HomeMy WebLinkAbout20131778.tiffSTATE OF COLORADO
John W. Hickenlooper, Governor
Christopher E. Urbina, MD, MPH
Executive Director and Chief Medical Officer
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 1, 2013
Dear Sir or Madam:
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
(303) 692-3090
RECEIVED
JUL 06201
COOMMIS 8 ERS
Colorado Department
of Public Health
and Environment
On July 4, 2013, the Air Pollution Control Division will publish a public notice for Whiting Oil and Gas
Corporation — Redtail Gas Plant, in the The Greeley Tribune. A copy of this public notice and the public
comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public
copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet
must be available for public inspection for a period of thirty (30) days from the date the public notice is
published. Please send any comment regarding this public notice to the address below.
Colorado Dept. of Public Health & Environment
APCD-S S -B I
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
` otheiL -1(t s(+3
CC PLI VW
2013-1778
STATE OF COLORADO
John W. Hickenlooper, Governor
Christopher E. Urbina, MD, MPH
Executive Director and Chief Medical Officer
Dedicated to protecting and improving the health and environment of the people of Colorado
4300 Cherry Creek Dr. S.
Denver, Colorado 80246-1530
Phone (303) 692-2000
Located in Glendale, Colorado
http://www.cdphe.state.co.us
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
(303)-692-3090
Website Title: Whiting Oil and Gas Corporation — Redtail Gas Plant — Weld County
Released To: The Greeley Tribune
On: July 1, 2013
Published: July 4, 2013
PUBLIC NOTICE OF A PROPOSED PROJECT
OR ACTIVITY WARRANTING PUBLIC COMMENT
Colorado Department
of Public Health
and Environment
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: Redtail Gas Plant
natural gas processing plant
NE T/4 of Section 21, Township ION, Range 58W, approximately 15 miles north from Raymer
Weld County
The proposed project or activity is as follows: The applicant proposes to build a new natural gas processing plant
with a capacity of 20MMscf/day
The Division has determined that this permitting action is subject to public comment per Colorado Regulation No.
3, Part B, Section III.C due to the following reason(s):
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and drafts of Construction Permits 13WE1450, I3 WE1129,
13 WE1130, 13WE1681 and 13 WE1682 have been filed with the Weld County Clerk's office. A copy of the draft
permits and the Division's analyses 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:
Rebecca Vasil
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:
DATE ISSUED:
ISSUED TO:
13WE1129
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 Redtail Gas Plant, located in the NE 1/4 of Section 21,
Township 10N, Range 58W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
FLR-1
008
The flare emissions are from routine operations including: purge
gas, membrane waste gas, as well as emissions from compressor
blowdowns, plant blowdowns, and NGL loadout vapors. The 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 etseq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED
IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen
days after commencement of operation, by submitting a Notice of Startup form to the
Division. The Notice of Startup form may be downloaded online at
www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of
the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No.
3, Part B, Section III.G.1 and can result in the revocation of the permit.
2. Within one hundred and eighty days (180) after 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).
AIRS ID: 123/9AD0 Page 1 of 8
Wellhead Version 2012-1
f Public Health and Environment
Air Pollution Control Division
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction for a period of eighteen
months or more; (Hi) does not complete construction within a reasonable time of the
estimated completion date. The Division may grant extensions of the deadline per
Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Reference: Regulation No. 3, Part B, Section III.E.)
5. The following information for all permitted equipment except fugitive emissions from
equipment leaks shall be provided to the Division within fifteen (15) days after
commencement of operation.
• manufacturer
• model number
• serial number
This information shall be included with the Notice of Startup submitted for the equipment.
(Reference: Regulation No. 3, Part B, III.E.)
6. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Monthly Limits:
Facility
Equipment ID
AIRS
point
Pounds per Month
Emission Type
NO„
VOC
CO
FLR-1
008
510
3975
2786
Point
(Note: Monthly limits are based on a 31 -day month.
The owner or operator shall calculate monthly emissions based on the calendar month.
Annual Limits:
Facility
Equipment ID
AIRS
point
Tons per Year
Emission Type
NO„
VOC
CO
FLR-1
008
3.0
23.4
16.4
Point
See "Notes to Permit Holder #4" for information on emission factors and methods used to calculate
limits.
AIRS ID: 123/9AD0
Page 2 of 8
f Public Health and Environment
Air Pollution Control Division
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from
each emission unit, on a rolling twelve (12) month total. By the end of each month a new
twelve-month total shall be calculated based on the previous twelve months' data. The
permit holder shall calculate emissions each month and keep a compliance record on site or
at a local field office with site responsibility, for Division review. This rolling twelve-month
total shall apply to all permitted emission units, requiring an APEN, at this facility.
8. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
FLR-1
008
Continuous- Pilot flare
VOC
PROCESS LIMITATIONS AND RECORDS
9. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the throughput shall be maintained by the applicant and made available
to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4)
Process/Consumption Limits
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
Monthly Limit
(31 Days)
FLR-1
008
Natural gas flaring
179 MMSCF/yr
15 MMSCF/mo
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.)
AIRS ID: 123/9ADO Page 3 of 8
f'Coloray De amen
f Public Health and Environment
Air Pollution Control Division
13. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable)
14. The owner or operator shall continuously monitor the process flare with a thermocouple to
ensure the continuous presence of a pilot flame.
15. The owner or operator shall continuously monitor the total gas volume routed to the flare by
a flow meter to show compliance with the emission limits covered in this permit.
OPERATING & MAINTENANCE REQUIREMENTS
16. 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
•
17. The operator shall complete an initial site specific extended gas analysis of the waste gas
produced at this site that is routed to the flare 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.
18. The owner or operator shall demonstrate compliance with Condition 12 using EPA Method
09 to measure opacity from the flare. (Reference: Regulation No. 1, Section II.A.5).
Periodic Testing Requirements
19. On an annual basis, the operator shall complete a site specific extended gas analysis of the
waste gas produced at this site that is routed to the flare in order to verify the VOC content
(weight fraction) of this emission stream used in the permit application. Results of testing
shall be used to determine site -specific emission factors using Division approved methods.
ADDITIONAL REQUIREMENTS
20. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3,
Part A, II.C)
a. Annually 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
AIRS ID: 123/9AD0 Page 4 of 8
f Public Health and Environment
Air Pollution Control Division
c. Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
21. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit)
shall apply to this source at any such time that this source becomes major solely by virtue of
a relaxation in any permit condition. Any relaxation that increases the potential to emit
above the applicable Federal program threshold will require a full review of the source as
though construction had not yet commenced on the source. The source shall not exceed
. the Federal program threshold until a permit is granted. (Regulation No. 3 Part D).
GENERAL TERMS AND CONDITIONS
22. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
23. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide "final" authority for this activity or operation of this source. Final authorization of
the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self -certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self -Certify for Final Authorization
section of this permit.
24. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the 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.
25. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
26. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This 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.
AIRS ID: 123/9AD0 Page 5 of 8
en Public Health and Environment
Air Pollution Control Division
27. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
28. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Rebecca Vasil
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Whiting Oil and Gas Corporation
AIRS ID: 123/9AD0 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/airregs/100102agcccom mon 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 (lb/yr)
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Gas
Weight
Fraction of
Gas (%)
Emission
Factors
Uncontrolled
Emission
Factors
Controlled
Source
NOx
0.068
lb/MMBtu
0.068
lb/MMBtu
AP -42
CO
---AP-42
0.37
lb/MMBtu
0.37
lb/MMBtu
VOC
32.7
5162
Ib/mmscf
261.56
lb/mmscf
Engineering
Calculation
110543
n -hexane
0.63
0.458
Ib/mmscf
0.268
Ib/mmscf
Engineering
' Calculation
Note: The uncontrolled VOC and HAP emissions for this point were calculated using the analysis of
a gas sample collected from several wells. The controlled VOC emissions factors are based
on the flare control efficiency of 95%.
AIRS ID: 123/9AD0
Page 7 of 8
7.7771
mentI 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, NOx, CO
PSD
Synthetic Minor Source of:
VOC, NOx, CO
MACT HH
Area Source Requirements: Not Applicable
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at
the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A— Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A — Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A — Subpart Z
MACT
63.600-63.1199
Subpart AA — Subpart DDD
MACT
63.1200-63.1439
Subpart EEE — Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ — Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ — Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN — Subpart XXXXX(
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. cd phe.state. co. us/ap/oi Igasperm ittinci. htm I
AIRS ID: 123/9AD0
Page 8 of 8
Construction Permit Application
Preliminary Analysis Summary
Section 1 — Applicant Information
Company Name:
Whiting Oil and Gas Corporation
Permit Number:
13WE1129
Source Location:
NE 1/4 Sec. 21 T10N R58W, Weld County (attainment)
Equipment Description:
Plant flare with a minimum combustion efficiency of 95%.
AIRS ID:
123-9ADO-008
Date:
March 27th 2013
Review Engineer:
Rebecca Vasil
Control Engineer:
Chris Laplante
Section 2 — Action Completed
Grandfathered
Modification
APEN Required/Permit Exempt
X
CP1
Transfer of Ownership
APEN Exempt/Permit Exempt
Section 3 — Applicant Completeness Review
Was the correct APEN submitted for this source type?
X
Yes
No
Is the APEN signed with an original signature?
X
Yes
No
Was the APEN filled out completely?
X
Yes
No
Did the applicant submit all required paperwork?
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?
December 26, 2012
Section 4 — Source Description
AIRS Point
Equipment Description
008
Flare is used for upsets and/or emergencies. This flare receives: purge gas,
membrane waste gas, as well as emissions from compressor blowdowns, plant
blowdowns, and NGL loadout emissions. The flare has a minimum combustion
efficiency of 95%. The flare is not enclosed.
Is this a portable source?
Yes
X
No
Is this location in a non -attainment area for any criteria
pollutant?
Yes
X
No
If "yes", for what pollutant?
PMto
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)
PMto
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
008
Site -specific (Refer to Section 14 for calculations)
Did the applicant provide actual process data for the emission inventory?
X
Yes
No
Basis for Potential to Emit (PTE)
AIRS Point
Process Consumption/Throughput/Production
008
490,000 scf/day => 178,850,000 scf/yr = 179 mmscf/yr
Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory)
AIRS Point
Process Consumption/Throughput/Production
Data Year
008
490,000 scf/day => 178,850,000 scf/yr = 179 mmscf/yr
NA
Basis for Permitted Emissions (Permit Limits)
AIRS Point
Process Consumption/Throughput/Production
008
490,000 scf/day => 178,850,000 scf/yr = 179 mmscf/yr
Does this facility use control devices?
X
Yes
No
AIRS Point
Process
Control Device Description
% Reduction Granted
008
of
Continuous- Pilot Plant Flare
95
Point
NO„
VOC
CO
Single HAP
Total HAP
PTE:
008
3.01
462
16.37
0.04
(n -hexane)
0.04
Uncontrolled point source
emission rate:
008
3.01
462
16.37
0.04
(n -hexane)
0.04
Controlled point source
emission rate:
008
3.01
23.4
16.37
0.024
(n -hexane)
0.024
Section 7 — Non -Criteria / Hazardous Air Pollutants
Pollutant
CAS #
BIN
Uncontrolled
Emission Rate
(lb/yr)
Are the
emissions
reportable?
Controlled Emission
r
Rate Ib! Y )
n -Hexane
110543
C
82
NO
48
Note: Regulation 3, Part A, Section Il.B.3.b APEN emission reporting requirements for non -criteria air
pollutants are based on potential emissions without credit for reductions achieved by control
devices used by the operator.
Section 8 —Testing Requirements
Will testing be required to show compliance with any emission rate or regulatory
standard?
X
Yes
No
If "yes", complete the information listed below
AIRS Point
Process
Pollutant
Regulatory Basis
Test Method
008
01
VOC,
HAPS
State only requirement
Site -specific gas
analysis
Page 2
Section 9 — Source Classification
Is this a new previously un-permitted source?
X
Yes
No
What is this facility classification?
True
Minor
X
Synthetic
Minor
Major
Classification relates to what programs?
X
Title V
X
PSD
NA NSR
X
MACT
Is this a modification to an existing permit?
Yes
X
No
If "yes" what kind of modification?
Minor
Synthetic
Minor
Major
Section 10 — Public Comment
Does this permit require public comment per CAQCC Regulation 3?
X
Yes
No
If "yes", for which pollutants? Why? VOC, NOx and CO
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.iii (subject to MACT)?
Yes
X
No
For Reg. 3, Part B, IIl.C.1.d (synthetic minor emission limits)?
X
Yes
No
Section 11 — Modeling
is modeling required to demonstrate compliance with National Ambient
Air Quality Standards (NAAQS)?
If "yes", for which pollutants? Why?
NOx emissions are less than 40 TPY.
Yes
X
No
AIRS Point
Section 12 — Regulatory Review
Regulation 1 - Particulate,. Srnoke, Carbon Monoxide and Sulfur:Dioxide
008
Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or
operator of a source shall allow or cause the emission into the atmosphere of any air
pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive
opacity readings taken at 15 -second intervals for six minutes. The approved reference test
method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix
A (July, 1992)) in all subsections of Section II. A and B of this regulation.
Section II.A.5 - Smokeless Flare or Flares for the Combustion of Waste Gases No owner
or operator of a smokeless flare or other flare for the combustion of waste gases shall
allow or cause emissions into the atmosphere of any air pollutant which is in excess of
30% opacity for a period or periods aggregating more than six minutes in any sixty
consecutive minutes.
Regulation 2 --Odor
008
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.
Re up cationa-APENS Construction{Permits 0•eratin• Perth its PSD
008
Part A-APEN Requirements
Criteria Pollutants:
Applicant is required to file an APEN since emissions exceed 2 tons per year VOC
008
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 11.D.3.a)
Regulation 6 - New Source Performance Standards
008
None
Regulation 7 -- Volatile Organic. Compounds
008
None
Regulation 8 .-:Hazardous Air:Pollutants
008
None
Page 3
Section 13 — Aerometric Information Retrieval System Coding Information
Point
Process
Process Description
Emission
Factor
Pollutant /
CAS #
Fugitive
(Y/N)
Emission Factor
Source
Control
(%)
008
01
.
5162
lb/MMscf
VOC
No
Engineering
Calculation
95
Flare
0.068
lb/MMBtu
NOx
No
AP -42,
Table 13.5-1
NA
0.37
Ib/MMBtu
CO
No
AP -42,
Table 13.5-1
NA
0.458
lb/MMscf
n -hexane
No
Engineering
Calculation
95
SCC
31000205 -Flares
Section 14 — Miscellaneous Application Notes
AIRS Point I 008 1 Flare
Emissions were calculated using:
(scf/hr) * (Ib/lb-mol) *(1-(95/100)) / (379.4 scf/Ib-mol) = lb/hr * (hr/yr) / 2000 lb/T) = TPY
VOC = (462 TPY * 2000 lb/T) / (179 mmscf/yr) = 5162 lb/mmscf
NOx and CO (from AP -42, Chapter 13, Table 13.5-1 (NOx = 0.068 lb/mmbtu; CO = 0.37 lb/mmbtu)
Emission factors for HAPS are:
To calculate emission factors, take the emissions (Ib/yr) and divide it by total throughput (mmscf/yr).
n -hexane = (82 Ib/yr) / 179 mmscf/yr = 0.458 lb/mmscf
Emissions generated from the flare are:
Uncontrolled Total (Ib/yr)
Controlled Total (Ib/yr)
NOx
6020
6020
VOC
924,000
46,820
CO
32,740
32,740
n -hexane
82
48
An extended gas analysis was provided in the application dated 03/27/2012. The gas analysis was
performed less than a year of submittal. An updated extended gas analysis will not be required because:
-an extended gas analysis was performed within a year of this submittal and included with this package
Page 4
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO:
13WE1130
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 Redtail Gas Plant, located in the NE1/4 Sec. 21 T10N
R58W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
FUG -1
009
Equipment leaks (fugitive VOCs) from a natural gas processing
plant.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO
AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et seq) TO THOSE GENERAL TERMS AND CONDITIONS
INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than
fifteen days after commencement of operation, by submitting a Notice of Startup
form to the Division. The Notice of Startup form may be downloaded online at
www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup
of the permitted source is a violation of Air Quality Control Commission (AQCC)
Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit.
2. Within one hundred and eighty days (180) after commencement of operation,
compliance with the conditions contained in this permit shall be demonstrated to the
Division. It is the owner or operator's responsibility to self -certify compliance with the
conditions. Failure to demonstrate compliance within 180 days may result in revocation
of the permit. (Reference: Regulation No. 3, Part B, II.G.2).
AIRS ID: 123/9AD0 Page 1 of 9
Fugitive SM/M Version 2012-2
Health and Environment
it Pollution Control Division
3. This permits c e if oopliatorkafuthe swi- for which this permit was
issued: (i) does not commence construction/modification or operation of this source
within 18 months after either, the date of issuance of this construction permit or the date
on which such construction or activity was scheduled to commence as set forth in the
permit application associated with this permit; (ii) discontinues construction for a period
of eighteen months or more; (iii) does not complete construction within a reasonable
time of the estimated completion date. The Division may grant extensions of the
deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B,
III.F.4.)
4. The operator shall 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 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
6. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Monthly Limits:
Facility
Equipment ID
AIRS
Point
Pounds per Month
Emission Type
VOC
FUG -1
009
1030
Fugitive
(Note: Monthly limits are based on a 31 -day month.)
The owner or operator shall calculate monthly emissions based on the calendar month.
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission Type
VOC
FUG -1
009
6.1
Fugitive
See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
During the first twelve (12) months of operation, compliance with both the monthly and
annual emission limitations is required. After the first twelve (12) months of operation,
compliance with only the annual limitation is required.
AIRS ID: 123/9ADO Page 2 of 9
Health and Environment
it Pollution Control Division
Compliance wnn t II be teal rned b ecording 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.
7. The operator shall calculate actual emissions from this emissions point based on
representative component counts for the facility with the most recent gas and liquids
analyses, as required in the Compliance Testing and Sampling section of this permit.
The operator shall maintain records of the results of component counts and sampling
events used to calculate actual emissions and the dates that these counts and events
were completed. These records shall be provided to the Division upon request.
STATE AND FEDERAL REGULATORY REQUIREMENTS
8. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation
of the source. During periods of startup, process modification, or adjustment of control
equipment visible emissions shall not exceed 30% opacity for more than six minutes in
any sixty consecutive minutes. Emission control devices subject to Regulation 7,
Sections XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation
No. 1, Section II.A.1. & 4.)
9. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
10. The fugitive emissions addressed by AIRS ID 009 are subject to the New Source
Performance Standards requirements of Regulation No. 6, Part A, Subpart OOOO,
Standards of Performance for Crude Oil and Natural Gas Production, Transmission and
Distribution including, but not limited to, the following:
§60.5365 Applicability: The group of all equipment, except compressors, within a
process unit for which you commence construction, modification or reconstruction
after August 23, 2011 is an affected facility per §60.5365(f).
§60.5400 Standards: The group of all equipment, except compressors, within a
process unit must comply with the requirements of §60.5400 and §60.5401.
• §60.5410: Owner or operator must demonstrate initial compliance with the
standards using the requirements in §60.5410(f).
• § 60.5415: Owner or operator must demonstrate continuous compliance with the
standards using the requirements in §60.5415(f).
• § 60.5421: Owner or operator must comply with the recordkeeping requirements of
§60.5421(b).
• § 60.5422: Owner or operator must comply with the reporting requirements of
paragraphs (b) and (c) of this section in addition to the requirements of § 60.487a(a),
(b), (c)(2)(i) through (iv), and (c)(2)(vii) through (viii).
11. The reciprocating compressors grouped with the fugitive emissions addressed by AIRS
ID 009 are subject to the New Source Performance Standards requirements of
Regulation No. 6, Part A, Subpart OOOO, Standards of Performance for Crude Oil and
AIRS ID: 123/9AD0 Page 3 of 9
Natural Gas Er
following:
• §60.5385(a) — Owner or operator must replace the reciprocating compressor rod packing
according to either paragraph §60.5385(a)(1) or (2).
o §60.5385(a)(1) - Before the compressor has operated for 26,000 hours. The
number of hours of operation must be continuously monitored beginning upon
initial startup of your reciprocating compressor affected facility, or October 15,
2012, or the date of the most recent reciprocating compressor rod packing
replacement, whichever is later.
o §60.5385(a)(2) - Prior to 36 months from the date of the most recent rod packing
replacement, or 36 months from the date of startup for a new reciprocating
compressor for which the rod packing has not yet been replaced.
• §60.5410 — Owner or operator must demonstrate initial compliance with the standards
as detailed in §60.5410(c).
• §60.5415 — Owner or operator must demonstrate continuous compliance with the
standards as detailed in §60.5415(c).
• §60.5420 - Owner or operator must comply with the notification, reporting, and
recordkeeping requirements as specified in §60.5420(a), §60.5420(b)(1),
§60.5420(b)(4), and §60.5420(c)(3).
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.)
COMPLIANCE TESTING AND SAMPLING
Initial. Testing Requirements
13. Within one hundred and eighty days (180) after commencement of operation, the owner
or operator shall complete the initial extended gas analysis of gas samples that are
representative of volatile organic compound (VOC) and hazardous air pollutants (HAP)
that may be released as fugitive emissions. This extended gas analysis shall be used in
the compliance demonstration as required in the Emission Limits and Records section of
this permit. The operator shall submit the results of the gas analysis and emission
calculations to the Division as part of the self -certification process to ensure compliance
with emissions limits.
14. Within one hundred and eighty days (180) after commencement of operation, 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
15. On an annual basis, the owner or operator shall complete an extended gas analysis of
gas samples that are representative of volatile organic compounds (VOC) and
hazardous air pollutants (HAP) that may be released as fugitive emissions. This
parnentOf P Health and Environment
{.ir Pollution Control Division
(t YM
,
and flistribution in_c.Liading, but not limited to, the
AIRS ID: 123/9AD0 Page 4 of 9
Health and Environment
r Pollution Control Division
extended gas ysi* shtheeornphance dstration as required in the
Emission Limits and Records section of this permit.
16. This facility is subject to the leak detection and repair (LDAR) requirements of 40 C.F.R
Part 60, Subpart OOOO.
ADDITIONAL REQUIREMENTS
17, A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation
No. 3, Part A, II.C)
a. Annually by April 30`h whenever a significant increase in emissions occurs as
follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions
of five (5) tons per year or more, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions
of five percent or 50 tons per year or more, whichever is less, above the level
reported on the last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less,
above the level reported on the last APEN submitted to the Division.
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
c. Whenever new control equipment is installed, or whenever a different type of
control equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
18. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit)
shall apply to this source at any such time that this source becomes major solely by
virtue of a relaxation in any permit condition. Any relaxation that increases the potential
to emit above the applicable Federal program threshold will require a full review of the
source as though construction had not yet commenced on the source. The source shall
not exceed the Federal program threshold until a permit is granted. (Regulation No. 3
Part D).
GENERAL TERMS AND CONDITIONS:
19. This permit and any attachments must be retained and made available for inspection
upon request. The permit may be reissued to a new owner by the APCD as provided in
AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership
and the submittal of a revised APEN and the required fee.
20. If this permit specifically states that final authorization has been granted, then the
remainder of this condition is not applicable. Otherwise, the issuance of this construction
permit does not provide "final" authority for this activity or operation of this source. Final
authorization of the permit must be secured from the APCD in writing in accordance with
the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section
III.G. Final authorization cannot be granted until the operation or activity commences
and has been verified by the APCD as conforming in all respects with the conditions of
AIRS ID: 123/9AD0 Page 5 of 9
f PFyplic=Health and Environment
it Pollution Control Division
the permit. Once =certificati . III paths .hbeen ewed and approved by the
Division, it will provide written documentation of such final authorization. Details for
obtaining final authorization to operate are located in the Requirements to Self -
Certify for Final Authorization section of this permit.
21. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the 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.
22. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with
the provisions of Section 25-7-114.5(7)(a), C.R.S.
23. Each and every condition of this permit is a material part hereof and is not severable.
Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire
permit and upon such occurrence, this permit shall be deemed denied ab initio. This
permit may be revoked at any time prior to self -certification and final authorization by the
Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality
Control Act and regulations of the Air Quality Control Commission (AQCC), including
failure to meet any express term or condition of the permit. If the Division denies a
permit, conditions imposed upon a permit are contested by the owner or operator, or the
Division revokes a permit, the owner or operator or owner or operator of a source may
request a hearing before the AQCC for review of the Division's action.
24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution
Prevention and Control Act or the regulations of the AQCC may result in administrative,
civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121
(injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S.
By:
Rebecca Vasil
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Whiting Oil and Gas Corporation
AIRS ID: 123/9AD0
Page 6 of 9
li'Health and Environment
it Pollution Control Division
Notes to Permit Holder - ime o
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 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 Pad 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 Pad II.E.1. of the Common Provisions
Regulation. See:
http://www. cdphe. state. co. us/requ lations/airregs/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)
009
Benzene
71432
A
90
Yes
28
5) The emission levels contained in this permit are based on the following emission factors:
Component
Gas Service
Heavy Oil
Light Oil
Water/Oil
Service
Control
Factor**
Connectors
935
0
318
0
30%
Flanges
448
0
124
0
30%
Open-ended Lines
0
0
0
0
0%
Pump Seals
0
0
10
0
0%
Valves
357
0
78
0
75%
Other*
54
A
0
0
75%
VOC Content (w£
fraction)
0.5077
0.0000 .
1.0000
0.0000
Benzene Content
(wt. fraction)
0.0019
0.0000
0.0000
0.0000
Toluene Content
(wt. fraction)
0.0021
0.0000
0.0000
0.0000
Ethylbenzene (wt.
fraction)
0.0002
0.0000
0.0000
0.0000
Xylenes Content
(wt. fraction)
0.0004
0.0000
0.0000
0.0000
n -hexane Content
(wt. fraction)
0.0146
0.0000
0.0000
0.0000
*Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms,
drains, dump arms, hatches, instrument meters, polish rods and vents
AIRS ID: 123/9AD0
Page 7 of 9
** Control factors frams,
oIora rapDe
C
TOC Emission Factors (kg/hr-component):
ealth and Environment
it Pollution Control Division
Component
Gas Service
Heavy Oil
Light Oil
Water/Oil
Service
Connectors
2.0E-04
7.5E-06
2.1E-04
1.1E-04
Flanges
3.9E-04
3.9E-07
1.1E-04
2.9E-06
Open-ended Lines
2.0E-03
1.4E-04
1.4E-03
2.5E-04
Pump Seals
2.4E-03
NA
1.3E-02
2.4E-05
Valves
4.5E-03
8.4E-06
2.5E-03
9.8E-05
Other
8.8E-03
3.2E-05
7.5E-03
1.4E-02
Source: EPA -453/R95-017.
Compliance with emissions limits in this permit will be demonstrated by using the TOC emission
factors listed in the table above with representative component counts, multiplied by the VOC content
from the most recent gas analysis.
6) in accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
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/Major Source of:
VOC, NOx and CO
PSD
Synthetic Minor/Major Source of:
NOx and CO
MACT HH
Area Source Requirements: Not Applicable
NSPS KKK
Not Applicable
NSPS OOOO
Applicable
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess. aov/
AIRS ID: 123/9AD0
Page 8 of 9
Health and Environment
it Pollution Control Division
Part 60: Standards`o-f rforiiiance
fO Stahrilhources
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/oiluasoermittino.html
AIRS ID: 123/9AD0 Page 9 of 9
Construction Permit Application
Preliminary Analysis Summary
Section 1 — Applicant Information
Company Name:
Whiting Oil and Gas Corporation
Permit Number:
13WE1130
Source Location:
NE 1/4 Sec. 21 T10N R58W, Weld County (attainment)
Equipment Description:
Fugitive emissions
AIRS ID:
123-9AD0-009
Date:
March 11th 2013
Review Engineer:
Rebecca Vasil
Control Engineer:
Chris Laplante
Section 2 — Action Completed
Grandfathered
I Modification
APEN Required/Permit Exempt
X
CP1
Transfer of Ownership
j APEN Exempt/Permit Exempt
Section 3 — Applicant Completeness Review
Was the correct APEN submitted for this source type?
X
Yes
No
Is the APEN signed with an original signature?
X
Yes
No
Was the APEN filled out completely?
X
Yes
No
Did the applicant submit all required paperwork?
X
Yes
No
Did the applicant provide ample information to determine emission rates?
X
Yes
No
If you answered "no" to any of the above, when did you mail an
Information Re uest letter to the source?
On what date was this application complete?
December 26, 2012
Section 4 — Source Description
AIRS Point
Equipment Description
009
Fugitive VOC leak emissions
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?
PM,o
CO
Ozone
Is this location in an attainment maintenance area for
an criteria ollutant?
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
009
EPA -453/R-95-017, Table 2-4
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
009
Equipment Type
Gas
Heavy Oil (or
Heavy Liquid)
Light Oil (or
Light Liquid)
Water/Oil
Connectors
935
318
Flanges
448
124
Open -Ended Lines
Pump Seals
10
Valves
357
78
Other
54
Basis
for Actual Emissions Reported During this APEN Filing (Reported to Inventory)
AIRS Point
Process Consumption/Throughput/Production
009
Equipment Type
Gas
Heavy Oil (or
Heavy Liquid)
Light Oil (or
Light Liquid)
Water/Oil
Connectors
935
318
Flanges
448
124
Open -Ended Lines
Pump Seals
10
Valves
357
78
Other
54
Basis for Permitted Emissions (Permit Limits)
AIRS Point
Process Consumption/Throughput/Production
009
Equipment Type
Gas
Heavy Oil (or
Heavy
Liquid)
Light Oil (or
Light Liquid)
Water/Oil
Connectors
935
318
Flanges
448
124
Open -Ended Lines
Pump Seals
10
Valves
357
78
Other
54
Does this source use a control device?
X
Yes (LDAR Program)
X
No
Section 6 — Emission Summary (tons per year)
Point
NO,
VOC
CO
Single HAP
Total HAP
PTE:
009
---
15.9
---
0.3 (n -Hexane)
0.5
Uncontrolled point
source emission rate:
009
---
15.9
---
0.3 (n -Hexane)
0.5
Controlled point
source emission rate:
009
---
6.04
---
0.11 (n -Hexane)
0.14
Section 7 — Non -Criteria / Hazardous Air Pollutants
Pollutant
CAS #
BIN
Uncontrolled
Emission Rate
(1b/yr)
Are the
emissions
reportable?
Controlled Emission
Rate (Iblyr)
Benzene
71432
A
90
Yes
28
Page 2
Toluene
108883
C
99
No
31
Ethylbenzene
100414
C
9
No
3
Xylenes
1330207
C
19
No
6
n -Hexane
110543
C
689
No
218
Note: Regulation 3, Part A, Section ll.B.3.b APEN emission reporting requirements for non -criteria air
pollutants are based on potential emissions without credit for reductions achieved by control
devices used by the operator.
Section 8 Testing Requirements
Will testing be required to show compliance with any emission rate or regulatory
standard?
X
Yes
No
If "yes", complete the information listed below
AIRS Point
Process
Pollutant
Regulatory Basis
Test Method
009
01
VOC,
HAPS
State only requirement
Site -specific gas
analysis
009
01
VOC,
HAPS
State only requirement
Hard count of
components
Section 9 — Source Classification
Is this a new previously un-permitted source?
X
Yes
No
What is this facility classification?
True
Minor
X
Synthetic
Minor
Major
Classification relates to what programs?
X
Title V
X
PSD
NA NSR
X
MACT
Is this a modification to an existing permit?
Yes
X
No
If "yes" what kind of modification?
Minor
Synthetic
Minor
Major
Section 10 — Public Comment
Does this permit require public comment per CAQCC Regulation 3?
X
Yes
No
If "yes", for which pollutants? Why?
VOC, NOx and CO
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.iii (subject to MACT)?
Yes
X
No
For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)?
X
Yes
No
Section 11 — Modeling
Is modeling required to demonstrate compliance with National Ambient
Air Quality Standards (NAAQS)?
If "yes", for which pollutants? Why?
Yes
X
No
AIRS Point
Section 12 — Regulatory Review
l gulation'1 - Particulate, Smoke, Carbon Monoxide andSulfurDioxide
009
Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator
of a source shall allow or cause the emission into the atmosphere of any air pollutant which
is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings
taken at 15 -second intervals for six minutes. The approved reference test method for
visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July,
1992)) in all subsections of Section II. A and B of this regulation.
Regulation 2 - Odor
Page 3
009
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
009
Part A-APEN Requirements
Criteria Pollutants: Applicant is required to file an APEN since emissions
exceed 2 tons per year VOC
009
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 ILD.3.a)
009
Part B, III.D.2 - RACT requirements for new or modified minor sources
This section of Regulation 3 requires RACT for new or modified minor sources located in
nonattainment or attainment/maintenance areas. This source is not located in the 8 -hour
ozone nonattainment area.
Since source is in attainment, RACT is not required.
Regulation 6 - New Source Performance Standards.
009
NSPS KKK: Equipment Leaks of VOC from onshore natural gas processing plants.
Affected facilities at onshore natural gas facilities (any processing site engaged in
the extraction of natural gas liquids from field gas, fractionation of mixed natural gas
liquids (NGLs) or both).
Is this source at a "natural gas processing plant?" Yes
Is this source subject to NSPS KKK? NO
Source is a natural gas processing plant built after August 23, 2011
009
NSPS 0000: Standards of Performance for Crude Oil and Natural Gas Production,
Transmission and Distribution. For fugitive emissions at natural gas processing
plants subject to NSPS 0000. This subpart establishes emission standards and
compliance schedules for the control of volatile organic compounds (VOC) and
sulfur dioxide (SO2 ) emissions from affected facilities that commence construction,
modification or reconstruction after August 23, 2011.
Is this source at a "natural gas processing plant?" Yes
Is this source subject to NSPS 0000? Yes
Source is a natural gas processing plant built after August 23,2011
Regulation 7 — Volatile Organic Compounds
009
Section XII.G: If facility is a natural gas processing plant located in non -attainment
area, then subject to Section XII.G.
Regulation 8 — Hazardous Air Pollutants
009
MACT HH: If facility is MAJOR source for HAP at a natural gas processing plant
ONLY (summation of HAPS of dehydrators and fugitives), then fugitive emissions
are subject to MACT HH.
Is this facility considered MAJOR for HAPS? No
Is this source subject to MACT HH? No
Source not a major for HAPs
Section 13 — Aerometric Information Retrieval System Coding Information
Point
Process
Process Description
Pollutant /
CAS #
Fugitive
(Y/N)
Emission Factor
Source
Control
(%)
009
01
Fugitive VOC Leak
Emissions
VOC
Yes
EPA -453/R-95-017,
Table 2-4
NA
SCC
31000220: All Equip. Leak Fugitives (Valves, flanges, connections, seals, drains)
Page 4
Section 14 — Miscellaneous Application Notes
AIRS Point
009
Fugitive VOC Leak Emissions
The control factors for the active LDAR program
Connectors 30%
Flanges 30%
Open -Ended Lines 0%
Pump Seals
Valves
Other
0%
75%
75%
are:
Page 5
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:
13WE1450
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 Redtail Gas Plant, located in the NE 1/4 of Section 21,
Township 1 ON, Range 58W, 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
007
Three (3) 400 BBL fixed roof storage tanks used to store
condensate. Emissions from these tanks are controlled by an
open flare.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR
QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED
IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen
days after commencement of operation, by submitting a Notice of Startup form to the
Division. The Notice of Startup form may be downloaded online at
www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of
the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No.
3, Part B, Section III.G.1 and can result in the revocation of the permit.
2. Within one hundred and eighty days (180) after commencement of operation, compliance
with the conditions contained in this permit shall be demonstrated to the Division. It is the
owner or operator's responsibility to self -certify compliance with the conditions. Failure to
demonstrate compliance within 180 days may result in revocation of the permit. (Reference:
Regulation No. 3, Part B, 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
AIRS ID: 123/9AD0 Page 1 of 8
Condensate Tank SM/M Version 2012-1
\
application ass ' wit {hrs pe mJt (ii) d ,o _ues conaM.iction for a period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
estimated completion date. The Division may grant extensions of the deadline per
Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Reference: Regulation No. 3, Part B, Section III.E.)
5. The 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.
lid'Health and Environment
it Pollution Control Division
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Monthly Limits:
Facility
Equipment ID
AIRS
Point
Pounds per Month
Emission Type
NO
VOC
CO
TK-1, TK-2, TK-3
007
----
170
---
Point
(Note: Monthly limits are based on a 31 -day month.)
The owner or operator shall calculate monthly emissions based on the calendar month.
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission Type
NO
VOC
CO
TK-1, TK-2, TK-3
007
---
1.0
---
Point
See "Notes to Permit Holder for information on emission factors and methods used to calculate limits.
During the first twelve (12) months of operation, compliance with both the monthly and
annual emission limitations is required. After the first twelve (12) months of operation,
compliance with only the annual limitation is required.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from
each emission unit, on a rolling twelve (12) month total. By the end of each month a new
twelve-month total shall be calculated based on the previous twelve months' data. The
permit holder shall calculate emissions each month and keep a compliance record on site or
at a local field office with site responsibility, for Division review. This rolling twelve-month
total shall apply to all permitted emission units, requiring an APEN, at this facility.
7. 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: 123/9AD0 Page 2 of 8
iHealth and Environment
it Pollution Control Division
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
TK-1, TK-2,
TK-3
007
Continuous -Pilot Open Flare
VOC and HAPs
PROCESS LIMITATIONS AND RECORDS
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
Monthly Limit
(31 days)
TK-1, TK-2,
TK-3
007
Condensate throughput
2900
BBUyr
246
BBUmonth
The owner or operator shall calculate monthly process rates based on the calendar month.
During the first twelve (12) months of operation, compliance with both the monthly and
annual throughput limitations is required. After the first twelve (12) months of operation,
compliance with only the annual limitation is required.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder shall calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
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 Number 3, Part B, III.E.)
(State only enforceable)
10. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable)
11. The flare covered by this permit shall be designed and operated in accordance with
§60.18(b). If a flare is used to control emissions of volatile organic compounds to comply
with §60.18(b), it shall have no visible emissions during normal operations, be operated with
a flame present at all times, and a Method 22 must be conducted in order to determine
compliance.
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.
AIRS ID: 123/9ADO Page 3 of 8
f P blid'Health and Environment
Air Pollution Control Division
Revisions to otri q m rjs
p- �a - ®ject,o.,e;., sn appo�al prior to implementation.
(Reference: Regulation No. 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
13. The operator shall complete site specific sampling including a compositional analysis of the
pre -flash pressurized condensate routed to these storage tanks and a sales oil analysis to
determine RVP and API gravity. Testing shall be in accordance with the guidance contained
in PS Memo 05-01. Results of testing shall be used to determine a site -specific emissions
factor 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.
14. The owner or operator shall demonstrate compliance with Condition 11, using EPA Method
22 to measure opacity from the flare.
ADDITIONAL REQUIREMENTS
15. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3,
Part A, II.C)
a. Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of
five (5) tons per year or more, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of
five percent or 50 tons per year or more, whichever is less, above the level reported
on the last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above
the level reported on the last APEN submitted to the Division.
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
c. Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
16. 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: 123/9AD0 Page 4 of 8
GENERAL TERMS °' a., r• N
Health and Environment
it Pollution Control Division
17. 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.
18. 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.
19. 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.
20. 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.
21. 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.
22. 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.
23. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
AIRS ID: 123/9AD0 Page 5 of 8
By:
Health and Environment
it Pollution Control Division
Rebecca Vasil
Permit Engineer
Permit Histo
Issuance
Date
Description
issuance 1
This Issuance
Issued to Whiting Oil and Gas Corporation
AIRS ID: 123/9AD0 Page 6 of 8
Notes to Permit Holder
time o e 5slianee.
lics'Health and Environment
it Pollution Control Division
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.cdphe.state.co. us/regulations/ai rregs/100102agcccom mon 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 (lb/yr)
007
Benzene
71432
A
80
YES
4.4
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Emission Factors
Uncontrolled
lb/BBL
Condensate
Throughput
Emission Factors
Controlled
lb/BBL
Condensate
Throughput
Source
VOC
13.7
0.685
CDPHE
71432
Benzene
0.024
0.0012
CDPHE
Note: The controlled emissions factors for 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, NOx, CO
AIRS ID: 123/9AD0
Page 7 of 8
Depa pnenl f lic'Health and Environment
P it Pollution Control Division
PSD
Aluitaintlidgiabr.aprcetaai
VOC, NOx, CO
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 : //ec fr. gp oac ce ss. 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/oilgaspermitting.html
AIRS ID: 123/9AD0 Page 8 of 8
Construction Permit Application
Preliminary Analysis Summary
Section 1 —Applicant Information
Company Name:
Whiting Oil and Gas Corporation
Permit Number:
13WE1450
Source Location:
NE 1/4 Sec. 21 T10N R58W, Weld County (attainment)
Equipment Description:
3-400bbl Condensate Storage tanks
AIRS ID:
123-9AD0-007
Date:
March 26`" 2013
Review Engineer:
Rebecca Vasil
Control Engineer:
Chris Laplante
Section 2 — Action Completed
Grandfathered
Modification
APEN Required/Permit Exempt
X
CP1
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 i
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?
December 26th 2013
Section 4 — Source Description
AIRS Point
Equipment Description
007
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?
PM1°
CO
, Ozone
Is this location in an attainment maintenance area for
any criteria pollutant?
Yes
X
No
CO
Ozone
If "yes", for what pollutant?
(Note: These pollutants are subject to minor source
RACT per Regulation 3, Part B, Section III.D.2)
PM1c
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
I Section 5— Emission Estimate Information I
AIRS Point
Emission Factor Source
007
CDPHE Condensate Storage Tank Emission Factors
Did the applicant provide actual process data for the emission inventory?
X
Yes I
No
Basis for Potential to Emit (PTE)
AIRS Point ! Process Consumption/Throughput/Production
007
3480 BBL per year (2900 x 1.2)
Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory)
AIRS Point
Process Consumption/Throughput/Production
Data Year
007 ,I 2900 BBL per year
NA
Basis for Permitted Emissions (Permit Limits)
AIRS Point Process Consumption/Throughput/Production
007 i 2900 BBL per year
Does this source use a control device?
X
Yes
No
I
AIRS Point I Process
Control Device Description
% Reduction
Granted
007
01
Continuous -Pilot Flare
95
Section 6 — Emission Summary (tons per year)
Point
NO,
VOC
CO
Single HAP
Total HAP
PTE:
007
---
24
---
0.37 (n -Hexane)
0.40
Uncontrolled point
source emission rate:
007
---
19.9
---
0.30 (n -Hexane)
0.34
Controlled point
source emission rate:
007
---
1.0
---
0.015 (n -Hexane)
0.017
Section 7 — Non -Criteria / Hazardous Air Pollutants
Uncontrolled
Are the
Controlled Emission
Pollutant
CAS #
BIN
Emission Rate
(lb/yr)
emissions
reportable?
Ib! r
Rate ( y )
Benzene
71432
A
70
Yes
4
n -Hexane
110543
C
609
No
30
Note: Regulation 3, Part A, Section ll.B.3.b APEN emission reporting requirements for non -criteria air
pollutants are based on potential emissions without credit for reductions achieved by control
devices used by the operator.
Section 8 —Testing Requirements
Will testing be required to show compliance with any emission rate or regulatory
standard?
X
Yes
No
If "yes'', complete the information listed below
AIRS Point
Process
Pollutant
Regulatory Basis
Test Method
007
01
VOC,
HAPs
PS Memo 05-01
Liquids Analyses
according to PS
Memo 05-01
Page 2
Section 9 — Source Classification
Is this a new previously un-permitted source?
X
Yes
No
What is this facility classification?
True
Minor
X
Synthetic
Minor
Major
Classification relates to what programs?
X
Title V
X
PSD
NA NSR
X
MACT
Is this a modification to an existing permit?
Yes
X
No
If "yes" what kind of modification?
Minor
Synthetic
Minor
Major
Section 10 — Public Comment
Does this permit require public comment per CAQCC Regulation 3?
X
Yes
No
If "yes", for which pollutants? Why? VOC, NOx, CO
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)?
X
Yes
No
Section 11 — Modeling
Is modeling required to demonstrate compliance with National Ambient
Air Quality Standards (NAAQS)?
If "yes", for which pollutants? Why?
Yes
X
No
AIRS Point
Section 12 — Regulatory Review
Regulation 1 - Particulate, Smoke, Carbon Monoxideand Sulfur Dioxide
007
Section 1I.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
007
Section I.A - No person, wherever located, shall cause or allow the emission of odorous air
contaminants from any single source such as to result in detectable odors which are
measured in excess of the following limits: For areas used predominantly for residential or
commercial purposes it is a violation if odors are detected after the odorous air has been
diluted with seven (7) or more volumes of odor free air.
Re• ulatiorn 1- APENs;-`Construction Permits„;0perating Permits, PSD
007
Part A-APEN Requirements
Criteria Pollutants: Applicant is required to file an APEN since emissions
exceed 2 tons per year VOC
007
Part B — Construction Permit Exemptions
Applicant is required to obtain a permit since uncontrolled VOC emissions from this
facility are greater than the 5.0 TPY threshold (Reg. 3, Part B, Section lLD.3.a)
Regulation 6 - New Source Performance Standards
007
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
Storage vessels are not greater than 471 bbl
Page 3
Re®ulation 7 — Volatile Organic Compounds
007
XII. VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS
(Applicant is not subject to the emission control requirements for condensate tanks
since it is located in an attainment area.)
XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS...
(Applicant is not currently subject to this since actual uncontrolled emissions are
less than 20 tpy of VOC.)
Regulation 8"- Hazardous Air Pollutants
007
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.
007
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
(%)
007
01
Midstream
Condensate
Storage Tanks
326.1905
lb/1000 gal
throughput
V0C
No
CDPHE PS Memo 05-01
(converted to lb/1000 gal).
95
0.5714
lb/1000 gal
throughput
Benzene /
71432
No
CDPHE PS Memo 05-01
(converted to lb/1000 gal)
95
5.0
lb/1000 gal
throughput
n -Hexane
/ 110543
No
CDPHE PS Memo 05-01
(converted to lb/1000 gal)
95
SCC
40400311 - Fixed Roof Tank, Condensate, working+breathing+flashing losses
Section 14— Miscellaneous Application Notes
AIRS Point
This source is not located in the 8 -hour ozone non -attainment area (Weld County is in partial attainment).
Therefore, the provisions of Regulation 7, Section XII do not apply to this source. The statewide
requirements of Regulation 7, Section XVII.C do not apply to this source since actual uncontrolled
emissions are less than 20 tpy.
007
Condensate Storage Tanks
The original application for the condensate tanks was a GP01. If the GP01 was used, that would make
the tanks NSPS OOOO applicable because of the 39 tpy bubble limit. The operator then decided to use
an individual permit in order to limit emissions below 6 tpy so NSPS OOOO would not be triggered.
The APEN originally had a higher throughput (3650 bbl/year), causing the VOC to be greater than 20tpy
(25 tpy). This would mean that Regulation 7, Section XVII.C would apply and an open flare could not be
used to control the tanks. Tom Gibbons of Whiting requested a change in throughput to 2900 bbl/year in
order to have Regulation 7, Section XVII.C not apply so they could use an open flare instead of an
enclosed flare. The result was a lowering of uncontrolled VOC emissions from 25 tpy to 19.9 tpy.
Page 4
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO:
13WE1681
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 Redtail Gas Plant, located in the NE 1/4 of Section 21,
Township 10N, Range 58W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
GEN-1
010
One (1) Solar Tubines, Model Saturn T-1201 MKII, Serial Number
TBD, simple cycle, natural-gas fired, combustion turbine rated at
11.2 MMBtu/hr heat input (LVH) based on 100% load and 59.0
degrees Fahrenheit ambient temperature. Carbon monoxide
emissions from the turbine are controlled by a selective catalytic
oxidation unit.
This turbine may be replaced with another Solar Turbines Saturn T-1201 MKII turbine in
accordance with the temporary turbine replacement provision or with another Solar Turbines
Saturn T-1201 MKII in accordance with the permanent replacement provision of the Alternate
Operating Scenario (AOS), included in this permit as Attachment A.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR
QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED
IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen
days after commencement of operation, by submitting a Notice of Startup form to the
Division. The Notice of Startup form may be downloaded online at
www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of
the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No.
3, Part B, Section III.G.1 and can result in the revocation of the permit.
AIRS ID: 123/9AD0 Page 1 of 16
Turbine SM/M Version 2012-1
pftFieF1 of Public Health and Environment
Air Pollution Control Division
Within one hundred and eighty days (180) after commencement of operation, compliance
with the conditions contained in this permit shall be demonstrated to the Division. It is the
owner or operator's responsibility to self -certify compliance with the conditions. Failure to
demonstrate compliance within 180 days may result in revocation of the permit. (Reference:
Regulation No. 3, Part B, II.G.2).
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
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, Pad B, III.F.4.)
The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as pad of the self -certification process.
(Reference: Regulation No. 3, Part B, Section III.E.)
5. The following information shall be provided to the Division within fifteen (15) days after
commencement of operation.
• manufacturer
• model number
• serial number
This information shall be included with the Notice of Startup submitted for the equipment.
(Reference: Regulation No. 3, Part B, III.E.)
6. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Monthly Limits CASE 1:
Facility
Equipment ID
AIRS
Point
Pounds per Month
Emission Type
NO„
VOC
CO
SO2
GEN-1
010
2446
17
798
17
Point
Monthly Limits CASE 2:
Facility
Equipment ID
AIRS
Point
Pounds per Month
Emission Type
NO,
VOC
CO
SO2
GEN-1
010
741
3
240
5
Point
AIRS ID: 123/9AD0
Page 2 of 16
oi'Public Health and Environment
Air Pollution Control Division
(Note: Monthly limits are based on a 31 -day month.)
The owner or operator shall calculate monthly emissions based on the calendar month.
Annual Limits CASE 1:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission Type
NO,{
VOC
CO
SO2
GEN-1
010
14.4
0.1
4.7
0.1
Point
See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Annual Limits CASE 2:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission Type
NOx
VOC
CO
SO2
GEN-1
010
4.36
0.02
1.41
0.03
Point
See "Notes to Permit Holder'forinformation on emission factors and methods used to calculate limits.
During the first twelve (12) months of operation, compliance with both the monthly and
annual emission limitations is required. After the first twelve (12) months of operation,
compliance with only the annual limitation is required.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from
each emission unit, on a rolling twelve (12) month total. By the end of each month a new
twelve-month total shall be calculated based on the previous twelve months' data. The
permit holder shall calculate emissions each month and keep a compliance record on site or
at a local field office with site responsibility, for Division review. This rolling twelve-month
total shall apply to all permitted emission units, requiring an APEN, at this facility.
8. For the purposes of permitted emissions limits and fuel use CASE 1 represents periods of
operation when the turbine is used for generating prime power at this gas plant. During
prime power production the emissions points covered under points 003 and 006 shall not
operate (listed the specific compressor points). CASE 2 represents periods of operation
when the turbine is used for backup power generation only. During CASE 2 scenario, all
other permitted emissions points at the facility may operate. The operator of this facility shall
track and record the periods of time, fuel use and emissions which occurs during each of
CASE 1 and CASE 2 operational scenarios. Records shall be made available to the Division
upon request.
9. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
GEN-1
010
SCO
CO
AIRS ID: 123/9AD0
Page 3 of 16
t of Public Health and Environment
Air Pollution Control Division
PROCESS LIMITATIONS AND RECORDS
10. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rate shall be maintained by the owner or operator
and made available to the Division for inspection upon request. (Reference: Regulation 3,
Part B, II.A.4)
Process/Consumption Limits CASE 1:
Facility
Dment
Equipment
AIRS
Point
Process Parameter
Annual
Limit
Monthly
Limat(31
d Ys)
GEN-1
010
Consumption of natural gas as a
fuel
62.72
MMscf/yr
5.33
MMscf/month
Process/Consumption Limits CASE 2:
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual
Limit
Monthly
Limit (31
days)
GEN-1
010
Consumption of natural gas as a
fuel
18.96
MMscf/yr
1.61
MMscf/month
the owner or operator shall calculate monthly process rates based on the calendar month
During the first twelve (12) months of operation, compliance with both the monthly and
annual throughput limitations is required. After the first twelve (12) months of operation,
compliance with only the annual limitation is required.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder shall calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
11. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the
subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.)
(State only enforceable)
12. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of
the source. During periods of startup, process modification, or adjustment of control
equipment visible emissions shall not exceed 30% opacity for more than six minutes in any
sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections
XII.C.1.d or XVIl.B.1.c shall have no visible emissions. (Reference: Regulation No. 1,
Section II.A.1. & 4.)
13. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable)
14. This source is subject to the Particulate Matter and Sulfur Dioxide Emission Regulations of
Regulation 1 including, but not limited to, the following(Regulation 1, Section lll.A.1)::
a. No owner or operator shall cause or permit to be emitted into the atmosphere from
any fuel -burning equipment, particulate matter in the flue gases which exceeds the
following (Regulation 1, Section III.A.1)::
AIRS ID: 123/9ADO Page 4 of 16
Public Health and Environment
Air Pollution Control Division
(i)
For fuel burning equipment with designed heat inputs greater than 1x106
BTU per hour, but less than or equal to 500x106 BTU per hour, the following
equation will be used to determine the allowable particulate emission
limitation.
PE=0.5(FI)-6.26
Where:
PE = Particulate Emission in Pounds per million BTU heat input.
Fl = Fuel Input in Million BTU per hour.
b. Emissions of sulfur dioxide shall not emit sulfur dioxide in excess of the following
combustion turbine limitations. (Heat input rates shall be the manufacturer's
guaranteed maximum heat input rates).
New sources (Regulation 1, Section VI.B.4.c):
(i) Combustion Turbines with a heat input of less than 250 Million BTU per hour:
0.8 pounds of sulfur dioxide per million BTU of heat input.
15. This source is subject to the New Source Performance Standards requirements of
Regulation 6, Part B including, but not limited to, the following (Regulation 6, Part B, Section
II):
a. Standard for Particulate Matter — On and after the date on which the required
performance test is completed, no owner or operator subject to the provisions of this
regulation may discharge, or cause the discharge into the atmosphere of any
particulate matter which is:
For fuel burning equipment generating greater than one million but less than
250 million Btu per hour heat input, the following equation will be used to
determine the allowable particulate emission limitation:
PE=0.5(FI)"o.26
Where:
PE is the allowable particulate emission in pounds per million Btu heat input.
Fl is the fuel input in million Btu per hour.
If two or more units connect to any opening, the maximum allowable
emission rate shall be the sum of the individual emission rates.
(i)
(ii) Greater than 20 percent opacity.
b. Standard for Sulfur Dioxide — On and after the date on which the required
performance test is competed, no owner or operator subject to the provisions of this
regulation may discharge, or cause the discharge into the atmosphere sulfur dioxide
in excess of:
(i)
Sources with a heat input of less than 250 million Btu per hour: 0.8 lbs.
SO2/million Btu.
16. The combustion turbines are subject to the New Source Performance Standards
requirements of Regulation No. 6, Part A, Subpart GG, Standards of Performance for
Stationary Combustion Turbines including, but not limited to, the following:
• 40 CFR, Part 60, Subpart A — General Provisions
• §60.4332 — Standard for Nitrogen Oxides
o §60.332 (a) - On and after the date on which the performance test required by
§ 60.8 is completed, every owner or operator subject to the provisions of this
subpart shall comply with the following,
AIRS ID: 123/9AD0 Page 5 of 16
e o'r' Public Health and Environment
Air Pollution Control Division
(2) No owner or operator subject to the provisions of this subpart shall
cause to be discharged into the atmosphere from any stationary gas
turbine, any gases which contain nitrogen oxides in excess of:
14.4)
STD =0.0150 Y +F
where:
STD = allowable ISO corrected (if required as given in § 60.335(b)(1))
NOx emission concentration (percent by volume at 15 percent
oxygen and on a dry basis),
Y = manufacturer's rated heat rate at manufacturer's rated peak load
(kilojoules per watt hour), or actual measured heat rate based
on lower heating value of fuel as measured at actual peak load
for the facility. The value of Y shall not exceed 14.4 kilojoules
per watt hour, and
F = NOx emission allowance for fuel -bound nitrogen as defined in
paragraph (a)(4) of this section.
(3) The use of F in paragraphs (a)(1) and (2) of this section is optional.
That is, the owner or operator may choose to apply a NOx allowance for
fuel -bound nitrogen and determine the appropriate F -value in accordance
with paragraph (a)(4) of this section or may accept an F -value of zero.
(4) If the owner or operator elects to apply a NOx emission allowance for
fuel -bound nitrogen, F shall be defined according to the nitrogen content
of the fuel during the most recent performance test required under § 60.8
as follows:
Fuel -bound nitrogen (percent by
weight)
F (NOxpercent by volume)
N ≤.015
0
0.015 <N≤0.1
0.04 (N)
0.1<N50.25
0.004+0.0067(N-0.1)
N >0.25
0.005
Where:
N = the nitrogen content of the fuel (percent by weight).
or:
Manufacturers may develop and submit to EPA custom fuel -bound
nitrogen allowances for each gas turbine model they manufacture. These
fuel -bound nitrogen allowances shall be substantiated with data and must
AIRS ID: 123/9AD0
Page 6 of 16
Public Health and Environment
Air Pollution Control Division
be approved for use by the Administrator before the initial performance
test required by § 60.8. Notices of approval of custom fuel -bound nitrogen
allowances will be published in the FEDERAL REGISTER.
o §60.332 (k) - Stationary gas turbines with a heat input greater than or equal to
10.7 gigajoules per hour (10 million Btu/hour) when fired with natural gas are
exempt from paragraph (a)(2) of this section when being fired with an emergency
fuel.
• §60.333 - Standard for Sulfur Dioxide.
o §60.333 (a)- No owner or operator subject to the provisions of this subpart shall
cause to be discharged into the atmosphere from any stationary gas turbine any
gases which contain sulfur dioxide in excess of 0.015 percent by volume at 15
percent oxygen and on a dry basis or
o §60.330 (b) - No owner or operator subject to the provisions of this subpart shall
burn in any stationary gas turbine any fuel which contains total sulfur in excess of
0.8 percent by weight (8000 ppmw).
• §60.334 — Monitoring of Operations
• H60.335— Test Methods and Procedures
17. This source is subject to the New Source Performance Standards requirements of
Regulation 6, Part A, Subpart A, General Provisions, apply.
a. At all times, including periods of start-up, shutdown, and malfunction, the facility and
control equipment shall, to the extent practicable, be maintained and operated in a
manner consistent with good air pollution control practices for minimizing emissions.
Determination of whether or not acceptable operating and maintenance procedures
are being used will be based on information available to the Division, which may
include, but is not limited to, monitoring results, opacity observations, review of
operating and maintenance procedures, and inspection of the source. (Reference:
Regulation 6, Part A. General Provisions from 40 CFR 60.11(d))
b. No article, machine, equipment or process shall be used to conceal an emission
which would otherwise constitute a violation of an applicable standard. Such
concealment includes, but is not limited to, the use of gaseous diluents to achieve
compliance with an opacity standard or with a standard which is based on the
concentration of a pollutant in the gases discharged to the atmosphere. (§60.12)
c. Written notification of construction and initial startup dates shall be submitted to the
Division as required under §60.7.
d. Records of startups, shutdowns, and malfunctions shall be maintained, as required
under §60.7.
e. Performance tests shall be conducted as required under §60.8.
OPERATING & MAINTENANCE REQUIREMENTS
18. 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.)
AIRS ID: 123/9AD0 Page 7 of 16
Public Health and Environment
Air Pollution Control Division
Initial Testing Requirements
19. This turbine is subject to the initial testing requirements of 40 C.F.R. Part 60, Subpart GG,
as referenced in this permit.
Periodic Testing Requirements
20. The operator shall conduct, at a minimum, semi-annual portable analyzer monitoring of the
turbine exhaust outlet emissions of nitrogen oxides (NOx) and carbon monoxide (CO) to
monitor compliance with the emissions limits. Results of all tests conducted shall be kept on
site and made available to the Division upon request.
ADDITIONAL REQUIREMENTS
21. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3,
Part A, II.C)
a. Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of
five (5) tons per year or more, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of
five percent or 50 tons per year or more, whichever is less, above the level reported
on the last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above
the level reported on the last APEN submitted to the Division.
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
c. Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
f. Within 14 calendar days of commencing operation of a permanent replacement
turbine under the alternative operating scenario outlined in this permit as Attachment
A. The APEN shall include the specific manufacturer, model and serial number and
horsepower of the permanent replacement turbine, the appropriate APEN filing fee
and a cover letter explaining that the owner or operator is exercising an alternative -
operating scenario and is installing a permanent replacement turbine. Submittal of
an updated APEN is also required for replacement of components if such
replacement results in a change of serial number.
22. 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
AIRS ID: 123/9AD0 Page 8 of 16
OT Public Health and Environment
Air Pollution Control Division
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:
23. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
24. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide "final" authority for this activity or operation of this source. Final authorization of
the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self -certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self -Certify for Final Authorization
section of this permit.
25. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the owner or operator and is conditioned upon conduct of the activity, or
construction, installation and operation of the source, in accordance with this information and
with representations made by the owner or operator or owner or operator's agents. It is valid
only for the equipment and operations or activity specifically identified on the permit.
26. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
27. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the owner or operator, or the Division revokes a permit, the
owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
28. 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.
29. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
AIRS ID: 123/9AD0 Page 9 of 16
Are -7 —)Public
. sue,,; �._
e oY Public Health and Environment
Air Pollution Control Division
By:
Rebecca Vasil
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Whiting Oil and Gas Corporation
AIRS ID: 123/9AD0 Page 10 of 16
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 lI.E.1. of the Common Provisions Regulation. See:
http://www.cdphe.state.co. us/regulations/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.
CASE 1:
AIRS
Point
Pollutant
CAS #
BIN
Uncontrolled
Emission
Rate
(Ib/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (lb/yr)
010
---
---
---
---
---
---
CASE 2:
AIRS
Point
Pollutant
- CAS #
BIN
Uncontrolled
Emission
Rate
(Ib/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (Ib/yr)
010
---
---
---
---
---
---
5) The emission levels contained in this permit are based on the following emission factors:
CAS
Pollutant
Emission
Uncontrolled
lb/MMBtu
Factors
PPMV
-
Source
Emission Factors
Ib/MMBtu
— Controlled
PPMV
Source
NOx
5.98E-01
150
Mfr
5.98E-01
150
Mfr
CO
9.71E-01
400
Mfr
1.95E-01
400
Mfr
VOC
2.10E-03
---
AP -42
2.10E-03
---
AP -42
Emission factors are based on a Brake -Specific Fuel Consumption Factor of 11,169 Btu/hp-hr, a site -
rated horsepower value of 1,001 HP and a fuel heat value of 767 Btu/scf.
AIRS ID: 123/9AD0
Page 11 of 16
oPublic Health and Environment
Air Pollution Control Division
3 ara �•: cl l
kse
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, NOx, CO
PSD
Synthetic Minor Source of:
VOC,NOx,CO
MACT YYYY
Area Source: Not Applicable
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at
the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A — Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A — Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A — Subpart Z
MACT
63.600-63.1199
Subpart AA — Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ — Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ — Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN — Subpart XXXXXX
9) An Oil and Gas Industry Construction Permit Self -Certification Form is included with this permit packet.
Please use this form to complete the self -certification requirements as specified in the permit conditions.
Further guidance on self -certification can be found on our website at:
http://www.cdphe.state.co.us/ap/oilciaspermittinch html
AIRS ID: 123/9AD0 Page 12 of 16
or Public Health and Environment
Air Pollution Control Division
ATTACHMENT A:
ALTERNATIVE OPERATING SCENARIOS
TURBINES WITHOUT CONTINUOUS EMISSIONS MONITORING
August 16, 2011
1. Routine Turbine Component Replacements
The following physical or operational changes to the turbines in this permit are not considered a
modification for purposes of NSPS GG, major stationary source NSR/PSD, or Regulation No. 3,
Part B. Note that the component replacement provisions apply ONLY to those turbines subject to NSPS
GG. Neither pre-GG turbines nor post GG turbines (i.e. KKKK turbines) can use those provisions.
1) Replacement of stator blades, turbine nozzles, turbine buckets, fuel nozzles, combustion chambers,
seals, and shaft packings, provided that they are of the same design as the original.
2) Changes in the type or grade of fuel used, if the original gas turbine installation, fuel nozzles, etc. were
designed for its use.
3) An increase in the hours of operation (unless limited by a permit condition)
4) Variations in operating loads within the engine design specification.
5) Any physical change constituting routine maintenance, repair, or replacement.
Turbines undergoing any of the above changes are subject to all federally applicable and state only
requirements set forth in this permit (including monitoring and record keeping). If replacement of any of
the components listed in (1) or (5) above results in a change in serial number for the turbine, a letter
explaining the action as well as a revised APEN and appropriate filing fee shall be submitted to the
Division within 30 days of the replacement.
Note that the repair or replacement of components must be of genuinely the same design. Except in
accordance with the Alternate Operating Scenario set forth below, the Division does not consider that this
allows for the entire replacement (or reconstruction) of an existing turbine with an identical new one or one
similar in design or function. Rather, the Division considers the repair or replacements to encompass the
repair or replacement of components at a turbine with the same (or functionally similar) components.
2. Alternative Operating Scenarios
The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of
combustion turbines and turbine components has been reviewed in accordance with the requirements of
Regulation No. 3., Part A, Section WA, Operational Flexibility- Alternative Operating Scenarios,
Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source
New Source Review and Prevention of Significant Deterioration, and it has been found to meet all
applicable substantive and procedural requirements. This permit incorporates and shall be considered a
Construction Permit for any turbine or turbine component replacement performed in accordance with this
AOS, and the owner or operator shall be allowed to perform such turbine or turbine component
replacement without applying for a revision to this permit or obtaining a new Construction Permit.
AIRS ID: 123/9AD0 Page 13 of 16
2.1 Turbine Replacement
of Public Health and Environment
Air Pollution Control Division
The following AOS is incorporated into this permit in order to deal with a turbine breakdown or
periodic routine maintenance and repair of an existing onsite turbine that requires the use of a
temporary replacement turbine. "Temporary" is defined as in the same service for 90 operating days
or less in any 12 month period. "Permanent" is defined as in the same service for more than 90
operating days in any 12 month period. The 90 days is the total number of days that the turbine is in
operation. If the turbine operates only part of a day, that day shall count as a single day towards the
90 -day total. The compliance demonstrations and any periodic monitoring required by this AOS are in
addition to any compliance demonstrations or periodic monitoring required by this permit.
Any permanent turbine replacement under this AOS shall result in the replacement turbine being
considered a new affected facility for purposes of NSPS and shall be subject to all applicable
requirements of that Subpart including, but not limited to, any required Performance Testing.
All replacement turbines are subject to all federally applicable and state -only requirements set forth in
this permit (including monitoring and record keeping).
The results of all tests and the associated calculations required by this AOS shall be submitted to the
Division within 30 calendar days of the test or within 60 days of the test if such testing is required to
demonstrate compliance with the NSPS requirements. Results of all tests shall be kept on site for
five (5) years and made available to the Division upon request.
The owner or operator shall maintain a log on -site and contemporaneously record the start and stop
date of any turbine replacement, the manufacturer, date of manufacture, model number, horsepower,
and serial number of the turbine (s) that are replaced during the term of this permit, and the
manufacturer, model number, horsepower, and serial number of the replacement turbine.
2.1.1 The owner or operator may temporarily replace an existing turbine that is covered by this permit
with a turbine that is the exact same make and model as the existing turbine without modifying
this permit, so long as the temporary replacement turbine complies with the emission limitations
for the existing permitted turbine and other requirements applicable to the original turbine.
Measurement of emissions from the temporary replacement turbine shall be made as set forth
in section 2.2.
2.1.2 The owner or operator may permanently replace the existing turbine that is covered by this
permit with a turbine that is the exact same make and model as the existing turbine without
modifying this permit so long as the permanent replacement turbine complies with the emission
limitations and other requirements applicable to the original turbine as well as any new
applicable requirements for the replacement turbine. Measurement of emissions from the
temporary replacement turbine shall be made as set forth in section 2.2.
2.1.3 An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and
serial number and horsepower of the permanent replacement turbine shall be filed with the
Division for the permanent replacement turbine within 14 calendar days of commencing
operation of the replacement turbine. The APEN shall be accompanied by the appropriate
APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative
operating scenario and is installing a permanent replacement turbine. This AOS cannot be
used for permanent turbine replacement of a grandfathered or permit exempt turbine or a
turbine that is not subject to emission limits. The owner or operator shall agree to pay fees
based on the normal permit processing rate for review of information submitted to the Division
in regard to any permanent turbine replacement.
AIRS ID: 123/9AD0 Page 14 of 16
2.2 Portable Analyzer Testing
Public Health and Environment
Air Pollution Control Division
Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping
Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss.
streamlining the testing requirements.
Note that the testing required by this Condition may be used to satisfy the periodic testing requirements
specified by the permit for therelevant time period (i.e. if the permit requires quarterly portable analyzer
testing, this test conducted under the AOS will serve as the quarterly test and an additional portable
analyzer test is not required for another three months).
The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required
by this Condition, if approved in advance by the Division.
The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the
exhaust from the replacement turbine using a portable flue gas analyzer within seven (7) calendar days of
commencing operation of the replacement turbine.
All portable analyzer testing required by this permit shall be conducted using the most current version of
the Division's Portable Analyzer Monitoring Protocol as found on the Division's website. Results of the
portable analyzer tests shall be used to monitor the compliance status of this unit.
For comparison with an annual-(tons/year) or short term (lbs/Unit of time) emission limit, the results of the
tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or
year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation
the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever
applies.
For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or
concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement
turbine will be subject to, the results of the test shall be converted to the appropriate units as described in
the above -mentioned Portable Analyzer Monitoring Protocol document.
If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the
absence of credible evidence to the contrary, the source may certify that the turbine is in compliance with
both the NOX and CO emission limitations for the relevant time period.
Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if
the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission
limitations, the'turbine will be considered to be out of compliance from the date of the portable analyzer
test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or
until the turbine is taken offline.
2.3 Applicable Regulations for Permanent Turbine Replacements
2.3.1 NSPS for Stationary Gas Turbines: 40 CFR 60, Subpart GG
§60.330 Applicability and designation of affected facility.
(a) The provisions of this subpart are applicable to the following affected facilities: All stationary gas
turbines with a heat input at peak load equal to or greater than 10.7 gigajoules (10 million Btu) per
hour, based on the lower heating value of the fuel fired.
(b) Any facility under paragraph (a) of this section which commences construction, modification, or
reconstruction after October 3, 1977, is subject to the requirements of this part except as provided
in paragraphs (e) and U) of §60.332.
AIRS ID: 123/9AD0 Page 15 of 16
et oil Public Health and Environment
Air Pollution Control Division
A Subpart GG applicability determination as well as an analysis of applicable Subpart GG
monitoring, record keeping, and reporting requirements for the permanent turbine replacement shall
be included in any request for a permanent turbine replacement
Note that under the provisions of Regulation No. 6. Part B, Section I.B. that Relocation of a source
from outside of the State of Colorado into the State of Colorado is considered to be a new source,
subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to
Colorado becomes equivalent to the commence construction date for purposes of determining the
applicability of NSPS GG requirements).
2.3.2 NSPS for Stationary Combustion Turbines: 40 CFR 60, Subpart KKKK
§60.4305 Does this subpart apply to my stationary combustion turbine?
(a) If you are the owner or operator of a stationary combustion turbine with a heat input at peak load
equal to or greater than 10.7 gigajoules (10 MMBtu) per hour, based on the higher heating value of
the fuel, which commenced construction, modification, or reconstruction after February 18, 2005,
your turbine is subject to this subpart. Only heat input to the combustion turbine should be included
when determining whether or not this subpart is applicable to your turbine. Any additional heat input
to associated heat recovery steam generators (HRSG) or duct burners should not be included when
determining your peak heat input. However, this subpart does apply to emissions from any
associated HRSG and duct burners.
(b) Stationary combustion turbines regulated under this subpart are exempt from the requirements
of subpart GG of this part. Heat recovery steam generators and duct burners regulated under this
subpart are exempted from the requirements of subparts Da, Db, and Dc of this part.
A Subpart KKKK applicability determination as well as an analysis of applicable Subpart KKKK
monitoring, recordkeeping, and reporting requirements for the permanent turbine replacement shall
be included in any request for a permanent turbine replacement
Note that under the provisions of Regulation No. 6. Part B, Section I.B. that Relocation of a source
from outside of the State of Colorado into the State of Colorado is considered to be a new source,
subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to
Colorado becomes equivalent to the commence construction date for purposes of determining the
applicability of NSPS KKKK requirements).
2.4 Additional Sources
The replacement of an existing turbine with a new turbine is viewed by the Division as the installation of a
new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an
advanced construction permit review. The AOS cannot be used for additional new emission points for any
site; a turbine that is being installed as an entirely new emission point and not as part of an AOS-approved
replacement of an existing onsite turbine has to go through the appropriate Construction/Operating
permitting process prior to installation
AIRS ID: 123/9AD0 Page 16 of 16
Construction Permit Application
Preliminary Analysis Summary
Section 1 — Applicant Information
Company Name:
Whiting Oil and Gas Corporation
Permit Number(s):
13WE1681
Source Location:
Red Tail Gas Plant
NE 1/4 of Section 21 of T10N, R58W, Weld County
Equipment Description:
Turbine
AIRS ID: , 123/9AD0/010
Date:
April 30th 2013
Review Engineer:
Rebecca Vasil
Control Engineer:
Chris Laplante
Section 2 — Action Completed
X
CP1
Modification
APEN Required/Permit Exempt
Final Approval
Transfer of Ownership
APEN Exempt/Permit Exempt
Section 3 — Applicant Completeness Review
Was the correct APEN submitted for this source type?
X
Yes
No
Is the APEN signed with an original signature?
X
Yes
No
Was the APEN filled out completely?
X
Yes
No
Did the applicant submit all required paperwork?
X
Yes
No
Did the applicant provide ample information to determine emission rates?
X
Yes
No
If you answered "no" to any of the above, when did you mail an
Information Request letter to the source?
On what date was this application complete?
April 23"' 2013
ISection 4 — Source Description
AIRS Point
Equipment Description
010
One (1) Solar Tubines, Model Saturn T-1201 MKII, Serial Number TBD, simple
cycle, natural-gas fired, combustion turbine rated at 11.2 MMBtu/hr (LVH) based
on 100% load and 59.0 degrees Fahrenheit ambient temperature. This turbine is
equipped with SoLoNOx technology. This turbine may be temporarily or
permanently replaced under the Alternative Operating Scenario (AOS) provisions
contained in Attachment A.
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?
PKo
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
Page 1
Is this source located in the 8 -hour ozone non -
attainment region? (Note: If "yes" the provisions
i
of Regulation 7, Sections XII and XVI may
Yes X
No
apply)
Section 5 - Emission Estimate Information
AIRS Point
Emission Factor Source
010
Emissions from the turbine are based on manufacturer's data for NOR, CO. AP -42 Tables
for VOC. PM and HAPS.
Did the applicant provide actual process data for the emission inventory? i l: Yes
X
No
Basis for Potential to Emit (PTE)
AIRS Point
Process Consumption/Throughput/Production
010
(CASE 1)
62.72 MMSCF natural gas consumed by turbine per year
010
(CASE 2)
18.96 MMSCF natural gas consumed by turbine per year
Basis for Permitted Emissions (Permit Limits)
AIRS Point
Process Consumption/Throughput/Production
010
(CASE 1)
62.72 MMSCF per year (Based on natural gas heat value of 767 btu/scf)
010
(CASE 2)
18.96 MMSCF per year (Based on natural gas heat value of 767 btu/scf)
Does this source use a control device?
X
Yes
No
AIRS Point
Process
Control Device Description
Pollutant
% Reduction
Granted
010
01
SCO (SoLowNOx considered process)
CO
80
Point
(process)
pM
SO2
NO,r
VOC
CO
Single HAP
Total HAPs
PTE
010
(CASE 1)
0.16
0.082
14.41
0.05
23.39
0.0171
(Formaldehyde)
0.02
010
(CASE 2)
0.05
0.025
4.36
0.02
7.07
0.005
(Formaldehyde)
0.01
Uncontrolled
emission rates:
010
(CASE 1)
0.16
0.082
14.41
0.05
23.39
0.0171
(Formaldehyde)
0.02
0105
(CASE 2)
0.05
0.025
4.36
0.02
7.07
(Formaldehyde)
0.01
Controlled point
source emission
rate:
010
(CASE 1)(Formaldehyde)
0.16
0.082
14.41
0.05
4.68
0.0171
0.02
010
(CASE 2)
0.05
0.025
4.36
0.02
1.41
0.005
(Formaldehyde)
0.01
Section 7 — Non -Criteria / Hazardous Air Pollutants
AIRS Point
Pollutant
CAS #
BIN
_
Uncontrolled
Emission Rate
(lb/yr)
Arc the
emissions
reportable?
Controlled
Emission Rate
(ib/yr)
010
(CASE 1)
Formaldehyde
50000
A
34.1
NO
N/A
Benzene
71432
A
0.577
NO
N/A
Toluene
108883
C
6.25
NO
N/A
Ethylbenzene
100414
C
1.54
NO
N/A
Xyene
1330207
C
3.08
NO
N/A
Page 2
Acetaldehyde
75070
A
1.92
NO
N/A
010
(CASE 2)
Formaldehyde
50000
A
10.3
NO
N/A
Benzene
71432
A
0.174
NO
N/A
Toluene
108883
C
1.89
NO
N/A
Ethylbenzene
100414
C
0.465
NO
N/A
Xylene
1330207
C
0.93
NO
N/A
Acetaldehyde
75070
A
0.581
NO
N/A
Note: Regulation 3, Part A, Section 11.B.3.b APEN emission reporting requirements for non -criteria air
pollutants are based on potential emissions without credit for reductions achieved by control
devices used by the operator.
Section 8 —Testing Requirements
Will testing be required to show compliance with any emission rate or regulatory
standard?
X
Yes
No
If "yes", complete the information listed below
AIRS Point
Process
Pollutant
Regulatory Basis
Test Method
010
01 & 02
NOx
NSPS GG periodic performance test
SOx
NSPS GG periodic performance test
Section 9 — Source Classification
Is this a new previously un-permitted source?
X
Yes
I No
i
What is this facility classification? I
True
Minor
X
Synthetic
Minor
Major
Classification relates to what programs?
X
Title V
X
PSD
NA NSR
X
MACT
Is this a modification to an existing permit?
Yes
X
No
If "yes" what kind of modification?
Minor
Synthetic
Minor
Major
Section 10 — Public Comment
Does this permit require public comment per CAQCC Regulation 3?
X
Yes
No
If "yes", for which pollutants? Why?
NOx, CO, VOC
For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)?
Yes
X
No
For Reg. 3, Part B, I11.C.1.c.iii (subject to MACT)?
Yes
X
No
For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)?
X
Yes
No
Section 11 — Modeling
Is modeling required to demonstrate compliance with National Ambient
Air Quality Standards (NAAQS)?
If "yes", for which pollutants? Why?
Yes
X
No
Page 3
Section 13—Aerometric Information Retrieval System Coding Information
Point
Process
Process Description
Emission
Factor
Pollutant /
CAS #
Fugitive
(Y/N)
Emission Factor
Source
Control
(%)
010
001
0.0034
lb/MMBtu fuel
heat input
SO2
No
AP -42 Table
3.1-2a
0.0
0.06008
lb/MMBtu fuel
heat input
NOx
No
Solar
Manufacturer
0.0
0.06096
lb/MMBtu fuel
heat input
CO
No
Solar
Manufacturer
80
0.00698
lb/MMBtu fuel
heat input
VOC
No
Solar
Manufacturer
0.0
0.00071
Ib/MMBtu fuel
heat input
Formaldehyde
No
AP -42 Table
3.1-3
0.0
0.000012
Ib/MMBtu fuel
heat input
Benzene
No
AP -42 Table
3.1-3
0.0
0.000133
lb/MMBtu fuel
heat input
Toluene
No
AP -42 Table
- 3.1-3
0.0
0.000033
lb/MMBtu fuel
heat input
Ethylbenzene
No
AP -42 Table
3.1-3
0.0
0.000065
lb/MMBtu fuel
heat input
Xylene
No
AP -42 Table
3.1-3
0.0
0.000041
lb/MMBtu fuel
heat input
Acetaldehyde
No
AP -42 Table
3.1-3
0.0
SCC
20200201 — Internal Combustion Engines: Industrial: Natural Gas: Turbine
Page 4
Section 14 —Miscellaneous Application Notes
AIRS Point
010
Solar Saturn T-1201 MKII Turbine for Electric Generation
A natural gas -fired, 800 -kW, Solar Saturn T-1201 MKII combustion turbine (GEN-1) will
provide electric power until line power is available from the utility company, at which time the
unit will provide backup electric power to the plant. The unit is capable of running all electrical
services at the Redtail Gas Plant.
Since the turbine will initially provide prime electric power before line power is established, two emission
scenarios are provided. The scenarios were established to limit facility wide NOx emissions to below 40
tpy in order to avoid modeling requirements.
1. Case 1 (prime power): annual fuel consumption is limited to 62.72 MMscf/yr (to limit facility -wide NOx
to less than 40 tpy). It is assumed that one inlet compressor (ENG-3) and one refrigeration compressor
(ENG-6) are not yet operating while the turbine is providing prime power.
2. Case 2 (backup power): annual fuel consumption is limited to 18.96 MMscf/yr (to limit facility -wide
NOx to less than 40 tpy). It is assumed that ENG-3 and ENG-6 have been installed and are operating
while the turbine is designated to provide backup power.
The turbine will be fired by natural gas produced at the facility and is rated at 1001 HP. The turbine is Dry
Low NOx (SoLowNOx) design in which combustion is staged to minimize NOx emissions. This turbine is
not equipped with a duct burner.
For the purpose of this analysis the SoLowNOx design of the turbine is considered integral to the process
and not an add-on control device. The turbine is equipped with selective catalytic oxidation (SCO) to
control emissions; a conservative estimate is that SCO will provide 80% control of CO emissions.
This turbine is subject to NSPS GG :
This is an existing turbine manufactured prior to February 18,
2005, thus predating the NSPS Subpart KKKK applicability date. Consequently, the turbine is
subject to NSPS Subpart GG and will meet the applicable NOx and SO2 emissions limits (150
ppmv for each pollutant). Solar Turbines provided the following turbine uncontrolled emissions
data (see Attachment C):
NOx = 6.7 lb/hr (150 ppmv)
CO = 10.88 lb/hr (400 ppmv)
Page 5
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
PERMIT NO: 13WE1682
DATE ISSUED:
ISSUED TO:
CONSTRUCTION PERMIT
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 Redtail Gas Plant, located in the NE 1/4 of Section 21,
Township 10N, Range 58W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment ID
AIRS
Point
Description
GEN-2
011
One (1) Make: TO BE DETERMINED, Model: TO BE
DETERMINED, S/N: TO BE DETERMINED, diesel -fired,
reciprocating internal combustion engines, having a site
rated output at or below 361 HP or 250 kW, powering
generator sets. This engine is equipped with no controls.
This emission unit is used as an emergency generator,
running all electrical services at the office building.This
engine are subject to NSPS liii Tier 3 Standards.
This engine may be replaced with another engine in accordance with the temporary engine
replacement provision or with the manufacturer and model submitted to the Division per
Requirements to Self -Certify for Final Authorization in accordance with the permanent
replacement provision of the Alternate Operating Scenario (AOS), included in this permit as
Attachment A.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO
AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS
INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than
fifteen days after commencement of operation, by submitting a Notice of Startup
form to the Division. The Notice of Startup form may be downloaded online at
www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup
AIRS ID: 123/9AD0
Page 1 of 12
Diesel Engine SM/M Version 2012-1
Cowcado D( pa
4 or Public Health and Environment
Air Pollution Control Division
of the permitted source is a violation of Air Quality Control Commission (AQCC)
Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit.
2. Within one hundred and eighty days (180) after commencement of operation,
compliance with the conditions contained in this permit shall be demonstrated to the
Division. It is the owner or operator's responsibility to self -certify compliance with the
conditions. Failure to demonstrate compliance within 180 days may result in revocation
of the permit. (Reference: Regulation No. 3, Part B, II.G.2).
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; (H) discontinues construction for a period
of eighteen months or more; (iii) does not complete construction within a reasonable
time of the estimated completion date. The Division may grant extensions of the
deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B,
III.F.4.)
The following information shall be provided to the Division within fifteen (15) days after
commencement of operation.
• manufacture date
• construction date
• order date
• date of relocation into Colorado
• 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. Within thirty days (30) after commencement of operation of the engine, the
owner/operator shall submit to the Division a modified APEN specifying the equipment
as installed, including details such as but not limited to, horsepower, make, model, serial
number, and emission factors.
6. 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.)
7. The operator shall retain the permit final authorization letter issued by the Division after
completion of self -certification, with the most current construction permit. This
construction permit alone does not provide final authority for the operation of this source.
AIRS ID: 123/9AD0 Page 2 of 12
ColOrk. do D!
Public Health and Environment
Air Pollution Control Division
EMISSION LIMITATIONS AND RECORDS
8. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Monthly Limits:
Facility
Equipment
ID
AIRS
point
Pounds per Month
Emission Type
SOx
PM
NO,
VOC
CO
GEN-2
011
19
3
61
61
53
Point
(Note: Monthly limits are based on a 31 -day month.)
The owner or operator shall calculate monthly emissions based on the calendar month.
Annual Limits:
Facility
Equipment
ID
AIRS
point
Tons per Year
Emission Type
SOx
PM
NO,
VOC
CO
GEN-2
011
0.1
0.0
0.4
0.4
0.3
Point
See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
During the first twelve (12) months of operation, compliance with both the monthly and
annual emission limitations is required. After the first twelve (12) months of operation,
compliance with only the annual limitation is required.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)
from each emission unit, on a rolling twelve (12) month total. By the end of each month
a new twelve-month total shall be calculated based on the previous twelve months' data.
The permit holder shall calculate emissions each month and keep a compliance record
on site or at a local field office with site responsibility, for Division review. This rolling
twelve-month total shall apply to all permitted emission units, requiring an APEN, at this
facility.
PROCESS LIMITATIONS AND RECORDS
9. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rate shall be maintained by the owner or
operator and made available to the Division for inspection upon request. (Reference:
Regulation 3, Part B, II.A.4)
Process/Consumption Limits
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual
Limit
Monthly Limit
(31 days)
GEN-2
011
Consumption of diesel gas as a fuel
5100
gallons/year
433
gallons/month
AIRS ID: 123/9ADO
Page 3 of 12
Public Health and Environment
Air Pollution Control Division
The owner or operator shall calculate monthly process rates based on the calendar
month.
During the first twelve (12) months of operation, compliance with both the monthly and
annual throughput limitations is required. After the first twelve (12) months of operation,
compliance with only the annual limitation is required.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on
the previous twelve months' data. The permit holder shall calculate throughput each
month and keep a compliance record on site or at a local field office with site
responsibility, for Division review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on
the subject equipment for ease of identification. (Reference: Regulation Number 3, Part
B, III.E.) (State only enforceable)
11. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation
of the source. During periods of startup, process modification, or adjustment of control
equipment visible emissions shall not exceed 30% opacity for more than six minutes in
any sixty consecutive minutes. Emission control devices subject to Regulation 7,
Sections XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation
No. 1, Section II.A.1. & 4.)
12. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
13. This engine is subject to the New Source Performance. Standards requirements of
Regulation No. 6, Part A, Subpart 1111, Standards of Performance for Stationary
Compression Ignition Internal Combustion Engines (CI ICE) including, but not limited to,
the following:
a. Owners and operators of 2007 model year and later non -emergency stationary
CI ICE with a displacement of less than 30 liters per cylinder must comply with
the emission standards for new CI engines in 40 CFR 60.4201 for their 2007
model year and later stationary CI ICE, as applicable.
b. All fuel used shall meet the following specifications:
(1) Sulfur content shall not exceed 15 ppm.
(2) Have a minimum cetane index of 40 or
Have a maximum aromatic compound content of 35% by volume.
Compliance shall be demonstrated by maintaining copies of the fuel
specifications provided by the supplier on -site or in a readily accessible location
and made available to the Division for inspection upon request.
c. All engines and control devices must be installed, configured, operated, and
maintained according to the specifications and instructions provided by the
engine manufacturer.
AIRS ID: 123/9AD0 Page 4 of 12
d.
edit o Public Health and Environment
Air Pollution Control Division
If the engine is equipped with a diesel particulate filter, the filter must be installed
with a backpressure monitor that notifies the owner or operator when the high
backpressure limit of the engine is approached. Records shall be kept of any
corrective action taken after the backpressure monitor has notified the owner or
operator that the high backpressure limit is approached. If the engine is an
emergency stationary CI internal combustion engine that does not meet the
standards applicable to non -emergency engines, you must install a non-
resettable hour meter prior to startup of the engine per Subpart 1111 §60.4209(a).
e. If engine is used for emergency purposes, a non-resettable hour meter must be
installed prior to start-up. (Reference: NSPS 1111, § 60.4209 (a))
14. The following requirements of Regulation No. 6, Part A, Subpart A, General Provisions,
including but not limited to, apply:
a. At all times, including periods of start-up, shutdown, and malfunction, the facility
and control equipment shall, to the extent practicable, be maintained and
operated in a manner consistent with good air pollution control practices for
minimizing emissions. Determination of whether or not acceptable operating and
maintenance procedures are being used will be based on information available to
the Division, which may include, but is not limited to, monitoring results, opacity
observations, review of operating and maintenance procedures, and inspection
of the source. (Reference: Regulation No. 6, Part A. General Provisions from 40
CFR 60.11
b. No article, machine, equipment or process shall be used to conceal an emission
which would otherwise constitute a violation of an applicable standard. Such
concealment includes, but is not limited to, the use of gaseous diluents to
achieve compliance with an opacity standard or with a standard which is based
on the concentration of a pollutant in the gases discharged to the atmosphere.
(§ 60.12)
OPERATING & MAINTENANCE REQUIREMENTS
15. This source is not required to follow a Division -approved operating and maintenance
plan.
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
16. The owner or operator shall demonstrate compliance with Condition 11, using EPA
Method 9 to measure opacity from this source. The opacity shall be measured and
interpreted as an average of the readings taken over fifteen (15) second intervals for a
total of six (6) minutes. (Reference: Regulation No. 1, Section II.A.1 & 4)
ADDITIONAL REQUIREMENTS
17. 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:
AIRS ID: 123/9ADO Page 5 of 12
of Public Health and Environment
Air Pollution Control Division
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions
of five (5) tons per year or more, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions
of five percent or 50 tons per year or more, whichever is less, above the level
reported on the last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less,
above the level reported on the last APEN submitted to the Division.
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
c. Whenever new control equipment is installed, or whenever a different type of
control equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
f Within 14 calendar days of commencing operation of a permanent replacement
engine under the alternative operating scenario outlined in this permit as
Attachment A. The APEN shall include the specific manufacturer, model and
serial number and horsepower of the permanent replacement engine, the
appropriate APEN filing fee and a cover letter explaining that the owner or
operator is exercising an alternative -operating scenario and is installing a
permanent replacement engine.
18. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit)
shall apply to this source at any such time that this source becomes major solely by
virtue of a relaxation in any permit condition. Any relaxation that increases the potential
to emit above the applicable Federal program threshold will require a full review of the
source as though construction had not yet commenced on the source. The source shall
not exceed the Federal program threshold until a permit is granted. (Regulation No. 3
Part D).
GENERAL TERMS AND CONDITIONS:
19. This permit and any attachments must be retained and made available for inspection
upon request. The permit may be reissued to a new owner by the APCD as provided in
AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership
and the submittal of a revised APEN and the required fee.
20. If this permit specifically states that final authorization has been granted, then the
remainder of this condition is not applicable. Otherwise, the issuance of this construction
permit does not provide "final" authority for this activity or operation of this source. Final
authorization of the permit must be secured from the APCD in writing in accordance with
the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section
III.G. Final authorization cannot be granted until the operation or activity commences
and has been verified by the APCD as conforming in all respects with the conditions of
the permit. Once self -certification of all points has been reviewed and approved by the
Division, it will provide written documentation of such final authorization. Details for
AIRS ID: 123/9AD0 Page 6 of 12
or Public Health and Environment
Air Pollution Control Division
obtaining final authorization to operate are located in the Requirements to Self -
Certify for Final Authorization section of this permit.
21. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the 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.
22. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with
the provisions of Section 25-7-114.5(7)(a), C.R.S.
23. Each and every condition of this permit is a material part hereof and is not severable.
Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire
permit and upon such occurrence, this permit shall be deemed denied ab initio. This
permit may be revoked at any time prior to self -certification and final authorization by the
Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality
Control Act and regulations of the Air Quality Control Commission (AQCC), including
failure to meet any express term or condition of the permit. If the Division denies a
permit, conditions imposed upon a permit are contested by the 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.
24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate. •
25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution
Prevention and Control Act or the regulations of the AQCC may result in administrative,
civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121
(injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S.
By:
Rebecca Vasil
Permit Engineer
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Whiting Oil and Gas Corporation
AIRS ID: 123/9AD0
Page 7 of 12
¶ o 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.cdphe.state.co. us/requ lations/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
(Ib/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (Ib/yr)
011
---
---
---
--
---
---
5) The emission levels contained in this permit are based on the following emission factors:
CAS
Pollutant
Emission
Uncontrolled
lb/MMBtu
Factors -
g/kW-hr
NOx
1.0
3.13
CO
8.784-01
0.60
VOC
1.0
0.27
SOx
0.29
1.25
*Note that these emission factors are based on manufacturer's specifications for maximum load and
represent the manufacturer's not -to -exceed values. Emission standards requirements per 40 CFR 60
Subpart 1111 are based on a weighted cycle average.
AIRS ID: 123/9AD0
Page 8 of 12
do Dpa
r''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:
NOx, CO, VOC
PSD
Synthetic Minor Source of:
NOx, CO, VOC
NSPS IIII
Area Source Requirements: Applicable
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A — Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A — Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A — Subpart Z
MACT
63.600-63.1199
Subpart AA — Subpart DDD
MACT
63.1200-63.1439
Subpart EEE — Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ — Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ — Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN -- Subpart XXXXXX
9) An Oil and Gas Industry Construction Permit Self -Certification Form is included with this permit
packet. Please use this form to complete the self -certification requirements as specified in the permit
conditions. Further guidance on self -certification can be found on our website at:
http://www.cdphastate.co.us/ap/oilciaspermittirm.html
AIRS ID: 123/9AD0
Page 9 of 12
or Public Health and Environment
Air Pollution Control Division
ATTACHMENT A:
ALTERNATIVE OPERATING SCENARIOS
STATIONARY (CI) ENGINE
October 1, 2011
2. Alternative Operating Scenarios
The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of
Stationary (CI) engines has been reviewed in accordance with the requirements of Regulation No. 3., Part
A, Section IV.A, Operational Flexibility- Alternative Operating Scenarios, Regulation No. 3, Part B,
Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and
Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and
procedural requirements. This permit incorporates and shall be considered a Construction Permit for any
engine replacement performed in accordance with this AOS, and the owner or operator shall be allowed
to perform such engine replacement without applying for a revision to this permit or obtaining a new
Construction Permit.
2.1 Engine Replacement
The following AOS is incorporated into this permit in order to deal with an engine
breakdown or periodic routine maintenance and repair of an existing onsite engine that
requires the use of either a temporary or permanent replacement engine. "Temporary" is
defined as in the same service for 90 operating days or less in any 12 month period.
"Permanent" is defined as in the same service for more than 90 operating days in any 12
month period. The 90 days is the total number of days that the engine is in operation. If
the engine operates only part of a day, that day shall count as a single day towards the 90 -
day total. The compliance demonstrations and any periodic monitoring required by this
AOS are in addition to any compliance demonstrations or periodic monitoring required
by this permit.
All replacement engines are subject to all federally applicable and state -only
requirements set forth in this permit (including monitoring and record keeping.
The results of any all tests and the associated calculations required by this AOS shall be
submitted to the Division within 60 days. Results of all tests shall be kept on site for five
(5) years and made available to the Division upon request.
The owner or operator shall maintain a log on -site and contemporaneously record the start and
stop date of any engine replacement, the manufacturer, date of manufacture, model
number, horsepower, and serial number of the engine(s) that are replaced during the term
of this permit, and the manufacturer, model number, horsepower, and serial number of
the replacement engine.
2.1.1 The owner or operator may temporarily replace an existing engine that is covered by
this
permit with a different engine without modifying this permit, so long as the
temporary replacement engine complies with all permit limitations and other
requirements applicable to the existing engine. Calculation of emissions from the
temporary replacement engine shall be made as set forth in section 2.1.3.
2.1.2 An Air Pollutant Emissions Notice (APEN) that includes the specific
AIRS ID: 123/9AD0 Page 10 of 12
o"Public Health and Environment
Air Pollution Control Division
manufacturer, model and serial number and horsepower of the permanent
replacement engine shall be filed with the Division for the permanent replacement
engine within 14 calendar days of commencing operation of the replacement
engine. The APEN shall be accompanied by the appropriate APEN filing fee, a
cover letter explaining that the owner or operator is exercising an alternative operating
scenario and is installing a permanent replacement engine and an analysis of any
new applicable requirements for the replacement engine as required by Condition
2.2. This submittal shall be accompanied by a certification from the Responsible
Official indicating that "based on the information and belief formed after
reasonable inquiry, the statements and information included in the submittal are
true, accurate and complete".
This AOS cannot be used for permanent engine replacement of a grandfathered
or permit exempt engine or an engine that is not subject to emission limits.
The owner or operator shall agree to pay fees based on the normal permit processing
rate
for review of information submitted to the Division in regard to any permanent
engine replacement.
2.1.3 Compliance of the replacement engine with the applicable emission limitations of
the original engine shall be monitored by one of the following methods:
1) Manufacturer certified emission factors showing compliance.
2) Stack tests of same make and model showing compliance. This would
only be considered if the test was done under similar conditions to
Colorado (i.e. at altitude).
3) Stack tests on the engine.
2.2 Applicable Regulations for Permanent Engine Replacements
2.2.1 NSPS for stationary compression ignition internal combustion engines: 40 CFR
Part 60, Subpart 1111.
A permanent replacement engine that is ordered after July 11, 2005 and
manufactured after April 1, 2006 or is modified or reconstructed after July 11,
2005 is subject to the requirements of 40 CFR Part 60, Subpart 1111. An analysis
of applicable monitoring, recordkeeping, and reporting requirements for the
permanent engine replacement shall be included in any request for a permanent
engine replacement.
Note that under the provisions of Regulation No. 6. Part B, section I.B. that
Relocation of a source from outside of the State of Colorado into the State of
Colorado is considered to be a new source, subject to the requirements of
Regulation No. 6 (i.e., the date that the source is first relocated to Colorado
becomes equivalent to the date of manufacture for purposes of determining the
applicability of NSPS 1111 requirements).
2.2.2. MACT for Stationary Reciprocating Internal Combustion Engines:40 CFR Part
63, Subpart ZZZZ.
Any permanent replacement engine located at either an area or major source is
subject to the requirements of 40 CFR Part 63, Subpart ZZZZ. An analysis of
AIRS ID: 123/9AD0 Page 11 of 12
e o Public Health and Environment
Air Pollution Control Division
t&9
applicable monitoring, recordkeeping, and reporting requirements for the
permanent engine replacement shall be included in any request for a permanent
engine replacement.
2.3 Additional Sources
The replacement of an existing engine with a new engine is viewed by the Division as the
installation of a new emissions unit, not "routine replacement" of an existing unit. The
AOS is therefore essentially an advanced construction permit review. The AOS cannot
be used for additional new emission points for any site; an engine that is being installed
as an entirely new emission point and not as part of an AOS-approved replacement of an
existing onsite engine has to go through the appropriate Construction/Operating
permitting process prior to installation.
AIRS ID: 123/9AD0 Page 12 of 12
Internal Combustion Diesel Generator
Applicant:
Permit Number:
Unit Use:
Location:
County:
County Health Dept:
Engine Make
Engine Model No.
Engine Serial No.
Controls/Efficiencies
Type Emission Unit
Generator Kilowatt:
Horsepower:
Fuel Consumption:
Fuel Flow Rate:
Heating Value:
Calculated:
Annual Operation:
Capacity Factor.:
Fuel Type:
Sulfur Contant
Hours/Year Potential
Whiting Oil and Gas Corporation Engineer:
13WE1682 AIRs ID:
Electric power generation for aggregate processing unit
address Status:
Weld Date:
Weld County Department of Public lieREN dpiration Date:
TBD
TBD
TBD
Rebecca Vasil
123/9AD0/011
Attainment
21 -Jun -13
blank
Permit Status: Initial Approval
Modification:
Emergency Generator
250 kW
0 hp
17.0 gal/hr
5100 gal/yr or 300 hours/year
0 MMBtu/hr
0.139 MMBtu/gal
17.0 gal/hr
5,100 gal/yr
708.9 MMBtu/yr
360.5 Horsepower
2.4 MMBtu/hr
300.0 hr/yr
0.03
No. 2 Fuel Oil
0.05 Percent by weight
250
Emission Factor
Pollutant Ib/h•*hr lb/MMBtu lb/hr
PM 0.000329 0.0502 0.1186
PM10 0.002200 0.3356 0.7931
8O2 0.002050 0.3127 0.7390
NOx 0.006581 1.0039 2.3722
VOC 0.006581 1.0039 2.3722
CO 0.005758 0.8784 2.0757
Benzene (BIN A) 0.000006 0.0009 0.0022
Toluene (BIN C) 0.000003 0.0004 0.0010
Xylene (BIN C) 0.000002 0.0003 0.0007
Formaldehyde (BIN A) 0.000008 0.0012 0.0028
Acetaldehyde (BIN A) 0.000005 0.0008 0.0018
Acrolein (BIN A) 0.000001 0.0001 0.0002
Na.hthalene BIN B 0.000001 0.0001 0.0002
tons/
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0.12
0.11
0.36
0.36
0.31
0.66
0.29
0.21
0.84
0.55
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