HomeMy WebLinkAbout20141072.tiff STATE OF COLORADO
John W.Hickenlooper,Governor 76-7•c
Larry Wolk,MD,MSPH aw . R\
Executive Director and Chief Medical Officer /c -°�"-
Dedicated to protecting and improving the health and environment of the people of Colorado C
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4300 Cherry Creek Dr.S. Laboratory Services Division \av7»
Denver,Colorado 80246-1530 8100 Lowry Blvd.
Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department
Located in Glendale,Colorado (303)692-3090 of Public Health
www.colorado.gov/cdphe and Environment
Weld County -Clerk to the Board
1150 O Street
PO Box 758
Greeley, CO 80632 RECEIVED
March 31, 2014 APR 0 3 2011i
WELD COUNTY
COMMISSIONERS
Dear Sir or Madam:
On April 3, 2014, the Air Pollution Control Division will publish a public notice for Carrizo Oil and Gas, Inc
— Shull 1-25-9-60, in the The Greeley Tribune. A copy of this public notice and the public comment packet
are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public
copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet
must be available for public inspection for a period of thirty (30) days from the date the public notice is
published. Please send any comment regarding this public notice to the address below.
Colorado Dept. of Public Health & Environment
A PC D-SS-B l
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
1'L (m.m' HL l� .$' 2014-1072
U q IN y- -4- 1`I
STATE OF COLORADO
John W.Hickenlooper,Governor - -
Larry Wolk, MD,MSPH .o or
Executive Director and Chief Medical Officer Nc rQ
.- o
Dedicated to protecting and improving the health and environment of the people of Colorado i - r
•
4300 Cherry Creek Dr. S. Laboratory Services Division •evc `
Denver,Colorado 80246-1530 8100 Lowry Blvd.
Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department
Located in Glendale,Colorado (303)692-3090 of Public Health
www.colorado,gov/cdphe and Environment
Website Title: Carrizo Oil and Gas, Inc—Shull 1-25-9-60— Weld County
Released To: The Greeley Tribune
On: March 31, 2014
Published: April 3, 2014
PUBLIC NOTICE OF A PROPOSED PROJECT
OR ACTIVITY WARRANTING PUBLIC COMMENT
Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado
Air Pollution Control Division for the following source of air pollution:
Applicant: Carrizo Oil and Gas, Inc
Facility: Shull 1-25-9-60
Crude oil production well site with associated natural gas.
SESE SEC25 T9N R60W
Weld County
The proposed project or activity is as follows: The applicant proposes to permit crude oil storage tanks and
separator venting for acrude oil production well with associated natural gas
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.I.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 13WE2632 have been tiled
with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the
Division's website at www.colorado.gov/cdphe/AirPublicNotices
The Division hereby solicits submission of public comment from any interested person concerning the ability of
the proposed project or activity to comply with the applicable standards and regulations of the Commission. The
Division will receive and consider written public comments for thirty calendar days after the date of this Notice.
Any such comment must be submitted in writing to the following addressee:
David Thompson
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South.APCD-SS-B 1
Denver. Colorado 80246-1530
cdphe.commentsapcdcristate.co.us
STATE OF COLORADO
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COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
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AIR POLLUTION CONTROL DIVISION "e
TELEPHONE: (303)692-3150 *« �
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CONSTRUCTION PERMIT
PERMIT NO: 13WE2632
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 facility, known as the Shull 1-25-9-60, located in the SESE of Section 25,
Township 9N, Range 60W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS
Equipment Point Description
ID
TANKS 002 Three (3) 400 BBL fixed roof storage tanks used to store Crude Oil.
Emissions from these tanks are controlled by a combustor.
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 sect),TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED
IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen
days after issuance of this permit, by submitting a Notice of Startup form to the
Division. The Notice of Startup form may be downloaded online at
www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of
the permitted source is a violation of Air Quality Control Commission (AQCC)Regulation No.
3, Part B, Section III.G.1 and can result in the revocation of the permit.
2. Within one hundred and eighty days(180)after issuance of this permit, compliance with the
conditions contained in this permit shall be demonstrated to the Division. It is the owner or
operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate
compliance within 180 days may result in revocation of the permit. (Reference: Regulation
No. 3, Part B, 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 permit
application associated with this permit; (ii)discontinues construction for a period of eighteen
AIRS ID: 123/9BCA/002 Page 1 of 7
Condensate Tank SM/M Version 2012-1
olor Depa en f li Health and Environment
it Pollution Control Division
months or m doe, of oakete ion wi 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 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
Emission Type
VOC CO
Equipment ID Point NO,
TANKS 002 --- 14.10 --- Point
See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits.
During the first twelve (12) months of operation, compliance with both the monthly and
annual emission limitations is required. After the first twelve (12) months of operation,
compliance with only the annual limitation is required.
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
TANKS 002 Combustor VOC and HAPS
AIRS ID: 123/9BCA/002 Page 2 of 7
t oolora^f4Depai nerr of Pyblic Health and Environment
,Air Pollution Control Division
PROCESS LIMITAT �.�C ND: E)ORDS .
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 002 Crude Oil throughput 41,172 BBL/yr
The owner or operator shall calculate monthly process rates based on the calendar month.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months'data. The permit holder shall calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility,for Division
review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
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.1.c shall have no visible emissions. (Reference: Regulation No. 1,
Section II.A.1. &4.)
11. 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)(B).
12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable)
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
Periodic Testing Requirements
14. The owner or operator shall demonstrate compliance with Condition 14, using EPA Method
9 to measure opacity from the flare. (Reference: Regulation No. 1, Section II.A.1 & 4)
AIRS ID: 123/9BCA/002 Page 3 of 7
olor Depa en f li Health and Environment
it Pollution Control Division
ADDITIONAL REQ N
15. A revised Air Pollutant Emission Notice(APEN)shall be filed:(Reference: Regulation No. 3,
Part A, II.C)
a. Annually by April 30`"whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of
five (5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds(VOC) and nitrogen oxides sources (NO„) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO, per year, a
change in annual actual emissions of one (1) ton per year or more or five percent,
whichever is greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of
five percent or 50 tons per year or more,whichever is less, above the level reported
on the last APEN submitted; or
For any non-criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above
the level reported on the last APEN submitted to the Division.
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
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.
16. 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
17. 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.
18. 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
AIRS ID: 123/9BCA/002 Page 4 of 7
Color Depa ens df P bliCHealth and Environment
it Pollution Control Division
1,1
written docum . ion'o'f su fin31aufhori =tails fo . btaining final authorization
to operate are located in the Requirements to Self-Certify for Final Authorization
section of this permit.
19. 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.
20. 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.
21. 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.
22. 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.
23. 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:
David Thompson
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Carrizo Oil & Gas, Inc.
AIRS ID: 123/9BCA/002 Page 5 of 7
tY ... "olor. , ..Depa nen 8f P lid'Health and Environment
it Pollution Control Division
H
Notes to Permit Holder :' e o .e k°SS3LanC " `'
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
Point Pollutant CAS# BIN (Ib/yr) reportable? Rate(Ib/yr)
Benzene 71432 A 988 YES 49
002
Hexane 110543 C 8,646 YES 432
5) The emission levels contained in this permit are based on the following emission factors:
Point 001:
Emission Factors Emission Factors
CAS# Pollutant Uncontrolled Controlled Source
lb/BBL Crude Oil lb/BBL Crude Oil
Throughput Throughput
VOC 13.7 0.685 CDPHE
110543 n-Hexane 0.024 0.0012 CDPHE
71432 Benzene 0.21 0.0105 CDPHE
Note: The controlled emissions factors for point 002 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:
AIRS ID: 123/9BCA/002 Page 6 of 7
.4-4,(
i3 olora*t Depai nen, of Ptblic-Health and Environment
,Air Pollution Control Division
Applicable
Requirement Status
Operating Permit Synthetic Minor of:
VOCs
NANSR Synthetic Minor of:
VOCs
MACT HH Major Source Requirements: Not Applicable
Area Source Requirements: Not Applicable
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at
the website listed below:
http://ecfr.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
9) An Oil and Gas Industry Construction Permit Self-Certification Form is included with this permit packet.
Please use this form to complete the self-certification requirements as specified in the permit conditions.
Further guidance on self-certification can be found on our website at:
www.colorado.gov/cdphe/oilciaspermits
AIRS ID: 123/9BCA/002 Page 7 of 7
Construction Permit Application
Preliminary Analysis Summary
Section 1 —Applicant Information
Company Name: Carrizo Oil &Gas, Inc
Permit Number: 13WE2632
Source Location: SESE SEC26 T9N R60W
Equipment Description: Crude Oil Storage Tanks
AIRS ID: 123/9BCA/002
Date: 12/18/13
Review Engineer: David Thompson
Control Engineer: Chris Laplante
Section 2—Action Completed
Grandfathered Modification APEN Required/Permit Exempt
x Initial Approval Transfer of Ownership APEN Exempt/Permit Exempt
* If tank is a true minor source at a true minor facility, it may be granted "Final Approval"without first
being issued an Initial Approval permit
*Grandfathered exemption is for any tanks in service prior to December 30, 2002
Section 3—Applicant Completeness Review
Was the correct APEN submitted for this source type? X Yes No
Is the APEN signed with an original signature? X Yes No
Was the APEN filled out completely? X Yes No
Did the applicant submit all required paperwork? X Yes No
Did the applicant provide ample information to determine emission rates? X Yes No
If you answered "no" to any of the above, when did you mail an
Information Request letter to the source?
On what date was this application complete? August 12, 2013
Section 4—Source Description
AIRS Point Equipment Description
002 One (1) above ground 300 bbl atmospheric condensate storage tank
Is this a portable source? Yes X No
Is this location in a non-attainment area for any criteria Yes No
pollutant?
If"yes", for what pollutant? PMio CO x Ozone
Is this location in an attainment maintenance area for Yes X No
any criteria pollutant?
If"yes", for what pollutant?
(Note: These pollutants are subject to minor source PM10 CO Ozone
RACT per Regulation 3, Part B, Section III.D.2)
Is this source located in the 8-hour ozone non-
attainment region? (Note: If"yes" the provisions of x Yes No
Regulation 7, Sections XII and XVII.C may apply)
Page 1
Section 5—Emission Estimate Information
AIRS Point Emission Factor Source
002 CDPHE Condensate Storage Tank Emission Factors
Did the applicant provide actual process data for the emission inventory? X Yes No
Basis for Potential to Emit(PTEI
AIRS Point Process Consumption/Throughput/Production
002 41,172 bbl/yr
Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory)
AIRS Point Process Consumption/Throughput/Production Data Year
002 41,172 bbl/yr 2008
Basis for Permitted Emissions(Permit Limits)
AIRS Point Process Consumption/Throughput/Production
002 41,172 bbl/yr
Does this source use a control device? x Yes No
% Reduction
AIRS Point Process Control Device Description
Granted
002 01 Combustor 95
Section 6—Emission Summar/ (tons per year)
Point NO, VOC CO Single HAP Total HAP
PTE: 002 282.03 4.3 (Hexane) 4.8
Uncontrolled point 002 282.03 4.3 (Hexane) 4.8
source emission rate:
Controlled point 14.10 0.2 0.2
source emission rate:
Total APEN Reported 14.10 0.2 0.2
emissions:
Section 7—Non-Criteria/ Hazardous Air Pollutants
Uncontrolled Are the Controlled Emission
Pollutant CAS# BIN Emission Rate emissions Ibl r
(Iblyr) reportable? Rate( y )
Benzene 71432 A 988 Yes 49
n-Hexane 110543 C 8,646 No 432
Note: Regulation 3, Part A, Section II.B.3.b APEN emission reporting requirements for non-criteria air
pollutants are based on potential emissions without credit for reductions achieved by control
devices used by the operator.
Section 8—Testing Requirements
Will testing be required to show compliance with any emission rate or regulatory Yes x No
standard?
If"yes", complete the information listed below
AIRS Point Process Pollutant Regulatory Basis Test Method
VOC, Liquids Analyses
002 01 HAPS PS Memo 05-01 according to PS
Memo 05-01
Page 2
Section 9—Source Classification
Is this a new previously un-permitted source? X Yes No
What is this facility classification? True x Synthetic Major
Minor Minor
Classification relates to what programs? x Title V PSD x NA NSR MACT
Is this a modification to an existing permit? Yes X No
If"yes"what kind of modification? Minor Synthetic Major
Minor
Section 10—Public Comment
Does this permit require public comment per CAQCC Regulation 3? x Yes No
If"yes",for which pollutants?Why?
For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)? Yes No
For Reg. 3, Part B, III.C.1.c.ii (subject to MACT)? Yes No
For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? x Yes No
Section 11 —Modeling
Is modeling required to demonstrate compliance with National Ambient Yes X No
Air Quality Standards (NAAQS)?
If"yes", for which pollutants?Why?
AIRS Point Section 12—Regulatory Review
Regulation 1 - Particulate Smoke, Carbon Monoxide and Sulfur Dioxide
Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator
of a source shall allow or cause the emission into the atmosphere of any air pollutant which
is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings
taken at 15-second intervals for six minutes. The approved reference test method for
visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July,
002 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
002 measured in excess of the following limits: For areas used predominantly for residential or
commercial purposes it is a violation if odors are detected after the odorous air has been
diluted with seven (7) or more volumes of odor free air.
Regulation 3 -APENs, Construction Permits, Operating Permits, PSD
Part A-APEN Requirements
Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for:
002 each individual emission point in a non-attainment area with uncontrolled actual emissions
of two tons per year or more of any individual criteria pollutant(pollutants are not summed)
for which the area is non-attainment
(Applicant is required to file an APEN since emissions exceed 2 tons per year VOC)
Part B—Construction Permit Exemptions
002 Applicant is required to obtain a permit since uncontrolled VOC emissions from this
facility are greater than the 5.0 TPY threshold(Reg. 3, Part B, Section II.D.3.a)
Regulation 6 - New Source Performance Standards
Page 3
NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84.
002 Is this source greater than 19,800 gallons (471 bbl)? Yes or No
Is this source subject to NSPS Kb?Yes or No
WHY?
Regulation 7—Volatile Organic Compounds
002 Tank is crude oil, Therefore Regulation 7 does not apply.
Regulation 8—Hazardous Air Pollutants
MACT EEEE: Organic Liquids Distribution
002 Pick one:
• This source is not subject to MACT EEEE because it is not located at a major
source of HAP.
MACT HH
002 Pick one:
• This source is not subject to MACT HH because it is not located at a major source
of HAP.
Section 13—Aerometric Information Retrieval System Coding Information
Point Process Process Emission Pollutant/ Fugitive Emission Factor Source Control
Description Factor CAS# (Y/N) (%)
326.1905 CDPHE PS Memo 05-01
lb/1000 gal V0C No (converted to lb/1000 gal) 95
throughput
E&P Condensate 0.5714 Benzene/ CDPHE PS Memo 05-01
01 Storage Tanks lb/1000 gal 71432 No (converted to lb/1000 gal) 95
002 throughput
5.0 n-Hexane CDPHE PS Memo 05-01
lb/1000 gal / 110543 No (converted to lb/1000 gal) 95
throughput
SCC 40400311 —Fixed Roof Tank, Condensate,working+breathing+flashing losses
Section 14—Miscellaneous Application Notes
AIRS Point 002 Condensate Storage Tanks
State-Developed Emission factors are:
Condensate Tank Default
County Emission Factors (lb/1000 gal)
VOC Benzene n-Hexane
Adams, Arapahoe, Boulder, Broomfield, Crowley, 326.1905 0.5714 5.0
Denver, Douglas, El Paso, Elbert, Jefferson,
Larimer, Logan, Morgan, Philips, Pueblo, Sedgwick,
Washington, Weld, Yuma
Garfield, Mesa, Rio Blanco and Moffat 238.0952 1.1429 3.3333
Cheyenne, Kiowa, Kit Carson, Lincoln 71.4286 0.0952 1.6667
Remainder of Colorado 280.9524 0.8095 4.4048
The contents of this storage vessel is Crude Oil. Therefore, the provisions of Regulation 7, Section XII do
not apply to this source.
Page 4
dfT s� + g,
5 . STATE OF COLORADO
.0c CQ(O
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT 44 °�
AIR POLLUTION CONTROL DIVISION -- ` -
TELEPHONE: (303)692-3150 �. ,r,03,
*18763
CONSTRUCTION PERMIT
PERMIT NO: 13WE2634
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 facility, known as the Shull 1-25-9-60, located in the SESE of Section 25,
Township 9N, Range 60W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS
Equipment Point Description
ID
SEPARATOR 004 Separator controlled by an open flare. Flare has a minimum
combustion efficiency of 95%.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR
QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S.(25-7-101 et seq),TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED
IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division)no later than fifteen
days after issuance of this permit, by submitting a Notice of Startup form to the
Division. The Notice of Startup form may be downloaded online at
www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of
the permitted source is a violation of Air Quality Control Commission (AQCC)Regulation No.
3, Part B, Section III.G.1 and can result in the revocation of the permit.
2. Within one hundred and eighty days(180)after issuance of this permit, compliance with the
conditions contained in this permit shall be demonstrated to the Division. It is the owner or
operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate
compliance within 180 days may result in revocation of the permit. (Reference: Regulation
No. 3, Part B, 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 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
AIRS ID: 123/9BCA/004 Page 1 of 8
Wellhead Template Version 2012-1
a ol• De en f Public Health and Environment
amp, Air Pollution Control Division
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 following information for all permitted equipment except fugitive emissions from
equipment leaks 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 Emission T e
Equipment ID Point NO, VOC CO yP
SEPARATOR 004 1.2 13.0 6.7 Point
See "Notes to Permit Holder#4"for information on emission factors and methods used to calculate
limits.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)from
each emission unit, on a rolling twelve (12) month total. By the end of each month a new
twelve-month total shall be calculated based on the previous twelve months' data. The
permit holder shall calculate emissions each month and keep a compliance record on site or
at a local field office with site responsibility, for Division review. This rolling twelve-month
total shall apply to all permitted emission units, requiring an APEN, at this facility.
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
Control Device
Equipment ID Point Controlled
SEPARATOR 004 Separator controlled by a 40' flare stack VOC, HAPs
PROCESS LIMITATIONS AND RECORDS
AIRS ID: 123/9BCA/004 Page 2 of 8
11,
A,
W�V' a Coloo Dekjia,,ment f Public Health and Environment
r Air Pollution Control Division
8. This source shall be limited to the following maximum processing rates as listed below.
Annual records of the throughput shall be maintained by the applicant and made available to
the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4)
Process/Consumption Limits
Facility AIRS Process Parameter Annual Limit
Equipment ID Point
SEPARATOR 004 Natural gas flaring 27.2 MMSCF/yr
The owner or operator shall calculate monthly process rates based on the calendar month.
STATE AND FEDERAL REGULATORY REQUIREMENTS
9. The permit number and AIRS ID number shall be marked on the subject equipment for ease
of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable)
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. (Reference: Regulation No. 1, Section II.A.1. & 4.)
11. No owner or operator of a smokeless flare or other flare for the combustion of waste
gases shall allow or cause emissions into the atmosphere of any air pollutant which is in
excess of 30% opacity for a period or periods aggregating more than six minutes in any
sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.5.)
12. These sources are subject to the odor requirements of Regulation No. 2. (State only
enforceable)
OPERATING & MAINTENANCE REQUIREMENTS
13. Upon startup of these points, the applicant shall follow the operating and maintenance
(O&M) plan and record keeping format approved by the Division, in order to demonstrate
compliance on an ongoing basis with the requirements of this permit. Revisions to your
O&M plan are subject to Division approval prior to implementation. (Reference: Regulation
No. 3, Part B, Section III.G.7.).
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
14. The operator shall complete an initial site specific extended gas analysis of the natural gas
produced at this site in order to verify the VOC, benzene,toluene, ethylbenzene, xylenes, n-
hexane,and 2,2,4-trimethylpentane content(weight fraction)of this emission stream used in
the permit application. Results of testing shall be used to determine site-specific emission
factors using Division approved methods. Results of site-specific sampling and analysis
shall be submitted to the Division as part of the self-certification and used to demonstrate
compliance with the emissions factors chosen for this emissions point.
15. The owner or operator shall demonstrate compliance with Condition 10 using EPA Method 9
to measure opacity from the flare. (Reference: Regulation No. 1, Section II.A.5).
AIRS ID: 123/9BCA/004 Page 3 of 8
Col De ent f Public Health and Environment
Air Pollution Control Division
Periodic Testing Requirements
16. On an annual basis,the operator shall complete a site specific extended gas analysis of the
natural gas produced at this site that is routed to the flare in order to verify the VOC content
(weight fraction) of this emission stream used in the permit application. Results of testing
shall be used to determine site-specific emission factors using Division approved methods.
ADDITIONAL REQUIREMENTS
17. A revised Air Pollutant Emission Notice(APEN)shall be filed: (Reference: Regulation No. 3,
Part A, II.C)
a. Annually whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of
five (5) tons per year or more, above the level reported on the last APEN; or
For any non-criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above
the level reported on the last APEN submitted to the Division.
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
c. Whenever new control equipment is installed,or whenever a different type of control
equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
18. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit)
shall apply to this source at any such time that this source becomes major solely by virtue of
a relaxation in any permit condition. Any relaxation that increases the potential to emit
above the applicable Federal program threshold will require a full review of the source as
though construction had not yet commenced on the source. The source shall not exceed
the Federal program threshold until a permit is granted. (Regulation No. 3 Part D).
GENERAL TERMS AND CONDITIONS
19. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
20. If this permit specifically states that final authorization has been granted,then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide"final"authority for this activity or operation of this source. Final authorization of
the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
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
AIRS ID: 123/9BCA/004 Page 4 of 8
Colo a4 De ent )f Public Health and Environment
31> 17 Air Pollution Control Division
to operate are located in the Requirements to Self-Certify for Final Authorization
section of this permit.
21. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the applicant and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the applicant or applicant's agents. It is valid only for the
equipment and operations or activity specifically identified on the permit.
22. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
23. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence,this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self-certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the applicant, or the Division revokes a permit,the applicant
or owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
David Thompson
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Carrizo Oil & Gas, Inc.
AIRS ID: 123/9BCA/004 Page 5 of 8
of De en f Public Health and Environment
Air Pollution Control Division
Notes to Permit Holder:
1) The permit holder is required to pay fees for the processing time for this permit.An invoice for these fees
will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of
the invoice. Failure to pay the invoice will result in revocation of this permit(Reference: Regulation No.3,
Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are based on
the consumption rates requested in the permit application. These limits may be revised upon request of
the permittee providing there is no exceedance of any specific emission control regulation or any ambient
air quality standard. A revised air pollution emission notice (APEN) and application form must be
submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The permittee shall notify the Division of any
malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon
as possible, but no later than noon of the next working day, followed by written notice to the Division
addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See:
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
Point Pollutant CAS# BIN (Ib/yr) reportable? Rate (Ib/yr)
Benzene 71432 A 919 Yes 46
Toluene 108883 C 595 No 30
004 Ethylbenzene 100414 C 76 No 4
Xylenes 1130207 C 168 No 8
n-Hexane 110543 C 6773 Yes 339
5) The emission levels contained in this permit are based on the following emission factors:
Weight Emission Emission
CAS# Pollutant Fraction of Factors Factors Source
Gas (%) Uncontrolled Controlled
NOx 0.068 0.068 AP-42
lb/MMBtu lb/MMBtu
CO 0.37 0.37 AP-42
lb/MMBtu lb/MMBtu
VOC 23.59 19,099.22 954.96 Engineering
lb/MMscf lb/MMscf Calculation
71432 Benzene 0.0164 33.80 1.69 Engineering
lb/MMscf lb/MMscf Calculation
108883 Toluene 0.0098 21.88 1.09 Engineering
lb/MMscf lb/MMscf Calculation
AIRS ID: 123/9BCA/004 Page 6 of 8
f; 1-
,.v Colofa Del°4tment?f Public Health and Environment
Air Pollution Control Division
Syr •
Weight Emission Emission
CAS# Pollutant Fraction of Factors Factors Source
Gas(%) Uncontrolled Controlled
100414 Ethylbenzene 0.0010 2.80 0.14 Engineering
lb/MMscf lb/MMscf Calculation
6.16 0.31 Engineering
1330207 Xylenes 0.0024
lb/MMscf lb/MMscf Calculation
110543 n-hexane 0.1095 248.99 12.45 Engineering
lb/MMscf lb/MMscf Calculation
Note: The uncontrolled VOC and HAP emissions for this point were calculated using the October
29, 2012 analysis of a gas sample collected from the Shull 1-25-9-60 well. The controlled
VOC and HAP emissions factors for point 004 are based on the flare control efficiency of
95%.
Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors
listed in the table above with representative component counts, multiplied by the VOC content from the
most recent gas and liquids analyses.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this
permit is valid for a term of five years from the date it was received by the Division. A revised APEN
shall be submitted no later than 30 days before the five-year term expires. Please refer to the most
recent annual fee invoice to determine the APEN expiration date for each emissions point associated
with this permit. For any questions regarding a specific expiration date call the Division at(303)-692-
3150.
7) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of
VOCs, HAPs
NANSR Synthetic Minor Source of
VOCs, HAPs
MACT HH Area Source Requirements: Not Applicable
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at
the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A—Subpart KKKK
NSPS Part 60, Appendixes Appendix A—Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT 63.1-63.599 Subpart A—Subpart Z
MACT 63.600-63.1199 Subpart AA—Subpart DDD
MACT 63.1200-63.1439 Subpart EEE—Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY
AIRS ID: 123/9BCA/004 Page 7 of 8
4„
oil! Del ent f Public Health and Environment
° Air Pollution Control Division
MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM
MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX
9) An Oil and Gas Industry Construction Permit Self-Certification Form is included with this permit packet.
Please use this form to complete the self-certification requirements as specified in the permit conditions.
Further guidance on self-certification can be found on our website at:
www.colorado.qov/cdphe/oilqaspermits
Only include if there are self-certification requirements in this permit.
AIRS ID: 123/9BCA/004 Page 8 of 8
Construction Permit Application
Preliminary Analysis Summary
Section 1 —Applicant Information
Company Name: Carrizo Oil & Gas, Inc
Permit Number: 13WE2632
Source Location: SESE SEC25 T9N R60W
Equipment Description: Point 004: Plant flare with a minimum combustion efficiency of 95%.
AIRS ID: 123/9BCA/004
Date: 12/18/13
Review Engineer: David Thompson
Control Engineer Chris Laplante
Section 2—Action Completed
Grandfathered Modification APEN Required/Permit Exempt
x CP1 Transfer of Ownership APEN Exempt/Permit Exempt
*If tank is a true minor source at a true minor facility, it shall be granted "Final Approval"
Section 3—Applicant Completeness Review
Was the correct APEN submitted for this source type? X Yes No
Is the APEN signed with an original signature? X Yes No
Was the APEN filled out completely? X Yes No
Did the applicant submit all required paperwork? X Yes No
Did the applicant provide ample information to determine emission rates? X Yes No
If you answered "no"to any of the above, when did you mail an
Information Request letter to the source?
On what date was this application complete? August 12, 2013
Section 4—Source Description
AIRS Point Equipment Description
Flare/ Separator controlled by a 40'flare stack. Flare has a minimum combustion
Separator efficiency of 95%. The flare is not enclosed.
Is this a portable source? Yes X No
Is this location in a non-attainment area for any criteria x Yes No
pollutant?
If"yes", for what pollutant? PM10 CO x Ozone
Is this location in an attainment maintenance area for Yes x No
any criteria pollutant?
If"yes", for what pollutant?
(Note: These pollutants are subject to minor source PM10 CO Ozone
RACT per Regulation 3, Part B, Section III.D.2)
Is this source located in the 8-hour ozone non-
attainment region? (Note: If"yes" the provisions of x Yes No
Regulation 7, Sections XII and XVII,C may apply)
Page 1
Section 5—Emission Estimate Information
AIRS Point Emission Factor Source
004 Site-specific using VOC weight fraction (Refer to Section 14 for calculations)
Did the applicant provide actual process data for the emission inventory? X Yes No
Basis for Potential to Emit(PTE)
AIRS Point Process Consumption/Throughput/Production
004 17,261 scf/day => 6,300,000 scf/yr= 6.3 mmscf/yr
Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory)
AIRS Point Process Consumption/Throughput/Production Data Year
004 17,261 scf/day => 6,300,000 scf/yr=6.3 mmscf/yr
Basis for Permitted Emissions (Permit Limits)
AIRS Point Process Consumption/Throughput/Production
004 17,261 scf/day a 6,300,000 scf/yr=6.3 mmscf/yr
Does this facility use control devices? X Yes No
AIRS Point Process Control Device Description % Reduction Granted
95%
(only 95/a is allowed)
004 at Open Flare 95
Section 6—Emission Summary (tons per year)
Point NO, VOC CO Single HAP Total HAP
PTE: 004 0.3 70.9 1.62 1.3 (n-hexane) 1.8
Uncontrolled point 004 0.3 70.9 1.62 1.3 (n-hexane) 1.8
source emission rate:
Controlled point 004 0.3 3.5 1.62 0.07 (n-hexane) 0.09
source emission rate:
TOTAL PERMITTED 004 0.3 3.5 1.62 0.07 (n-hexane) 0.09
(TPY)
Note: if the site includes GP01, the VOC controlled limit is 39 TPY and for GP05 the controlled limit is 10
TPY.
Section 7—Non-Criteria/Hazardous Air Pollutants
Uncontrolled Are the Controlled Emission
Pollutant CAS# BIN Emission Rate emissions Ib/ r
(Ib/yr) reportable? Rate( y )
Flare/separator-Point 004
Benzene 71432 A 499 Yes 25
Toluene 108883 C 358 No 18
Ethylbenzene 100414 C 53 No 3
Xylenes 1130207 C 92 No 5
n-Hexane 110543 C 2636 Yes 132
Note: Regulation 3, Part A, Section II.B.3.b APEN emission reporting requirements for non-criteria air
pollutants are based on potential emissions without credit for reductions achieved by control
devices used by the operator.
Section 8—Testing Requirements
Will testing be required to show compliance with any emission rate or regulatory Yes x No
standard?
Page 2
If"yes", complete the information listed below
AIRS Point Process Pollutant Regulatory Basis Test Method
Section 9—Source Classification
What is this facility classification? True X Synthetic Major
Minor Minor
Classification relates to what programs? X Title V PSD x NA NSR MACT
Is this a modification to an existing permit? Yes X No
If"yes" what kind of modification? Minor Synthetic Major
Minor
Section 10—Public Comment
Does this permit require public comment per CAQCC Regulation 3? Yes x No
If"yes", for which pollutants?Why? VOC
For Reg. 3, Part B, III.C.1.a (emissions increase> 25/50 tpy)? Yes x No
For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)? Yes x No
For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? Yes x No
Section 11 —Modeling
Is modeling required to demonstrate compliance with National Ambient Yes X No
• Air Quality Standards (NAAQS)?
If"yes", for which pollutants?Why? NOx emissions are less than 40 TPY.
AIRS Point Section 12— Regulatory Review
Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide
Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or
operator of a source shall allow or cause the emission into the atmosphere of any air
pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive
opacity readings taken at 15-second intervals for six minutes. The approved reference test
method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix
004 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
at contaminants from any single source such as to result in detectable odors which are
004 measured in excess of the following limits: For areas used predominantly for residential or
commercial purposes it is a violation if odors are detected after the odorous air has been
diluted with seven (7)or more volumes of odor free air.
Page 3
Regulation 3-APENs, Construction Permits, Operating Permits, PSD
Part A-APEN Requirements
Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for:
each individual emission point in a non attainment area with uncontrolled actual emissions
004 of two tons per year or more of any individual criteria pollutant (pollutants are not summed)
for which the area is non attainment.
(Applicant is required to file an APEN since emissions exceed/are less than 2 tons
per year VOC)
Part B—Construction Permit Exemptions
004 Applicant is required to obtain a permit since uncontrolled VOC emissions from this
facility are greater than the 5.0 TPY threshold(Reg. 3, Part B, Section II.D.3.a)
Regulation 6-New Source Performance Standards
004 None
Regulation 7—Volatile Organic Compounds
Regulation 8—Hazardous Air Pollutants
004 None
Section 13—Aerometric Information Retrieval System Coding Information
Point Process Process Description Emission Pollutant/ Fugitive Emission Factor Control
Factor CAS# (Y/N) Source (%)
22509.2779 VOC No Engineering 95
lb/MMscf Calculation
94.452 AP-42,
lb/MMscf NOx No Table 13.5-1 NA
513.93 AP-42,
•
lb/MMscf CO No Table 13.5-1 NA
79.1506 Benzene No Engineering 95
Ib/MMscf Calculation
01 Flare
003 56.8947 T Engineering
oluene No 95
lb/MMscf Calculation
8.4040 Ethlybenzen Engineering
lb/MMscf a No Calculation 95
14.5669 Xylenes No Engineering 95
lb/MMscf Calculation
418.3937 Engineering
lb/MMscf n-hexane No Calculation 95
SCC 31000205-Flares
Page 4
Section 14—Miscellaneous Application Notes
AIRS Point 004 Flare
Operator provided an extended gas analysis and emissions were calculated using EPA Emission
Inventory Improvement Program Publication, Volume II, Chapter 10-Displacement equation (10.4-3)
where:
Ex = Q * MW*Xx/C
Ex = emissions of pollutant x
Q =Volumetric flow rate/volume of gas processed
MW= Molecular weight of gas = SG of gas * MW of air
Xx= mass fraction of x in gas
C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm
Emissions generated from the flare are:
Uncontrolled Total (Ib/yr) Controlled Total (lb/yr)
NOx 595 595
VOC 141,808 7,090
CO 3,238 3,238
Benzene 499 25
Toluene 358 18
Ethylbenzene 53 3
Xylenes 92 5
n-hexane 2636 132
224-TMP 2 0
An extended gas analysis/gas analysis was provided in the application dated 10/29/13. The gas analysis
was perfomed less than a year of submittal. An updated extended gas analysis will not be required
because:
Pick one:
-an extended gas analysis was performed within a year of this submittal and included with this package
Page 5
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