HomeMy WebLinkAbout20163487.tiffV21OlieiLLJ
' I I \s1 r301(-0
COLORADO
Department of Public
Health et Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
11500 St
PO Box 758
Greeley, CO 80632
November 1, 2016
RECEIVED
NOV 0 7 2016
WELD COUNTY
COMMISSIONERS
Dear Sir or Madam:
On November 3, 2016, the Air Pollution Control Division will begin a 30 -day public notice period for
Whiting Oil and Gas Corporation - Razor 12F 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 Ft Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.govlcdphe
John W. Hickentooper, Governor Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
cC- PLC mm/TP) HLCPB),
(kAJCER/CH/ TM(C.K3
it/$/Ifo
2016-3487
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Whiting Oil and Gas Corporation - Razor 12F Production Battery - Weld County
Notice Period Begins: November 3, 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 12F Production Battery
Oil Et Gas well production facility
SENW Section 12 T10N R58W
Weld County
The proposed project or activity is as follows: Synthetic minor permits for a well production facility outside
of the ozone non -attainment area of Weld County. Applicant requests federally enforceable requirements
to attain synthetic minor status and to avoid NSPS OOOO requirements.
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 Permits 16WE0910, 16WE0911,
16WE0912, 16WE0914, and 16WE0915 have been filed with the Weld County Clerk's office. A copy of the
draft permits and the Division's analyses 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:
Andy Gruel
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
1 I hi COLORADO
Summary of Preliminary Analysis - NG RICE
Company Name Whiting Oil and Gas Corporation
Facility Name Razor 12F Production Battery
Facility Location SENW Section 12 T10N R58W
Facility Equipment ID ENG-01
Permit No.
AIRS
Review Date
Permit Engineer
16WE0910
123/9ECD/002
09/15/2016
Andy Gruel
Requested Action New permit/newly reported emission
Issuance No.
Emission Point Description
One (1) Caterpillar, Model G3516B, Serial Number JEF01595, natural gas -fired, turbo -charged, 4SLB reciprocating internal
combustion engine, site rated at 1084 horsepower. This engine shall be equipped with a selective catalytic oxidation catalyst.
Control credit is granted for CO. This engine powers a gas lift compressor.
Natural Gas Consumption
Requested (mmscf/yr)
51.58
Requested (mmscf/m)
4.38
Fuel Heat Value (btu/scf)
1486
BSCF (Btu/hp-hr)
8071
Emission Factor Sources
Hours of Operation
PTE Calculated at (hpy)
Permit limits calculated at (hpy)
8760
8760
Uncontrolled
Controlled
NOx
spec sheet says 0.5, applicant requests 1.0
0
VOC
spec sheet says 0.45, applicant requested C
0
CO
o
0
Formaldehyde
0.00
0
SOX
AP -42; Table 3.2-2 (7/2000); Natural Gas
No Control
TSP
AP -42; Table 3.2-2 (7/2000); Natural Gas
No Control
PM10
AP -42; Table 3.2-2 (7/2Q00); Natural Gas
No Control
PM2.5
AP -42; Table 3.2-2 (7/2000); Natural Gas
No Control
Other Pollutants
AP -42
AP -42
Point Summary of Criteria Emissions (t
Uncontrolled
Requested
Controlled
Requested
PTE
Proposed Control
Efficiency
NOx
10.5
10.5
10.5
0.0%
VOC
7.3
7.3
7.3
0.0%
CO
25.4
20.9
25.4
17.7%
SOX
0.0
0.0
0.0
0.0%
TSP
0.4
0.4
0.4
0.0%
PM10
0.4
0.4
0.4
0.0%
PM2.5
0.4
0.4
0.4
0.0%
Total HAPs*
0.0
0.0
4.6
0.0%
*Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de
minimus thresholds. PTE includes all HAPs calculated, even those below de minimus.
Point Summary of Hazardous Air Pollutants (lb/yr
HAP Name
Uncontrolled
Requested
Controlled
Requested
PTE
Proposed Control
Efficiency
Formaldehyde
7747
7747
7747
0.0%
Acetaldehyde
641
641
641
0.0%
Acrolein
394
394
394
0.0%
Methanol
*
192
0.0%
n -Hexane
*
*
85
0.0%
Benzene
*
*
34
0.0%
Toluene
*
*
31
0.0%
*Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED
UNCONTROLLED is greater than de minimus
Permitting Requirements
Ambient Air Impacts
No NAAQS violations expected (see details of modeling analysis)
Public Comment
Public Comment Required
MACT ZZZZ
New/Recon 4SLB over 500 HP located at a(n) Area Source
Reg 7 XVII.E
Standards (g/hp-hr)
NOx: 1.0 CO: 2.0 VOC: 0.7
Reg 7 XVI.B (Ozone NAA
requirements) applies?
No
MACT ZZZZ (area source)
Is this engine subject to MACT ZZZZ area
source requirements?
Yes
NSPS JJJJ
Is this engine subject to NSPS JJJJ?
Yes
Note: JJJJ requriements are not currently included as permit conditions because the reg has not
been adopted into Reg 6.
o
Comments/Notes
0
Summary of Preliminary Analysis - NG RICE
Company Name Whiting Oil and Gas Corporation
Facility Name Razor 12F Production Battery
Facility Location SENW Section 12 T1 ON R58W
Facility Equipment ID ENG-02
Permit No.
AIRS
Review Date
Permit Engineer
16WE0911
123/9ECD/003
09/15/2016
Andy Gruel
Requested Action New permit/newly reported emission
Issuance No. 1
Emission Point Description
One (1) Caterpillar, Model G3516B, Serial Number JEF01591, natural gas -fired, turbo -charged, 4SLB reciprocating internal
combustion engine, site rated at 1084 horsepower. This engine shall be equipped with a selective catalytic oxidation catalyst.
Control credit is granted for CO. This engine powers a gas lift compressor.
Natural Gas Consumption
Requested (mmscf/yr)
51.58
Requested (mmscf/m)
4.38
Fuel Heat Value (btu/scf)
1486
BSCF (Btu/hp-hr)
8071
Emission Factor Sources
Hours of Operation
PTE Calculated at (hpy)
Permit limits calculated at (hpy)
8760
8760
Uncontrolled
Controlled
NOx
spec sheet says 0.5, applicant requests 1.0
no control
VOC
spec sheet says 0.45, applicant requested C
no control
CO
manuf. Spec
SCO
Formaldehyde
manuf. spec
no control
SOX
AP -42; Table 3.2-2 (7/2000); Natural Gas
No Control
TSP
AP -42; Table 3.2-2 (7/2000); Natural Gas
No Control
PM 10
AP -42; Table 3.2-2 (7/2000); Natural Gas
No Control
PM2.5
AP -42; Table 3.2-2 (7/2000); Natural Gas
No Control
Other Pollutants
AP -42
AP -42
Point Summary of Criteria Emissions (t
Uncontrolled
Requested
Controlled
Requested
PTE
Proposed Control
Efficiency
NOx
10.5
10.5
10.5
0.0%
VOC
7.3
7.3
7.3
0.0%
CO
25.4
20.9
25.4
17.7%
SOx
0.0
0.0
0.0
0.0%
TSP
0.4
0.4
0.4
0.0%
PM10
0.4
0.4
0.4
0.0%
PM2.5
0.4
0.4
0.4
0.0%
Total HAPs*
0.0
0.0
4.6
0.0%
"Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de
minimus thresholds. PTE includes all HAPs calculated, even those below de minimus.
Point Summary of Hazardous Air Pollutants (lb/yr
HAP Name
Uncontrolled
Requested
Controlled
Requested
PTE
Proposed Control
Efficiency
Formaldehyde
7747
7747
7747
0.0%
Acetaldehyde
641
641
641
0.0%
Acrolein
394
394
394
0.0%
Methanol
*
*
192
0.0%
n -Hexane
*
*
85
0.0%
Benzene
*
*
34
0.0%
Toluene
*
*
31
0.0%
*Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED
UNCONTROLLED is greater than de minimus
Permitting Requirements
Ambient Air Impacts
Source is not required to model based on Division Guidelines
Public Comment
Public Comment Required
MACT ZZZZ
New/Recon 4SLB over 500 HP located at a(n) Area Source
Reg 7 XVII.E
Standards (g/hp-hr)
NOx: 1.0 CO: 2.0 VOC: 0.7
Reg 7 XVI.B (Ozone NAA
requirements) applies?
No
MACT ZZZZ (area source)
Is this engine subject to MACT 7777 area
Yes
source requirements?
NSPS JJJJ
II
Is this engine subject to NSPS JJJJ?
Yes
Note: JJJJ requriements are not currently included as permit conditions because the reg has not
been adopted into Reg 6.
Comments/Notes
0
Colorado Air Permitting Project
Version No. 1.00
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer:
Package It:
Received Date:
Review Start Date:
Section 01 - Facility Information
Andy Gruel
352556
8/22/2016
9/14/2016
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?
non -attainment area?
❑ Carbon Monoxide (CO)
Section 02 - Emissions Units In Permit Application
Whiting Oil and Gas Corporation
123
9ECD
Razor 12F Production Battery
SENWSection 12 T10N R58W
Exploration & Production Welk; Pad
Oil & Natural Gas Production: & Process{
No
❑ Particulate Matter (PM)
O Ozone (NOx & VOC)
AIRs Point #
Emissions Source Type
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering Remarks
001
-
-
Yes ; .
16WE0909.XP
-
-
Nt)
APEN Required /"
Permit Exempt
--
Fugitive dust from haul
roads. Emissios below
permit thresholds for TSP,
PMtn RM7.S
002
uGasermit
Natral RICE
YesP
16WE0910
CP1
Yes
krtiI
Issuance
003
Itrzrak Gas RIFE ,":
j ;
Yes °
16WE0911
CP1
Yes
Permlt initial
Issuance
004
Produced water Storage Tank
Yes
16W E0912
CP1
Y g
Permit Initial
005
Hydrocarbon Liquid Loading
-
No -;,
16WE0913.XP
Nd
ADEN Required
Permit Exempt
XP b/c loading less than
238 bbl/day of crude oil
006
Crude Oil Storage Tank
Yes
16W E0914
CP1
Yes
Permit Initial
Issuance
007
Se aratorVent`ing
�:.
Yes;..
16WE0915
CPI
Yes
Permitt.Initial
Issuance
Section 03 - Description of Project
Applicant requests a synthetic minor permit for awell production facility outside of the ozone non -attainment area. Applicant requests federally
enforceable requirements to attain synthetic minor status and to avoid 0000 requirements.
Section 04 - Public Comment Requirments
Is Public Comment Required?
If yes, why?1
Requestin
Section 05 - Ambient Air Impact Analysis Requirements
Was a quantitative modeling analysis required?2 No '
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? Yes
If yes, explain what programs and which pollutants here:
Title V Operating Permits (OP) VOC, HAPs (total, n -hexane, benzene, toluene)
Is this stationary source a major source?
If yes, explain what programs and which pollutants here:
Condensate Storage Tank(s) Emissions Inventory
Issuance Date: December 30, 2015
Section 01- Adminstrative Information
Facility AIRs ID:
123
County
9607 004
Plant Point
16WE0912 CP1
Section 02 - Eouipment Description Details
Detailed Emissions Unit
Description:
Eight (8) 400 -bbl fixed -roof aboveground,
Emission Control Device VRI.i with backup itareibntrol; assuming 7% VRO downtime.
Description: efficiency of Rare during VRU downtime.
Requested Overall VOC & HAP Control
Efficiency %: 99.5108 100% control when VRU is active; 7% VRU downtime and 3% downstream gas
plant downtime; 95% control during downtime; see calm below
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Produced Water Throughput =
Requested Permit Limit Throughput =
Potential to Emit (PTE) Produced Water
Throughput=
Secondary Emissions - Combustion Device(s)
High heat value of waste gas =
Low heat value of waste gas =
Volume of waste gas emitted per BBL of liquids
produced = p.117" scf/bbl
Actual heat content of waste gas routed to combustion device
Request HHV heat content of waste gas routed to combustion device =
Potential to Emit (PTE) Filly heat content of waste gas routed to combustion device =
Request LHV heat content of waste gas routed to combustion device =
Potential to Emit (PTE) LHV heat content of waste gas routed to combustion device =
Barrels (bbl) per year
Barrels (bbl) per year
Barrels (bbl) per year
Section 04 - Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
1221`. Btu/scf
1113 Btu/scf
em downtime, and 95%control
Actual Produced Water Throughput While Emissions Controls Operating =
HHV used for NOx calculation
LHV used for CO calculation
643,211 scf/yr / 5475000 bbl/yr
0 MMBTU per year
785 MMBTU per year
785 MMBTU per year
716 MMBTU per year
716 MMBTU per year
Pollutant
PM2.5
Produced Water Storage Tanks
Uncontrolled E.F.
(Ibs/bbl Produced
Water
Throughput)
Controlled E.F.
(Ibs/bbl
Produced
Water
Throughput)
Control Device
Uncontrolled E.F.
(Ibs/MMBtu
waste heat
combusted)
Uncontrolled
E.F. (Ibs/bbl
Produced
Water
Throughput)
0.0000
MINNEMMIE
emsrrEmii
0.0001
0,00023
wools
0.000027
0.000038
0.000001
0.000001
0.0000001
0.0000001
0.000001
0.0000002
0.0000
0.000010
Emissions Factor Source Citation
.hill'\\(
0.000041
hill Lull'
\'.11lW.Ill\
\llll�.11l\` t
\Mill i\X71O- -
Section 95 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
PM10
PM2.5
NOx
VOC
CO
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.027
0.0
0.0
75.3
75.3
0.37
0.0
0.0
0.1
0.1
0.111
0.0
0.0
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
6.3E-01
6.3E-01
• 3.1E-03
0.0E+00
0.0E+00
4.4E-01
4.4E-01
2.1E-03
0.0E+00
0.0E+00
4.4E-02
- 4.4E-02
2.1E-04
0.0E+00
0.0E+00
7.4E-02
7.4E-02
3.6E-04
0.0E+00
0.0E+00
8.2E-01
8.ZE-01
4.0E-03
0.0E+00
0.0E+00
1.0E-01
1.0E-01
5.1E-04
0.0E+00
0.0E+00
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, 8
Source requires a permit
Regulation 7, Section XVII.B, C.1, C.3
Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3, a
Regulation 7, Section XVII.C.2
Storage tank is subject to Regulation 7, Section XVII.C.2, as provide
Regulation 6, Part A, NIPS Subpart 0000
Storage Tank is not subject to NSPS 0000
(See regulatory applicability worksheet for detailed analysis)
Uncontrolled PTE (Ib/yr)
1259
876
88
148
1643
208
Controllef PTE
(Ib/yr)
6.2
4.3
0.4
0.7
8.0
1.0
2 of 3 K:\PA\2016\16WE0912.CP1.xlsm
Condensate Storage Tank(s) Emissions Inventory
Issuance Date: December 30, 2015
Section 07 - Initial and Periodic Sampling and Testing Reouirements
123-9ECD-004
Does the company use a site specific emisions factor to estimate emissions?
If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid water sample drawn
at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered
representative which generally means site -specific and collected within one year of the application received date.
However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to
use an older site -specific sample.
If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor. See PS Memo 14-03, Questions 5.9 and 5.12 for additional guidance on testing.
16WE0912 CP1
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain and intial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling
Section 08 - Technical Analysis Notes
Applicant requests a federally -enforceable control requirement for the tanks to reduce VOC emissions to less than 6.tpy per vessel, by using two VRUs to collect the vapors to gas gathering, Owing VRU>'.
downtime (assumed 7%) or downstream gas plant downtime (3%), the vapors will be sent to the Low Pressure. Backup/Emergency Flare (FLR-02) with a manufacturer's guaranteed control efficiency of
98% and with. 95% control efficiency assumed for emissions estimates, The VRU downtime and gas gathering downtimes are multi plied together. Overall, this leads to a control efficiency of:
(1-VRU downtime%) * (1 -Gathering system downtime %) = (1-.07)*(1-03) = 90.21 %of vapors aresent to gathering system. a.
Vapors not sent to gathering system: 1-.9021= 6.79%.
Of that 9.79%, the flare controls 95%. 1-: (0.0979 "` (1-0,55))-= 99.5105 %.
Applicant used the results of a flash liberation analysis to determine the gas to
These results were combined to arrive at the emission factors listed above.
Section 09 - Inventory SCC Coding and Emissions Factors
ions. Applicant also used EPA Tanks 4.094 to model tank working and breathing emissions.:.
AIRS Point a Process 8 SCC Code
004 01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses
Uncontrolled
Emissions
Pollutant Factor Control % Units
NOx 0.0002 0 lb/1,000 gallons liquid throughput
VOC 0.6548 100 lb/1,000 gallons liquid throughput
CO 0.0010 0 lb/1,000 gallons liquid throughput
Benzene 0.0055 100 lb/1,000 gallons liquid throughput
Toluene 0.0038 100 lb/1,000 gallons liquid throughput
Ethylbenzene 0.0004 100 lb/1,000 gallons liquid throughput
Xylene 0.0006 100 lb/1,000 gallons liquid throughput
n -Hexane 0.0071 100 lb/1,000 gallons liquid throughput
224 TMP 0.0009 100 lb/1,000 gallons liquid throughput
3 of 3
K:\PA\2016\16W E0912.CP1.xlsm
Colorado Air Permitting Project
Version No. 1.00
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer:
Package #:
Received Date:
Review Start Date:
Section 01 - Facility Information
Andy Gruel
352556.
8/22/2016
9/14/2016
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 non -attainment area?
If yes, for what pollutant? ['Carbon Monoxide (CO)
Whiting. Oil and Gas Corporation
123
9ECD
Razor 12F Production Battery
SENW Section 12 T1ON R58W
Exploratiorri:&Production Well Pad.,....
Oil & Natural Gas. Productions& Processn
Section 02 - Emissions Units In Permit Application
❑ Particulate Matter (PM) O Ozone (Nox & VOC)
AIRs Point #
Emissions Source Type
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering Remarks
001
..
Other tExplain)
....
Yes
16WE0909.XP
No
-�
ADEN RE €#1Ted
Permit Bier*
Fugitive dust from haul
roads. Emissions below
permit thresholds for TSP,
PM1n PM9 S
002
:Natural Gas RICE
Yes " '
16WE0910 E0910
CPI
Yes
°. Permi j tial
lssuuance
003
l tural Gas RICE
<..: ...'<ltsrfcai
yes
16WE0911
CPI
Yes
F,ietTpk�j�"l,
g :R ;,-
004
Produced at r'Storage`Cank
Yes
16WE0912
CPI
Yes
Pitt
Issuance--
QOS
. �
FYydrocarban Liquatd l caadltrg :
;' . No
16WE0913.XP
tklo
ADEN Required/
Permit Exempt
XP bfc loading less than
238 bbljday of crude oil
006
CrjtdeQ to 4g.:40
Yes
16WE0914
CPI
Yes
P Initial
R uance
007
Separator erat€ra&:. ;
Y'es ' ;-
16WE0915
CPI
Perttiatt:lr}ttta
Issuance.:.
Section 03 - Description of Project
Applicant requests a synthetic minor permit for a well production facility outside of the ozone non -attainment area. Applicant requests federally
enforceable requirements to attain synthetic minor status and to avoid 0000 requirements.
Section 04 - Public Comment Requirments
Is Public Comment Required?
If yes, why?'
Requ
yntq
is MinorP
Section 05 - Ambient Air Impact Analysis Requirements
Was a quantitative modeling analysis required?2 No
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? No,
Is this stationary source a synthetic minor? Yes
If yes, explain what programs and which pollutants here:
Title V Operating Permits (OP) : VOC, HAPs (total, n-hexane,benzene, toluene)
Is this stationary source a major source?
If yes, explain what programs and which pollutants here:
Crude Oil Storage Tank(s) Emissions Inventory
Section 01- Adminstrative Information
'Facility AIRs ID:
16WE0914 CP1
Section 02 - Equipment Description Details
123
County
9ECDI
Plant
Point
Detailed Emissions Unit
Description:
Sixteen (16)400 -barrel fixed -roof atmospheric crudeoil storage vessels connected via liquid manRold
lency of
Emission Control Device VRU with hockupflaresontrot assuming 7% VRU downtime and 3% gathering system downtime, and 93%.:
Description: Hare during VRU downtime
Requested Overall VOC & HAP Control
Efficiency %: 99.5105 100% control when VRU is active; 7% VRU downtime and 3% downstream gas
plant downtime; 95% control during downtime; see calcs below
Section 03- Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Throughput =
Requested Permit Limit Throughput =
Potential to Emit (PTE) Throughput =
Barrels (bbl) per year
Barrels (bbl) per year
Barrels (bbl) per year
Secondary Emissions - Combustion Device(s)
HHV Heat content of waste gas= 2722Btu/scf
LHV heat content of waste gas= 2508 Btu/scf
Volume of waste gas emitted per BBL of liquids
produced = 5.66? scf/bbl
Actual heat content of waste gas routed to combustion device
Request HHV heat content of waste gas routed to combustion device =
Potential to Emit (PTE) HHV heat content of waste gas routed to combustion device =
Request LHV heat content of waste gas routed to combustion device =
Potential to Emit (PTE) LHV heat content of waste gas routed to combustion device =
Section 04- Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
Actual Crude Oil Throughput While Emissions Controls Operating =
vapor flow 8,672,948 scf/yr
0 MMBTU per year
23,608 MMBTU per year
23,608 MMBTU per year
21,752 MMBTU per year
21,752 MMBTU per year
Crude Oil Storage Tanks
Control Device
Pollutant
PM10
PM2.5
NOx
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
Uncontrolled E.F. Controlled E.F.
(Ibs/bbl Crude Oil (lbs/bbl Crude
Throughput) Oil Throughput)
Section 05 - Emissions Inventory
Uncontrolled E.F
(Ibs/MMBtu
waste heat
combusted)
Uncontrolled
E.F. (Ibs/bbl
Crude Oil
Throughput)
Emissions Factor Source Citation
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
PM10
0.0
0.0
0.0
0.0
0.0
PM2.5
0.0
0.0
0.0
0.0
0.0
NOx
0.8
0.8
0.80
0.0
0.0
VOC
4924.8
4924.8
24.11
0.0
0.0
CO
3.4
3.4
3.37
0.0
0.0
Potential to Emit
Requested Permit Limits
Actual Emissions
Hazardous Air Pollutants
Uncontrolled
Uncontrolled Controlled
Uncontrolled Controlled
(tons/year)
(tons/year) (tons/year)
(tons/year) )tons/year)
Benzene
2.2E+01
2.2E+01
1.1E-01 -
0.0E+00
0.0E+00
Toluene
2.0E+01
2.0E+01
9.9E-02
0.0E+00
0.0E+00
Ethylbenzene
3.4E+00
3.4E+00
1.7E-02
0.0E+00
0.0E+00
Xylene
8.0E+00
8.0E+00
3.9E-02
0.0E+00
0.0E+00
n -Hexane
1.4E+02
1.4E+02
6.9E-01
0.0E+00
0.0E+00
224 TMP
3.1E+00
3.1E+00
1.5E-02
0.0E+00
0.0E+00
Section 06- Regulatory Summary Ana sis
Regulation 3, Parts A,B
Source requires a permit
Regulation 7, Section XVII.B, C.1, C.3
Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3, as provided
Regulation 7, Section XVII.C.2
Storage tank is subject to Regulation 7, Section XVIl.O2, as provided below
Regulation 6, Part A, NIPS Subpart Kb
Storage Tank is not subject to NSPS Kb
Regulation 6, Part A, NSPS Subpart 0000
Storage Tank is not subject to NSPS 0000
Regulation 8, Part E, MACT Subpart HH
Storage Tank is not subject to MACT HH
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
Uncontrolled PTE (lb/yr)
43997
40318
6745
16097
280079
6285
Controlled PTE
(Ib/yr)
215
197
33
79
1371
31
2 of 3
K:\PA\2016\16 W E0912.CP1.xlsm
Crude Oil Storage Tank(s) Emissions Inventory
Does the company use the state default emissions factors to estimate emissions?
If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 20 tons VOC per year?
If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03
Does the company use a site specific emisions factor to estimate emissions?
If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample of crude oil drawn at the
facility being permitted?
If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03.
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain and intial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling
Section 08 - Technical Analysis Notes
Applicant requestea federally�enforceable contro( requirement forthe tanks to reduce VOC emissions to less than 6.tpy per vessel, by using twoVRUs to collectthe vapors togas gathering.
(assumed7%) or downstream gas plant downtime (3%), the vapors mill besent to the Low Pressure Backup/Emergency Flare (FLO 02) with a mahufecturer'sguaranteed control efficiency o
control efficlencyassumed for: emissionseslimates. The VRUdowntlme and ges gathering dpwntimesare multiplied together Overall, this leadsto a control<efficiency of:
VRU downtme Pc) • (1 Gathers g system dbwnttme %) = (1-.07)'(1-03) = 90.2i %of vapors are sentta gathering system.
Vapors not sent to gathering system: 1-,90211 9,79%.
Of that 9.79%,..tlte flare controls 95%. 1- (0.0979 • (1-0.96)) = 99.310s%.
9 5105 %.
Working, breathing, and flashing emissions were modeled usingAspen HYSiS,Tanks 4_09d, artd a
The gas heat content was 2722'. Btu/scf for NOx emissions,. and 2508 Btu/scf for CO emissions.
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Points
Process # SCC Code
006 01
1
Definitions for Drop Down Lists
Storage Tank Emissions Factor Options
State Default E.F. (includes flash)
Other (Documented in Technical Analysis Notes)
Site Specific E.F. (includes flash)
Site Specific EPA TANKS E.F. Working and Breathing Only
Qualifiers
No
Yes
Not applicable - stabilized tank
Control Devices
Enclosed Flare
Open Flare
Vapor Recovery Unit (VRU)
Control Device Combustion Emissions Factor Options
AP -42 Chapter 13.5 Industrial Flares (NOx/CO)
TNRCC Flare Emissions Guidance (NOx/CO)
AP -42 Table 1.4-2 (PM10/PM.2.5)
SCC Codes - Storage Tank Emissions
4-04-003-12 Fixed Roof Tank, Crude Oil, working+breathing+flashing losses
4-04-003-02 Fixed Roof Tank: Working & Breathing Losses
4-04-003-22 External Floating Roof Tank, Crude Oil, working+breathing+flashing
4-04-003-06 External Floating Roof Tank: Working and Breathing Losses
4-04-003-32 Internal Floating Roof Tank, Crude Oil, working+breathing+flashing
4-04-003-07 Internal Floating Roof Tank: Working and Breathing Losses
SCC Codes - Flaring Combustion Emissions
3-10-001-60 Flares
Pollutant
NOx
VOC
CO
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
Uncontrolled
Emissions
Factor
0.02
153.0
0.10
0.68
0.63
0.10
0.25
4.35
0.10
g VRU-downtime
and with 95%
Control% Units
0 lb/1,000 gallons crude oil throughput
100 lb/1,000 gallons crude oil throughput
0 lb/1,000 gallons crude oil throughput
100 lb/1,000 gallons crude oil throughput
100 lb/1,000 gallons crude oil throughput
100 lb/1,000 gallons crude oil throughput
100 lb/1,000 gallons crude oil throughput
100 lb/1,000 gallons crude oil throughput
100 lb/1,000 gallons crude oil throughput
3 of 3
K:\PA\2016\16W E0912.CP1.xlsm
Colorado Air Permitting Project
Version No. 1.00
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer:
Package #:
Received Date:
Review Start Date:
Section 01 - Facility Information
Andy Gruel
352556
8/22/2016
9/14/2016
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 non -attainment area? Na
If yes, for what pollutant? ❑ Carbon Monoxide (CO) El Particulate Matter (PM)
Whiting Oil and Gas Corporation
123
9ECD
Razor 12F Production Battery
SENW Section 12 T1ON RSBW
Exploration & Production Well Pad
O€f & fafuraUGas-Production;& Processing
Section 02 - Emissions Units In Permit Application
El Ozone (NOx & VOC)
AIRs Point #
Emissions Source Type
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering Remarks
001
_
other {i 7€ffiain;
.;••,•i .. �,-•¢;:; ,•:i,-
Yes
16WE0909.XP
�I
-,,,
APEN aired/
Permit E9tempt :
.••.. .nay:
Fugitive st om haul
roads. Emissions mr below
permit thresholds for TSP,
PMtn PM? -S
002
Natural a€RiCE
Yes
16WE0910
CP1
Yes
Permit Irti;tai
Issuance
003
Natural Gas RICE
Yes
16WE0911
CP1
`e
Permit Initial
Issuance
004
Produced W Storage Tank
Yep -
16WE0912
CPi
Permit Initial
Issuance
005
Hydrocarbon Liquid Loading
E+tCt
16WE0913.XP
APEN Required /'
Permit Exempt
XP bit loading less than
238 bbl/day of crude oil
006
Crude:Oil storage Tank
Yes
16WE0914
CP1,.'
Permit Initial
Issuance
007
Separator;Venlietg
YU
16WE0915
CPi
yep
PEfrmit Iriiti
Isstliaarle�
Section 03 - Description of Project
Applicant requests a synthetic minor permit for a well production facility outside of the ozone non -attainment area. Applicant requests federally
enforceable requirements to attain synthetic minor status and to avoid 0000 requirements.
Section 04 - Public Comment Requirments
Is Public Comment Required?
If yes, why?"
R+
Section 05 - Ambient Air Impact Analysis Requirements
Was a quantitative modeling analysis required?'
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
r Per
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:
Title V Operating Permits (OP) : VOC, HAPs (total, n -hexane, benzene, toluene)
Is this stationary source a major source?
If yes, explain what programs and which pollutants here:
N
YE
Produced Natural Gas Venting/Flaring Preliminary Analysis
Colorado Department of Public Health and Environment
Air Pollution Control Division
123-9ECD-007 16WE0915 CP1 APEN rec'd 8/22/16
Point Description: Venting and flaring from four gas/liquid separators during periods of gathering system downtime.
Emission Calculation Method
EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3)
Ex=Q`MW*Xx/C
Ex = emissions of pollutant x
Q = Volumetric flow rate/volume of gas processed
MW = Molecular weight of gas = SG of gas * MW of air
Xx = mass fraction of x in gas
C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm
Throughput (Q)
MW
45.3 MMscf/yr
26.884 lb/lb-mol
5171.2 scf/hr
0.124 MMscf/d
3.85 MMscf/mo
mole %
MW
Ibx/Ibmol
mass fraction
E
lb/hr
lb/yr
tpy
Helium
0
4.0026
0.000
0.000
Helium
0.0
0
0.00
CO2
3.44
44.01
1.514
0.056
CO2
20.6
180763
90.38
N2
1.119
28.013
0.313
0.012
N2
4.3
37427
18.71
methane
60.762
16.041
9.747
0.363
methane
132.8
1163763
581.88
ethane
13.125
30.063
3.946
0.147
ethane
53.8
471121
235.56
propane
12.389
44.092
5.4626
0.203
propane
74.5
652224
326.11
isobutane
1.354
58.118
0.7869
0.029
isobutane
10.7
93957
46.98
n -butane
4.726
58.118
2.7467
0.102
n -butane
37.4
327948
163.97
isopentane
0.898
72.114
0.6476
0.024
isopentane
8.8
77321
38.66
n -pentane
1.165
72.114
0.8401
0.031
n -pentane
11.5
100310
50.16
cyclopentane
0.284
70.13
0.1992
0.007
cyclopentane
2.7
23781
11.89
n -Hexane
0.234
86.18
0.2017
0.007501
n -Hexane
2.75
24078
12.04
cyclohexane
0.0980
84.16
0.0825
0.003
cyclohexane
1.1
9848
4.92
Other hexanes
0.093
86.18
0.0801
0.003
Other hexanes
1.1
9570
4.78
heptanes
0.183
100.21
0.1834
0.007
heptanes
2.5
21896
10.95
methylcyclohexane
0.027
98.19
0.0265
0.001
methylcyclohexane
0.4
3165
1.58
224-TMP
0.018
114.23
0.0206
0.000765
224-TMP
0.3
2455
1.23
Benzene
0.026
78.12
0.0203
0.000756
Benzene
0.3
2425
1.21
Toluene
0.012
92.15
0.0111
0.000411
Toluene
0.2
1320
0.66
Ethylbenzene
0.003
106.17
0.0032
0.000118
Ethylbenzene
0.0
380
0.19
Xylenes
0.014
106.17
0.0149
0.000553
Xylenes
0.2
1775
0.89
C8+ Heavies
0.03
121.24
0.0364
0.001
C8+ Heavies
0.5
4343
2.17
VOC mass fraction:
26.884
Notes
Mole %, MW, and mass fractions from site -specific gas analysis sampled 6/14/16.
Emissions are based on 8760 hours of operation per year.
MW of C8+ was assumed by applicant and I accepted it.
0.4227 Total VOC Emissions (Uncontrolled)
annual limit assuming 95% control
monthly limit assuming 95% control (lb/mo.)
678.4
33.92
5761.7
Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment
Air Pollution Control Division
Flaring Information
Equipment Description
Flare combusts separator gas during gathering system downtime.
Manufacturer
Model
Serial Number
Pilot Gas Hi•h
Pilot Gas Low Heatin
Se.arator Gas
Se.arator Gas
Pilot Gas Flow Rate
Pilot Gas Throu.h.ut
Pilot Gas Throu •h.ut
Se.arator Gas Throu
Se.arator Gas Throu
H
Low
h
Heating Value
Value (for CO)
Heating Value
Heating Value
(@ HHV)
(@ LHV)
hput (@ HHV)
hput (@ LHV)
Flare Industries
SFVP
824
2516
2315
1486
1355
1.54
Btu/scf
Btu/scf
Btu/scf
Btu/scf
MMscf/yr
MMBtu/yr
MMBtu/yr
MMBtu/yr
MMBtu/yr
3874.64
3565.1
67315.8
61381.5
Combustion emission factor source: AP -42: Chapter 13.5
0.068
lb NOX/MMBtu
tpy NOX
0.31
lb CO/MMBtu
tpy CO
2.42
Emissions Summary
10.07
2.42
tpy NOX
Uncontrolled/PTE
10.07
tpy CO
678.4
tpy VOC
Controlled
33.92
tpy VOC
123-9ECD-007
16WE0915 CP1
APEN rec'd 8/22/16
NOx emissions based on HHV.
CO emissions based on LHV.
Uncontrolled
Total (Ib/yr)
Reportable?
Controlled Total
(lb/yr)
Benzene
2425
Yes
121
Toluene
1320
Yes
66
Ethylbenzene
380
Yes
19
Xylenes
1775
Yes
89
n -hexane
24078
Yes
1204
224-TMP
2455
Yes
123
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 3
Part A:
An APEN is required for this source because uncontrolled VOC emissions exceed
two tons per year in an attainment area.
Part B:
A permit is required for this source because uncontrolled VOC emissions from this
facility exceed five tons per year in an attainment area.
This source is not subject to Section III.D.2 (Minor Source RACT) because it is not
located in a nonattainment area.
Is public comment
required?
Public Comment Required
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, XVII.B.2
Produced Natural Gas Venting/Flaring Preliminary Analysis
SCC Coding:
Emission Factors for Permit
Uncontrolled
31000205
NOX
106.9
lb/MMscf natura
CO
444.4
lb/MMscf natura
VOC
29951
lb/MMscf natura
Benzene
53.535
lb/MMscf natura
Toluene
29.146
lb/MMscf natura
Ethylbenzene
8.3951
lb/MMscf natura
Xylenes
39.1771
lb/MMscf natura
n -Hexane
531.53
lb/MMscf natura
224-TMP
54.1945
lb/MMscf natura
Controlled
NOX
106.9
lb/MMscf natural
CO
444.4
lb/MMscf natura
VOC
1498
lb/MMscf natura
b/MMsct natura
Benzene
2.6768
1 oluene
1.4573
b/MMsct natura
Ethylbenzene
0.4198
b/MMsct natura
Xylenes
1.9589
b/MMsct natura
n -Hexane
26.5763
b/MMsct natura
224- I MI-'
2.7097
b/MMsct natura
gas vented
gas vented
gas vented
gas vented
gas vented
gas vented
gas vented
'gas vented
gas vented
gas vented
gas vented
gas vented
gas vented
gas vented
gas vented
gas vented
gas vented
gas vented
Colorado Department of Public Health and Environment
Air Pollution Control Division
123-9ECD-007
16WE0915 CP1
APEN rec'd 8/22/16
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
PERMIT NO:
16WE0910
CONSTRUCTION PERMIT
1876
Issuance 1
DATE ISSUED:
ISSUED TO: Whiting Oil and Gas Corporation
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the Razor 12F Production Battery, located in SENW of Section
12 of T1 ON 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 (1) Caterpillar, Model G3516B, Serial Number
JEF01595, natural gas -fired, turbo -charged, 4SLB
reciprocating internal combustion engine, site rated at 1084
horsepower at 1100 RPM. This engine shall be equipped
with a selective catalytic oxidation catalyst. Control credit is
granted for CO. This engine powers a gas lift compressor.
This engine may be replaced with 4nother engine in accordance with the temporary engine
replacement provision or with another Caterpillar G3516B engine in accordance with the
permanent replacement provision of the Alternate Operating Scenario (AOS), included in
this permit as Attachment A.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO
AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS
INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. This construction permit represents final permit approval and authority to operate this
emissions source. Therefore, it is not necessary to self -certify. (Regulation 3, Part B,
Section III.G.5).
EMISSION LIMITATIONS AND RECORDS
2. 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)
AIRS ID: 123/9ECD/002 Page 1 of 13
NGEngine Version 2014-1
Monthly Limits:
Public Health and Environment
Air Pollution Control Division
Facility
Equipment ID
AIRS
Point
Pounds per Month
Emission Type
NO X
VOC
CO
ENG-01
002
1779
1245
3557
Point
The owner or operator shall calculate monthly emissions based on the calendar month.
Facility -wide emissions of each individual hazardous air pollutant shall be less than
1,359 lb/month.
Facility -wide emissions of total hazardous air pollutants shall be less than 3,398
lb/month.
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission Type
NO X
VOC
CO
ENG-01
002
10.5
7.4
21.0
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.
During the first twelve (12) months of operation, compliance with both the monthly and
annual emission limitations is required. After the first twelve (12) months of operation,
compliance with only the annual limitation is required.
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.
3. 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
Selective catalytic oxidation catalyst
CO
AIRS ID: 123/9ECD/002
Page 2 of 13
Public Health and Environment
Air Pollution Control Division
PROCESS LIMITATIONS AND RECORDS
4. 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
Monthly Limit
(31 days)
ENG-01
002
Consumption of natural gas as a fuel
51.58
MMscf/yr
4.831
MMscf/month
Fuel consumption shall be measured by one of the following methods: individual engine
fuel meter; facilty-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.
During the first twelve (12) months of operation, compliance with both the monthly and
annual throughput limitations is required. After the first twelve (12) months of operation,
compliance with only the annual limitation is required.
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
5. 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)
6. 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.)
7. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
OPERATING & MAINTENANCE REQUIREMENTS
8. 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.)
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Public Health and Environment
Air Pollution Control Division
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
9. This source is not required to conduct initial testing, unless otherwise directed by the
Division or other state or federal requirement.
Periodic Testing Requirements
10. 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
11. 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.
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.
12. 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
AIRS ID: 123/9ECD/002 Page 4 of 13
Public Health and Environment
Air Pollution Control Division
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
13. 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.
14. 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.
15. 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.
16. 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.
17. 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.
18. 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.
19. 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.
AIRS ID: 123/9ECD/002 Page 5 of 13
By:
Andy Gruel, P.E.
Permit Engineer
Public Health and Environment
Air Pollution Control Division
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Whiting Oil and Gas Corporation.
AIRS ID: 123/9ECD/002 Page 6 of 13
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
Emission
Rate
(lb/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (Ib/yr)
002
Formaldehyde
50000
7747
Yes
7747
Acetaldehyde
75070
641
Yes
641
Acrolein
107028
394
Yes
394
5) The emission levels contained in this permit are based on the following emission factors:
Point 002:
CAS
Pollutant
Emission
Uncontrolled
Ib/MMBtu
Factors -
g/bhp-hr
Emission
Controlled
lb/MMBtu
Factors —
g/bhp-hr
NOx
0.273
1.0
0.273
1.0
CO
0.664
2.43
0.546
2.0
VOC
0.191
0.7
0.191
0.7
50000
Formaldehyde
0.101
0.37
0.101
0.37
75070
Acetaldehyde
0.00836
0.0169
0.00836
0.0169
107028
Acrolein
0.00514
0.0074
0.00514
0.0074
Emission factors are based on a Brake -Specific Fuel Consumption Factor of 8071 Btu/hp-hr, a
site -rated horsepower value of 1084 hp, and a fuel heat value of 1486 Btu/scf.
Emission Factor Sources:
CAS
Pollutant
Uncontrolled EFSource
Controlled EF Source
NOx
Manufacturer's Spec
No Control
CO
Manufacturer's Spec
Manufacturer's Spec
VOC
Manufacturer's Spec
No Control
50000
Formaldehyde
Manufacturer's Spec
No Control
75070
Acetaldehyde
AP -42 Table 3.2-2 (7/2000)
No Control
AIRS ID: 123/9ECD/002
Page 7 of 13
Public Health and Environment
Air Pollution Control Division
CAS
Pollutant
Uncontrolled EFSource
Controlled EF Source
107028
Acrolein
AP -42 Table 3.2-2 (7/2000)
No Control
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the
most recent 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 engine is subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for
Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal Register
posting — effective March 18, 2008). This rule has not yet been incorporated into Colorado Air Quality
Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA
website at: http://www.epa.qov/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). A copy of the complete subpart is
available on the EPA website at: http://www.epa.qov/ttn/atw/area/fr18ia08.pdf Additional information
regarding area source standards can be found on the EPA website at:
http://www. epa. qov/ttn/atw/area/area rules. htm I
9) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, HAPs (total, benzene, toluene, n -hexane)
PSD
Synthetic Minor Source of: VOC
MACT ZZZZ
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 XXXXXX
AIRS ID: 123/9ECD/002
Page 8 of 13
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: 123/9ECD/002 Page 9 of 13
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.
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Public Health and Environment
Air Pollution Control Division
For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or
concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement
engine will be subject to, the results of the test shall be converted to the appropriate units as described in
the above -mentioned Portable Analyzer Monitoring Protocol document.
If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the
absence of credible evidence to the contrary, the source may certify that the engine is in compliance with
both the NOX and CO emission limitations for the relevant time period.
Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if
the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission
limitations, the engine will be considered to be out of compliance from the date of the portable analyzer
test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or
until the engine is taken offline.
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: 123/9ECD/002 Page 11 of 13
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: 123/9ECD/002 Page 12 of 13
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: 123/9ECD/002 Page 13 of 13
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
PERMIT NO:
16WE0911
CONSTRUCTION PERMIT
Issuance 1
DATE ISSUED:
ISSUED TO: Whiting Oil and Gas Corporation
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the Razor 12F Production Battery, located in SENW of Section
12 of T1 ON R58W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment ID
AIRS
Point
Description
ENG-02
003
One (1) Caterpillar, Model G3516B, Serial Number
JEF01591, natural gas -fired, turbo -charged, 4SLB
reciprocating internal combustion engine, site rated at 1084
horsepower at 1100 RPM. This engine shall be equipped
with a selective catalytic oxidation catalyst. Control credit is
granted for CO. This engine powers a gas lift compressor.
This engine may be replaced with another engine in accordance with the temporary engine
replacement provision or with another Caterpillar G3516B engine in accordance with the
permanent replacement provision of the Alternate Operating Scenario (AOS), included in
this permit as Attachment A.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO
AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS
INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. This construction permit represents final permit approval and authority to operate this
emissions source. Therefore, it is not necessary to self -certify. (Regulation 3, Part B,
Section III.G.5).
EMISSION LIMITATIONS AND RECORDS
2. 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)
AIRS ID: 123/9ECD/003 Page 1 of 13
NGEngine Version 2014-1
Monthly Limits:
Public Health and Environment
Air Pollution Control Division
Facility
Equipment ID
AIRS
Point
Pounds per Month
Emission Type
NO X
VOC
CO
ENG-02
003
1779
1245
3557
Point
The owner or operator shall calculate monthly emissions based on the calendar month.
Facility -wide emissions of each individual hazardous air pollutant shall be less than
1,359 lb/month.
Facility -wide emissions of total hazardous air pollutants shall be less than 3,398
lb/month.
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission Type
NO X
VOC
CO
ENG-02
003
10.5
7.4
21.0
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.
During the first twelve (12) months of operation, compliance with both the monthly and
annual emission limitations is required. After the first twelve (12) months of operation,
compliance with only the annual limitation is required.
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.
3. 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-02
003
Selective catalytic oxidation catalyst
CO
AIRS ID: 123/9ECD/003
Page 2 of 13
Public Health and Environment
Air Pollution Control Division
PROCESS LIMITATIONS AND RECORDS
4. 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
Monthly Limit
(31 days)
ENG-02
003
Consumption of natural gas as a fuel
51.58
MMscf/yr
4.831
MMscf/month
Fuel consumption shall be measured by one of the following methods: individual engine
fuel meter; facilty-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.
During the first twelve (12) months of operation, compliance with both the monthly and
annual throughput limitations is required. After the first twelve (12) months of operation,
compliance with only the annual limitation is required.
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
5. 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)
6. 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.)
7. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
OPERATING & MAINTENANCE REQUIREMENTS
8. 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.)
AIRS ID: 123/9ECD/003 Page 3 of 13
Public Health and Environment
Air Pollution Control Division
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
9. This source is not required to conduct initial testing, unless otherwise directed by the
Division or other state or federal requirement.
Periodic Testing Requirements
10. 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
11. 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.
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.
12. 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
AIRS ID: 123/9ECD/003 Page 4 of 13
Public Health and Environment
Air Pollution Control Division
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
13. 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.
14. 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.
15. 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.
16. 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.
17. 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 shalP 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.
18. 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.
19. 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.
AIRS ID: 123/9ECD/003 Page 5 of 13
Public Health and Environment
Air Pollution Control Division
By:
Andy Gruel, P.E.
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Whiting Oil and Gas Corporation.
AIRS ID: 123/9ECD/003 Page 6 of 13
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-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
Emission
Rate
(Ib/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (Ib/yr)
003
Formaldehyde
50000
7747
Yes
7747
Acetaldehyde
75070
641
Yes
641
Acrolein
107028
394
Yes
394
5) The emission levels contained in this permit are based on the following emission factors:
Point 003:
CAS
Pollutant
Emission
Uncontrolled
lb/MMBtu
Factors -
g/bhp-hr
Emission
Controlled
Ib/MMBtu
Factors —
g/bhp-hr
NOx
0.273
1.0
0.273
1.0
CO
0.664
2.43
0.546
2.0
VOC
0.191
0.7
0.191
0.7
50000
Formaldehyde
0.101
0.37
0.101
0.37
75070
Acetaldehyde
0.00836
0.0169
0.00836
0.0169
107028
Acrolein
0.00514
0.0074
0.00514
0.0074
Emission factors are based on a Brake-Specfic Fuel Consumption Factor of 8071 Btu/hp-hr, a
site -rated horsepower value of 1084 hp, and a fuel heat value of 1486 Btu/scf.
Emission Factor Sources:
CAS
Pollutant
Uncontrolled EFSource
Controlled EF Source
NOx
Manufacturer's Spec
No Control
CO
Manufacturer's Spec
Manufacturer's Spec
VOC
Manufacturer's Spec
No Control
50000
Formaldehyde
Manufacturer's Spec
No Control
75070
Acetaldehyde
AP -42 Table 3.2-2 (7/2000)
No Control
107028
Acrolein
AP -42 Table 3.2-2 (7/2000)
No Control
AIRS ID: 123/9ECD/003
Page 7 of 13
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 engine is subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for
Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal Register
posting — effective March 18, 2008). This rule has not yet been incorporated into Colorado Air Quality
Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA
website at: http://www.epa.gov/ttn/atw/area/fr18ja08.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). 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. qov/ttn/atw/area/arearules. html
9) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, HAPs (total, benzene, toluene, n -hexane)
PSD
Synthetic Minor Source of: VOC
MACT ZZZZ
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 XXXXXX
AIRS ID: 123/9ECD/003
Page 8 of 13
do p e o 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: 123/9ECD/003 Page 9 of 13
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 pot 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: 123/9ECD/003 Page 10 of 13
Public Health and Environment
Air Pollution Control Division
For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or
concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement
engine will be subject to, the results of the test shall be converted to the appropriate units as described in
the above -mentioned Portable Analyzer Monitoring Protocol document.
If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the
absence of credible evidence to the contrary, the source may certify that the engine is in compliance with
both the NOX and CO emission limitations for the relevant time period.
Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if
the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission
limitations, the engine will be considered to be out of compliance from the date of the portable analyzer
test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or
until the engine is taken offline.
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: 123/9ECD/003 Page 11 of 13
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, § 1.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: 123/9ECD/003 Page 12 of 13
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: 123/9ECD/003 Page 13 of 13
Permit number:
Date issued:
Issued to:
DO
on trol Division
Department of Public Health & Environment
CONSTRUCTION PERMIT
16WE091 2
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General Description:
Issuance: 1
Whiting Oil and Gas Corporation
Razor 12F Production Battery
123/9ECD
SENW Section 12 T10N R58W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
PW-01
through
PW-08
004
Eight (8) 400 -bbl fixed -roof atmospheric
storage tanks for storage of produced water.
Vapor Recovery Unit
and Backup 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 the
specific general terms and conditions included in this document and the following specific terms and
conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit shall be
demonstrated to the Division. It is the owner or operator's responsibility to self -certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may result
in revocation of the permit. A self certification form and guidance on how to self -certify
compliance as required by this permit may be obtained online at
www.colorado.gov/pacific/cdphe/air-permit-self-certification. (Regulation Number 3, Part B,
Section III.G.2.)
2. 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.)
3. 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.
!COLORADO
Air Pollution Control Division
De≥.>ariml"^iY'- t : ubi :Ilearh fi Esreunrur'`ac
Page 1 of 7
EMISIT S .R D tsCO.: 'S
4. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4. )
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO.
VOC
CO
PW-01 through
PW-08
004
---
0.03
0.4
0.12
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be
determined on a rolling twelve (12) month total. By the end of each month a new twelve
month total is calculated based on the previous twelve months' data. The permit holder shall
calculate actual emissions each month and keep a compliance record on site or at a local field
office with site responsibility for Division review.
5. 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
PW-01
through
PW-08
004
Two (2) Vapor Recovery Units (VRUs) deliver
tank vapors to gas gathering system. During
VRU downtime, vapors are routed to an open
flare (Flare Industries, model: MAVP-0824, sn:
F500000740.)
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
6. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
PW-01
through
PW-08
004
Produced Water
throughput
5,475,000 barrels
Compliance with the annual throughput limits shalt 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.
COLORADO
Air Pollution Control Division
Npar nerit P,41.iw: Health & ,:Znvir xtrnent
Page 2 of 7
7.„, o e r era r ll con uously monitor and record Vapor Recovery Unit (VRU)
pera
8. The owner or operator must use monthly VRU and 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
9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
shall be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
10. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
11. The open flare covered by this permit has been approved as an alternative emissions control
device under Regulation Number 7, Section XVII.B.2.e. The open flare must have no visible
emissions during normal operations, 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.
12. The storage tank covered by this permit is subject to the emission control requirements in
Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air
pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If
a combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons except where the combustion device has been authorized by permit prior to May
1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section
XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to
the Division upon request. This control requirement must be met within 90 days of the data
that the storage tank commences operation.
13. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission
Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2.
OPERATING Et MAINTENANCE REQUIREMENTS
14. Upon startup of these points, the owner or operator shall follow the most recent operating and
maintenance (OEM) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
the OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3,
Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
15. 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)
COLORADO
Air Pollution Control Division
rconr.:ent
Page 3 of 7
16. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or
activity; or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
GENERAL TERMS AND CONDITIONS
18. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation dumber 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
19. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self -certification of all
points has been reviewed and approved by the Division, it will provide written documentation
of such final authorization. Details for obtaining final authorization to operate are located in
the Requirements to Self -Certify for Final Authorization section of this permit.
20. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
:COLORADO
Air Pollution Control Division
Public I'if:Fg6!'4 6 ElviruR":unt
Page 4 of 7
21. ss .ems is y s ed .therwm ', the general and specific conditions contained in this
ermi :v- . =�� • ' -d by = APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
22. 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.
23. 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.
24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Andy Gruel, P.E.
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Whiting Qil and Gas Corporation.
COLORADO
Air Pollution Control Division
ULl{"u', Hf:dNR ,'E1VV,,,r, l(
Page 5 of 7
Note • a if o -r ax' th =im:+f this o mit 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
(Ib/yr)
004
Benzene
71432
1259
7
Toluene
108883
876
5
Ethylbenzene
100414
88
1
Xylenes
1330207
148
1
n -Hexane
110543
1643
8
2,2,4-
Trimethylpentane
540841
208
1
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds
per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution
Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 004:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
N0x
---
0.000010
AP -42 Ch.13-5
CO
---
0.000041
AP -42 Ch.13-5
V0C
0.0275
0.0001
Flash liberation
analysis (flash)
and EPA Tanks
whi£�
4.09D (working
breathing)
71432
Benzene
0.00023
0.000001
108883
Toluene
0.00016
0.000001
100414
Ethylbenzene
0.000016
0.0000001
1330207
Xylene
0.000027
0.0000001
110543
n -Hexane
0.0003
0.000001
540841
2,2,4-
Trimethylpentane
0.000038
0.0000002
COLORADO
Air Pollution Control Division
rmmeni of Public hle&N>n 6 Environment
Page 6 of 7
s facto for this point are based on an overall control efficiency of
follow
When operating, VRUs are assumed to collect 100% of vapors. VRU downtime is estimated at 7%,
and gathering system downtime is estimated at 3%. The flare control efficiency is 95%. The
overall control efficiency is 1-((1-(1-0.07)`(1-0.03))"(1-0.95)) = 0.995105.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to
the most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division
at (303)-692-3150.
7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and
associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A)
when applicable.
8) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, HAPs (total, benzene, toluene, n -hexane)
PSD
Synthetic Minor Source of: VOC
MACT HH
Area Source Requirements: Not Applicable
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
COLORADO
Air Pollution Control Division
TDeoit,krne�ii ,37 n,Wr:}feat?,S E'^murirr: n[
Page 7 of 7
Permit number:
Date issued:
Issued to:
DO
on trol Division
Department of Public health & Environment
CONSTRUCTION PERMIT
16WE0914
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General Description:
Issuance: 1
Whiting Oil and Gas Corporation
Razor 12F Production Battery
123/9ECD
SENW Section 12 T10N R58W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
TK-01
through
TK-16
006
Sixteen (16) 400 -bbl fixed -roof atmospheric
storage vessels used to store crude oil.
Vapor Recovery Unit
and Backup 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 the
specific general terms and conditions included in this document and the following specific terms and
conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit shall be
demonstrated to the Division. It is the owner or operator's responsibility to self -certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may result
in revocation of the permit. A self certification form and guidance on how to self -certify
compliance as required by this permit may be obtained online at
www.colorado.gov/pacific/cdphe/air-permit-self-certification. (Regulation Number 3, Part B,
Section III.G.2.)
2. 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.)
3. 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.
COLORADO
Air Pollution Control Division
Page 1 of 7
EMISk IT I S DCOS
4. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4. )
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NOX
VOC
CO
TK-01 through
TK-16
006
---
0.8
24.2
3.4
Point
ot"NP
e: See otes toPermit 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.
5. The emission points in the table below shall be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
TK-01
through
TK-16
006
Two (2) Vapor Recovery Units (VRUs) deliver
tank vapors to gas gathering system. During
VRU downtime, vapors are routed to an open
flare (Flare Industries, model: MAVP-0824, sn:
FS00000740.)
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
6. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
TK-01
through
TK-16
006
Crude Oil throughput
1,533,000 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.
1COLORADO
Air Pollution Control Division
�RtYYtL!)i Public Health ^..i'vironrrumL
Page 2 of 7
7.
peraa
uously monitor and record Vapor Recovery Unit (VRU)
8. The owner or operator must use monthly VRU and gathering system downtime records, monthly
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
9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
shall be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
10. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
11. The open flare covered by this permit has been approved as an alternative emissions control
device under Regulation Number 7, Section XVII.B.2.e. The open flare must have no visible
emissions during normal operations, 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.
12. The storage tank covered by this permit is subject to the emission control requirements in
Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air
pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If
a combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons except where the combustion device has been authorized by permit prior to May
1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section
XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to
the Division upon request. This control requirement must be met within 90 days of the date
that the storage tank commences operation.
13. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission
Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2.
OPERATING It MAINTENANCE REQUIREMENTS
14. 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
15. 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)
(COLORADO
Air Pollution Control Division
srn rai+ 1 Health is Esr trormr,e t
Page 3 of 7
16. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A,
II.C. )
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or
activity; or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
GENERAL TERMS AND CONDITIONS
18. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number ?, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
19. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self -certification of all
points has been reviewed and approved by the Division, it will provide written documentation
of such final authorization. Details for obtaining final authorization to operate are located in
the Requirements to Self -Certify for Final Authorization section of this permit.
20. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
COLORADO
An Pollution Control Division
De.,: arcrioni, of Public Health =m irorim=nt
Page 4 of 7
21. therwi. , the general and specific conditions contained in this
ermi .v- .-- .- - " "'-d by ' `= APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
22. 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.
23. 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.
24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Andy Gruel, P.E.
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Whiting Oil and Gas Corporation.
COLORADO
Air Pollution Control Division
arnerd[% Putd�: rtvaith 5 N:r"vorv^ant
Page 5 of 7
No :,. r 3•l :: > th- this T ; . it 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-reps
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's
analysis of the specific compounds emitted if the source(s) operate at the permitted limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
006
Benzene
71432
43997
215
Toluene
108883
40318
197
Ethylbenzene
100414
6745
33
Xytenes
1330207
16097
79
n -Hexane
110543
280079
1371
2,2,4-
Trimethylpentane
540841
6285
31
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds
per year ( b/yr) are reportable and may result in annual emission fees based on the most recent Mr Pollution
Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 006:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
NOx
---
0.0010
AP -42 Ch. 13-5
CO
---
0.0044
AP -42 Ch. 13-5
VOC
6.245
0.031
Aspen HYSIS (flash),
Tanks 4.09d
(working/breathing)
based on a site -
specific pressurized
liquid sample
71432
Benzene
0.0287
0.0001
108883
Toluene
0.0263
0.0001
100414
Ethylbenzene
0.0044
0.00002
1330207
Xylene
0.0105
0.0001
110543
n -Hexane
0.1827
0.0009
540841
2,2,4-
Trimethylpentane
0.0041
0.00002
COLORADO
Air Pollution Control Division
=.-a.aarcrnem is Public Healthfr Environment
Page 6 of 7
factors r this point are based on an overall control efficiency of
.5 , al folio
When operating, VRUs are assumed to collect 100% of vapors. VRU downtime is estimated at 7%,
and gathering system downtime is estimated at 3%. The flare control efficiency is 95%. The
overall control efficiency is 1-((1-(1-0.07)*(1-0.03))*(1-0.95)) = 0.995105.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to
the most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division
at (303)-692-3150.
7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and
associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A)
when applicable.
8) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, HAPs (total, benzene, toluene, n -hexane)
PSD
Synthetic Minor Source of: VOC
MACT HH
Area Source Requirements: Not Applicable
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
` NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-61599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
COLORADO
Air Pollution Control Division
smewt%t Pulls:}.{eaESte t.lvvorvrent
Page 7 of 7
Permit number:
Date issued:
Issued to:
Co
Air Po
I Depar
CONSTRUCTION PERMIT
16WE0915
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General Description:
Issuance: 1
Whiting Oil and Gas Corporation
Razor 12F Production Battery
123/9ECD
SENW Section 12 T10N R58W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
SEP-01
through
SEP-04
007
Venting and flaring of gas from four (4) 2 -
phase separators during downtime of the gas
gathering system.
Open Flare
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this
specific general terms and conditions included in this document and the following specific terms and
conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit shall be
demonstrated to the Division. It is the owner or operator's responsibility to self -certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may result
in revocation of the permit. A self certification form and guidance on how to self -certify
compliance as required by this permit may be obtained online at
www.colorado.Qov/pacific/cdphe/air-permit-self-certification. (Regulation Number 3, Part B,
Section III.G.2.)
2. 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.
COLORADO
Air Pollution Control Division
int :t`or btk lirattn5'Erwirorurim
Page 1 of 7
3. The operator shall corna i ti. co nce e ing d sampling as required in this
permit and submit the t e D" a rt the self -certification process.
(Regulation Number 3, P e
4. 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
5. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4. )
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NOX
VOC
CO
SEP-01 through
SEP-04
007
---
2.5
34.0
10.1
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be
determined on a rolling twelve (12) month total. By the end of each month a new twelve
month total is calculated based on the previous twelve months' data. The permit holder shall
calculate actual emissions' each month and keep a compliance record on site or at a local field
office with site responsibility for Division review.
6. The emission points in the table below shall be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
SEP-01
through
SEP-04
007
Emissions from the separators are routed to
an Open Flare during gas gathering system
downtime
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
7. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
SEP-01 through
04
007
Natural Gas Venting
45.3 MMscf
'COLORADO}
Air Pollution Control Division
ine"ii of :°uMlc lle.'iNh b Elvirorrrnene
Page 2 of 7
Compliance with the an o h. li shat b det mined on a rolling twelve (12)
month total. By the end . o a - wet ont total is calculated based on the
previous twelve months' cal e throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
8. 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 separators) using the flow
meter. The owner or operator shall use monthly throughput records to demonstrate compliance
with the process limits contained in this permit and to calculate emissions as described in this
permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
shall be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
10. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
11. The open flare covered by this permit has been approved as an alternative emissions control
device under Regulation Number 7, Section XVII.B.2.e. The open flare must have no visible
emissions during normal operations, 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.
12. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only).
On or after August 1, 2014, gas coming off a separator, produced during normal operation from
any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be
routed to a gas gathering line or controlled from the date of first production by air pollution
control equipment that achieves an average hydrocarbon control efficiency of 95%. If a
combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons.
OPERATING Et MAINTENANCE REQUIREMENTS
13. Upon startup of these points, the owner or operator shall follow the most recent operating and
maintenance (OFtM) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3,
Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
14. The owner 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)
;COLORADO
Air Pollution Control Division
ar msri ct Pubic t i+:uit^. a e!^:ironrr;>_ nc
Page 3 of 7
Periodic Testing Require
15. This source is not requi ting, u less otherwise directed by the
Division or other state or e•eral requirement.
ADDITIONAL REQUIREMENTS
16. 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,t per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or
activity; or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 daysebefore the existing APEN expires.
17. 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
18. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
19. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self -certification of all
COLORADO
Air Pollution Control Division
tmt.re•_r kb z Healthd mironment
Page 4 of 7
points has been reviewe
of such final authorizatio
the Requirements to S
fy
v- by t Pivis n
o •bta` fin a
ut
it wi provide written documentation
tho ation to operate are located in
n s n of this permit.
20. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
21. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
22. 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.
23. 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.
24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Andy Gruel, P.E.
Permit Engineer
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Whiting Oil and Gas Corporation.
COLORADO
Air Pollution Control Division
DE"..s"nfrw`.u%1 uubk; Health J''E,wirorrne i1
Page 5 of 7
Notes to Permit Holder at the tim
1) The permit holder is requir- _'''' " ay =s e = _ ebbing ti r> -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
(Ib/yr)
Controlled
Emissions
(lb/yr)
007
Benzene
71432
2425
121
Toluene
108883
1320
66
Ethylbenzene
100414
380
19
Xylenes
1130207
1775
89
n -Hexane
110543
24078
1204
2,2,4-
Trimethylpentane
540841
2455
123
Note: All non cntena reportable pollutants in the tablea ove with uncontrolled emission rates above 0.125 ton
per year (ton/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution
Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 007:
CAS #
Pollutant
Uncontrolled
Emission Factors
(Ib/MMscf)
Controlled
Emission Factors
(lb/MMscf)
Source
NOx
106.9
106.9
AP -42 Ch. 13.5
CO
444.4
444.4
AP -42 Ch. 13.5
VOC
29951
1498
Mass Balance
71432
Benzene
53.535
2.6768
Mass Balance
108883
Toluene
29.146
1.4573
Mass Balance
100414
Ethylbenzene
8.3951
0.4198
Mass Balance
1330207
Xylene
39.1771
1.9589
Mass Balance
110543
n -Hexane
531.53
26.5763
Mass Balance
540841
2,2,4-Trimethylpentane
54.1945
2.7097
Mass Balance
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%.
COLORADO
Air Pollution Control. Division
+ GJ'frtrneril Public 1'.4fti, , 6.:''e^iRo ,rn.,!ln
Page 6 of 7
6) In accordance with C.R.S. 25 -
this permit is valid for a term
APEN shall be submitted no an .. for eve-yeaLerm 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:
otice (APEN) associated with
eived by the Division. A revised
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, HAPs (total, benzene, toluene, n -hexane)
PSD
Synthetic Minor Source of: VOC
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
COLORADO
Air Pollution Control Division
Deoarirnerit �c:t P 4blic Heath , rn:fronrnent
Page 7 of 7
Internal Combustion En
AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Reci
Emission Source AIRS ID: 12 3
[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
Request for NEW permit or newly reported emission source
Request for coverage under GENERAL PERMIT number GP02 (Natural Gas Only)
O
CC
472
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Change fuel or equipment
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Whiting Oil and Gas Corporation
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Source Location:
O
Transfer of ownership
Change permit limit
Request APEN Update
N
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Emissions data must be completed. Blank APENs will not be accepted
Denver, CO 80290
303-802-8369
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Section 03 — General Information
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For new or reconstructed sources, the projected startup date is
For existing sources, operation began
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Normal hours of source operation:
General description of equipment purpose:
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