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Home My WebLink About20181254.tiffCOLORADO Department of Public Health €r Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150O St PO Box 758 Greeley, CO 80632 April 10, 2018 Dear Sir or Madam: RECEIVED APR 1 3 2013 WELD COUNTY COMMISSIONERS On April 12, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for Whiting Oil and Gas Corporation - Horsetail 08D. 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 & 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., 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 �vbl�c PAI LL) oN/a3/ig cc: PLC fY)o-/TP), HLCU'T), Pw c ER/CH/ J'm✓cis) ot-l/i9/Ig' 2018-1254 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Whiting Oil and Gas Corporation - Horsetail 08D - Weld County Notice Period Begins: April 12, 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 08D Oil and gas production facility NWNW Section 8, T10N, R57W Weld County The proposed project or activity is as follows: Increase throughput and emissions for gas flaring at well production facility based on addition of eight (8) new wells. 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 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 15WE1379 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: Bradley Eades Package #: 372026 Received Date: 1I/29/201Z._.. Review Start Date: 2/14/2018 Section 01- Facility Information Company Name: Whiting Oil and Gas Corporation', County AIRS ID: 123 Plant AIRS ID: 9E2A '. Facility Name: Horsetail 080 Battery Physical Address/Locatio NWNW quadrant of Section 8, Township 10N, Range 57WW, 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? No _ ,� If yes, for what pollutant? Lyon Manmade (CO) Ecurate Matter (PM) " (NOx & VOC) Weld Quadrant Section I Township Range 57W NWNW 8 10N Section 02 - Emissions Units In Permit Application AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 002 Separator Venting Condensate Tank, •01 through SEP-02, FLI TK-01 through.TK-14 Yes 15W51379 16WE0301 2 3 Permit Modification Permit Modification 004 PW-D1 through PW-06 Yes 16WE030O 3 Pe Modi 005 for Vet SEP-OS Yes 16WE0302 2 Permit Modification Permit Initial Issuance Permit Initial Issuance 007 008 DUST -01 ENG-03 Yes 17WE1213 17W E1214 a 1 Yes Fugitive Dust Section 03 - Description of Project Existing exploration and production facility, Whiting has submitted this modification to include increased production from eight (8) new wells (now 12 wells total) that began production August 30,2017. In addition, Whiting is adding fugitive dust emissions from haul road traffic as well as one (1) natural gas fired RICE used for gas lift:. Note that loadout at facility is primarily conducted using "LACT" pipeline and only a portion is loaded into tank trucks resulting in emissions below reporting thresholds. With this modification, this facility will be a Major source for Title V purposes with controlled emissions of VOC over 100 Vs/. Based on guidance in. PS Memo 09-01, the Title V permit application Is due within 1 year of the Issuance of this permit since the modification does not result in physical change in the equipment, but. as Increase in production. Section 04- Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Ye 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) No Yes SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Is this stationary source a major source? If yes, explain what programs and which pollutants here SO2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Yes NOx CO J VOC PM2.5 PM10 TSP ❑ ❑J HAPs ❑ Cl Separator Venting Emissions Inventory Section 01- Administrative Information Facility AIRs ID: 123 County 9E2A Plant 001 Point Section 02 - Equipment Description Details Venting of gas from two (2)2 -phase separators and two (2) 3 -phase heater treaters when Redtail Gas Gathering system is unavailable. Detailed Emissions Unit Description: Open flare Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter 95 Nelonaf Ved ' Yes isau, „, , Imt�Ekxf agd,opEeattan �„ 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: No Is VRU process equipment: 0.00 MMscf per year 118.62 MMscf per year 118.62 MMscf 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 1552 Btu/scf(HHV) Description cf/bbl 'NO ACTUAL EMISSIONS REPORTED 1417 Btu/scf (LHV) The inlet 2 phase separators are directly upstream of the 3 phase separators (heater treaters). The emissionsstreams from both of these separators combines before being routed to a flare. This combined stream was sampled and the resulting analysis way used to calculate emission factors for this point. The requested gas throughput is based on an estimated maximum vent rate of 115,000 sof/hr and 5%(438 hrs) ofAedtail Gathering System downtime: Commingled sample was collected 10/11/2017. Displacement Equation Ex = Q• MW • Xx/C MW 27.72 Weight % Helium 0.00 CO2 4,37 N2 0.87 methane 34.15 ethane 15.35 propane 21.17 isobutane 2,89 n -butane 9.82 isopentane 2.37 n -pentane 3.18 cyclopentane 0.19 n -Hexane 0.93 cyclohexane 0.14 Other hexanes - 1.13 heptanes 2.04 methylcyclohexane 0.28 224-TMP 0.04 Benzene 0.09 Toluene 0.25 Ethylbenzene 0.07 Xylenes - 0.08 C8+ Heavies 0.58 Total VOC Wt % 100.0 45.25 Ib/Ib-mol 2 of 5 K:\PA\2015\15WE1379.CP2.xlsm Separator Venting Emissions Inventory Emission Factors Separator Venting Pollutant Uncontrolled Controlled (Ib/MMsef) (lb/MMscf) (Gas Throughput) (Gas Throughput) Emission Factor Source VOC 33097.7300 1654.8865 Benzene Toluene 69.381 180.443 51.211 60.439 681.445 26.179 3.4690 9.0221 2.5606 3.0219 34.0723 1.3089 Ethylbenzene Xylene n -Hexane 224 TMP Emission Factor Source Pollutant Primary Control Device Uncontrolled (Ib/MMBtu) (Waste Heat Combusted) Uncontrolled Ib/MMscf (Gas Throughput) PM10 PM2.5 SOx NOx CO 0.0075 0.0075 0.0006 0.0680 0.3100 11.564 11.564 0.913 105.536 439.270 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 0.70 0.00 0.00 0.70 0.70 0.70 0.00 0.00 0.70 0.70 0.05 0.00 0.00 0.05 0.05 6.39 0.00 0.00 6.39 6.39 1963.11 0.00 0.00 1963.11 98.16 26.61 0.00 0.00 26.607 26.607 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 _ 8230 0 0 8230 412 21405 0 0 21405 1070 6075 0 0 6075 304 7170 0 0 7170 358 80836 0 0 80836 4042 3105 0 0 3105 155 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XVII.0, 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 0011.B.2.0 Does the company use site specific emission factors based on a gas sample to estimate emissions? Yss 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 maybe 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? Yes_ 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? Yes 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 3 of 5 K:\PA\2015\ 15WE1379.CP2.xlsm Separator Venting Emissions Inventory Section 08 - Technical Analysis Notes CO uses 1HV in converting lb/MMBtu to lb/MMscf while other secondary combustion pollutants use HHV. This is based on footnotef of AP-42fable 13.5-2. Previously, the emission unit description in the permit only contained the 2 -phase separators. However, this point also includes emissions from gas flared from the 3 -phase heater treaters. This has been updated in the process description with this mod. Emission calculations in previous issuances included heater -treaters. Applicant has included emissions from combustion of pilot gas in the reported emission limit for NOx and CO. Pilot emissionsare based on pilot . burner rating of 0.44 MMbtu/hr (2 burners) and pilot gas heating values of 2516 btu/scf (HHV) and 2315 btu/scf (lHV) for Propane. This results in the following emissions from pilot gas combustion: 0.132 tpy NOx and. 0.553 tpy CO.. Emissionfactors for NOx were converted from 0.068 lb/MMbtu to 171.08 lb/MMscf using a propane fuel heating, value of 2516 btu/scf (HHV). Emission factors for CO were converted from 0.31 lb/MMbtu to 717.6516/MMscf using a propane fuel heating value of 2315 btu/scf (2HV):. While the control device pilot fuel is not a limited parameter, I have included pilot fuel combustion calculations in the notes to permit holder since its emissions contribute totbe overall NOx and CO'. limit. The flare controlling this point was approved as an alternative emission control device per Reg 7 Section )CVII.B.2.e. and the approval will be carded forward with this issuance since emissions continue to be based on 5% gathering system downtime. 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 11.56 0 lb/MMSCF PM2.5 11.56 0 Ib%MMSCF SOx 0.91 0 lb/MMSCF NOx 105.54 0 lb/MMSCF VOC 33097.73 95 lb/MMSCF CO 439.27 0 lb/MMSCF Benzene 69.38 95 Ib/MMSCF Toluene 180.44 95 lb/MMSCF Ethylbenzene 51.21 95 lb/MMSCF Xylene 60.44 95 lb/MMSCF n -Hexane 681.45 95 lb/MMSCF 224 TMP 26.18 95 lb/MMSCF 4 of 5 K:\PA\2015\15 W E1379.CP2.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 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. 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)? 'Von 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? Yes Yes Yes "'I 'Tice control device for this separator is subject to Regulation 7, Section XVil.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 15WE1379 Permit number: Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: General Description: truction Permit Air Pollution Control Division Issuance: 2 Whiting Oil and Gas Corporation Horsetail 08D Production Facility 123/9E2A NWNW SEC 8 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-04 001 Flaring of gas from two (2) 2 -phase separators and two (2) 3 -phase heater treaters during gas gathering system downtime. Open Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. 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.) 2. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction 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.) 3. 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.) Separator Version Syn Minor 2015-1 Page 1 of 9 4. The operator shall tain completion of self c1 tific on wi permit alone does n+a pro e foal EMISSION LIMITATIONS AND RECORDS it fin hori " n lett the os curr t onstr! tho[ty fo,, the peration issued by the Division, after tion permit. This construction f this source. 5. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO SEP-01 through SEP-04 001 --- 6.4 98.2 26.6 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. 6. 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 SEP-01 through SEP- 04 001 Open Flare VOC and HAP PROCESS LIMITATIONS AND RECORDS 7. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit SEP-01 through SEP- 04 001 Gas Flaring 118.62 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 COLORADO Air Pollution Control Division Page 2 of 9 twelve months' dat The r older > talc throe hput each month and keep a compliance record o nsibility, for Division review. 8. The owner or oper co o ni -cord • olumetric flow rate of natural gas flared from the high-pressure separators and heater treaters using a flow meter. The flow meter shall continuously measure flow rate and record total volumetric flow routed to the open flare from the separators. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits specified and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. 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) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. 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 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. 12. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING I* 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. The owner/operator shall complete an initial site specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, of the 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 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 COLORADO Air Pollution Control Division Page 3 of 9 emissl te with he emissions point. If a site a ctor lopethrough this Analysis is greater than the emissions f ° tors b ►.-rmi .p licati and established in the "Notes to Permit Holder" th ope ' or all b ift to e D ision wit n 60 days, or in a timeframe as agreed to by the Di , a req fo _ A4 it .' ion to aditress this/these inaccuracy(ies). Periodic Testing Requirements 15. On an annual basis, the owner/operator shall complete a site specific extended gas analysis ("Analysis") of the 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 16. All previous versions of this permit are cancelled upon issuance of this permit. 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 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 issuance of 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 COLORADO Air Pollution Control Division Page 4 of 9 relaxation that incr es th will require a full revew o source. The source all (Regulation Number GENERAL TERMS AND CONDITIONS appli ble Federal program threshold st ctiona: ad not yet commenced on the ram thr hold until a permit is granted. 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 21. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all. points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Bradley Eades Permit Engineer COLORADO Air Pollution Control Division Page 5 of 9 Permit History Issuance Date Description Issuance 1 June 2, 2016 Whiting Oil and Gas Corporation Synthetic Minor facility Issuance 2 This Issuance Issued to Whiting Oil and Gas Corporation Facility is Major for Title V COLORADO Air Pollution Control Division Page 6 of 9 Notes to Permit Holder at th 1) The permit holder is req fees will be issued afte of receipt of the invoice. Failure to pay the (Regulation Number 3, Part A, Section VI.B.) it "sessi ® time fo elder s invoice will result his permit. An invoice for these ay the invoice within 30 days in revocation of this permit. 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. AIRS Point Pollutant CAS # Uncontrolled Emissions (Ib/yr) Controlled Emissions (Ib/yr) 001 Benzene 71432 8230 412 Toluene 108883 21405 1070 Ethylbenzene 100414 6075 304 Xylenes 1130207 7170 358 n -Hexane 110543 80836 4042 2,2,4- Trimethylpentane 540841 3105 155 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 001: Combustion of waste gas (gas f aring) CAS # Pollutant Weight fraction of waste gas (%) Uncontrolled Emission Factors lb/MMSCF Controlled Emission Factors lb/MMSCF Source NOx --- --- 105.54 AP 42 CO --- --- 439.27 VOC 45.25 33097.73 1654.89 Gas Analysis 71432 Benzene 0.09 69.38 3.47 108883 Toluene 0.25 180.44 9.02 100414 Ethylbenzene 0.07 51.21 2.56 COLORADO Air Pollution Control Division Page 7 of 9 CAS # Polluta F$. • f ctio oast gas (%) U , ont lied Emi on ctors Controlled fission Factors lb/MMSCF Source 1330207 Xylene 0.08 60.44 3.02 110543 n -Hexane 0.93 684.45 34.07 540841 2,2,4- Trimethylpentane 0.04 26.18 1.31 Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. Emission factors for N0x and CO are from AP -42 Chapter 13.5. The N0x emission factor was converted from "lb/MMbtu" to "lb/MMscf" using an HHV of 1,552 Btu/scf. The CO emission factor was converted from "lb/MMbtu" to "lb/MMscf" using an LHV of 1,417 Btu/scf. Combustion of pilot fuel gas (propane) CAS # Pollutant Uncontrolled Emission Factors lb/MMSCF Controlled Emission Factors lb/MMSCF Source NOx --- 171.08 AP 42 CO --- 717.65 Note: Emission factors for N0x and CO are from AP -42 Chapter 13.5. The N0x emission factor was converted from "lb/MMbtu" to "lb/MMscf" using a propane HHV of 2516 Btu/scf. The CO emission factor was converted from "lb/MMbtu" to "lb/MMscf" using an LHV of 2315 Btu/scf. Emissions are based on a pilot burner rating of 0.44 MMbtu/hr with two (2) burners. 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 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 COLORADO Air Pollution Control Division Page 8 of 9 MACT 63.1-63.59 w part ,.° `bpar MACT 63.600-63. 99 A S " art by a DDD MACT 63.1200- 4`39 Subp fttEEIttibfegi PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division Page 9 of 9 15WE1379 Permit number: Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: General Description: truction Permit Air Pollution Control Division Issuance: 2 Whiting Oil and Gas Corporation Horsetail 08D Production Facility 123/9E2A NWNW SEC 8 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-04 001 Flaring of gas from two (2) 2 -phase separators and two (2) 3 -phase heater treaters during gas gathering system downtime. Open Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C. R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. 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.) 2. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction 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.) 3. 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.) Separator Version Syn Minor 2015-1 Page 1 of 9 4. The operator shall completion of self -c+ permit alone does n tain a "it fin hori: tific on wi they. os .curr proycle ft,�al athoty fothe issued by the Division, after tion permit. This construction f this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO SEP-01 through SEP-04 001 --- 6.4 98.2 26.6 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. 6. 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 SEP-01 through SEP- 04 001 Open Flare VOC and HAP PROCESS LIMITATIONS AND RECORDS 7. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit SEP-01 through SEP- 04 001 Gas Flaring 118.62 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 COLORADO Air Po€€uiion Control Division Page 2 of 9 twelve months' dat compliance record o thro' hput each month and keep a to res risibility, for Division review. 8. The owner or oper ,i.'°-`c• o , �•rn • -cord olumetric flow rate of natural gas flared from the high-pressure separators and heater treaters using a flow meter. The flow meter shall continuously measure flow rate and record total volumetric flow routed to the open flare from the separators. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits specified and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. 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) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. 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 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. 12. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. 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 OFtM 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. The owner/operator shall complete an initial site specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, of the 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 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 COLORADO Air Pollution Control Division Page 3 of 9 emissions point. If a site e emissic, ctor' loped through this Analysis is greater than the emissions f tors bntltte with he rmi pplicatian and established in the "Notes to Permit Holder" th. ope_* or all sub F t to a D. ision wit n 60 days, or in a timeframe as agreed to by the Di s t; req fo " it tfrr on to " ` ss this/these inaccuracy(ies). Periodic Testing Requirements 15. On an annual basis, the owner/operator shall complete a site specific extended gas analysis ("Analysis") of the 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 16. Alt previous versions of this permit are cancelled upon issuance of this permit. 17. 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. 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 issuance of 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 COLORADO Air Pollution Control Division Page 4 of 9 relaxation that incr-.es thm p. <,al to .bov apph:ble Federal program threshold will require a full r- ew o h .o e a ho`"th c. t' coon ad not yet commenced on the source. The source all t e ee$ the ede l pr ram thr hold until a permit is granted. (Regulation Numbe , its C D). GENERAL TERMS AND CONDITIONS 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 21. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Bradley Eades Permit Engineer COLORADO ', Air Pollution Control Division Page 5 of 9 Permit History Issuance Date Description Issuance 1 June 2, 2016 Whiting Oil and Gas Corporation Synthetic Minor facility Issuance 2 This Issuance Issued to Whiting Oil and Gas Corporation Facility is Major for Title V COLORADO Air Pollution Control Division Page 6 of 9 Notes to Permit Holder at th 1) The permit holder is req ed t..ay ee`'; or t pr.essl time fo , his permit. An invoice for these fees will be issued afte - mi s " e . •lder sb •ay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/agcc-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 (Ib/yr) 001 Benzene 71432 8230 412 Toluene 108883 21405 1070 Ethylbenzene 100414 6075 304 Xylenes 1130207 7170 358 n -Hexane 110543 80836 4042 2,2,4- Trimethylpentane 540841 3105 155 N 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 001: Combustion of waste gas (gas f aring) CAS # Pollutant Weight fraction of waste gas (%) Uncontrolled Emission Factors lb/MMSCF Controlled Emission Factors lb/MMSCF Source NOx --- --- 105.54 AP 42 CO --- --- 439.27 VOC 45.25 33097.73 1654.89 Gas Analysis 71432 Benzene 0.09 69.38 3.47 108883 Toluene 0.25 180.44 9.02 100414 Ethylbenzene 0.07 51.21 2.56 COLORADO Air Pollution Control Division Page 7 of 9 CAS # Polluta ig f cti , as gas (%) U out lied Emi 'on ctors Controlled g mission Factors lb/MMSCF Source 1330207 Xylene 0.08 60.44 3.02 110543 n -Hexane 0.93 684.45 34.07 540841 Trimethylpentane 0.04 26.18 1.31 Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. Emission factors for N0x and CO are from AP -42 Chapter 13.5. The N0x emission factor was converted from "lb/MMbtu" to "lb/MMscf" using an HHV of 1,552 Btu/scf. The CO emission factor was converted from "lb/MMbtu" to "lb/MMscf" using an LHV of 1,417 Btu/scf. Combustion of pilot fuel gas (propane) CAS # Pollutant Uncontrolled Emission Factors lb/MMSCF Controlled Emission Factors lb/MMSCF Source NOx --- 171.08 AP 42 CO --- 717.65 Note: Emission factors for N0x and CO are from AP -42 Chapter 13.5. The N0x emission factor was converted from "lb/MMbtu" to "lb/MMscf" using a propane HHV of 2516 Btu/scf. The CO emission factor was converted from "lb/MMbtu" to "lb/MMscf" using an LHV of 2315 Btu/scf. Emissions are based on a pilot burner rating of 0.44 MMbtu/hr with two (2) burners. 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 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 COLORADO Air Pollution Control Division Page 8 of 9 MACT 63.1-63.59 } , part bpar I_ MACT 63.600-63.j 99 Su ar = by DDD MACT 63.1200-6 . ub EE . PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division Page 9 of 9 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: 15WE1379 AIRS ID Number: 123 /9E2A/ 001 [Leave blank unless APCD has already assigned a permit d and AIRS ID] Company equipment Identification: SEP-01 through SEP-04 [Pro'vic e Facility Equipment ID to identify how this e 4iiipment is referenced within your organization] Section 1 - Administrative Information Company Name': Site Name: Whiting Oil and Gas Corporation Horsetail 08D Site Location: NWNW Section 8, T10N, R57W Mailing Address: (Include Zip Code) 1700 Broadway, Suite 2300 Denver, CO 80290 E -Mail Address': CDPHECorrespondence@whiting.com Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Ashley Brinkerhoff Phone Number: 970-373-7249 '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. Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. COLORADO Form APCD-211 - Natural Gas Venting APED - Rev, 03/2017 Permit Number: 15WE1379 AIRS ID Number: 123 / 9E2A / 001 [Leave bi.ank un es APCD has atreadv assigned a permit. " and AIRS ID] Section 2- Requested Action ❑ NEW permit OR newly -reported emission source - OR - ❑✓ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit ✓❑ Change permit limit ❑ Transfer of ownership' ✓❑ Other (describe below) -OR - ❑ APEN submittal for update only (Please note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Permit modification to add production from (8) eight new wells. 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Flaring associated gas from (2) 2 -phase separators For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 06 / 30 / 2015 / / ❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions Form APCD-211 -Natural Gas Venting APEN Rev 03/2017 days/week weeks/year ❑ Yes ❑ Yes ❑✓ No ❑✓ No (� COLORADO 2 I F7A L�T�7Jtt.. C vL O R AwD O Permit Number: 15WE 1379 [Leave hank untess APCD has already y assign AIRS ID Number: 123 / 9E2A/ 001 'D1 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 #: # of Pistons: Volume per event: Capacity: Leak Rate: Gal/min Scf/hr/pist 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: 1 552 , BTU/SCF Requested: 118.6 MMSCF/year Actual: MMSCF/year -OR- Requested: Bbl/yr Actual: Bbi/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth Process Properties: Molecular Weight: VOC (mole %) 23.253 VOC (Weight %) 45.30 Benzene (mole %) 0.034 Benzene (Weight %) 0.095 Toluene (mole %) 0.074 Toluene (Weight %) 0.247 Ethylbenzene (mole %) 0.018 Ethylbenzene (Weight %) 0.070 Xylene (mole %) 0.022 Xylene (Weight %) 0.083 n -Hexane (mote %) 0.300 n -Hexane (Weight %) 0.933 2,2,4-Trimethylpentane (mole %) 0.009 2,2,4-Trimethylpentane (Weight %) 0.036 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 a n -Hexane, temperature, and pressure) Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017 3Ir 40 Permit Number: 15WE1379 AIRS ID Number: 123 / 9E2A/ 001 [Leave blank un.e≥s, APCD has already assigned a permit. r and AIRS €D Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.8598/-103.772706 FLR-01 >2,000 4,514 215.5 Indicate the direction of the stack outlet: (check one) E Upward ❑ Horizontal ❑ Downward ❑ 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: Requested Control Efficiency VRU Downtime or Bypassed Make/Model: ❑ Combustion Device: Pollutants Controlled: Rating: Type: VOC and HAPs 598 Open Flare Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: N/A MMBtu/hr Make/Model: Flare Industries/SFVP-0824 95 98 % % Waste Gas Heat Content Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating 1,552 Btu/scf 0.44 MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested 0/0 OLORADO Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017 4 PM Permit Number: 15WE 1379 AIRS ID Number: 123 / 9E2Ai 001 blank, unless APCD has already asa:n ecl , pern,,it ,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): Pollutant Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) PM SOX NO, VOC Gas is sent to gas gathering pipeline w/open flare as backup 95% CO HAPs Gas is sent to gas gathering pipeline w/open flare as backup 95% Other: From what year is the following reported actual annual emissions data? Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Uncontrolled Emission Factor Emission Factor Units Emission Factor Source (AP -42, Mfg. etc) Actual; Annual Emissions; Requ Uncontrolled (Tons/year) Controlled (Tons/year) Uncontrolled (Tons/year) Controlled6 (Tons/year) 0.0075 lb/MMBtu AP -42 de minimis de minimis SOX 9.465 lb/MMscf Gas Analysis de minimus de minimis NOX 0.068 lb/MMBtu AP -42 6.39 VOC 33,097.73 lb/MMscf Gas Analysis 1963.1 98.16 CO 0.31 lb/MMBtu AP -42 26.60 Benzene 69.38 lb/MMscf Gas Analysis 4.12 0.21 Toluene 180.44 lb/MMscf Gas Analysis 10.70 0.54 Ethylbenzene 51.21 lb/MMscf Gas Analysis 3.04 0.15 Xylenes 60.44 lb/MMscf Gas Analysis 3.59 0.18 n -Hexane 681.44 lb/MMscf Gas Analysis 40.42 2.02 2,2,4- Trimethylpentane 26.19 Ib/MMscf Gas Analysis 1.55 0.08 Other: 5 Requested values wilt 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 51 ORADO Permit Number: 15WE1379 AIRS ID Number: 123 / 9E2A/ 001 [Leave hank unless APCD has asigned 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. November 28, 2017 Signature of Legalluth ri d Person (not a vendor or consultant) Date Ashley Brinkerhoff 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-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: //www.colorado.gov/cdphe/apcd ORADO Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017 6 I Hello