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Home My WebLink About20180256.tiffCOLORADO Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 January 2, 2018 Dear Sir or Madam: RECEIVED JAN 0 8 2013 WELD COUNTY COMMISSIONERS On January 4, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for Whiting Oil and Gas Corporation - Horsetail 29G . 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 8 Environment APCD-SS-B1 430O 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., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer 'LVk Iic. maule_GO CG: PL C►tAMiTP) l-iLC T7') , 01- `�—t$ PWCE12!am/ ,7741CK) Of -2z —/$ 2018-0256 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Whiting Oil and Gas Corporation - Horsetail 29G - Weld County Notice Period Begins: January 4, 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 29G Oil and gas production facility SWNE Section 29 T10N R57W Weld County The proposed project or activity is as follows: Source is proposing to increase throughput to condensate storage tanks based on the addition of one (1) new well. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 17WE1002 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: Bradley Eades 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: Package It: Received Date: Review Start Date: Section 01 - Facility Information Company Name: Whiting Oil and Gas Corporation County AIRS ID: 123 Plant AIRS ID:. 9003 - Facility Name: Horsetail 29G Production Battery Physical Address/Locatio SWNE quadrant of Section 296, Township -SON, Range. 57W, in Weld County, Colorado Type of Facility: Exploration & Produet€an Well Pad What industry segment? Oil & Natural Gas Production .& Processai As this facility located in a NAAQS non -attainment area? ," If yes, for what pollutant? Don Monoxide (CO) Pa iniate Matter (PM) ne (500 & VOC) Weld Quadrant Section Township Range VNE Section 02 - Emissions Units In Permit Application. AIRS Point 4 Emissions Source Type Equipment Name Emissions Control? Permit - issuance Self Cert Required? Action Engineering Remarks 001 '-Hydrocarbon Liquid Loading LOAD 0i- Yes-:'" 17WE1001 1 ,= • Yes ;, P'ar€ft lltitiai- Issuance 002 SeparatorV nOOng SEP-01 and SEP-07 • .. Yes _ 15 E0131' 2 , l,. No emit . '. Modification" :'005 Crude QilTank TKOZ-TKOR yes. 17W51002- 1 yes- P Permit initial issuance Section 03 - Description of Project s application is for an existing E&P facility in the attainment area of Weld Coany. With this application, Whiting isryjoesting-the following changes:. Cancel the existing GPO& registration for crude oil tanks andadd point 005 to a new individual:. construction. permit: Modify existing permit 15WE0811 remove the loadout missions point (moved 001) and ad'd an additional 2 -phase 'separator that services a new well.ai facility, (Horsetail 290-2043). *Request new individual permit for loadout-and modify limits based on new requested throughput and site-specifidi samples, Permit number 17WE1002-has uncontralled:emissions greater than 100tpy-VOC and will have new synthetic minor limits on PIE to avoid Title V requirements: Therefore,17WE1002 will go to public noticeatthis time. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? I7WE10Dg-on) Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? INo 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) Non -Attainment New Source Review (NANSR) _ Is this stationary source a major source? If yes, explain what programs and which pollutants here SO2 NOx Prevention of Significant Deterioration (PSD) _ Title V Operatirg Permits (OP) Non -Attainment New Source Review (NANSR) SO2 NOx CO VOC PM2.5 PM10 TSP HAPs PM2 S PM10 TSP HAPs Crude Oil Storage Tank(s) Emissions Inventory Section 01- Administrative Information Facility AIRs ID: County Plan Poin Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency k: Section 03 -Processing Rate Information for Emiss(onc Estimates Primary Emissions- Storage Tank(s) Actual Throughput= Requested Permit Umit Throughput= Barrels (hbl) per year Actual Crude Oil Throughput While Emissions Controls Operating = Barrels (bbl) per year Potential to Emit (PTE) Throughput= Barrels (hbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per BBL of liquids produced = _ Actual heat content of waste gas routed to combustion device= Requested heat content of waste gas routed to combustion device = Btu/scf scf/bbl 540 MMBTU per year 7,857 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 7,857 MMBTU per year Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? Emission Factors Crude Oil Tank Pollutant Benzene Toluene Uncontrolled Controlled (Ib/bbl) (Ib/bbl) Section 05 - Emissions Inventory (Crude Oil (Crude Oil Throughput) Throughput) 0.0005 Ethylbenzene ;>as' Uuq :vi ( `': 0.0001 Xylene ? rz tt1023 0.0001 n -Hexane 224 TMP Itllllll?iitR 00217.: V 0.0001 0.0062 Pollutant Control Device Uncontrolled Uncontrolled (Ih/MMBtu) (Ib/bbl) (waste heat (Cmde Oil combusted) Throughput) PM10 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) VOC PM10 PM2.5 NO8 CO 167,4 11.5 0.6 167.4 8.4 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.3 0.0 0.0 0.3 0.3 1.2 0.1 0.1 1.2 1.2 Hazardous Air Pollutants Potential to Emit Uncontrolled )(bs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Reque ted Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 1008 69.34 3.47 1008 SO 1000 68.74 3.44 1000 50 140 0.65 0.48 140 7 251 17.26 0.86 251 13 13607 935.69 46.78 13607 680 230 15.84 0.79 230 12 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A,0 Source requires a permit Regulation 7, Section XVII.B, C.l, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NIPS Subpart Kb Storage Tank is not subject to N5P5 Kb Regulation 6, Part A, NIPS Subpart 0000 Storage Tank is not subject to NIPS 0000 Regulation 8, Part E, MACi Subpart HH Storage Tank is not subject to MACI HH (See regulatory applicability worksheet for detailed analysis) 2 of 5 K:\PA\2017\17WE1002.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 r "s 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 5CC Coding and Emissions Fasters AIRS Point # Process # 5CC Code 005 01'22 Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.01 0 lb/1,000 gallons crude oil throughput PM2.5 0.01 0 lb/1,000 gallons crude oil throughput NOR 0.12 0 Ib/1,000 gallons crude oil throughput VOC 72.8 95 lb/1,000 gallons crude oil throughput CO 0.53 0 lb/1,000 gallons crude oil throughput Benzene 0.22 95 lb/1,000 gallons crude oil throughput Toluene 0.22 95 l6/1,000 gallons crude oil throughput Ethylbenzene 0.03 95 lb/1,000 gallons crude oil throughput Xylene 0.05 95 lb/1,000 gallons crude oil throughput n -Hexane 2.96 95 lb/1,000 gallons crude oil throughput 224 TMP 0.05 95 lb/1,000 gallons crude oil throughput 3 of 5 K:\PA\2017\17 W E1002.CP1.xlsm Crude Oil Storage Tank Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements 'Source is in the Non -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 II.0.3)? 'You have indicated that source is in the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section I I.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 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section II.D.2)? ISource requires a permit 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? No Yes '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 (m5) ("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 60.111b? 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"3 in 60.111b? 5. Does the storage vessel store a "volatile organic liquid (VOL)" as defined In 60.111b? 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 pressures 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(60.11ob(b))? Storage Tank is not subject to N5PS Kb Subpart A, General Provisions §60.112b - Emissions Control Standards for VOC §60.113b - Testing and Procedures §60.115b - Reporting and Recordkeeping Requirements §60.116b - Monitoring of Operations Source Req Go to next urce Req Continue - Continue - Go to the n Source Is st Source is st Storage Tar 40 CFR, Part 60, Subpart OOOO, 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 Septem her 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"1 per 60.5430? Yes 'Storage Tank is not subject to NSPS OOOO 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 §60.5416(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 OOOO due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS OOOO per 60.5365(e)(2) even if potential VOC emissions drop below 6 tons per year] 40 CFR, Part 63, Subpart MACT 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 liquldst (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"4 in 63.7617 4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"' per 63.761? 5. Is th'e tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart OOOO? Yes IStorage Tank is not subject to MACT NH 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. Continue -' Storage Tar Continue - Storage Tar CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 17WE 1002 Issuance: 1 Whiting Oil and Gas Corporation Facility Name: Horsetail 29G Production Battery Plant AIRS ID: 123/9DD3 Physical Location: SWSE Sec 29 T10N R57W County: Weld County General Description: Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description TK-01 to TK-06 005 Six (6) 400 barrel 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 ,fir 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 operators 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.) 3. This permit'shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months COLORADO Air Poiiution Control Division ..)evottivirt of i trhr4 Hezith E ewiroritn r t Page 1 of 7 e''of this construction permit or the date on which such cti, o� cti°'ty w�, sc ,rduled to commence as set fo'rth in the permit application associate • with is permi ii .iscontinues 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 ' plete all initial compliance testing and sampling as required in this permit and submit t e sults to the Division as part of the self -certification process. (Regulation Number 3, Part B ection III.E.) 5. The operator sh 3 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 to TK-06 005 --- --- 8.4 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Compliance with the annual 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 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 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.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled TK-01 to TK- 06 005 Enclosed Combustor VOC Et HAP PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID. AIRS Point Process Parameter Annual Limit TK-01 to TK- 06 005 Crude Oil Throughput 109,500 barrels The owner or operator shall monitor monthly process rates based on the calendar month. COLORADO Air Pollution Control Division Envirc'.i?1e, t Page 2 of 7 t limits shall be determined on a rotting twelve (12) month new twelve-month total is calculated based on the previous welve mont s' •ata. The permi older shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit n, -- d ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be mark d • th subject equipment for ease of identification. (Regulation Number 3, Part B, Section III. E. ) .;Mate only enforceable) 10. This source is sub;,°! ct to the odor requirements of Regulation Number 2. (State only enforceable) 11. 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: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • Alt 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. 12. 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 shall 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 the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 13. 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 a MAINTENANCE REQUIREMENTS 14. 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 15. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. !COLORADO Air Pollution Control Division sr.p=s'x,'ri1 Pc6atcbiCt "tvL:'>rt1'£t Y'tw:t Page 3 of 7 ADDIT 17. `^"' seEmce (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 s (5) tons itting less than 100 tons per year, a change in actual emissions of five r year or more, above the level reported on the last APEN; or For vola e organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattnt 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. GENERAL TERMS AND CONDITIONS 18. 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. 19. 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. 20. 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. 21. 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. COLORADO Air Pollution Control Division Gt Pubtit 3-ie'cthni_'4RDY'T1tent Page 4 of 7 22. �; d ex, cond' �f thine permit is a material part hereof and is not severable. Any ge J or' •.e of a , +ndi•n hereof shall constitute a rejection of the entire permit and upon such occurrence, this permi s all 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. I on denies a permit, conditions imposed upon a permit are contested by the owner or pe to or the Division revokes a permit, the owner or operator of a source may request a hearin ' iefore the AQCC for review of the Division's action. 23. Section 25-7-114. 2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) •ay 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. 24. 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: Bradley Eades Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Whiting Oil and Gas Corporation New construction permit for existing source previously permitted with GP08. COLORADO I Air Pollution Control Division 'melt t;,= P&Putiktb;e t! . s En, ir6nrnent Page 5 of 7 Notes > Perm. l H� ,. - '. t the:=. .f th �� o- 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-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. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 005 Benzene 71432 1008 50 Toluene 108883 1000 50 Ethylbenzene 100414 140 7 Xylenes 1330207 251 13 n -Hexane 110543 13607 680 2,2,4- Trimethylpentane 540841 230 12 Note: Alt 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 005: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source V0C 3.0575 0.153 Aspen HYSYS Version 8.4 Et EPA TANKS 4.09 71432 Benzene 0.0092 0.0005 108883 Toluene 0.0091 0.0005 1330207 Xylene 0.0023 0.0001 110543 n -Hexane 0.1243 0.0062 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 thispermit 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 Air Pollution Control Division _:_vert'N_re P bla Heath 3 Enwere tent Page 6 of 7 th as a I -692- d ermine the APEN expiration date for each emissions point estions regarding a specific expiration date call the Division 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: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC PSD or NANSR True Minor MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 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 ..k'ir rknt Ui Pbfi C He [9 &}, &tnment Page 7 of 7 Crude Oil Storage Tank(s) APE 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 fitted 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 (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.govlpacificicdphelair-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: jl Y ' ( 6a AIRS ID Number: 123 / 9DD3 / 005 Section 1 - Administrative Information Company Name': Whiting Oil and Gas Corporation Site Name: Horsetail 29G Production Battery Site Location: SWNE, Sec 29, T1 ON, R57W Mailing Address: 1700 Broadway, Zip p Code) 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: COPHEcorrespondence@whifing,com i 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 wilt be issued by APCD via e-mail to the address provided. 368891 LORAOO Permit Number: AIRS ID Number: 123 / 9DD3 / 005 Section 2 - Requested Action ® NEW permit OR newly -reported emission source Q Request coverage under traditional construction permit O 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 O Change company name ❑ Change permit limit O Transfer of ownership3 O Other (describe below) OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - 1:1 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: (6) 400 bbl crude oil tanks For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 hours/day 7 January 31, 2015 Storage tank(s) located at: 0 Exploration & Production (E&P) site days/week 52 weeks/year O Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? ■ Yes ❑i No Are Flash Emissions anticipated from these storage tanks? O Yes O No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes 0 No ill Are you requesting ≥ 6 ton/yr V0C emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No • El OLORADO 2 Permit Number: AIRS ID Number: 123 / 9D03 / 005 Section 4 - Storage Tank(s) Information Actual Annual Amount (bbllyear) equested Annual Permit Limit" (bbl/year) Crude Oil Throughput .7,530 toq,S-(:) From what year is the actual annual amount? 2016 Average API gravity of sates oil: 38.3 degrees 0 Internal floating roof Tank design: ID Fixed roof 109,500 RVP of sates oil: 5.0 0 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 (monthlyear) Date of First Production (month/year) TK-O+ Ihiptalh TKA5 2,400 10/2014 01/2015 API Number 05 - 123 - 38804 ells Serviced by this Stara Tank or Tank Bate Name of Well Horsetail 29G-20128 (E&P Sites'0nty) Newly Reported, Well 05 - 123 - 38807 Horsetail 29G-2043 U O Requested values wilt become permit limitations. Requested limit(s) should consider future growth. 5 The E£tP 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 (La₹itude/Longitude or VIM)' 40.810706/-103.77218 Operator Stack ` ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ftlsec) COMB -02 35 >2000 5.63 0.008 Indicate the direction of the stack outlet: (check one) 0✓ Upward O Downward ❑ Horizontal O Other (describe): O Upward with obstructing raincap Indicate the stack opening and size: (check one) [J Circular Interior stack diameter (inches): 48 ❑ Square/rectangle Interior stack width (inches): a Other (describe): Interior stack depth (inches): COtORAD0 3l Permit Number: AIRS iD Number: 123 / 9003 / 005 AIRS I 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 Device: Pollutants Controlled: VOC and HAPS Rating: 18.21 MMBtu/hr Type: Enclosed Combustor Make/Model: L E ED/1_30-001 1 -000 Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: 2729 Btu/scf Constant Pilot Light: ❑ Yes ❑ No Pilot Burner Rating: 0.13 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 (EStP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 21 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 two (2) 2 -phase separators where gas is separated from liquids. The liquids are transferred to two (2) heater treaters that are equipped with burners to facilitate further separation into streams of gas, crude oil, and produced water. The streams are transferred to storage tanks. LO A0O 4 Benzene Permit Number: AIRS ID Number: 123 / 9DD3 / 005 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): VOC Enclosed Combustor Overall Requested Control Efficiency % reduction in emissions) 95 NOx CO t#APs Enclosed Combustor 95 Other: From what year is the f©!lowing reported actual annual emissions data 2016 3.0575 lb/bbl HYSYS.& Tanks 4.09 VOC NOx Uncontrolled Basis 0.068 lb/MMbtu Criteria Pollutant Emissions Inventory Source (AP -42, Mfg. etc) AP -42 Actual Annual Emissions 4 Requested Annual Permit Emission l imit(s) Uncontrolled Emissions (Tonslyear) -778-( 1 Controlled Emissions? (Tons/year) Uncontrolled Emissions onslyear) 167.4 Controlled Emissions {Tonsiyear) 8.37 de minimus CO 0.310 ib/MMbtu AP -42 -0721— de minimus Non-Cri Chemical Abstract Service (CAS). Number eria Reportable Pollutant Emissions Invento Emission Factorb; Actual An tal Emissions Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Pounds/year) Controlled Emissions? (Pounds/year) 71432 0.0092 lb/bbl HYSYS d Tanks 4.00 Toluene 108883 0.0091 lb/bbl HYSYS &Tanks 4.09 Ethylbenzene Xylene n -Hexane 100414 0.0013 lb/bbl HYSYS 8 Tanta 4.09 -64140 1330207 110543 0.0023 0.1243 lblbbl ib/bbl HYSYS 41404 4.09 WOOS 8 Tanks 4.09 4.6 13 2,2,4- Trimethylpentane 540841 0.0021 HYSYS a 74045 4.09 4 Requested values wilt 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. 5I COLORADO -ik6 mevLN.:Sa-. saat Permit Number: AIRS ID Number: 123 / 9DD3 / 005 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 upd, ' General Permit GP08, I further certify that this source is and will be operated in full comp(iap '"witl ch co it rf`of the applicable General Permit. 9/8/2017 Signat`of Legally Authorized Person (not a vendor or consultant) Date Jacob Parker Environmental Professional III Name (print) Title Check the appropriate box to request a copy of the: i] Draft permit prior to issuance Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration. of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 and the General Permit registration fee of $250, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https: I//www.colorado.gov/cdphe/apcd 6I Hello