HomeMy WebLinkAbout20143789.tiff CDPHE COLORADO
CO 0 Department of Public
Health ir Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
1150 0 St
PO Box 758
Greeley, CO 80632
December 2, 2014
Dear Sir or Madam:
On December 3, 2014, the Air Pollution Control Division will begin a 30-day public notice period for
Carrizo Oil 8 Gas, Inc. - Nelson Ranches 1-33, 4-27-1-59. A copy of this public notice and the public
comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health 8 Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
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4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe gov/cdphe :(per e o.
John W. Hickenlooper, Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer
i2-10 -1'-1 C8- PLRwf fit /`r// 2014-3789
CDPHE E Air Pollution Control Division
CONotice of a Proposed Project or Activity Warranting Public
or
Comment
Website Title: Carrizo Oil €t Gas, Inc. - Nelson Ranches 1-33, 4-27-1-59 - Weld County
Notice Period Begins: December 3, 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 Ft Gas, Inc.
Facility: Nelson Ranches 1-33, 4-27-1-59
Oil and Gas Exploration and Production Facility
SWSE SEC 28 T
Weld County
The proposed project or activity is as follows: Applicant proposes to receive a permit for the construction
of an oil and gas exploration and production facility.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section
III.C.1.a (25 tpy in a non-attainment area and/or 50 tpy in an attainment area)
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 14WE0563 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:
Christopher Kester
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
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STATE OF COLORADO
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COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT r .p,,
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CONSTRUCTION PERMIT
PERMIT NO: 14WE0563
Issuance 1
DATE ISSUED:
ISSUED TO: Carrizo Oil & Gas, Inc.
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the Nelson Ranches 1-33,4-27-10-59, located in the SWSE of
Section 28, Township 10N, Range 59W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS
Equipment point Description
ID
Six (6) 400 BBL Crude Oil Storage Tanks. Emissions from these
TANKS 003 tanks are controlled by a 48" Cimarron Enclosed Flare (95%
destruction efficiency).
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR
QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S.(25-7-101 et seq),TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED
IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than
fifteen days after issuance of this permit, by submitting a Notice of Startup form
to the Division. The Notice of Startup form may be downloaded online at
https://www.colorado.00v/pacific/cdphe/other-air-permitting-notices. Failure to notify the
Division of startup of the permitted source is a violation of Air Quality Control
Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the
revocation of the permit.
2. Within one hundred and eighty days(180)after issuance of this permit,compliance with
the conditions contained in this permit shall be demonstrated to the Division. It is the
owner or operator's responsibility to self-certify compliance with the conditions. Failure
to demonstrate compliance within 180 days may result in revocation of the permit.
(Reference: Regulation No. 3, Part B, III.G.2).
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source
within 18 months after either,the date of issuance of this construction permit or the date
AIRS ID: 123/9C901003 Page 1 of 11
Condensate Tank SM/M Version 2012-1
Depa e f li Health and Environment
it Pollution Control Division
on whichDolor
ity uled mence as set forth in the
permit application associated with this permit;(ii)discontinues construction for a period
of eighteen months or more; (iii) does not complete construction within a reasonable
time of the estimated completion date. The Division may grant extensions of the
deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B,
III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in
this permit and submit the results to the Division as part of the self-certification process.
(Reference: Regulation No. 3, Part B, Section III.E.)
5. The following information about the enclosed flare 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
TANKS 003 --- 7.1 --- 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 compliancerecord 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: 12319C901003 Page 2 of 11
olor . Depa e f - •Ii Health and Environment
it Pollution Control Division
Facility AIRS Pollutants
Equipment Point Control Device Controlled
ID
TANKS 003 48" Cimarron Enclosed Flare (95%destruction VOC
efficiency)
PROCESS LIMITATIONS AND RECORDS
9. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates shall be maintained by the owner or
operator and made available to the Division for inspection upon request. (Reference:
Regulation 3, Part B, II.A.4)
Process/Consumption Limits
Facility AIRS
Equipment Point Process Parameter Annual Limit
ID
TANKS 003 Crude Oil Throughput 165,217 BBUyr
The owner or operator shall calculate monthly process rates based on the calendar month.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months'data. The permit holder shall calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility,for Division
review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
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 permit fulfills the requirement to hold a valid permit reflecting the storage tank and
associated control device per the Colorado Oil and Gas Conservation Commission rule
805b(2)(A).
13. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
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
AIRS ID: 123/9C90/003 Page 3 of 11
olor Depa e f Ii Health and Environment
it Pollution Control Division
an obse I o from tside 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 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;
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XVII.C, /is • • 'ft•s' '..- • :: tion 'I equipment to ensure that
the valves for the piping from the storage tank to the air pollution control
equipment are open; and
XVII.C.1.d.(v) If a combustion device is used, inspection of the device for the
presence or absence of smoke. If smoke is observed, either the equipment
must be immediately shut-in to investigate the potential cause for smoke and
perform repairs, as necessary, or EPA Method 22 must be conducted to
determine whether visible emissions are present for a period of at least one
(1) minute in fifteen (15) minutes.
XVII.C.1.e. If storage tanks or associated equipment is unsafe, difficult, or inaccessible to
monitor, the owner or operator is not required to monitor such equipment until it
becomes feasible to do so.
XVII.C.2. Capture and monitoring requirements for storage tanks that are fitted with
air pollution control equipment as required by Sections XII.D. or XVII.C.1.
XVII.C.2.a. Owners or operators of storage tanks must route all hydrocarbon emissions to
air pollution control equipment, and must operate without venting hydrocarbon
emissions from the thief hatch (or other access point to the tank) or pressure relief
device during normal operation, unless venting is reasonably required for
maintenance, gauging, or safety of personnel and equipment. Compliance must be
achieved in accordance with the schedule in Section XVII.C.2.b.(ii).
XVII.C.2.b. Owners or operators of storage tanks subject to the control requirements of
Sections XII.D.2., XVII.C.1.a, or XVI I.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: 12319C90/003 Page 5 of 11
olo Depa e f li Health and Environment
it Pollution Control Division
Dt 't th ions i rdance 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.
XVI I.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: 123/9C901003 Page 6 of 11
llolor Depa, en 4 • .Ii Health and Environment
A
A it Pollution Control Division
A
OPERATING & M4 Gs • N ._,..
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 22 to determine the presence or absence of visible emissions. "Visible
Emissions" means observations of smoke for any period or periods of duration greater
than or equal to one (1) minute in any fifteen (15) minute period during normal
operation. (Reference: Regulation No. 7 Section XVII.AII)
Periodic Testing Requirements
19. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Method 22 on a weekly basis to determine the presence or absence of visible
emissions as required in the Operating and Maintenance Plan. "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.All)
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
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.
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Depa e f li Health and Environment
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21. Federal rDolor
r a D, N )shall apply to this source
at any such time that this source becomes major solely by virtue of a relaxation in any
permit condition. Any relaxation that increases the potential to emit above the
applicable Federal program threshold will require a full review of the source as though
construction had not yet commenced on the source. The source shall not exceed the
Federal program threshold until a permit is granted. (Regulation No. 3 Parts C and D).
22. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From
Oil and Natural Gas Production Facilities major stationary source requirements shall
apply to this stationary source at any such time that this stationary source becomes
majorsolely by virtue of a relaxation in any permit limitation and shall be subject to all
appropriate applicable requirements of Subpart HH. (Reference: Regulation No.8,Part
E)
GENERAL TERMS AND CONDITIONS
23. 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.
24. 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.
25. 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.
26. 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.
27. 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.
AIRS ID: 12319C901003 Page 8 of 11
Depa en f Ii Health and Environment
it Pollution Control Division
28. SectionDolor
re all s 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.
29. 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:
6/Aitv.t./if____
Christopher Kester
Oil and Gas Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Carrizo Oil & Gas Inc.
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Depa e f li Health and Environment
it Pollution Control Division
Notes to Permit HolderDolor
e an .
1) The permit holder is required to pay fees for the processing time for this permit.An invoice for these fees
will be issued after the permit is issued.The permit holder shall pay the invoice within 30 days of receipt of
the invoice. Failure to pay the invoice will result in revocation of this permit(Reference: Regulation No.3,
Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are based on
the consumption rates requested in the permit application. These limits 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:
https://www.coloradomov/pacific/cdohe/aocc-reqs
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis
of the specific compounds emitted if the source(s)operate at the permitted limitations.
Controlle
Uncontrolled d
Emission Are the Emission
AIRS Rate emissions Rate
Point Pollutant CAS# (Ib/yr) reportable? (Ib/yr)
Benzene 71432 5,052 Yes 253
n-Hexane 110543 24,305 Yes 1,215
Toluene 108883 6,237 Yes 312
003
Xylenes 1330207 1,748 Yes 87
224-TMP 540841 1,752 Yes 88
. Ethylbenzene 100414 322 Yes 16
5) The emission levels contained in this permit are based on the following emission factors:
Emission Factors Emission Factors
Uncontrolled Controlled
(lb/BBL (Ib/BBL Source
Condensate Condensate
Pollutant CAS# Throughput) Throughput)
VOC --- 1.72 0.086
Benzene 71432 0.031 0.0016
n-Hexane 110543 0.147 0.0074 E&P
Toluene 108883 0.038 0.0019 TANKS
Xylenes 1330207 0.011 0.0006
224-TMP 540841 0.011 0.0006
Ethylbenzene 100414 0.002 0.0001
AIRS ID: 12319C901003 Page 10 of 11
olor-A Depa en -f ' di Health and Environment
4 it Pollution Control Division
Note: The co 5•, is f +r ps. =. I I bas •:.:*.:the flare control efficiency of
95%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice(APEN) associated with this
permit is valid for a term of five years from the date it was received by the Division. A revised APEN
shall be submitted no later than 30 days before the five-year term expires. Please refer to the most
recent annual fee invoice to determine the APEN expiration date for each emissions point associated
with this permit. For any questions regarding a specific expiration date call the Division at(303)-692-
3150.
7) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor/Major Source of:
VOC&HAP
PSD Synthetic Minor/Major Source of:
VOC&HAP
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://ecfcepoaccess. ov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A—Subpart KKKK
NSPS Part 60, Appendixes Appendix A—Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT 63.1-63.599 Subpart A—Subpart Z
MACT 63.600-63.1199 Subpart AA—Subpart DDD
MACT 63.1200-63.1439 Subpart EEE—Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY
MACT 63.6580-63.8830 Subpart 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.00v/pacific/cdphe/air-permit-self-certification
AIRS ID: 123/9C90/003 Page 11 of 11
Construction Permit Application
Preliminary Analysis Summary
Section 1 —Applicant Information
Company Name: Carrizo Oil &Gas, Inc.
Permit Number: 14WE0563
Source Location: SWSE SEC 28 T10N R59W
Equipment Description: Six(6)400 BBL Crude Oil Storage Tanks
AIRS ID: 123-9C90-003
Date: 09/02/2014
Review Engineer Christopher Kester
Control Engineer: Stefanie Rucker
Section 2—Action Completed
X 1s`Issuance Modification APEN Required/Permit Exempt
Final Approval Transfer of Ownership APEN Exempt/Permit Exempt
* If tank is a true minor source at a true minor facility, it may be granted "Final Approval"without first
being issued an Initial Approval permit
*Grandfathered exemption is for any tanks in service prior to December 30, 2002
Section 3—Applicant Completeness Review
Was the correct APEN submitted for this source type? X Yes No
Is the APEN signed with an original signature? X Yes No
Was the APEN filled out completely? X Yes No
Did the applicant submit all required paperwork? X Yes No
Did the applicant provide ample information to determine emission rates? X Yes No
If you answered "no"to any of the above, when did you mail an
Information Request letter to the source?
On what date was this application complete? January 24th,2014
Section 4—Source Description
AIRS Point Equipment Description
003 Six(6)400 BBL Crude Oil Storage Tanks
Is this a portable source? Yes X No
Is this location in a non-attainment area for any criteria Yes X No
pollutant?
If"yes", for what pollutant? PKo CO Ozone
Is this location in an attainment maintenance area for Yes X No
any criteria pollutant?
If"yes", for what pollutant?
(Note: These pollutants are subject to minor source PM10 CO Ozone
RACT per Regulation 3, Part B, Section III.D.2)
Is this source located in the 8-hour ozone non-
attainment region? (Note: If"yes" the provisions of Yes X No
Regulation 7, Sections XII and XVII.C may apply)
Page 1
Section 5—Emission Estimate Information
AIRS Point Emission Factor Source
003 Weighted Average of two emission factors developed from 2 E&P Tank runs using
projected annual production from each well to determine"wei ht".
Did the applicant provide actual process data for the emission inventory? X Yes No
Bas for Actual'Emtsst6t s wed During'this JLp I rt
Repoed to tmrento ry)AIRS Point Process Consumption/Throughput/Production Data Year
003 N/A N/A
Baste for Permitted Emissions(P'L 1itst
AIRS Point Process Consumption/Throughput/Production
003 165217 BBLJyr
Does this source use a control device? X Yes No
AIRS Point Process Control Device Description % Reduction
Granted
003 01 48'Cimarron Enclosed Flare 95
Point NO, VOC(tpy) CO Total HAP(Ibs/yr)
Uncontrolled point 003 — 142.13 39,416
source emission rate:
Controlled point 003 -- 7.11 -- 1,971
source emission rate:
Section 7—Non-Criteria/Hazardous Air Pollutants
Uncontrolled An Ma*mink" Controlled Emission
Pollutant CAS# Emission Rate reportable? Ra{�(Iblyr)
(lb/yr)
Benzene 71432 5,052 Y 253
n-Hexane 110543 24,305 Y 1,215
Toluene 108833 6,237 Y 312
Xylenes 1330207 1,748 Y 87
2,2,4 TMP 540841 1,752 Y 88
Ethylbenzene 100414 322 Y 16
Note: Regulation 3, Part A, Section ll.B.3.b APEN emission reporting requirements for non-criteria air
pollutants are based on potential emissions without credit for reductions achieved by control
devices used by the operator.
Section 8—Testing Requirements
Will testing be required to show compliance with any emission rate or regulatory Yes X No
standard?
If"yes", complete the information listed below
AIRS Point Process Pollutant Regulatory Basis Test Method
Page 2
Section 9—Source Classification
Is this a new previously un-permitted source? X Yes No
What is this facility classification? True X Synthetic Major
Minor Minor
Classification relates to what programs? X Title V X PSD NA NSR MACT
Is this a modification to an existing permit? Yes X No
If"yes"what kind of modification? Minor Synthetic Major
Minor
Section 10—Public Comment
Does this permit require public comment per CAQCC Regulation 3? X Yes No
If"yes",for which pollutants?Why?
For Reg. 3, Part B, III.C.1.a (emissions increase>25/50 tpy)? X Yes No
For Reg. 3, Part B, III.C.1.c.ii (subject to MACT)? Yes No
For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? X Yes No
Section 11 —Modeling
Is modeling required to demonstrate compliance with National Ambient Yes X No
Air Quality Standards (NAAQS)?
If"yes", for which pollutants?Why?
AIRS Point Section 12—Regulatory Review
Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide
Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator
of a source shall allow or cause the emission into the atmosphere of any air pollutant which
is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings
taken at 15-second intervals for six minutes. The approved reference test method for
visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A(July,
003 1992)) in all subsections of Section II. A and B of this regulation.
Section II.A.5-Smokeless Flare or Flares for the Combustion of Waste Gases No owner
or operator of a smokeless flare or other flare for the combustion of waste gases shall
allow or cause emissions into the atmosphere of any air pollutant which is in excess of
30% opacity for a period or periods aggregating more than six minutes in any sixty
consecutive minutes.
Regulation 2—Odor
Section I.A-No person, wherever located, shall cause or allow the emission of odorous air
contaminants from any single source such as to result in detectable odors which are
003 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.
Requlation 3-APENs, Construction Permits, Operating Permits, PSD
Part A-APEN Requirements
Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for
003 each individual emission point in an attainment area with uncontrolled actual emissions of
two tons per year or more of any individual criteria pollutant (pollutants are not summed)for
which the area is attainment.
(Applicant is required to file an APEN since emissions exceed 2 tons per year VOC)
003 Part B—Construction Permit Exemptions
Applicant is permit exempt, Req 3 Section II.D.1.n but is requesting FEL's.
Requlation 6-New Source Performance Standards
Page 3
NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84.
003 Is this source greater than 19,800 gallons (471 bbl)? No
Is this source subject to NSPS Kb?No
This point is also pre-custody transfer—not subject to Kb
Regulation 7—Volatile Organ compounds
XII. VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS
(Applicant is not subject to the emission control requirements for condensate tanks
003 since it is located in an attainment area.)
XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS...
Regulation 8—Hazardous Air Pollutants
MACT EEEE: Organic Liquids Distribution
Pick one:
• This source is not subject to MACT EEEE because it is not located at a major
003 source of HAP.
• This source is not subject to MACT EEEE because it is located at a"production
field facility"as defined in 40 CFR 63.761 (located upstream of the natural gas
processing plant).
MACT HH
Pick one:
• This source is not subject to MACT HH because it is not located at a major source
003 of HAP.
• This source is not subject to MACT HH because it is not a"storage vessel with the
potential for flash emissions"as defined in 40 CFR 63.761 because annual •
average hydrocarbon liquid will be less than 500 BBUday(182,500 BBL/yr).
Section 13—Aerometric Information Retrieval System Coding Information
Emission
Process Pollutant/ Fugitive Emission Factor Control
Point Process Description Factor CAS# (Y/N) - Source (%)
(lb/BBL)
Weighted Average—
1.72 VOC No Two E&P Tank Runs 95
with Projected Annual
Production
Weighted Average—
Benzene/ Two E&P Tank Runs
0.0306 71432 N° with Projected Annual 95
Production
Weighted Average—
n-Hexane/ Two E&P Tank Runs
0.147 110543 N° with Projected Annual 95
Production
Weighted Average—
01 E&P Crude 0.0378 Toluene/ N° Two E&P Tank Runs 95
003 Storage Tanks 108833 with Projected Annual
Production
Weighted Average—
Xylenes/ Two E&P Tank Runs
.01 006 1330207 N° with Projected Annual 95
Production
Weighted Average—
0.0106 224 TMP/ No Two E&P Tank Runs 95
540841 with Projected Annual
Production
Weighted Average—
0.00195 Ethylbenzene No TwoE&P Tank Runs 95
/100414 with Projected Annual
Production
SCC 40400311 —Fixed Roof Tank,Condensate,working+breathing+flashing losses
Page 4
STATE OF COLORADO
0,?
c
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION FQ
TELEPHONE: (303)692-3150
CONSTRUCTION PERMIT
PERMIT NO: 14WE0565
Issuance 1
DATE ISSUED:
ISSUED TO: Carrizo Oil & Gas Inc.
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the Nelson Ranches 1-33, 4-27-10-59, located in the
SWSE of Section 28, Township 10N, Range 59W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS
Equipment Point Description
ID
LOAD 005 Truck loadout of crude oil. Emissions from the loadout are not
controlled.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO
AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS
INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than
fifteen days after issuance of this permit, by submitting a Notice of Startup form to
the Division. The Notice of Startup form may be downloaded online at
https://www.colorado.nov/pacific/cdphe/other-air-permittinq-notices. Failure to notify the
Division of startup of the permitted source is a violation of Air Quality Control
Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the
revocation of the permit.
2. Within one hundred and eighty days (180) after issuance of this permit, compliance with
the conditions contained in this permit shall be demonstrated to the Division. It is the
owner or operator's responsibility to self-certify compliance with the conditions. Failure to
demonstrate compliance within 180 days may result in revocation of the permit.
(Reference: Regulation No. 3, Part B, III.G.2).
AIRS ID: 12319C901005 Page 1 of 7
Condensate Loadout TM Version 2012-1
Co do p e o Public PollutionHealthand ControlEnvironment Division
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.)
4. The operator shall retain the permit final authorization letter issued by the Division after
completion of self-certification, with the most current construction permit. This
construction permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
5. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Annual Limits:
Facility AIRS Tons per Year
Equipment Point Emission Type
ID VOC
LOAD 005 8.3 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.
PROCESS LIMITATIONS AND RECORDS
6. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rate 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)
AIRS ID: 12319C90/005 Page 2 of 7
Co do p e o Public Health and Environment
Air Pollution Control Division
Process/Consumption Limits
Facility AIRS
Equipment Point Process Parameter Annual Limit
ID
LOAD 005 Crude Oil Loaded 165,217 BBL/yr
The owner or operator shall calculate monthly process rates based on the calendar
month.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on
the previous twelve months' data. The permit holder shall calculate throughput each
month and keep a compliance record on site or at a local field office with site
responsibility, for Division review.
7. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference:
Regulation 3, Part B, III.E)
STATE AND FEDERAL REGULATORY REQUIREMENTS
8. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
9. The owner or operator shall follow loading procedures that minimize the leakage of
VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B,
III.E):
a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or
other liquid or vapor loss during loading and unloading.
b. All compartment hatches (including thief hatches) shall be closed and latched at
all times when loading operations are not active, except for periods of
maintenance, gauging, or safety of personnel and equipment.
c. The owner or operator shall inspect loading equipment and operations onsite at
the time of inspections to monitor compliance with Condition 9 (a) and (b) above.
The inspections shall occur at least monthly. Each inspection shall be
documented in a log available to the Division on request.
10. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated
and maintained so as to minimize leakage of volatile organic compounds to the
atmosphere to the maximum extent practicable.
OPERATING & MAINTENANCE REQUIREMENTS
11. This source is not required to follow a Division-approved operating and maintenance
plan.
AIRS ID: 12319C901005 Page 3 of 7
Co do p e o Public PollutionHealthand Control DivisionEnvironment
COMPLIANCE TESTING AND SAMPLING
12. This source is not required to comply with any testing and sampling requirements.
ADDITIONAL REQUIREMENTS
13. 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.
14. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at
any such time that this source becomes major solely by virtue of a relaxation in any
permit condition. Any relaxation that increases the potential to emit above the applicable
Federal program threshold will require a full review of the source as though construction
had not yet commenced on the source. The source shall not exceed the Federal
program threshold until a permit is granted. (Regulation No. 3 Part D).
GENERAL TERMS AND CONDITIONS
15. 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.
16. If this permit specifically states that final authorization has been granted, then the
remainder of this condition is not applicable. Otherwise, the issuance of this construction
permit does not provide "final" authority for this activity or operation of this source. Final
authorization of the permit must be secured from the APCD in writing in accordance with
the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section
AIRS ID: 123/9C901005 Page 4 of 7
lip Co A do • p e ° o Public Health and Environment
ll
Air Pollution Control Division
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.
17. 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.
18. 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.
19. 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.
20. 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.
21. 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: gkttlff____
Christopher Kester
Oil and Gas Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Carrizo Oil & Gas Inc.
AIRS ID: 123/9C90/005 Page 5 of 7
Co do p e o Pueanviom
Airblic PollutionH lth ControlandE r
Divisionnent
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: https://www.colorado.gov/pacific/cdphe/aocc-regs
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis
of the specific compounds emitted if the source(s)operate at the permitted limitations.
Uncontrolled
Emission Are the Controlled
AIRS Rate emissions Emission
Point Pollutant CAS# (Ib/yr) reportable? Rate(Ib/yr)
n-Hexane 110543 1416 Yes N/A
005 Benzene 71432 298 Yes N/A
Toluene 108883 361 Yes N/A
5) The emission levels contained in this permit are based on the following emission factors:
Emission Factors -Uncontrolled
Pollutant CAS# (lb/1000gal) Source
VOC — 2.4
n-Hexane 110543 0.043 AP-42
Benzene 71432 0.052
Toluene 108883 0.204
The uncontrolled VOC emission factor was calculated using AP-42, Chapter 5.2, Equation 1
(version 1/95) using the following values:
L= 12.46"S*P*M/T
S=0.6 (Submerged loading: dedicated normal service)
P(true vapor pressure) = 3.4 psia
M (vapor molecular weight) = 50 Ib/Ib-mol
T(temperature of liquid loaded)=529.67°R
AIRS ID: 12319C90/005 Page 6 of 7
llCo A do 8 p e o Public Health and Environment
{ Air Pollution Control Division
The uncontrolled non-criteria reportable air pollutant (NCRP) emission factors were calculated by
multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor.
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 &HAP
PSD Synthetic Minor/Major Source of:
VOC&HAP
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A—Subpart KKKK
NSPS Part 60,Appendixes Appendix A—Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT 63.1-63.599 Subpart A—Subpart Z
MACT 63.600-63.1199 Subpart AA—Subpart DDD
MACT 63.1200-63.1439 Subpart EEE—Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM
MACT 63.8980-End Subpart NNNNN—Subpart X00000(
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: 123/9C90/005 Page 7 of 7
Construction Permit Application
Preliminary Analysis Summary
Section 1 —Applicant Information
Company Name: Carrizo Oil & Gas, Inc.
Permit Number: 14WE0565
Source Name: Nelson Ranches 1-33, 4-27-10-59
Source Location: SWSE SEC 28 T10N R59W
Equipment Description: Crude Oil Truck Loading
AIRS ID: 123-9C90-005
Review Date: Christopher Kester
Review Engineer: Stefanie Rucker
Section 2—Action Completed
X CP1 Modification APEN Required/Permit Exempt
Final Approval Transfer of Ownership APEN Exempt/Permit Exempt
Section 3—Applicant Completeness Review
Was the correct APEN submitted for this source type? X Yes No
Is the APEN signed with an original signature? X Yes No
Was the APEN filled out completely? X Yes No
Did the applicant submit all required paperwork? X Yes No
Did the applicant provide ample information to determine emission rates? X Yes No
If you answered "no"to any of the above, when did you mail an
Information Request letter to the source?
On what date was this application complete? January 241°,2014
Section 4—Source Description
AIRS Point Equipment Description
005 Crude Oil Truck Loading
Is this a portable source? Yes X No
Is this location in a non-attainment area for any criteria Yes X No
pollutant?
If"yes", for what pollutant? PM10 CO Ozone
Is this location in an attainment maintenance area for Yes X No
any criteria pollutant?
If"yes", for what pollutant?
(Note: These pollutants are subject to minor source PM10 CO Ozone
RACT per Regulation 3, Part B, Section III.D.2)
Is this source located in the 8-hour ozone non-
attainment region?(Note: If"yes"the provisions of Yes X No
Regulation 7, Sections XII and XVII.C may apply)
Is this source located at an oil and gas exploration site? X Yes No
Page 1
If yes, does this source load less than 10,000 gallons of
crude oil per day on an annual average, splash fill less
than 6750 bbl of condensate(hydrocarbons that have Yes X No
an API gravity of 40 degrees or greater) per year or
submerged fill less than 16,308 bbl of condensate per
year?
Is this source located at a facility that is considered a
major source of hazardous air pollutant(HAP) Yes X No
emissions?
Will this equipment be operated in any NAAQS
nonattainment area? Yes X No
Does this source load gasoline into transport vehicles? Yes X No
Section 5—Emission Estimate Information
AIRS Point Emission Factor Source
AP-42: Chapter 5.2, Equation 1
L= 12.46'S'P'M/T
005 L= loading losses in lb per 1000 gallons loaded
S= Saturation Factor
P=true vapor pressure of liquid loaded [psia]
M =molecular weight of vapors[lb/lb-mole]
T=temperature of bulk liquid loaded [deg. R]
Did the applicant provide actual process data for the emission inventory? X Yes No
Basis for Permitted Entissioris(Permit LirriiLsj.; .
AIRS Point Process Consumption/Throughput/Production
005 165,217 BBL Crude Oil Loaded per Year
Does this source use a control device? Yes X No
Section 6—Emission Summa (tons per year)
Point NO„ VOC CO HAP
Permitted point source 005 8.32 — 1.04
emission rate:
Section 7—Non-Criteria/Hazardous Air Pollutants
Uncontrolled Are the emissions Controlled Emission
Pollutant CAS# Emissl )Rete reportable? Rate(lb/yr)
Benzene 71432 _ 300 Y NA
n-Hexane 110543 1420 Y NA
Toluene 108883 360 Y NA
Ethylbenzene 100414 19 N NA
Xylenes 1130207 102 N NA
224 TMP 540841 102 N NA
Note: Regulation 3, Part A, Section ll.B.3.b APEN emission reporting requirements for non-criteria air
pollutants are based on potential emissions without credit for reductions achieved by control
devices used by the operator.
Section 8—Testing Requirements
Will testing be required to show compliance with any emission rate or regulatory Yes X No
standard?
Page 2
Section 9—Source Classification
Is this a new previously un-permitted source? X Yes No
What is this facility classification? True X Synthetic Major
Minor Minor
Classification relates to what programs? X Title V X PSD NA NSR MACT
Is this a modification to an existing permit? Yes X No
If"yes"what kind of modification? Minor Synthetic Major
Minor
Section 10—Public Comment
Does this permit require public comment per CAQCC Regulation 3? Yes X No
If"yes", for which pollutants?Why?
For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)? Yes No
For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)? Yes No
For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? Yes No
Section 11 —Modeling
Is modeling required to demonstrate compliance with National Ambient Yes X No
Air Quality Standards (NAAQS)?
AIRS Point Section 12—Regulatory Review
Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide
Visible emissions shall not exceed twenty percent(20%) opacity during normal operation of
005 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.)
Regulation 2—Odor
Section I.A- No person, wherever located, shall cause or allow the emission of odorous air
contaminants from any single source such as to result in detectable odors which are
005 measured in excess of the following limits: For areas used predominantly for residential or
commercial purposes it is a violation if odors are detected after the odorous air has been
diluted with seven (7) or more volumes of odor free air.
Regulation 3-APENs, Construction Permits, Operating Permits, PSD
Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for
each individual emission point in an attainment area with uncontrolled actual emissions of
two tons per year or more of any individual criteria pollutant(pollutants are not summed)for
which the area is attainment.
(Applicant is required to file an APEN since emissions exceed 2 tons per year VOC)
Part B—Construction Permit Exemptions
Applicant is required to obtain a permit since uncontrolled VOC emissions from this
005 facility are greater than the 5.0 TPY threshold(Reg. 3, Part B, Section II.D.3.a)
Part B, III.D.2 - RACT requirements for new or modified minor sourdes
This section of Regulation 3 requires RACT for new or modified minor sources located in
nonattainment or attainment/maintenance areas. This source is/is not located in the 8-hour
ozone nonattainment area, but not the 1-hour ozone area.
Since source is in attainment, RACT is not required. However, operator is using 0.6
saturation factor, which does satisfy RACT requirements.
Regulation 6-New Source Performance Standards
005 No applicable subpart. This facility is not a bulk gasoline terminal.
Page 3
Regulation 7—Volatile Organio'Compounds
No sections apply. Per Regulation 7, Section VI.C, a terminal is defined as a petroleum
liquid storage and distribution facility that has a daily average throughput of more than
005 76,000 liters of gasoline(20,000 gallons), which is loaded directly into transport vehicles.
This facility is neither a terminal, nor a bulk plant per definitions in Reg 7, Section VI.C.
Regulation 6—Hazardous Air Pollutants
005 None
Section 13—Aerometric Information Retrieval System Coding Information
Process/ Emission Emission
Process Pollutant/ Fugitive Control
Point Process Description throughput Factor CAS# (y/ry) Factor (%)
Limit (Ib/1000gal) Source
2.39 VOC N AP-42 0
Benzene/
0.043 AP-42 0
Truck Condensate 165217 N
01 71432
Loadout BBLJyr 0.204 n-Hexane N AP-42 0
005 /110543
0.052 Toluene/ N AP-42 0
108883
SCC 40600132: Crude Oil: Submerged Loading (Normal Service) Use if S=0.6
•
Page 4
Section 14—Miscellaneous Application Notes
AIRS Point 002 Truck Condensate Loadout
Units Basis
S 0.6 Submerged loading:
dedicated normal service
based on source's
description/drawings
P 7.25 Psia Based on extended natural
gas sample OR based on
EPA TANKs run
M 50 Lb/lb-mole Based on extended natural
gas sample OR based on
EPA TANKs run
T 520 Deg R Based on source's
knowledge of bulk liquid
temperature OR based on
EPA TANKs run
L Lb/10^3 gal Clarify if this value is used
to calculate annual
emissions or if
methane/ethane are
removed to represent VOC
vs TOC or if a safety factor
is applied OR any other
relevant notes
Lb/bbl
AP-42: Chapter 5.2
Equation 1
L = 12.46*S*P*M/T
L= loading losses in lb per 1000 gallons loaded
S = Saturation Factor
P =true vapor pressure of liquid loaded [psia]
M = molecular weight of vapors [lb/lb-mole]
T=temperature of bulk liquid loaded [deg. R]
Use the loadout PA spreadsheet to calculate emission factor and emissions
L 5.21Ib/10^3 gal
2.19E-01 Ib/bbl
Annual requested Throughput 1443960ga1/yr
Annual requested VOC emissions 75251b/yr
3.76tpy
4
Page 5
STATE OF COLORADO
of-C
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT ,I
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303)692-3150 “.eti„,t'.;
CONSTRUCTION PERMIT
PERMIT NO: 14WE0566
Issuance 1
DATE ISSUED:
ISSUED TO: Carrizo Oil & Gas Inc.
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the Konig 2-31-11-59, located in Lot 4 of Section 31,Township
11N, Range 59W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS
Equipment Point Description
ID
SEPARATOR 006 Separator controlled by an open flare. Flare has a minimum
combustion efficiency of 95%.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR
QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S.(25-7-101 et seq),TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED
IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen
days after issuance of this permit, by submitting a Notice of Startup form to the
Division. The Notice of Startup form may be downloaded online at
www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of
the permitted source is a violation of Air Quality Control Commission(AQCC)Regulation No.
3, Part B, Section III.G.1 and can result in the revocation of the permit.
2. Within one hundred and eighty days(180)after issuance of this permit,compliance with the
conditions contained in this permit shall be demonstrated to the Division. It is the owner or
operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate
compliance within 180 days may result in revocation of the permit. (Reference: Regulation
No. 3, Part B, III.G.2).
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i)does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii)discontinues construction for a period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
AIRS ID: 123/9C90/006 Page 1 of 9
Wellhead Version 2012-1
•
olo De pa e f li
it PollutionHealthand Control DivisionEnvironment
estimated co d T 'sio ant ions of the deadline per
Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self-certification process.
(Reference: Regulation No. 3, Part B, Section III.E.)
5. Within one hundred and eighty(180) days after issuance of this permit,the operator shall
install a flow meter to monitor and record volumetric flow rate of natural gas vented from this
separator.The operator shall used 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.
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 yp
SEPARATOR 006 3.4 59.5 18.3 Point
See 'Notes to Permit Holder#4"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.
The operator shall continuously monitor and record the volumetric flowrate of natural gas
vented from the separator using a flow meter. The flow meter shall continuously measure
flowrate and record total volumetric flow vented from the separator.The operator shall use
monthly throughput records to demonstrate compliance with the process limits and to
calculate emissions as described in this permit.
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: 12319C90/006 Page 2 of 9
olor Depa en .f 'Ii Health and Environment
it Pollution Control Division
fir, FL (�"' �
Facility
Pollutants
Equipment Control Device
ID Point Controlled
Separator 006 Separator controlled by an open flare VOC and HAP
PROCESS LIMITATIONS AND RECORDS
9. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the throughput shall be maintained by the applicant and made available
to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4)
Process/Consumption Limits
Facility AIRS
Equipment Point Process Parameter Annual Limit
ID
Separator 006 Natural gas flaring 60.2 MMSCF/yr
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 number 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. (Reference: Regulation No. 1, Section II.A.1. &4.)
12. 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.)
13. These sources are subject to the odor requirements of Regulation No. 2. (State only
enforceable)
14. 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.)
AIRS ID: 123/9C90/006 Page 3 of 9
olor Depa e f Ii Health and
it Pollution ControlEnvironment Division
OPERATING & MAINTENANCE REQUIREMENTS
15. Upon startup of this point, the applicant shall follow the operating and maintenance (O&M)
plan and record keeping format approved by the Division, in order to demonstrate
compliance on an ongoing basis with the requirements of this permit. Revisions to your
O&M plan are subject to Division approval prior to implementation. (Reference: Regulation
No. 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
16. The owner or operator shall demonstrate compliance with opacity requirements using EPA.
Method 9 to measure opacity from the flare. (Reference: Regulation No. 1,Section II.A.5).
Periodic Testing Requirements
17. The owner or operator shall demonstrate compliance with opacity requirements using EPA
Method 22 to measure opacity from the flare on a monthly basis. (Reference: Regulation No.
1, Section I I.A.5).
18. 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
19. A revised Air Pollutant Emission Notice(APEN)shall be filed:(Reference: Regulation No.3,
Part A, II.C)
a. Annually whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of
five (5) tons per year or more, above the level reported on the last APEN; or
For any non-criteria reportable pollutant:
If the emissions increase by 50%or five (5)tons per year,whichever is less, above
the level reported on the last APEN submitted to the Division.
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
c. Whenever new control equipment is installed,or whenever a different type of control
equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
20.- Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at
any such time that this source becomes major solely by virtue of a relaxation in any permit
condition. Any relaxation that increases the potential to emit above the applicable Federal
program threshold will require a full review of the source as though construction had not yet
AIRS ID: 123/9C90/006 Page 4 of 9
olor- t Depa en wf • ;.Ii Health and Environment
•it Pollution Control Division
commenced .- -- u�r .. :. s-.+ , ..a- ceed 4 ederal program threshold
until a permit is granted. (Regulation No. 3 Part D).
GENERAL TERMS AND CONDITIONS
21. 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.
22. 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.
23. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the applicant and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the applicant or applicant's agents. It is valid only for the
equipment and operations or activity specifically identified on the permit.
24. 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.
25. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence,this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self-certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the applicant, or the Division revokes a permit,the applicant
or owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
26. 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.
27. 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.
AIRS ID: 123/9090/006 Page 5 of 9
RoloAe. F
f li and Environment
it PollutionHealth Control Division
By:
Christopher Kester
Oil and Gas Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to: Carrizo Oil & Gas, Inc.
AIRS ID: 12319C90/006 Page 6 of 9
olor ,, Depa en i ..f .h '`Health and Environment
•it Pollution Control Division
=°t
Notes to Permit Holder:
1) The permit holder is required to pay fees for the processing time for this permit.An invoice for these fees
will be issued after the permit is issued.The permit holder shall pay the invoice within 30 days of receipt of
the invoice. Failure to pay the invoice will result in revocation of this permit(Reference: Regulation No. 3,
Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are based on
the consumption rates requested in the permit application. These limits may be revised upon request of
the permittee providing there is no exceedance of any specific emission control regulation or any ambient
air quality standard. A revised air pollution emission notice (APEN) and application form must be
submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The permittee shall notify the Division of any
malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon
as possible, but no later than noon of the next working day, followed by written notice to the Division
addressing all of the criteria set forth in Part II E.1 of the Common Provisions Regulation. See:
http://www.colorado.gov/cs/Satellite?c=Document C&childpagename=CDPHE-
Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis
of the specific compounds emitted if the source(s) operate at the permitted limitations.
Uncontrolled
Emission Are the Controlled
AIRS Rate emissions Emission
Point Pollutant CAS# (lb/yr) reportable? Rate(Ib/yr)
Benzene 71432 10880 Yes 540
Toluene 108883 8880 Yes 440
006 Xylenes 1130207 2880 Yes 140
n-Hexane 110543 62260 Yes 3420
Ethylbenzene 100414 1080 Yes 60
5) The emission levels contained in this permit are based on the following emission factors:
Weight Emission Emission
CAS# Pollutant Fraction of Factors Factors Source
Gas (%) Uncontrolled Controlled
NOx - 0.068 --- AP-42
lb/MMbtu
__ 0.370
Ib/MMBtu
VOC 26.7 24.05 1.203 Engineering
lb/MMBtu lb/MMBtu Calculation
71432 Benzene 0.0804 180.63 9.032 Engineering
lb/MMscf lb/MMscf Calculation
108883 Toluene 0.0606 147.33 7.367 Engineering
Ib/MMscf lb/MMscf Calculation
AIRS ID: 123/9C90/006 Page 7 of 9
olo Depa e THealth
and Environment
Pollution Control Division
In
CAS# Pollutant Fraction of Factors Factors Source
Gas(%) Uncontrolled Controlled
1330207 47.90 2.395 Engineering
Xylenes 0.0171
lb/MMscf lb/MMscf Calculation
1133.8 56.69 Engineering
110543 n-Hexane 0.4784
lb/MMscf lb/MMscf Calculation
17.92 0.896 Engineering
100414 Ethylbenzene 0.0064
Ib/MMscf lb/MMscf Calculation
Note: The uncontrolled VOC and HAP emissions for this point were calculated using a weighted
average of two gas sample collected from the Nelson Ranches 1-33 and 4-27 wells on
December 27,2013.The controlled VOC and HAP emissions factors for point 006 are based
on the flare control efficiency of 95%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice(APEN) associated with this
permit is valid for a term of five years from the date it was received by the Division.A revised APEN
shall be submitted no later than 30 days before the five-year term expires. Please refer to the most
recent annual fee invoice to determine the APEN expiration date for each emissions point associated
with this permit. For any questions regarding a specific expiration date call the Division at(303)-692-
3150.
7) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor/Major Source of:
VOC and HAP
PSD or NANSR Synthetic Minor/Major Source of:
VOC and HAP
MACT HH 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://ecf r.a poaccess.o ov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A—Subpart KKKK
NSPS Part 60,Appendixes Appendix A—Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT 63.1-63.599 Subpart A—Subpart Z
MACT 63.600-63.1199 Subpart AA—Subpart DDD
MACT 63.1200-63.1439 Subpart EEE—Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY
MACT - 63.6580-63.8830 Subpart 7777-Subpart MMMMM
MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX
AIRS ID: 123/9C90/006 Page 8 of 9
olor- Depa en f 'Ii Health and Environment
it Pollution Control Division
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: 123/9C90/006 Page 9 of 9
Produced Natural Gas Venting/Flaring Preliminary Marysis Colorado Department of Public Health and Enwnnment
Air Pollution Control Division
Preliminary Alanlysis SEPARATOR 123-9C90-006
Attainment Status
Division Intonation PM10 Attainment
Engineer: Pester PM2 5 Attainment
Control Engineer: Stefanie Rucker , 50x Attainment
Renew Oate. 09/03/2014 NOx Attainment
Application Date_ 014412014 VOC Attainment
Facili Infomation CO Attainment
4WE066o
Count X 123 Weld
AIRs Facile Y 9C90
Point% 006
acil pulpmentle SEPARATOR
Comas Name: arrao i as Inc
SourrcecLocatan. 1
l 21'111
Elevation(feet)52'.2
New Permit Modicalion ADEN
X (CPI) (Issuance Of RetuRedlPermll
Transfer 0l APEN
Ownership ExempwPermd
Notes
Equipment Description
This source vents natural gas from: a well head separator
Emissions from this source are muted lB an opeMlame fare
Natural gas vaMing from a well head separator Emissions from this source are fouled Ill an open-fame hare.
55m On Celcuftpn Method
EPA Emission Inventory Improvement Program Publication Volume II,Chapter 10•Displacement Equation(104-3)
Ex=emissions of pollutant x
0=Volumetre lbw mtelvolume of gas processed
MW=Molecular weigh of gas=SG of gas'MW of as
Xx=mass fraction of x in gas
C=molar volume of ideal gas(379 scl/Ibmol)at60F and 1 atm
Throughput(0) B02 MMsc1M I 0072.1 tots I 5.11 MMsc9mo I
MW 29290 lb/lb-mot0001 MMsclla
mole% 'MW Iho bT dir bmol mass traction E 1r I
Helium 001 40026 0000 0000 Helium 0064
CO2 2.41 44,01 1,061 0.036 CO2 19.2 180471
N2 099 20013 0277 0009 N2 50 44051
meths. 57 45 16.041 9.216 0 315 methane 187.1 1483790
ethane 2 0 00 3 13905 33 727 0.127 ethane 676 592050
propse 133425 4.092 50830 0201 propane 10.7 934446
sobutane 15636 58.118 09087 0.031 iwbutse 165 144342
nbutae S9bb he 118 340(2 0.118 n-buMn b20 504/44,
rsopentane 1.3099 72114 09446 0032 pentane 171 150043
nmentane 24 m
19493 /2114 1 4/ 004fi 242 211851
0.1703 70.13 0-1250 0004 23 19062
n-Hexane 04784 138.18 04123 0.014 75 65407
Mbhexane 01301 8416 01102 0.004 cyclone/me 20 17499
Other homes 08266 4610 07120 0024 Oilier hexanes 129 1131£1.
heptnes 04728 10021 04738 0016 heotales 8.6 75257
methiecwb 0 0 thsk hemne 0.1095 98.19 1075 004 mg bhexse 1.9 17078
224-TMP 00003 11423 00003 0000 224-TMP 00 54
Benzene 0004 70.12 00658 0002 Benzene 12 10423
Toluene 00006 92.15 00558 0002 Toluene 10 8870
Ehrylbenaene 00064 10417 00088 0000 EMNbmame 0.1 1079
X4enes 00171 105.17 0.0182 0.001 xysnes 0 3 2084
Ce.Heaves 02983 8026 03834 0013 CB.Hearcs 70 60098
999532 VOC mass fraction. 05124 Total VOO Emissions(Uncontrolled)
29290 annual lint assuming 95%control
Notes month/Flint assuming 95%control ORM.)
Mole%.MW.and mass 0ec0ons horn Nelwn Ranches 1.33.4.27-10-59 pas anthems
I calculated the average MW of Ca-hazed on tie avnage MW on the analysis ter Neoae.
Flaring Information
Fm Desenplion
Mare to combust produced gas until pipeline is available attars wellhead Merit/
Manufacturer TOO
Model Number TOO
Oosl HeigV Tao
Gas HeatingValue 1620.2 Btelscl
MMEitu
Throughput 989206a MMBtWyr
Combustion emission factor source AP-42 Chapter 13.5
3336'tpYPDX I 1030Itp/CO lb MBIu
Emissions Summary
336 tpy NOX
Uncontrolled/PTE 13.30 toy CO
1191 985 toy VOC
Controlled 59599 tpv VOC
Uncontrolled Total ScenarioA Controlled
llbtys) Reportable? Total(INyel
Benzene 10423 Yes 521
Toluene 8070 Yes 004__.
Ethvlhetene 1079 Yes 54
Xylenes 2804 Yes 144
n-hexane 65487 Yes 3274
224-TMP 54 No 3
Regulatory Applicability
AOCC Remtla4on 1
Prodced Natural Ges Venting/Flenng Prelsne.ry Mab!'e Colorado OepaNmnl of Public HUM and Ertmmerd
Air Pollution Control Orson
Tee sown is slgMt the opacity requirements fur Porte in BMcn I1A9:'No owner or operator of a
smwen Pore or other Pon forth.combustion of wane gases Mall'Now or sow emissions Tito the
O n.ohai of env H pollutant which th e even of 30%awes.'
AOCC Relate 0
Section LA.ppnen to eat em"vcn souns'No perm;weather"sated.shall pew or Slow the emission of
odorous at contaminants hcm any Sege source wish ne reed in delectable W.Sikh at.maasued in
• M of the/Wowing Irmo:For areas used predominantly for readmitted of commercial puposn tea
'boom to-Mrs en deeded after the odwws ea has teen diluted wM sawn(71or mom volumes doe.
AO ab'
AOCC R.Wat1on 3
M APEN'e rewind for
stemma*
area because urcoroo ed VOC emissions weed no
P HA tonAewr war ere forthesa all
A permit o mooed
rewired for Ne wall because dcWNOYd VOL emissions Lomtle
Molly mwd five tons per year In an ahaMaM eras.
Part B: !meted
n..noaernent 8adbn 19.03(Minor Soot.RACTfbxow ilonot
oath e a nawtesanenl are..
A public canner' Public Comment Required
mired?
Facility Stabs
The%city S.synthetic nwor nun of VCCMAP for Tide V appllWbiiy
This hasty a.synthetic minor source of VCGMAP for POD eppecabety
lrmbeloa Faders for Pew
111.7376 ad
O 607.964 .
396008298
•(fS7}i.' 173.1420
T 147.3427 MMlao natal invented
17.9284 ....: .r_,�_r. ., vented
47.9026 weed
E•..'Tf!.� 1087.8239 weed
G 0.9042 .t.., . ....r vented
Cdnoaed
NO% 111.7376 bMMM neural ass vented
CO 60]984 .,s1„,„, W„,„, e ass nted
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