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Home My WebLink About20163518.tiffAir Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Whiting Oil and Gas Corporation — Razor 33 Central Production Battery — Weld County Notice Period Begins: November 10, 2016 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 33 Central Production Battery Central Production Battery SWSW, Section 18, T10N, R57W Weld County The proposed project or activity is as follows: Operator wishes to permit a central production battery. Thirty two storage tanks, eight separators, RICE, loadout and VRTs. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 15WE1260 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: Kirk Bear Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B 1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us Pu tiC Ro/iew it/o�I/icc cc •• PLc m \7/TP), HLce> ) PwCE_RtCH/ern/ctc) ttfIL /I( COLORADO 1AV =:= 2016-3518 COLORADO Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 November 8, 2016 Dear Sir or Madam: On November 10, 2016, the Air Pollution Control Division will begin a 30 -day public notice period for Whiting Oil and Gas Corporation — Razor 33 Central Production Battery. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health & Environment APCD-SS-B 1 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 STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 PERMIT NO: DATE ISSUED: ISSUED TO: CONSTRUCTION PERMIT 15WE1260 Whiting Oil and Gas Corporation Issuance 1 THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the Razor 33 Central Porduction Battery, located in SESW, Section 33, T10N, R58W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description ENG-01 002 One Caterpillar, G3516, JEF02800, natural gas -fired, turbo- charged, 4SLB reciprocating internal combustion engine, site rated at 1311 horsepower at 1400 RPM. This engine shall be equipped with an oxidation catalyst and air -fuel ratio control. This emission unit is used as a gas lift compressor. This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Caterpillar G3516 engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at https://www.colorado.clov/pacific/cdphe/other-air- permitting-notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify AIRS ID: 123-9E20-002 Page 1 of 14 Colorado Department of Public Health and Environment Air Pollution Control Division compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, 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 after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The following information shall be provided to the Division within fifteen (15) days of the latter of commencement of operation or issuance of this permit. • manufacture date • construction date • order date • date of relocation into Colorado • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type NO X VOC CO ENG-01 002 12.7 8.9 25.3 Point See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. AIRS ID: 123-9E20-002 Page 2 of 14 Colorado Department of Public Health and Environment Air Pollution Control Division Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 8. The owner or operator shall track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility emission limitations as seen below. An inventory of each insignificant activity and associated emission calculations shall be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities shall be defined as any activity or equipment, which emits any amount but does not require an Air Pollutant Emission Notice (APEN). Total emissions from the facility, including permitted emissions and insignificant activities, shall not exceed: • 100 tons per year of any criteria pollutant and/or • 10 tons per year of a single hazardous air pollutant and/or • 25 tons per year of total hazardous air pollutants (HAP). 9. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled ENG-01 002 Oxidation catalyst and air/fuel ratio controller VOC, CO, HAPS PROCESS LIMITATIONS AND RECORDS 10. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit ENG-01 002 Consumption of natural gas as a fuel 61.51 MMscf/yr AIRS ID: 123-9E20-002 Page 3 of 14 Colorado Department of Public Health and Environment Air Pollution Control Division Fuel consumption shall be measured by one of the following methods: individual engine fuel meter; facility -wide fuel meter attributed to fuel consumption rating and hours of operation; or manufacturer -provided fuel consumption rate. The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 11. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 12. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. & 4.) 13. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 14. This equipment is subject to the control requirements for natural gas -fired reciprocating internal combustion engines under Regulation No. 7, Section XVII.E (State only enforceable). The owner or operator of any natural gas -fired reciprocating internal combustion 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: Maximum' Engine HP Construction or Relocation Date Emission Standard in g/hp-hr NOx CO VOC <100HP Any N/A N/A N/A ≥100HP and <500HP January 1, 2008 January 1, 2011 2.0 1.0 4.0 2.0 1.0 0.7 ≥500HP July 1, 2007 July 1, 2010 2.0 1.0 4.0 2.0 1.0 0.7 Maximum engine horsepower is the nameplate rating of the engine and does not account for deration. OPERATING & MAINTENANCE REQUIREMENTS AIRS ID: 123-9E20-002 Page 4 of 14 Colorado Department of Public Health and Environment Air Pollution Control Division 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. A source initial compliance test shall be conducted on emissions point 123-9E20-002 to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emission limits in this permit. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time (Reference: Regulation No. 3, Part B., Section III.G.3) Oxides of Nitrogen using EPA approved methods. Carbon Monoxide using EPA approved methods. Periodic Testing Requirements 17. This engine is subject to the periodic testing requirements as specified in the operating and maintenance (O&M) plan as approved by the Division. Revisions to your O&M plan are subject to Division approval. Replacements of this unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b Whenever there is a change in the owner or operator of any facility, process, or activity; or AIRS ID: 123-9E20-002 Page 5 of 14 Colorado Department of Public Health and Environment Air Pollution Control Division c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine, the appropriate APEN filing fee and a cover letter explaining that the owner or operator is exercising an alternative -operating scenario and is installing a permanent replacement engine. 19. Federal regulatory program requirements (i.e. PSD or NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 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 No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 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 No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self - Certify for Final Authorization section of this permit. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This AIRS ID: 123-9E20-002 Page 6 of 14 Colorado Department of Public Health and Environment Air Pollution Control Division 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: Kirk Bear Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Whiting Oil and Gas Corporation AIRS ID: 123-9E20-002 Page 7 of 14 Colorado Department of Public Health and Environment Air Pollution Control Division Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-reps 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (Ib/yr) Reportable Controlled Emissions (lb/yr) 002 Formaldehyde 50000 9621 yes 2405 Acetaldehyde 75070 68Q yes 680 Acrolein 107028 420 yes 420 5) The emission levels contained in this permit are based on the following emission factors: Pollutant Emission Factors Uncontrolled g/bhp-hr Emission Factors Controlled g/bhp-hr NOx 1.00 1.00 CO 3.10 2.00 VOC 1.47 0.70 Emission factors are based on a Brake -Specific Fuel Consumption Factor of 7123 Btu/hp-hr, a site -rated horsepower value of 1311, and a fuel heat value of 1330 Btu/scf. Emission Factor Sources: Pollutant Uncontrolled EF Source Controlled EF Source NOx manufacturer NA CO manufacturer Whiting Oil and Gas Corporation VOC manufacturer Whiting Oil and Gas Corporation Formaldehyde manufacturer Whiting Oil and Gas Corporation Acetaldehyde AP -42 NA Acrolein AP -42 NA 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 AIRS ID: 123-9E20-002 Page 8 of 14 Colorado Department of Public Health and Environment Air Pollution Control Division associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This engine is subject to 40 CFR, Part 60, Subpart JJJJ-Standards of Performance for Stationary Spark Ignition Internal Combustibn Engines (See January 18, 2008 Federal Register posting — effective March 18, 2008). This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA website at: http://www.epa.gov/ttn/atw/area/fr18ia08.pdf 8) This engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January 18, 2008 Federal Register posting - effective March 18, 2008). The January 18, 2008 amendments to include requirements for. area sources and engines < 500 hp located at major sources have not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 8. A copy of the complete subpart is available on the EPA website at: http://www.epa.gov/ttn/atw/area/fr18ia08.pdf Additional information regarding area source standards can be found on the EPA website at: http://www.epa.qovittn/atw/area/arearules.html 9) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, HAPs PSD Synthetic Minor Source of: VOC, HAPs MACT ZZZZ Major Source Requirements: Not Applicable Area Source Requirements: Applicable 10) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A — Subpart KKKK NSPS Part 60, Appendixes Appendix A — Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A — Subpart Z MACT 63.600-63.1199 Subpart AA — Subpart DDD MACT 63.1200-63.1439 Subpart EEE — Subpart PPP MACT 63.1440-63.6175 Subpart QQQ — Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ — Subpart MMMMM MACT 63.8980 -End Subpart NNNNN — Subpart XX(XXX 11) A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification AIRS ID: 123-9E20-002 Page 9 of 14 Colorado Department of Public Health and Environment Air Pollution Control Division ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES October 12, 2012 2. Alternative Operating Scenarios The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility -Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS, and the owner or operator shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with a compressor engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month period. "Permanent" is defined as in the same service for more than 90 operating days in any 12 month period. The 90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90 day total. The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit. All replacement engines are subject to all federally applicable and state -only requirements set forth in this permit (including monitoring and record keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5) years and made available to the Division upon request. The owner or operator shall maintain a log on -site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make them available to the Division upon request. 2.1.1 The owner or operator may temporarily replace an existing compressor engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other requirements applicable to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. AIRS ID: 123-9E20-002 Page 10 of 14 Colorado Department of Public Health and Environment Air Pollution Control Division 2.1.2 The owner or operator may permanently replace the existing compressor engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found at http://www.cdphe.state.co.us/ap/oilgaspermitting.html. This submittal shall be accompanied by a certification from the Responsible Official indicating that "based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at: https://www.colorado.gov/pacific/sites/default/files/AP Portable-Analyzer-Monitoring-Protocol.pdf Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever applies. AIRS ID: 123-9E20-002 Page 11 of 14 Colorado Department of Public Health and Environment Air Pollution Control Division For comparison with a short-term limit that is either input based (Ib/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine will be subject to, the results of the test shall be converted to the appropriate units as described in the above -mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline. 2.3 Applicable Regulations for Permanent Engine Replacements 2.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B § II.D.2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and to NOX and SO2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr. For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating internal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOX: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (§ 60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State - Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified below: Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non- selective catalyst and air fuel controller to reduce emission. Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. AIRS ID: 123-9E20-002 Page 12 of 14 Colorado Department of Public Health and Environment Air Pollution Control Division The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. Emission Standards: Section XVII.E — State -only requirements Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Max Engine HP Construction or Relocation Date Emission Standards in G/hp-hr NO X CO VOC January 1, 2008 2.0 4.0 1.0 100<Hp<500 January 1, 2011 1.0 2.0 0.7 500<Hp July 1, 2007 July 1,2010 2.0 1.0 4.0 2.0 1.0 0.7 The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. 2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ requirements). However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, § 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. 2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting AIRS ID: 123-9E20-002 Page 13 of 14 Colorado Department of Public Health and Environment Air Pollution Control Division requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. 2.4 Additional Sources The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site; an engine that is being installed as an entirely new emission point and not as part of an AOS- approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. AIRS ID: 123-9E20-002 Page 14 of 14 PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Kirk. Bear 341892 12/14/2015 9/12/2016 Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: Type of Facility: What industry segment? Whit.€ng Oil and Gas Corporation 123 9E20 Razor 33 Central Production Ba SESW, Section 33, T10N, R58W'. [oration &:Production Oil & Natural Gas Product Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? ❑ Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application Particulate Matter (PM) ❑ Ozone (N AIRs Point # Emissions Source Type Emissions Control? Permit # Issuance # 002 15WE1260 Section 03 - Description of Project central production, battery to feed Red Tail Gas Plant Section 04 - Public Comment Requirments Is Public Comment Required? If yes, why?1 Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required?2 If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, explain what programs and which pollutants here: Prevention of Significant Deterioration (PSD): VOC: Title V Operating Permits (OP) : VOC, HAPs. Is this stationary source a major source? If yes, explain what programs and which pollutants here: Data for Drop Down Lists Facility Type List Exploration & Production Well Pad Natural Gas Compressor Station Natural Gas Processing Plant Produced Water Injection Facility Produced Water Management Facility Oil Stabilization (Exploration & Production) Oil Storage and Pipeline Injection Natural Gas Storage Other (Describe facility type in Section 03) Emission Point List Amine Sweetening Unit Condensate Storage Tank Crude Oil Storage Tank Diesel RICE EG Dehydrator Fugitive Component Leaks Hydrocarbon Liquid Loading Maintenance Blowdowns Natural Gas RICE Pneumatic Pump Process Flare Produced Water Storage Tank Produced Water Storage Pond Separator Venting TEG Dehydrator Turbine Vapor Recovery Tower (VRT) Boiler or Process Heater Other (Explain) Emissions Control List Enclosed Flare Leak Detection and Repair Program Non -Selective Catalytic Reduction (NSCR) Open Flare Oxidation Catalyst Thermal Oxidizer Vapor Recovery Unit to fuel system header Vapor Recovery Unit to plant inlet Permit Action Types APEN Exempt APEN Required / Permit Exempt Permit Initial Issuance Permit Modification Cancellation No Action Requested Facility Classifications N/A Major Synthetic Minor True Minor Qualifiers No Yes Public Comment Requesting Synthetic Minor Permit Greater than 25 tons per year in Non -Attainment Area Greater than 50 tons per year in an Attainment Area Alternative Control per Reg 7, Sec XII.D.2.b.(ii) Other (Divison Discretion) NAAQS Pollutants Carbon Monoxide (CO) Particulate Matter (PM) Ozone (NOx & VOC) Industry Segment Oil & Natural Gas Production & Processing Natural Gas Transmission & Storage ❑ Ozone (NOx & VOC) Self Cert Required? Action Engineering Remarks Division Information Engineer: Kirk Bear Control Engineer: Christopher Laplante Review Date: 09/12/2016 Application Date: 12/14/2015 Facility Identifiers Permit No. 15WE1260 AIRs County# 123 (Weld Facility # 9E20 Facility Type: exploration and production facility ❑ Located in the 8 -hour non -attainment area? Administrative Information Potentially located in ozone nonattainment area True Minor Synthetic Minor for: r voc Company Name: Whiting Oil and Gas Corporation Source Name: Razor 33 Central Production Battery Source Location: SESW, Section 33, T10N, R58W SIC: 1311 Mailing Address 1: Whiting Oil and Gas Corporation Address Address 2: 1700 Broadway, Suite 2300 ty, State Zip: Denver, Colorado 80290 Name: Chenine Wosniak Person To Phone: 303 802 8369 Contact Fax: 720 644 3636 Email: chenine.wosniak@whiting.com Requested Action Self Certification Required? Issuance Number: Yes 1 rNox rCO Source Description: Oil and gas exploration and production facility known as the Razor 33 Central Production Battery, located in the SESW, Section 33, T10N, R58W, Weld County, Colorado. Point Name Type Control Action 002 ENG-01 Engine Catalytic Oxidizer Newly reported source One Caterpillar, G3516, JEF02800, natural gas -tired, turbo -charged, 4SLB reciprocating internal 002 combustion engine, site rated at 1311 horsepower at 1400 RPM. This engine shall be equipped with an oxidation catalyst and air -fuel ratio control. This emission unit is used as a gas lift compressor. Engine Information Engine date of m 5/21/2014 Manufacturer: Caterpillar Model Number: G3516 Serial Number JEF02800 RPM: 1400 Site -rated RPM: 1400 Engine Function Compression berating Mfg's Max. Rated Horsepower @ sea level: - 1380 Horsepower used for calcuations: 1311 BSCF @ 100% Load (btu/hp-hr): 7123 Site - Rated BSCF @ 100% load (btu/hp-hr): 7123 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 7021.242857 scf/hr ACTUAL Annual Fuel Consumption 61.51 MMscf/yr MHA PU I tN I JAL Annual rue(. Consumption 61.506 MMscf/yr REQUESTED Annual Fuel Consumption 61.506 MMscf/yr Fuel Heating Value 1330 btu/scf Emission Control Information This engine shall be equipped with an oxidation catalyst and air -fuel ratio control. Emissions Summary Table Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source NOx 1,000 g/hp-hr 1.000 g/hp-hr 12.6 tpy 12.6 tpy Manufacturer CO 3.100 g/hp-hr 2.022 g/hp-hr 39.2 tpy 25.5 tpy Manufacturer VOC 1.470 g/hp-hr 0.706 g/hp-hr 18.6 tpy 8.9 tpy Manufacturer Formaldehyde 0.360 g/hp-hr 0.095 g/hp-hr 9096 lb/yr 2400 lb/yr AP -42 Acetaldehyde 0.008 glhp-hr 0.008 g/hp-hr 211 lb/yr 211 lb/yr AP -42 Acrolein 0.005 g/hp-hr 0.005 g/hp-hr 130 lb/yr 130 lb/yr AP -42 Benzene 0.000 g/hp-hr 0.000 g/hp-hr 11 lb/yr 11 lb/yr AP -42 requested and received permission from operator to change control percents in order to conform to Reg 7. Regulatory Requirements Ambient Air Imps Source is not required to model based.on Division Guidelines/No NAAQS violations expected (see details Public Comment Public Comment Required MACT 7777 Facility is an area source of HAPs, so engine is not subject to major source requirements. Engine is new Reg 7 XVII.E.2 Standards (g/hp- hr) The engine is subject to Reg 7 because max engine rating is greater than 100 hp, it was constructed after 11/1/2008 and it is not subject to MACT ZZZZ or NSPS JJJJ Reg 7 XVII.E.3 E.3 Reg 7 XVI.B (Ozone NM requirements) applies? Not located in NAA so not subject to Reg 7 XVI.B MACT 7777 (area source) Is this engine subject to MACT 7777 area source requirements? Yes NSPS JJJJ Is this engine subject to NSPS JJJJ? I No Note: JJJJ requirements are not currently included as permit conditions because the reg has not been 15W E1260.CP1.xlsm AIRS (County/Plant) 123/9E20 Permit No. 15WE1260 Date 9/12/2016 Point # SCC Pollutant or CAS Uncontrolled Emission Factor 002 20200254 VOC 1.47 g/hp-hr 002 20200254 NOx 1 g/hp-hr 002 20200254 CO 3.1 g/hp-hr 002 20200254 Benzene 0 g/hp-hr 002 20200254 Formaldehyde 0.36 g/hp-hr Emisison Factor Source Controlled Actual Emissions (tpy)* Controlled Requested Emissions (tpy)* PTE (tpy)* Ctrl. Eff% ` NCRP = reportable ? Manufacturer 8.9 18.6 52% Yes Manufacturer 12.6 12.6 0% Yes Manufacturer 25.5 39.2 35% Yes AP -42 11.1 11.1 0% No AP -42 2400.2 9095.6 74% Yes STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 15WE1261 DATE ISSUED: ISSUED TO: Whiting Oil and Gas Corporation Issuance 1 THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas exploration and production facility known as the Razor 33 Central Production Battery, located in the SESW, Section33, T10N, R58W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description PW-01 thru PW-14 003 Fourteen 400 barrel fixed roof storage vessels used to store produced water. Emission are controlled by a VRU operating with a gas gathering system. An open flare is an emergency back-up to these controls. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days after commencement of operation or issuance of this permit, whichever comes later, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, 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. (Reference: Regulation No. 3, Part B, 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 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 AIRS ID: 123 9E20 003 Page 1 of 11 Colorado Department of Public Health and Environment Air Pollution Control Division 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 NO X VOC CO PW-01 thru PW-14 003 -- 0.6 -- Point See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. 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 emission limitations as seen below. An inventory of each insignificant activity and associated emission calculations shall be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities shall be defined as any activity or equipment, which emits any amount but does not require an Air Pollutant Emission Notice (APEN). • 100 tons per year of any criteria pollutant and/or • 10 tons per year of a single hazardous air pollutant and/or • 25 tons per year of total hazardous air pollutants (HAP). 8. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) AIRS ID: 123 9E20 003 Page 2 of 11 Colorado Department of Public Health and Environment Air Pollution Control Division Facility Equipment ID AIRS Point Control Device Pollutants Controlled PW-01 thru PW-14 003 Open Flare at 95% control VOC, HAPs VRU at 93% operating time VOC, HAPs Gas Gathering at 95% collection time VOC, HAPs 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. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit PW-01 thru PW-14 003 Produced Water with VRU and gas gathering in operation 619,915 barrels Produced water with VRU or gas gathering system not operating 84,535 barrels Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 10. The owner or operator shall continuously monitor and record Vapor Recovery Unit (VRU) operation and downtime. The owner or operator shall continuously monitor and record Gas Gathering System (Redtail Gas Plant) operation and downtime. 11. The owner or operator must use monthly VRU and Gas Gathering System downtime records, monthly produced water throughput records, calculation methods detailed in the O&M Plan, and the emission factors established in the Notes to Permit Holder to demonstrate compliance with the process and emissions limits specified in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 12. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 13. 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 I I.A.1. & 4.) AIRS ID: 123 9E20 003 Page 3 of 11 Colorado Department of Public Health and Environment Air Pollution Control Division 14. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 15. The flare(s) covered by this permit is subject to Regulation No. 7, Section XVII.B General Provisions (State only enforceable). These requirements include, but are not limited to: XVII.B.2.b If a 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, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. XVII.B.2.d Auto -igniters: All combustion devices used to control emissions of hydrocarbons must be equipped with and operate an auto -igniter as follows: XVII.B.2.d.(i) All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device. XVII.B.2.d.(ii) 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 tanks covered by this permit are subject to Regulation 7, Section XVII.C emission control requirements. These requirements include, but are not limited to: Section XVII.C.1. Control and monitoring requirements for storage tanks XVII.C.1.b. Owners or operators of storage tanks with uncontrolled actual emissions of VOCs equal to or greater than six (6) tons per year based on a rolling twelve- month total must operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. XVII.C.1.b.(i)(a) Control requirements of Section XVII.C.1.b. must be achieved within ninety (90) days of the date that the storage tank commences operation. XVII.C.1.d. Beginning May 1, 2014, or the applicable compliance date in Section XVII.C.1.b.(i), whichever comes later, owners or operators of storage tanks subject to Section XVII.C.1. must conduct audio, visual, olfactory ("AVO") and additional visual inspections of the storage tank and any associated equipment (e.g. separator, air pollution control equipment, or other pressure reducing equipment) at the same frequency as liquids are loaded out from the storage tank. These inspections are not required more frequently than every seven (7) days but must be conducted at least every thirty one (31) days. Monitoring is not required for storage tanks or associated equipment that are unsafe, difficult, or inaccessible to monitor, as defined in Section XVII.C.1.e. The additional visual inspections must include, at a minimum: XVII.C.1.d.(i) Visual inspection of any thief hatch, pressure relief valve, or other access point to ensure that they are closed and properly sealed; AIRS ID: 123 9E20 003 Page 4 of 11 Colorado Department of Public Health and Environment Air Pollution Control Division XVII.C.1.d.(ii) Visual inspection or monitoring of the air pollution control equipment to ensure that it is operating, including that the pilot light is lit on combustion devices used as air pollution control equipment; XVII.C.1.d.(iii) If a combustion device is used, visual inspection of the auto -igniter and valves for piping of gas to the pilot light to ensure they are functioning properly; XVII.C.1.d.(iv) Visual inspection of the air pollution control equipment to ensure that the valves for the piping from the storage tank to the air pollution control equipment are open; and XVII.C.1.d.(v) If a combustion device is used, inspection of the device for the presence or absence of smoke. If smoke is observed, either the equipment must be immediately shut-in to investigate the potential cause for smoke and perform repairs, as necessary, or EPA Method 22 must be conducted to determine whether visible emissions are present for a period of at least one (1) minute in fifteen (15) minutes. XVII.C.1.e. If storage tanks or associated equipment is unsafe, difficult, or inaccessible to monitor, the owner or operator is not required to monitor such equipment until it becomes feasible to do so. XVII.C.2. Capture and monitoring requirements for storage tanks that are fitted with air pollution control equipment as required by Sections XII.D. or XVII.C.1. XVII.C.2.a. Owners or operators of storage tanks must route all hydrocarbon emissions to air pollution control equipment, and must operate without venting hydrocarbon emissions from the thief hatch (or other access point to the tank) or pressure relief device during normal operation, unless venting is reasonably required for maintenance, gauging, or safety of personnel and equipment. Compliance must be achieved in accordance with the schedule in Section XVII.C.2.b.(ii). XVII.C.2.b. Owners or operators of storage tanks subject to the control requirements of Sections XII.D.2., XVII.C.1.a, or XVII.C.1.b. must develop, certify, and implement a documented Storage Tank Emission Management System ("STEM") plan to identify, evaluate, and employ appropriate control technologies, monitoring practices, operational practices, and/or other strategies designed to meet the requirements set forth in Section XVII.C.2.a. Owners or operators must update the STEM plan as necessary to achieve or maintain compliance. Owners or operators are not required to develop and implement STEM for storage tanks containing only stabilized liquids. The minimum elements of STEM are listed below. XVII.C.2.b.(i) STEM must include selected control technologies, monitoring practices, operational practices, and/or other strategies; procedures for evaluating ongoing storage tank emission capture performance; and monitoring in accordance with approved instrument monitoring methods following the applicable schedule in Section XVII.C.2.b.(ii) and Inspection Frequency in Table 1. XVII.C.2.b.(ii) Owners or operators must achieve the requirements of Sections XVII.C.2.a. and XVII.C.2.b. and begin implementing the required AIRS ID: 123 9E20 003 Page 5 of 11 Colorado Department of Public Health and Environment Air Pollution Control Division approved instrument monitoring method in accordance with the following schedule: XVII.C.2.b.(ii)(a) A storage tank constructed on or after May 1, 2014, must comply with the requirements of Section XVII.C.2.a. by the date the storage tank commences operation. The storage tank must comply with Section XVII.C.2.b. and implement the approved instrument monitoring method inspections within ninety (90) days of the date that the storage tank commences operation. XVII.C.2.b.(ii)(d) Following the first approved instrument monitoring method inspection, owners or operators must continue conducting approved instrument monitoring method inspections in accordance with the Inspection Frequency in Table 1. Table 1 — Storage Tank Inspections Threshold: Storage Tank Uncontrolled Actual VOC Emissions (tpy) Approved Instrument Monitoring Method Inspection Frequency Phase -In Schedule > 6 and < 12 Annually January 1, 2016 > 12 and < 50 Quarterly July 1, 2015 > 50 Monthly January 1, 2015 XVII.C.2.b.(iii) Owners or operators are not required to monitor storage tanks and associated equipment that are unsafe, difficult, or inaccessible to monitor, as defined in Section XVII.C.1.e. XVII.C.2.b.(iv) STEM must include a certification by the owner or operator that the selected STEM strategy(ies) are designed to minimize emissions from storage tanks and associated equipment at the facility(ies), including thief hatches and pressure relief devices. XVII.C.3. Recordkeeping XVII.C.3. The owner or operator of each storage tank subject to Sections XII.D. or XVII.C. must maintain records of STEM, if applicable, including the plan, any updates, and the certification, and make them available to the Division upon request. In addition, for a period of two (2) years, the owner or operator must maintain records of any required monitoring and make them available to the Division upon request, including: XVII.C.3.a. The AIRS ID for the storage tank. XVII.C.3.b. The date and duration of any period where the thief hatch, pressure relief device, or other access point are found to be venting hydrocarbon emissions, except for venting that is reasonably required for maintenance, gauging, or safety of personnel and equipment. AIRS ID: 123 9E20 003 Page 6 of 11 Colorado Department of Public Health and Environment Air Pollution Control Division XVII.C.3.c. The date and duration of any period where the air pollution control equipment is not operating. XVII.C.3.d. Where a combustion device is being used, the date and result of any EPA Method 22 test or investigation pursuant to Section XVII.C.1.d.(v). XVII.C.3.e. The timing of and efforts made to eliminate venting, restore operation of air pollution control equipment, and mitigate visible emissions. XVII.C.3.f. A list of equipment associated with the storage tank that is designated as unsafe, difficult, or inaccessible to monitor, as described in Section XVII.C.1.e., an explanation stating why the equipment is so designated, and the plan for monitoring such equipment. OPERATING & MAINTENANCE REQUIREMENTS 17. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 18. The owner or operator shall demonstrate compliance with opacity standards, using EPA Method 22 to measure opacity from the flare. (Reference: Regulation No. 1, Section II.A.1 & 4) ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or AIRS ID: 123 9E20 003 Page 7 of 11 Colorado Department of Public Health and Environment Air Pollution Control Division e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine, the appropriate APEN filing fee and a cover letter explaining that the owner or operator is exercising an alternative -operating scenario and is installing a permanent replacement engine. 20. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). 21. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities major stationary source requirements shall apply to this stationary source at any such time that this stationary source becomes major solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of Subpart HH. (Reference: Regulation No. 8, Part E) GENERAL TERMS AND CONDITIONS 22. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 23. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self - Certify for Final Authorization section of this permit. 24. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 25. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. AIRS ID: 123 9E20 003 Page 8 of 11 Colorado Department of Public Health and Environment Air Pollution Control Division 26. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 27. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 28. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Kirk Bear Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Whiting Oil and Gas Corporation AIRS ID: 123 9E20 003 Page 9 of 11 Colorado Department of Public Health and Environment Air Pollution Control Division Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: http://www.colorado.gov/cs/Satellite?c=Document C&childpagename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641 &pagename=CBONWrapper 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Reportable Controlled Emissions (lb/yr) 003 Benzene 71432 4931 Yes 29 n -Hexane 110543 15498 Yes 90 5) The emission levels contained in this permit are based on the following emission factors: Pollutant Emission Factors Uncontrolled lb/bbl Produced Water Throughput Source VOC 0.262 CDPHE n -Hexane 0.022 CDPHE Benzene 0.007 CDPHE Note: The controlled emissions for this point are based on the flare control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, HAPs AIRS ID: 123 9E20 003 Page 10 of 11 Colorado Department of Public Health and Environment Air Pollution Control Division PSD Synthetic Minor Source of: VOC, HAPs MACT HH 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 9) A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification AIRS ID: 123 9E20 003 Page 11 of 11 PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Kirk Bear 341892 12/14/2015 9/12/2016 Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: Type of Facility: What industry segment? Is this facility located in a NAAQS n If yes, for what pollutant? Whiting Oll and Gas Corporation 123 9E20 Razor 33 Central Production Battery SESW, Section 33, T1}N, R58W on -attainment area? Cl Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application Particulate Matter (PM) O Ozone (N AIRs Point # Emissions Source Type Emissions Control? Permit # Issuance # 003 15WE1261, Section 03 - Description of Project produced water backed up with a flare as gathering or VRU is not in operation. Section 04 - Public Comment Requirments Is Public Comment Required? If yes, why?1 Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required?2 If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, explain what programs and which pollutants here: Prevention of Significant Deterioration (PSD): SO2, NOx, CO, VOC, PM2.5, PM10 Title V Operating Permits (OP) : SO2, NOx, CO, VOC, PM2.5, PM10, TSP, HAPs Non -Attainment New Source Review (NANSR): NOx, VOC Is this stationary source a major source? If yes, explain what programs and which pollutants here: Prevention of Significant Deterioration (PSD): 5O2, NOx, CO,, VOC PM2.5, PM10 Title V Operating Permits, (OP) :,SO2, NOx, CO, VOC, PM2.5, PM10, TSP, HAPs Non -Attainment New Source Review (NANSR): NOx, VOC Data for Drop Down Lists Facility Type List Exploration & Production Well Pad Natural Gas Compressor Station Natural Gas Processing Plant Produced Water Injection Facility Produced Water Management Facility Oil Stabilization (Exploration & Production) Oil Storage and Pipeline Injection Natural Gas Storage Other (Describe facility type in Section 03) Emission Point List Amine Sweetening Unit Condensate Storage Tank Crude Oil Storage Tank Diesel RICE EG Dehydrator Fugitive Component Leaks Hydrocarbon Liquid Loading Maintenance Blowdowns Natural Gas RICE Pneumatic Pump Process Flare Produced Water Storage Tank Produced Water Storage Pond Separator Venting TEG Dehydrator Turbine Vapor Recovery Tower (VRT) Boiler or Process Heater Other (Explain) Emissions Control List Enclosed Flare Leak Detection and Repair Program Non -Selective Catalytic Reduction (NSCR) Open Flare Oxidation Catalyst Thermal Oxidizer Vapor Recovery Unit to fuel system header Vapor Recovery Unit to plant inlet Permit Action Types APEN Exempt APEN Required / Permit Exempt Permit Initial Issuance Permit Modification Cancellation No Action Requested Facility Classifications N/A Major Synthetic Minor True Minor Qualifiers No Yes Public Comment Requesting Synthetic Minor Permit Greater than 25 tons per year in Non -Attainment Area Greater than 50 tons per year in an Attainment Area Alternative Control per Reg 7, Sec XII.D.2.b.(ii) Other (Divison Discretion) NAAQS Pollutants Carbon Monoxide (CO) Particulate Matter (PM) Ozone (NOx & VOC) Industry Segment Oil & Natural Gas Production & Processing Natural Gas Transmission & Storage ❑ Ozone (NOx & VOC) Self Cert Required? Engineering Remarks Division Information Engineer: Kirk Bear Control Engineer: Stephanie Spector Review Date: 09/21/2016 Application Date: 03/25/2016 Facility Identifiers Permit No. 15WE1261 AIRs County# 123 'Weld Facility # 9E20 Facility Type: exploration and production facility ❑ Located in the 8 -hour non -attainment area? Administrative Information Potentially located in ozone nonattainment area True Minor Synthetic Minor for: VOC r NOx r CO Company Name: Whiting Oil and Gas Corporation Source Name: Razor 33 Central Production Battery Source Location: SESW, Section33, T10N, R58W SIC: 1311 Address 1: Whiting Oil and Gas Corporation Mailing Address Address 2: 1700 Broadway, Suite 2300 ty, State Zip: Denver, Colorado 80290 Name: Chenine Wosniak Person To Phone: 303 802 8369 Contact Fax: 720 644 3636 Email: cdphecorrespondence@whiting.com 'Requested Action Self Certification Required? Issuance Number: Yes 1 Source Description: Oil and gas exploration and production facility known as the Razor 33 Central Production Battery, located in the SESW, Section33, T10N, R58W, Weld County, Colorado. Point Name Type Control Action 003 PW-01 thru PW-14 Water Tanks Flare Newly reported source 003 Fourteen 400 barrel fixed roof storage vessels used to store produced water Emissions Calculations Requsted Throughput 704450 bbl Control Flare Efficiency 95.00% Emissions Summary Table emission are collected by a VRU which vents. emissions 7% of the time. Gathering sysytem douwntime is 5%. 100% control efficiency Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 0.262 lb/bbl 92.28 tpy 4.61 tpy CDPHE Benzene 0.007 lb/bbl 4931 lb/yr 247 lb/yr CDPHE n -Hexane 0.022 lb/bbl 15498 lb/yr 775 lb/yr CDPHE Regulatory Review Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section II. A and B of this regulation. Section II.A.5 - Smokeless Flare or Flares for the Combustion of Waste Gases 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 for a period or periods aggregating more than six minutes in any sixty consecutive minutes. Regulation 2'— Odor Section I.A - 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. STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 PERMIT NO: DATE ISSUED: ISSUED TO: CONSTRUCTION PERMIT 15WE1262 Whiting Oil and Gas Corporation Issuance 1 THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas exploration and production facility known as the Razor 33 Central Production Facility, located in the SESW, Section33, T10N, R58W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description LOAD -01 004 Hydrocarbon Loadout to Tanker Trucks. Emissions are controlled by a VRU operating with a gas gathering system. An emergency open flare is a back-up to these controls when they are not operating. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days after commencement of operation or issuance of this permit, whichever comes later, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, 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. (Reference: Regulation No. 3, Part B, 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 after either, the date of issuance of this construction permit or the date AIRS ID: 123 9E20 004 Page 1 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division 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 (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type NO, VOC CO LOAD -01 004 0.0 0.1 0.0 Point See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 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 emission limitations as seen below. An inventory of each insignificant activity and associated emission calculations shall be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities shall be defined as any activity or equipment, which emits any amount but does not require an Air Pollutant Emission Notice (APEN). Total emissions from the facility, including permitted emissions and insignificant activities, shall not exceed: • 100 tons per year of any criteria pollutant and/or • 10 tons per year of a single hazardous air pollutant and/or AIRS ID: 123 9E20 004 Page 2 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division • 25 tons per year of total hazardous air pollutants (HAP). 8. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled LOAD -01 004 Emergency Open Flare at 95% control VOC, HAPs VRU at 93% operating time VOC, HAPs Gas Gathering at 95% collection time VOC, HAPs 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. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit LOAD -01 004 Oil with VRU and gas gathering in operation 89,936 barrels Oil with VRU or gas gathering system not operating 12,264 barrels Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 10. The owner or operator shall continuously monitor and record Vapor Recovery Unit (VRU) operation and downtime. The owner or operator shall continuously monitor and record Gas Gathering System (Redtail Gas Plant) operation and downtime. 11. The owner or operator must use monthly VRU and Gas Gathering System downtime records, monthly produced water throughput records, calculation methods detailed in the O&M Plan, and the emission factors established in the Notes to Permit Holder to demonstrate compliance with the process and emissions limits specified in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 12. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 13. 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 AIRS ID: 123 9E20 004 Page 3 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division 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 I I.A.1. & 4.) 14. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 15. The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.E): a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. b. All compartment hatches (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. The owner or operator shall inspect loading equipment and operations on site at the time of the inspection to ensure compliance with the conditions (a) and (b) above. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. 16. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. OPERATING & MAINTENANCE REQUIREMENTS 17. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 18. The owner or operator shall demonstrate compliance with opacity standards, using EPA Method 22 to measure opacity from the flare. (Reference: Regulation No. 1, Section II.A.1 & 4) ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or AIRS ID: 123 9E20 004 Page 4 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 20. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). 21. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities major stationary source requirements shall apply to this stationary source at any such time that this stationary source becomes major solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of Subpart HH. (Reference: Regulation No. 8, Part E) GENERAL TERMS AND CONDITIONS 22. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 23. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self - Certify for Final Authorization section of this permit. 24. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information AIRS ID: 123 9E20 004 Page 5 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 25. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 26. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 27. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 28. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Kirk Bear Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Whiting Oil and Gas Corporation AIRS ID: 123 9E20 004 Page 6 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: http://www.colorado.gov/cs/Satellite?c=Document C&childpaaename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper 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) Reportable Controlled Emissions (Ib/yr) 004 Benzene 71432 23 No 1 n -Hexane 110543 304 Yes 2 5) The emission levels contained in this permit are based on the following emission factors: Pollutant Emission Factors Uncontrolled lb/bbl loaded - Source VOC 0.0691 AP -42 Benzene 0.0002 AP -42 n -Hexane 0.0030 AP -42 The uncontrolled VOC emission factor was calculated using AP -42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L = 12.46" S*P*M/ T S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 2.03 psia M (vapor molecular weight) = 54.95 Ib/Ib-mol T (temperature of liquid loaded) = 508 °R 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 AIRS ID: 123 9E20 004 Page 7 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, HAPs PSD Synthetic Minor Source of: VOC, HAPs MACT HH 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.groaccess.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 9) A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification AIRS ID: 123 9E20 004 Page 8 of 8 PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Kirk Bear 341892 12/14/2015 9/12/20.16;: Company Name: Whiting Oil and Gas Corporation County AIRS ID: 123 Plant AIRS ID: 9E20 Facility Name: Razor 33 Central Production Battery Physical Address/Location: SESW, Section 33,-T10N, R58W Type of Facility: What industry segment? Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? ❑ Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application Particulate Matter (PM) ❑ Ozone (N AIRs Point # Emissions Source Type Emissions Control? Permit # Issuance # 004 15WE1262 Section 03 - Description of Project Section 04 - Public Comment Requirments Is Public Comment Required? If yes, why?1 Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required?2 If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, explain what programs and which pollutants here: Prevention of Significant Deterioration (PSD): S02, NOx, CO,. VOC,PM2.5, PM 10 Title V Operating Permits (OP) : SO2, NOx, CO, VOC, PM 5, PM10, TSP, HAPs Non -Attainment New Source. Review (NANSR): NOx, V Is this stationary source a major source? If yes, explain what programs and which pollutants here: Prevention of Significant Deterioration (PSD): SO2, NOx,..CO V©C,.PM2.5, PM10 .: Title V Operating Permits (OP) : SO2, NOx, CO, VOC, PM 2.5, PM10, TSP, HAPs Non Attainment New Source Review (NANSR): NOx, VOC Data for Drop Down Lists Facility Type List Exploration & Production Well Pad Natural Gas Compressor Station Natural Gas Processing Plant Produced Water Injection Facility Produced Water Management Facility Oil Stabilization (Exploration & Production) Oil Storage and Pipeline Injection Natural Gas Storage Other (Describe facility type in Section 03) Emission Point List Amine Sweetening Unit Condensate Storage Tank Crude Oil Storage Tank Diesel RICE EG Dehydrator Fugitive Component Leaks Hydrocarbon Liquid Loading Maintenance Blowdowns Natural Gas RICE Pneumatic Pump Process Flare Produced Water Storage Tank Produced Water Storage Pond Separator Venting TEG Dehydrator Turbine Vapor Recovery Tower (VRT) Boiler or Process Heater Other (Explain) Emissions Control List Enclosed Flare Leak Detection and Repair Program Non -Selective Catalytic Reduction (NSCR) Open Flare Oxidation Catalyst Thermal Oxidizer Vapor Recovery Unit to fuel system header Vapor Recovery Unit to plant inlet Permit Action Types APEN Exempt APEN Required / Permit Exempt Permit Initial Issuance Permit Modification Cancellation No Action Requested Facility Classifications N/A Major Synthetic Minor True Minor Qualifiers No Yes Public Comment Requesting Synthetic Minor Permit Greater than 25 tons per year in Non -Attainment Area Greater than 50 tons per year in an Attainment Area Alternative Control per Reg 7, Sec XII.D.2.b.(ii) Other (Divison Discretion) NAAQS Pollutants Carbon Monoxide (CO) Particulate Matter (PM) Ozone (NOx & VOC) Industry Segment Oil & Natural Gas Production & Processing Natural Gas Transmission & Storage ❑ Ozone (NOx & VOC) Self Cert Required? Action Engineering Remarks Division Information Engineer: Kirk Bear Control Engineer: Stephanie Spector Review Date: 09/19/2016 Application Date: 03/23/2016 Facility Identifiers Permit No. 15WE1262 AIRs County# 123 'Weld Facility # 9E20 Facility Type: exploration and production facility ❑ Located in the 8 -hour non -attainment area? Administrative Information Potentially located in ozone nonattainment area 0 True Minor 0 Synthetic Minor for: r VOC Company Name: Whiting Oil and Gas Corporation Source Name: Razor 33 Central Production Facility Source Location: SESW, Section33, T10N, R58W SIC: 1311 Address 1: Whiting Oil and Gas Corporation Mailing Address Address 2: 1700 Broadway, Suite 2300 ty, State Zip: Denver, Colorado 80290 Name: Chenine Wosniak Person To Phone: 303 802 8369 Contact Fax: 720 644 3636 Email: CDPHECorrespondence@whiting.com Requested Action Self Certification Required? Issuance Number: Yes 1 r NOx r CO Source Description: Oil and gas exploration and production facility known as the Razor 33 Central Production Facility, located in the SESW, Section33, T1 ON, R58W, Weld County, Colorado. Point Name Type Control Action 004 LOAD -01 Loadout Flare I Newly reported source 004 Hydrocarbon Loadout to Tanker Trucks Calculations L = 12.46*S*P*M/T (AP -42: Chapter 5.2, Equation 1) L = loading losses in lb per 1000 gallons loaded Factor Meaning Value Units Source S Saturation Factor 0.6 AP -42 P True Vapor Pressure 2.03 psia HYSIS M Molecular Weight of Vap 54.95 lb/lb-mole TANKS T Liquid Temperature 507 deg. R Field Data L Annual requested Throughput Annual requested VOC emissions Control: Flare Efficiency: 99.42% NCRPs Component Mass Fraction 1.64 lb/1000 gal 0.07 lb/bbl Benzene 0.0033 n -hexane 0.0430' Toluene 0.0020' Xylenes 0.0020 Source: 102200 bbl/yr 4292400 gal/yr 7060 lb/yr 3.53 tpy emission are collected by a VRU which vents emissions 7% of the time. Gathering sysytem douwntime is 5%. 100% control efficiency. Pressurized oil sample input into HYSIS and TANKS Emissions Summary Table Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 0.0691 lb/bbl 3.5 tpy 0.0 tpy AP -42 Benzene 0.0002 lb/bbl 23 lb/yr 0 lb/yr AP -42 n -Hexane 0.0030 lb/bbl 304 lb/yr 2 lb/yr AP -42 Toluene 0.0001 lb/bbl 14 lb/yr 0 lb/yr AP -42 Xylenes 0.0001 lb/bbl 14 lb/yr 0 lb/yr AP -42 Regulatory Review Regulation 3 !- APEN! and Permitting Requirements Is this site considered an exploration and production location (e.g. well pad)? If yes, review the following two exemptions for applicability: Does the operator unload less than 10,000 gallons (238 BBLs) per day of crude oil on an annual average basis? If yes, this emissions point is categorically exempt from permit requirements per Regulation 3, Part B, Section II.D.1.1 Does this operator unload less than 6,750 bbls per year of condensate via splash fill or 16,308 bbls per year of condensate via submerged fill procedure? No If yes, this emissions point is categorically exempt from permit requirements per Regulation 3, Part B, Section II.D.1.1 Yes No STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: DATE ISSUED: ISSUED TO: 15WE1263 Whiting Oil and Gas Corporation Issuance 1 THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas exploration and production facility known as the Razor 33 Central Production Facility, located in the SESW, Section33, T1 ON, R58W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description TK-01 thru TK-18 005 Eighteen 400 barrel crude oil storage tanks. Emissions are controlled by a VRU operating with a gas gathering system. An emergency open flare is a back-up to these controls when they are not operating. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days after commencement of operation or issuance of this permit, whichever comes later, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, 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. (Reference: Regulation No. 3, Part B, 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 AIRS ID: 123 9E20 005 Page 1 of 11 Colorado Department of Public Health and Environment Air Pollution Control Division 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 (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type NO X VOC CO TK-01 thru TK- 18 005 0.1 0.6 0.1 Point See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Include individual HAP limit if facility is syn minor for HAPs and permitted limit is under 8.0 tpy. Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. Include total HAP limit if facility is syn minor for HAPs and permitted limit is under 20.0 tpy. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 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 emission limitations as seen below. An inventory of each insignificant activity and associated emission calculations shall be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities shall be defined as any activity or AIRS ID: 123 9E20 005 Page 2 of 11 Colorado Department of Public Health and Environment Air Pollution Control Division equipment, which emits any amount but does not require an Air Pollutant Emission Notice (APEN). Total emissions from the facility, including permitted emissions and insignificant activities, shall not exceed: • 100 tons per year of any criteria pollutant and/or • 10 tons per year of a single hazardous air pollutant and/or • 25 tons per year of total hazardous air pollutants (HAP). 8. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled TK-01 thru TK-18 004 Emergency Open Flare at 95% control VOC, HAPs VRU at 93% operating time VOC, HAPs Gas Gathering at 95% collection time VOC, HAPs 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. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit TK-01 thru TK- 18 005 Oil with VRU and gas gathering in operation 899,360 barrels Oil with VRU or gas gathering system not operating 122,640 barrels Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 10. The owner or operator shall continuously monitor and record Vapor Recovery Unit (VRU) operation and downtime. The owner or operator shall continuously monitor and record Gas Gathering System (Redtail Gas Plant) operation and downtime. 11. The owner or operator must use monthly VRU and Gas Gathering System downtime records, monthly produced water throughput records, calculation methods detailed in the O&M Plan, and the emission factors established in the Notes to Permit Holder to demonstrate compliance with the process and emissions limits specified in this permit. AIRS ID: 123 9E20 005 Page 3 of 11 Colorado Department of Public Health and Environment Air Pollution Control Division STATE AND FEDERAL REGULATORY REQUIREMENTS 12. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 13. 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 I I.A.1. & 4.) 14. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 15. Point 005: The flare(s) covered by this permit is subject to Regulation No. 7, Section XVII.B General Provisions (State only enforceable). These requirements include, but are not limited to: XVII.B.2.b If a 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, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. XVII.B.2.d Auto -igniters: All combustion devices used to control emissions of hydrocarbons must be equipped with and operate an auto -igniter as follows: XVII.B.2.d.(i) All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device. XVII.B.2.d.(ii) 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 tanks covered by this permit are subject to Regulation 7, Section XVII.C emission control requirements. These requirements include, but are not limited to: Section XVII.C.1. Control and monitoring requirements for storage tanks XVII.C.1.b. Owners or operators of storage tanks with uncontrolled actual emissions of VOCs equal to or greater than six (6) tons per year based on a rolling twelve- month total must operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. XVII.C.1.b.(i)(a) Control requirements of Section XVII.C.1.b. must be achieved within ninety (90) days of the date that the storage tank commences operation. XVII.C.1.d. Beginning May 1, 2014, or the applicable compliance date in Section XVII.C.1.b.(i), whichever comes later, owners or operators of storage tanks subject to Section XVII.C.1. must conduct audio, visual, olfactory ("AVO") and additional visual inspections of the storage tank and any associated equipment (e.g. separator, air pollution control equipment, or other pressure reducing AIRS ID: 123 9E20 005 Page 4 of 11 Colorado Department of Public Health and Environment Air Pollution Control Division equipment) at the same frequency as liquids are loaded out from the storage tank. These inspections are not required more frequently than every seven (7) days but must be conducted at least every thirty one (31) days. Monitoring is not required for storage tanks or associated equipment that are unsafe, difficult, or inaccessible to monitor, as defined in Section XVII.C.1.e. The additional visual inspections must include, at a minimum: XVII.C.1.d.(i) Visual inspection of any thief hatch, pressure relief valve, or other access point to ensure that they are closed and properly sealed; XVII.C.1.d.(ii) Visual inspection or monitoring of the air pollution control equipment to ensure that it is operating, including that the pilot light is lit on combustion devices used as air pollution control equipment; XVII.C.1.d.(iii) If a combustion device is used, visual inspection of the auto -igniter and valves for piping of gas to the pilot light to ensure they are functioning properly; XVII.C.1.d.(iv) Visual inspection of the air pollution control equipment to ensure that the valves for the piping from the storage tank to the air pollution control equipment are open; and XVII.C.1.d.(v) If a combustion device is used, inspection of the device for the presence or absence of smoke. If smoke is observed, either the equipment must be immediately shut-in to investigate the potential cause for smoke and perform repairs, as necessary, or EPA Method 22 must be conducted to determine whether visible emissions are present for a period of at least one (1) minute in fifteen (15) minutes. XVII.C.1.e. If storage tanks or associated equipment is unsafe, difficult, or inaccessible to monitor, the owner or operator is not required to monitor such equipment until it becomes feasible to do so. XVII.C.2. Capture and monitoring requirements for storage tanks that are fitted with air pollution control equipment as required by Sections XII.D. or XVII.C.1 XVII.C.2.a. Owners or operators of storage tanks must route all hydrocarbon emissions to air pollution control equipment, and must operate without venting hydrocarbon emissions from the thief hatch (or other access point to the tank) or pressure relief device during normal operation, unless venting is reasonably required for maintenance, gauging, or safety of personnel and equipment. Compliance must be achieved in accordance with the schedule in Section XVII.C.2.b.(ii). XVII.C.2.b. Owners or operators of storage tanks subject to the control requirements of Sections XII.D.2., XVII.C.1.a, or XVII.C.1.b. must develop, certify, and implement a documented Storage Tank Emission Management System ("STEM") plan to identify, evaluate, and employ appropriate control technologies, monitoring practices, operational practices, and/or other strategies designed to meet the requirements set forth in Section XVII.C.2.a. Owners or operators must update the STEM plan as necessary to achieve or maintain compliance. Owners or operators are not required to develop and implement STEM for storage tanks containing only stabilized liquids. The minimum elements of STEM are listed below. AIRS ID: 123 9E20 005 Page 5 of 11 Colorado Department of Public Health and Environment Air Pollution Control Division XVII.C.2.b.(i) STEM must include selected control technologies, monitoring practices, operational practices, and/or other strategies; procedures for evaluating ongoing storage tank emission capture performance; and monitoring in accordance with approved instrument monitoring methods following the applicable schedule in Section XVII.C.2.b.(ii) and Inspection Frequency in Table 1. XVII.C.2.b.(ii) Owners or operators must achieve the requirements of Sections XVII.C.2.a. and XVII.C.2.b. and begin implementing the required approved instrument monitoring method in accordance with the following schedule: XVII.C.2.b.(ii)(a) A storage tank constructed on or after May 1, 2014, must comply with the requirements of Section XVII.C.2.a. by the date the storage tank commences operation. The storage tank must comply with Section XVII.C.2.b. and implement the approved instrument monitoring method inspections within ninety (90) days of the date that the storage tank commences operation. XVII.C.2.b.(ii)(d) Following the first approved instrument monitoring method inspection, owners or operators must continue conducting approved instrument monitoring method inspections in accordance with the Inspection Frequency in Table 1. Table 1 — Storage Tank Inspections Threshold: Storage Tank Uncontrolled Actual VOC Emissions (tpy) Approved Instrument Monitoring Method Inspection Frequency Phase -In Schedule > 6 and < 12 Annually January 1, 2016 > 12 and < 50 Quarterly July 1, 2015 > 50 Monthly January 1, 2015 XVII.C.2.b.(iii) Owners or operators are not required to monitor storage tanks and associated equipment that are unsafe, difficult, or inaccessible to monitor, as defined in Section XVII.C.1.e. XVII.C.2.b.(iv) STEM must include a certification by the owner or operator that the selected STEM strategy(ies) are designed to minimize emissions from storage tanks and associated equipment at the facility(ies), including thief hatches and pressure relief devices. XVII.C.3. Recordkeeping XVII.C.3. The owner or operator of each storage tank subject to Sections XII.D. or XVII.C. must maintain records of STEM, if applicable, including the plan, any updates, and the certification, and make them available to the Division upon request. In addition, for a period of two (2) years, the owner or operator must AIRS ID: 123 9E20 005 Page 6 of 11 Colorado Department of Public Health and Environment Air Pollution Control Division maintain records of any required monitoring and make them available to the Division upon request, including: XVII.C.3.a. The AIRS ID for the storage tank. XVII.C.3.b. The date and duration of any period where the thief hatch, pressure relief device, or other access point are found to be venting hydrocarbon emissions, except for venting that is reasonably required for maintenance, gauging, or safety of personnel and equipment. XVII.C.3.c. The date and duration of any period where the air pollution control equipment is not operating. XVII.C.3.d. Where a combustion device is being used, the date and result of any EPA Method 22 test or investigation pursuant to Section XVII.C.1.d.(v). XVII.C.3.e. The timing of and efforts made to eliminate venting, restore operation of air pollution control equipment, and mitigate visible emissions. XVII.C.3.f. A list of equipment associated with the storage tank that is designated as unsafe, difficult, or inaccessible to monitor, as described in Section XVII.C.1.e., an explanation stating why the equipment is so designated, and the plan for monitoring such equipment. OPERATING & MAINTENANCE REQUIREMENTS 17. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 18. The owner or operator shall demonstrate compliance with opacity standards, using EPA Method 22 to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one (1) minute in any fifteen (15) minute period during normal operation. (Reference: Regulation No. 7, Section XVII.A.II) ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or AIRS ID: 123 9E20 005 Page 7 of 11 Colorado Department of Public Health and Environment Air Pollution Control Division For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 20. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). 21. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities major stationary source requirements shall apply to this stationary source at any such time that this stationary source becomes major solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of Subpart HH. (Reference: Regulation No. 8, Part E) GENERAL TERMS AND CONDITIONS 22. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 23. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self - Certify for Final Authorization section of this permit. 24. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. AIRS ID: 123 9E20 005 Page 8 of 11 Colorado Department of Public Health and Environment Air Pollution Control Division 25. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 26. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 27. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 28. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Kirk Bear Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Whiting Oil and Gas Corporation AIRS ID: 123 9E20 005 Page 9 of 11 Colorado Department of Public Health and Environment Air Pollution Control Division Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An_ invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: http://www.colorado.00v/cs/Satellite?c=Document C&childpagename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641 &pagename=CBONWrapper 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emission Rate (lb/yr) Are the emissions reportable? Controlled Emission Rate (lb/yr) 005 Benzene 71432 1226 Yes 7 n -Hexane 110543 10629 Yes 62 Toluene 108883 818 Yes 5 Xylenes 1330207 204 No 1 Ethyl Benzene 100414 102 No 1 224 TMP 540841 920 Yes 5 5) The emission levels contained in this permit are based on the following emission factors: Pollutant Emission Factors Uncontrolled lb/bbl Oil Throughput Source NOx 0.068 AP -42 CO 0.310 AP -42 VOC 0.1970 HYSIS/TANKS n -Hexane 0.0104 HYSIS/TANKS Benzene 0.0012 HYSIS/TANKS Toluene 0.0008 HYSIS/TANKS Ethylbenzene 0.0001 HYSIS/TANKS Xylenes 0.0002 HYSIS/TANKS 224 TMP 0.0009 HYSIS/TANKS AIRS ID: 123 9E20 005 Page 10 of 11 Colorado Department of Public Health and Environment Air Pollution Control Division 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, HAPs PSD Synthetic Minor Source of: VOC, HAPs MACT HH 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 9) A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at: http://www.colorado.dov/pacific/cdphe/air-permit-self-certification AIRS ID: 123 9E20 005 Page 11 of 11 PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01 - Facility Information Kirk Bear 341892 12/14/2015 9/12/2016 - Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: Type of Facility: What industry segment? Is this facility located in a NAAQS If yes, for what pollutant? Whiting Oil and Gas Corporation 123 9E20 Razor 33 Central Production Battery SESW, Section 33, T1ON, R58W Exploration & Production Well Pad:.. Oi tura as Production & Prot; non -attainment area? ❑ Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application Particulate Matter (PM) ❑ Ozone (N AIRs Point # Emissions Source Type Emissions Control? Permit # Issuance # 005 Section 03 - Description of Project 15WE1263 Section 04 - Public Comment Requirments Is Public Comment Required? If yes, why?1 Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required?2 If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, explain what programs and which pollutants here:_ Prevention of Significant Deterioration (PSD): 5O2, NOx, CO, VOC, PM2.5, PM I-0 Title V Operating Permits (OP) : SO2, NOx, CO, VOC, PM2.5, PM10,TSP, HAPs. Non -Attainment New Source Review (NANSR): NOx, VOC Is this stationary source a major source? If yes, explain what programs and which pollutants here: Prevention of ti i t t De terioration (PSD): SO2, NOx, CO, VOC, PI1f2.5, PM TiitleV Operating Permits (OP) : SO2, NOx, CO, VOC, P 2.5, PM10,TSP, HAPs on -Attainment New Source Review (NANSR): NOx, VOC ". Data for Drop Down Lists Facility Type List Exploration & Production Well Pad Natural Gas Compressor Station Natural Gas Processing Plant Produced Water Injection Facility Produced Water Management Facility Oil Stabilization (Exploration & Production) Oil Storage and Pipeline Injection Natural Gas Storage Other (Describe facility type in Section 03) Emission Point List Amine Sweetening Unit Condensate Storage Tank Crude Oil Storage Tank Diesel RICE EG Dehydrator Fugitive Component Leaks Hydrocarbon Liquid Loading Maintenance Blowdowns Natural Gas RICE Pneumatic Pump Process Flare Produced Water Storage Tank Produced Water Storage Pond Separator Venting TEG Dehydrator Turbine Vapor Recovery Tower (VRT) Boiler or Process Heater Other (Explain) Emissions Control List Enclosed Flare Leak Detection and Repair Program Non -Selective Catalytic Reduction (NSCR) Open Flare Oxidation Catalyst Thermal Oxidizer Vapor Recovery Unit to fuel system header Vapor Recovery Unit to plant inlet Permit Action Types APEN Exempt APEN Required / Permit Exempt Permit Initial Issuance Permit Modification Cancellation No Action Requested Facility Classifications N/A Major Synthetic Minor True Minor Qualifiers No Yes Public Comment Requesting Synthetic Minor Permit Greater than 25 tons per year in Non -Attainment Area Greater than 50 tons per year in an Attainment Area Alternative Control per Reg 7, Sec XII.D.2.b.(ii) Other (Divison Discretion) NAAQS Pollutants Carbon Monoxide (CO) Particulate Matter (PM) Ozone (NOx & VOC) Industry Segment Oil & Natural Gas Production & Processing Natural Gas Transmission & Storage ❑ Ozone (NOx & VOC) Self Cert Required? Action Engineering Remarks Division Information Engineer: Kirk Bear Control Engineer: Stephanie Spector Review Date: 09/19/2016 Application Date: 03/23/2016 Facility Identifiers Permit No. 15WE1263 AIRs County# 123 Weld Facility # 9E20 Facility Type: exploration and production facility ❑ Located in the 8 -hour non -attainment area? Administrative Information Potentially located in ozone nonattainment area O True Minor Synthetic Minor for: i�VOC j"NOx rCO Company Name: Whiting Oil and Gas Corporation Source Name: Razor 33 Central Production Facility Source Location: SESW, Section33, T10N, R58W SIC: 1311 Address 1: Whiting Oil and Gas Corporation Mailing Address Address 2: 1700 Broadway, Suite 2300 ity, State Zip: Denver, Colorado 80290 Name: Chenine Wosniak Person To Phone: 303 802 8369 Contact Fax: 720 644 3636 Email: CDPHECorrespondence@whiting.com Requested Action Self Certification Required? Issuance Number: Yes 1 Source Description: Oil and gas exploration and production facility known as the Razor 33 Central Production Facility, located in the SESW, Section33, T10N, R58W, Weld County, Colorado. Point Name Type Control Action 005 TK-01 thru TK-18 Oil Tanks Flare Newly reported source 005 Eighteen 400 barrel crude oil storage tanks Calculations Requsted Throughput 1022000 bbl Control Flare Efficiency 99.42%! Emissions Summary Table emission are collected by a VRU which vents emissions 7% of the time. Gathering sysytem douwntime is 5%. 100% control efficiency. Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 0.197 lb/bbl 100.7 tpy 0.6 tpy HYSIS/TANKS Benzene 0.001'2lb/bbl 1226 lb/yr 7 lb/yr HYSIS/TANKS n -Hexane 0.0104 lb/bbl 10629 lb/yr 62 lb/yr HYSIS/TANKS 224 TMP 0.0009 lb/bbl 920 lb/yr 5 lb/yr HYSIS/TANKS Xylene 0.0002 lb/bbl 204 lb/yr 1 lb/yr HYSIS/TANKS Toulene 0.0008 lb/bbl 818 lb/yr 5 lb/yr HYSIS/TANKS E Benz 0.0001 lb/bbl 102 lb/yr 1 lb/yr HYSIS/TANKS Regulatory Review Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section II. A and B of this regulation. Section II.A.5 - Smokeless Flare or Flares for the Combustion of Waste Gases 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 for a period or periods aggregating more than six minutes in any sixty consecutive minutes. Regulation 2 — Odor Section I.A - 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. Regulation 6 - New Source Performance Standards NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84. This source is not subject because each tank is less than 19,800 gallons (471 bbl) NSPS OOOO: for storage vessels in the natural gas production, transmission, and processing segments. This source is not subject because each tank emits less than 6 tpy VOC. Regulation 7 —Volatile Oraanic'Compounds XII. VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS (Applicant is not subject to the emission control requirements for condensate tanks since it is located in an attainment area.) XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS... (Applicant is currently subject to this since actual uncontrolled emissions are greater than 20 tpy of VOC.) STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 PERMIT NO: DATE ISSUED: ISSUED TO: CONSTRUCTION PERMIT 15WE1264 Whiting Oil and Gas Corporation Issuance 1 THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas exploration and production facility known as the Razor 33 Central Production Facility, located in the SESW, Section33, T10N, R58W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description SEP-01 thru SEP-04. 006 Four high pressure separators controlled by an emergency open flare during VRU downtime. Flare has a minimum control efficiency of 95%. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days after commencement of operation or issuance of this permit, whichever comes later, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, 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. (Reference: Regulation No. 3, Part B, 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 after either, the date of issuance of this construction permit or the date AIRS ID: 123 9E20 006 Page 1 of 9 Colorado Department of Public Health and Environment Air Pollution Control Division 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. 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 2000 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. (Reference: Regulation No. 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 (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type NO),VOC CO SEP-01 thru SEP-04 006 6.4 67.7 29.0 Point ee "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Include individual HAP limit if facility is syn minor for HAPs and permitted limit is under 8.0 tpy. Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. Include total HAP limit if facility is syn minor for HAPs and permitted limit is under 20.0 tpy. 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 emission limitations as seen below. An inventory of each insignificant activity and associated emission calculations shall be made available to the Division for inspection upon request. For the AIRS ID: 123 9E20 006 Page 2 of 9 Colorado Department of Public Health and Environment Air Pollution Control Division purposes of this condition, insignificant activities shall be defined as any activity or equipment, which emits any amount but does not require an Air Pollutant Emission Notice (APEN). Total emissions from the facility, including permitted emissions and insignificant activities, shall not exceed: • 100 tons per year of any criteria pollutant and/or • 10 tons per year of a single hazardous air pollutant and/or • 25 tons per year of total hazardous air pollutants (HAP). 9. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled SEP-01 thru SEP-04 006 Emissions from the separators are routed to an emergency open flare during Redtail Gas Plant downtime VOC, HAPs 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. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit SEP-01 thru SEP-04 006 Natural Gas Vented from Separator 140.8 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. 12. The owner or operator shall continuously monitor and record Gas Gathering System (Redtail Gas Plant) downtime. 13. The owner or operator must use monthly Gas Gathering System (Redtail Gas Plant), monthly condensate/crude oil throughput records, calculation methods detailed in the AIRS ID: 123 9E20 006 Page 3 of 9 Colorado Department of Public Health and Environment Air Pollution Control Division O&M Plan, and the emission factors established in the Notes to Permit Holder to demonstrate compliance with the process and emissions limits specified in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 14. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 15. 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 I I.A.1. & 4.) 16. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 17. The open flare covered by this permit has been approved as an alternative emissions control device under Regulation Number 7, Section XVII.B.2.e. The open flare must have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16, and be designed so that an observer can, by means of visual observation from the outside of the open flare, or by other convenient means approved by the Division, determine whether it is operating properly. This open flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 18. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING & MAINTENANCE REQUIREMENTS 19. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 20. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or AIRS ID: 123 9E20 006 Page 4 of 9 Colorado Department of Public Health and Environment Air Pollution Control Division absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) Periodic Testing Requirements 21. On an annual basis, the owner/operator shall complete a site specific extended gas analysis ("Analysis") of the natural gas vented from this emissions unit in order to verify the VOC content (weight fraction) of this emission stream. Results of the Analysis shall be used to calculate site -specific emission factors for the pollutants referenced in this permit (in units of Ib/MMSCF gas vented) using Division approved methods. 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 these inaccuracies. ADDITIONAL REQUIREMENTS 22. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 23. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). AIRS ID: 123 9E20 006 Page 5 of 9 Colorado Department of Public Health and Environment Air Pollution Control Division 24. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities major stationary source requirements shall apply to this stationary source at any such time that this stationary source becomes major solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of Subpart HH. (Reference: Regulation No. 8, Part E) GENERAL TERMS AND CONDITIONS 25. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 26. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self - Certify for Final Authorization section of this permit. 27. 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. 28. 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. 29. 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. 30. 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. AIRS ID: 123 9E20 006 Page 6 of 9 Colorado Department of Public Health and Environment Air Pollution Control Division 31. 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: Kirk Bear Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Whiting Oil and Gas Corporation AIRS ID: 123 9E20 006 Page 7 of 9 Colorado Department of Public Health and Environment Air Pollution Control Division Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: http://www.colorado.gov/cs/Satellite?c=Document C&chi ldpagename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641 &pagename=CBONWrapper 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) Are the emissions reportable? Controlled Emissions (lb/yr) 006 Benzene 71432 12886 Yes 644 n -Hexane 110543 48280 Yes 2414 Toluene 108883 9928 Yes 496 Ethylbenzene 100414 2169 Yes 108 Xylenes 1330207 3116 Yes 156 5) The emission levels contained in this permit are based on the following emission factors: Pollutant Emission Factors Uncontrolled lb/MMscf Emission Factors Controlled lb/MMscf Source NOx (lb/MMBtu) 0.068 0.068 AP -42 CO (lb/MMBtu) 0.31 0.31 AP -42 VOC 19224.7055 961.2353 Gas Analysis Benzene 91.5179 4.5759 Gas Analysis Toluene 70.5106 3.5255 Gas Analysis Ethylbenzene 15.4073 0.7704 Gas Analysis Xylenes 22.1304 1.1065 Gas Analysis n -hexane 342.9009 17.1451 Gas Analysis 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 AIRS ID: 123 9E20 006 Page 8 of 9 Colorado Department of Public Health and Environment Air Pollution Control Division most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, HAPs PSD Synthetic Minor Source of: VOC, HAPs MACT HH 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. q po a ccess. q ov/ 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 9) A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification AIRS ID: 123 9E20 006 Page9of9 PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01 - Facility Information Kirk Bear 341892 12/14/2015 9/12/2016 Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Whiting Oil and Gas Corporation: 123 9E20 Razor 33 Central Production Battery Physical Address/Location: SESW, Section 33, T10N, R58W Type of Facility: Exploration & Produt'' What industry segment? U Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application Particulate Matter (PM) ❑ Ozone (N AIRs Point # Emissions Source Type Emissions Control? Permit # Issuance # 006. Section 03 - Description of Project Section 04 - Public Comment Requirments Is Public Comment Required? If yes, why?1 Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required?2 If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, explain what programs and which pollutants here: Prevention of Significant Deterioration (PSD): SO2,.NOx, CO, VOC, PM2.5, PM.10 Title V Operating Permits (OP) : SO2, NOx, CO, VOC, PM2 5,PM10, TSP, HAPs Non -Attainment New Source Review (NANSR): NOx, VOC Is this stationary source a major source? If yes, explain what programs and which pollutants here: Prevention of Significant Deterioration (PSD): SO2, NOx, CO, VOC, PM2„ Title V Operating Permits (OP) : SO2, NOx, CO, VOC, PM2.5, PM10, TSP, HAPs Non -Attainment New Source Review (NANSR): NOx, VOC Data for Drop Down Lists Facility Type List Exploration & Production Well Pad Natural Gas Compressor Station Natural Gas Processing Plant Produced Water Injection Facility Produced Water Management Facility Oil Stabilization (Exploration & Production) Oil Storage and Pipeline Injection Natural Gas Storage Other (Describe facility type in Section 03) Emission Point List Amine Sweetening Unit Condensate Storage Tank Crude Oil Storage Tank Diesel RICE EG Dehydrator Fugitive Component Leaks Hydrocarbon Liquid Loading Maintenance Blowdowns Natural Gas RICE Pneumatic Pump Process Flare Produced Water Storage Tank Produced Water Storage Pond Separator Venting TEG Dehydrator Turbine Vapor Recovery Tower (VRT) Boiler or Process Heater Other (Explain) Emissions Control List Enclosed Flare Leak Detection and Repair Program Non -Selective Catalytic Reduction (NSCR) Open Flare Oxidation Catalyst Thermal Oxidizer Vapor Recovery Unit to fuel system header Vapor Recovery Unit to plant inlet Permit Action Types APEN Exempt APEN Required / Permit Exempt Permit Initial Issuance Permit Modification Cancellation No Action Requested Facility Classifications N/A Major Synthetic Minor True Minor Qualifiers No Yes Public Comment Requesting Synthetic Minor Permit Greater than 25 tons per year in Non -Attainment Area Greater than 50 tons per year in an Attainment Area Alternative Control per Reg 7, Sec XII.D.2.b.(ii) Other (Divison Discretion) NAAQS Pollutants Carbon Monoxide (CO) Particulate Matter (PM) Ozone (NOx & VOC) Industry Segment Oil & Natural Gas Production & Processing Natural Gas Transmission & Storage ❑ Ozone (NOx & VOC) Self Cert Required? Action Engineering Remarks Division Information Engineer: Kirk Bear Control Engineer: Stephanie Spector Review Date: 09/19/2016 Application Date: 03/23/2016 Facility Identifiers Permit No. 15WE1263 AIRs County# 123 (Weld Facility # 9E20 Facility Type: exploration and production facility ❑ Located in the 8 -hour non -attainment area? Administrative Information Potentially located in ozone nonattainment area O True Minor Synthetic Minor for: r voc Company Name: Whiting Oil and Gas Corporation Source Name: Razor 33 Central Production Facility Source Location: SESW, Section33, T10N, R58W SIC: 1311 Mailing Address 1: Whiting Oil and Gas Corporation Address Address 2: 1700 Broadway, Suite 2300 ity, State Zip: Denver, Colorado 80290 Name: Chenine Wosniak Person To Phone: 303 802 8369 Contact Fax: 720 644 3636 Email: CDPHECorrespondence@whiting.com Requested Action Self Certification Required? Issuance Number: Yes 1 NOx r- co Source Description: Oil and gas exploration and production facility known as the Razor 33 Central Production Facility, located in the SESW, Section33, T10N, R58W, Weld County, Colorado. Point Name Type Control Action 006 SEP-01 thru SEP-04 Separator Venting Flare Newly reported source Four separators controlled by one enclosed flare during gas gathering system downtime. Flare has a 006 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/Ib-mol) at 60F and 1 atm Throughput (O) MW 140.8 22.13 MMscf/yr Ib/Ib-mol 16073.05936 0.385753425 scf/hr MMscf/d mole °/Q MW Ibx/Ibmol mass fraction lb/hr lb/yr tpy Helium 0.0000 4.0026 0.000 0.000 0.00 0.00 0.00 CO2 2.5859 44.01 1.138 0.051 48.26 422791.78 211.40 N2 1.0762 28.013 0.301 0.014 12.79 111999.49 56.00 methane 71.0721 16.041 11.401 0.515 483.49 4235396.09 2117.70 ethane 11.4564 30.063 3.444 0.156 146.06 1279510.72 639.76 propane 8.2861 44.092 3.654 0.165 154.94 1357292.39 678.65 isobutane 0.8103 58.118 0.471 0.021 19.97 174952.42 87.48 n -butane 2.7448 58.118 1.595 0.072 67.65 592631.61 296.32 isopentane 0.5085 72.114 0.367 0.017 15.55 136230.39 68.12 n -pentane 0.6714 72.114 0.484 0.022 20.53 179872.33 89.94 cyclopentane 0.0389 70.13 0.027 0.001 1.16 10134.84 5.07 n -Hexane 0.1508 86.18 0.130 0.006 5.51 48280.45 24.14 cydohexane 0.0675 84.16 0.057 0.003 2.41 21104.40 10.55 Other hexanes 0.1868 86.18 0.161 0.007 6.83 59806.28 29.90 heptanes 0.1683 100.21 0.169 0.008 7.15 62655.42 31.33 methylcyclohexane 0.0402 98.19 0.039 0.002 1.67 14664.15 7.33 224-TMP 0.0002 114.23 0.000 0.000 0.01 84.87 0.04 Benzene 0.0444 78.12 0.035 0.002 1.47 12885.72 6.44 Toluene 0.0290 92.15 0.027 0.001 1.13 9927.89 4.96 Ethylbenzene 0.0055 106.17 0.006 0.000 0.25 2169.34 1.08 Xylenes 0.0079 106.17 0.008 0.000 0.36 3115.96 1.56 C8+ Heavies 0.0488 116 0.057 0.003 2.40 21030.10 10.52 100.00 Notes VOC mass fracl 0.329 Total VOC (Uncontrolled)) 1353.42 67.7 15WE1264.CP1.xlsm Four separators controlled by one enclosed flare during gas gathering system downtime. Flare has a 006 minimum control efficiency of 95%. Flaring Information Equipment Description Flare to combust low-pressure separator as during VRU downtime. Manufacturer Model 40' Flare Stack Serial Number Gas Heating Value 1330 Btu/scf Throughput 187264 MMBtu/yr Overall Control 95.00% Combustion emission factor source: AP -42: Chapter 13.5 0.068 Ilb NOX/MMBtu Emissions Summary Table Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 19225 lb/MMscf 961.24 lb/MMscf 1353.4 tpy 67.7 tpy Gas Analysis Nox 0.07 lb/MMBTU 0.07 Ib/MMBTU 6.4 tpy 6.4 tpy AP -42 CO 0.31 lb/MMBTU 0.31 lb/MMBTU 29.0 tpy 29.0 tpy AP -42 Benzene 91.52 lb/MMscf 4.58 lb/MMscf 12886 lb/yr 644 lb/yr Gas Analysis n -Hexane 342.90 lb/MMscf 17.15 lb/MMscf 48280 lb/yr 2414 lb/yr Gas Analysis Toluene 70.51 lb/MMscf 3.53 lb/MMscf 9928 lb/yr 496 lb/yr Gas Analysis Xylenes 22.13 lb/MMscf 1.11 lb/MMscf 3116 lb/yr 156 lb/yr Gas Analysis Ethylbenzene 15.41 lb/MMscf 0.77 lb/MMscf 2169 lb/yr 108 lb/yr Gas Analysis 0.310 Ilb CO/MMBtu Regulatory Applicability AQCC Regulation 1 This source is subject to the opacity requirements for flares in Section II.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 control requirements of Reg 7, Section XVII.B.2 15WE1264.CP1.xlsm COLORADO Air Pollution Control Division Department of Public Health b Environment CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 16WE0895 Issuance: 1 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Whiting Oil and Gas Corporation Razor 33 Central Production Battery 123 9E20 007 SESW, Section 33, 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-13 and SEP-14 007 Two vapor recovery towers with with two vapor recovery units controlled by an emergency open flare. Flare has a minimum combustion efficiency of 95%. Open Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1 YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting- notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at COLORADO Air Pollution Control Division 1,1ezah.b __,rvvorvr:�rii Page 1 of 8 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 after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. 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 25 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.) ) Annual Limits: Facility Equipment ID AIRS Point Tons per Year E Emission yp e NO. VOC CO Point SEP-13 and SEP-14 007 0.4 11.6 1.7 Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 8. The owner or operator shall track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility potential emission limitations as seen below. An inventory of each insignificant activity and associated emission calculations shall be made available to the Division for inspection upon request. For the purposes of this condition, !COLORADO Air Pollution Control Division zit•%k.*c Heat:±£, Envir uuxsnrit Page 2 of 8 insignificant activities shall be defined as any activity or equipment, which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. Total potential emissions from the facility, including all permitted emissions and potential to emit from all insignificant activities, shall be less than: • 100 tons per year of VOC; and • 10 tons per year of N -hexane; and • 25 tons per year of total hazardous air pollutants (HAP). 9. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled SEP-13 and SEP-14 007 Emissions from the two Vapor Recovery Towers are routed to an Open Flare during Vapor Recovery Unit and/or Gas Gathering System (Redtail Gas Plant) downtime. VOC and HAPs 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-13 and SEP-14 007 Natural Gas Vented to the Low Pressure Open Flare 4.2 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. 12. The owner or operator shall continuously monitor and record Vapor Recovery Unit (VRU) operation while emissions are routed to the control device. The owner or operator shall continuously monitor and record Redtail gas gathering system operation while emissions are routed to the control device. 13. The owner or operator must use monthly VRU downtime records, Redtail gas gathering system downtime records, monthly condensate/crude oil throughput records, calculation methods detailed in the O&M Plan, and the emission factors established in the Notes to Permit Holder to demonstrate compliance with the process and emissions limits specified in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS -COLORADO Air Pollution Control Division Health a Environment ment Page 3 of 8 14. 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) 15. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 16. 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 property. This open flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 17. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING Et MAINTENANCE REQUIREMENTS 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. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) ADDITIONAL REQUIREMENTS 20. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in COLORADO Air Pollution Control Division De"aarmerit of ?!vtst:C Heattit& Environment Page 4 of 8 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. 21. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 22. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 23. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 24. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 25. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 26. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and COLORADO Air Pollution Control Division nt:Y °vtw Health 6 ^STvururxnc Page 5 of 8 regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 27. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 28. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Kirk Bear Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Whiting Oil and Gas Corporation COLORADO Mr Pollution Control Division _JCfT2r,.3 PUL& H,Mth S r. rwircarm,u. Page 6 of 8 Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (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. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 007 Benzene 71432 2943 147 Toluene 108883 2042 102 Ethylbenzene 100414 235 12 Xylenes 1130207 588 29 n -Hexane 110543 24831 1242 224 TMP 540841 2152 108 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 lb/year 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: CAS # Pollutant Uncontrolled Emission Factors lb/MMscf Controlled Emission Factors lb/MMscf Source N0x 0.068 lb/MMBtu 0.068 lb/MMBtu AP -42 CO 0.31 lb/MMBtu 0.310 lb/MMBtu AP -42 V0C 110256 5513 HYSYS 71432 Benzene 700.8 35.04 HYSYS 108883 Toluene 486.3 24.32 HYSYS 100414 Ethylbenzene 56.03 2.802 HYSYS 1330207 Xylene 140.1 7.004 HYSYS 110543 n -Hexane 5913 295.6 HYSYS 540841 224 TMP 512.4 25.62 HYSIS Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. COLORADO Air Pollution Control Division Department or Pbud4 Hexane Emoronment Page 7 of 8 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, HAPs PSD Synthetic Minor Source of: VOC, HAPs 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 6O: 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 DPHE COLORADO An- Pollution Control Division imetit of b tc Health S E>rivrnvrrvR Page 8 of 8 PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01 - Facility Information Kirk Bear 341892 12/14/2015 9/12/2016. Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: Type of Facility: What industry segment? Is this facility located in a NAAQS n If yes, for what pollutant? Whiting Oil and Gas Corporation 123 9E20 Razor 33 Central Production. Battery SESW, Section 33, T1ON, R58 on -attainment area? ❑ Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application Particulate Matter (PM) ❑ Ozone (N AIRs Point # Emissions Source Type Emissions Control? Permit # Issuance # 007 1 Section 03 - Description of Project Section 04 - Public Comment Requirments Is Public Comment Required? If yes, why?1 Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required?2 If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, explain what programs and which pollutants here: Prevention of Significant Deterioration (PSD): SO2, NOx, CO VOC PM2_5, PM10 Title V Operating Permits (OP) : 5O2, NOx, CO, VOC, PM2.5, PM10, TSP, HAPs Non Attainment New Source Review (NANSR) NOx, VOC Is this stationary source a major source? If yes, explain what programs and which pollutants here: Prevention of Significant Deterioration (PSD): 5O2, NOx, CO, VOC, PM2.5,,PM10 Title V Operating Permits (OP) : SO2, NOx, CO,; VOC, PM2.5, `PM10, TSP, HAPs Non -Attainment New Source Review (NANSR): NOx, VOC Data for Drop Down Lists Facility Type List Exploration & Production Well Pad Natural Gas Compressor Station Natural Gas Processing Plant Produced Water Injection Facility Produced Water Management Facility Oil Stabilization (Exploration & Production) Oil Storage and Pipeline Injection Natural Gas Storage Other (Describe facility type in Section 03) Emission Point List Amine Sweetening Unit Condensate Storage Tank Crude Oil Storage Tank Diesel RICE EG Dehydrator Fugitive Component Leaks Hydrocarbon Liquid Loading Maintenance Blowdowns Natural Gas RICE Pneumatic Pump Process Flare Produced Water Storage Tank Produced Water Storage Pond Separator Venting TEG Dehydrator Turbine Vapor Recovery Tower (VRT) Boiler or Process Heater Other (Explain) Emissions Control List Enclosed Flare Leak Detection and Repair Program Non -Selective Catalytic Reduction (NSCR) Open Flare Oxidation Catalyst Thermal Oxidizer Vapor Recovery Unit to fuel system header Vapor Recovery Unit to plant inlet Permit Action Types APEN Exempt APEN Required / Permit Exempt Permit Initial Issuance Permit Modification Cancellation No Action Requested Facility Classifications N/A Major Synthetic Minor True Minor Qualifiers No Yes Public Comment Requesting Synthetic Minor Permit Greater than 25 tons per year in Non -Attainment Area Greater than 50 tons per year in an Attainment Area Alternative Control per Reg 7, Sec XII.D.2.b.(ii) Other (Divison Discretion) NAAQS Pollutants Carbon Monoxide (CO) Particulate Matter (PM) Ozone (NOx & VOC) Industry Segment Oil & Natural Gas Production & Processing Natural Gas Transmission & Storage ❑ Ozone (NOx & VOC) Self Cert Required? Action Engineering Remarks Division Information Engineer: Kirk Bear Control Engineer: Stephanie Spector Review Date: 09/19/2016 Application Date: 12/11/2015 Facility Identifiers Permit No. 16WE0895 AIRS County# 123 (Weld Facility # 9E20 Facility Type: exploration and production facility ❑ Located in the 8 -hour non -attainment area? Administrative Information Potentially located in ozone nonattainment area O True Minor 0 Synthetic Minor for: VOC (- NOx r Co Company Name: Whiting Oil and Gas Corporation Source Name: Razor 33 Central Production Facility Source Location: SESW, Section33, T10N, R58W SIC: 1311 Address 1: Whiting Oil and Gas Corporation Mailing Address Address 2: 1700 Broadway, Suite 2300 ity, State Zip: Denver, Colorado 80290 Name: Chenine Wosniak Person To Phone: 303 802 8369 Contact Fax: 720 644 3636 Email: CDPHECorrespondence@whiting.com Requested Action Self Certification Required? Issuance Number: Yes 1 Source Description: Oil and gas exploration and production facility known as the Razor 33 Central Production Facility, located in the SESW, Section33, T10N, R58W, Weld County, Colorado. Point Name Type Control Action 007 SEP-13 and SEP-14 Separator Venting Flare Newly reported source 0.0000 2.5859 1.0762 71.0721 11.4564 8.2861 0.8103 2.7448 0.5085 0.6714 0.0389 0.1508 0.0675 0.1868 0.1683 0.0402 0.0002 Four vapor recovery towers controlled by one open flare during VRU downtime. Flare has a minimum 007 control efficiency of 95%. Equipment Description This source vents natural gas from: Emissions from this source are: four vapor recovery towers routed to a flare Natural gas venting from four vapor recovery towers. 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/Ib-mol) at 60F and 1 atm Throughput (Q) MW 4.2 49.2 MMscf/yr Ib/Ib-mol 479.45 0.01 scf/hr MMscf/d mole % MW Ibx/Ibmol mass fraction lb/hr lb/yr tpy Helium 0.0000 4.0026 0.000 0.000 0.00 0.00 0.00 CO2 1.2100 44.01 0.533 0.011 0.67 5901.29 2.95 N2 1.1500 28.013 0.322 0.007 0.41 3569.99 1.78 methane 10.7100 16.041 1.718 0.035 2.17 19038.42 9.52 ethane 16.1000 30.063 4.840 0.098 6.12 53637.47 26.82 propane 30.9600 44.092 13.651 0.277 17.27 151276.28 75.64 isobutane 3.9200 58.118 2.278 0.046 2.88 25246.83 12.62 n -butane 15.7500 58.118 9.154 0.186 11.58 101438.15 50.72 isopentane 3.2200 72.114 2.322 0.047 2.94 25732.71 12.87 n -pentane 4.0700 72.114 2.935 0.060 3.71 32525.51 16.26 cyclopentane 1.0900 70.13 0.764 0.016 0.97 8471.11 4.24 n -Hexane 2.6000 86.18 2.241 0.046 2.83 24830.75 12.42 cyclohexane 0.6900 84.16 0.581 0.012 0.73 6435.24 3.22 Otherhexanes 5.3600 86.18 4.619 0.094 5.84 51189.56 25.59 heptanes 1.3400 100.21 1.343 0.027 1.70 14880.79 7.44 methylcyclohexane 0.4900 98.19 0.481 0.010 0.61 5331.79 2.67 224-TMP 0.1700 114.23 0.194 0.004 0.25 2151.98 1.08 Benzene 0.3400 78.12 0.266 0.005 0.34 2943.41 1.47 Toluene 0.2000 92.15 0.184 0.004 0.23 2042.37 1.02 Ethylbenzene 0.0200 106.17 0.021 0.000 0.03 235.31 0.12 Xylenes 0.0500 106.17 0.053 0.001 0.07 588.28 0.29 C8+ Heavies 0.5800 120.6860345 0.700 0.014 0.89 7757.02 3.88 100.0200 Notes VOC mass fracl 2151.984697 0.849 Total VOC (Uncontrolled) 231.54 11.57692749 16WE0895.CP1.xlsm Four vapor recovery towers controlled by one open flare during VRU downtime. Flare has a minimum 007 control efficiency of 95%. Flaring Information Equipment Description Flare to combust low-pressure separator as during VRU downtime. Manufacturer Model Serial Number Gas Heating Value 2618 Btu/scf Throughput 10996 MMBtu/yr VRU Information Equipment Description Engine to recompress as to sales line Make TBD Model TBD Requested Control 100.00% Annual Bypass Tim 7.00% Backup Flare Overall Control 95.00% Combustion emission factor source: 0.07 Ilb NOX/MMBtu Emissions Summary Table AP -42: Chapter 13.5 0.31 jibCO/MMBtu Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 110256 lb/MMscf 5512.82 lb/MMscf 231.5 tpy 11.6 tpy Gas Analysis Nox 0.07 lb/MMBTU 0.07 lb/MMBTU 0.4 tpy 0.4 tpy AP -42 CO 0.31 lb/MMBTU 0.31 lb/MMBTU 1.7 tpy 1.7 tpy AP -42 Benzene 700.81 lb/MMscf 35.04 lb/MMscf 2943 lb/yr 147 lb/yr Gas Analysis n -Hexane 5912.08 lb/MMscf 295.6042 lb/MMscf 24831 lb/yr 1242 lb/yr Gas Analysis Toluene 486.280 lb/MMscf 24.3140 lb/MMscf 2042 lb/yr 102 lb/yr Gas Analysis Xylenes 140.066 lb/MMscf 7.0033 lb/MMscf 588 lb/yr 29 lb/yr Gas Analysis Ethylbenzene 56.026 lb/MMscf 2.8013 lb/MMscf 235 lb/yr 12 lb/yr Gas Analysis 224 512.377 lb/MMscf 25.6189 lb/MMscf 2152 lb/yr 108 lb/yr Gas Analysis Regulatory Applicability AQCC Regulation 1 This source is subject to the opacity requirements for flares in Section II.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 control requirements of Reg 7, Section XVII.B.2 16WE0895.CP1.xlsm Internal Combustion En AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Reci 0 a Emission Source �� K:. it E a [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] 0 z W Facility Equipment ID: uested Action (check applicable request boxes) Section 02 — Re Section 01— Administrative Information Co O N Co Co L i A 0 Pr A) a) U a O Q T Co E Co Co x p, O C' u 5 y - .00 O d W .2 1. y a V U O a a to d � ❑ El L >., W Co z w a V 0 o d z 7 1--I d °' .-at a . ` w w o�" A z O In co ®❑❑ Whiting Oil and Gas Corporation Change fuel or equipment 07 N r O Cl Transfer of ownership Change permit limit Request PORTABLE source permit Request APEN Update El ON Ca N 0 0 t a N Denver, CO 80290 Chenine Wozniak 720-644-3636 E 0 z LJ O z Section 03 — General Information For new or reconstructed sources, the projected startup date is: For existing sources, operation began on: A) T Co C) a a,) N A) 0 Co Ca 0 N C 0 N N Normal hours of source operation: Gas Lift Compressor Engine General description of equipment purpose: Co d C O c U Co C a'C.+ O Ta • 0 Co O C d L CA a N A O -Co C C 0 0 0 4 C O C 'C• o b 'Co C E a� W W L M m cn C0 0 1 tV N N cFn .0 al a) di;e `O U, a s V , 1� Co:M c�1'M o c O'0 Z 4) 0 O �� :72.,"Z1 Er..) �a a c a\/ O ,/ �" fl E h CCo E O � z ��-.yy. L f ca g w C W 'O Cd U F,� +�.+ X30 1.4 I., y o .T. O R, Co 7 y 00 41) Co a � g.Q ° o �'' • ° a. 0 A? E• 33I3 �3 Sao a o dg 0 00 C Co r' UM'1 O C c A 0 3 -000 T o .1' e E d `o o b Co > a C o, U o o U o o ,.. coIl op wO 0 0.E c0i C �' 0 O y U .� Co o ro Y o A U o u>90 ...) �v Udal �A Lia� 0 occ'r APEN forms: h ermitstatus U 0 Co ro 0 O U Application status: h 0 71: OD v C O� N cCd pin 9 1-1 En O O p O O paa W a co co 0 0 -+ O N 0 0 0 0 0.) 0 Cr CCr 0 O 0 00 w 0 O .0 .0 C-) C-) ZZ In 0 N M e construction commenced: 11/05/2014 Date the engine was ordered: z Date of any reconstruction/modification: d\' z O 0 0 z a) El a) 0 0 C ZE C .5 ro C-0 > N b0[ p 0 N CA o a0 C 3L Section 04 — Engine Information M Engine displacement: 0 0 CO N O w O z C CCC a Cd U ❑ ❑ Engine function: 0 0 C- 0 00 '--1 0 0 1-4 M H ro a) 0 O bi °0 .5 .) 01 0 E E Co Co ha)" z Pa M N r-� N e Brake Specific Fuel Consumption @ 100% Load: C Turbocharged El C 0 N a) a) U7 ® ❑ o ( 0 N f/i El 0 What is the maximum number of hours this engine is used for emergency back—up power? CV �C, W M FORM APCD-201 x Internal Combustion En 5czt V 0 it 1�1 I C'^ Ct Emission Source Permit Number: 5 0.0 0 al 745. al 0 O • O • .9 aid N ..9 a) O 0.y ed x • aq U vp2 F-� 5! en A0 0 NN o o, q o O - • a 00 00 O r -103.870215 en 0O ac Q N3 U o J 00 ti CO N N M N Width (inches) Horizontal ❑ Down ❑ Other: Length (inches) = ❑ Vertical with obstructing raincap 0 ® 4) 0 C) U a, U V N v] 4) an bo O K W N Direction of stack outlet (check one): Circular: Inner Diameter (inches) = tion Information Section 06 — Fuel Consum W -.O • a] a O a)' y5 g u O Z tn N 40 0' O ,f7 N N N 1,330 Btu/scf Requested Permit Limi 61.51 MMscf/yr 4- . CU 4 b eel d 7,021 SCF/hr Natural Gas O z 0 N O U ® 0 In I • Wy V 4 .0 • O • • O VI O cd 3 • y •o q y .o an a ,an • W �q I C O '4 y a 4, U Ct z 0[ .0 0 v 0 d 0 0 •h 4) L 0 '0 q as 0 0 i ti y Estimation Method or Emission Factor Source 1 AP -42 AP -42 N AP -42 Requested Manf Spec Manf Spec Manf Spec AP -42 . AP -42 Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Requested Permitted Emissions' O` -G—O- U H De;Minimis C .tl g A .C -g- Aad .p 4 ei,J A ` 12.7 O, O en N ti ti y M O N O r I DeMinimis Uncontrolled (Tons/Year) H AI A H . g A y . Q A De Mininiis/ 12.7 39.2 4.56 M N De Minimis Actual Calendar Year Emissions2 Controlled (Tons/Year) N ( o 3 r- S Uncontrolled (Tons/Year). Q 0 O b Emission Factor Units ?a Pa � 0. Oa a g/hp-hr g/hp-hr a — � Pa Ib/MMBtu Uncontrolled Basis ON 0 O o 0 O N o 0 O Go ,, O C C O O • H t...,O 7 .-i *y • en ,D t*) O vo en 000 co O im.)) v O O O O O Control Efficiency (% Reduction) IA !A rl- M Control Device Description Secondary g ' sco O up O coo Pollutant F" a pa., xcn O Cn XON II VOC 0 U Formaldehyde Acetaldehyde Acrolein Benzene 4) ...; O � a C7 O U .4i'O o 42- g, 4 p, O O 0 e. b F. O O v • U -t ccl y 1-1 cd 30 g b El 0 p 0 O sh n2 ,6 y o -d •b•.. a) , 4)01 yg-, a d w O C- 0 N r, o' .a 4 4_ e.cd � ❑ L. 4) ..7 'b a A N co O 3 .'1 • 0 U) ,H o au ba) V O .1 ,4 5 N .-i 4.... � .-,,-.1 O - p , m O (,) y, U ") q '� y O • 0 ad a _ ca) yd >., 0 .. A Q p.5 co c d a) c 45 • a; a ad d ' t N Q = c•••c•••••o U Pa z 'O 0 0, RW ,... Cr) •2 ,- 0 .0 W C N Q) w ay 0 0 d g v b4 '. • Q U N 00 >, •a p U �. Is a, b4 e0ap q a °a 3 v 0 .0 - 0 O an �o H ) sow Pw, y•y -oo a o d O O °; q ad o ° 1r q y y •on cn ,-i C/] 11-, -Cl] Environmental Professional III H- a a) 4 ti Q O i w - a) 013 aa) w 0 a) 2 Form APCD-201-RICEAPEN-Ver.02.10.2014.docx 1-4 E4 ad AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Produced Water Stora Emission Source AIRS ID: / Z3 unless APCD has already assigned a permit # & AIRS ID] 1v W Permit Number: [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] PW-01 throu Facility Equipment ID: 0 .) A X O A a ad a) 6) ) 0 ,1 0 L C- a) N O, O �1 C IOi F:d 0 ad a v 2 Cd P.•= 0.. -❑ ad L c x G. W 7.1 .� W d '- U y .� d z 0 > a O o 44 Z cd A L L r, w? 0 , o „4,,a Cr 04 74 Section 02 — Re Section 01— Administrative Information s❑a ❑ ❑ Whiting Oil and Gas Corporation z U 3 Change company name O U ❑ ay O C7 Transfer of ownership A Cd 4) O C7 a) as E a W o - i C ' L fl o w 0 U w P. a 00 00 U U C) w It) r oo C _o 0 U U ,_o. 0 W N 0 0 C. A Section 03 — General Information En N N 3a)zzzzz N In •0 0 ® ® ® Z ❑ 0 0 0 N 0 I❑ ❑ ❑ ❑ m o. A -0 N N Normal Hours of Source Operation: z 3 o ® ro 3 c i N o ° c 0' 0V) o C, A 2 Cal 400 Al o k'+ W p,0 O O O 0 A m �. U o O ,� p c a 17,'> 4) U g ❑ ❑U <c, -,)g,1,) 0U 8 +>' 0 cdal O W 0 cd o cC Fal a) a c ccO� Eo �,c 0 `) co C > o o O z A O C LL q c c U o 0 0 .0 loEA .0 v E -r4 v) a U yL C.) O O n y °, T C.' W Lv U. y 2 ® 55 b' to Al U U U 4,0 0 U a) U -C^ 0 ° "0 co 0 0 ° O 1•, 0 0 0. C i L C) Rt U 7 O L oa .0 C) 0 0 a C) a Cd a) 0 0 U •0 w 0 0) ar Q w 0 C a0+ s `. ad C L a, Cl. C 7. > .Z O d 0 .n o 0 O\ _ L U❑ U y N •O N .i O C O , O L L � a ° O\ O a 15, • a3 p N .Nr 0 N "a0+ 5 i., - F, 0 EA rte.°E oy'o z ^�w�0ddo a•" U C C 0 w.S0 q_y 3° 0 =i '0 c•Jd O''0 a 0 L °L' `� c oD C W d a a) Ti1° o Cd C g d td) ` 0 y bEl aa) 0 a 0 v y s0. W o c• 3 a y O O'i O ;4F-.. E ° aL _, g .o •7 d ;�� Sr ww l!` T O fr- Information a' Cd d Section 04 — Stora C) ° pdo .0 A 0 Requested Permit Limit: Produced Water Internal Floating Roof: Fixed Roof: do 0 eo A 400 • Date Of First Production (Month/Year) In N N C x d 0 O L - 0 0 -. 4. +0' C) 0 y yet crt O > *-0 A CD Cd L C y N 00 In PW-01 -14 Wells Serviced by this Storage Tank or Tank Battery (E&P Sites Only) Newly Reported Well ti DEIIIIE Name of Well Razor 33M-2801, Razor 33M-2803, Razor 33M-2804, Razor 33-2813H Razor 33N-2805, Razor 33N-2806, Razor 33N-2807, Razor 33N-2808 Razor 33O-2809, Razor 33O-2810, Razor 33O-2811, Razor 33O-2812 Razor 33P-3313, Razor 33P-3314, Razor 33P-3315, Razor 33P-3316 API Number 05 -123 - 39256, -39257, -39258, -36579 05 - 123 - 39260, -39261, -39259, -39264 05-123-39307, -39306, -39308, -39305 05-123-40216, -40219,- 40218, -40220 AP Form-APCD-207-ProducedWaterTank-APEN.doc N 0 0 0 m P•� FORM APCD-207 0 AIR POLLUT Emission Source AIRS ID: Permit Number: LID •O O N O OD �Ob Y O a Ir 00 00 00 et tn H z h O d it O LTi O O CO O E U O CZ 0 O Q V 41.7 J' 0 a; aF W o w " H - v II C C) 0.0 Ca .� b 0 3 N O 0 x ❑ ❑ Vertical ❑ Vertical with obstructing raincap ❑ Circular: Inner Diameter (inches) = Direction of stack outlet (check one): Exhaust Opening Shape & Size (check one): roduced water tanks. O a) CO aration, followed b hose heater treater se z Estimation Method or Emission Factor Source N 7 PS Memo 09-02 AP -42 PS Memo 09-02 PS Memo 09-02 II • Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Requested Permitted Emissions Controlled (Tons/Year) 7 .Ewi.Eo A o A o M 0 O cr Uncontrolled (Tons/Year) $ $ Actual Calendar Year Emission Controlled (Tons/Year) X41 6- — 0 m T N Uncontrolled (Tons/Year) Emission Factor I I I Uncontrolled Basis 0.068 (controlled) 0.262 0.310 (controlled) I O o 0 N O 0 Pollutant N °z° O - CO Benzene II I Toluene a A A ;, w II Xylenes n -Hexane O t. C. r' 5 H N N U d W y ad PI+ T 00 O O In of a w0 ea v O. U � G d U C' a°' Section 10 —A L Environmental Mana C O CO a L 12 Gti 4, Qa AP Fomi-APCD-207-ProducedWaterTank-APEN.doc N 0 0 N O 0 0ti FORM APCD-207 O U O in Permit Number: [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] Facility Equipment ID Section 02 — Requested Action (Check applicable request boxes) Section 01— Administrative Information General Permit GP07 Individual Permit d CO O 0) Whiting Oil and Gas Corporation CO z Ly h C w O a ❑ ❑ . . a, CO a w CO O) d 8 w z y CL O Z $ y r a O m Q O - U 8 DI ai A ° a z O O u .. td. U U O O O O Cn a®❑aa CI Z CI ' O O UU zc 3 O C O O U G) w or C O CO w 0 V 6) d A O O0 O O U N CDPHECorrespondence@Whiting.com Whiting.com E-mail Addres Addl. Info. & Notes: Section 03 — General Information 0) a) 3 N et 'O O Normal Hours of Source Operation: N N _ O 6) O L C.) N 40 O 'CO CO U) N o F N CO O a Date operation began or projected st General description of equipment and purpose: Don't know O O O 5 5 O O O Don't know El EDO Z' z z z z ❑ ® ®®® 2 < < V) V) V) CO N O0 O O N ® ❑ ❑ ❑ ❑ 0) 0) CL CO O O ca 0 cn Ate. 1. O O C s� O I' U ap 0 O 0 C Q o U) O C bD O o c p O p O U w O O X r0 Mn9 00 U a) en 0� 0 C O U o CO o zw O 4) 8 0 0 cn w V cn U) ♦ O O cn O O O -OO O O U C O O O O 0) 0 b m C O .Nr CO U w 7 ti 00 'O 0) w L1 0 8 .H w A C .8 ct .8'° U p o c y ° 8 • ob a) > U ^N A? ♦ ♦ CO O CO 1.4 w CO ^o O a 7 O CO O V V] O CJ 'O C U Condensate Product Loaded: .G C d 8 O U 4 U 00 CO 8 O -CO C) C.4 d wr O O. O O W O OO CO a`a)) p C O CO U 0) 0) 0 a) CO•' Annual Volume Loaded: Tank Trucks O 0) .44 8 0) CO 0 U C 0 0. h H C 7 II 03 d > L67+ O C u CO V 4) b N L C u w O b To d U v 0 dO4 oV w � C • ci Molecular Weight of Displaced Vapors: a. True Vapor Pressure: C 0 0) i a) 8 O U d CO CO 0 'O C a) 0. O a) 3.7 C r L O CE 4 CC' C) pz N C) b 0 C. CO C C CO U d O CO O C) W b y 0 Q' P4 Loads per year: Load Line Volume4 ov/ttn/c hief/ap42/c h05/index.html). FORM APCD-208 CO 0O qtr O1 AP Form-APCD-208-HydrocarbonLiquidLoadingAPEN.doc N 0 O Cd I- H O .13 CO CD a O CO R u O C id CO U) U Permit Number: o en QA F. o 01 N oo O O r -103.870215 oo z 0 J ar CO w O Q aw A 'd' 0) r ❑ Horizontal ❑ Down ❑ Other: Length (inches) = Vertical with obstructing raincap a -4 O V N U N • 0 o 00 O C/) U bA v W 0. O 0 o• U � • X LU 00 Circular: Inner Diameter (inches) = Section 07 — Control Device Information VOC & HAP Control Efficiency: o w O\ z cr fx❑ a, U U G F. w • O O o y. o U• py E o 0 03E COa c) o U E— - U Section 08 - Emissions Inventory Information a a CO 0 'CO R CO CO d 0 r 0 s L d 1.d CO L 67 a d ou 'fl a) CO 0' a 0 CO O a N i 00 a as en O O CO N G PQ O 0 O O d N G a1 N O 0 R a d 'CO CI O w 0 O O CO N d) b 00 O 0 O O d N N O.1 O.l 0 O 0 0 6) 00 U CI z Data year for actual calendar year emissions below & throughput in Sec. 04 (e.g. 2007): 0 V a CO a .10 u a ti i a CO d u COO CD E 0 O A 0 CO a CO co) Estimation Method or Emission Factor Source AP -42 Hysys & Tanks 4.09d N K Hysys & Tanks 4.09d Hysys & Tanks 4.09d Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Requested Permitted Emissions Controlled (Tons/Year) 1 .s o .2 c o P o g o A A Uncontrolled (Tons/Year) M " 11 f M O O O Actual Calendar Year Emissions5 Controlled (Tons/Year) COrn M Uncontrolled (Tons/Year) Emission Factor Units i E. y `ion `ion O 0 O 0 O 0 Uncontrolled Basis 0.068 (controlled) .-r O 0.310 (controlled) O O O co Control Efficiency (% Reduction) Identify in Section 07 Control Device Description G 0 0 N cn Primary Pollutant VOC OU Benzene n -Hexane a O 0 d 3 ., V 8 C0 .02 O d CO 0. E = O U Si a 7 14 w G •,-A .5 1: Z7 a G a z 07 w a o a s .0 0 9 d 3 A' C a O L ▪ O U O L o CO • O E .CO4` ▪ c) q 4. a 9 'R9 00 a o a .1 CO WA i. y CO y L Z I L i. u W O W p+ .COO L ` d :41 U 5 = z v F M. wa CO.d� E°o w .0J. 0 °o • i, au as W CO• 45'.e r O E R i. A '3 o 0O� CO. 'O u y L R1 4 H d d • a r..) a y Cr a 00 47 R L C) A 6+ L 0 " a b a o o d o �., xo1 a y o s. U 'O ° Q u d U L Z7 W d Environmental Mana i 0 M N S7 V Fa R AP_Fotm-APCD-208-HydrocarbonLiquidLoadingAPEN.doc AIR POLLUTANT 0 Emission Source AIRS [Leave blank unless APCD has already assigned a permit # & AIRS ID] Permit Number: your organization.] [Provide Facility Equipment ID to identify how this equipment is referenced wi 00 H TK-01 throu Facility Equipment ID: Section 02 — Re Section 01— Administrative Information 1-0 o 0 UU U zE75 Whiting Oil and Gas Corporation z a. Change process or equipment b 3 Transfer of ownership Change permit limit a) a) u7 N r APEN Submittal for Permit Exempt/Grandfathered source N N 0 0 U N APEN Submittal for update only (Please note blank APEN's will not be accepted) 0 C 303-802-8369 0 0) 0 z Section 03 — General Information For new or reconstructed sources, the projected startup date is: V) 0 N N N For existing sources, operation began on: N N Normal Hours of Source Operation: GJ d CO re!0o . A G Q O w w_° w Ft o 0) L 0) z el 0 co o ° O gAI G W N o -o.O Ft•° a; o y ❑ ❑ 0 U O o 0 �0U C a C7 O IHO a O ' a3 0 d� up ... • a N U o a U o a� z0 CO .8 , w Al 0 00 o ° p m a O 2 O 8 a N a) >, A ro � 0 4 F4 H 0 Eighteen (18) 400 -bbl crude oil storage tanks hi 0 0 9 0 0. 8 a 0 0) w 0 0 0. F v w 0 C7 n. A O 0 0 0 0 0 0 69 L N 6, cd L 764 O 8 ti C a•=ox80 Lu 00 cu a) wai -C 0. L aa7 H V c0 C > % L wPC .2 C Q g w CO d,'N 0 7 L 8 CO 0. -00.4=4,z 0 o O I W fn W a •3a=0) R o Eu n a�a— q�lr.'a �ere d J 0 000 00N F •0 P 00 •5 2 O 0) a - ro G' O O o p O 0 C • ti o Q o U r, 0 0 .5 ,D .a a 00 r.6 ¢� APEN forms: h Ft ://www.colorad Information y CO d Section 04 — Stora T) z Actual While Controls Operational: 00 RVP of Sales Oil h N 00 .0 .0 '0 N 0 z` a O Tb •v 0 r M External Floating Roof: Internal Floating Roof: Fixed Roof: 0 N N Installation Date of most recent N 00 Total Volume of a a F C 01) 0 00 N r s d N 7 d Sr 000 I� L' 000 0) a CO 00 CO L 0 00 '. 0 AP Form-APCD-210-CrudeTankAPEN.doc N 0 a) 00 00 FORM APCD-210 "-C, CA Emission Source AIRS ID: Permit Number: Section 06 —Stack (Source, if no combustion) Location (Datum & either Lat/Long or UTM) O O 0) b 0 w �^ oa .O 80 ai W -42 O S 00 O • A q O O O ,,o ' • QU O C7 a. 40 B In 00 00 00 -103.870215 coo O 0. O Q aw a, H 1 x ❑ Section 07 — Control Device°Information tower to crude oil tanks. or recover d m 40 N ' �•N O y Cip 6)0 cl 0? N O c`0 0) 0 U O 0 3 CL. N .y U 60 O 414 0 > N O O .0 •O goo GL O r.�� a O y ti N r� I a•,� 00 0 a0i 0 •- • °AI) N Cl)0.4 Information 0 O 40 5 0 4- O O .p 0 "rJ 0 O Cad h4 0 0 C) O 0 O y rn ON 0 0 4) CJ z Emission Factor Data Source I AP -42 Hysys & Tanks 4.09d II AP -42 Hysys & Tanks 4.09d Hysys & Tanks 4.09d Hysys & Tanks 4.09d Hysys & Tanks 4.09d Please use the APCD Non -Criteria Re ortable Air Pollutant Addendum form to report pollutants not listed above. Requestseermitted Emissions AP [ Controlled (Tons/Y) 0.02 ,�,�,�...yyy,,, O 0 H O v 61 . v D O H O O O Uncontrolled (To$'ear) N 0 0 40 o 7 o M in 7 o O4 Actual Calendar Year Emission Controlled (Tons/Year) Uncontrolled (Tons/Year) I ^i"�ni fission Factor Units 0 a O dm O .0 .0 Uncontrolled Basis 0.068 (controlled) 04 .-i 0 0.310 (controlled) o O 00 00 O O 00 o O Pollutant xON Benzene Toluene N II n -Hexane ❑7) y N y O. T O O U a - - a >, x N E '0 W E-. N N Section 10 —A ad Environmental Mana Jaeadeesan Sethuraman O N N N O G CC C) O. C) aI a O a C) N 0 0a w • A E ° zo ti .5 80 2a co L • O U .a rr.I �U O 74 8, 4ti e, o q cd W .0 Q N O 7 U V) w a o z 'O OW O • Q 2° o D • b O T`° 3 0 C)l b w 6N Q G 'z U p a ,,s O a 0 N 0 q 40' - ry 0 a 0. 0 0 004 'o c ro C) c 4) O '0 0 .0 C) O. '0 0) 0. CC a c00 y � y C)on E.a-s g of I y 3 5 '5 > o U ii 1'! 01 o o b C) c❑❑O .Y g 0 .cn HH 0. Q W0 Q Q ® ❑ AP Fonn-APCD-210-CrudeTankAPEN.doc FORM APCD-210 (APEN) & Application for Construction Permit — Natural Gas Ventin AIR POLLUTANT EMISSION NOTICE y .G y 0 ca T 0. vs ❑ o 0 O CL a a W 0 ° H U) o a) al •- o tolo a) -° >, ai a a) . E O 0 F 0 -ta O — 41 a+ 0 CO01 O M. ea h r! a) W y •- a _ C.) e.) t 'a) .yq H 0. 'O .r co h W O O 0 ar 0 U) m S O F L 0 a O y `V y as 8 q o c/)0 u y aJ 0 0. 0. ❑ ❑ '� a1 O 0 ' 7 Lp.' a Z5 d a d U) 3 ? g 'O cu a) G (ri S= -U d q .Ui a) y E 0O — .- .. 0 a Emission Source [Leave blank unless APCD has already assigned a permit # & AIRS ID] Permit Number: 1-1 [Provide Facility Equipment ID to identify how this equipment is referenced wi Facility Equipment ID: D d LI d) V 0 U) U) U aJ U) U Ca 0 u U) 6) U) Section 02 — Re Section 01— Administrative Information O a) Vi‘ UU U Z Whiting Oil and Gas Corporation C) U) z C ad 0 0 U V7 N 7 0 0 ta 0 a) ON GO 0 O U N O U i G 01 f=1 303-802-8369 o - E a O z In O 720-644-3636 CDPHECorrespondence@Whiting.com E-mail Addr Section 03 — General Information a) a) U N U 0 O Flaring Associated Gas from Separators General description of equipment and purpose: 2 '0 o 0 0 o0ov) CL ,�-' r. I. r. U :08 76 O W i -0 O O a) U � y � IJ..f � Id•`o•_ o,W�� p G o?f W O� a rip Cr-1 U u y 2cip = x 8 ›3F a) ad T o o, = 7--, 7• ..—,!•� O 0 O O cr caa .FU, UO - 0 LP - G -� C L N O 6 cd ^U T O 0= d 0 ti ' O j' V 71t a) N 's'7 G J �+ O O 7 E CL )..i U CIO O 0 cl).� O O w A >.., O U o c o a 0 O �.flvirU fl 2 o aoAo; z.m .. U ax)•5UdIA w Qvi Application status:http:// Q5 O z N Section 04 — Processing Eauinment Information U) C) U) O y a 0 U) MMscf/event Blowdowns: J } o 5 O f•) 4- O eel z U) P Process Parameters: a2oi` H in U N X 5 GO O 0 0) 0 a, N .2 MMy °Op 7 O CO U `4', y o .07.. p,...16 '5 Ni cn 9. QIS 0 0 > °".,1' IIB z N O O Q 0 0 g 0 0 0 gO4 I- 0 0 .0 go to U U U El El O °) I\4oleculr Wt. GO r. Vented Gas Propertie APCD-211 ICI H 'Requested values will become permit limitations. Requested level shall be Emission Source AIRS ID: / I Section 06 —Stack (Source, if no combustion) Location (Datum & either Lat/Long or UTM) Permit Number: 0) ) • ti 0) CO CO O CO 0 O Lc.) 5 w 1�1 O 6 0 N 0 o V I 0 -103.870215 DAD z o 0 CO CO Ni A CO O A O co 'Am U : - • Ln Tr" 3 Q U Direction of stack outlet (check one): Width (inches) Other: Length (inches) = Circular: Inner Diameter (inches) = Exhaust Opening Shape & Size (check one): Section 07 — Control Device Information Section 08 — Emissions Inventory Information & Emission Control Information z Estimation Method or Emission Factor Source Gas Analysis AP -42 N Gas Analysis Gas Analysis Gas Analysis Gas Analysis Gas Analysis II II Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Requested Permitted Emissions Controlled (Tons/Year) N TO 9 - A N _n O N N O U'O ) O_ GO _OO H N - Uncontrolled (Tons/Year) T In $ i $ i $ t Actual Calendar Year Emissions4 b 0 U U " Uncontrolled (Tons/Year) M A * i Emission Factor Units I . lb/MMBtu O iitli A .. O 3 .. 6 y O Uncontrolled Basis 0.068 (controlled) 0.310 (controlled) till! Control Efficiency (% Reduction) In S 0\ co O\ I � T. _ In c:; Overall Collection Efficiency b Oi bi O In 01 95 It) In 0, Control Device Description Secondary CO w CO w CO w 0 w 0 w 0 w a Pollutant >zC)o O Benzene Toulene a' w II Xylene g k Z ai O a A 0 s 0) 0 L e G O 0 W a co w O A O U E Q 0 '0 O C) O y b q CO o 0 0 u U C. O YE!' w .y -Ow ¢® O O C1 a) Environmental Professional RI Ctl N 0 V • Signature of Person Legally Authorized to SupplyData U 5 0 U FORM APCD-211 AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Natural Gas Ventin N O X41 a - Emission Source [Leave blank unless APCD has already assigned a permit # & AIRS ID] Permit Number: [Provide Facility Equipment ID to identify how this equipment is referenced within your organization. Facility Equipment ID: uested Action (check applicable request boxes) Section 02 — Re Section 01— Administrative Information in 0 P. 0 a. p i.. a w 0 0 0 .> co 0 co a y 0 = 0 .E a O 0 O 0 0. •0 E x O wo �0.4 0 0 4) .0 0 4 ,.° o 44 .vi o g o 0 0 .C 0 O F o. O g 0 G • . U 0., ,0 E 5 41 0 O ❑ ❑ i y '2 y 4) > ••-. a) a) a) W .0 Z a >, m z q U W O4) •u4 aoi 2• o ¢ W . 0 c c W c 0 ro c . 'j b o 41) 0 0 U U y Cr C ® ❑ 0 >>d ❑ ❑ Mailing Address: O U 4) a) 4) 4) 303-802-8369 Emissions based on assumed VRU downtime (7%) and Redtail gas gathering system 720-644-3636 downtime (5%), with backup flare control (95%) Section 03 — General Information 4) PA 7 O 0 H i a) a, in 0 CU 0) ' O 3 .ayy ,py 'O '0 0 w cd 7 0 0 0 0U0 0 .0 0 4) 461 4) fa, o O a 0 or) U E ° O z 0 b0 G General description of equipment and purpose: O z QS nonattainment area? O 43 O 0 O CO o 00 Cn Z 0 U W I Q I \m tinm W 00 y C��ft ay N N 0 ❑ C::' --0' r o• ..0 go .a) 0, W eoi 'o C W a p C% to d b9 .a . 00 Cro tr-�Q . O _ w y ° o m ro 3 47i -x x 0 E C. 0 0 F. E d. i 0 ° 0° o >' o O. ..0 ' p y 5'00 w O o O 7 o o a o U U a' d o ., U OU ° U c 0 d ° .. CO Lg 6) A O y C bD .w 3 "O in 0 00 E d D 0 .� > •U L C 70 >`O ti E a.,,Uoo O U 2 .^ q-, " Oqp? LO U 0 C o = o d U g...,7, o . 'fl , . ti - Pa O a = m y s. A on po. '_" .• pUp,� a 4ki'V¢aA w° �� APEN forms:h Application sta z0 g 0 "0 4) 4) O O a) bD ta ^ 4.) ao 4) CO U 4) 4) iA C a 0 0 4) E 4) 0 CO :-4) 0 F 0 0 0 00 C N oo 00 a Process Parameters: ><E N to N 4T 4) 4) N U ^ so ai 7 -0 °) tt 4) 0 o E 00 M 'n 0 � E N r 0 4) 0 N o) 0 4 a 0 CO Ca) 4) a C) CO ett FORM APCD-211 (APEN) & Application for Construction Permit — Natural Gas Ventin AIR POLLUTANT EMISSION 111 Emission Source Permit Number: Section 06 —Stack (Source, if no combustion) Location (Datum & either Lat/Long or UTM) Section 05 — Stack Information (Combustion stacks must be listed here) S U • oco2 3 U 0 O. 8 M on'S Td (cc.no N o Z en 5 z aw 4o O A 00 o . 0 x� d' N CO Section 07 — Control Device Information CO b0 4) 4) ® Combustion Device used for control of: Ii d A CO 44 0 odel/Serial #: CO In U 00 N w 0 z N O z EI O QD 5 5 C U ® VRU used for control of: Make/Model: 30 -hp electric N Co ti Control Efficiency: Requested VOC & N Annual time that VRU is bypassed (emissions vented d A 0 O VRU recycles venting e ribe Any Othe C) Section 08 — Emissions Inventory Information & Emission Control Information z Estimation Method or Emission Factor Source Hysys &Tanks 4.09d 'Ay Cho Hysys &Tanks 4.09d Hysys &Tanks 4.09d Hysys &Tanks 4.09d II Hysys &Tanks 4.09d Hysys &Tanks 4.09d ON S C E+ 04 I� Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. �I Requested Permitted EM issions Controlled (Ton /Year) s10 an 4-o H 2.33 en ~ O .4 co O 0.05 co O O O 0.62 © O Uncontrolled ,(Tons/Year) 1438.4 6-4 4-4 o 6.27 0.77 60 77.11 00 Actual Calendar Year Emissions4 Controlled (Tons/Year) Uncontrolled (Tons/Year), Emission Factor Units To. as 0 0 0 0 0 0 Uncontrolled Basis. 41.751 0.068 (controlled) 0.310 (controlled) 0.2644 - N 00 O In N O - N O 2.2383 ON O Control Efficiency (% Reduction) it) in 0 95 in OP 95 in O) 95 Overall Collection Efficiency 00 00 00 00 00 00 00 00 O 00 00 00 00 00 Control Device Description Secondary L ca w L cc w I Flare co C es w I Flare Flare Flare Primary VRU Pollutant VOC XON II O Benzene N CO C H NN a ,D 7>, W Xylene N 0N x CO )9 7 P. >, N •g H U a • N 4-d 0 N 4) CO FORM APCD-211 Hello