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HomeMy WebLinkAbout20153155.tiff RECEIVED COPHE COLORADO SEP 28 2015 CO Department of Public Health&Environment WELD COUNTY COMMISSIONERS Dedicated to protecting and improving the health and environment or the people of Colorado Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 September 23, 2015 Dear Sir or Madam: On September 30, 2015, the Air Pollution Control Division will begin a 30-day public notice period for Carrizo Oil Et Gas, Inc. - Shull 35 Multipad. 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 Afiv 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe ((c ip .� John Lt,‘,W. Hickenlooper,Governor I Larry Wolk,MD,MSPH,Executive Director and Chief Medical Officer ‘ =sm , C C : /° ielf)� 07o15 , G 2015-3155 CDPHE Air Pollution Control Division CO '�, ,, Notice of a Proposed Project or Activity Warranting Public � Comment If iM Website Title: Carrizo Oil Et Gas, Inc. - Shull 35 Multipad - Weld County Notice Period Begins: September 30, 2015 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Carrizo Oil Et Gas, Inc. Facility: Shull 35 Multipad Oil and Gas Exploration and Production Facility NENE of Section 35, Township 9N, Range 60W Weld County The proposed project or activity is as follows: Natural gas venting from 3 separators controlled by open flare when pipeline is unavailable, crude oil storage tanks controlled by enclosed flare, produced water tanks controlled by enclosed flare, crude oil loading into trucks controlled by enclosed flare, and three internal combustion engines at an exploration and production facility. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non-attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 15WE0240 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: Christian Lesniak Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us 1 I W COLORADO ' rD P�&E�YeCvnMr.Ars, STATE OF COLORADO o Fcota •LO- • '• D • T � •F P C HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303)692-3150 * *7876/ CONSTRUCTION PERMIT PERMIT NO: 15 5W E0240 E0240 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 Shull 35 Multi-pad, located in the NENE Section 35, Township 9N, Range 60W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Separator 001 Three separators controlled by one open flare during pipeline unavailability. 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). AIRS ID: 123/9D90 Page 1 of 8 olor. A Depa en ' •li Health and Environment •it Pollution Control Division 3. This permit s e if;:- • - o•- • the s' for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a. reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The following information for the point control device shall be provided to the Division within fifteen (15) days after issuance of permit. • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO VOC CO Emission Type X Separator 001 4.0 49.3 21.8 Point See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling AIRS ID: 123/9D90 Page 2 of 8 Depa en . ' •Ii Health and Environment it Pollution Control Division twelve-month I. I . - t. -= mi•-' .ion u-' equiring an APEN, at this facility. 8. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID Separator 001 Open Flare VOC PROCESS LIMITATIONS AND RECORDS 9. 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 AIRS Equipment Point Process Parameter Annual Limit ID Separator 001 Gas Vented from Separators 85.2 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. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. 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) 11. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. 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.) 12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 13. The flare covered by this permit is subject to Regulation No. 7, Section XVII.B General Provisions (State only enforceable). All air pollution control equipment shall be operated and maintained pursuant to the manufacturing specifications or equivalent to the extent practicable, and consistent with technological limitations and good engineering and maintenance practices. The owner or operator shall keep manufacturer specifications or equivalent on file. In addition, all such air pollution control equipment shall be adequately AIRS ID: 123/9D90 Page 3 of 8 olor- Depa en . •li Health and Environment it Pollution Control Division designed and e - +nt T, cy r- nd to handle reasonably foreseeable fluctuations in emissions of VOCs and other hydrocarbons during normal operations. Fluctuations in emissions that occur when the separator dumps into the tank are reasonably foreseeable. The open flare covered by this permit has been approved as an alternative emissions control device under Regulation No. 7, Section XVII.B.2.e. The open flare shall have no visible emissions during normal operations and be designed so that an observer can, by means of visual observation from the outside of the open flare, or by other convenient means approved by the Division, determine whether it is operating properly. The operator shall comply with all applicable requirements of Section XVII. The owner/operator must equip the open flare with an operational auto-igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. (Regulation No. 7, Section XVII.B.) Per Regulation no. 7, Section XVII.B.2.d, all combustion devices used to control emissions of hydrocarbons must be equipped with and operate an auto-igniter. 14. The separators covered by this permit are subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98%for hydrocarbons. OPERATING & MAINTENANCE REQUIREMENTS 15. Upon startup of 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. Point 001: The owner or operator shall demonstrate compliance with opacity standards, using EPA Method 22 to measure opacity from the flare. (Reference: Regulation No. 1, Section II.A.1 &4; Regulation No. 7, Section XVII.B) ADDITIONAL REQUIREMENTS 17. 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: AIRS ID: 123/9D90 Page 4 of 8 - 1110000.6. olor Depa en : •li 'Health and Environment •it Pollution Control Division Fora a • a For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 18. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). 19. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities major stationary source requirements shall apply to this stationary source at any such time that this stationary source becomes major solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of Subpart HH. `(Reference: Regulation No. 8, Part E) 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 AIRS ID: 12319D90 Page 5 of 8 olor. Depa en . •Ii `Health and Environment it Pollution Control Division I II.G. Final a ion - • - an.v he o• •n or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self- Certify for Final Authorization section of this permit. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: '✓7 ``. �`� Christian Lesniak Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Carrizo Oil & Gas, Inc. AIRS ID: 123/9D90 Page 6 of 8 k _ olor. ' Depa_ en ' •Ii Health and Environment A it' Control Division Pollution Cont o 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: http://www.colorado.gov/cs/Satellite?c=Document C&childpagename=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# (lb/yr) reportable? (Ib/yr) Benzene 71432 6644.1 Yes 332.2 n-Hexane 110543 41007.1 Yes 2050.4 001 Toluene 108883 6318.2 Yes 315.9 Ethylbenzene 100414 429.6 Yes 21.5 Xylenes 1330207 795.6 Yes 39.8 5) The emission levels contained in this permit are based on the following emission factors: Point 001: Weight Emission Emission Pollutant Fraction of Factors Factors Source Gas(%) Uncontrolled Controlled lb/MMscf Ib/MMscf NOx ObIMMBTU) --- 0.068 0.068 AP-42 CO (Ib/ (Ib/MMBTU) --- 0.37 0.37 AP-42 VOC 36.12 23094.3934 1154.7197 Gas Analysis Benzene 0.038 77.9826 3.8991 Gas Analysis Toluene 0.031 74.1577 3.7079 Gas Analysis Ethylbenzene 0.002 5.0424 0.2521 Gas Analysis Xylenes 0.003 9.3377 0.4669 Gas Analysis n-hexane 0.21 481.3043 24.0652 Gas Analysis AIRS ID: 123/9D90 Page 7 of 8 IIIolorl Depa en . •Ii Health and Environment I it Pollution Control Division 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice(APEN)associated with this permit is'valid for a term of five years from the date it was received by the Division.A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, HAPs PSD or NANSR Synthetic Minor Source of:VOC, HAPs MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.q po access.q ov/ 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 777Z—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart)OOOOO( 9) A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification AIRS ID: 123/9D90 Page 8 of 8 Division Infc Three separators controlled by one enclosed flare during pipeline unavailability. Flare Engineer: Christian Lesniak Control Engineer: Stefanie Rucker Review Date: 08/19/2015 Application Date: 01/14/2015 routed to a flare Facility Identifiers Permit No. 15WE0240 Potentially located in ozone nonattainment area AIRS County# 123 (Weld Facility# 9D90 Facility Type: exploration and production facility ❑✓ Located in the 8-hour non-attainment area? O True Minor ® Synthetic Minor for: I✓' VOC r NOx r CO Administrative Information Company Name: Carrizo Oil &Gas, Inc. Source Name: Shull 35 Multi-pad Source Location: NENE Section 35, Township 9N, Range 60W SIC: 1311 Address 1: Carrizo Oil&Gas, Inc. Mailing Address 2: 500 Dallas,Suite 2300 Address City,State Zip: Houston,TX 77002 Name: Patricia Moden • Person To Phone: 713-328-1036 Contact Fax: 713-328-1060 Email: Patricia.Moden@crzo.net 'Requested Action Self Certification Required? Yes Issuance Number: 1 Source Description: Oil and gas exploration and production facility known as the Shull 35 Multi-pad, located in the NENE Section 35,Township 9N, Range 60W,Weld County, Colorado. Point Name Type Control Action Newly 001 Separator Separator Venting Flare reported source Three separators controlled by one enclosed flare during pipeline unavailability.Flare has a - 001 minimum control efficiency of 95%. Equipment Description This source vents natural gas from: a well head separator Emissions from this source are: routed to a flare Natural gas venting from a well head separator.Emissions from this source are routed to a flare. Calculations Emission Calculation Method EPA Emission Inventory Improvement Program Publication:Volume II,Chapter 10-Displacement Equation(10.4-3) Ex=Q*MW*Xx/C Ex=emissions of pollutant x Q=Volumetric flow rate/volume of gas processed MW=Molecular weight of gas=SG of gas*MW of air Xx=mass fraction of x in gas C=molar volume of ideal gas(379 scf/lb-mol)at 60F and 1 atm Throughput(Q) 85.2 MMscf/yr 9726.0274 scf/hr MW 24.23 lbltb-mol 0.23342466 MMscf/d mole% MW lbx/Ibmol mass fraction lb/hr lb/yr tpy Sample 1 Sample 2 Sample 3 Helium 0.02000 4.0026 0.001 0.000 0.02 180 0.09 0.02 0.02 0.02 CO2 2.43000 44.01 1.069 0.044 27.44 240413 120.21 2.33 2.47 2.49 N2 1.17333 28.013 0.329 0.014 8.43 73889 36.94 1.10 1.22 1.2 methane 67.09397 16.041 10.763 0.444 276.19 2419442 1209.72 64.85 66.9126 69.523 ethane 11.05843 30.063 3.324 0.137 85.31 747354 373.68 10.56 11.3608 11.2542 propane 9.29127 44.092 4.097 0.169 105.13 920948 460.47 8.84 9.8543 9.1771 isobutane 0.97433 58.118 0.566 0.023 14.53 127297 63.65 0.93 1.0687 0.926 n-butane 3.37170 58.118 1.960 0.081 50.29 440514 220.26 3.22 3.7781 3.121 isopentane 0.67990 72.114 0.490 0.020 12.58 110221 55.11 0.64 0.8043 0.5923 n-pentane 0.91847 72.114 0.662 0.027 17.00 148896 74.45 0.86 1.1082 0.784 cyclopentane 0.08450 70.13 0.059 0.002 1.52 13322 6.66 0.08 0.1079 0.069 n-Hexane 0.21167 86.18 0.182 0.008 4.68 41007 20.50 0.19 0.2699 0.171 cyclohexane 0.05497 84.16 0.046 0.002 1.19 10399 5.20 0.05 0.0723 0.0438 Other hexanes 0.37663 86.18 0.325 0.013 8.33 72967 36.48 0.34 0.4823 0.3027 heptanes 0.17330 100.21 0.174 0.007 4.46 39040 19.52 0.16 0.2158 0.144 methylcyclohexane 0.03800 98.19 0.037 0.002 0.96 8388 4.19 0.03 0.0478 0.0317 224-TMP 0.00083 114.23 0.001 0.000 0.02 214 0.11 0.00 0.001 0.0011 Benzene 0.03783 78.12 0.030 0.001 0.76 6644 3.32 0.04 0.0478 0.0298 Toluene 0.03050 92.15 0.028 0.001 0.72 6318 3.16 0.02 0.054 0.0182 Ethylbenzene 0.00180 106.17 0.002 0.000 0.05 430 0.21 0.00 0.0015 0.0021 Xylenes 0.00333 106.17 0.004 0.000 0.09 796 0.40 0.00 0.0031 0.0031 C8+Heavies 0.07503 120 0.090 0.004 2.31 20241 10.12 0.07 0.0753 0.0759 VOC mass fr 0.3612 Total VOC(Uncontrolled) 983.82 Notes Mole%,MW,and mass fractions from average of Shull 3-35-9-60,2-35-9-60 and 1-35-9-60 gas analyses,collected 11/14/2014 Emissions are based on 3500 hours of operation per year. 0 15WE0240.CP1.xlsm 4M"11, "'F.N'4.,1W! `"....S .By` , A IA .u. Three separators controlled by one enclosed flare during pipeline unavailability.Flare has a 001 minimum control efficiency of 95%. Flaring Information Equipment Description Flare to combust low-pressure separator gas during pipeline unavailability Manufacturer TBD Model TBD Serial Number TBD Gas Heating Value 1384.6 Btu/scf Throughput 117967.92 MMBtu/yr VRU Information Equipment Description Engine to recompress gas to sales line. Make TBD Model TBD Requested Control 0.00% Annual Bypass Tim 0.00% Backup Flare Overall Control 95.00% Combustion emission factor source: AP-42:Chapter 13.5 0.07 Ilb NOX/MMBtu 0.37 IIb CO/MMBtu Emissions Summary Table Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissio Source VOC 23094 lb/MMscf 1154.72 lb/MMscf 983.8 tpy 49.2 tpy Gas Analysis Nox 0.07 Ib/MMBTU 0.07 lb/MMBTU 4.0 tpy 4.0 tpy AP-42 CO 0.37 lb/MMBTU 0.37 lb/MMBTU 21.8 tpy 21.8 tpy AP-42 Benzene 77.98 lb/MMscf 3.90 lb/MMscf 6644 lb/yr 332 lb/yr Gas Analysis n-Hexane 481.30 lb/MMscf 24.0652 lb/MMscf 41007 lb/yr 2050 lb/yr Gas Analysis Toluene 74.158 lb/MMscf 3.7079 lb/MMscf 6318 lb/yr 316 lb/yr Gas Analysis Xylenes 9.338 lb/MMscf 0.4669 lb/MMscf 796 lb/yr 40 lb/yr Gas Analysis Ethylbenzene 5.042 lb/MMscf 0.2521 lb/MMscf 430 lb/yr 21 lb/yr Gas Analysis Regulatory Applicability AQCC Regulation 1 This source is subject to the opacity requirements for flares in Section II,A.5:'No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30%opacity.' AQCC Regulation 2 Section I.A applies to all emission sources."No person,wherever located,shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven(7)or more volumes of odor free air." AQCC Regulation 7 Was the well newly constructed,hydraulically fractured,or recompleted on or after August 1,2014? yes This separator is subject to Reg 7,Section XVII.G.and control requirements of Reg 7,Section XVII.B.2 Notes-Source has requested use of an open flare,which the Division has granted with the following provisions: The Division will generally approve the use of open flares for use on separators or storage tanks on a case by case basis through a permitting action,with the following caveats: • The open flare is for backup or upset conditions only; The onsite storage tanks are controlled by an ECD or VRU(this open flare can be backup to the storage tank VRU); • The source has provided a request and technical justification for this request in their permit application; • The flare will be able to control to 95%and have a manufacturer's design guarantee of 98%control;and • The flare will operate with no visible emissions,be equipped with an autoigniter(by the dates in the rule),and otherwise be able to comply with the requirements of Section XVII.B. 15WE0240.CP1.xlsm E0240.CP1.xlsm x h .z STATE OF COLORADO •LO' • •• D - • -Tv •FP C HEALTH AND ENVIRONMENT ,. co zo AIR POLLUTION CONTROL DIVISION A� TELEPHONE: (303)692-3150 *4. * *J87g* CONSTRUCTION PERMIT PERMIT NO: I5 V V E 024 1 Issuance 1 DATE ISSUED: & ISSUED TO: Carrizo Oil Gas, Incl. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas exploration and production facility known as the Shull 35 Multi-pad, located in the NENE Section 35, Township 9N, Range 60W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID LOAD 002 Hydrocarbon Loadout to Tanker Trucks 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 AIRS ID: 123/9D90 Page 1 of 8 olor. Depa en . - •Ii Health and Environment I it Pollution Control Division within 18 mon - eit- h . ,,•f i- - - -Y if this truction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, I I I.F.4.) 4. The following information shall be provided to the Division within fifteen (15) days after issuance of permit. • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 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 X LOAD 002 - 5.0 - Point See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 7. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) AIRS ID: 123/9D90 Page 2 of 8 olor Depa en P :ill Health and Environment Ir. Pollution Control Division Facility ° Pollutants Equipment Point Control Device Controlled ID LOAD 002 Enclosed Flare VOC 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. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Equipment Point Process Parameter Annual Limit ID LOAD 002 Oil Loaded 127,341 BBL 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. 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.) 10. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 11. This source is located in an ozone non-attainment or attainment-maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Crude oil loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III.E) The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.E): a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. b. All compartment hatches (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. AIRS ID: 123/9D90 Page 3 of 8 olor. ii Depa en •Ii Health and Environment I it Pollution Control Division c. The o .pe - s ' -per :;equi• -< and operations on site at the time of the inspection to ensure compliance with the conditions (a) and (b) above. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. 12. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. OPERATING & MAINTENANCE REQUIREMENTS 13. 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 No compliance testing or sampling required ADDITIONAL REQUIREMENTS 14. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5)tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or AIRS ID: 123/9D90 Page 4 of 8 olor.; Depa en . • •Ii `Health and Environment 'i it Pollution Control Division e. No lat .0 d v ,e''k r- a -r • Ne 15. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 16. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 17. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self- Certify for Final Authorization section of this permit. 18. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 19. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 20. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 21. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the AIRS ID: 123/9D90 Page 5 of 8 olor Depa en . ' 'II Health and Environment A it Pollution Control Division Division in wr. es ' _ = ,, = -tie- 'ermit -on notification, annual fee billing will terminate. 22. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: "1/1 * - ../. /4z,..: Christian Lesniak Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Carrizo Oil & Gas, Inc. Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: http://www.colorado.aov/cs/Satellite?c=Document C&childpaqename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper AIRS ID: 123/9D90 Page 6 of 8 �.n olor Depa en� . - 'Ii i 'Health and Environment II • •It- Pollution Control Division 4) The following emis • -,,��:n- - •- z-ale ;.- s are - --,-ted 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# (lb/yr) reportable? (lb/yr) Benzene 71432 272.9 Yes 91.4 n-Hexane 110543 1458.6 Yes 488.6 002 Toluene 108883 674.4 Yes 225.9 Xylenes 1330207 345.5 Yes 115.7 5) The emission levels contained in this permit are based on the following emission factors: Point 002: Emission Factors - Uncontrolled Source Pollutant lb/BBL loaded VOC 0.2322 AP-42 Benzene 0.0022 n-Hexane 0.0115 Pressurized Liquid Sample Toluene 0.0053 Xylenes 0.0027 The uncontrolled VOC emission factor was calculated using AP-42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L= 12.46*S*P*M/T S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 5.88 psia M (vapor molecular weight) =66.6 Ib/lb-mol T(temperature of liquid loaded) = 529.67 °R The uncontrolled non-criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor. Controlled emission factors are based on a vapor collection efficiency of 70% (for vapor balanced loading)and a flare efficiency of 95%, which combine to give a final control efficiency of 66.5%. AIRS ID: 123/9D90 Page 7 of 8 Ill olorl Depa en . ' •li Health and Environment it Pollution Control Division 6) In accordance with -7- , P• .ssion , ,.- (APEN)associated with this permit is valid for a term of five years from the date it was received by the Division.A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement . Operating Permit Synthetic Minor Source of: VOC, HAPs PSD or NANSR Synthetic Minor Source of: VOC, HAPs MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.q poaccess.qov/ 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 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: 123/9D90 Page 8 of 8 Division Information Engineer: Christian Lesniak Control Engineer: Stefanie Rucker Review Date: 08/20/2015 Application Date: 01/14/2015 Facility Identifiers Permit No. 15WE0241 Potentially located in ozone nonattainment area AIRS County# 123 'Weld Facility# 9D90 Facility Type: exploration and production facility ❑� Located in the 8-hour non-attainment area? O True Minor Synthetic Minor for: P'V0C r N0x r CO Administrative Information Company Name: Carrizo Oil &Gas, Inc. Source Name: Shull 35 Multi-pad Source Location: NENE Section 35, Township 9N, Range 60W SIC: 1311 Address 1: Carrizo Oil&Gas, Inc. Mailing Address 2: 500 Dallas,Suite 2300 Address ty,State Zip: Houston,TX 77002 Name: Patricia Moden Person To Phone: 713-328-1036 Contact Fax: 713-328-1060 Email: Patricia.Moden@crzo.net I Requested Action Self Certification Required? Yes Issuance Number: 1 Source Description: Oil and gas exploration and production facility known as the Shull 35 Multi-pad, located in the NENE Section 35, Township 9N, Range 60W,Weld County,Colorado. Point Name Type Control Action Newly 002 LOAD Loadout Flare reported source 002 Hydrocarbon Loadout to Tanker Trucks The table of inputs below enables you to calculate the loading loss emissions factor"L". If you choose to use a state default emissions Calculations factor,you may enter is directly into cell B14 L= 12.46*S*P*M/T(AP-42:Chapter 5.2, Equation 1) in units lb/1,000 gallons which will overwrite L= loading losses in lb per 1000 gallons loaded Factor Meaning Value Units Source S Saturation Factor 0.6 AP-42 P True Vapor Pressure 5.88 psia Sales Oil Analysis M Molecular Weight of VaF 66.6 lb/lb-mole AP-42 T Liquid Temperature 529.67 deg. R Field Data 70IDeg F L 5.53 lb/10^3 gal AP-42 Interpolation 2.32E-01 lb/bbl 9 66.6 5.87852 8.3 68 5.1284 Annual requested Throughput 127341 BBL/yr 10 66 6.2 5348322 gal/yr Annual requested VOC emissions 29562 lb/yr 14.78 tpy Capture Eff 70% Control: Flare Efficiency: 95.00% NCRPs Component Mass Fraction If the operator provides HAP speciation from a stable"sales oil" Benzene 0.0092 analysis,enter the mass fraction from this data. Alternatively,if n-hexane 0.0493 the operator modeled a pressurized oil to develop a site specific Toluene 0.0228 emissions factor,enter the modeled mass fraction for the Xylenes 0.0117 Source: Pressurized oil analysis Emissions Summary Table Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 0.2321 lb/bbl _ 14.8 tpy 5.0 tpy AP-42 Benzene 0.0021 lb/bbl 272.9 lb/yr 91.4 lb/yr AP-42 n-Hexane 0.0115 lb/bbl 1459 lb/yr 488.6 lb/yr AP-42 Toluene 0.0053 lb/bbl 674 lb/yr 225.9 lb/yr AP-42 Xylenes 0.0027 lb/bbl 346 lb/yr 115.7 lb/yr AP-42 Regulatory Review 'Regulation 3-APEN and Permitting Requirements Is this site considered an exploration and production location (e.g.well pad)? Yes If yes, review the following two exemptions for applicability: Does the operator unload less than 10,000 gallons(238 BBLs)per day of crude oil on an annual average basis? No .. .�. .... .. .. .. i' f. ., a wA a..♦. If yes,this emissions point is categorically exempt from permit requirements per Regulation 3,Part B,Section 11.0.1.1 Does this operator unload less than 6,750 bbls per year of condensate via splash fill or 16,308 bbls per year of condensate via submerged fill procedure? No If yes,this emissions point is categorically exempt from permit requirements per Regulation 3,Part B,Section 11.0.1.1 STATE OF COLORADO .0v coy •LO- • '• D - -T •F P = C HEALTH AND ENVIRONMENT . AIR POLLUTION CONTROL DIVISION TELEPHONE: (303)692-3150 * * 4-7876* CONSTRUCTION PERMIT PERMIT NO: 15 V V E0243 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 Shull 35 Multi-pad, located in the NENE Section 35, Township 9N, Range 60W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID TANKS 004 Thirteen (13) above ground 400 bbl atmospheric crude oil storage tanks, controlled by an 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 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). AIRS ID: 123/9D90 Page 1 of 11 olorl Depa en . - •Ii Health and Environment I it Pollution Control Division 3. This permit s e . e if - • s o• • the se,, for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The 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 X TANKS 004 - 20.9 4.9 Point See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 7. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled. ID AIRS ID: 123/9D90 Page 2 of 11 I olorl'Depa en . iii Health and Environment it Pollution Control Division Ad' TANKS En v ,e VOC 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. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Equipment Point Process Parameter Annual Limit ID TANKS 004 Oil Throughput 127,341 BBL 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 I I.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. XVIl.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. AIRS ID: 123/9D90 Page 3 of 11 olor Depa en . ' •li Health and Environment it Pollution Control Division XVII.B.2.d.(ii) _ I. , u .= - •ns ire M 2014, must be equipped with an operational auto-igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The storage tanks covered by this permit are subject to Regulation 7, Section XVII.C emission control requirements. These requirements include, but are not limited to: Section XVII.C.1. Control and monitoring requirements for storage tanks XVII.C.1.b. Owners or operators of storage tanks with uncontrolled actual emissions of VOCs equal to or greater than six (6) tons per year based on a rolling twelve- month total must 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. XVII.C.1.b.(i)(a) Control requirements of Section XVII.C.1.b. must be achieved within ninety (90) days of the date that the storage tank commences operation. XVII.C.1.d. Beginning May 1, 2014, or the applicable compliance date in Section XVII.C.1.b.(i), whichever comes later, owners or operators of storage tanks subject to Section XVII.C.1. must conduct audio, visual, olfactory ("AVO") and additional visual inspections of the storage tank and any associated equipment (e.g. separator, air pollution control equipment, or other pressure reducing equipment) at the same frequency as liquids are loaded out from the storage tank. These inspections are not required more frequently than every seven (7) days but must be conducted at least every thirty one (31) days. Monitoring is not required for storage tanks or associated equipment that are unsafe, difficult, or inaccessible to monitor, as defined in Section XVII.C.1.e. The additional visual inspections must include, at a minimum: XVII.C.1.d.(i) Visual inspection of any thief hatch, pressure relief valve, or other access point to ensure that they are closed and properly sealed; XVII.C.1.d.(ii) Visual inspection or monitoring of the air pollution control equipment to ensure that it is operating, including that the pilot light is lit on combustion devices used as air pollution control equipment; XVII.C.1.d.(iii) If a combustion device is used, visual inspection of the auto-igniter and valves for piping of gas to the pilot light to ensure they are functioning properly; XVII.C.1.d.(iv) Visual inspection of the air pollution control equipment to ensure that the valves for the piping from the storage tank to the air pollution control equipment are open; and XVII.C.1.d.(v) If a combustion device is used, inspection of the device for the presence or absence of smoke. If smoke is observed, either the equipment must be immediately shut-in to investigate the potential cause for smoke and perform repairs, as necessary, or EPA Method 22 must be conducted to determine whether visible emissions are present for a period of at least one (1) minute in fifteen (15) minutes. XVII.C.1.e. If storage tanks or associated equipment is unsafe, difficult, or inaccessible to monitor, the owner or operator is not required to monitor such equipment until it becomes feasible to do so. AIRS ID: 123/9D90 Page 4 of 11 � olor- en, Depa •Ii `Health and Environment dmII •it Pollution Control Division XVII.C.2. Ca• �_ �Id r 't• , _ ,�= -q - "� for -ge tanks that are fitted with air pollution control equipment as required by Sections XII.D. or XVII.C.1. XVII.C.2.a. Owners or operators of storage tanks must route all hydrocarbon emissions to air pollution control equipment, and must operate without venting hydrocarbon emissions from the thief hatch (or other access point to the tank) or pressure relief device during normal operation, unless venting is reasonably required for maintenance, gauging, or safety of personnel and equipment. Compliance must be achieved in accordance with the schedule in Section XVII.C.2.b.(ii). XVII.C.2.b. Owners or operators of storage tanks subject to the control requirements of Sections XII.D.2., XVII.C.1.a, or XVII.C.1.b. must develop, certify, and implement a documented Storage Tank Emission Management System ("STEM") plan to identify, evaluate, and employ appropriate control technologies, monitoring practices, operational practices, and/or other strategies designed to meet the requirements set forth in Section XVII.C.2.a. Owners or operators must update the STEM plan as necessary to achieve or maintain compliance. Owners or operators are not required to develop and implement STEM for storage tanks containing only stabilized liquids. The minimum elements of STEM are listed below. XVII.C.2.b.(i) STEM must include selected control technologies, monitoring practices, operational practices, and/or other strategies; procedures for evaluating ongoing storage tank emission capture performance; and monitoring in accordance with approved instrument monitoring methods following the applicable schedule in Section XVII.C.2.b.(ii) and Inspection Frequency in Table 1. XVII.C.2.b.(ii) Owners or operators must achieve the requirements of Sections XVII.C.2.a. and XVII.C.2.b. and begin implementing the required approved instrument monitoring method in accordance with the following schedule: XVII.C.2.b.(ii)(a) A storage tank constructed on or after May 1, 2014, must comply with the requirements of Section XVII.C.2.a. by the date the storage tank commences operation. The storage tank must comply with Section XVII.C.2.b. and implement the approved instrument monitoring method inspections within ninety (90) days of the date that the storage tank commences operation. XVII.C.2.b.(ii)(d) Following the first approved instrument monitoring method inspection, owners or operators must continue conducting approved instrument monitoring method inspections in accordance with the Inspection Frequency in Table 1. Table 1 — Storage Tank Inspections Threshold: Storage Tank Approved Instrument Phase-In Schedule Uncontrolled Actual VOC Monitoring Method Emissions (tpy) Inspection Frequency AIRS ID: 123/9D90 Page 5 of 11 II olor. Depa en . ' •li Health and Environment •it Pollution Control Division d < • r. ly January 1, 2016 > 12 and < 50 Quarterly July 1, 2015 > 50 Monthly January 1, 2015 XVII.C.2.b.(iii) Owners or operators are not required to monitor storage tanks and associated equipment that are unsafe, difficult, or inaccessible to monitor, as defined in Section XVII.C.1.e. XVII.C.2.b.(iv) STEM must include a certification by the owner or operator that the selected STEM strategy(ies) are designed to minimize emissions from storage tanks and associated equipment at the facility(ies), including thief hatches and pressure relief devices. XVII.C.3. Recordkeeping XVII.C.3. The owner or operator of each storage tank subject to Sections XII.D. or XVII.C. must maintain records of STEM, if applicable, including the plan, any updates, and the certification, and make them available to the Division upon request. In addition, for a period of two (2) years, the owner or operator must maintain records of any required monitoring and make them available to the Division upon request, including: XVII.C.3.a. The AIRS ID for the storage tank. XVII.C.3.b. The date and duration of any period where the thief hatch, pressure relief device, or other access point are found to be venting hydrocarbon emissions, except for venting that is reasonably required for maintenance, gauging, or safety of personnel and equipment. XVII.C.3.c. The date and duration of any period where the air pollution control equipment is not operating. XVII.C.3.d. Where a combustion device is being used, the date and result of any EPA Method 22 test or investigation pursuant to Section XVII.C.1.d.(v). XVII.C.3.e. The timing of and efforts made to eliminate venting, restore operation of air pollution control equipment, and mitigate visible emissions. XVII.C.3.f. A list of equipment associated with the storage tank that is designated as unsafe, difficult, or inaccessible to monitor, as described in Section XVII.C.1.e., an explanation stating why the equipment is so designated, and the plan for monitoring such equipment. 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.) AIRS ID: 123/9D90 Page 6 of 11 olor. Depa en P •Ii Health and Environment it Pollution Control Division COMPLIANCE TE :•N r 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 (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 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). 18. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities major stationary source requirements shall apply AIRS ID: 123/9D90 Page 7 of 11 olor. Depa en . - ell '''Health and Environment A it Pollution Control Division to this statio =ce n > ti - -.5 sta '.- - source becomes major solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of Subpart HH. (Reference: Regulation No. 8, Part E) GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self- Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the 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. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality 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. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, AIRS ID: 12319D90 Page 8 of 11 olor.A.Depa en .. •Ii Health and Environment it Pollution Control Division civil or crimi .� : ,`ce-- k_ o - u -,ions 115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. Christian Lesniak Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Carrizo Oil & Gas, Inc. Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: http://www.colorado.qov/cs/Satellite?c=Document C&childpagename=CDPHE- . Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper AIRS ID: 123/9D90 Page 9 of 11 olor- Depa en . - •li Health and Environment it Pollution Control Division 4) The following emis , in- - . le • s are -ted 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# (lb/yr) reportable? (lb/yr) Benzene 71432 14134.9 Yes 706.7 n-Hexane 110543 84809.1 Yes 4240.5 Toluene 108883 12988.8 Yes 649.4 004 Xylene 1330207 2521.4 Yes 126.1 Ethylbenzene 100414 714.4 Yes 35.7 224 540841 5692.1 Yes 284.6 Trimethylpentane 5) The emission levels contained in this permit are based on the following emission factors: Point 004: Emission Factors Pollutant Uncontrolled Source lb/BBL Oil Throughput NOx 0.068(lb/mmBtu) AP-42 CO 0.37(lb/mmBtu) AP-42 VOC 6.55 E&P TANK n-Hexane 0.666 E&P TANK Benzene 0.111 E&P TANK Toluene 0.102 E&P TANK Ethylbenzene .00561 E&P TANK Xylenes .0198 E&P TANK Note: The controlled emissions for this point are based on the flare control efficiency of 95%. NOx and CO emissions are based on a fuel heating value of 3823.76 btu/scf and a vapor throughput of 54.12 (scf/bbl), as provided by E&P Tanks. AIRS ID: 123/9D90 Page 10 of 11 olor- Depa en' . '� •Ii Health' and Environment it Pollution Control Division 6) In accordance with , -7 .. P. ° 'ssion -� - (APEN)associated with this permit is valid for a term of five years from the date it was received by the Division.A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, HAPs PSD or NANSR Synthetic Minor Source of: VOC, HAPs MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.qpoaccess.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 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: 123/9D90 Page 11 of 11 a x Division Information Engineer: Christian Lesniak Control Engineer: Stefanie Rucker Review Date: 08/27/2015 Application Date: 01/14/2015 Facility Identifiers Permit No. 15WE0243 Potentially located in ozone nonattainment area AIRS County# 123 'Weld Facility# 9D90 Facility Type: exploration and production facility ❑� Located in the 8-hour non-attainment area? O True Minor ® Synthetic Minor for: F VOC r NOx r CO Administrative Information Company Name: Carrizo Oil &Gas, Inc. Source Name: Shull 35 Multi-pad Source Location: NENE Section 35, Township 9N, Range 60W SIC: 1311 Address 1: Carrizo Oil&Gas, Inc. Mailing Address 2: 500 Dallas,Suite 2300 Address ty,State Zip: Houston,TX 77002 Name: Patricia Moden Person To Phone: 713-328-1036 Contact Fax: 713-328-1060 Email: Patricia.Moden@crzo.net 'Requested Action Self Certification Required? Yes Issuance Number: 1 Source Description: Oil and gas exploration and production facility known as the Shull 35 Multi-pad, located in the NENE Section 35, Township 9N, Range 60W,Weld County,Colorado. Point Name Type Control Action 004 TANKS Oil Tanks Flare New Permit Issuance 004 Thirteen (13)above ground 400 bbl atmospheric crude oil storage tanks,controlled by an enclosed flare GOR 54.12 scf/bbl Calculations HC vapor 6891695 scf Requsted Throughput 127341 bbl Heat Value 3823.76 btu/scf (From E&P tank 26352.19 mm btu Tons Control Flare I Nox 0.068 lb/mmBtu 0.89597437 Efficiency 95.00%l CO 0.37 lb/mmBtu 4.875154663 Emissions Summary Table Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 6.55 lb/bbl 417.0 tpy 20.9 tpy E&P TANK Benzene 0.111 lb/bbl 14134.851 lb/yr 706.7426 lb/yr E&P TANK n-Hexane 0.666 lb/bbl 84809.106 lb/yr 4240.455 lb/yr E&P TANK toluene 0.102 lb/bbl 12988.782 lb/yr 649.4391 lb/yr E&P TANK Xylene 0.0198 lb/bbl 2521.3518 lb/yr 126.0676 lb/yr E&P TANK 224 Trimet 0.0447 lb/bbl 5692.1427 lb/yr 284.6071 lb/yr E&P TANK Ethylbenze 0.00561 lb/bbl 714.38301 lb/yr 35.71915 lb/yr E&P TANK 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. 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