The requested is based on the highest 12 months * 1.1 for the
tanks (oil and water). One other change is the combustor. There is only one now, not two, and with lower
tank throughput emissions have decreased.
Thanks,
Ashley
From: Gillette - CDPHE, Kira[mailto:kira.gillette@state.co.us]
Sent: Friday, September 25, 2015 1:30 PM
To: EEE <ashley.campsie@eeeng.net>
Cc: Patricia Whitenight <Patricia.Whitenight@crzo.net>
Subject: Re: Carrizo Bringelson 8-20: 98% efficiency request
Thank you for the new information Ashley!
Redlining the APENs should be fine. I just want to make sure I'm using the numbers Carrizo expects:
Unit AIRS pt old throughput new 2014 actual new permit limits
Cr Oil tanks
PW tanks
HC Loadout
Separator
001
002
003
004
[Quoted text hidden]
[Quoted text hidden]
429,123 bbl/yr
148,547 bbl/yr
429,123 bbl/yr
66.5 MMscf/yr
221,456 bbl
64,907 bbl
221,456 bbl
7.2 MMscf
301,788 bbl/yr
76,919 bbl/yr
301,788 bbl/yr
39.9 MMscf/yr
https://mail.google.com/mail/u/0/?ui=2&ik= bdd6ca9821 &view=pt&search=i nbox&msg=150065703d28ce35&si m l=150065703d28ce35 1/1
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ed Action (check applicable request boxes)
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Section 01— Administrative Information
Request for NEW permit or newly reported emission source
Request MODIFICATION to existing permit (check each box below that applies)
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Gas Venting
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