HomeMy WebLinkAbout20132376.tiffSTATE OF COLORADO
John W. Hickenlooper, Governor
Karin McGowan
Interim Executive Director
Dedicated to protecting and improving the health and environment of the people of Colorado
4300 Cherry Creek Dr. S.
Denver, Colorado 80246-1530
Phone (303) 692-2000
Located in Glendale, Colorado
http://www.cdphe.state.co.us
Weld County Clerk & Recorder
1402 N 17th Ave
Greeley, CO 80631
August 15, 2013
Dear Sir or Madam:
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
(303) 692-3090
Colorado Department
of Public Health
and Environment
PIECE/ vet)
AUG 2913P► U R
On August 18, 2013, the Air Pollution Control Division will publish a public notice for Whiting Oil and Gas
Corp. — Terrace Gas Plant, in the The Greeley Tribune. A copy of this public notice and the public comment
packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public
copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet
must be available for public inspection for a period of thirty (30) days from the date the public notice is
published. Please send any comment regarding this public notice to the address below.
Colorado Dept. of Public Health & Environment
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
Nit, /Celiac) "h3
2013-2376
STATE OF COLORADO
John W. Hickenlooper, Governor
Karin McGowan
Interim Executive Director
Dedicated to protecting and improving the health and environment of the people of Colorado
4300 Cherry Creek Dr. S.
Denver, Colorado 80246-1530
Phone (303) 692-2000
Located in Glendale, Colorado
http://www.cdphe.state.co.us
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
(303) 692-3090
Website Title: Whiting Oil and Gas Corp. — Terrace Gas Plant — Weld County
Colorado Department
of Public Health
and Environment
Released To: The Greeley Tribune
On: August 15, 2013
Published: August 18, 2013
PUBLIC NOTICE OF A PROPOSED PROJECT
OR ACTIVITY WARRANTING PUBLIC COMMENT
Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado
Air Pollution Control Division for the following source of air pollution:
Applicant:
Facility:
Whiting Oil and Gas Corp.
Terrace Gas Plant
Natural gas processing plant
NWNE of Section 18, T10N, R58W
Weld County
The proposed project or activity is as follows: Addition of a facility flare to an existing natural gas processing
plant.
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):
• 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 13 WE 1780 havebeen 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 www.Colorado.gov/cdphe/AirPublicNotices
The Division hereby solicits submission of public comment from any interested person concerning the ability of
the proposed project or activity to comply with the applicable standards and regulations of the Commission. The
Division will receive and consider written public comments for thirty calendar days after the date of this Notice.
Any such comment must be submitted in writing to the following addressee:
Stephanie Chaousy
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-BI
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO:
13WE1780
Issuance 1
DATE ISSUED:
ISSUED TO: Whiting Oil and Gas Corporation
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the Terrace Gas Plant, located in the NWNE of Section 18,
Township 10 North, Range 58 West, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
FLR-1
007
Continuous pilot plant flare for combusting residue gas. The flare
will be utilized when the third party natural gas pipeline is not
available. The emissions unit is designed as an open flare.
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 commencement of operation, 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 commencement of operation, compliance
with the conditions contained in this permit shall be demonstrated to the Division. It is the
owner or operator's responsibility to self -certify compliance with the conditions. Failure to
demonstrate compliance within 180 days may result in revocation of the permit. (Reference:
Regulation No. 3, Part B, III.G.2).
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction for a period of eighteen
AIRS ID: 123/0444
Page 1 of 8
Wellhead Template Version 2012-1
f Public Health and Environment
Air Pollution Control Division
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 for all permitted equipment 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)
Monthly Limits:
Facility
Equipment ID
AIRS
Point
Pounds per Month
Emission Type
NO„
VOC
CO
FLR-1
007
1,614
10,821
8,782
Point
(Note: Monthly limits are based on a 31 -day month.)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission Type
yp
NO,
VOC
CO
FLR-1
007
9.5
63.7
51.7
Point
See "Notes to Permit Holder #4" for information on emission factors and methods used to calculate
limits.
During the first twelve (12) months of operation, compliance with both the monthly and
annual emission limitations is required. After the first twelve (12) months of operation,
compliance with only the annual limitation is required.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from
each emission unit, on a rolling twelve (12) month total. By the end of each month a new
twelve-month total shall be calculated based on the previous twelve months' data. The
permit holder shall calculate emissions each month and keep a compliance record on site or
at a local field office with site responsibility, for Division review. This rolling twelve-month
total shall apply to all permitted emission units, requiring an APEN, at this facility.
AIRS ID: 123/0444
Page 2 of 8
Public Health and Environment
Air Pollution Control Division
8. The owner or operator shall track emissions from all ins'gnificant activities at the facility on
an annual basis to demonstrate compliance with the facility emission limitations as seen
below. An inventory of each insignificant activity and associated emission calculations shall
be made available to the Division for inspection upon request. For the purposes of this
condition, insignificant activities shall be defined as any activity or equipment, which emits
any amount but does not require an Air Pollutant Emission Notice (APEN).
Total emissions from the facility, including permitted emissions and insignificant activities,
shall not exceed:
• 100 tons per year of any criteria pollutant
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 iri this permit (Reference: Regulation No.3, Part B, Section III.E.)
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
FLR-1
007
Open flare
VOC HAP
PROCESS LIMITATIONS AND RECORDS
10. This source shall be limited to the following maximum processing rates as listed below.
Annual records of the throughput shall be maintained by the applicant and made available to
the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4)
Process/Consumption Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual
Limit
Monthly Limit
(31 days)
FLR-1
007
Natural gas flaring
258
MMSCF/yr
21.9
MMscf/month
The owner or operator shall calculate monthly process rates based on the calendar month.
During the first twelve (12) months of operation, compliance with both the monthly and
annual throughput limitations is required. After the first twelve (12) months of operation,
compliance with only the annual limitation is required.
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
11. 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)
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.)
AIRS ID: 123/0444 Page 3 of 8
f Public Health and Environment
Air Pollution Control Division
13. These sources are subject to the odor requirements of Regulation No. 2. (State only
enforceable)
OPERATING & MAINTENANCE REQUIREMENTS
14. Upon startup of these points, the owner or operator shall follow the most recent operating
and maintenance (O&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions
to your O&M plan are subject to Division approval prior to implementation. (Reference:
Regulation No. 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
15. The operator shall complete an initial site specific extended gas analysis of the natural gas
routed to the process flare at this site in order to verify the VOC, benzene, toluene,
ethylbenzene, xylenes and; n -hexane composition (weight %). Results of testing shall be
used to calculate site -specific emission factors for each constituent referenced above
(lb/mmscf gas flared) using Division approved methods. Results of site -specific sampling
and analysis shall be submitted to the Division as part of the self -certification and used to
demonstrate emissions are less than or equal to with the emissions factors listed in the notes
to permit holder contained in this permit for this emissions point.
16. The owner or operator shall demonstrate compliance with Condition 12 using EPA Method 9
to measure opacity from the flare. (Reference: Regulation No. 1, Section II.A.5).
ADDITIONAL REQUIREMENTS
17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3,
Part A, II.C)
a. Annually whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of
five (5) tons per year or more, above the level reported on the last APEN; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above
the level reported on the last APEN submitted to the Division.
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
c. Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
18. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall
apply to this source at any such time that this source becomes major solely by virtue of a
relaxation in any permit condition. Any relaxation that increases the potential to emit above
the applicable Federal program threshold will require a full review of the source as though
AIRS ID: 123/0444 Page 4 of 8
f Public Health and Environment
Air Pollution Control Division
construction had not yet commenced on the source. The source shall not exceed the
Federal program threshold until a permit is granted. (Regulation No. 3 Part D).
GENERAL TERMS AND CONDITIONS
19. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation No. 3, Part B, Section 11.6 upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
20. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide "final" authority for this activity or operation of this source. Final authorization of
the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self -certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self -Certify for Final Authorization
section of this permit.
21. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the applicant and is conditioned upon conduct of the activity, or construction, installation
and operation of the source, in accordance with this information and with representations
made by the applicant or applicant's agents. It is valid only for the equipment and operations
or activity specifically identified on the permit.
22. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
23. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the applicant, or the Division revokes a permit, the applicant
or owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
AIRS ID: 123/0444 Page 5 of 8
By:
Public Health and Environment
Air Pollution Control Division
Stephanie Chaousy, P.E.
Permit Engineer
Permit Histor
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Whiting Oil and Gas Corporation. Newly
permitted flare at a synthetic minor facility.
AIRS ID: 123/0444 Page 6 of 8
f Public Health and Environment
Air Pollution Control Division
Notes to Permit Holder:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees
will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of
the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3,
Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are based on
the consumption rates requested in the permit application. These limits maybe 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.cdphe.state.co.usirequlationsiairreqs/1 001 02aqcccom m onprovisionsreq.pdf.
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
Point
Pollutant
CAS #
BIN
Uncontrolled
Emission
Rate
(lb/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (lb/yr)
007
Benzene
71432
A
507
Yes
25
Toluene
108883
C
176
No
9
Ethylbenzene
100414
C
3
No
0
Xylenes
1130207
C
9
No
1
n -Hexane
110543
C
11,115
Yes
556
5) The emission levels contained in this permit are based on the following emission factors:
Point 007:
CAS #
Pollutant
Emission
Factors
Uncontrolled
Emission
Factors
Controlled
Source
NOx
0.068
lb/MMBtu
0.068 lb/MMBtu
AP -42, Table 13.5-1
CO
0.37 lb/MMBtu
0.37 lb/MMBtu
AP -42, Table 13.5-1
VOC
9872.8682
lb/MMscf
493.6434
lb/mmscf
HYSYS: Engineering
Calculation
71432
Benzene
1.9651
lb/MMscf
0.0983Ib/mmscf
HYSYS: Engineering
Calculation
108883
Toluene
0.6822
lb/MMscf
00341 lb/mmscf
.
HYSYS: Engineering
Calculation
100414
Ethylbenzene
0.0116
lb/MMscf
0.00061b/mmscf
HYSYS: Engineering
Calculation
AIRS ID: 123/0444
Page 7 of 8
f Public Health and Environment
Air Pollution Control Division
CAS #
Pollutant
Emission
Factors
Uncontrolled
Emission
Factors
Controlled
Source
1330207
Xylenes
0.0349
lb/MMscf
0.00171b/mmscf
HYSYS: Engineering
Calculation
110543
n -hexane
43,0814
lb/MMscf
2.1541 lb/mmscf
HYSYS: Engineering
Calculation
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
Requirement
Status
Operating Permit
Synthetic Minor Source:
VOC
PSD
Synthetic Minor Source:
VOC
MACT HH
Area Source Requirements: Not Applicable
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at
the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A — Subpart KKKK
NSPS
Part 60. Appendixes
Appendix A — Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A — Subpart Z
MACT
63.600-63.1199
Subpart AA — Subpart DDD
MACT
63.1200-63.1439
Subpart EEE — Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ — Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ — Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN — Subpart XXXXXX
9) An Oil and Gas Industry Construction Permit Self -Certification Form is included with this permit packet.
Please use this form to complete the self -certification requirements as specified in the permit conditions.
Further guidance on self -certification can be found on our website at:
www.colorado.gov/cdphe/oilgasperm its
AIRS ID: 123/0444
Page 8 of 8
Construction Permit Application
Preliminary Analysis Summary
Section 1 —Applicant Information
Company Name:
Whiting Oil and Gas Corporation
Permit Number:
13WE1780
Source Location:
Terrace Gas Plant
NWNE Section 18, T10N, R58W, Weld County (attainment)
Equipment Description:
Open plant flare
AIRS ID:
123-0444-007
Date:
July 15, 2013
Review Engineer:
Stephanie Chaousy, PE
Control Engineer:
Chris Laplante
—Action Completed
Grandfathered
Modification
APEN Required/Permit Exempt
X
CP1
Transfer of Ownership
APEN Exempt/Permit Exempt
Section 3 — Applicant Completeness Review
Was the correct APEN submitted for this source type?
X
Yes
No
Is the APEN signed with an original signature?
X
Yes
No
Was the APEN filled out completely?
X
Yes
No
Did the applicant submit all required paperwork?
Yes
X
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?
See Section 14
On what date was this application complete?
March 28, 2013
Section 4 — Source Description
AIRS Point
Equipment Description
007
Continuous pilot plant flare for combusting residue gas. The flare will be utilized
when the third party natural gas pipeline is not available. The flare is open and not
enclosed.
Is this a portable source?
Yes
X
No
Is this location in a non -attainment area for any criteria
pollutant?
Yes
X
No
If "yes", for what pollutant?
PM10
CO
Ozone
Is this location in an attainment maintenance area for
any criteria pollutant?
Yes
X
No
If "yes", for what pollutant?
(Note: These pollutants are subject to minor source
RACT per Regulation 3, Part B, Section III.D.2)
PM10
CO
Ozone
Is this source located in the 8 -hour ozone non -
attainment region? (Note: If "yes" the provisions of
Regulation 7, Sections XII and XVII.C may apply)
Yes
X
No
Page 1
Section 5 — Emission Estimate Information
AIRS Point
Emission Factor Source
007
Operator used AP -42, Table 13.5-1 for NOX and CO combustion of residue gas and
AP -42, Table 1.4-1 for NOX and CO pilot and igniter. Operator used HYSYS for VOC
and HAPS. See Section 14 for calculations.
Did the applicant provide actual process data for the emission inventory? X
Yes No
Basis for Potential to Emit (PTE)
AIRS Point
Process Consumption/Throughput/Production
007
258 mmscf/yr at 3,096 hr/yr
Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory)
AIRS Point ; Process Consumption/Throughput/Production
Data Year
007 1258 mmscf/yr at 3,096 hr/yr
NA
Basis for Permitted Emissions (Permit Limits)
AIRS Point
Process Consumption/Throughput/Production
007
258 mmscf/yr at 3,096 hr/yr
Does this source have a control device?
X
This source is a control device
AIRS Point
Process
Control Device Description
% Reduction Granted i
007
01
Open flare
95 J
Section 6 — Emission Summary (tons per year)
Total
HAP
Point
NO„
VOC
CO
SOx
PM10
Single
HAP
PTE:
007
9.5
1274
51.7
---
5.6
(n-hexane)
5'9
Uncontrolled point
source emission rate:
007
9.5
1274
51.7
--
---
5.9
(n -hexane)
5.9
Controlled point
source emission rate:
007
9.5
63.7
51.7
--
---
Q'3
(n -hexane)
0.3
Section 7 — Non -Criteria / Hazardous Air Pollutants
Pollutant
FUncontrolled
CAS #
BIN
Emission Rate
(Ib/yr)
e
emiarssionsthe
reportable?
f, Controlled Emission
Rate (Ib/yr)
Benzene
71432
A
507
Yes
25
Toluene
108883
C
176
No
9
Ethylbenzene
100414
C
3
No
0
Xylenes
1130207
C
9
No 1
n -Hexane
110543
C
11,115
Yes 556
Note: Regulation 3, Part A, Section II.B.3.b APEN emission reporting requirements for non -criteria air
pollutants are based on potential emissions without credit for reductions achieved by control
devices used by the operator.
Section 8 —Testing Requirements
Will testing be required to show compliance with any emission rate or regulatory
standard?
Yes X No
If "yes", complete the information listed below
AIRS Point I 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 point classification?
True
Minor
X
Synthetic
Minor
Major
What is this facility classification?
True
Minor
X
Synthetic
Minor
Major
Classification relates to what programs?
X
Title V
X
PSD
NA NSR
X
MACT
Is this a modification to an existing permit?
Yes
X
No
If "yes" what kind of modification?
Minor
Synthetic
Minor
Major
Section 10 — Public Comment
Does this permit require public comment per CAQCC Regulation 3?
X
Yes
No
If "yes", for which pollutants? Why? VOC
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.iii (subject to MACT)?
Yes
X
No
For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)?
X
Yes
No
Section 11 —Modeling
Is modeling required to demonstrate compliance with National Ambient
Air Quality Standards (NAAQS)?
If "yes", for which pollutants? Why?
Yes
X
No
AIRS Point
Section 12 — Regulatory Review
'Regulation'x1"- Particul"ate„`Smoke: Carbon Mori kid"e and Sulf ra Dioxide
007
Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or
operator of a source shall allow or cause the emission into the atmosphere of any air
pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive
opacity readings taken at 15 -second intervals for six minutes. The approved reference test
method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix
A (July, 1992)) in all subsections of Section II. A and B of this regulation.
Section II.A.5 - Smokeless Flare or Flares for the Combustion of Waste Gases No owner
or operator of a smokeless flare or other flare for the combustion of waste gases shall
allow or cause emissions into the atmosphere of any air pollutant which is in excess of
30% opacity for a period or periods aggregating more than six minutes in any sixty
consecutive minutes.
.Recitation 2 r. Odd`r`: t
007
Section I.A - No person, wherever located, shall cause or allow the emission of odorous
air contaminants from any single source such as to result in detectable odors which are
measured in excess of the following limits: For areas used predominantly for residential or
commercial purposes it is a violation if odors are detected after the odorous air has been
diluted with seven (7) or more volumes of odor free air.
Page 3
"-'
Regulation 3 - APENs. ConstructionPermits, Operating Permits, PSD: :t ' i A
007
Part A-APEN Requirements
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
criteria pollutants)
007
Part B - Construction Permit Exemptions
Applicant is required to obtain a permit since uncontrolled VOC emissions from this
facility are greater than the 5.0 TPY threshold (Reg. 3, Part B, Section Il.D.3.a)
Regulation 6 - New Source Performance Standards ,. „ ,;;...,,, .:. K..
007
None
Regulation 7 —Volatile Organic'Compounds .
007
None
Regulation 8 — Hazardous Air Pollutants ;„..." _ r 'C me
007
None
Section 13 — Aerometric Information Retrieval System Coding Information
Point
Process
Process Description
Emission
Factor
Pollutant /
CAS #
Fugitive
(Y/N)
Emission Factor
Source
Control
(%)
007
9872 8682
Ib/MMscf
VOC
No
HYSYS-
Engineering
Calculation
95
0.068
ib/MMBtu
NOx
No
AP -42,
Table 13.5-1
0
• 0.37
lb/MMBtu
CO
No
AP -42,
Table 13.5-1
0
1.9651 Ib/MMscf
Benzene
No
HYSYS-
Engineering
Calculation
95
01
Flare
0.6822
lb/MMscf
Toluene
No
HYSYS-
Engineering
Calculation
95
0.0116
lb/MMscf
Ethlybenzene
No
HYSYS-
Engineering
Calculation
95
0.0349
lb/MMscf
Xylenes
No
HYSYS-
Engineering
Calculation
95
43.0814
Ib/MMscf
n -hexane
No
HYSYS-
Engineering
Calculation
95
SCC 131000205 -Flares
Page 4
Section 14 — Miscellaneous Application Notes
AIRS Point
A permit will be issued because uncontrolled VOC emissions are greater than 5 TPY since source is in
attainment Weld County.
I sent the operator some questions on the application on 7/15/13, and received response on 7/17/13:
1. I was looking at the calculation sheets, and it looks like the flare has reportable emissions for n -
hexane and benzene. The calculation sheet did not tabulate n -hexane, but if it is 15.7 TPY, it calculates
to 31448.4 lb/yr and benzene is calculated to 538 lb/yr. This is not addressed on the APEN. I believe the
supplemental APEN sheet for non -criteria pollutants is necessary. Please fill it out and email it me when
you are done. Because the emissions from the flare are not controlled, would this make this major for
HAPS since n -hexane is greater than 10 TPY? Yes, you are correct; both benzene and n -hexane are
above the reporting thresholds for non -criteria pollutants (benzene was identified as such in the
application, but n -hexane was not). Attached is the APEN addendum for the flare. The uncontrolled n -
hexane is 5.9 tpy (it would be 15.7 tpy if operated 8760 hr/yr). In addition, I noted that the residue gas
flow as modeled by HYSYS should be 2.0 MMscfd (not 2.5 MMscfd which is the overall inlet flow to the
plant) and I have adjusted the emissions calculations accordingly. This affects values listed in the APEN
Form APCD-200, too, so 1 have attached a redline version for your use. I have also attached updated
emissions and the facility -wide emissions Form APCD-102.
2. And if you could explain Tom how you got the VOC emissions. The HYSYS calculation sheet is
showing a high VOC emission number (3603 TPY). Not sure where that is coming from compared to
what is on the APEN of 27.1 TPY. From the HYSYS modeling (see material stream labeled "To Sales
this is the gas that would be flared [see attached HYSYS excerpt from the 3/28/2013 application]), the
uncontrolled (vented) VOC is 822.7 lb/hr (which amounts to 1353 tpy @ 3288 hr/yr; it would be 3603 tpy if
operated 8760 hr/yr). Upon flaring with 98% control, the VOC emissions are 27.1 tpy.
I wrote the operator back on 7/18/13 that the Division does not accept 98% control from flares, and asked
if the flare was enclosed or open. This change in VOC emissions triggered synthetic minor status for this
facility. This permit will require public comment.
Operator used AP -42 emission factors for NOX and CO: Table 1.4-1 for the potential emissions from the
pilot and igniter and Table 13.5-1 from the combustion of residue gas and then the two emissions were
summed together: The emissions from the pilot and igniter were minimal, most of the emissions came
from the combustion of residue gas.
NOx = 100 lb/mmscf (Table 1.4-1) and 0.068 lb/mmbtu (Table 13.5-1)
CO = 84 lb/mmscf (Table 1.4-1) and 0.037 lb/mmbtu (Table 13.5-1)
003
Flare
NOx = 0.068 lb 1083 btu 258 mmscf 1 T
mmbtu scf yr 2000 lb
= 9.50 TPY
CO = 0.37 lb 1083 btu 258 mmscf 1 T = 51.69 TPY
mmbtu scf yr 2000 lb
VOC and HAPS were calculated using HYSYS ("To Sales" Stream):
VOC = 1273.6 * 2000/258 = 9872.8682 lb/mmscf
Benzene = (507 lb/yr) / 258 mmscf/yr = 1.9651 lb/mmscf
Toluene = (176 lb/yr) / 258 mmscf/yr = 0.6822 lb/mmscf
Ethylbenzene = (3 lb/yr) / 258 mmscf/yr = 0.0116 lb/mmscf
Xylenes = (9 lb/yr) / 258 mmscf/yr =0.0349 lb/mmscf
n -hexane = (11115 lb/yr) / 258 mmscf/yr = 43.0814 lb/mmscf
Page 5
AIRS Point
003
Flare continued
The gas analysis used in the HYSYS was an average of 8 wells entering into the Terrace gas plant
(composite of representative wet gas samples from Whiting's Redtail well sites). Dates were not provided
on the gas analyses so I am not sure when these were sampled. An updated extended gas analysis will
be required because I do not know the actual sample dates of the average and want to make sure the
emissions are within the permitted limits.
I sent the operator a bunch of questions on 7/18/13:
1. Thank you for your emails. Is this flare enclosed or not? Also, even though we know
manufacturers guarantee 95%+ on control, the division will only permit 95% control destruction
efficiency. Unless it can be tested, (and if it is open, that is impossible), 95% is more of a
guarantee and the last thing we want to do is write a permit that you will be out of compliance
with before you get it. The Division has a lot of testing data that shows these flares meet closer
to 95%. I can put in the permit "with a minimum destruction efficiency of 95%". By doing this, the
permittable VOC emissions should be 67.7 TPY VOC. This would also mean that the controlled
benzene would be 27 lb/yr. When I calculated n -hexane, I got a little higher number (3.6*3288) =
11837 lb/yr uncontrolled and 592 lb/yr controlled at 95%. On 7/19/13, the operator wrote back:
The flare will be open. I've attached the. revised calculations and emission factors for the flare
with 95% control and keeping VOC emissions just under 100 tpy; this equates to flaring 258
MMscf/yr of residue gas.
2. This also shows that technically the uncontrolled VOC emissions from this flare will be 1353 TPY,
making this facility synthetic minor (which you did acknowledge in the revised Form 102). The
VOC is being controlled to 67.7 TPY. Fortunately this facility is still controlled under the 100 TPY
threshold, but it is very close. I calculated permittable emissions of 95.8 TPY for VOC and 93.6
TPY for CO. The insignificant tracking condition will probably be in this permit, and this permit
will require public comment as well. Operator provided new calculation sheets on 7/19/13.
3. So, since the uncontrolled VOC would 1323 TPY, that should be listed under the "uncontrolled"
on the APEN, and then 67.7 TPY under the "controlled" part VOC (no controlled emissions under
NOx and CO). Operator provided a new APEN for redlining on 7/19/13.
4. Also, the emission factor tweaked a little bit with the higher n -hexane:
11837/274 = 43.2007 lb/mmscf. Operator responded on 7/19/13: The difference in n -hexane is
due to rounding.
5. The VOC emission factor listed on the revised APEN actually the controlled emission factor. The
uncontrolled emission factor is: VOC = 1323 * 2000/274 = 9656.9343 lb/mmscf
I think this is what should be on the APEN, as well as 95% in the control column. Operator
provided a new APEN for redlining on 7/19/13 reflecting this change.
6. Also; do you have a copy of the gas analysis used in the HYSYS? I would like to confirm it was
what was used in the HYSYS as well as the date of the sample. Operator provided a gas
analysis on 7/19/13.
Page 6
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Section 02 —R
Information
Section 01— Administrati
Request for NEW permit or newly reported emission source
Whiting Oil and Gas Corporation
Company Name
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Section 07 — Emissions Inventory Information & Emission Control Information
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VOC CLAY T5 h„ cirjyo 1fifi�'('L.} lb/MMscf 27.0&\a q (O'3.'� HYSYS v7.3
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July 19, 2013
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