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Home My WebLink About20181874.tiffCOLORADO Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 11500 St PO Box 758 Greeley, CO 80632 June 13, 2018 Dear Sir or Madam: RECEIVED JUN 142018 WELD COUNTY COMMISSIONERS On June 14, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for Whiting Oil and Gas Corporation - Horsetail 07 West 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 ft 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 S., John W. Hickenlooper, Governor Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer c � PL.(M.fkI T 43), IA L(J T), pw(cR.fe.Ff(sn�Ic1) off— ILA -IQ 2018-1874 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Whiting Oil and Gas Corporation - Horsetail 07 West CPB - Weld County Notice Period Begins: June 14, 2018 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: Horsetail 07 West CPB Oil a Gas Central Production Facility SENW SEC 7 T10N R57W Weld County The proposed project or activity is as follows: Oil Et Gas Central Production Facility The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 17WE1114 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such comment must be submitted in writing to the following addressee: Christopher Kester Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Christopher Ke Package 8: 370350'' Received Date: 10/18/2017 Review Start Date: 1/1/2018 Section 01 - Facility Information Company Name: Whiting Oil and Gas Corporation County AIRS ID: 123. Plant AIRS ID: 9F8B Facility Name: Horsetail 07 West Central Production Bette Physical Address/Locatio SENW quadrant of Section 7, Township 10N, Range 57W, in Weld County, Colorado Type of Facility: Exploration & Production Well Pad What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? '.. If yes, for what pollutant? Don Motivate (CO) Weld Section 02 - Emissions Units In Permit Application Pa iculate Matter (PM) Quadrant Section Township Range NW ION 57 Oiz e (NOx & VOC) AIRS Point U Emissions Source Type Equipment Name Emissions Control? Permit N Issuance It Self Cert Required? Action Engineering Remarks 001 Separator Venting SEP-01 through Sep -08 Yes 17WE1114 1 yes Permrt Initial Issuance 002 Vapor Recovery Tower (VRT) SEP-26 and SEP-27 Yes 17WE1115 1. Yes Permit Initial Issuance 003 PrdducedWSterTank -. PW-01 through PW-08 Yes 17W51115 1 Yes Permit Initial Issuance 004 Other (Explain) DUST -01-: Yes - 17WE1117.XP :1 No APEN Required --/Permit Exempt Fugitive Dust. 005 Crude Oil Tank TK-01 through TK-16 Yes 17WE1118 S Yes Petm(LIn•tial Issuance . 006 NaturalGas RICE ENG 02 Yes 17WE1119 1 Yes Permit Initial >: Issuance .007 Natural Gas RICE ENG-01 Yes 17W 2D '. 1 yas .' Permit Initial once Section 03 - Description of Project Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Greater than 50 tons: Y€5 in ace Attainment Area Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) SO2 No Yes NOx CO VOC PM2.5 PM10 TSP HAPs ❑ ❑ ❑ ❑ Colorado Air Permitting Project Non -Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, explain what programs and which pollutants here: 5O2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) NOx CO VOC PM 5 PM10 TSP HAPs El II Separator Venting Emissions Inventory Section 01- Administrative Information Facility AIRs ID: 9F6& Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Eight (8} two phase separators and Emission Control Device Description: Open Flare'. Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates ' Primary Emissions - Separator Actual Throughput =T' Requested Permit Limit Throughput = MMscf per year MMscf per year Potential to Emit (PTE) Throughput = 109.5 MMscf per year Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare) Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL o liquids throughput: Section 04 - Emissions Factors & Methodologies The 2 phaseseparators₹ emission factoesfor. Ex=QC MW cxx/C • Btu/scf (REV) b/Ib-mol Weight % Helium CO2 N2 methane ethane 0-.0000- 4,44;19 2 14-6621. propane isobutane n -butane isopentane n -pentane c(clopentane n -Hexane cyclohexane Other hexanes heptanes methylcyclohexane 224-TMP - Benzene Toluene Ethylbenzene Xylenes C8+ Heavies r'. 20.3&47'', 2.8294 93996 3752: 0.155 0.7728 .6.1472 2-_4170 0'_0822 ..a0858 :._6;6152. Total VOC Wt % 100.0003 46.2088 scf/bbl 1411.5 Btu/Scf (LHV) tedtoa flare Tb¢ coi binesi react sgas 3atnpled and edto Icuiate 3 of 34 - K:\PA\2017\ 17WE1114.CP1.xlsm Separator Venting Emissions Inventory Emission Factors Separator Venting Pollutant Uncontrolled Controlled (lb/MMscf) (Ib/MMscf) (Gas Throughput) (Gas Throughput) VOC 34735.8499 1736.7925 Benzene Toluene 64.4972 464.7102 106.5180 197.8514 580.9254 61.7910 3.2249 23.2355 5.3259 9.8926 29.0463 3.0895 Ethylbenzene Xylene n -Hexane 224 TMP Pollutant Primary Control Device Emisson Factor Source Uncontrolled Uncontrolled (Ib/MMBtu) lb/MMscf (Waste Heat Combusted) (Gas Throughput) Emission Factor Source PM10 PM2.5 0075::7:. 11.513 11.513 0.909 .O.0075:' 0,0666.>.::' 5Ox NOx CO 105.074 437.565 013580'-. Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) PM10 PM2.5 SOx NOx VOC CO 0.63 0.63 0.63 0.63 0.63 0.63 0.63 0.63 0.63 0.63 0.05 0.05 0.05 0.05 0.05 5.88 5.88 5.88 5.88 5.88 1901.79 1901,79 95.09 1901.79 95.09 24.51 24.51 24.51 24.51 24.51 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 7062 7062 353 7062 353 50886 50886 2544 50886 2544 11664 11664 583 11664 583 21665 21665 1083 21665 1083 63611 63611 3181 63611 - 3181 6766 6766 338 6766 338 Section 06 - Regulates Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XVII.B, G Regulation 7, Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Source requires a permit Source is subject to Regulation 7, Section XVII.B.2, G The control device for this separator is subject to Regulation 7, Section XVII.B.2.e 3.531218984 25.4428855 5.831861656 10.83236406 31.8056647 3.38305595 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 under this AIRS ID, and should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year? If yes, the permit will contain: -An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. -A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. W81 the operator have a meter installed and operational upon startup of this point? No If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes 0.176560949 1.272144275 0.291593083 0.541618203 1.590283235 0.169152797 4 of 34 K:\PA\2017\17W E1114.CP1.xlsm Separator Venting Emissions Inventory Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # Process # SCC Cade 001 01 3-10-001-60 Flares Uncontrolled Emissions Pollutant Factor Control % Units PM10 11.51 0 lb/MMSCF PM2.5 11.51 0 lb/MMSCF 500 0.91 0 lb/MMSCF NOx 105.07 0 lb/MMSCF VOC 34735.85 95 Ib/MMSCF CO 437.57 0 Ib/MMSCF Benzene 64.50 95 lb/MMSCF Toluene 464.71 95 Ib/MMSCF Ethylbenzene 106,52 95 Ib/MMSCF Xylene 197.85 95 lb/MMSCF n -Hexane 580.93 95 lb/MMSCF 224 TMP 61.79 95 Ib/MMSCF 5 of 34 K:\PA\2017\ 17WE1114.CP1.xlsm Separator Venting Emissions Inventory Cell: A2 Comment: cdmoney: Enter the facility AIRS ID number (County/Plant/Point) if previously assigned by the Air Pollution Control Division (APCD). If you are reporting a new point at a site with an existing County and Plant ID, fill in the known information. Cell: A7 Comment: cdmoney: Enter a detailed description of the emission unit (how many separators, type (high pressure, low pressure, vapor recovery tower (VRT), etc.) so this information can be copied directly into the equipment description in the permit. For example: One (1) low-pressure separator Cell: A9 Comment: cdmoney: Examples: Enclosed Flare during VRU downtime Enclosed Flare Open Flare Thermal Oxidizer Cell: A10 Comment: cdmoney: This value represents the requested overall control efficiency for a single control device. If the source is requesting a more complex control scenario, such as permitting for control device downtime or permitting for a backup control device with different control efficiency than the primary control device, this PA needs to be edited to address the unique control scenarios. One option is to create a worksheet for each control scenario and an additional worksheet for total emissions. Another option is to create additional tables within this worksheet for the other control scenario and total emissions. Cell: Al2 Comment: Use the appropriate Process Parameter based on how the emissions are estimated and engineer's judgment. Use Natural Gas Venting as a process parameter if: • The point has a PTE greater than 100 tpy of VOC, AND • the point includes a HP/HLP/LP separator OR Use Natural Gas Venting as a process parameter if: • The owner operator is requesting Natural Gas Venting as a process parameter, AND • The owner operator is willing to use a flow meter Use Liquids Throughput as a process parameter if: • the point has a PTE less than 100 tpy of VOC, or • the point is a VRT permitted by itself Cell: A14 Comment: This selection indicates whether or not the operator will have a gas meter installed and operational upon issuance of the permit. If not, the operator shall agree to install a meter within 180 days of startup. If the operator will not have a meter installed and operational upon startup, the "volume of waste gas emitted per BBL of liquids throughput" (i.e. the value specified in cell B31) shall be used to monitor gas volume. Cell: A19 Comment: This value represents the actual throughput Cell: A20 Comment: This value represents the requested separator gas volume or corresponding liquid throughput the operator will accept as a permit limit and the basis for the permitted emissions in a traditional construction permit. The requested limit must be based on the volume of liquid throughput (BBL per year) if the operator is not required to install a gas flow meter. If the operator is required to install a gas flow meter, the requested limit must be based on volume of gas. The operator can request a throughput limit less than the gas production rate of the separator or total liqud throughput but this value will be the enforceable permitted limit and will be the basis for calculating requested emissions for the separator. For example, if a portion of the separator stream is being recycled as part of the process (e.g. via a VRU), then the requested throughput maybe limited to the gas volume routed to flare or liquid throughput while emissions are routed to flare. If the source does not want to take credit for recycling (or the recycling is determined to not be part of the process), then the requested separator gas volume is the maximum vent rate at requested operating hours or total liquid throughput. Cell: A21 Comment: This value represents requested throughput. The "Potential to Emit (PTE) Throughput" is the same as the "Requested Permit Limit Throughput" for this source type. Cell: A23 Comment: The information provided in this section will establish the portion of the gas stream to be recycled. Cell: A25 Comment: The vapor recovery unit (VRU) is considered process equipment if 100% collection is assumed while the VRU is operating. If source is requesting less than 100% collection efficiency while the VRU is operational, it is likely the VRU is not considered process and should be addressed as a control device. Refer to PS -Memo 99-03 for additional guidance. Cell: A27 Comment: The information provided in this section will establish the basis to estimate secondary emissions that result from emissions controls that combust VOC and HAP emissions from the separator Cell: A29 Comment: Gas heating value is the amount of heat produced.from the complete combustion of a unit of fuel. The higher (or gross) heating value is obtained when all products of combustion are cooled to the pre -combustion temperature, water vapor formed during combustion is condensed, and necessary corrections have been made. This value represents the maximum heat content of the separator gas emitted. This value is based on the site -specific gas sample if available, the modeled value, or the weighted average if this point represents more than one gas stream such as LP separator gas plus VRT gas. Cell: A30 Comment: This value represents the ratio of the volume of waste gas emitted from the separator(s) per barrel of condensate/crude oil produced. If a process simulator (i.e. ProMax, HYSYS, etc.) is used, then the volume of waste gas produced should be based on the TOTAL gas flow from the separation equipment as predicted by the model. This waste gas volume is then divided by the number of barrels used in the model run. For example, if the gas stream from the separator is recycled, then the scf/bbl ratio is: (flow rate recycled +flow rate to flare) / (number of barrels used in the model run) If operator is measuring gas flow using a meter, this cell is left blank. Cell: A32 6 of 34 K:\PA\2017\17WE1114.CP1.xlsm Separator Venting Emissions Inventory Comment: This section establishes the process rates that are the basis for; actual emissions and will be reported to the Division's emissions inventory system; requested permitted emissions that will become a limit in the permit issued; and the potential to emit used to establish if the facility should be considered a true minor, synthetic minor or major source under Colorado Regulation 3 permitting programs. Cell: A35 Comment: Enter a detailed description of basis for emission calculations. Include details of the process setup and any sample analyses used (include where the sample was pulled, date of the sample, etc.). If a model is used, indicate which type of model and basis for model inputs. For example: This VRT is located downstream of an inlet (high pressure) separator and low pressure separator where the liquids undergo gas/liquid separation prior to the VRT. A pressurized liquid sample was taken from the low pressure separator at 32 psig; 90.3 deg F (sampled: 2/15/2017) and modeled, using ProMax Ver 4.0, through the VRT. The mass fractions, molecular weight (MW), and vent rate of the waste gas stream are derived from the modeled VRT gas stream "VRT Vapors to Bumer". The ProMax model was run based on 1 bbl/day condensate throughput. Cell: A38 Comment: This equation may be referenced in EPA Emission Inventory Improvement Program Publication: Volume II; Chapter 10 - Displacement Equation (10.4-3). Where: Ex = emissions of pollutant x Q= Volumetric flow rate/volume of gas processed MW = Molecular weight of gas = SG of gas • MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/Ib-mol) at 60F and 1 atm Cell: B42 Comment: The values input tothis table represent the % by weight in the gas stream (i.e. if the value is 40%, then "40" must be input here) If additional pollutants must be added to this table based on the reported stream composition, the user can insert a row as follows: If pollutant is a VOC: -select the entire row that includes "C8+ Heavies" in the spreadsheet by right clicking on the row # next to column A -select "insert" from the drop down menu If pollutant is not a VOC: -select the entire ram that includes "propane" in the spreadsheet by right clicking on the row # next to column A -select "insert" from the drop down menu Cell: A65 Comment: This must be 100% Cell: B70 Comment: When cell indicates "(Ib/MMscf)": EF= Xxx MW 10^6/C where: EF = emission factor (lb/MMscf) MW = Molecular weight of gas = SG of gas • MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/Ib-mol) at 60F and 1 atm When cell indicates")lb/bbl)": EF = Xxx MW x GLR/ C where: EF = emission factor (lb/bbl) MW = Molecular weight of gas = SG of gas • MW of air Xx = mass fraction of x in gas GLR = volume of waste gas emitted per barrel of liquids throughput (scf/bbl) C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm Note: GLR is referenced from the value input in Section 03 - Cell: D79 Comment: NOx and CO emissims factors from AP -42 Table 1.4-1 may be used only when a thermal oxidizer is used to control emissions. Cell: B82 Comment: The operator should provide emissions factors for NOx, CO and PM10/PM2.5 which represent the post combustion emissions resulting from the emissions control device (e.g. secondary emissions). Ensure the emission factors are in the correct units of Ib/MMBtu (convert within the cells to establish correct units if needed). Leave NOx, CO and ►M10/PM2.5 E.F. blank if the unit is not controlled. Cell: C82 Comment: This column automatically converts emission factors from Ib/MMBtu to lb/MMscf waste gas combusted since ongoing compliance demonstration for actual emissions will be calculated using actual waste gas volume multiplied by an emission factor. It is more straightforward to convert all emission factors into units correlating to the process limit. The lb/MMscf emission factors for NOx, CO and PM should be listed in the Notes to Permit Holder section of the permit. Cell: A90 Comment: All values contained in the emissions inventory section are automatically calculated based on the information provided in the preceding sections. Cell: E93 Comment: Secondary emissions from control devices are listed in the uncontrolled and. controlled columns in this emissions inventory table. While secondary emissions are not generated until the emitting unit is controlled, the secondary emissions are not actually being controlled so H is appropriate to list the secondary emissions as uncontrolled. Also, by listing the secondary emissions under uncontrolled and controlled, facility emissions can be more clearly summarized and the facility source classification regarding true minor/synthetic minor/major status can be more logically assessed. Cell: A112 Comment: cdmoney: This section will be automatically populated based on the regulatory analysis worksheet. Cell: A134 Comment: cdmoney: 7 of 34 K:\PA\2017\17WE1114.CP1xlsm Separator Venting Emissions Inventory This section should include discussion to support decisions made throughout this document if there are anomalies or unique circumstances or any area that warrant a more thorough evaluation and/or explanation. For example, if unique modeling was performed to develop the emission factor or if there is a unique process set-up that impacts emission factors and/or regulatory applicability. S of 34 K:\PA\2017\17WE1114.CP1xlsm Separator Venting Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Attainment. Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)7 Yes Yes ' 'Source requires a permit NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section II.D.2)? 'You have indicated that source is in the Attainment Area Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? Source Req Source Req Source is st 'Source is subject to Regulation 7, Section XVII.B.2, G Section XVII.B.2 —General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G - Emissions Control Alternative Emissions Control (Optional Section) a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? 'The control device for this separator issubject to Regulation 7, Section XVil.R.2,e Section XVII.B.2.e —Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend," "may," "should," and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. The control Separator Venting Emissions Inventory Section 01- Administrative Information Fadlity AIRs ID: 123 ......,, _ County 4E6$ Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: earnequipmentj A vapor recovery unit (ffttu}with-na morethat 12% down[imejfiypas enelosedfl ce ddridg PR Emission Control Device Description: -- • Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Section 03- Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU Is VRU process equipment: Barrels (bbl) per year Barrels (bbl) per year 271,560 Barrels (bbl) per year 2,263,000 Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare) Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL of liquids throughput: Section 04- Emissions Factors & Methodologies 2186.: Btu/scf 32.06O7 scf/bbl Displacement Equation Ex=Q•MW• %x/C Weight % Helium 0,000€- 02 fi N2 methane ethane 76 22.3170 35 propane isobutane n -butane 5.4290. 2: 585' opentane A. 9.034 n -pentane cyclopentane n -Hexane cyclohexane Other hexanes heptanes methylcyclohexane 224-TMP 0.095 Benzene Toluene Ethylbenzene Xylenes CB+Heavies 0.6 0 738 0.6906 0.0780 0.0693 0.01._9 Total VOC Wt % b/Ib-mol 2008 10 of 34 K:\PA\2017\ 17WE1114.CP1.xlsm Separator Venting Emissions Inventory Emission Factors Separator Venting Section 05 - Emissions Inventory Pollutant VOC Benzene 224 TMP Pollutant PM2.5 SOx NOx CO Uncontrolled Controlled (lb/bbl) (lb/bbl) Emission Factor Source (Liquid Throughput) (Liquid Throughput) 2.7665 0.1383 0.0029 0,0001 0.0025 0.0004 0.0012 0.0001 0.0000 0.0001 0.0013 0.0035 0.0002 Primary Control Device Uncontrolled Uncontrolled (lb/MMBtu) lb/bbl (Waste Heat Combusted) (Gas Throughput) 0.0075- 0.001 0.0075 0.0006- 0.068Q 0.000 0.005 0.01996 Emission Factor Source • Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) PM10 PM2.5 sox NOx VOC CO 0.07 0.07 0.07 0.07 0.07 0.07 0,07 0.07 0.07 0.07 0.01 0.01 0.01 0.01 0.01 0.65 0.65 0.65 0.65 0.65 375.64 375.64 18.78 375.64 18.78 2.71 2.71 2.71 2.71 2.71 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 785 785 39 785 39 692 692 35 692 35 115 115 6 115 6 313 313 16 313 16 6824 6824 341 6824 341 958 958 48 958 48 Section 06- Regulatory Summ Analysis Regulation 3, Parts A, B Facility attainment -area status has not been established yet Regulation 7, Section XVII.B, G Source is subject to Regulation 7, Section XVII.B.2, G Regulation 7, Section XVII.B.2.e I The control device for this separator is subject to Regulation 7, Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Using Liquid Throughput to Monitor Compliance Does the company use site specific emission factors based on a pressurized liquid sample (Sampled upstream of the equipment covered under this AIRS ID) and process simulation to estimate emissions? Yes -' This sample should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it maybe appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to collect a site -specific liquid sample and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes 11 of 34 K:\PA\2017\17 W E1114. CP1.xlsm Separator Venting Emissions Inventory Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 002 Process# SCC Code 01 3-10-001-29 Oil & Gas Production: Gasdiquid separation Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.52 0 lb/1000bbl PM2.5 0.52 0 lb/1000bbl SOx 0.04 0 lb/1000bbl NOx 4.77 0 lb/1000bbl VOC 2766.51 95 Ib/1000bb1 CO 19.96 0 lb/1000bbl Benzene 2.89 95 lb/1000bbl Toluene 2.55 95 lb/1000bbl Ethylbenzene 0.42 95 lb/1000bbl Xylene 1.15 95 Ib/lo0abbl n -Hexane 25.13 95 lb/1000bbl 224 TMP 3.53 95 lb/1000bbl 12 of 34 K:\PA\2017\ 17WE1114.CP1.xlsm Separator Venting Emissions Inventory Cell: A2 Comment: cdmoney: Enter the facility AIRS ID number (County/Plant/Point) if previously assigned by the Ar Pollution Control Division (APCD). If you are reporting a new point at a site with an existing County and Plant ID, fill in the known information. Cell: A7 Comment: cdmoney: Enter a detailed description of the emission unit (how many separators, type (high pressure, low pressure, vapor recovery tower (VRT), etc.) so this information can be copied directly into the equipment description in the permit. For example: One (1) low-pressure separator Cell: A9 Comment: cdmoney: Examples: Enclosed Flare during VRU downtime Enclosed Flare Open Flare Thermal Oxidizer Cell: A10 Comment: cdmoney: This value represents the requested overall control efficiency for a single control device. If the source is requesting a more complex control scenario, such as permitting for control device downtime or permitting for a backup control device with different control efficiency than the primary control device, this PA needs to be edited to address the unique control scenarios. One option is to create a worksheet for each control scenario and an additional worksheet for total emissions. Another option is to create additional tables within this worksheet for the other control scenario and total emissions. Cell: Al2 Comment: Use the appropriate Process Parameter based on how the emissions are estimated and engineer's judgment. Use Natural Gas Venting as a process parameter if: • The point has a PTE greater than 100 tpy of VOC, AND • the point includes a HP/HLP/LP separator OR Use Natural Gas Venting as a process parameter if: • The owner operator is requesting Natural Gas Venting as a process parameter, AND • The owner operator is willing to use a flow meter Use Liquids Throughput as a process parameter if: • the point has a PTE less than 100 tpy of VOC, or • the point is a VRT permitted by itself Cell: A14 Comment: This selection indicates whether or not the operator will have a gas meter installed and operational upon issuance of the permit. If not, the operator shall agree to install a meter within SB0 days of startup. If the operator will not have a meter installed and operational upon startup, the "volume of waste gas emitted per BBL of liquids throughput" (i.e. the value specified in cell B31) shall be used to monitor gas volume. Cell: A19 Comment: This value represents the actual throughput Cell: A20 Comment: This value represents the requested separator gas volume or corresponding liquid throughput the operator will accept as a permit limit and the basis for the permitted emissions in a traditional construction permit. The requested limit must be based on the volume of liquid throughput (BBL per year) if the operator is not required to Install a gas flow meter. If the operator is required to install a gas flow meter, the requested limit must be based on volume of gas. The operator ran request a throughput limit less than the gm production rate of the separator or total liquid throughput but this value will be the enforceable permitted limit and will be the basis for calculating requested emissions for the separator. For example, if a portion of the separator stream is being recycled as part of the process (e.g. via a VRU), then the requested throughput may be limited to the gas volume routed to flare or liquid throughput while emissions are routed to flare. If the source does not want to take credit for recycling (or the recycling is determined to not be part of the process), then the requested separator gas volume is the maximum vent rate at requested operating hours or total liquid throughput. Cell: A21 Comment: This value represents requested throughput. The "Potential to Emit (PTE) Throughput" is the same as the "Requested Permit Limit Throughput" for this source type. Cell: A23 Comment: The information provided in this section will establish the portion of the gas stream S. be recycled. Cell: A25 Comment: The vapor recovery unit (VRU) is considered process equipment if 100% collection is assumed while the VRU is operating. If source is requesting less than 100% collection efficiency while the VRU is operational, it is likely the VRU is not considered process and should be addressed as a control device. Refer to PS -Memo 99-03 for additional guidance. Cell: A27 Comment: The information provided in this section will establish the basis to estimate secondary emissions that result from emissions controls that combust VOC and HAP emissions from the separator Cell: A29 Comment: Gas heating value is the amount of heat produced from the complete combustion of a unit of fuel. The higher (or gross) heating value is obtained when all products of combustion are cooled to the pre -combustion temperature, water vapor formed during combustion is condensed, and necessary corrections have been made. This value represents the maximum heat content of the separator gas emitted. This value is based on the site -specific gas sample if available, the modeled value, or the weighted average if this point represents more than one gas stream such as LP separator gas plus VRT gas. Cell: MO Comment: This value represents the ratio of the volume of waste gas emitted from the separator(s) per barrel of condensate/crude oil produced. If a process simulator (i.e. ProMax, HYSYS, etc.) is used, then the volume of waste gas produced should _ be based on the TOTAL gas flow from the separation equipment as predicted by the model. This waste gas volume is then divided by the number of barrels used in the model run. For example, if the gas stream from the separator is recycled, then the scf/bbl ratio is: (flow rate recycled +flov1 rate to flare) / (number of barrels used in the model run) If operator is measuring gas flow using a meter, this cell is let blank. Cell: A32 13 of 34 K:\PA\2017\17WE1114.CP1xlsm Separator Venting Emissions Inventory Comment: This section establishes the process rates that are the basis for; actual emissions and will be reported to the Division's emissions inventory system; requested permitted emissions that will become a limit in the permit issued; and the potential to emit used to establish if the facility should be considered a true minor, synthetic minor or major source under Colorado Regulation 3 permitting programs. Cell: A35 Comment: Enter a detailed description of basis for emission calculations. Include details of the process setup and any sample analyses used (include where the sample was pulled, date of the sample, etc.). If a model is used, indicate which type of model and basis for model inputs. For example: This VRT is located downstream of an inlet (high pressure) separator and low pressure separator where the liquids undergo gas/liquid separation prior to the VRT. A pressurized liquid sample was taken from the low pressure separator at 32 psig; 90.3 deg F (sampled: 2/15/2017) and modeled, using ProMax Ver 4.0, through the VRT. The mass fractions, molecular weight (MW), and vent rate of the waste gas stream are derived from the modeled VRT gas stream "VRT Vapors to Burner". The ProMax model was run based on 1 bbl/day condensate throughput. Cell: A38 - Comment: This equation may be referenced in EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3). Where: Ex = emissions of pollutant x 4 = Volumetric flow rate/volume of gas processed MW = Molecular weight of gas = SG of gas • MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm Cell: B42 Comment: The values input to this table represent the % by weight in the gas stream (i.e. if the value is 40%, then "40" must be input here) If additional pollutants must be added to this table based on the reported stream composition, the user can insert a row as follows: If pollutant is a VOC: select the entire row that includes "C8+ Heavies" in the spreadsheet by right clicking on the row # next to column A select "insert" from the drop down menu If pollutant is not a VOC: select the entire row that includes "propane" in the spreadsheet by right clicking on the row # next to column A select "insert" from the drop down menu Cell: A65 Comment: This must be 100% Cell: 870 Comment: When cell indicates "(Ib/MMscf)": EF=Xx xMW x 10.6 /C where: EF = emission factor (Ib/MMscf) MW = Molecular weight of gas = SG of gas MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/Ib-mol) at 60F and 1 atm When cell indicates "(lb/bbl)": EF = Xx x MW x GLR/C where: EF = emission factor (lb/bbl) MW = Molecular weight of gas = SG of gas • MW of air Xx = mass fraction of x in gas GLR = volume of waste gas emitted per barrel of liquids throughput (scf/bbl) C = molar volume of ideal gas (379 scf/Ib-mol) at 60F and 1 atm Note: GLR is referenced from the value input in Section 03 Cell: D79 Comment: NOx and CO emissions factors from AP -42 Table 1.4-1 may be used only when a thermal oxidizer is used to control emissions. Cell: 882 Comment: The operator should provide emissions factors for NOx, CO and PM10/PM2.5 which represent the post combustion emissions resulting from the emissions control device (e.g. secondary emissions). Ensure the emission factors are in the correct units of Ib/MMBtu (convert within the cells to establish correct units if needed). Leave NOx, CO and PM10/PM2.5 E.F. blank if the unit is not controlled. Cell: C82 Comment: This column automatically converts emission factors from Ib/MMBtu to Ib/MMscf waste gas combusted since ongoing compliance demonstration for actual emissions will be calculated using actual waste gas volume multiplied by an emission factor. R is more straightforward to convert all emission factors into units correlating to the process limit. The lb/MMscf emission factors for NOx, CO and PM should be listed in the Notes to Permit Holder section of the permit. Cell: A90 Comment: All values contained in the emissions inventory section are automatically calculated based on the information provided in the preceding sections. Cell: E93 Comment: Secondary emissions from control devices are listed in the uncontrolled and controlled columns in this emissions inventory table. While secondary emissions are not generated until the emitting unit is controlled, the secondary emissions are not actually being controlled so it is appropriate to list the secondary emissions as uncontrolled. Also, by listing the secondary emissions under uncontrolled and controlled, facility emissions can be more clearly summarized and the facility source classification regarding true minor/synthetic minor/major status can be more logically assessed. Cell: A112 Comment: cdmoney: This section will be automatically populated based on the regulatory analysis worksheet. Cell: A130 Comment: cdmoney: 14 of 34 K:\PA\2017\ 17WE1114.CP1.xlsm Separator Venting Emissions Inventory This section should include discussion to support decisions made throughout this document if there are anomalies or unique circumstances or any area that warrant a more thorough evaluation and/or explanation. For example, if unique modeling was performed to develop the emission factor or if there is a unique process set-up that impacts emission factors and/or regulatory applicability. 15 of 34 K:\PA\2017\17WE1114.CP1.xlsm Separator Venting Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)? 'Source requires apermit NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section II.D.2)? (Not enough information Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? 'Source is subject to Regulation 7, Section XVII,B.2, G Section XVII.B.2 —General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G - Emissions Control Alternative Emissions Control (Optional Section( a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? 'The control device for this separator is subject to Regulation 7, Section XVII.B.2.e Section XVII.B.2.e —Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend," "may," "should," and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Source Req ( Source Req The control Produced Water Storage Tank(s) Emissions Inventory Section 01- Administrative Information Facility AIRs ID: 123 9F6B Plant 0037' Point Section 02- Eouipment Description Details Detailed Emissions Unit Eight (8)!„ Description: Emission Control Device Enclosed FI; Description: Requested Overall VOC & HAP Control Efficiency %: ater storage tanks Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Produced Water Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Produced Water Throughput = Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per BBL of liquids produced = 2 scf/bbl Actual heat content of waste gas routed to combustion device= Requested heat content of waste gas routed to combustion device = 5,475,000: Barrels (bbl) per year 5,475,0001 Barrels (bbl) per year 15,0001 Barrels (bbl) per year Btu/scf 1693 Actual Produced Water Throughput While Emissions Controls Operating = 20,192 MMBTU per year 20,192 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 20,192 MMBTU per year Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Emission Factors Produced Water Tank Pollutant Uncontrolled Controlled (Ib/bbl) (Ib/bbl) (Produced Water Throughput) (Produced Water Throughput) VOC 0,115005___.. 0.000305.. 0.000100 0.000007 0.000014 0.005750 0.000015 Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP Pollutant 0.000005 0.000000 0.000001 0.002003 0.000002 Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (lb/bbl) (Produced Water Throughput) (waste heat combusted) PM10 PM2.5 NOx CO Section 05 - Emissions Inventory 0.0680 0.0000 0.0000 1,3Ta#t12;3 Y(#[ IY.z:5...:.::1. 0.0003 Emission Factor Source Emission Factor Source 0.00105 Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) VOC PM10 PM2.5 NOx CO 314.83 314.83 15.74 314.83 15.74 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.69 0.69 0,69 0.69 0.69 2.87 2.87 2.87 2.87 2.87 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (Ibs/yearl (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 1668 1668 83 1668 83 547 547 27 547 27 36 36 2 36 2 74 74 4 74 4 219321 219321 10966 219321 10966 170 170 9 170 9 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart 0000 Storage Tank is not subject to NSPS 0000 See regulatory applicability worksheet for detailed analysis) 0.8338 0.2734 0.0180 0.0372 109.6606 0.0851 0.0417 0.0137 0.0009 0.0019 5.4830 0.0043 5,479,: 17 of 34 K:\PA\2017\17W E1114.CP1.xlsm Produced Water Storage Tank(s) Emissions Inventory Section 07- Initial and Periodic Sampling and Testing Requirements Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid water sample drawn at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor. See PS Memo 14-03, Questions 5.9 and 5.12 for additional guidance on testing. Does the company request a control device efficiency greater than 95%for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes i)peratar used aflrasYii l beratibn3�n�algs's to Mate the emission factorsfor tb po nt That analysis s Section 09- Inventory SCC Coding and Emissions Factors AIRS Point # 003 Process # SCC Code 01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses Pollutant PM10 PM2.5 NOx VOC CO Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP Uncontrolled Emissions Factor 0.00 0.00 0.01 2.7 0.02 0.01 0.00 0.00 0.00 0.95 0.00 Control % Units 0 lb/1,000 gallons liquid throughput O lb/1,000 gallons liquid throughput O lb/1,000 gallons liquid throughput 95 lb/1,000 gallons liquid throughput O lb/1,000 gallons liquid throughput 95 lb/1,000 gallons liquid throughput 95 Ib/1,000 gallons liquid throughput 95 l b/1,000 gallonsliquid throughput 95 lb/1,000 gallons liquid throughput 95 lb/1,000 gallons liquid throughput 95 lb/1,000 gallons liquid throughput 18 of 34 K:\PA\2017\17W E1114.CP1.xlsm Separator Venting Emissions Inventory Section 01- Administrative Information 'Facility AIRS ID: 123 County 9F6B Plant 003 Section 02- Equipment Description Details Detailed Emissions Unit Description: Produced vafei Emission Control Device Description: Enclosed Flare Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Primary Emissions - Separator Actual Throughput = Requested Permit Unlit Throughput Potential to Emit (PTE) Throughput Section 03 - Processing Rate Information for Emissions Estimates H 000,0 Barrels (bbl) per year 000:0.; Barrels (bbl) per year Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: _ -,-1844 Btu/scf (HHV) Volume of waste gas emitted per BBL of liquids throughput: 2+! scf/bbl Section 04- Emissions Factors & Methodologies Displacement Equation Ex = Q. MW • Xx/C MW 38.025487' Weight Helium CO2 N2 methane ethane 19:701€ 7.0110: §6833' propane isobutane n -butane isopentane n -pentane cyclopentane n -Hexane cyclohexane Other hexanes heptanes methylcyclohexane 224-TMP I Cj151 Benzene l 0.1479. Toluene Ethylbynzene Xylenes C8+ Heavies 2 0__327 0.0766 944 564 9.0295: 0485 1.0032: 0.0065. 0.0833 Total VOC Wt % 99.9999 55.8441 Ib/Ib-mol 1411.5 Btu/Scf (LHV) 19 of 34 K:\PA\2017\ 17WE1114.CP1.xlsm Separator Venting Emissions Inventory Emission Factors Separator Venting Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) (Liquid Throughput) (Liquid Throughput) Emission Factor Source VOC 0.11500 0.00030 0.00010 0.00001 0.00001 0.04006 0.00003 0.0058 0.0000 0.0000 0.0000 0,0000 0,0020 0.0000 Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP Emission Factor Source Pollutant Primary Control Device Uncontrolled Uncontrolled (Ib/MMBtu( lb/bbl (Waste Heat Combusted) (Gas Throughput) PM10 PM2.5 0,000 0.000 0.000 0.000 0,001 0.0075 5Ox NOx CO 0006 Section OS - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) PM10 PM2.5 5Ox NOx VOC CO 0.08 0,08 0.08 0.08 0.08 0.08 0.08 . 0.08 0.08 0.08 0.01 0.01 0.01 0.01 0.01 0.82 0.82 0.82 0.82 0.82 314.83 314.83 15.74 314.83 15.74 2.95 2.95 2.95 2.95 2.95 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (Has/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 16668 1668 83 1668 83 547 547 27 547 27 36 36 2 36 2 74 74 4 74 4 219321 219321 10966 219321 10966 170 170 9 170 9 0.833799094 0.273422962 0.018040278 0.037208073 109.660648 0.085127561 0.041689955 0.013671148 0.000902014 0.001860404 5.483032399 0.004256378 20 of 34 K:\PA\2017\17WE1114.CP1.xlsm Separator Venting Emissions Inventory Cell: A2 Comment: cdmoney: Enter the facility AIRS ID number (County/Plant/Point) if previously assigned by the Air Pollution Control Division (APCD). If you are reporting a. new point at a site with an existing County and Plant ID, fill in the known information. Cell: A7 Comment: cdmoney: Enter a detailed description of the emission unit (how many separators, type (high pressure, low pressure, vapor recovery tower (VRT), etc.) so this information can be copied directly into the equipment description in the permit. For example: One (1) low-pressure separator Cell: A9 Comment: cdmoney: Examples: Enclosed Flare during VRU downtime Enclosed Flare Open Flare Thermal Oxidizer Cell: A10 Comment: cdmoney: This value represents the requested overall control efficiency for a single control device. If the source is requesting a more complex control scenario, such as permitting for control device downtime or permitting for a backup control device with different control efficiency than the primary control device, this PA needs to be edited to address the unique control scenarios. One option is to create a worksheet for each control scenario and an additional worksheet for total emissions. Another option is to create additional tables within this worksheet for the other control scenario and total emissions. Cell: Al2 Comment: Use the appropriate Process Parameter based on how the emissions are estimated and engineer's judgment. Use Natural Gas Venting as a process parameter if: • The point has a PTE greater than 100 tpy of VOC, AND • the point includes a HP/HLP/LP separator OR Use Natural Gas Venting as a process parameter if: • The owner operator is requesting Natural Gas Venting as a process parameter, AND • The owner operator is willing to use a flow meter Use Liquids Throughput as a process parameter if: • the point has a PTE less than 100 tpy of VOC, or • the point is a VRT permitted by itself Cell: A14 Comment: This selection indicates whether or not the operator will have a gas meter installed and operational upon issuance of the permit. If not, the operator shall agree to install a meter within 180 days of startup. If the operator will not have a meter installed and operational upon startup, the "volume of waste gas emitted per BBL of liquids throughput" (i.e. the value specified in cell B31) shall be used to monitor gas volume. Cell: A39 Comment: This value represents the actual throughput Cell: A20 Comment: This value represents the requested separator gas volume or corresponding liquid throughput the operator will accept as a permit limit and the basis for the permitted emissions in a traditional construction permit. The requested limit must be based on the volume of liquid throughput (BBL per year) if the operator is not required to install a gas flow meter. If the operator is required to Install a gas flow meter, the requested limit must be based on volume of gas. The operator can request a throughput limit less than the gas production rate of the separator or total liquid throughput but this value will be the enforceable permitted limit and will be the basis for calculating requested emissions for the separator. For example, if a portion of the separator stream is being recycled as part of the process (e.g. via a VRU), then the requested throughput may be limited to the gas volume routed to flare or liquid throughput while emissions are muted to flare. If the source does not want to take credit for recycling (or the recycling is determined to not be part of the process), then the requested separator gas volume is the maximum vent rate at requested operating hours or total liquid throughput. Cell: A21 Comment: This value represents requested throughput. The "Potential to Emit (PTE) Throughput"' is the same as the "Requested Permit Limit Throughput" for this source type. Cell: A23 Comment: The information provided in this section will establish the basis to estimate secondary emissions that result from emissions controls that combust VOC and HAP emissions from the separator Cell: A25 Comment: Gas heating value is the amount of heat produced from the complete combustion of a unit of fuel. The higher (or gross) heating value is obtained when all products of combustion are cooled to the pre -combustion temperature, water vapor formed during combustion is condensed, and necessary corrections have been made. This value represents the maximum heat content of the separator gas emitted. This value is based on the site -specific gas sample if available, the modeled value, or the weighted average if this point represents more than one gas stream such as LP separator gas plus VRT gas. Cell: A26 Comment: This value represents the ratio of the volume of waste gas emitted from the separator(s) per barrel of condensate/crude oil produced. If a process simulator (i.e. ProMax, HYSYS, etc.) is used, then the volume of waste gas produced should be based on the TOTAL gas flow from the separation equipment as predicted by the model. This waste gas volume is then divided by the number of barrels used in the model run. For example, if the gas stream from the separator is recycled, then the scf/bbl ratio is: (flow rate recycled flow rate to flare) / (number of barrels used in the model run) If operator is measuring gas flow using a meter, this cell is left blank. Cell: A28 Comment: This section establishes the process rates that are the basis for; actual emissions and will be reported to the Division's emissions inventory system; requested permitted emissions that will become a limit in the permit issued; and the potential to emit used to establish if the facility should be considered a true minor, synthetic minor or major source under Colorado Regulation 3 permitting programs. Cell: A32 Comment: This equation maybe referenced in EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3). Where: 21 of 34 K:\PA\2017\ 17WE1114.CP1xlsm Separator Venting Emissions Inventory Ex = emissions of pollutant x Q= Volumetric flow rate/volume of gas processed MW = Molecular weight of gas = SG of gas • MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/Ib-cool) at 60F and 1 atm Cell: 836 Comment: The values input to this table represent the % by weight in the gas stream (i.e. if the value is 40%, then "40" must be input here) If additional pollutants must be added to this table based on the reported stream composition, the user can insert a row as follows: If pollutant is a VOC: -select the entire row that includes "Cu. Heavies" in the spreadsheet by right clicking on the row a next to column A -select "insert" from the drop down menu If pollutant is not a VOC: -select the entire row that includes "propane" in the spreadsheet by right clicking on the row R next to column A -select "insert" from the drop down menu Cell: A59 Comment: This must be 100% Cell: 864 Comment: When cell indicates "(lb/MMscf)": EF=Xxx MW x 10^6/C where: EF = emission factor (lb/MMscf) MW = Molecular weight of gas = SG of gas • MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/Ib-cool) at 60F and 1 atm When cell indicates "(lb/bbl)": EF= Xx x MW x GLR/C where: EF = emission factor (lb/bbl) MW = Molecular weight of gas = SG of gas * MW of air Xx = mass fraction of x in gas GLR = volume of waste gas emitted per barrel of liquids throughput (scf/bbl) C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm Note: GLR is referenced from the value input in Section 03 Cell: D73 Comment: NOx and CO emissions factors from AP -42 Table 1.4-1 may be used only when a thermal oxidizer is used to control emissions. Cell: B76 Comment: The operator should provide emissions factors for NOx, CO and PM10/PM2.5 which represent the post combustion emissions resulting from the emissions control device (e.g. secondary emissions). Ensure the emission factors are in the correct units of lb/MMBtu (convert within the cells to establish correct units if needed). Leave NOx, CO and PM10/PM2.5 E.F. blank if the unit is not controlled. Cell: C76 Comment: This column automatically converts emission factors from lb/MMBtu to lb/MMscf waste gas combusted since ongoing compliance demonstration for actual emissions will be calculated using actual waste gas volume multiplied by an emission factor. It is more straightforward to convert all emission factors into units correlating to the process limit. The lb/MMscf emission factors for NOx, CO and PM should be listed in the Notes to Permit Holder section of the permit. Cell: A84 Comment: All values contained In the emissions inventory section are automatically calculated based on the information provided in the preceding sections. Cell: E87 Comment: Secondary emissions from control devices are listed in the uncontrolled and controlled columns in this emissions inventory table. While secondary emissions are not generated until the emitting unit is controlled, the secondary emissions are not actually being controlled so it is appropriate to list the secondary emissions as uncontrolled. Also, by listing the secondary emissions under uncontrolled and controlled, facility emissions can be more clearly summarized and the facility source classification regarding true minor/synthetic minor/major status can be more logically assessed. 22 of 34 K:\PA\2017\ 17WE1114.CP1.xlsm Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: ;Christopher Keste. Package #: 370350 Received Date: 10/18/2017 Review Start Date: 1/1/2018 Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Horsetail 07 West Central Production Battery Physical Address/Locatio SENW quadrant of Section 7, Township 10N, Range 57W, in Weld County, Colorado Type of Facility: Exploration & Production Well Pad What industry segment? tail & Natural Gas Production & Processing _ Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? on Monoxide (CO) Whiting Oil and Gas Corporation 123 9F66 Weld Section 02 - Emissions Units In Permit Application Quadrant Section Township Range EN W 7 10N 7 P©a iculate Matter (PM) Ene (NOx & VOC) AIRS Point # Emissions Source Type Equipment Name Emissions Control? permit # Issuance # Self Cert Required? Action Engineering Remarks 001 Separator Venting SEP01throughSep-08 Yes 17WE1114 1 Yes°ermttInitial Issuance 002 Vapor RecoveryTower (VRT) - SEP-26 and SEP-27 - Yes 17WE1115 1 Yes Permit Initial Issuance 003 Pro ducedWaterTank. PW-01 through PW-08 Yes 17WE1116 1 Yes "Permit101tial Issuance 004 - Other (Explain) DUST -01 Yes 17W E1117.XP i Na APEN Required /Permit Exempt Fugitive Dust 005 Crude Oil Tank- TK 01 through TK-16 Yes 17WE1118 1 Yes permit initial issuance 006 Natural Gas RICE ENG-02 : Yes - 17WE1119 - 1 Yes Permit Initial Gssuance 007 Natural Gas RICE ENG-01 - yes 17WE1120 1 Yes Permit Initial Issuance. Section 03 - Description of Project Section 04 - Public Comment Requirements Is Public Comment Required? If yes, yes, why? Greater than 50 tons per year (sac Attainment Area Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) SO2 Yes_::::;:_. NOx CO VOC PM2.5 PM10 TSP HAPs ❑ ❑ ❑ ❑ Colorado Air Permitting Project Non -Attainment New Source Review (NANSR) Is this stationary source a major source? ;;', , If yes, explain what programs and which pollutants here: 5O2 NOx Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) CO VOC PM2.5 PM10 TSP HAPs El El Separator Venting Emissions Inventory Section 01- Administrative Information Facility AIRs ID: 123 9F68'.'. Plant Point Section 02- Equipment Description Details Detailed Emissions Unit Description: Eight(8}Ywgphase separatorsand eigl Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: 503: MMscf per year 9$ MMscf per year 109.5 MMscf per year Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare) Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL of liquids throughput: Section 04- Emissions Factors & Methodologies Description The 2 phase emission factor Displacement Equation Ex =Q• MW• Xx/C 545 Btu/scf(HHV) Weight % Helium CO2 N2 methane ethane 00000' 4.4079. 33532. ''. 31.9683 14.0621 propane isobutane n -butane isopentane n -pentane cyclopentane n -Hexane cyclohexane Other hexanes heptanes methylcyclohexane 224-TMP Benzene Toluene Ethylbenzene Xylenes C8+ Heavies 47 2:8294 9.5990 5 52 .7728 472 70 522 0858 i7 €7:2632: 0208 Total VOC Wt % 100.0003 46.2088 scf/bbl Ib/Ih-mol 1411.5 Btu/Scf (LHV) 3 of 34 K:\PA\2017\17WE1114.CP1.xlsm Separator Venting Emissions Inventory IMEITECE Pollutant Separator Venting Uncontrolled (Ib/MMscf) Controlled (lb/MMscf) 34735.8499 MIME IIMEITI 464,7102 106.5180 alEC glIOM Pollutant Section 05 - Emissions Inventory 580.9254 61.7910 9.8926 29.0463 Primary Control Device Uncontrolled (lb/MMBtu) (Waste Heat Comhusted) Uncontrolled lb/MMscf 0.0075 0,0075 00006 3.0680. 0.3100 (Gas Throughput) 0.909 105.074 Emission Factor Source Emission Factor Source Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) PM10 PM2.5 SOx NOx VOC CO 0.63 0:63 0.63 0.63 0.63 0.63 0.63 0,63 0.63 0.63 0.05 0.05 0.05 0.05 0.05 5.88 5.88 5.88 5.88 5.88 1901.79 1901.79 95.09 1901.79 95.09 24.51 24.51 24.51 24.51 24.51 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year( (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 7062 7062_ 353 7062 353 50886 50886 2544 50886 2544 11664 11664 583 11664 583 21665 21665 1083 21665 1083 63611 63611 3181 63611 3181 6766 6766 338 6766 338 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section 10/11.B, G Regulation 7, Section XVII.8.2.e (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Source requires a permit Source is subject to Regulation 7, Section XVII.B.2, G The control device for this separator is subject to Regulation 7, Section XVII.B.2.e 3.531218984 25.4428855 5.831861656 10.83236406 31.8056647 3.38305595 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 under this AIRS ID, and should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year? If yes, the permit will contain: -An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. -A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. Will the operator -have a meter installed and operational upon startup of this point? No If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes 0.176560949 1.272144275 0.291593083 0.541618203 1.590283235 0.169152797 4 of 34 K:\PA\2017\17W E1114.CP1.xlsm Separator Venting Emissions Inventory Section 09 - inventory SCC Coding and Emissions Factors AIRS Point # Process # SCC Code 001 01 3-10-001-60 Flares Uncontrolled Emissions Pollutant Factor Control % Units PM10 11.51 0 lb/MMSCF PM2.5 11.51 0 Ib/MMSCF SOx 0.91 0 Ib/MMSCF NOx 105.07 0 Ib/MMSCF VOC 34735.85 95 Ib/MMSCF CO 437.57 0 Ib/MMSCF Benzene 64.50 95 lb/MMSCF Toluene 464.71 95 Ib/MMSCF Ethylbenzene 106.52 95 Ib/MMSCF Xylene 197.85 95 Ib/MMSCF n -Hexane 580.93 95 ib/MMSCF 224 TMP 61.79 95 ib/MMSCF 5 of 34 K:\PA\2017\17WE1114.CP1.xism Separator Venting Emissions Inventory Cell: A2 Comment: cdmoney: Enter the facility AIRS ID number (County/Plant/Point) if previously assigned by the Air Pollution Control Division (APCD). If you are reporting a new point at a site with an existing County and Plant ID, fill in the known information. Cell: A7 Comment: cdmoney: Enter a detailed description of the emission unit (how many separators, type (high pressure, low pressure, vapor recovery tower (VRT), etc.) so this information can be copied directly into the equipment description in the permit. For example: One (1) low-pressure separator Cell: A9 Comment: cdmoney: Examples: Enclosed Flare during VRU downtime Enclosed Flare Open Flare Thermal Oxidizer Cell: A10 Comment: cdmoney: This value represents the requested overall control efficiency for a single control device. If the source is requesting a more complex control scenario, such as permitting for control device downtime or permitting for a backup control device with different control efficiency than the primary control device, this PA needs to be edited to address the unique control scenarios. One option is to create a worksheet for each control scenario and an additional worksheet for total emissions. Another option is to create additional tables within this worksheet for the other control scenario and total emissions. Cell: Al2 Comment: Use the appropriate Process Parameter based on how the emissions are estimated and engineers judgment. Use Natural Gas Venting as a process parameter if: • The point has a PTE greater than 100 tpy of VOC, AND • the point includes a HP/HLP/LP separator OR Use Natural Gas Venting as a process parameter if: • The owner operator is requesting Natural Gas Venting as a process parameter, AND • The owner operator is willing to use a flow meter Use Liquids Throughput as a process parameter if: • the point has a PTE less than 100 tpy of VOC, or • the point is a VRT permitted by itself Cell: A14 Comment: This selection indicates whether or not the operator will have a gas meter installed and operational upon issuance of the permit. If not, the operator shall agree to install a meter within 180 days of startup. If the operator will not have a meter installed and operational upon startup, the "volume of waste gas emitted per BBL of liquids throughput" (i.e. the value specified in cell B31) shall be used to monitor gas volume. Cell: A19 Comment: This value represents the actual throughput Cell: 020 Comment: This value represents the requested separator gas volume or corresponding liquid throughput the operatorwill accept as a permit limit and the basis for the permitted emissions in a traditional construction permit. The requested limit must be based on the volume of liquid throughput (BBL per year) if the operator is not required to install a gas flow meter. If the operator is required to install a gas flow meter, the requested limit must be based on volume of gas. The operator can request a throughput limit less than the gas production rate of the separator or total liquid throughput but this value will be the enforceable permitted limit and will be the basis for calculating requested emissions for the separator. For example, if a portion of the separator stream is being recycled as part of the process (e.g. via a VRU), then the requested throughput maybe limited to the gas volume routed to flare or liquid throughput while emissions are muted to flare. If the source does not want to take credit for recycling (or the recycling is determined to not be part of the process), then the requested separator gas volume is the maximum vent rate at requested operating hours or total liquid throughput. Cell: A21 Comment: This value represents requested throughput. The "Potential to Emit (PTE) Throughput" is the same as the "Requested Permit Limit Throughput" for this source type. Cell: A23 Comment: The information provided in this section will establish the portion of the gas stream to be recycled. Cell: A25 Comment: The vapor recovery unit (VRU) is considered process equipment if 100% collection is assumed while the VRU is operating. If source is requesting less than 100% collection efficiency while the VRU is operational, it is likely the VRU is not considered process and should be addressed as a control device. Refer to PS -Memo 99-03 for additional guidance. Cell: A27 Comment: The information provided in this section will establish the basis to estimate secondary emissions that result from emissions controls that combust VOC and HAP emissions from the separator Cell: A29 Comment: Gas heating value is the amount of heat produced from the complete combustion of a unit of fuel. The higher (or gross) heating value is obtained when all products of combustion are cooled to the pre -combustion temperature, water vapor formed during combustion is condensed, and necessary corrections have been made. This value represents the maximum heat content of the separator gas emitted. This value is based on the site -specific gas sample if available, the modeled value, or the weighted average if this point represents more than one gas stream such as LP separator gas plus VRT gas. Cell: A30 Comment: This value represents the ratio of the volume of waste gas emitted from the separator(s) per barrel of condensate/crude oil produced. If a process simulator (i.e. ProMax, HYSYS, etc.) is used, then the volume of waste gas produced should be based on the TOTAL gas flow from the separation equipment as predicted by the model. This waste gas volume is then divided by the number of barrels used in the model run. For example, if the gas stream from the separator is recycled, then the scf/bbl ratio is: (flow rate recycled flow rate to flare) / (number of barrels used in the model run) If operator is measuring gas flow using a meter, this cell is left blank. Cell: A32 6 of 34 K:\PA\2017\ 17WE1114.CP1.xlsm Separator Venting Emissions Inventory Comment: This section establishes the process rates that are the basis for; actual emissions and will be reported to the Division's emissions inventory system; requested permitted emissions that will become a limit in the permit issued; and the potential to emit used to establish if the facility should be considered a true minor, synthetic minor or major source under Colorado Regulation 3 permitting programs. Cell: A35 Comment: Enter a detailed description of basis for emission calculations. Include details of the process setup and any sample analyses used (include where the sample was pulled, date of the sample, etc.). If a model is used, indicate which type of model and basis for model inputs. For example: This VRT is located downstream of an inlet (high pressure) separator and low pressure separator where the liquids undergo gas/liquid separation prior to the VRT. A pressurized liquid sample was taken from the low pressure separator at 32 psig; 90.3 deg F (sampled: 2/15/201.7) and modeled, using ProMax Ver 4.0, through the VRT. The mass fractions, molecular weight (MW), and vent rate of the waste gas stream are derived from the modeled VRT gas stream "VRT Vapors to Bumer". The ProMax model was run based on 1 bbl/day condensate throughput. Cell: A38 Comment: This equation may be referenced in EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3). Where: Ex = emissions of pollutantx Q = Volumetric flow rate/volume of gas processed MW = Molecular weight of gas = SG of gas e MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/Ib-mol) at 60F and 1 atm Cell: B42 Comment: The values input to this table represent the % by weight in the gas stream (i.e. if the value is 40%, then "40" must be input here) If additional pollutants must be added to this table based on the reported stream composition, the user can insert a row as follows: If pollutant is a VOC: -select the entire row that includes "C8+ Heavies" in the spreadsheet by right clicking on the row p next to column A -select "insert" from the drop down menu If pollutant is not a VOC: -select the entire row that includes "propane" in the spreadsheet by right clicking on the row ff next to column A -select "insert" from the drop down menu Cell: A65 Comment: This must be 100% Cell: 070 Comment: When cell indicates "(Ib/MMscf)": EF = Xxx MWx 10"6/C where: EF = emission factor (lb/MMscf) MW = Molecular weight of gas = SG of gas * MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/Ib-mol) at 60F and 1 atm When cell indicates "(lb/bbl)": EF = XxxMW x GLR/C where: EF = emission factor (Ib/bbl) MW = Molecular weight of gas = SG of gas * MW of air Xx = mass fraction of x in gas GLR = volume of waste gas emitted per barrel of liquids throughput (scf/bbl) C = molar volume of ideal gas (379 scf/Ib-mol) at 60F and 1 atm Note: GLR is referenced from the value input in Section 03 Cell: D79 Comment: NOx and CO emissions factors from AP -42 Table 1.4-1 may be used only when a thermal oxidizer is used to control emissions. Cell: 882 Comment: The operator should provide emissions factors for NOx, CO and PM10/PM2.5 which represent the post combustion emissions resulting from the emissions control device (e.g. secondary emissions). Ensure the emission factors are in the correct units of lb/MMBtu (convert within the cells to establish correct units if needed). Leave NOx, CO and PM10/PM2.5 E.F. blank if the unit is not controlled. Cell: C82 Comment: This column automatically converts emission factors from lb/MMBtu to lb/MMscf waste gas combusted since ongoing compliance demonstration for actual emissions will be calculated using actual waste gas volume multiplied by an emission factor. It is more straightforward to convert all emission factors into units correlating to the process limit. The lb/MMscf emission factors for NOx, CO and PM should be listed in the Notes to Permit Holder section of the permit. Cell: A90 Comment: All values contained in the emissions inventory section are automatically calculated based on the information provided in the preceding sections. Cell: E93 Comment: Secondary emissions from control devices are listed in the uncontrolled and controlled columns in this emissions inventory table. While secondary emissions are not generated until the emitting unit is controlled, the secondary emissions are not actually being controlled so it is appropriate to list the secondary emissions as uncontrolled. Also, by listing the secondary emissions under uncontrolled and controlled, facility emissions can be more clearly summarized and the facility source classification regarding true minor/synthetic minor/major status can be more logically assessed. Cell: A112 Comment: cdmoney: This section will be automatically populated based on the regulatory analysis worksheet. Cell: A134 Comment: cdmoney: 7 of 34 K:\PA\2017\17WE1114.CP1.xlsm Separator Venting Emissions Inventory This section should include discussion to support decisions made throughout this document if there are anomalies or unique circumstances or any area that warrant a more thorough evaluation and/or explanation. For example, if unique modeling was performed to develop the emission factor or if there is a unique process set-up that impacts emission factors and/or regulatory applicability. 8 of 34 K:\PA\2017\ 17WE1114.CP1.xlsm Separator Venting Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)? 'Source requires a permit NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section II.D.2)? 'You have indicated that source is in the Attainment Area Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? 'Source is subject to Regulation 7, Section XVII.B.2, G Section XVII.B.2 —General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G - Emissions Control Alternative Emissions Control (Optional Section) a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? 'The control device for this separator is subject to Regulation 7, Section XVll.B.2.e Section XVII.B.2.e — Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend," "may," "should," and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must' and "required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Yes' Source Req Source Req gaga The control Separator Venting Emissions Inventory Section 01- Administrative Information Fadlity AIRs ID: 123 County 9F60 Plant 002 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency % Limited Process Parameter rsiNIMORIFINEEI Section 03 - Processing Rate Information for Emissions Estimates Prenary Emissions - Separator Actual Throughput Requested Permit Limit Throughput Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: 271,560.! Barrels (bbl) per year 271,560.0 Barrels (bbl) per year 271,560 Barrels (661) per year ire equipment is being permitted so that the VRT tnay.. downtime/bypass,. enclosed flare during VRU bypass. 2,263,000 Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare) Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL of? liquids throughput: Section 04 - Emissions Factors & Methodologies Displacement Equation Ex= CO MW • Xx/C } Btu/scf 7`. scf/bbl _..... _ 4:: Weight % Helium CO2 N2 methane ethane propane isobutane n -butane isopentane n -pentane cyclopentane n -Hexane cyclohexane Other hexanes heptanes methylcyclohexane 224 -IMP Benzene Toluene Ethylbenzene Xylenes CB+ Heavies 0.6161 7 22.3170 35.1385 5.4290 21_.1585 4.7352 6.0344 0.6835 0.7385 0:6986 0.0950 0:0786 0.0633 0.0115 0.0314 0.3295 100.00 Total VOC Wt 75.25 Ib/Ib-mol 2008 10 of34 K:\PA\2017\17W E1114.CP1.xlsm Separator Venting Emissions Inventory Emission Factors Separator Venting Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) (Liquid Throughput) aiquid Throughput) VOC 2.7665 0.0029 0.0025 0.1383 0.0001 0.0001 0.0000 0.0001 0.0013 0.0002 Benzene Toluene Ethylbenzene 00004 0.0012 0.0251 0.0035 Xylene n -Hexane 224 TMP Emission Factor Source Emission Factor Source Pollutant Uncontrolled (Ib/MMBtu) (Waste Heat Combusted) Primary Control Device Uncontrolled lb/bbl (Gas Throughput) PM10 PM2.5 0.001 0.001 0.000 0.000 00075::: _.. 0.0006- 0.0580 0,3100 50x NOx CO 0.01996 Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) PM10 PM2.5 500 NOx VOC CO 0.07 0.07 0.07 0.07 0.07 0.07 0.07 0.07 0.07 0.07 0.01 0.01 0.01 0.01 0.01 0.65 0.65 0.65 0.65 0.65 375.64 375.64 18.78 375.64 18.78 2.71 2.71 2.71 2.71 2.71 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (Ibs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 IMP 785 785 39 785 39 692 692 35 692 35 115 115 6 115 6 313 313 16 313 16 6824 6824 341 6824 341 958 958 48 958 48 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XVII.B, G Regulation 7, Section XVII.8.2.e (See regulatory applicability worksheet for detailed analysis) Facility attainment -area status has not been established yet Source is subject to Regulation 7, Section XVII.8.2, G The control device forthis separator is subject to Regulation 7, Section XVII.B.2.e Section 07 - Initial and Periodic Sampling and Testing Requirements Using Liquid Throughput to Monitor Compliance Does the company use site specific emission factors based on a pressurized liquid sample (Sampled upstream of the equipment covered under this AIRS ID) and process simulation to estimate emissions? This sample should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to collect a site -specific liquid sample and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes 11 of 34 K:\PA\2017\17W E1114.CP1.xlsm Separator Venting Emissions Inventory Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # Process # SCC Code 002 01 3-10-001-29 Oil & Gas Production: Gas/liquid separation Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.52 0 16/1000661 PM2.5 0.52 0 Ib/10006bl 5Ox 0.04 0 Ib/1000bbl NOx 4.77 0 lb/1000bbl VOC 2766.51 95 16/1000661 CO 19.96 0 16/1000661 Benzene 2.89 95 lh/1000bbl Toluene 2.55 95 Ib/1000661 Ethylbenzene 0.42 95 16/1000661 Xylene 1.15 95 Ib/1000bbl n -Hexane 25.13 95 Ib/1000bbl 224 TMP 3.53 95 Ib/1000bbl 12 of 34 K:\PA\2017\17WE1114.CP1.xlsm Separator Venting Emissions Inventory Cell: A2 Comment: cdmoney: Enter the facility AIRS ID number (County/Plant/Point) if previously assigned by the Air Pollution Control Division (APCD). If you are reporting a new point at a site with an existing County and Plant ID, fill in the known information. Cell: A7 Comment: cdmoney: Enter a detailed description of the emission unit (how many separators, type (high pressure, low pressure, vapor recovery tower (VRT), etc.) so this information can be copied directly into the equipment description in the permit. For example: One (1) low-pressure separator Cell: A9 Comment: cdmoney: Examples: Enclosed Flare during VRU downtime Enclosed Flare Open Flare Thermal Oxidizer Cell: A10 Comment: cdmoney: This value represents the requested overall control efficiency for a single control device. If the source is requesting a more complex control scenario, such as permitting for control device downtime or permitting for a backup control device with different control efficiency than the primary control device, this PA needs to be edited to address the unique control scenarios. One option is to create a worksheet for each control scenario and an additional worksheet for total emissions. Another option is to create additional tables within this worksheet for the other control scenario and total emissions. Cell: Al2 Comment: Use the appropriate Process Parameter based on how the emissions are estimated and engineer's judgment. Use Natural Gas Venting as a process parameter if: • The point has a PTE greater than 100 tpy of VOC, AND • the point includes a HP/HLP/LP separator OR Use Natural Gas Venting as a process parameter if: • The owner operator is requesting Natural Gas Venting as a process parameter, AND • The owner operator is willing to use a flow meter Use Uquids Throughput as a process parameter if: • the point has a PTE less than 100 tpy of VOC, or • the point is a VRT permitted by itself Cell: A14 Comment: This selection indicates whether or not the operator will have a gas meter installed and operational upon issuance of the permit. If not, the operator shall agree to install a meter within 180 days of startup. If the operator will not have a meter installed and operational upon startup, the "volume of waste gas emitted per BBL of liquids throughput" (i.e. the value specified in cell B31) shall be used to monitor gas volume. Cell: Alt Comment: This value represents the actual throughput Cell: A20 Comment: This value represents the requested separator gas volume or corresponding liquid tlroughput the operator will accept as a permit limit and the basis for the permitted emissions in a traditional construction permit. The requested limit must be based on the volume of liquid throughput (BBL per year) if the operator is rot required to install a gas flow meter. If the operator is required to install a gas flow meter, the requested limit must be based on volume of gas. The operator can request a throughput limit less than the gas production rate of the separator or total liquid throughput but this value will be the enforceable permitted limit and will be the basis for calculating requested emissions for the separator. For example, if a portion of the separator stream is being recycled as part of the process (e.g. via a VRU), then the requested throughput maybe limited to the gas volume routed to flare or liquid throughput while emissions are routed to flare. If the source does not want to take credit for recycling (or the recycling is determined to not be part of the process), then the requested separator gas volume is the maximum vent rate at requested operating hours or total liquid throughput. Cell: A21 Comment: This value represents requested throughput. The "Potential to Emit (PIE) Throughput" is the same as the "Requested Permit Limit Throughput" for this source type. Cell: A23 Comment: The information provided in this section will establish the portion of the gas stream to be recycled. Cell: A25 Comment: The vapor recovery unit (VRU) is considered process equipment if 100% collection is assumed while the VRU is operating. If source is requesting less than 100% collection efficiency while the VRU is operational, it is likely the VRU is not considered process and should be addressed as a control device. Refer to PS -Memo 99-03 for additional guidance. Cell: A27 Comment: The information provided in this section will establish the basis to estimate secondary emissions that result from emissions controls that combust VOC and HAP emissions from the separator Cell: A29 Comment: Gas heating value is the amount of heat produced from the complete combustion of a unit of fuel. The higher (or gross) heating value is obtained when all products of combustion are cooled to the pm -combustion temperature, water vapor formed during combustion is condensed, and necessary corrections have bee. made. This value represents the maximum heat content of the separator gas emitted. This value is based on the site -specific gas sample if available, the modeled value, or the weighted average if this point represents more than one gas stream such as LP separator gas plus VRT gas. Cell: A30 Comment: This value represents the ratio of the volume of waste gas emitted from the separator(s) per barrel of condensate/crude oil produced. If a process simulator (i.e. ProMax, HYSYS, etc.) is used, then the volume of waste gas produced should be based on the TOTAL gas flow from the separation equipment as predicted by the model. This waste gas volume is then divided by the number of barrels used in the model run. For example, if the gas stream from the separator is recycled, then the scf/bbl ratio is: (flow rate recycled +flow rate to flare) / (number of barrels used in the model run) If operator is measuring gas flow using a meter, this cell is left blank. Cell: A32 13 of 34 K:\PA\2017\ 17WE1114.CP1.xlsm Separator Venting Emissions Inventory Comment: This section establishes the process rates that are the basis for; actual emissions and will be reported to the Division's emissions inventory system; requested permitted emissions that will become a limit in the permit issued; and the potential to emit used to establish if the facility should be considered a true minor, synthetic minor or major source under Colorado Regulation 3 permitting programs. Cell: A35 Comment: Enter a detailed description of basis for emission calculations. Include details of the process setup and any sample analyses used (include where the sample was pulled, date of the sample, etc.). If a model is used, indicate which type of model and basis for model inputs. For example: This VRT is located downstream of an inlet (high pressure) separator and low pressure separator where the liquids undergo gas/liquid separation prior to the VRT. A pressurized liquid sample was taken from the low pressure separator at 32 psig; 90.3 deg F (sampled: 2/15/2017) and modeled, using ProMax Ver 4.0, through the VRT. The mass fractions, molecular weight (MW), and vent rate of the waste gas stream are derived from the modeled VRT gas stream "VRT Vapors to Burner". The ProMax model was run based on 1 bbl/day condensate throughput. Cell: A38 Comment: This equation may be referenced in EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10- Displacement Equation (10.4-3). Where: Ex = emissions of pollutant x = Volumetric flow rate/volume of gas processed MW = Molecular weight of gas = SG of gas u MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm Cell: 842 Comment: The values input to this table represent the % by weight in the gas stream (i.e. If the value is 40%, then "40" must be input here) If additional pollutants must be added to this table based on the reported stream composition, the user can insert a mw as follows: If pollutant is a VOC: -select the entire row that includes "Co* Heavies" in the spreadsheet by right clicking on the row If next to column A -select "insert" from the drop down menu if pollutant is not a VOC: -select the entire row that includes "propane" in the spreadsheet by right clicking on the row 8 next to column A -select "insert" from the drop down menu Cell: A65 Comment: This must be 100% Cell: 070 Comment: When cell indicates "(lb/MMscf)": EF = Xxx MW x 10A6 /C where: EF = emission factor (lb/MMscf) MW = Molecular weight of gas = SG of gas MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/lb-mol) at 601 and 1 atm When cell indicates "(16/661)": EF= Xxx MW x GLR/C where: EF = emission factor (lb/bbl) MW = Molecular weight of gas = SG of gas s MW of air Xx = mass fraction of x in gas GLR = volume of waste gas emitted per barrel of liquids throughput (scf/bbl) C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm Note: GLR is referenced from the value input in Section 03 Cell: D79 Comment: NOx and CO emissions factors from AP -42 Table 1.4-1 may be used only when a thermal oxidizer is used to control emissions. Cell: B82 Comment: The operator should provide emissions factors for NOx, CO and PM10/PM2.5 which represent the post combustion emissions resulting from the emissions control device (e.g. secondary emissions). Ensure the emission factors are in the correct units of lb/MMBtu (convert within the cells to establish correct units if needed). Leave NOx, CO and PM10/PM2.5 E.F, blank if the unit is not controlled. Cell: C82 Comment: This column automatically converts emission factors from Ib/MMBtu to lb/MMscf waste gas combusted since ongoing compliance demonstration for actual emissions will be calculated using actual waste gas volume multiplied by an emission factor. It is more straightforward to convert all emission factors into units correlating to the process limit. The Ib/MMscf emission factors for NOx, CO and PM should be listed in the Notes to Permit Holder section of the permit. Cell: A90 Comment: All values contained in the emissions inventory section are automatically calculated based on the information provided in the preceding sections. Cell: E93 Comment: Secondary emissions from control devices are listed in the uncontrolled and controlled columns in this emissions inventory table. While secondary emissions are not generated until the emitting unit is controlled, the secondary emissions are not actually being controlled so it is appropriate to list the secondary emissions as uncontrolled. Also, by listing the secondary emissions under uncontrolled and controlled, facility emissions can be more clearly summarized and the facility source classification regarding true minor/synthetic minor/major status can be more logically assessed. Cell: A112 Comment: cdmoney: This section will be automatically populated based on the regulatory analysis worksheet. Cell: A130 Comment: cdmoney: 14 of 34 K:\PA\2017\17WE1114.CP1.xlsm Separator Venting Emissions Inventory This section should include discussion to support decisions made throughout this document if there are anomalies or unique circumstances or any area that warrant a more thorough evaluation and/or explanation. For example, if unique modeling was performed to develop the emission factor or if there is a unique process set-up that impacts emission factors and/or regulatory applicability. - 15 of 34 K:\PA\2017\17WE1114.CP1.xlsm Separator Venting Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in Me Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? 'Source requires a permit NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section ll.D.1.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section II.D.2)? Not enough information Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? Source is subject to Regulation 7, Section XVII.B.2, G Section XVII.B.2 —General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G -Emissions Control Alternative Emissions Control (Optional Section) a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? 'The control device for this separator is subject to Regulation 7, Section XVII.B.2.e Section XVII.B.2.e—Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend," "may," "should," and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself Yes Yes 1. Source Req Source Req The control Produced Water Storage Tank(s) Emissions Inventory Section 01- Administrative Information Facility AIRS ID: 123 _I 9260 County Plant Section 02- Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Enclosed Flare Description: Requested Overall VOC & HAP Control Efficiency 16: roducedlwate Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions • Storage Tank(s) Actual Produced Water Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Produced Water Throughput = Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per BBL of liquids produced= """ '-', 2" scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 008", Barrels (bbl) per year i Barrels )bbl) per year Barrels (bbl) per year Btu/sd 1693 Actual Produced Water Throughput While Emissions Controls Operating = 5,475,000;:. 20,192 MMBTU per year 20,192 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 20,192 MMBTU per year Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Emission Factors Produced Water Tank Pollutant Uncontrolled Controlled (Ib/bbl) (Ib/bbl) (Produced Water Throughput) (Produced Water Throughput) VOC 0.11500 0.000305 0.000110..'''ll.. 0.000007.'- 0.005750 0.000015 0.000005 Benzene Toluene Ethylbenzene 0.000000 0.000001 0.002003 0.000002 Xylene 0.000014 n -Hexane 224 TMP 0.000031 Pollutant Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (lb/bbl) (waste heat combusted) (Produced Water Throughput) Emission Factor Source Emission Factor Source PMDO PM2.5 0.0075 0.0075 0,0680...,,:.:. 0.0000 0.0000 0.0003 NOx CO 0.00105 Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) VOC 314.83 314.83 15.74 314.83 15.74 PM10 0.08 0.08 0.08 0.08 0.08 PM2.5 0.08 0.08 0.08 . - 0.08 0.08 NOx 0.69 0.69 0.69 0.69 0.69 CO 2.87 2.87 2.87 2.87 2.87 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 1668 1668 83 1668 83 Toluene 547 547 27 547 27 Ethylbenzene 36 36 2 36 2 Xylene 74 74 4 74 4 n -Hexane 219321 219321 10966 219321 10966 224 TMP 170 170 9 170 9 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section )(VII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank -is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart 0000 Storage Tank is not subject to NSPS 0000 (See regulatory applicability worksheet for detailed analysis) 0.8338 0.2734 0.0180 0.0372 109.6606 0.0851 0.0417 0.0137 0.0009 0.0019 5.4830 0.0043 17 of 34 K:\PA\2017\ 17WE1114.CP1.xlsm Produced Water Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use a site specific emissions factor to estimate emissions? ,. If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid water sample drawn at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered representative which generally meanssite-specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor. See PS Memo 14-03, Questions 5.9 and 5.12 for additional guidance on testing. Does the company request a control device efficiency greater than 95% for a flare or combustion device? ti If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08- Technical Analysis Notes Operator'. used a flash liberation analysis to coins he emission factor Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 003 That analysis is on the neztsheat of this file. Process # SCC Code 01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/1,000 gallons liquid throughput PM2.5 0.00 0 lb/1,000 gallons liquid throughput NOx 0.01 0 lb/1,000 gallons liquid throughput VDC 2.7 95 lb/1,000 gallons liquid throughput CO 0.02 0 lb/1,000 gallons liquid throughput Benzene 0.01 95 lb/1,000 gallons liquid throughput Toluene 0.00 95 lb/1,000 gallons liquid throughput Ethylbenzene 0.00 95 lb/1,000 gallons liquid throughput Xylene 0.00 95 Ib/1,000 gallons liquid throughput n -Hexane 0.95 95 lb/1,000 gallons liquid throughput 224 TMP 0.00 95 lb/1,000 gallons liquid throughput 18 of 34 K:\PA\2017\17WE1114.CPl.xlsm Separator Venting Emissions Inventory Section 01- Administrative Information Facility AIRS ID: County 9F6B Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Produced'' Emission Control Device Description: Enclosedflare Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter tankflash lberationsanalysis co ions. Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Throughput 5,475,000.0;: Barrels (bbl) per year 5,475,000.0: Barrels (bbl) per year 0{ Barrels (bbl) per year Secondary Emissions - Combustion Device(s) for Air Pollution Contrail Separator Gas Heating Value: Volume of waste gas emitted per BBL of liquids throughput: Section 04 - Emissions Factors & Methodologies Displacement Equation Ex=Q'MW'Xx/C 1844: Btu/scf (HHV) scf/bbl MW 39.025997 Weight % Helium 0.0000'. CO2 ? ]5.1432 N2 2.3002: methane S 13.7714 ethane 7.0119' propane 4 6833 isobutane 0:2212 n -butane ➢..9281 isopentane <. 01327! n -pentane '.'...0:.:1911- cyclopentane 0.0766: n -Hexane 19 4517: 1clohexane L_.fl.0195'. Other hexanes < 10.3994 heptanes 19-.3564 methylcyclohexane 0.0295 224-TMP 0.0151 Benzene 0:1479 Toluene 0.0485'.. Ethylbenzene 00032. Xylenes 0 0066'. C8+ Heavies 00833 Total VOC Wt % 99.9999 55.8441 6/16-mal 1411.5 Btu/Scf (U -IV) 19 of 34 K:\PA\2017\17WE1114.CP1.xlsm Separator Venting Emissions Inventory Emission Factors Separator Venting Pollutant Uncontrolled Controlled (Ih/bbl) (lb/bbl) (Liquid Throughput) (Liquid Throughput) Emission Factor Source Voc 0.11500 0.00030 0.00010 0.00001 0.00001 0.04006 0.00003 0.0058 Benzene Toluene 0.0000 0.0000 0.0000 0.0000 0.0020 0.0000 Ethylbenzene Xylene n -Hexane 224 TMP Emission Factor Source Pollutant Primary Control Device Uncontrolled Uncontrolled (Ib/MMBtu) lb/bbl (Waste Heat Combusted) (Gas Throughput) PM10 PM2.5 00075_, 00©75 5.0006 o ass0 0.3100 0.000 0.000 - 0.000 0.000 0.001 SOx NOx CO Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) PM10 PM2.5 SOx Non VOC CO 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.01 0.01 0.01 0.01 0.01 0.82 0.82 0.82 0.82 0.82 314.83 314.83 15.74 314.83 15.74 2.95 2.95 2.95 2.95 2.95 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled )lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene xylene n -Hexane 224 TMP 1668 1668 83 1668 83 547 547 27 547 27 36 36 2 36 2 74 74 4 74 4 219321 219321 10966 219321 10966 170 170 9 170 9 0.833799094 0.273422962 0.018040278 0.037208073 109.660648 0.085127561 0.041689955 0.013671148 0.000902014 0.001860404 5.483032399 0.004256378 20 of 34 K:\PA\2017\17WE1114.CP1.xlsm Separator Venting Emissions Inventory Cell: A2 Comment: cdmoney: Enter the facility AIRS ID number (County/Plant/Point) if previously assigned by the Air Pollution Control Division (APCD). If you are reporting a new point at a site with an existing County and Plant ID, fill in the known information. Cell: A7 Comment: cdmoney: Enter a detailed description of the emission unit (how many separators, type (high pressure, low pressure, vapor recovery tower (VRT), etc.) so this information can be copied directly into the equipment description in the permit. For example: One (1) low-pressure separator Cell: A9 Comment: cdmoney: Examples: Enclosed Flare during VRU downtime Enclosed Flare Open Flare Thermal Oxidizer Cell: A10 Comment: cdmoney: This value represents the requested overall control efficiency for a single control device. If the source is requesting a more complex control scenario, such as permitting for control device downtime or permitting for a backup control device with different control efficiency than the primary control device, this PA needs to be edited to address the unique control scenarios. One option is to create a worksheet for each control scenario and an additional worksheet for total emissions. Another option is to create additional tables within this worksheet for the other control scenario and total emissions. Cell: Al2 Comment: Use the appropriate Process Parameter based on how the emissions are estimated and engineer's judgment. Use Natural Gas Venting as a process parameter if: • The point has a PTE greater than 100 tpy of VOC, AND • the point includes a HP/HLP/LP separator OR Use Natural Gas Venting as a process parameter if: • The owner operator is requesting Natural Gas Venting as a process parameter, AND • The owner operator is willing to use a flow meter Use Liquids Throughput as a process parameter if: • the point has a PTE less than 100 tpy of VOC, or • the point is a VRT permitted by itself Cell: A14 Comment: This selection indicates whether or not the operator will harm a gas meter installed and operational upon issuance of the permit. If not, the operator shall agree to install a meter within 180 days of startup. If the operator will not have a meter installed and operational upon startup, the "volume of waste gas emitted per BBL of liquids throughput" (i.e. the value specified in cell 831) shall be used to monitor gas volume. Cell: A19 Comment: This value represents the actual throughput Cell: A20 Comment: This value represents the requested separator gas volume or corresponding liquid throughput the operator will accept as a permit limit and the basis for the permitted emissions in a traditional construction permit. The requested limit must be based on the volume of liquid throughput (BBL per year) if the operator is not required to install a gas flow meter. If the operator is required to install a gas flow meter, the requested limit must be based on volume of gas. The operator can request a throughput limit less than the gas production rate of the separator or total liquid throughput but this value will be the enforceable permitted limit and will be the basis for calculating requested emissions for the separator. For example, if a portion of the separator stream is being recycled as part of the process (e.g. via a VRU), then the requested throughput may be limited to the gas volume routed to flare or liquid throughput while emissions are routed to flare. If the source does not want to take credit for recycling (or the recycling is determined to not be part of the process), then the requested separator gas volume is the maximum vent rate at requested operating hours or total liquid throughput. Cell: A21 Comment: This value represents requested throughput. The "Potential to Emit (PTE) Throughpet" is the same as the "Requested Permit Umit Throughput" for this source type. Cell: A23 Comment: The information provided in this section will establish the basis to estimate secondary emissions that result from emissions controls that combust VOC and HAP emissions from the separator Cell: A25 Comment: Gas heating value is the amount of heat produced from the complete combustion of a unit of fuel. The higher (or gross) heating value is obtained when all products of combustion are cooled to the pre -combustion temperature, water vapor formed during combustion is condensed, and necessary corrections have been made. This value represents the maximum heat content of the separator gas emitted. This value is based on the site -specific gas sample if available, the modeled value, or the weighted average if this point represents more than one gas stream such as LP separator gas plus VRT gas. Cell: A26 Comment: This value represents the ratio of the volume of waste gas emitted from the separator(s) per barrel of condensate/crude oil produced. If a process simulator (i.e. ProMax, HYS15, etc.) is used, then the volume of waste gas produced should be based on the TOTAL gas flow from the separation equipment as predicted by the model. This waste gas volume is then divided by the number of barrels used in the model run. For example, if the gas stream from the separator is recycled, then the scf/bbl ratio is: (flow rate recycled + flow rate to flare) / (number of barrels used in the model run) If operator is measuring gas flow using a meter, this cell is left blank. Cell: A28 Comment: This section establishes the process rates that are the basis for; actual emissions and will be reported to the Division's emissions inventory system; requested permitted emissions that will become a limit in the permit issued; and the potential to emit used to establish if the facility should be considered a true minor, synthetic minor or major source under Colorado Regulation 3 permitting programs. Cell: A32 Comment: This equation may be referenced in EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 -Displacement Equation (10.4-3). Where: 21 of 34 K:\PA\2017\ 17WE1114.CP1,olsm Separator Venting Emissions Inventory Ex = emissions of pollutant s O = Volumetric flow rate/volume of gas processed MW = Molecular weight of gas = SG of gas ' MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/Ib-mol) at 60F and 1 atm Cell: 836 Comment: The values input to this table represent the % by weight in the gas stream (i.e. if the value is 40%, then "40" must be input here) If additional pollutants must be added to this table based on the reported stream composition, the user can insert a row as follows: If pollutant is a VOC: -select the entire row that includes "C8+ Heavies" in the spreadsheet by right clicking on the row n next to column A -select "insert" from the drop down menu If pollutant is not a VOC: -select the entire row that includes "propane" in the spreadsheet by right clicking on the row 9 next to column A -select "insert" from the drop down menu Cell: A59 Comment: This must be 100% Cell: 964 Comment: When cell indicates "(Ib/MMscf)": EF=Xxx MW x 10^6/C where: EF = emission factor (lb/MMscf) MW = Molecular weight of gas = SG of gas . MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm When cell indicates "(lb/bbl)", EF = Xxx MW x GLR / C where: EF = emission factor (lb/bbl) MW = Molecular weight of gas = SG of gas MW of air Xx = mass fraction of x in gas GLR = volume of waste gas emitted per barrel of liquids throughput (scf/bbl) C = molar volume of ideal gas (379 scf/Ib-mol) at 601 and 1 atm Note: GLR is referenced from the value input in Section 03 Cell: D73 Comment: NOx and CO emissions factors from AP -42 Table 1.4-1 maybe used only when a thermal oxidizer is used to control emissions. Cell: B76 Comment: The operator should provide emissions factors for NOx, CO and PM10/PM2.5 which represent the post combustion emissions resulting from the emissions control device (e.g. secondary emissions). Ensure the emission factors are in the correct units of lb/MMBtu (convert within the cells to establish correct units if needed). Leave NOx, CO and PM10/PM2.5 E.F. blank if the unit is not controlled. Cell: C76 Comment: This column automatically converts emission factors from lb/MMBtu to lb/MMscf waste gas combusted since ongoing compliance demonstration for actual emissions will be calculated using actual waste gas volume multiplied by an emission factor. It is more straightforward to convert all emission factors into units correlating to the process limit. The Ib/MMscf emission factors for NOx, CO and PM should be listed in the Notes to Permit Holder section of the permit. Cell: A84 Comment: All values contained in the emissions inventory section are automatically calculated based on the information provided in the preceding sections. Cell: E87 Comment: Secondary emissions from control devices are listed in the uncontrolled and controlled columns in this emissions inventory table. While secondary emissions are not generated until the emitting unit is controlled, the secondary emissions are not actually being controlled so it is appropriate to list the secondary emissions as uncontrolled. Also, by listing the secondary emissions under uncontrolled and controlled, facility emissions can be more clearly summarized and the facility source classification regarding true minor/synthetic minor/major status can be more logically assessed. 22 of 34 K:\PA\2017\ 17WE1114.CP1.xlsm Produced Water Storage Tank Regulatory Analysis Worksheet Please note that NSPS Kb might be might be applicable for certain tanks at water management and Injection facilities. If the tanks you are reviewing are at one of these facilities, please review NSPS Kb. Colorado Regulation 3 Parts A and B - APEN and Permit Requirements 'Source is in the Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the operator claiming less than 1% crude oil and Is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? mocESEA No ra 'Source requires a permit NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 2TPV, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section 11.0.2)? You have indicated that source is in the Attaininerit Area Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this produced water storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor station or natural gas processing plant? 3. Is this produced water storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions' of this storage tank equal to or greater than 6 tons per year VOC? No Yes 'Storage tank is subject to Regulation 7, Section XVII, a, C.1 & C.3 Section XVII.B—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1 - Emissions Control and Monitoring Provisions Section XVII.C.3 - Recordkeeping Requirements 5. Does the produced water storage tank contain only "stabilized" liquids? If no, the following additional provisions apply. !Storage tank is sup(ect to Regulation' 7, Section XVII.C.7 Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this produced water storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this produced water storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? 3. Are potential VOC emissions' from the Individual storage vessel greater than or equal to 6 tons per year? 4. Does this produced water storage vessel meet the definition of "storage vessel"' per 60.5430? Subpart A, General Provisions per §60.5425 Table 3 460.5395 - Emissions Control Standards for VOC §60.5413 -Testing and Procedures §60.5395(g) - Notification, Reporting and Recordkeeping Requirements - 460.5416(c) - Cover and Closed Vent System Monitoring Requirements 460.5417 - Control Device Monitoring Requirements [Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, It should remain subject to NSPS 0000 per 60.5365(e((2( even If potential VOC emissions drop below 6 tons per year) RACT Review RACT review is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. If the tank meets both criteria, then review RACE requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend," "may," "should," and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Source Req Go to next Source Req Continue -' Continue -' Go to the n Source is Sc N. '.;Source is st Continue -' Storage Tar 006 Fugitive Emissions from Haul Road for Crude Oil and Produced Water Loadout E = k(s/12)^a *(W/3)^b AP -42 13.2.2, Equation 1a E = emission factor (IbNMT (VMT=Vehicle Miles Travelled)) k = constant from table 13.2.2-2 s = surface material silt content (%) a = constant from table 13.2.2-2 W = mean vehicle weight (tons) b= constant from table 13.2.2-2 Constants W (tons) s* (%) E (lb/VMT) Pollutant k a b W, Empty W, Loaded W, Avg TSP (PM) 4.9 0.7 0.45 14 42.5 28.25 5 7.28 PM -10 1.5 0.9 0.45 14 42.5 28.25 5 1.87 PM -2.5 0.15 0.9 0.45 14 42.5 28.25 5 0.19 *CDOT 2011 Standar Specification Book Table 703-3 Class 6 Aggregate Base Course Total Estimated VMT: 969 miles/yr Emissions Summary Table Pollutant E (lb/VMT) Uncontrolled Emissions Control Factor** Controlled Emissions TSP (PM) 7.28 3.53 tpy 21.9% 2.76 tpy PM -10 1.87 0.91 tpy 21.9% 0.71 tpy PM -2.5 0.19 0.09 toy 21.9% 0.07 toy **Natural mitigation from precipitation per EPA AP -42 Volume 1 Fifth Edition - November 2006 Table 13.2.2-2 Equation 2; number of days with natural preciptiation from figure AP -42 Figure 13.2.2-1 Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.1. & 4.) Regulation 3 - APENs, Construction Permits,, Operating Permits;PSD= Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: each individual emission point in an attainment area with uncontrolled actual emissions of two tons per year or more of any individual criteria pollutant (pollutants are not summed) for which the area is attainment. SCC 31088801: Fugitive Haul Road Emissions This source is below APEN reporting thresholds and is APEN exempt. Crude Oil Storage Tank(s) Emissions Inventory Section 01- Administrative Information 'Facility AIRs ID: 005 County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Fourteen (14}.400 bbl Crude Odstoragetanl Emission Control Device Enc Description: Requested Overall VOC & HAP Control Efficiency %: Section 03- Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Throughput= Secondary Emissions- Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per BBL of liquids produced = L6'. scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 15,200 Barrels (bbl) per year 05200`. Barrels (bbl) per year 05,200. Barrels (bbl) per year Btu/scf 2315 Actual Crude Oil Throughput While Emissions Controls Operating = 905,200. 5,921 MMBTU per year 5448.3988 5,921 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 5,921 MMBTU per year Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Emission Factors Crude Oil Tank Pollutant Uncontrolled Controlled (Ib/bbl) (Ib/bbl) (Crude Oil Throughput) (Crude Oil Throughput) VOC 0.2377 0.0003-$H 0.000142 0.011885 0.000009 0.000007 0.000001 0.000003 0.000085 0.000011 Benzene Toluene Ethylbenzene Xylene x000020 .000060 n -Hexane 224 IMP , 0,051690 -.. 0,000210 Pollutant Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (lb/bbl) (waste heat combusted) (Crude Oil Throughput) Emission Factor Source Emission Factor Source PM10 PM2.5 0.0000 0.11000 0.0004 0.0020 0.0075LLL 0.0680:.......... 600 CO z Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) VOC PM10 PM2.5 NOx CO 107.6 107.6 5.4 107.6 5.4 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0,0 0.2 0.2 0.2 0.2 0.2 0.9 0.9 0.9 0.9 0.9 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled fibs/Year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 167 167 8 167 8 129 129 6 129 fi 18 18 1 18 1 54 54 3 54 3 1530 1530 76 1530 76 190 390 10 190 10 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A,B Source requires a permit Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, Cl & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C,2 Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6, Part A, NSPS Subpart 0000 Storage Tank Is not subject to NSPS 0000 Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MAC'" HO (See regulatory applicability worksheet for detailed analysis) 25 of 34 K:\PA\2017\17W E1114.CP1.xlsm Crude Oil Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 20 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03 Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample of crude oil drawn at the facility being permitted? If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point 8 Process 0 SCC Code 005 01 Uncontrolled Emissions Pollutant Factor Control% Units PM10 0.00 0 lb/1,000 gallons crude oil throughput PM2.5 0.00 0 lb/1,000 gallons crude oil throughput NOx 0.01 0 lb/1,000 gallons crude oil throughput VOC 5.7 95 lb/1,000 gallons crude oil throughput CO 0.05 0 lb/1,000 gallons crude oil throughput Benzene 0.00 95 lb/1,000 gallons crude ail throughput Toluene 0.00 95 lb/1,000 gallons crude oil throughput Ethylbenzene 0.00 95 lb/1,000 gallons crude oil throughput Xylene 0.00 95 lb/1,000 gallons crude oil throughput n -Hexane 0.04 95 lb/1,000 gallons crude oil throughput 224 TMP 0.01 95 lb/1,000 gallons crude oil throughput 26 of 34 K:\PA\2017\17WE1114.CP1.xlsm Separator Venting Emissions Inventory Section 01.- Administrative Information 'Facility Allis ID: County Plant Poin Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %) Limited Process Parameter Primary Emissions - Separator Actual Throughpu Requested Permit Limit Throughput = Potential to Emit (PTE) Throughput e477457tf EuE Section 03 - Processing Rate Information for Emissions Estimates 800-D Barrels (bbl) per year Barrels (bbl) per year .A Barrels (bbl) per year Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL o liquids throughput: Section 04- Emissions Factors & Methodologies Displacement Equation Ex=Q°MW•Xx/C Weight % Helium C02 N2 methane ethane 844 - propane isobutane n -butane isopentane n -pentane cyclopentane n -Hexane cyclohexane Other hexanes heptanes methylcyclohexane 224-TMP Benzene Toluene- Ethylbenzene Xylenes CS, Heavies St; 0-32171 398. Total VOC Wt % 99.4576 79.1627 Btu/scf (HHV) scf/bbl b/lb-mol 2169 Btu/Scf (LHV) 27 of 34 K:\PA\2017\17WE1114.CP1.xlsm Separator Venting Emissions Inventory Emission Factors Separator Venting Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) (Liquid Throughput) (Liquid Throughput) VOC 1.75601 0.00332 0.00285 0.00043 0.00092 0.03316 0.00389 0.0878 0.0002 0.0001 0.00002 0.00005 0.0017 0.0002 Benzene Toluene Ethylbenzene xylene n -Hexane 224 TMP Emission Factor Source Emission Factor Source Pollutant Primary Control Device Uncontrolled Uncontrolled (Ib/MMBtu) lb/bbl (Waste Heat Combusted) (Gas Throughput) PM10 PM2.5 9.0075 0.0075 0.000 0.000 0.000 0.003 0.013 500 NOx CO 0096x' Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) PM10 PM2.5 5Ox NOx VOC CO 0.22 0.22 0.22 0.22 0.22 0.22 0.22 0.22 0.22 0.22 0.02 0.02 0.02 0.02 0.02 2.05 2.05 2.05 2.05 2.05 1192.15 1192.15 59.61 1192.15 59.61 8.54 8.54 8.54 8.54 8.54 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled Ohs/year) (lbs/year) Benzene Toluene Ethylbenzene Itylene n -Hexane 224 TMP 5193 5193 260 5193 260 3873 3873 194 3873 194 581 581 29 581 29 1253 1253 63 1253 63 45024 45024 2251 45024 2251 5275 5275 264 5275 264 Total Emission Summary 2.596670896 1.936500329 0.290475049 0.626428516 22.51181633 2.637748176 0.129833545 0.096825016 0.014523752 0.031321426 1.125590816 0.131887409 28 of 34 K:\PA\2017\17WE1114.CP1.xlsm Separator Venting Emissions Inventory Cell: A2 Comment: cdmoney: Enter the facility AIRs ID number (County/Plant/Point) if previously assigned by the Air Pollution Control Division (APCD). If you are reporting a new point at a site with an existing County and Plant ID, fill in the known information. Cell: A7 Comment: cdmoney: Enter a detailed description of the emission unit (how maw separators, type (high pressure, low pressure, vapor recovery tower (VRT), etc.) so this information can be copied directly into the equipment description in the permit. For example: One (1) low-pressure separator Cell: A9 Comment: cdmoney: Examples: Enclosed Flare during VRU downtime Enclosed Flare Open Flare Thermal Oxidizer Cell: A10 Comment: cdmoney: This value represents the requested overall control efficiency for a single control device. If the source is requesting a more complex control scenario, such as permitting for control device downtime or permitting for a backup control device with different control efficiency than the primary control device, this PA needs to be edited to address the unique control scenarios. One option is to create a worksheet for each control scenario and an additional worksheet for total emissions. Another option is to create additional tables within this worksheet for the other control scenario and total emissions. Cell: Al2 Comment: Use the appropriate Process Parameter based on how the emissions are estimated and engineer's judgment. Use Natural Gas Venting as a process parameter if: • The point has a PTE greater than 100 tpy of VOC, AND • the point includes a HP/HLP/LP separator OR Use Natural Gas Venting as a process parameter if: • The owner operator is requesting Natural Gas Venting as a process parameter, AND • The owner operator is willing to use a flow meter Use Liquids Throughput as a process parameter if: • the point has a PTE less than 100 tpy of VOC, or • the point is a VRT permitted by itself Cell: A14 Comment: This selection indicates whether or not the operator will ham a gas meter installed and operational upon issuance of the permit. If not, the operator shall agree to install a meter within 180 days of startup. If the operator will not have a meter installed and operational upon startup, the "voume of waste gas emitted per BBL of liquids throughput" (i.e. the value specified in cell 831) shall be used to monitor gas volume. Cell: A19 Comment: This value represents the actual throughput Cell: A20 Comment: This value represents the requested separator gas volume or corresponding liquid throughput the operator will accept as a permit limit and the basis for the permitted emissions in a traditional construction permit. The requested limit must be based on the volume of liquid throughput (BBL per year) if the operator is not required to install a gas flow meter. If the operator is required to install a gas flow meter, the requested limit must be based on volume of gas. The operator can request a throughput limit less than the gas production rate of the separator or total liquid throughput but this value will be the enforceable permitted limit and will be the basis for calculating requested emissions for the separator. For example, if a portion of the separator stream is being recycled as part of the process (e.g. via a VRU), then the requested throughput maybe limited to the gas volume routed to flare or liquid throughput while emissions are rooted to flare. If the source does not want to take credit for recycling (or the recycling is determined to not be part of the process), then the requested separator gas volume is the maximum vent rate at requested operating hours or total liquid throughput. Cell: A21 Comment: This value represents requested throughput. The "Potential to Emit (PTE) Throughput" is the same as the "Requested Permit Limit Throughput" for this source type. Cell: A23 Comment: The information provided in this section will establish the basis to estimate secondary emissions that result from emissions controls that combust VOC and HAP emissions from the separator Cell: A25 Comment: Gas heating value is the amount of heat produced from the complete combustion of a unit of fuel. The higher (or gross) heating value is obtained when all products of combustion are cooled to the precombustion temperature, water vapor formed during combustion is condensed, and necessary corrections have been made. This value represents the maximum heat content of the separator gas emitted. This value is based on the site -specific gas sample if available, the modeled value, or the weighted average if this point represents more than one gas stream such as LP separator gas plus VRT gas. Cell: A26 Comment: This value represents the ratio of the volume of waste gas emitted from the separator(s) per barrel of condensate/crude oil produced. If a process simulator (i.e. ProMax, HYSy5, etc.) is used, then the volume of waste gas produced should be based on the TOTAL gas flow from the separation equipment as predicted by the model. This waste gas volume is then divided by the number of barrels used in the model run. For example, if the gas stream from the separator is recycled, then the scf/bbl ratio is: (flow rate recycled +flow rate to flare) / (numberof barrels used in the model run) If operator is measuring gas flow using a meter, this cell is left blank. Cell: A28 Comment: This section establishes the process rates that are the basis for; actual emissions and will be reported to the Division's emissions inventory system; requested permitted emissions that will become a limit in the permit issued; and the potential to emit used to establish if the facility should be considered a true minor, synthetic minor or major source under Colorado Regulation 3 permitting programs. Cell: A32 Comment: This equation maybe referenced in EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3). Where: 29 of 34 K:\PA\2017\17WE1114.CP1.xlsm Separator Venting Emissions Inventory Ex = emissions of pollutant x 4= Volumetric flow rate/volume of gas processed MW = Molecular weight of gas = SG of gas * MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm Cell: 836 Comment: The values input to this table represent the % by weight in the gas stream (i.e. if the value is 40%, then "40" must be input here) If additional pollutants must be added to this table based on the reported stream composition, the user can insert a row as follows: If pollutant is a VOC: -select the entire row that includes "Cu* Heavies" in the spreadsheet by right clicking on the row 9 next to column A -select "insert" from the drop down menu If pollutant is not a VOC: -select the entire row that includes "propane" in the spreadsheet by right clicking on the row N next to column A -select "insert" from the drop down menu Cell: A59 Comment: This must be 100% Cell: 864 Comment: When cell indicates "(lb/MMscf)": EF= Xx x MW x 10^6/C where: EF = emission factor (lb/MMscf) MW = Molecular weight of gas = SG of gasMW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm When cell indicates "(lb/bbl)", EF=Xxx MW x GLR/C where: EF = emission factor (lb/bbl) MW = Molecular weight of gas = SG of gas' MW of air Xx = mass fraction of x in gas GLR = volume of waste gas emitted per barrel of liquids throughput (scf/bbl) C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm Note: GLR is referenced from the value input in Section 03 Cell: D73 Comment: NOx and CO emissions factors from AP -42 Table 1.4-1 may be used only when a thermal oxidizer is used to control emissions. Cell: 876 Comment: The operator should provide emissions factors for NOx, CO and PM10/PM2.5 which represent the post combustion emissions resulting from the emissions control device (e.g. secondary emissions). Ensure the emission factors are in the correct units of Ib/MMBtu (convert within the cells to establish correct units if needed). Leave NOx, CO and PM10/PM2.5 E.F. blank if the unit is not controlled. Cell: C76 Comment: This column automatically converts emission factors from lb/MMBtu to lb/MMscf waste gas combusted since ongoing compliance demonstration for actual emissions will be calculated using actual waste gas volume multiplied by an emission factor. It is more straightforward to convert all emission factors into units correlating to the process limit. The lb/MMscf emission factors for NOx, CO and PM should be listed in the Notes to Permit Holder section of the permit. Cell: A84 Comment: All values contained in the emissions inventory section are automatically calculated based on the information provided in the preceding sections. Cell: E87 Comment Secondary emissions from control devices are listed in the uncontrolled and controlled columns in this emissions inventory table. While secondary emissions are not generated until the emitting unit is controlled, the secondary emissions are not actually being controlled so it is appropriate to list the secondary emissions as uncontrolled. Also, by listing the secondary emissions under uncontrolled and controlled, facility emissions can be more clearly summarized and the facility source classification regarding true minor/synthetic minor/major status can be more logically assessed. 30 of 34 K:\PA\2017\17WE1114.CP1xlsm Crude Oil Storage Tank Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements 'Source is in the Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the construction date prior to 4/14/2014 and not modified after 4/14/14 (See PS Memo 14-03 for additional guidance on grandfather applicability)? 2a. If answer to #2 is yes, is the crude oil throughput less than 40,000 gallons per year? 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section I I.D.3)? 'Source requires a permit NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the construction date prior to 4/14/2014 and not modified after 4/14/14 (See PS Memo 14-03 for additional guidance on grandfather applicability)? 2a. If answer to #2 is yes, is the crude oil throughput less than 40,000 gallons per year? 3. Are total facility uncontrolled VOC emissions from the greater than 2TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section II.D.2)? 'You have indicated that source is in the Attainment Area Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this crude oil storage tank' located at an oil and gas exploration and production operation , well production facility, natural gas compressor station or natural gas processing plant? 3. Is this crude oil storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions' of this storage tank equal to or greater than 6 tons per year VOC? 'Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Section XVII.B —General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1 - Emissions Control and Monitoring Provisions Section XVII.C.3 - Recordkeeping Requirements 5. Does the crude oil storage tank contain only "stabilized" liquids? If no, the following additional provisions apply. 'Storage tank is subject to Regulation 7, Section XVIi.C.2 Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m3) (-472 BBLs]? 2. Does the storage vessel meet the following exemption in 60.111b(d)(4)? a. Does the vessel has a design capacity less than or equal to 1,589.874 m3 [^'10,000 BBL] used for petroleum' or condensate stored, processed, or treated prior to custody transfer' as defined in 60.1116? 3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984? 4. Does the tank meet the definition of "storage vessel"' in 60.1116? 5. Does the storage vessel store a "volatile organic liquid (VOL)"' as defined in 60.1116? 6. Does the storage vessel meet any one of the following additional exemptions: a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa ["29.7 psi] and without emissions to the atmosphere (60.110b(d)(2))?; or b. The design capacity is greater than or equal to 151 m3 [`950 BBL] and stores a liquid with a maximum true vapor pressure' less than 3.5 kPa (60.110b(b))?; or c. The design capacity is greater than or equal to 75 M3 ["472 BBL] but less than 151 m3 ["950 BBL] and stores a liquid with a maximum true vapor pressure' less than 15.0 kPa(60.110b(b))? Storage Tank is not subject to WS Kb Subpart A, General Provisions §60.112b - Emissions Control Standards for VOC §60.113b - Testing and Procedures §60.115b - Reporting and Recordkeeping Requirements 460.1166 - Monitoring of Operations No, Yell....::..,,,'. No Yes Yes,;.11 Y, Source Req Go to next Go to next i Source Req Continue -` Continue - Go to the n Source is st klo.7 Source Is SL Storage Tar 40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this crude oil storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this crude oil storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? 3. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year? 4. Does this crude oil storage vessel meet the definition of "storage vessel"' per 60.5430? Yes Storage Tank is not subject to NSPS 0000 Subpart A, General Provisions per §60.5425 Table 3 §60.5395 - Emissions Control Standards for VOC §60.5413 -Testing and Procedures §60.5395(g) - Notification, Reporting and Recordkeeping Requirements 560.5416(c) - Cover and Closed Vent System Monitoring Requirements §60.5417 - Control Device Monitoring Requirements [Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per 60.5365(e)(2( even if potential VOC emissions drop below 6 tons per year] 40 CFR, Part 63, Subpart MACY HI -I, Oil and Gas Production Facilities 2. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: a. A facility that processes, upgrades or stores hydrocarbon liquids' )63.760(a))2)); OR b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user' (63.760)a)(3))? 1. Is the tank located at a facility that is major' for HAPs? 3. Does the tank meet the definition of "storage vessel"' in 63.761? 4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"' per 63.761? 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000? 'Storage Tank is not subject to MACT I ll-I Subpart A, General provisions per §63.764 (a) Table 2 §63.766- Emissions Control Standards §63.773 - Monitoring §63.774 - Recordkeeping §63.775 - Reporting RACT Review RACT review is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. If the tank meets both criteria, then review RACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend," "may," "should," and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself Yes Continue -' Continue -' Storage Tar One (1) Caterpillar, G3516B, SN: JEF02642, natural gas -fired, naturally aspirated, 4SLB reciprocating internal combustion engine, site rated at 1311 horsepower. This engine shall be equipped with an oxidation catalyst and air -fuel ratio control. This emission unit is used for natural gas compression. 006 Engine Information Engine date of m 11/11/2014 Manufacturer: Caterpillar Model Number: G3516B Serial Number: JEF02642 Engine Function Compression berating Mfg's Max. Rated Horsepower @ sea level: 1311 Horsepower used for calcuations: 1311 BSCF @ 100% Load (btu/hp-hr): 8180 Site - Rated BSCF @ 100% load (btu/hp-hr): 8180 Other Parameters Engine Type 4SLB Aspiration turbo -charged Electrical Generator Max Site Rating (kw) 0 Max hrs/yr of Operation 8760 Calculations Fuel Use Rate @ 100% Load 10513.70588 scf/hr ACTUAL Annual Fuel Consumption 92.1 MMscf/yr MAA -'U I EN I IAL Annual}Uel Consumption 92.100 MMscf/yr REQUESTED Annual Fuel Consumption 92.100 MMscf/yr Fuel Heating Value 1020 btu/scf Emission Control Information This engine shall be equipped with an oxidation catalyst and air -fuel ratio control Emissions Summary Table Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source NOx 1.000 g/hp-hr 1.000 g/hp-hr 12.63 tpy 12.63 tpy Manufacturer CO 3.100 g/hp-hr 1.500 g/hp-hr 39.16 tpy 18.95 tpy Manufacturer VOC 1.830 g/hp-hr 0.700 g/hp-hr 23.12 tpy 8.84 tpy Manufacturer Formaldehyde 0.360 g/hp-hr 0.250 g/hp-hr 9096 lb/yr 6316 lb/yr Manufacturer Acetaldehyde 0.00836 lb/MMBTU 0.008 lb/MMBTU 785 lb/yr 785 lb/yr AP -42 Acrolein 0.00514 Ib/MMBTU 0.005 lb/MMBTU 483 lb/yr 483 lb/yr AP -42 Benzene 0.00044 lb/MMBTU 0.000 Ib/MMBTU 41 lb/yr 41 lb/yr AP -42 17WE1114.CP1.xlsm One (1) Caterpillar, G3516B, SN: JEF02641, natural gas -fired, naturally aspirated, 4SLB reciprocating internal combustion engine, site rated at 1311 horsepower. This engine shall be equipped with an oxidation catalyst and air -fuel ratio control. This emission unit is used for natural gas compression. 005 Engine Information Engine date of mfg 11/11/2014 Manufacturer: Caterpillar Model Number. G3516B Serial Number. JEF02641 Engine Function Compression berating Mfg's Max. Rated Horsepower @ sea level: 1311 Horsepower used for calcuations: 1311 BSCF @ 100% Load (btu/hp-hr): 8180 Site - Rated BSCF @ 100% load (btWhp-hr): 8180 Other Parameters Engine Type 4SLB Aspiration turbo -charged Electrical Generator Max Site Rating (kw) 0 Max hrs/yr of Operation 8760 Calculations Fuel Use Rate @ 100% Load 10513.70588 scf/hr ACTUAL Annual Fuel Consumption 92.1 MMscf/yr MAX rU I tN I IAL Annuai}uel Consumption 92.100 MMscf/yr REQUESTED Annual Fuel Consumption 92.100 MMscf/yr Fuel Heating Value 1020 btu/scf Emission Control Information This engine shall be equipped with an oxidation catalyst and air -fuel ratio control Emissions Summary Table Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source NOx 1.000 g/hp-hr 1.000 quip -hr 12.63 tpy 12.63 tpy Manufacturer CO 3.100 g/hp-hr 1.500 gi ip-hr 39.16 tpy 18.95 tpy Manufacturer VOC 1.830 g/hp-hr 0.700 gThp-hr 23.12 tpy 8.84 tpy Manufacturer Formaldehyde 0.360 g/hp-hr 0.250 guip-hr 9096 lb/yr 6316 lb/yr Manufacturer Acetaldehyde 0.00836 Ib/MMBTU 0.008 Ib/NMBTU 785 lb/yr 785 lb/yr AP -42 Acrolein 0.00514 Ib/MMBTU 0.005 Ib/NMBTU 483 lb/yr 483 lb/yr AP -42 Benzene 0.00044 Ib/MMBTU 0.000 Ib/NMBTU 41 lb/yr 41 lb/yr AP -42 17WE1114.CP1.xlsm DO ontrol Division Department of Public Health £r Environment Permit number: Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: General Description: STRUCTION PERMIT Issuance: 1 Whiting Oil and Gas Corporation Horsetail 07 West CPB 123/9F6B SENW SEC 7 T10N R57W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description PW-01 through PW- 08 003 Eight (8) 400 barrel fixed roof storage vessels used to store produced water Enclosed Combustor 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 the 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 Pollution Control Division zr≤iS Putrnerit Page 1 of 8 3. his p y'mi= s` expix �ae oer.r operator of the source for which this permit was issued: s nn/modification or operation of this source within 18 months a ter eit er, the •a e o 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 Div', grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator sha `, omplete all initial compliance testing and sampling as required in this permit and submit the sults to the Division as part of the self -certification process. (Regulation Number 3, Part ction 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 PW-01 through PW-08 003 --- --- 15.8 2.9 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. 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 are defined as any activity or equipment, which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. COLORADO Air Pollution Control Division ai'U%r' rtt, f ra 4%ctttiki �JC£ , G rlvr�r,rr Page 2 of 8 8. establishes in ow shall be operated and maintained with the emissions der to reduce emissions to less than or equal to the limits gu a ion Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled PW-01 through PW- ;,,; 003 08 Enclosed Combustor 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 PW-01 through PW- 08 003 Produced Water throughput 5,475,000 barrels The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and 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) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, 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 enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating property. This flare must be equipped with an operational auto -igniter. 13. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shalt install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to COLORADO Air Pollution Control Division Fvbt _ it Ltiv=nr`le+;C Page 3 of 8 t 'il requirement must be met within 90 days of the date that tion. 14. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING Et MAINTENANCE REQUIREMENTS 15. Upon startup + •oints, the owner or operator shall follow the most recent operating and maintenance (O ) plan and record keeping format approved by the Division, in order to demonstrate co fiance on an ongoing basis with the requirements of this permit. Revisions to the OEtM plan arubject to Division approval prior to implementation. (Regulation Number 3, Part B, Section . = °7. ) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. 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. This source is subject to the provisions of Regulation Number 3, Part C, Operating Permits (Title V of the 1990 Federal Clean Air Act Amendments). The application for the Operating Permit is COLORADO Air Pollution Control Division rx:;t of Pu&c lieu€tn u E*vbonrnprlt Page 4 of 8 commencement of operation of any piece of equipment 20. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The u all not exceed the Federal program threshold until a permit is granted. (Regulation Num E'°' r 3, Parts C and D). GENERAL TERMS AND C = = ITIONS 21. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation 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. 22. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation 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. 23. 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. 24. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 25. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the 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. 26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. COLORADO Air Pollution Control Division ,:`2parttn'nt,ei Pub4i: Yiea th V Ervir Mtent Page 5 of 8 e By: Christopher Kester Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Whiting Oil and Gas Corporation COLORADO Air Pollution Control Division ^ panty nt of !AAA Health a Err,itorinte,st Page 6 of 8 Notes Per H.. - ; t the, .• th m, p mit issuance: 1) T it his d<a,. 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. (Regulation Number 3, Part A, Section VI.B.) 2) The production based on the consum upon request of the control regulation or and complete appli terial processing limits and emission limits contained in this permit are ion rates requested in the permit application. These limits may be revised ner or operator providing there is no exceedance of any specific emission ambient air quality standard. A revised air pollution emission notice (APEN) 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. AIRS Point Pollutant CAS # Uncontrolled Emissions (Ib/yr) Controlled Emissions (lb/yr) 003 Benzene 71432 1,666 83 Toluene 108883 545 27 Ethylbenzene 100414 37 2 Xylenes 1330207 74 4 n -Hexane 110543 218,998 10,950 2,2,4- Trimethylpentane 540841 168 8 Note: All non -criteria reportable poi utants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) 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/bbl Controlled Emission Factors lb/bbl Source CO 0.00105 0.00105 AP -42 V0C 0.115 0.005750 Site Specific Flash Liberation Analysis 71432 Benzene 0.000305 0.000015 108883 Toluene 0.000100 0.000005 110543 n -Hexane 0.040041 0.002000 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 COLORADO Mr Pollution Control Division Dept-ment d ruti€&&Envip3nment Page 7 of 8 th as a )-692- 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is cl follows: ermine the APEN expiration date for each emissions point estions regarding a specific expiration date call the Division Applicable Requirement Status Permit Major Source of: t VOCOperating Synthetic Minor Source of: HAPs PSD Synthetic Minor Source of: V0C 9) 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 I.X.partment of Pubs A a tea r h Erwirorrter:t Page 8 of 8 Permit number: Date issued: Issued to: ADO n Contro c Heal CONSTRUCTION PERMIT 17WE1114 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Whiting Oil and Gas Corporation Horsetail 07 West CPB 123/9F6B SENW SEC 7 T10N R57W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description SEP-01 through SEP-16 001 Eight (8) 2 -phase separators and eight (8) 3- 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 Preverrtion 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 Mr Pollution Control Division T fg,t m. t vE PuOi>c K Ot 6 Gryvurr r Page 1 of 9 3. expi , er or oper `or r e source R this permi • s issued: enc o tion/modif ��.9 ,•peration ' i ource withi 8 months e da• •f is pace of t constr <•on per or the date on ich such r activ , was s uled + commen' . s set h in the permit • • lication with thi .- (ii) . ., �.≥ -s cons : "" : •-"•od of eigh •'ths 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. Upon issuance of this permit, the operator shall install a flow meter to monitor and record volumetric flow rate of natural gas vented from each separator covered by this permit. 5. 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.) 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. (Regulation Number 3, Part B, Section II.A.4.) ) s permit s does not c er either, stru _ ..• Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO SEP-01 through SEP-16 001 --- 5.9 95.1 24.6 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. 8. The owner or operator shall track emissions from all insignificant activities at the facility on an annual basis. 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 are defined as any activity or equipment, which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. 9 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 Division I DLparVnent of Ii?'btcu..e fs E, �vixorrui' Page 2 of 9 t rough SEP-16 E the a r ;: ted to an Open Flare utants C =. rolled HAP 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 rates shalt 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 through SEP-16 001 Natural Gas Flaring 109.5 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. 11. Upon issuance of the permit, the owner or operator shall continuously monitor and record the volumetric flow rate of natural gas flared 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 12. 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) 13. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 14. 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. 15. 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 welt, 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. COLORADO Air Pollution Control Division D.4,-ater Puk*z Nc n..h>a_dironrnert Page 3 of 9 16. •n startup hese ints - owner or �. = . 3 fall folio 'he ` st recent o ating and ng for approv by the Division, _' order to comp an . �:, �. �....,, .� with ., 1r f this per ons 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 17. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 18. On an annual basis, the owner/operator shall complete a site specific extended gas analysis ("Analysis") of the natural gas vented from this emissions unit in order to verify the VOC content (weight fraction) of this emission stream. Results of the Analysis shall be used to calculate site - specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis shall be used to demonstrate that the emissions factor established through the Analysis are less than or equal to, the emission factor submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factor submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). ADDITIONAL REQUIREMENTS 19. 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 (NOr) 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. !COLORADO Air Pollution Control Division r.,%`Pa ;:'x:rt C,f Y'tNa€ ASeti:Yn u Elvitormem Page 4 of 9 20. Number 3, =operating P its (Title e applic the Operat Permit is f opera £ of any piece o „ quipment 21. 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 22. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation 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. 23. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation 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. 24. 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. 25. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 26. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the 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. 27. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 28. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. COLORADO Air Pollution Control Division t or Pub*:31e&t:h & E;.ttonrnent Page 5 of 9 Permit History Issuance Date Description Issuance 1 This Issuance Issued to Whiting Oil and Gas Corporation COLORADO I Air Pollution Control. Division Notes t 1) The fee permit iss ees forth y:° . - time fo s p- it. An invo for these ssued. =:`' e permi lder sh ay the invoice w n 30 days e inv..,;n ure .• .,€,, invoi evocation .. ermit. (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 (lb/yr) Controlled Emissions (lb/yr) SEP-01 through SEP- 16 001 Benzene 71432 7056 353 Toluene 108883 50820 2541 Ethylbenzene 100414 11644 582 Xylenes 1330207 21631 1082 n -Hexane 110543 63524 3176 2,2,4- Trimethylpentane 540841 6759 338 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The Poi CAS # onta Pollutant ermit are U ontrolled mission .T Factors (lb/MMSCF) the folio Con ; ed mission Factors (lb/MMSCF) sion factor Source NOx 105.074 105.074 AP -42 CO 437.565 437.565 AP -42 VOC 34715.84 1735.79 71432 Benzene 64.44 3.22 108883 Toluene 464.10 23.21 100414 Ethylbenzene 106.34 5.32 1330207 Xylene 197.55 9.88 110543 n -Hexane 580.14 29.01 540841 2,2,4-Trimethylpentane 61.72 3.09 Site Specific Gas Sample Analysis 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 Major Source of: VOC; Synthetic Minor Source of: HAPs PSD Synthetic Minor Source of: voc 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY COLORADO Air Pollution Control Division Ei Page 8 of 9 ICOLORADO Air Pollution Control Division t)epat-k.;.tot VUbk. Health *'s Ivirrrvnet t Page 9 of 9 CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 17WE1115 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Whiting Oil and Gas Corporation Horsetail 07 West CPB 123/9F6B SENW SEC 7 T10N R57W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description SEP-26 and SEP-27 002 Two (2) Vapor Recovery Towers (VRT) 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 Mr Pollution Control Division Page 1 of 9 3. expi = er or opera source this perms as issued: tion/modif •peration `. is source withi 8 months ce of t constron per or the date on ich such uled + commen s set th in the perms'-..lication is e. with thi """`'"'= , (ii) . r -s cons Y . .-`'od of eigh -- • the 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.) .A.4. ) Annual Limits: s permit s does not c er either, stru Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO SEP-26 and SEP-27 002 --- --- 18.8 3.1 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. 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 are defined as any activity or equipment, which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. COLORADO Air Pollution Control Division HeeSin s EY^irrmr>tier:F Page 2 of 9 8. emission trot equip ablished i below sh order to r tion Nu aer 3, P rated an sions to , Secti II.E.) ned with t emissions or equal F „." he limits aci lity Equipment ID Point Control Device nts Controlled SEP-26 and SEP-27 002 Emissions from the VRTs are routed to an Open Flare VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the 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-26 and SEP-27 002 Crude Oil Throughput during VRU or gas gathering system downtime 271,560 bbl/yr Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 10. The owner or operator shall continuously monitor and record VRT downtime. 11. The owner or operator must use monthly VRT downtime records, monthly condensate/crude oil throughput records, calculation methods detailed in the Ol-tM Plan, and the emission factors established in the Notes to Permit Holder to demonstrate compliance with the process and emissions limits specified in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 12. 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) 13. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 14. 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 I Air Pollution Control Division Dep,.. r,7,4,d of Public ti:atn Cs E;:Rora?tent Page 3 of 9 15. separato -__"F ere • it is subj to' • ulation 7, • XVII.G. (St Only). On 201 ing off a soduced d ng n mal operat from any ed, h ,aulic fracturor recleted o nd gas well, mu either be s gath& line ontrod from th ate of •roduction b •ollution ;- • o .,.; % equipment " ��°' � hiev = - ge hl efficiency . If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING Et MAINTENANCE REQUIREMENTS 16. 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 17. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 18. On an annual basis, the owner or operator shall complete a site specific analysis ("Analysis"), including a compositional analysis of the pre -flash pressurized hydrocarbon liquid routed to the equipment covered in this permit. Testing shall be in accordance with the guidance contained in PS Memo 05-01. Results of the Analysis shall be submitted to the Division as part of the self - certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to. Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). ADDITIONAL REQUIREMENTS 19. 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 (NOr) 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. !COLORADO Air Pollution Control Division uiortru^3t %.xrpvist,W •+ u E -r nors:atr:. Page 4 of 9 r the • e in the o .` -•erator of €ity, processactivity; er ne .ntrol m+ipmes installe •r whe ' -;-r a different ty• :;•f control pment • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 20. This source is subject to the provisions of Regulation Number 3, Part C, Operating Permits (Title V of the 1990 Federal Clean Air Act Amendments). The application for the Operating Permit is due within one year of the earliest commencement of operation of any piece of equipment covered by this permit. 21. 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 22. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation 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. 23. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation 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. 24. 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. 25. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 26. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the 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. !COLORADO Air Pollution Control Division EkR xrC f Pbek'z He itt. G Er.rirvrraie'tl Page 5 of 9 27. tion 25 -7 - ice (APEN) rce or act', ance • es requir n Air Pollu Emission sts of ins t io and admim :tion. If a notify K' . Division in writin -questing ee bill u will terminate. 28. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Christopher Kester Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Whiting Oil and Gas Corporation 'COLORADO Air Pollution Control. Division neparftht ut Pbw iiieGtgh a Envir sfinea Page 6 of 9 Notes t• -rmit Hold t the: .+ " permit iss 1) Thermit holde equi to • ees for th . " time fo s pe it. An invofor these fee ll be ]ss fter t •ermi ssued e perm] ]der sh..ay the invoice w 30 days e invurea:h==..., ..invoi .. eax . evocation s.aermit. (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-reps 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 (lb/yr) Controlled Emissions (lb/yr) SEP-26 and SEP-27 002 Benzene 71432 783 39 Toluene 108883 691 35 Ethylbenzene 100414 115 6 Xylenes 1330207 314 16 n -Hexane 110543 6817 341 2,2,4- Trimethylpentane 540841 959 48 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. COLORADO Air Pollution Control Division Page 7 of 9 5) The Poi CAS # onta Pollutant Source ermit are U !€ ontrolled mission Factors (lb/bbl) the folio Con ed mission Factors ' (lb/bbl) sion factor CO 0.01996 0.01996 AP -42 VOC 2.7665 0.1383 71432 Benzene 0.0029 0.0001 108883 Toluene 0.0025 0.0001 100414 Ethylbenzene 0.0004 0.0000 1330207 Xylene 0.0012 0.0001 110543 n -Hexane 0.0251 0.0013 540841 2,2,4-Trimethylpentane 0.0035 0.0002 VMG Simulation with pressurized upstream liquids sample analysis as inputs 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 Permit Major Source of: t VOCOperating Synthetic Minor Source of: HAPs PSD Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix 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 COLORADO i Air Pollution Control Division tx.putmf tDt Pub'ik-iYn.M ESr,.Avnent. Page 8 of 9 COLORADO Air Pollution Control Division t ep rt±r t of P.rbE:_ Heiskn. s E rorormerit Page 9 of 9 DO ontrol Division Department of Publip Health Et Environment Permit number: Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: General Description: STRUCTION PERMIT Issuance: 1 Whiting Oil and Gas Corporation Horsetail 07 West CPB 123/9F6B SENW SEC 7 T10N R57W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description TK-01 through TK- 14 005 Fourteen (14) fixed roof storage vessels used to store crude oil Enclosed Combustor 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 the 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 9 3. �:� his p x mi s expi �""` e o er <. r operator of the source for which this permit was issued: n. co e e coruc .•n/modification or operation of this source within 18 months a ter eit er, the •ae o 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 Div' grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator sha % omplete all initial compliance testing and sampling as required in this permit and submit the sults to the Division as part of the self -certification process. (Regulation Number 3, Part~ction 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 TK-01 through TK-14 005 --- 2.4 65.1 9.7 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. 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 are defined as any activity or equipment, which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. COLORADO IAir Pollution Control Division I a" 1),:at ser.,t a Public we,A th & Envir&rrr . Page 2 of 9 8. ow shall be operated and maintained with the emissions der to reduce emissions to less than or equal to the limits egu a ion Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled TK-01 through TK- 005 14 Enclosed Combustor 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 Process Parameter Annual Limit TK-01 through TK- 14 005 Process 1 Crude Oil throughput with Vapor Recovery Tower (point 002) bypassed 1,357,800 barrels Process 2 Crude Oil throughput 2,263,000 barrels The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 10. The owner or operator shall continuously monitor and record VRT downtime. 11. The owner or operator must use monthly VRT downtime records, monthly condensate/crude oil throughput records, calculation methods detailed in the O&M Plan, and the emission factors established in the Notes to Permit Holder to demonstrate compliance with the process and emissions limits specified in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 12. 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) 13. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 14. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, 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 enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: COLORADO Air Pollution Control. Division Page 3 of 9 st:' led on or after May 1, 2014, must be equipped with an to i ter '.on 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. 15. The storage r= r red by this permit is subject to the emission control requirements in Regulation Nam. r Section XVII.C.1. The owner or operator shall install and operate air pollution control = quipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion de e is used, it must have a design destruction efficiency of at least 98% for hydrocarbons e. where the combustion device has been authorized by permit prior to May 1, 2014. The source shalt follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 16. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING Ft MAINTENANCE REQUIREMENTS 17. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (OEM) 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 OEtM 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 18. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 19. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 20. 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 !COLORADO Air Pollution Control Division rtable 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 • Wheneve new control equipment is installed, or whenever a different type of control equipme ' replaces an existing type of control equipment; or • Whenev. .... permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 21. This source is subject to the provisions of Regulation Number 3, Part C, Operating Permits (Title V of the 1990 Federal Clean Air Act Amendments). The application for the Operating Permit is due within one year of the earliest commencement of operation of any piece of equipment covered by this permit. 22. 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 23. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation 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. 24. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation 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. 25. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 26. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 27. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division COLORADO Air Pollution Control Division Department of Ptc fe TdVGYirnc^t;( Page 5 of 9 olorado Air Quality Control Act and regulations of the Air isslo >FAst including failure to meet any express term or condition of e permi . the Division :ernes a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 28. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN ` �,' an annual fee to cover the costs of inspections and administration. If a source or activit : to be discontinued, the owner must notify the Division in writing requesting a cancellation of e permit. Upon notification, annual fee billing will terminate. 29. Violation of the ms 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: Christopher Kester Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Whiting Oil and Gas Corporation COLORADO Air Pollution Control Division Oep:o.sr kr,t r.,t Pub _ Heath 5..invirnnrneic Page 6 of 9 Notes mit issuance: 1) T it hfor 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. (Regulation Number 3, Part A, Section VI.B.) 2) The production based on the consum upon request of the control regulation or and complete appli terial processing limits and emission limits contained in this permit are ion rates requested in the permit application. These limits may be revised ner or operator providing there is no exceedance of any specific emission y ambient air quality standard. A revised air pollution emission notice (APEN) 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. AIRS Point Pollutant CAS # Uncontrolled Emissions (Ib/yr) Controlled Emissions (lb/yr) 005 (process 1 VRT Bypass) Benzene 71432 5,224 261 Toluene 108883 3,893 195 Ethylbenzene 100414 587 29 Xylenes 1330207 1,261 63 n -Hexane 110543 45,385 2,269 2,2,4- Trimethylpentane 540841 5,316 266 005 (process 2 - VRT Operational) Benzene 71432 168 8 Toluene 108883 133 7 Ethylbenzene 100414 20 1 Xylenes 1330207 54 3 n -Hexane 110543 1523 76 2,2,4- Trimethylpentane 540841 196 10 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. }COLORADO Air Pollution Control Division partment :; RAW:. a Seetltn & E^rfronr&ent Page 7 of 9 it are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source 0.003 0.003 AP 42 x • 0.013 0.013 V0C 1.7567 0.0878 VMG Simulation with pressurized upstream liquids sample analysis as inputs 71432 ngi:enzene 0.00382 0.0002 108883 !-_'luene 0.00285 0.0001 100414 Ethylbenzene 0.00043 0.00002 1330207 Xylene 0.00092 0.00005 110543 n -Hexane 0.03340 0.0017 540841 2,2,4-Trimethylpentane 0.00389 0.0002 Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. Point 005 (Process 2 - VRT Operational): CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source N0x 0.0004 0.0004 AP 42 CO 0.0020 0.0020 V0C 0.2377 0.011885 VMG Simulation with pressurized upstream liquids sample analysis as inputs 71432 Benzene 0.000185 0.000009 108883 Toluene 0.000142 0.000007 100414 Ethylbenzene 0.000020 0.000001 1330207 Xylene 0.000060 0.000003 110543 n -Hexane 0.001690 0.000085 540841 2,2,4-Trimethylpentane 0.000210 0.000011 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 permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Major Source of: V0C; Synthetic Minor Source of: HAPs PSD Synthetic Minor Source of: V0C COLORADO }AirPollutions Control Division raieq . bi Het ;n & Enos,?see t Page 8 of 9 http://ecfr.gpoaccess.gov/ vironment Electronic Code of Federal Regulations can be Part 60: Standards of Performance for New Stationary Sources NSPS 60. -E Subpart A - Subpart KKKK NSPS Part 60 ppendixes Appendix A - Appendix Part 63: Nation mission 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 oryvRt Page 9 of 9 DC ontrol Division Department of Public Health er Environment Permit number: Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: General Description: STRUCTION PERMIT Issuance: 1 Whiting Oil and Gas Corporation Horsetail 07 West CPB 123/9F6B SENW SEC 7 T10N R57W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description ENG-02 006 One (1) Caterpillar, G3516B, SN: JEF02642, natural gas -fired, naturally aspirated, 4SLB reciprocating internal combustion engine, site rated at 1311 horsepower. This emission unit is used for natural gas compression. Oxidation Catalyst and air/fuel ratio controller This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Caterpillar G3516B 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 the 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. COLORADO t Air Pollution Control Division DcpaY?'r ¢ Public l.feilltb Ena,ircriniMl Page 1 of 11 2. ( 80) of the latter of commencement of operation or issuance per nce th conditions contained in this permit shall be demonstrated to e Division. It is e 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. K.. ,'on Number 3,. Part B, Section III.G.2.) 3. This permit shall ' pire if the owner or operator of the source for which this permit was issued: (i) does not com '-nce construction/modification or operation of this source within 18 months after either, th date of issuance of this construction permit or the date on which such construction or - ity 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.) .A.4. ) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO), VOC CO ENG-01 006 --- 12.7 8.9 19.0 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. 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 are defined as any activity or equipment, which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. COLORADO Air Pollution Control Division 'melt t Pub*: i teas"h ss Ewnonment Page 2 of 11 8. list permit. b-' ow shall be operated and maintained with the emissions der to reduce emissions to less than or equal to the limits ion Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled ENG-01I +6 Oxidation Catalyst and air/fuel ratio controller VOC and CO PROCESS LIMITATIONS AND RECORDS 9. This source shalt 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 ENG-01 006 Consumption of natural gas as a fuel 92.1 MMscf The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 11. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. Et 4.) 12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) OPERATING Et MAINTENANCE REQUIREMENTS 13. 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 14. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements ICOLORADO Air Pollution Control Division Page 3 of 11 15. "_m -'s ` bject pen •i testing requirements of 40 C.F.R Part 63, Subpart ZZZZ. 16. ng s to • •ic testing requirements as specified in the operating and maintenance (OEM) 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 RE S UIR 17. A revised Air •oll =;ant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually , April 30th whenever a significant increase in emissions occurs as follows: For an ria 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 (NOr) 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. 18. This source is subject to the provisions of Regulation Number 3, Part C, Operating Permits (Title V of the 1990 Federal Clean Air Act Amendments). The application for the Operating Permit is due within one year of the earliest commencement of operation of any piece of equipment covered by this permit. 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 COLORADO Air Pollution Control Division Department d E Jrnnrnent Page 4 of 11 ity or operation of this source. Final authorization of the APCD in writing in accordance with the provisions of 25-7- 4.5(12 a . and Al __ egulation 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 auto:- - . Details for obtaining final authorization to operate are located in the Requiremen to el "` Certify for Final Authorization section of this permit. 22. This permit is iss : d in reliance upon the accuracy and completeness of information supplied by the owner or of_: rator and is conditioned upon conduct of the activity, or construction, installation an ration 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: Christopher Kester Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Whiting Oil and Gas Corporation COLORADO Air Air Pollution Control. Division .apavnent :r Puik_ 3- ier₹th n Livimmerc Page 5 of 11 Notes Per e H t . t the .• f th p mit issuance: 1) T ' . it h is d - - 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. (Regulation Number 3, Part A, Section VI.B.) 2) The production based on the consum upon request of the control regulation or and complete appli terial processing limits and emission limits contained in this permit are ion rates requested in the permit application. These limits may be revised ner or operator providing there is no exceedance of any specific emission y ambient air quality standard. A revised air pollution emission notice (APEN) 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. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 006 Formaldehyde 50000 9115 6330 Acetaldehyde 75070 785 785 Acrolein 107028 483 483 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) 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 006: CAS # Pollutant Uncontrolled Emission Factors g/hp-hr Controlled Emission Factors g/hp-hr Source N0x 1.00 1.00 Manufacturer Specifications CO 3.10 1.50 V0C 1.83 0.70 50000 Formaldehyde 0.36 0.25 75070 Acetaldehyde 0.00836 (lb/MMBtu) 0.00836 (lb/MMBtu) AP 42 107028 Acrolein 0.00514 (lb/MMBtu) 0.00514 (lb/MMBtu) 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 COLORADO Air Pollution Control Division I liATActine tt of Public Health & E rxnorsm: rt Page 6 of 11 e tions regarding a specific expiration date call the Division 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. tw/area/fr181a08.pdf 8) This facility is classifi • as follows: Applicable Requirement Status Operating Permit Major Source of: VOC; Synthetic Minor Source of: HAPs PSD Synthetic Minor Source of: VOC 9) 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 imers:s' Vubtt 11eLi k v eviro :rnei:! Page 7 of 11 ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS RE PROCATING INTERNAL COMBUSTION ENGINES October 12, 2012 1. 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. 1.1 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 1.1.2 and make them available to the Division upon request. 1.1.1 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 1.2. 1.1.2 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 1.2. COLORADO Air Pollution Control Division tU€� iie�tn u:;in�ra:t• :t Page 8 of 11 An Ai . ant E "•ns (A " ' ' ncludes 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 en ;pie Applicability Reports can be foundat tt•`://www.colorado.gov/pacific/cdphe/alternate-operating-scenario-aos-reporting- forms. This submittal shall accompanied by a certification from the Responsible Official indicating that "based on the information and be( f formed after reasonable inquiry, the statements and information included in the submittal are true, accurat=nd 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. 1.2 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 shalt 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 -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. 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 COLORADO Air Pollution Control Division I Depsrt,neri � e h G E sivortrr0ht Page 9 of 11 conside indicat to of the portable analyzer test until a portable analyzer test emission limitations or until the engine is taken offline. 1.3 Applicable Regulations for Permanent Engine Replacements 1.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B S II.D.2 All permanent replace = es that are located in an area that is classified as attainment/maintenance or nonattainment must ap ' ..so 'ably Available Control Technology (RACT) for the pollutants for which the area is attainment/maintenance or=,'onattainment. Note that both VOC and NOX are precursors for ozone. RACT shall be applied for any level of emis''.ns of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 attainment/maintenance area, @ACT 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 5O2: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (5 60.331) and 40 CFR Part 72 (5 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 1.3.2 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. 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 1.1.2. 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: [COLORADO I Air Pollution Control Division D,p rtrv_ ,t Pb..,: K≥,e.th Envir frrient Page 10 of 11 C. stru ., • n or cat' * . Emission Standards in G/hp-hr NOx CO VOC 100<Hp<500 January 1, 2008 January 1, 2011 2.0 1.0 4.0 2.0 1.0 0.7 500<Hp The source shall submit cop July 1, 2007 1, 2010 2.0 1.0 4.0 2.0 1.0 0.7 of the relevant App icability Reports required under Condition 2.1.2. 1.3.3 NSPS for stationary + . 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 1.1.2. 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 1.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 1.2. 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, S I.B (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. 1.3.4 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 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 1.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 1.2. 1.4 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. COLORADO Air Pollution Control Division PtIbii_ ).!Ntith (( ErNirorirrent Page 11 of 11 DO ontrol Division Department of Public Health b Environment Permit number: Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: General Description: STRUCTION PERMIT Issuance: 1 Whiting Oil and Gas Corporation Horsetail 07 West CPB 123/9F6B SENW SEC 7 T10N R57W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description ENG-01 007 One (1) Caterpillar, G3516B, SN: JEF02641, natural gas -fired, naturally aspirated, 4SLB reciprocating internal combustion engine, site rated at 1311 horsepower. This emission unit is used for natural gas compression. Oxidation Catalyst and air/fuel ratio controller This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Caterpillar G3516B 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 the 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. COLORADO Air Pollution Control Division Depart-6eof i'ubti F€666,16 f=rvro'arsner:C Page 1 of 11 2. �n u ed a �"ty d., ( 80) of the latter of commencement of operation or issuance ce =r3'th t:'- conditions contained in this permit shall be demonstrated to e Division. It is e 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. ,' - "on Number 3, Part B, Section III.G.2.) 3. This permit shall x pire if the owner or operator of the source for which this permit was issued: (i) does not corn -nce construction/modification or operation of this source within 18 months after either, th date of issuance of this construction permit or the date on which such construction or ity 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 ENG-01 007 --- 12.7 8.9 19.0 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. 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 are defined as any activity or equipment, which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. COLORADO Air Pollution Control Division 2i?%-r'x?ter;f C'.rrir6nmetit Page 2 of 11 8. he a :`'ss�n ;'ints ',: """"�' tabl�,b-"'ow shall be operated and maintained with the emissions list der to reduce emissions to less than or equal to the limits establishes in this permit. egu a ion Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled ENG-01 14 7 Oxidation Catalyst and air/fuel ratio controller VOC and CO 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 ENG-01 007 Consumption of natural gas as a fuel 92.1 MMscf The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 11. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. & 4.) 12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) OPERATING & MAINTENANCE REQUIREMENTS 13. 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 14. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements COLORADO Air Pollution Control Division L'rZorrroner,t or Puri;_ F eaE n v Cryvorr erl Page 3 of 11 15. testing requirements of 40 C.F.R Part 63, Subpart ZZZZ. 16. -ng s to -dic testing requirements as specified in the operating and maintenance (OEM) plan as approved by the Division. Revisions to your OEtM 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 RE • UIR 17. A revised Air ant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually „; April 30th whenever a significant increase in emissions occurs as follows: For an "`- ria 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. 18. This source is subject to the provisions of Regulation Number 3, Part C, Operating Permits (Title V of the 1990 Federal Clean Air Act Amendments). The application for the Operating Permit is due within one year of the earliest commencement of operation of any piece of equipment covered by this permit. 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 COLORADO A rPollution Control Division ..zP::rE?'r_•: t -fir Vey Seukh'v £≥raarrner Page 4 of 11 ti ity or operation of this source. Final authorization of the APCD in writing in accordance with the provisions of 25-7- 4.5(12 a .R. . and As egulation 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 aut • Details for obtaining final authorization to operate are located in the Requiremen to el !`Certify for Final Authorization section of this permit. 22. This permit is iss a�, d in reliance upon the accuracy and completeness of information supplied by the owner or o rator and is conditioned upon conduct of the activity, or construction, installation an ration 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: Christopher Kester Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Whiting Oil and Gas Corporation COLORADO Air Pollution Control Division Departr'lem of P ubkw I'{E'i3 *' 6 t6:SIYOY'3;11S:C Page 5 of 11 Notes Per =:' H e . t the " ""� f th ,^ p mit issuance: 1) T = -s1t h 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. (Regulation Number 3, Part A, Section VI.B.) 2) The production based on the consum upon request of the control regulation or and complete appli terial processing limits and emission limits contained in this permit are on rates requested in the permit application. These limits may be revised ner or operator providing there is no exceedance of any specific emission y ambient air quality standard. A revised air pollution emission notice (APEN) 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. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 007 Formaldehyde 50000 9115 6330 Acetaldehyde 75070 785 785 Acrolein 107028 483 483 Note: All non -criteria reportable pol utants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) 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 007: CAS # Pollutant Uncontrolled Emission Factors g/hp-hr Controlled Emission Factors g/hp-hr Source N0x 1.00 1.00 Manufacturer Specifications , CO 3.10 1.50 V0C 1.83 0.70 50000 Formaldehyde 0.36 0.25 75070 Acetaldehyde 0.00836 (lb/MMBtu) 0.00836 (lb/MMBtu) AP 42 107028 Acrolein 0.00514 (lb/MMBtu) 0.00514 (lb/MMBtu) 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 shalt 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 COLORADO Air Pollution Control Division Dzpert ; nt Ph } i th.0 E-ranaranent Page 6 of 11 as at ions regarding a specific expiration date call the Division 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.epatw/area/fr18ja08.pdf 8) This facility is classifi '• as follows: Applicable Requirement Status Operating Permit Major Source of: V0C; Synthetic Minor Source of: HAPs PSD Synthetic Minor Source of: V0C 9) 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 epratme t of ik.Vic t e M ..v l ;vaorrne t Page 7 of 11 ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS RE PROCATING INTERNAL COMBUSTION ENGINES October 12, 2012 1. 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. 1.1 Engine Replacement 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 1.1.2 and make them available to the Division upon request. 1.1.1 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 1.2. 1.1.2 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 1.2. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shalt 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 COLORADO Air Pollution Control Division D33=Paerlent P3.33,333:, 333.3.33.313-3_* E tia`Orv:tert Page 8 of 11 operate ; scena a i .tallin ane: r`�lacement engine, and a copy of the relevant Applicability Reports for the plac . ent gi Ex pie lity Repo •e :`• •" a "'""" :'^ .// .. `.do.gov/pacific/cdphe/alternate-operating-scenarioraos-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 use • , nent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to e issi li its. The owner or operator shall ', ree to pay fees based on the normal permit processing rate for review of information submitted to the Division in -gard to any permanent engine replacement. 1.2 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-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. 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. 1.3 Applicable Regulations for Permanent Engine Replacements 1.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B § II.D.2 COLORADO Air Pollution Control. Division oepartmert of Pub Fe f', t1;YN'GYV?ti?nt Page 9 of 11 All per : Went 'pla t engi'�" : t ar "o '' ted in an area that is classified as attainment/maintenance or nonatt. men 'ust .•pl easy, ably aila Control Technology (RACT) for the pollutants for which the area is attai - _ `"" aint tai - . '•"'- 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 prey M10, if the potential to emit of NOX or S02 exceeds 40 tons/yr. For purposes of this AOS, e following shall be considered RACT for natural gas fired reciprocating internal combustion engines: VOC: The emissio tations 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 (5 60.331) and 40 CFR Part 72 (5 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 1.3.2 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. 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 1.1.2. 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 100<Hp<500 January 1, 2008 January 1, 2011 2.0 1.0 4.0 2.0 1.0 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. 1.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ OLORADO ollution Control Division t Jr Publi: Health u €7,imriment Page 10 of 11 A perm ent r� ac: a engin.- "" . 's ma fa tured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1 X008' en,=nesss tr°•n 50l.� p, 1/2007 for engines greater than or equal to 500 hp except for lean burn =' " - grea . n . : •.l t. • • • . d 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 1.1.2. 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 un. .n 1.2, if approved in advance by the Division, provided that such test is conducted within the time frame s ect.'z-d i Condition 1.2. Note that under the provisi s of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of the State of Colorado into t State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the •. - hat 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, S 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. 1.3.4 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 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 1.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 1.2. 1.4 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. COLORADO Air Pollution Control Division pet61';f, E•wiromteft Page 11 of 11 RcceMr,J► !Polls 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.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: `\Li AIRS ID Number: IZT /9 t-6/ ,/CL) I [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification: SEP-01 through SEP-16 [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Site Name: Whiting Oil and Gas Corporation Horsetail 07 West CPB Site Location: SENW Section 7, T10N, R57W 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: 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-211 - Natural Gas Venting APEN - Rev 03/2017 COLORADO 1 Dgeumret el Public . Ne4glb Farveeefeeee 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 ownership3 ❑ 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: 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 (8) heater treaters. Flaring associated gas from (8) 2 -phase separators For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: / / 07 / 19 / 2017 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 APEN - Rev 03/2017 days/week weeks/year ❑ Yes ❑ Yes ❑✓ No El No 'COLORADO 2 I AV of wua HealN6 F.nV11MID1nt 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: Model: ❑ Blowdown 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: 500,000 SCF/hr Vent Gas Heating Value: 1 545 BTU/SCF Requested: 109.5 - 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 %) 23.66 VOC (Weight %) 46.23 - Benzene (mole %) 0.031 Benzene (Weight %) 0.086 Toluene (mole %) 0.191 Toluene (Weight %) 0.618 Ethylbenzene (mole %) 0.038 Ethylbenzene (Weight %) 0.142 Xylene (mole %) 0.071 Xylene (Weight %) 0.263 n -Hexane (mole %) 0.255 n -Hexane (Weight %) 0.773 2,2,4-Trimethylpentane (mole %) 0.0205 2,2,4-Trimethylpentane (Weight %) 0.082 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 ft n -Hexane, temperature, and pressure) CI Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017 3 I M�(COLORADO ,"' Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information 40.856353/-103.797294 TM O era s c I of Diisc arge, eigh : ... , ro e �� em P Y � FtQV& at max hK 6 ti " �e oat FLR-01 40 >2,000 4,167 199 Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Downward ❑ Horizontal ❑ Other (describe): 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: Size: Make/Model: Requested Control Efficiency VRU Downtime or Bypassed % ❑ Combustion Device: Pollutants Controlled: VOC and HAPs Rating: 598 MMBtu/hr 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 Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating 1,545 'Btu/scf 0.44 MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested 0/0 Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017 COLORADO 4 I �. CO�.,, Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # 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? 0 Yes 0 No If yes, please describe the control equipment AND state the overall control efficiency (% reduction): Pollutants 14 R ara A- Control Equipment Descnptton , Overall Re iueste Control a Efficiency PM SOX 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: 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.) - Polliitant # fi F Uncontrolled Emission ' Factor Ernissio t Fact r, ' Umi{f -.Emission factor , Source r.Y r. :: ,. Actu 11n a�Eisissio R ,:r til Requested 1 a er >Ik -t-- Uncontrolled zCor trolledlt lncontrolled 'Cofifrollgd PM 0.0075 lb/MMBtu AP -42 De Minimis SOX 0.963 Ib/MMscf Gas Analysis De Minimis NO), 0.068 lb/MMBtu AP -42 5.88 , VOC 34,715.84 Ib/MMscf Gas Analysis 1900.7- 95.03 - CO 0.31 lb/MMBtu AP -42 24.51 - Benzene ` 64.44 IblTvlMscf Gas Analysis 3.53 — 0.18 -- Toluene 464.10 IbMlMscf Gas Analysis 25.41 - 1.27 - Ethylbenzene 106.34 Ib/MMscf Gas Analysis 5.82 - 0.29 Xylenes 197.55 Ib/MMscf Gas Analysis 10.82 - 0.54 i n -Hexane 580.14 Ib/MMscf Gas Analysis 31.76 - 1.59 - 2,2,4-61.72 Trimethyipylpentane Ib/MMscf Gas Analysis 3.38 - 0.17 - 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 COLORADO 5I•.Ilepartmentaf Public lYYN b EnNno.uevM 49 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. January 10, 2018 Signs a of Legally Authorized Person (not a vendor or consultant) J cob Parker Name (please print) Date Environmental Professional Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance 0 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 C01.1211 ADO 6 Keteive4 1301 it 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: 1 Z3 /9C0/001_ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification: SEP-26 and SEP-27 [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: Horsetail 07 West CPB Site Location: SENW, Section 7, T1 ON, R57W Mailing Address: (Include 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. Form APCD-205 - Natural Gas Venting APEN - Rev 03/2017 COLORADO 1I t Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit 4 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' ❑ 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: 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 flash gas from Vapor Recovery Towers For existing sources, operation began on: For new or reconstructed sources, the projected 2 / start-up date is: 0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: / / 1 / 2018 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 ❑✓ No ❑ Yes ❑✓ No Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 2 I AyCOLORADO k�nw� 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: Model: ❑ Blowdown 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: SCF/hr Vent Gas Heating Value: BTU/SCF Requested: MMSCF/year Actual: MMSCF/year -OR- Requested: 2,263,000 Bbl/yr Actual: Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) sho�li ld consider future process growth Process Properties: Molecular Weight: VOC (mole %) 62.26 voC (Weight %) 75.25 Benzene (mole %) 0.044 Benzene (Weight %) 0.079 Toluene (mole %) 0.033 Toluene (Weight %) 0.069 Ethylbenzene (mole %) 0.005 Ethylbenzene (Weight %) 0.012 Xylene (mole %) 0.013 Xylene (Weight %) 0.021 n -Hexane (mole %) 0.345 n -Hexane (Weight %) 0.684 2,2,4-Trimethylpentane (mole %) 0.037 2,2,4-Trimethylpentane (Weight %) 0.096 Additional Required Information: ❑ Attach a representative gas analysis (including BTEX 8 n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX 8 n -Hexane, temperature, and pressure) p Form APCD-2O5 -Natural Gas Venting APEN - Rev 03/2017 ,COLORADO 3,A®,, Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit and AIRS ID] Section 5 - Stack Information Geographical Coordinates atitudefLongitude or UTM) 40.856353/-103.797294 z ` Operator-.' Stack ID No Discharge Height Above G ou d Level (Feet) �4 Ate. ° emp T �� a �'' kg Blow Rate « (A FM) " F Veloci ' #�{ s ..• FLR-02 40 >2000 16.6 1.4 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): ❑ Other (describe): ❑ Upward with obstructing raincap 6 Section 6 - Control Device Information ❑✓ VRU: Pollutants Controlled: VRT Gas (VOC and HAPs) Size: 60 -hp electric Requested Control Efficiency VRU Downtime or Bypassed Make/Model: 100 12 Jordan Tech nologies/J-SCG10-3.05-60 3603 ❑ Combustion Device: Pollutants Controlled: VRT Gas (VOC and HAPs) Rating: 148 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 2,456 Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating 0.44 MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested 0 Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 4I Ater /S_►� Hepvm E u 111. Ate HeO L Enwe�D O Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # 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. wa Efen %`reduction n` emissions) PM SOX 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: 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.) ollutan Pt � Uncontrolled Emission Factor '` ' - Emission' Factor Units`_:.--6.04417-:Uncontrolled '- • Emission Factor Source r�Requst� ActualAnnual Erniili nS '` * ' `� � IsSlo nf7al ']t;°. 1711 Mfg"etc) (Tons/yer)a Controlled6 -(fops/year')> Uncontrolled : (Tons)year)'' ' r Conteolled (T4nilyear)` PM 0.0075 lb/MMBtu Ib/MMBtu De Minimis SOx NOx 0.068 - lb/MMBtu AP -42 De Minimis VOC 2.7636 ' lb/bbl VMG 375.24 / 18.76' CO 0.310 ' lb/MMBtu AP -42 3.05' Benzene 0.0029 - lb/bbl VMG 0.39/ 0.02 ' Toluene 0.0025 - lb/bbl VMG 0.35 - 0.02 ' Ethylbenzene 0.0004 — lb/bbl VMG 0.06 / 0.003 ' Xylenes 0.0012 , lb/bbl VMG 0.16 / 0.01 , n -Hexane 0.0251 lb/bbl VMG 3.41 . 0.17 2'2'4 Trimethylpentane 0.0035' lb/bbl VMG 0.48 ' 0.024 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider futureprocess growth. 6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-2O5 -Natural Gas Venting APEN - Rev 03/2017 51 AVVCOLORADO 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 Le January 10, 2018 y orized Person (not a vendor or consultant) Ashley Brinkerhoff 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 Form APCD-205 -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 Ay COLORADO 6 I • H m"",°"° Heat. 6 . of Men. received 11 Iol It Produced Water Storage Tank(s) APEN - Form APCD-207 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 tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, 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 and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. 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: r? .., —S / I V, ,/CL) 3 [Leave blank unless APCD has already assigned a permit f# and AIRS ID] Section 1 - Administrative Information Company Name': Whiting Oil and Gas Corporation Site Name: Horsetail 07 West CPB Site Location: SENW Section 7, T10N, R57W Mailing Address: (Include Zip Code) 1700 Broadway, Suite 2300 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 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-207 - Produced Water Storage Tank(s) APEN - Revision 07/2017 COLORADO 1 I HWNbEnvVeitm�� eix 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 E Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP05 ❑ GPM If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN filing fee. - OR ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment ❑ Change company name ❑ Change permit limit ❑ Transfer of ownership' ❑ Other (describe below) OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a 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: For existing sources, operation began on: (8) 400 bbl produced water tanks For new or reconstructed sources, the projected start-up date is: July 19, 2017 Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week ❑✓ Exploration £t Production (EEtP) site 52 weeks/year LI Midstream or Downstream (non EFtP) site Will this equipment be operated in any NAAQS nonattainment area? • Yes • No Are Flash Emissions anticipated from these storage tanks? IS Yes • No Are these storage tanks located at a commercial facility that accepts oil production• wastewater for processing? Yes No D Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? ■ Yes p No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No • 4 Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No • p Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2017 ,COLORADO 2 I ®' �mdwui x..�imtrcnweNn.m Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit A and AIRS ID] Section 4 - Storage Tank(s) Information Adual Annual Amount- '' bbl% ear . Requested Annual Permit Limrt4. /year) ear (1)61 Produced Water Throughput: 5,475,000 From what year is the actual annual amount? Tank design: 0 Fixed roof ❑ Internal floating roof ❑ External floating roof Storage Tank ID, # of Liquid Manifold Storage Vessels in Storage Tank. Total,Volume of Storage Tank (blot) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date -of First Production. (month/year) PW-01 to PW-08 8 3,200 06/2017 07/2017 ells Serviced by this Storage Tank or Tank Battery (E&P: Sites Only); um arse of ewly Reported Well 05 - 123 - 36647 Horsetail 07-0611H 05 - 123 -41651 Horsetail 07E-0601 El 05 - 123 - 41647 Horsetail 07E-0602 05 - 123 -41649 Horsetail 07E-0603 05 - 123 -41652 Horsetail 07E-0604 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 5 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates - 40.856353/-103.797294 Operator Stack -= ID No. - Discharge Height Above ;"" Ground Level (feet), Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) -. COMB -01 35 >2000 20.8 0.01 Indicate the direction of the stack outlet: (check one) D Upward ❑ Horizontal ❑ Downward ❑ Other (describe): ❑ Upward with obstructing raincap Indicate the stack opening and size: (check one) B Circular Interior stack diameter (inches): 96 ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): Form APCD-2O7 - Produced Water Storage Tank(s) APEN - Revision 07/2017 COLORADO 3I 6 "' Mea1N E+Mronmen+ Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor ❑ Recovery Unit (VRU): Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: ❑ Combustion r Device: Pollutants Controlled: VOC and HAPs Rating: 42.5 MMBtu/hr Type: Open Flare Make/Model: Crimson Energy/CE 1000 Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: N/A 95 % 98 Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: 1,844 0.06 Btu/scf MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 -Gas/Liquids Separation Technology Information (E£tP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 53 psig Describe the separation process between the well and the storage tanks: A combined stream of liquids and natural gas is extracted from the wells and transferred to eight (8) 2 -phase separators wheregasis separated from liquids. The liquids are transferred to eight (8) heater treaters that are each equipped with a burner to facilitate further separation into streams of gas, crude oil, and produced water. The separated streams of crude oil and produced water are transferred to storage tanks. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2017 COLORADO 4I _I; "'—`717,:' Hyolueent VOC Enclosed Combustor Permit Number: AIRS ID Number: / / (Leave blank unless APCD has already assigned a permit tt and AIRS ID] Section 8 - Emissions Inventory Information Attach alt emissions calculations and emission factor documentation to this APEN form6. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Overall Requested. Control, Efficiency 95 NOx CO HAPs Enclosed Combustor 95 Other: From what year is the following reported actual annual emissions data? Uncontrolled Basis Units Criteria, Pollutant Emissions Inventory Source P42, Mfg. etc) ctual Annual Em>ssions Uncontrolled. Emissions (Tons/year) VOC 0.115 lb/bbl Flash Analysis 314.4 — 15.7 Uncontrolled Emissions ', (Tons/year) NOx 0.068 lb/MMBtu AP -42 De Minimis CO 0.31 lb/MMBtu AP -42 2.87 — Non -Criteria Reportable Pollutant Emissions Inventorye t Chemical Name Chemical Abstract. Service CAS (. ) Number Mission -Factor: . Actual Annual Emissions lncontrolled Basis Units - Source (AP 42,= Mfg. etc g � - ,A, Uncontrolled Emissions,- Pounds/ear i y ) y Controlled ssi Emissions :. (Pounds ye �- Benzene 71432 0.0003 lb/bbl Flash Analysis Ve(.OG $3 Toluene 108883 0,0001 lb/bbl Flash Analysis SCI S Z 7 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.0400 lb/bbl Flash Analysis Z1 % 199 169 SO 2,2,4- Trimethylpentane 540841 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-207 - Produced Water Storage Tank(s)-APEN - Revision 07/2017 COLORADO 5 I A. o • Huth b sms o.,S .R, 36 Permit Number. AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and MRS [DI Section 9 - 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 r- stration for covge under General Permit GP05 or GP08, I further certify that this source is and will be operated compliance ondition of the applicable General Permit. January 10, 2018 Signe of Legally Authorized Person (not a vendor or consultant) Date cob Parker Environmental Professional Name (print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance Q 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 5250, 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 For more information or assistance call: 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-2O7 - Produced Water Storage Tank(s) APEN - Revision 07/2017 6 I ascOLo!Aao ....•.r..w. Rtaivi1 YI.Tn/i r Crude Oil Storage Tank(s) APEN - Form APCD-210 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 tanks that store crude oil associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. condensate storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Fdrm APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. 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: 12, 3 / 11tt f / (xj7' [Leave blank unless APCD has already assigned a hermit # and AIRS ID] Section 1 - Administrative Information Company Name': Whiting Oil and Gas Corporation Site Name: Horsetail 07 West CPB Site Location: SENW Section 7, T1 ON, R57W Mailing Address: (Include Zip Code) 1700 Broadway, Suite 2300 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-210 - Crude Oil Storage Tank(s) APEN - Revision 07/2017 1 AVCOLORADO Da•ranert of wwc 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 ❑✓ Request coverage under traditional construction permit ❑ Request coverage under General Permit GP08 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN filing fee. -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment ❑ Change company name ❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et 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: For existing sources, operation began on: (14) 400 bbl crude oil tanks For new or reconstructed sources, the projected start-up date is: July 19, 2017 Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 weeks/year 0 Exploration a Production (E£EP) site ❑ Midstream or Downstream (non EFtP) site Will this equipment be operated in any NAAQS nonattainment area? • Yes • No Are Flash Emissions anticipated from these storage tanks? • Yes • No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No p Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual• emissions ≥ 6 ton/yr (per storage tank)? Yes No D Form APCD-21O - Crude Oil Storage Tank(s) APEN - Revision 07/2017 COLORADO 2 I ° °�of Rea.6 Enwenmtnt Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) -Requested Annual Permit Limit' - - (bb(/year) Crude Oil Throughput: 2,263,000 2,263,000 From what year is the actual annual amount? Permitted Average API gravity of sales oil: 34.0 degrees Tank design: ❑✓ Fixed roof ❑ Internal floating roof RVP of sales oil: 4.8 ❑ External floating roof Storage Tank ID # of Liquid Manifold, Storage, Vessels in Storage Tank Total Volume of : Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production: ,: (month/year) TK-01 toTK-14 14 5,600 06/2017 07/2017 API .Number .. Wells Serviced by this Storage Tank or Tank Battery5. (EEtP Sites On y) Name`of Well Newly Reported Well 05 - 123 - 36647 Horsetail 07-0611H ❑ 05 - 123 - 41651 Horsetail 07E-0601 05 -123 -41647 Horsetail 07E-0602 05 - 123 - 41649 Horsetail 07E-0603 05 - 123 - 41652 Horsetail 07E-0604 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 5 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.856353/-103.797294 Operator Stack - ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) COMB -01 35 >2000 54 0.02 Indicate the direction of the stack outlet: (check one) ❑� Upward ❑ Horizontal ❑ Downward ❑ Other (describe): ❑ Upward with obstructing raincap Indicate the stack opening and size: (check one) Circular Interior stack diameter (inches): 96 ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): Form APCD-21O - Crude Oil Storage Tank(s) APEN - Revision 07/2017 ,COLORADO 3 IAV H)=- XaLL+hbEnvbenm m Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: ❑ Combustion Device: Pollutants Controlled: VOC and HAPs Rating: 42.5 Type: Open Flare MMBtu/hr Make/Model: Crimson Energy/CE 1000 Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: N/A Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: 2,357 0.06 Btu/scf MMBtu/hr ❑ Closed Loop System Description of the dosed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: % Section 7 -Gas/Liquids Separation Technology Information (E8 P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 51 psig Describe the separation process between the well and the storage tanks: A combined stream of liquids and natural gas is extracted from the wells and transferred to eight (8) 2 -phase separators where gas is separated from liquids. The liquids are transferred to eight (8) heater treaters. Produced water is transferred to storage tanks, and crude oil is transferred to two (2) VRTs and then to the storage tanks. Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 07/2017 COLORADO 4I AV '' c HeYN b FnWrnmtn Benzene VOC Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit n and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form6. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Descnption of Control Methods Overall RequestedControl Efficiency _ ,... (% reduction in emissions, Enclosed Combustor 95 NOx CO HAPs Enclosed Combustor 95 Other: From what year is the following reported actual annual emissions data? Permitted Criteria Pollutant Emissions Inventory VOC Uncontrolled Basis Emission Factor Controlled Emissions (Tons/year) Requested Annuai Pennil Emission Limit(s), Units Source SAP -42, Mfg. etc) Uncontrolled:. Emissions • -(Tons/year)' Uncontrolled Emissions (Ton /year): ontrolled`' •missions (Tons/year): 1.7567/0.2377 lb/bbl Flash AnalysisNMG 1300.23 ' 65.01 ' NOx 0.068 Ib/M M Btu AP -42 2.31 " CO 0.31 Ib/MMBtu AP -42 9.67 ' on -Criteria Reportable Pollutant Emissions Inventory Chemical Abstract Service (CAS) Number Emission fFactorb Uncontrolled._ Basis ' Units Source` (AP 42,` Mfg. etc) ctual Annual Emissions 5,392.6 269.6 71432 0.0038 / 0.0002 lb/bbl Flash AnalysisNMG Toluene 108883 0.0029 / 0.0001 lb/bbl Flash AnalysisNMG 4,025.6 i 201.3 Ethylbenzene 100414 0.0004 / 0.00002 lb/bbl Flash AnalysisNMG 606.9 30.3 , Xylene 1330207 0.0009 / 0.0001 lb/bbl Flash AnalysisNMG 1,314.8 ' 65.7 ' n -Hexane 110543 0.0334 / 0.0017 lb/bbl Flash AnalysisNMG 46,908.6 2,345.4 2,2,4- Trimethylpentane 540841 0.0039 / 0.0002 lb/bbl Flash AnalysisNMG. 5,512.5 - 275.6 ' 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 Attach crude oil laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-21O - Crude Oil Storage Tank(s) APEN - Revision 07/2017 • COLORADO 5 I 1{uMbEnvhnnnlnl Permit Number: AIRS ID Number: {Leave blank unless APCD has already assigned a permit = and AIRS ID] Section 9 - 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 GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. Signature of Lega January 10, 2018 zed Person (not a vendor or consultant) Date Ashley Brinkerhoff Environmental Professional Name (print) Title Check the appropriate box to request a copy of the: 0✓ Draft permit prior to issuance [-J 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 $250, 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 For more information or assistance call: 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-210 - Crude Oil Storage Tank(s) APEN - Revision 07/2017 6 Av COCOLOLO R::.D ''ADO IIffahT 6 Enwaruvn� 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: C- AIRS ID Number: 113 / I4Z/00 [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: Horsetail 07 West CPB Site Location: SENW, Section 7, T10N, R57W 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 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-2O1 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 COLORADO 1 1AVa im tWINbEnN�eMnnM 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 ❑ Change permit limit ❑ APEN submittal for update only ❑ Transfer of ownership4 ❑ Other (describe below) -OR- - 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) Normal Hours of Source Operation: 24 Seasonal use percentage: Dec -Feb: 25 August 18, 2017 ❑Yes ✓❑No hours/day 7 days/week 52 weeks/year Mar -May: 25 June -Aug: 25 Sept -Nov: 25 Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 2 A® Department COLORADO of r..Lk Ru1�A6 En,t, .,,nnl 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 ❑ Pump ❑ Water Pump ❑ Emergency Back-up 0 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: G3516B hours/year Serial Number6: JEF02642 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? 1,311 hp - kW What is the engine Brake Specific Fuel Consumption at 100% Load? 8,180 BTU/hp-hr Engine Features: Cycle Type: ❑ 2 -Stroke ❑✓ 4 -Stroke Combustion: 0 Lean Burn ❑ Rich Burn Ignition Source: ❑ 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? 0 Oz Sensor (mV) ENO Sensor (ppm) Is this engine equipped with a Low-NOX design? ❑ Yes 0 No Engine Dates: What is the manufactured date of this engine? February 26 2014 ❑ Other: What date was this engine ordered? May 30, 2017 What is the date this engine was first located to Colorado? May 18, 2017 What is the date this engine was first placed in service/operation? August 18, 2017 What is the date this engine commenced construction? May 18, 2017 What is the date this engine was last reconstructed or modified? N/A Is this APEN reporting an AOS replacement engine? ❑ Yes 0 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 GPOZ is requested. Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 COLORADO- 3 AV , XrIW b EnNennrtwM Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates 40.856353/-103.797294 xr � Operator of ;Al 3l t-.ek n p c r e Hei t Above Groun Le elac Temp 0... ' a Flow Rate � ' Velocity } - ENG-02 23.7 1,027 9,057 192.3 Indicate the direction of the Stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) E Circular ❑ Square/Rectangle ❑ Other (describe): Interior stack diameter (inches): 12 ❑ Upward with obstructing raincap Interior stack diameter (inches): Interior stack depth (inches): Section 6 - Fuel Data and Throughput Information Fuel Use ate @ 100% Loader 7�(SCF hour) 3 t 5�h1SCFi/yearj Actual Arl uial�u flu -el -Use v c 2 :Requested Annual Per it'Urn N„ (N SCE/year 10,514 92.10 From what year is the actual annual amount? Indicate the type of fuel used': ❑✓ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf) O 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 1f.xP..m�4 mn5u Hulce 6 Envs+onme.0 Formaldehyde TSP (PM) Permit Number: AIRS ID Number: [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): Primary Control Equipment Description Overall Requested Control Efficiency Moth PM2.5 SOX NOx VOC SCO with AFRC 61.7% CO SCO with AFRC 48.4% 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? TSP (PM) Uncontrolled Basis Units Criteria Pollutant Emissions Inventory Source (AP 42, Mfg. etc) Uncontrolle Emissions' (Tons/year), nested Annual Permit Emission Limit(s)7 " Uncontrolled Emissions a," , (Tons/year) Controlled 4 Emissions ` (Tons/year) r .` 0.00991 Ib/MMBtu AP -42 De Minimis De Minimis PM 10 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 1.00e g/hp-hr NSPS JJJJ 12.7 - 12.7 CO 1.83 g/hp-hr Manf Spec 23.2 0- 8.9 - g/hp-hr Manf Spec 39.2 e 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: ❑✓ Yes ❑ No Non -Criteria Reportable Pollutant Emissions Inventory Chemical Abstract Service (CAS) Number: Emission Factor Uncontrolled 7. :x Basis Umts J Source (AP -42, r :.Mfg.etc)_ 50000 0.36 g/hp-hr Manf Spec Acetaldehyde Acrolein Benzene 75070 107028 71432 0.00836 0.00514 Ib/MMBtu Ib/MMBtu AP -42 AP -42 dual Annual Emissions' Uncontrolled Emissions Poundslveari 91►S CI g3 Controlled Emissions-, (Pounds year) �GG,3v -OS 981 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 UV COLORADO 5II&XulUi 6 Envtmnm�nf 30 Permit Number. AIRS ID Number: / / (Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification 1 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 comp,�ial�e with eadition of general permit GP02. January 10, 2018 Signal 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 Q 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 5152.90 and the General Permit registration fee of 51,500, 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://iwnv.colorado.gov/cdphe/apcd Form APCD-201- Reciprocating Internal Combustion Engine APEN - Revision 1/2017 COloNA00 6( ':~ Rtcrci•iti 0011% 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: `23 / f r4 B /cDV -7 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Site Name: Whiting Oil and Gas Corporation Horsetail 07 West CPB Site Location: SENW, Section 7, T1 ON, R57W 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 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 1 A® COLORADO Deparbarstd Public HWN& Env`aannunl 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 ❑ Change permit limit ❑ Transfer of ownership' D Other (describe below) -OR - ❑ APEN submittal for update only - 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.cotorado.Rov/cdphe/attainment) Normal Hours of Source Operation: 24 Seasonal use percentage: Dec -Feb: 25 August 18, 2017 ❑ Yes 0 No hours/day 7 days/week 52 weeks/year Mar -May: 25 June -Aug: 25 Sept -Nov: 25 Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 COLORADO 2 I R" w=cm.,Z,� .m 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 ❑ Pump ❑ Water Pump E Emergency Back-up ❑ Other: ❑✓ Compression What is the maximum number of hours this engine will be used for emergency back-up power? 0 Engine Make: Caterpillar Engine Model: G3516B Serial Number6: JEF02641 hours/year 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? 1,311 hp kW What is the engine Brake Specific Fuel Consumption at 100% Load? 8,180 BTU/hp-hr Engine Features: Cycle Type: ❑ 2 -Stroke ✓❑ 4 -Stroke Combustion: ❑✓ Lean Burn ❑ Rich Burn Ignition Source: ❑ Spark ❑ Compression Aspiration: ❑ Natural -❑ Turbocharged Is this engine equipped with an Air/Fuel ratio controller (AFRC)? ❑✓ Yes ❑ No If yes, what type of AFRC is in use? ❑✓ OZ Sensor (mV) ❑NOX Sensor (ppm) Is this engine equipped with a Low-NOx design? ❑ Yes ❑✓ No Engine Dates: What is the manufactured date of this engine? February 26, 2014 ❑ Other: What date was this engine ordered? May 30, 2017 What is the date this engine was first located to Colorado? May 18, 2017 What is the date this engine was first placed in service/operation? August 18, 2017 What is the date this engine commenced construction? May 18, 2017 What is the date this engine was last reconstructed or modified? N/A Is this APEN reporting an AOS replacement engine? ❑ 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 mustbe submitted if coverage under GP02 is requested. Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 3 ACOLORADO _ x."roN Permit Number: AIRS ID Number: / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information 40.856353/-103.797294 Operator �t�ck lD Plo 9 c,+�-- Discharge H fight � Above Ground Levelk�� ,� ti� 1 Temp A .n. vd Y < Flow Ra ted €a F°d' a r Velocity s�, ENG-01 23.7 1,028 9,057 192.3 Indicate the direction of the Stack outlet: (check one) ❑ Downward ❑ Other (describe): ❑✓ Upward E Horizontal Indicate the stack opening and size: (check one) ❑✓ Circular ❑ Square/ Rectangle ❑ Other (describe): Interior stack diameter (inches): 12 ❑ Upward with obstructing raincap Interior stack diameter (inches): Interior stack depth (inches): Section 6 - Fuel Data and Throughput Information S� Fueel Use Rate C� 1OO Load ry (SCF/hour) f Actua Annual Fue Se (�VIMSCF/years-: rh RequesteddAnnual Permit L it' M4MSCFI year) , z 10,514 92.10 - From what year is the actual annual amount? Indicate the type of fuel used': ❑✓ 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 I AV COLORADO 4 xP,m��mdwee� Has1.N 6 Ga.vmm�N 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): Overall Requested Control ,•, Efficiency PM10 PM2.5 SOx NOx VOC SCO with AFRC 61.7% CO SCO with AFRC 48.4% 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? Criteria Pollutant Emissions Inventory,--,---:-., _ Emission Factor Actual Annual Emissionsg / ..,p , .r rc > . Requested Annua[ Permit Emission Unit t Pollutant Uncontrolled gals Units Source (AP 42 N1fg. etc) ' Uncontrolled Emissions ': = (Tons/yearV Controlled { Emissions : (Tonsl year) Uncontrolled Emissions sl year); - Controlled Emissions " Tonslyear) . . 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 NOx 1.0 ' g/hp-hr NSPS JJJJ 12.7 / 12.7 / VOC 1.83 ' g/hp-hr Manf Spec 23.2 / 8.9 i CO 3.10 / g/hp-hr Manf Spec 39.2 i —29:2 • /Q(f 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 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Abstract'', Service (CAS) Number Emission Factor'; Actual Annual Emissions. ncontrolled'::' Basis g/hp-hr Manf Spec Jncontrolled �' Emissions' Pounds/year) 50000 0.36 Acetaldehyde 75070 0.00836 Ib/MMBtu AP -42 =Controlled Emissions (Pounds/year)y , 33J -$5 Acrolein 107028 0.00514 Ib/MMBtu AP -42 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 WV COLORADO 5 1 7Nm .1u�N 6 EnwaNraN 24 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 comp >-1 "e with each h coil ition of general permit GP02. January 10, 2018 Sign . of Legally Authorized Person (not a vendor or consultant) Date acob Parker Environmental Professional Name (please print) Title Check the appropriate box to request a copy of the: El 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 Or visit the APCD website at: Denver, CO 80246-1530 Make check payable to: https://www.colorado.gov/cdphe/apcd Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 6 IR, cocORAao Hello