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Home My WebLink About20161050.tiff A CDPHE COLORADO II Co Department of Public Health Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 11500 St PO Box 758 RECEIVE® Greeley, CO 80632 March 15, 2016 MAR 21 2016 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On March 16, 2016, the Air Pollution Control Division will begin a 30-day public notice period for Whiting Oil and Gas Corporation - Horsetail 30 Central Production Battery. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Ft. Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, P/j Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure ?1,1-bli-r-il 010 PO L1 .3I , 201 3'028-�mlr, CC= 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.go‘.,...,,.,., 1 :!-1,0,50 a John W. Hickenlooper, Governor Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer ', *\. * »lily'-`'.__ CDPHE Air Pollution Control Division CO Notice of a Proposed Project or Activity Warranting Public TM Comment Website Title: Whiting Oil and Gas Corporation - Horsetail 30 Central Production Battery - Weld County Notice Period Begins: March 16, 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: Horsetail 30 Central Production Battery Oil and gas central production facility SWNE Section 30, T10N, R57W Weld County The proposed project or activity is as follows: Applicant will operate an oil and gas production facility servicing multiple wells. New synthetic minor limits will exist for produced water tanks and flaring of gas produced in gas/liquid separators during Redtail gas gathering system downtime. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permits 16WE0019, 16WE0022 and 16WE0023 have been filed with the Weld County Clerk's office. A copy of the draft permits and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air- permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such comment must be submitted in writing to the following addressee: Bradley Eades Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us WtV COLORADO 1I `j CDPHE Construction Permit CO 1 Air Pollution Control Division Permit number: 16WE0019 Issuance: 1 Date issued: Issued to: Whiting Oil and Gas Corporation Facility Name: Horsetail 30 Central Production Battery Plant AIRS ID: 123/9E18 Physical Location: SWNE SEC 30 T10N R57W County: Weld County General Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Point Equipment Description Description ID PW-01 Sixteen (16) 400 barrel fixed roof storage Enclosed Combustion THROUGH 003 vessels used to store produced water Device PW-16 This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 2. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) forage TanK tersinn Svn miner 2C 5-1 Page 1 of 7 1 II A 3. o. a s .11 pl e all i ial compliance testing and sampling as required in this ermi d a. it - - ults • he Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 4. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NO. VOC CO Type PW-01 THROUGH PW- 003 --- --- 10.6 --- Point 16 Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility-wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 6. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility AIRS Control Device Pollutants Equipment ID Point Controlled PW-01 THROUGH 003 Enclosed Combustor(s) VOC and HAP PW-16 PROCESS LIMITATIONS AND RECORDS 7. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility AIRS Process Parameter Annual Limit Equipment ID Point PW-01 THROUGH 003 Produced Water throughput 1,612,214 barrels PW-16 f, COPHE COLORADO CO It: Air Pollution Control Division x,»u:r, . ,.,,,b1.,1.,t it t s :<or,- „r Page 2 of 7 r m. . pli c it th nn l throw°a put limits shall be determined on a rolling twelve (12) ont al. he . "• each • th 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 ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 9. This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed, have no visible emissions during normal operations, and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto-igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto-igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto-igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 12. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 13. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING a MAINTENANCE REQUIREMENTS 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (OEM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of coPrle COLORADO Air Pollution Control Division -:r1 _$��E�,�,� �,��,� Page 3 of 7 .le i ,.°'on- "Vi :ale ission means observations of smoke for any period or periods of •urat •` •r-. the • -•ual t. •"`e minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) Periodic Testing Requirements 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 18. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). 19. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities major stationary source requirements shall apply to this stationary source at any such time that this stationary source becomes major solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of Subpart HH. (Regulation Number 8, Part E, Subpart HH) GENERAL TERMS AND CONDITIONS 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC EDAE COLORADO : ir CO A Pollution Control Division f ar:no, I oatas i le-t, r<curr rnt Page 4 of 7 la n` m er Pa B, Sect <n II.B. upon a request for transfer of ownership and the ubmi o se nd th- -quired fee. 21. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Bradley Eades Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Whiting Oil and Gas Corporation CDPHE COLORADO Air Pollution Control Dunstan ��•�J 11 1, Page 5 of 7 No - -r . th- ', - this - - it issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Uncontrolled Controlled Point Pollutant CAS# Emissions Emissions (Ib/yr) (Ib/yr) Benzene 71432 11285 564 003 n-Hexane 110543 35469 1773 Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year(lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 003: Uncontrolled Controlled CAS# Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl VOC 0.262 0.013 CDPHE 71432 Benzene 0.007 3.5E-04 CDPHE 110543 n-Hexane 0.022 1.1E-03 CDPHE Note: The controlled emissions factors 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: 4 cDP" COLORADO co ,,,--.' Air Pollution Control Division 111E .,:rz,e f..4�4 11e.,-.,:_-aD-nr;� Page 6 of 7 Requirement a us Operating Permit Synthetic Minor Source of: VOC, n-Hexane, Benzene, total HAPs PSD Synthetic Minor Source of: VOC MACT HH 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.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX CDPHE COLORADO CO Air Pollution Control Division Page 7 of 7 Colorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details Review Engineer: Bradley Eades Package#: 333487 Received Date: 6/23/2015,a revised application was received 12/18/2015 Review Start Date: 12/4/2015 Section 01-Facility Information Company Name: Whiting Oil and Gas Corporation County AIRS ID: 123 Plant AIRS ID: 9E18 Facility Name: Horsetail 30 Central Production Battery Physical Address/Location: SWNE SEC 30 T10N R57W Type of Facility: Exploration&Production Well Pad What industry segment? Oil&Natural Gas Production&Processing Is this facility located in a NAAQS non-attainment area? No If yes,for what pollutant? ❑Carbon Monoxide(CO) ❑Particulate Matter(PM) ❑Ozone(NOx&VOC) Section 02-Emissions Units In Permit Application Emissions Self Cert AIRs Point# Emissions Source Type Permit# Issuance# Action Engineering Remarks Control? Required? Fugitive dust from haul APEN Required/ road traffic associated 001 Other(Explain) No 15WE1227 XP No Permit Exempt with loadout Permit Initial 002 Natural Gas RICE Yes 16WE0018 1 Yes Issuance Permit Initial 003 Produced Water Storage Tank Yes 16WE0019 1 Yes Issuance Permit Initial 004 Hydrocarbon Liquid Loading Yes 16WE0020 1 Yes Issuance Permit Initial 005 Crude Oil Storage Tank Yes - 16WE0021 1 Yes Issuance Venting from HLP Separators to open Permit Initial flare(during VRU 006 Separator Venting Yes 16WE0022 1 Yes Issuance downtime) Source is tracking Permit Initial -_ liquid throughput and 007 Vapor Recovery Tower(VRT) Yes 16WE0023 1 Yes Issuance VRU downtime Intermittent bleed pneumatic devices. Determined to be insignificant source when evaluated as individual point 008 Other(Explain) 16WE0024 Cancellation, sources Colorado Air Permitting Project Section 03-Description of Project Horsetail 30 Central Production Battery is a new oil and gas production facility located outside of the designated ozone non-attainment area.The initial applicaiton was submitted 12/18/2015 and included points 001 through 006.A revised application was received 12/18/2015 and added to this package.The revisions requested individual permits for the eight points listed above.After discussion with Chenine Wozniak at Whiting,a cancellation request was submitted for point 008. Production enters six 2-phase separators and subsequently six 3-phase heater-treaters.Produced gas from the separators and heater-treaters are routed to Redtail Gas Gathering system.When this system is not available to receive gas,the produced gas is routed to an open flare(point 006).. Crude oil from the heater-treaters enters four VRTs to facilitate further gas/liquid separation prior to storage.Gas from the VRT is also sent to Redtail gathering or flared(point 007).From the VRT,crude oil enters storage and is transferred via pipline using LACE unit or by truck loadout.Vapors from produced water tanks and condensate tanks are routed to enclosed combustors. It should be noted that with the revisions submitted on 12/18/2015,Whiting requested allowable 2%control device downtime(pilot downtime)be addressed explicitly in the permit along with 989E destruction efficiency for flares. Following discussion with permitting supervisors it was determined that based on complications related to applicability of Regulation 7,XVII control requirements,the Division does not intend to grant such a request at this time.As a result,Whiting has agreed to increase requested throughputs for these emissions points Application requested 2%control device downtime during periods when emissions are routed to the Flare.Following internal discussions it was determined that based on complications related to applicability of Regulation 7,XVII control requirements,the Division does not intend to grant such a_request at this time. Regulation 7,Section XVII statement of basis and purpose aknowledges that there will be control device downtime for controls required per XVII and sites required "average control efficiency of 95%" as a mechanism for allowing operators some downtime without violation occuring so long as the downtime does not result in an average control efficiency less than 95%considering the engineered control efficiency(manufacturer guaranteed 98%for this flare). For the purposes of this permit an overall control efficiency of 95%is granted. It is assumed that this granted control efficiency considers downtime,destruction efficiency,and collection/capture efficiency. The throughput has been increased for each point controlled by a flare to allow the operator to report up to 2%of the throughput as uncontrolled without exceeding emissions limits.All limits in the permit are based on the requested througput and 95%overall control. Section 04-Public Comment Requirments Is Public Comment Required? Y If yes,why?' Ger than SO tons per yearirater than SO tons per yearin an Attainment Area Section 05-Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required?2 No If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? No Is this stationary source a synthetic minor? Yes If yes,explain what programs and which pollutants here: Prevention of Significant Deterioration(PSD):VOC Title V Operating Permits(OP):VOC, HAPs Is this stationary source a major source? No If yes,explain what programs and which pollutants here: • • One(1)Caterpillar, Model G3516,Serial Number JEF02724,natural gas-fired,turbocharged,4SLB reciprocating internal combustion engine,site rated at 1,380 horsepower at 1,400 RPM.This engine shall be equipped with an oxidation catalyst and air-fuel ratio control.This emission unit is used for natural gas compression. 002 Engine Information Engine date of m 4/17/2014 Manufacturer:Caterpillar Model Number G3516 Serial Number: JEF02724 RPM: 1400 Site-rated RPM: 1400 Engine Function Compression Derating (Mfg's Max.Rated Horsepower @ sea level: 1380 Horsepower used for calcuations: 1380 BSCF @ 100%Load(btu/hp-hr): 7211 Site-Rated BSCF @ 100%load(btu/hp-hr): 7211 Other Engine Type 4SLB Parameters Aspiration turbo-charged Electrical Generator Max Site Rating(kw) 0 Max hrs/yr of Operation 8760 ' Calculations Fuel Use Rate @ 100%Load 7872.146191 scf/hr ACTUAL Annual Fuel Consumption 68.960 MMscf/yr MAX HU I EN I IAL Annual Fuel Consumption 68.960 MMscf/yr REQUESTED Annual Fuel Consumption 68.960 MMscf/yr Fuel Heating Value 1264 btu/scf Emission Control Information This engine shall be equipped with an oxidation catalyst and air-fuel ratio control Emissions Summary Table Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source %Reduction NOx 1.00 g/hp-hr 1.000 g/hp-hr 13.30 tpy 13.30 tpy Manufacturer(Caterpillar 0.0% CO 2.43 g/hp-hr 2.008 g/hp-hr 32.37 tpy 26.70 tpy Manufacturer(Pre-catalyt 17.5% VOC 1.50 g/hp-hr 0.700 gmp-hr 19.95 tpy 9.31 tpy Manufacturer(Pre-catalyt 53.3% Formaldehyde 0.440 g/hp-hr 0.440 g/hp-hr 11702 lb/yr 11702 lb/yr Manufacturer(EMIT) 0.0% Acetaldehyde 0.008 Ib/MMBTU 0.008 Ib/MMBTU 732 lb/yr 732 lb/yr AP-42 0.0% Acrolein 0.005 Ib/MMBTU 0.005 Ib/MMBTU 446 lb/yr 446 lb/yr AP-42 0.0% Benzene 0.0004 Ib/MMBTU 0.000 Ib/MMBTU 38 lb/yr 38 lb/yr AP-42 0.0% *Applicant is using most conservative value for uncontrolled emissions between specs provided by Caterpillar and Emit Technologies(both engine specific). Regulatory Requirements �Source is not required to model based on Division Guidelines/No NAAQS violations expected(see details Ambient Air Imp of modeling analysis) Public Comment Public Comment Not Required. Facility is an area source of HAPs,so engine is not subject to major source requirements.Engine is"new" MACT 7777 since engine was construction after 6/12/06.Requirements of MACT 7777 will be fulfilled with NSPS JJJJ compliance. Reg 7 XVII.E.2 The engine is not subject to Reg 7 XVII.E because the engine is subject to an emissions control Standards(g/hp-requirement under a New Source Performance Standard("NSPS").(Reg 7 Section XVIl.B.5) hr) Reg 7 XVI.B (Ozone NAA Not located in NAA so not subject to Reg 7 XVI.B requirements) applies? 15WE1227.CP2.xlsm One(1)Caterpillar, Model G3516,Serial Number JEF02724,natural gas-fired,turbocharged,4SLB reciprocating internal combustion engine,site rated at 1,380 horsepower at 1,400 RPM.This engine shall be equipped with an oxidation catalyst and air-fuel ratio control.This emission unit is used for natural gas compression. 002 MACT 7777(area Is this engine subject to MACT 7777 area source requirements? Yes source) Is this engine subject to NSPS JJJJ? I Yes NSPS JJJJ Note:JJJJ requriements are not currently included as permit conditions because the reg has not been adopted into Reg 6. *Subject to 60.4230(a)(4)(i) Manufactured on or after July 1,2007 w/max engine power greater than 500 hp. '60.4233 Emission Standards for Owners and Operators (e)max engine power greater than 100hp must comply with Table 1. Non-emergency SI Natural Gas(except lean burn 500<HP<1350)manufactured date 7/1/2010: NOx:1 g/hp-hr CO:2 g/hp-hr VOC:0.7 g/hp-hr 15WE1227.CP2.xlsm E1227.CP2.xlsm Sixteen(16)above ground 400 bbl produced water storage tanks.Emissions from the tanks are controlled by an enclosed flare(s) 003 Emissions Calculations Requsted Throughput 1,612,214 bbl Control Flare Efficiency 95.00% Emissions Summary Table Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 0.262 lb/bbl 211.200034 tpy 10.56 tpy CDPHE Benzene 0.007 lb/bbl 11285.498 lb/yr 564.2749 lb/yr CDPHE n-Hexane 0.022 lb/bbl 35468.708 lb/yr 1773.435 lb/yr CDPHE Regulatory Review Section II.A.1-Except as provided in paragraphs 2 through 6 below,no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20%opacity.This standard is based on 24 consecutive opacity readings taken at 15-second intervals for six minutes.The approved reference test method for visible emissions measurement is EPA Method 9(40 CFR,Part 60,Appendix A(July,1992))in all subsections of Section II.A and B of this regulation. Section II.A.5-Smokeless Flare or Flares for the Combustion of Waste Gases No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30%opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. Regulation 2—Odor Section I.A-No person,wherever located,shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven(7)or more volumes of odor free air. NOTES: *In initial application received 06/23/2015 the following was indicated:Emissions are primarily recompressed to sales pipeline using electric VRU(Jordan J-SCG10G1.57-30-4803).During VRU downtime emissions are routed to flare(Flare Industries/MAVP-0824).During analysis,a revised application was submitted requesting the control scenario represented in this permit(emissions are controlled by Leed Enclosed Combustors). *Application requested 2%control device downtime during periods when emissions are routed to the Flare.This request was denied based on complications with Reg 7 Section XVII applicabilty. For the purposes of this permit an overall control efficiency of 95%is granted. It is assumed that this granted control efficiency considers downtime,destruction efficiency,and collection/capture efficiency. The applicant originally requested 1,168,000 bbl/yr as the throughput,however this was increased to 1,612,214 bbl/yr to allow the operator to report up to 2%of the throughput as uncontrolled without exceeding emissions limits. 004 Hydrocarbon Loadout to Tanker Trucks *Requested throughput is based on assumption of 50%of total oil througput is with Lease Automatic Custody Transfer Unit in use. 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 1.72 psia TANKS 4.0/Sales Oil Composition from Hysys M Molecular Weight of Vap 53.7 lb/lb-mole TANKS 4.0/Sales Oil Composition from Hysys T Liquid Temperature 507.51 deg.R TANKS 4.0/Sales Oil Composition from Hysys L 1.36 lb/10^3 gal 5.71E-02 lb/bbl Annual requested Throughput 188993.58 BBL/yr 7937730.2 gal/yr Annual requested VOC emissions 10800 lb/yr 5.40 tpy Control: Flare Efficiency: 95% NCRPs Component Mass Fraction Benzene 0.0030 n-hexane 0.0310 Toluene 0.0020 Xylenes 0.0010 Source: Stable Sales Oil composition(Hysys) Emissions Summary Table Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 0.0571 lb/bbl 5.4 tpy 0.27 tpy AP-42 Benzene 0.0002 lb/bbl 32.4 lb/yr 1.6 lb/yr AP-42 n-Hexane 0.0018 lb/bbl 335 lb/yr 16.7 lb/yr AP-42 Toluene 0.0001 lb/bbl 22 lb/yr 1.1 lb/yr AP-42 Xylenes 0.0001 lb/bbl 11 lb/yr 0.5 lb/yr AP-42 Regulatory Review 'Regulation 3-APEN and Permitting Requirements Is this site considered an exploration and production location(e.g.well pad)? Yes 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 avenge basis? No If yes,this emissions point is categorically exempt from permit requirements per Regulation 3,Part B,Section II.D.1.1 Does this operator unload less than 6,750 bbls per year of condensate via splash fill or 16,308 bbls per year of condensate via submerged fill procedure? No If yes,this emissions point is categorically exempt from permit requirements per Regulation 3,Part B,Section II.D.1.I NOTES: *RVP reported on sales oil analysis is RVP 6.Values used from table 7.1-2 are for Crude oil RVP 5.Values for RVP 5 were accepted here since resulting change emissions were insignifcant when extrapolating,and RVP based on Figure 7.1-13a in AP-42 results in RVP<4 for a liquid bulk temperature of 60F. *Requested throughput is conservatively based on 10%of the total throughput to the tanks(point 005)since LACT is expected to be in use a minimum 90%of the time(liquids routed directly to pipeline). *Application requested 2%control device downtime during periods when emissions are routed to the Flare. This request was denied based on complications with Reg 7 Section XVII applicabilty. For the purposes of this permit an overall control efficiency of 95%is granted. It is assumed that this granted control efficiency considers downtime,destruction efficiency,and collection/capture efficiency. The applicant originally requested 135,095 bbl/yr as the throughput,however this was increased to 188,994 bbl/yr to allow the operator to report up to 2%of the throughput as uncontrolled without exceeding emissions limits. 005 Thirty-eight(38)above ground 400 bbl atmospheric crude oil storage tanks. Calculations Requsted Throughput 1862904 bbl Control Flare Efficiency 95.00%I Emissions Summary Table Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source I VOC 0.0874 lb/bbl 81.40 tpy 4.07 tpy Hysys/EPATai Benzene 0.0004 lb/bbl 763 lb/yr 38 lb/yr Hysys/EPA Tai Toluene 0.0003 lb/bbl 627 lb/yr 31 lb/yr Hysys/EPA Tai Ethylbenze 0.0001 lb/bbl 101 lb/yr 5 lb/yr Hysys/EPA Tai Xylenes 0.0001 lb/bbl 220 lb/yr 11 lb/yr Hysys/EPA Tai 2,2,4-TMP 0.0004 lb/bbl 670 lb/yr 34 lb/yr Hysys/EPA Tai n-Hexane 0.0032 lb/bbl 6017 lb/yr 301 lb/yr Hysys/EPA Tai Secondary Emissions-Combustion Device(s) gas= 2335 Btu/scf Volume of waste gas emitted per BBL of liquids produced= 0.58842795 scf/bbl* Request heat content of waste gas routed to combus 2,560 MMBTU per year Potential to Emit(PTE)heat content of waste gas 2,560 MMBTU per year *scf/bbl is based on std.gas flow(Hysys simulation) Pollutant Emission Factor Emissions while controlled Source Nox 0.068 lb/MMbtu 0.1 tpy AP-42 CO 0.31 lb/MMBtu 0.4 tpy AP-42 I Regulatory Review Section II.A.1 -Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20%opacity.This standard is based on 24 consecutive opacity readings taken at 15-second intervals for six minutes.The approved reference test method for visible emissions measurement is EPA Method 9(40 CFR, Part 60,Appendix A(July, 1992))in all subsections of Section II.A and B of this regulation. Section II.A.5-Smokeless Flare or Flares for the Combustion of Waste Gases No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30%opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. Regulation 2—Odor Section I.A-No person,wherever located,shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven(7)or more volumes of odor free air. Regulation 6 New Source Performance Standards NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84. This source is not subject because each tank is less than 19,800 gallons(471 bbl) NSPS OOOO:for storage vessels in the natural gas production,transmission,and processing segments. This source is not subject because each"storage vessel"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 subject to Section XVII.C because uncontrolled acutal emissions are permitted greater than 6 tpy VOC. NOTES: *Liquids from wellhead undergo three stages of gas/liquid separation prior to storage in tanks(2-phase Separator->3-phase Separator/Heater Treater->VRT-->Tanks)Emissions from the VRT and Tanks were modeled in Hysys using a pressurized liquid sample from the 3-phase heater-treater.Working and breathing losses were calculated using EPA Tanks and a full speciation of the sales oil obtained from the Hysys model. *Secondary emissions are below APEN thresholds and will therefore not be included as permit limits **Application requested 2%control device downtime during periods when emissions are routed to the Flare. This request was denied based on complications with Reg 7 Section XVII applicabilty. For the purposes of this permit an overall control efficiency of 95%is granted. It is assumed that this granted control efficiency considers downtime,destruction efficiency,and collection/capture efficiency. The applicant originally requested 1,350,500 bbl/yr as the throughput,however this was increased to 1,862,904 bbl/yr to allow the operator to report up to 2%of the throughput as uncontrolled without exceeding emissions limits. Six(6)high-pressure,2—phase separators controlled by flare during downtime of the gas gathering system.Flare 006 has a minimum control efficiency of 95%. (Separator 01 through 06) Equipment Description This source vents natural gas from: a well head separator Emissions from this source are: recompressed Natural gas venting from a well head separator.Emissions from this source are recompressed. Calculations Emission Calculation Method EPA Emission Inventory Improvement Program Publication:Volume II,Chapter 10-Displacement Equation(10.4-3) Ex=Q*MW*Xx/C Ex=emissions of pollutant x Q=Volumetric flow rate/volume of gas processed MW=Molecular weight of gas=SG of gas*MW of air Xx=mass fraction of x in gas C=molar volume of ideal gas(379 scf/lb-mol)at 60F and 1 atm 1.46 71.54 Throughput(Q) 100.8 MMscf/yr 11506.90953 scf/hr MW 22.49 Ib/Ib-mol 0.276165829 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 1.212 0.054 36.81 322475.38 161.24 N2 1.33 28.013 0.373 0.017 11.32 99165.65 49.58 methane 73.81 16.041 11.841 0.526 359.49 3149153.09 1574.58 ethane 10.86 30.063 3.263 0.145 99.08 867932.08 433.97 propane 7.12 44.092 3.138 0.140 9526 834486.53 417.24 isobutane 0.66 58.118 0.386 0.017 11.72 102636.62 51.32 n-butane 2.16 58.118 1.254 0.056 38.08 333569.01 166.78 isopentane 0.38 72.114 0.270 0.012 8.21 71924.10 35.96 n-pentane 0.47 72.114 0.335 0.015 10.18 89185.89 44.59 cyclopentane 0.03 70.13 0.018 0.001 0.53 4663.02 2.33 n-Hexane 0.09 86.18 0.073 0.003 2.22 19482.69 9.74 cyclohexane 0.03 84.16 0.029, 0.001 0.87 7610.41 3.81 Other hexanes 0.12 86.18 0.101 0.004 3.06 26817.36 13.41 heptanes 0.09 100.21 0.089 0.004 2.71 23720.55 11.86 methylcyclohexane 0.02 98.19 0.018 0.001 0.54 4700.71 2.35 224-TMP 0.00 114.23 0.000 0.000 0.00 0.00 0.00 Benzene 0.02 78.12 0.017 0.001 0.52 4570.97 2.29 Toluene 0.01 92.15 0.012 0.001 0.36 3186.12 1.59 Ethylbenzene 0.00 106.17 0.004 0.000 0.13 1129.50 0.56 Xylenes 0.01 106.17 0.005 0.000 0.16 1411.87 0.71 C8+Heavies 0.03 146.43 0.041 0.002 1.24 10904.65 5.45 VOC mass frac 0.2575 Total VOC(Uncontrolled) 770.00 Notes Mole%,MW,and mass fractions from Horsetail 30 CTB gas analysis collected 10/02/2015. Emissions are based on 8760 hours of operation per year. I calculated the average MW of C8+based on the average MW on the analysis for the gas. 15 WE1227.CP2.xlsm i Six(6)high-pressure,2—phase separators controlled by flare during downtime of the gas gathering system.Flare 006 has a minimum control efficiency of 95%. Flaring Information Equipment Description Flare to combust separator gas during collection system downtime. Equipment ID FLR-01 Manufacturer Flare Industries Model SFVP-0824 Serial Number SFVP-0824 Gas Heating Value 1264 Btu/scf Throughput 128675.8667 MMBtu/yr Control Efficiency 95.00% *An additional 1 MMscf/yr is added to the total volume to account for pilot gas(for secondary emissions of Nox and CO) Combustion emission factor source: AP-42:Chapter 13.5 0.07 1Ib NOX/MMBtu 0.31 jib CO/MMBtu Emissions Summary Table Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 15277.70 lb/MMscf 763.88 lb/MMscf 770.0 tpy 38.50 tpy Gas Analysis Nox 86.80 lb/MMscf 86.80 Ib/MMscf 4.37 tpy 4.37 tpy AP-42 CO 395.73 Ib/MMscf 395.73 lb/MMscf 19.9 tpy 19.94 tpy AP-42 Benzene 45.347 lb/MMscf 2.27 lb/MMscf 4571 lb/yr 229 lb/yr Gas Analysis n-Hexane 193.280 lb/MMscf 9.6640 lb/MMscf 19483 lb/yr 974 lb/yr Gas Analysis Toluene 31.608 lb/MMscf 1.5804 lb/MMscf 3186 lb/yr 159 lb/yr Gas Analysis Xylenes 14.007 lb/MMscf 0.7003 lb/MMscf 1412 lb/yr 71 lb/yr Gas Analysis Ethylbenzene 11.205 lb/MMscf 0.5603 lb/MMscf 1129 lb/yr 56 lb/yr • Gas Analysis Regulatory Applicability AQCC Regulation 1 This source is subject to the opacity requirements for flares in Section II.A.5:'No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity.' AQCC Regulation 2 Section I.A applies to all emission sources."No person,wherever located,shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven(7)or more volumes of odor free air." AQCC Regulation 7 Was the well newly constructed,hydraulically fractured,or recompleted on or after August 1,2014? yes This separator is subject to Reg 7,Section XVII.G.and control requirements of Reg 7,Section XVII.B.2 NOTES: "Application requested 2%control device downtime during periods when emissions are routed to the Flare.This request was denied based on complications with Reg 7 Section XVII applicabilty. For the purposes of this permit an overall control efficiency of 95%is granted. It is assumed that this granted control efficiency considers downtime,destruction efficiency,and collection/capture efficiency.The applicant originally requested 73 MMscf/yr as the throughput,however this was increased to 100.8 MMscf/yr to allow the operator to report up to 2%of the throughput as uncontrolled without exceeding emissions limits. "Since the separation equipment covered by this permit is subject to Section XVII.G.,the open flare is subject to control device requirements per XVII.G.and XVII.B.Per applicant,this flare is in compliance with all applicable sections of Section XVII except section XVII.B.2.b requirement for enclosed combustion device.Application indicates that Whiting is requesting use of the open flare as an alternative emissions control equipment per XVII.B.2.e..This request has been approved since the control device meets requiremetns outlined in section 2.3 of PS-Memo 15-03.Primarily,the operator will ensure compliance with all requiements of section XVII(besides being enclosed), and the control device serves as a backup to the primary collection system which utilizes a VRU. **Secondary emissions resulting from combution of waste gas are calculated assuming the entirety of the gas is controlled by the flare for permitting puposes.As previously noted,applicant has notified that a small amount of downtime is expected for the control device whichWhiting intends to report as uncontrolled. Whiting should , however continue to demonstrate compliance with the secondary emissions assuming the entirety of the gas is controlled.Since the limits are based on inflated througput (beyond what the operator reasonably expects for PTE)it is not anticipated that this would create a compliance issue. **Per email correspondence from Chenine Wozniak on 1/12/2016,FLR-01 (this high pressure flare)is equipped with a meter that directly measures the volume of gas routed to it from the Separators. **I added 1 MMscf/yr to gas total for calculating MMBtu/yrthrougput when calculating secondary emissions of Nox and CO.This value was derived by operator based on 114 scf/hr and continuous operation of the pilot. 15WE1227.CP2.xlsm Four(4)vapor recovery towers(VRTs)controlled by flare during downtime of the gas gathering system.Flare has a 006 minimum control efficiency of 95%. (Separator 16 through 19) Equipment Description This source vents natural gas from: a well head separator Emissions from this source are: recompressed Natural gas venting from a well head separator.Emissions from this source are recompressed. Emission Calculation Review A Hysys model was run based on a pressurized liquid sample from the Heater-treater(3-phase separator)prior to the VRT.The model was run assuming a liquid throughput of 1,350,500 bbl/yr(3700 bbl/day).lb/hr emission rates are from Hysys model "Vapor to VRU"stream.The lb/yr emission rate was calculated assuming 8760 hr/yr operation and divided by the total throughput in the model(3700 bbl/day).This results in a lb/bbl emission factor.Emissions are calculated based on the requested liquid througput to the VRT during VRU downtime. Calculations Total throughput to VRT: 1,350,500.00 bbl/yr collection system downtime: 16% (VRU/Redtail gathering) 'Throughput during downtime: 217,126.28 Jbbl/yr Pollutant Emissions rate(Hysys) Emissions rate Uncontrolled Emissions Factor VOC 197.957 lb/hr 1734103.32 lb/yr 1.28 lb/bbl Benzene 1.119 lb/hr 9802.44 lb/yr 0.01 lb/bbl Toluene 0.943 lb/hr 8260.68 lb/yr 0.01 lb/bbl Ethylbenzene 0.154 lb/hr 1349.04 lb/yr 0.00 lb/bbl Xylenes 0.34 lb/hr 2978.4 lb/yr 0.00 lb/bbl n-Hexane 7.902 lb/hr 69221.52 lb/yr 0.05 lb/bbl 2,2,4-TMP 0.917 lb/hr 8032.92 lb/yr 0.01 lb/bbl Notes Mole%,MW,and mass fractions input to Hysys from Horsetail 30 CTB gas analysis collected 10/02/2015. 15WE1227.CP2.xlsm Four(4)vapor recovery towers(VRTs)controlled by flare during downtime of the gas gathering system.Flare has a 006 minimum control efficiency of 95%. Flaring Information Equipment Description Flare to combust separator gas during collection system downtime. Manufacturer Flare Industries Model MAVP-0824 Serial Number TBD Gas Heating Value 2169 Btu/scf GOR 14.92 scf/bbl 32361.48 Btu/bbl Throughput 217,126.28 bbl/yr 7,026.53 MMBtu/yr 'Control Efficiency 95.00% Combustion emission factor source: AP-42:Chapter 13.5 0.07 Ilb NOX/MMBtu 0.31 Ilb CO/MMBtu Emissions Summary Table Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 1.284I1b/bbl 0.064 lb/bbl 139.4 tpy 6.97 tpy Gas Analysis Nox 0.002 lb/bbl 0.002 lb/bbl 0.2 tpy 0.2 tpy AP-42 CO 0.010 lb/bbl 0.01003 lb/bbl 1.1 tpy 1.1 tpy AP-42 Benzene 0.007 lb/bbl 0.00036 lb/bbl 1576 lb/yr 79 lb/yr Gas Analysis n-Hexane 0.051 lb/bbl 0.00256 lb/bbl 11129 lb/yr 556 lb/yr Gas Analysis Toluene 0.006 lb/bbl 0.00031 lb/bbl 1328 lb/yr 66 lb/yr Gas Analysis Xylenes 0.002 lb/bbl 0.00011 lb/bbl 479 lb/yr 24 lb/yr Gas Analysis Ethylbenzene 0.001 lb/bbl 0.00005 lb/bbl 217 lb/yr 11 lb/yr Gas Analysis Regulatory Applicability AQCC Regulation 1 This source is subject to the opacity requirements for flares in Section II.A.5:'No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30%opacity.' AQCC Regulation 2 Section I.A applies to all emission sources."No person,wherever located,shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven(7)or more volumes of odor free air." AQCC Regulation 7 Was the well newly constructed,hydraulically fractured,or recompleted on or after August 1,2014? yes This separator is subject to Reg 7,Section XVII.G.and control requirements of Reg 7,Section XVII.B.2 NOTES: **Application requested 2%control device downtime during periods when emissions are routed to the Flare.This request was denied based on complications with Reg 7 Section XVII applicabilty. For the purposes of this permit an overall control efficiency of 95%is granted. It is assumed that this gran ted control efficiency considers downtime,destruction efficiency,and collection/capture efficiency.The originally requested througput was increased to 217,126 bbl/yr to allow the operator to report up to 2%of the throughput to the VRT during VRU downtime as uncontrolled without exceeding emissions limits. **Since the separation equipment covered by this permit is subject to Section XVII.G.,the open flare is subject to control device requirements per XVII.G.and XVII.B.Per applicant, '.. this flare is in compliance with all applicable sections of Section XVII except section XVII.B.2.6 requirement for enclosed combustion device.Application indicates that Whiting is '.. requesting use of the open flare as an alternative emissions control equipment per XVII.B.2.e.This request has been approved since the control device meets requiremetns outlined !'. in section 2.3 of PS-Memo 15-03.Primarily,the operator will ensure compliance with all requiements of section XVII(besides being enclosed),and the control device serves as a backup to the primary collection system which utilizes a VRU. **Secondary emissions are below APEN thresholds and will therefore not be included as permit limits **Per correspondence from Chenine Wozniak,this emission unit is not equipped with a meter to directly measure the volume o f gas directed to the flare.As a result,Whiting has requested to monitor compliance using the crude oil throughput to the VRT during VRU(collection system)downtime.This request has been approved since emissions were modeled `.. using a site-specific pressurized liquid sample was taken upstream of the VRT.A permit condition will be included that requires monitoring of VRU downtime. 15WE1227.CP2.xlsm CDPHE Construction Permit CO 1Air Pollution ControlDivision Permit number: 1 6WE0022 Issuance: 1 Date issued: Issued to: Whiting Oil and Gas Corporation Facility Name: Horsetail 30 Central Production Battery Plant AIRS ID: 123/9E18 Physical Location: SWNE SEC 30 T10N R57W County: Weld County General Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment ID Point Equipment Description Description SEP-01 through Flaring of natural gas from six (6) high- SEP-06 006 pressure separators during gas gathering Open Flare system downtime. This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 2. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) Seca atct ,e,-. 9 ::r 5_ Page 1 of 7 3. o. a s ll pl e all i iat compliance testing and sampling as required in this •ermi . d •`• it "= - ults • "he Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 4. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NO), VOC CO Type SEP-01 THROUGH SEP- 006 --- 4.4 38.5 20.0 Point 06 Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility-wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 6. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility AIRS Control Device Pollutants Equipment ID Point Controlled SEP-01 THROUGH 006 Open Flare VOC and HAP SEP-06 PROCESS LIMITATIONS AND RECORDS 7. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility AIRS Process Parameter Annual Limit Equipment ID Point SEP-01 THROUGH 006 Natural Gas Venting 100.8 MMSCF SEP-06 CDPME COLORADO CO ' ' Air Pollution Control Division Fled:•:@ ^elf JfTniiYC Page 2 of 7 o r o rat ha monito onthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 8. The owner or operator shall continuously monitor and record the volumetric flow rate of natural gas flared from the high-pressure separator(s) using a flow meter. The flow meter shall continuously measure flow rate and record total volumetric flow routed to the open flare from the separators. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits specified and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. The open flare covered by this permit has been approved as an alternative emissions control device under Regulation Number 7, Section XVII.B.2.e. The open flare must have no visible emissions during normal operations and be designed so that an observer can, by means of visual observation from the outside of the open flare, or by other convenient means approved by the Division, determine whether it is operating properly. This open flare must be equipped with an operational auto-igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto-igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto-igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 12. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING £t MAINTENANCE REQUIREMENTS 13. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 14. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of j COP HE COLORADO Co Air Pollution Control Division Page 3 of 7 • ti• g ,..te tha or qual to:.mne minute in any fifteen minute period during normal •pera • (-- . •ti• •`-r 7, - ons XVII.B.2. and XVII.A.16) ADDITIONAL REQUIREMENTS 15. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 16. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 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 Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 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 Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation cIv COLORADO co --' Air Pollution Control Division De-,Arin r0,U ,{ , Page 4 of 7 i 1 off ch in u oriz ion Details =r obtaining final authorization to operate are located in e R re t - rtify • inal Authorization section of this permit. 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: Bradley Eades Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Company Name, Inc. CDPrtE COLORADO CO An'Pollution Control Division .:R • Page 5 of 7 No - _`-r ' .1 ...th- -- this - it issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Uncontrolled Controlled Point Pollutant CAS# Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 4571 229 Toluene 108883 3186 159 006 Ethylbenzene 100414 1129 56 Xylenes 1130207 1412 71 n-Hexane 110543 19483 974 Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 006: Uncontrolled Controlled CAS# Pollutant Emission Factors Emission Factors Source lb/MMSCF lb/MMSCF N0x --- 86.80 AP 42 CO --- 395.73 V0C 15277.70 763.88 71432 Benzene 45.34 2.27 108883 Toluene 31.61 1.58 100414 Ethylbenzene 11.20 0.56 Gas Analysis 1330207 Xylene 14.01 0.70 110543 n-Hexane 193.28 9.66 Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. Emission factors for NOx and CO are from AP-42 Chapter 13.5 and HHV of 1,264 Btu/scf. 4 DP E COLORADO Co t Air Pollution Control Division f �E A.-„,: I P:,t :Ile_at:b 1,,tior,rrenuu Page 6 of 7 6) Is . . .a e h .R.S. 5- 14.1, e h Air Pollutant Emission Notice (APEN) associated with perm a a ive y 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 Status Requirement Operating Permit Synthetic Minor Source of: VOC, Benzene, n-Hexane, Total HAPs PSD Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX CDP HE COLORADO An Pollution Control Division Page 7 of 7 cDPH>~ Construction Permit +C -' Air Pollution Control Division Permit number: 1 6WE0023 Issuance: 1 Date issued: Issued to: Whiting Oil and Gas Corporation Facility Name: Horsetail 30 Central Production Battery Plant AIRS ID: 123/9E18 Physical Location: SWNE SEC 30 T10N R57W County: Weld County General Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Point Equipment Description Description ID SEP-16 Flaring of natural gas from four(4)Vapor THROUGH 007 Recovery Towers (VRTs) during gas gathering Open Flare SEP-19 system downtime. This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 2. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) F.4.) _aster Syr) v aror Page 1 of 7 3. o. : a s ll pl5-=e all i ial compliance testing and sampling as required in this ermi d ""s it - - ults • he Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 4. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit atone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NO VOC CO Type SEP-16 THROUGH SEP- 007 --- --- 7.0 --- Point 19 Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility-wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 6. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility AIRS Control Device Pollutants Equipment ID Point Controlled SEP-16 THROUGH 007 Open Flare VOC and HAP SEP-19 PROCESS LIMITATIONS AND RECORDS 7. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility AIRS Process Parameter Annual Limit Equipment ID Point SEP-16 Crude Oil Throughput to the VRT THROUGH 007 during vapor recovery unit (VRU) 217,127 barrels SEP-19 downtime CDPHE COLORADO Air Pollution Control Division •f -cw::r I lie-. Page 2 of 7 I$oRthEjonthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 8. The owner or operator shall continuously monitor and record VRU downtime. VRU downtime shall be defined as times when the VRT gas is routed to the flare. The total hours of downtime and liquid throughput during VRU downtime shall be recorded on a monthly basis and used to demonstrate compliance with the process limits specified and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. The open flare covered by this permit has been approved as an alternative emissions control device under Regulation Number 7, Section XVII.B.2.e. The open flare must have no visible emissions during normal operations and be designed so that an observer can, by means of visual observation from the outside of the open flare, or by other convenient means approved by the Division, determine whether it is operating properly. This open flare must be equipped with an operational auto-igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto-igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto-igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 12. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING£t MAINTENANCE REQUIREMENTS 13. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the 0EtM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 14. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) CO HE COLORADO O Air Pollution Control Division Page 3 of 7 A f id E T in 'eq re w nts 15. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 16. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 17. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 18. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 19. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it wilt provide written documentation LSE COLORADO CO f Air Pollution Control Division Ibl« fedt Page 4 of 7 of ch in u oriz ion Details °-r obtaining final authorization to operate are located in e R re t' - rtify inal Authorization section of this permit. 20. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 21. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 22. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 23. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Bradley Eades Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Whiting Oil and Gas Corporation A COP" ,COLORADO 0 6y Air Pollution Control Division Page 5 of 7 lb A No .. : - --r " •l th- - - this -'` = it issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-reps 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Uncontrolled Controlled Point Pollutant CAS# Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 1576 79 Toluene 108883 1328 66 007 Ethylbenzene 100414 217 11 Xylenes 1130207 479 24 n-Hexane 110543 11129 556 Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 007: Uncontrolled Controlled CAS# Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl VOC 1.284 0.064 71432 Benzene 0.007 0.0004 108883 Toluene 0.006 0.0003 HYSYS Version 8.4 100414 Ethylbenzene 0.001 0.00005 1330207 Xylene 0.002 0.00011 110543 n-Hexane 0.051 0.0026 Note: The controlled emissions factors 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 p_ " E COLORADO co ` Air Pollution Control Division Dearr, 1 ,.4 ;,1 ie.r •I OF, >lE Page 6 of 7 • r en n al f inv 'ce to d-ermine the APEN expiration date for each emissions point :cote h errhit. ny q ons regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, Benzene, n-Hexane, total HAPs PSD Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX COPHE COLORADO O Mr Pollution Control Dru ion Page 7 of 7 U O _ h �/ G y O O O O O > N _ G z --, ., O C. eV 3 >,ZZZZZ w a °a ° d 000v, Ca 'O N L y, ✓' m .. . -.lP - E > C. 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