HomeMy WebLinkAbout20162606.tiffCOLORADO
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
1150OSt
PO Box 758
Greeley. CO 80632
August 2, 2016
Dear Sir or Madam:
RECEIVED
AUG 0 5 2016
On August 4. 2016, the Air Pollution Control Division will begin a 30 -day public notice period for Whiting Oil
and Gas Corporation — Razor 29F Production Facility. A copy of this public notice and the public comment
packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public
copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet
must be available for public inspection for a period of thirty (30) days from the beginning of the public notice
period. Please send ally comment regarding this public notice to the address below.
Colorado Dept. of Public Health & Environment
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver. Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
John W. Hickenlooper, Governor Larry Wotk, MD, MSPH, Executive Director and Chief Medical Officer
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2016-2606
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public Comment
Website Title: Whiting Oil and Gas Corporation — Razor 29F Production Facility — Weld County
Notice Period Begins: August 4.2016
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 29F Production Facility
Exploration and production facility
SENW, Section 29.'1'10, 1(58W
Weld County
The proposed project or activity is as follows: the operator is requesting permits for an exploration and production facility
The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3. Part
B. Section III.C due to the following reason(s):
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements
• the Division has determined that public comment is warranted because: Regulation 7, XII.D.2.b.(ii)
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 16WE0257 have been filed with the
Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's
website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability of the
proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division
will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such
comment must be submitted in writing to the following addressee:
Kirk Bear
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South. APCD-SS-Bl
Denver. Colorado 80246-1530
cdphe.commentsapcd.@state.co.us
iiAV
COLOR A DO
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO:
DATE ISSUED:
ISSUED TO:
16WE0257
E0257
Whiting Oil and Gas Corporation
Issuance 1
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas exploration and production facility known as the Razor 29F Production
Facility, located in the SENW, Section 29, T1 ON, R58W, Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment ID
AIRS
Point
Description
PW-01 thru
PW-02
001
Two 400 barrel produced water storage tanks controlled
with an enclosed combustor.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO
AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS
INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than
fifteen days after commencement of operation or issuance of this permit,
whichever comes later, by submitting a Notice of Startup form to the Division. The
Notice of Startup form may be downloaded online at
www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup
of the permitted source is a violation of Air Quality Control Commission (AQCC)
Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit.
2. Within one hundred and eighty days (180) after commencement of operation or issuance
of this permit, whichever comes later, compliance with the conditions contained in this
permit shall be demonstrated to the Division. It is the owner or operator's responsibility to
self -certify compliance with the conditions. Failure to demonstrate compliance within 180
days may result in revocation of the permit. (Reference: Regulation No. 3, Part B,
III.G.2).
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source
within 18 months after either, the date of issuance of this construction permit or the date
on which such construction or activity was scheduled to commence as set forth in the
permit application associated with this permit; (ii) discontinues construction for a period
AIRS ID: 123-9E58 Page 1 of 11
Colorado Department of Public Health and Environment
Air Pollution Control Division
of eighteen months or more; (iii) does not complete construction within a reasonable
time of the estimated completion date. The Division may grant extensions of the
deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B,
III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Reference: Regulation No. 3, Part B, Section III.E.)
5. The following information shall be provided to the Division within fifteen (15) days after
issuance of permit.
• manufacturer
• model number
• serial number
This information shall be included with the Notice of Startup submitted for the equipment.
(Reference: Regulation No. 3, Part B, III.E.)
6. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This
construction permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission Type
NO x
VOC
CO
PW-01 thru
PW-02
001
0.1
0.9
0.1
Point
See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Facility -wide emissions of each individual hazardous air pollutant shall be less than 8.0
tpy.
Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)
from each emission unit, on a rolling twelve (12) month total. By the end of each month
a new twelve-month total shall be calculated based on the previous twelve months' data.
The permit holder shall calculate emissions each month and keep a compliance record
on site or at a local field office with site responsibility, for Division review. This rolling
twelve-month total shall apply to all permitted emission units, requiring an APEN, at this
facility.
8. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
AIRS ID: 123-9E58 Page 2 of 11
Colorado Department of Public Health and Environment
Air Pollution Control Division
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
PW-01 thru
PW-02
001
Enclosed Combustor
VOC, HAPs
PROCESS LIMITATIONS AND RECORDS
9. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates shall be maintained by the owner or
operator and made available to the Division for inspection upon request. (Reference:
Regulation 3, Part B, II.A.4)
Process/Consumption Limits
Facility
Equipment ID
AIRS Point
Process Parameter
Annual Limit
PW-01 thru
PW-02
001
Produced Water Throughput
140,890 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.
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. 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)
11. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation
of the source. During periods of startup, process modification, or adjustment of control
equipment visible emissions shall not exceed 30% opacity for more than six minutes in
any sixty consecutive minutes. Emission control devices subject to Regulation 7,
Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation
No. 1, Section II.A.1. & 4.)
12. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
13. The flare(s) covered by this permit is subject to Regulation No. 7, Section XVII.B
General Provisions (State only enforceable). These requirements include, but are not
limited to:
XVII.B.2.b If a combustion device is used to control emissions of volatile organic
compounds to comply with Section XVII, it shall be enclosed, have no visible
emissions during normal operations, and be designed so that an observer can,
by means of visual observation from the outside of the enclosed combustion
device, or by other means approved by the Division, determine whether it is
operating properly.
AIRS ID: 123-9E58 Page 3 of 11
Colorado Department of Public Health and Environment
Air Pollution Control Division
XVII.B.2.d Auto -igniters: All combustion devices used to control emissions of
hydrocarbons must be equipped with and operate an auto -igniter as follows:
XVII.B.2.d.(i) All combustion devices installed on or after May 1, 2014, must be equipped
with an operational auto -igniter upon installation of the combustion device.
XVII.B.2.d.(ii) All combustion devices installed before May 1, 2014, must be equipped
with an operational auto -igniter by or before May 1, 2016, or after the next
combustion device planned shutdown, whichever comes first.
14. The storage tanks covered by this permit are subject to Regulation 7, Section XVII.C
emission control requirements. These requirements include, but are not limited to:
Section XVII.C.1. Control and monitoring requirements for storage tanks
XVII.C.1.b. Owners or operators of storage tanks with uncontrolled actual emissions of
VOCs equal to or greater than six (6) tons per year based on a rolling twelve-
month total must operate air pollution control equipment that achieves an
average hydrocarbon control efficiency of 95%. If a combustion device is used, it
must have a design destruction efficiency of at least 98% for hydrocarbons.
XVII.C.1.b.(i)(a) Control requirements of Section XVII.C.1.b. must be achieved
within ninety (90) days of the date that the storage tank commences
operation.
XVII.C.1.d. Beginning May 1, 2014, or the applicable compliance date in Section
XVII.C.1.b.(i), whichever comes later, owners or operators of storage tanks
subject to Section XVII.C.1. must conduct audio, visual, olfactory ("AVO") and
additional visual inspections of the storage tank and any associated equipment
(e.g. separator, air pollution control equipment, or other pressure reducing
equipment) at the same frequency as liquids are loaded out from the storage
tank. These inspections are not required more frequently than every seven (7)
days but must be conducted at least every thirty one (31) days. Monitoring is not
required for storage tanks or associated equipment that are unsafe, difficult, or
inaccessible to monitor, as defined in Section XVII.C.1.e. The additional visual
inspections must include, at a minimum:
XVII.C.1.d.o) Visual inspection of any thief hatch, pressure relief valve, or other
access point to ensure that they are closed and properly sealed;
XVII.C.1.d.(ii) Visual inspection or monitoring of the air pollution control
equipment to ensure that it is operating, including that the pilot light is lit
on combustion devices used as air pollution control equipment;
XVII.C.1.d.(iii) If a combustion device is used, visual inspection of the auto -igniter
and valves for piping of gas to the pilot light to ensure they are functioning
properly;
XVII.C.1.d.(iv) Visual inspection of the air pollution control equipment to ensure
that the valves for the piping from the storage tank to the air pollution
control equipment are open; and
XVII.C.1.d.(v) If a combustion device is used, inspection of the device for the
presence or absence of smoke. If smoke is observed, either the
equipment must be immediately shut-in to investigate the potential cause
for smoke and perform repairs, as necessary, or EPA Method 22 must be
AIRS ID: 123-9E58 Page 4 of 11
Colorado Department of Public Health and Environment
Air Pollution Control Division
conducted to determine whether visible emissions are present for a
period of at least one (1) minute in fifteen (15) minutes.
XVII.C.1.e. If storage tanks or associated equipment is unsafe, difficult, or inaccessible
to monitor, the owner or operator is not required to monitor such equipment until
it becomes feasible to do so.
XVII.C.2. Capture and monitoring requirements for storage tanks that are fitted
with air pollution control equipment as required by Sections XII.D. or
XVII.C.1.
XVII.C.2.a. Owners or operators of storage tanks must route all hydrocarbon emissions
to air pollution control equipment, and must operate without venting hydrocarbon
emissions from the thief hatch (or other access point to the tank) or pressure
relief device during normal operation, unless venting is reasonably required for
maintenance, gauging, or safety of personnel and equipment. Compliance must
be achieved in accordance with the schedule in Section XVII.C.2.b.(ii).
XVII.C.2.b. Owners or operators of storage tanks subject to the control requirements of
Sections XII.D.2., XVII.C.1.a, or XVII.C.1.b. must develop, certify, and implement
a documented Storage Tank Emission Management System ("STEM") plan to
identify, evaluate, and employ appropriate control technologies, monitoring
practices, operational practices, and/or other strategies designed to meet the
requirements set forth in Section XVII.C.2.a. Owners or operators must update
the STEM plan as necessary to achieve or maintain compliance. Owners or
operators are not required to develop and implement STEM for storage tanks
containing only stabilized liquids. The minimum elements of STEM are listed
below.
XVII.C.2.b.(i) STEM must include selected control technologies, monitoring
practices, operational practices, and/or other strategies; procedures for
evaluating ongoing storage tank emission capture performance; and
monitoring in accordance with approved instrument monitoring methods
following the applicable schedule in Section XVII.C.2.b.(ii) and Inspection
Frequency in Table 1.
XVII.C.2.b.(ii) Owners or operators must achieve the requirements of Sections
XVII.C.2.a. and XVII.C.2.b. and begin implementing the required
approved instrument monitoring method in accordance with the following
schedule:
XVII.C.2.b.(ii)(a) A storage tank constructed on or after May 1, 2014, must
comply with the requirements of Section XVII.C.2.a. by the date the
storage tank commences operation. The storage tank must comply with
Section XVII.C.2.b. and implement the approved instrument monitoring
method inspections within ninety (90) days of the date that the storage
tank commences operation.
XVII.C.2.b.(ii)(d) Following the first approved instrument monitoring method
inspection, owners or operators must continue conducting approved
instrument monitoring method inspections in accordance with the
Inspection Frequency in Table 1.
Table 1 — Storage Tank Inspections
AIRS ID: 123-9E58
Page 5 of 11
Colorado Department of Public Health and Environment
Air Pollution Control Division
Threshold: Storage Tank
Uncontrolled Actual VOC
Emissions (tpy)
Approved Instrument
Monitoring Method
Inspection Frequency
Phase -In Schedule
> 6 and ≤ 12
Annually
January 1, 2016
> 12 and < 50
Quarterly
July 1, 2015
> 50
Monthly
January 1, 2015
XVII.C.2.b.(iii) Owners or operators are not required to monitor storage tanks and
associated equipment that are unsafe, difficult, or inaccessible to monitor,
as defined in Section XVII.C.1.e.
XVII.C.2.b.(iv) STEM must include a certification by the owner or operator that
the selected STEM strategy(ies) are designed to minimize emissions from
storage tanks and associated equipment at the facility(ies), including thief
hatches and pressure relief devices.
XVII.C.3. Recordkeeping
XVII.C.3. The owner or operator of each storage tank subject to Sections XII.D. or
XVII.C. must maintain records of STEM, if applicable, including the plan, any
updates, and the certification, and make them available to the Division upon
request. In addition, for a period of two (2) years, the owner or operator must
maintain records of any required monitoring and make them available to the
Division upon request, including:
XVII.C.3.a. The AIRS ID for the storage tank.
XVII.C.3.b. The date and duration of any period where the thief hatch, pressure relief
device, or other access point are found to be venting hydrocarbon emissions,
except for venting that is reasonably required for maintenance, gauging, or safety
of personnel and equipment.
XVII.C.3.c. The date and duration of any period where the air pollution control equipment
is not operating.
XVII.C.3.d. Where a combustion device is being used, the date and result of any EPA
Method 22 test or investigation pursuant to Section XVII.C.1.d.(v).
XVII.C.3.e. The timing of and efforts made to eliminate venting, restore operation of air
pollution control equipment, and mitigate visible emissions.
XVII.C.3.f. A list of equipment associated with the storage tank that is designated as
unsafe, difficult, or inaccessible to monitor, as described in Section XVII.C.1.e., an
explanation stating why the equipment is so designated, and the plan for monitoring
such equipment.
OPERATING & MAINTENANCE REQUIREMENTS
15. Upon startup of these points, the owner or operator shall follow the most recent
operating and maintenance (O&M) plan and record keeping format approved by the
AIRS ID: 123-9E58 Page 6 of 11
Colorado Department of Public Health and Environment
Air Pollution Control Division
Division, in order to demonstrate compliance on an ongoing basis with the requirements
of this permit. Revisions to your O&M plan are subject to Division approval prior to
implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
16. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Method 22 to determine the presence or absence of visible emissions. "Visible
Emissions" means observations of smoke for any period or periods of duration greater
than or equal to one (1) minute in any fifteen (15) minute period during normal operation.
(Reference: Regulation No. 7, Section XVII.A.II)
ADDITIONAL REQUIREMENTS
17. 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.
18. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit)
shall apply to this source at any such time that this source becomes major solely by
virtue of a relaxation in any permit condition. Any relaxation that increases the potential
to emit above the applicable Federal program threshold will require a full review of the
source as though construction had not yet commenced on the source. The source shall
not exceed the Federal program threshold until a permit is granted. (Regulation No. 3
Part D).
GENERAL TERMS AND CONDITIONS
19. 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
AIRS ID: 123-9E58 Page 7 of 11
Colorado Department of Public Health and Environment
Air Pollution Control Division
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.
20. 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.
21. 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.
22. 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.
23. 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.
24. 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.
25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution
Prevention and Control Act or the regulations of the AQCC may result in administrative,
civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121
(injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S.
By:
Kirk Bear
Permit Engineer
AIRS ID: 123-9E58 Page 8 of 11
Colorado Department of 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: 123-9E58 Page 9 of 11
Colorado Department of Public Health and Environment
Air Pollution Control Division
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these
fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of
receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference:
Regulation No. 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN)
and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written notice
to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: http://www.colorado.gov/cs/Satellite?c=Document C&childpagename=CDPHE-
Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWraoper
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis
of the specific compounds emitted if the source(s) operate at the permitted limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(Ib/yr)
Reportable
Controlled
Emissions
(lb/yr)
001
Benzene
71432
986
Yes
49
001
n -Hexane
110543
3100
Yes
155
5) The emission levels contained in this permit are based on the following emission factors:
Pollutant
Emission Factors
Uncontrolled
lb/bbl Produced
Water Throughput
Source
VOC
0.262
CDPHE
n -Hexane
0.022
CDPHE
Benzene
0.007
CDPHE
Note: The controlled emissions for this point are based on the flare control efficiency of 95%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the
most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division at
(303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC
AIRS ID: 123-9E58
Page 10 of 11
Colorado Department of Public Health and Environment
Air Pollution Control Division
PSD
Synthetic Minor Source of: VOC
MACT HH
Major Source Requirements: Not Applicable
Area Source Requirements: Not Applicable
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.qpoaccess.qov/
r. q poa c cess. q ov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A — Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A — Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A — Subpart Z
MACT
63.600-63.1199
Subpart AA — Subpart DDD
MACT
63.1200-63.1439
Subpart EEE — Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ — Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ — Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN — Subpart XXXXXX
9) A self certification form and guidance on how to self -certify compliance as required by this permit may
be obtained online at: http://wvw.colorado.gov/pacific/cdphe/air-permit-self-certification
AIRS ID: 123-9E58 Page 11 of 11
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer:
Package #:
Received Date:
Review Start Date:
Section 01- Facility Information
Kirk Bear
343236
1/20/2016
Company Name:
County AIRS ID:
Plant AIRS ID:
Facility Name:
Physical Address/Location:
Type of Facility:
What industry segment?
Whiting Oil and Gas Corporation
123
9E58
Razor 08E Production Facility
SENW, Section 29, T10N, R58W
Exploration & Production Well Pad
Oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area?
If yes, for what pollutant? ❑ Carbon Monoxide (CO)
Section 02 - Emissions Units In Permit Application
Yes
❑ Particulate Matter (PM) E Ozone (N
AIRs Point #
Emissions Source Type
Emissions
Control?
Permit it
Issuance #
001
Produced Water Storage Tank
Yes
16WE0257
1
002
Hydrocarbon Liquid Loading
No
16WE0258
1
003
Crude Oil Storage Tank
Yes
16WE0259
1
004
Process Flare
Yes
16WE0260
1
Section 03 - Description of Project
Operator asking for permits on this E and P site. Site is syn-minor for VOC and HAP so sending to I
Section 04 - Public Comment Requirments
Is Public Comment Required?
If yes, why?1
Requesting Synthetic Minor Perm
open flare
Section 05 - Ambient Air Impact Analysis Requirements
Was a quantitative modeling analysis required?2
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
it.
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
Non -Attainment New Source Review (NANSR): VOC
Is this stationary source a major source?
If yes, explain what programs and which pollutants here:
No
Yes
Data for Drop Down Lists
Facility Type List
Exploration & Production Well Pad
Natural Gas Compressor Station
Natural Gas Processing Plant
Produced Water Injection Facility
Produced Water Management Facility
Oil Stabilization (Exploration & Production)
Oil Storage and Pipeline Injection
Natural Gas Storage
Other (Describe facility type in Section 03)
Emission Point List
Amine Sweetening Unit
Condensate Storage Tank
Crude Oil Storage Tank
Diesel RICE
EG Dehydrator
Fugitive Component Leaks
Hydrocarbon Liquid Loading
Maintenance Blowdowns
Natural Gas RICE
Pneumatic Pump
Process Flare
Produced Water Storage Tank
Produced Water Storage Pond
Separator Venting
TEG Dehydrator
Turbine
Vapor Recovery Tower (VRT)
Boiler or Process Heater
Other (Explain)
Emissions Control List
Enclosed Flare
Leak Detection and Repair Program
Non -Selective Catalytic Reduction (NSCR)
Open flare
Oxidation Catalyst
Thermal Oxidizer
Vapor Recovery Unit to fuel system header
Vapor Recovery Unit to plant inlet
Permit Action Types
APEN Exempt
APEN Required / Permit Exempt
Permit Initial Issuance
Permit Modification
Cancellation
No Action Requested
Facility Classifications
N/A
Major
Synthetic Minor
True Minor
Qualifiers
No
Yes
Public Comment
Requesting Synthetic Minor Permit
Greater than 25 tons per year in Non -Attainment Area
Greater than 50 tons per year in an Attainment Area
Alternative Control per Reg 7, Sec XII.D.2.b.(ii)
Other (Divison Discretion)
NAAQS Pollutants
Carbon Monoxide (CO)
Particulate Matter (PM)
Ozone (NOx & VOC)
Industry Segment
Oil & Natural Gas Production & Processing
Natural Gas Transmission & Storage
......................
E Ozone (NOx & VOC)
Self Cert
Required?
Action
Engineering Remarks
__.................. ...
Permit Initia
Issuance
:
Per€nit.InitraF
Na
.............................
.............................
.... ___._..................
..............................
..... _..........................
Yes`
.. nilZiZrfing
PC. Also has open flare request. Form completed.
Division Information
Engineer:
Kirk Bear
Control Engineer:
Chris Laplante
Review Date:
03/16/2016
Application Date:
01/20/2016
Facility Identifiers
Permit No.
16WE0257
AIRS
County #
123 IWeld
Facility #
9E58
Facility Type:
exploration and production facility
❑� Located in the 8 -hour non -attainment area?
Administrative Information
Company Name:
Whiting Oil and Gas Corporation
Source Name:
Razor 29F Production Facility
Source Location:
SENW, Section 29, T10N, R58W
SIC:
1311
Address 1:
Whiting Oil and Gas Corporation
Mailing
Address
Address 2:
1700 Broadway, Suite 2300
ty, State Zip:
Denver, Colorado 80290
Name:
Justin Korkus
Person To
Phone:
303 802 8332
Contact
Fax:
720 644 3636
Email:
justin.korkus@whiting.com
Potentially located in ozone nonattainment area
Q True Minor
Synthetic Minor for:
F7 VOC r Nox r co
Requested Action
Self Certification Required?
Issuance Number:
Yes
1
Source Description:
Oil and gas exploration and production facility known as the Razor 29F Production Facility, located in the SENW,
Section 29, T1 ON, R58W, Weld County, Colorado.
Point
Name
Type
Control
Action
001
Tanks
Water Tanks
Flare
Newly
reported
source
002
001 Two 400 barrel produced water storage tanks
Emissions Calculations
Requsted Throughput
140890
bbl
Control
Flare
Efficiency
95.00%
Emissions Summary Table
Pollutant
Emission Factor
Uncontrolled Emissions
Controlled Emissions
Source
V0C
0.262
lb/bbl
18.46
tpy
0.9
tpy
CDPHE
Benzene
0.007
lb/bbl
986
lb/yr
49
lb/yr
CDPHE
n -Hexane
0.022
lb/bbl
3100
lb/yr
155
lb/yr
CDPHE
Regulatory Review
Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator of a source
shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20%
opacity. This standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six
minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40
CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section II. A and B of this regulation.
Section II.A.5 - Smokeless Flare or Flares for the Combustion of Waste Gases No owner or operator
of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions
into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods
aggregating more than six minutes in any sixty consecutive minutes.
Regulation 2 — Odor
Section LA - 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.
note: this is the third time the throughput has changed for this point.
AIRS (County/Plant) 123/9E58
Permit No. 16WE0257
Date 3/16/2016
Point #
SCC
Pollutant or CAS
Uncontrolled Emission
Factor
001
40400315
VOC
6.238 lb/1000 qa
001
40400315
Benzene
0.167 lb/1000 ga
001
40400315
n -Hexane
0.524 lb/1000 ga
Emisison Factor Source
Controlled
Actual
Emissions
(tpy)*
Controlled
Requested
Emissions
(tpy)*
PTE (tpy)*
Ctrl.
Eff%
NCRP =
reportable
?
CDPHE
0.7
13.4
95%
Yes
CDPHE
35.8
715.4
95%
Yes
CDPHE
112.4
2248.4
95%
Yes
0
Emission Source AIRS ID:
[Leave blank unless APED has already assigned a permit # & AIRS ID]
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FORM APCD-207
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO:
DATE ISSUED:
ISSUED TO:
16W E0258
Whiting Oil and Gas Corporation
Issuance 1
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas exploration and production facility known as the Razor 29F Production
Facility, located in the SENW, Section 29, T10N, R5SW, Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment ID
AIRS Point
Description
LOAD -01
002
Hydrocarbon Loadout to Tanker Trucks
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO
AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS
INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than
fifteen days after commencement of operation or issuance of this permit,
whichever comes later, b rLsubmittinq a Notice of Startup form to the Division. The
Notice of Startup form may be downloaded online at
www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup
of the permitted source is a violation of Air Quality Control Commission (AQCC)
Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit.
2. Within one hundred and eighty days (180) after commencement of operation or issuance
of this permit, whichever comes later, compliance with the conditions contained in this
permit shall be demonstrated to the Division. It is the owner or operator's responsibility to
self -certify compliance with the conditions. Failure to demonstrate compliance within 180
days may result in revocation of the permit. (Reference: Regulation No. 3, Part B,
III.G.2).
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source
within 18 months after either, the date of issuance of this construction permit or the date
on which such construction or activity was scheduled to commence as set forth in the
permit application associated with this permit; (ii) discontinues construction for a period
of eighteen months or more; (iii) does not complete construction within a reasonable
AIRS ID: 123-9E58-001 Page 1 of 7
Colorado Department of Public Health and Environment
Air Pollution Control Division
time of the estimated completion date. The Division may grant extensions of the
deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B,
I I I. F.4.)
4. The following information shall be provided to the Division within fifteen (15) days after
issuance of permit.
• manufacturer
• model number
• serial number
This information shall be included with the Notice of Startup submitted for the equipment.
(Reference: Regulation No. 3, Part B, III.E.)
5. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This
construction permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission Type
NO x
VOC
CO
LOAD -01
002
--
3.0
--
Point
See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Facility -wide emissions of each individual hazardous air pollutant shall be less than 8.0
tpy.
Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)
from each emission unit, on a rolling twelve (12) month total. By the end of each month
a new twelve-month total shall be calculated based on the previous twelve months' data.
The permit holder shall calculate emissions each month and keep a compliance record
on site or at a local field office with site responsibility, for Division review. This rolling
twelve-month total shall apply to all permitted emission units, requiring an APEN, at this
facility.
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. (Reference:
Regulation 3, Part B, II.A.4)
AIRS ID: 123-9E58-001 Page 2 of 7
Colorado Department of Public Health and Environment
Air Pollution Control Division
Process/Consumption Limits
Facility
Equipment ID
AIRS Point
Process Parameter
Annual Limit
LOAD -01
002
Oil Loaded
204,400 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.
STATE AND FEDERAL REGULATORY REQUIREMENTS
8. 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)
9. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation
of the source. During periods of startup, process modification, or adjustment of control
equipment visible emissions shall not exceed 30% opacity for more than six minutes in
any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.1. & 4.)
10. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable.
11. The owner or operator shall follow loading procedures that minimize the leakage of
VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B,
III.E):
a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or
other liquid or vapor loss during loading and unloading.
b. All compartment hatches (including thief hatches) shall be closed and latched at
all times when loading operations are not active, except for periods of
maintenance, gauging, or safety of personnel and equipment.
c. The owner or operator shall inspect loading equipment and operations on site at
the time of the inspection to ensure compliance with the conditions (a) and (b)
above. The inspections shall occur at least monthly. Each inspection shall be
documented in a log available to the Division on request.
12. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated
and maintained so as to minimize leakage of volatile organic compounds to the
atmosphere to the maximum extent practicable.
OPERATING & MAINTENANCE REQUIREMENTS
13. This source is not required to follow a Division -approved operating and maintenance
plan.
COMPLIANCE TESTING AND SAMPLING
14. There are no requirements in this section.
AIRS ID: 123-9E58-001 Page 3 of 7
Colorado Department of Public Health and Environment
Air Pollution Control Division
ADDITIONAL REQUIREMENTS
15. 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.
16. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit)
shall apply to this source at any such time that this source becomes major solely by
virtue of a relaxation in any permit condition. Any relaxation that increases the potential
to emit above the applicable Federal program threshold will require a full review of the
source as though construction had not yet commenced on the source. The source shall
not exceed the Federal program threshold until a permit is granted. (Regulation No. 3
Part D).
GENERAL TERMS AND CONDITIONS
17. 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.
18. 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.
AIRS ID: 123-9E58-001 Page 4 of 7
Colorado Department of Public Health and Environment
Air Pollution Control Division
19. 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.
20. 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.
21. 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.
22. 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.
23. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution
Prevention and Control Act or the regulations of the AQCC may result in administrative,
civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121
(injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S.
By:
Kirk Bear
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Whiting Oil and Gas Corporation
AIRS ID: 123-9E58-001
Page 5 of 7
Colorado Department of Public Health and Environment
Air Pollution Control Division
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these
fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of
receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference:
Regulation No. 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN)
and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written notice
to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: http://www.colorado.gov/cs/Satellite?c=Document C&childpaciename=CDPHE-
Main%2FDOcument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis
of the specific compounds emitted if the source(s) operate at the permitted limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Reportable?
Controlled
Emissions
(Ib/yr)
002
Benzene
71432
30
No
NA
002
n -Hexane
110543
279
No
NA
5) The emission levels contained in this permit are based on the following emission factors:
Pollutant
Emission Factors
Uncontrol
lb/bbl loaded
-
ed
Source
VOC
0.0290
AP -42
Benzene
0.0001
AP -42
n -Hexane
0.0014
AP -42
The uncontrolled VOC emission factor was calculated using AP -42, Chapter 5.2, Equation 1
(version 1/95) using the following values:
L = 12.46*S*P*M/T
S = 0.6 (Submerged loading: dedicated normal service)
P (true vapor pressure) = 0.82 psia
M (vapor molecular weight) = 56.97 Ib/Ib-mol
T (temperature of liquid loaded) = 505 °R
The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying
the HYSIS HAP weight percent by the VOC emission factor.
AIRS ID: 123-9E58-001
Page 6 of 7
Colorado Department of Public Health and Environment
Air Pollution Control Division
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the
most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division at
(303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC
PSD
Synthetic Minor Source of: VOC
MACT HH
Major Source Requirements: Not Applicable
Area Source Requirements: Not Applicable
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.qpoaccess.qov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A — Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A — Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A — Subpart Z
MACT
63.600-63.1199
Subpart AA — Subpart DDD
MACT
63.1200-63.1439
Subpart EEE — Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ — Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ — Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN — Subpart XXXXXX
9) A self certification form and guidance on how to self -certify compliance as required by this permit may
be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification
AIRS ID: 123-9E58-001
Page 7 of 7
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer:
Package #:
Received Date:
Review Start Date:
Section 01 - Facility Information
Kirk Bear
343236
1/20/2016
Company Name:
County AIRS ID:
Plant AIRS 1D:
Facility Name:
Physical Address/Location:
Type of Facility:
What Industry segment?
Is this facility located in a NAAQS
If yes, for what pollutant?
Whiting Oil and Gas Corporation
123
9E58
Razor OBE Production Facility
SENW, Section 29, 710N, R58W
Exploration & Production. Well Pad'
Oil. & Natural Gas Production & Pocessing:
non -attainment area? Yes
❑ Carbon Monoxide (CO) O Particulate Matter (PM) ['Ozone (Nox & VOC)
Section 02 - Emissions Units In Permit Application
AIRS Point #
Emissions Source Type
Emissions
Control?
Permit#
Issuance*
Self Cert
Required?
Action
Engineering Remarks
001
•Produced Water Storage Tank
Yes
16WE0257
1
Xes .
.:. Permit Initial
. lsstiancae
002
Hydrocarbon Liquid Loading
NO
16WE0258
1
No
Permit Initial
Issuance
003
. . ..
Crude Oil Storage:Tank
.. . .
. Yes
16W E0259
1
.yes •:"
Permit Initial
' :• fstyance•
004
Process Flare . ..: "
Yes
16WE0260
1
..Yes ::.,
• Permit Initial
:. ...Issuance ..
Section 03 - Description of Project
Operator asking for permits on this E and P site. Site is syn-minor for VOC and HAP so sending to PC. Also has open flare request. Form completed.
Section 04 - Public Comment Requirments
Is Public Comment Required? Yes
If yes, why?1 Requesting Synthetic Minor Permit..
open flare
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?
If yes, explain what programs and which pollutants here:
Title V Operating Permits (OP) : VOC
Non -Attainment New Source Review (NANSR): VOC
Is this stationary source a major source?
If yes, explain what programs and which pollutants here:
Data for Drop Down Lists
Facility Type List
Exploration & Production Well Pad
Natural Gas Compressor Station
Natural Gas Processing Plant
Produced Water Injection Facility
Produced Water Management Facility
Oil Stabilization (Exploration & Production)
Oil Storage and Pipeline Injection
Natural Gas Storage
Other (Describe facility type in Section 03)
Emission Point List
Amine Sweetening Unit
Condensate Storage Tank
Crude Oil Storage Tank
Diesel RICE
EG Dehydrator
Fugitive Component Leaks
Hydrocarbon Liquid Loading
Maintenance Slowdowns
Natural Gas RICE
Pneumatic Pump
Process Flare
Produced Water Storage Tank
Produced Water Storage Pond
Separator Venting
TEG Dehydrator
Yes
Turbine
Vapor Recovery Tower (VRT)
Boiler or Process Heater
Other (Explain)
Emissions Control List
Enclosed Flare
Leak Detection and Repair Program
Non -Selective Catalytic Reduction (NSCR)
Open Flare
Oxidation Catalyst
Thermal Oxidizer
Vapor Recovery Unit to fuel system header
Vapor Recovery Unit to plant inlet
Permit Action Types
APEN Exempt
APEN Required / Permit Exempt
Permit Initial Issuance
Permit Modification
Cancellation
No Action Requested
Facility Classifications
N/A
Major
Synthetic Minor
True Minor
Qualifiers
No
yes
Public Comment
Requesting Synthetic Minor Permit
Greater than 25 tons per year in Non -Attainment Area
Greater than SO tons per year in an Attainment Area
Alternative Control per Reg 7, Sec XII,D.2.b.(ii)
Other (Divison Discretion)
NAAQS Pollutants
Carbon Monoxide (CO)
Particulate Matter (PM)
Ozone (Nox & VOC)
Industry Segment
Oil & Natural Gas Production & Processing
Natural Gas Transmission & Storage
Division Information
Engineer:
Kirk Bear
Control Engineer:
Chris Laplante
Review Date:
03/16/2016
Application Date:
01/20/2016
Facility Identifiers
Permit No.
16WE0258
AIRS
County #123
'Weld
Facility tf
9E58
Facility Type:
exploration and production facility
O Located in the 8 -hour non -attainment area?
Administrative Information
Company Name:
Whiting Oil and Gas Corporation
Source Name:
Razor 29F Production Facility
Source Location:
SENW, Section 29, T10N, R58W
SIC:
1311
Address 1:
Whiting Oil and Gas Corporation
Mailing
Address 2:
1700 Broadway, Suite 2300
Address
ty, State Zip:
Denver, Colorado 80290
Name:
Justin Korkus
Person To
Phone:
303 802 8332
Contact
Fax:
720 644 3636
Email:
justin.korkus@whiting.com
Potentially located in ozone nonattainment area
O True Minor
Synthetic Minor for:
r VOC r NOx r CO
Requested Action
Self Certification Required?
Issuance Number:
Yes
1
Source Description:
Oil and gas exploration and production facility known as the Razor 29F Production Facility, located in the SENW,
Section 29, T10N, R58W, Weld County, Colorado.
Point
Name
Type
Control
Action
002
LOAD -01
Loadout
None
Newly
reported
source
002 Hydrocarbon Loadout to Tanker Trucks
operator changed throughput and requests explanation of how calculations are done.
Calculations
L = 12.46*S*P*M/T (AP -42: Chapter 5.2, Equation 1)
L = loading losses in lb per 1000 gallons loaded
Factor
Meaning
Value
Units
Source
S
Saturation Factor
0.6
AP -42
P
True Vapor Pressure
0.82
psia
Sales Oil A
M
Molecular Weight of Vap
56.97
lb/lb-mole
AP -42
T
Liquid Temperature
505.3
deg. R
Field Data
0.6912 lb/1000 gal
0.0290 lb/bbl
Annual requested Throughput
Annual requested VOC emissions
Control: None
Efficiency: 0.00%
NCRPs
Component
Benzene
0.0050
n -hexane
0.0470
Toluene
Xylenes
Source:
Mass Fraction
HYSIS
Emissions Summary Table
alysis
bbl/day
204400 bbl/yr 560
8584800 gal/yr
5933 lb/yr
2.97 tpy
Operator modeled in HYSIS
Pollutant
Emission Factor
Uncontrolled Emissions
Controlled Emissions
Source
VOC
0.0290
lb/bbl
3.0 tpy
3.0 tpy
AP -42
Benzene
0.00015
lb/bbl
30 lb/yr
30 lb/yr
AP -42
n -Hexane
0.00136
lb/bbl
279 lb/yr
279 lb/yr
AP -42
Regulatory Review
Regulation 3 - APEN and Permittinq Requirements
Is this site considered an exploration and production location (e.g. well pad)?
If yes, review the following two exemptions for applicability:
Does the operator unload less than 10,000 gallons (238 BBLs) per day of crude oil on an annual average basis?
If yes, this emissions point is categorically exempt from permit requirements per Regulation 3. Part B, Section 11,0,1 I
Does this operator unload less than 6,750 bbls per year of condensate via splash fill or
16,308 bbls per year of condensate via submerged fill procedure?
If yes. this emissions point is categorically exempt from permit requirements per Regulation 3, Part B. Section 11.0.1.1
NOTE: This is the 2nd set of throughputs run for this site.
No
Yes
No
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Section 02 — Re
Section 01 — Administrative Information
General Permit C
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STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO: 16WE0259
DATE ISSUED:
ISSUED TO: Whiting Oil and Gas Corporation
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Issuance 1
Oil and gas exploration and production facility known as the Razor 29F Production
Facility, located in the SENW, Section 29, T1 ON, R58W, Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment ID
AIRS
Point
Description
TK-01 thru TK-04
003
Four 400 barrel crude oil storage tanks controlled with
an enclosed combustor.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO
AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS
INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than
fifteen days after commencement of operation or issuance of this permit,
whichever comes later, by submitting a Notice of Startup form to the Division. The
Notice of Startup form may be downloaded online at
www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup
of the permitted source is a violation of Air Quality Control Commission (AQCC)
Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit.
2. Within one hundred and eighty days (180) after commencement of operation or issuance
of this permit, whichever comes later, compliance with the conditions contained in this
permit shall be demonstrated to the Division. It is the owner or operator's responsibility to
self -certify compliance with the conditions. Failure to demonstrate compliance within 180
days may result in revocation of the permit. (Reference: Regulation No. 3, Part B,
III.G.2).
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source
within 18 months after either, the date of issuance of this construction permit or the date
on which such construction or activity was scheduled to commence as set forth in the
permit application associated with this permit; (ii) discontinues construction for a period
of eighteen months or more; (iii) does not complete construction within a reasonable
AIRS ID: 123-9E58-003 Page 1 of 11
Colorado Department of Public Health and Environment
Air Pollution Control Division
time of the estimated completion date. The Division may grant extensions of the
deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B,
III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Reference: Regulation No. 3, Part B, Section III.E.)
5. The following information shall be provided to the Division within fifteen (15) days after
issuance of permit.
• manufacturer
• model number
• serial number
This information shall be included with the Notice of Startup submitted for the equipment.
(Reference: Regulation No. 3, Part B, III.E.)
6. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This
construction permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission Type
NO x
VOC
CO
TK-01 thru TK-
04
003
0.1
3.8
0.6
Point
See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Facility -wide emissions of each individual hazardous air pollutant shall be less than 8.0
tpy.
Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)
from each emission unit, on a rolling twelve (12) month total. By the end of each month
a new twelve-month total shall be calculated based on the previous twelve months' data.
The permit holder shall calculate emissions each month and keep a compliance record
on site or at a local field office with site responsibility, for Division review. This rolling
twelve-month total shall apply to all permitted emission units, requiring an APEN, at this
facility.
8. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
AIRS ID: 123-9E58-003 Page 2 of 11
Colorado Department of Public Health and Environment
Air Pollution Control Division
Facility
Equipment ID
AIRS Point
Control Device
Pollutants
Controlled
TK-01 thru TK-04
003
Enclosed Combustor
VOC, HAPs
PROCESS LIMITATIONS AND RECORDS
9. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates shall be maintained by the owner or
operator and made available to the Division for inspection upon request. (Reference:
Regulation 3, Part B, II.A.4)
Process/Consumption Limits
Facility
Equipment ID
AIRS Point
Process Parameter
Annual Limit
TK-01 thru TK-04
003
Oil Throughput
204,400 barrels/year
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on
the previous twelve months' data. The permit holder shall calculate throughput each
month and keep a compliance record on site or at a local field office with site
responsibility, for Division review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. The permit number and 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)
11. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation
of the source. During periods of startup, process modification, or adjustment of control
equipment visible emissions shall not exceed 30% opacity for more than six minutes in
any sixty consecutive minutes. Emission control devices subject to Regulation 7,
Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation
No. 1, Section II.A.1. & 4.)
12. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
13. The flare(s) covered by this permit is subject to Regulation No. 7, Section XVII.B
General Provisions (State only enforceable). These requirements include, but are not
limited to:
XVII.B.2.b If a combustion device is used to control emissions of volatile organic
compounds to comply with Section XVII, it shall be enclosed, have no visible
emissions during normal operations, and be designed so that an observer can,
by means of visual observation from the outside of the enclosed combustion
device, or by other means approved by the Division, determine whether it is
operating properly.
AIRS ID: 123-9E58-003 Page 3 of 11
Colorado Department of Public Health and Environment
Air Pollution Control Division
XVII.B.2.d Auto -igniters: All combustion devices used to control emissions of
hydrocarbons must be equipped with and operate an auto -igniter as follows:
XVII.B.2.d.(i) All combustion devices installed on or after May 1, 2014, must be equipped
with an operational auto -igniter upon installation of the combustion device.
XVII.B.2.d.(ii) All combustion devices installed before May 1, 2014, must be equipped
with an operational auto -igniter by or before May 1, 2016, or after the next
combustion device planned shutdown, whichever comes first.
14. The storage tanks covered by this permit are subject to Regulation 7, Section XVII.C
emission control requirements. These requirements include, but are not limited to:
Section XVII.C.1. Control and monitoring requirements for storage tanks
XVII.C.1.b. Owners or operators of storage tanks with uncontrolled actual emissions of
VOCs equal to or greater than six (6) tons per year based on a rolling twelve-
month total must operate air pollution control equipment that achieves an
average hydrocarbon control efficiency of 95%. If a combustion device is used, it
must have a design destruction efficiency of at least 98% for hydrocarbons.
XVII.C.1.b.(i)(a) Control requirements of Section XVII.C.1.b. must be achieved
within ninety (90) days of the date that the storage tank commences
operation.
XVII.C.1.d. Beginning May 1, 2014, or the applicable compliance date in Section
XVII.C.1.b.(i), whichever comes later, owners or operators of storage tanks
subject to Section XVII.C.1. must conduct audio, visual, olfactory ("AVO") and
additional visual inspections of the storage tank and any associated equipment
(e.g. separator, air pollution control equipment, or other pressure reducing
equipment) at the same frequency as liquids are loaded out from the storage
tank. These inspections are not required more frequently than every seven (7)
days but must be conducted at least every thirty one (31) days. Monitoring is not
required for storage tanks or associated equipment that are unsafe, difficult, or
inaccessible to monitor, as defined in Section XVII.C.1.e. The additional visual
inspections must include, at a minimum:
XVII.C.1.d.(i) Visual inspection of any thief hatch, pressure relief valve, or other
access point to ensure that they are closed and properly sealed;
XVII.C.1.d.(ii) Visual inspection or monitoring of the air pollution control
equipment to ensure that it is operating, including that the pilot light is lit
on combustion devices used as air pollution control equipment;
XVII.C.1.d.(iii) If a combustion device is used, visual inspection of the auto -igniter
and valves for piping of gas to the pilot light to ensure they are functioning
properly;
XVII.C.1.d.(iv) Visual inspection of the air pollution control equipment to ensure
that the valves for the piping from the storage tank to the air pollution
control equipment are open; and
XVII.C.1.d.(v) If a combustion device is used, inspection of the device for the
presence or absence of smoke. If smoke is observed, either the
equipment must be immediately shut-in to investigate the potential cause
for smoke and perform repairs, as necessary, or EPA Method 22 must be
AIRS ID: 123-9E58-003 Page 4 of 11
Colorado Department of Public Health and Environment
Air Pollution Control Division
conducted to determine whether visible emissions are present for a
period of at least one (1) minute in fifteen (15) minutes.
XVII.C.1.e. If storage tanks or associated equipment is unsafe, difficult, or inaccessible
to monitor, the owner or operator is not required to monitor such equipment until
it becomes feasible to do so.
XVII.C.2. Capture and monitoring requirements for storage tanks that are fitted
with air pollution control equipment as required by Sections XII.D. or
XVII.C.1.
XVII.C.2.a. Owners or operators of storage tanks must route all hydrocarbon emissions
to air pollution control equipment, and must operate without venting hydrocarbon
emissions from the thief hatch (or other access point to the tank) or pressure
relief device during normal operation, unless venting is reasonably required for
maintenance, gauging, or safety of personnel and equipment. Compliance must
be achieved in accordance with the schedule in Section XVII.C.2.b.(ii).
XVII.C.2.b. Owners or operators of storage tanks subject to the control requirements of
Sections XII.D.2., XVII.C.1.a, or XVII.C.1.b. must develop, certify, and implement
a documented Storage Tank Emission Management System ("STEM") plan to
identify, evaluate, and employ appropriate control technologies, monitoring
practices, operational practices, and/or other strategies designed to meet the
requirements set forth in Section XVII.C.2.a. Owners or operators must update
the STEM plan as necessary to achieve or maintain compliance. Owners or
operators are not required to develop and implement STEM for storage tanks
containing only stabilized liquids. The minimum elements of STEM are listed
below.
XVII.C.2.b.(i) STEM must include selected control technologies, monitoring
practices, operational practices, and/or other strategies; procedures for
evaluating ongoing storage tank emission capture performance; and
monitoring in accordance with approved instrument monitoring methods
following the applicable schedule in Section XVII.C.2.b.(ii) and Inspection
Frequency in Table 1.
XVII.C.2.b.(ii) Owners or operators must achieve the requirements of Sections
XVII.C.2.a. and XVII.C.2.b. and begin implementing the required
approved instrument monitoring method in accordance with the following
schedule:
XVII.C.2.b.(ii)(a) A storage tank constructed on or after May 1, 2014, must
comply with the requirements of Section XVII.C.2.a. by the date the
storage tank commences operation. The storage tank must comply with
Section XVII.C.2.b. and implement the approved instrument monitoring
method inspections within ninety (90) days of the date that the storage
tank commences operation.
XVII.C.2.b.(ii)(d) Following the first approved instrument monitoring method
inspection, owners or operators must continue conducting approved
instrument monitoring method inspections in accordance with the
Inspection Frequency in Table 1.
Table 1 — Storage Tank Inspections
AIRS ID: 123-9E58-003
Page 5 of 11
Colorado Department of Public Health and Environment
Air Pollution Control Division
Threshold: Storage Tank
Uncontrolled Actual VOC
Emissions (tpy)
Approved Instrument
Monitoring Method
Inspection Frequency
Phase -In Schedule
> 6 and < 12
Annually
January 1, 2016
> 12 and < 50
Quarterly
July 1, 2015
> 50
Monthly
January 1, 2015
XVII.C.2.b.(iii) Owners or operators are not required to monitor storage tanks and
associated equipment that are unsafe, difficult, or inaccessible to monitor,
as defined in Section XVII.C.1.e.
XVII.C.2.b.(iv) STEM must include a certification by the owner or operator that
the selected STEM strategy(ies) are designed to minimize emissions from
storage tanks and associated equipment at the facility(ies), including thief
hatches and pressure relief devices.
XVII.C.3. Recordkeeping
XVII.C.3. The owner or operator of each storage tank subject to Sections XII.D. or
XVII.C. must maintain records of STEM, if applicable, including the plan, any
updates, and the certification, and make them available to the Division upon
request. In addition, for a period of two (2) years, the owner or operator must
maintain records of any required monitoring and make them available to the
Division upon request, including:
XVII.C.3.a. The AIRS ID for the storage tank.
XVII.C.3.b. The date and duration of any period where the thief hatch, pressure relief
device, or other access point are found to be venting hydrocarbon emissions,
except for venting that is reasonably required for maintenance, gauging, or safety
of personnel and equipment.
XVII.C.3.c. The date and duration of any period where the air pollution control equipment
is not operating.
XVII.C.3.d. Where a combustion device is being used, the date and result of any EPA
Method 22 test or investigation pursuant to Section XVI I.C.1.d.(v).
XVII.C.3.e. The timing of and efforts made to eliminate venting, restore operation of air
pollution control equipment, and mitigate visible emissions.
XVII.C.3.f. A list of equipment associated with the storage tank that is designated as
unsafe, difficult, or inaccessible to monitor, as described in Section XVII.C.1.e., an
explanation stating why the equipment is so designated, and the plan for monitoring
such equipment.
OPERATING & MAINTENANCE REQUIREMENTS
15. Upon startup of these points, the owner or operator shall follow the most recent
operating and maintenance (O&M) plan and record keeping format approved by the
Division, in order to demonstrate compliance on an ongoing basis with the requirements
AIRS ID: 123-9E58-003 Page 6 of 11
Colorado Department of Public Health and Environment
Air Pollution Control Division
of this permit. Revisions to your O&M plan are subject to Division approval prior to
implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
16. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Method 22 to determine the presence or absence of visible emissions. "Visible
Emissions" means observations of smoke for any period or periods of duration greater
than or equal to one (1) minute in any fifteen (15) minute period during normal operation.
(Reference: Regulation No. 7, Section XVII.A.II)
ADDITIONAL REQUIREMENTS
17. 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.
18. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit)
shall apply to this source at any such time that this source becomes major solely by
virtue of a relaxation in any permit condition. Any relaxation that increases the potential
to emit above the applicable Federal program threshold will require a full review of the
source as though construction had not yet commenced on the source. The source shall
not exceed the Federal program threshold until a permit is granted. (Regulation No. 3
Part D).
GENERAL TERMS AND CONDITIONS
19. 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.
AIRS ID: 123-9E58-003 Page 7 of 11
Colorado Department of Public Health and Environment
Air Pollution Control Division
20. 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.
21. 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.
22. 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.
23. 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.
24. 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.
25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution
Prevention and Control Act or the regulations of the AQCC may result in administrative,
civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121
(injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S.
By:
Kirk Bear
Permit Engineer
AIRS ID: 123-9E58-003 Page 8 of 11
Colorado Department of 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: 123-9E58-003 Page 9 of 11
Colorado Department of Public Health and Environment
Air Pollution Control Division
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these
fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of
receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference:
Regulation No. 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN)
and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written notice
to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: http://www.colorado.gov/cs/Satellite?c=Document C&childpagename=CDPHE-
Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis
of the specific compounds emitted if the source(s) operate at the permitted limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Reportable
Controlled
Emissions
(lb/yr)
003
Benzene
71432
2310
Yes
115
n -Hexane
110543
14758
Yes
738
Toluene
108883
2351
Yes
118
Ethylbenzene
100414
409
No
20
Xylenes
1330207
572
Yes
29
224 TMP
540841
1860
Yes
93
5) The emission levels contained in this permit are based on the following emission factors:
Pollutant
Emission Factors
Uncontrolled
lb/bbl Oil
Source
NOx
0.068
HYSIS
CO
0.31
HYSIS
VOC
1.0084
HYSIS
n -Hexane
0.0722
HYSIS
Benzene
0.0113
HYSIS
Toluene
0.0115
HYSIS
Ethylbenzene
0.0020
HYSIS
Xylenes
0.0028
HYSIS
224 TMP
0.0091
HYSIS
Note: The controlled emissions for this point are based on the flare control efficiency of 95%.
AIRS ID: 123-9E58-003
Page 10 of 11
Colorado Department of Public Health and Environment
Air Pollution Control Division
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the
most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division at
(303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC
PSD
Synthetic Minor Source of: VOC
MACT HH
Major Source Requirements: Not Applicable
Area Source Requirements: Not Applicable
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.qpoaccess.qov/
poaccess. q ov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A — Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A — Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A — Subpart Z
MACT
63.600-63.1199
Subpart AA— Subpart DDD
MACT
63.1200-63.1439
Subpart EEE — Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ — Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ — Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN — Subpart XXXXXX
9) A self certification form and guidance on how to self -certify compliance as required by this permit may
be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification
AIRS ID: 123-9E58-003
Page 11 of 11
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer:
Package #:
Received Date:
Review Start Dare:
Section 01 - Facility Information
Kirk Bear
343236
1/20/2016
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? Yes •
If yes, for what pollutant? ID Carbon Monoxide (CO) O Particulate Master (PM)
Whiting CHI and Gas Corporation
123
9E58
Razor 08E Production Facility
SENW, Section 29, T10N, R58W
Exploration & Production Well Pad '
Oil & Natural Gas Production &Processing.
Section 02 - Emissions Units In Permit Application
2 Ozone (NOx & VOC)
AIRS Point#
Emissions Source Type
Emissions
Control?
Permit
issuance #
Self Cert
Required?
Action
Engineering Remarks
001
PrliducedWater Storage Tank
: Yes
16WE0257
1
Yes
:: Permit Initial
Issuance
002
Hydrocarbon Liquid Loading
No
16WEE}2S8
1
fqo.
Permit Initial
<ESSiiance
003
Crude Oil Storage Tank.,
Yes:
16WE0259
1
• Yes • .
PermitInitial.
Issuance
004
Process Flare.
-:..Yes:...
16WE0260
1
,:... Yes' .:.:
Permit Initial
.. Issuance
Section 03 - Description of Project
Operator asking for permits on this E and P site. Site is syn-minor for V0C and HAP so sending to PC. Also has open flare request. Form completed.
Section 04 - Public Comment Requirments
Is Public Comment Required? Yes
If yes, why?' Requesting Synthetic Minor Permit
open flare
Section 05 - Ambient Air Impact Analysis Requirements
Was a quantitative modeling analysis required?` No
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
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
Non -Attainment New Source Review (NANSR): VOC
Is this stationary source a major source?
If yes, explain what programs and which pollutants here:
Data for Drop Down Lists
Facility Type List
Exploration & Production Well Pad
Natural Gas Compressor Station
Natural Gas Processing Plant
Produced Water Injection Facility
Produced Water Management Facility
Oil Stabilization (Exploration & Production)
Oil Storage and Pipeline Injection
Natural Gas Storage
Other (Describe facility type in Section 031
Emission Point List
Amine Sweetening Unit
Condensate Storage Tank
Crude Oil Storage Tank
Diesel RICE
EG Dehydrator
Fugitive Component Leaks
Hydrocarbon Liquid Loading
Maintenance Blowdowns
Natural Gas RICE
Pneumatic Pump
Process Flare
Produced Water Storage Tank
Produced Water Storage Pond
Separator Venting
TEG Dehydrator
Yes
Turbine
Vapor Recovery Tower (VRT)
Boiler or Process Heater
Other (Explain)
Emissions Control List
Enclosed Flare
Leak Detection and Repair Program
Non -Selective Catalytic Reduction (NSCR)
Open Flare
Oxidation Catalyst
Thermal Oxidizer
Vapor Recovery Unit to fuel system header
Vapor Recovery Unit to plant inlet
Permit Action Types
APEN Exempt
APEN Required / Permit Exemp:
Permit Initial Issuance
Permit Modification
Cancellation
No Action Requested
Facility Classifications
N/A
Major
Synthetic Minor
True Minor
Qualifiers
No
Yes
Public Comment
Requesting Synthetic Minor Permit
Greater than 25 tons per year in Non -Attainment Area
Greater than 50 tons per year in an Attainment Area
Alternative Control per Reg ], Sec XII.D.2.b.(ii)
Other (Davison Discretion)
NAAQS Pollutants
Carbon Monoxide (CO)
Particulate Matter (PM)
Ozone (NOx & VOC)
Industry Segment
Oil & Natural Gas Production & Processing
Natural Gas Transmission & Storage
Division Information
Engineer:
Kirk Bear
Control Engineer:
Chris Lapiante
Review Date:
03/16/2016
Application Date:
01/20/2016
Facility Identifiers
Permit No.
16WE0259
AIRS
County#
123 IWeld
Facility #
9E58
Facility Type:
exploration and production facility
El Located in the 8 -hour non -attainment area?
Administrative Information
Company Name:
Whiting Oil and Gas Corporation
Source Name:
Razor 29F Production Facility
Source Location:
SENW, Section 29, T1 ON, R58W
SIC:
1311
Mailing
Address 1:
Whiting Oil and Gas Corporation
Address
Address 2:
1700 Broadway, Suite 2300
ty, State Zip:
Denver, Colorado 80290
Name:
Justin Korkus
Person To
Phone:
303 802 8332
Contact
Fax:
720 644 3636
Email:
justin.korkus@whiting.com
Potentially located in ozone nonattainment area
True Minor
Synthetic Minor for:
rvoc rNOx r- co
Requested Action
Self Certification Required?
Issuance Number:
Yes
1
Source Description:
Oil and gas exploration and production facility known as the Razor 29F Production Facility, located in the SENW,
Section 29, T10N, R58W, Weld County, Colorado.
Point
Name
Type
Control
Action
003
TK-01 thru
TK-04
Oil Tanks
Flare
Newly
reported
source
003 Four 400 barrel crude oil storage tanks
notes: operator increased flow rate, also had incorrect emission factors/emissions on APEN
operator requests explanation of HYSIS and TANKS calculations.
Calculations
Requsted Throughput
204400
bbl
Control
Efficiency
Flare
95.00%]
Emissions Summary Table
Pollutant
Emission Factor
Uncontrolled Emissions
Controlled Emissions
Source
VOC
1.0084
lb/bbl
103.1 tpy
5.2 tpy
Hysys
Benzene
0.0113
lb/bbl
2310 lb/yr
115 lb/yr
Hysys
n -Hexane
0.0722
lb/bbl
14758 lb/yr
738 lb/yr
Hysys
toulene
0.0115
lb/bbl
2351 lb/yr
118 lb/yr
Hysys
ebenz
0.002
lb/bbl
409 lb/yr
20 lb/yr
Hysys
xylene
0.0028
lb/bbl
572 1b/yr
29 lb/yr
Hysys
224
0.0091
lb/bbl
1860 lb/yr
93 lb/yr
Hysys
Regulatory Review
Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow
or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is
based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference
test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all
subsections of Section II. A and B of this regulation.
Section II.A.5 - Smokeless Flare or Flares for the Combustion of Waste Gases No owner or operator of a
smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the
atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six
minutes in any sixty consecutive minutes.
Regulation 2 — Odor
Section I.A - No person, wherever located, shall cause or allow the emission of odorous air contaminants from any
single source such as to result in detectable odors which are measured in excess of the following limits: For areas
used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous
air has been diluted with seven (7) or more volumes of odor free air.
Regulation 6 - New Source Performance Standards
NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23184.
This source is not subject because each tank is less than 19.800 gallons (471 bbl)
NSPS OOOO: for storage vessels in the natural gas production, transmission, and processing segments.
This source is not subject because each tank emits less than 6 tpy VOC.
Regulation 7 — Volatile Organic Compounds
XII. VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS
(Applicant is not subject to the emission control requirements for condensate tanks since it is located in
an attainment area.)
XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS...
Applicant is currently subject to this since actual uncontrolled emissions are greater than 20 tpy of VOC.)
Note: This is the second set of throughputs I have run and created permits for. See email string
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API Number
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Justin Korkus
AI' Fonn-APCD-210-CruderankAPEN.doc
FORM APCD-210
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO: 16WE0260
DATE ISSUED:
ISSUED TO: Whiting Oil and Gas Corporation
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Issuance 1
Oil and gas exploration and production facility known as the Razor 29F Production
Facility, located in the SENW, Section 29, T10N, R58W, Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment ID
AIRS
Point
Description
SEP-01
004
A single two-phase separator controlled by an open flare
when the gas plant is unavailable. Open flare has a
minimum control efficiency of 95%.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO
AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS
INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than
fifteen days after commencement of operation or issuance of this permit,
whichever comes later, by submitting a Notice of Startup form to the Division. The
Notice of Startup form may be downloaded online at
www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup
of the permitted source is a violation of Air Quality Control Commission (AQCC)
Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit.
2. Within one hundred and eighty days (180) after commencement of operation or issuance
of this permit, whichever comes later, compliance with the conditions contained in this
permit shall be demonstrated to the Division. It is the owner or operator's responsibility to
self -certify compliance with the conditions. Failure to demonstrate compliance within 180
days may result in revocation of the permit. (Reference: Regulation No. 3, Part B,
III.G.2).
3. 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 flared
from each separator. The operator shall use the gas flow rate listed in the application for
actual flow rate until the flow meter is installed, not to exceed one hundred and eighty
(180) days after issuance of this permit.
AIRS ID: 123-9E58-004 Page 1 of 8
Colorado Department of Public Health and Environment
Air Pollution Control Division
4. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source
within 18 months after either, the date of issuance of this construction permit or the date
on which such construction or activity was scheduled to commence as set forth in the
permit application associated with this permit; (ii) discontinues construction for a period
of eighteen months or more; (iii) does not complete construction within a reasonable
time of the estimated completion date. The Division may grant extensions of the
deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B,
III.F.4.)
5. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Reference: Regulation No. 3, Part B, Section III.E.)
6. The following information shall be provided to the Division within fifteen (15) days after
issuance of permit.
• manufacturer
• model number
• serial number
This information shall be included with the Notice of Startup submitted for the equipment.
(Reference: Regulation No. 3, Part B, III.E.)
7. 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
8. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission Type
NO x
VOC
CO
SEP-01
004
0.3
4.4
1.3
Point
See "Notes to Permit Holderfor information on emission factors and methods used to calculate limits.
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.
9. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
AIRS ID: 123-9E58-004
Page 2 of 8
Colorado Department of Public Health and Environment
Air Pollution Control Division
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
SEP-01
004
Open Flare for Emergency Purposes
VOC, HAPs
PROCESS LIMITATIONS AND RECORDS
10. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates shall be maintained by the owner or
operator and made available to the Division for inspection upon request. (Reference:
Regulation 3, Part B, II.A.4)
Process/Consumption Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
SEP-01
004
Associated gas flared from
separator for emergency purposes.
5.6 MMscf
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on
the previous twelve months' data. The permit holder shall calculate throughput each
month and keep a compliance record on site or at a local field office with site
responsibility, for Division review.
11. The owner or operator shall continuously monitor and record the volumetric flow rate of
natural gas flared from the separator using a flow meter. The flow meter shall
continuously measure flow rate and record total volumetric flow flared from each
separator. The owner or operator shall use monthly throughput records to demonstrate
compliance with the process limits specified in this permit and to calculate emissions as
described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
12. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on
the subject equipment for ease of identification. (Reference: Regulation Number 3, Part
B, III.E.) (State only enforceable)
13. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation
of the source. During periods of startup, process modification, or adjustment of control
equipment visible emissions shall not exceed 30% opacity for more than six minutes in
any sixty consecutive minutes. Emission control devices subject to Regulation 7,
Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation
No. 1, Section II.A.1. & 4.)
14. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
15. The flare(s) covered by this permit is subject to Regulation No. 7, Section XVII.B
General Provisions (State only enforceable). These requirements include, but are not
limited to:
• XVII.B.2.b If a combustion device is used to control emissions of volatile organic
compounds to comply with Section XVII, it shall be enclosed, have no visible
AIRS ID: 123-9E58-004 Page 3 of 8
Colorado Department of Public Health and Environment
Air Pollution Control Division
emissions during normal operations, and be designed so that an observer can,
by means of visual observation from the outside of the enclosed combustion
device, or by other means approved by the Division, determine whether it is
operating properly.
• XVII.B.2.d Auto -igniters: All combustion devices used to control emissions of
hydrocarbons must be equipped with and operate an auto -igniter as follows:
• XVII.B.2.d.(i) All combustion devices installed on or after May 1, 2014, must be
equipped with an operational auto -igniter upon installation of the combustion
device.
• XVII.B.2.d.(ii) All combustion devices installed before May 1, 2014, must be
equipped with an operational auto -igniter by or before May 1, 2016, or after the
next combustion device planned shutdown, whichever comes first.
OPERATING & MAINTENANCE REQUIREMENTS
16. Upon startup of these points, the owner or operator shall follow the most recent
operating and maintenance (O&M) plan and record keeping format approved by the
Division, in order to demonstrate compliance on an ongoing basis with the requirements
of this permit. Revisions to your O&M plan are subject to Division approval prior to
implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
17. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Method 9 to measure opacity from the flare. (Reference: Regulation No. 1, Section I I.A.1
& 4)
Periodic Testing Requirements
18. There are no requirements in this section.
ADDITIONAL REQUIREMENTS
19. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation
No. 3, Part A, II.C)
a. Annually by April 30th whenever a significant increase in emissions occurs as
follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions
of five (5) tons per year or more, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions
of five percent or 50 tons per year or more, whichever is less, above the level
reported on the last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less,
above the level reported on the last APEN submitted to the Division.
AIRS ID: 123-9E58-004 Page 4 of 8
Colorado Department of Public Health and Environment
Air Pollution Control Division
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
c. Whenever new control equipment is installed, or whenever a different type of
control equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
20. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit)
shall apply to this source at any such time that this source becomes major solely by
virtue of a relaxation in any permit condition. Any relaxation that increases the potential
to emit above the applicable Federal program threshold will require a full review of the
source as though construction had not yet commenced on the source. The source shall
not exceed the Federal program threshold until a permit is granted. (Regulation No. 3
Part D).
GENERAL TERMS AND CONDITIONS
21. 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.
22. 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.
23. 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.
24. 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.
25. 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
AIRS ID: 123-9E58-004 Page 5 of 8
Colorado Department of Public Health and Environment
Air Pollution Control Division
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.
26. 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.
27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution
Prevention and Control Act or the regulations of the AQCC may result in administrative,
civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121
(injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S.
By:
Kirk Bear
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Whiting Oil and Gas Corporation
AIRS ID: 123-9E58-004 Page 6 of 8
Colorado Department of Public Health and Environment
Air Pollution Control Division
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these
fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of
receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference:
Regulation No. 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN)
and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written notice
to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: http://www.colorado.gov/cs/Satellite?c=Document C&childpaqename=CDPHE-
Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis
of the specific compounds emitted if the source(s) operate at the permitted limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(Ib/yr)
Reportable
Controlled
Emissions
(Ib/yr)
004
Benzene
71432
387
Yes
19
004
n -Hexane
110543
2930
Yes
147
004
Toluene
108883
437
Yes
22
004
Ethylbenzene
100414
85
No
4
004
Xylenes
1330207
231
No
12
5) The emission levels contained in this permit are based on the following emission factors:
Pollutant
Weight
Fraction
of Gas
(%)
Emission
Factors
Uncontrolled
Ib/MMscf
Emission
Factors
Controlled
lb/MMscf
Source
NOx (lb/MMBTU)
---
0.068
0.068
AP -42
CO (lb/MMBTU)
---
0.31
0.31
AP -42
VOC
22.37
31651.4423
1582.5721
Gas Analysis
Benzene
0.033
68.8445
3.4422
Gas Analysis
Toluene
0.032
77.8048
3.8902
Gas Analysis
Ethylbenzene
0.005
15.1271
0.7564
Gas Analysis
Xylenes
0.015
41.1794
2.059
Gas Analysis
n -hexane
0.229
521.4004
26.07
Gas Analysis
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the
AIRS ID: 123-9E58-004
Page 7 of 8
Colorado Department of Public Health and Environment
Air Pollution Control Division
most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division at
(303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC
PSD
Synthetic Minor Source of: VOC
MACT HH
Major Source Requirements: Not Applicable
Area Source Requirements: Not Applicable
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http: //ecfr. u po a ccess. q ov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A— Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A — Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
SubpartA— SubpartZ
MACT
63.600-63.1199
Subpart AA — Subpart DDD
MACT
63.1200-63.1439
Subpart EEE — Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ — Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ — Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN — Subpart XXXXXX
9) A self certification form and guidance on how to self -certify compliance as required by this permit may
be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification.
AIRS ID: 123-9E58-004 Page 8 of 8
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer:
Package #:
Received Date:
Review Start Date:
Section 01 - Facility Information
Kirk Bear
343236
1/20/2016
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?
Whiting Oil and Gas Corporation
123
9E58
Razor 08E Production Facility
SENW, Section 29, T10N, R58W
Exploration & Production Well Pad
Oil & Natural Gas Production & Processing
Yes
❑ Carbon Monoxide (CO) ❑ Particulate Matter (PM) Q Ozone (N
Section 02 - Emissions Units In Permit Application
AIRs Point #
Emissions Source Type
Emissions
Control?
Permit #
Issuance #
001
Produced Water Storage Tank
Yes
16WE0257
1
002
Hydrocarbon Liquid Loading
No
16WE0258
1
003
Crude Oil Storage Tank
Yes
16WE0259
1
004
Process Flare
Yes
16WE0260
1
Section 03 - Description of Project
Operator asking for permits on this E and P site. Site is syn-minor for VOC and HAP so sending to I
Section 04 - Public Comment Requirments
Is Public Comment Required?
If yes, why?1
Requesting Synthetic Minor Permit
open flare
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?
If yes, explain what programs and which pollutants here:
Title V Operating Permits (OP) : VOC
Non Attainment New Source Review (NANSR): VOC
Is this stationary source a major source?
If yes, explain what programs and which pollutants here:
No
yes
No
Data for Drop Down Lists
Facility Type List
Exploration & Production Well Pad
Natural Gas Compressor Station
Natural Gas Processing Plant
Produced Water Injection Facility
Produced Water Management Facility
Oil Stabilization (Exploration & Production)
Oil Storage and Pipeline Injection
Natural Gas Storage
Other (Describe facility type in Section 03)
Emission Point List
Amine Sweetening Unit
Condensate Storage Tank
Crude Oil Storage Tank
Diesel RICE
EG Dehydrator
Fugitive Component Leaks
Hydrocarbon Liquid Loading
Maintenance Blowdowns
Natural Gas RICE
Pneumatic Pump
Process Flare
Produced Water Storage Tank
Produced Water Storage Pond
Separator Venting
TEG Dehydrator
Turbine
Vapor Recovery Tower (VRT)
Boiler or Process Heater
Other (Explain)
Emissions Control List
Enclosed Flare
Leak Detection and Repair Program
Non -Selective Catalytic Reduction (NSCR)
Open Flare
Oxidation Catalyst
Thermal Oxidizer
Vapor Recovery Unit to fuel system header
Vapor Recovery Unit to plant inlet
Permit Action Types
APEN Exempt
APEN Required / Permit Exempt
Permit Initial Issuance
Permit Modification
Cancellation
No Action Requested
Facility Classifications
N/A
Major
Synthetic Minor
True Minor
Qualifiers
No
Yes
Public Comment
Requesting Synthetic Minor Permit
Greater than 25 tons per year in Non -Attainment Area
Greater than 50 tons per year in an Attainment Area
Alternative Control per Reg 7, Sec XII.D.2.b.(ii)
Other (Divison Discretion)
NAAQS Pollutants
Carbon Monoxide (CO)
Particulate Matter (PM)
Ozone (NOx & VOC)
Industry Segment
Oil & Natural Gas Production & Processing
Natural Gas Transmission & Storage
O Ozone (NOx & VOC)
Self Cert
Required?
Action
Engineering Remarks
Permit Initial
Issuance
Permit Initial'
Issuance
Yes
it Initia
Yes
Issuance
........................................
.............................
..................................
PC. Also has open flare request. Form completed.
Division Information
Engineer:
Kirk Bear
Control Engineer:
Chris Laplante
Review Date:
03/16/2016
Application Date:
01/20/2016
Facility Identifiers
Permit No.
16WE0260
AIRS
County #
123 (Weld
Facility #
9E58
Facility Type:
exploration and production facility
❑� Located in the 8 -hour non -attainment area?
Administrative Information
Company Name:
Whiting Oil and Gas Corporation
Source Name:
Razor 29F Production Facility
Source Location:
SENW, Section 29, T10N, R58W
SIC:
1311
Address 1:
Whiting Oil and Gas Corporation
Mailing
Address
Address 2:
1700 Broadway, Suite 2300
ty, State Zip:
Denver, Colorado 80290
Name:
Justin Korkus
Person To
Phone:
303 802 8332
Contact
Fax:
720 644 3636
Email:
justin.korkus@whitine.com
Potentially located in ozone nonattainment area
O True Minor
Synthetic Minor for:
r VOC r NOx r co
Requested Action
Self Certification Required?
Issuance Number:
Yes
Source Description:
Oil and gas exploration and production facility known as the Razor 29F Production Facility, located in the SENW,
Section 29, T10N, R58W, Weld County, Colorado.
Point
Name
Type
Control
Action
004
SEP-01
Separator Venting
Flare
Newly
reported
source
A single two-phase separator controlled by an enclosed flare. Flare has a minimum control efficiency of
004 95%.
Equipment Description
This source vents natural gas from
Emissions from this source are:
a well head separator
routed to a flare
Natural gas venting from a well head separator. Emissions from this source are routed to a flare.
Calculations
Emission Calculation Method
EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10 4-3)
Ex = Q MW Xx / C
Ex = emissions of pollutant x
Q = Volumetric flow rate/volume of gas processed
MW = Molecular weight of gas = SG of gas *MW of air
Xx = mass fraction of x in gas
C = molar volume of ideal gas (379 scf/Ib-mol) at 60F and 1 atm
Throughput (O)
MW
5.62
27.2872
MMsct/yr
Ib/Ib-mol
641.5525114
0.01539726
scf/hr
MMscf/d
mole%
MW
Ibx/Ibmol
mass fraction
lb/hr
lb/yr
tpy
Helium
0.00
4.0026
0.000
0.000
0.00
0.00
0.00
CO2
2 76
44.01
1 215
0.045
2.06
18015.08
9.01
N2
0.70
28013
0.195
0.007
0.33
2898.60
1.45
methane
59.93
16.041
9 614
0.352
16 27
142558.50
71.28
ethane
14.19
30.063
4267
0.156
7.22
63274.86
31.64
propane
13.28
44.092
5.855
0.215
9.91
86824.42
43.41
isobutane
131
58.118
0.762
0.028
1.29
11298.23
5.65
n -butane
442
58.118
2.571
0.094
4.35
38125.28
19.06
isopentane
075
72.114
0.544
0.020
0.92
8070.33
4.04
n -pentane
1.00
72.114
0.722
0.026
1.22
10710.53
5.36
cyclapentane
0.12
70.13
0.087
0.003
0.15
1284.30
0.64
n -Hexane
0.23
86.18
0.198
0.007
0.33
2930.27
1.47
cyclahexane
0.06
84.16
0.049
0.002
0.08
727.56
0.36
Other hexanes
0.31
86.18
0.264
0.010
0.45
3916.82
1.96
heptanes
0.43
100.21
0.435
0.016
0.74
6444.62
3.22
methylcyclohexane
0.00
98.19
0.000
0.000
0.00
0.00
0.00
224-TMP
0.02
114.23
0.021
0.001
0.04
318.45
0.16
Benzene
0.03
78.12
0.026
0.001
0.04
386.91
0.19
Toluene
0.03
92.15
0.029
0.001
0.05
437.26
0.22
Ethylbenzene
0.01
106.17
0.006
0.000
0.01
85.01
0.04
Xylenes
001
106.17
0.016
0001
003
231.43
0.12
C8+ Heavies
0.34
119 2085646
0.411
0.015
0.70
6089.67
3.04
99 96
Notes
VOC mass fray
0 440
Total VOC (Uncontrolled)
88 94
16WE0260.CP1.xlsm
A single two-phase separator controlled by an enclosed flare. Flare has a minimum control efficiency of
004 95%.
Flaring Information
Equipment Description
Flare to combust low-pressure separator gas during VRU downtime.
Manufacturer
Steffes
Model
SHP-6
Serial Number
TBD
Gas Healing Value
1525
Btu/scf
Throughput
8570.5
MMBtu/yr
VRU Information NA
Equipment Description
En•ine to recom•ress as to sales line
Overall Control
95.00%
Flare
Combustion emission factor source:
0.07 jIb NOX/MMBtu
Emissions Summary Table
Pollutant
Uncontrolled Emission Factor
Controlled Emission Factor
Uncontrolled Emissions
Controlled Emissions
Source
V0C
31651
lb/MMscf
1582.57 lb/MMscf
88.9 tpy
4.4 tpy
Gas Analysis
Nox
0.07
Ib/MMBTU
0.07 Ib/MMBTU
0.3 tpy
0.3 tpy
AP -42
CO
0.31
Ib/MMBTU
0.31 Ib/MMBTU
1.3 tpy
1.3 tpy
AP -42
Benzene
68.64
lb/MMscf
3.44 lb/MMscf
387 lb/yr
19 lb/yr
Gas Analysis
n -Hexane
521.40
lb/MMscf
26.0700 lb/MMscf
2930 lb/yr
147 lb/yr
Gas Analysis
Toluene
77.805
lb/MMscf
3.8902 lb/MMscf
437 lb/yr
22 lb/yr
Gas Analysis
Xylenes
41.179
lb/MMsd
2.0590 lb/MMscf
231 lb/yr
12 lb/yr
Gas Analysis
Ethylbenzene
15.127
tb/MMscf
0.7564 lb/MMscf
85 lb/yr
4 lb/yr
Gas Analysis
224
56.700
lb/MMscf
2.8350 lb/MMscf
319 lb/yr
16 lb/yr
Gas Analysis
AP -42: Chapter 13.5
0.31 I Ib CO/MMBtu
Regulatory Applicability
AQCC Regulation 1
This source is subject to the opacity requirements for flares in Section ll.A.5:'No owner or operator of a smokeless flare or other
flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in
excess of 30% opacity.'
AQCC Regulation 2
Section I.A applies to all emission sources. "No person, wherever located, shall cause or allow the emission of odorous air
contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits:
For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air
has been diluted with seven (7) or more volumes of odor free air."
AQCC Regulation 7
Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014?
yes
This separator is subject to Reg 7, Section XVII.G. and control requirements of Reg 7, Section XVII.B.2
16WE0260.CP1.xlsm
AIRS (County/Plant) 123/9E58
Permit No. 16WE0260
Date 3/16/2016
Point #
SCC
Pollutant or CAS
Uncontrolled Emission
Factor
004
31000205
VOC
31651.442 Ib/MMscf
004
31000205
NOx
0.068 Ib/MMBTU
004
31000205
CO
0.31 Ib/MMBTU
004
31000205
Benzene
68.8451b/MMscf
004
31000205
n -Hexane
521.41b/MMscf
004
31000205
Toluene
77.805 Ib/MMscf
004
31000205
Ethylbenzene
15.127 lb/MMscf
004
31000205
Xylenes
41.179 lb/MMscf
Emisison Factor Source
Controlled
Actual
Emissions
(tpy)*
Controlled
Requested
Emissions
(tpy)*
PTE (tpy)*
Ctrl.
Eff%
NCRP =
reportable
?
Gas Analysis
4.4
88.9
95%
Yes
AP -42
0.3
0.3
0%
No
AP -42
1.3
1.3
0%
Yes
Gas Analysis
19.3
386.9
95%
Yes
Gas Analysis
146.5
2930.3
95%
Yes
Gas Analysis
21.9
437.3
95%
Yes
Gas Analysis
4.3
85
95%
No
Gas Analysis
11.6
231.4
95%
No
W
0-
Emission Source AIRS ID:
[Leave blank unless APCD has already assigned a permit # & AIRS ID]
Permit Number:
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization.]
Facility Equipment ID:
uested Action (check applicable request boxes)
Section 02 — Re
Section 01 — Administrative Information
Request for NEW permit or newly reported emission source
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Razor 08E Production Facility
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Source Location: SENW Section 29 T ION R58W
Elevation: 4,815
Request to limit I-APs with a Federally enforceable limit on PTE
1700 Broadway, Suite 2300
CC
ZIP Code: 80290
303-802-8332
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