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Home My WebLink About20142767 4 COPHE COLORADO LI Co Department of Public Health b 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 2.2014 Dear Sir or Madam: On September 5.2014,the Air Pollution Control Division will publish a public notice for Carrizo Oil and Gas, Inc.—Speaker 27-11 Multi-Pad, 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 RECEIVED Denver,Colorado 80246-1530 Attention: Clara Gonzales SEP 0 8 2014 Regards, ,n WELD COUNTY 1 7i COMMISSIONERS Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure I (7.4'! r C D 1 V 6 0I \,.. .,:-,.',,,I,-_/-,-..; ;,, f:' , 76 8 % e7I.buld eut.er. cC e= 1�L;"Pu►, HI_ 9 -(0 - P-1 9/S 2014-2767 CDPHE Public Notice Of A Proposed Project tia Or Activity Warranting Public CO Comment Website Title: Carrizo Oil and Gas, Inc.—Speaker 27-11 Multi-Pad— Weld County Released To: The Greeley Tribune On: September 2. 2014 Published: September 5, 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, lnc. Facility: Speaker 27-11 Multi-Pad Oil and gas exploration and production facility NWNW, Section 27,T8N. R61W Weld County The proposed project or activity is as follows: Operator requests to permit nine 400 barrel crude oil tanks with a through-put of 116,316 barrels of crude oil per year. Operator requests to permit three separators with a 25' flare stack. Through-put will be limited to 95.9 MMscf of 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 III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3. Part B, Section III.C.I.a(25 tpy in a non-attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis.and a draft of Construction Permit 14 4W E0842 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/pacitic/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 address: Kirk Bear Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-Bl Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us eV0 COLORADO s 1 I DO STATE OF COLORADO `°` COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303)692-3150 :\ . •1876 CONSTRUCTION PERMIT PERMIT NO: 14WE0842 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 Speaker 27-11 Multi-Pad, located in the NWNW, Section 27, Township 8N, Range 61W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Point Description Equipment ID TANKS 004 Nine 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/ao/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 deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) AIRS ID: 123-9CBE-004 Page 1 of 10 Colorado Department of Public Health 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 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 Emission Type Equipment ID Point NO, VOC CO TANKS 004 5.7 Point See'Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. 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.) Facility AIRS Point Control Device Pollutants Equipment ID Controlled TANKS 004 Enclosed Flare VOC AIRS ID: 123-9CBE-004 Page 2 of 10 Colorado Department of Public Health and Environment Air Pollution Control Division 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 004 Oil Throughput 116316 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 XVII.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. 15. 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 AIRS ID: 123-9CBE-004 Page 3 of 10 Colorado Department of Public Health and Environment Air Pollution Control Division 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 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 AIRS ID: 123-9CBE-004 Page 4 of 10 Colorado Department of Public Health and Environment Air Pollution Control Division 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.(H)(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 AIRS ID: 123-9CBE-004 Page 5 of 10 Colorado Department of Public Health and Environment Air Pollution Control Division XVII.C.2.b.(iii) Owners or operators are not required to monitor storage tanks and associated equipment that are unsafe, difficult, or inaccessible to monitor, as defined in Section XVII.C.1.e. XVII.C.2.b.(iv) STEM must include a certification by the owner or operator that the selected STEM strategy(ies) are designed to minimize emissions from storage tanks and associated equipment at the facility(ies), including thief hatches and pressure relief devices. XVII.C.3. Recordkeeping XVII.C.3. The owner or operator of each storage tank subject to Sections XII.D. or XVII.C. must maintain records of STEM, if applicable, including the plan, any updates, and the certification, and make them available to the Division upon request. In addition, for a period of two (2) years, the owner or operator must maintain records of any required monitoring and make them available to the Division upon request, including: XVII.C.3.a. The AIRS ID for the storage tank. XVII.C.3.b. The date and duration of any period where the thief hatch, pressure relief device, or other access point are found to be venting hydrocarbon emissions, except for venting that is reasonably required for maintenance, gauging, or safety of personnel and equipment. XVII.C.3.c. The date and duration of any period where the air pollution control equipment is not operating. XVII.C.3.d. Where a combustion device is being used, the date and result of any EPA Method 22 test or investigation pursuant to Section XVII.C.1.d.(v). XVII.C.3.e. The timing of and efforts made to eliminate venting, restore operation of air pollution control equipment, and mitigate visible emissions. XVII.C.3.f. A list of equipment associated with the storage tank that is designated as unsafe, difficult, or inaccessible to monitor, as described in Section XVII.C.1.e., an explanation stating why the equipment is so designated, and the plan for monitoring such equipment. OPERATING & MAINTENANCE REQUIREMENTS 16. 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 17. The owner or operator shall demonstrate compliance with opacity standards, using EPA Method 22 to determine the presence or absence of visible emissions. Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one(1) minute in any fifteen (15) minute period during normal operation. (Reference: Regulation No. 7, Section XVII.A.II) AIRS ID: 123-9CBE-004 Page 6 of 10 Colorado Department of Public Health and Environment Air Pollution Control Division 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 volatile organic compounds (VOC) and nitrogen oxides sources (NO ) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 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 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 AIRS ID: 123-9CBE-004 Page 7 of 10 Colorado Department of Public Health and Environment Air Pollution Control Division 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 Issuance Date Description Issuance 1 This Issuance Issued to Carrizo Oil and Gas, Inc. AIRS ID: 123-9CBE-004 Page 8 of 10 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. AIRS Uncontrolled Controlled Point Pollutant CAS# Emissions Reportable? Emissions (Ib/yr) (lb/yr) 004 Benzene 71432 11054 Yes 553 004 n-Hexane 110543 62552 Yes 3128 004 Toluene 108883 10333 Yes 517 004 Ethylbenzene 100414 822 Yes 41 004 Xylenes 1330207 3036 Yes 152 004 2,2,4 Trimethylpentane 540841 4399 Yes 220 5) The emission levels contained in this permit are based on the following emission factors: Emission Factors Pollutant Uncontrolled Source (lb/bbl Crude Oil) VOC 1.9700 E&P TANK n-Hexane 0.5380 E&P TANK Benzene 0.0950 E&P TANK Toluene 0.0888 E&P TANK Ethylbenzene 0.0071 E&P TANK Xylenes 0.0261 E&P TANK 2,2,4 TMP 0.0378 E&P TANK Note: The controlled emissions for this point are based on the flare control efficiency of 95%. AIRS ID: 123-9CBE-004 Page 9 of 10 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/Major Source of: VOC NANSR Synthetic Minor/Major 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: htto://ecfr.aooaccess.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 SubparIQQQ—Subpart YYYY MALT 63.6580-63.8830 Subpart 7777-Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXX( 9) A self certification form apd guidance on how to self-certify compliance as required by this permit may be obtained online at: htto://www.colorado.00v/cacifiGcdohe/air-permit-self-certification AIRS ID: 123-9CBE-004 Page 10 of 10 Division Information Engineer: Kirk Bear Control Engineer: Christopher Laplant Review Date: 08/18/2014 Application Date: 04/03/2014 Facility Identifiers Permit No. 14WE0842 AIRS County# 123 Weld Facility# 9CBE Facility Type: exploration and production facility '❑Located in the 8-hour non-attainment area? O True Minor 0 Synthetic Minor for: T VOC r NOx r Co Administrative Information Company Name: Carrizo Oil and Gas, Inc. Source Name: Speaker 27-11 Multi-Pad Source Location: NWNW, Section 27, Township 8N, Range 61W SIC: 211111 Address 1: Carrizo Oil and Gas, Inc. Mailing Address 2: 500 Dallas,Suite 2300 Address /,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 Speaker 27-11 Multi-Pad, located in the NWNW, Section 27,Township 8N, Range 61W,Weld County,Colorado. Point Name Type Control Action Newly 004 TANKS Oil Tanks Flare reported source 004 Nine 400 barrel crude oil storage tanks Calculations Requsted Throughput 116316 bbl Control Flare Efficiency 95.00%I Emissions Summary Table Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 1.9700 lb/bbl 114.6 tpy 5.7 tpy E&P TANK Benzene 0.0950 lb/bbl 11050 lb/yr 553 lb/yr E&P TANK n-Hexane 0.5380 lb/bbl 62578 lb/yr 3129 lb/yr E&P TANK Toluene 0.0888 lb/bbl 10329 lb/yr 516 lb/yr E&P TANK Ethylbenze 0.0071 lb/bbl 822 lb/yr 41 lb/yr E&P TANK Xylenes 0.0261 lb/bbl 3036 lb/yr 152 lb/yr E&P TANK 224Trimett 0.0378 lb/bbl 4397 lb/yr 220 lb/yr E&P TANK Regulatory Review Section IIA.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 IIA.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 T .. Section IA-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 n -N P a NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84. This source is not subject because each tank is less than 19,800 gallons(471 bbl) NSPS OOOO:for storage vessels in the natural gas production,transmission,and processing segments. This source is not subject because each tank emits less than 6 tpy VOC. 'ce 7-V n 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 crude oil.) XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS... AIRS(County/Plant)123/9CBE Permit No. 14WE0842 Date 8/18/2014 Controlled Controlled Actual Requested NCRP= Uncontrolled Emission Emissions Emissions Ctd. reportable Point# 5CC Pollutant or CAS Factor Emisson Factor Source (ipy)' (ipyl' PTE(toy)* Eft% ? 004 VOC 46905 lb/1000 qa ESP TANK 5.7 114.6 95% Yes 004 Benzene 2.262 lb/1000 qa ESP TANK 552.5 11050 95% Yes 004 n-Hexane 128110/1000 qa ESP TANK 3128.9 62578 95% Yes 004 Toliene 2.115 lb/1000 qa ESP TANK 516.4 10328.9 95% Yes 004 Ethylbenzene 0.169l0/1000 qa E&P TANK 41.1 8224 95% Yes 004 Xylenes 0.622 lb/1000 qa E&P TANK 1518 30358 95% Yes STATE OF COLORADO aQ COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303)692-3150 :rc • *1876 CONSTRUCTION PERMIT PERMIT NO: 14WE0845 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 Speaker 27-11 Multi-Pad, located in the NWNW, Section 27, Township 8N, Range 61W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Description Equipment ID Point Three separators controlled by a 25'flare stack. Flare has a SEPARATOR 007 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.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. 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. AIRS ID: 123-9CBE-007 Page 1 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division 4. 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.) 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 SEPARATOR 007 4.7 62.5 25.6 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: 123-9CBE-007 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 007 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 007 Gas Vented from Separators 95.9 MMscf Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 11. Upon installation of the flow meter required under Condition 3, 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 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.) AIRS ID: 123-9CBE-007 Page 3 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division 15. The open flare covered by this permit has been approved as an alternative emissions control device under Regulation No. 7, Section XVII.B.2.e. The open flare shall have no visible emissions during normal operations and be designed so that an observer can, by means of visual observation from the outside of the open flare, or by other convenient means approved by the Division, determine whether it is operating properly. The operator shall comply with all applicable requirements of Section XVII. The owner/operator must equip the open flare with an operational auto-igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. (Regulation No. 7, Section XVII.B.) 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.5). 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 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: 123-9CBE-007 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 II.B 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: 123-9CBE-007 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: 123-9CBE-007 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&childpaciename=CDPHE- Main°/02FDocument C%2FCBONAddLinkView&cid=1251599389641&paciename=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. Uncontrol led Controlled AIRS Pollutant CAS# Emissions Reportable? Point (Ib/yr) Emissions(Ib/yr) 007 Benzene 71432 9502 Yes 475 007 n-Hexane 110543 51572 Yes 2579 007 Toluene 108883 5896 Yes 295 007 Ethylbenzene 100414 564 Yes 28 007 Xylenes 1330207 1475 Yes 74 5) The emission levels contained in this permit are based on the following emission factors: Point 007: Emission Pollutant Factors Source Uncontrolled lb/MMscf NOx(lb/MMBtu) 0.068 AP-42 CO(lb/MMBtu) 0.37 AP-42 VOC 18.031 Gas Analysis Benzene 99.13 Gas Analysis Toluene 61.51 Gas Analysis Ethylbenzene 5.88 Gas Analysis Xylenes 15.39 Gas Analysis n-hexane 538.00 Gas Analysis 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 AIRS ID: 123-9CBE-007 Page 7 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division 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/Major Source of: VOC NANSR Synthetic Minor/Major 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.gooaccess.aov/ 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: 123-9CBE-007 Page 8 of 8 Division Information Engineer: Kirk Bear Control Engineer: Christopher Laplant Review Date: 08/19/2014 Application Date: 04/03/2014 Facility Identifiers Permit No. 14WE0845 AIRS County# 123 Weld Facility# 9CBE Facility Type: exploration and production facility 0 Located in the 8-hour non-attainment area? 0 True Minor Synthetic Minor for: I✓ VOC r NOx r CO Administrative Information Company Name: Carrizo Oil and Gas, Inc. Source Name: Speaker 27-11 Multi-Pad Source Location: NWNW, Section 27, Township 8N, Range 61W 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 Speaker 27-11 Multi-Pad, located in the NWNW, Section 27,Township 8N, Range 61W,Weld County, Colorado. Point Name Type Control Action Newly 007 SEPARATOR Separator Venting Flare reported source Three separators controled by a 25'flare stack.Flare has a minimum combustion efficiency of 95%. The 007 flare is not endosed. . Equipment Description This source vents natural gas from: three separators Emissions from from this source are: routed to a flare Natural gas venting from three separators.Emissions from this source are routed to a flare.. Calculations • Fmission Calculation Mikhail 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 raterwlume of gas processed MW=Molecular weight of gas=SG of gas'MW of air Xx=mass fraction d x in gas C=molar volume of ideal gas(379 sdAb- o at 8OF and 1 atm Throughput(O) 95.9 MMsd/yr 10947.48858 sdM MW 25.66 blbmol 0.282739726 MMad/d mole% MW EXIbmd mess fraction bM brr my Helium 0.01 4.0028 0.000 0.000 0.01 101.28 0.05 C02 2.72 44.01 1.197 0.047 34.58 302900.28 151.45 N2 _ 0.79 28.013 0.221 0.009 8.39 55997.17 28.00 methane 84.90 18.041 10.411 0.406 300.71 2634241.17 1317.12 ' ethane 13.15 30.063 3.954 0.154 114.22 1000805.64 500.30 propane 10.42 44.092 4.595 . 0.179 132.71 1162581.98 581.29 Isobutane 1.14 58.118 0.861 0.026 19.09 167220.19 83.81 nbutane 3.81 58.118 2.215 0.088 63.98 580483.97 280.24 hsopentene 0.77 72.114 0.558 0.022 18.13 141270.72 70.84 n-pease 1.03 72.114 0.740 0.029 21.39 187345.19 93.87 cydepentale 0.10 70.13 0.070 0.003 2.03 17763.04 8.88 n-Hamne 0.24 88.18 0.204 0.008 5.89 51594.17 25.80 cydohesa a 0.06 84.16 0.054 0.002 1.56 13871.83 6.84 Other resales 0.41 86.18 0.354 0.014 1022 89559.28 44.78 heptanes 0.20 100.21 0.205 0.008 _5.92 51828.82 25.91 methylcyddhexane 0.05 98.19 0.048 0.002 1.38 12099.73 6.05 224-IMP 0.00 114.23 0.000 0.000 0.00 28.90 0.01 Benzene 0.04 78.12 0.032 0.001 0.93 8183.55 4.09 Toluene 0.03 92.15 0.023 0.001 0.67 5899.23 2.95 Ethylbenzene 0.00 108.17 0.002 0.000 0.06 584.18 0.28 Xylem 0.00 108.17 0.005 0.000 0.15 1316.37 0.86 C8+Heavies 0.09 137.4837288 0.130 0.005 3.77 33013.91 16.51 VOC mess had 0.386 Total VOC(Uncontrolled) 1252.21 e Mole%,MW,and mass fractions from Critter Creek 2-03H gas analysis. Emissions are based on 8780 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 Tornado Model 25'Flare Stack Serial Number 12345678 Gas Heating Value 1445.3 Btu/scf Throughput 138604.27 MMBlu/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 llb NOX/MMBtu 0.37 lib CO/MMBtu Emissions Summary Table Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 26114.96 lb/MMscf 1305.75 lb/MMscf 1252.21 tpy 62.61 tpy Gas Analysis Nox 0.07 Ib/MMBTU 0.07 lb/MMBTU 4.71 tpy 4.71 tpy AP-42 CO 0.37 Ib/MMBTU 0.37 Ib/MMBTU 25.64 tpy 25.64 tpy AP-42 Benzene 85.33 lb/MMscf 4.27 lb/MMscf 8183.55 lb/yr 409.18 lb/yr Gas Analysis n-Hexane 538.00 lb/MMscf 26.90 lb/MMscf 51594.17 lb/yr 2579.71 lb/yr Gas Analysis Toluene 61.51 lb/MMscf 3.08 lb/MMscf 5899.23 lb/yr 294.96 lb/yr Gas Analysis Xylenes 13.73 lb/MMscf 0.69 lb/MMscf 1316.37 lb/yr 65.82 lb/yr Gas Analysis Ethylbenzene 5.86 lb/MMscf 0.29 lb/MMscf 564.16 lb/yr 28.21 lb/yr Gas Analysis Regulatory Applicability AQCC Regulation 1 This source is subject to the opacity requirements for flares in Section II.A.5:'No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30%opacity.' 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)123I9C8E Permit No.14WE0845 Date 8/19/2014 Controlled Controlled Actual Requested NCRP= Uncontrolled Emission Emissions Emissions C61. reportable Point# SCC Pollutant or CAS Factor Emisison Factor Sauce SPY)' My)' PTE(tpY)' E8% ? 007 31000205 VOC 28114.962 INMMscf Gas Analysis 62.6 1252.2 95% Yes 007 31000205 NOx 0.088 INMMBTI AP-42 4.7 4.7 0% Yes 007 i,31000205 CO 0.37 IWMMBTL AP-42 25.6 25.6 0% Yes 007 31000205 Benzene 85.334 BYMMscf Gas Analysis 409.2 8183.6 95% Yes 007 31000205 n-Hexane 538 lb/MMscf Gas Analysis 2579.7 51594.2 95% Yes 007 31000205 Toluene 81.5141bMMsrf Gas Analysis 295 5899.2 95% Yes 007 31000205 E9rylbemene 5.883 th/MMed Gas Analysis 28.2 564.2 95% Yes 007 31000205 Xylenes 13.726 lb/MMsd Gas Analysis 65.8 1316.4 95% Yes v W O or p u a O C-4- a. u O. pc o .1:j a O. T eY� 6 m 3-- .--.� ,.. F V V W ❑ y L• 'N U I.I M M ') N -2 4.3 a a o e WW0. . °' (NI rnrn .N , 3, e C7 Q r a w .o .o.p a o g o R G GI u p E M M M ` q J O v — w U y — c o0o P. 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