HomeMy WebLinkAbout20142941.tiff 441/4 CDPHE COLORADO
CO Department of Public
Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County-Clerk to the Board
1150 O St
RECEIVED
7 PO Box 758
Greeley.•
CO 80632 SEP 2 4 201'±
• September 22.2014• WELD COUNTY
COMMISSIONERS
Dear Sir or Madam:
• On September 25.2014,the Air Pollution Control Division will publish a public notice for Carrizo Oil and Gas,
Inc.—Nelson Ranches 1-27-10-59, 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
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver,Colorado 80246-1530
Attention: Clara Gonzales
Regards.
/F ��i
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
4300 Cherry Creek Drive S.,Denver,CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe I r <r;,„• ., . ,,,:.,. . ,,o,
John W. Hickenlooper,Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer :. t;:
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CDPHE Public Notice Of A Proposed Project
CO '�-%' Or Activity Warranting Public Comment
Website Title: Carrizo Oil and Gas. Inc.—Nelson Ranches 1-27-10-59—Weld County
Released To: The Greeley Tribune
On: September 22,2014
Published: September 25.2014
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 and Gas. Inc.
Facility: Nelson Ranches 1-27-10-59
Oil and gas exploration and production facility
13.2 miles east of Grover,Colorado 80729(SESE. Section 28,T10N, R59W)
Weld County
The proposed project or activity is as follows:
Operator requests a permit to operate three 400 bbl crude oil tanks with a maximum through-put of 56.861 barrels of
crude oil per year.
Operator requests a permit to operate a separator and a 25' flare stack with a maximum through-put of 53.2 MMscf
separator vapors per year.
The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part
B, Section 111.C due to the following reason(s):
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application.the Division's analysis.and a draft of Construction Permit 14WE0174 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:
Kirk Bear
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South,APCD-SS-B I
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
COLOR&DO
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STATE OF COLORADO
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COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT ew
AIR POLLUTION CONTROL DIVISION iSts
TELEPHONE: (303)692-3150
w1876E
CONSTRUCTION PERMIT
PERMIT NO: 14WE0174
Issuance 1
DATE ISSUED:
ISSUED TO: Carrizo Oil and Gas, Inc.
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas exploration and production facility known as the Nelson Ranches 1-27-10-
59, located in the SESE, Section 28, Township 10N, Range 59W, Weld County,
Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS Description
Equipment ID Point
TANKS 002 Three 400 barrel crude oil storage tanks
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 estimated completion date. The Division may grant extensions of the
AIRS ID: 123-9C3E-002 Page 1 of 11
Colorado Department of Public Health and Environment
Air Pollution Control Division
deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B,
III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self-certification process.
(Reference: Regulation No. 3, Part B, Section III.E.)
5. The following information shall be provided to the Division within fifteen (15) days after
issuance of permit.
• manufacturer
• model number
• serial number
This information shall be included with the Notice of Startup submitted for the equipment.
(Reference: Regulation No. 3, Part B, III.E.)
6. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self-certification, with the most current construction permit. This
construction permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Annual Limits:
Facility AIRS Tons per Year
Equipment ID Point NO VOC CO Emission Type
NO,,
TANKS 002 5.3 Point
See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits.
Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0
tpy.
Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)
from each emission unit, on a rolling twelve (12) month total. By the end of each month
a new twelve-month total shall be calculated based on the previous twelve months' data.
The permit holder shall calculate emissions each month and keep a compliance record
on site or at a local field office with site responsibility, for Division review. This rolling
twelve-month total shall apply to all permitted emission units, requiring an APEN, at this
facility.
8. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
AIRS ID: 123-9C3E-002 Page 2 of 11
Colorado Department of Public Health and Environment
Air Pollution Control Division
Facility Equipment ID AIRS Point Control Device Pollutants Controlled
TANKS 002 Enclosed Flare VOC
PROCESS LIMITATIONS AND RECORDS
9. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates shall be maintained by the owner or
operator and made available to the Division for inspection upon request. (Reference:
Regulation 3, Part B, II.A.4)
Process/Consumption Limits
Facility AIRS Point Process Parameter Annual Limit
Equipment ID
TANKS 002 Oil Throughput 56861 bbl
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on
the previous twelve months' data. The permit holder shall calculate throughput each
month and keep a compliance record on site or at a local field office with site
responsibility, for Division review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on
the subject equipment for ease of identification. (Reference: Regulation Number 3, Part
B, III.E.) (State only enforceable)
11. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation
of the source. During periods of startup, process modification, or adjustment of control
equipment visible emissions shall not exceed 30% opacity for more than six minutes in
any sixty consecutive minutes. Emission control devices subject to Regulation 7,
Sections XII.C.1.d or XVI1.B.1.c shall have no visible emissions. (Reference: Regulation
No. 1, Section II.A.1. &4.)
12. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
13. 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.)
14. 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.
AIRS ID: 123-9C3E-002 Page 3 of 11
Colorado Department of Public Health and Environment
Air Pollution Control Division
15. 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.
16. 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.
XVII.C.1.d. Beginning May 1, 2014, or the applicable compliance date in Section
XVII.C.1.b.(i), whichever comes later, owners or operators of storage tanks
constructed before May 1, 2014 subject to Section XVII.C.1. must conduct audio,
visual, olfactory ("AVO") and additional visual inspections of the storage tank and
any associated equipment (e.g. separator, air pollution control equipment, or
other pressure reducing equipment) at the same frequency as liquids are loaded
out from the storage tank. These inspections are not required more frequently
than every seven (7) days but must be conducted at least every thirty one (31)
days. Monitoring is not required for storage tanks or associated equipment that
are unsafe, difficult, or inaccessible to monitor, as defined in Section XVII.C.1.e.
The additional visual inspections must include, at a minimum:
XVII.C.1.d.(i) Visual inspection of any thief hatch, pressure relief valve, or other
access point to ensure that they are closed and properly sealed;
XVII.C.1.d.(ii) Visual inspection or monitoring of the air pollution control
equipment to ensure that it is operating, including that the pilot light is lit
on combustion devices used as air pollution control equipment;
XVII.C.1.d.(iii) If a combustion device is used, visual inspection of the auto-igniter
and valves for piping of gas to the pilot light to ensure they are functioning
properly;
XVII.C.1.d.(iv) Visual inspection of the air pollution control equipment to ensure
that the valves for the piping from the storage tank to the air pollution
control equipment are open; and
AIRS ID: 123-9C3E-002 Page 4 of 11
Colorado Department of Public Health and Environment
Air Pollution Control Division
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 to develop and implement STEM for storage tanks
containing only stabilized liquids. The minimum elements of STEM are listed
below.
XVII.C.2.b.(i) STEM must include selected control technologies, monitoring
practices, operational practices, and/or other strategies; procedures for
evaluating ongoing storage tank emission capture performance; and
monitoring in accordance with approved instrument monitoring methods
following the applicable schedule in Section XVII.C.2.b.(ii) and Inspection
Frequency in Table 1.
XVII.C.2.b.(ii) Owners or operators must achieve the requirements of Sections
XVII.C.2.a. and XVII.C.2.b. and begin implementing the required
approved instrument monitoring method in accordance with the following
schedule:
XVII.C.2.b.(ii)(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
AIRS ID: 123-9C3E-002 Page 5 of 11
Colorado Department of Public Health and Environment
Air Pollution Control Division
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, for a period of two (2) years, the owner or operator must
maintain records of any required monitoring and make them available to the
Division upon request, including:
XVII.C.3.a. The AIRS ID for the storage tank.
XVII.C.3.b. The date and duration of any period where the thief hatch, pressure relief
device, or other access point are found to be venting hydrocarbon emissions,
except for venting that is reasonably required for maintenance, gauging, or safety
of personnel and equipment.
XVII.C.3.c. The date and duration of any period where the air pollution control equipment
is not operating.
XVII.C.3.d. Where a combustion device is being used, the date and result of any EPA
Method 22 test or investigation pursuant to Section XVII.C.1.d.(v).
XVII.C.3.e. The timing of and efforts made to eliminate venting, restore operation of air
pollution control equipment, and mitigate visible emissions.
XVII.C.3.f. A list of equipment associated with the storage tank that is designated as
unsafe, difficult, or inaccessible to monitor, as described in Section XVII.C.1.e., an
explanation stating why the equipment is so designated, and the plan for monitoring
such equipment.
AIRS ID: 123-9C3E-002 Page 6 of 11
Colorado Department of Public Health and Environment
Air Pollution Control Division
OPERATING & MAINTENANCE REQUIREMENTS
17. 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.)
ADDITIONAL REQUIREMENTS
18. 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 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.
19. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit)
shall apply to this source at any such time that this source becomes major solely by
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
20. This permit and any attachments must be retained and made available for inspection
upon request. The permit may be reissued to a new owner by the APCD as provided in
AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership
and the submittal of a revised APEN and the required fee.
21. If this permit specifically states that final authorization has been granted, then the
remainder of this condition is not applicable. Otherwise, the issuance of this construction
AIRS ID: 123-9C3E-002 Page 7 of 11
Colorado Department of Public Health and Environment
Air Pollution Control Division
permit does not provide "final" authority for this activity or operation of this source. Final
authorization of the permit must be secured from the APCD in writing in accordance with
the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section
III.G. Final authorization cannot be granted until the operation or activity commences
and has been verified by the APCD as conforming in all respects with the conditions of
the permit. Once self-certification of all points has been reviewed and approved by the
Division, it will provide written documentation of such final authorization. Details for
obtaining final authorization to operate are located in the Requirements to Self-
Certify for Final Authorization section of this permit.
22. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the owner or operator and is conditioned upon conduct of the activity, or
construction, installation and operation of the source, in accordance with this information
and with representations made by the owner or operator or owner or operator's agents.
It is valid only for the equipment and operations or activity specifically identified on the
permit.
23. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with
the provisions of Section 25-7-114.5(7)(a), C.R.S.
24. Each and every condition of this permit is a material part hereof and is not severable.
Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire
permit and upon such occurrence, this permit shall be deemed denied ab initio. This
permit may be revoked at any time prior to self-certification and final authorization by the
Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality
Control Act and regulations of the Air Quality Control Commission (AQCC), including
failure to meet any express term or condition of the permit. If the Division denies a
permit, conditions imposed upon a permit are contested by the owner or operator, or the
Division revokes a permit, the owner or operator of a source may request a hearing
before the AQCC for review of the Division's action.
25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution
Prevention and Control Act or the regulations of the AQCC may result in administrative,
civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121
(injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S.
By:
Kirk Bear
Permit Engineer
Permit History
AIRS ID: 123-9C3E-002 Page 8 of 11
Colorado Department of Public Health and Environment
Air Pollution Control Division
Issuance Date Description
Issuance 1 This Issuance Issued to Carrizo Oil and Gas, Inc.
AIRS ID: 123-9C3E-002 Page 9 of 11
Colorado Department of Public Health and Environment
Air Pollution Control Division
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these
fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of
receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference:
Regulation No. 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN)
and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written notice
to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: http://www.colorado.gov/cs/Satellite?c=Document C&childpagename=CDPHE-
Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis
of the specific compounds emitted if the source(s) operate at the permitted limitations.
Uncontrolled
Emission Are the Controlled
AIRS Rate emissions Emission Rate
Point Pollutant CAS# (Ib/yr) reportable? (lb/yr)
002 Benzene 71432 3736 Yes 187
II
002 n-Hexane 110543 21948 Yes 1097
002 Toluene 108883 3122 Yes 156
002 Ethylbenzene 100414 284 Yes 14
002 Xylenes 1330207 739 Yes 37
002 224 TMP 540841 1382 Yes 69
5) The emission levels contained in this permit are based on the following emission factors:
Emission Factors
Pollutant Uncontrolled Source •
lb/bbl Oil
Throughput
VOC 3.72 E&P TANK
n-Hexane 0.386 E&P TANK
Benzene 0.0657 E&P TANK
Toluene 0.0549 E&P TANK
Ethylbenzene 0.005 E&P TANK
Xylenes 0.013 E&P TANK
224 TMP 0.024
Note: The controlled emissions for this point are based on the flare control efficiency of 95%.
AIRS ID: 123-9C3E-002 Page 10 of 11
Colorado Department of Public Health and Environment
Air Pollution Control Division
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division.A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the
most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division at
(303)-692-3150.
7) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of: VOC
PSD Synthetic Minor Source of: VOC
MACT HH Major Source Requirements: Not Applicable
Area Source Requirements: Not Applicable
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.qpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A—Subpart KKKK
NSPS Part 60,Appendixes Appendix A—Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT 63.1-63.599 Subpart A—Subpart Z
MACT 63.600-63.1199 Subpart AA—Subpart DDD
MACT 63.1200-63.1439 Subpart EEE—Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM
MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX
9) A self certification form and guidance on how to self-certify compliance as required by this permit may
be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification.
AIRS ID: 123-9C3E-002 Page 11 of 11
Division Information
Engineer: Kirk Bear
Control Engineer: Christopher Laplant
Review Date: 09/05/2014
Application Date: 11/26/2013
Facility Identifiers
Permit No. 14WE0174
AIRS County# 123 Weld
Facility q 9C3E
Facility Type: exploration and production facility
❑Located in the 8-hour non-attainment area? O True Minor
® Synthetic Minor for: l VOC r NOx r CO
Administrative Information
Company Name: Carrizo Oil and Gas, Inc.
Source Name: Nelson Ranches 1-27-10-59
Source Location: SESE, Section 28, Township 10N, Range 59W
SIC: 211111
Mailing Address 1: Carrizo Oil and Gas, Inc.
Address Address 2: 500 Dallas,Suite 2300
City,State Zip: Houston,Texas 77002
Name: Patricia Moden
Person To Phone: 713 328 1036
Contact Fax: 713 328 1060
Email: Patricia.Moden@crzo.net
Requested Action
Self Certification Required? Yes
Issuance Number: 1
Source Description:
Oil and gas exploration and production facility known as the Nelson Ranches 1-27-10-59, located in the SESE, Section
28,Township 10N, Range 59W,Weld County, Colorado.
Point Name Type Control Action
Newly
002 TANKS Oil Tanks Flare reported
source
002 Three 400 barrel crude oil storage tanks
Calculations
Requsted Throughput 56861 bbl
Control Flare
Efficiency 95.00%j
Emissions Summary Table
Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source
VOC 3.72 lb/bbl 105.8 tpy 5.3 tpy E&P TANK
Benzene 0.066 lb/bbl 3736 lb/yr 187 lb/yr E&P TANK
n-Hexane 0.386 Ib/bbl 21948 lb/yr 1097 lb/yr E&P TANK
Toluene 0.055 lb/bbl 3122 lb/yr 156 lb/yr E&P TANK
Ethylbenze 0.005 lb/bbl 284 lb/yr 14 lb/yr E&P TANK
Xylenes 0.013 lb/bbl 739 lb/yr 37 lb/yr E&P TANK
224TMP 0.024 lb/bbl 1382 lb/yr 69 lb/yr E&P TANK
Regulatory Review
Section II.A.1 -Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall
allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20%opacity.This
standard is based on 24 consecutive opacity readings taken at 15-second intervals for six minutes. The
approved reference test method for visible emissions measurement is EPA Method 9(40 CFR, Part 60,
Appendix A(July, 1992))in all subsections of Section II.A and B of this regulation.
Section II.A.5-Smokeless Flare or Flares for the Combustion of Waste Gases No owner or operator of a
smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the
atmosphere of any air pollutant which is in excess of 30%opacity for a period or periods aggregating more than
six minutes in any sixty consecutive minutes.
R ulation 2—Odor
Section I.A-No person,wherever located, shall cause or allow the emission of odorous air contaminants from
any single source such as to result in detectable odors which are measured in excess of the following limits:
For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after
the odorous air has been diluted with seven(7)or more volumes of odor free air.
R ulation 6-New Source Performance Standards
NSPS Kb: for storage vessels greater than 19,800 gallons after 7123/84.
This source is not subject because each tank is less than 19,800 gallons(471 bbl)
NSPS OOOO:for storage vessels in the natural gas production,transmission,and processing
segments.
This source is not subject because each tank emits less than 6 tpy VOC.
Regulation 7—Volatile Or anic Com unds
XII.VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS
(Applicant is not subject to the emission control requirements for condensate tanks since it is located
in an attainment area.)
XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS...
(Applicant is currently subject to this since actual uncontrolled emissions are greater than 20 tpy of
VOC.)
AIRS(County/Plant)123/9C3E
Penult No. 14WE0174
Dale 9/5/2014
Controlled Controlled
Actual Requested NCRP=
Uncontrolled Emission Emissions Emissions CM. reportable
Point# 5CC Pollutant or CAS Factor Emisison Factor Source (ipy)' (ipyp PTE(toy)* Eff%
002 VOC 88.572 lb/1000 ga E&P TANK 53 1058 95% Yes
002 Berzene 1565 lb/1000 qa E&P TANK 1868 3735.8 95% Yes
002 n-Hexane 9.191 lb/1000 ga E&P TANK 10974 21948.3 95% Yes
002 Toluene 1.307 lb/1000 ga E82 TANK 156.1 3121.7 95% Yes
002 Ethylbenzene 0.119 lb/1000 ga E&P TANK 14.2 284.3 95% Yes
002 Xylenes 0.31 lb/1000 ga E&P TANK 37 739.2 95% Yes
002 224TMP 00243 69 1382
STATE OF COLORADO
ap cow.
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
t
TELEPHONE: (303) 692-3150 �v� s„
x`846
CONSTRUCTION PERMIT
PERMIT NO: 14WE0177
Issuance 1
DATE ISSUED:
ISSUED TO: Carrizo Oil and Gas, Inc.
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas exploration and production facility known as the Nelson Ranches 1-27-10-
59, located in the SESE, Section 28, Township 10N, Range 59W, 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 25' 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 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.cdohe.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 estimated completion date. The Division may grant extensions of the
AIRS ID: 123-9C3E-005 Page 1 of 8
Colorado Department of Public Health and Environment
Air Pollution Control Division
deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B,
III.F.4.)
4. Within one hundred and eighty days (180) after issuance of this permit, the operator
shall install a flow meter to monitor and record volumetric flow rate of natural gas vented
from each low pressure separator. The operator shall use the gas flow rate listed in the
application for actual flow rate until the flow meter is installed, not to exceed one
hundred and eighty (180) days after issuance of this permit.
5. 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.)
6. 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.)
7. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self-certification, with the most current construction permit. This
construction permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
8. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Annual Limits:
Facility AIRS Tons per Year
Equipment ID Point NO VOC CO Emission Type
x
SEPARATOR 005 2.5 29.6 13.5 Point
See"Notes to Permit Holder'for information on emission factors and methods used to calculate limits.
Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0
tpy.
Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)
from each emission unit, on a rolling twelve (12) month total. By the end of each month
a new twelve-month total shall be calculated based on the previous twelve months' data.
The permit holder shall calculate emissions each month and keep a compliance record
on site or at a local field office with site responsibility, for Division review. This rolling
twelve-month total shall apply to all permitted emission units, requiring an APEN, at this
facility.
AIRS ID: 123-9C3E-005 Page 2 of 8
Colorado Department of Public Health and Environment
Air Pollution Control Division
9. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
Facility Pollutants
AIRS Point Control Device
Equipment ID Controlled
SEPARATOR 005 Open Flare VOC
PROCESS LIMITATIONS AND RECORDS
10. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates shall be maintained by the owner or
operator and made available to the Division for inspection upon request. (Reference:
Regulation 3, Part B, II.A.4)
Process/Consumption Limits
Facility AIRS Process Parameter Annual Limit
Equipment ID Point
SEPARATOR 005 Gas Vented from Separator 53.2 MMscf
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on
the previous twelve months' data. The permit holder shall calculate throughput each
month and keep a compliance record on site or at a local field office with site
responsibility, for Division review.
11. Upon installation of the flow meter required under Condition 4, the owner or operator
shall continuously monitor and record the volumetric flow rate of natural gas vented from
each low pressure separator using a flow meter. The flow meter shall continuously
measure flow rate and record total volumetric flow vented from each separator. The
owner or operator shall use monthly throughput records to demonstrate compliance with
the limits specified in Condition 10 and to calculate emissions as described in this
permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
12. 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)
13. 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.)
14. No owner or operator of a smokeless flare or other flare for the combustion of waste
gases shall allow or cause emissions into the atmosphere of any air pollutant which is in
AIRS ID: 123-9C3E-005 Page 3 of 8
Colorado Department of Public Health and Environment
Air Pollution Control Division
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.)
15. The open flare covered by this permit has been approved as an alternative emissions
control device under Regulation No. 7, Section XVI1.B.2.e. The open flare shall have no
visible emissions during normal operations and be designed so that an observer can, by
means of visual observation from the outside of the open flare, or by other convenient
means approved by the Division, determine whether it is operating properly. The
operator shall comply with all applicable requirements of Section XVII. The
owner/operator must equip the open flare with an operational auto-igniter by or before
May 1, 2016, or after the next combustion device planned shutdown, whichever comes
first. (Regulation No. 7, Section XVII.B.)
16. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
OPERATING & MAINTENANCE REQUIREMENTS
17. Upon startup of these points, the owner or operator shall follow the most recent
operating and maintenance (O&M) plan and record keeping format approved by the
Division, in order to demonstrate compliance on an ongoing basis with the requirements
of this permit. Revisions to your O&M plan are subject to Division approval prior to
implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
18. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Method 9 to measure opacity from the flare. (Reference: Regulation No. 1, Section II.A.1
&4)
Periodic Testing Requirements
• 19. 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
20. 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 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: 123-9C3E-005 Page 4 of 8
Colorado Department of Public Health and Environment
Air Pollution Control Division
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.
21. 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
22. 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 11.8 upon a request for transfer of ownership
and the submittal of a revised APEN and the required fee.
23. 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.
24. 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.
25. 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.
26. 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
AIRS ID: 123-9C3E-005 Page 5 of 8
Colorado Department of Public Health and Environment
Air Pollution Control Division
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.
27. 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.
28. 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:
Kirk Bear
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Carrizo Oil and Gas, Inc.
AIRS ID: 123-9C3E-005 Page 6 of 8
Colorado Department of Public Health and Environment
Air Pollution Control Division
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these
fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of
receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference:
Regulation No. 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN)
and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written notice
to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: http://www.colorado.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 Are the Controlled
AIRS Emissions emissions Emissions
Point Pollutant CAS # (Ib/yr) reportable? (Ib/yr)
005 Benzene 71432 3343 Yes 167
005 n-Hexane 110543 22879 Yes 1144
005 Toluene 108883 1901 Yes 95
005 Xylenes 1330207 313 Yes 16
5) The emission levels contained in this permit are based on the following emission factors:
Emission Factors
Pollutant Uncontrolled Source
lb/MMscf
NOx(lb/MMBTU) 0.068 AP-42
CO (lb/MMBTU) 0.37 AP-42
VOC 22272.00 Gas Analysis
Benzene 62.86 Gas Analysis
Toluene 35.74 Gas Analysis
Ethylbenzene 2.80 Gas Analysis
Xylenes 5.88 Gas Analysis
n-hexane 430.21 Gas Analysis
AIRS ID: 123-9C3E-005 Page 7 of 8
Colorado Department of Public Health and Environment
Air Pollution Control Division
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN)associated with
this permit is valid for a term of five years from the date it was received by the Division.A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the
most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division at
(303)-692-3150.
7) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of: VOC
PSD Synthetic Minor Source of: VOC
MACT HH Major Source Requirements: Not Applicable
Area Source Requirements: Not Applicable
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.q poaccess.q ov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A—Subpart KKKK
NSPS Part 60,Appendixes Appendix A—Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT 63.1-63.599 SubpartA—SubpartZ
MACT 63.600-63.1199 Subpart AA—Subpart DDD
MACT 63.1200-63.1439 Subpart EEE—Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY
MACT 63.6580-63.8830 Subpart 7777-Subpart MMMMM
MACT 63.8980-End Subpart NNNNN—Subpart XXXXXJ(
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: 123-9C3E-005 Page 8 of 8
Division Information
Engineer: Kirk Bear
Control Engineer: Christopher Laplant
Review Date: 09/09/2014
Application Date: 11/26/2013
Facility Identifiers
Permit No. 14WE0177
AIRS County# 123 Weld
Facility# 9C3E
Facility Type: exploration and production facility
❑Located in the 8-hour non-attainment area? O True Minor
® Synthetic Minor for: I✓ V0C r N0x r CO
Administrative Information
Company Name: Carrizo Oil and Gas, Inc.
Source Name: Nelson Ranches 1-27-10-59
Source Location: SESE, Section 28, Township 10N, Range 59W
SIC: 211111
Address 1: Carrizo Oil and Gas, Inc.
Mailing Address 2: 500 Dallas, Suite 2300
Address
City,State Zip: Houston,Texas 77002
Name: Patricia Moden
Person To Phone: 713 328 1036
Contact Fax: 713 328 1060
Email: Patricia.Moden@crzo.net
'Requested Action
Self Certification Required? Yes
Issuance Number 1
Source Description:
Oil and gas exploration and production facility known as the Nelson Ranches 1-27-10-59, located in the SESE, Section
28,Township 10N, Range 59W,Weld County, Colorado.
Point Name Type Control Action
Newly
005 SEPARATOR Separator Venting Flare reported
source
Separator controlled by a 25'flare stack.Flare has a minimum combustion efficiency of 95%. The flare is
005 not enclosed.
Equipment Description
This source vents natural gas from: a well head separator
Emissions from this source are: routed to a flare
Natural gas venting from a well head separator.Emissions from this source are routed to a flare.
Calculations
Emission Calculation Method
EPA Emission Inventory Improvement Program Publication:Volume II,Chapter 10-Displacement Equation(10.4-3)
Ex=Q*MW*Xx/C
Ex=emissions of pollutant x
Q=Volumetric flow rate/volume of gas processed
MW=Molecular weight of gas=SG of gas`MW of air
Xx=mass fraction of x in gas
C=molar volume of ideal gas(379 scf/Ib-mol)at 60F and 1 atm
Throughput(0) 53.2 MMscf/yr 6073.059361 scf/hr
MW 24.31 Ib/Ib-mol 0.145753425 MMscf/d
mole% MW Ibx/Ibmol mass fraction lb/hr lb/yr tpY
Helium 0.02 4.0026 0.001 0.000 0.01 112.37 0.06
CO2 2.87 44.01 1.175 0.048 18.83 164943.44 82.47
N2 1.16 28.013 0.325 0.013 5.21 45613.15 22.81
methane 69.60 16.041 11.164 0.459 178.90 1567125.37 783.56
ethane 10.66 30.063 3.206 0.132 51.38 450050.79 225.03
propane 9.14 44.092 4.029 0.188 64.58 565572.30 282.79
isobunane 0.93 58.118 0.541 0.022 8.66 75901.92 37.95
n-butane 3.34 58.118 1.942 0.080 31.12 272607.34 136.30
isopentane 0.64 72.114 0.464 0.019 7.44 65159.17 32.58
n-pentane 0.88 72.114 0.835 0.026 10.17 89109.23 44.55
cyclopentane 0.08 70.13 0.055 0.002 0.88 7688.25 3.84
n-Hexane 0.19 86.18 0.183 0.007 2.61 22887.59 11.44
cyclohexane 0.04 84.16 0.038 0.002 0.60 5280.63 2.84
Other hexanes 0.33 86.18 0.284 0.012 4.54 39811.34 19.91
heptanes 0.15 100.21 0.147 0.006 2.38 20683.57 10.33
methylcyclohexane 0.03 98.19 0.029 0.001 0.46 4024.60 2.01
224-TMP 0.00 114.23 0.000 0.000 000 16.03 0.01
Benzene 0.03 78.12 0.024 0.001 0.38 3344.53 1.67
Toluene 0.01 92.15 0.014 0.001 0.22 1901.45 0.95
Ethylbenzene 0.00 106.17 0.001 0.000 0.02 149.03 0.07
Xylenes 0.00 106.17 0.002 0.000 0.04 312.96 0.16
C8+Heavies 0.05 137.4837288 0.074 0.003 1.19 10440.49 5.22
99.97 VOC mass fracl 0.347 Total VOC(Uncontrolled) 592.44
Notes
Mole%,MW,and mass fractions from Critter Creek 2-03H gas analysis.
Emissions are based on 8760 hours of operation per year.
I calculated the average MW of C8+based on the average MW on the analysis for the gas.
Flaring Information
Equipment Description
Flare to combust produced gas until pipeline is available at this wellhead facility.
Manufacturer
Model 25'Flare Stack
Serial Number
Gas Heating Value 1367.2 Btu/scf
Throughput 72735.04 MMBtu/yr
VRU Information
Equipment Description
Engine to recompress gas to sales line.
Make
Model
Requested Control 100.00%
Annual Bypass Tim 50.00%
Backup Flare
Overall Control 95.00%
Combustion emission factor source'. AP-42:Chapter 13.5
0.07 lb NOX/MMBtu 0.37 Ilb CO/MMBtu
Emissions Summary Table
Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source
V0C 22272.00 lb/MMscf 1113.60 lb/MMscf 592.44 tpy 29.62 tpy Gas Analysis
Nox 0.07 Ib/MMBTU 0.07 Ib/MMBTU 2.47 tpy 2.47 tpy AP-42
CO 0.37 Ib/MMBTU 0.37 lb/MMBTU 13.46 spy 13.46 tpy AP-42
Benzene 62.67 lb/MMscf 3.14 lb/MMscf 3344.53 lb/yr 167.23 lb/yr Gas Analysis
n-Hexane 430.22 lb/MMscf 21.51 lb/MMscf 22887.59 lb/yr 1144.38 lb/yr Gas Analysis
Toluene 35.74 lb/MMscf 1.79 lb/MMscf 1901.45 lb/yr 95.07 lb/yr Gas Analysis
Xylenes 5.88 lb/MMscf 0.29 lb/MMscf 312.96 lb/yr 15.65 lb/yr Gas Analysis
Ethylbenzene 2 B0 lb/MMscf 0.14 lb/MMscf 149.03 lb/yr 7.45 lb/yr Gas Analysis
Regulatory Applicability
AQCC Regulation 1
This source is subject to the opacity requirements for flares in Section II.A.5:'No owner or operator of a smokeless flare or other
flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in
excess of 30%opacity.'
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."
AIRS(County/Plant)123/9C3E
Permit No. 14WE0177
Date 9/9/2014
Controlled Controlled
Actual Requested NCRP=
Uncontrolled Emission Emissions Emissions CM. reportable
Point# SCC Pollutant or CAS Factor Emisison Factor Source (tpyp (tpyl' PTE(tpy)* Eff% ?
005 31000205 VOC 22272 lb/MMscf Gas Analysis 296 5924 95% Yes
005 31000205 NOx 0.068 lb/MMBTL AP-42 25 25 0% Yes
005 31000205 CO 037 lb/MMBIL AP-42 13.5 13.5 0% Yes
005 31000205 Benzene 62.867 Ib/MMsd Gas Analysis 167.2 3344.5 95% Yes
005 31000205 n-Hexane 430.218 lb/MMscf Gas Analysis 1144.4 22887.6 95% Yes
005 31000205 Toluene 35.742 lb/MMscf Gas Analysis 95.1 1901.5 95% Yes
005 31000205 Ethylbenzene 2.801 lb/MMscf Gas Analysis 7.5 149 95% No
005 31000205 Xylenes 5.883 lb/MMscf Gas Analysis 156 313 95% ,Yes
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