HomeMy WebLinkAbout20190807.tiffCOLORADO
Department of Public
Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
1150 0 St
PO Box 758
Greeley, CO 80632
February 12, 2019
Dear Sir or Madam:
RECEIVED
FEB 19 2019
WELD COUNTY
COMMISSIONERS
On February 14, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for
Whiting Oil and Gas Corporation - Razor 25 CPB. A copy of this public notice and the public comment
packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health >t Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
4300 Cherry Creek Drive 5., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
ice- Ub1►c Q .teja) CC.PLCTQ) NL(5 )
2/251 19 PwcS'M (ER IcttiC:h)
2114119
2019-0807
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Whiting Oil and Gas Corporation - Razor 25 CPB - Weld County
Notice Period Begins: February 14, 2019
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: Razor 25 CPB
Central Production Battery
SESW SEC 25 T10N R58W
Weld County
The proposed project or activity is as follows: Engine, venting >:t flaring activities.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section
III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area)
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 18WE0071 have been
filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are
available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Comments may be submitted using the following options:
• Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page
also includes guidance for public participation
• Send an email to cdphe.commentsapcd@state.co.us
• Send comments to our mailing address:
Timothy Sharp
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
APO
d
Summary of Preliminary Analysis - NG RICE
Company Name Whiting Oil and Gas Corporation
Facility Name Razor 25 CPB
Facility Location SESW SEC 25 T10N R58W
Facility Equipment ID ENG-01
Permit No.
AIRS
Review Date
Permit Engineer
18WE0071
123/9f951001
05/16/2018
Timothy Sharp
Requested Action New permit/newly reported emission
Issuance No. 1
Emission Point Description
One (1) Caterpillar, Model G3516J, Serial Number N6W00226, natural gas -fired, turbo -charged, 4SLB reciprocating internal
combustion engine, site rated at 1380 horsepower. This engine shall be equipped with an oxidation catalyst and air -fuel ratio
control. This emission unit is used for natural gas compression.
Natural Gas Consumption
Requested (mmscf/yr)
95.64
Requested (mmscf/m)
8.12
Fuel Heat Value (btu/scf)
1020
BSCF (Btu/hp-hr)
8070
Emission Factor Sources
Hours of Operation
PTE Calculated at (hpy)
Permit limits calculated at (hpy)
8760
8760
Uncontrolled
Controlled
NOx
Manufacturer
Manufacturer
VOC
Manufacturer
Manufacturer
CO
Manufacturer
Catalyst Manufacturer
Formaldehyde
Manufacturer
Catalyst Manufacturer
SOX
0
No Control
TSP
0
No Control
PM10
0
No Control
PM2.5
0
No Control
Other Pollutants
Describe EF sources - HAPs etc.
Describe EF sources - HAPs, etc.
Point Summary of Criteria Emissions (t
Uncontrolled
Requested
Controlled
Requested
PTE
Proposed Control
Efficiency
NOx
13.3
13.3
13.3
0.0%
VOC
9.3
9.3
9.3
0.0%
CO
32.4
25.4
32.4
21.5%
SOx
0.0
0.0
0.0
TSP
0.0
0.0
0.0
PM 10
0.0
0.0
0.0
PM2.5
0.0
0.0
0.0
Total HAPs*
0.0
0.0
6.5
28.9%
*Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de
minimus thresholds. PTE includes all HAPs calculated, even those below de minimus.
Point Summary of Hazardous Air Pollutants (lb/yr
HAP Name
Uncontrolled
Requested
Controlled
Requested
PTE
Proposed Control
Efficiency
Formaldehyde
11460
7730
11460
32.6%
Acetaldehyde
816
816
816
0.0%
Acrolein
501
501
501
0.0%
n -Hexane
*
108
0.0%
Benzene
*
*
43
0.0%
1,1,2,2-Tetrachloroethar
*
*
*
#DIV/0!
1,1,2-Trichloroethane
*
*
*
#DIV/0!
*Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED
UNCONTROLLED is greater than de minimus
Permitting Requirements
Ambient Air Impacts
Source is not required to model based on Division Guidelines
Public Comment
Public Comment Required
MACT ZZZZ
New/Recon 4SLB over 500 HP located at a(n) Area Source
Reg 7 XVII.E
Standards (g/hp-hr)
NOx: 1.0 CO: 2.0 VOC: 0.7
Reg 7 XVI.B (Ozone NAA
requirements) applies?
No
MACT Z777 (area source)
Is this engine subject to MACT 7777 area
Yes
source requirements?
NSPS JJJJ
Is this engine subject to NSPS JJJJ?
Yes
Note: JJJJ requriements are not currently included as permit conditions because the reg has not
been adopted into Reg 6.
Comments/Notes
0
Summary of Preliminary Analysis - NG RICE
Company Name Whiting Oil and Gas Corporation
Facility Name Razor 25 CPB
Facility Location SESW SEC 25 T10N R58W
Facility Equipment ID ENG-02
Permit No.
AIRS
Review Date
Permit Engineer
18WE0072
123/9f951002
05/16/2018
Timothy Sharp
Requested Action New permit/newly reported emission
Issuance No. 1
Emission Point Description
One (1) Caterpillar, Model G3516J, Serial Number N6W00216, natural gas -fired, turbo -charged, 4SLB reciprocating internal
combustion engine, site rated at 1380 horsepower. This engine shall be equipped with an oxidation catalyst and air -fuel ratio
control. This emission unit is used for natural gas compression.
Natural Gas Consumption Hours of Operation
Requested (mmscf/yr)
95.64
Requested (mmscf/m)
8.12
Fuel Heat Value (btu/scf)
1020
BSCF (Btu/hp-hr)
8070
Emission Factor Sources
PTE Calculated at (hpy)
Permit limits calculated at (hpy)
8760
8760
Uncontrolled
Controlled
NOx
o
0
VOC
o
0
CO
o
0
Formaldehyde
0.00
0
SOX
0
No Control
TSP
0
No Control
PM10
0
No Control
PM2.5
0
No Control
Other Pollutants
Describe EF sources - HAPs etc.
Describe EF sources - HAPs, etc.
Criteria Emissions (t
'
Uncontrolled
Requested
Controlled
Requested
PTE
Proposed Control
Efficiency
NOx
13.3
13.3
13.3
0.0%
VOC
9.3
9.3
9.3
0.0%
CO
32.4
25.4
32.4
21.5%
SOx
0.0
0.0
0.0
TSP
0.0
0.0
0.0
PM10
0.0
0.0
0.0
PM2.5
0.0
0.0
0.0
Total HAPs*
0.0
0.0
5.7
32.6%
*Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de
minimus thresholds. PTE includes all HAPs calculated, even those below de minimus.
Point Summary of Hazardous Air Pollutants Ib/yr)
HAP Name
Uncontrolled
Requested
Controlled
Requested
PTE
Proposed Control
Efficiency
Formaldehyde
11460
7730
11460
32.6%
1,1,2,2-Tetrachloroethar
*
*
*
#DIV/0!
1,1,2-Trichloroethane
*
*
*
#DIV/0!
1,3 -Butadiene
*
*
*
#DIV/0!
1,3-Dichloropropene
*
*
*
#DIV/0!
2-Methylnaphthalene
*
*
*
#DIV/0!
2,2,4-Trimethylpentane
*
*
*
#DIV/0!
*Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED
UNCONTROLLED is greater than de minim us
Permitting Requirements
Ambient Air Impacts
Source is not required to model based on Division Guidelines
Public Comment
Public Comment Required
MACT ZZZZ
New/Recon 4SLB over 500 HP located at a(n) Area Source
Reg 7 XVII.E
Standards (g/hp-hr)
NOx: 1.0 CO: 2.0 VOC: 0.7
Reg 7 XVI.B (Ozone NAA
requirements) applies?
No
MACT ZZZZ (area source)
Is this engine subject to MACT ZZZZ area -
source requirements?
Yes
NSPS JJJJ
Is this engine subject to NSPS JJJJ?
Yes
Note: JJJJ requriements are not currently included as permit conditions because the reg has not
been adopted into Reg 6.
Comments/Notes
0
Colorado Air P�rmittir�g Project
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details
Review Engineer. .fiEmathy Sh�rp
Package#: 3737o8����: .
Received Date: lJll/241S � -
Review Start Date: .Sj15/Z013 � ��
Section Ol-Facility Information
CompanyName: WhitingE7iS&Ga5Carpa.=�#ttin ', Quadrant Section Township Range
County AIRSID: I123 � � . SESW �25 . 1GN. , �. 58
PlantAIRSID: �9P95 '
FaciliYyName: ,fiazor25��,CPS _ ,,, . ,.�.^ .. ... .., , . . _ ,�_ ...
Physical
Address/Location: SESw qir�rant of Se�ion 25,lowr�ship i0N,aange SSw
County: Weld County
Type of Facility: ;��plartian&P�d�raet'iazi_1Ffe14 Pacl .: ......_ , �. .-. .-
W hat industry segment?';Oii&tvaturaf Gas PsaBuct�an&fi�rac��zna _
_
Is this facility located in a NAAQS non-attainment area? � N4
ff yes,for what pollutant? �[ Carhon Monox de(C0) [] Particulate Matter(PM) ❑ o�one�Nox�va>
Section 02-Emissions Units in Permit Appiication
Emissions Self Cert Engineering
AIRs Point# Emissions Source Type Equipment Name Permit# Issuance# ACYion
Control? Required7 Remarks
_ Fe�mlt l�iteat
.flfS1. �..��is��tlC21C"idS��:lc�.�-:: . �ERl�a-01��.�.. Y2S �: 18UVE0Q71 3.�� Y�S t5SU�[tC2
�� ����� � � ». �..�� :-„= � �F6YTni�IIt�1C4�I �
� f1�62 � �aT�ura3Gas�IC�-� ENG-�Z. Y2s �� 1SWE047Z. 1 ----�es -� #ssuanes��.. � .
.:, �_. . .. _ . . __. . . � .VRUJPipe3ir2-
P�rmit initiai dowrntime�
043 Se�.��aiczrw�nTin�' s2parators Yes 18WE0073 1' Yes issu�rice ' 12%
.. � .. . �. .. � � � VFiUJPipetine�..�
-. � � £���xi£InittaE ��downYfine�3
- .._ �_ - ;� ' -- _
"GQ� .._: ._��a�atorVent�g. � crudetan[� � 3�8s �- 18WE0Q74 E =�'2s . �_. =SSuar2ce �i�q
„��, . <_. �:Vflt3JPkpel9ne
. � � � Pe�r^nit'fnl�€�dc�wntime�
045 Sp�r�tffrUen�i��. watertank Yes 18WE�75 2 Yes s'ssuance 12%
Section 03-�escription of Project
_ �,
Applicarf has cam�f�ted an Ai;ern�₹ive Emisslons Reques₹�Form aiong wl₹h a techn;ca!justificat:caii�fnr usa c`an Open Fl��e as cantral during ga5•gathering pipe3ine�. .
'� downfime in the a�₹ainment are-c.This reque'st has been atrprovsd. � �� �� �
Section 04-Pu61ic Comment Requirements
Is Public Comment Required? Yes' �
If yes,why? Greatax thart 5D toris peryear in an h�xatnmantArea � .... . �
___._ . . . __ .... ____. _.... '
Section DS-Ambient Ac Impact Analysis Requirement�
Was a quantitative modeling analysis required? 'ho'
If yes,for what poilutarts? '
If yes,attach a copy of Technical Services Unit modeling results summary.
Sedion 06-Facility-Wide Stationary Source Classification
Is this stationary source a true minor? Na .
Is this stationary source a synthetic minor? j Yes -
If yes,indicate prograrrvs and which pollutantr: �5O2 N0x� CO VOC PM2.5 PM10 TSP HAPs
..... . _ ...__..
Colarad��ir Permitting Project
Preventionof5ignifcantDeterioration(PSD) ❑ [� Q � � �
Title V Operating Permits(OP) � � � � � � � ,�'
Non-Attainment New Source Re�iew(NANSR) � �,
Is this stationary source a major source? �����r� ���
If yes,explain what programs and which poilutants here so2 Nox co Voc PM2.5 PMio T5P HAPs
Prevention of Signifcant Deterioration(PSD) � � � � Q �
Title V Operating Permits(OP) � � � Q � � Q � .
Non-Attainment New Source Re�.iew(NANSR) � �
Separatot Venting Emissions Inventory
003 5eparator Venting
�
FacllityAlRSID: _ .,:i'`3-- _ 3F96p� � a93 � :
_ . »,,,.,....,� ,,.... , , .
Couniy Plant Point
Section 02-Equipment Descriation�etails ,
,,:,.; , r - ,. ., _,
;separatarvent �urin 'as`thertn downsiEne .:�;: ,.,, . � :� , ,,;: � S€���".+� -:
.: .� ;&�. $� �,. , .,., .>: _ a���:
Detailed Emissions Unit Descnption: `, - ''" -^- . _ � �� - --
.. „ : , ,;,: ,,, ..:�'ii
. . , ;. ,,; . .... ....,: :
•Rp�n F3ar�+ �'.� "�"��'
Emission Conirol Device Description� �_'; "" "� '' "' . " '' "' ��""' ,
., ...,,,.� , . ,. ..: , „ ,„ . .
Requested Overali VOC&HAP Control Effic ency%: . �.. .
Limited Process Parometer p,.y� �•�--a�= �� ' ��
. h...�:� ..
W .,r .,- ,::.
Gasmeter �Fas.���.5�e ,'�,,,:- :� -a;
Seccion 03-Pracessine Rate Intormation for Emissions Estimates
Primary Emissions-Separator
ActualThroughput : �:��'�MMscFperyear
RequestedPermrtLimitThroughput 73,O,IMMscFperyear Reques[edMonthlyThroughput= 6 MMscFpermonth
PotentialtoEmit(PTE)Throughput= 73 MMscFperyear �
Process Control(Recyding) .
Equipped with a Vfttl:�is'�� '�-' �'�e
Is VRU pracess equipment:��s�. � - .��Umm�trolled and contralied emissions used to establish requested permit limits are hased only on when ihe VRU is bypassed(i.e.waste gas volume that is routed to ihe flare)
....�:,,-......a_..,.. .
Secondary Emissions-Combustion Devire(s)for Air Pollution Control
SeparatorGasHeatingValue. ' YST.�ttf��;etu/scF
Volume of was[e gas emitted per BBL of� ��,.,��F �
liquidsthroughput: -'iF sd/bbl
Sec[ion 04-Emissions Fac[ors&Methodolo¢ies
�escription
MW 27.5412'�.I6/Ih-mol DisplacementEquation .
Ex=Q'MW`Xx/C
Weight%
Helium �������.�.'�
CO2 �
N2 { �,1G �
_..
methane � ' :�'�.'35 3� ._ . .. . _._... . . . _._. . _ ..._ . ... . . ..
..—.. � —_... _ _. —_ .. . . ___. __—_.._ . . ._._ . ....- _.. .. _._—. ___— . __._ __—.. . . _
ethane ' ��.15
propane ' ZG.94 -
iso6utane z.°3���
n-6utane 9�3' �
isopentane 2 3'��
n-pentane "��i �
cyclopentane �.L".37
n-Hexane a�:58
cyclohexane D.27
Otherhexanes 1 73�
heptanes S.t.li
methylcydohexane ..8:3?
224-TMP t�.27'.
Benzene : �:�.I�:
Taluene 313�
Ethylbenzene ^'v"3
Xylenes � G,G'5�. �
C8+Heavies 1.33
Toial �� �� 99.97
VOC Wt% 45.82
Emission Factors Separator Venting
Umm�trolled Contralled
Pollutant (Ib/MMscf) (Ib/MMscf� EmissionFacCorSource
(GasThroughput) (GasThroughput�
VOC 33297.6985 1564.5549 � �' �-��
" " �� -.rv�^'.: �'�G-, -�o--F
eenzene 84.9�87 4.2474 �'"'� �p;f��
Toluene 9G.8552 4.8433 � "' i��+;,�yx.�� `° � .
Ethylbenzene 18.3850 0.9192 �;��.,����������`'�
Xylene 45.9587 2.2999 '�����``���i„�Py � �
1�fi `�� a
_y
n-Hexane 715.1239 35.7562 � � ��
224 TMP 126.2967 6.3148 ;�;-. ` �` �'(�,,,�',�,,,_ _: , .
, �. ..�_ 7-:,,:
Primary Contml Device
Uncontrolled Un<ontrolled
Pollutant (I6/MMBtu) 16/MMscf EmissionFactor5ource
(Waste Heat
Com6usied) (Gas7hroughpu4)
PM10 0.000 ; ��.,p.�
PM25 �� 0.000 � r��-� .F �.�'�'
SOx ` ��� 0.000 ay�, �� � � �
NOz 0.668� 105.400 �'��{}p-+f₹�„�,�°�3Y� . ����i
CO fi.316C 48U.500 ,,w'.'�� �..Jq-�'1��F,ts#yEet�... _„ �,;,. ��.v.wvx.z
3 oF 14 K:\PA\2018\I8WE0073.CPl.xlsm
Separator Venting Emissions Inventory
Sectio�OS-Emiss' ns Inventory
Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits
Criteria Pollutants Uncontrolled Unconirolled Controlled Uncantrolled Conirolled Conirotled
(tans/year) (tons/year) (tons/year) (tors/yeer) (tons/year) (Ibs/month)
rnnio o.00 o.oa o.00 o.oa o.00 0
PM2.5 0.00 0.00 o.eo o.00 a.ao 0
so. o.00 o.00 o.ao o.aa a.ao 0
PJOX 3.85 O.QC 0.00 3.U5 3.85 653 - -
VOC 1P15.37 Q.Q6 0.00 1215.37 50.77 10322
CO 17.54 0.00 0.00 ll.54 17.54 7979
Potential to Emit Actual Emissions Requested Permit Limits
HazardousAirPollutants Umm�trolled Umm�trolled Controlled Unca�ntrolled Conirolled
(16s/year) (16s(year) (Ibs/year) �165/year) �Ihs/year�
Benzene 62�1 0 0 S201 310 3.101 0.155
7oluene 7071 0 0 s071 354 3.536 0.177
Ethyl6enzene 1342 0 0 7342 b7 0.671 0.034
Xylene 3358 0 0 3'�53 3'00 1.679 0.084
n-Hexane 52204 0 0 5220d ?610 26.102 1.305
224 TMP 922a 0 0 4220 461 4.610 0.230
SectionOfi-Fe ulato Summa Anal sis
Regulation 3,Parts A,B Source requires a permit
Regulation 7,Section XVII.e,G 5ource is subjeet to Regulation 7,Seciion XVii.6.2,G
Regulation 7,Section XVII.82.e The mntrol device far this separamr i�subject to Regu7azion 7,Section XVil.a.2e
(See regulatory applicability worksheet for de4ailed analysis) �
Sectio�07-Initial and Periodic Samplin¢and Tes4in¢Requiremen6
Using GasThroughput to Monitor Compiiance
�����':
Does the mmpany use siie specifc emission fac[ors 6ased on a�as sample to estimate emissions? �',�,�kSW;�,,,.�f;,�il��L„3,,;.,�
This sample should represent the gas outlet of the equipment covered underihis AIRs ID,and should have 6een collecced witNn one year ofthe application received date However,if
the facility has not heen modified(e.g.,no new wells 6rought on-line),then it may 6e app�opriate to use an older site-specific sample.
If no,the permit will contain an"Initial Testing RequiremenY'to collect a site-specifc�as sample from ihe equipmerrt heing permitted and conduct an emission factor
analysisto demonstrate that the emission factors are less than or equal to the emissions facmrs esta6lished with this application. .
Are facilit wide ermitted emissions of VOC reaterthan or e ual to 90 tons R ��,����' � -
Y- P g 9 Peryea �r...<.��...<..�. ....a&a
If yes,the permit will contain:
-An"Initial Testing Requirement"to collect a site-specific�as sample from the equiprnent being permitted and conduc[an emission fac[or analysisto demons[rate that the
emission factors are lessthan or equal to the emissions factors esta6lished with Yhis application.
-A"Periodic7esting Requi ment"to collec[a site-specific gas sample fram the equipment 6eing permitted and mnduct an emissiori factor analysis to demonstratethat ihe
re . . . _ . .._. . . . . . . _ . ._ .
---�� em ssion factors are less than or equal to the emissions factors estahlished with this application on an annual basis.--� � --�-� -- - - �------� ---- � � — � �--- - - ----
Will the operator have a meter installed and operational upon startup of this point? Yes
If no,the permit will contain a condition Yhai requires the operatorto calculate gasthroughput usingihe liquid ihraughput until the meter is instalied and opeational�not
to exceed 180 days).This mndition will use ihe"Volume of waste gas emitted per BBL of liquidsihroughput"(scf/bbi)value in section 03.
Does the company reques[a control device efficiency greaterthan 95%for a flare or combustion devire? '7�v�'3�Yg �� E;;�"� _
If yes,the permit wiil contain and initial compliance test condition to demonstratethe destruction efficiency of ihe mmbustion device based
on inleY and outlet concentration sampling
Ycu have indicated a6ove that th=monimred process pareme±er is natural gas uented.The foiloviing question=_do not require=_n answer.
„=,.y� .,ii . _. �„_. T
- ,.. ;.. . . .� r^ :
/- l. - � a-.. �,'�� � � .,: �;.
_ = ,_ .,.- . . : ' . :- . .
g f:,
_, l. ;." ' . ` '..,. �
�� /' l' �'"� �.' -;J- ,/ �,;
'
;, u. . .,,,, � ' Y.
/,
.:, _.. ., • ._' - �.::.� � ' ' �
� �, C
..._� :.m ...- .. .. .,,;
�;;
�l � l � �
4 af 14 K:\PA\2018\38WE0073.CPl.xlsm
Separator Veniing Emissions Inventory
5 ct 08 T h I A I is Notes
H , ,,, , . ....,., ..,. . :: ..AF,;.. ,:::,.. . , �� . .��.: . ; ;.. . �. .r, a;a/////,
= _ :
€-�2�PF tineotuatsmeas5ur,r�d�pMztrti'sgiasislPracessiim�cea₹<uta,€ionsi+Feas�t�4„te�.aAplacanthasfiguredumm�rrnit�,�guresbntLpElVtobel�0'lUnc4n�croli�d�emiss¢ansar�e�hexeFn���..�ea�_ena�ve. �,.�,�,f� . <.;
�ii�y,�'���yoi : ��>�'v.-�� .. . . K :�:
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C� ��j �i'r ..._/ ���� : � �����3 � � - ��v, :
,.�y . �. /�/� �: � �` ���ti : %� �c \ \ N� fi# ' � � �' ":
�- ,`�`��.. ', -- „,�. � �i.�S�v�� � ; �5 r ��.2 E�� � "li�� � �.�.: iii��3�.� ��'`\ �i
<- ' 2\� � �eca�Y ���� � �a i i "\\ �/5FE�o ��ike
/ � m / i �l 2`�
s - ��i �`��v�� �x i G/// ,, i� ti'�lr'i� �\� �,�� '�
Z� i // �/i- / EE�,�� : /i Y �ii� : � F�� d Il E@�L.�
'���.�: _ \�����, C��'°' ��kj E � ✓ia - ii d _ �.���/ � �
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F � ,
,-......,,, ,.,_.� ,.,.,.. __._� ,.,_,_.�� � � .,,,,,��.H.u.��... ��,�...,....��. __�
��,.,.,,.., .,....
. Section 09-Inventory SCC Codii¢and Emissions Factors
. . Uncontrolled
Emissions
AIRS Poinf 1F Process# SCC Code Pollutant Factor Conirol% Units
003 Ol 3-�0-001�G Plares PM10 G.oc 0 ib/NIMS[F
PM2.5 0.00 0 Ib/MMSCi'
' SOx 0.06 0 :UJMMStP
NOx SOS.nO 0 1�/MMStF
VOC 33297.70 95 ib/Mm5CF
. CO 420.Sa 0 Ib/MMSCF
- Benzene 8495 95 Ib/MMSC�
" Toluene 96.87 95 IbfMM5CF
Ethylbenzene iS.38 95 i6(MMSCF
Xylene 46A0 95 !h/MMSCF
� n-Hexane 715.11 95 in/MM3CF
224�7MP 126.30 95 Ib/Po'InP�5CP
5 of 14 . K:\PA\2018\18WE0073.CP1.xlsm
_ _.. __. . .... . .... ... ... ._... . _.,.,....
_
Separator Venting Regulatory Analysis Worksheet � � �
Colorado Re ula[ion 3 Parts A and B-NPEN and Permit Re u enYs
Soursx is in tfie Attainment Area
ATTAINMENT
1 Are uncontrolled actual em ss'ons From any cr teria pollutants f�om ih 5 ndividual source g�eater than 2 TPY(Regulat�an 3,PartA,Sectian II.D.l.a)? ��Source Req
2. A�etotalfa<ilityunonirolledVOCemissionsgreaterthan5TPY,NOxgreate�thanlOTPVorCOemissionsgreaterthanlOTPY(Regulation3,Part8,Sectionll.�3�7 `-:SourceReq
Source requires a permit
NON-A7TAINMEM
1. Areun<ontrolledemissionsFromanycrite�iapollutantsfromthisindividualsaurcegreaterthanliPY�Regulation3,PartA,5ectionll.�.l.a)7. . . .
2. AretatalfacilityunconCrolledVOCemissionsfromthegrea[erthan2TPY,NOxgreaterthan5TPYorCOemissionsgreaterthan]DTPY(Regulatian3,PartB,5eciionll.D.2�7
You have indicated that sourre is i�ihe Attainment Pree
Colorado Reeulation].Seciioe XVII
1. Was the well newlv�onstrmcted,hydraulicallyfractured,or recampleted on or after August 1,20142 Y85�:: ::Source is s�
Source is subjecx xa RZQulation]Secton NVII.8.2 G �
Sec[ion XVII.B.2—General Provisions forAir Pollution Control Equipment and Prevention of Emissions
Section MVII.G-Emissians Cont�ol
AlternaNye Emissions Conirol lOptional5ection)
a. Is this separator controlled 6y a back-up or alternate combustion device(i.e.,notthe primary roMrol device)that is nnt enclosed7 ____ The coMrol
Thecont�oidevice₹or:hisseparatorissuhjectteasgulotian]SectionXVil.8.2.e � I
SecHon XVII.B.2.e-Alternative emissions control equipment
Disclaimer
This documerd assists ope2tors wifh determining applicability of certain requiraments of tha Clean AirAct,i4s implementing regulations,and AirQuality Cortfro/Commission regulations.This document is �
not a rule orregulation,and fhe ana/ysis it contains may not applyto a parficular situation based upon the individual facts and circumstances.This document does no[change or subsfitufe foranylaw,
regulaG'on,or any othe�legally binding requirement andls not legally enfolceable.In the event of any contiict behveen the language olthis document and the language ofthe Clean AirAct„its implementing
regulaU'ons,aod Air QualityConfrol Commission 2gulafions,the language of the statute orregulation will control. The use of non-mandatorylanguage such as"recommend,""may,""shoultl,"and"can,"is
intended fo descnbe APCD interpretations antl recommendations.Mandatory terminology such as"musC'amJ"required"are intended to describe controlling reyuirements under the ferms o(the Clean Air
Act and Air qr�ality Confrol Commission regulafions,buf fhis tlocument does not establish legally binding requirements in and o(itse/f.
� . . ... .. . _ __. .
. .._ .. .. .. . . . _ _ ._... . . .. .
Separator Venting Emissions inventory
0045eparator Venting �
.r IY3;u„cs,_,4I....,£E�.;�-.9695 �i ,,, Eati Q44,.�;:: �a....�.:
FacilityAlRs ID: �ounty Plant Point
Section 02-Eouioment Description Details
'�tznbngsrarnprsgsGr'°` Qx[vessr�y�u�ac�gpGpeHne'+�awne¢me� ;, a a� -: _ ;z:<
Detailed Emissions Unit Des<npnon a��; _�,,,,,,,';� �� , _ ���. .;��.. , „,,,,���,.�„�x�a�,a,�,,,,w;, ,,,,,,, „�- ���;.,,��„�,
ctpen€iazc�'�� , ..� ', 1��€E�.:�� ��i�
Fmission Control�evice Desmption .: z�a��,�,,,, •� �',, : �� EE`�,.:.r�C���, .,-,,,, , ,.,
,: ... . ,, , . ,,,.E��� `Ca°a.s,.a,...,,,.„ . ..,. ,,',;,�.
Requested Overall VOC&HAP Control Effinency/. ,����F,,,,, 9S����.,; .
Limited Process Parameter �SdfrgC���T#�,',iµ, � ��'����',.,� ��
Gasmeter ��rrr er�sc.uga«ftyu'�i� ��ss -
�.'3� — _r_.. . _ ...
Section 03-Processine Rate Indormation for Emissions Estimates
Primary Emissions-Separatoe .
ActualThroughput=z �� .:-.iMMscFperyear
q g p �, k�MMscFperyear RequestedMonihlyThroughput= � MMscFpermonih . ,
Re uested Permit LimitThrou h ut ; � � ��
PatentialtoEmit(PTE�Throughput= 4MMscFperyear
Process Control��Recycling)
Equipped w th a VRU:�� ��
Is VRU process ecpwpment.���,r���.��Uncontrolled and mntrolled emissions used to esta6lish requested permit limits are 6ased only on when the VRU is bypassed(i.e.was[e gas volume that is routed to 2he flare)
Secondary Emissions-Combustion Device(s)for Air Pollution Control
SeparatorGasHeatingValue: - 235fl'-8tu/scF
Volume of waste gas emitted per BBLof�
liquidsthroughput: t!'�. scf/hbI .
Section 04-Emissions Factors&Methodolo¢ies �
D scr�p[�on
� ��. ,�'� �l r f���'��'� , : �
: \ ��- /% v `_/� : � ., i, ah
' , � '; � •� :: re � /���; _ ��� i ii
; „ //
'..//,,,,/,. ;>-i'., 3,,,�„� '.��..�F.l�� .... ''�. , ,,; ,.. . �„-;,,,,.,,c�; � „z<&'/e,...,.i: ,,. .,. . .......�' ��,�i�/,y , . ,,,, ,,,,���..... ... . .
MW „�F3.6EtfE Ih/Ib-mal _.. . DisplacementEquation . . .
Ex=Q*MW*Xx/C �
Weight%
Heliurti ;.��� f7.tll5;
CO2 1:SS'
N2 .:.`; 2.?# �
._ _ methane _. . _ . . ., : •xqq . ____ . ..._ .... _ ... _. ._. .._ ._ . _ ... ... .. _. .. .._. _ . . .._
— _ _ "� . — —___—_ — _ —. _.___—__ _ _.___. — .__—_—_ ._ __ _-__—_— ___ __ .
ethane •.:, t'2.t1S: .
propane ii� ,��%%i%36.7��.
iso6utane �?� ;��,S.84'�. . � ,
mbutane ��^:I�k�£15'�.
isopentane �� �....:�_.�-� �4'�4A'�.
n-Pentane „�,,,.. ���".�.�8'
cyclopentane a.d8'.
n-Hexane %/ .-.13t1'�,
cyclohexane ''�+'.'.u,��;if:28��:
Other hexanes ....7��b`- , ,���35"�. � - �
heptanes f���:83 . _ . .
methylcyclohexane •`.(i:'��€ �
224-TMP �3`,�:, I :'U.l''-€: . �
eenzene �•°. ��� ,,,Q.�
Toluene ,�au,;,,,.J. �=1#:'flfi
Ethyl6enzene ,..tS.0S
Xylenes ���� "`C�.fl2'�. .
C8+Heavies ',.6:6��.
Total � 99.30 �
NOC Wt°/a - 79.03
Emission Fac[ors Separamr Venting
Uncontralled Controlled
Pollu4ant (Ib/MMsci) (16/MMscf) EmissionFactor5ource
(GasThroughput) (6asThroughput)
VOC 9Y987.5135 45543757 -
h
Benzene 145.2182 7.?6fl9 '��'�n�`�,`5''� ~\ ���
Tal�ene 82.059& 4.133D '��-� .<+`�:�'��'„
�
Ethylbenzene 8.7592 0.4380 � �^����,�. �'�y� �,
%ylene 19.5925 0.9795 `� s a����•���"`-��\
h
n-Hexane 1498.3978 74.9199 �� �������� � '"i',''
≥ � ��.����4c� .
224TMP 161.0078 IIA504 �n.�„�.,k.:. , .o,x,,,.,,;"' �...,,....,:
Primary Contral Device
Uncontrolled Umm�[rolled �
Pallutant (Ib/MMBtu) 16/MMscfi EmissionfactorSouece -
(Waste Heat
Combusted) (GasYhroughput)
PM10 ��' '. OA60 c'���F� ,,,� r� � :,�.�.#'es"°"�Y^Si��.
PM2.5 c : '�'�: O.OOfI �� ���1.a-�a�s�l�'� ���' ���.,
SOx " �'''�.�� 0A60 � � � ���
�s,���� � '�?�i�`�,�,�'c� �'��� `ti�
NOx Q�6�k 159.800
, '. .-. . -... �cn.i�+•.
CO 4Y3�.tlG , i 728SG0 .- ._ . ..;,.us,,,'�n`,��� ...,:
7 of 14 K:\PA\2018\18WE0073.CPl.xism
Separator Venting Emissions(nventory
Sectian O5-Emissions Inventory
PoteMial to Emit Actual Emission Requested Permit Limits Requested Monthly Limits
Criteria Pollutants Umm�trolled Unconirolied 5 controlled Uncamtrolled Controlled Controlled
(tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (Ibs/month)
PM10 0.00 9.60 L�.(30 6.ba 0.00 0
PM2.5 0.0Q 0.00 a.a0 O.Op 0A0 o ,
sox o.no �.00 a.�o a.ao c.00 0
Nox D32 o.oa o.ao osz oaz =s �
VOC i2�4.95 0.00 C.40 184.45 4.22 155i�
CO 1.48 0.00 0.0� 1 c8 1.48 252
Poten[ial to Emit Actual Emission Requested Permit Limits �
HazardousAirPollutanis Umm�trolled Uncontrolled 5 Conirolled Unc�trolled ConCrolled
(Ibs/year) (Ihs/year) (Ibs/year) (Ibs/year) (I6s/year) .
6enzene 585 0 6 Sg3 39 0.294 0.015
Toluene 332 0 0 332 17 0.166 0.008
Ethyl6enzene 35 0 0 35 2 0.018 0.001
Xylene 79 0 0 79 4 0.040 0.002
n-Hexane E069 0 L' 5�69 303 3.034 0.152
224TMP 65i 0 0 E52 33 0.326 0.016
Section O6-Reeulatory Summary Analysis
Regulation 3,Parts A,B 5au:ca requires a permit -
Regulation 7,Section XVII.6,G Saurce is subjac:to Regulafio:�7,Ss<tion XV11.8.2,G
Regulation 7 Section XVII.B.2.e The cor.frol derrive far chls separa₹o:is subject to Regulation 7,Seccion R`Jil.s.2.e
(See regulatory applicability wod<sheetfior detailed analysis)
Section 07-Initial and Periodic Samplire¢and Testine Reouirements
Using Gas Throughpuk to Monitar Compliance
�,r=
f;:
Does the company use site specific emission factors 6ased on a+�as sample to estimate emissions? ,�'ffi'.�'/����'�
This sample should represent the gas ouilet ofthe equipment mvered underthis AIRs ID,and should have 6een collected within one year of the application received date.However,i{
the facility has not heen modified(e.g.;no new welis brought on-line),then it may 6e appropriate to use an older site-specific sample.
If no,the permi₹will contain an"Initial Testing Requirement"to mliec[a site-specific�as sample from the equipment 6eing permitted and conduct an emission factor
analysis to demonstratethatthe emission factors are less than or equal to the emissions factors estahlished with ih's application.
Are facilky-wide permitted emissions of VOC greater than or equal to 90 tons per year? ��� --:
_,.,_...............
If yes,the permit will contain: �
-An"Initiai Testing BequiremenY"to collect a site-specific gas sample from the equipment 6eing permitted and conduct an emission factor analysis to demonstrate that ihe
emission factors are less Yhan or equal to the emissionsfactors esta6lished with this application. ' -
-A"PeriodicTas4ing RequiremenY'to coliect a site-specific gas sample from the equipmen4 4eing permitted-and conduct an emission factor analysis to demonsiate that the
. ___.. ... .. . . _ __ . ...
. . _ . . __ _._. _. . . ._ . ...
--�- ---��emissionfactorsarelessthanorequaltotheernissionsfactorsestablishedwiihthisapplicationonanannual6asis.------- -�-- ---- -- --- ------- . --- ---------- � � --- - ----- --
Will the operator have a meter installed and operational upon startup of this point? _
If no,the permit will contain a condition thac requires the aperatorto calculate gas throughpui using Yhe liquid throughput on4il ihe meter is installed and ope�ational(not
to exceed 180 days�.This condition will use the"Volume of waste gas emitted per BBL of liquidsthroughput"(sd/661)value in section 03. .
Does the company request a wntrol device efficiency greaterthan 95%for a flare or comhustion device? �',_, ty ,,
If yes,the permit wili contain and initial compliance test condition to demonstratethe desiruction e�ciency of the combustion device based
on inlet and outlet concentration sampling
You have indicated aaove thaY the.mo�Yored pra<=ss par=_me?Ur�s natural gas verYed.Tne fo?Io:vEttg ques4ions do noe require ar znsw=r. . �
�-�
�a•
;,,. � " ,:..._. , .- /�^ /. . . .
:ri- �" r� . ," ?- ... . . ,-,r"�
...� . .a.,.
_ �� ��l"�1�,�lfr
�: r
9f
. �'_ . -" , oi
. .._ ._,. .,',x. . _ _
, / ' � / .� w, s;� � la
� � �_ l O�"�� � �� �
�:' �_; �m
... � � .
8 of 14 . K:\PA\2018\18WE0073.CPl.xlsm
Separator Venting Emissions Inveniory
se�tio�oa-re�h�t�ai n�ai sis Noees
;�EY9G pipe�lne downtiima a,5sumed fpr emrssionsjproceis latn9tcalcutations:Please note,��SpfiranY:has figurad�tnicprrtrolkd it�iires an APEN'tp be lOq'�.Vncanetmkteci emis�₹ons are,tfierefnre conseruative. �
Sectian 09-Inventory SCC Godn¢and Emissions Factors
Uncontrolled
Emissions
AIRS Point# Process# SCC Cade Pollutant Factor Control% Units
004 Ol 3-'i�-00'I-60Flares PM10 0.00 0 Ib/MMSCF
PM2.5 0.00 0 Ib/MMSCF
SOx 0.00 0 Ib/MMSGF
NOx 159.80 0 Ib/MMSCF
VOC 91087.SY 95 Ib/MMSCF
CO 728.50 0 Ib/Mh95CF
Benzene 14512 95 Ib/MMSCF
Toluene 82.06 95 Ib/MMSCF
_ Ethylbenzene 8.76 95 Ib/MM5CF
Xylene 19.59 95 Ib/MMSCF
n-Hexane 1445.40 95 Ib/MMSCF
. 224 TMP 151.01 95 Ib/MMSCf
. . . _ _.. ._ .__ . _ . _ . . .
g a{14 K:\PA\2018\18WE0073.CPl.xlsm
� SeparetorVentingRegulatoryMalysisWorksheet .
Colaradofte ulatlon3PartsAandB-APENandPermitRe ulrements
Source is in the Attainment Area
ATfAINMEM
1 Are uncantrolled actual em ssions from any cr ter a pollutan[s from N s ndmdual source greaterihan 2 TPY(Regulat�on 3,Part A,Sect on II D l.a)7 -5 e fteq
2 Are total fac I ty un onhalled VOC em'ss'ans greater ihan 5 TPY,NOx grea[erthan 10 TPY or CO em ss ons greaterlhan 10 TPY(Regulat on 3,Par[B,Section II.D.3)1 Yeh%.��":'��,��;Saurce Req
c
So�rce requlms a permit
NON-ATTAINMENT
1. Areuncontrolledemissionsfromanycriteriapollutantsfromihisindivid�alsourcegreaterthanlTPY(kegulation3,PartA,5ectlonll.�.i.a)?
2. AretotalfacilltyunwntrolledVOCemissionsfromthegreaterthan2TPY,NOxgreaterthan5TPVorCOemissionsgreaterfhanlOTPY�Regulation3,Parte,Section11.0,2)7
Vou ha�e i�dicated thet source is in the Attainment Aree
Colorado Re¢ulaMon 7,Sec[lan xVll
1. WasthewellnewlYconstructed,hydraulicallytractured,orre<ompletedonaraRerNugusY1,20147 _ „��Sourcelssi
Sou�ce is sublect to fteeulaxion],Sec[ion%V11.8.2,G '
Sectian%V11.8.2-General Pravisians for Air PolluYian Cont�ol Equipment and Prevention of Emisslons
Sectlon%VII.G-Emissions Control
Aliernative Em�ulons Controi(Oot onai 5ec[on)
a. Is th s separator cantrolled by a ba<k up or alternate<ombust'on dev re('.e,natthe pnmary mntrol dev'ce)Nat is not enclosed7 �The control
ITheconlroldevicefarinissepamiorissvbieRtoRegulation]SeRionXV11.8.2.e � � �
Sectlon%VII.B.2.e-Altemative emissions control equipment
Oi5claimef
7his document assists operators with defermining applicability of certain requirements of the C/ean Air Act,ifs implemenGng regulafions,and Air 4ualityCordrol Commission iegulafions.This documenf is
not a rule orregulation,and the analysis it confains may not apply fo a paRicular situation based upon(he indivitlual/ac�s and circumstances.This documenf does not change orsu6stifute loranylaw,
regulatton,or any otherlegally binding requirement and is not legally anforceable.ln the event of any conflicf between fhe language of fhis documenf and fhe language of fhe Clean AirAct„ifs implementing
regulations,andAirQualityConfrol Commission regula6ons,the language ol fhe statute or regulaG'on will control. The use ofnon-mandatorylanguage such as'recommend,"'may,"'should,"and'can,"is
intended fo descnbe APCD interpretations andrecommendations.Mandafory terminology such as'musl"and°required"are intended to dascnbe confrolling requi�emenls undarfhe terms o/the C/ean Air
Acl andAir Quality Conirol Commission regulaG'ons,but this documenf does nof establish legally binding requirements in and ofitself.
Separator Venting Emissions Inveniory
005 Separeror Venting
`i, ,,,,,,,123°.vi„ , ::"� 3F95 .: - D45..::.�....:t
FacilityAlRsID: County � Plant � �� Point
5ectioo o2-Equipment�escriQYion�etails
� P" --2"t7"�i ' :: : S k:F
uen�₹»sass�a-v�kwtt�prpzf3rednwnkii»essprgssurFse �cedu�a`te�preerssuasse3 .: : : ..�:
Detailed Emissions Unit Descr pt on ,'. �� ,,,.,,: _,/�;,,cs��s��.�..:', �,,,,,,,, ��� ,:��.�»;a. ,...�
:Ctpen 3ar� ,.. ',. , . : y - .
: �
� Emission Cantral Device Descripnon: ,'�, ,;-,, ,., ,�: ,,,, � „ �''�, yii� ;, -; ����.,v,l„y„ �
,,,,,�'. �?� ".'�... I
Requested Overall VOC&HAP Control Efficiency%: 9S ;;. , �
Limited Process Parameter '�r�te3r,.�� �: ��� "�'� -
Gasmeter .Y��s,mei�[:�___, _ ,_, .�
Section 03-Processin¢Rate In#ormation for Emissions Estimates
Primary Emissions-Separator .
• ActualThroughput �' ��,;MMscFperyear
RequestedPermdLimitThroughput S,S"MMscfperyear RequestedMonthlyThroughput= o MMs6permonth
PotentialtoEmit(PTE)Throughput= 2 MMsciperyear _
Process Control(Recycling) �
Equipped wrth a VRU�p`�c : �`"
\
Is VRU process eq ip ent ',�s�� � ��Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is 6ypassed(i.e.waste gas volume that is routed to ihe flare)
Secondary Emissions-Com6ustion Device�s)for Air Poliution ConYrol
Separator Gas Heating Value: � '�.�2d17IsBtu/sd
Volume of waste gas emitted per BBLof
liquids throughput: scf/hbl
Section 04-Emissions Factors&Methodolo¢ies
D iph n
„ . i� . r � '�'� �. .:
, : g��`°����� � �... ��y� / i �;
5 % ' �"R`�i� - ,.„ �� � ��� �RF 3'
���!�ii,,, �:: , ,,;" ti�� ��,",��,,,�,,;,_,, ., ��c;,,,,,�,.,
���
�
,� i ,;��
MW '�25:£RS':!Ib/16-mol Displacement Equation . .
� Ex=q*MW*Xx/C
Weight%
Helium -��i.;,,, .::::::n=€i� � .
CO2 ':� > ,;`.1�::�8;
N2 ' .:•��� '!, r&�3a": _ .._._
� methane ....__ ... _ .�::: �! Z5r�' ____ ._ . ...._�:- _.. ._� . . ... . � _ -. __ _ . .. . .. - . .. .
._.____ _.__. . _--___—. _ - _ __ ._._ _-- _—_ .
� ethane '��28�7;9� �
propane ��Z�3.�f1; -
iso6utane �� , s 2.89
n-hutane ii�',L�p�,:3`7,2$'..
sopentane �`�`�,a��/,/°!;:;"'.t''flP�: .
n-pentane ,aa.,. , '1:27'�. �
cyclopentane ��. •'"0.�3! � , , �
n-Hexane �!�0.75 . � _
cyclohexane , �4, �," !�.23:'
Otherhexanes ���„ix:1t} � �
heptanes - ;��Qs�.9�i
m ethylcycbhexane ,...`:��7.°��,�-��- -
224-TMP `�. �7;;� � .
Benzene ��� -C3�2�a
Toluene ;Q,1;
Ethylbenzene ;II.{}k �
Xylenes � ^.���a�' � ,
C8+Hea ,.4:22�
Total �a10�.00 -
V�OC Wt% 38.41
Emission Fac[ors Separator Venting
Uncontrolled Controlled EmissionFactorsource
Pollutant (16/MMsc� (Ib/MMscf)
(Gas Throughput) (Gas Throughput)
VOC 29501.3745 1375.0937
''�i ���Y��t�+�4tly� �.
Benzene 1a3.70b2 9.6&53 ������ '' ��� ��`� a�;
Taluene 9&.9269 4.9C63 ��'" � � ` �������
��
Ethyl6enzene 6.5285 0.3264 � - �������`°� - �
. Xylene 15.E990 0.7°4S ;�i�� � -
�a�� �',s��r zti���
n-Hexane 60�.9283 30.2464 y�, � - � �� �;��$
�c�., �`�����
224 TMP 39.5554 1.9775 �,s?,,,�`,�'�.,s,..,,,,.. '
Primary Control Device
Uncon[rolled Unwntrolled
Pollutant (Ib/MMStu) I6/MMscf EmissionFactor5ource
(WasteHeat .
Combusted) �GasThroughput)
" PM10 ��_.?,;;'. 0.004 �` �. �C 5 .'s F„,;�?:.
PM2.5 :C ' 0.000 �Ta� '� '"y� - �'*�u��`�:
sox ��3�s;r.., o.noo �`���� .�� ��
Nax ��tkassv ,;�. ss.sao `�' �. -- er�.�;��,�t�3�'�,��
CO ,,._6s3��t3:, .. 437.100 ;�: .�Ld ..�u,5��itx�Ye's,.�.....- 3'f
11 of 14 K:\PA\2018\18WE0073.CPl.xlsm
Separator Jenting Emissions Inventory
Section 0S-Emissions Inventory
Potential to Emit Actual Emissions Re�uested Permit Limits ftequested Monthly Limits
Cnteria Poliutants Uncontrolled Unconirolled Controlled Unconirolled Controlled Controlled
(tons/year) (tons/year) (tons/year) (tons/year) (tans/year) (Ibs/month)
PM10 0.�0 QA0 6.J0 9.G6 0.�9 4
PM2.5 0.a0 0.00 0.C0 fl.Q0 0.�0 0 �
SOx DA� 0.00 Q.60 0.00 0.00 0
NOu �.�3 C.00 a.a0 6.07 0.�7 � 12 � -
VOC 2Z.i3 G.0C 0.�0 R.13 l.il ?83
CO 0.33 0.00 0.00 �.33 0.33 55
Potential to Emit Actual Emissions Raauested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Umm�trolled Controlled �
(16s/year) �Ihs/year� (Ihs/year) Q6s/year) (16s/year�
Benzene Z?1'_ 0 6 29? ?5 0.145 0.007
Toluene 148 0 0 14'H 7 0.074 0.004
Ethylbenzene 1C o il 1U 0 0.005 0.000
%ylene ZR 0 0 2'i 1 0.012 0.001
n-Hexane a07 0 0 907 45 - 0.454 0.023
224 TMP 59 0 � 0 59 3 0.030 0.001
Section 06-Re ulato Summa Anal i
Regulation 3,Parts A,6 5ource reouires a perm.iz
Regulation 7,Section XV�II.B,G Source is sub�ect to°egulation 7,Sect€c�3 XV11.81,G -
Regulation 7 Section XVil.B.2.e The cor,trol dwi<e for YhEs separator is suhject io Rag.ulatian 7,Sectinn XVl1.e.2.e
(5ee regulatory applica6ility worksheef for detailed analysis)
Section 07-Initial and Periodic 5amplia¢and Testin¢Requirements
Using Gas Throughput to Moni₹or Compliance �
�
Does the company use site specific emission factors based on a gas sample to estimate emissions? �
This sample should represent the gas outlet of the equipment covered underthis AIRs ID,and should have heen collected within one year ofthe application received date.However,if
Che facility has not been modified(e.g.,no new wells 6rought on-line),then iY may be appropriate to use an older site-specifc sample.
If no,ihe permit will contain an"Initial Testing Requirement"to collect a site-specific gas sample from the equipment being permitCed and conduct an emissio�factur
analysisto demonstrate that the emission factors are less than or equal ta the emissions factors established with this application.
- �Are facility-wide permitted emissions of VOC greaterthan or equal to 90 tons per year? __„� � � �
If yes,the permit will contain:
-An"Initial7esYing RequiremenY'to mllect a site-specifc�as sample irom the equipment 6eing permitted and conduct an emission factor analysis to demonstrate thaithe
emission fac[ors are lessthan ur equal to ihe emissions factors estabiished with 4his application.
-A"PeriodicTesYing RequirernenY'2o collect a site-specific gas sample from the equipment heing permiited and conduct an emission factor analysis to demonsirate that ihe
. . .. _ .. .__.... .. _ _ .. .._. _. �._ _ .. _ _ _..:. . . ___. _ . .
�-� —�-- em sslon factors are less than or equal to the emissions factors esta6lished with this application on an annual basis.- — --�—��- �- - - --------—� --- -------- ----------- ------ �- -----
Will the operator have a meter ins[zlled and operational upon startup of this point? Yes
If no,the permit will contain a mndition tha#requiresthe operatorto calculafe gas throughput using Yhe Iiquid thmughput until the meter is installed and vperational(not
Yo exceed 180 days).This condition will use the"Volume of�Naste gas emitted per BBL of liquids throughpuP'(sd/661)value in section 03. �
Dces the company request a mntrol device efficiencygreaterthan 95%for a flare or com6ustion device? Ik,t ��'-;����.�,���`,`�
If yes,Yhe permit will mntain and initial compliance test condition to demonstrate the desiruction e�ciency of the wm6ustion device based
on inlet and outlet conceniration sampling
You have indicaYed above ihat The mor�l2or=d orac=ss parameYer Is naturzl gas vented.Tne foliow:ng qu=_stEons do not requ�re an answer.
e �..
. . . ,., ..., �- , .�" �,..� ,,, �,..' � ,- �,.. - ' .
.. " � //.-•, � . /. :; �. �< ' r'` l�-� l ,.F
- /
�. ��= l l r-rs
;�
� � l n i
. , 12of14 K:\PA\2018\38WE0073.CPS.xism
Separator Venting Emissions Inventory
s tion OS Te hnical A�s�s Notes
72f prpe.f�'�e ttownYrme assumed fUr ettt`issfon5fp�o.re;slirFi#��+IcWaS oqs.P�eflsen'ota,���;Ccznt;nas₹igu-ee�ur�eoMmlled{(�ures or�APEN₹o Ue 1G0%.Uflcan�trallederois�ori�are,[harefcre coe;ervaUve
Section 09-Inventory SCC Co�nQ and Emissions Factors
Uncantrolled
Emissions
AIRS Point# Process# SCC Code PollutanY Factor Control% Units
005 Ol 3-70-00'i-&0 Fiares PM30 0.00 0 ib/MMSCF
� PM2.5 0.00 0 Ib/MMSCF
� SOz o.oG 0 Ib/PlIM5CP
NOx 95.88 0 14/MMSCF
VOC 29501.87 95 16/MMSCF
CO 437.16 0 Ib/MMSCF
Benzene 193.77 95 ih/MMSCF
Toluene 98.93 95 Ib/MMSCF
, Ethyl6enzene 6.53 95 Ib/MMSCF
Xylene 15.90 95 Ib/MMSCF
n-Hexane 604.53 95 Ib/MMSCF
224 TMP 39.56 95 ib(MMSCF
13 of 14 K:\PA\2018\18WE0073.CPl.xlsm
Separator Venting Regulatory Analysis Worksheet
CaloradaRe�latlon3PartsNandB-APENandPermitReu ents
Sour<e is in the Attainment Area
AT(AINMEM �
1. Are uncontrolled actual em'ss�ons from any cr ter a pallutants from th s nd v dual source greater than 2 TPY(Regulat on 3,PartA,Sectlon II.D.1 a�7 ,8'-'�`5 e Req
2 Are total fac I ty uncantrolled VOC em ss ans greater than 5 TPY,NOx greater than 10 TPV or CD em sslons greater than 10 TPY(Regulatlon 3,Part B,Section II.D.3)? '(.E5 Sourre Req
Source requlres a permit
NON-ATTAINMEM
_ 1. Are uncontrolled emissions f�om any cn[eria pollutants from[his indlvidual saurce g�eater than 1 TPY(Regulation 3,Part A,Secfion II.D.l.a�?
2. Aretotalfacilityumm�trolhedVOCemissionsfromthegreaterthan2TPV,NOxgreaterthan5TPYorCOemissionsgreaterthanlOTPY(Regulation3,Parte,5eNanII.D.2)7
You ha�e i�dicated that source is in ihe 0.ttaimment Area
[olorado Ra¢ulation 7,Sectlan%VII ,� ����
1 wasthewellnewtymnstructed,hydaulicalWfractured,arrecompletedonarafterAugust1,20147 g�5 urceisst
Source-s subjectto ftegulat on]Section X411.6.2 G � �
SeRion XVII.8.2—General Provisions for Air Pollutlon Cantral Equipment and Prevention of Emissions
Seccion XVII.G-Emissions Control
Alternative Emissions Cari[ro110pilanal5eRlo�1 � �
a. Is this separator controlled by a back-up or aliernate combustion device(I.e.,noi the primary mnhol device)that is rnt endosed7 �,;.����.�`�°;�The control
Theconvoldev'cefarth�ssepaatorissubjec[ioRegulation]SeRionXVl1.8.2.e �� � �
Se�tinnXVll.9.2.e—Alternative emissians conirol equipment
Dlsclaimer
This documerd assrsts ope2fors with deteimining applicability of certain requirements offha C/ean Ai�Act,its implemenb'ng regulations,and AirQuality Co�frol Commission regulaG'ons.This document is
nof a rule o�regulatlon,and the analysis il contains may not appry to a particular sifuation based upon Ihe indivitlual/acts and circumsfances.This tlocuma�does nof change orsubsfitute for any law,
regulat'on,or any otherlegally binding requiremenf and is not legally enforceable,In the event of any conRict between the language o(this documenf and the language offhe Clean AirAct„its implementing
regulations,aod AirQualiry Control Commission iagulations,the lan9uage of the stafute orregulafion will contro/. The use of non-mandatory language such as"racommend,""may,""should,"and"can,"is
intended to descnbe APCD interpretations and recommendafions.Mandatory terminology such as"musf"arN"required"are infended to describe confrollinqrequi�ements underthe terms o(the Clean Air
Act and AirQuality Control Commission regulafions,buf this document doas nof esfablish legally binding re4uiremenfs in and ofifself.
STATE OF COLON
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
PERMIT NO:
18WE0071
CONSTRUCTION PERMIT
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 Razor 25 CPB, located in SESW SEC 25 T10N R58W, in
Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment ID
AIRS
Point
Description
ENG-01
001 -
One (1) Caterpillar, Model G3516J, Serial Number N6W00226,
natural gas -fired, turbo -charged, 4SLB reciprocating internal
combustion engine, site rated at 1380 horsepower. This engine
shall be equipped with an oxidation catalyst and air -fuel ratio
control. This emission unit is used for natural gas compression.
This engine may be replaced with another engine in accordance with the temporary engine
replacement provision or with another Caterpillar, Model G3516J engine 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 of the latter of commencement of operation or issuance of this permit,
by submitting a Notice of Startup form to the Division. The Notice of Startup form
may be downloaded online at https://www.colorado.gov/pacific/cdphe/other-air-
permitting-notices. Failure to notify the Division of startup of the permitted source is a
violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section
III.G.1 and can result in the revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
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
AIRS ID: 123/9F95 Page 1 of 15
NGEngine Version 2014-1
compliance with the conditions. Failure to demonstrate compliance within 180 days may
result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2).
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; (iii) does not complete construction within a reasonable
time of the estimated completion date. The Division may grant extensions of the
deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B,
III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Reference: Regulation No. 3, Part B, Section III.E.)
5. The following information shall be provided to the Division within fifteen (15) days of the
latter of commencement of operation or issuance of this permit.
• 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.)
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
ENG-01
001
2262
1585
4524
Point
(Note: Monthly limits are based on a 31 -day month.)
The owner or operator shall calculate monthly emissions based on the calendar month.
Facility -wide emissions of each individual hazardous air pollutant shall be less than
1,359 lb/month.
AIRS ID: 123/9F95
Page 2 of 15
Public Health and Environment
Air Pollution Control Division
Facility -wide emissions of total hazardous air pollutants shall be less than 3,398
lb/month.
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission Type
NOX
VOC
CO
ENG-01
001
13.3
9.3
26.7
Point
See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility -wide emissions of each individual hazardous air pollutant shall be less than 8.0
tpy.
Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
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. The owner or operator shall track emissions from all insignificant activities at the facility
on an annual basis to demonstrate compliance with the facility emission limitations as
seen below. An inventory of each insignificant activity and associated emission
calculations shall be made available to the Division for inspection upon request. For the
purposes of this condition, insignificant activities shall be defined as any activity or
equipment, which emits any amount but does not require an Air Pollutant Emission
Notice (APEN).
Total emissions from the facility, including permitted emissions and insignificant
activities, shall not exceed:
• 100 tons per year of any criteria pollutant and/or
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
ENG-01
001
Selective catalytic oxidizer and air/fuel ratio
controller
CO
AIRS ID: 123/9F95
Page 3 of 15
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
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual
Limit
Monthly Limit
(31 days)
ENG-01
001
Consumption of natural gas as a fuel
95.7
MMscf/yr
8.2
MMscf/month
Fuel consumption shall be measured by one of the following methods: individual engine
fuel meter; facilty-wide fuel meter attributed to fuel consumption rating and hours of
operation; or manufacturer -provided fuel consumption rate.
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 XVII.B.2.b 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)
OPERATING & MAINTENANCE REQUIREMENTS
14. Upon startup of these points, the owner or operator shall follow the most recent
operating and maintenance (O&M) plan and record keeping format approved by the
Division, in order to demonstrate compliance on an ongoing basis with the requirements
of this permit. Revisions to your O&M plan are subject to Division approval prior to
implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.)
AIRS ID: 123/9F95 Page 4 of 15
Public Health and Environment
Air Pollution Control Division
COMPLIANCE TESTING AND SAMPLING
Periodic Testing Requirements
15. This engine is subject to the periodic testing requirements of 40 C.F.R Part 63, Subpart
ZZZZ.
16. This engine is subject to the periodic testing requirements as specified in the operating
and maintenance (O&M) plan as approved by the Division. Revisions to your O&M plan
are subject to Division approval. Replacements of this unit completed as Alternative
Operating Scenarios may be subject to additional testing requirements as specified in
Attachment A. 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:
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 or NANSR) shall apply to this source
at any such time that this source becomes major solely by virtue of a relaxation in any
permit condition. Any relaxation that increases the potential to emit above the applicable
Federal program threshold will require a full review of the source as though construction
had not yet commenced on the source. The source shall not exceed the Federal
program threshold until a permit is granted. (Regulation No. 3 Part D).
GENERAL TERMS AND CONDITIONS
AIRS ID: 123/9F95 Page 5 of 15
Public Health and Environment
Air Pollution Control Division
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
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 isa material part hereofandis 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.
AIRS ID: 123/9F95 Page 6 of 15
By:
Public Health and Environment
Air Pollution Control Division
Timothy Sharp
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Whiting Oil and Gas Corporation
AIRS ID: 123/9F95 Page 7 of 15
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: https://www.colorado.dov/pacific/cdphe/aqcc-reqs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis
of the specific compounds emitted if the source(s) operate at the permitted limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emission
Rate
(lb/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (Ib/yr)
001
Formaldehyde
50000
11460
YES
7730
Acetaldehyde
75070
816
YES
-
Acrolein
107028
501
YES
-
n -Hexane
110543
108
NO
-
Benzene
71432
43
NO
-
5) The emission levels contained in this permit are based on the following emission factors:
Point 001:
CAS
Pollutant
Emission
Uncontrolled
Ib/MMBtu
Factors -
g/bhp-hr
Emission
Controlled
lb/MMBtu
Factors —
g/bhp-hr
NOx
2.73E-01
1.00E00
2.73E-01
1.00E00
CO
6.64E-01
2.43E00
5.21 E-01
2.00E00
VOC
1.91E-01
7.00E-01
1.91E-01
7.00E-01
50000
Formaldehyde
1.17E-01
4.30E-1
7.90E-02
2.90E-01
75070
Acetaldehyde
8.36E-03
-
8.36E-03
-
107028
Acrolein
5.14E-03
-
5.14E-03
-
Emission factors are based on a Brake -Specific Fuel Consumption Factor of 8070 Btu/hp-hr, a
site -rated horsepower value of 1380, and a fuel heat value of 1020 Btu/scf.
Emission Factor Sources:
CAS
Pollutant
Uncontrolled EFSource
Controlled EF Source
NOx
Manufacturer
Manufacturer
CO
Manufacturer
Catalyst Manufacturer
AIRS ID: 12319F95
Page 8 of 15
Public Health and Environment
Air Pollution Control Division
CAS
Pollutant
Uncontrolled EFSource
Controlled EF Source
VOC
Manufacturer
Manufacturer
50000
Formaldehyde
Manufacturer
Catalyst Manufacturer
75070
Acetaldehyde
AP -42
AP -42
107028
Acrolein
AP -42
AP -42
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 engine is subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for
Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal Register
posting — effective March 18, 2008). This rule has not yet been incorporated into Colorado Air Quality
Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA
website at: http://www.epa.gov/ttn/atw/area/fr18ia08.pdf
8) This engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards for
Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January 18,
2008 Federal Register posting - effective March 18, 2008). The January 18, 2008 amendments to
include requirements for area sources and engines < 500 hp located at major sources have not yet
been incorporated into Colorado Air Quality Control Commission's Regulation No. 8. A copy of the
complete subpart is available on the EPA website at: http://www.epa.gov/ttn/atw/area/fr18ia08.pdf
Additional information regarding area source standards can be found on the EPA website at:
http://www. epa.gov/ttn/atw/area/arearules. html
9) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC; HAP
PSD or NANSR
Synthetic Minor Source of: VOC
MACT ZZZZ
Area Source Requirements: Applicable
10) 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
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
AIRS ID: 123/9F95
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Public Health and Environment
Air Pollution Control Division
MACT
63.6580-63.8830
Subpart ZZZZ — Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN — Subpart XXXXXX
11) A self certification form and guidance on how to self -certify compliance as required by this permit may
be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification
AIRS ID: 12319F95 Page 10 of 15
Public Health and Environment
Air Pollution Control Division
ATTACHMENT A:
ALTERNATIVE OPERATING SCENARIOS
RECIPROCATING INTERNAL COMBUSTION ENGINES
October 12, 2012
2. Alternative Operating Scenarios
The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of
natural gas fired reciprocating internal combustion 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 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 NSPS or MACT 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 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. In addition to the log, the
owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make
them available to the Division upon request.
2.1.1 The owner or operator may temporarily replace an existing engine that is subject to the emission
limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a
different manufacturer, model, or horsepower as the existing 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. Measurement of emissions from the temporary replacement engine
shall be made as set forth in section 2.2.
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Public Health and Environment
Air Pollution Control Division
2.1.2 The owner or operator may permanently replace the existing engine with another engine with the
same manufacturer, model, and horsepower engines without modifying this permit so long as the
permanent replacement engine complies with all permit limitations and other requirements applicable to
the existing engine as well as any new applicable requirements for the replacement engine. Measurement
of emissions from the permanent replacement engine and compliance with the applicable emission
limitations shall be made as set forth in section 2.2.
An Air Pollutant Emissions Notice (APEN) that includes the specific 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 a copy of the relevant Applicability Reports for the replacement engine.
Example Applicability
Reports can be found at https://www.colorado.gov/pacific/cdphe/altemate-operating-scenario-aos-
reporting-forms. 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.
2.2 Portable Analyzer Testing
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 the relevant 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 engine using a portable flue gas analyzer within seven (7) calendar days of
commencing operation of the replacement engine.
All portable analyzer testing required by this permit shall be conducted using the Division's Portable
Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at:
https://www.colorado.gov/pacific/sites/default/files/AP Portable-Analyzer-Monitorinq-Protocol.pdf
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.
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Public Health and Environment
Air Pollution Control Division
For comparison with a short-term limit that is either input based (Ib/mmBtu), output based (g/hp-hr) or
concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement
engine 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 engine 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 engine 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 engine is taken offline.
2.3 Applicable Regulations for Permanent Engine Replacements
2.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B § II.D.2
All permanent replacement engines that are located in an area that is classified as
attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT)
for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and
NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which
the area is in attainment/maintenance or nonattainment, except as follows:
In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of
emissions and to NOX and SO2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds
40 tons/yr.
For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating
internal combustion engines:
VOC: The emission limitations in NSPS JJJJ
CO: The emission limitations in NSPS JJJJ
NOX: The emission limitations in NSPS JJJJ
SO2: Use of natural gas as fuel
PM10: Use of natural gas as fuel
As defined in 40 CFR Part 60 Subparts GG (§ 60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains
20.0 grains or less of total sulfur per 100 standard cubic feet.
2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State -
Only conditions).
Control Requirements: Section XVI
Any permanent replacement engine located within the boundaries of an ozone nonattainment area is
subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified
below:
Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non-
selective catalyst and air fuel controller to reduce emission.
Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation
catalyst to reduce emissions.
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Public Health and Environment
Air Pollution Control Division
The above emission control equipment shall be appropriately sized for the engine and shall be operated
and maintained according to manufacturer specifications.
The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2.
Emission Standards: Section XVII.E — State -only requirements
Any permanent engine that is either constructed or relocated to the state of Colorado from another state,
after the date listed in the table below shall operate and maintain each engine according to the
manufacturer's written instructions or procedures to the extent practicable and consistent with
technological limitations and good engineering and maintenance practices over the entire life of the
engine so that it achieves the emission standards required in the table below:
Max Engine HP
Construction or
Relocation Date
Emission Standards in G/hp-hr
NOx
CO
VOC
January 1, 2008
2.0
4.0
1.0
100<Hp<500
January 1, 2011
1.0
2.0
0.7
500≤Hp
July 1, 2007
July 1, 2010
2.0
1.0
4.0
2.0
1.0
0.7
The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2.
2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ
A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater
than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp
except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for
lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements
of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting
requirements for the permanent engine replacement shall be included in the Applicability Reports
required under Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this
AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this
AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted
within the time frame specified in Condition 2.2.
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 manufacture date for purposes of determining the applicability of NSPS JJJJ
requirements).
However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does,
any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ,
there will be an additional step added to the determination of the NSPS. Under the provisions of
Regulation No. 6, Part B, § 1.8 (which is referenced in Part A), any engine relocated from outside of the
State of Colorado into the State of Colorado is considered to be a new source, subject to the
requirements of NSPS JJJJ.
2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ
A permanent replacement engine located at either an area or major source is subject to the requirements
in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting
AIRS ID: 123/9F95 Page 14 of 15
Public Health and Environment
Air Pollution Control Division
requirements for the permanent engine replacement shall be included in the Applicability Reports
required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this
AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under
Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time
frame specified in Condition 2.2.
2.4 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: 12319F95 Page 15 of 15
STATE OF COLON
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
PERMIT NO:
18WE0072
CONSTRUCTION PERMIT
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 Razor 25 CPB, located in SESW SEC 25 T10N R58W, in
Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment ID
AIRS
Point
Description
ENG-02
002
One (1) Caterpillar, Model G3516J, Serial Number N6W00216,
natural gas -fired, turbo -charged, 4SLB reciprocating internal
combustion engine, site rated at 1380 horsepower. This engine
shall be equipped with an oxidation catalyst and air -fuel ratio
control. This emission unit is used for natural gas compression.
This engine may be replaced with another engine in accordance with the temporary engine
replacement provision or with another Caterpillar, Model G3516J engine 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 of the latter of commencement of operation or issuance of this permit,
by submitting a Notice of Startup form to the Division. The Notice of Startup form
may be downloaded online at https://www.colorado.gov/pacific/cdphe/other-air-
permitting-notices. Failure to notify the Division of startup of the permitted source is a
violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section
III.G.1 and can result in the revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
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
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NGEngine Version 2014-1
Public Health and Environment
Air Pollution Control Division
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 I.G.2).
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source
within 18 months after either, the date of issuance of this construction permit or the date
on which such construction or activity was scheduled to commence as set forth in the
permit application associated with this permit; (ii) discontinues construction for a period
of eighteen months or more; (iii) does not complete construction within a reasonable
time of the estimated completion date. The Division may grant extensions of the
deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B,
III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Reference: Regulation No. 3, Part B, Section III.E.)
5. The following information shall be provided to the Division within fifteen (15) days of the
latter of commencement of operation or issuance of this permit.
• 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.)
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
NOx
VOC
CO
ENG-02
002
2262
1585
4524
Point
(Note: Monthly limits are based on a 31 -day month.)
The owner or operator shall calculate monthly emissions based on the calendar month.
Facility -wide emissions of each individual hazardous air pollutant shall be less than
1,359 lb/month.
AIRS ID: 123/9F95
Page 2 of 15
Public Health and Environment
Air Pollution Control Division
Facility -wide emissions of total hazardous air pollutants shall be less than 3,398
lb/month.
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission Type
NO.
VOC
CO
ENG-02
002
13.3
9.3
26.7
Point
See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility -wide emissions of each individual hazardous air pollutant shall be less than 8.0
tpy.
Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
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. The owner or operator shall track emissions from all insignificant activities at the facility
on an annual basis to demonstrate compliance with the facility emission limitations as
seen below. An inventory of each insignificant activity and associated emission
calculations shall be made available to the Division for inspection upon request. For the
purposes of this condition, insignificant activities shall be defined as any activity or
equipment, which emits any amount but does not require an Air Pollutant Emission
Notice (APEN).
Total emissions from the facility, including permitted emissions and insignificant
activities, shall not exceed:
• 100 tons per year of any criteria pollutant and/or
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
ENG-02
002
Selective catalytic oxidizer and air/fuel ratio
controller
CO
AIRS ID: 123/9F95
Page 3 of 15
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
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual
Limit
Monthly Limit
(31 days)
ENG-02
002
Consumption of natural gas as a fuel
95.7
MMscf/yr
8.2
MMscf/month
Fuel consumption shall be measured by one of the following methods: individual engine
fuel meter; facilty-wide fuel meter attributed to fuel consumption rating and hours of
operation; or manufacturer -provided fuel consumption rate.
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 XVII.B.2.b 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)
OPERATING & MAINTENANCE REQUIREMENTS
14. Upon startup of these points, the owner or operator shall follow the most recent
operating and maintenance (O&M) plan and record keeping format approved by the
Division, in order to demonstrate compliance on an ongoing basis with the requirements
of this permit. Revisions to your O&M plan are subject to Division approval prior to
implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.)
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Public Health and Environment
Air Pollution Control Division
COMPLIANCE TESTING AND SAMPLING
Periodic Testing Requirements
15. This engine is subject to the periodic testing requirements of 40 C.F.R Part 63, Subpart
ZZZZ.
16. This engine is subject to the periodic testing requirements as specified in the operating
and maintenance (O&M) plan as approved by the Division. Revisions to your O&M plan
are subject to Division approval. Replacements of this unit completed as Alternative
Operating Scenarios may be subject to additional testing requirements as specified in
Attachment A. 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:
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 or NANSR) shall apply to this source
at any such time that this source becomes major solely by virtue of a relaxation in any
permit condition. Any relaxation that increases the potential to emit above the applicable
Federal program threshold will require a full review of the source as though construction
had not yet commenced on the source. The source shall not exceed the Federal
program threshold until a permit is granted. (Regulation No. 3 Part D).
GENERAL TERMS AND CONDITIONS
AIRS ID: 123/9F95 Page 5 of 15
Public Health and Environment
Air Pollution Control Division
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
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.
AIRS ID: 123/9F95 Page 6 of 15
By:
Public Health and Environment
Air Pollution Control Division
Timothy Sharp
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Whiting Oil and Gas Corporation
AIRS ID: 123/9F95 Page 7 of 15
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: https://www.colorado.gov/pacific/cdphe/agcc-reqs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis
of the specific compounds emitted if the source(s) operate at the permitted limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emission
Rate
(Ib/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (lb/yr)
002
Formaldehyde
50000
11460
YES
7730
Acetaldehyde -
75070 - -
816
YES
Acrolein
107028
501
YES
n -Hexane
110543
108
NO
Benzene
71432
43
NO
5) The emission levels contained in this permit are based on the following emission factors:
Point 002:
CAS
Pollutant
Emission
Uncontrolled
lb/MMBtu
Factors -
g/bhp-hr
Emission
Controlled
lb/MMBtu
Factors —
g/bhp-hr
NOx
2.73E-01
1.00E00
2.73E-01
1.00E00
CO
6.64E-01
2.43E00
5.21 E-01
2.00E00
VOC
1.91 E-01
7.00E-01
1.91 E-01
7.00E-01
50000
Formaldehyde
1.17E-01
4.30E-1
7.90E-02
2.90E-01
75070
Acetaldehyde
8.36E-03
-
8.36E-03
-
107028
Acrolein
5.14E-03
-
5.14E-03
-
Emission factors are based on a Brake-Speclic Fuel Consumption Factor of 8070 Btu/hp-hr, a
site -rated horsepower value of 1380, and a fuel heat value of 1020 Btu/scf.
Emission Factor Sources:
CAS
Pollutant
Uncontrolled EFSource
Controlled EF Source
NOx
Manufacturer
Manufacturer
CO
Manufacturer
Catalyst Manufacturer
AIRS ID: 123/9F95
Page 8 of 15
Public Health and Environment
Air Pollution Control Division
CAS
Pollutant
Uncontrolled EFSource
Controlled EF Source
VOC
Manufacturer
Manufacturer
50000
Formaldehyde
Manufacturer
Catalyst Manufacturer
75070
Acetaldehyde
AP -42
AP -42
107028
Acrolein
AP -42
AP -42
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 engine is subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for
Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal Register
posting — effective March 18, 2008). This rule has not yet been incorporated into Colorado Air Quality
Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA
website at: http://www.epa.gov/ttn/atw/area/fr18ia08.pdf
8) This engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards for
Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January 18,
2008 Federal Register posting - effective March 18, 2008). The January 18, 2008 amendments to
include requirements for area sources and engines < 500 hp located at major sources have not yet
been incorporated into Colorado Air Quality Control Commission's Regulation No. 8. A copy of the
complete subpart is available on the EPA website at: http://www.epa.gov/ttn/atw/area/fr18ia08.pdf
Additional information regarding area source standards can be found on the EPA website at:
http://www. eoa.gov/ttn/atw/area/arearu les. htm I
9) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC; HAP
PSD or NANSR
Synthetic Minor Source of: VOC
MACT ZZZZ
Area Source Requirements: Applicable
10) 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
AIRS ID: 123/9F95
Page 9 of 15
Public Health and Environment
Air Pollution Control Division
MACT
63.6580-63.8830
Subpart ZZZZ — Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN — Subpart XXXXXX
11) A self certification form and guidance on how to self -certify compliance as required by this permit may
be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification
AIRS ID: 123/9F95 Page 10 of 15
Public Health and Environment
Air Pollution Control Division
ATTACHMENT A:
ALTERNATIVE OPERATING SCENARIOS
RECIPROCATING INTERNAL COMBUSTION ENGINES
October 12, 2012
2. Alternative Operating Scenarios
The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of
natural gas fired reciprocating internal combustion 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 cyder 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 oount 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 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 NSPS or MACT 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 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. In addition to the log, the
owner or operator shall maintain a copy of all Applicabiity Reports required under section 2.1.2 and make
them available to the Division upon request.
2.1.1 The owner or operator may temporarily replace an existing engine that is subject to the emission
limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a
different manufacturer, model, or horsepower as the existing 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. Measurement of emissions from the temporary replacement engine
shall be made as set forth in section 2.2.
AIRS ID: 123/9F95 Page 11 of 15
Public Health and Environment
Air Pollution Control Division
2.1.2 The owner or operator may permanently replace the existing engine with another engine with the
same manufacturer, model, and horsepower engines without modifying this permit so long as the
permanent replacement engine complies with all permit limitations and other requirements applicable to
the existing engine as well as any new applicable requirements for the replacement engine. Measurement
of emissions from the permanent replacement engine and compliance with the applicable emission
limitations shall be made as set forth in section 2.2.
An Air Pollutant Emissions Notice (APEN) that includes the specific 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 a copy of the relevant Applicability Reports for the replacement engine.
Example Applicability
Reports can be found at https://www.colorado.gov/pacific/cdphe/alternate-operating-scenario-aos-
reporting-forms. 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.
2.2 Portable Analyzer Testing
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 the relevant 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 engine using a portable flue gas analyzer within seven (7) calendar days of
commencing operation of the replacement engine.
All portable analyzer testing required by this permit shall be conducted using the Division's Portable
Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at:
https://www.colorado.aov/pacific/sites/default/files/AP Portable-Analyzer-Monitoring-Protocol.pdf
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.
AIRS ID: 12319F95 Page 12 of 15
Public Health and Environment
Air Pollution Control Division
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
engine 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 engine 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 engine 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 engine is taken offline.
2.3 Applicable Regulations for Permanent Engine Replacements
2.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B § II.D.2
All permanent replacement engines that are located in an area that is classified as
attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT)
for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and
NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which
the area is in attainment/maintenance or nonattainment, except as follows:
In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of
emissions and to NOX and SO2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds
40 tons/yr.
For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating
internal combustion engines:
VOC: The emission limitations in NSPS JJJJ
CO: The emission limitations in NSPS JJJJ
NOX: The emission limitations in NSPS JJJJ
SO2: Use of natural gas as fuel
PM10: Use of natural gas as fuel
As defined in 40 CFR Part 60 Subparts GG (§ 60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains
20.0 grains or less of total sulfur per 100 standard cubic feet.
2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State -
Only conditions).
Control Requirements: Section XVI
Any permanent replacement engine located within the boundaries of an ozone nonattainment area is
subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified
below:
Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non-
selective catalyst and air fuel controller to reduce emission.
Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation
catalyst to reduce emissions.
AIRS ID: 123/9F95 Page 13 of 15
Col do 'gip e4 o Public Health and Environment
Air Pollution Control Division
The above emission control equipment shall be appropriately sized for the engine and shall be operated
and maintained according to manufacturer specifications.
The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2.
Emission Standards: Section XVII.E — State -only requirements
Any permanent engine that is either constructed or relocated to the state of Colorado from another state,
after the date listed in the table below shall operate and maintain each engine according to the
manufacturer's written instructions or procedures to the extent practicable and consistent with
technological limitations and good engineering and maintenance practices over the entire life of the
engine so that it achieves the emission standards required in the table below:
Max Engine HP
Construction or
Relocation Date
Emission Standards in G/hp-hr
NOx
CO
VOC
January 1, 2008
2.0
4.0
1.0
100<Hp<500
January 1, 2011
1.0
2.0
0.7
500≤Hp
July 1, 2007
July 1, 2010
2.0
1.0
4.0
2.0
1.0
0.7
The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2.
2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ
A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater
than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp
except for lean burn engines greater than or equal to 500 hp and less than -1,350 hp, and 1/1/2008 for
lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements
of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting
requirements for the permanent engine replacement shall be included in the Applicability Reports
required under Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this
AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this
AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted
within the time frame specified in Condition 2.2.
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 manufacture date for purposes of determining the applicability of NSPS JJJJ
requirements).
However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does,
any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ,
there will be an additional step added to the determination of the NSPS. Under the provisions of
Regulation No. 6, Part B, § 1.8 (which is referenced in Part A), any engine relocated from outside of the
State of Colorado into the State of Colorado is considered to be a new source, subject to the
requirements of NSPS JJJJ.
2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ
A permanent replacement engine located at either an area or major source is subject to the requirements
in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting
AIRS ID: 123/9F95 Page 14 of 15
Public Health and Environment
Air Pollution Control Division
requirements for the permanent engine replacement shall be included in the Applicability Reports
required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this
AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under
Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time
frame specified in Condition 2.2.
2.4 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: 12319F95 Page 15 of 15
Permit number:
Date issued:
Issued to:
Co
Air Po
Depart
CONSTRUCTION PERMIT
18WE0073
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General Description:
Issuance: 1
Whiting Oil and Gas Corporation
Razor 25 CPB
123/9F95
SESW SEC 25 T10N R58W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
SEP-01 to
SEP-08
003
Four (4) two-phase separators and four (4)
three-phase heater treaters
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 this
specific 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 of
the latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting-
notices. Failure to notify the Division of startup of the permitted source is a violation of Air
Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result
in the revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
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. A self certification form and guidance on how to self -certify
compliance as required by this permit may be obtained online at
COLORADO
Air Pollution Control Div sign
)inn btnwrta; t
Page 1 of 8
www.colorado.gov/pacifi (Regulation Number 3, Part B,
Section III.G.2.)
3. This permit shall expire i e owner or operator o f e source or 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. (Regulation Number 3,
Part B, Section 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.
(Regulation Number 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. (Regulation Number 3,
Part B, Section II.A.4.)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO.
VOC
CO
SEP-01 to SEP-
08
003
---
4.0
60.7
16.7
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, 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 actual emissions each month and keep a compliance record on site or at a local field
office with site responsibility for Division review.
7. The owner or operator shall track emissions from all insignificant activities at the facility on an
annual basis to demonstrate compliance with the facility potential emission limitations as seen
below. An inventory of each insignificant activity and associated emission calculations shall be
made available to the Division for inspection upon request. For the purposes of this condition,
insignificant activities shall be defined as any activity or equipment, which emits any amount
but does not require an Air Pollution Emission Notice (APEN) or is permit exempt.
Total potential emissions from the facility, including all permitted emissions and potential to
emit from all insignificant activities, shall be less than:
• 100 tons per year of VOC
COLORADO
Air Pollution Control Division
000s
Page 2 of 8
8. The emission points in t
control equipment as lis
established in this perm
maintained with the emissions
ess than or equal to the limits
Se , III.E.)
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
SEP-01 to
SEP-08
003
Open Flare during gas -gathering downtime
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
9. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
SEP-01 to SEP-
08
003
Natural Gas Venting
73.0 MMSCF
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder shall calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
10. - _The _owner _or_ operator _shall _ continuously_ monitor and record the volumetric flow rate_ of
natural gas vented from the separator(s) using the flow meter. The owner or operator shall use
monthly throughput records to demonstrate compliance with the process limits contained in
this permit and to calculate emissions as described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
11. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
shall be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
12. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
13. The open flare covered by this permit has been approved as an alternative emissions control
device under Regulation Number 7, Section XVII.B.2.e. The open flare must have no visible
emissions during normal operations, as defined under Regulation Number 7, XVII.A.16, and be
designed so that an observer can, by means of visual observation from the outside of the open
flare, or by other convenient means approved by the Division, determine whether it is
operating properly. This open flare must be equipped with an operational auto -igniter
according to the following schedule:
• All combustion devices installed on or after May 1, 2014, must be equipped with an
operational auto -igniter upon installation of the combustion device;
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
COLORADO
Pal CwItrol orison
Page 3 of 8
14. The separator covered b athis -r ` sub: to latio ' 7, Section XVII.G. (State Only).
On or after August 1, 201 gas o n •ff . -. rat.: , rodu -d during normal operation from
any newly constructed, d, ple - 'it and gas well, must either be
routed to a gas gathering line or controlled from the date of first production by air pollution
control equipment that achieves an average hydrocarbon control efficiency of 95%. If a
combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons.
OPERATING Et MAINTENANCE REQUIREMENTS
15. Upon startup of these points, the owner or operator shall follow the most recent operating and
maintenance ((NM) 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
the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3,
Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
16. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of
visible emissions. "Visible Emissions" means observations of smoke for any period or periods of
duration greater than or equal to one minute in any fifteen minute period during normal
operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16)
Periodic Testing Requirements
17. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A,
II.C.)
)
• Annually by April 30"' whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or
activity; or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
COLORADO
A nun Control DiViSiork
Page 4 of 8
• Whenever a perm
• No later than 30
19. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any
such time that this source becomes major solely by virtue of a relaxation in any permit
condition. Any relaxation that increases the potential to emit above the applicable Federal
program threshold will require a full review of the source as though construction had not yet
commenced on the source. The source shall not exceed the Federal program threshold until a
permit is granted. (Regulation Number 3, Parts C and D).
GENERAL TERMS AND CONDITIONS
20. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
21. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity, commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self -certification of all
points has been reviewed and approved by the Division, it will provide written documentation
of such final authorization. Details for obtaining final authorization to operate are located in
the Requirements to Self -Certify for Final Authorization section of this permit.
22. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
23. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
24. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a
permit are contested by the owner or operator, or the Division revokes a permit, the owner or
operator of a source may request a hearing before the AQCC for review of the Division's action.
25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Timothy Sharp
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Whiting Oil and Gas Corporation
FT
COLORADO
Air Pa lutioiz Control Division
Page 6 of 8
Notes to Permit Holder at the ti
1) The permit holder is requir: °'•ay '? -s e = :-='ng ti a 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.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written
notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: https://www.colorado.gov/pacific/cdphe/agcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's
analysis of the specific compounds emitted if the source(s) operate at the permitted limitations.
Facility
Equipment ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(tPY)
Controlled
Emissions
(tPY)
SEP-01 to
SEP-08
003
Benzene
71432
3.101
0.155
Toluene
108883
3.536
0.177-
Ethylbenzene
100414
0.671
0.034
Xylenes
1330207
1.679
0.084
n -Hexane
110543
26.102
1.305
2,2,4-
Trimethylpentane
540841
4.610
0.230
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 0.125 tons
per year (tpy) are reportable and may result in annual emission fees based on the most recent Air Pollution
Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 003:
CAS #
Pollutant
Uncontrolled
Emission Factors
(lb/MMSCF)
Controlled
Emission Factors
(lb/MMSCF)
Source
N0x
0.068
AP -42
CO
0.310
AP -42
V0C
33297.6986
1664.8849
Site Sample
71432
Benzene
84.9487
4.2474
Site Sample
108883
Toluene
96.8662
4.8433
Site Sample
100414
Ethylbenzene
18.3850
0.9192
Site Sample
1330207
Xylene
45.9987
2.2999
Site Sample
110543
n -Hexane
715.1239
35.7562
Site Sample
COLORADO
Air Pollution Control Division
C artMert sf Punt: ) ua¢Crt ix f
Page 7 of 8
A TT
CAS #
Pollutant ji
c roll
s F
/
ontr led
sion actors
F)
Source
)
(lb/
540841
2'2'4
Trimethylpentane
126.2967
6.3148
Site Sample
Note: The controlled emissions factors for this point 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, HAPs
PSD or NANSR
Synthetic Minor Source of: VOC
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
COLORADO
Air Pollution Control Division
Page 8 of 8
Permit number:
Date issued:
Issued to:
Co
Air Po
Depar
CONSTRUCTION PERMIT
1 8WE0074
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General Description:
Issuance: 1
Whiting Oil and Gas Corporation
Razor 25 CPB
123/9F95
SESW SEC 25 T10N R58W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
SEP-10
004
Venting from crude oil process vessel during
gas -gathering downtime.
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 this
specific 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 of
the latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting-
notices. Failure to notify the Division of startup of the permitted source is a violation of Air
Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result
in the revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
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. A self certification form and guidance on how to self -certify
compliance as required by this permit may be obtained online at
www.colorado.gov/pacific/cdphe/air-permit-self-certification. (Regulation Number 3, Part B,
Section III.G.2.)
COLORADO
u PotlUtion Control Division
. rg( Paa ac kiktthbErmturnvrt
Page 1 of 8
3. This permit shall expire or which this permit was issued:
(i) does not commence c io '/ .difi or p ratio of this source within 18 months
after either, the date an • co •n p t 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. (Regulation Number 3,
Part B, Section 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.
(Regulation Number 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. (Regulation Number 3,
Part B, Section II.A.4.)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO.
VOC
CO
SEP-10
004
---
---
9.3
---
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, 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 actual emissions each month and keep a compliance record on site or at a local field
office with site responsibility for Division review.
7. The owner or operator shall track emissions from all insignificant activities at the facility on an
annual basis to demonstrate compliance with the facility potential emission limitations as seen
below. An inventory of each insignificant activity and associated emission calculations shall be
made available to the Division for inspection upon request. For the purposes of this condition,
insignificant activities shall be defined as any activity or equipment, which emits any amount
but does not require an Air Pollution Emission Notice (APEN) or is permit exempt.
Total potential emissions from the facility, including all permitted emissions and potential to
emit from all insignificant activities, shall be less than:
• 100 tons per year of VOC
8. The emission points in the table below shall be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
COLORADO
Air Pollution Control D vision
P u «
Page 2 of 8
A TT
Facility
Equipment ID
AIRS
Point
of v e
Pollutants
Controlled
SEP-10
004
Open Flare during VRU or gas -gathering
downtime
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
9. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
SEP-10
004
Natural Gas Venting
4.1 MMSCF
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder shall calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
10. The owner or operator shall continuously monitor and record the volumetric flow rate of
natural gas vented from the separator(s) using the flow meter. The owner or operator shall use
monthly throughput records to demonstrate compliance with the process limits contained in
this permit and to calculate emissions as described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
11. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
shall be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
12. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
13. The open flare covered by this permit has been approved as an alternative emissions control
device under Regulation Number 7, Section XVII.B.2.e. The open flare must have no visible
emissions during normal operations, as defined under Regulation Number 7, XVII.A.16, and be
designed so that an observer can, by means of visual observation from the outside of the open
flare, or by other convenient means approved by the Division, determine whether it is
operating properly. This open flare must be equipped with an operational auto -igniter
according to the following schedule:
• All combustion devices installed on or after May 1, 2014, must be equipped with an
operational auto -igniter upon installation of the combustion device;
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
14. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only).
On or after August 1, 2014, gas coming off a separator, produced during normal operation from
any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be
routed to a gas gathering line or controlled from the date of first production by air pollution
control equipment that achieves an average hydrocarbon control efficiency of 95%. If a
combustion device is us
hydrocarbons.
OPERATING a MAINTENANCE R • I `EM
ructi efficiency of at least 98% for
15. Upon startup of these points, the owner or operator shall follow the most recent operating and
maintenance (O&tM) 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
the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3,
Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
16. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of
visible emissions. "Visible Emissions" means observations of smoke for any period or periods of
duration greater than or equal to one minute in any fifteen minute period during normal
operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16)
Periodic Testing Requirements
17. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NO.) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or
activity; or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
19. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any
such time that this source becomes major solely by virtue of a relaxation in any permit
OLORADO
Pollution Control Division
Page 4 of 8
condition. Any relaxatio that nc -a the aen l to e t above the applicable Federal
program threshold will r hough construction had not yet
commenced on the sour eral program threshold until a
permit is granted. (Regulation Number 3, Parts C and D).
GENERAL TERMS AND CONDITIONS
20. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
21. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self -certification of all
points has been reviewed and approved by the Division, it will provide written documentation
of such final authorization. Details for obtaining final authorization to operate are located in
the Requirements to Self -Certify for Final Authorization section of this permit.
22. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
23. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
24. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a
permit are contested by the owner or operator, or the Division revokes a permit, the owner or
operator of a source may request a hearing before the AQCC for review of the Division's action.
25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Timothy Sharp
Permit Engineer
COLORADO
Air Pollution Control Division
Page 5 of 8
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Whiting Oil and Gas Corporation
OLORADO
Winn. Control Division
Page 6 of 8'
Notes to Permit Holder at the tim
1) The permit holder is requir •ay she 'ng ti-- 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.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written
notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's
analysis of the specific compounds emitted if the source(s) operate at the permitted limitations.
Facility
Equipment ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(tPY)
Controlled
Emissions
(tPY)
SEP-10
004
Benzene
71432
0.294
0.015
Toluene -
108883
0.166
0.008 - -_
Ethylbenzene
100414
0.018
0.001
Xylenes
Y
1330207
0.040
0.002
n -Hexane
110543
3.034
0.152
2,2,4-
Trimethylpentane
540841
0.326
0.016
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 0.125 tons
per year (tpy) are reportable and may result in annual emission fees based on the most recent Air Pollution
Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 004:
CAS #
Pollutant
Uncontrolled
Emission Factors
(lb/MMSCF)
Controlled
Emission Factors
(lb/MMSCF)
Source
N0x
0.068
AP -42
CO
0.310
AP -42
V0C
91087.5135
4554.3757
Site Sample
71432
Benzene
145.2182
7.2609
Site Sample
108883
Toluene
82.0598
4.1030
Site Sample
100414
Ethylbenzene
8.7592
0.4380
Site Sample
1330207
Xylene
19.5929
0.9796
Site Sample
110543
n -Hexane
1498.3978
74.9199
Site Sample
'COLORADO
.Air Pollutipel Control Division
Page 7 of 8
CAS #
Pollutant
c•,"" rol :"r
s F. • '_:
.„/ r )
ontr led
Sion actors
(lb/ F)
-
Source
_.-_,
540841
2,
Trimethylpentane
161.0078
8.0504
Site Site Sample
Note: The controlled emissions factors for this point 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, HAPs
PSD or NANSR
Synthetic Minor Source of: VOC
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix
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
COLORADO
Air PQUution Control Davisiori
rimmt
Page 8 of 8
Permit number:
Date issued:
Issued to:
Co
Air Po
Depart
CONSTRUCTION PERMIT
18WE0075
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General Description:
Issuance: 1
Whiting Oil and Gas Corporation
Razor 25 CPB
123/9F95
SESW SEC 25 T10N R58W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
SEP-11
005
Venting from produced water process vessel
during gas -gathering downtime.
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 this
specific 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 of
the latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting-
notices. Failure to notify the Division of startup of the permitted source is a violation of Air
Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result
in the revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
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. A self certification form and guidance on how to self -certify
compliance as required by this permit may be obtained online at
www.colorado.gov/pacific/cdphe/air-permit-self-certification. (Regulation Number 3, Part B,
Section III.G.2.)
[COLORADO
Air Pollution Control Division
Page 1 of 8
3. This permit shall expire i
(i) does not commence c
after either, the date -''•an
or which this permit was issued:
ratio of this source within 18 months
co • • n p t 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. (Regulation Number 3,
Part B, Section 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.
(Regulation Number 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. (Regulation Number 3,
Part B, Section II.A.4.)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NOX
VOC
CO
SEP-11
005
---
---
1.1
---
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, 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 actual emissions each month and keep a compliance record on site or at a local field
office with site responsibility for Division review.
7. The owner or operator shall track emissions from all insignificant activities at the facility on an
annual basis to demonstrate compliance with the facility potential emission limitations as seen
below. An inventory of each insignificant activity and associated emission calculations shall be
made available to the Division for inspection upon request. For the purposes of this condition,
insignificant activities shall be defined as any activity or equipment, which emits any amount
but does not require an Air Pollution Emission Notice (APEN) or is permit exempt.
Total potential emissions from the facility, including all permitted emissions and potential to
emit from all insignificant activities, shall be less than:
• 100 tons per year of V0C
8. The emission points in the table below shall be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
COLORADO
Control Division
ent Pts»Gr vg ,S.wor,',,nmc
Page 2 of 8
Facility
Equipment ID
AIRS
Point
of �'=v' a
Pollutants
Controlled
SEP-11
005
Open Flare during VRU or gas -gathering
downtime
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
9. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
SEP-11
005
Natural Gas Venting
1.5 MMSCF
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder shall calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
10. The owner or operator shall continuously monitor and record the volumetric flow rate of
natural gas vented from the separator(s) using the flow meter. The owner or operator shall use
monthly throughput records to demonstrate compliance with the process limits contained in
this permit and to calculate emissions as described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
11. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
shall be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
12. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
13. The open flare covered by this permit has been approved as an alternative emissions control
device under Regulation Number 7, Section XVII.B.2.e. The open flare must have no visible
emissions during normal operations, as defined under Regulation Number 7, XVII.A.16, and be
designed so that an observer can, by means of visual observation from the outside of the open
flare, or by other convenient means approved by the Division, determine whether it is
operating properly. This open flare must be equipped with an operational auto -igniter
according to the following schedule:
• All combustion devices installed on or after May 1, 2014, must be equipped with an
operational auto -igniter upon installation of the combustion device;
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
14. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only).
On or after August 1, 2014, gas coming off a separator, produced during normal operation from
any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be
routed to a gas gathering line or controlled from the date of first production by air pollution
control equipment that achieves an average hydrocarbon control efficiency of 95%. If a
₹COLORADO
Air Pollution CoatttO1Division
Page 3 of 8
combustion device is us
hydrocarbons.
OPERATING Et MAINTENANCE R • I ' EM
efficiency of at least 98% for
15. 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
the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3,
Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
16. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of
visible emissions. "Visible Emissions" means observations of smoke for any period or periods of
duration greater than or equal to one minute in any fifteen minute period during normal
operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16)
Periodic Testing Requirements
17. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or
activity; or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
19. Federal regulatory. program requirements (i.e. PSD, NANSR) shall apply to this source at any
such time that this source becomes major solely by virtue of a relaxation in any permit
COLORADO
Pollution Control Divit;3cat
Page 4 of 8
condition. Any relaxatio that nc -a th:.ten :l toe t above the applicable Federal
program threshold will r: uire f l ; vie a M: u ` e a hough construction had not yet
commenced on the sour e - - n. -. th eral program threshold until a
permit is granted. (Regulation Number 3, Parts C and D).
GENERAL TERMS AND CONDITIONS
20. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
21. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final' authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self -certification of all
points has been reviewed and approved by the Division, it will provide written documentation
of such final authorization. Details for obtaining final authorization to operate are located in
the Requirements to Self -Certify for Final Authorization section of this permit.
22. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
23. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
24. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a
permit are contested by the owner or operator, or the Division revokes a permit, the owner or
operator of a source may request a hearing before the AQCC for review of the Division's action.
25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Timothy Sharp
Permit Engineer
COLORADO
Air otion Control Division
Serr ot'Flax Re*th rAntormum
Page 5 of 8
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Whiting Oil and Gas Corporation
AFT
COLORADO
Au Pollution contr+st Division
k7¢a3L: r`.€ysxcrgnene
Page 6 of 8
Notes to Permit Holder at the tim
1) The permit holder is requir- ""'.ay --s a ng ti + 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.
(Regulation Number 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 shalt notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written
notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's
analysis of the specific compounds emitted if the source(s) operate at the permitted limitations.
Facility
Equipment ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(tPY)
Controlled
Emissions
(tPY)
SEP-11
005
Benzene
71432
0.145
0.007
__-Toluene -
108883
0.074 --
-
0.004 - -
Ethylbenzene
100414
0.005
0.000
Xylenes
Y
1330207
0.012
0.001
n -Hexane
110543
0.454
0.023
2,2,4-
Trimethylpentane
540841
0.030
0.001
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 0.125 tons
per year (tpy) are reportable and may result in annual emission fees based on the most recent Air Pollution
Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 005:
CAS #
Pollutant
Uncontrolled
Emission Factors
(lb/MMSCF)
Controlled
Emission Factors
(lb/MMSCF)
Source
N0x
0.068
AP -42
CO
0.310
AP -42
V0C
29501.8745
1475.0937
Site Sample
71432
Benzene
193.7062
9.6853
Site Sample
108883
Toluene
98.9269
4.9463
Site Sample
100414
Ethylbenzene
6.5286
0.3264
Site Sample
1330207
Xylene
15.8990
0.7949
Site Sample
110543
n -Hexane
604.9288
30.2464
Site Sample
COLORADO
Air Pollution Control Division
Page 7 of 8
CAS #
Pollutant1.00)
c roll
s F
ontr led
sion actors
(lb/ F)
Source
)
540841
2,2,4
Trimethylpentane
39.5554
1.9778
Site Sample
Note: The controlled emissions factors for this point 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, HAPs
PSD or NANSR
Synthetic Minor Source of: VOC
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix
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
COLORADO
Air Pothitior, Control Division
Fortrotrnem
Page 8 of 8
V l&'V' "v -- -.. - -V.•--..- --
" �' i G'(JJ
Reciprocating Internal Combustion
Engine APEN - Form APCD-201
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
AU sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for reciprocating internal combustion engines (RICE). If your engine is a diesel compression
ignition engine or your emission unit does not fall into the RICE category, there may be a more specific APEN for
your source (e.g. diesel compression ignition engine, mining operations, asphalt plant, crusher, screen, etc.). In
addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your
reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)
website at: www.colorado.gov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number:
i w 06
AIRS ID Number:
123 /c1F9/0°
/ 0 °
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name':
Site Name:
Site Location:
Whiting Oil and Gas Corporation
Razor 25 CPB
Site Location
SESW Sec 25, T10N, R58W County: Weld
Mailing Address:
(include Zip Code) 1700 Broadway, Suite 2300
Portable Source
Home Base:
Denver, CO 80290
NAICS or SIC Code: 1 31 1
Permit Contact:
Phone Number:
E -Mail Address2: coPHEcorrespondence@whiting.com
Jacob Parker
(303) 357-4078
1
Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
373702
® COLORADO
1 m xwn.,�.n �, wee
Permit Number:
AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
Q NEW permit OR newly -reported emission source (check one below)
O STATIONARY source ❑ PORTABLE source
❑ Request coverage under a Construction Permit
❑ Request coverage under General Permit GP023 (Natural Gas Only)
If General Permit coverage is requested, the General Permit registration fee of $1,500.00 must be submitted along
with the APEN Filing fee.
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
O Change fuel or equipment ❑ Change company name ❑ Add point to existing permit
O Change permit limit ❑ Transfer of ownership's O Other (describe below)
-OR-
❑ APEN submittal for update only (Blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
❑ APEN submittal for permit-exempt/grandfathered source
❑ Notification of Alternate Operating Scenario (AOS) permanent replacements
Additional Info Et Notes:
3 Only one engine may be reported per APEN for GP02 coverage. Coverage under GP02 is voluntary.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
5 This does not apply to General Permit GP02, as it does not contain a provision for AOS permanent replacements.
Section 3 - General Information
Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3, etc)? Yes
If yes, provide the Company Equipment Identification No.
ENG-01
General description of equipment and purpose: Gas Lift Compressor Engine
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is:
Will this equipment be operated in any NAAQS nonattainment area?
(http: / /www.colorado. gov/cdphe/attainment)
Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year
February 1, 2018
❑ Yes 0 No
Seasonal use percentage: Dec -Feb: 25 Mar -May: 25 June -Aug: 25 Sept -Nov: 25
COLORADO
Form APCD-2O1 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 2 I� =7r, ¢`„
Permit Number: AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit n and AIRS ID]
Section 4 - Engine Information
Engine
Function:
❑ Primary and/or Peaking O Emergency Back-up
O Pump ❑ Water Pump ❑ Other:
0 Compression
What is the maximum number of hours this engine will be used for emergency
back-up power? 0
Engine Make: Caterpillar Engine Model: G3516J
What is the maximum designed horsepower rating? 1380 hp What is the engine displacement? l/cyl
What is the maximum manufacturer's site -rating? 1311 hp kW
What is the engine Brake Specific Fuel Consumption at 100% Load? 8,071 BTU/hp-hr
Engine Features:
Cycle Type: O 2 -Stroke 0 4 -Stroke Combustion: 0 Lean Burn O Rich Burn
Ignition Source: 0 Spark ❑ Compression Aspiration: ❑ Natural 0 Turbocharged
Is this engine equipped with an Air/Fuel ratio controller (AFRC)? 0 Yes D No
hours/year
Serial Number': N6WO0226
If yes, what type of AFRC is in use? 0 O2 Sensor (mV) ONOx Sensor (ppm)
Is this engine equipped with a Low-NOx design? O Yes 0 No
Engine Dates:
What is the manufactured date of this engine? June 9, 2017
O Other:
What date was this engine ordered? April 19, 2017
What is the date this engine was first located to Colorado? August 24, 2017
What is the date this engine was first placed in service/operation? N/A
What is the date this engine commenced construction? April 19, 2017
What is the date this engine was last reconstructed or modified? N/A
Is this APEN reporting an AOS replacement engine? ❑ Yes ✓❑ No
if yes, provide the make, model, and serial number of the old engine below:
Engine Make:
Engine Model: Serial Number:
6 The serial number must be submitted if coverage under GP02 is requested.
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 3
A® co�oRaoo
Permit Number:
AIRS ID Number:
/ /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.803575, -103.8128
Operator'
Stack iQ No
Discharge ale ght
Above Ground level
(Feet)
Temp
( -
Flow state
(ACFM)
Velocity
fftl )
ENG-01
22.5
830
8,070
165.8
Indicate the direction of the Stack outlet: (check one)
0 Upward
O Horizontal
❑ Downward
O Other (describe):
Indicate the stack opening and size: (check one)
Circular
O Square/Rectangle
❑ Other (describe):
Interior stack diameter (inches):
8
O Upward with obstructing raincap
Interior stack diameter (inches): Interior stack depth (inches):
Section 6 - Fuel Data and Throughput Information
Fuel Use Rate @ 100% Load
(SCF/hour) - _
Actual Annual Fuel Use
(MMSCF/year) -
Requested Annual Permit Limit'
(MMSCF/year)
10,374
90.87
From what year is the actual annual amount?
Indicate the type of fuel used$:
0 Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf)
❑ Field Natural Gas Heating value: BTU/scf
❑ Propane (assumed fuel heating value of 2,300 BTU/scf)
❑ Landfill Gas Heating Value: BTU/scf
❑ Other (describe): Heating Value (give units):
Requested values will become permit limitations. Requested limit(s) should consider future process growth.
8 If fuel heating value is different than the listed assumed value, provide this information in the "Other" field.
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
Y COLORADO
4 LSM� MPanroen�>i Yu.r
14�J'll h [�....m�mew.
fi.
Permit Number:
AIRS ID Number:
TSP (PM)
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Emissions Inventory Information
Attach alt emission calculations and emission factor documentation to this APEN form. The APCD website has a
Natural Gas Fired Engines Calculator available to assist with emission calculations.
Is any emission control equipment or practice used to reduce emissions? O Yes ❑ No
If yes, describe the control equipment AND state the overall control efficiency (% reduction):
Primary Control Equipment Description
verall,Requested Control_;
Efficiency •
(% reduction in emissions).
PM10
PM2.5
SOX
NON.
VOC
SCO with AFRC
61.7%
CO
SCO with AFRO
17.7%
Other:
Use the following tables to report criteria and non -criteria pollutant emissions from source:
(Use the data reported in Section 6 to calculate these emissions.)
From what year is the following reported actual annual emissions data? Permit Limits
Pollutant
TSP (PM)
Uncontrolled
Basis
Criteria Pollutant Emissions inventory
Source
(AP -42,
Mfg. etc)
Actual Annual Emissions9
Uncontrolled
Emissions
(Tons/year)
Controlled
Emissions
(Tons/year)
Requested Annual Permit
Emission Limit(s)'
Uncontrolled''
Emissions
(Tons/year)
Controlled
Emissions
(Tonslyear)
PM10
PM2.5
0.00991
Ib/MMBtu
AP -42
De Minimis
De Minimis
0.00991
Ib/MMBtu
AP -42
De Minimis
De Minimis
0.00991
Ib/MMBtu
AP -42
De Minimis
De Minimis
SOX
NOX
VOC
0.000588
ib/MMBtu
AP -42
De Minimis
De Minimis
0.50
g/hp-hr
Requested
6.3
6.3
1.83
g/hp-hr
Manf Spec
23.2
8.9
CO
2.43
9/hp-hr
Manf Spec
30.8
25.3
Does the emissions source have any uncontrolled actual emissions of non -criteria
❑✓ Yes
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year?
❑ No
If yes, please use the following table to report the non -criteria pollutant (HAP) emissions from source:
Chemical Name
Formaldehyde
Acetaldehyde
Non -Criteria Reportable Pollutant. Emissions Inventory
Chemical
Abstract
Service (CAS)
Number
50000
Emission Factor
Uncontrolled
Basis
0.36
Units
g/hp-hr
Source
(AP -42, .`
Mfg. etc)
Merit Spec
Actual Annual Emissions9
Uncontrolled
Emissions
(Pounds/year)
9110
Controlled Emissions
(Pounds/year)
6330
75070
107028
0.00836
Ib/MMBtu
AP -42
775
775
Acrolein
Benzene
0.00514
lb/MMBtu
AP -42
476
476
71432
0.00044
Ib/MMBtu
AP -42
De Minimis
De Minimis
Other:
7 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
4 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
5 'AYCOLORADO
.artr€.n H.FNNfi
ii
N
Permit Number:
AIRS ID Number: /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct. If this is a registration for coverage under general permit GP02, I further certify that this source is and will
be operated in full compliance with each condition of general permit GP02.
January 16, 2018
Signaof Legally Authorized Person (not a vendor or consultant) Date
Jacob Parker
Environmental Professional
Name (please print)
Title
Check the appropriate box to request a copy of the:
❑Q Draft permit prior to issuance
Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $152.90 and the General Permit For more information or assistance call:
registration fee of $1,500, if applicable to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
Make check payable to: https://www.colorado.gov/cdphe/apcd
Colorado Department of Public Health and Environment
Telephone: (303) 692-3150
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
6 I AVCOLORADO
==,„
RECEIVED
JUN 12261.8
Reciprocating Internal Combustion
Engine APEN -- Form APCD-201
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for reciprocating 4nternal combustion engines (RICE). If your engine is a diesel compression
ignition engine or your emission unit does not fall into the RICE category, there may be a more specific APEN for
your source (e.g. diesel compression ign-ition engine, mining operations, asphalt plant, crusher, screen, etc.-). In
addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your
reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)
website at: www.colorado.aov/cdphe/aped.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: \ A.) 00'4- I AIRS ID Number: i a3
[Leave blank unless APCD has already assigned a permit r and AIRS ID]
Section 1 - Administrative Information
Company Name': Whiting Oil and Gas Corporation
Site Name: Razor 25 CPB
Site Location: SESW, Section 25, T1 ON, R58W
Mailing Address:
(Include Zip Code) 1700 Broadway, Suite 2300
Portable Source
Home Base:
Denver, CO 80290
Site Location
County: Weld
NAICS or SIC Code: 131 1
Permit Contact: Ashley Brinkerhoff
Phone Number: 303-390-1596
E -Mail Address2: CDPHEcorrespondence@whiting.com
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1 /2017
Ot'O H.A DO-
's11.21takittK
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section _2 - Requested Action
✓❑ NEW permit OR newly -reported emission source (check one below)
❑✓ STATIONARY source 0 PORTABLE source
❑✓ Request coverage under a Construction Permit
❑ Request coverage under General Permit GP023 (Natural Gas Only)
If General Permit coverage is requested, the General Permit registration fee of $1,500.00 must be submitted along
with the APEN Filing fee.
- OR -
O MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit
❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below)
- OR
• APEN submittal for update only (Blank APENs will not be accepted)
ADDITIONAL PERMIT ACTIONS -
❑ APEN submittal for permit-exempt/grandfathered source
❑ Notification of Alternate Operating Scenario (AOS) permanent replacements
Additional Info Et Notes:
3 Only one engine may be reported per APEN for GP02 coverage. Coverage under GP02 is voluntary.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
5 This does not apply to General Permit GP02, as it does not contain a provision for AOS permanent replacements.
Section 3 - General Information
Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3, etc)? Yes
If yes, provide the Company Equipment Identification No.
ENG-01
General description of equipment and purpose: Gas Lift Compressor Engine
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is: June 1, 2018
Will this equipment be operated in any NAAQS nonattainment area?
(http://www.colorado.qov/cdphe/attainment)
Normal Hours of Source Operation: 24
❑ Yes ✓❑ No
hours/day 7 days/week 52 weeks/year
Seasonal use percentage: Dec -Feb: 25 Mar -May: 25
June -Aug: 25
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
Sept -Nov: 25
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS !DJ
Section 4 - Engine Information
Engine
Function:
❑ Primary and/or Peaking
❑ Pump ❑ Water Pump
❑ Emergency Back-up
O Other:
0 Compression
What is the maximum number of hours this engine will be used for emergency
back-up power? 0
hours/year
Engine Make: Caterpillar Engine Model: G3516J Serial Number6: N6W00226
What is the maximum designed horsepower rating? 1,380 hp What is the engine displacement? 4.3 l/cyl
What is the maximum manufacturer's site -rating? 1,380 hp kW
What is the engine Brake Specific Fuel Consumption at 100% Load? 8,070 BTU/hp-hr
Engine Features:
Cycle Type: O 2 -Stroke 0 4 -Stroke Combustion: O Lean Burn ❑ Rich Burn
Ignition Source: ❑ Spark ❑ Compression Aspiration: O Natural O Turbocharged
Is this engine equipped with an Air/Fuel ratio controller (AFRC)? 0 Yes O No
If yes, what type of AFRC is in use? 0 O2 Sensor (mV) ❑NOX Sensor (ppm)
Is this engine equipped with a Low-NOX design? ❑ Yes 0 No
Engine Dates:
What is the manufactured date of this engine? June 9, 2017
O Other:
What date was this engine ordered? April 19, 2017
What is the date this engine was first located to Colorado? August 24, 2017
What is the date this engine was first placed in service/operation? June 1, 2018
What is the date this engine commenced construction? August 24, 2017
What is the date this engine was last reconstructed or modified? N/A
Is this APEN reporting an AOS replacement engine? O Yes 0 No
If yes, provide the make, model, and serial number of the old engine below:
Engine Make: Engine Model:
6 The serial number must be submitted if coverage under GP02 is requested.
Serial Number:
Form APCD-201 Reciprocating Internal Combustion Engine APEN - Revision 1/2017
aLO R.A-DO
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
40.80358/-103.8128
�.m
ENG-01
22.5
830
8,070
165.8
Indicate the direction of the Stack outlet: (check one)
❑✓ Upward
O Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑✓ Circular
❑ Square/Rectangle
❑ Other (describe):
Interior stack diameter (inches):
12
O Upward with obstructing raincap
Interior stack diameter (inches): Interior stack depth (-inches):
Section 6 - Fuel Data and Throughput Information
10,918
95.64
From what year is the actual annual amount?
Indicate the type of fuel used":
O Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf)
O Field Natural Gas Heating value: BTU/scf
O Propane (assumed fuel heating value of 2,300 BTU/scf)
❑ Landfill Gas Heating Value: BTU /scf
❑ Other (describe):
Heating Value (give units):
Requested values will become permit limitations. Requested limit(s) should considerfutureprocess growth.
8 If fuel heating value is different than the listed assumed value, provide this information in the "Other" field.
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
Permit Number:
AIRS iD Number:
Formaldehyde
TSP (PM)
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Emissions Inventory Information
Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a
Natural Gas Fired Engines Calculator available to assist with emission calculations.
Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No
If yes, describe the control equipment AND state the overall control efficiency (% reduction):
nested
tticiency
reduction emissions
PM10
PM2.5
SOX
NOX
VOC
CO
SCO with AFRC
21.5%
Other:
Use the following tables to report criteria and non -criteria pollutant emissions from source:
(Use the data reported in Section 6 to calculate these emissions.)
From what year is the following reported actual annual emissions data? Permitted
Criteria Pollutant Emissions Inventory
Uncontrolled . '':
Basis
Source -=
(AP -42,
Mfg. etc):.
ctual Annual Emissions:
nested Annua.
Emission -:Limit
Uncontrolled
Emissions
(Tons] year)
ontrolled
"Emissions!
(Tons/year)
Uncontrolled
Emissions"
(Tons/year):-"
ontrolled'.
missions
Tons/year)
TSP (PM)
0.00991
• Ib/MMBtu
AP -42
De Minimis
De Minimis
PM10
PM2.5
0.00991
Ib/MMBtu
AP -42
De Minimis
De Minimis
0.00991
lb/MMBtu
AP -42
De Minimis
De Minimis
SOX
NOX
VOC
0.000588
Ib/MMBtu
AP -42
De Minimis
De Minimis
1.0
g/hp-hr
NSPS JJJJ
13.3
13.3
0.70
g/hp-hr
NSPS JJJJ
9.3
9.3
CO
2.43
g/hp-hr
Manf Spec
32.4
26.7
Does the emissions source have any uncontrolled actual emissions of non -criteria
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year?
If yes, please use the following table to report the non -criteria pollutant (HAP) emissions from source:
E Yes ❑ No
on Criteria Reportable. Pollutant Emissions Inventory
emica
stract'
service (CAS)
Number
mission'',Fact+
to
nnual.Emissions''
0.43
g/hp-hr
Manf Spec
ncontrolled
Emissions
'Pounds/yenr)°
- 7,730
50000
75070
11,460
Acetaldehyde
0.00836
Ib/MMBtu
AP -42
816
816
Acrolein
107028
0.00514
Ib/MMBtu
AP -42
501
501
Benzene
71432
Other:
7 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
9 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 5
COLOR.ADO
.,m
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct. If this is a registration for coverage under general permit GP02, I further certify that this source is and will
be operated in full compliance with each condition of general permit GP02.
Signature of Legally A
Ashley Brinkerhoff
June 12, 2018
n (not a vendor or consultant) Date
Environmental Professional
Name (please print)
Title
Check the appropriate box to request a copy of the:
E Draft permit prior to issuance
❑✓ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $152.90 and the General Permit For more information or assistance call:
registration fee of $1,500, if applicable to:
Colorado Department of Public Health and Small Business Assistance Program
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South Or visit the APCD website at:
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
Telephone: (303) 692=3150
(303) 692-3175 or (303) 692-3148
https: / /www.colorado. goy / cd phe / apcd
Form APCD-201 Reciprocating Internal Combustion Engine APEN Revision 1/2017
COLORADO
sl:ns:cawh+ittmNni
CDPHE
Reciprocating Internal Combustion
Engine APEN - Form APCD-201
Air Pollutant -Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for reciprocating internal combustion engines (RICE). If your engine is a diesel compression
ignition engine or your emission unit does not fall into the RICE category, there may be a more specific APEN for
your source (e.g. diesel compression ignition engine, mining operations, asphalt plant, crusher, screen, etc.). In
addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your
reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)
website at: www.colorado.gov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number:
AIRS ID Number: (-z3 R F 57 a 0
[Leave blank unless APCD has already assigned a permit a` and AIRS ID]
Section 1 - Administrative Information
Company Name': Whiting Oil and Gas Corporation
Site Name: Razor 25 CPB
Site Location: SESW Sec 25, T1 ON, R58W
Mailing Address:
(Include Zip Code) 1700 Broadway, Suite 2300
Portable Source
Home Base:
Denver, CO 80290
Site Location
County: Weld
NAiCS or SIC Code: 1311
Permit Contact: Jacob Parker
Phone Number: (303) 357-4078
E -Mail Address2: CDPHEcorrespondence@whiting.com
Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
Form APCD-201 Reciprocating Internal Combustion Engine APEN - Revision 1/2017
373703
COLORADO
1 I . �` „
H.�A:4 fi L
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
❑ NEW permit OR newly -reported emission source (check one below)
O STATIONARY source O PORTABLE source
O Request coverage under a Construction Permit
❑ Request coverage under General Permit GP023 (Natural Gas Only)
If General Permit coverage is requested, the General Permit registration fee of $1,500.00 must be submitted along
with the APEN Filing fee.
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
O Change fuel or equipment O Change company name O Add point to existing permit
O Change permit limit O Transfer of ownership4 O Other (describe below)
-OR -
❑ APEN submittal for update only (Blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
• APEN submittal for permit-exempt/grandfathered source
❑ Notification of Alternate Operating Scenario (AOS) permanent replacements
Additional Info Et Notes:
3 Only one engine may be reported per APEN for GP02 coverage. Coverage under GP02 is voluntary.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
5 This does not apply to General Permit GP02, as it does not contain a provision for AOS permanent replacements.
Section 3 - General Information
Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3, etc)? Yes
If yes, provide the Company Equipment Identification No.
ENG-02
General description of equipment and purpose: Gas Lift Compressor Engine
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is: December 1, 2017
Will this equipment be operated in any NAAQS nonattainment area?
(http: //www.colorado.Rov/cdphe/attainment)
❑ Yes 0 No
Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year
Seasonal use percentage: Dec -Feb: 25 Mar -May: 25 June -Aug: 25 Sept -Nov: 25
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
2 i AYCOLORADO
i=7,17.=.,
Permit Number:
AIRS ID Number: /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Engine Information
Engine ❑ Primary and/or Peaking ❑ Emergency Back-up
Function: ❑ Pump ❑ Water Pump O Other:
What is the maximum number of hours this engine will be used for emergency
back-up power? 0
Compression
hours/year
Engine Make: Caterpillar Engine Model: G3516J Serial Number': N6W00216
What is the maximum designed horsepower rating? 1380 hp What is the engine displacement?
What is the maximum manufacturer's site -rating? 1311 hp kW
What is the engine Brake Specific Fuel Consumption at 100% Load? 8,071 BTU/hp-hr
l/cyl
Engine Features:
Cycle Type: O 2 -Stroke ❑✓ 4 -Stroke Combustion: ❑✓ Lean Burn O Rich Burn
Ignition Source: E Spark ❑ Compression Aspiration: ❑ Natural Turbocharged
Is this engine equipped with an Air/Fuel ratio controller (AFRC)? 0 Yes ❑ No
If yes, what type of AFRC is in use? p O2 Sensor (mV) ❑NOx Sensor (ppm) O Other:
Is this engine equipped with a Low-NOx design? ❑ Yes 0 No
Engine Dates:
What is the manufactured date of this engine? June 9, 2017
What date was this engine ordered? April 19, 2017
What is the date this engine was first located to Colorado? August 24, 2017
What is the date this engine was first placed in service/operation? December 1, 2017
What is the date this engine commenced construction? April 19, 2017
What is the date this engine was last reconstructed or modified? N/A
Is this APEN reporting an AOS replacement engine? ❑ Yes Q No
If yes, provide the make, model, and serial number of the old engine below:
Engine Make: Engine Model: Serial Number:
6 The serial number must be submitted if coverage under GP02 is requested.
Form APCD-201 - Reciprocating Internal Combustion Engine APEN Revision 1/2017
ifCOl0 R4D0
H�n1 M f
Permit Number:
AIRS ID Number: /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.803575, -103.8128
Operator
Stack ID No
Discharge Height
Above Ground`Levet
_
(Feet
Temp.
(•
Flow Rate
(ACFM)
Velocity
(ltl3ec
ENG-01
22.5
830
8,070
165.8
Indicate the direction of the Stack outlet: (check one)
❑✓ Upward
O Horizontal
❑ Downward
O Other (describe):
Indicate the stack opening and size: (check one)
Circular
❑ Square/Rectangle
❑ Other (describe):
Interior stack diameter (inches):
8
❑ Upward with obstructing raincap
Interior stack diameter (inches): Interior stack depth (inches):
Section 6 - Fuel Data and Throughput Information
Fuel Use Rate® 100% Load
(SCF/hour)
Actual Annual Fuel Use
(MM5CFl year)
Requested Annual Permit Limit
(MMSCF/year)
10,374
90.87
From what year is the actual annual amount?
Indicate the type of fuel useds:
0 Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf)
❑ Field Natural Gas Heating value: BTU/scf
❑ Propane (assumed fuel heating value of 2,300 BTU/scf)
❑ Landfill Gas Heating Value: BTU/scf
❑ Other (describe): Heating Value (give units):
7 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
8 If fuel heating value is different than the listed assumed value, provide this information in the "Other" field.
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
COLORADO
4 1 Ier
•r
Permit Number:
AIRS ID Number:
/ /
TSP (PM)
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Emissions Inventory Information
Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a
Natural Gas Fired Engines Calculator available to assist with emission calculations.
1s any emission control equipment or practice used to reduce emissions? El Yes El No
If yes, describe the control equipment AND state the overall control efficiency (% reduction):
Overall ;Requested Contro:
Efficiency
(% reduction in emissions)
PM10
PM2.5
SOX
NOx
VOC
SCO with AFRC
61.7%
CO
SCO with AFRC
17.7%
Other:
Use the following tables to report criteria and non -criteria pollutant emissions from source:
(Use the data reported in Section 6 to calculate these emissions.)
From what year is the following reported actual annual emissions data? Permit Limits
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor
Actual Annual Emissions v
Requested Annual Permit
7
Emission Limit(s)
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc).
Uncontrolled
Emissions ;
(Tons/year)
Controlled
Emissions
(Tons/year)
Uncontrolled
Emissions
(Tons/year)
Controlled
Emissions
(Tons/year)
TSP (PM)
0.00991
Ib/MMBtu
AP -42
De Minimis
De Minimis
PM10
0.00991
Ib/MMBtu
AP -42
De Minimis
De Minimis
PM2.5
0.00991
Ib/MMBtu
AP -42
De Minimis
De Minimis
SOX
0.000588
Ib/MMBtu
AP -42
De Minimis
De Minimis
NO
0.50
g/hp-hr
Requested
6.3
6.3
VOC
1.83
g/hhp-hr
Manf Spec
23.2
8.9
CO
2.43
g/hp-hr
Manf Spec
-
30.8
25.3
Does the emissions source have any uncontrolled actual emissions of non -criteria 0 Yes
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year?
If yes, please use the following table, to report the non -criteria pollutant (HAP) emissions from source:
❑ No
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service CAS
( )
Number
Emission Factor
- Actual Annual Emissions'
Uncontrolled
Basis
Units
Source `
(AP -42,
Mfg. etc)
Uncontrolled
Emissions
(Pounds/year)
Controlled. Emissions
(Pounds/year)
Formaldehyde
50000
0.36
g/hp-hr
Manf Spec
9110
6330
Acetaldehyde
75070
0.00836
Ib/MMBtu
AP -42
775
775
Acrolein
107028
0.00514
Ib/MMBtu
AP -42
476
476
Benzene
71432
0.00044
Ib/MMBtu
AP -42
De Minimis
De Minimis
Other:
7 Requested values wilt become permit limitations. Requested limit(s) should consider future process growth.
9 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
.74
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
COLORADO
.. r�
5 IAY K
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit r and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct. If this is a registration for coverage under general permit GP02, I further certify that this source is and will
be operated in full compliance with each condition of general permit GP02.
January 16, 2018
Signatu of Legally Authorized Person (not a vendor or consultant) Date
Jacob Parker
Environmental Professional
Name (please print)
Title
Check the appropriate box to request a copy of the:
J Draft permit prior to issuance
❑r Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $152.90 and the General Permit For more information or assistance call:
registration fee of $1,500, if applicable to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
Make check payable to: https://www.colorado.gov/cdphe/apcd
Colorado Department of Public Health and Environment
Telephone: (303) 692-3150
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 6'AY
COLORADO
Reciprocating Internal Combustion JUN l 2 2018
Engine APEN - Form APCD-201
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for reciprocating internal combustion engines (RICE). If your engine is a diesel compression
ignition engine or your emission unit does not fall into the RICE category, there may be a more specific APEN for
your source (e.g. diesel compression ignition engine, mining operations, asphalt plant, crusher, screen, etc.). In
addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your
reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)
website at: www.colorado.gov/cdphe/apcd. -
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 -days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: ($ WS o 041 AIRS ID Number: ( 2 3 / 5 /O O
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information.
Company Name': Whiting Oil and Gas Corporation
Site Name: Razor 25 CPB
Site Location: SESW, Section 25, T1 ON, R58W
Mailktg Address:
(Include Zip code) 1700 Broadway, Suite 2300
Portable Source
Home Base:
Denver, CO 80290
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact: Ashley Brinkerhoff
Phone Number: 303-390-1596
E -Mail Address2: CDPHECorrespondence@whiting.com
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
COLOR ADO
tleparmant
arannro-Ent, hoamuxu
Permit Number:
AIRS ID Number: /
[Leave blank unless APCD has already assigned a permit and AIRS ID]
Section 2 - Requested Action
❑ NEW permit OR newly -reported emission source (check one below)
❑✓ STATIONARY source ❑ PORTABLE source
❑✓ Request coverage under a Construction Permit
❑ Request coverage under General Permit GP023 (Natural Gas Only)
If General Permit coverage is requested, the General Permit registration fee of $1,500.00 must be submitted along
with the APEN Filing fee.
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit
O Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below)
-OR -
❑ APEN submittal for update only (Blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
El APEN submittal for permit-exempt/grandfathered source
❑ Notification of Alternate Operating Scenario (AOS) permanent replacements
Additional Info Et Notes:
3 Only one engine may be reported per APEN for GP02 coverage. Coverage under GP02 is voluntary.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
5 This does not apply to General Permit GP02, as it does not contain a provision for AOS permanent replacements.
Section 3 - General Information
Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3, etc)? Yes
If yes, provide the Company Equipment Identification No.
ENG-02
General description of equipment and purpose: Gas Lift Compressor Engine
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is:
Will this equipment be operated in any NAAQS nonattainment area?
(http://www.colorado.gov/cdphe/attainment)
December 1, 2017
❑ Yes 0 No
Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year
Seasonal use percentage: Dec -Feb: 25 Mar -May: 25 June -Aug: 25 Sept -Nov: 25
Form APCD-201 Reciprocating Internal Combustion Engine APEN - Revision 1/2017
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Engine Information
Engine
Function:
❑ Primary and/or Peaking
0 Pump ❑ Water Pump
❑ Emergency Back-up
❑ Other:
0 Compression
What is the maximum number of hours this engine will be used for emergency
back-up power? 0
hours/year
Engine Make: Caterpillar Engine Model: G3516J Serial Number6: N6W00216
What is the maximum designed horsepower rating? 1,380 hp What is the engine displacement? 4.3 l/cyl
What is the maximum manufacturer's site -rating? 1,380 hp kW
What is the engine Brake Specific Fuel Consumption at 100% Load? 8,070 BTU/hp-hr
Engine Features:
Cycle Type: ❑ 2 -Stroke ❑✓ 4 -Stroke Combustion: ❑✓ Lean Burn ❑ Rich Burn
Ignition Source: 0 Spark ❑ Compression Aspiration: 0 Natural 0 Turbocharged
Is this engine equipped with an Air/Fuel ratio controller (AFRC)? ✓❑ Yes 0 No
If yes, what type of AFRC is in use? ❑✓ 02 Sensor (mV) ONOx Sensor (ppm) ❑ Other:
Is this engine equipped with a Low-NOx design? ❑ Yes ❑✓ No
Engine Dates:
What is the manufactured date of this engine? June 1, 2017
What date was this engine ordered? April 19, 2017
What is the date this engine was first located to Colorado? August 24, 2017
What is the date this engine was first placed in service/operation? December 1, 2017
What is the date this engine commenced construction? August 24, 2017
What is the date this engine was last reconstructed or modified? N/A
Is this APEN reporting an AOS replacement engine? 0 Yes E No
If yes, provide the make, model, and serial number of the old engine below:
Engine Make: Engine Model: Serial Number:
6 The serial number must be submitted if coverage under GP02 is requested.
Form APCD-201 - Reciprocating internal Combustion Engine APEN Revision 1/2017 3
117 COLOEs0TC?
Sia.IN,tb E1w3N+CtMUT,!
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
40.80358/-103.8128
Q' ¢
b'
�
830
®
nn.
8,070
165.8
EN G-02
22.5
Indicate the direction of the Stack outlet: (check one)
❑✓ Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
-0 Circular
❑ Square/Rectangle
❑ Other (describe):
Interior stack diameter (inches):
Interior stack diameter (inches):
12
0 Upward with obstructing raincap
Interior stack depth (inches):
Section 6 - Fuel Data and Throughput Information
Yd
riA'h
Ube Rat
o��i'
00% Load>
iii�
's.. ,..
&fj
>..,,,
E ;.
Actual Annual Fu'
ik-,,. >... ,..fi4%� $5i - :��
se
.�rrr .
..?
,d' C Y zkf' 3.E
quest d A real mil Lz ttt
e
%,� ... roP'�/; s.
10,918
95.64
From what year is the actual annual amount?
Indicate the type of fuel used:
❑✓ Pipeline Natural Gas
❑ Field Natural Gas
❑ Propane
O Landfill Gas
Other (describe):
(assumed fuel heating value of 1,020 BTU/scf)
Heating value: BTU/scf
(assumed fuel heating value of 2,300 BTU/scf)
Heating Value: BTU/scf
Heating Value (give units):
7 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
s If fuel heating value is different than the listed assumed value, provide this information in the "Other" field.
Form APCD-201 Reciprocating Internal Combustion Engine APEN - Revision 1/2017
co�:a�.kao
Psmtic
v��
Permit Number:
AIRS ID Number:
/ /
Formaldehyde
50000
11,460
TSP (PM)
TSP (PM)
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Emissions Inventory Information
Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a
Natural Gas Fired Engines Calculator available to assist with emission calculations.
Is any emission control equipment or practice used to reduce emissions? O Yes
❑ No
If yes, describe the control equipment AND state the overall control efficiency (% reduction):
Iverall Re uestedrControl
icien
reduction in "emissior.
PM t0
PM2.5
5Ox
NOX
VOC
CO
SCO with AFRO
21.5%
Other:
Use the following tables to report criteria and non -criteria pollutant emissions from source:
(Use the data reported in Section 6 to calculate these emissions.)
From what year is the following reported actual annual emissions data?
Permitted
riteria Pollutant;Emissions Inventor
ctual Annual
Uncontrolled
Emission
(Tonslyear)
missteps'
ontrolled
:missions;
Tonslyear).:.:
De Minimis
De Minimis
0.00991
lb/MMBtu
AP -42
PMt0
PM2 5
0.00991
Ib/MMBtu
AP -42
De Minimis
De Minimis
0.00991
Ib/MMBtu
AP -42
De Minimis
De Minimis
SOX
NOx
VOC
0.000588
Ib/MMBtu
AP -42
De Minimis
De Minimis
1.0
g/hp-hr
NSPS JJJJ
13.3
13.3
0.70
g/hp-hr
NSPS JJJJ
9.3
9.3
CO
2.43
g/hp-hr
Manf Spec
32.4
26.7
Does the emissions source have any uncontrolled actual emissions of non -criteria Yes
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year?
If yes, please use the following table to report the non -criteria pollutant (HAP) emissions from source:
❑ No
n Cnteria Reportable. Pollutani Emissions , nventor
mission Facto
ua
raual
mission
ontrolled Emission
(Pounds!year) `;
0.43
g/hp-hr
Manf Spec
7,730
Acetaldehyde
75070
0.00836
Ib/MMBtu
AP -42
816
816
Acrolein
107028
0.00514
Ib/MMBtu
AP -42
501
501
Benzene
71432
Other:
7 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
9 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
COR.AOO
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
Permit Number:
AIRS ID Number: / f
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct. If this is a registration for coverage under general permit GP02, I further certify that this source is and will
be operated jp.,full compliance with each condition of general permit GP02.
Signature of Legally Au
Ashley Brinkerhoff
June 12, 2018
(not a vendor or consultant) Date
Environmental Professional
Name (please print)
Title
Check the appropriate box to request a copy of the:
E✓ Draft permit prior to issuance
❑✓ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, Ii.C. for revised APEN requirements.
Send this form along with $152.90 and the General Permit
registration fee of $1,500, if applicable to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
Telephone: (303) 692-3150
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https: //www.colorado.gov/cdphe/apcd
DO
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
(o'
Natural Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid
separators, welt head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does
not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN
(Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms can be found on the Air Pollution Control Division (APCD) website at:
www.colorado.Rov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number:
AIRS ID Number: I 12) 003
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Company equipment Identification: • SEP-62, SEP-64, SEP-65, SEP-68, SEP-75 TO SEP-76, SEP-79, & FLR-02
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Namel:
Site Name:
Site Location:
Whiting Oil and Gas Corporation
Razor 25 CPB
Site Location
SESW Sec 25, T10N, R58W County: Weld
Mailing Address:
(Include Zip Code) 1700 Broadway, Suite 2300
Denver, CO 80290
E Mail Address2: CDPHEcorrespondence@whiting.com
NAICS or SIC Code: 1311
Permit Contact: Jacob Parker
Phone Number: (303) 357-4078
'Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will
appear on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
Form APCD-2 i 1 iJrtural Gas Venting ADEN - Rev 03/2017 373704
1 [�Y<OIORSDD
i�.9LS
Permit Number:
AIRS II) Number: /
[Leave blank uniess APCD has uheady assigned a permit 4 cud -AIRS [D].
Section 2- Requested Action
❑ NEW permit OR newly -reported emission source
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
• Change fuel or equipment ❑ Change company name 0 Add point to existing permit
❑ Change permit limit 0 Transfer of ownership' 0 Other (describe below)
-OR-
❑ APEN submittal for update only (Please note blank APENs will not be accepted) •
- ADDITIONAL PERMIT ACTIONS -
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info £t Notes:
int
3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
•
Section 3 General Information
General description of equipment and purpose:
(4) 3 -phase separators
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up dateis:
(4) 2 -phase separators and
October / 18 / 2018
❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day
Will this equipment be operated in any NAAQS nonattainment
area
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions
Form APCD-211 -Natural Gas Venting ADEN Rev 03/2017
days/week weeks/year
❑ Yes
❑ Yes
0 No
0 No
fy�.cOLDRdDD
2 INrn4R t-r.
Permit Number: AIRS ID Number: / /
[Leave la .es ';PCD ..
c iscied -pe mii and i-:IR.'.i ID]
Section 4.- Process Equipment Information
Q Gas/Liquid Separator
O Well Head Casing
O Pneumatic Pump
Make: Model:
❑ Compressor Rod Packing
Make: Model:
❑ Blowdown Events
# of Events/year:
O Other
Description:
Serial #: Capacity: Gal/min
# of Pistons: Leak Rate: Scf/hr/pist
Volume per event: MMscf/event
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural
Gas Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? Yes
Natural Gas Venting
Process Parameters4:
Liquid Throughput
Process Parameters4:
❑ No
Maximum Vent
Rate:
187 500
SCF/hr
Vent Gas
Heating Value:
1 550
BTU/SCF
Requested:
32.9
MMSCF/year
Actual:
MMSCF/year
-OR-
Requested:
Bbl/yr
Actual:
Bbl/yr
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Process Properties:
Molecular Weight:
VOC (mole %)
23.167
VOC (Weight %)
45.80
Benzene (mole %)
0.041
Benzene (Weight %)
0.12
Toluene (mole %)
0.040
Toluene (Weight %)
0.13
Ethylbenzene (mole %)
0.007
Ethylbenzene (Weight %)
0.03
Xytene (mole %)
0.016
Xylene (Weight %)
0.06
n -Hexane (mole %)
0.315
n -Hexane (Weight %)
0.98
2,2,4-Trimethylpentane
(mole %)
2,2,4-Trimethylpentane
0.042 (Weight %)
0.17
Additional Required Information:
❑� Attach a representative gas analysis (including BTEX & n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX R n -Hexane, temperature, and
pressure)
0
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
3I
®Y
COLORADO
Department aro-K
Halt, b Lemisonrtw o
Permit Number:
AIRS ID Number: /
[Leave ,
ID.
_�ta .., �_m e>� APCD has as��ned ,_ pern,;rt an
d ..� �
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.803575, -103.8128
Operator
'Mack iti o
Discharge Height
Above Ground Level
(feet)
Tertip
( F)
Flow Rate
(ACFi1!)
Velocity
ftlsec)
FLR-02
40
>2000
3,125
149.2
Indicate the direction of the stack outlet: (check one)
0 Upward
❑ Horizontal
❑ Downward
O Other (describe):
Indicate the stack opening and size: (check one)
0 Circular
D Other (describe):
Interior stack diameter (inches):
❑ Upward with obstructing raincap
8
Section 6 - Control Device Information
❑ VRU:
Pollutants Controlled:
Size:
Make/Model:
Requested Control Efficiency
VRU Downtime or Bypassed
❑ Combustion
Device:
Pollutants Controlled:
Rating:
Type:
VOC and HAPs
598
Open Flare
Requested Control Efficiency:
MMBtu/hr
Make/Model: Flare Industries SFVP-0824
95
Manufacturer Guaranteed Control Efficiency 98
Minimum Temperature:
N/A
Waste Gas Heat Content 1,550 Btu/scf
Constant Pilot Light: O Yes O No Pilot burner Rating
0.16 MMBtu/hr
Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0/0
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
4I
®V
COLORADO
Mpat<
Department
ne u..aeem.e,
Permit Number:
AIRS II) Number:
[Leave blank sunless APCD has al ead/ as. e ned a hermit r and AIRS ID]
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? j1 Yes O No
If yes,
p
Pollutant
PM
lease describe the control equipment AND state the overall control efficiency (% reduction):
Overall Requested Control
Efficiency
(% reduction in emissions)
Control Equipment Description
SOX
NO„
VOC
Gas is sent to gas gathering pipeline with open flare as backup
95%
CO
HAPs
Gas is sent to gas gathering pipeline with open flare as backup
95%
Other:
Permit Limits
From what year is the following reported actual annual emissions data?
Use the following table to report the criteria pollutant emissions from source:
Pollutant _
Uncontrolled
Emission
Factor `
Emission
Factor
Units
Emission
Factor
Source
(AP -42,
Mfg. etc)
Actual Annual Emissions
Requested. Annual Permit
s
Emiss�on'Ltmit(s)
Uncontrolled
(Tons/year)
Controlled6
(Tons/year)
Uncontrolled
(Tons/year)
Controlled
(Tons/year)
PM
0.0075
lb/MMBtu
AP -42
De minimis
SOX
0.0006
lb/MMBtu
Gas Analysis
De minimis
NO„
0.068
lb/MMBtu
AP -42
De minimis
VOC
33229.43
lb/MMscf
Gas Analysis
545.79
27.29
CO
0.310
lb/MMBtu
AP -42
7.40
Benzene
84.82
Ib/MMscf
Gas Analysis
1.39
0.07
Toluene
96.66
)lb/MMscf
Gas Analysis
1.59
0.08
Ethylbenzene
18.47
lb/MMscf
Gas Analysis
0.30
0.02
Xylenes
45,89
lb/MMscf
Gas Analysis
0.75
0.04
n -Hexane
714.38
lb/MMscf
Gas Analysis
11.73
0.59
th
Trimehylpeylpe ntane
126.15
lb/MMscf
Gas Analysis
2.07
0.10
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-211 -Natural Gas Venting APEN Rev 03/2017
I � - COLORADO
5 �F rim m
Neal. Y
Permit Number:
AIRS ID Number: /
[Leave blarlk _sties; ,APCD has ct. s-eLy ,..1suer.1 a permit AIRS ID]
.r .
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct.
January 16, 2018
Signature,9ttegally Authorized Person (not a vendor or consultant) Date
Jacob Parker Environmental Professional
Name (please print) Title
Check the appropriate box to request a copy of the:
El Draft permit prior to issuance
�✓ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
Send this form along with $152.90 to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and
Environment
Telephone: (303) 692-3150
Form APCD-211 -Natural Gas Venting APEN -- Rev 03/2017
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https://www.colorado.gov/cdphe/apcd
A® COLORADO
Natural G.as Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
‘114I220iq
This APEN is to be used for Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid
separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does
not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN
(Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms can be found on the Air Pollution Control Division (APCD) website at:
www.colorado.Rov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number:
I gwe 0073 AIRS ID Number: I z 3 ' l JF'5• 16,03
[Leave blank unless APCD has already assigned a permit f and AIRS ID]
Company equipment Identification: SEP-01 through SEP-08
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Namel: Whiting Oil and Gas Corporation
Site Name: Razor 25 CPB
Site Location: SESW Section 25, T10N, R58W
Mailing Address:
(Include Zip Code) 1700 Broadway, Suite 2300
Denver, CO 80290
E -Mail Address2: CDPHECorrespondence@whiting.com
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact: Ashley Brinkerhoff
Phone Number: 303-390-1596
1Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will
appear on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
Form APCD-211 - Natural Gas Venting APEN - Rev 03/2017
DatpuravAnkof 11/4.1*.
coLo Aaa.
b1)..:
Permit Number:
AIRS ID Number: /
[Leave blank unless APCD has already assigned a permit # and AIRS ID)
Section 2- Requested Action
0 NEW permit OR newly -reported emission source
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
O Change fuel or equipment ❑ Change company name ❑ Add point to existing permit
O Change permit limit 0 Transfer of ownership' ❑ Other (describe below)
-OR-
❑ APEN submittal for update only (Please note blank APENs will not be accepted)
ADDITIONAL PERMIT ACTIONS -
Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Ft Notes:
3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
and (4) 3 -phase heater treaters
Flaring associated gas from (4) 2 -phase separators
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
10 / 18 / 2017
Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day
Witt this equipment be operated in any NAAQS nonattainment
area
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
days /week weeks/year
O Yes
❑ Yes
0 No
❑✓ No
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit r and AIRS ID]
Section 4 - Process Equipment Information
El Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model:
❑ Compressor Rod Packing
Make: Model:
❑ B lowdown Events
# of Events/year:
❑ Other
Description:
Serial #: Capacity: Gal/min
# of Pistons: Leak Rate: Scf/hr/pist
Volume per event: MMscf/event
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural
Gas Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? ❑ Yes
Natural Gas Venting
Process Parameters4:
Liquid Throughput
Process Parameters4:
❑ No
Maximum Vent
Rate:
166 667
SCF/hr
Vent Gas
Heating Value:
1 550
,
BTU/SCF
Requested:
73.0
MMSCF/year
Actual:
MMSCF/year
-OR-
Requested:
Bbl/yr
Actual:
Bbl/yr
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Process Properties:
Molecular Weight:
VOC (mote %)
23.17
VOC (Weight %)
45.80
Benzene (mole %)
0.041
Benzene (Weight %)
0.117
Toluene (mole %)
0.040
Toluene (Weight %)
0.133
Ethylbenzene (mole %)
0.007
Ethylbenzene (Weight %)
0.025
Xylene (mole %)
0.016
Xylene (Weight %)
0.063
n -Hexane (mole %)
0.315
n -Hexane (Weight %)
0.985
2,2,4-Trimethylpentane
(mole %)
0.042
2,2,4-Trimethylpentane
(Weight %)
0.174
Additional Required Information:
❑✓ Attach a representative gas analysis (including BTEX it n -Hexane, temperature, and pressure).
Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and
pressure)
Form APCD-211 -Natural Gas Venting APEN Rev O3/2017
Permit Number:
AIRS ID Number:
/ /
[Leave blank unless APCD has already assigned a permit r and AIRS ID]
Section 5 - Stack Information
Geographkal Coordinates
a₹ tzidellongliude',or U , .``
40.80358/-103.8128
,"YP
FLR-01
. 40
>2,000
2,778
132.6
Indicate the direction of the stack outlet: (check one)
0 Upward
O Horizontal
❑ Downward
O Other (describe):
Indicate the stack opening and size: (check one)
❑✓ Circular Interior stack diameter (inches):
❑ Other (describe):
O Upward with obstructing raincap
8
Section 6 - Control Device Information
❑✓ VRU:
Pollutants Controlled:
Size:
Make /Model:
Requested Control Efficiency
VRU Downtime or Bypassed
❑ Combustion
Device:
Pollutants Controlled: VOC and HAPs
Rating:
598
MMBtu/hr
h r
Type: Open Flare Make/Model: Flare Industries/SFVP-0824
Requested Control Efficiency:
95 %
Manufacturer Guaranteed Control Efficiency 98 %
Minimum Temperature:
N/A
Waste Gas Heat Content 1,580 Btu/scf
Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating
0.44 MMBtu/hr
Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0/0
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
41
COLORADO
DCpirtrn. II tat E
Permit Number:
AIRS ID Number:
PM
[Leave blank unless APCD has already assigned a permit Y and AIRS ID]
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No
If yes, please describe the control equipment AND state the overall control efficiency (% reduction):
PM
SO,
NO,
VOC
Gas is sent to gas gathering pipeline w/open flare as backup
95%
' CO
HAPs
Gas is sent to gas gathering pipeline w/open flare as backup
95%
Other:
From what year is the following reported actual annual emissions data?
Use the following table to report the criteria pollutant emissions from source:'
(Use the data reported in Sections 4 and 6 to calculate these emissions.)
Uncontrolled
Emission
actor
Emission
Factor;: .
Units:
Emission
Factor.
Source
(AP -42,
Mfg. etc).
Uncontrolled
(Tons/year) ..
Controlled6
(Tons/year)
Control led ;;
,a7.; ns/year)
Uncontrolled
(Tons/year)
0.0075
Ib/MMBtu
AP -42
De Minimis
SO,
NO),
0.068
lb/MMBtu
Btu
AP -42
3.98
VOC
33229.43
lb/MMscf
Gas Analysis
1,212.88
60.64
CO
0.31
I b/M M Btu
AP -42
16.56
Benzene
84.82
lb/MMscf
Gas Analysis
3.10
0.15
Toluene
96.66
lb/MMscf
Gas Analysis
3.53
0.18
Ethylbenzene
18.47
lb/MMscf
Gas Analysis
0.67
0.03
Xylenes
45.89
lb/MMscf
Gas Analysis
1.67
0.08
n -Hexane
714.38
lb/MMscf
Gas Analysis
26.07
1.30
2,2,4-
Trimethylpentane
126.15
lb/MMscf
Gas Analysis
4.60
0.23
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct...
Signature of Legally A
Ashley Brinkerhoff
June 12, 2018
n (not a vendor or consultant) Date
Environmental Professional
Name (please print)
Title
Check the appropriate box to request a copy of the:
El Draft permit prior to issuance
✓� Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
Send this form along with $152.90 to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable, to:
Colorado Department of Public Health and
Environment
Telephone: (303) 692-3150
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https: / /www.colorado.gov/cdphe /apcd
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017 6 I
ORADO
motrumuc
Natural Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid
separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does
not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN
(Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms can be found on the Air Pollution Control Division (APCD) website at:
www.colorado.gov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 1 D (JOE() Ch? -1 -.\AIRS ID Number: (ri.__(10 /4C51 00`
[Leave blank unless APCD has already assigned a permit = and AIRS ID]
Company equipment Identification: SEP-21, FLR-02
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Name: Whiting Oil and Gas Corporation
Site Name: Razor 25 CPB
Site Location: SESW Sec 25, T10N, R58W
Mailing Address:
(include Zip Code)
1700 Broadway, Suite 2300
Denver, CO 80290
E -Mail Address: CDPHECOrreSpOndenCe@Whiting.COM
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact: Jacob Parker
Phone Number: (303) 357-4078
1Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will
appear on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
Form APCD-21 1 - Natural Gas Venting APEN - Rev 03/7017
373705
COLORADO
1 ANT
��: a rnIr.aRm..,
Permit Number:
AIRS ID Number:
[Leave iD[ank. 4PCP l„ dt eau,
p ern'Lt and AIRS VLSI
Section 2- Requested Action
E] NEW permit OR newly -reported emission source
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit
❑ Change permit limit ❑ Transfer of ownership' 0 Other (describe below)
- OR -
APEN submittal for update only (Please note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes: Crude Oil Vessel
3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
Flaring associated gas from crude oil
vessel during VRU and gas gathering downtime.
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
/ /
October / 18 / 2018
0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day
Will this equipment be operated in any NAAQS nonattainment
area
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions
days/week weeks/year •
O Yes ❑r No
O Yes ❑✓ No
Form APED-211-Naturat Gas Venting APEN - Rev 03/2017
2
AY
COLORADO
Lemv nm n1
Permit Number: AIRS ID Number: / /
ht,..ti-,Les/PC'
per,.,. - AI
PS
Section 4 - Process Equipment Information
❑ Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model:
❑ Compressor Rod Packing
Make: Model:
❑ Blowdown Events
# of Events/year:
Other
Description: Crude Oil Pressurized Vessel
Serial #: Capacity: Gal/min
# of Pistons: Leak Rate: Scf/hr/pist
Volume per event: MMscf/event
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural
Gas Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? I] Yes
Natural Gas Venting
Process Parameters4:
Liquid Throughput
Process Parameters4:
❑ No
Maximum Vent
Rate:
8 ,� 5
SCF/hr
Vent Gas
Heating Value:
2 350
BTU/SCF
Requested:
2.36
MMSCF/year
Actual:
MMSCF/year
-OR-
Requested:
Bbl/yr
Actual:
Bbl/yr
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Process Properties:
Molecular Weight:
VOC (mole %)
64.994
VOC (Weight %)
79.03
Benzene (mole %)
0.07
Benzene (Weight %)
0.1260
Toluene (mole %)
0.034
Toluene (Weight %)
0.0712
Ethylbenzene (mole %)
0.003
Ethylbenzene (Weight %)
0.0076
Xylene (mole %)
0.007
Xylene (Weight %)
0.0170
n -Hexane (mole %)
0.659
n -Hexane (Weight %)
1.3001
2,2,4-Trimethylpentane
(mole %)
0.053
2,2,4-Trimethylpentane
4-Trimethylpentane
(Weight %)
0.1397
Additional Required Information:
CI Attach a representative gas analysis (including BTEX ft n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and
pressure)
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
3j
Air
COLORADO
Permit Number:
!?tauk unless APCD
AIRS ID Number:
/ /
AIRS Imo]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.803575, -103.8128
Operator;
StaCk1D No
Discharge Height;
Above Ground Level
(Feet)
Temp
CF)
;Flow Rate
(ACFM)
Velocity':
(ftlsec)
FLR-02
40
>2000
3,125
149.2
Indicate the direction of the stack outlet: (check one)
❑r Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
0 Circular Interior stack diameter (inches):
D Other (describe):
❑ Upward with obstructing raincap
8
Section 6 - Control Device Information
❑ VRU:
Pollutants Controlled:
Size:
Make/Model:
Requested Control Efficiency %
VRU Downtime or Bypassed
%
Combustion
Device:
Pollutants Controlled: VOC and HAPs
Rating: 598 MMBtu/hr
Make/Model: Flare Industries SFVP-0824
95 %
Type: Open Flare
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency
Minimum Temperature:
N/A
98 %
Waste Gas Heat Content 1 ,550 Btu/scf
Constant Pilot Light: O Yes ❑ No Pilot burner Rating 0.16 MMBtu/hr
Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0/0
Form APCD-21'I -Natural Gas Venting APEN - Rev 03/2017
A® COLORADO
4 .o ,nK
PM
Permit Number:
AIRS ID Number: /
i)t f k ie PCB- has i -c_y 4 ? permit_ AIRS ID]
Section -7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No
If yes, please describe the control equipment AND state the overall control efficiency (% reduction):
Overall Requested Control
Efficiency
(% reduction in emissions)
Control Equipment Description
SOX
NOx
VOC
Gas is sent to gas gathering pipeline with open flare as backup
95%
CO
HAPs
Gas is sent to gas gathering pipeline with open flare as backup
95%
Other:
Permit Limits
From what year is the following reported actual annual emissions data?
Use the following table to report the criteria pollutant emissions from source:
Pollutant
Uncontrolled
Uncontrolled
Emission
Factor
Emission
Emission
Factor
Units
Emission
Factor
Factor
Source
(AP -42,
Mfg. etc)
Actual Annual Emissions
Actual Annual Emissions
Requested Annual Permit
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
(Tons/year)
Controlled6
(Tons/year)
Uncontrolled
(Tons/year)
Controlled
(Tons/year)
PM
0.0075
lb/MMBtu
AP -42
De minimis
SOX
NO),
0.068
Ib/MMBtu
AP -42
De minimis
VOC
1.685
lb/bbl
Gas Analysis
1537.58
5.38
CO
0.310
Ib/MMBtu
AP -42
De minimis
Benzene
0.0027
lb/bbl
Gas Analysis
2.45
0.01
Toluene
0.0015
lb/bbl
Gas Analysis
1.39
0.005
Ethylbenzene
0.0002
lb/bbl
Gas Analysis
De minimis
De minimis
Xylenes
0.0004
Ib/bbl
Gas Analysis
De minimis
De minimis
n -Hexane
0.0277
lb/bbl
Gas Analysis
25.26
0.088
2'2'4-
Trimethylpentane
0.0030
lb/bbl
Gas Analysis
2.71
0.010
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-211 -Natural Gas Venting APEN Rev 03/2017
5 I AV
COLORADO
c<wnn.ntot
Nn.LTb Envnanmvn,
Permit Number:
AIRS ID Number: / /
.`r'_:) Has 7..,11: , 7 ;.I', ID1
• E:
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct.
January 16, 2018
Signat of Legally Authorized Person (not a vendor or consultant) Date
Jacob Parker
Environmental Professional
Name (please print)
Title
Check the appropriate box to request a copy of the:
0 Draft permit prior to issuance
p Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
Send this form along with $152.90 to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and
Environment
Telephone: (303) 692-3150
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https: //www.colorado.govicdphe/apcd
A® COLORADO
6 I Ocf I�m[n!c4Fvt�lr.
L \/7-.T,
JUN 1 2 201R
Natural Gas Venting APEN — Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
AR sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You niay be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal. -
This APEN is to be used for Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid
separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does
not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN
(Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms can be found on the Air Pollution Control Division (APCD) website at:
www.colorado.aov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, iI.C. for revised APEN requirements.
Permit Number:
AIRS ID Number: f Fts / O f
[Leave blank unless APCD has already assigned.a permit # and AIRS ID]
Company equipment Identification: SEP-10, FLR-01
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information;
Company Name': Whiting Oil and Gas Corporation
Site Name: Razor 25 CPB
Site Location: SESW, Section 25, T1 ON, R58W
Mailing Address:
(delude Zip Code) 1700 Broadway, Suite 2300
Denver, 20 80290
E -Mail Address2: CDPHECorrespondence@whiting.com
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact: Ashley Brinkerhoff
Phone Number: 303-390-1596
'Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will
appear on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
..................
A
Form APCD-205 - Natural Gas Venting APEN - Rev 03/2017
Permit Number: AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit and AIRS ID]
Section 2- Requested Action
O NEW permit OR newly -reported emission source
- OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name
❑ Change permit limit ❑ Transfer ofownership3
OR
• APEN submittal for update only (Please note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
• Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info a Notes: Crude Oil Process Vessel
❑ Add point to existing permit
❑ Other (describe below)
3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
VRU or gas gathering downtime.
Flaring gas from crude oil vessel during
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
/ /
10 / 18 / 2017
❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day
Will this equipment be operated in any NAAQS nonattainment
area
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions
days /week weeks /year
❑ Yes 0 No
❑ Yes ❑✓ No
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
21
.COLORADO
•
Permit Number:
AIRS ID Number: /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Process Equipment Information
❑ Gas/Liquid Separator
• Well Head Casing
❑ Pneumatic Pump
Make: Model:
❑ Compressor Rod Packing
_ Make:
Serial #:
Capacity: Gal/min
Model: # of Pistons: Leak Rate: Scf/hr/pist
❑ Blowdown Events
# of Events/year: Volume per event:
❑� Other
Description: Crude Oil Pressurized Vessel
MMscf/event
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural
Gas Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? ❑✓ Yes
Natural Gas Venting
Process Parameters':
Liquid Throughput
Process Parameters4:
❑ No
Maximum Vent
Rate:
3 854
,
SCF/hr
Vent Gas
Heating Value:
2 350
,
BTU/SCF
Requested:
4.05
MMSCF/year
Actual:
MMSCF/year
-OR-
Requested:
Bbl/yr
Actual:
Bbl/yr
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Process Properties:
Molecular Weight:
VOC (mole %)
64.994
VOC (Weight %)
79.03
Benzene (mole %)
0.07
Benzene (Weight %)
0.126
Toluene (mole %)
0.034
Toluene (Weight %)
0.071
Ethylbenzene (mole %)
0.003
Ethylbenzene (Weight %)
0.076
Xylene (mole %)
0.007
Xylene (Weight %)
0.017
n -Hexane (mole %)
0.659
n -Hexane (Weight %)
1.300
methylpentane
2, 2, 4-Trimethylpentane 2,2,4-Trimethylpentane
(mole %) 0.053 (Weight %)
0.1397
Additional Required Information:
Attach a representative gas analysis (including BTEX £t n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX Ft n -Hexane, temperature, and
pressure)
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
COLORADO..
31 Itsyszterte at 011.104c
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit = and AIRS ID]
Section 5 - Stack Information
eographical Coordinates(-.
(La₹itude/Longiiude`or L/TM)
40.80358/-103.8128
3
, �Utsc
Star tv��
`�� 8
ar eHeet:Jghtto
n eve
1 ��Fx r�)-� �G
��.�
Y
pve.;E
FLR-01
40
>2000
64.2
3.1
Indicate the direction of the stack outlet: (check one)
❑ Downward
❑ Other. (describe):
❑✓ Upward
❑ Horizontal
Indicate the stack opening and size: (check one)
❑✓ Circular Interior stack diameter (inches):
❑ Other (describe):
❑ Upward with obstructing raincap
8
Section 6 - Control Device Information
❑✓ VRU:
Pollutants Controlled: VOC and HAPs
Size: 60 -hp electric
Requested Control Efficiency
VRU Downtime or Bypassed
Make/Model:
100 %
12 %
Jordan Technologies/J-SCG10-3.05-60-4803
❑ Combustion
Device:
Pollutants Controlled: VOC and HAPs
Rating: 598 MMBtu/hr
Type: Open Flare Make/Model: Flare Industries/SFVP-0824
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency
Minimum Temperature:
NA
95
98
%
%
Waste Gas Heat Content 2,350 Btu/scf
Constant Pilot Light: ❑✓ Yes O No Pilot burner Rating
0.44
MMBtu/hr
Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0/0
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit r and AIRS ID]
Section.7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No
If yes, please describe the control equipment AND state the overall control efficiency (% reduction):
Overall Requested Control F:
Efficiency
reduction, emissions
PM
SO,
NO,
VOC
Gas is sent to gas gathering pipeline w/ open flare as backup
95%
CO
HAPs
Gas is sent to gas gathering pipeline w/ open flare as backup
95%
Other:
Permit Limits
From what year is the following reported actual annual emissions data?
Use the following table to report the criteria pollutant emissions from source:
(Use the data reported in Sections 4 and 6 to calculate these emissions.)
PM
Pollutant
Uncontrolled
Emission
Factor
Emission
Factor
Units
Emission
Factor -'
Source
(AP -42r..
Mfg. etc)
Controlledb
(Tons/year)
Uncontrolled
• (Tons/year)
Controlled
(Tons/year)-
Uncontrolled
(Tons/year)
0.0075
lb/MMBtu
Btu
Ib/MMBtu
De Minimis
SO,
NO),
0.068
lb/MM Btu
AP -42
De Minimis
VOC
1.685
lb/bbl
Flash Liberation
1,537.6
9.23
CO
0.310
Ib/MiMBtu
AP -42
De Minimis
Benzene
0.0027
lb/bbl
Flash Liberation
2.45
0.01
Toluene
0.0015
lb/bbl
Flash Liberation
1.39
0.01
Ethylbenzene
0.0002
lb/bbl
Flash Liberation
0.15
0.001
Xylenes
0.0004
lb/bbl
Flash Liberation
0.33
0.002
n -Hexane
0.0277
lb/bbl
Flash Liberation
25.26
0.15.
2,2,4-
Trimethylpentane
Other:
0.0030
lb/bbl
Flash Liberation
2.71
0.02
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Farm APCD-205 -Natural Gas Venting APEN - Rev 03/2017
Permit Number:
AIRS ID Number: - / /
[Leave blank unless APCD has already assigned a permit r and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct.
Signature of Legally A
Ashley Brinkerhoff
June 12, 2018
n (not a vendor or consultant) Date
Environmental Professional
Name (please print)
Title
Check the appropriate box to request a copy of the:
✓� Draft permit prior to issuance
✓� Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
Send this form along with $152.90 to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and
Environment
Telephone: (303) 692-3150
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https: //www.colorado.gov/cdphe/apcd
Form APCD-205 -Natural Gas Venting ADEN - Rev 03/2017
6!
COLORADO.
ar-coPut.
Natural Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for. Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid
separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does
not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN
(Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms can be found on the Air Pollution Control Division (APCD) website at:
www.colorado.gov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number:
AIRS ID Number: . Z 3 /� �C
[Leave blank unless APCD has already assigned a permit k and AIRS ID]
Company equipment Identification: • SEP-22, FLR-02
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Name': Whiting Oil and Gas Corporation
Site Name: Razor 25 CPB
Site Location: SESW Sec 25, T10N, R58W
Mailing Address:
(Include Zip Code) 1700 Broadway, Suite 2300
Denver, CO 80290
E -Mail Address: CDPHEcorrespondence@whiting.com
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact: Jacob Parker
Phone Number: (303) 357-4078
IPlejase use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will
appear on all documents issued by the APCD. Any changes wilt require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
Form APCD-211 - Natural Gas Venting APEN - Rev 03'2017
373706
�® COLORADO
1ctw.o-m.-�t rwc
NUYJ L 6nv'.eenmen„
Permit Number:
AIRS ID Number: /
[Leave hank APCD has ni ]]iar;y a;s sned a permit t] and AIRS ID] .
Section 2- Requested Action
O NEW permit OR newly -reported emission source
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
4 Change fuel or equipment ❑ Change company name 0 Add point to existing permit
0 Change permit limit 0 Transfer of ownership' 0 Other (describe below)
OR -
• APEN submittal for update only (Please note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
1 Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes: Produced Water Vessel
3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
,
• M_
Section 3 - General Information
General description of equipment and purpose:
Flaring associated gas from produced water
vessel during VRU and gas gathering downtime.
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
October / 18 / 2018
❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day days/week weeks/year
Will this equipment be operated in any NAAQS nonattainment
area
is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
O Yes
❑ Yes
❑✓ No
❑✓ No
J1�COLORe DO
2 liM9 txo� a�nv
Permit Number: AIRS ID Number: / /
Section 4 - Process Equipment Information
❑ Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model:
Serial #:
Capacity: Gal/min
❑ Compressor Rod Packing
Make: Model: # of Pistons: Leak Rate: Scf/hr/pist
❑ Blowdown Events
# of Events/year: - Volume per event: MMscf/event
fJ Other -
Description: Produced Water Pressurized Vessel
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural
Gas Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? El Yes
Natural Gas Venting
Process Parameters4:
Liquid Throughput
Process Parameters4:
❑ No
Maximum Vent
Rate:
1 425
,
SCF/hr
Vent Gas
Heating Value:
1 410
,
BTU/SCF
Requested:
0.874
MMSCF/year
Actual:
MMSCF/year
-OR-
Requested:
Bbl/yr
Actual:
Bbl/yr
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Process Properties:
Molecular Weight:
VOC (mole %)
22.155
VOC (Weight %)
38.41
Benzene (mole %)
0.094
Benzene (Weight %)
0.25
Toluene (mole %)
0.041
Toluene (Weight %)
0.13
Ethylbenzene (mole %)
0.002
Ethylbenzene (Weight %)
0.01
Xylene (mole %)
0.006
Xylene (Weight %)
0.02
n -Hexane (mole %)
0.266
n -Hexane (Weight %)
0.79
entane
2,2,4 Trimethy(mole %)
0.013
2,2,4 Trimet hpentane
(Weight %)
0.05
Additional Required Information:
2 Attach a representative gas analysis (including BTEX ft n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX & n -Hexane, temperature, and
pressure)
Form APCU-211 -Natural Gas Venting APEN - Rev 03/2017 -
Ay COLORADO
e..UTY Lrv+unmene
Permit Number:
AIRS ID Number: /
nnipsri APIr ,:nn -any ie!! cif._ and AIRS,
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.803575, -103.8128
Operator _
StaCLc 1D.Nn
Discharge Height `
Above` Ground Level
(eet)
Temp
('F)
Flow Rate
fACFM)
Velocity
eft/secs) =.
FLR-02
40
>2000
3,125
149.2
Indicate the direction of the stack outlet: (check one)
D Upward
❑ Horizontal
❑ Downward
El Other (describe):
Indicate the stack opening and size: (check one)
Q Circular Interior stack diameter (inches):
❑ Other (describe):
El Upward with obstructing raincap
8
Section 6 - Control Device Information
O VRU:
Pollutants Controlled:
Size:
Make/Model:
Requested Control Efficiency
VRU Downtime or Bypassed
D Combustion
Device:
Pollutants Controlled: VOC and HAPs
Rating: 598 MMBtu/hr
Type: Open Flare Make/Model: Flare Industries SFVP-0824
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency
Minimum Temperature:
N/A
95
98
%
%
Waste Gas Heat Content 1,410 Btu/scf
Constant Pilot Light: O Yes El No Pilot burner Rating 0.16 MMBtu/hr
Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0/0
Form APCD-211 -Natural Gas Venting APEN Rev 03/2017
4I AY
COLORADO
Hra!�n h Enronnnr. t
ft
Permit Number:
AIRS ID Number:
e h19 _ ,.e;, kPC ha �tv gnFd � Geer nit :' dr d Jk 1D1
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? Yes ❑ No
If yes, please describe the control equipment AND state the overall control efficiency (% reduction):
Overall Requested control
Efficiency
(%reduction' in emissions)
Pollutant
PM
Control Equipment Description
SOX
NO,,
VOC
CO
Gas is sent to gas gathering pipeline with open flare as backup
95%
HAPs
Other:
Gas is sent to gas gathering pipeline with open flare as backup
95%
From what year is the following reported actual annual emissions data?
Permit Limits
Use the following table to report the criteria pollutant emissions from source:
Pollutant
Uncontrolled
Emission
Factor
Emission
Factor
Units
Emission
Factor
Source
(AP -42,
Mfg. etc)
-
Actual _ Annual Emissions
Requested. Annual Permit..
•Emission aimit(s)3
Uncontrolled
(Tons/year).
Controlled6
(Tons/year).
Uncontrolled
(Tons/year)
Controlled
(Tons/year):
PM
0.0075
lb/MMBtu
AP -42
De minimis
SOX
NO„
0.068
lb/MMBtu
AP -42
De minimis
VOC
0.056
lb/bbl
Gas Analysis
184.07
0.64
CO
0.310
lb/MMBtu
AP -42
De minimis
Benzene
0.000
lb/bbl
Gas Analysis
1.21
0.004
Toluene
0.000
lb/bbl
Gas Analysis
0.62
0.002
Ethylbenzene
0.000
lb/bbl
Gas Analysis
De minimis
De minimis
Xylenes
0.000
lb/bbl
Gas Analysis
De minimis
De minimis
n -Hexane
0.001
lb/bbl
Gas Analysis
3.77
0.01
Trimethylphylpentane
0.000
lb/bbl
Gas Analysis
0.25
0.001
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6Annual-emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APED -211 Natural Gas Venting APEN Rev 03`2017
�coioReoo
5 � w�ms�.H��Gx
H.,.Hi Y frv+wnmrn.
Permit Number: AIRS ID Number: / /
r
Section 8 Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct.
January 16, 2018
Sigre of Legally Authorized Person (not a vendor or consultant)
Jacob Parker
Date
Environmental Professional
Name (please print) Title
Check the appropriate box to request a copy of the:
0 Draft permit prior to issuance
❑r Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
Send this form along with $152.90 to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and
Environment
Telephone: (303) 692-3150
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https://www.colorado.gov/cdphe/apcd
6l
AY
COLORADO
Jut, 122018
Natural Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid
separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does
not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN
(Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms can be found on the Air Pollution Control Division (APCD) website at:
www.colorado.gov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: I l.) e CEO --"?- AIRS ID Number: I a3 /C(p95lcws
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Company equipment Identification: SEP-11, FLR-01
[Provide Facility Equipment lb to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Name':
Site Name:
Whiting Oil and Gas Corporation
Razor 25 CPB
Site Location: SESW, Section 25, T10N, R58W
Mailing Address:
(include Zip Code) 1700 Broadway, Suite 2300
Denver, CO 80290
E -Mail Address2: CDPHECorrespondence@whiting.com
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact: Ashley Brinkerhoff
Phone Number: 303-390-1596
'Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will
appear on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
Form APCD-2O5 - Natural Gas Venting APEN - Rev 03/2017
Ca:...OR A Da.
rasx�srn+ne.nf;.vu.�.
Permit Number:
AIRS ID Number: /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2- Requested Action
✓❑ NEW permit OR newly -reported emission source
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit
❑. Change permit limit ❑ Transfer of ownership' 0 Other (describe below)
-OR -
❑ APEN submittal for update only (Please note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
✓❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info & Notes: Produced Water Process Vessel
3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
Flaring gas from produced water vessel
during VRU or gas gathering downtime.
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
/ /
10 / 18 / 2017
❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day
Will this equipment be operated in any NAAQS nonattainment
area
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions
days/week weeks/year
O Yes
O Yes
❑✓ No
❑✓ No
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
COLORA DO
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Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Process Equipment Information
O Gas/Liquid Separator
O Well Head Casing
❑ Pneumatic Pump
Make: Model:
❑ Compressor Rod Packing
Make: Model:
Serial #:
Capacity: Gal/min
# of Pistons: Leak Rate: Scf/hr/pist
❑ Blowdown Events
# of Events/year: Volume per event: MMscf/event
0 Other
Description: Produced Water Pressurized Vessel
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural
Gas Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? ❑✓ Yes
Natural Gas Venting
Process Parameters4:
Liquid Throughput
Process Parameters4:
❑ No
Maximum Vent
Rate:
1 425
SCF/hr
Vent Gas
Heating Value:
1 410
BTU/SCF
Requested:
1.50
MMSCF/year
Actual:
MMSCF/year
-OR-
Requested:
Bbl/yr
Actual:
Bbl/yr
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Process Properties:
Molecular Weight:
VOC (mole %)
22.16
VOC (Weight %)
38.41
Benzene (mole %)
0.094
Benzene (Weight %)
0.252
Toluene (mole %)
0.041
Toluene (Weight %)
0.129
Ethylbenzene (mole %)
0.002
Ethylbenzene (Weight %)
0.009
Xylene (mole %)
0.006
Xylene (Weight %)
0.021
n -Hexane (mole %)
0.266
n -Hexane (Weight %)
0.788
2,2,4-Trimethylpentane
(mole %)
0.013
2,2,4-Trimethylpentane
(Weight %)
0.052
Additional Required Information:
❑✓ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and
pressure)
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
Permit Number:
AIRS ID Number:
/ /
[Leave blank unless APED has already assigned a permit # and MRS ID]
Section 5 - Stack Information
23.75
1.1
FLR-01
3eograptireal�Coocrli hat
(Latitude7Longatude-car L TM)
40
40.80358/-103.8128
>2000
Indicate the direction of the stack outlet: (check one)
❑✓ Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑✓ Circular Interior stack diameter (inches):
O Other (describe):
O Upward with obstructing raincap
8
Section 6 - Control Device Information
❑✓ VRU:
Pollutants Controlled: VOC and HAPs
Size: 60 -hp electric
Requested Control Efficiency
VRU Downtime or Bypassed
Make /Model:
100
12 %
Jordan Technologies/J-SCG10-3.05-60-4803
O Combustion
J
Device:
Pollutants Controlled: VOC and HAPs
Rating: 598 MMBtu/hr
Type: Open Flare Make/Model: Flare lndustries/SFVP-0824
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency
Minimum Temperature:
NA
95 %
98 %
Waste Gas Heat Content
Constant Pilot Light: p Yes O No Pilot burner Rating
1,410
0.44
Btu /scf
MMBtu/hr
r
Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
4I
.COLORADO.
Permit Number:
AIRS ID Number:
PM
[Leave blank unless APCD has already assigned a permit and AIRS IDI
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No
If yes„ please describe the control equipment AND state the overall control efficiency (% reduction):
PM
SO,
NOX
VOC
Gas is sent to gas gathering pipeline w/ open flare as backup
95%
CO
HAPs
Gas is sent to gas gathering pipeline w/ open flare as backup
95%
Other:
Permit Limits
From what year is the following reported actual annual emissions data?
Use the following table to report the criteria pollutant emissions from source:
(Use the data reported in Sections 4 and 6 to calculate these emissions.)
Uncontrolled
'Er ission
Factor'.;"
Emission.
Factor
I b/M M Btu
Emission,
Factor`.
Source
(AP -42,
Mfg. etc)
ncontrolled
(Tonsfyear) .
Controlledb
(Tons/year) .
ncontrolled
(Tons/year)
Controlled,
0.0075
Ib/MMBtu
De Minimis
SOX
NO,
0.068
Ib/M M Btu
AP -42
De Minimis
VOC
0.0560
lb/bbl
Flash Liberation
184.07
1.10
CO
0.310
I b/M M Btu
AP -42
De Minimis
Benzene
0.0004
lb/bbl
Flash Liberation
1.21
0.007
Toluene
0.0002
lb/bbl
Flash Liberation
0.62
0.004
Ethylbenzene
0.00001
lb/bbl
Flash Liberation
De Minimis
De Minimis
Xylenes
0.00003
lb/bbl
Flash Liberation
De Minimis
De Minimis
n -Hexane
0.0011
lb/bbl
Flash Liberation
3.77
0.02
2,2,4-
Trimethylpentane
0.0001
lb/bbl
Flash Liberation
0.25
0.001
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-205 Natural Gas Venting APEN - Rev 03/2017
Permit Number:
AIRS ID Number:
/ I
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct.
Signature of Legally Aut
Ashley Brinkerhoff
June 12, 2018
(not a vendor or consultant) Date
Environmental Professional
Name (please print)
Title
Check the appropriate box to request a copy of the:
❑ Draft permit prior to issuance
(] Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
Send this form along with $152.90 to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and
Environment
Telephone: (303) 692-3150
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https://www.colorado.gov/cdphe/apcd
Form APCD-205 -Natural Gas Venting ADEN - Rev 03/2017 6 I
COLOR ADO
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