HomeMy WebLinkAbout20180260.tiffCOLORADO
Department of Public
Health ft Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
11500 St
PO Box 758
Greeley, CO 80632
January 18, 2018
Dear Sir or Madam:
RECEIVED
JAN 2, 2 2018
WELD COUNTY
COMMISSIONERS
On January 25, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for
Whiting Oil and Gas Corporation Razor 12H Production Facility. 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 a 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
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2018-0260
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Whiting Oil and Gas Corporation - Razor 12H Production Facility - Weld County
Notice Period Begins: January 25, 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: Razor 12H Production Facility
Well Producation Facility
SENE SEC 12 T10N R58W
Weld County
The proposed project or activity is as follows: Operator proposes a new well production facility in an
attainment area
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 17WE0976 have been
filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are
available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Any such comment must be submitted in writing to the following addressee:
Christopher Kester
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
Colorado Air Permitting Project
Project Details
Review Engineer:..
Package #:
Received Date:
Review Start Date:
Section 01- Facility Information
Company Name:.
County AIRS ID:
PlantAIRS ID: 9FRF
Facility Name: Razor 12H PProduc-tion Facility';
Physical Address/Location: SENE quadrant of Section 12, Township 10N, Range 58WW, in Weld County, Colorado
Type of Facility: Exploration &: Production Well Pad
What industry segment? Oil ,& NaturatGas production & Processing
Is this facility located in a NAAQS non -attainment area? No
If yes, for what pollutant? E' Carbon Monoxide (CO) fl Particulate Matter (PM)
ItitingOil and Gas Corporation`
Weld
Quadrant
Section
Township I Range
SENE
ION
58W
Section 02 - Emissions Units In Permit Application
Ozone (NOx & VOC)
AIRS Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
Self Cert
Issuance #
Required?
Action
Engineering
Remarks
001
Produced Water Tank
FW (}1through
PW-08 rl
Yes
171=JE0976
Yes
Permit Initial
''°Issuance
002
Crude Oil Tank
TK-01
TK-15
Yes .
17W 0977
1
Yes. ,
Permit Initial
Issuance
003
Separator Venting
5&,-01 through
SEP 04
Yes
17WE0978
I
Yes
ermit initial
Issuance
004-
Natural Gas RICE....
ENG-01
Yes
17W E0979
1
Yes
Permit Initial -_
issuance
005
€yatural Gas RICE
ENG-02
Yes
17WE0980
1
Yes'
Permit Initial
Issuance
006
Other (€xplain)
DUST -01
?`es
17W E0981
1
Yes
Permit Initial :
Issuance
Fugitive. Dust
from haul Roads
Section 03 - Description of Project
Ne synthetic minor facility in the attainmentarea:.
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why? -
Yes
westing Synthetic Minor Pe
Section 05 - Ambient Air Impact Analysis Requirements
Was a quantitative•modeling analysis required? No
• If yes, for what pollutants?
If yes, attach a copy of Technical. Services Unit modeling results summary.
Colorado Air Permitting Project
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:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
SO2 NOx
❑ ❑
❑ ❑
SO2 NOx
❑ ❑
❑ ❑
CO VOC PM2.5 PM10 TSP
❑ ❑ O ❑
❑ .❑ O ❑ ❑ O
CO VOC PM2.5 PM10 TSP HAPs
❑ O ❑ ❑
❑ o ❑ ❑ ❑ O
HAPs
Produced Water Storage Tank(s) Emissions Inventory
Section 01- Administrative Information
'Facility AIRS ID:
County Plant
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Requested Overall VOC & HAP Control
Efficiency %:
Section 03- Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Produced Water Throughput=
Requested Permit Limit Throughput=
Potential to Emit (PTE) Produced Water
Throughput =
Secondary Emissions - Combustion Device(s)
Heat content of waste gas=
Volume of waste gas emitted per BBL of liquids
produced= i;4ni.s„ u;=lt` scf/bbl
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
Barrels (bbl) per year Actual Produced Water Throughput While Emissions Controls Operating =
Barrels (bbl) per year
Barrels (bbl) per year
Btu/scf 1187 LHV
4,540 MMBTU per year
4,540 MMBTU per year
Potential to Emit (PTE) heat content of waste gas routed to combustion device= 4,540 MMBTU per year
Section 04- Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
Emission Factors Produced Water Tank
Pollutant
Uncontrolled Controlled
(Ib/bbl) (lb/bbl)
(Produced
(Produced Water Water
Throughput) Throughput)
VOC
t);4
PE
0.000940
0.000010
Benzene
Toluene
Ethylbenzene
Oldie 0.000006
OdOO.11 0.0000
Xylene
Hexane -0;004 f.WI10~'i :i! 0.000016
fat
ji 0.000002
224 TMP
t0
0.000003
Pollutant
PM10
Control Device
Uncontrolled Uncontrolled
(Ib/MMBtu) (lb/bbl)
(waste heat
combusted)
(Produced
Water
Throughput)
0.0000
Emission Factor Source
Emission Factor Source
st
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
(tans/year) (tons/year)
VOC
123.37
123.37
2.90
_ 123.37
2.90
PM10
0.02
0.02
0.02
0.02
0.02
PM2.5
0.00
0.00
0.00
0.00
0.00
NOx
0.15
0.15
0.15
0.15
0.15
CO
0.64'
0.64
0,64
0.64
0.64
Potential to Emit
Actual Emissions
Requested Permit Limits
Hazardous Air Pollutants
Uncontrolled
Uncontrolled Controlled
Uncontrolled Controlled
(lbs/year)
(lbs/year) (bs/year)
(lbs/year) (lbs/year)
Benzene
2652
2652
62
2652
62
Toluene
1604
1604
38
1604
38
Ethylbenzene
197
197
5
197
5
Xylene
617
617
14
617
14
n -Hexane
4133
4133
97
4133
97
224 TMP
753
753
18
753
18
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XVILB, C.1, C.3
Storage tank is subjectto Regulation 7, SectiortXVll, B, C.1 & C.3
Regulation 7, Section XVILC.2
Storage tank is subject to Regulation 7, Section XVII.C.2
Regulation 6, Part A,NSPS Subpart 0000
Stoiage Tank is not subject to NSPS 0000
(See regulatory applicability worksheet for detailed analysis)
3 of 18 K:\PA\2017\17WE0976.CP1.olsm
Produced Water Storage Tank(s) Emissions Inventory
Section 07 - Initial and Periodic Sampling and Testing Requirements
Does the company use a site specific emissions factor to estimate emissions?' • •
If yes and ifthereare flash emissions, are the emissions factors.based on a -pressurized liquid water -sample drawn a
the facility being permitted and'analyzed usingflash.liberation analysis? This sample. should be considered
representative which generally means site -specific and collected within one year of the application received date.
However, ifthe.facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to -use
an older site -specific sample. -
. If no, the permitwill contain an "Initial Compliance" testing requirementto develop a site specific emissions factor. See PS Memo 14-03, questions 5.9 and 5.12 for additional guidance on testing.
Does the -company request a control device efficiency greater than 95% for a flare oh combustion device?
If yes, the permit.will contain and-initlal'compliance test condition to demonstrate the destruction efficiency of the combustion device based an inlet and outlet concentration sampling
Section 08 Technical Analysis Notes
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point# Process .# SCC Code
001 ' 01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses
Uncontrolled
Emissions
Pollutant Factor Control '% Units.
PM10 0.00 - 0 lb/1,000 gallons liquid throughput
PM2.5. - 0.00 - 0 lb/1,000 gallons -liquid throughput
NOx 0.00 0 . lb/1,000 gallons liquid throughput
VOC 1.0 98 lb/1,000 gallons liquid throughput
CO 0.00 0 16/1,000 gallons liquid throughput
Benzene 0.01 98- l6/1,000 gallons liquid throughput -
Toluene - - 0.01 98 lb/1,000 gallons liquid throughput'
Ethylbenzene _. 0.00 98 lb/1,000 gallons liquid throughput
Xylene- - 0.00 - .98., lb/1,000 gallons liquid throughput .
n -Hexane, , 0.02, 98 lb/1,000 gallons liquid throughput
224TMP 0.00 - 98 ` lb/1,000 gallons liquidthroughput
4 of 18 - - K:\PA\2017\ 17WE0976.CPlxlsm
003 Calculation of produced water tank emission factors based on a site specific flash liberation analysis
Calculations
Emission Calculation Method
EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3)
Ex=Q*MW*Xx/C
Ex = emissions of pollutant x
Q = Volumetric flow rate/volume of gas processed
MW = Molecular weight of gas = SG of gas * MW of air
Xx = mass fraction of x in gas
C = molar volume of ideal gas (379 scf/Ib-rtol) at 60F and 1 atm
Maximum Vent Rate
Throughput (Q)
MW
15297
7.4022
scf/hr
MMscf/yr
Ib/Ib-mol
33.3
845
0.02028
scf/hr
MMscf/d
mole %
MW
Ibx/Ibmol
mass fraction
Ib/hr
lb/yr
tpy
Helium
0.0000%
0.0000
0.00
0.00
CO2
20.2800%
15.0567
131896.66
65.95
N2
13.5100%
10.0304
87866.07
43.93
methane
16.1100%
11.9607
104775.89
52.39
ethane
12.1200%
8.9984
78825.81
39.41
propane
14.8100%
10.9955
96320.98
i 48.16
isobutane
1.3900%
1.0320
9040.25
4.52
n -butane
5.8700%
4.3581
38177.19
19.09
isopentane
1.1200%
0.8315
7284.23
3.64
n -pentane
1.6400%
1.2176
10666.20
5.33
cyclopentane
0.5800%
0.4306
3772.19
1.89
n -Hexane
0.6200%
0.4603
4032.34
2.02
cyclohexane
0.3200%
0.2376
2081.21
1.04
Other hexanes
1.2200%
0.9058
7934.61
3.97
heptanes
-
1.0400%
0.7721
6763.93
3.38
methylcyclohexane
0.2800%
0.2079
1821.06
0.91
224-TMP
0.1100%
0.0817
715.42
0.36
Benzene
0.4000%
0.2970
2601.51
1.30
Toluene
0.2500%
0.1856
1625.94
0.81
Ethylbenzene
0.0300%
0.0223
195.11
0.10
Xylenes
0.1000%
0.0742
650.38
0.33
08+ Heavies
8.2000%
6.0880
53331.00
26.67
VOC mass frail
0.380
Total VOC (Uncontrolled)
123.51
Notes
Mole %, MW, and mass fractions from Critter Creek 2-03H produced water flash liberation gas analysis collected 6/9/2017.
17WE0976.CP1.xlsm
Produced Water Storage Tank Regulatory Analysis Worksheet
Please note that NSPS Kb might be might be applicable for certain tanks at water management and injection facilities. If the tanks you are reviewing are at one of these facilities, please rev
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
'You have indicated that source is in the Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M)
3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
'Source requires a permit
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M)
3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section II.D.2)?
'You have indicated that source is in the Attainment Area
Colorado Regulation 7, Section XVII
1. Is this tank located at a transmission/storage facility?
2. Is this produced water storage tank' located at an oil and gas exploration and production operation , well production facility2, natural gas compressor station3 or natural gas processing plant?
3. Is this produced water storage tank a fixed roof storage tank?
4. Are uncontrolled actual emissions4 of this storage tank equal to or greater than 6 tons per year VOC?
'Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3
Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.C.1- Emissions Control and Monitoring Provisions
Section XVII,C,3 - Recordkeeping Requirements
5. Does the produced water 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 OOOO, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution
Is this produced water storage vessel located at a facility in the onshore oil and natural gas productionsegment, natural gas processing segment or natural gas transmission and storage segment of the
1. industry?
2. Was this produced water storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015?
3: Are potential VOC emissions2 from the individual storage vessel greater than or equal to 6 tons per year?
4. Does this produced water storage vessel meet the definition of "storage vessel" per 60.5430?
'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]
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 Ac
and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself.
Crude Oil Storage Tank(s) Emissions Inventory
Section 01- Administrative Information
'Facility AIRs ID:
rd's t a M
County
Plant
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Requested Overall VOC & HAP Control
Efficiency %:
Section 03- Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Throughput=
Requested Permit UmitThroughput =
Potential to Emit (PTE) Throughput =
Secondary Emissions - Combustion Device(s)
Heat content of waste gas=
Volume of waste gas emitted per BBL of liquid
produced= i ,'.y{ scf/bbl
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
}, Barrels (bbl) per year Actual Crude Oil Throughput While Emissions Controls Operating =
Barrels )bbl) per year
Barrels (bbl) per year
Btu/scf
2313.31 LHV
39,369 MMBTU per year
39,369 MMBTU per year
Potential to Emit (PTE) heatcontent of waste gas routed to combustion device = 39,369 MMBTU per year
Section 04- Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
Emission Factors Crude Oil' Tank
Pollutant
Uncontrolled Controlled
(lb/bbl) [lb/bbl)
(Crude Oil (Crude Oil
Throughput) Throughput)
Emission FactarSource
VOC
0.05618
0.00012
0.00009
0.09001
0.00004
0.00105
0.00010
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
i
Emission FactorSource
Pollutant
Control Device
Uncontrolled Uncontrolled
(Ib/MMBtu) (lb/bbl)
(waste heat (Crude Oil
combusted) Throughput)
PM10
0,0004
0.0004
0.004I
0.0187
CO
IMINMOIS
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tonsYyear)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
VOC
PM10
PM2.5
NOx
CO
1608,0
1658.0
39.0
1658.0
38.962
0,1
0.1
Ott
0.1
0.1
0.1
0.1
R1
0.1
0.1
1.3
1.3
1.3
1.3
1.3
5.5
5.5
5.5
5,5
5.5
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 IMP
6796
j 6796
160
6796
160
5132
5132
121
5132
121
694
694
1,6
694
16
2358
2358
55
2352
' 55
61722
61722
1450
61722
1450
6103
6103
143
6103
143
Section 06 - Regulatory Summa Analysis
Regulation 3, Parts A,B
Source requires a permit
Regulation 7, Section XVII.B, C.1, C.3
Storage tank is subject to Regulation 7, Section XVII, B, C.18& C.3
Regulation 7, Section XVII.C.2
Storage tank is subject to Regulation 7, Section XVII.C2
Regulation 6, Part A, NSPS 5ubpart Kb
Storage Tank is not subject to NSPS Kb
Regulation 6, Part A, NSPS-Subpart 0000
Storage Tank is not subject to NSPS 0000
Regulation 8, Part E, MACT Subpart HE
Storage Tank is not subject to MALT HH
(See regulatory applicability worksheet for detailed analysis)
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 Sans VOC per year?
Byes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03
8 of 18 K/ PA\2017\17 W E0476,CP1.XIsm
Crude Oil Storage Tank(s) Emissions Inventory
Does the company use a site specific emissions factor to estimate emissions?
If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample of crude oil drawn at the
facility being permitted?
If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS
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 Factors
AIRS Point #
002
Process # SCC Cade
01
Definitions for Drop Down Lists
Storage Tank Emissions Factor Options
Crude Oil State E.F. (includes flash)
Site Specific E.F. (includes flash)
Site Specific EPA TANKS E.F. Working and Breathing Only
Other (Documented in Technical Analysis Notes)
Qualifiers
No
Yes
Not applicable - stabilized tank
control Devices
Enclosed Flare
Open Flare
Vapor Recovery Unit (VRU)
Control Device Combustion Emissions Factor Options
NOx CO PM
AP -42 Chapter 13.5 Industri AP -42 Chapter 13.5 AP -42 Table L4-2 (PM10/PM.2.5)
TNRCC Flare Emissions GuidTNRCC Flare Emissic Other- Explain
AP -42 Table 1.4-1 (NOx) AP -42 Table 1.4-1 (CO)
Other- Explain Other- Explain
SCC Codes - Storage Tank Emissions
4-04-003-12 Fixed Roof Tank, Crude Oil, working+breathing+flashing losses
4-04-003-02 Fixed Roof Tank: Working & Breathing Losses
4-04-003-22 EMernal Floating Roof Tank, Crude Oil, working+hreathing+flashing
4-04-003-06 External Floating Roof Tank: Working and Breathing Losses
4-04-003-32 Internal Floating Roof Tank, Crude Oil, working+hreathing+flashing
4-04-003-07 Internal Floating Roof Tank: Working and Breathing Losses
SCC Codes- Flaring Combustion Emissions
3-10-001-60 Flares
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
NOx 0.05 0 lb/1,000 gallons crude oil throughput
VOC 56.9 98 lb/1,000 gallons crude oil throughput
CO 0.19 0 lb/1,000 gallons crude oil throughput
Benzene 0.12 98 lb/1,000 gallons crude oil throughput
Toluene 0.09 98 lb/1,000 gallons crude oil throughput
Ethylbenzene 0.01 98 lb/1,000 gallons crude oil throughput
Xylene 0.04 98 lb/1,000 gallons crude oil throughput
n -Hexane 1.06 98 lb/1,000 gallons crude oil throughput
224 TMP 0.10 98 lb/1,000 gallons crude oil throughput
9 of 18 K:\PA\2017\17WE0976.CP1.xism
003 Calculation of crude oil tank emission factors based on a site specific flash liberation analysis
Calculations
Emission Calculation Method
EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3)
Ex=Q*MW*Xx/C
Ex = emissions of pollutant x
Q = Volumetric flow rate/volume of gas processed
MW = Molecular weight of gas = SG of gas * MW of air
Xx = mass fraction of x in gas
C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm
Maximum Vent Rate
Throughput (Q)
MW
scf/hr
MMscf/yr
Ib/Ib-mol
32.7332
46.5282
3736.666667
scf/hr
MMscf/d
0.08968
mole %
MW
Ibx/Ibmol
mass fraction
lb/hr
lb/yr
tpy
Helium
0.00000
0.0000
0.00
0.00
C02
0.01730
7.9361
69520.30
34.76
N2
0.02494
11.4408
100221.74
50.11
methane
0.03230
14.8153
129781.93
64.89
ethane
0.11130
51.0553
447244.55
223.62
propane
0.32133
147.4033
1291253.09
645.63
isobutane
0.05408
24.8061
217301.15
108.65
n -butane
0.19351
88.7679
777606.61
388.80
isopentane
0.04631
21.2422
186081.32
93.04
n -pentane
0.05960
27.3406
239503.45
119.75
cyclopentane
0.00676
3.1015
27169.17
13.58
n -Hexane
0.01509
6.9232
60647.42
30.32
cyclohexane
0.00338
1.5524
13598.65
6.80
Other hexanes
0.02574
11.8074
103432.54
51.72
heptanes
0.01320
6.0562
53052.42
26.53
methylcyclohexane
0.00286
1.3115
11488.93
5.74
224-TMP
0.00151
0.6945
6084.03
3.04
Benzene
0.00168
0.7716
6759.14
3.38
Toluene
0.00125
0.5753
5039.22
2.52
Ethylbenzene
0.00018
0.0826
723.33
0.36
Xylenes
-
0.00060
0.2729
2391.02
1.20
C8+ Heavies
0.06060
27.7989
243517.94
121.76
VOC mass fracl
0.808
Total VOC (Uncontrolled)
Notes
Mole %, MW, and mass fractions from Critter Creek 2-03H crude oil flash liberation gas analysis collected 6/9/2017.
1622.8
17WE0976.CP1.xlsm
Crude Oil Storage Tank Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
IYou have indicated that source is in the Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the construction date prior to 4/14/2014 and not modified after 4/14/14 (See PS Memo 14-03 for additional guidance on grandfather applicability)?
2a. If answer to #2 is yes, is the crude oil throughput less than 40,000 gallons per year?
3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section ll.D.3)?
Source requires a permit
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the construction date prior to 4/14/2014 and not modified after 4/14/14 (See PS Memo 14-03 for additional guidance on grandfather applicability)?
2a. If answer to #2 is yes, is the crude oil throughput less than 40,000 gallons per year?
3. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section II.D.2)?
'You have indicated that source is in the Attainment Area
Colorado Regulation 7, Section XVII
1. 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 facility2, natural gas compressor station3 or natural gas processing plant?
3. Is this crude oil storage tank a fixed roof storage tank?
4. Are uncontrolled actual emissions° of this storage tank equal to or greater than 6 tons per year VOC?
'Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3
Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.C.1 - Emissions Control and Monitoring Provisions
Section XVII.C.3 - Recordkeeping Requirements
5. Does the crude oil storage tank contain only "stabilized" liquids? If no, the following additional provisions apply.
'Storage tank is subject to Regulation 7, Section XVII.C.2
Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment
40 CFR, Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels
1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m3) ["472 BBLs]?
2. Does the storage vessel meet the following exemption in 60.111b(d)(4)?
a. Does the vessel has a design capacity less than or equal to 1,589.874 m3 ["10,000 BBL] used for petroleum' or condensate stored, processed, or treated prior to custody transfer2 as defined in 61
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)"5 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 (60.11nb(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 pressure6 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 pressure6 less than 15.0 kPa(60.110b(b))?
'Storage Tank is not subject to NSPS 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
40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution
1. Is this crude oil storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry?
2. Was this crude oil storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015?
3. Are potential VOC emissions2 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?
'Storage Tank is not subject to NSPS 0000
Subpart A, General Provisions per §60.5425 Table 3
§60.5395 - Emissions Control Standards for VOC
§60.5413 - Testing and Procedures
§60.5395(g) - Notification, Reporting and Recordkeeping Requirements
§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 HH, 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 Iiquids2 (63.760(a)(2)); OR
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 user3
b. (63.760(a)(3))?
1. Is the tank located at a facility that is majors for HAPs?
3. Does the tank meet the definition of "storage vessel"4 in 63.761?
4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"5 per 63.761?
5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000?
'Storage Tank is not subject to MACT NH
Subpart A, General provisions per §63.764 (a) Table 2
§63.766 - Emissions Control Standards
§63.7,73 - Monitoring
§63.774 - Record keeping
§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 Ac
and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself
003
Eight (8) low-pressure separators controlled by one open flare during VRU downtime. Flare has a minimum
control efficiency of 95%.
Equipment Description
This source vents natural gas from:
Emissions from this source are:
a well head separator
routed to a flare
Natural gas venting from a well head separator. Emissions from this source are routed to a flare.
Calculations
Emission Calculation Method
EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 Displacement Equation (10.4-3)
Ex=Q*MW*Xx/C
Ex = emissions of pollutant x
Q = Volumetric flow rate/volume of gas processed
MW = Molecular weight of gas = SG of gas * MW of air
Xx = mass fraction of x in gas
C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm
Maximum Vent Rate
Throughput (Q)
MW
500000
scf/hr
MMscf/yr
Ib/Ib-mol
25.6
26.37
2922.374429
0.070136986
scf/hr
MMscf/d
mole %
MW
Ibx/Ibmol
mass fraction
lb/hr
lb/yr
tpy
Helium
0.0000%
0.0000
0.00
0.00
CO2
4.8651%
9.8923
86656.80
43.33
N2
1.0588%
2.1529
18859.27
9.43
methane -
37.6431%
. 76.5407
670496.12
335.25
ethane
15.4438%
31.4023
275083.82
137.54
propane
20.9654%
42.6295
373434.16
186.72
isobutane
2.7440%
5.5794
48875.93
24.44
n -butane
9.2398%
18.7875
164578.63
82.29
isopentane
2.0755%
4.2202
36968.65
18.48
n -pentane
2.7249%
5.5406
48535.72
24.27
cyclopentane
0.1475%
0.2999
2627.26
1.31
n -Hexane
0.6505%
1.3227
11586.66
5.79
cyclohexane
0.0743%
0.1511
1323.43
0.66
Other hexanes
0.8632%
1.7552
15375.25
7.69
heptanes
1.0681%
2.1718
19024.92
9.51
methylcyclohexane
0.0914%
0.1858
1628.01
0.81
224-TMP
0.0118%
0.0240
210.18
0.11
Benzene
0.0535%
0.1088
952.94
0.48
Toluene
0.0641%
0.1303
1141.74
0.57
Ethylbenzene
0.0128%
0.0260
227.99
0.11
Xylenes
0.0278%
0.0565
495.17
0.25
C8+ Heavies
0.1740%
0.3538
3099.28
1.55
VOC mass Tract
Notes
mass fractions from Razor 12H gas analysis collected 8/8/2017.
17WE0976.CP1.xlsm
0.410
Total VOC (Uncontrolled)
365.04
Eight (8) low-pressure separators controlled by one open flare during VRU downtime. Flare has a minimum
003 control efficiency of 95%.
Flaring Information
Equipment Description
Gas Heating Value
Throughput
1475.09
Btu/scf
MMBtu/yr
37762.304
Overall Control
95.00%
1343 LHV
3854.4 MMBtu/yr (Pilot)
Combustion emission factor source:
AP -42: Chapter 13.5
0.068 Ilb NOX/MMBtu
0.31 IIb CO/MMBtu
Emissions Summary Table
Pollutant
Uncontrolled Emission Factor
Controlled Emission Factor
Uncontrolled Emissions
Controlled Emissions
Source
V0C
28519
lb/MMscf
1425.95 lb/MMscf
365.04 tpy
18.25 tpy
Gas Analysis
Nox
0.07
Ib/MMBTU.
0.07 lb/MMBTU.
1.41 tpy
1.41 tpy
AP -42
CO
0.31
Ib/MMBTU
0.31 lb/MMBTU
5.93 tpy
5.93 tpy
AP -42
Benzene
37.22
lb/MMscf
1.86 lb/MMscf
953 lb/yr
48 lb/yr
Gas Analysis
n -Hexane
452.50
lb/MMscf
22.6302 lb/MMscf
11587 lb/yr
579 lb/yr
Gas Analysis
Toluene
44.599
lb/MMscf
2.2300 lb/MMscf
1142 lb/yr
57 lb/yr
Gas Analysis.
Xylenes
19.343
lb/MMscf
0.9671 lb/MMscf
495 lb/yr
25 lb/yr
Gas Analysis
Ethylbenzene
8.906
lb/MMscf
0.4453 lb/MMscf
228 lb/yr
11 lb/yr
Gas Analysis
Regulatory Applicability
AQCC Regulation 1
This source is subject to the opacity requirements for flares in Section I I.A.5:'No owner or operator of a smokeless flare or other flare
for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30%
opacity.'
AQCC Regulation 2
Section I.A applies to all emission sources. "No person, wherever located, shall cause or allow the emission of odorous air
contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For
areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been
diluted with seven (7) or more volumes of odor free air."
AQCC Regulation 7
Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014?
Yes
This separator is subject to Reg 7, Section XVII.G. and contrd requirements of Reg 7, Section XVII.B.2
One (1) Caterpillar, G3516B, SN: JEF03159, natural gas -fired, naturally aspirated, 4SLB
reciprocating internal combustion engine, site rated at 1311 horsepower. This engine shall be
equipped with an oxidation catalyst and air -fuel ratio control. This emission unit is used for natural
gas compression.
004
Engine Information
Engine date of m
11/11/2014
Manufacturer:
Caterpillar
Model Number:
G3516B
Serial Number:
JEF03159
Engine Function
Compression
Derating
Mfg's Max. Rated Horsepower @ sea level:
1311
Horsepower used for calcuations:
1311
BSCF @ 100% Load (btu/hp-hr):
8180
Site - Rated BSCF @ 100% load (btu/hp-hr):
8180
Other Parameters
Engine Type
4SLB
Aspiration
turbo -charged
Electrical Generator Max Site Rating (kw)
0
Max hrs/yr of Operation
8760
Calculations
Fuel Use Rate @ 100% Load
10513.70588 scf/hr
ACTUAL Annual Fuel Consumption
92.1 MMscf/yr
MAX NU I tN I IAL. Annua I-uel
Consumption
92.100 MMscf/yr
REQUESTED Annual Fuel
Consumption
92.100 MMscf/yr
Fuel Heating Value
1020 btu/scf
Emission Control Information
This engine shall be equipped with an oxidation catalyst and air -fuel ratio control
Emissions Summary Table
Pollutant
Uncontrolled Emission Factor
Controlled Emission Factor
Uncontrolled Emiss
Controlled Emissio
Source
NOx
1.000
g/hp-hr
1.000
g/hp-hr
12.63
tpy
12.63
tpy
Manufacturer
CO
3.100
g/hp-hr
2.000
g/hp-hr
39.16
tpy
25.27
tpy
Manufacturer
VOC
1.830
g/hp-hr
0.700
g/hp-hr
23.12
tpy
8.84
tpy
Manufacturer
Formaldehyde
0.360
g/hp-hr
0.360
g/hp-hr
9096
lb/yr
9096
lb/yr
Manufacturer
Acetaldehyde
0.00836
Ib/MMBTU
0.008
Ib/MMBTU
785
lb/yr
785
lb/yr
AP -42
Acrolein
0.00514
Ib/MMBTU
0.005
Ib/MMBTU
483
lb/yr
483
lb/yr
AP -42
Benzene
0.00044
Ib/MMBTU
0.000
Ib/MMBTU
41
lb/yr
41
lb/yr
AP -42
17WE0976.CP1.xlsm
One (1) Caterpillar, G3516B, SN: JEF02767, natural gas -fired, naturally aspirated, 4SLB
reciprocating- internal combustion engine, site rated at 1311 horsepower. This engine shall be
equipped with an oxidation catalyst and air -fuel ratio control. This emission unit is used for natural
gas compression.
005
Engine Information
Engine date of m
11/11/2014
Manufacturer:
Caterpillar
Model Number:
G3516B
Serial Number:
JEF02767
Engine Function
Compression
Derating
Mfg's Max. Rated Horsepower @ sea level:
1311 _
Horsepower used for calauations:
1311
BSCF @ 100% Load (btu/hp-hr):
-- 8180
Site - Rated BSCF @ 100% load (btu/hp-hr):
8180
Other Parameters
Engine Type
4SLB
-
Aspiration
turbo -charged
Electrical Generator Max Site Rating (kw)
0
Max hrs/yr of Operation
8760
Calculations
Fuel Use Rate @ 100% Load
10513.70588 scf/hr
ACTUAL Annual Fuel Consumption
92.1 MMscf/yr
MAX VU I try I IAL Annualruei
Consumption
92.100 MMscf/yr
REQUESTED Annual Fuel
Consumption
92.100 MMscf/yr
Fuel Heating Value
1020 btu/scf
Emission Control Information
This engine shall be equipped with an oxidation catalyst and air -fuel ratio control
Emissions Summary Table
Pollutant
Uncontrolled Emission Factor
Controlled Emission Factor
Uncontrolled Emissic
Controlled Emissio
Source
NOx
1.000
g/hp-hr
1.000
g/hp-hr
12.63
tpy
12.63
tpy
Manufacturer
CO
3.100
g/hp-hr
2.000
g/hp-hr
39.16
tpy
25.27
tpy
Manufacturer
VOC
1.830
g/hp-hr
0.700
g/hp-hr
23.12
tpy
8.84
tpy
Manufacturer
Formaldehyde
0.360
g/hp-hr
0.360
g/hp-hr
9096
lb/yr
9096
lb/yr
Manufacturer
Acetaldehyde
0.00836
lb/MMBTU
0.008
lb/MMBTU
785
lb/yr
785
lb/yr
AP -42
Acrolein
0.00514
Ib/MMBTU
0.005
lb/MMBTU
483
lb/yr
483
lb/yr
AP -42
Benzene
0.00044
lb/MMBTU
0.000
lb/MMBTU
41
lb/yr
41
lb/yr
AP -42
17WE0976.CP1.xlsm
006 Fugitive Emissions from Haul Road for Crude Oil and Produced Water Loadout
E = k(s/12)^a *(W/3)^b AP -42 13.2.2, Equation 1a
E = emission factor (lb/VMT (VMT=Vehicle Miles Travelled))
k = constant from table 13.2,2-2
s= surface material silt content (%)
a = constant from table 13.2.2-2
W = mean vehicle weight (tons),
b= constant from table 13.2.2-2
Constants
W (tons)
s* (%)
E (lb/VMT)
Pollutant
k
a
b
W, Empty
W, Loaded
W, Avg
TSP (PM)
4.9
0.7
0.45
14
42...5
28.25
5
7.28.
PM -10
1.5
0.9
0.45
14
42.5
28.25
5
1.87
PM -2.5
0.15
0.9
D.45
14
42.5
28.25
5
0.19
*CDOT"2011 Standar Specification Book -Table 703-3 Class 6 Aggregate Base Course
Total Estimated VMT: 2,399 miles/yr
Emissions Summary Table
Pollutant
E (lb/VMT)
Uncontrolled
Emissions
Control Factor**
Controlled
Emissions
TSP (PM)
7.28
8.74
tpy
21.9%
6.82
tpy
PM -10
1.87
2.24
tpy
21.9%
1.75
tpy
PM -2.5
0.19
0.22
toy
21.9%
0.18
toy
`*Natural mitigation from precipitation per EPA AP -42 Volume 1 Fifth Edition - November 2006 Table 13.2.2-2 Equation 2; number of days with
natural preciptiation from figure AP -42 Figure 13.2.2-1
Regulation 4 - Particulate, Smoke. Carbon Monoxide and Sulfur Dioxide
Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup,, process modification,
or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes.
(Reference: Regulation No. 1, Section II.A.1. & 4.)
Regulation 3= APENs, Construction Permits, Operating. Permits; PSD
Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for each individual emission point in an attainment area with
uncontrolled actual emissions of two tons per year or more of any individual criteria pollutant (pollutants are not summed) for which the area is
attainment.
SCC
31088801: Fugitive Haul Road Emissions
D
ontrol Division
Department of Public Health b Environment
Permit number:.
Date issued:
Issued to:
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General Description:
STRUCTION PERMIT
Issuance: 1
Whiting Oil and Gas Corporation
Razor 12H Production Facility
123/9F5F
SENE SEC 12 T10N R58W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment ID
AIRS
Point
Equipment Description
Emissions Control
Description
PW-01 through
PW-08
0O1
Eight (8) 400 barrel fixed roof storage
vessels used to store condensate produced
water
Vapor Recovery Unit
(VRU) &t Enclosed
Combustor
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission
and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general
terms and conditions included in this document and the following specific terms and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the
latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/ pacific/ cdphe/other-air-permitting-
notices. Failure to notify the Division of startup of the permitted source is a violation of Air
Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result
inthe revocation of the permit:
2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance
of this permit, compliance with the conditions contained in this permit shall be demonstrated to
the Division. It is the owner or operator's responsibility to self -certify compliance with the
conditions. Failure to demonstrate compliance within 180 days may result in revocation of the
permit. A self certification form and guidance on how to self -certify compliance as required by
this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self-
certification. (Regulation Number 3, Part B, Section IiI.G.2.)
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
S Air Poiltttion Control Division
e`of this construction permit or the date on which such
duled to commence as set forth in the permit application
associate • with t is permi ii :iscontinues construction for a periodof 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. Within sixty i `after issuance of this permit, the operator shall replace the open flare
currently on -site th an enclosed combustor. Until the enclosed combustor is installed, the open
flare must be co nuously operated to achieve the emissions limits and regulatory requirements
listed in this per t.
5. The operator shall complete all initial compliance testing and sampling as required in this permit
and submit the results to the Division as part of the self -certification process. (Regulation
Number 3, Part B, Section III.E.)
6. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
7. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part
B, Section II.A.4.)
)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NOX
VOC
CO
PW-01 through
PW-08
001
---
---
3.0
---
Point
Note: See "Notes to Permit Holder for information on emission factors and methods used to calculate
limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 9.2 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.
The owner or operator shall track emissions from all insignificant activities at the facility on an
annual basis to demonstrate compliance with the facility potential emission limitations as
indicated below. An inventory of each insignificant activity and associated emission calculations
shall be made available to the Division for inspection upon request. For the purposes of this
condition, insignificant activities are defined as any activity or equipment, which emits any
amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt.
(Reference: Regulation 3, Part C. II.E.)
Total emissions from the facility, including all permitted emissions and potential to emit from
all insignificant activities, shall be less than:
• 9.2 tons per year of formaldehyde
Air Pollution Control Division
3 `..%rt1M`�r't^R%^.f. t}f i?LLEY$ 4€C3446s ,atYiYv?wa
Page 2 of 8
9. "" -mi _ p. th m- -low 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
Equipme :'"
AIRS
Point
Control Device
Pollutants
Controlled
PW-01 throu r
PW-O8
OO1
Vapor Recovery Unit (VRU) Et Enclosed
Combustor during VRU or gas gathering
system downtime
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
10. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
PW-01
through PW-
O8
OO1
Total Produced water
throughput
6,168,500 barrels
Produced water throughput
during VRU or gas gathering
system downtime
2,899,195 barrels
The owner or operator shalt monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month
total. By the end of each month a new twelve-month total is calculated based on the previous
twelve months' data. The permit holder shall calculate throughput each month and keep a
compliance record on site or at a local field office with site responsibility, for Division review.
11. The owner or operator shall continuously monitor and record produced water throughput and
Vapor Recovery Unit (VRU) downtime while emissions are routed to the control device.
12. The owner or operator must use monthly VRU downtime records, monthly produced water
throughput records, calculation methods detailed in the OEtM Plan, and the emission factors
established in the Notes to Permit Holder to demonstrate compliance with the process and
emissions limits specified in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
13. 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)
14. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable)
15. The combustion device covered by this permit is subject to Regulation Number 7, Section
XVII.B.2. General Provisions (State only enforceable). If a_, flare or other combustion device is
used to control emissions of volatile organic compounds to comply with Section XVII, it shall be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation
from the outside of the enclosed flare or combustion device, or by other convenient means
approved by the Division, determine whether it is operating property. This flare must be equipped
with an operational auto -igniter according to the following schedule:
ICOLORADO
Air Pollution Control. Division
1 k'k:tz-"-r T tut Pubtw a n 6 t6wi hart: t
Page 3 of 8
t= led on or after May 1, 2014, must be equipped with an
on installation of the combustion device;
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion device
planned shutdown., whichever comes first.
16. The storage red by -this permit is subject to the emission control requirements in
Regulation N m. Section XVI1.C.1. The owner or operator shall install and operate air
pollution control quipment that achieves an average hydrocarbon control efficiency of 95%. If
a combustion de e is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons e .� n. 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.
17. 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 & MAINTENANCE REQUIREMENTS
18. Upon startup of these points, the owner or operator shall follow the most recent operating and
maintenance (O&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
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
19. This source is not required to conduct initial testing, unless otherwise directed by the Division or
other state or federal requirement.
Periodic Testing Requirements
20. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
21. All previous versions of this permit are cancelled upon issuance of this permit.
22. 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
Air Potixttio i Control Division
6 erair6r666r
Page 4 of 8
rtable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Wheneve :new control equipment is installed, or whenever a different type of control
equipm replaces an existing type of control equipment; or
• Whenev- -;permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
GENERAL TERMS AND CONDITIONS
23. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation
Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a
revised APEN and the required fee.
24. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self -certification of all
points has been reviewed and approved by the Division, it will provide written documentation of
such final authorization. Details for obtaining final authorization to operate are located in the
Requirements to Self -Certify for Final Authorization section of this permit.
25. This permit is issued in reliance upon the accuracy and completeness of information supplied by
the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only for
the equipment and operations or activity specifically identified on the permit.
26. Unless specifically stated otherwise, the general and specific conditions contained in this permit
have been determined by the APCD to be necessary to assure compliance with the provisions of
Section 25-7-114.5(7)(a), C.R.S.
27. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and
upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked
at any time prior to self -certification and final authorization by the Air Pollution Control Division
(APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air
Quality Control Commission (AQCC), including failure to meet any express term or condition of
the permit. If the Division denies a permit, conditions imposed upon a permit are contested by
the owner or operator, or the Division revokes a permit, the owner or operator of a source may
request a hearing before the AQCC for review of the Division's action.
28. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission
Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a
source or activity is to be discontinued, the owner must notify the Division in writing requesting
a cancellation of the permit. Upon notification, annual fee billing will terminate.
29. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
COLORADO
( Aix Pollution Control Division
t D, ,r>urtIt Yfthi 3seiim vE;;�jr�r;m n
Page 5 of 8
By:
Chris • • , ster
Permit E ineer
n 25-7-115 (enforcement), -121 (injunctions), -122 (civil
es), C.R.S.
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Whiting Oil and Gas Production
COLORADO
Air Pollution Control Division.
& ^ArorY ,ent
mit issuance:
1) T for the processing time for this permit. An invoice for these
fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days
of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production
based on the consum
upon request of the
control regulation or
and complete appli
terial processing limits and emission limits contained in this permit are
ion rates requested in the permit application. These limits may be revised
ner or operator providing there is no exceedance of any specific emission
ambient air quality standard. A revised air pollution emission notice (APEN)
form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of
any malfunction condition which causes a violation of any emission limit or limits stated in this permit
as soon as possible, but no later than noon of the next working day, followed by written notice to
the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation.
See: https://www.colorado.gov/pacific/cdphe/aqcc-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.
N
per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution
Emission Notice.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(Ib/yr)
001
Benzene
71432
2,638
62
Toluene
108883
1,619
38
Xylenes
1330207
631
15
n-liexane
110543
4,108
97
2,2,4-
Trimethylpentane
540841
751
18
5) The emission levels contained in this permit are based on the following emission factors:
Point 001:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
VOC
0.04000
0.000940
Site Specific
produced
water flash
liberation
sample
analysis
71432
Benzene
0.00043
0.000010
108883
Toluene
0.00026
0.000006
1330207
Xylene
0.00010
0.000002
110543
n -Hexane
0.00067
0.000016
540841
2,2,4-Trimethylpentane
0.00012
0.000003
Note: The controlled emissions factors for this point are based on 100% VRU control efficiency, 47% VRU
downtime, and the combustor control efficiency of 95% during VRU downtime for an overall control
efficiency of 97.65%.
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
,COLORADO
Mr Pollution Control Division
^uep%atiry ,t of P tti_ Pket .n i E.irrorrfle t
Page 7 of 8
31 days before the five-year term expires. Please refer to
e inv E e t'.determine the APEN expiration date for each emissions point
associated wi is permit. For any questions regarding a specific expiration date call the Division
at (303)-692-3150.
7) This permit fulfills the requirement to hold a:valid permit reflecting the storage tank and associated
control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when
applicable.
8) This facility is classifi• as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of:
V0C and HAP
PSD
Synthetic Minor Source of:
V0C
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
COLORADO
Air Pollution Control Division.
I Deput,x,
Department of
Permit number:
Date issued:
Issued to:
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General Description:
D
trol Division
btic Health & Environment.
STRUCTION PERMIT
Issuance: 1
Whiting Oil and Gas Corporation
Razor 12H Production Facility
123/9F5F
SENE SEC 12 T10N R58W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment ID
AIRS
Point
Equipment Description
Emissions Control
Description
TK-01 through
TK-16
002
Sixteen (16) 400 barrel fixed roof storage
vessels used to store crude oil
Vapor Recovery Unit
(VRU) Et 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 induded in this document and the following specific terms and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the
latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting-
notices. Failure to notify the Division of startup of the permitted source is a violation of Air
Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result
in the revocation of the permit.
2 Within one hundred and eighty days (180) of the latter of commencement of operation or issuance
of this permit, compliance with the conditions contained in this permit shall be demonstrated to
the Division. It is the owner or operator's responsibility to self -certify compliance with the
conditions. Failure to demonstrate compliance within 180 days may result in revocation of the
permit. A self certification form and guidance on how to self -certify compliance as required by
this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self
certification. (Regulation Number 3, Part B, Section III.G.2.)
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
Page 1 of 8
e of this construction permit or the date on which such
ty w ; sc duled to commence as set forth in the permit application
associate • with t�is permi iiM .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. Within sixty _;.i=after issuance of this permit, the operator shall replace the open flare
currently on -site th an enclosed combustor. Until the enclosed combustor is installed, the open
flare must be co s;'nuously operated to achieve the emissions limits and regulatory requirements
listed in this per `i:t.
5. The operator shall complete all initial compliance testing and sampling as required in this permit
and submit the results to the Division as part of the self -certification process. (Regulation
Number 3, Part B, Section III.E.)
6. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
7. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part
B, Section II.A.4.)
)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO.
VOC
CO
TK-01 through
TK-16
002
---
---
39.0
5.7
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 9.2 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be
determined on a rolling twelve (12) month total. By the end of each month a new twelve month
total is calculated based on the previous twelve months' data. The permit holder shall calculate
actual emissions each month and keep a compliance record on site or at a local field office with
site responsibility for Division review.
8. The owner or operator shall track emissions from all insignificant activities at the facility on an
annual basis to demonstrate compliance with the facility potential emission limitations as
indicated below. An inventory of each insignificant activity and associated emission calculations
shall be made available to the Division for inspection upon request. For the purposes of this
condition, insignificant activities are defined as any activity or equipment, which emits any
amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt.
(Reference: Regulation 3, Part C. II.E.)
Total emissions from the facility, including all permitted emissions and potential to emit from
all insignificant activities, shall be less than:
• . 9.2 tons per year of formaldehyde
ICOLORADO
Mr Pollution Control Division
9.
b -^''ow shall be operated and maintained with the emissions
der to reduce emissions to less than or equal to the limits
in this permit. ' egu a ion Number 3, Part B, Section II I. E.)
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
TK-01 thr•g
TK-16
02
Vapor Recovery Unit (VRU) £t Enclosed
Combustor during VRU or gas gathering system
downtime
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
10. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates 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 through
TK-16
002
Total Crude oil
throughput
1,387,000 barrels
Crude oil throughput
during VRU or gas
gathering system
downtime
651,890 barrels
The owner or operator shall monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month
total. By the end of each month a new twelve-month total is calculated based on the previous
twelve months' data. The permit holder shall calculate throughput each month and keep a
compliance record on site or at a local field office with site responsibility, for Division review.
11. The owner or operator shall continuously monitor and record crude oil throughput and Vapor
Recovery Unit (VRU) downtime while emissions are routed to the control device.
12. The owner or operator must use monthly VRU downtime records, monthly crude oil throughput
records, calculation methods detailed in the O£tM Plan, and the emission factors established in
the Notes to Permit Holder to demonstrate compliance with the process and emissions limits
specified in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
13. 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 IlI.E.) (State only enforceable)
14. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable)
15. The combustion device covered by this permit is subject to Regulation Number 7, Section
XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is
used to control emissions of volatile organic compounds to comply with Section XVII, it shall be
enclosed; have no visible emissions during normal operations, as defined under. Regulation
Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation
from the outside of the enclosed flare or combustion device, or by other convenient means
approved by the Division, determine whether it is operating properly. This flare must be equipped
with an operational auto -igniter according to the following schedule:
COLORADO
Air Pollution Control Division
tl. partsne .t r;t = l.etath U ET--iir or,r:ter t
Page3of8
t led on or after May 1,, 2014, must be equipped with an
on installation of the combustion device;
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
16. The storage red by this permit is subject to the emission control requirements in
Regulation N m• :r Section XVI1 C.1. The owner or operator shall install and operate air
pollution control quipment that achieves an average hydrocarbon control efficiency of 95%. If
a combustion de ' e is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons e�. • where the combustion device has been authorized by permit prior to May
1, 2014. The source 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.
17. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission
Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2.
OPERATING Et MAINTENANCE REQUIREMENTS
18. Upon startup of these points, the owner or operator shall follow the most recent operating and
maintenance (O&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
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
19. This source is not required to conduct initial testing, unless otherwise directed by the Division or
other state or federal requirement.
Periodic Testing Requirements
20. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
21. All previous versions of this permit are cancelled upon issuance of this permit.
22. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
COLOR A O
Air Po€tution Contra k)jvision
Otgiitct HoaWt erwVOnmenc
Page 4 of 8
rtable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Wheneve::.new control equipment is installed, or whenever a different type of control
equipm `' replaces an existing type of control equipment; or
• Whenev permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
GENERAL TERMS AND CONDITIONS
23. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation
Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a
revised APEN and the required fee.
24. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self -certification of all
points has been reviewed and approved by the Division, it will provide written documentation of
such final authorization. Details for obtaining final authorization to operate are located in the
Requirements to Self -Certify for Final Authorization section of this permit.
25. This permit is issued in reliance upon the accuracy and completeness of information supplied by
the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only for
the equipment and operations or activity specifically identified on the permit.
26. Unless specifically stated otherwise, the general and specific conditions contained in this permit
have been determined by the APCD to be necessary to assure compliance with the provisions of
Section 25-7-114.5(7)(a), C.R.S.
27. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and
upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked
at any time prior to self -certification and final authorization by the Air Pollution Control Division
(APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air
Quality Control Commission (AQCC), including failure to meet any express term or condition of
the permit. If the Division denies a permit, conditions imposed upon a permit are contested by
the owner or operator, or the Division revokes a permit, the owner or operator of a source may
request a hearing before the AQCC for review of the Division's action.
28. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission
Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a
source or activity is to be discontinued, the owner must notify the Division in writing requesting
a cancellation of the permit. Upon notification, annual fee billing will terminate.
29. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
COLORADO
Air Pollution Control Division
^s_ tir .tor. Pub W.c tha E:trimrrn.v
Page 5 of 8
By:
25-7-115 (enforcement), -121 (injunctions), -122 (civil
ies), C.R.S.
Chris • r F' seer
Permit E:'aineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Whiting Oil and Gas Production
COLORADO
AirPottntion Control Division
Pt.rt+Nr E:es₹'ry t* e- iror;ment
Page 6 of 8
Notes mit issuance:
1) T it h for the processing time for this permit. An invoice for these
fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days
of receipt of the invoice. Failure to pay the invoice wilt result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production.
based on the consum
upon request of the
control regulation or
and complete appli
terial processing limits and emission limits contained in this permit are
ion rates requested in the permit application. These limits may be revised
ner or operator providing there is no exceedance of any specific emission
y ambient air quality standard. A revised air pollution emission notice (APEN)
form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of
any malfunction condition which causes a violation of any emission limit or limits stated in this permit
as soon as possible, but no later than noon of the next working day, followed by written notice to
the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation.
See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's
analysis of the specific compounds emitted if the source(s) operate at the permitted limitations.
AIRS
Point"
Pollutant
CAS #
Uncontrolled
Emissions
(Ib/yr)
Controlled
Emissions
(lb/yr)
002
Benzene
71432
6,857
.161
Toluene
108883
5,120
120
Ethylbenzene
100414
735
17
Xylenes
1330207
2,418
57
n -Hexane
110543
61,724
1,450
2,2,4-
Trimethylpentane
540841
6,095
143
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 002:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
CO
0.0187
0.0187
AP 42 Chapter
13.5
VOC
2.3907
0.05618
Site Specific
crude oil flash
liberation
sample
analysis
71432
Benzene
0.0049
0.00012
108883
Toluene
0.0037
0.00009
100414
Ethylbenzene
0.0005
0.00001
1330207
Xylene
0.0017
0.00004
110543
n -Hexane
0.0445
0.00105
540841
2,2,4-Trimethylpentane
0.0044
0.00010
ICOLORADO
Air Pollution Control Division
epartm t Ii,Wle 4xu# N s E. vor ent
Page 7 of 8
r this point are based on 100% VRU control efficiency, 47% VRU
control efficiency of 95% during VRU downtime for an overall control.
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 . invoice to determine the APEN expiration date for each emissions point
associated with t ``'s •; rm ` . For any questions regarding a specific expiration date call the Division
at (303)-692-3150.
7) This permit fulfills th requirement to hold a valid permit reflecting the storage tank and associated
control device per ,...,,- Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when
applicable.
8) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of:
V0C and HAP
PSD
Synthetic Minor Source of:
V0C
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for. Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
OLORAAO
Pollution Control Division
of Publi=c }. .s ,.eorrnent
Page 8 of 8
Permit number:
Date issued:
Issued to:
ADO
n Contro
c Heal
CONSTRUCTION PERMIT
17WE0978
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General Description:
Issuance: 1
Whiting Oil and Gas Corporation
Razor 12H Production Facility
123/9F5F
SENE SEC 12 T10N R58W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment ID
AIRS
Point
Equipment Description
Emissions Control
Description
SEP-01 through
SEP-08
003
Four (4) 2 -phase separators and Four (3) 3-
phase separators
Open Flare
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission
and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general
terms and conditions included in this document and the following specific terms and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the
latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting-
notices. Failure to notify the Division of startup of the permitted source is a violation of Air
Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result
in the revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance
of this permit, compliance with the conditions contained in this permit shall be demonstrated to
the Division. It is the owner or operator's responsibility to self -certify compliance with the
conditions. Failure to demonstrate compliance within 180 days may result in revocation of the
permit. A self certification form and guidance on how to self -certify compliance as required by
this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self-
certification. (Regulation Number 3, Part B, Section III.G.2.)
COLORADO
Air Pollution Control Division
.vat: s^:t -ot. hots i- im Er timirt rnent
Page 1 of 8
3. er or oper or . e source A. s b this permi as issued:
tion/modif �� •peration v: is:'.ource within E; 8 months
ce of t constr 'on per �` or the date on ich such
was suled commen' - ..s set h in the perms •lication
a ed with the (ii) s -s cons r • •~- 'od of eigh • the or
more; (iii) does not complete construction within a reasonable time of the estimated completion
date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section
III.F.4.)
4. Within one hundred and eighty days (180) after issuance of this permit, the operator shall install
a flow meter to monitor and record volumetric flow rate of natural gas vented from each
separator covered by this permit. Until the flow meter is installed, the operator shall monitor
and record condensate/crude produced through the separator and estimate the gas flow rate
based on standard cubic feet (scf) per barrel (bbl) of 18.4 scf/bbl estimated in the permit
application.
5. The operator shall complete all initial compliance testing and sampling as required in this permit
and submit the results to the Division as part of the self -certification process. (Regulation
Number 3, Part B, Section III.E.)
6. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
7. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part
B, Section II.A.4.)
)
s permit s
does not c
er either,
stru
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO),
VOC
CO
SEP-01 through
SEP-08
003
---
---
18.2
6.0
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 9.2 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be
determined on a rolling twelve (12) month total. By the end of each month a new twelve month
total is calculated based on the previous twelve months' data. The permit holder shall calculate
actual emissions each month and keep a compliance record on site or at a local field office with
site responsibility for Division review.
8. The owner or operator shall track emissions from all insignificant activities at the facility on an
annual basis to demonstrate compliance with the facility potential emission limitations as
indicated below. An inventory of each insignificant activity and associated emission calculations
shall be made available to the Division for inspection upon request. For the purposes of this
condition, insignificant activities are defined as any activity or equipment, which emits any
amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt.
(Reference: Regulation 3, Part C. II.E.)
COLORADO
AirPollution Control Division
rrner;t
Page 2 of 8
rom including
ctivi : •e less tha
per y
9. a emission points in a table •e ow s a t be opera e. an maintained wit e 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.)
potential mit from
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
SEP-01 through
SEP-08
003
Open Flare during VRU or gas gathering
system downtime
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
10. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates 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-08
003
Natural Gas Routed to the
Flare from the separators
25.6 MMSCF
Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month
total. By the end of each month a new twelve-month total is calculated based on the previous
twelve months' data. The permit holder shall calculate throughput each month and keep a
compliance record on site or at a local field office with site responsibility, for Division review.
11. Upon installation of the flow meter, the owner or operator shall continuously monitor and record
the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The
owner or operator shall use monthly throughput records to demonstrate compliance with the
process limits contained in this permit and to calculate emissions as described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
12. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part
B, Section III.E.) (State only enforceable)
13. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable)
14. The open flare covered by this permit has been approved as an alternative emissions control
device under Regulation Number 7, Section XVII.B.2.e. The open flare must have no visible
emissions during normal operations, as defined under Regulation Number 7, XVII.A.16, and be
designed so that an observer can, by means of visual observation from the outside of the open
flare, or by other convenient means approved by the Division, determine whether it is operating
properly. This open flare must be equipped with an operational auto -igniter according to the
following schedule:
• All combustion devices installed on or after May 1, 2014, must be equipped with an
operational auto -igniter upon installation of the combustion device;
COLORADO
Mr Pollution Control Division
.,nt',r Putt be th GErvvoerce=e
Page 3 of 8
installed ., or- .y 1, 201 be equip • with an
by or befo ' 016, or a ! r next comb on device
•ver co
15. . or cove :T; .. is p .: ;.... ct to ' ;on XVII.G. ( y). 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 It MAINTENANCE REQUIREMENTS
16. Upon startup of these points, the owner or operator shall follow the most recent operating and
maintenance (O&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
the OEM plan are subject to Division approval prior to implementation. (Regulation Number 3,
Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
17. The owner/operator shall complete an additional 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 natural gas vented from this emissions
unit in order to verify the VOC, benzene, toluene, ethylbenzene, xylenes, n -hexane, and 2,2,4-
trimethylpentane content (weight fraction) of this emission stream. The extended gas analysis
must be representative of the combined streams from all eight separators at this facility. 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 emissions point. If any site specific emissions
factor developed through this Analysis is greater than the emissions factors submitted with the
permit application and established in the "Notes to Permit Holder" the operator shall submit to
the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit
modification to address this/these inaccuracy(ies).
Periodic Testing Requirements
18. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
19. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
COLORADO
Air Pollution Control Division
-girt vo il or Ykfbl ^_ s V'f:th & E ti60nment
Page 4 of 8
tons per
ear or mor
or any no a rep • utant.
ore, a c
r is less,
actual emi
e level rep
ns of five
ed on the
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
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 operators 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.
COLORADO
Air Pollution Control Division
„¢RY'nk: t of PiibW.^_ HEu. h'vEnvimnmelt
Page 5 of 8
25.
tion 25 -7 -
ice (APEN)
rce or act'
ance -
•
quires tha
al fee to c
nued, t
notif
es requir- .:n Air Pollux Emission
sts of ins , io and admini .tion. If a
notify Division in writi °€equesting
ee bill will terminate.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Christopher Kester
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Whiting Oil and Gas Production
OLORADO
Air Pollution Control Division
rent or Public 1.4.1tt Ermmnment
Page 6 of 8
Notes t
1) The
fee
rmit Hold
rmit holde
ll be issu
permit iss
ees for thpe it. An invo =' for these
ssued.e perms>,lder sh ay the invoice w n 30 days
e inv.'_ ,..: ',, ure gin, invoi a evocation ermit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN)
and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of
any malfunction condition which causes a violation of any emission limit or limits stated in this permit
as soon as possible, but no later than noon of the next working day, followed by written notice to
the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation.
See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's
analysis of the specific compounds emitted if the source(s) operate at the permitted limitations.
Facility
Equipment ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
SEP-01 through
SEP-08
003
Benzene
71432
952
48
Toluene
108883
1,142
57
Xylenes
1330207
493
25
n -Hexane
110543
11,587
579
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 003:
CAS #
Pollutant
Uncontrolled
Emission Factors
(lb/MMSCF)
Controlled
Emission Factors
(lb/MMSCF)
Source
N0x
110.54
110.54
AP -42 Chapter 13.5
CO
463.00
463.00
V0C
28,484.63
1,424.23
Site Specific Gas
Sample Analysis
71432
Benzene
37.26
1.86
108883
Toluene
44.69
2.23
1330207
Xylene
19.31
0.97
110543
n -Hexane
452.25
22.63
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%.
The emission factors listed above are based on modeled separator temperature of 139 °F and separator
pressure of 100 psig.
COLORADO
Aiz Pollution Control Division
� ep�..rC;,•T r t or P bt4 Healt,', en,lr ar:ti:r t
Page 7 of 8
6) In a
this
APE
the
rdance wit
rmit is vali
hall be su
st r
.R.S.
r at
ted
nual fe
awith this pe
at (303)-692-3150.
7) This facility is classified as follows:
ter
voice
any
each Air P " Emission "EN) associ • with
years fro "t was rec-! e• the Divisio revised
30 days ''-fore th`. 've-year m expires. Pleas fer to
eter a the APE ; •irati• •.te for each emi ;`•ns point
gardin' . - f - • :lion date c. - r ision
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of:
VOC and HAP
PSD
Synthetic Minor Source of:
VOC
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
COLORADO
Air Pollution Control Division
Page 8 of 8
CONSTRUCTION PERMIT
Permit number:
Date issued:
Issued to:
17WE0979
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Issuance:
1
Whiting Oil and Gas Corporation
Razor 12H Production Facility
123/9F5F
SENE SEC 12 T10N R58W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
ENG-01
004
One (1) Caterpillar, G3516B, SN: JEF03159,
natural gas -fired, naturally aspirated, 4SLB
reciprocating internal combustion engine, site
rated at 1311 horsepower. This emission unit
is used for natural gas compression.
Oxidation catalyst and
air fuel ratio control
This engine may be replaced with another engine in accordance with the temporary engine
replacement provision or with another Caterpillar, G3516B engine in accordance with the permanent
replacement provision of the Alternate Operating Scenario (AOS), included in this permit as
Attachment A.
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission
and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general
terms and conditions included in this document and the following specific terms and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the
latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting-
notices. Failure to notify the Division of startup of the permitted source is a violation of Air
Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result
in the revocation of the permit.
'COLORADO
Air Pollution Control Division
rl�.�tw cieu
Page 1 of 11
2.
hin one hu
his permit
Division.
diti
this
mpli
is th
ure to
. self certi
permit may be obtained
certification. (Regulation Number 3, Part B, Section III.G.2).
s (180) of
the conditi
operato
corn
online
of comme
ed in this
respon ity to
nce within . .:0 da
e on
of operatio
rmi halt be dem
-certify complia
a result in revo
compliant
r issuance
trated to
with the
on of the
red by
at www.colorado.Rov/pacific/cdphe/air-permit-self-
3. This permit shall expire if the owner or operator of the source for which this permit was issued:.
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated completion
date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b.
(Reference: Regulation No. 3, Part B, III.F.4.)
4. The operator shalt complete all initial compliance testing and sampling as required in this permit
and submit the results to the Division as part of the self -certification process. (Reference:
Regulation No. 3, Part B, Section II I. E. )
5. The operator shall retain the permit final authorization letter issued by the Division after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part
B, Section II.A.4.)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO,
VOC
CO
ENG-01
004
---
12.7
8.9
25.3
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 9.2 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be
determined on a rolling twelve (12) month total. By the end of each month a new twelve month
total is calculated based on the previous twelve months' data. The permit holder shall calculate
actual emissions each month and keep a compliance record on site or at a local field office with
site responsibility for Division review.
7. The owner or operator shall track emissions from all insignificant activities at the facility on an
annual basis to demonstrate compliance with the facility potential emission limitations as
indicated below. An inventory of each insignificant activity and associated emission calculations
shall be made available to the Division for inspection upon request. For the purposes of this
condition, insignificant activities are defined as any activity or equipment, which emits any
COLORADO
Air Pollution Control Division
s,<rttrr_�:t ci R�bWi' 4 th & E'n u`onr:tar;t
Page 2 of 11
sion Noti • ) or is per exempt.
s and potential -mit from
• 9.2 tons per year of formaldehyde
8. The emission points in the table below shall be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment ID
AIRS
Point
Control Device
-Pollutants
Controlled
ENG-01
004
Oxidation catalyst and air -fuel ratio control
VOC and CO
PROCESS LIMITATIONS AND RECORDS
1. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
ENG-01
004
Consumption of Natural
Gas as a Fuel
92.1 MMSCF
Fuel consumption shall be measured by one of the following methods: individual engine fuel
meter or facilty-wide fuel meter attributed to fuel consumption rating and hours of operation.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month
total. By the end of each month a new twelve-month total is calculated based on the previous
twelve months' data. The permit holder shall calculate throughput each month and keep a
compliance record on site or at a local field office with site responsibility, for Civision review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
2. 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)
3. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the
source. During periods of startup, process modification, or adjustment of control equipment
visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive
minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall
have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. a 4.)
4. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable)
5. This equipment is subject to the control requirements for stationary and portable engines in the
8 -hour ozone control area under Regulation No. 7, Section XVI.B.2. For lean burn reciprocating
internal combustion engines, an oxidation catalyst shall be required.
6.
OPERATING £t MAINTENANCE REQUIREMENTS
COLORADO
I Air Pollution Control Division
i Department of Publiz Me !th G n rm rt
Page 3 of 11
7.
n startup
intenance
onstrate
are sub
ection III.
owner or
ecord kee
going b
shall folio i-►r, st recent o . ating and
t approv •y e Division, order to
equire is of this permit. visions to
m.lemation. (Regulatio umber 3,
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
8. This source is not required to conduct initial testing, unless -otherwise directed by the Division or
other state or federal requirement.
Periodic Testing Requirements
9. This engine is subject to the periodic testing requirements of 40 C.F.R Part 63, Subpart ZZZZ.
10. This engine is subject to the periodic testing requirements as specified in the operating and
maintenance (OEM) plan as approved by the Division. Revisions to your OttM plan are subject to
Division approval. Replacements of this unit completed as Alternative Operating Scenarios may
be subject to additional testing requirements as specified in Attachment A.
ADDITIONAL REQUIREMENTS
9. 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 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
10. 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
;COLORADO
Air Pollution Control Division
Page 4 of 11
ber 3, Pa
ised APEN
his perm
the
on a requ
ee.
ansfer of • , - r''• and the s ittal of a
11. = ` •ecific ; slat- at fin uthoriza granted, then th " emainder
ion is cab -- the • nstruction es 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.
12. 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.
13. 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.
14. 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.
15. 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.
16. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Christopher Kester
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Whiting Oil and Gas Production
_COLORADO
( Air Pollution Control Division
Je{:er:;The .t F Pubti•_ i'411*.h Environment
Page 5 of 11
Notes t.' -rmit Hold= _t the permit iss
1) The rmit holde :' requi ees for th
fee ' ll be issu- 'after t ssued.
e inv
(Regulation Number 3, Part A, Section VI.B.)
pe`° it. An invo for these'
ay the invoice n 30 days
evocation ermit.
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 Il.E.1 of the Common Provisions Regulation.
See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's
analysis of the specific compounds emitted if the source(s) operate at the permitted limitations.
Facility
Equipment ID
AIRS
Point
Pollutant .
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
ENG-01
004
Formaldehyde
50000
9,115
9,115
Acetaldehyde
75070
785
785
Acrolein
107028
483
483
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds
per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution
Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 004:
CAS #
Pollutant
Uncontrolled
Emission Factors
(g/hp-hr)
Controlled
Emission Factors
(g/hp-hr)
Source
N0x
1.0
1.0
Manufacturer
Specifications
CO
3.1
2.0
V0C
1.83
0.7
50000
Formaldehyde
0.36
0.36
75070
Acetaldehyde
0.00836 (lb/MMBtu)
0.00836 (lb/MMBtu)
AP -42
107028
Acrolein
0.00514 (lb/MMBtu)
0.00514 (lb/MMBtu)
Note: Emission factors are based on a Brake -Specific Fuel Consumption Factor of 8,180 Btu/hp-hr, a site -
rated horsepower value of 1311, and a fuel heat value of 1,020 Btu/scf.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to
the most recent annual fee invoice to determine the APEN expiration date for each emissions point
COLORADO
Air Pollution Control Division
artnertt lA" Pt ht4 fieui"?.C EMininn l•nt
Page 6 of 11
ass
at
7) This
specific
date call Division
Applicable Requirement
Status
Operating Permit
Synthetic Minor Source of:
VOC and HAP
PSD
Synthetic Minor Source of:
VOC
MACT ZZZZ
Major Source Requirements: Not Applicable
Area Source Requirements: Applicable
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
ATTACHMENT A:
ALTERNATIVE OPERATING SCENARIOS
RECIPROCATING INTERNAL COMBUSTION ENGINES
1. Alternative Operating Scenarios
The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas
fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of
Regulation No. 3., Part A, Section IV.A, Operational Flexibility -Alternative Operating Scenarios, Regulation No. 3,
Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and
Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural
requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement
performed in accordance with this AOS, and the owner or operator shall be allowed to perform such engine
replacement without applying for a revision to this permit or obtaining a new Construction Permit.
1.1 Engine Replacement
'COLORADO
Air Pollution Control Division
:.nrz.'p int,t €i!i 'E
Page 7 of 11
The foll•` g AOS is in orate, permit in or with an e "w' x kdown or p-:" •ic routine
maintenand repai an e ing o engine t requi he use o ° `''ther temporary !'':•ermanent
replace engine. mpora ' s defi s in th jame servi `- . •r 90 op ing days or less in 12 month
perioF sdefin sa ore t s in any 12 d. The
90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that
day shall count as a single day towards the 90 day total. The compliance demonstrations and any periodic monitoring
required by this A0S are in addition to any compliance demonstrations or periodic monitoring required by this permit.
All replacement engines are subject to all federally applicable and state -only requirements set forth in this permit
(including monitoring and record keeping).
The results of all tests and the associated calculations required by this A0S shall be submitted to the Division within
30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with
NSPS or MACT requirements.
Results of all tests shall be kept on site for five (5) years and made available to the Division upon request.
The owner or operator shall maintain a log on -site and contemporaneously record the start and stop date of any
engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the
engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and
serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of alt
Applicability Reports required under section 1.1.2 and make them available to the Division upon request.
1.1.1 The owner or operator may temporarily replace an existing engine that is subject to the emission limits set
forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different
manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary
replacement engine complies with alt permit limitations and other requirements applicable to the existing engine.
Measurement of emissions from the temporary replacement engine shall be made as set forth in section 1.2.
1.1.2 The owner or operator may permanently replace the existing engine with another engine with the same
manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement
engine complies with all permit limitations and other requirements applicable to the existing engine as well as any
new applicable requirements for the replacement engine. Measurement of emissions from the permanent
replacement engine and compliance with the applicable emission limitations shall be made as set forth in section
1.2.
An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and
horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement
engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied
by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative
operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports
for the replacement engine. Example Applicability
Reports can be found at https://www.colorado.gov/pacific/cdphe/alternate-operating-scenario-aos-reporting-
forms. This submittal shall be accompanied by a certification from the Responsible Official indicating that "based
on the information and belief formed after reasonable inquiry, the statements and information included in the
submittal are true, accurate and complete".
This A0S cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine
that is not subject to emission limits.
The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information
submitted to the Division in regard to any permanent engine replacement.
1.2 Portable Analyzer Testing
Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable
Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing
requirements.
Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified
by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test
,COLORADO
I Air Pollution Control Division
^ra rune t it PLO:: Heafiri E;rvhrsner:t
Page 8 of 11
conduct
another
The own
Condi
y cond
in adv
erly test a F°_ itional port
er test is n. quired for
e analyzer test re gyred by this
The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from
the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation
of the replacement engine.
All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer
Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at:
https: / /www. colorado. gov/pacific /sites/default/files/AP_Portable-Analyzer-Monitoring-Protocol. pdf
Results of the portable analyzer tests shall be used to monitor the compliance status of this unit.
For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests
shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever
applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be
'multiplied by the maximum number of hours in the month or year (8760), whichever applies.
For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or
concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine will
be subject to, the results of the test shall be converted to the appropriate units as described in the above -mentioned
Portable Analyzer Monitoring Protocol document.
If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence
of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and
CO emission limitations for the relevant time period.
Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable
analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be
considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test
indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline.
1.3 Applicable Regulations for Permanent Engine Replacements
1.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B § II.D.2
All permanent replacement engines that are located in an area that is classified as attainment/maintenance or
nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is
attainment/maintenance or nonattainment. Note that both VOC and NOX are precursors for ozone. RACT shall be
applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment,
except as follows:
In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and
to NOX and SO2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr.
For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating internal
combustion engines:
VOC: The emission limitations in NSPS JJJJ
CO: The emission limitations in NSPS JJJJ
NOX: The emission limitations in NSPS JJJJ
SO2: Use of natural gas as fuel
PM10: Use of natural gas as fuel
As defined in 40 CFR Part 60 Subparts GG (S 60.331) and 40 CFR Part 72 (5 72.2), natural gas contains 20.0 grains or
less of total sulfur per 100 standard cubic feet.
COLORADO
Air Pollution Control. Division
Page 9 of 11
1.3.2 C. of Require s an• miss'• andards: R No. 7, S •ns L and XVII State -Only
Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the
applicable control requirements specified in Regulation No. 7, section XVI, as specified below:
Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non -selective catalyst
and air fuel controller to reduce emission.
Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to
reduce emissions.
The above emission control equipment shall be appropriately sized for the engine and shall be operated and
maintained according to manufacturer specifications.
The source shall submit _copies of the relevant Applicability Reports required under Condition 1.1.2.
Emission Standards: Section XVII.E - State -only requirements
Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the
date listed in the table below shall operate and maintain each engine according to the manufacturer's written
instructions or procedures to the extent practicable and consistent with technological limitations and good
engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards
required in the table below:
Max Engine HP
Construction or
Relocation Date
Emission Standards in G/hp-hr
NOx
CO
VOC
100<Hp<500
January 1, 2008
January 1, 2011
2.0
1.0
4.0
2.0
1.0
0.7
500≤Hp
July 1, 2007
July 1, 2010
2.0
1.0
4.0
2.0
1.0
0.7
The source shall submit copies of the relevant Applicability Reports required under Condition 1.1.2.
1.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ
A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25
hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean
burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater
than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An
analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement
shall be included in the Applicability Reports required under Condition 1.1.2. Any testing required by the NSPS is in
addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing
required by this AOS under Condition 1.2, if approved in advance by the Division, provided that such test is conducted
within the time frame specified in Condition 1.2.
Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of
the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of
Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture
date for purposes of determining the applicability of NSPS JJJJ requirements).
However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine
subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an
additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, 3 I.B
(which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of
Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ.
!COLORADO
Air Pollution Control Division
pU6Ii� Hear^.» EmimrIn\2nt
Page 10 of 11
1.3.4 Re
A perma
Part 63,
perm
ngine at ither an ark or ma). •-.urce is s '"' ct t. he requirem s in 40 CFR
analysi- the a: able mtoring, rem: keeping : "; d reporting requir nts for the
aceme plica• d under Co .2. Any
testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the
MACT can serve as the testing required by this AOS under Condition 1.2, if approved in advance by the Division,
provided that such test is conducted within the time frame specified in Condition 1.2.
1.4 Additional Sources
The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new
emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced
construction permit review. The AOS cannot be used for additional new emission points for any site; an engine that
is being installed as an entirely new emission point and not as part of an AOS-approved replacement of an existing
onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation.
(COLORADO
Air Potlution Control Division
'.:tiR to t Publiz Hea.n v Eavr rrwu
Page 11 of 11
CONSTRUCTION PERMIT
Permit number:
Date issued:
Issued to:
17WE0980
Issuance: 1
Whiting Oil and Gas Corporation
Facility Name: Razor 12H Production Facility
Plant AIRS ID: 123/9F5F
Physical Location: SENE SEC 12 T10N R58W
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
ENG-02
005
One (1) Caterpillar, G3516B, SN: JEF02767,
natural gas -fired, naturally aspirated, 4SLB
reciprocating internal combustion engine, site
rated at 1311 horsepower. This emission unit
is used for natural gas compression.
Oxidation catalyst and
air fuel ratio control
This engine may be replaced with another engine in accordance with the temporary engine
replacement provision or with another Caterpillar, G3516B engine in accordance with the permanent
replacement provision of the Alternate Operating Scenario (AOS), included in this permit as
Attachment A.
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission
and the Colorado Air Pollution Prevention and Control Act (C. R.S. 25-7-101 et seq), to this specific general
terms and conditions included in this document and the following specific terms and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the
latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting-
notices. Failure to notify the Division of startup of the permitted source is a violation of Air
Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result
in the revocation of the permit.
'COLORADO
AfrPollution Control Divisiol?,.,
I Uepartmentof PubVez bh t .n & ( lavnnrrtc ;t
Page 1 of 11
2. 't-da �'"s (180) oft of comme .0 r of oP eratio issuance
the conditied in this rmi ;,.;hall be dem trated to
operator: respon ity to -certify complia with the
monst corn! -:rice withi :0 da a result in revo.;' on of the
self certi :' •: orm r •= eon h." -C -' compliant -.r`"red by
this permit may be obtained online at www.colorado.gov/pacific/cdplie/air-permit-self-
certification. (Regulation Number 3, Part B, Section III.G.2).
hin one hu
his permit
Division.
diti
3. This permit shall expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated completion
date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b.
(Reference: Regulation No. 3, Part B, III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this permit
and submit the results to the Division as part of the self -certification process. (Reference:
Regulation No. 3, Part B, Section III.E.)
5. The operator shall retain the permit final authorization letter issued by the Division after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part
B, Section II.A.4.)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NOX
VOC
CO
ENG-02
005
---
12.7
8.9
25.3
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 9.2 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be
determined on a rolling twelve (12) month total. By the end of each month a new twelve month
total is calculated based on the previous twelve months' data. The permit holder shall calculate
actual emissions each month and keep a compliance record on site or at a local field office with
site responsibility for Division review.
7. The owner or operator shall track emissions from all insignificant activities at the facility on an
annual basis to demonstrate compliance with the facility potential emission limitations as
indicated below. An inventory of each insignificant activity and associated emission calculations
shall be made available to the Division for inspection upon request. For the purposes of this
condition, insignificant activities are defined as any activity or equipment, which emits any
(COLORADO
Mr Pollution Control Division
Deixa ment of PuiA Alai th v 6;-Nirormee:t
Page 2 of 11
Air Poltu
II.E.)
inctudi
• 9.2 tons per year of formaldehyde
8. The emission points in the table below shall be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
ENG-02
005
Oxidation catalyst and air -fuel ratio control
VOC and CO
PROCESS LIMITATIONS AND RECORDS
9. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
ENG-02
005
Consumption of Natural
Gas as a Fuel
92.1 MMSCF
Fuel consumption shall be measured by one of the following methods: individual engine fuel
meter or facilty-wide fuel meter attributed to fuel consumption rating and hours of operation.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month
total. By the end of each month a new twelve-month total is calculated based on the previous
twelve months' data. The permit holder shall calculate throughput each month and keep a
compliance record on site or at a local field office with site responsibility, for Division review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part
B, Section III.E.) (State only enforceable)
11. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the
source. During periods of startup, process modification, or adjustment of control equipment
visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive
minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall
have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. Et 4.)
12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable)
13. This equipment is subject to the control requirements for stationary and portable engines in the
8 -hour ozone control area under Regulation No. 7, Section XVI.B.2. For lean burn reciprocating
internal combustion engines, an oxidation catalyst shall be required.
14.
OPERATING Et MAINTENANCE REQUIREMENTS
;COLORADO
Air Pollution Control Division
o FLtbF: 1-iealth J E.tiVcl';C
Page 3 of 11
15.
•n startup
intenance
onstrate
Oa4
are sub
ection III.
owner or
ecord kee
going b
shall folio x I ifsst recent o ating and
t approves •y e Division, order to
�zP
equire is of this permit.•';visions to
m • lem ation. (Regulatio umber 3,
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
16. This source is not required to conduct initial testing, unless otherwise directed by the Division or
other state or federal requirement.
Periodic Testing Requirements
17. This engine is subject to the periodic testing requirements of 40 C.F.R Part 63, Subpart ZZZZ.
18. This engine is subject to the periodic testing requirements as specified in the operating and
maintenance (OEM) plan as approved by the Division. Revisions to your OaM plan are subject to
Division approval. Replacements of this unit completed as Alternative Operating Scenarios may
be subject to additional testing requirements as specified in Attachment A.
ADDITIONAL REQUIREMENTS
19. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NO,) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO,t 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
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
COLORADO
Air Pobiutiaxt Control Division
s y; Rrt of Ptht.4 Heath. 3.Envaorrxnt
Page 4 of 11
ber 3, Pa ;,'„=, Se and the s s_ ittal of a
ised APEN a the
21. his perm• •ecific,� slat at fin. uthoriza, has b granted, then th ,remainder
ion is '' 'cab , the .. .. nstruction es 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 shalt constitute a rejection of the entire permit and
upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked
at any time prior to self -certification and final authorization by the Air Pollution Control Division
(APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air
Quality Control Commission (AQCC), including failure to meet any express term or condition of
the permit. If the Division denies a permit, conditions imposed upon a permit are contested by
the owner or operator, or the Division revokes a permit, the owner or operator of a source may
request a hearing before the AQCC for review of the Division's action.
25. Section 25-7-114;7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission
Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a
source or activity is to be discontinued, the owner must notify the Division in writing requesting
a cancellation of the permit. Upon notification, annual fee billing will terminate.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Christopher Kester
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Whiting Oil and Gas Production
ICO.ORADO
Air Pollution Control Division
c'partme vx 3�ciE73 `d ;e ri v E:,rvor.rnfl,;
Page 5 of 11
Notes t
1) The
fee
rmit Hold
rmit holde
11 be iss
t the:. rtT-• `` permit iss
requi to •'' ees for th '- • • " - time f • "s pe it. An invo for these
fter t ; '. ermi ssued. e permi lder sh • • ay the invoice w n 30 days
e mv.' v, ure invoi e evocation ermit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN)
and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of
any malfunction condition which causes a violation of any emission limit or limits stated in this permit
as soon as possible, but no later than noon of the next working day, followed by written notice to
the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation.
See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's
analysis of the specific compounds emitted if the source(s) operate at the permitted limitations.
Facility
Equipment ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
ENG-02
005
Formaldehyde
50000
9,115
9,115
Acetaldehyde
75070
785
785
Acrolein
107028
483
483.
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds
per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution
Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 005:
CAS #
Pollutant
Uncontrolled
Emission Factors
(g/hp-hr)
Controlled
Emission Factors
(g/hp-hr)
Source
N0x
1.0
1.0
Manufacturer
Specifications
CO
3.1
2.0
V0C
1.83
0.7
50000
Formaldehyde
0.36
0.36
75070
Acetaldehyde
0.00836 (lb/MMBtu)
0.00836 (lb/MMBtu)
AP -42
107028
Acrolein
0.00514 (lb/MMBtu)
0.00514 (lb/MMBtu)
Note: Emission factors are based on a Brake -Specific Fuel Consumption Factor of 8,180 Btu/hp-hr, a site -
rated horsepower value of 1311, and a fuel heat value of 1,020 Btu/scf.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to
the most recent annual fee invoice to determine the APEN expiration date for each emissions point
COLORADO
Air Pollution Control Division
f s`J' & t s er,t,onT,r- a
Page 6 of 11
Applicable Requirement
MayeagiaRKIEHMUI rib
Status
Operating Permit
Synthetic Minor Source of:
V0C and HAP
PSD
Synthetic Minor Source of:
V0C
MACT ZZZZ
Major Source Requirements: Not Applicable
Area Source Requirements: Applicable
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
ATTACHMENT A:
ALTERNATIVE OPERATING SCENARIOS
RECIPROCATING INTERNAL COMBUSTION ENGINES
1. Alternative Operating Scenarios
The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas
fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of
Regulation No. 3., Part A, Section IV.A, Operational Flexibility -Alternative Operating Scenarios, Regulation No. 3,
Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and
Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural
requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement
performed in accordance with this AOS, and the owner or operator shall be allowed to perform such engine
replacement without applying for a revision to this permit or obtaining a new Construction Permit.
1.1 Engine Replacement
ICOLORADO
Air Pollution Control Division
•p _rtrr s Fvb4i=_ fret Oft 6 ErUitonmea,t
Page 7 of 11
The foll. ' `g AOS is in« orates . . permit in orR "� with an e I kdown or p ?.ic routine
mainten.: and repair an e' �;ing o engine t requi he use o ther temporary''•ermanent
replace engine. mpora x ;s defi , .s in th ame servi .r 90 op ing days or less in 12 month
peno -- - s defin sa ore t -- sin any 12 • d. The
90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that
day shall count as a single day towards the 90 day total. The compliance demonstrations and any periodic monitoring
required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit.
All replacement engines are subject to all federally applicable and state -only requirements set forth in this permit
(including monitoring and record keeping).
The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within
30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with
NSPS or MACT requirements.
Results of all tests shall be kept on site for five (5) years and made available to the Division upon request.
The owner or operator shall maintain a log on -site and contemporaneously record the start and stop date of any
engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the
engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and
serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all
Applicability Reports required under section 1.1.2 and make them available to the Division upon request.
1.1.1 The owner or operator may temporarily replace an existing engine that is subject to the emission limits set
forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different
manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary
replacement engine complies with all permit limitations and other requirements applicable to the existing engine.
Measurement of emissions from the temporary replacement engine shall be made as set forth in section 1.2.
1.1.2 The owner or operator may permanently replace the existing engine with another engine with the same
manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement
engine complies with all permit limitations and other requirements applicable to the existing engine as well as any
new applicable requirements for the replacement engine. Measurement of emissions from the permanent
replacement engine and compliance with the applicable emission limitations shall be made as set forth in section
1.2.
An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and
horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement
engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied
by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative
operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports
for the replacement engine. Example Applicability
Reports can be found at https://www.colorado.gov/pacific/cdphe/alternate-operating-scenario-aos-reporting-
forms. This submittal shall be accompanied by a certification from the Responsible Official indicating that "based
on the information and belief formed after reasonable inquiry, the statements and information included in the
submittal are true, accurate and complete".
This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine
that is not subject to emission limits.
The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information
submitted to the Division in regard to any permanent engine replacement.
1.2 Portable Analyzer Testing
Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable
Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing
requirements.
Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified
by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test
COLORADO
Air Pollution Control Division
%cork r of 1 A ale+.kith.& ET.nor meat
Page 8 of 11
conduct
another
The own
Condi
terly test a �;� ' itional port
er test is n., quired for
e analyzer test re ₹:_ ; red by this
The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from
the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation
of the replacement engine.
All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer
Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at:
https://www.colorado.gov/pacific/sites/default/files/AP Portable-Analyzer-Monitoring-Protocol.pdf
Results of the portable analyzer tests shall be used to monitor the compliance status of this unit.
For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests
shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever
applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be
multiplied by the maximum number of hours in the month or year (8760), whichever applies.
For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or
concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine will
be subject to, the results of the test shall be converted to the appropriate units as described in the above -mentioned
Portable Analyzer Monitoring Protocol document.
If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence
of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and
CO emission limitations for the relevant time period.
Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable
analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be
considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test
indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline.
1.3 Applicable Regulations for Permanent Engine Replacements
1.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B S ILD.2
All permanent replacement engines that are located in an area that is classified as attainment/maintenance or
nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is
attainment/maintenance or nonattainment. Note that both VOC and NOX are precursors for ozone. RACT shall be
applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment,
except as follows:
In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and
to NOX and SO2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr.
For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating internal
combustion engines:
VOC: The emission limitations in NSPS JJJJ
CO: The emission limitations in NSPS JJJJ
NOX: The emission limitations in NSPS JJJJ
5O2: Use of natural gas as fuel
PM10: Use of natural gas as fuel
As defined in 40 CFR Part 60 Subparts GG (5 60.331) and 40 CFR Part 72 (5 72.2), natural gas contains 20.0 grains or
less of total sulfur per 100 standard cubic feet.
COLORADO
I Air Pollution Control Division
vt•p:rrx:;t of P bie Health & E:Teirrovner,t
Page 9 of 11
1.3.2 C.•. of Require � s ant miss',• .� �'' andards: R Q ' ; No. 7, S ;�„ •ns I. and XVII. State -Only
conditio
Control
Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the
applicable control requirements specified in Regulation No. 7, section XVI, as specified below:
Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non -selective catalyst
and air fuel controller to reduce emission.
Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to
reduce emissions.
The above emission control equipment shall be appropriately sized for the engine and shall be operated and
maintained according to manufacturer specifications.
The source shall submit copies of the relevant Applicability Reports required under Condition 1.1.2.
Emission Standards: Section XVII.E - State -only requirements
Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the
date listed in the table below shall operate and maintain each engine according to the manufacturer's written
instructions or procedures to the extent practicable and consistent with technological limitations and good
engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards
required in the table below:
Max Engine HP
Construction or
Relocation Date
Emission Standards in G/hp-hr
NOx
CO
VOC
100<Hp<500
January 1, 2008
January 1, 2011
2.0
1.0
4.0
2.0
1.0
0.7
500≤Hp
July 1, 2007
July 1, 2010
2.0
1.0
4.0
2.0
1.0
0.7
The source shall submit copies of the relevant Applicability Reports required under Condition 1.1.2.
1.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ
A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25
hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean
burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater
than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An
analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement
shall be included in the Applicability Reports required under Condition 1.1.2. Any testing required by the NSPS is in
addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing
required by this AOS under Condition 1.2, if approved in advance by the Division, provided that such test is conducted
within the time frame specified in Condition 1.2.
Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of
the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of
Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture
date for purposes of determining the applicability of NSPS JJJJ requirements).
However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine
subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an
additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, § LB
(which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of
Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ.
OLORADO
Air Pollution Control Division
Page 10 of 11
A perma =:'t replacem ngine?."" ate• ither an ar'r or majr ' .urce is s ° '-ct ti . he requirem . sin 40 CFR
Part 63, art ZZZ anal si. the a k able mF:` toring, re ' keeping d reporting re uir nts for the
�= P Y P g� P g q
px.z.,pli -d under Co .2. Any
perm � . aceme �� inc t ica• �.=,_��s • .,. ,
testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the
MACT can serve as the testing required by this AOS under Condition 1.2, if approved in advance by the Division,
provided that such test is conducted within the time frame specified in Condition 1.2.
1.4 Additional Sources
The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new
emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced
construction permit review. The AOS cannot be used for additional new emission points for any site; an engine that
is being installed as an entirely new emission point and not as part of an AOS-approved replacement of an existing
onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation.
COLORADO
Air :Poiitt ion Control Division
3tment d Public HellW1 v aVorire.^,t
Page 11 of 11
gcc.eiuI4l quit.?
Produced Water Storage Tank(s)
APEN - Form APCD-207
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
Incorrectly or is missing information and requires re -submittal.
This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN
(Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of alt
available APEN forms and associated addendum forms can be found on the Air Pollution Control Division {APCD)
website at: _____)larada.aov/aacif ds 1 Ir-oermi c.
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, il.C. for revised APEN requirements.
Permit Number: j \AC 09 - (o AIRS ID Number: 1�3 / `IFSF / Dc)
[Leave blank unless APCD has already assigned a permit A and AIRS ID]
Section 1 - Administrative information
Company Namet: Whiting Oil and Gas Corporation
Site Name: Razor 12H Production Facility
Site Location: SENE Section 12, T1 ON, R58W
Mailing Address:
findude zip Code) 1700 Broadway, Suite 2300
Denver, CO 80290
Site Location
County: Weld
NAlC5 or 5iC Code: 1311
Permit Contact: Jacob Parker
Phone Number: 303-357-4078
E -Mail Address: cceHEcorrespondenceoehing.ccm
use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork,
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided,
Form APCD-2O7 Produced Water Storage Tanks) APEN Revision 07/2017
cocon•eo
1 i Fol.<
t
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit a and AIRS ID]
Section 2 -Requested Action
0 NEW permit OR newly -reported emission source
+❑ Request coverage under traditional construction permit
❑ Request coverage under a General Permit
O GP05 O GP08
if General Permit coverage is requested, the General Permit registration fee of $250 must be
submitted along with the APEN filing fee.
- OR -
O MODIFICATION to existing permit (check each box below thor applies)
❑ Change in equipment ❑ Change company name
❑ Change permit limit O Transfer of ownership3 p ❑ Other (describe below)
OR
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDmONAL PERMIT ACTIONS -
▪ APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info & Notes:. _
3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
For existing sources, operation began on:
(8) 400 bbl produced water tanks
For new or reconstructed sources, the projected start-up date is: May 30, 2017
Normal Hours of Source Operation: 24 hours/day 7 days/week 52
Storage tank(s) located at:
weeks/year
❑� Exploration & Production (E&P) site 0 Midstream or Downstream (non EEtP) site
Will this equipment be operated in any NAAQS nonattainment area?
❑
Yes
No
O
Are Flash Emissions anticipated from these storage tanks?
0
Yes
O
No
Are these storage tanks located at a commercial facility that accepts oil production
wastewater for processing?
Yes
No
III
`'Dathese storage tanks contain less than 1% by volume crude oil on an annual average basis?
O
Yes
❑
No
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)
805 series rules? If so, submit Form APCD-105.
❑
Yes
No
Are you requesting a 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions a 6 ton/yr (per storage tank)?
Yes
No
Ill
D
Form APCD•207 Produced Water Storage Tank(s) APEN - Revision 07/2817
2.i
AV
COLORADO
Popkernor M.'
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already ass,cned a permit r and AIRS ID]
Section 4 - Storage Tank(s) Information
Produces! Water Throughputs
Actual AnnualAmount
(bbl/ yrar)
From what year is the actual annual amount?
Tank design: 0 Fixed roof
O Internal floating roof
Requested Annual Permit Limit
6,168,500
O External floating roof
Storage,
Tank ID
PW-01 to PW-0e
# of Liquid Manifold Storage
Vessels in Storage Tank
8
Total Volume of
Storage Tank
(bbl) ..
3,200
Installation Date of Most
Recent Storage Vessel in
Storage Tank (month/year).
03/2015
Date of First
Production
(month/year)
05/2017
API Number.
05 - 123 -36052
05 • 123 -39152
Wells Serviced by this Storage Tank or Tank Battery5`(E8P Sites Only)
Name of Well
Razor 12-0141H
Razor 12H -0113A
Newly Reported' Well `.
05 - 123 - 39154
Razor 12H -0115A
05 - 123 - 39146
05 • 123 -39147
4 Requested values will become permit limitations. Requested limits) should consider future growth.
5 The E&P 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.
Razor 12H-01166
Razor 12H -1313A
Section 5 - Stack information
Operator Stack
ID No.
FLR-02
Geographical Coordinates
(LatitudelLongitnde or UTM)
40.854122/-103.806436
Discharge Height Above
Ground Level (feet)
40
Temp.
/°F)
>2000
Indicate the direction of the stack outlet: (cheek one)
Q Upward Q Downward
❑ Horizontal Q Other (describe):
Indicate the stack opening and size: (check one)
0 Circular interior stack diameter (Inches):
In Square/rectangle Interior stack width (inches):
Q Other (describe):
Flow Rate
f1CFN)
14.4
Velocity
(ft/sec)
1.2
O Upward with obstructing raincap
6
interior stack depth (irrhes):
Form APCD-2O7 - Produced Water Storage Tank(s) APEN - Revision 07/2017
l A� COLORADO
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assTned a permit # and AIRS ID)
Section 6 - Control Device Information
0 Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Vapor
0 Recovery
Unit (VRU):
Pollutants Controlled: VOC and HAPs
Size: 60 hp Make/Model: Jordan/J-SCG10-3.05-60803
Requested Control Efficiency: 100
VRU Downtime or Bypassed (emissions vented): 47
m Combustion
Device:
Pollutants Controlled: VOC and HAPs
Rating: 148
MMBtu/hr
Type: pare Er�l� Make/Model: Flare IndustrieslSFVP-0824
Requested Control Efficiency: 95
Manufacturer Guaranteed Control Efficiency: 98 9K
Minimum Temperature: N/A
3r.)
Waste Gas Heat Content: Btu/scf
Constant Pilot Light: ❑ Yes 0 No Pilot Burner Rating: 013 MMBtu/hr
0 Closed Loop System
Description of the closed loop system:
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
Section 7 -Gas/Liquids Separation Technology Information (E&P Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 29 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 four (4) 2 -phase separators where gas is separated from liquids.
The liquids are transferred to four (4) heater treaters that are each equipped with a burner to facilitate further separation into streams
of gas, crude oil, and produced water. The separated streams of crude oil and produced water are transferred to storage tanks.
Form APCD-2O7 - Produced Water Storage Tank(s) APEN - Revision 07/2017 4 i A®
COLORADO
w....,.»_ N..ac
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit It and AIRS ID]
Section 8 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN forma.
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
NOx
CO
%RVaim open Zara backup
Overall Requested Control
Efficiency
DV reduction=in emisslom)
HAPs
Other:
VRU Wsi open bete backup
From what year is the following reported actual annual emissions data?
Pollutant
:riteria.Pollutant Emissions Inventory
Emission Factors -
VOC
0.040
Ib/bbl
Flash Analysis
Actual Annual Emissions
Uncontrolled . Controlled
Emissions Emissions " ,
(Ton/year) (Toot/year)
Requested Annual Permit
Emission
Uncontrolled
Emissions .
(Tonslyeoe-)
NOx
0.068
Ib/MMBtu
AP -42
124.91
Controlled
Emissions
(Tons/year)
CO
0.31
ib/MMBtu
AP -42
Chemical Name
Toluene
Benzene
2.94
De Minimis
De Minimis
on=Criteria Reportable Pollutant Emissions Inventory
Chemical
Abstract
Service (CAS)
Number
71432
108883
Emission Factor‘
Uncontrolled
Basis.
0.0004
Source
(AP -42,
Mfg. etc)
ib/bbl Flash Analyse
Actual Annual Emissions
Uncontrolled
Emissions
(Pounds/year)
Controlled
Emissions?
(Pounds/year)
Z_
0.0003
Ethylbenzene
Xylene
n -Hexane
100414
1330207
110543
2,2,4-
Trimethylpentane
Ib/bbl Fiash Analysis
de minimis
0.0001
0.0007
lb/bbl Flash Analysis
lb/bbl Flash Analysis 1
I( [
31
I5
ib/bbl Flash Analysis
y
540841 0.0001
I Flash Analyse
�S(
I�
C.tLblo. ilItS(i1
{ Requested values will become permit limitations. Requested Limit(s) should consider future growth.
6 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are reouesting site specific
emissions factors according to the guidance In PS !Memo 14-03.
7 Annual emissions fees wilt he based on actual controlled emissions reported. If source has not yet started operating, Leave blank.
Form APCD-207 - Produced Water Storage Tank(s) APEN • Revision 07/2017
51®V
Coaoe•be
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS !a]
Section 9 - Applicant Certification
i hereby certify that all information contained herein and Information submitted with this application is complete, true
and correct. If this is a registration for coverage under General Permit GP05 or GP08, i further certify that this source is
and will be operated ryfull compliance wit each condition of the applicable General Permit.
November 28, 2017
Signature of Legally Authorized Person (not a vendor or consultant) Date
Jacob Parker Environmental Professional
Name (print)
Title
Check the appropriate box to request a copy of the:
ID Draft permit prior to issuance
E 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, B.C. for revised APEN requirements.
Send this form along with $152.90 and the General Permit
registration fee of $250, if applicable, to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
Telephone: (303) 692-3150
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https://www.colorado.gov/cdphe/apcd
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2017 6 I IA®
E040Ra00
RecewriJ VIM
Crude Oil Storage Tanks) APEN
Form APCD-21a
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for tanks that store crude oil associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
condensate storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). in addition, the
General APEN (Form APCD-200) is available if the specialty APEN options wilt 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: - ....mistikagy.Lpitticisstaktdrjamita.
This emission notice invalid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: i W C 0 7 7 AIRS ID Number I73 / gFSF/ OO7—
[Leave blank unless APCD has already assigned a permit k and AIRS ID)
Section l - Administrative information
Company Name1: Whiting Oil and Gas Corporation
Site Name: Razor 12H Production Facility
Site Location: SENE Section 12, 'PION, R58W
Mailing Address:
(Include zip code) 1700 Broadway, Suite 2300
Denver, CO 80290
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact: Jacob Parker
Phone Number: 303-357-4078
E -Mail Addressz: CCPHFCorrespondenteowwlieg,corsk
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on alt documents issued by the APCD. Any changes wilt require additional paperwork.
f Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
Form APCD-210 - Crude Oit Storage Tank(s) APEN - Revision 07/2017
II A
COLOR•DO
34143D
Permit Number: AIRS ID Number:
[Leave blank unless ARCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
0 NEW permit OR newly -reported emission source
+❑ 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 -
O MODIFICATION to existing permit (check each box below that applies)
O Change in equipment ❑ Change company name
O Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below)
-OR-
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit(PTE)
Additional Info Et Notes:
3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
(16) 400 bbl crude oil tanks
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is: May 30, 2017
Normal Hours of Source Operation: 24
hours/day 7
Storage tank(s) located at: 0 Exploration Et Production (EEtP) site
Will this equipment be operated in any NAAQS nonattainment area?
Are Flash Emissions anticipated from these storage tanks?
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)
805 series rules? If so, submit Form APCD-105.
Are you requesting z 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions e 6 ton/yr (per storage tank)?
days/week
52
weeks/year
O Midstream or Downstream (non EEiP) site
Yes
Form APCD-210 Crude Oil Storage Tank(s) APEN - Revision 07/2017
Yes
0
No
No
El
Yes
Yes
a
COLORADO
2 I � � M
No
No
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assified a permit # and AIRS ID)
Section 4 - Storage Tank(s) information
"Crude Oil Threuehfau
Actual Annual Amount Requested Annual Permit Limit4'
(bbl/year)
estil/yeer)
1,387,000
From what year is the actual annual amount?
Average API gravity of sates oil: 34.2 degrees
Tank design:
Fixed roof
❑ Internal floating roof
Storage # of Liquid Manifold Storage
-Tank ID Vessels In Storage Tank
TK-01 to TK.t
16
Total Volume of
Storage Tank
(bbl)
API Number_
6,400
RVP of sales oil: 6.7
I] External floating roof
Installation Date of Most
Recent Storage Vessel in
Storage Tank .(n onth)year)
03/2015
Date of First
Production -,
(month/year) -
05/2017
Wells Serviced b this Stora e Tank or Tank Battery 'E&P Sites On )
Name of Well"
05 - 123 - 39152
05 123 39154
05 • 123 •39146
05 • 123 •39147
Razor 12-0141H
Razor 12H -0113A
Razor 12H -0115A
Razor 12H-01168
Newly Reported Well
Ga
❑✓
O
Razor 12H -1313A.___ _ ..
0
4 Requested values wilt become permit limitations. Requested limit(s) should consider future growth,
5 The E&P Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to
report alt wells that are serviced by the equipment reported on this APEN form.
Section 5 - Stack information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.854122/-103.806436
Operator Stack i Discharge Height Above I Temp.
ID No. Ground Level (feet) (°F
FLR-02 40 L >2000
Indicate the direction of the stack outlet: (check one)
0 Upward
O Horizontal
Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑+ Circular
O Square/rectangle Interior stack width (Inches);
C❑ Other (describe):
Flow Rate
(ACFM)
53.4
Velocity
(ft/sec)
5.4
O Upward with obstructing raincap
1
Interior stack diameter (Inches): 6
interior stack depth (Inches):
Form APCD-21O - Crude Oil Storage Tank(s) APEN Revision 07/2017
COLORADO
3l AV
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS I0)
Section 6 —Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Vapor
❑✓ Recovery
Unit (VRU):
Pollutants Controlled: v0C and HAPs
Size: 60 hp Make/Model: Jordan/J-SCG10-3.05-60-4803
Requested Control Efficiency: 100
VRU Downtime or Bypassed (emissions vented): 47
Combustion
Device:
Pollutants Controlled: VOC and HAPs
Rating: 148 MMBtu/hr
Cn,`d Type: Flare Industries/SFVP-0824
��� epen Flare Make/Model:
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency: 98 %
Minimum Temperature: 2 �S9
P N/A Waste Gas Heat Content: 5— Btu/scf
Constant Pilot Light: ❑i Yes O No Pilot Burner Rating: 0.13 MMBtu/hr
Description of the closed loop system:
O Closed Loop System
O Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
Section 7 -Gas/Liquids Separation Technology Information (E&P Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 37
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 four (4) 2 -phase separators where gas is separated from liquids.
The liquids are transferred to four (4) heater treaters that are each equipped with a burner to facilitate further separation into streams
of gas, crude oil, and produced water. The separated streams of crude oil and produced water are transferred to storage tanks.
Form APCD-210 - Crude Oil Storage Tank(s) APEN -Revision 07/2017
4 I �� C0LDR4 Q0
'[1..an..r-M M1Mrt
IfMA.t R.-urn..R
Permit Number:
AIRS ID Number:
[Leave blank unles$APCD has already assigned a permit # and AIRS ID]
Section 8 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN forme.
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):
V0C
N0x
CO.
HAPs
Other:
VRU WO open Aare backup
ItMal
verall Requested Control
Efficiency
(% reductio,, in emissions)
VRU wI h open Aare backup
From what year is the following reported actual annual emissions data?
VOC
NOx
2.3907
0.068
Emission Fat
lb/bbl
Ib/MMBtu
Criteria Pollutant Emissions Inventory
Actual Annual Emissions
irce .uncontrolled?„:*
►P 42 Emissions
Flash Analysis
AP -42
Controlled °
Emissions
(Tons/year)`,
es
Requested Annual Permit
Emission Limit(s)''_
Uncontrolled
Emissions
(Tons/year)
1657.95 -
CO
0.31
Chemical Name
(
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
2,2,4-
Trimethylpentane
Ib/MMBtu
AP -42
Ion -Criteria Reportable Pollutant Emissions °invry
entor
Chemical Emission Factor' - Actual Annual Emissions
Abstract Source Uncontrolled Controlled
Service (CAS) Uncontrolled Units(AP-42, Emissions ?
Number 'Basis Emissiorts
Mfg. etc) (Poundsfyear) (Pounds/year) .,
GcS� (&(
(
w
Controlled
Emissions
(Tons/year)
38.96
De Minimis
5.62 -
71432
108883
100414
1330207
110543
0.0049
0.0037
0.0005
0.0017
0.0445
540841 f 0.0044
lb/bbl
lb/bbl
Flash Analysis
Flash Analysis S
Ib/bbl Flash Analysis 73s-
lb/bbl
lb/bbl
lb/bbl
Flash Analysis
ZNI ci
Flash Analysis 6 I -42.9
Flash Analysis
Co97
2a
S7
I,y�
14-13
( . e4er (111 41
I
4 Requested values willbecome permit limitations. Requested tImit(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.
Annual emissions fees will be based on actual controlled emissions reported, If source has not yet started operating, leave blank.
Form APCD•210 • Crude Oil Storage Tank(s) APEN - Revision 07/2017
5)A
COLORADO
.roe at et-
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already ass,gned a permit JJ and AIRS ID]
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct, if this is a registration for coverage under General. Permit GP08, i further certify that this source is and wilt
be operated in full compliance with each condition of the applicable General Permit.
Sign
-November28, 2017
e of Legally Authorized Person (not a vendor or consultant) Date
Jacob Parker
Name (print)
Environmental Professional
Title
Check the appropriate box to request a copy of the:
(] Draft permit prior to issuance
D Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II. C. for revised APEN requirements.
Send this form along with 5152.90 and the General Permit
registration fee of 5250, if applicable, to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-BI
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
Telephone: (303) 692-3150
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https:/ /www,colorado.gov/cdphe/apcd
Form APCD-21O -Crude OiE Storage Tanks) APEN - Revision 07/2017
Mir COLORADO
CDPHE
s
Natural Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
AUG 2 9 2017
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, btowdown 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/aped.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 11 v oa1g AIRS ID Number: I Z3 /Gtf5 P / 3
[Leave blank unless APCD has already assigned a permit t and AIRS iD]
Company equipment Identification: SEP-01 through '64 SE? -OS
[Provide -Facility Equipment ID to identify how this equipment is referenced vethin your organization]
C , ICcsitr • ?
l-2,17,1117
Section 1 - Administrative Information
Company Name: Whiting Oil and Gas Corporation
Site Name: Razor 12H Production Facility
Site Location: SENE Section 12, T1 ON, R58W
Mailing Address:
(Include Zip Code) 1700 Broadway, Suite 2300
Denver, CO 80290
E -Mail Address': CDPHECOrreSpOrlderiCe@Whiting.COM
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact: Jacob Parker
Phone Number: 303-357-4078
'Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will
appear on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
Form APCD-211 - Natural Gas Venting APEN - Rev 03'2.017
368431
NirCOLORADO
Nne4F. i fnrnannen�
Permit Number: AIRS ID Number:
e unless APCD has ,snd AIRS ;D
Section 2- Requested Action
❑✓ NEW permit OR newly -reported emission source
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name 0 Add point to existing permit
O Change permit limit
❑ Transfer of ownership3 ❑ Other (describe below)
-OR -
❑ APEN submittal for update only (Please note blank APENs will not be accepted)
ADDITIONAL PERMIT ACTIONS -
Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info £t 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:
3 L. K.a4 cr- 7 Pa-/c4r
Flaring associated gas from(2-phase separators I141-1/1-4
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
05 / 30 / 2017
❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day
Will this equipment be operated in any NAAQS nonattainment
area
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions
days/week weeks/year
O Yes 0 No
O Yes 0 No
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
COLORADO
2 I � =',":717Z.,=
�
Permit Number: AIRS ID Number:
Section 4 - Process Equipment Information
Q Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model:
❑ Compressor Rod Packing
Make: Model:
O Blowdown Events
# of Events/year:
• Other
Description:
Serial #: Capacity: Gal/min
# of Pistons: Leak Rate: Scf/hr/pist
Volume per event: MMscf/event
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural
Gas Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy?
Natural Gas Venting
Process Parameters4:
Liquid Throughput
Process Parameters4:
Yes
❑ No
Maximum Vent
Rate:
500 000
SCF/hr
Vent Gas
Heating Value:
1,474 -
BTU/SCF
Requested:
25:6 -- -
MMSCF/year .
Actual:
M►MSCf/year_:
-OR-
Requested:
Bbl/yr
Actual:
Bbl/yr
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Process Properties:
Molecular Weight:
V0C (mole %)
20.66
VOC (Weight %)
40.986
Benzene (mole %)
0.018
Benzene (Weight %)
0.054
Toluene(mole %)
0.018
Toluene (Weight %)
0.064
Ethylbenzene (mole %)
0.003
Ethylbenzene (Weight %)
0.013
Xylene (mole %)
0.007
Xylene (Weight %)
0.028
n -Hexane (mole %)
0.199
n -Hexane (Weight %)
0.651
2,2,4-Trimethytpentane
(mote %)
0.003
2,2,4-Trimethylpentane
(Weight %)
0.012
Additional Required Information:
❑✓ Attach a representative gas analysis (including BTEX Ft 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 403,'2017
A -1w, COLORADO
3 ®Y om.rraw.i n�r,ar
14a'mtr4 uonmon.
Permit Number:
AIRS ID Number:
r ,,it AIRS DI..
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.83015/-103.86586
operator'
Stack�D No
s ar a -el
Above Ground Level
(Feef)
E*Ijl P
{
10 Rd a
= r►CFAd)
eloi7
V
i(ft/sec)
FLR-01
40
>2,000
2,431
116.1
Indicate the direction of the stack outlet: (check one)
✓❑ Upward
❑ Horizontal
❑ Downward
D Other (describe):
Indicate the stack opening and size: (check one)
D Circular Interior stack diameter (inches):
❑ Other (describe):
❑ Upward with obstructing raincap
8
Section 6 Control Device Information
O VRU:
Pollutants Controlled:
Size:
Make/Model:
Requested Control Efficiency
VRU Downtime or Bypassed
Combustion
Device:
Pollutants Controlled: VOC and HAPs
Rating:
598
MMBtu/hr
Type: Open Flare Make/Model: Flare Industries/SFVP-0824
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency 98 %
Minimum Temperature: N/A
Waste Gas Heat Content
Constant Pilot Light: ❑✓ Yes O No Pilot burner Rating
1,474
0.13
Btu/scf
MMBtu/hr
Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0/0
COLORADO
Form APCD-211 -Natural Gas Venting APEN - Rely 03/2017
PM
Permit Number:
AIRS ID Number:
! eave. iAa ✓ un{. ss ARCED i1 , a! ;..,1y t' ict e I l D
,nit = and AIR ID
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? 0 Yes ❑ No
If yes, please describe the control equipment AND state the overall control efficiency (% reduction):
Control Equipment Description
Overall RequestedContr:
Efficiency
(% reduction fn emissions)
SOX
NOx
VOC
Gas is sent to gas gathering pipeline w/open flare as backup
95%
CO
HAPs
Gas is sent to gas gathering pipeline w/open flare as backup
95%
Other:
From what year is the following reported actual annual emissions data?
Use the following table to report the criteria pollutant emissions from source:
(Use the data reported in Sections 4 and 6 to calculate these emissions.)
Uncontrolled
Emission
Factor
Emission
Factor
Units
Emission
_Factor_ActualAnnuai
Source
(AP -42
Mfg. etc)
Emissions ,miss'rflry
Requested Annual Permit
Pollutant
art(3
Uncontrolled
(Tons/year)
Controlled6
(Tons/year)
Uncontrolled
(Tons/year)
Controlled
(Tons/year)
PM
0.0075
Ib/MMBtu
AP -42
De Minimis
SOx
NOx
0.068
Ib/MMBtu
AP -42
De Minimis
VOC
28,484.63
lb/MMscf
Gas Analysis
363.89 --
18.19
CO
0.31
lb/MMBtu
AP -42
5.92 ..-
Benzene
37.26
lb/MMscf
Gas Analysis
0.48 -
0.02
Toluene
44.69
Ib/MMscf
Gas Analysis
0.57 —
0.03
Ethylbenzene
8.95
lb/MMscf
Gas Analysis
De Minimis
De Minimis
Xylenes
19.31
Ity/MMscf
Gas Analysis
0.25-
0.01 -
n -Hexane
452.25
Ib/MMscf
Gas Analysis
5.78 '
0.29
2,2,4-
Trimethylpentane
8.13
Ib/MMscf
Gas Analysis
De Minimis
De Minimis
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
.k
.4
Form APCD-211 -Natural Gas Venting APEN -- Rev 03./2017
5 'MY'Atom, oMatic
Amy COLORADO
rcw.� r
Permit Number: AIRS ID Number:
n CD.h .t ad', i n d i and ppR.5ID}
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct.
Jacob Parker
August 28, 2017
nature of Legally Authorized Person (not a vendor or, consultant)
Date
Environmental Professional
Name (please print)
Check the appropriate box to request a copy of the:
0 Draft permit prior to issuance
0 Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
Send this form along with $152.90 to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-61
4300 Cherry Creek Drive South
Denver, CO 8O246-1530
Make check payable to:
Colorado Department of Public Health and
Environment
Telephone: (303) 692-3150
Forrh APCD-211 -Natural Gas Venting APEN Rev 03/2017
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https://www.colorado.gov/cdphe/apcd
LA COLORADO
6f
�tk `
CDPHE
r4ct„eta aln1i7
Reciprocating Internal Combustion
Engine APEN — Form APCD-201
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for reciprocating internal combustion engines (RICE). If your engine is a diesel compression
ignition engine or your emission unit does not fall into the RICE category, there may be a more specific APEN for
your source le.g. diesel compression ignition engine, mining operations, asphalt plant, crusher, screen, etc.). In
addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your
reporting needs. A list of all available APEN forrns can be found on the Air Pollution Control Division (APCD)
website at: www.calorado.Rov/cdphe/aped.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation -No. 3, Part A, !LC. for revised APEN requirements.
Permit Number:
17 -'WE C9
AIRS ID Number: 17,5 APs-i(j`-(
[Leave blank unless APCD has already assigned a perm Ft # and AIRS ID)
Section 1 Administrative Information
Company Name':
Site Name:
Site Location:
Whiting Oil and Gas Corporation
Razor 12H Production Facility
Site Location
SENE, Section 12, T10N, R58W County: Weld
Mailing Address:
(Include Zip Code) 1700 Broadway, Suite 2300
Portable Source
Home Base:
Denver, CO 802910
NAICS or SIC Code: 1311
Permit Contact: Jacob Parker
Phone Number: 303-357-4078
E -Mail Address': CDPHECorrespondenceljwhittng.com
Use.the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on alt documents issued by the APCD. Any changes wilt require additional paperwork.
2 Permits, exemption letters, and any processing invoices will beissued by APCD via e-mail to the address provided.
Form APCD-2O1 —Reciprocating Internal Combustion Engine APEN - Revision 1/2017
� 1AV
COLORADO
ADO
._m....a.
3614Z?
Permit Number: MRS ID Number:
(Leave blank unless APCD has already assigned a permit if and AIRS IDJ
Section 2 - Requested Action
NEW permit OR newly -reported emission source (check one below)
Q STATIONARY source 0 PORTABLE source
❑ Request coverage under a Construction Permit
❑ Request coverage under General Permit GP023 (Natural Gas Only)
if General Permit coverage is requested, the General Permit registration fee of 51,500.00 must be submitted along
with the APEN Filing fee.
-OR-
❑ MODIFICATION to existing permit (check Bad, box below that applies)
❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit
❑ Change permit limit ❑ Transfer of ownership4 0 Other (describe below)
-OR.
❑ APEN submittal for update only (Blank APENs will not be accepted)
- ADDmoMAL PERMIT Ac ions -
❑ APEN submittal forpermit-exempt/grandfathered source
D Notification of Alternate Operating Scenario (AOS) permanent replacements
Additional Info E Notes:
3 Only one engine may be reported per APEN for GP02 coverage. Coverage under GP02 is voluntary.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
5 This does not apply to General Permit GP02, as it does not contain a provision for AOS permanent replacements.
Section 3 - General information
Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3, etc)? Yes
If yes, provide the Company Equipment Identification No. ENG-01
General description of equipment and purpose: Gas LiktompreSSot Engine
Far existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is:
Will this equipment be operated in any NAAQS nonattainment area?
(http: //www. color. eov/cdiihe /attainment)
Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year
July 14, 2017
❑ Yes r❑ No
Seasonal use percentage: Dec -Feb; 25 Mar -May: 25 June -Aug: 25 Sept -Nov: 25
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
2-I it co�o*.ao
Permit Number: AIRS ID Number:
ILcave blank unless APED has already assigned a permit # and MRS ID]
Section 4 - Engine Information
Engine O Primary and/or Peaking ❑ Emergency Back-up 0 Compression
Function: O Pump ❑ Water Pump O Other:
What is the maximum number of hours this engine will be used for emergency
back-up power? 0
hours/year
Engine Make: Caterpillar Engine Model: G3516B Serial Number': JEF03159
What is the maximum designed horsepower rating? 1,380-- hp What is the engine displacement? 4.3 l/cyl
What is the maximum manufacturer's site -rating? 1,311 -' hp kW
What is the engine Brake Specific Fuel Consumption at 100% Load? 8,180 BTU/hp-hr
Engine Features:
Cycle Type: ❑ 2 -Stroke 12 4 -Stroke Combustion: Lean Burn O Rich Burn
Ignition Source: O Spark O Compression Aspiration: O Natural O Turbocharged
Is this engine equipped with an Air/Fuel ratio controller (AFRC)? 0Yes O No
If yes, what type of AFRC is in use? 0 O2 Sensor (mV) ❑NOx Sensor (ppm) ❑ Other:
Is this engine equipped with a Low-NOx design? O Yes 0 No
Engine Dates:
What is the manufactured date of this engine? November 11, 2014
What date was this engine ordered? January 6, 2017
$ - Yvhatis the datethis'engine waSlirstlikateirto Colorado?— Iebruary 2, 2017
What is the date this engine was first placed in service/operation? July 14, 2017
What is the date this engine commenced construction? February 2, 2017
What is the date this engine was last reconstructed or modified? N/A
Is this APEN reporting an AOS replacement engine? ❑ Yes 0 No
If yes, provide the, make, model, and serial number of the old engine below:
Engine Make: Engine Model: Serial Number:
6 The serial number must be submitted if 'coverage under GPOZ is requested.
Form APCD-201 - Reciprocating Internal Combustion Engine APEN • Revision 1/2017
3AY
COLORA'00
-.r-Y
Permit Number:
AIRS ID Number:
heave blank unless APCD has already assigned a permit and MRS 1D)
Section 5 - Stack Information
40.854122/-103.806436
raphical Coordinates
�- Operator
tick JD No
t
F '
scharge Neightr
Level
Above Ground Lel
_. ,�...h
L .� �...
Temp
_...
Flow Rate
1
..w'1r.
a.
Yell tY
tlsec)
ENG-01
23.7
1,027
8,828
187.3
indicate the direction of the Stack outlet: (check one)
0 Upward
0 Horizontal
❑ Downward
0 Other (describe):
Indicate the stack opening and size: (check one)
❑i Circular Interior stack diameter (inches):
0 Square/Rectangle Interior stack diameter (inches):
❑ Other (describe):
12
0 Upward with obstructing raincap
Interior stack -depth (inches):
Section 6 - Fuel Data and Throughput information
Fuel Use.Rate @ 100% Load
'{ (SCF/hour) .. '" _, _
Actual Annual Fuel Use
- (MMSCF/year) =
Requested Annual'Permit Limit
(MMSCFlyear
10,514 --
92.10 -- -
From what year is the actual annual amount?
Indicate the type of fuel used:
Pipeline Natural Gas . (assumed fuel heating value of 1,020 BTWscf) -
❑ Field Natural Gas Heating value: BTU/scf
❑ Propane (assumed fuel heating value of 2,300 BTU/scf)
❑ Landfill Gas Heating Value: BTU/scf
❑ Other (describe): Heating Value (give units):
7 Requested values will become permit limitations. Requested limitts) should consider future process growth.
a If fuel heating value is different than the listed assumed value, provide this information in the "Other" field.
Form APCD-2O1 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
41A 0.ca'on" o
1'
TSP (PM)
Permit Number.
AIRS ID Number:
/ /
[Leave blank unless APCD has already assigned a permit and AIRS ID]
Section 7 - Emissions Inventory Information
Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a
Natural Gas Fired Engines Calculator available to assist with emission calculations.
Is any emission control equipment or practice used to reduce emissions? Q Yes ❑ No
If yes, describe the control equipment AND state the overall control efficiency (% reduction):
'Fri Mary Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
PM,0
PM2,5
sox
NOx
VOC
CO
SCa wih AMC
Sco q4h 114=f4C
-524%- i. 7
35.5%'
Other:
Use the following tables to report criteria and non -criteria pollutant emissions from source:
(Use the data reported in Section 6 to calculate these emissions.)
From what year is the following reported actual annual emissions data?
-f?ollutarst•
TSP (PM)
Criteria Pollutant Emissions inventory;
Emission Factor Actual Annual Emissions°
Incontrolled ' Units
- Basis
0.00991
IbIMMBW
Source . Uncontrolled ;', Controlled
- (AP 42, Emissions Emissions
Mfg. etc) (Tons/year} (Tonslyear)
AP -42
Requested Annual Permit
Emission Limits
Uncontrolled . Controlled
Emissions Emissions
(Tonsyear) Irons/war)
Ds Minmis
Os Minims
PM,0
PM2,s
0.00991
4IMMBIu
AP -42
Ds Minim*
De Minirnis
0.00991
Ib/MMBtu
AP -42
Os Minima
DI Mirinis
SOx
NOx
VOC
0.000588
INMMBIu
AP -42
De Mmimis
D• Minima
1.0
i r
NSPS JJJJ
12.7 —
12.7 -
1.$3 s,4+_
y/hp ,r
Mary Spec
23.2 —
8.9 -
CO
3.10
yhp-hr
Mnf Spec
39.2 i
26.3 ,
Does the emissions source have any uncontrolled actual emissions of non -criteria Yes ❑ No
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year?
if yes, please use the following table to report the non -criteria pollutant (HAP) emissions from source:
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Non -Criteria Reportable Pollutant Emissions Inventory
hemical Emission Factor
Abstract..
Service (CAS)
Number
50000
75070
107028
71432
0.00314 -
0.00044 .
Uncontrolled
Basis
0.39 -
- : Units
081P -N
source
(AP -42,
Mfg. etcL
Mint Spec
Actual Annual Emissions9
Uncontrolled' Controlled Emissions
Emissions (Pounds/year)
(Pounds/year)
9(')4G,
0.80938
UKS (IKS
DA MEN
AIMMBW
PoNMBw
AP -42
AP -42
AP42
907,
Other:
7 Requested values will become permit limitations. Requested limits) should consider future process growth.
9 Annual emissions fees wilt be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-201 - Reciprocating internal Combustion Engine APEN - Revision 1/2017
5 i&Y
COLORADO
«.,�
Permit Number:
AIRS ID Number:
(Leave blank unless APCD has already assigned a permit # and MRS tD]
Section 8 - Applicant Certification
i hereby certify that all information contained herein and information submitted with this application is complete, true
and correct. If this is a registration for coverage under general permit GP02, I further certify that this source is and will
be operated in full corm lance wit each con on of general permit GPOZ.
Si gnatiire of legally Authorized Person (not a vendor or consultant)
Jacob Parker
November 28, 2017
Date
Environmental Professional
Name (please print)
Title
Check the appropriate box to request a copy of the:
[]✓ Draft permit prior to issuance
E 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 S152.90 and the General Permit
registration fee of $1,500, if applicable to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
Telephone: (303) 692-3150
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
or visit the APCD website at:
https://www.colorado,gov/cdphefapcd
Form APCD-201 - Reciprocating internal Combustion Engine APEN - Revision 1/2017
6 Al"
coL e m aso
g,aiuta 11'04I1
Reciprocating Internal Combustion
Engine APEN - Form APCD-201
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing Information and requires re -submittal.
This APEN is to be used for reciprocating internal combustion engines (RICE). if your engine is a diesel compression
ignition engine or your emission unit does not fall into the RICE category, there may be a more specific APEN for
your source (e.g. diesel compression ignition engine, mining operations, asphalt plant, crusher, screen, etc.). in
addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your
reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)
website at: www. colorado.tov/cdphe/at}cd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number. 1 W G 0 9 &) AIRS iD Number; 123 / ( FS7/00S—
[leave blank unless APCD ha: already ass•gned a permit and AIRS IDj
Section 1 - Administrative Information
Company Name': Whiting Oil and Gas Corporation
Site Name: Razor 12H Production Facility
Site Location
Site Location:
SENE, Section 12, T1 ON, R58W County: Weld
Mailing Address:
encrude zfP Coder 1700 Broadway, Suite 2300
Portable Source
Home Base:
Denver, CO 80290
NAICS or SIC Code: 1311
Permit Contact; Jacob Parker
Phone Number: 303-357-4078
E -Mail Address: COPHECarrespondence@whutreg.com
I Use the full, legal company name registered with the Colorado Secretary of State. This Is the company name that well appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
Form APCD•201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 1 I
COkORADO
.u. �:• :
Permit Number:
AIRS ID Number: /
[Leave btank unless APCD has already assigned a permit # and AIRS ID)
Section 2 -Requested Action
[] NEW permit OR newly -reported emission source (check one below)
❑ STATIONARY source 0 PORTABLE source
❑ Request coverage under a Construction Permit
0 Request coverage under General Permit GP023 (Natural Gas Only)
If General Permit coverage is requested, the General Permit registration fee of $1,500.00 must be submitted along
with the APEN Filing fee.
-OR-
❑ MODIFICATION to existing permit (check each box below that opprres)
O Change fuel or equipment 0 Change company name ❑ Add point to existing permit
❑ Change permit limit 0 Transfer of ownership' ❑ Other (describe below)
- OR
APEN submittal for update only (Blank APENs will not be accepted)
- ADDITIONAL PERMIT AcnoNs -
❑ APEN submittal for permit-exempt/grandfathered source
❑ Notification of Alternate Operating Scenario (AOS) permanent replacements
__AdditionaUnfo.It_Notes: _____ ---- ___ __ -
3 Only one engine may be reported per APEN for GP02 coverage. Coverage under GP0Z is voluntary.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-1O4) must be submitted.
s This does not apply to General Permit GPOZ, as it does not contain a provision for AOS permanent replacements.
Section 3 - General Formation
Does this engine have a Company Equipment Identification No. (e.g. ENG-t, Engine 3, etc)? Yes
If yes, provide the Company Equipment Identification No.
ENG-02
General description of equipment and purpose: Gas Lift Compressor Engine
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is:
WILL this equipment be operated in any NAAQS nonattainment area?
(htto: //www.colorado. eov /.cdphe /attainment)
July 14, au. -
❑ Yes ❑r No
Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year
Seasonal use percentage: Dec -Feb: 25 Mar -May: 25 June -Aug: 25 Sept -Nov: 25
Form APCD-2O1 - Reciprocating Internal Combustion Engine APEN . Revision 1/2017
2 Icy COL O■ -APO
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit p and AIRS IDj
Section 4 - Engine information
Engine ❑Primary and/or Peaking O Emergency Back-up Compression
Function: O Pump O Water Pump O Other:
What is the maximum number of hours this engine will be used for emergency
back-up power?
Engine Make: Caterpillar Engine Model: G3516B
What is the maximum designed horsepower rating? 1,380 ----
What is the maximum manufacturer's site -rating? 1,311 - hp
What is the engine Brake Specific Fuel Consumption at 100% Load?
Engine Features:
Cycle Type: O 2 -Stroke ❑i 4.5troke
Ignition Source: O Spark O Compression
0
hours/year
Serial Number6: JEF02767
What is the engine displacement? 4.3 l/cyl
kW
8,180 - BTU/hp-hr
Combustion: Q Lean Burn O Rich Burn
Aspiration: ❑ Natural O Turbocharged
is this engine equipped with an Air/Fuel ratio controller (AFRC)? ❑i Yes ❑ No
If yes, what type of AFRC is in use? Q Oz Sensor (my) ❑NOx Sensor (ppm)
is this engine equipped with a Low-NOx design? O Yes 0 No
Engine Dates:
What is themanufactured date of this engine? May 9, 2014
What date was this engine ordered? January 6, 2017
O Other:
What1S-the date his engine was fififlocated to Celnrado?--February2, 2017
What is the date this engine was first placed in service/operation? July 14, 2017
What is the date this engine commenced construction? February 2, 2017
What is the date this engine was last reconstructed or modified? N/A
Is this APEN reporting an AOS replacement engine? ❑ Yes 0 No
if yes, provide the make, model, and serial number of the old engine below:
Engine Make: Engine Model: Serial Number:
6 The serial number must be submitted tf coverage under GP02 is requested.
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
3 AY
AnArtorwolINAor
COLORADO
ENG-02
23.7
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assrtned a permit a and AIRS ID)
Section 5 - Stack Information
raphicat Coordinates
itifvdelLangithde or UTM)
40.854122/-103.806436
Dis..
charge .Heigh
ve Grounf Lev.
1,027
8,828
187.3
Indicate the direction of the Stack outlet: (check one)
r❑ Upward
O Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
O Upward with obstructing raincap
0 Circular Interior stack diameter (inches): 12
❑ Square/Rectangle Interior stack diameter (inches): Interior stack depth (inches):
❑ Other (describe):
Section 6 - Fuel Data and Throughput Information
Fuel -Use Rate • 100% Load`
(SCF/hour) `" -
Actual, Annual Fuel Use
(MMSCF/year)
RequestedKAnnual Permit Limit'
(MMSCFfyear),
10,514 -
92.10
From what year is the actual annual amount?
Indicate the type of fuel used`:
CO Pipeline Natural Gas (assumed fuel heating value of 1,020 BTUI/scf) .
O Field Natural Gas Heating value: BTU/scf
❑ Propane (assumed fuel heating value of 2,300 8TUfscf)
❑ Landfill Gas Heating Value: BTU/scf
❑ Other (describe): Heating Value (give units):
T Requested values will become permit limitations. Requested limits) should consider future process growth.
8
If fuel heating value is different than the listed assumed value, provide this information in the "Other" field.
Form APCD•201 - Reciprocating Internal Combustion Engine APED - Revision 1/2017
COLORADO
4 1,:,: "^� ,
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Emissions Inventory Information
Attach alt emission calculations and emission factor documentation to this APEN form. The APCD website has a
Natural Gas Fired Engines Calculator available to assist with emission calculations.
Is any emission control equipment or practice used to reduce emissions? ® Yes ❑ No
If yes, describe the control equipment AND state the overall control efficiency (% reduction):
7
J
TSP (PM)
PMt0
PM2:5
sax
NOX
VOC
Overall Requested Control
Efficiency
(% reduction in emissions)
CO
Other:
sco wan;AFRC
SCO with AFRC
38.5% —
Use the following tables to report criteria and non -criteria pollutant emissions from source:
(Use the data reported in Section 6 to calculate these emissions.)
From what year is the following reported actual annual emissions data?
TSP (PM)
PM10
PM 2.5
eria Pollutant Emissions invento
0.00991
mamma,
AP -42
actual Aninual Fm ssions9
Incontrolted'
Emissions
7ores/ ar
Controlled.
Emissions
(Tons, ar)
quested Annual Permit
Emission Limits)
Uncontrolled '
Emission's f'
(Tons/ year)
0.00991
ib/MMEttu
AP -42
SO2
NOX
vOC
CO
0.000588
IbIMMBIu
AP -42
1.0 e-
yhp-hr
1 SPS JJJJ
De Minim*
De Minims
De Mlnimis
De Minimis
4,47'
3.10 /
9111p -hr
Mani Spec
yitrp-hr Mani Spec
Does the emissions source have any uncontrolled actual emissions of non -criteria
pollutants (e.g. HAP- hazardous air pollutant) equal to or greater than 250 lbs/year?
If yes, please use the following table to report the non -criteria pollutant (HAP) emissions from source:
12.7
Controlled
Emissions
(Tons/year)
De Minim's
De Minims
De Minimit
De Miniris
23.2
39.2
12.7 -
7 Requested valueswill become permit limitations. Requested limit(s) should consider future process growth.
9
Benzene
Other:
71432
Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
rtable Pollutant Emissions Inventory_ -
m1ssion Factor ": Actual. Annual Emissions
I I Yes ❑ No
8.9 —
25:3
0.39 .. 41hp-hr 'Went Spec
0.00838
0.00044
AP42
INMMetu AP -42
Uncontrolled
Emissions
nds7 r
553
Controlled Emissions
Pliunds/year) ,...
04�
L1-3
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
COLOf ADO
5 iier
-:.^
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
s
Section 8 - Applicant Certification
i hereby certify that all information contained herein and information submitted with this application is complete, true
and correct. If this is a registration for coverage under general permit GP02, I further certify that this source is and will
be operated in full compliance with e condition of general permit GPOZ.
November28, 2017
rture of Legally Authorized Person (not a vendor or consultant) Date
Jacob Parker Environmental Professional
Name (please print)
Title
Check the appropriate box to request a copy of the:
Draft permit prior to issuance
I] Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, Ii.C. for revised APEN requirements.
Send this form along with $152.90 and the General Permit
registration fee of $1,500, if applicable to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
Telephone: (303) 692-3150
For more information or assistance call:
Small Business Assistance Program
(303) 692.3175 or (303) 692.3148
or visit the APCD website at:
https: //www.cotorado.gov/cdphe/apcd
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Rev ion 1/2017
6 arCOLORiAO
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