HomeMy WebLinkAbout20132039.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
July 24, 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
RECEIVED
JUL 302013
WELD COMMISSIONERS
On July 28, 2013, the Air Pollution Control Division will publish a public notice for Whiting Oil and Gas
Corporation — Wolf 35-2623H & Wolf 35-2613H Pad, in the The Greeley Tribune. A copy of this public
notice and the public comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public
copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet
must be available for public inspection for a period of thirty (30) days from the date the public notice is
published. Please send any comment regarding this public notice to the address below.
Colorado Dept. of Public Health & Environment
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
lie cifimi 715113
CC? FL, tit_,BA)
-7(31
2O13 -2O39
STATE OF COLORADO
John W. Hickenlooper, Governor
Kahn 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 80246-153O
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
Colorado Department
of Public Health
and Environment
Website Title: Whiting Oil and Gas Corporation — Wolf 35-2623H & Wolf 35-2613H Pad — Weld County
Released To: The Greeley Tribune
On: July 24, 2013
Published: July 28, 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: Whiting Oil and Gas Corporation
Facility: Wolf 35-2623H & Wolf 35-2613H Pad
Nine Wellpad Facilities in Weld County
Weld County
Weld County
The proposed project or activity is as follows: Operator is flaring gas from the separators at these facilities when
the pipeline is offline.
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.l.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 13WE1633 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 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:
Peter Armington
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B 1
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:
12WE1529
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 Horsetail 18-0733H Pad, located in the SWSE of Section
18, Township 10N, Range 57W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment ID
AIRS
Point
Description
TK-1,TK-2,TK-3
002
Three (3) 400 BBL fixed roof storage tanks used to store crude
oil. Emissions from these tanks are controlled by a 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 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, II.G.2).
3, This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction fora period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
AIRS ID: 123/9808/002 Page 1 of 7
Condensate Tank SM/M Version 2012-1
Colorado Department of Public Health and Environment
Air Pollution Control Division
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 following information shall be provided to the Division within fifteen (15) days after
issuance of permit.
• manufacturer
• model number
• serial number
This information shall be included with the Notice of Startup submitted for the equipment.
(Reference: Regulation No. 3, Part B, III.E.)
5. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
a 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
Equipment ID
AIRS
Point
Tons per Year
Emission Type
NO
NO,
VOC
CO
TK-1,TK-2,TK-3
002
---
1.75
---
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.
The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
Facility
Equipment ID
AIRS Point
Control Device
Pollutants
Controlled
TK-1,TK-2,TK-3
002
Flare
VOC
PROCESS LIMITATIONS AND RECORDS
AIRS ID: 123/9808/002
Page 2 of 7
Colorado Department of Public Health and Environment
Air Pollution Control Division
8. 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
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
TK-1,TK-2,TK-3
002
Oil throughput
160,600
BBUyr
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
9. 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 Number3, Part B, III.E.)
(State only enforceable)
10. 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.
11. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable)
OPERATING & MAINTENANCE REQUIREMENTS
12. Upon startup of these points, the owner or operator shall follow the most recent operating
and maintenance (O&M) plan and record keeping format approved by the Division, in order
to demonstrate compliance on an ongoing basis with the requirements of this permit.
Revisions to your O&M plan are subject to Division approval prior to implementation.
(Reference: Regulation No. 3, Part B, Section III.G.7.)
ADDITIONAL REQUIREMENTS
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
AIRS ID: 123/98O8/002
Page 3 of 7
Colorado Department of Public Health and Environment
Air Pollution Control Division
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above
the level reported on the last APEN submitted to the Division.
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
c. Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
14. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit)
shall apply to this source at any such time that this source becomes major solely by virtue of
a relaxation in any permit condition. Any relaxation that increases the potential to emit
above the applicable Federal program threshold will require a full review of the source as
though construction had not yet commenced on the source. The source shall not exceed
the Federal program threshold until a permit is granted. (Regulation No. 3 Part D).
15. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil and
Natural Gas Production Facilities major stationary source requirements shall apply to this
stationary source at any such time that this stationary source becomes major solely by virtue
of a relaxation in any permit limitation and shall be subject to all appropriate applicable
requirements of Subpart HH. (Reference: Regulation No. 8, Part E)
GENERAL TERMS AND CONDITIONS
16. 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.
17. 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.
18. 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.
19. 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.
AIRS ID: 123/9808/002 Page 4 of 7
Colorado Department of Public Health and Environment
Air Pollution Control Division
20. 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.
21. 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.
22. 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:
Peter Armington
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Whiting Oil and Gas Corporation
AIRS ID: 123/9808/002
Page 5 of 7
Colorado Department of Public Health and Environment
Air Pollution Control Division
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees
will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of
the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3,
Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are based on
the consumption rates requested in the permit application. These limits may be revised upon request of
the owner or operator providing there is no exceedance of any specific emission control regulation or any
ambient air quality standard. A revised air pollution emission notice (APEN) and complete application
form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any
malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon
as possible, but no later than noon of the next working day, followed by written notice to the Division
addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See:
http://www.cd phe. state.co. us/req ulations/airreqs/100102agcccommon provisionsreq. 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
(Ib/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (Ib/yr)
002
Benzene
71432
A
181
Yes
9
Hexane
110543
C
1,118
Yes
56
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Emission Factors
Uncontrolled
lb/BBL Oil
Throughput
Emission Factors
- Controlled
lb/BBL Oil
Throughput
Source
VOC
0.437
0.022
HYSYS & EPA
Tanks
110543
n -Hexane
0.0070
0.00035
HYSYS & EPA
Tanks
71432
Benzene
0.0011
0.000055
HYSYS & EPA
Tanks
Note: The controlled emissions factors for point 002 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:
AIRS ID: 123/9808/002
Page 6 of 7
Colorado Department of Public Health and Environment
Air Pollution Control Division
Applicable
, Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC. n -hexane
PSD
Synthetic Minor Source of: VOC
MACT HH
Area Source Requirements: Not Applicable
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at
the website listed below:
http://ecfr.gboaccess.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:
littp://www.cdphe.state.co.us/apioilqaspermittinq.html
AIRS ID: 123/9808/002 Page 7 of 7
Construction Permit Application
Preliminary Analysis Summary
Section 1 — Applicant Information
Company Name:
Whiting Oil and Gas Corporation
Permit Number:
12WE1529
Source Location:
SWSE Sec 18 T10N R57W
Equipment Description:
Three (3) 400 bbl crude oil tanks
AIRS ID:
123/9808/002
Date:
6/1/2013
Review Engineer:
Peter Armington
Control Engineer:
Carissa Money
Section 2 — Action Completed
Grandfathered
Modification
APEN Required/Permit Exempt
X
Initial Approval
I 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 17, 2013
Section 4 — Source Description
AIRS Point I Equipment Description
002 I Three (3) above ground 400 bbl atmospheric condensate storage tank
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
002
Source may provide site -specific emission factors using gas sample and E&P
Tanks. Will need to calculate emission factors from E&P Tanks.
Emission factor calculations are found in the 4/12/2012 application for permit -exempt
status for this site.
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
002
160,600 BBL per year
Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory)
AIRS Point
Process Consumption/Throughput/Production
Data Year
002
160,600 BBL per year
2012
Basis for Permitted Emissions (Permit Limits)
AIRS Point
Process Consumption/Throughput/Production
002
160,600 BBL per year
Does this source use a control device?
X
Yes
No
AIRS Point
Process
Control Device Description
% Reduction
Granted
002
01
Flare
95
Section 6 — Emission Summary (tons per year)
Point
NO,
VOC
CO
Single HAP
Total HAP
PTE:
002
35.1
0.56 (Hexane)
0.65
Uncontrolled point
source emission rate:
002
35.1
0.56 (Hexane)
0.65
Controlled point
source emission rate:
002
1.75
0.03 (Hexane)
0.03
Total APEN Reported
emissions:
002
1.75
0.03 (Hexane)
0.03
Section 7 — Non -Criteria / Hazardous Air Pollutants
Pollutant
CAS #
BIN
Uncontrolled
Emission Rate
(lb/yr)
Are the
emissions
reportable?
Controlled Emission
Ib! r
Rate ( y )
Benzene
71432
A
181
Yes
9
n -Hexane
110543
C
1,118
Yes
56
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.
Uncontrolled HAP emission rates taken from previous APEN filing.
Section 8 —Testing Requirements
Will testing be required to show compliance with any emission rate or regulatory
standard?
Yes
X
No
Page 2
Section 9 — Source Classification
Is this a new previously un-permitted source?
X i Yes
No
What is this facility classification?
True
Minor
X
Synthetic
Minor
Major
Classification relates to what programs?
X
Title V
X
PSD
I NA NSR
X
MACT
Is this a modification to an existing permit? I1Yes
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?
Yes
X
No
If "yes", for which pollutants? Why?
For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)?
Yes
X
No
For Reg. 3, Part B, III.C.1.c.ii (subject to MACT)?
Yes
X
No
For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)?
Yes
X
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 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide
002
Section Il.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.
Regulation 2 — Odor '
002
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.
Regulation 3 - APENs, Construction Permits, Operating Permits, PSD_
002
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 VOC)
002
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 II.D.3.a)
Regulation 6.- New Source Performance Standards
Page 3
002
NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84.
Is this source greater than 19,800 gallons (471 bbl)? No
Is this, source subject to NSPS Kb? No
Regulation 7 - Volatile Organic Compounds
002
Tanks contain crude oil; Regulation 7 does not apply.
Regulation 8 — Hazardous Air Pollutants
002
MACT EEEE: Organic Liquids Distribution
Pick one:
• This source is not subject to MACT EEEE because it is not located at a major
source of HAP,
002
MACT HH
Pick one:
• This source is not subject to MACT HH because it is not located at a major source
of HAP.
Section 13 — Aerometric Information Retrieval System Coding Information
Point
Process
Process
Description
Emission
Factor
Pollutant /
CAS #
Fugitive
(Y/N)
Emission Factor Source
Control
(%)
002
01
E&P Oil StorageBenzene
Tanks
10.4
lb/1000 gal
throughput
VOC
No
' HYSYS & EPA Tanks
95
0.0262
lb/1000 gal
throughput
/
71432
No
HYSYS & EPA Tanks
95
0.167
lb/1000 gal
throughput
n -Hexane
/ 110543
No
HYSYS & EPA Tanks
95
SCC
40400311 — Fixed Roof Tank, Condensate, working+breathing+flashing losses
Section 14 — Miscellaneous Application Notes
AIRS Point
002
Condensate Storage Tanks
A permit will be issued because the uncontrolled VOC emissions are greater than 2 TPY (APEN
threshold).
This source is not located in the 8 -hour ozone non -attainment area (this part of Weld County is in
attainment). The statewide requirements of Regulation 7 do not currently apply to this source because it
stores crude oil.
Page 4
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO: 131111E1625
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 Chalk Bluffs 36-13H Pad, located in the SWNW of Section
36, Township 10N, Range 60W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
Sep -1
004
Separator controlled by a 30' flare stack. Flare has a minimum
combustion efficiency of 95%. The flare is not enclosed,
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR
QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED
IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen
days after issuance of this permit, by submitting a Notice of Startup form to the
Division. The Notice of Startup form may be downloaded online at
www.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, II.G.2).
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction for a period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
AIRS ID: 123/9289/004 Page 1 of 8
Wellhead Version 2012-1
I
f Public Health and Environment
Air Pollution Control Division
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 except fugitive emissions from
equipment leaks 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
Equipment ID
AIRS
Point
Tons per Year
Emission Type
NO,
VOC
CO
Sep -1
004
5.9
78.9
11.7
Point
See "Notes to Permit Holder #4" for information on emission factors and methods used to caicuia
limits.
Facility -wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy.
Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from
each emission unit, on a rolling twelve (12) month total. By the end of each month a new
twelve-month total shall be calculated based on the previous twelve months' data. The
permit holder shall calculate emissions each month and keep a compliance record on site or
at a local field office with site responsibility, for Division review. This rolling twelve-month
total shall apply to all permitted emission units, requiring an APEN, at this facility.
8. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
AIRS ID: 123/9289/004 Page 2 of 8
"vf Public Health and Environment
Air Pollution Control Division
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
Sep -1
004
Separator controlled by a 30' flare stack
VOC
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
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
Sep -1
004
Natural gas flaring
41.98 MMSCF/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.
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)
OPERATING & MAINTENANCE REQUIREMENTS
14. Upon startup of these points, the applicant shall follow the operating and maintenance
(O&M) plan and record keeping format approved by the Division, in 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
AIRS ID: 123/9289/004 Page 3 of 8
f Public Health and Environment
Air Pollution Control Division
15. 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).
16. The operator shall complete an initial site specific extended gas analysis of the natural gas
produced at this site in order to verify the VOC, benzene, toluene, ethylbenzene, xylenes,
and n -hexane 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. Results of site -specific sampling and analysis shall be
submitted to the Division as part of the self -certification and used to demonstrate compliance
with the emissions factors chosen for this emissions point.
17. Within one hundred and eighty days (180) after issuance of this permit, the operator shall
complete a hard count of components at the source and establish the number of
components that are operated in "heavy liquid service", "light liquid service", "water/oil
service" and "gas service". The operator shall submit the results to the Division as part of
the self -certification process to ensure compliance with emissions limits.
Periodic Testing Requirements
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 or Title V Operating Permit)
shall apply to this source at any such time that this source becomes major solely by virtue of
a relaxation in any permit condition. Any relaxation that increases the potential to emit
above the applicable Federal program threshold will require a full review of the source as
though construction had not yet commenced on the source. The source shall not exceed
the Federal program threshold until a permit is granted. (Regulation No. 3 Part D).
AIRS ID: 123/9289/004 Page 4 of 8
f Public Health and Environment
Air Pollution Control Division
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.
By:
Peter Armington
AIRS ID: 123/9289/004 Page 5 of 8
Permit Engineer
f Public Health and Environment
Air Pollution Control Division
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Whiting Oil and Gas Corporation
AIRS ID: 123/9289/004 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 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.cdphe.state.co.us/req u lations/airreqs/1 001 02aacccommon provis ionsreq. 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
(Ib/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (Ib/yr)
004
Benzene
71432
A
2,679
Yes
134
Toluene
108883
C
3,364
Yes
168
n -Hexane
110543
C
22,692
Yes
1,135
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Weight
Percent of
Gas
Emission
Factors
Uncontrolled
Emission
Factors
Controlled
Source
NOx
0.138
Ib/MMBtu
0.138
lb/MMBtu
TCEQ
CO
0.2755
Ib/MMBtu
0.2755
lb/MMBtu
TCEQ
VOC
79.1
75,375
lb/MMscf
3,769
lb/MMscf
Engineering
Calculation
71432
Benzene
0.067
63.9 Ib/MMscf
3.19
Ib/MMscf
Engineering
Calculation
108883
Toluene
0.083
80.2 Ib/MMscf
4.01
lb/MMscf
Engineering
Calculation
110543
n -hexane
0.569
541 lb/MMscf
27 lb/MMscf
Engineering
Calculation
Note: The uncontrolled VOC and HAP emissions for this point were calculated using the 6/29/2011
analysis of a gas sample collected from the Chalk Bluffs 36-13H well. The controlled VOC and HAP
emissions factors for point 004 are based on the flare control efficiency of 95%.
AIRS ID: 123/9289/004
Page 7 of 8
f Public Health and Environment
Air Pollution Control Division
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this
permit is valid for a term of five years from the date it was received by the Division. A revised APEN
shall be submitted no later than 30 days before the five-year term expires. Please refer to the most
recent annual fee invoice to determine the APEN expiration date for each emissions point associated
with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-
3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, n -hexane
PSD
Synthetic Minor Source of: VOC
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at
the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A — Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A —Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A — Subpart Z
MACT
63.600-63.1199
Subpart M — Subpart DDD
MACT
63.1200-63.1439
Subpart EEE — Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ — Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ — Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN — Subpart 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:
http://www.cdphe.state.co.us/ap/oilciaspermitting.html
AIRS ID: 123/9289/004 Page 8 of 8
Produced Natural Gas Venting/Flaring Preliminary Analysis
Division information
Engineer:
Peter Armington
Control Engineer:
Carissa Money
Review Date:
05/01/2013
Application Date:
01/17/2013
Facility Information
Permit No.
13WE1625
AIRs
Coun #
Facility #
123 Weld
9289
004
SEP-1
Whiting Oil and Gas Corporation
Chalk Bluffs 36-13H Pad
SWNW Sec 36 T10N R60W
Point #
Facility Equipment ID
Company Name:
Colorado Department of Public Health and Environment
Air Pollution Control Division
Attainment Status
PM10
Attainment
PM2.5
Attainment
SOx
Attainment
NOx
Attainment
VOC
Attainment
CO
Attainment
Potentially Located within EAC - determine attainment status of NC
Source Name:
Source Location:
SIC:
1311
5230
Elevation (feet)
x
New Permit
(CPI)
Modification
(Issuance #)
APEN
Required/Permit
FxAmnt
Transfer of
Ownership
APEN
Exempt/Permit
Fxemnt
Notes
Equipment Description
This source vents natural gas from:
a well head separator
Emissions from this source are:
routed to an open -flame flare
Natural gas venting from a well head separator. Emissions from this source are routed to an open -
flame flare.
Emission Calculation Method
EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3)
Ex= Q*MW*Xx1C
Ex = emissions of pollutant x
Q = Volumetric flow rate/volume of gas processed
MW = Molecular weight of gas = SG of gas * MW of air
Xx = mass fraction of x in gas
C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm
Throughput (O)
MW
42 MMscf/yr
36.120 Ib/Ib-mol
4792.2 scf/hr
0.001 MMscf/d
3.57 MMscf/mo
mole %
MW
lbx/Ibmol
mass fraction
E
Iblhr
lb/yr
tpy
Helium
0
4.0026
0.000
0.000
Helium
0.0
0
0.00
CO2
1.156
44.01
0.509
0.014
CO2
6.4
56352
28.18
N2
0.594
28.013
0.166
0.005
N2
2.1
18431
9.22
methane
32.684
16.041
5.243
0.145
methane
66.3
580724
290.36
ethane
5.438
30.063
1.635
0.045
ethane
20.7
181082
90.54
propane
51.45
44.092
22.6853
0.628
propane
286.8
2512745
1256.37
isobutane
0.614
58.118
0.3568
0.010
isobutane
4.5
39526
19.76
n -butane
2.683
58.118
1.5593
0.043
n -butane
19.7
172717
86.36
isopentane
3.119
72.114
2.2492
0.062
isopentane
28.4
249137
124.57
n -pentane
0.834
72.114
0.6014
0.017
n -pentane
7.6
66618
33.31
cyclopentane
0
70.13
0.0000
0.000
cyclopentane
0.0
0
0.00
n -Hexane
0.2380
86.18
0.2051
0.006
n -Hexane
2.6
22719
11.36
cyclohexane
0.0650
84.16
0.0547
0.002
cyclohexane
0.7
6059
3.03
Other hexanes
0.552
86.18
0.4757
0.013
Other hexanes
6.0
52692
26.35
heptanes
0.243
100.21
0.2435
0.007
heptanes
3.1
26972
13.49
methylcyclohexane
0.004
98.19
0.0039
0.000
methylcyclohexane
0.0
435
0.22
224-TMP
0
114.23
0.0000
0.000
224-TMP
0.0
0
0.00
Benzene
0.031
78.12
0.0242
0.001
Benzene
0.3
2682
1.34
Toluene
0.033
92.15
0.0304
0.001
Toluene
0.4
3368
1.68
Ethylbenzene
0
106.17
0.0000
0.000
Ethylbenzene
0.0
0
0.00
Xylenes
0
106.17
0.0000
0.000
Xylenes
0.0
0
0.00
Produced Natural Gas Venting/Flaring Preliminary Analysis
Colorado Department of Public Health and Environment
Air Pollution Control Division
IC8+ Heavies I 0.2621 29.5571 0.0774 I 0.002 IC8+ Heavies I 1.0 I 8578
VOC mass fraction: 0.7909 Total VOC Emissions (Uncontrolled)
36.120 annual limit assuming 95% control
Notes monthly limit assuming 95% control (Ib/mo.)
Mole %, MW, and mass fractions from the Chalk Bluffs 36-13H gas analysis, dated 6/29/11.
Emissions are based on 8760 hours of operation per year.
I calculated the average MW of C8+ based on the average MW on the analysis for the gas.
4.29
1582.1
79.1
13437.2
♦ y
Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment
Air Pollution Control Division
Flaring Information
Equipment Description
Flare to combust produced gas until pipeline is available at this wellhead facility.
Manufacturer
TBD
Model
TBD
Serial Number
TBD
Gas Heating Value
2021.4
Btu/scf
Throughput
84858.372
MMBtu/yr
Combustion emission factor source: TCEQ
0.138
lb NOX/MMBtu
tpy NOX
0.2755
lb CO/MMBtu
tpy CO r
5.86
Emissions Summary
11,69
5.86
tpy NOX
Uncontrolled/PTE
11.69
tpy CO
1582.124
tpy VOC
Controlled
79.106
tpy VOC
Uncontrolled
Total (Ib/yr)
Bin
Scenario A
Reportable?
Controlled
Total (lb/yr)
Benzene
2682
A
Yes
134
Toluene
3368
C
Yes
168
Ethylbenzene
0
C
No
0
Xylenes
0
C
No
0
n -hexane
22719
C
Yes
1136
224-TMP
0
C
No
0
Regulatory Applicability
AQCC Regulation 1 _
This source is subject to the opacity requirements for flares in Section II.A.5:'No owner or operator
of a smokeless flare or other flare for the combustion of waste gases shall allow or cause
emissions into the atmosphere of any air pollutant which is in excess of 30% opacity.'
AQCC Regulation 2 _
Section I.A applies to all emission sources. "No person, wherever located, shall cause or allow the
emission of odorous air contaminants from any single source such as to result in detectable odors
which are measured in excess of the following limits: For areas used predominantly for residential
or commercial purposes it is a violation if odors are detected after the odorous air has been diluted
with seven (7) or more volumes of odor free air."
AQCC Regulation 3
Part A:
An APEN is required for this source because uncontrolled VOC emissions
exceed two tons per_year in an attainment area.
Part B:
A permit is required for this source because uncontrolled VOC emissions from
this facility exceed five tons per year in an attainment area.
This source is not subject to Section 111.0.2 (Minor Source RACT) because it
is not located in a nonattainment area.
Is public comment
required?
Public Comment Required
Facility Status
This facility is a synthetic minor source of VOC/HAP for Title V applicability.
This facility is a synthetic minor source of VOC for PSD applicability.
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO: 13WE1627
DATE ISSUED:
ISSUED TO:
Issuance 1
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 Horsetail 18-0733H Pad, located in the SWSE of Section
18, Township 10N, Range 57W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
Sep -1
007
Separator controlled by a 30' flare stack. Flare has a minimum
combustion efficiency of 95%. The flare is not enclosed.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR
QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED
IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen
days after issuance of this permit, by submitting a Notice of Startup form to the
Division. The Notice of Startup form may be downloaded online at
www.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, II.G.2).
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction fora period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
AIRS ID: 123/9808/007 Page 1 of 8
Wellhead Version 2012-1
f Public Health and Environment
Air Pollution Control Division
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 except fugitive emissions from
equipment leaks 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
Equipment ID
AIRS
Point
Tons per Year
Emission Type
yp
NO,
VOC
CO
Sep -1
007
9.3
76.6
18.5
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.
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
twelve-month total shall be calculated based on the previous twelve months' data. The
permit holder shall calculate emissions each month and keep a compliance record on site or
at a local field office with site responsibility, for Division review. This rolling twelve-month
total shall apply to all permitted emission units, requiring an APEN, at this facility.
8. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
AIRS ID: 123/9808/007 Page 2 of 8
f Public Health and Environment
Air Pollution Control Division
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
Sep -1
007
Separator controlled by a.30' flare stack
VOC
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
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
Sep -1
007
Natural gas flaring
86.87 MMSCF/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.
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)
OPERATING & MAINTENANCE REQUIREMENTS
14. Upon startup of these points, the applicant shall follow the operating and maintenance
(O&M) plan and record keeping format approved by the Division, in 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
AIRS ID: 123/9808/007 Page 3 of 8
1•
ment. f Public Health and Environment
Air Pollution Control Division
15. 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).
16. The operator shall complete an initial site specific extended gas analysis of the natural gas
produced at this site in order to verify the VOC, benzene, toluene, ethylbenzene, xylenes,
and n -hexane 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. Results of site -specific sampling and analysis shall be
submitted to the Division as part of the self -certification and used to demonstrate compliance
with the emissions factors chosen for this emissions point.
Periodic Testing Requirements
17, 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
18. 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.
19. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit)
shall apply to this source at any such time that this source becomes major solely by virtue of
a relaxation in any permit condition. Any relaxation that increases the potential to emit
above the applicable Federal program threshold will require a full review of the source as
though construction had not yet commenced on the source. The source shall not exceed
the Federal program threshold until a permit is granted. (Regulation No. 3 Part D).
GENERAL TERMS AND CONDITIONS
20. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
AIRS ID: 123/9808/007 Page 4 of 8
Public Health and Environment
Air Pollution Control Division
21. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide "final" authority for this activity or operation of this source. Final authorization of
the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self -certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self -Certify for Final Authorization
section of this permit.
22. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the 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.
23. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
24. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the 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.
25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Peter Armington
Permit Engineer
Permit Histo
Issuance
ry
Date
Description
AIRS ID: 123/9808/007
Page 5 of 8
Issuance.1
This Issuance
f Public Health and Environment
Air Pollution Control Division
Issued to Whiting Oil and Gas Corporation
AIRS ID: 123/9808/007 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 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.cdphe.state.co.us/regulations/airreqs/100102agcccommonprovisionsreq.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)
004
Benzene
71432
A
7,691
Yes
385
Toluene
108883
C
11,605
Yes
580
Xylenes
1330207
C
1,215
Yes
61
n -Hexane
110543
C
55,251
Yes
2,762
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Weight
Percent of
Gas
Emission
Factors
Uncontrolled
Emission
Factors
Controlled
Source
NOx
___
0.138
Ib/MMBtu
0.138
Ib/MMBtu
TCEQ
CO
___
0.2755
lb/MMBtu
0.2755
lb/MMBtu
TCEQ
VOC
46 95
35,271
lb/MMscf
1,763.5
lb/MMscf
Engineering
Calculation
71432
Benzene
0.118
88.6 lb/MMscf
4.43
lb/MMscf
Engineering
Calculation
108883
Toluene
0.176
133.7
lb/MMscf
6.68
lb/MMscf
Engineering
Calculation
1330207
Xylenes
0.019
14 lb/MMscf
0.70
lb/MMscf
Engineering
Calculation
110543
n -Hexane
0 847
636.7
lb/MMscf
31.8
Ib/MMscf
Engineering
Calculation
AIRS ID: 123/9808/007
Page 7 of 8
f Public Health and Environment
Air Pollution Control Division
Note: The uncontrolled VOC and HAP emissions for this point were calculated using the 2/21/2012
analysis of a gas sample collected from the Horsetail 18-0733H well. The controlled VOC and HAP
emissions factors for point 004 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
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, n -hexane
PSD
Synthetic Minor Source of: VOC
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
SubpartA— SubpartZ
MACT
63.600-63.1199
Subpart AA — Subpart DDD
MACT
63.1200-63.1439
Subpart EEE — Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ — Subpart YYYY
MACT
63.6580-63.8830
Subpart 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:
http://www.cdphe.state.co.us/ap/oilbaspermittinghtml
AIRS ID: 123/9808/007
Page 8 of 8
Produced Natural Gas Venting/Flaring Preliminary Analysis
Division Information
Engineer:
Peter Armington
Control Engineer:
Carissa Money
Review Date:
05/02/2013
Application Date:
01/17/2013
Facility Information
Permit No.
13WE1627
AIRs
County #
Facility #
9808
007
SEP-1
Whiting Oil and Gas Corporation
Horsetail 18 -0733 H P a d
SWSE Sec 18 T1 ON R57W
123 Weld
Point #
Facility Equipment ID
Colorado Department of Public Health and Environment
Air Pollution Control Division
Attainment Status
PM10
Attainment
PM2.5
Attainment
SOx
Attainment
NOx
Attainment
VOC
Attainment
CO
Attainment
Potentially Located within EAC - determine attainment status of NC
Company Name:
Source Name:
Source Location:
SIC:
1311
4802
Elevation (feet)
x
New Permit
(CPI)
Modification
(Issuance #)
APEN
Required/Permit
Fxemnt
Transfer of
Ownership
APEN
Exempt/Permit
Exemot
Notes
Equipment Description
This source vents natural gas from:
a well head separator
Emissions from this source are:
routed to an open -flame flare
Natural gas venting from a well head separator. Emissions from this source are routed to an open -
flame flare.
Emission Calculation Method
EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3)
Ex=0 MW*XxIC
Ex = emissions of pollutant x
Q = Volumetric flow rate/volume of gas processed
MW = Molecular weight of gas = SG of gas * MW of air
Xx = mass fraction of x in gas
C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm
Throughput (Q)
MW
87 MMsd/yr
28.470 Ib/Ib-mol
9916.7 scf/hr
0.002 MMscf/d
7.38 MMscf/mo
mole %
MW
Ibx/1nmol
mass fraction
E
lb/hr •
Ib/yr
tpy
Helium
0
4.0026
0.000
0.000
Helium
0.0
0
0.00
CO2
3.333
44.01
1.467
0.052
CO2
38.4
336215
168.11
N2
1.147
28.013
0.321
0.011
N2
8.4
73647
36.82
methane
56.604
16.041
9.080
0.319
methane
237.6
2081178
1040.59
ethane
14.085
30.063
4.234
0.149
ethane
110.8
970554
485.28
propane
13.967
44.092
6.1583
0.216
propane
161.1
1411541
705,77
isobutane
1.53
58.118
0.8892
0.031
isobutane
23.3
203813
101.91
n -butane
5.353
58.118
3.1111
0.109
n -butane
81.4
713080
356.54
isopentane
1.106
72.114
0.7976
0.028
isopentane
20.9
182812
91.41
n -pentane
1.31/
72.114
0.949/
0.033
n -pentane
24.9
217689
108.84
cyclopentane
0
70.13
0.0000
0.000
cyclopentane
0.0
0
0.00
n -Hexane
0.2800
86.18
0.2413
0.008
n -Hexane
6.3
55309
27.65
cyclohexane
0.0820
84.16
0.0690
0.002
cyclohexane
1.8
15818
7.91
Other hexanes
0.581
86.18
0.5007
0.018
Other hexanes
13.1
114766
57.38
heptanes
0.25
100.21
0.2505
0.009
heptanes
6.6
57422
28.71
methylcyclohexane
0
98.19
0.0000
0.000
methylcyclohexane
0.0
0
0.00
224-TMP
0
114.23
0.0000
0.000
224-TMP
0.0
0
0.00
Benzene
0.043
78.12
0.0336
0.001
Benzene
0.9
7699
3.85
Toluene
0.055
92.15
0.0507
0.002
Toluene
1.3
11617
5.81
Ethylbenzene
0
106.17
0.0000
0.000
Ethylbenzene
0.0
0
0.00
Xylenes
0.005
106.17
0.0053
0.000
Xylenes
0.1
1217
0.61
Produced Natural Gas Venting/Flaring Preliminary Analysis
Colorado Department of Public Health and Environment
Air Pollution Control Division -
IC8+ Heavies ) 0.2621 118 5401 0.3106 I 0.011 IC8+ Heavies 8.1 1 71186
VOC mass fraction: 0.4695 Total VOC Emissions (Uncontrolled)
28.470 annual limit assuming 95% control
Notes monthly limit assuming 95% control (lb/mo.)
Mole %, MW, and mass fractions from the Horsetail 18-0733H gas analysis, dated.2/21/12.
Emissions are based on 8760 hours of operation per year.
I calculated the average MW of C8+ based on the average MW on the analysis for the gas.
35.59
1532.0
76.6
13011.4
Produced Natural Gas Venting/Flaring Preliminary Analysis
Flaring Information
Eauipment DesCripfon
Flare to combust produced qas until pipeline is available at this wellhead facility.
Manufacturer
Model
Serial Number
Gas Heatingyalue
Throughput
TBD
TBD
TBD
1550
134648.5
Btu/scf
MMBtu/yr
Combustion emission factor source: TCEQ
0.138
lb NOX/MMBtu
tpy NOX
0.2755
lb CO/MMBtu
tpy CO
9.29
18.55
Emissions Summary
9.29
tpy NOX
Uncontrolled/PTE
18.55
tpy CO
1531.985
tpy VOC
Controlled
76.599
tpy VOC
Colorado Department of Public Health and Environment
Air Pollution Control Division
Uncontrolled
Total (lb/yr)
Bin
Scenario A
Reportable?
Controlled
Total (lb/yr)
Benzene
7699
A
Yes
385
Toluene
11617
C
Yes
581
Ethylbenzene
0
C
No
0
Xylenes
1217
C
Yes
61
n -hexane
55309
C
Yes
2765
224-TMP
0
C
No
0
Regulatory Applicability
AQCC Regulation 1 _
This source is subject to the opacity requirements for flares in Section II.A.5:'No owner or operator
of a smokeless flare or other flare for the combustion of waste gases shall allow or cause
emissions into the atmosphere of any air pollutant which is in excess of 30% opacity.'
AQCC Regulation 2 _
Section I.A applies to all emission sources. "No person, wherever located, shall cause or allow the
emission of odorous air contaminants from any single source such as to result in detectable odors
which are measured in excess of the following limits: For areas used predominantly for residential
or commercial purposes it is a violation if odors are detected after the odorous air has been diluted
with seven (7) or more volumes of odor free air."
AQCC Regulation 3
Part A:
An APEN is required for this source because uncontrolled VOC emissions
exceed two tons per year in an attainment area.
Part B:
A permit is required for this source because uncontrolled VOC emissions from
this facility exceed five tons per year in an attainment area.
This source is not subject to Section 111.0.2 (Minor Source RACT) because it
is not located in a nonattainment area.
Is public comment
required?
Public Comment Required
Facility Status
This facility is a synthetic minor source of VOC/HAP for Title V applicability.
This facility is a synthetic minor source of VOC for PSD applicability.
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO:
DATE ISSUED:
ISSUED TO:
13WE1628
Issuance 1
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 Pawnee 16-13H Pad, located in the NWSE of Section 16,
Township 10N, Range 59W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID.
AIRS
Point
Description
Sep -1
005
Separator controlled by a 30' flare stack. Flare has a minimum
combustion efficiency of 95%. The flare is not enclosed.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR
QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED
IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen
days after issuance of this permit, by submitting a Notice of Startup form to the
Division. The Notice of Startup form may be downloaded online at
www.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, II.G.2).
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction fora period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
AIRS ID: 123/9239/005 Page 1 of 9
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f Public Health and Environment
I Air Pollution Control Division
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 except fugitive emissions from
equipment leaks 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, lll.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
Equipment ID
AIRS
Point
Tons per Year
Emission Type
yp
NO„
VOC
CO
Sep -I
005
6.3
74.8
12.6
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.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from
each emission unit, on a rolling twelve (12) month total. By the end of each month a new
twelve-month total shall be calculated based on the previous twelve months' data. The
permit holder shall calculate emissions each month and keep a compliance record on site or
at a local field office with site responsibility, for Division review. This rolling twelve-month
total shall apply to all permitted emission units, requiring an APEN, at this facility.
8. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
AIRS ID: 123/9239/005 Page 2 of 9
f Public Health and Environment
Air Pollution Control Division
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
Sep -1
005
Separator controlled by a 30' flare stack
VOC
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
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
Sep -1
005
Natural gas flaring
49,64 MMSCF/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.
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)
OPERATING & MAINTENANCE REQUIREMENTS
14. Upon startup of these points, the applicant shall follow the operating and maintenance
(O&M) plan and record keeping format approved by the Division, in 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
AIRS ID: 123/9239/005 Page 3 of 9
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6lmentf&af Public Health and Environment
Air Pollution Control Division
15. 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).
16. The operator shall complete an initial site specific extended gas analysis of the natural gas
produced at this site in order to verify the VOC, benzene, toluene, ethylbenzene, xylenes,
and n -hexane 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. Results of site -specific sampling and analysis shall be
submitted to the Division as part of the self -certification and used to demonstrate compliance
with the emissions factors chosen for this emissions point.
Periodic Testing Requirements
17. 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
18. 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.
19. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit)
shall apply to this source at any such time that this source becomes major solely by virtue of
a relaxation in any permit condition. Any relaxation that increases the potential to emit
above the applicable Federal program threshold will require a full review of the source as
though construction had not yet commenced on the source. The source shall not exceed
the Federal program threshold until a permit is granted. (Regulation No. 3 Part D).
GENERAL TERMS AND CONDITIONS
20, This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
AIRS ID: 123/9239/005 Page 4 of 9
f Public Health and Environment
Air Pollution Control Division
21. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide "final" authority for this activity or operation of this source. Final authorization of
the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self -certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self -Certify for Final Authorization
section of this permit.
22. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the 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.
23. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
24. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the 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.
25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Peter Armington
Permit Engineer
Permit Histo
Issuance
ry
Date
Description
AIRS ID: 123/9239/005
Page 5of9
entf Public Health and Environment
Air Pollution Control Division
Issuance 1
This Issuance
Issued to Whiting Oil and Gas Corporation
AIRS ID: 123/9239/005 Page 6 of 9
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 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.cdphe.state.co. us/requlations/airregs/100102agcccommonprovisionsreg.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
(Ib/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (Ib/yr)
004
Benzene
71432
A
18,602
Yes
930
Toluene
108883
C
22,184
Yes
1,109
Ethylbenzene
100414
C
2,778
Yes
139
Xylenes
1330207
C
4,861
Yes
243
n -Hexane
110543
C
140,720
Yes .
7,036
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Weight
Percent of
Gas
Emission
Factors
Uncontrolled
Emission
Factors
Controlled
Source
NOx
___
0.138
lb/MMBtu
0.138
lb/MMBtu
TCEQ
CO
-__
0.2755
lb/MMBtu
0.2755
lb/MMBtu
TCEQ
VOC
64.45
60,300
lb/MMscf
3,015
lb/MMscf
Engineering
Calculation
71432
Benzene
0.401
375 lb/MMscf
18.8
lb/MMscf
Engineering
Calculation
108883
Toluene
0.473
447 lb/MMscf
22.4
lb/MMscf
Engineering
Calculation
100414
Ethylbenzene
0.060
56.0 lb/MMscf
2.80
lb/MMscf
Engineering
Calculation
AIRS ID: 123/9239/005
Page 7 of 9
(mentLi f Public Health and Environment
Air Pollution Control Division
CAS #
Pollutant
Weight
Percent of
Gas
Emission
Factors
Uncontrolled
Emission
Factors
Controlled
Source
1330207
Xylenes
0.105
98.0 Ib/MMscf
4.90
lb/MMscf
Engineering
Calculation
110543
n -Hexane
3.041
2.838
Ib/MMscf
1421b/MMscf
Engineering
Calculation
Note: The uncontrolled VOC and HAP emissions for this point were calculated using the 6/29/2011
analysis of a gas sample collected from the Pawnee 16-13H well. The controlled VOC and HAP emissions
factors for point 004 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
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, n -hexane
PSD
Synthetic Minor Source of: VOC
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.i.tpoaccess.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:
http://www.cdphe.state.co.us/ap/oiloaspermitting.html
AIRS ID: 123/9239/005
Page 8 of 9
mentOf Public Health and Environment
Air Pollution Control Division
AIRS ID: 123/9239/005 Page 9 of 9
Produced Natural Gas Venting/Flaring Preliminary Analysis
Division Information
Engineer:
Peter Armington
Control Engineer:
Carissa Money
Review Date:
05/02/2013
Application Date:
01/17/2013
Facility Information
Permit No.
13WE1628
Al Rs
County #
Facility #
Point #
9239
005
SEP-1
Whiting Oil and Gas Corporation
Pawnee 16-13H Pad
NWSE Sec 16 T10N R59W
123 Weld
Facility Equipment ID
Colorado Department of Public Health and Environment
Air Pollution Control Division
Attainment Status
PM10
Attainment
PM2.5
Attainment .
SOx
Attainment
NOx
Attainment
VOC
Attainment
CO
Attainment
Potentially Located within EAC - determine attainment status of NC
Company Name:
Source Name:
Source Location:
SIC:
1311
5115
Elevation (feet)
x
New Permit
(CPI)
Modification
(Issuance #)
Transfer of
Ownership
APEN
Required/Permit
Fxemot
APEN
Exempt/Permit
Fxemnt
Notes
Equipment Description
This source vents natural gas from:
a well head separator
Emissions from this source are:
routed to an open -flame flare
Natural gas venting from a well head separator. Emissions from this source are routed to an open -
flame flare.
Emission Calculation Method
EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3)
Ex=Q*MW*XxIC
Ex = emissions of pollutant x
Q = Volumetric flow rate/volume of gas processed
MW = Molecular weight of gas = SG of gas * MW of air
Xx = mass fraction of x in gas
C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm
Throughput (O)
MW
50 MMscf/yr
35.460 Ib/Ib-mol
5666.7 sd/hr
0.001 MMscf/d
4.22 MMscf/mo
mole %
MW
Ibx/Ibmol
mass fraction
E
lb/hr
lb/yr
tpy
Helium
0
4.0026
0.000
0.000
Helium
0.0
0
0.00
CO2
2.779
44.01
1.223
0.034
CO2
18.3
160189
80.09
N2
1.075
28.013
0.301
0.008
N2
4.5
39442
19.72
methane
48.213
16.041
7.734
0.218
methane
115.6
1012950
506.48
ethane
11.137
30.063
3.348
0.094
ethane
50.1
438524
219.26
propane
14.405
44.092
6.3515
0.179
propane
95.0
831889
415.94
isobutane
1.918
58.118
1.1147
0.031
isobutane
16.7
146000
73.00
n -butane
8.054
58.118
4.6808
0.132
n -butane
70.0
613077
306.54
isopentane
2.1
72.114
1.5144
0.043
isopentane
22.6
198350
99.17
n -pentane
3.203
72.114
2.3098
0.065
n -pentane
34.5
302530
151.27
cyclopentane
0
70.13
0.0000
0.000
cyclopentane
0.0
0
0.00
n -Hexane
1.2480
86.18
1.0755
0.030
n -Hexane
16.1
140868
70.43
cyclohexane
0.3700
84.16
0.3114
0.009
cyclohexane
4.7
40785
20.39
Otherhexanes
2.701
86.18
2.3277
0.066
Otherhexanes
34.8
304876
152.44
heptanes
1203
100.21
1.2055
0.034
heptanes
18.0
157895
78.95
methylcyclohexane
0
98.19
0.0000
0.000
methylcyclohexan 1
0.0
0
0.00
224-TMP
0
114.23
0.0000
0.000
224-TMP
0.0
0
0.00
Benzene
0.182
78.12
0.1422
0.004
Benzene
2.1
18622
9.31
Toluene
0.184
92.15
0.1696
0.005
Toluene
2.5
22208
11.10
Ethylbenzene
0.02
106.17
0.0212
0.001
Ethylbenzene
0.3
2781
1.39
Xylenes
0.035
106.17
0.0372
0.001
Xylenes
0.6
4867
2.43
Produced Natural Gas Venting/Flaring Preliminary Analysis
Colorado Department of Public Health and Environment
Air Pollution Control Division
ICe+ Heavies )
1.1731 135.7531 1.5924 I 0.045 IC8+ Heavies I 23.8 ( 208564
VOC mass fraction: 0.6445
35.460
Notes
Mole %, MW. and mass fractions from the Pawnee 16-13H gas analysis, dated 6/29/11.
Emissions are based on 8760 hours of operation per year.
I calculated the average MW of C8+ based on the average MW on the analysis for the gas.
Total VOC Emissions (Uncontrolled)
annual limit assuming 95%control
monthly limit assuming 95% control (lb/mo.)
104.28
1496.7
74.8
12711.3
Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment
Air Pollution Control Division
Flaring Information
Equipment Description
Flare to combust produced gas until pipeline is available at this wellhead facility.
Manufacturer
Model
Serial Number
Gas Heating Value
Throughput
TBD
TBD
TBD
1844
91536.16
Btu/scf
MMBtu/yr
Combustion emission factor source: TCEQ
0.138
lb NOX/MMBtu
tpy NOX
0.2755
lb CO/MMBtu
tpy CO
6.32
Emissions Summary
12.61
6.32
tpy NOX
Uncontrolled/PTE
12.61
tpy CO
1496.656
tpy VOC
Controlled
74.833
tpy VOC
Uncontrolled
Total (lb/yr)
Bin
Scenario A
Reportable?
Controlled
Total (Ib/yr)
Benzene
18622
A
Yes
931
Toluene
22208
C
Yes
1110
Ethylbenzene
2781
C
Yes
139
Xylenes
4867
C
Yes
243
n -hexane
140868
C
Yes
7043
224-TMP
0
C
No
0
Regulatory Applicability
AQCC Regulation 1 _
This source is subject to the opacity requirements for flares in Section II.A.5:'No owner or operator
of a smokeless flare or other flare for the combustion of waste gases shall allow or cause
emissions into the atmosphere of any air pollutant which is in excess of 30% opacity.'
AQCC Regulation 2 _
Section I.A applies to all emission sources. "No person, wherever located, shall cause or allow the
emission of odorous air contaminants from any single source such as to result in detectable odors
which are measured in excess of the following limits: For areas used predominantly for residential
or commercial purposes it is a violation if odors are detected after the odorous air has been diluted
with seven (7) or more volumes of odor free air."
AQCC Regulation 3
Part A:
An APEN is required for this source because uncontrolled VOC emissions
exceed two tons per year in an attainment area.
Part B:
A permit is required for this source because uncontrolled VOC emissions from
this facility exceed five tons per year in an attainment area.
This source is not subject to Section III.D.2 (Minor Source RACT) because it
is not located in a nonattainment area.
Is public comment
required?
Public Comment Required
Facility Status
This facility is a synthetic minor source of VOC/HAP for Title V applicability.
This facility is a synthetic minor source of VOC for PSD applicability.
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO:
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 36-11 H Pad, located in the NESE of Section 36,
Township 10N, Range 59W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
13WE1629
Issuance 1
Facility
Equipment
ID
AIRS
Point
Description
Sep -1
005
Separator controlled by a 30' flare stack. Flare has a minimum
combustion efficiency of 95%. The flare is not enclosed.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR
QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et sea), 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, bV 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, II.G.2).
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction fora period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
AIRS ID: 123/9290/005 Page 1 of 8
Wellhead Version 2012-1
f Public Health and Environment
Air Pollution Control Division
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 except fugitive emissions from
equipment leaks 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
Equipment ID
AIRS
Point
Tons per Year
Emission Type
NO,
VOC
CO
Sep -1
005
9.7
82.8
19.3
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.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from
each emission unit, on a rolling twelve (12) month total. By the end of each month a new
twelve-month total shall be calculated based on the previous twelve months' data. The
permit holder shall calculate emissions each month and keep a compliance record on site or
at a local field office with site responsibility, for Division review. This rolling twelve-month
total shall apply to all permitted emission units, requiring an APEN, at this facility.
8. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
AIRS ID: 123/9290/005 Page 2 of 8
f Public Health and Environment
Air Pollution Control Division
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
Sep -1
005
Separator controlled by a 30' flare stack
VOC
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
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
Sep -1
005
Natural gas flaring
92.71 MMSCF/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 oh 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)
OPERATING &MAINTENANCE REQUIREMENTS
14. Upon startup of these points, the applicant shall follow the operating and maintenance
(O&M) plan and record keeping format approved by the Division, in 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
AIRS ID: 123/9290/005 Page 3 of 8
f Public Health and Environment
Air Pollution Control Division
15. 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).
16. The operator shall complete an initial site specific extended gas analysis of the natural gas
produced at this site in order to verify the VOC, benzene, toluene, ethylbenzene, xylenes,
and n -hexane 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. Results of site -specific sampling and analysis shall be
submitted to the Division as part of the self -certification and used to demonstrate compliance
with the emissions factors chosen for this emissions point.
Periodic Testing Requirements
17. 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
18. 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.
19. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit)
shall apply to this source at any such time that this source becomes major solely by virtue of
a relaxation in any permit condition. Any relaxation that increases the potential to emit
above the applicable Federal program threshold will require a full review of the source as
though construction had not yet commenced on the source. The source shall not exceed
the Federal program threshold until a permit is granted. (Regulation No. 3 Part D).
GENERAL TERMS AND CONDITIONS
20. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
AIRS ID: 123/9290/005 Page 4 of 8
f Public Health and Environment
Air Pollution Control Division
21. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide "final" authority for this activity or operation of this source. Final authorization of
the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self -certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self -Certify for Final Authorization
section of this permit. •
22. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the 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 applicants agents. It is valid only for the
equipment and operations or activity specifically identified on the permit.
23. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
24. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the 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.
25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Peter Armington
Permit Engineer
Permit Histo
Issuance
ry
Date
Description
AIRS ID: 123/9290/005
Page 5 of 8
This Issuance
f Public Health and Environment
Air Pollution Control Division
Issuance 1
Issued to Whiting Oil and Gas Corporation
AIRS ID: 123/9290/005 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 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.cdphe.state.co. us/rep u lations/airregs/100102acicccom mon provisionsreg. 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)
005
Benzene
71432
A
6,109
Yes
305
Toluene
108883
C
8,106
Yes
405
n -Hexane
110543
C
43,803
Yes
2,190
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Weight
Percent of
Gas
Emission
Factors
Uncontrolled
Emission
Factors
Controlled
Source
NOx
_
0.138
lb/MMBtu
0.138
Ib/MMBtu
TCEQ
CO
0.2755
Ib/MMBtu
0.2755
lb/MMBtu
TCEQ
VOC
27
35,678
lb/MMscf
1,784
Ib/MMscf
Engineering
Calculation
71432
Benzene
0.092
66.0 lb/MMscf
3.30
Ib/MMscf
Engineering
Calculation
108883
Toluene
0.120
87.5 lb/MMscf
4.38
lb/MMscf
Engineering
Calculation
110543
n -Hexane
0.659
473 lb/MMscf
23.6
lb/MMscf
Engineering
Calculation
Note: The uncontrolled VOC and HAP emissions for this point were calculated using the 6/29/2011
analysis of a gas sample collected from the Terrace 36-11 H well. The controlled VOC and HAP emissions
factors for point 004 are based on the flare control efficiency of 95%.
AIRS ID: 123/9290/005
Page 7 of 8
mentf Public Health and Environment
Air Pollution Control Division
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this
permit is valid for a term of five years from the date it was received by the Division. A revised APEN
shall be submitted no later than 30 days before the five-year term expires. Please refer to the most
recent annual fee invoice to determine the APEN expiration date for each emissions point associated
with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-
3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, n -hexane
PSD
Synthetic Minor Source of: VOC
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:
http://www.cdphe.state.co.us/ap/oildaspermittind.html
AIRS ID: 123/9290/005 Page 8 of 8
Produced Natural Gas Venting/Flaring Preliminary Analysis
Division Information
Engineer:
Peter Armington
Control Engineer:
Carissa Money
Review Date:
05/03/2013
Application Date:
01/17/2013
Facility Information
Permit No.
13WE1629
AIRS
County #
Facility #
123 Weld
9290
005
SEP-1
Whiting Oil and Gas Corporation
Terrace 36-11H Pad
NESE Sec 36 T10N R59W
Point #
Facility Equipment ID
Colorado Department of Public Health and Environment
Air Pollution Control Division
Attainment Status
PM10
Attainment
PM2.5
Attainment
SOx
Attainment •
NOx
Attainment
VOC •
Attainment
CO
Attainment
Potentially Located within EAC - determine attainment status of NC
Company Name:
Source Name:
Source Location:
SIC:
1311
4846
Elevation (feet)
x
Notes
New Permit
(CPI)
Modification
(Issuance #)
Transfer of
Ownership
APEN
Required/Permit
Exemot
APEN
Exempt/Permit
Fxemol
Equipment Description
This source vents natural gas from:
a well head separator
Emissions from this source are:
routed to an open -flame flare
Natural gas venting from a well head separator. Emissions from this source are routed to an open -
flame flare.
Emission Calculation Method
EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3)
Ex=Q*MW*Xx/C
Ex = emissions of pollutant x
Q = Volumetric flow rate/volume of gas processed
MW = Molecular weight of gas = SG of gas * MW of air
Xx = mass fraction of x in gas
C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm
Throughputrg
93 MMscf/yr 10583.3 scf/hr
27.174 Iblib-mol 0.002 MMscf/d
7.87 MMscf/mo
mole %
MW
Ibx/Ibmol
mass fraction
E
lb/hr •
lb/yr
tpy
Helium
0
4.0026
0.000
0.000
Helium
0.0
0
0.00
CO2
1.662
44.01
0.731
0.027
CO2
20.4
178924
89.46
N2
2.072
28.013
0.580
0,021
N2
16.2
141983
70.99
methane
59.717
16.041
9.579
0.353
methane
267.5
2343240
1171.62
ethane
9.184
30.063
2.761
0.102
ethane
77.1
675385
337.69
propane
21.497
44.092
9.4785
0.349
propane
264.7
2318596
1159.30
isobutane
1.067
58.118
0.6201
0.023
isobutane
17.3
151692
75.85
n -butane
2.392
58.1-)8
1.3902
0.ob1
n -butane
38.8
340063
170.03
isopentane
0.476
72.114
0.3433
0.013
isopentane
9.6
83968
41.98
n -pentane
0.672
72.114
0.4846
0.018
n -pentane
13.5
118543
59.27
cyclopentane
0
70.13
0.0000
0.000
cyclopentane
0.0
0
0.00
n -Hexane
0.2080
86.18
0.1793
0.007
n -Hexane
5.0
43849
21.92
cyclohexane
0.0630
84.16
0.0530
0.002
cyclohexane
1.5
12970
6.48
Other hexanes
0.452
86.18
0.3895
0.014
Other hexanes
10.9
95287
47.64
heptanes
0.221
100.21
0.2215
0.008
heptanes
6.2
54174
27.09
methylcyclohexane
0.003
98.19
0.0029
0.000
methylcyclohexanc
0.1
721
0.36
224 -IMP
0
114.23
0.0000
0.000
224-TMP
0.0
0
0.00
Benzene
0.032
78.12
0.0250
0.001
Benzene
0.7
6115
3.06
Toluene
0.036
92.15
0.0332
0.001
Toluene
0.9
8115
4.06
Ethylbenzene
0
106.17
0.0000
0.000
Ethylbenzene
0.0
0
0.00
Xylenes
0
106.17
0.0000
0.000
Xylenes
0.0
0
0.00
Produced Natural Gas Venting/Flaring Preliminary Analysis
Colorado Department of Public Health and Environment
Air Pollution Control Division
IC8+ Heavies )
VOC mass fraction: 0.4976
27.174
Notes
Mole %, MW. and mass fractions from the Pawnee 16-13H gas analysis, dated 6/29/11.
Emissions are based on 8760 hours of operation per year
I calculated the average MW of C8+ based on the average MW on the analysis for the gas.
0.2461 122.3241 0.3009 1 0.011 IC8+ Heavies I 8.4 I 73609
Total VOC Emissions (Uncontrolled)
annual limit assuming 95% control
monthly limit assuming 95% control (lb/mo.)
36.80
1653.9
82.7
14046.4
Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment
Air Pollution Control Division
Flaring Information
Equipment Descript on
Flare to combust produced gas until pipeline is available at this wellhead facility.
Manufacturer
Model
Serial Number
Gas Heating Value
Throughput
TBD
TBD
TBD
1512
140177.52
Btu/scf
MMBtu/yr
Combustion emission factor source: TCEQ
0.138
lb NOX/MMBtu
tpy NOX
0.2755
lb CO/MMBtu
tpy CO
9.67
19.31
Emissions Summary
9.67
tpy NOX
Uncontrolled/PTE
19.31
tpy CO
1653.850
tpy VOC
Controlled
82.693
tpy VOC
Uncontrolled
Total (Ib/yr)
Bin
Scenario A
Reportable?
Controlled
Total (lb/yr)
Benzene
6115
A
Yes
306
Toluene
8115
C
Yes
406
Ethylbenzene
0
C
No
0
Xylenes
0
C
No
0
n -hexane
43849
C
Yes
2192
224-TMP
0
C
No
0
Regulatory Applicability
AQCC Regulation 1 _
This source is subject to the opacity requirements for flares in Section II.A.5:'No owner or operator
of a smokeless flare or other flare for the combustion of waste gases shall allow or cause
emissions into the atmosphere of any air pollutant which is in excess of 30% opacity.'
AQCC Regulation 2 _
Section I.A applies to all emission sources. "No person, wherever located, shall cause or allow the
emission of odorous air contaminants from any single source such as to result in detectable odors
which are measured in excess of the following limits: For areas used predominantly for residential
or commercial purposes it is a violation if odors are detected after the odorous air has been diluted
with seven (7) or more volumes of odor free air."
ion 3
Part A:
An APEN is required for this sburce because uncontrolled VOC emissions
exceed two tons per year in an attainment area.
Part B:
A permit is required for this source because uncontrolled VOC emissions from
this facility exceed five tons per year in an attainment area.
This source is not subject to Section III.D.2 (Minor Source RACT) because it
is not located in a nonattainment area.
Is public comment
required?
Public Comment Required
Facility Status
This facility is a synthetic minor source of VOC/HAP for Title V applicability.
This facility is a synthetic minor source of VOC for PSD applicability.
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO:
13WE1630
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 Wild Horse 16-13H Pad, located in the SWNW of Section
16, Township 9N, Range 59W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
Sep -1
006
Separator controlled by a 30' flare stack. Flare has a minimum
combustion efficiency of 95%. The flare is not enclosed.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR
QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED
IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen
days after issuance of this permit, by submitting a Notice of Startup form to the
Division. The Notice of Startup form may be downloaded online at
www.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, II.G.2).
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction for a period of eighteen
months or more; (Hi) does not complete construction within a reasonable time of the
AIRS ID: 123/9383/005 Page 1 of 8
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Air Pollution Control Division
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 except fugitive emissions from
equipment leaks 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
Equipment ID
AIRS
Point
Tons per Year
Emission Type
NO„
VOC
CO
Sep -1
006
2.5
17.2
5.0
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.
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.
The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
AIRS ID: 123/9383/005 Page 2 of 8
Public Health and Environment
Air Pollution Control Division
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
Sep -1
006
Separator controlled by a 30' flare stack
VOC
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
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
Sep -1
006
Natural gas flaring
25.55 MMSCF/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.
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)
OPERATING & MAINTENANCE REQUIREMENTS
14. Upon startup of these points, the applicant shall follow the operating and maintenance
(O&M) plan and record keeping format approved by the Division, in 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
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Air Pollution Control Division
15. 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).
16. The operator shall complete an initial site specific extended gas analysis of the natural gas
produced at this site in order to verify the VOC, benzene, toluene, ethylbenzene, xylenes,
and n -hexane 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. Results of site -specific sampling and analysis shall be
submitted to the Division as part of the self -certification and used to demonstrate compliance
with the emissions factors chosen for this emissions point.
Periodic Testing Requirements
17. 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
18. 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.
19. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit)
shall apply to this source at any such time that this source becomes major solely by virtue of
a relaxation in any permit condition. Any relaxation that increases the potential to emit
above the applicable Federal program threshold will require a full review of the source as
though construction had not yet commenced on the source. The source shall not exceed
the Federal program threshold until a permit is granted. (Regulation No. 3 Part D).
GENERAL TERMS AND CONDITIONS
20. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
AIRS ID: 123/9383/005 Page 4 of 8
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Air Pollution Control Division
21. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide "final" authority for this activity or operation of this source. Final authorization of
the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self -certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self -Certify for Final Authorization
section of this permit.
22. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the 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.
23. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
24. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the 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.
25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention.
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Peter Armington
Permit Engineer
Permit Histo
Issuance
ry
Date
Description
AIRS ID: 123/9383/005
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F:1
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Air Pollution Control Division
Issuance 1
This Issuance
Issued to Whiting Oil and Gas Corporation
AIRS ID: 123/9383/005 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 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.cd phe.state.co. us/req ulations/airreqs/100102agcccommon provisionsreq. 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 (Ib/yr)
006
Benzene
71432
A
2,104
Yes
105
Toluene
108883
C
1,924
Yes
96
n -Hexane
110543
C
17,237
Yes
862
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Weight
Percent of
Gas
Emission
Factors
Uncontrolled
Emission
Factors
Controlled
Source
NOx
0.138
lb/MMBtu
0.138
lb/MMBtu
TCEQ
CO
0.2755
lb/MMBtu
0.2755
lb/MMBtu
TCEQ
VOC
39.51
26,660
lb/MMscf
1,333
lb/MMscf
Engineering
Calculation
71432
Benzene
0.401
82.4 lb/MMscf
4.12
lb/MMscf
Engineering
Calculation
108883
Toluene
0.473
75.4 lb/MMscf
3.77
lb/MMscf
Engineering
Calculation
n -Hexane
3.041
675 lb/MMscf
33.110543
lb/MMscf
Engineering
allat
Calculation
Note: The uncontrolled VOC and HAP emissions for this point were calculated using the 6/29/2011
analysis of a gas sample collected from the Wild Horse 16-13H well. The controlled VOC and HAP
emissions factors for this point are based on the flare control efficiency of 95%.
AIRS ID: 123/9383/005
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Air Pollution Control Division
L.
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 of: VOC, n -hexane
PSD
Synthetic Minor Source of: VOC
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:
htto://www.cdphe.state.co.us/ap/oilgaspermittinghtml
AIRS ID: 123/9383/005 Page 8 of 8
Produced Natural Gas Venting/Flaring Preliminary Analysis
Division Information
Engineer:
Peter Armington
Control Engineer:
Carissa Money
Review Date:
05/03/2013
Application Date:
01/17/2013
Facility Information
Permit No.
13WE1630
AIRs
County #
Facility #
123 Weld
Point #
9383
006
SEP-1
Whiting Oil and Gas Corporation
Wild Horse 16-13H Pad
SWNW Sec 16 T9N R59W
Facility Equipment ID
Colorado Department of Public Health and Environment
Air Pollution Control Division
Attainment Status
PM10
Attainment
PM2.5
Attainment
SOx
Attainment
NOx
Attainment
VOC
Attainment
CO
Attainment
Potentially Located within EAC - determine attainment status of NC
Company Name:
Source Name:
Source Location:
SIC:
1311
5052
x
Elevation (feet)
New Permit
(CP1)
Modification
(Issuance #)
Transfer of
Ownership
APEN
Required/Permit
Fxemnt
APEN
Exempt/Permit
Fxemnt
Notes
Equipment Description
This source vents natural gas from:
a well head separator
Emissions from this source are:
routed to an open -flame flare
Natural gas venting from a well head separator. Emissions from this source are routed to an open -
flame flare.
Emission Calculation Method
EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement. Equation (10.4-3)
Ex= Q"MW*Xx/C
Ex = emissions of pollutant x
Q = Volumetric flow rate/volume of gas processed
MW = Molecular weight of gas = SG of gas * MW of air
Xx = mass fraction of x in gas
C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm
Throughput (O)
MW
26 MMscf/yr
25.574 Ib/Ib-mol
2916.7 scf/hr
0.001 MMscf/d
2.17 MMscf/mo
mole %
MW
Ibx/Ibmol
mass fraction
E
lb/hr
lb/yr
tpy
Helium
0
4.0026
0.000
0.000
Helium
0.0
0
0.00
CO2
2.218
44.01
0.976
0.038
CO2
7.5
65806
32.90
N2
0.909
28.013
0.255
0.010
N2
2.0
17166
8.58
methane
66.399
16.041
10.651
0.416
methane
82.0
718033
359.02
ethane
11.935
30.063
3.588
0.140
ethane
27.6
241884
120.94
propane
9.904
44.092
4.3669
0.171
propane
33.6
294389
147.19
isobutane
1.082
58,118
0.6288
0.025
isobutane
4.8
42393
21.20
n -butane
3.985
58.118
2.3160
0.091
n -butane
17.8
156132
/8.07
isopentane
0.86
72.114
0.6202
0.024
isopentane
4.8
41809
20.90
n -pentane
1.208
72.114
0.8711
0.034
n -pentane
6.7
58727
29.36
cyclopentane
0
70.13
0.0000
0.000
cyclopentane
0.0
0
0.00
n -Hexane
0.2970
86.18
0.2560
0.010
n -Hexane
2.0
17255
8.63
cyclohexane
0.0740
84.16
0.0623
0.002
cyclohexane
0.5
4198
2.10
Other hexanes
0.656
86.18
0.5653
0.022
Other hexanes
4.4
38112
19.06
heptanes
0.228
100.21
0.2285
0.009
heptanes
1.8
15403
7.70
methylcyclohexane
0.003
98.19
0.0029
0.000
methylcyclohexane
0.0
199
0.10
224 -IMP
0
114.23
0.0000
0.000
224-TMP
0.0
0
0.00
Benzene
0.04
78.12
0.0312
0.001
Benzene
0.2
2107
1.05
Toluene
0.031
92.15
0.0286
0.001
Toluene
0.2
1926
0.96
Ethylbenzene
0
106.17
0.0000
0.000
Ethylbenzene
0.0
0
0.00
Xylenes
0
106.17
0.0000
0.000
Xylenes
0.0
0
0.00
Produced Natural Gas Venting/Flaring Preliminary Analysis
Colorado Department of Public Health and Environment
Air Pollution Control Division
IC8+ Heavies
(
0.1711 73.8581 0.1263 I
0.005 IC8+ Heavies I 1.0 I 8514
VOC mass fraction: 0.3951
25.574
Notes
Mole %, MW, and mass fractions from the Wild Horse 16-13H gas analysis, dated 6/29/11.
Emissions are based on 8760 hours of operation per year.
I calculated the average MW of C8+ based on the average MW on the analysis for the gas.
Total VOC Emissions (Uncontrolled)
annual limit assuming 95% control
monthly limit assuming 95% control (lb/mo.)
4.26
340.6
17.0
2892.6
Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment
Air Pollution Control Division
Flaring Information
Equipment Description
Flare to combust produced gas until pipeline is available at this wellhead facility.
Manufacturer
Model
Serial Number
Gas Heating Value
Throughput
TBD
TBD
TBD
1433
Btu/scf
MMBtu/yr
36613.15
Combustion emission factor source: TCEQ
0.138
lb NOX/MMBtu
tpy NOX
0.2755
lb CO/MMBtu
tpy CO 1
2.53
Emissions Summary
5.04
2.53
tpy NOX
Uncontrolled/PTE
5.04
tpy CO
340.581
tpy VOC
Controlled
17.029
tpy VOC
Uncontrolled
Total (lb/yr)
Bin
Scenario A
Reportable?
Controlled
Total (Ib/yr)
Benzene
2107
A
Yes
105
Toluene
1926
C
Yes
96
Ethylbenzene
0
C
No
0
Xylenes
0
C
No
0
n -hexane
17255
C
Yes
863
224-TMP
0
C
No
0
Regulatory Applicability
AQCC Regulation 1 _
This source is subject to the opacity requirements for flares in Section II.A.5:'No owner or operator
of a smokeless flare or other flare for the combustion of waste gases shall allow or cause
emissions into the atmosphere of any air pollutant which is in excess of 30% opacity.'
AQCC Regulation 2
Section I.A applies to all emission sources. "No person, wherever located, shall cause or allow the
emission of odorous air contaminants from any single source such as to result in detectable odors
which are measured in excess of the following limits: For areas used predominantly for residential
or commercial purposes it is a violation if odors are detected after the odorous air has been diluted
with seven (7) or more volumes of odor free air."
AQCC Regulation 3
Part A:
An APEN is required for this source because uncontrolled VOC emissions
exceed two tons per year in an attainment area.
Part B:
A permit is required for this source because uncontrolled VOC emissions from
this facility exceed five tons per year in an attainment area.
This source is not subject to Section III.D.2 (Minor Source RACT) because it
is not located in a nonattainment area.
Is public comment
required?
Public Comment Required
Facility Status
This facility is a synthetic minor source of VOC/HAP for Title V applicability.
This facility is a synthetic minor source of VOC for PSD applicability.
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO:
13WE1632
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 Wildhorse 02-0224H Pad, located in the NENW of Section
2, Township 9N, Range 59W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
Sep -1
005
Separator controlled by a 30' flare stack. Flare has a minimum
combustion efficiency of 95%. The flare is not enclosed.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR
QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED
IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen
days after issuance of this permit, by submitting a Notice of Startup form to the
Division. The Notice of Startup form may be downloaded online at
www.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, II.G.2).
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction fora period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
AIRS ID: 12319A72/005 Page 1 of 9
Wellhead Version 2012-1
f Public Health and Environment
Air Pollution Control Division
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 except fugitive emissions from
equipment leaks 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
Equipment ID
AIRS
Point
Tons per Year
Emission Type
yp
NO,,
VOC
CO
Sep -1
005
10.1
77.3
20.1
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.
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: 12319A721005 Page 2 of 9
f Public Health and Environment
Air Pollution Control Division
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
Sep -1
005
Separator controlled by a 30' flare stack
VOC
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
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
Sep -1
005
Natural gas flaring
97.09 MMSCF/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.
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)
OPERATING & MAINTENANCE REQUIREMENTS
14. Upon startup of these points, the applicant shall follow the operating and maintenance
(O&M) plan and record keeping format approved by the Division, in 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
AIRS ID: 123/9A72/005 Page 3 of 9
f Public Health and Environment
Air Pollution Control Division
15. The operator shall complete an initial site specific extended gas analysis of the natural gas
produced at this site in order to verify the VOC, benzene, toluene, ethylbenzene, xylenes,
and n -hexane 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. Results of site -specific sampling and analysis shall be
submitted to the Division as part of the self -certification and used to demonstrate compliance
with the emissions factors chosen 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).
Periodic Testing Requirements
17. 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
18. 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.
19. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit)
shall apply to this source at any such time that this source becomes major solely by virtue of
a relaxation in any permit condition. Any relaxation that increases the potential to emit
above the applicable Federal program threshold will require a full review of the source as
though construction had not yet commenced on the source. The source shall not exceed
the Federal program threshold until a permit is granted. (Regulation No. 3 Part D).
GENERAL TERMS AND CONDITIONS
20. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
AIRS ID: 123/9A72/005 Page 4 of 9
f Public Health and Environment
Air Pollution Control Division
21. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide "final" authority for this activity or operation of this source. Final authorization of
the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self -certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self -Certify for Final Authorization
section of this permit.
22. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the 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.
23. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
24. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution,
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the 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.
25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Peter Armington
Permit Engineer
Permit Histo
Issuance
ry
Date
Description
AIRS ID: 123/9A721005
Page 5 of 9
Issuance 1
This Issuance
f Public Health and Environment
Air Pollution Control Division
Issued to Whiting Oil and Gas Corporation
AIRS ID: 123/9A72/005 Page 6 of 9
ment ibf 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 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.cdphe.state.co. us/requlations/airreqs/100102agcccommonprovisionsreq.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)
005
Benzene
71432
A
13,994
Yes
700
Toluene
108883
C
15,328
Yes
766
Ethylbenzene
100414
C
816
No
41
Xylenes
1330207
C
6,792
Yes
340
n -Hexane
110543
C
93,463
Yes
4,973
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Weight
Percent of
Gas
Emission Emission
Factors Factors
Uncontrolled Controlled
Source
NOx
- -
0.138 0.138
lb/MMBtu lb/MMBtu
TCEQ
CO
---lb/MMBtu
0.2755
0.2755
lb/MMBtu
TCEQ
VOC
44.59
31,862
lb/MMscf
1,593
1b/MMscf
Engineering
Calculation
71432
Benzene
0.202
1441b/MMscf
7.2 lb/MMscf
Engineering
Calculation
108883
Toluene
0.218
158 lb/MMscf
r
7.9 Ib/MMscf Engineering
Calculation
100414
Ethylbenzene
0.012
8.41b/MMscf
0.42 Engineering
Ib/MMscf f Calculation
AIRS ID: 123/9A72/005
Page 7of9
,ago De entf Public Health and Environment
Air Pollution Control Division
CAS #
Pollutant
Weight
Percent of
Gas
Emission
Factors
Uncontrolled
Emission
Factors
Controlled
Source
1330207
Xylenes
0.098
70 lb/MMscf
3.5 lb/MMscf
Engineering
Calculation
110543
n-l-lexane
1.435
1,026
lb/MMscf
51.3
lb/MMscf
Engineering
Calculation
Note: The uncontrolled VOC and HAP emissions for this point were calculated using the 9/18/2012
analysis of a gas sample collected from the Wildhorse 02-0224H well. The controlled VOC and HAP
emissions factors for point 004 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
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, n -hexane
PSD
Synthetic Minor Source of: VOC
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:
http://www.cdphe.state.co.us/an/oilqaspermittinp.html
AIRS ID: 123/9A72/005
Page 8 of 9
AIRS ID: 123/9A72/005
f Public Health and Environment
Air Pollution Control Division
Page 9of9
Produced Natural Gas Venting/Flaring Preliminary Analysis
Division Information
Engineer:
Peter Armington
Control Engineer:
Carissa Money
Review Date:
05/06/2013
Application Date:
01/17/2013
Facility Information
Permit No.
13WE1632
AIRs
County #
Facility #
123 Weld
Point #
9A72
005
SEP-1
Whiting Oil and Gas Corporation
Wildhorse 02-0224H Pad
NENW Section 2 T9N R59W
Facility Equipment ID
Colorado Department of Public Health and Environment
Air Pollution Control Division
Attainment Status
PM10
Attainment
PM2.5
Attainment
SOx
Attainment
NOx
Attainment
VOC
Attainment
CO
Attainment
Potentially Located within EAC - determine attainment status of NC
Company Name:
Source Name:
Source Location:
SIC:
1311
4994
Elevation (feet)
x
New Permit
(CP1)
Modification
(Issuance #)
APEN
Required/Permit
Exemot
Transfer of
Ownership
APEN
Exempt/Permit
Examnt
Notes
Equipment Description
This source vents natural q s from:
Emissions from this source are:
a well head separator
routed to an open -flame flare
Natural gas venting from a well head separator. Emissions from this source are routed to an open -
flame flare.
Emission Calculation Method
EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3)
Ex=Q*MW`Xx/C
Ex = emissions of pollutant x
Q = Volumetric flow rate/volume of gas processed
MW = Molecular weight of gas = SG of gas * MW of air
Xx = mass fraction of x in gas
C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm
Throughput (O)
MW
97 MMscf/yr 11083.3 scf/hr
27.080 Ibflb-mol 0.002 MMscf/d
8.25 MMscf/mo
mole %
MW
lbx/Ibmol
mass fraction
E
Iblhr
Ib/yr
tpy
Helium
0
4.0026
0.000
0.000
Helium
0.0
0
0,00
C02
2.19
44.01
0.964
0.036
C02
28.2
246906
123.45
N2
0.244
28.013
0.068
0.003
N2
2.0
17510
8.75
methane
64.288
16.041
10.312
0.381
methane
301.6
2641780
1320.89
ethane
12.173
30.063
3.660
0.135
ethane
107.0
937487
468.74
propane
10.448
44.092
4.6067
0.170
propane
134.7
1180126
590.06
isobutane
1.205
58.118
0.7003
0.026 _
isobutane
20.5
179404
89,70
329.33
n -butane
4.424
58.118
2.5711
0.095
n -butane
75.2
658660
isopentane
1.012
72.114
0.7298
0.027
isopentane
21.3
186954
93.48
n -pentane
1.492
72.114
1.0759
0.040
n -pentane
31.5
275628
137,81
cyclopentane
0.172
70.13
0.1206
0.004
cyclopentane
3.5
30901
15.45
n -Hexane
0.4510
86.18
0.3887
0.014
n -Hexane
11.4
99568
49.78
cyclohexane
0.1280
84.16
0.1077
0.004
cyclohexane
3.2
27596
13.80
Other hexanes
0.69
86.18
0.5946
0.022
Other hexanes
17.4
152332
' 76.17
heptanes
0.489
100.21
0.4900
0.018
heptanes
14.3
125532
62.77
methylcyclohexane
0
98.19
0.0000
0.000
methylcyclohexane
0.0
0
0.00
224-TMP
0
114.23
0.0000
0.000
224-TMP
0.0
0
0.00
Benzene
0.07
78.12
0.0547
0.002
Benzene
1.6
14009
7.00
Toluene
0.065
92.15
0.0599
0.002
Toluene
1.8
15344
7.67
Ethylbenzene
0.003
106.17
0.0032
0.000
Ethylbenzene
0.1
816
0.41
Xylenes
0.025
106.17
0.0265
0.001
Xylenes
0.8
6800
3.40
Produced Natural Gas Venting/Flaring Preliminary Analysis
Colorado Department of Public Health and Environment
Air Pollution Control Division
1C8+ Heavies 1 0.4321 126.3651 0.5459 1 0.020 1C8+ Heavies 1 16.0 1 139844
VOC mass fraction: 0.4459 Total VOC Emissions ('Uncontrolled)
27.080 annual limit assuming 95% control
Notes monthly limit assuming 95% control (113/mo.)
Mole %, MW, and mass fractions from the Pawnee 16-13H gas analysis, dated 6/29/11.
Emissions are based on 876D hours of operation per year.
I calculated the average MW of C8+ based on the average MW on the analysis for the gas.
69.92
1546.8
77.3
13136.8
Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment
Air Pollution Control Division
Flaring Information
Equipment Description
Flare to combust produced gas until pipeline is available at this wellhead facility.
Manufacturer
Model
Serial Number
Gas Heating Value
Throughput
TBD
TBD
TBD
1502
145829.18
Btu/scf
MMBtu/yr
Combustion emission factor source: TCEQ
0.138
10.06
lb NOX/MMBtu
tpy NOX
0.2755
lb CO/MMBtu
tpy CO
Emissions Summary
20.09
10.06
tpy NOX
Uncontrolled/PTE
20.09
tpy CO
1546.757
tpy VOC
Controlled
77.338
tpy VOC
Uncontrolled
Total (lb/yr)
Bin
Scenario A
Reportable?
Controlled
Total (lb/yr)
Benzene
14009
A
Yes
700
Toluene
15344
C
Yes
767
Ethylbenzene
816
C
No
41
Xylenes
6800
C
Yes
340
n -hexane
99568
C
Yes
4978
224-TMP
0
C
No
0
Regulatory Applicability
AQCC Regulation 1 _
This source is subject to the opacity requirements for flares in Section 11.A.5:'No owner or operator
of a smokeless flare or other flare for the combustion of waste gases shall allow or cause
emissions into the atmosphere of any air pollutant which is in excess of 30% opacity.'
AQCC Regulation 2 _
Section I.A applies to all emission sources. "No person, wherever located, shall cause or allow the
emission of odorous air contaminants from any single source such as to result in detectable odors
which are measured in excess of the following limits: For areas used predominantly for residential
or commercial purposes it is a violation if odors are detected after the odorous air has been diluted
with seven (7) or more volumes of odor free air."
AQCC Regulation 3
Part A:
An APEN is required for this source because uncontrolled VOC emissions
exceed two tons per year in an attainment area.
Part B:
A permit is required for this source because uncontrolled VOC emissions from
this facility exceed five tons per year in an attainment area.
This source is not subject to Section 111.D.2 (Minor Source RACT) because it
is not located in a nonattainment area.
Is public comment
required?
Public Comment Required ..
Facility Status
This facility is a synthetic minor source of VOC/HAP for Title V applicability.
This facility is a synthetic minor source of VOC for PSD applicability.
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO:
DATE ISSUED:
ISSUED TO:
13WE1633
Issuance 1
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 Wolf 35-2623H Pad, located in the SWSE of Section 35,
Township 10N, Range 59W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
Sep -1
007
Separator controlled by a 30' flare stack. Flare has a minimum
combustion efficiency of 95%. The flare is not enclosed.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR
QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED
IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen
days after issuance of this permit, by submitting a Notice of Startup form to the
Division. The Notice of Startup form may be downloaded online at
www.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
operators responsibility to self -certify compliance with the conditions. Failure to demonstrate
compliance within 180 days may result in revocation of the permit. (Reference: Regulation
No. 3, Part B, II.G.2).
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction fora period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
AIRS ID: 123/9893/007 Page 1 of 8
Wellhead Version 2012-1
?menti f Public Health and Environment
Air Pollution Control Division
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 except fugitive emissions from
equipment leaks 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.)
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
Equipment ID
AIRS
point
Tons per Year
Emission Type
NOx
VOC
CO
Sep -1
007
4.4
34.8
8.8
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.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from
each emission unit, on a rolling twelve (12) month total. By the end of each month a new
twelve-month total shall be calculated based on the previous twelve months' data. The
permit holder shall calculate emissions each month and keep a compliance record on site or
at a local field office with site responsibility, for Division review. This rolling twelve-month
total shall apply to all permitted emission units, requiring an APEN, at this facility.
8. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
AIRS ID: 123/9893/007 Page 2 of 8
Public Health and Environment
Air Pollution Control Division
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
Sep -1
007
Separator controlled by a 30' flare stack
VOC
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
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
Sep -1
007
Natural gas flaring
42.34 MMSCF/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.
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)
OPERATING & MAINTENANCE REQUIREMENTS
14, Upon startup of these points, the applicant shall follow the operating and maintenance
(O&M) plan and record keeping format approved by the Division, in 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
AIRS ID: 123/9893/007 Page 3 of 8
f Public Health and Environment
Air Pollution Control Division
15. 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).
16. The operator shall complete an initial site specific extended gas analysis of the natural gas
produced at this site in order to verify the VOC, benzene, toluene, ethylbenzene, xylenes,
and n -hexane 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. Results of site -specific sampling and analysis shall be
submitted to the Division as part of the self -certification and used to demonstrate compliance
with the emissions factors chosen for this emissions point.
Periodic Testing Requirements
17. 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
18. 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.
19. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit)
shall apply to this source at any such time that this source becomes major solely by virtue of
a relaxation in any permit condition. Any relaxation that increases the potential to emit
above the applicable Federal program threshold will require a full review of the source as
though construction had not yet commenced on the source. The source shall not exceed
the Federal program threshold until a permit is granted. (Regulation No. 3 Part D).
GENERAL TERMS AND CONDITIONS
20. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
AIRS ID: 123/9893/007 Page 4 of 8
f Public Health and Environment
Air Pollution Control Division
21. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide "final" authority for this activity or operation of this source. Final authorization of
the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self -certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self -Certify for Final Authorization
section of this permit.
22. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the 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.
23. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
24. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the 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.
25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Peter Armington
Permit Engineer
Permit Histo
Issuance
ry
Date
Description
AIRS ID: 123/9893/007
Page 5 of 8
This Issuance
De ,Ament f Public Health and Environment
itt Air Pollution Control Division
Issuance 1
Issued to Whiting Oil and Gas Corporation
AIRS ID: 123/9893/007 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 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. cd phe. state.co. us/req ulations/airreqs/100102agcccommon provisionsreq. 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
(Ib/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (Ib/yr)
007
Benzene
71432
A
5,144
Yes
257
Toluene
108883
C
4,525
Yes
226
n -Hexane
110543
C
43,567
Yes
2,178
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Weight
Percent of
Gas
Emission
Factors
Uncontrolled
Emission
Factors
Controlled
Source
NOx
---
0.138
Ib/MMBtu
0.138
lb/MMBtu
TCEQ
CO
0.2755
Ib/MMBtu
0.2755
Ib/MMBtu
TCEQ
VOC
45.30
32,797
Ib/MMscf
1,640
lb/MMscf
Engineering
Calculation
71432
Benzene
0.168
122 lb/MMscf
6.08
lb/MMscf
Engineering
Calculation
108883
Toluene
0.146
107 lb/MMscf
5.35
lb/MMscf
Engineering
Calculation
110543
n -Hexane
1.422
1,030
lb/MMscf
51.5
lb/MMscf
Engineering
Calculation
Note: The uncontrolled VOC and HAP emissions for this point were calculated using the 3/31/2012
analysis of a gas sample collected from the Wolf 35-2623H well. The controlled VOC and HAP emissions
factors for point 007 are based on the flare control efficiency of 95%.
AIRS ID: 123/9893/007
Page 7 of 8
of Public Health and Environment
Air Pollution Control Division
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this
permit is valid for a term of five years from the date it was received by the Division. A revised APEN
shall be submitted no later than 30 days before the five-year term expires. Please refer to the most
recent annual fee invoice to determine the APEN expiration date for each emissions point associated
with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-
3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, n -hexane
PSD
Synthetic Minor Source of: VOC
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at
the website listed below:
htto://ecfr.gmoaccess.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 XJCOOOC
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:
http://www.cdphe.state.co.us/apioilqaspermittinci.html
AIRS ID: 123/9893/007 Page 8 of 8
Produced Natural Gas Venting/Flaring Preliminary Analysis
Division Information
Engineer:
Peter Armington
Control Engineer:
Carissa Money
Review Date:
05/06/2013
Application Date:
01/17/2013
Facility Information
Permit No.
13WE1633
AIRs
County #
Facility #
123 Weld
Point #
9893
007
SEP-1
Whiting Oil and Gas Corporation
Wolf 35-2623H & Wolf 35-2613H Pad
SWSE Sec 35 T1ON R59W
Facility Equipment ID
Colorado Department of Public Health and Environment
Air Pollution Control Division
Attainment Status
PM10
Attainment
PM2.5
Attainment
SOx
Attainment
NOx
Attainment
VOC
Attainment
CO
Attainment
Potentially Located within EAC - determine attainment status of NC
Company Name:
Source Name:
Source Location:
SIC:
1311
5007
Elevation (feet)
x
New Permit
(CP1)
Modification
(Issuance #)
APEN
Required/Permit
Exempt
APEN
Exempt/Permit
Exempt
Transfer of
Ownership
Notes
Equipment Description
This source vents natural gas from:
Emissions from this source are:
a well head separator
routed to an open -flame flare
Natural gas venting from a well head separator. Emissions from this source are routed to an open -
flame flare.
Emission Calculation Method
EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3)
Ex=Q*MW* Xx/C
Ex = emissions of pollutant x
Q = Volumetric flow rate/volume of gas processed
MW = Molecular weight of gas = SG of gas * MW of air
Xx = mass fraction of x in gas
C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm
Wolf 35-2623H
Throughput(Q)
MW
42 MMscf/yr
27.440 Ib/lb-mol
4833.3 scf/hr
0.001 MMscf/d
3.60 MMscf/mo
mole %
MW
Ibx/Ibmol
mass fraction
E
lb/hr
lb/yr
tpy
Helium
0
4.0026
0.000
0.000
Helium
0.0
0
0.00
CO2
2.22
44.01
0.977
0.036
CO2
12.5
109148
54.57
N2
1.639
28.013
0.459
0.017
N2
5.9
51292
25.65
methane
62.223
16.041
9.981
0.364
methane
127.3
1115049
557.52
ethane
11.95
30.063
3.593
0.131
ethane
45.8
401339
200.67
propane
11.062
44.092
4.8775
0.178
propane
62.2
544885
272.44
isobutane
1.262
58.118
0.7334
0.027
isobutane
9.4
81937
40.97
n -butane
4./05
58.118
2.7345
0.100
n -butane
34.9
305479
152.74
isopentane
1.044
72.114
0.7529
0.027
isopentane
9.6
84107
42.05
n -pentane
1.519
72.114
1.0954
0.040
n-penlane
14.0
122374
61.19
cyclopentane
0
70.13
0.0000
0.000
cyclopentane
0.0
0
0.00
n -Hexane
0.4530
86.18
0.3904
0.014
n -Hexane
5.0
43613
21.81
cyclohexane
0.1240
84.16
0.1044
0.004
cyclohexane
1.3
11658
5.83
Other hexanes
0.847
86.18
0.7299
0.027
Other hexanes
9.3
81546
40.77
heptanes
0.5
100.21
0.5011
0.018
heptanes
6.4
55975
27.99
methylcyclohexane
0
. 98.19
0.0000
0.000
methylcyclohexane
0.0
0
0.00
224-TMP
0
114.23
0.0000
0.000
224-TMP
0.0
0
0.00
Benzene
0.059
78.12
0.0461
0.002
Benzene
0.6
5149
2.57
Toluene
0.044
92.15
0.0405
0.001
Toluene
0.5
4530
2.26
Ethylbenzene
0.001
106.17
0.0011
0.000
Ethylbenzene
0.0
119
0.06
Xylenes
0.001
106.17
0.0011 _
0.000
Xylenes
0.0
119
0.06
Produced Natural Gas Venting/Flaring Preliminary Analysis
IC8+ Heavies I
0.3471 121.607( 0.4220 I 0.015 IC8+ Heavies
VOC mass fraction: 0.4530
27.440
Notes
Mole %, MW, and mass fractions from the Pawnee 16-13H gas analysis, dated 6/29/11.
Emissions are based on 8760 hours of operation per year.
I calculated the average MW of C8+ based on the average MW on the analysis for the gas.
Colorado Department of Public Health and Environment
Air Pollution Control Division
5.4 I 47141
Total VOC Emissions (Uncontrolled)
annual limit assuming 95% control
monthly limit assuming 95% control (lb/mo.)
23.57
694.3
34.7
5896.9
Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment
Air Pollution Control Division
Flaring Information
Equipment Descript'on
Flare to combust produced gas until pipeline is available at this wellhead facility.
Manufacturer
Model
Serial Number
Gas Heating Value
Throughput
TBD
TBD
TBD
1502
63594.68
Btu/scf
MMBtu/yr
Combustion emission factor source: TCEQ
0.138
lb NOX/MMBtu
tpy NOX
0.2755
lb CO/MMBtu
tpy CO I
4.39
Emissions Summary
8.76
4.39
tpy NOX
Uncontrolled/PTE
8.76
tpy CO
694.316
tpy VOC
Controlled
34.716
tpy VOC
Uncontrolled
Total (lb/yr)
Bin
Scenario A
Reportable?
Controlled
Total (lb/yr)
Benzene
5149
A
Yes
257
Toluene
4530
C
Yes
226
Ethylbenzene
119
C
No
6
Xylenes
119
C
No
6
n -hexane
43613
C
Yes
2181
224-TMP
0
C
No
0
Regulatory Applicability
AQCC Regulation 1 _
This source is subject to the opacity requirements for flares in Section li.A.5:'No owner or operator
of a smokeless flare or other flare for the combustion of waste gases shall allow or cause
emissions into the atmosphere of any air pollutant which is in excess of 30% opacity.'
AQCC Regulation 2 _
Section I.A applies to all emission sources. "No person, wherever located, shall cause or allow the
emission of odorous air contaminants from any single source such as to result in detectable odors
which are measured in excess of the following limits: For areas used predominantly for residential
or commercial purposes it is a violation if odors are detected after the odorous air has been diluted
with seven (7) or more volumes of odor free air."
C Regulation 3
Part A:
An APEN is required for this source because uncontrolled VOC emissions
exceed two tons per year in an attainment area.
Part B:
A permit is required for this source because uncontrolled VOC emissions from
this facility exceed five tons per year in an attainment area.
This source is not subject to Section III.D.2 (Minor Source RACT) because it
is not located in a nonattainment area.
Is public comment
required?
Public Comment Required
Facility Status
This facility is a synthetic minor source of VOC/HAP for Title V applicability.
This facility is a synthetic minor source of VOC for PSD applicability.
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO: 13WE1634
DATE ISSUED:
ISSUED TO:
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the Wolf 35-2613H Pad, located in the SWSE of Section 35,
Township 10N, Range 59W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Issuance 1
Whiting Oil and Gas Corporation
Facility
Equipment
ID
AIRS
Point
Description
Sep42
008
Separator controlled by a 30' flare stack. Flare has a minimum
combustion efficiency of 95%. The flare is not enclosed.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR
QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED
IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen
days after issuance of this permit, by submitting a Notice of Startup form to the
Division. The Notice of Startup form may be downloaded online at
www.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, II.G.2).
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction for a period of eighteen
months or more; (Hi) does not complete construction within a reasonable time of the
AIRS ID: 123/9893/008 Page 1 of 8
Wellhead Version 2012-1
L
'ment f Public Health and Environment
„1 Air Pollution Control Division
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 except fugitive emissions from
equipment leaks 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
Equipment ID
AIRS
point
Tons per Year
Emission Type
NO„
VOC
CO
Sep -2
008
2.7
22.0
5.3
Point
ee "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.
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.
The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
AIRS ID: 123/9893/008 Page 2 of 8
f Public Health and Environment
Air Pollution Control Division
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
Sep -2
008
Separator controlled by a 30' flare stack
VOC
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
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
Sep -2
008
Natural gas flaring
25.19 MMSCF/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.
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)
OPERATING & MAINTENANCE REQUIREMENTS
14. Upon startup of these points, the applicant shall follow the operating and maintenance
(O&M) plan and record keeping format approved by the Division, in 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
AIRS ID: 123/9893/008 Page 3.of 8
ol• a: De'4.a en f Public Health and Environment
Air Pollution Control Division
15. 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).
16. The operator shall complete an initial site specific extended gas analysis of the natural gas
produced at this site in order to verify the VOC, benzene, toluene, ethylbenzene, xylenes,
and n -hexane 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. Results of site -specific sampling and analysis shall be
submitted to the Division as part of the self -certification and used to demonstrate compliance
with the emissions factors chosen for this emissions point.
Periodic Testing Requirements
17. 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
18. 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.
19. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit)
shall apply to this source at any such time that this source becomes major solely by virtue of
a relaxation in any permit condition. Any relaxation that increases the potential to emit
above the applicable Federal program threshold will require a full review of the source as
though construction had not yet commenced on the source. The source shall not exceed
the Federal program threshold until a permit is granted. (Regulation No. 3 Part D).
GENERAL TERMS AND CONDITIONS
20. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
AIRS ID: 123/9893/008 Page 4 of 8
f Public Health and Environment
Air Pollution Control Division
21. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide "final" authority for this activity or operation of this source. Final authorization of
the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self -certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self -Certify for Final Authorization
section of this permit.
22. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the 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.
23. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
24. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the 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.
25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Peter Armington
Permit Engineer
Permit Histo
Issuance
ry
Date
Description
AIRS ID: 123/9893/008
Page 5 of 8
This Issuance
f Public Health and Environment
Air Pollution Control Division
Issuance 1
Issued to Whiting Oil and Gas Corporation
AIRS ID: 123/9893/008 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 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:l/www. cdphe.state.co. us/regulations/airreqs/100102agcccommonprovisionsreq. 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)
008
Benzene
71432
A
2,800
Yes
140
Toluene
108883
C
3,120
Yes
156
Xylenes
1330207
C
1,339
Yes
67
n -Hexane
110543
C
21,510
Yes
1,075
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Weight
of
Gas
Emission
Factors
Uncontrolled
Emission
Factors
Controlled
Source
Source
NOx
"""
0.138
lb/MMBtu
0.138
lb/MMBtu
TCEQ
CO
___
0.2755
Ib/MMBtu
0.2755
lb/MMBtu
TCEQ
VOC
46.89
35,041
lb/MMscf
1752
lb/MMscf
Engineering
Calculation
71432
Benzene
0.149
111 lb/MMscf
5.56
lb/MMscf
Engineering
Calculation
108883
Toluene
0.164
124 lb/MMscf
6.20
lb/MMscf
Engineeringat
n
Calculation
110543
n -Hexane
1.145
855 lb/MMscf
42.7
lb/MMscf
Engineering
Calculation
AIRS ID: 123/9893/008
Page 7 of 8
rsment!
f Public Health and Environment
Air Pollution Control Division
Note: The uncontrolled VOC and HAP emissions for this point were calculated using the 9/18/2012
analysis of a gas sample collected from the Wolf 35-2613H well. The controlled VOC and HAP emissions
factors for point 008; 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
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, n -hexane
PSD
Synthetic Minor Source of: VOC
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:
http://www.cdphe.state.co.us/arVoilpaspermittinchhtml
AIRS ID: 123/9893/008
Page 8 of 8
Produced Natural Gas Venting/Flaring Preliminary Analysis
Division Information
Engineer:
Peter Armington
Control Engineer:
Carissa Money
Review Date:
05/06/2013
Application Date:
01/17/2013
Facility Information
Permit No.
13WE1634
AIRs
County #
Facility #
9893
008
SEP-2
Whiting Oil and Gas Corporation
Wolf 35-2623H & Wolf 35-2613H Pad
SWSE Sec 35 T10N R59W
123 Weld
Point #
Facility Equipment ID
Colorado Department of Public Health and Environment
Air Pollution Control Division
Attainment Status
PM10
Attainment
PM2.5
Attainment
SOx
Attainment
NOx
Attainment
VOC
Attainment
CO
Attainment
Potentially Located within EAC - determine attainment status of NC
Company Name:
Source Name:
Source Location:
SIC:
1311
5007
Elevation (feet)
x
New Permit
(CP1)
Modification
(Issuance #)
APEN
Required/Permit
Fxemnt
APEN
Exempt/Permit
Exempt
Transfer of
Ownership
Notes
Equipment Description
This source vents natural gas from:
Emissions from this source are:
a well head separator
routed to an open -flame flare
Natural gas venting from a well head separator. Emissions from this source are routed to an open -
flame flare.
Emission Calculation Method
EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3)
Ex=Q*MW*Xx/C
Ex = emissions of pollutant x
Q = Volumetric flow rate/volume of gas processed
MW = Molecular weight of gas = SG of gas * MW of air
Xx = mass fraction of x in gas
C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm
Wolf 35-2613H
Throughput (Q)
MW
25 MMscf/yr
28.322 Ib/lb-mol
2875.0 scf/hr
0.001 MMscf/d
2.14 MMscf/mo
mole %
MW
lbx/Ibmol
mass fraction
E
Iblhr
lbtyr
tpy
Helium
0
4.0026
0.000
0.000
Helium
0.0
0
0.00
CO2
2.39
44.01
1.052
0.037
CO2
8.0
69896
34.95
N2
2.182
28.013
0.611
0.022
N2
4.6
40618
20.31
methane
57.575
16.041
9.236
0.326
methane
70.1
613717
306.86
ethane
13.78
30.063
4.143
0.146
ethane
31.4
275286
137.64
propane
13.1
44.092
5.7761
0.204
propane
43.8
383826
191.91
isobutane
1.435
58.118
0.8340
0.029
isobutane
6.3
55420
27.71
n -butane
5.036
58.118
2.9268
0.103
n -butane
22.2
194491
9/.25
isopentane
1.008
72.114
0.7269
0.026
isopentane
5.5
48304
24.15
n -pentane
1.407
72.114
1.0146
0.036
n -pentane
7.7
67424
33.71
cyclopentane
0.151
70.13
0.1059
0.004
cyclopentane
0.8
7037
3.52
n -Hexane
0.3760
86.18
0.3240
0.011
n -Hexane
2.5
21533
10.77
cyclohexane
0.1020
84.16
0.0858
0.003
cyclohexane •
0.7
5704
2.85
Other hexanes
0.586
86.18
0.5050
0.018
Other hexanes
• 3.8
33559
16.78
heptanes
0.402
100.21
0.4028
0.014
heptanes
3.1
26769
13.38
methylcyclohexane
0
98.19
0.0000
0.000
methylcyclohexanc
0.0
0
0.00
224-TMP
0
114.23
0.0000
0.000
224-TMP
0.0
0
0.00
Benzene
0.054
78.12
0.0422
0.001
Benzene
0.3
2803
1.40
Toluene
0.051
92.15
0.0470
0.002
Toluene
0.4
3123
1.56
Ethylbenzene
0.01
106.17
0.0106
0.000
Ethylbenzene
0.1
706
0.35
Xylenes
0.019
106.17
0.0202
0.001
Xylenes
0.2
1340
0.67
Produced Natural Gas Venting/Flaring Preliminary Analysis
Colorado Department of Public Health and Environment
Air Pollution Control Division
IC8+ Heavies I 0.336! 136.4891 0.4586 I 0:016 IC8+ Heavies I 3.5 I 30475
VOC mass fraction: 0.4689
28.322
Notes
Mole %, MW, and mass fractions from the Pawnee 16-13H gas analysis, dated 6/29/11.
Emissions are based on 8760 hours of operation per year,
I calculated the average MW of C8+ based on the average MW on the analysis for the gas.
Total VOC Emissions (Uncontrolled)
annual limit assuming 95% control
monthly limit assuming 95% control (lb/mo.)
15.24
441.3
22.1
3747.7
Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment
Air Pollution Control Division
Flaring Information
Equipment Descripton
Flare to combust produced gas until pipeline is available at this wellhead facility.
Manufacturer
Model
Serial Number
Gas Heating Value
Throughput
TBD
TBD
TBD
1538
38734.53
Btu/scf
MMBtu/yr
Combustion emission factor source: TCEQ
0.138
lb NOX/MMBtu
tpy NOX
0.2755
lb CO/MMBtu
tpy CO
2.67
Emissions Summary
5.34
1
2.67
tpy NOX
Uncontrolled/PTE
5.34
tpy CO
441.257
tpy VOC
Controlled
22.063
tpy VOC
'
Uncontrolled
Total (Ib/yr)
Bin
Scenario A
Reportable?
Controlled
Total (lb/yr)
Benzene
2803
A
Yes
140
Toluene
3123
C
Yes
156
Ethylbenzene
706
C
No
35
Xylenes
1340
C
Yes
67
n -hexane
21533
C
Yes
1077
224-TMP
0
C
No
0
Regulatory Applicability
AQCC Regulation 1
This source is subject to the opacity requirements for flares in Section Il.A.5:'No owner or operator
of a smokeless flare or other flare for the combustion.of waste gases shall allow or cause
emissions into the atmosphere of any air pollutant which is in excess of 30% opacity.'
AQCC Regulation 2 _
Section I.A applies to all emission sources. "No person, wherever located, shall cause or allow the
emission of odorous air contaminants from any single source such as to result in detectable odors
which are measured in excess of the following limits: For areas used predominantly for residential
or commercial purposes it is a violation if odors are detected after the odorous air has been diluted
with seven (7) or more volumes of odor free air."
Part A:
An APEN is required for this source because uncontrolled VOC emissions
exceed two tons per year in an attainment area.
Part B:
A permit is required for this source because uncontrolled VOC emissions from
this facility exceed five tons per year in an attainment area.
This source is not subject to Section 111.O.2 (Minor Source RACT) because it
is not located in a nonattainment area.
Is public comment
required?
Public Comment Required
Facility Status
This facility is a synthetic minor source of VOC/HAP for Title V applicability
This facility is a synthetic minor source of VOC for PSD applicability.
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO:
DATE ISSUED:
ISSUED TO:
13WE1635
Issuance 1
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 Wold 36-3624H Pad, located in the NENW of Section 36,
Township 10N, Range 59W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
Sep -1
005
Separator controlled by a 30' flare stack. Flare has a minimum
combustion efficiency of 95%. The flare is not enclosed.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR
QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED
IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen
days after issuance of this permit, by submitting a Notice of Startup form to the
Division. The Notice of Startup form may be downloaded online at
www.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, II.G.2).
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction fora period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
AIRS ID: 123/9969/005 Page 1 of 9
Wellhead Version 2012-1
grin
enf Public Health and Environment
( Air Pollution Control Division
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 except fugitive emissions from
equipment leaks 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.)
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
Equipment ID
AIRS
Point
Tons per Year
Emission Type
yp
NQ
VOC
CO
Sep -1
008
6.5
77.0
13.0
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.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from
each emission unit, on a rolling twelve (12) month total. By the end of each month a new
twelve-month total shall be calculated based on the previous twelve months' data. The
permit holder shall calculate emissions each month and keep a compliance record on site or
at a local field office with site responsibility, for Division review. This rolling twelve-month
total shall apply to all permitted emission units, requiring an APEN, at this facility.
8. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
AIRS ID: 123/9969/005 Page 2 of 9
f Public Health and Environment
Air Pollution Control Division
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
Sep -1
005
Separator controlled by a 30' flare stack
VOC
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
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
Sep -1
005
Natural gas flaring
51.1 MMSCF/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.
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)
OPERATING & MAINTENANCE REQUIREMENTS
14. Upon startup of these points, the applicant shall follow the operating and maintenance
(O&M) plan and record keeping format approved by the Division, in 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
AIRS ID: 123/9969/005 Page 3 of 9
f Public Health and Environment
Air Pollution Control Division
15. 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).
16. The operator shall complete an initial site specific extended gas analysis of the natural gas
produced at this site in order to verify the VOC, benzene, toluene, ethylbenzene, xylenes, n -
hexane, and 2,2,4-trimethylpentane 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. Results of site -specific sampling and analysis
shall be submitted to the Division as part of the self -certification and used to demonstrate
compliance with the emissions factors chosen for this emissions point.
Periodic Testing Requirements
17. 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
18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3,
Part A, Il.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.
19. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit)
shall apply to this source at any such time that this source becomes major solely by virtue of
a relaxation in any permit condition. Any relaxation that increases the potential to emit
above the applicable Federal program threshold will require a full review of the source as
though construction had not yet commenced on the source. The source shall not exceed
the Federal program threshold until a permit is granted. (Regulation No. 3 Part D).
GENERAL TERMS AND CONDITIONS
20. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
AIRS ID: 123/9969/005 Page 4 of 9
f Public Health and Environment
Air Pollution Control Division
21. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide "final" authority for this activity or operation of this source. Final authorization of
the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self -certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self -Certify for Final Authorization
section of this permit.
22. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the 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.
23. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
24. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the 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.
25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Peter Armington
Permit Engineer
Permit Histo
Issuance
ry
Date
Description
AIRS ID: 123/9969/005
Page 5 of 9
Issuance 1
This Issuance
f Public Health and Environment
Air Pollution Control Division
Issued to Whiting Oil and Gas Corporation
AIRS ID: 123/9969/005 Page 6 of 9
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 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.cdphe.state.co.us/req u lations/airreqs/100102agcccommon provisionsreq. 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
(Ib/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (Ib/yr)
008
Benzene
71432
A
19,149
Yes
957
Toluene
108883
C
22,837
Yes
1,142
Ethylbenzene
100414
C
2,860
Yes
143
Xylenes
1330207
C
5,004
Yes
250
n -Hexane
110543
C
144,859
Yes
7,243
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Weight
Percent of
Gas
Emission
Factors
Uncontrolled
Emission
Factors
Controlled
Source
NOx
0.138
lb/MMBtu
0.138
lb/MMBtu
TCEQ
CO
0.2755
lb/MMBtu
0.2755
lb/MMBtu
TCEQ
VOC
64.45
35,041
lb/mmscf
1752
lb/mmscf
Engineering
Calculation
71432
Benzene
0.4
375 lb/mmscf
18.8
lb/mmscf
Engineering
Calculation
108883
Toluene
0.5
447 lb/mmscf
22.4
lb/mmscf
Engineering
Calculation
100414
Ethylbenzene
0.1
56 lb/mmscf
2.8 lb/mmscf
Engineering
Calculation
AIRS ID: 123/9969/005
Page 7 of 9
entt f Public Health and Environment
Air Pollution Control Division
CAS
Pollutant
Weight
Percent of
Gas
Emission
Factors
Uncontrolled
Emission
Factors
Controlled
Source
1330207
Xylenes
0.1
98 lb/mmscf
4.9 lb/mmscf
Engineering
Calculation
110543
n -Hexane
3.0
28371b/mmscf
141.8
lb/mmscf
Engineering
Calculation
Note: The uncontrolled VOC and HAP emissions for this point were calculated using the 9/18/2012
analysis of a gas sample collected from the Pawnee 16-13H well. The controlled VOC and HAP emissions
factors for point 008; 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
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, n -hexane
PSD
Synthetic Minor Source of: VOC
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
SubpartA—SubpartKKKK
NSPS
Part 60, Appendixes
Appendix A — Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
SubpartA—SubpartZ
MACT
63.600-63.1199
Subpart AA — Subpart DDD
MACT
63.1200-63.1439
Subpart EEE — Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ — Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ — Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN — SubpartXXX)O(X
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:
http://www.cdphe.state.co.us/ap/oilqaspermitting.html
AIRS ID: 123/9969/005
Page 8 of 9
of Public Health and Environment
Air Pollution Control Division
AIRS ID: 123/9969/005 Page 9 of 9
Produced Natural Gas Venting/Flaring Preliminary Analysis
Division Information
Engineer:
Peter Armington
Control Engineer:
Carissa Money
Review Date:
05/06/2013
Application Date:
l!
01/17/2013
Facility Information
Permit No.
13WE1635
AIRs
County #
Facility #
123 Weld
9969
005
SEP-1
Whiting Oil and Gas Corporation
Wolf 36-3624H
NENW Sec 36 T10N R59W
Point #
Facility Equipment ID
Colorado Department of Public Health and Environment
Air Pollution Control Division
Attainment Status
PM10
Attainment
PM2.5
Attainment
SOx
Attainment
NOx
Attainment
VOC
Attainment
CO
Attainment
Potentially Located within EAC - determine attainment status of NC
Company Name:
Source Name:
Source Location:
SIC:
1311
4925
Elevation (feet)
x
New Permit
(CP1)
Modification
(Issuance #)
APEN
Required/Permit
Exempt
Transfer of
Ownership
Notes
APEN
Exempt/Permit
Exempt
Equipment Description
This source vents natural gas from:
a well head separator
Emissions from this source are:
routed to an open -flame flare
Natural gas venting from a well head separator. Emissions from this source are routed to an open -
flame flare.
Emission Calculation Method
EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3)
Ex = Q * MW*Xx/C
Ex = emissions of pollutant x
Q = Volumetric flow rate/volume of gas processed
MW = Molecular weight of gas = SG of gas * MW of air
Xx = mass fraction of x in gas
C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm
Throughput (Q)
MW
51 MMscf/yr
35.460 Ibllb-mot
5833.3 scf/hr 1
0.001 MMscr/d {
4.34 MMscf/mo
(
mole %
MW
lbx/Ibmol
mass fraction
E
lb/hr
lb/yr
tpy
Helium
0
4.0026
0.000
0.000
Helium
0.0
0
0.00
CO2
2.779
44.01
1.223
0.034
CO2
18.8
164900
82.45
N2
1.075
28.013
0.301
0.008
N2
4.6
40602
20.30
methane
48.213
16.041
7.734
0.218
methane
119.0
1042743
521.37
ethane
11.137
30.063
3.348
0.094
ethane
51.5
451421
225.71
propane
14.405
44.092
6.3515
0.179
propane
97.8
856357
428.18
isobutane
1.918
58.118
1.1147
0.031
isobutane
17.2
150294
75.15
n -butane
8.054
58.116
4.6806
0.132
n -butane
/2.0
631108
315.55
isopentane
2.1
72.114
1.5144
0.043
isopentane
23.3
204183
102.09
n -pentane
3.203
72.114
2.3098
0.065
n -pentane
35.6
311428
155.71
cyclopentane
0
70.13
0.0000
0.000
cyclopentane
0.0
0
0.00
n -Hexane
1.2480
86.18
1.0755
0.030
n -Hexane
16.6
145012
72.51
cyclohexane
0.3700
84.16
0.3114
0.009
cyclohexane
4.8
41985
20.99
Other hexanes
2.701
86.18
2.3277
0.066
Other hexanes
35.8
313843
156.92
heptanes
1.203
100.21
1.2055
0.034
heptanes
18.6
162539
81.27
methylcyclohexane
0
98.19
0.0000
0.000
methylcyclohexane
0.0
0
0.00
224-TMP
0
114.23
0.0000
0.000
224-TMP
0.0
0
0.00
Benzene
0.182
78.12
0.1422
0.004
Benzene
2.2
19170
9.58
Toluene
0.184
92.15
0.1696
0.005
Toluene
2.6
22861
11.43
Ethylbenzene
0.02
106.17
0.0212
0.001
Ethylbenzene
0.3
2863
1.43
Xylenes
0.035
106.17
0.0372
0.001
Xylenes
0.6
5010
2.51
Produced Natural Gas Venting/Flaring Preliminary Analysis
Colorado Department of Public Health and Environment
Air Pollution Control Division
IC8+ Heavies
Notes
Mole %, MW, and mass fractions from the Pawnee 16-13H gas analysis, dated 6/29/11.
Emissions are based on 8760 hours of operation per year.
I calculated the average MW of O8+ based on the average MW on the analysis for the gas.
1.173( 135.7531 1.5924 ( 0.045 1C8+ Heavies
VOC mass fraction: 0.6445 Total VOC Emissions (Uncontrolled)
35.460 annual limit assuming 95% control
monthly limit assuming 95% control (lb/mo.)
24.5 1 214698
107.35
1540.7
77.0
13085.2
Produced Natural Gas Venting/Flaring Preliminary Analysis
Flaring Information
Equipment Descriptbn
Flare to combust produced gas until pipeline is available at this wellhead facility.
Manufacturer
Model
Serial Number
Gas Heating Value
Throughput
TBD
TBD
TBD
1844
94228.4
Btu/scf
MMBtu/yr
Combustion emission factor source: TCEQ
0.138
lb NOX/MMBtu
tpy NOX
0.2755
lb CO/MMBtu
toy CO
6.50
12.98
Emissions Summary
6.50
tpy NOX
Uncontrolled/PTE
12.98
tpy CO
1540.676
tpy VOC
Controlled
77.034
tpy VOC
Colorado Department of Public Health and Environment
Air Pollution Control Division
Uncontrolled
Total (Iblyr)
Bin
Scenario A
Reportable?
Controlled
Total (Ib/yr)
Benzene
19170
A
Yes
958
Toluene
22861
C
Yes
1143
Ethylbenzene
2863
C
Yes
143
Xylenes
5010
C
Yes
251
n -hexane
145012
C
Yes
7251
224 -IMP
0
C
No
0
Regulatory Applicability
AQCC Regulation 1
This source is subject to the opacity requirements for flares in Section II.A.5:'No owner or operator
of a smokeless flare or other flare for the combustion of waste gases shall allow or cause
emissions into the atmosphere of any air pollutant which is in excess of 30% opacity.'
AQCC Regulation 2 _
Section I.A applies to all emission sources. "No person, wherever located, shall cause or allow the
emission of odorous air contaminants from any single source such as to result in detectable odors
which are measured in excess of the following limits: For areas used predominantly for residential
or commercial purposes it is a violation if odors are detected after the odorous air has been diluted
with seven (7) or more volumes of odor free air."
AQCC Regulation 3
Part A:
An APEN is required for this source because uncontrolled VOC emissions
exceed two tons per year in an attainment area.
Part B:
A permit is required for this source because uncontrolled VOC emissions from
this facility exceed five tons per year in an attainment area.
This source is not subject to Section III.D.2 (Minor Source RACT) because it
is not located in a nonattainment area.
Is public comment
required?
Public Comment Required
Facility Status
This facility is a synthetic minor source of VOC/HAP for Title V applicability.
This facility is a synthetic minor source of VOC for PSD applicability.
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(Provide Facility Equipment ID to identify how this equipment is referenced within your organization.]
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Section 02 — Re
Section 01— Administrative Information
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Change permit limit
Request to limit RAPs with a Federally enforceable limit on PTE .
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1700 Broadway, Suite 2300
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