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Home My WebLink About20142919.tiff rco�E COLORADO CO . Department of Public Health fr Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150O St PO Box 758 Greeley, CO 80632 September 17, 2014 Dear Sir or Madam: On September 20, 2014, the Air Pollution Control Division will publish a public notice for Carrizo Oil Et Gas, Inc. - Gaffney 2-29-8-61, 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 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 • 2014-2919 Ht 7V'-iaLciU RAJ 4 9 q '1 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-592.2000 www.colorado.gov/cdphe ( 7 4$7," rol. 9— L'f- I� John W. Hickenlooper,Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer N o? C E Public Notice Of A Proposed Project CO Or Activity Warranting Public Comment Website Title: Carrizo Oil & Gas, Inc. - Gaffney 2-29-8-61 - Weld County Released To: The Greeley Tribune On: September 17, 2014 Published: September 20, 2014 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 & Gas, Inc. Facility: Gaffney 2-29-8-61 Oil and gas exploration and production facility SWNW Section 29, T8N, R61W Weld County The proposed project or activity is as follows: Oil and gas exploration and production facility including seven (7) crude oil tanks and a wellhead flare. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • 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 Permits 14WE1145 and 14WE1148 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: Stephanie Chaousy 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 AWV COLORADO N .ti. . STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT w ¢ ' AIR POLLUTION CONTROL DIVISION TELEPHONE:(303)692-3150 *1876* CONSTRUCTION PERMIT PERMIT NO: 14WE1145 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 Gaffney 2-29-8-61, located in the SWNW of Section 29, Township 8 North, Range 61 West, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID TANKS 002 Seven (7)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 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 https://www.colorado.gov/pacific/cdphe/other-air-permitting-notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180)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: 123/9CEE Page 1 of 10 Condensate Tank SM/M Version 2012-1 olo De pa e f li Heal h and Environment it Pollution Control Division months or m e ion • 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 retain the permit final authorization letter issued by the Division, after completion of self-certification,with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility MRS Tons per Year Emission Type Equipment ID Point NO, VOC CO Tanks 002 — 6.5 — Point See`Notes to Permit Holder"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. 6. 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 MRS Pollutants Equipment Point Control Device Controlled ID Tanks 002 Combustor VOC and HAPS PROCESS LIMITATIONS AND RECORDS 7. 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 MRS Equipment Point Process Parameter Annual Limit ID Tanks 002 Crude oil throughput 60,018 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 AIRS ID: 123/9CEE Page 2 of 10 olor Depa e f bli and it PollutionHealth ControlEnvironment Division keep a compli. • - - •rd 't to ice wi responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 8. 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) 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 XVll.B.1.c 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. Beginning May 1, 2015, the flare covered by this permit is subject to Regulation No. 7,. Section XVII.B General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed, have no visible emissions during normal operations, and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. The operator shall comply with all applicable requirements of Section XVII. 12. Beginning May 1, 2015, the flare 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.1.b If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed, have no visible emissions during normal operations, and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. The operator shall comply with all applicable requirements of Section XVII. XVII.B.2.d.(ii)All combustion devices installed before May 1, 2014, must be equipped with an operational auto-igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 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)(b) Control requirements of Section XVII.C.1.b. must be achieved by May 1, 2015. AIRS ID: 123/9CEE Page 3 of 10 00Depa e f Ii Health and Environment it Pollution Control Division XVII.C.1.d. B M or icab pliance date in Section XVII.C.1.b.(i), whichever comes later, owners or operators of storage tanks constructed before May 1, 2014 subject to Section XVII.C.1. must conduct audio, visual,olfactory("QVO")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. XVII.C.2.Capture and monitoring requirements for storage 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 AIRS ID: 123/9CEE Page 4 of 10 olor Depa e f bli Health and Environment it Pollution Control Division to dev: .. n for nks 'ning 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)(b) A storage tank constructed before May 1, 2014, must comply with the requirements of Sections XVII.C.2.a. and XVII.C.2.b. by May 1, 2015. Approved instrument monitoring method inspections must begin within ninety (90) days of the Phase-In Schedule in Table 1, or within thirty(30) days for storage tanks with uncontrolled actual VOC emissions greater than 50 tons per year. 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 > 6 and < 12 Annually 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, AIRS ID: 123/9CEE Page 5 of 10 Dlo Depa e f Ii Health and Environment 'r Pollution Control Division for a o rat st 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.) COMPLIANCE TESTING AND SAMPLING Periodic 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.AII) ADDITIONAL REQUIREMENTS 16. A revised Air Pollutant Emission Notice(APEN)shall be filed: (Reference: Regulation No.3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant For sources emitting less than 100 tons per year, a change in actual emissions of five (5)tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO,) in ozone nonattainment areas emitting less than 100 tons of VOC or NO,per year,a change AIRS ID: 123/9CEE Page 6 of 10 olor Depa e f bli Health and Environment it Pollution Control Division in ann - le ' n (1 ear or 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)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 Parts C and 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 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 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 11.6 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 AIRS ID: 123/9CEE Page 7 of 10 lo Depa e f Ii Health and Environment 'r Pollution Control Division representatio y t r er or tor'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, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. • By: Stephanie Chaousy, PE Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Company Name, Inc. Newly permitted crude oil tanks at a synthetic minor facility. AIRS ID: 123/9CEE Page 8 of 10 A aColor� Depa e f bli Health and Environment it Pollution Control Division Notes to Permit Holder - e of •er .an . 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 maybe revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice(APEN)and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions.The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https.//www.colorado.qov/pacific/cdphe/acicc-reqs 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s)operate at the permitted limitations. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Point Pollutant CAS# BIN (Ib/yr) reportable? Rate(lb/yr) Benzene 71432 A 4018 Yes 201 ' Toluene 108883 C 3670 Yes 184 Ethylbenzene 100414 C 252 Yes 13 002 Xylene 1330207 C 1272 Yes 64 Hexane 110543 C 25108 Yes 1255 2,2,4-TMP, 540841 C 1736 Yes 87 5) The emission levels contained in this permit are based on the following emission factors: Point 002: Emission Factors Emission Factors CAS# Pollutant Uncontrolled Controlled Source lb/BBL Crude Oil lb/BBL Crude Oil Throughput Throughput VOC 4.308 0.2154 E&P Tanks 71432 Benzene 0.0669 0.0033 E&P Tanks 108883 Toluene 0.0611 0.0031 E&P Tanks 100414 Ethylbenzene 0.0042 0.0002 E&P Tanks 1330207 Xylene 0.0212 0.0011 E&P Tanks 110543 n-Hexane 0.4183 0.0209 E&P Tanks 540841 2,2,4-TMP 0.0289 0.0014 E&P Tanks AIRS ID: 123/9CEE Page 9 of 10 olo Depa e f li Health and Environment it Pollution Control Division Note: The co ased combustor control efficiency of 95%. 6) In accordance with C.R.S.25-7-114.1,each Air Pollutant Emission Notice(APEN)associated with this permit is valid for a term of five years from the date it was received by the Division.A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at(303)-692- 3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, n-hexane, total HAPS NANSR Synthetic Minor Source of: VOC 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 M—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 XXXXX( 9) A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at htto://www.coloradoxiovkiacifickdohe/air-oermit-Self-Certification AIRS ID: 123/9CEE Page 10 of TO Construction Permit Application • Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Carrizo Oil &Gas, Inc. Permit Number 14WE1145 Gaffney 2-29-8-61 Source Location: SWNW Section 29,T8N, R61W,Weld County(non-attainment) Equipment Description: Crude oil tanks AIRS ID: 123-9CEE-002 Date: September 8,2014 Review Engineer. Stephanie Chaousy, PE Control Engineer: Chris Laplante Section 2—Action Completed Grancffathered Modification APEN Required/Permit Exempt X CP1 Transfer of Ownership APEN Exempt/Permit Exempt Section 3—Applicant Completeness Review Was the correct APEN submitted for this source type? X Yes No Is the APEN signed with an original signature? X Yes No Was the APEN filled out completely? X Yes No Did the applicant submit all required paperwork? X Yes No Did the applicant provide ample information to determine emission rates? X Yes No If you answered "no"to any of the above, when did you mail an Information Request letter to the source? On what date was this application complete? May 22, 2014 Section 4—Source Description AIRS Point Equipment Description 002 Seven (7) above ground 400 bbl atmospheric crude oil storage tanks. Emissions from these tanks are controlled by a combustor. 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? 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 Source provided site-specific emission factors using gas sample and E&P Tanks. See Section 14 for calculations. Did the applicant provide actual process data for the emission inventory? Yes X No Basis for Potential to Emit(PIP AIRS Point Process Consumption/Throughput/Production 002 60,018 BBL per year(1m 30 days x 0.4 x 1.2) Pasls for Permitted Emissions(Permit Limits) AIRS Point Process ConsumpdonlThroughput/Production 002 600018 BBL per year Does this source use a control device? X Yes No AIRS Point Process Control Device Description %Reduction Granted 002 01 Combustor 95 Section 6—Emission Summar•(tons per year) Point NO, VOC CO Single HAP Total HAP PTE: 002 — 129.3 — 12.6(Hexane) 18.0 Uncontrolled point 002 — 129.3 — 12.6(Hexane) 18.0 source emission rate: Controlled point 002 — 6.5 — 0.6(Hexane) 0.9 source emission rate: Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled a.m. Pollutant CAS# BIN Emission Rate same, Rate Emission Controlled Em Em (Iblyr) r) Benzene 71432 A 4018 Yes 201 Toluene 108883 C 3670 Yes 184 Ethylbenzene 100414 C 252 Yes 13 Xylenes. 1330207 C 1272 Yes 64 n-Hexane 110543 C 25108 Yes 1255 2,2,4-TMP 540841 C 1736 Yes 87 Note: Regulation 3, Part A, Section ll.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? 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 Page 2 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)? X Yes No For Reg. 3, Part B, III.C.1.c.ii (subject to MACT)? Yes X No For Reg. 3, Part B, III.C.1.d(synthetic minor emission limits)? X Yes No Section 11 —Modeling Is modeling required to demonstrate compliance with National Ambient Yes X No Air Quality Standards(NAAQS)? If"yes", for which pollutants?Why? AIRS Point Section 12— Regulatory Review Regulation 1 - Particulate. Smoke. Carbon Monoxide and Sulfur Dioxide —S ection 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 002 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. 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 one ton 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 1 ton 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 2.0 TPY threshold(Reg.3, Part B, Section 11.D.2.a) Regulation 6- New Source Performance Standards NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84. Is this source greater than 19,800 gallons(471 bbl)? No 002 Is this source subject to NSPS Kb? No WHY? All tanks are less than 471 bbl (all are 400 bbl). Therefore, the source does not meet the criteria of this subpart. Regulation 7—Volatile Organic Compound_s 002 None Regulation 8—Hazardous Air Pollutants MACT EEEE: Organic Liquids Distribution 002 This source is not subject to MACT EEEE because it is not located at a major source of HAP. 002 MACT HH This source is not subject to MACT HH because it is not located at a major source of HAP. Page 3 Section 13—Aerometric Information Retrieval System Coding Information Process Emission Pollutant/ Fugitive Control Point Process Description Factor CAS# (Y/N) Emission Factor Source (%) 102.5724 V0C No E&P Tanks 95 lb/1000 gal 1.5940 Benzene/ No E&P Tanks 95 lb/1000 gal 71432 1.4559 Toluene/ No E&P Tanks 95 Ib/1000 qal 108883 01 E&P Crude oil 0.1 lb/1000 Ethylbenz/ No E&P Tanks 95 002 Storage Tanks gal 100414 0.5046 Xylenes/ No E&P Tanks 95 lb/1000 gal 1330207 • 9.9621 n-Hexane No E&P Tanks 95 lb/1000 gal / 110543 0.6887 2,2,4-TMP No E&P Tanks 95 lb/1000 gal /540841 SCC 40400312—Fixed Roof Tank,Crude oil,working+breathing+flashing losses Section 14—Miscellaneous Application Notes AIRS Point 002 Crude oil Storage Tanks A permit will be issued because the uncontrolled VOC emissions are greater than 2 TPY(permit threshold). Operator provided site-specific emission factors using a gas analysis sampled on 4/16/2014 and E&P Tanks. Uncontrolled emission factors are: VOC= (129.28"2000)/60018=4.3080 lb/bbl *1000/42= 102.5724 Ib/1000 gal Benzene= (2.009'2000)/60018= 0.0669 Ib/bbl '1000/42= 1.5940 Ib/1000 gal Toluene= (1.835'2000)/60018=0.0611 Ib/bbl *1000/42= 1.4559 lb/1000 gal Ethylbenzene= (0.126*2000)/60018=0.0042 lb/bbl '1000/42= 0.10 Ib/1000 gal Xylenes= (0.636'2000)/60018=0.0212 lb/bbl*1000/42=0.5046 Ib/1000 gal n-hexane=(12.554'2000)/60018=0.4183 lb/bbl*1000/42=9.9621 Ib/1000 gal 2,2,4-IMP= (0.868'2000)/60018=0.0289 lb/bbl *1000/42=0.6887 lb/1000 gal Page 4 RAFTSTATE OF COLORADO ov.coo COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT e AIR POLLUTION CONTROL DIVISION 1:144.1*' TELEPHONE:(303)692-3150 . + 1876` CONSTRUCTION PERMIT PERMIT NO: 14WE1148 Issuance 1 DATE ISSUED: ISSUED TO: Carrizo Oil & Gas, Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural gas production facility, known as Gaffney 2-29-8-61, located in the SWNW of Section 29, Township 8 North, Range 61 West, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Description Equipment ID Point SEPARATOR 005 Separator controlled by a flare stack. Flare has a minimum combustion efficiency of 95%. The flare is not enclosed. 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 APCD no later than fifteen days after issuance of this permit or activity by submitting a Notice of Startup(NOS)form to the APCD. The Notice of Startup (NOS)form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the APCD of startup of the permitted source is a violation of 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 on this permit shall be demonstrated to the Division. It is the permittee'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, II.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 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.) AIRS ID: 123/9CEE Page 1 of 7 Condensate Tank Version 2009-1 C do e rtm t of Public Hp and Environment Air Pollution Control Division 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 SEPARATOR 005 4.2 48.9 23.0 Point See "Notes to Permit Holder#4"for information on emission factors and methods used to calculate limits. Compliance with the synthetic minor status of this facility shall be determined by recording the facility's annual criteria pollutant emissions, from each emission unit, on a rolling (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 monthly emissions 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 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 Control Device Pollutants Equipment ID Point Controlled SEPARATOR 005 Open flare VOC PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum consumption, processing and/or operational rates as listed below. Monthly records of the actual natural gas 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 005 Natural gas flaring 90.7 MMSCF/yr Compliance with the yearly natural gas 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 • AIRS ID: 123/9CEE Page 2 of 7 C ado e artm t of Public Health and Environment Air Pollution Control Division based on the previous twelve months' data. The permit holder shall calculate monthly natural gas throughput 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 number shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 10. 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.). 11. These sources are subject to the odor requirements of Regulation No. 2. (State only enforceable) OPERATING & MAINTENANCE REQUIREMENTS 12. 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 orderto 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 13. 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). Periodic Testing Requirements 14. The owner or operator shall sample the gas routed to the flare to determine the heat content on an annual basis ADDITIONAL REQUIREMENTS 15. 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 volatile organic compounds (VOC) and nitrogen oxides sources (NO.) in ozone nonattainment areas emitting less than 100 tons of VOC or NO.per year,a change in annual actual emissions of one(1)ton per year or more or five percent,whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or AIRS ID: 123/9CEE EE Page 3 of 7 23 9C g do a ofPult EnvnmDC Air blic PollutionHeahand Control iroDivisention 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 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. 19. 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. 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 AIRS ID: 123/9CEE Page 4 of 7 C ado e artm t of Public PollutionHealthand Control DEnvironmentivision 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. 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: Stephanie Chaousy, PE Permit Engineer Air Pollution Control Division Permit History Issuance Date Description Issuance 1 This Issuance Facility-wide permit for: (1) process flare. New synthetic minor source facility. AIRS ID: 123/9CEE Page 5 of 7 do e rtmof PulteDC Air blic PollutionHeahand ControlEnvironm Divisionnt 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 perk as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: htto://www.cdohe.state.co.us/reaulations/airreas/100102aacccom monorovisionsrea.adf. 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s)operate at the permitted limitations. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Point Pollutant CAS# BIN (lb/yr) reportable? Rate(ib/yr) Benzene 71432 A 6059 Yes 303 Toluene 108883 C 3993 Yes 200 005 Ethylbenzene 100414 C 356 Yes 18 Xylenes 1130207 C 788 Yes 39 n-Hexane 110543 C 38873 Yes 1944 5) The emission levels contained in this permit are based on the following emission factors: Point 005: Weight Emission Emission Factors CM# Pollutant Fraction of Factors Controlled Source Gas(%) Uncontrolled NOx 0.068 AP-42 _ Ib/MMBtu 0.068 lb/MMBtu CO - 0.37 lb/MMBtu 0.37 lb/MMBtu AP-42 VOC 33 78 21592.25 1079.61 Engineering Ib/MMSCF lb/mmscf Calculation 71432 Benzene 0.1045 66'77 3.34Ib/mmscf Engineering Ib/MMSCF Calculation 108883 Toluene 0.0688 44.00 2.2 lb/mmscf Engineering Ib/MMSCF Calculation 100414 Ethylbenzene 0.0061 3'92 0.196 lb/mmscf Engineering Ib/MMSCF Calculation AIRS ID: 123/9CEE Page 6 of 7 C ado e artm t of Pub1) lic PollutionHealthand ControlEnvironment Division Weight Emission Emission Factors CAS# Pollutant Fraction of Factors Controlled Source Gas(%) Uncontrolled 1330207 Xylenes 0.0136 8'68 0.434 lb/mmscf Engineering Ib/MMSCF Calculation 110543 n-hexane 0.0067 428'4 21.42 lb/mmscf Engineering Ib/MMSCF Calculation Note: The uncontrolled VOC and HAP emissions for this point were calculated using the April 16, 2014 analysis of a gas sample collected from the Gaffney 2-29-8-61 well.The controlled VOC and HAP emissions factors for point 005 are based on the flare control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division.A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit.For any questions regarding a specific expiration date call the Division at(303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic minor Source: VOC, n-hexane,total HAPS NANSR Synthetic Minor Source: VOC 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://ecfrapoaccess.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: 123/9CEE Page 7 of 7 Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment Air Pollution Control Division Division Information Engineer: Stephanie Chaousy,PE Attainment Status Control Engineer: Chris Laplante] PM10 Attainment Review Date: 09/08/2014 PM2.5 Attainment Application Date: 05/22/2014 SOx Attainment NOx Nonattainmen VOC Nonattainmen Facility Information CO Attainment Permit No. 14WE1148 County# 123 Weld AIRs Facility# 9CEE Point# 005 Facility Equipment ID Separator Company Name: Carrizo Oil&Gas,Inc. Source Name: Gaffney 2-29-8-61 SWNW Section 29,T8N,R61W Source Location: SIC: 1311 Elevation(feet)5000 New Permit Modification APEN X (CPI) (Issuance#) Required/Permit Exempt Transfer of APEN Ownership Exempt/Permit Fxemot Notes Equipment Description This source vents natural gas from: a well head separator Emissions from this source are: routed to an open-flame flare Natural gas venting from a well head separator.Emissions from this source are routed to an open- flame flare. 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/Ib-mol)at 60F and 1 atm Throughput(0) 91 MMscf/yr I 10353.9 scf/hr I 7.70 MMscf/mo MW 24.230 lbilb-mol 0.002 MMscf(d mole% MW Ibx/Ibmol mass fraction E lb/hr Ib/yr tpy Helium 0.01 4.0026 0.000 0.000 Helium 0.0 96 0.05 CO2 255 44.01 1.122 0.046 CO2 30.7 268571 134.29 N2 1.01 28.013 0.283 0.012 N2 7.7 67709 33.85 methane 69.4858 16.041 11.146 0.460 methane 304.5 2667446 1333.72 ethane 11.6247 30.063 3.495 0.144 ethane 95.5 836339 418.17 propane 8.7707 44.092 3.8672 0.160 propane 105.6 925470 462.73 isobutane 9426 58.118 5478.2027 226.092 isobutane 149658.7 1311010509 655505.25 n-butane 3.1455 58.118 1.8287 0.0/5 n-butane 50.0 43/643 218.82 isopentane 0.6302 72.114 0.4545 0.019 isopentane 12.4 108759 54.38 n-pentane 0.6292 /2.114 U.5980 0.025 n-pentane 16.3 143102 11.55 cyclopentane 0.0722 70.13 0.0506 0.002 cyclopentane 1.4 12117 6.06 n-Hexane 0.1884 86.18 0.1624 0.007 n-Hexane 4.4 38856 19.43 cyclohexane 0.0519 84.16 0.0437 0.002 cyclohexane 1.2 10453 5.23 Otherhexanes 0.3418 86.18 0.2946 0.012 Otherhexanes 8.0 70493 35.25 heptanes 0.1641 100.21 0.1644 0.007 heptanes 4.5 39354 19.68 methylcyclohexane 0.03883 98.19 0.0381 0.002 methylcyclohexane 1.0 9124 4.56 224-TMP 0.0002 114.23 0.0002 0.000 224-TMP 0.0 55 0.03 Benzene 0.0324 78.12 0.0253 0.001 Benzene 0.7 6057 3.03 Toluene 0.0181 92.15 0.0167 0.001 Toluene 0.5 3992 2.00 Ethylbenzene 0.0014 106.17 0.0015 0.000 Ethylbenzene 0.0 356 0.18 Xylenes 0.0031 106.17 0.0033 0.000 Xylenes 0.1 788 0.39 Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment Air Pollution Control Division IC8+Heavies I 0.0881) -8043419.0521 5477.5694 I -226.068 IC8+Heavies I -149841.4 (aIMMOI -655429.36 VOC mass hrlb is 0.3377 Total VOC Emission(Uncanbolled) 979.2 24.230 annual gnat assuming 95%control 49.0 Nolte monthly limit assuming 95%control(lbhno.) 8316.6 Mole%,MW,and mass fractions from Gaffney 2-2&&81 4/16/4014 gas analysis. Emissions are based on 8760 hours of operation per yew. I calculated the average MW of C8+based on the average MW on the analysis for the gas. Flaring Information E9gl nes D ffi'Ag4.4II Flare to combust produced gas until pi line is available at this wellhead facility. Manufacturer TBD Model TBD Serial Number TBD Gas Heating Value 1388 BtWad Throughput 124077.6 MMBtuNr Combustion emission factor source: AP-42:Chapter 13.5 0.068 lb NOX/MMStu 0.37 lb CO/MMBtu 4.22 tpy NOX 22.95 toy CO Emissions Summary 4.22 tpy NOX Uncontrolled/I* 22.95 spy CO 979.209 toy VOC Controlled 48.960 tpy VOC • Uncontrolled Operator Seenerio A Controlled Operator Total(Ib&r) uncontrolled Bin Reportable? Total(Ib/yr) controlled Benzene 6057 8859 A Yes 303 303 Toluene 3992 3993 C Yes 200 200 Ethylbenzene 358 358 C No 18 18 Xylenes 788 788 C No 39 39 n-hexane 38856 38873 C Yes 1943 1944 224-IMP 55 C No 3 Regulatory Applicability AOCC Regulation 1 This source is subject to the opacity requirements for flares in Section II.A5:'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.' AOCC 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." AOCC Regulation 3 An APEN is required for this source because uncontrolled VOC emissions Part A exceed one ton per year in a nonattainment area for ozone. A permit is required for this source because uncontrolled VOC emissions from this facility exceed two tons per year in a nonattainment area for ozone. Part B: This source is subject to Section III.D.2(Minor Source RACT)because it is located in a nonattainment area.RACT for this source has been determined to be the use of a flare to control emissions. Is public comment Public Comment Required required? ItiPerator ana revision unconir0eso emissions are eiigfny ainerent. I anew mis is sue to rooming in mein mooelin(1/spreaasneets to what was on the APEN.Their emissions are a little higher than the Divisions,so I will accept their calculations. 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