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Home My WebLink About20143083.tiff CDPHE ICOLORADO Co Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 11500 St PO Box 758 RECEIVED Greeley, CO 80632 lc. (� J 4,L t'1 September 30, 2014 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On October 3, 2014, the Air Pollution Control Division will publish a public notice for Whiting Oil and Gas Corporation - Razor 21 Central Production Battery, in the The Greeley Tribune. 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 date the public notice is published. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Ec Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, •-I Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe r"� :^�">�' = John W. Hickenlooper, Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer t.:. f... J 2014-3083 ' /01'3ilq ��w, itfL10 CD Public Notice Of A Proposed Project in a. CO Or Activity Warranting Public Comment Website Title: Whiting Oil and Gas Corporation - Razor 21 Central Production Battery - Weld County Released To: The Greeley Tribune On: September 30, 2014 Published: October 3, 2014 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Whiting Oil and Gas Corporation Facility: Razor 21 Central Production Battery production battery NWNE Section 21, T10N, R58W Weld County The proposed project or activity is as follows: The applicant proposes a wellpad with two engines, produced water tanks, crude oil tanks, loadout, with separator venting and associated fugitives. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non-attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and drafts of Construction Permits 14WE0889, 14WE0890, 14WE0891, 14WE0892, 14WE0893, 14WE0894, 14WE0895, 14WE0896 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such comment must be submitted in writing to the following addressee: Rebecca Vasil Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us I A® COLOR ADO 1 a; r - STATE OF COLORADO fpF C„„ ts COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION .d TELEPHONE: (303) 692-3150 +e a s. CONSTRUCTION PERMIT PERMIT NO: 14WE0889 Issuance 1 DATE ISSUED: ISSUED TO: Whiting Oil and Gas Corporation THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the Razor 21 Central Production Battery, located in NWNE Section 21 T10N R58W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Description Equipment ID Point One (1) Caterpillar, Model G3516, Serial Number JEF01264, natural gas-fired, turbo-charged, 4SLB reciprocating internal RZ-ENG-1 021 combustion engine, site rated at 1311 horsepower. This engine shall be equipped with an oxidation catalyst and air- fuel ratio control. This emission unit is used as a gas lift compressor engine. This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Caterpillar G3516 engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days after issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at https://www.colorado.gov/pacific/cdphe/other-air-permitting-notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. AIRS ID: 123/9AD0/021 Page 1 of 14 NGEngine Version 2014-1 Co A do • p e o Public Health and Environment 6 Air Pollution Control Division 2. Within one hundred and eighty days (180) after 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. (Reference: Regulation No. 3, Part B, III.G.2). 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The following information shall be provided to the Division within fifteen (15) days after issuance of permit. • manufacture date • construction date • order date • date of relocation into Colorado • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS Annual Limits: Facility AIRS Tons per Year Emission Type V0C CO Equipment ID Point NO. RZ-ENG-1 021 6.3 8.9 6.2 Point See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. AIRS ID: 123/9ADO/021 Page 2 of 14 • Col do p e o Public Health and Environment Air Pollution Control Division Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 7. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID RZ-ENG-1 021 SCO VOC, CO and HCHO PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Equipment Point Process Parameter Annual ID RZ-ENG-1 021 Consumption of natural gas as a fuel 83.31 MMscf/yr The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 10. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, AIRS ID: 123/9ADO/021 Page 3 of 14 iCo A do Pp e o Public Health and Environment 6 Air Pollution Control Division Sections XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. & 4.) 11. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) OPERATING & MAINTENANCE REQUIREMENTS 12. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 13. A source initial compliance test shall be conducted on emissions point 021 to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emission limits in this permit. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time (Reference: Regulation No. 3, Part B., Section III.G.3) Oxides of Nitrogen using EPA approved methods. Carbon Monoxide using EPA approved methods. Formaldehyde Periodic Testing Requirements 14. This engine is subject to the periodic testing requirements as specified in the operating and maintenance (O&M) plan as approved by the Division. Revisions to your O&M plan are subject to Division approval. Replacements of this unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A. ADDITIONAL REQUIREMENTS 15. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or AIRS ID: 123/9AD0/021 Page 4 of 14 Co do B r} e of Public Health and Environment Air Pollution Control Division For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine, the appropriate APEN filing fee and a cover letter explaining that the owner or operator is exercising an alternative-operating scenario and is installing a permanent replacement engine. 16. Federal regulatory program requirements (i.e. PSD or NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 17. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 18. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self- Certify for Final Authorization section of this permit. 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. AIRS ID: 123/9AD0/021 Page 5 of 14 Co do C■p e o PubI..) lic PollutionHealthand Control DivisionEnvironment 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: Rebecca Vasil Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Whiting Oil and Gas Corporation AIRS ID: 123/9AD0/021 Page 6 of 14 Co ji ado ri' p e o Public Health and Environment Air Pollution Control Division Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.E) 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/acicc-reqs 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. Uncontrolled Are the Controlled AIRS Pollutant CAS# BIN Emission emissions Emission Point Rate reportable? Rate (Ib/yr) (Ib/yr) Formaldehyde 50000 A 10,634 Yes 1,276 Acetaldehyde 75070 A 800 Yes 800 Acrolein 107028 A 492 Yes 492 021 Methanol 67561 C 239 No 239 n-Hexane 110543 C 106 No 106 Benzene 71432 A 42 No 42 Toluene 108883 C 39 No 39 5) The emission levels contained in this permit are based on the following emission factors: Point 021: Emission Factors - Emission Factors— Uncontrolled Controlled CAS Pollutant lb/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr NOx 0.1324 0.50 0.1324 0.50 CO 0.7624 2.88 0.1296 0.49 VOC 0.2197 0.83 0.1868 0.71 50000 Formaldehyde 0.1112 0.42 0.0133 0.05 75070 Acetaldehyde 0.0084 0.03 0.0084 0.03 107028 Acrolein 0.0051 0.02 0.0051 0.02 Emission factors are based on a Brake-Specific Fuel Consumption Factor of 8328 Btu/hp-hr, a site-rated horsepower value of 1311, and a fuel heat value of 1148 Btu/scf. AIRS ID: 123/9AD0/021 Page 7 of 14 Co do p e o Public Health and Environment o Ft Air Pollution Control Division Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer 0 CO Manufacturer 0 VOC Manufacturer 0 50000 Formaldehyde Manufacturer 0 75070 Acetaldehyde AP-42; Table 3.2-2 No Control (7/2000); Natural Gas 107028 Acrolein AP-42; Table 3.2-2 No Control (7/2000); Natural Gas 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN)associated with this permit is valid for a term of five years from the date it was received by the Division.A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This engine is subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal Register posting—effective March 18, 2008). This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA website at: http://www.epa.qov/ttn/atw/area/fr18ia08.odf 8) This engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January 18, 2008 Federal Register posting - effective March 18, 2008). The January 18, 2008 amendments to include requirements for area sources and engines < 500 hp located at major sources have not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 8. A copy of the complete subpart is available on the EPA website at: http://www.epa.qov/ttn/atw/area/fr18ia08.pdf Additional information regarding area source standards can be found on the EPA website at: http://www.epa.qovittn/atw/area/arearules.html 9) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, HAPs PSD Synthetic Minor Source of: VOC MACT ZZZZ Area Source Requirements:Applicable 10) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60,Appendixes Appendix A—Appendix I AIRS ID: 123/9AD0/021 Page 8 of 14 Co do , per' e o'Public Health and Environment Air Pollution Control Division 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 PA—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=WO( 11) A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification AIRS ID: 123/9AD0/021 Page 9 of 14 1 Co do p e o Public Health and Environment Air Pollution Control Division ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES October 12, 2012 2.Alternative Operating Scenarios The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility-Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS, and the owner or operator shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with a compressor engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month period. "Permanent" is defined as in the same service for more than 90 operating days in any 12 month period. The 90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90 day total. The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit. All replacement engines are subject to all federally applicable and state-only requirements set forth in this permit(including monitoring and record keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5)years and made available to the Division upon request. The owner or operator shall maintain a log on-site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make them available to the Division upon request. 2.1.1 The owner or operator may temporarily replace an existing compressor engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other requirements applicable to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. AIRS ID: 123/9AD0/021 Page 10 of 14 • " a Col. do p •' e of Public Health and Environment Air Pollution Control Division M1f •.a'Pw0.: 2.1.2 The owner or operator may permanently replace the existing compressor engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found at http://www.cdphe.state.co.us/ap/oilgaspermitting.htmi. This submittal shall be accompanied by a certification from the Responsible Official indicating that"based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. • The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at: http://www.colorado.qov/cs/Satel I ite/CD PHE-AP/CBO N/1251596520270. Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year(whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year(8760), whichever applies. AIRS ID: 123/9AD0/021 Page 11 of 14 ., Co do p e o Public Health and Environment Air Pollution Control Division For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine will be subject to, the results of the test shall be converted to the appropriate units as described in the above-mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline. 2.3 Applicable Regulations for Permanent Engine Replacements 2.3.1 Reasonably Available Control Technology(RACT): Reg 3, Part B § II.D.2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and to NOX and SO2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr. For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating internal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOX: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (§60.331) and 40 CFR Part 72 (§72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State- Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified below: Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non- selective catalyst and air fuel controller to reduce emission. Lean bum engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. AIRS ID: 123/9AD0/021 Page 12 of 14 Col ' do p e o Public Health and Environment I Air Pollution Control Division afata The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. Emission Standards: Section XVII.E—State-only requirements Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Construction or Emission Standards in G/hp-hr Max Engine HP Relocation Date NOX CO VOC January 1, 2008 2.0 4.0 1.0 100<Hp<500 January 1, 2011 1.0 2.0 0.7 July 1, 2007 2.0 4.0 1.0 500≤Hp July 1, 2010 1.0 2.0 0.7 The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. 2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ requirements). However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, § 7.8 (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. 2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting AIRS ID: 123/9AD0/021 Page 13 of 14 D; Co A do Pp e o Public Health and Environment Air Pollution Control Division requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. 2.4 Additional Sources The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site; an engine that is being installed as an entirely new emission point and not as part of an AOS- approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. AIRS ID: 123/9AD0/021 Page 14 of 14 STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT Fe a AIR POLLUTION CONTROL DIVISION , •\k‘6,1;,0i* TELEPHONE: (303)692-3150 +Ian CONSTRUCTION PERMIT PERMIT NO: 14WE0890 Issuance 1 DATE ISSUED: ISSUED TO: Whiting Oil and Gas Corporation THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the Razor 21 Central Production Battery, located in NWNE Section 21 T10N R58W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Description Equipment ID Point One (1) Caterpillar, Model G3508B, Serial Number RBK01312, natural gas-fired, turbo-charged, 4SLB RZ-ENG-2 022 reciprocating internal combustion engine, site rated at 690 horsepower. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control. This emission unit is used as a gas lift compressor engine. This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Caterpillar G3508B engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days after issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at https://www.colorado.gov/pacific/cdphe/other-air-permittinq-notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. AIRS ID: 123/9AD0/022 Page 1 of 14 NGEngine Version 2014-1 Co do m p e o' Pu Airblic PollutionHealthand Control DivisionEnvironment 2. Within one hundred and eighty days (180) after 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. (Reference: Regulation No. 3, Part B, III.G.2). 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The following information shall be provided to the Division within fifteen (15) days after issuance of permit. • manufacture date • construction date • order date • date of relocation into Colorado • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO VOC CO Emission Type RZ-ENG-2 022 3.3 3.5 3.3 Point See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. AIRS ID: 123/9ADO/022 Page 2 of 14 Co do ;' p e o Public Health and Environment Air Pollution Control Division Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 8. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID VOC, CO and RZ-ENG-2 022 SCO HCHO PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment PoRint S Annual Process Parameter Limit ID RZ-ENG-2 022 Consumption of natural gas as a fuel 43.42 MMscf/yr The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 11. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control AIRS ID: 123/9AD0/022 Page 3 of 14 Co do L>Ip e o Public Health and Environment j■r. Air Pollution Control Division equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. &4.) 12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) OPERATING & 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 your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 14. A source initial compliance test shall be conducted on emissions point 022 to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emission limits in this permit. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time (Reference: Regulation No. 3, Part B., Section III.G.3) Oxides of Nitrogen using EPA approved methods. Carbon Monoxide using EPA approved methods. Formaldehyde Periodic Testing Requirements 15. This engine is subject to the periodic testing requirements as specified in the operating and maintenance (O&M) plan as approved by the Division. Revisions to your O&M plan are subject to Division approval. Replacements of this unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A. ADDITIONAL REQUIREMENTS 16. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or AIRS ID: 123/9AD0/022 Page 4 of 14 Col do . p e o Public Health and Environment Air Pollution Control Division r2 For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 17. Federal regulatory program requirements (i.e. PSD or NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 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 No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 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 No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self- Certify for Final Authorization section of this permit. 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. AIRS ID: 123/9AD0/022 Page 5 of 14 Co do p e o Public Health and Environment Air Pollution Control Division 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: Rebecca Vasil Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Whiting Oil and Gas Corporation AIRS ID: 123/9AD01022 Page 6 of 14 Co ro rip e o Public Health and Environment Air Pollution Control Division Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aacc-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. Uncontrolled Are the Controlled AIRS Pollutant CAS# BIN Emission emissions Emission Point Rate reportable? Rate(Ib/yr) (lb/yr) Formaldehyde 50000 A 4,397 Yes 440 Acetaldehyde 75070 A 417 Yes 417 Acrolein 107028 A 256 Yes 256 022 Methanol 67561 C 125 No 125 n-Hexane 110543 C 55 No 55 Benzene 71432 A 22 No 22 Toluene 108883 C 20 No 20 5) The emission levels contained in this permit are based on the following emission factors: Point 022: Emission Factors - Emission Factors— Uncontrolled Controlled CAS Pollutant Ib/MMBtu g/bhp-hr Ib/MMBtu g/bhp-hr NOx 0.1337 0.50 0.1337 0.50 CO 0.7271 2.72 0.1309 0.49 VOC 0.1417 0.53 0.1417 0.53 50000 Formaldehyde 0.0882 0.33 0.0088 0.03 75070 Acetaldehyde 0.0084 0.03 0.0084 0.03 107028 Acrolein 0.0051 0.02 0.0051 0.02 Emission factors are based on a Brake-Specific Fuel Consumption Factor of 8247 Btu/hp-hr, a site-rated horsepower value of 690, and a fuel heat value of 1148 Btu/scf. AIRS ID: 123/9AD0/022 Page 7 of 14 Co do p e 0 Public Health ti and Environment o 1■�_ Air Pollution Control Division Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx manufacturer 0 CO manufacturer 0 VOC manufacturer 0 50000 Formaldehyde manufacturer 0 75070 Acetaldehyde AP-42; Table 3.2-2 (7/2000); No Control Natural Gas 107028 Acrolein AP-42; Table 3.2-2 (7/2000); No Control Natural Gas 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN)associated with this permit is valid for a term of five years from the date it was received by the Division.A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This engine is subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal Register posting—effective March 18, 2008). This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA website at: http://www.epa.qov/ttn/atw/area/fr18ia08.pdf 8) This engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January 18, 2008 Federal Register posting - effective March 18, 2008). The January 18, 2008 amendments to include requirements for area sources and engines < 500 hp located at major sources have not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 8. A copy of the complete subpart is available on the EPA website at: http://www.epa.aov/ttn/atw/area/fr18ia08.pdf Additional information regarding area source standards can be found on the EPA website at: http://www.epa.qov/ttn/atw/area/arearules.html 9) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, HAPs PSD Synthetic Minor Source of: VOC MACT ZZZZ Area Source Requirements: Applicable 10) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60,Appendixes Appendix A—Appendix I AIRS ID: 123/9AD0/022 Page 8 of 14 Co do • p ' e o Public Health and Environment 5 Air Pollution Control Division Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 SubpartA—SubpartZ MACT 63.600-63.1199 Subpart PA—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 11) A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification AIRS ID: 123/9AD0/022 Page 9 of 14 Co do p e o Public Health and Environment Air Pollution Control Division ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES October 12, 2012 2.Alternative Operating Scenarios The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility-Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS, and the owner or operator shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with a compressor engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month period. "Permanent" is defined as in the same service for more than 90 operating days in any 12 month period. The 90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90 day total. The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit. If the facility is a major stationary source for NANSR/PSD and this engine does not have limits below significance levels in Reg 3, part D, Il.A.42 (e.g., 39 tpy NOx limit, etc.), permanent replacements am not allowed and the permanent language should be removed;also change every instance of 90 in this paragraph to 270. All replacement engines are subject to all federally applicable and state-only requirements set forth in this permit(including monitoring and record keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5)years and made available to the Division upon request. The owner or operator shall maintain a log on-site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make them available to the Division upon request. • 2.1.1 The owner or operator may temporarily replace an existing compressor engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other AIRS ID: 123/9AD0/022 Page 10 of 14 Co ro rr e o Public Health and Environment Air Pollution Control Division requirements applicable to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. 2.1.2 The owner or operator may permanently replace the existing compressor engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. The AOS cannot be used for the permanent replacement of an entire engine at any source that is currently a major stationary source for purposes of Prevention of Significant Deterioration or Non- Attainment Area New Source Review ("PSD/NANSR") unless the existing engine has emission limits that are below the significance levels in Reg 3, Part D, II.A.42. Delete this paragraph if the facility is not major for PSD or NANSR. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found at http://www.cdphe.state.co.us/ap/oilgaspermitting.html. This submittal shall be accompanied by a certification from the Responsible Official indicating that"based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. Nothing in this AOS shall preclude the Division from taking an action, based on any permanent engine replacement(s), for circumvention of any state or federal PSD/NANSR requirement. Additionally, in the event that any permanent engine replacement(s) constitute(s) a circumvention of applicable PSD/NANSR requirements, nothing in this AOS shall excuse the owner or operator from complying with PSD/NANSR and applicable permitting requirements. Delete this paragraph if the facility is not major for PSD or NANSR. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. AIRS ID: 123/9AD0/022 Page 11 of 14 I Co do p e o Public Health and Environment Air Pollution Control Division The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol(ver March 2006 or newer)as found on the Division's web site at: htto://www.colorado.gov/cs/Satellite/CDPHE-AP/CBON/1251596520270. Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year(whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year(8760), whichever applies. For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine will be subject to, the results of the test shall be converted to the appropriate units as described in the above-mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline. 2.3 Applicable Regulations for Permanent Engine Replacements If the facility is a major stationary source for NANSR/PSD and this engine does not have limits below significance levels in Reg 3, part D, II.A.42(e.g., 39 tpy NOx limit, etc.), permanent replacements are not allowed 2.3.1 Reasonably Available Control Technology(RACT): Reg 3, Part B § II.D.2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and to NOX and 5O2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr. For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating internal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOX: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM10: Use of natural gas as fuel AIRS ID: 123/9AD0/022 Page 12 of 14 Co do • p1 e o Public Health and Environment Air Pollution Control Division As defined in 40 CFR Part 60 Subparts GG (§60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State- Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified below: Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non- selective catalyst and air fuel controller to reduce emission. Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. Emission Standards: SectionXVII.E— State-only requirements Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Construction or Emission Standards in G/hp-hr Max Engine HP Relocation Date NOX CO VOC January 1, 2008 2.0 4.0 1.0 100<Hp<500 January 1, 2011 1.0 2.0 0.7 July 1, 2007 2.0 4.0 1.0 500<Hp July 1, 2010 1.0 2.0 0.7 The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. 2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. AIRS ID: 123/9ADO/022 Page 13 of 14 J ! Co A do p e o' Public Health and Environment Air Pollution Control Division Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ requirements). However, as of October 1, 2011 the.Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part 8, §1.8 (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. 2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. 2.4 Additional Sources The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site; an engine that is being installed as an entirely new emission point and not as part of an AOS- approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. AIRS ID: 123/9AD0/022 Page 14 of 14 STATE OF COLORADO � oF Co�R COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT '� � ; AIR POLLUTION CONTROL DIVISION TELEPHONE: (303)692-3150 *1816 CONSTRUCTION PERMIT PERMIT NO: 14WE0891 Issuance 1 DATE ISSUED: ISSUED TO: Whiting Oil and Gas Corporation THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the Razor 21 Central Production Battery, located in the NWNE of Section 21, Township 10N, Range 58W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID RZ-SEP1 thru RZ- Separators controlled by a 40' flare stack. Flare has a minimum SEP-8, RZ- 023 combustion efficiency of 95%. The flare is not enclosed. FLR-1 THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S.(25-7-101 et seq),TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division)no later than fifteen days after issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at https://www.colorado.gov/pacific/cdphe/other-air-permittinq-notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days(180)after 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. (Reference: Regulation No. 3, Part B, III.G.2). AIRS ID: 123/9AD0 Page 1 of 8 Wellhead Version 2012-1 D of Dee en f Public Health and Environment Air Pollution Control Division 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i)does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii)discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The following information for all permitted equipment except fugitive emissions from equipment leaks shall be provided to the Division within fifteen (15) days after issuance of permit. • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification,with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis).(Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO, VOC CO Emission Type RZSEPI thru RZ-SEP- 023 --- 21.7 --- Point 8, RZ-FLR-1 See "Notes to Permit Holder#4"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or AIRS ID: 123/9AD0 Page 2 of 8 I of De en f Public Health and Environment Air Pollution Control Division at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 8. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID RZ-SEP1 thru RZ- 023 Separators controlled by a 40' flare stack VOC, and HAPs SEP-8, RZ- FLR-1 PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the throughput shall be maintained by the applicant and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Process Parameter Annual Limit Equipment ID Point RZ-SEP1 thru RZ-SEP- 023 Natural gas flaring 35 MMSCF/yr 8, RZ-FLR-1 The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months'data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility,for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and AIRS ID number shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 11. Visible emissions shall not exceed twenty percent(20%)opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30%opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.1. & 4.) 12. 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. (Reference: Regulation No. 1, Section II.A.5.) 13. These sources are subject to the odor requirements of Regulation No. 2. (State only enforceable) AIRS ID: 123/9AD0 Page 3 of 8 . illi ohA . De en f Public Health and Environment Air Pollution Control Division 14. The flare covered by this permit is subject to Regulation No. 7, Section XVII.B.2 General Provisions(State only enforceable). All air pollution control equipment shall be operated and maintained pursuant to the manufacturing specifications or equivalent to the extent practicable, and consistent with technological limitations and good engineering and maintenance practices. The owner or operator shall keep manufacturer specifications or equivalent on file. In addition, all such air pollution control equipment shall be adequately designed and sized to achieve the control efficiency rates and to handle reasonably foreseeable fluctuations in emissions of VOCs and other hydrocarbons during normal operations. Fluctuations in emissions that occur when the separator dumps into the tank are reasonably foreseeable. 15. Per Regulation no. 7, Section XVII.B.2.d, all combustion devices used to control emissions of hydrocarbons must be equipped with and operate an auto-igniter. 16. The separator covered by this permit is subject to Regulation 7,Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING & MAINTENANCE REQUIREMENTS 17. Upon startup of these points, the applicant shall follow the operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 18. The owner or operator shall demonstrate compliance with opacity standards using EPA Method 9 to measure opacity from the flare. (Reference: Regulation No. 1, Section II.A.5). Periodic Testing Requirements 19. On an annual basis,the operator shall complete a site specific extended gas analysis of the natural gas produced at this site that is routed to the flare in order to verify the VOC content (weight fraction) of this emission stream used in the permit application. Results of testing shall be used to determine site-specific emission factors using Division approved methods. ADDITIONAL REQUIREMENTS 20. A revised Air Pollutant Emission Notice(APEN)shall be filed:(Reference: Regulation No.3, Part A, II.C) a. Annually whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or AIRS ID: 123/9AD0 Page 4 of 8 of De en f Public Health and Environment Air Pollution Control Division For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5)tons per year,whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a differenttype of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 21. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 22. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 23. If this permit specifically states that final authorization has been granted,then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide"final"authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 24. This permit is issued in reliance upon the accuracy and completeness of information supplied by the applicant 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 applicant or applicants agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 25. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 26. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence,this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and AIRS ID: 123/9AD0 Page 5 of 8 D • oh. A + De en f Public Health and Environment Air Pollution Control Division 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 applicant,or the Division revokes a permit,the applicant or owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 27. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 28. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative,civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions),-122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Rebecca Vasil Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Whiting Oil and Gas Corporation AIRS ID: 123/9AD0 Page 6 of 8 of De °P en f Public Health and Environment Air Pollution Control Division Notes to Permit Holder: 1) The permit holder is required to pay fees for the processing time for this permit.An invoice for these fees will be issued after the permit is issued.The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit(Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the permittee 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 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 permittee 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-reqs 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. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Point Pollutant CAS# (lb/yr) reportable? Rate(Ib/yr) Benzene 71432 1800 Yes 100 Toluene 108883 1280 Yes 64 003 Ethylbenzene 100414 300 Yes 14 Xylenes 1130207 400 Yes 20 n-Hexane 110543 14000 Yes 700 5) The emission levels contained in this permit are based on the following emission factors: Weight Emission Emission CAS# Pollutant Fraction of Factors Factors Source Gas (%) Uncontrolled Controlled NOx 0.068 0.068 AP-42 lb/MMBtu lb/MMBtu CO 0.37 AP-42 0.37 lb/MMBtu lb/MMBtu VOC 37.43 24800 1240 Engineering lb/mmscf lb/mmscf Calculation 71432 Benzene 0.08 51.4 2.6 Engineering lb/mmscf lb/mmscf Calculation 108883 Toluene 0.06 36.6 1.8 Engineering lb/mmscf lb/mmscf Calculation 100414 Ethylbenzene 0.01 8.6 0.4 Engineering lb/mmscf lb/mmscf Calculation AIRS ID: 123/9AD0 Page 7 of 8 Dof De en f Public PollutionHealthand Control DivisionEnvironment Weight Emission Emission CAS# Pollutant Fraction of Factors Factors Source Gas(%) Uncontrolled Controlled 1330207 Xylenes 0.02 11.4 0.6 Engineering lb/mmscf lb/mmscf Calculation 110543 n-hexane 0.60 400 20 Engineering lb/mmscf lb/mmscf Calculation Note: The uncontrolled VOC and HAP emissions for this point were calculated using the January 28,2014 analysis of a gas sample collected from the Razor 27 well.The controlled VOC and HAP emissions factors are based on the flare control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division.A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at(303)-692- 3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC and HAPs PSD Synthetic Minor Source of: VOC MACT HH Area Source Requirements: Not Applicable/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 XXXXX( 9) A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at: http://www.colorado.qov/pacific/cdphe/air-permit-selfcertification AIRS ID: 123/9AD0 Page 8 of 8 STATE OF COLORADO ,,: �' J /F_co COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT ��/�� AIR POLLUTION CONTROL DIVISION *,, C r TELEPHONE: (303)692-3150 **'--.m'. •1876• CONSTRUCTION PERMIT PERMIT NO: 14WE0892 Issuance 1 DATE ISSUED: ISSUED TO: Whiting Oil and Gas Corporation THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the Razor 21 Central Production Battery, located in the NWNE of Section 21, Township 10N, Range 58W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID RZ-PW-1 Twenty four (24) 400 BBL fixed roof storage tanks used to store through 024 produced water. Emissions from these tanks are controlled by a RZ-PW-24 t VRU. During VRU downtime emissions are routed to an open flare. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S.(25-7-101 et seq),TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division(the Division) no later than fifteen days after issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at https://www.colorado.gov/pacific/cdphe/other-air-permittinq-notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days(180)after 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. (Reference: Regulation No. 3, Part B, III.G.2). 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i)does not commence construction/modification or operation of this source within 18 months after either the date of issuance of this construction permit or the date on which such AIRS ID: 123/9AD0 Page 1 of 12 Produced Water Tank SM/M Version 2012-1 olor Depa en f li Health and Environment it Pollution Control Division construction ' w o as s h in the permit application associated with this permit; (ii)discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification,with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO VOC CO Emission Type RZ-PW-1 through RZ- 024 --- 0.9 --- Point PW-24 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 shallbe less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 7. Operator shall calculate monthly and annual rolling 12 month total emissions based on the volume production records required by this permit and the emission factors established in the "Notes to Permit Holder"for the two process control scenarios. AIRS ID: 123/9AD0 Page 2 of 12 olor Depa en f li Health and Environment it Pollution Control Division 8. The emission th ble sh ated aintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID RZ-PW-1 through 024 VRU VOC and HAPs RZ-PW-24 RZ-PW-1 through 024 Open Flare VOC and HAPs RZ-PW-24 PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following processing rate as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment Port Process Parameter Annual ii ID RZ-PW-1 1,460,000 through 024 Produced water throughput BBUyr RZ-PW-24 The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months'data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 10. Operator shall monitor and record discrete production volumes during both VRU operation and VRU downtime when emissions are routed to the flare. 11. Records shall be kept in either an electronic file or hard copy provided that they can be promptly supplied to the Division upon request. All records shall be retained for a consecutive period of three years. STATE AND FEDERAL REGULATORY REQUIREMENTS 12. The permit number and AIRS ID point number(e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 13. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 14. The flare covered by this permit is subject to Regulation No. 7, Section XVII.B General Provisions (State only enforceable). These requirements include, but are not limited to: AIRS ID: 123/9AD0 Page 3 of 12 olor Depa en f li Health and Environment it Pollution Control Division XVII.B.1.b IfjJf o ' n used ntrol 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. The operator shall comply with all applicable requirements of Section XVII. XVII.B.2.d.(ii)All combustion devices installed before May 1, 2014, must be equipped with an operational auto-igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. If an operator has an open flare controlling equipment as required under Section XVII, the flare may not need to be enclosed, if: • The open flare was permitted prior to May 1, 2014; • The operator has commenced operation of the E&P facility with an open flare prior to May 1, 2014 and has submitted a permit application to the Division in a timely manner, but has not yet received a permit; or • The operator has commenced operation of a crude oil storage tank controlled by an open flare prior to May 1, 2014. Even with an open flare, sources are subject to the requirements to employ an auto-igniter (per Section XVII.B.2.d.(ii)), to operate with no visible emissions, and to control emissions with at least a 95% efficiency. 15. The storage tanks covered by this permit are subject to Regulation 7, Section XVII.C emission control requirements. These requirements include, but are not limited to: Section XVII.C.1. Control and monitoring requirements for storage tanks XVII.C.1.b. Owners or operators of storage tanks with uncontrolled actual emissions of VOCs equal to or greater than six(6)tons per year based on a rolling twelve-month total must operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. XVII.C.1.b.(i)(b) Control requirements of Section XVII.C.1.b. must be achieved by May 1, 2015. XVII.C.1.d. Beginning May 1, 2014, or the applicable compliance date in Section XVII.C.1.b.(i), whichever comes later, owners or operators of storage tanks constructed before May 1, 2014 subject to Section XVII.C.1. must conduct audio, visual,olfactory("AVO")and additional visual inspections of the storage tank and any associated equipment (e.g. separator, air pollution control equipment, or other pressure reducing equipment)at the same frequency as liquids are loaded out from the storage tank. These inspections are not required more frequently than every seven (7)days but must be conducted at least every thirty one(31)days. Monitoring is not required for storage tanks or associated equipment that are unsafe,difficult,or inaccessible to monitor, as defined in Section XVII.C.1.e. The additional visual inspections must include, at a minimum: XVII.C.1.d.(i) Visual inspection of any thief hatch, pressure relief valve, or other access point to ensure that they are closed and properly sealed; AIRS ID: 123/9AD0 Page 4 of 12 , IV °loll Depa+ en .f • l.li ''Health and Environment 4 it Pollution Control Division XVII.C - Pisu. in p-T4,,,.,n•r -i .. `:• ofthe ,: r,+Ilutioncontrol equipment to ensure that it is operating, including that the pilot light is lit on combustion devices used as air pollution control equipment; XVII.C.1.d.(iii) If a combustion device is used, visual inspection of the auto-igniter and valves for piping of gas to the pilot light to ensure they are functioning properly; XVII.C.1.d.(iv)Visual inspection of the air pollution control equipment to ensure that the valves for the piping from the storage tank to the air pollution control equipment are open; and XVII.C.1.d.(v) If a combustion device is used, inspection of the device for the presence or absence of smoke. If smoke is observed, either the equipment must be immediately shut-in to investigate the potential cause for smoke and perform repairs, as necessary, or EPA Method 22 must be conducted to determine whether visible emissions are present for a period of at least one (1) minute in fifteen (15) minutes. XVII.C.1.e. If storage tanks or associated equipment is unsafe, difficult, or inaccessible to monitor, the owner or operator is not required to monitor such equipment until it becomes feasible to do so. XVII.C.2. Capture and monitoring requirements for storage tanks that are fitted with air pollution control equipment as required by Sections XII.D. or XVII.C.1. XVII.C.2.a. Owners or operators of storage tanks must route all hydrocarbon emissions to air pollution control equipment, and must operate without venting hydrocarbon emissions from the thief hatch (or other access point to the tank) or pressure relief device during normal operation, unless venting is reasonably required for maintenance, gauging, or safety of personnel and equipment. Compliance must be achieved in accordance with the schedule in Section XVII.C.2.b.(ii). XVII.C.2.b. Owners or operators of storage tanks subject to the control requirements of Sections XII.D.2., XVII.C.1.a, or XVII.C.1.b. must develop, certify, and implement a documented Storage Tank Emission Management System("STEM")plan to identify, evaluate, and employ appropriate control technologies, monitoring practices, operational practices, and/or other strategies designed to meet the requirements set forth in Section XVII.C.2.a. Owners or operators must update the STEM plan as necessary to achieve or maintain compliance. Owners or operators are not required to develop and implement STEM for storage tanks containing only stabilized liquids. The minimum elements of STEM are listed below. XVII.C.2.b.(i) STEM must include selected control technologies, monitoring practices, operational practices, and/or other strategies; procedures for evaluating ongoing storage tank emission capture performance; and monitoring in accordance with approved instrument monitoring methods following the applicable schedule in Section XVII.C.2.b.(ii) and Inspection Frequency in Table 1. XVII.C.2.b.(ii) Owners or operators must achieve the requirements of Sections XVII.C.2.a. and XVII.C.2.b. and begin implementing the required approved instrument monitoring method in accordance with the following schedule: XVII.C.2.b.(ii)(b)A storage tank constructed before May 1, 2014, must comply with the requirements of Sections XVII.C.2.a. and XVII.C.2.b. by May 1, 2015. AIRS ID: 123/9AD0 Page 5 of 12 olor Depa en f li Health and Environment it Pollution Control Division JJ i it d ins ' ns must begin within ninety (90) days of the Phase-In Schedule in Table 1, or within thirty(30) days for storage tanks with uncontrolled actual VOC emissions greater than 50 tons per year. XVII.C.2.b.(ii)(d) Following the first approved instrument monitoring method inspection, owners or operators must continue conducting approved instrument monitoring method inspections in accordance with the Inspection Frequency in Table 1. Table 1 — Storage Tank Inspections Threshold: Storage Tank Approved Instrument Phase-In Schedule Uncontrolled Actual VOC Monitoring Method Emissions (tpy) Inspection Frequency > 6 and < 12 Annually January 1, 2016 > 12 and < 50 Quarterly July 1, 2015 > 50 Monthly January 1, 2015 XVII.C.2.b.(iii) Owners or operators are not required to monitor storage tanks and associated equipment that are unsafe,difficult,or inaccessible to monitor,as defined in Section XVII.C.1.e. XVII.C.2.b.(iv) STEM must include a certification by the owner or operator that the selected STEM strategy(ies) are designed to minimize emissions from storage tanks and associated equipment at the facility(ies), including thief hatches and pressure relief devices. XVII.C.3. Recordkeeping XVII.C.3. The owner or operator of each storage tank subject to Sections XII.D. or XVII.C. must maintain records of STEM, if applicable, including the plan, any updates, and the certification, and make them available to the Division upon request. In addition, for a period of two (2) years, the owner or operator must maintain records of any required monitoring and make them available to the Division upon request,including: XVII.C.3.a. The AIRS ID for the storage tank. XVI I.C.3.b.The date and duration of any period where the thief hatch, pressure relief device, or other access point are found to be venting hydrocarbon emissions, except for venting that is reasonably required for maintenance,gauging,or safety of personnel and equipment. XVII.C.3.c.The date and duration of any period where the air pollution control equipment is not operating. XVII.C.3.d. Where a combustion device is being used, the date and result of any EPA Method 22 test or investigation pursuant to Section XVII.C.1.d.(v). AIRS ID: 123/9AD0 Page 6 of 12 Lr olor Depa en yf •IHealth and Environment it Pollution Control Division 1rn is ;. XVII.C.3.e. T e •• of _ a-h, ate a ,tg, restore operation of air pollution control equipment, and mitigate visible emissions. XVII.C.3.f. A list of equipment associated with the storage tank that is designated as unsafe, difficult, or inaccessible to monitor, as described in Section XVII.C.1.e., an explanation stating why the equipment is so designated, and the plan for monitoring such equipment. OPERATING & MAINTENANCE REQUIREMENTS 16. Flares shall have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the flare, or by other convenient means approved by the Division, determine whether the flare is operating properly. 17. If a control device is used to comply with the emission limits of this permit, the following conditions must be met: a. Leakage of VOCs to the atmosphere must be minimized as follows: (i) Thief hatch seals shall be inspected for integrity annually and replaced as necessary. Thief hatch covers shall be weighted and properly seated. (ii) Pressure relief valves (PRV) shall be inspected for proper operation annually and replaced as necessary. PRVs shall be set to release at a pressure that will ensure flashing, working and breathing losses are routed to the control device under normal operating conditions. (iii) Annual inspections of thief hatches and PRV shall be documented with an indication of status, a description of any problems found, and their corrective action. 18. Control devices shall be adequately designed, and operated and maintained according to manufacturer specifications to achieve a control efficiency of at least 95%, and to handle reasonably foreseeable fluctuations in emissions of VOCs. Fluctuations in emissions that occur when the separator dumps into the tank are reasonably foreseeable. 19. The owner or operator shall monitor and document the proper operation of the control device. Time intervals between monitoring shall not exceed 14 days. Indications of improper operation for a flare include, but are not limited to, absence of pilot light, malfunction of electronic ignition, and/or presence of smoke. A check box is suitable for recording proper operation. Improper operation of a control device shall be further documented with a description of the problem and its corrective action, the date range the control was inoperable, and the produced water production through the battery during the downtime. If the owner or operator cannot document the date that the control equipment became inoperable then downtime shall be assumed to have started directly after the last documented monitoring event. During control device downtime, emissions shall be considered to be uncontrolled. AIRS ID: 123/9AD0 Page 7 of 12 RA Depa en f li Health and Environment it Pollution Control Division COMPLIANCE TE Initial Testing Requirements 20. The owner or operator shall demonstrate compliance with opacity standards, using EPA Method 22 to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one (1) minute in any fifteen (15) minute period during normal operation. (Reference: Regulation No. 7 Section XVII.AlI) Periodic Testing Requirements 21. No compliance requirements under this section. ADDITIONAL REQUIREMENTS 22. A revised Air Pollutant Emission Notice(APEN)shall be filed:(Reference: Regulation No.3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more,whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50%or five (5)tons per year,whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed,or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 23. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 24. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section 11.6 upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. AIRS ID: 123/9AD0 Page 8 of 12 iiiolor Depa en i f ,:di Health and Environment r •it Pollution Control Division 25 If this permit s!,.7,1•,,,-- st , %h:':-,,..1r,.-ut;1 ., :,ft has • , ,,ranted,then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final"authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 26. 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. 27. 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. 28. 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. 29. 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. 30. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. AIRS ID: 123/9AD0 Page 9 of 12 i olor Depa en f li Health and Environment it Pollution Control Division By: Rebecca Vasil Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Whiting Oil and Gas Corporation AIRS ID: 123/9AD0 Page 10 of 12 olor Depa en .f 91.11 ."Health and Environment S it Pollution Control Division Notes to Permit Holder e o e an 1) The permit holder is required to pay fees for the processing time for this permit.An invoice for these fees will be issued after the permit is issued.The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit(Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions.The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www colorado.qov/pacific/cdp he/agcc-reqs 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. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Point Pollutant CAS# (lb/yr) reportable? Rate(Ib/yr) Benzene 71432 10,220 YES 45 024 n-Hexane 110543 32,120 YES 142 5) The emission levels contained in this permit are based on the following emission factors: Point 024: Process 01: VRU in operation Emission Factors Emission Factors CAS# Pollutant Uncontrolled Controlled Source lb/BBL Produced lb/BBL Produced Water Throughput Water Throughput VOC 0.262 0.0 PS Memo 09-02 110543 n-Hexane 0.007 0.0 PS Memo 09-02 71432 Benzene 0.022 0.0 PS Memo 09-02 Note: The controlled emissions factors for process 01 are based on the VRU control efficiencies of 100 %. AIRS ID: 123/9AD0 Page 11 of 12 olor Depa en f li Health and Environment it Pollution Control Division Process 02: VRU n. -tio i ut re Emission Factors Emission Factors CAS# Pollutant Uncontrolled Controlled Source lb/BBL Produced lb/BBL Produced Water Throughput Water Throughput VOC 0.262 0.0131 PS Memo 09-02 110543 n-Hexane 0.007 0.00035 PS Memo 09-02 71432 Benzene 0.022 0.0011 PS Memo 09-02 Note: The controlled emissions factors for process 02 are based on the flare control efficiencies of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice(APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at(303)-692- 3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, 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 7777—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXX( 9) A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at: http://www.colorado.qov/pacific/cdphe/air-permit-self-certification AIRS ID: 123/9AD0 Page 12 of 12 STATE OF COLORADO I f COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION `�' '", .-.� TELEPHONE: (303)692-3150 `Jan t CONSTRUCTION PERMIT PERMIT NO: 14WE0893 Issuance 1 DATE ISSUED: • ISSUED TO: Whiting Oil and gas Corporation THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the Razor 21 Central Production Battery,located in the NWNE of Section 21, Township 10N, Range 58W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID RZ-TK-1 Thirty two (32) 400 BBL fixed roof storage tanks used to store through 025 crude oil. Emissions from these tanks are controlled by a VRU. RZ-TK-32 During VRU downtime emissions are routed to an open flare. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S.(25-7-101 et seq),TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division)no later than fifteen days after issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at https://www.colorado.gov/pacific/cdphe/other-air-permitting-notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days(180)after 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. (Reference: Regulation No. 3, Part B, III.G.2). 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i)does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which AIRS ID: 123/9AD0 Page 1 of 12 Condensate Tank SM/M Version 2012-1 Depa en f li Health and Environment it Pollution Control Division such construDolor t w d mme s set forth in the permit application associated with this permit;(ii)discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification,with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Emission Type Equipment ID Point NO„ VOC CO RZ-TK-1 through RZ- 025 --- 1.2 --- Point TK-32 See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 7. Operator shall calculate monthly and annual rolling 12 month total emissions based on the volume production records required by this permit and the emission factors established in the "Notes to Permit Holder"for the two process control scenarios. AIRS ID: 123/9AD0 Page 2 of 12 olor Depa en f li Health and Environment it Pollution Control Division 8. The emission th le sh ated aintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID RZ-TK-1 through 025 VRU VOC and HAPs RZ-TK-32 RZ-TK-1 through 025 Open Flare VOC and HAPs RZ-TK-32 PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Equipment Part Process Parameter Annual Limit ID RZ-TK-1 2,372,500 through 025 Crude Oil throughput BBL/yr RZ-TK-32 The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months'data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 10. Operator shall monitor and record discrete production volumes during both VRU operation and VRU downtime when emissions are routed to the flare. 11. Records shall be kept in either an electronic file or hard copy provided that they can be promptly supplied to the Division upon request. All records shall be retained for a consecutive period of three years. STATE AND FEDERAL REGULATORY REQUIREMENTS 12. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 13. This source is subject to the odor requirements of Regulation No.2. (State only enforceable) AIRS ID: 123/9AD0 Page 3 of 12 olor Depa en f li Health and Environment it Pollution Control Division 14. The flare cove- is i je lation 7, Section XVII.B General Provisions(State only enforceable). These requirements include, but are not limited to: XVII.B.1.b 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. The operator shall comply with all applicable requirements of Section XVII. XVII.B.2.d.(ii)All combustion devices installed before May 1, 2014, must be equipped with an operational auto-igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. If an operator has an open flare controlling equipment as required under Section XVII, the flare may not need to be enclosed, if: • The open flare was permitted prior to May 1, 2014; • The operator has commenced operation of the E&P facility with an open flare prior to May 1,2014 and has submitted a permit application to the Division in a timely manner, but has not yet received a permit; or • The operator has commenced operation of a crude oil storage tank controlled by an open flare prior to May 1, 2014. Even with an open flare, sources are subject to the requirements to employ an auto-igniter (per Section XVII.B.2.d.(ii)), to operate with no visible emissions, and to control emissions with at least a 95% efficiency. 15. The storage tanks covered by this permit are subject to Regulation 7, Section XVII.C emission control requirements. These requirements include, but are not limited to: Section XVII.C.1. Control and monitoring requirements for storage tanks XVII.C.1.b. Owners or operators of storage tanks with uncontrolled actual emissions of VOCs equal to or greater than six(6)tons per year based on a rolling twelve-month total must operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. XVII.C.1.b.(i)(b) Control requirements of Section XVII.C.1.b. must be achieved by May 1, 2015. XVII.C.1.d. Beginning May 1, 2014, or the applicable compliance date in Section XVII.C.1.b.(i), whichever comes later, owners or operators of storage tanks constructed before May 1, 2014 subject to Section XVII.C.1. must conduct audio, visual,olfactory("AVO")and additional visual inspections of the storage tank and any associated equipment (e.g. separator, air pollution control equipment, or other pressure reducing equipment)at the same frequency as liquids are loaded out from the storage tank. These inspections are not required more frequently than every seven (7)days but must be conducted at least every thirty one(31)days. Monitoring is not required for storage tanks or associated equipment that are unsafe,difficult,or inaccessible to monitor, as defined in Section XVII.C.1.e. The additional visual inspections must include, at a minimum: AIRS ID: 123/9AD0 Page 4 of 12 wad*r olor a Depa en s �f -.II Health and Environment ¢; t• .. . . it Pollution Control Division XVII.C e su c p!t ,.“.of v€\r. •• atch 3 sure relief valve, or other access point to ensure that they are closed and properly sealed; XVII.C.1.d.(ii)Visual inspection or monitoring of the air pollution control equipment to ensure that it is operating, including that the pilot light is lit on combustion devices used as air pollution control equipment; XVII.C.1.d.(iii) If a combustion device is used, visual inspection of the auto-igniter and valves for piping of gas to the pilot light to ensure they are functioning properly; XVII.C.1.d.(iv)Visual inspection of the air pollution control equipment to ensure that the valves for the piping from the storage tank to the air pollution control equipment are open; and XVII.C.1.d.(v) If a combustion device is used, inspection of the device for the presence or absence of smoke. If smoke is observed, either the equipment must be immediately shut-in to investigate the potential cause for smoke and perform repairs, as necessary, or EPA Method 22 must be conducted to determine whether visible emissions are present for a period of at least one (1) minute in fifteen (15) minutes. XVII.C.1.e. If storage tanks or associated equipment is unsafe, difficult, or inaccessible to monitor, the owner or operator is not required to monitor such equipment until it becomes feasible to do so. XVII.C.2. Capture and monitoring requirements for storage tanks that are fitted with air pollution control equipment as required by Sections XII.D. or XVII.C.1. XVII.C.2.a. Owners or operators of storage tanks must route all hydrocarbon emissions to air pollution control equipment, and must operate without venting hydrocarbon emissions from the thief hatch (or other access point to the tank) or pressure relief device during normal operation, unless venting is reasonably required for maintenance, gauging, or safety of personnel and equipment. Compliance must be achieved in accordance with the schedule in Section XVII.C.2.b.(ii). XVII.C.2.b. Owners or operators of storage tanks subject to the control requirements of Sections XII.D.2., XVII.C.1.a, or XVII.C.1.b. must develop, certify, and implement a documented Storage Tank Emission Management System("STEM")plan to identify, evaluate, and employ appropriate control technologies, monitoring practices, operational practices, and/or other strategies designed to meet the requirements set forth in Section XVII.C.2.a. Owners or operators must update the STEM plan as necessary to achieve or maintain compliance. Owners or operators are not required to develop and implement STEM for storage tanks containing only stabilized liquids. The minimum elements of STEM are listed below. XVII.C.2.b.(i) STEM must include selected control technologies, monitoring practices, operational practices, and/or other strategies; procedures for evaluating ongoing storage tank emission capture performance; and monitoring in accordance with approved instrument monitoring methods following the applicable schedule in Section XVII.C.2.b.(ii) and Inspection Frequency in Table 1. XVII.C.2.b.(ii) Owners or operators must achieve the requirements of Sections XVII.C.2.a. and XVII.C.2.b. and begin implementing the required approved instrument monitoring method in accordance with the following schedule: AIRS ID: 123/9AD0 Page 5 of 12 olor Depa en f li Health and Environment it Pollution Control Division XVII.C !` o efor 1, 2014, must comply with the requirements of Sections XVII.C.2.a. and XVII.C.2.b. by May 1, 2015. Approved instrument monitoring method inspections must begin within ninety (90) days of the Phase-In Schedule in Table 1, or within thirty (30) days for storage tanks with uncontrolled actual VOC emissions greater than 50 tons per year. XVII.C.2.b.(ii)(d) Following the first approved instrument monitoring method inspection, owners or operators must continue conducting approved instrument monitoring method inspections in accordance with the Inspection Frequency in Table 1. Table 1 — Storage Tank Inspections Threshold: Storage Tank Approved Instrument Phase-In Schedule Uncontrolled Actual VOC Monitoring Method Emissions (tpy) Inspection Frequency > 6 and < 12 Annually January 1, 2016 > 12 and < 50 Quarterly July 1, 2015 > 50 Monthly January 1, 2015 XVII.C.2.b.(iii) Owners or operators are not required to monitor storage tanks and associated equipment that are unsafe,difficult,or inaccessible to monitor,as defined in Section XVII.C.1.e. XVII.C.2.b.(iv) STEM must include a certification by the owner or operator that the selected STEM strategy(ies) are designed to minimize emissions from storage tanks and associated equipment at the facility(ies), including thief hatches and pressure relief devices. XVII.C.3. Recordkeeping XVII.C.3. The owner or operator of each storage tank subject to Sections XII.D. or XVII.C. must maintain records of STEM, if applicable, including the plan, any updates, and the certification, and make them available to the Division upon request. In addition, for a period of two (2) years, the owner or operator must maintain records of any required monitoring and make them available to the Division upon request,including: XVII.C.3.a. The AIRS ID for the storage tank. XVII.C.3.b.The date and duration of any period where the thief hatch, pressure relief device, or other access point are found to be venting hydrocarbon emissions, except for venting that is reasonably required for maintenance, gauging, or safety of personnel and equipment. XVII.C.3.c.The date and duration of any period where the air pollution control equipment is not operating. XVII.C.3.d. Where a combustion device is being used, the date and result of any EPA Method 22 test or investigation pursuant to Section XVII.C.1.d.(v). AIRS ID: 123/9AD0 Page 6 of 12 olor. ': Depa en f • . •Ii ``Health and Environment it Pollution Control Division XVII.C.3.e. T ;_ipil of gat•.e = ad- ate ,-g, restore operation of air pollution control equipment, and mitigate visible emissions. XVII.C.3.f. A list of equipment associated with the storage tank that is designated as unsafe, difficult, or inaccessible to monitor, as described in Section XVII.C.1.e., an explanation stating why the equipment is so designated, and the plan for monitoring such equipment. OPERATING & MAINTENANCE REQUIREMENTS 16. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 17. The operator shall complete site specific sampling including a compositional analysis of the pre-flash pressurized condensate routed to these storage tanks and a sales oil analysis to determine RVP and API gravity. Testing shall be in accordance with the guidance contained in PS Memo 05-01. Results of testing shall be used to determine a site-specific emissions factor using Division approved methods. Results of site-specific sampling and analysis shall be submitted to the Division as part of the self-certification and used to demonstrate compliance with the emissions factors chosen for this emissions point. 18. The owner or operator shall demonstrate compliance with opacity standards, using EPA Method 22 to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one (1) minute in any fifteen (15) minute period during normal operation. (Reference: Regulation No. 7 Section XVII.AII) Periodic Testing Requirements 19. No compliance requirements under this section. ADDITIONAL REQUIREMENTS 20. A revised Air Pollutant Emission Notice (APEN)shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or AIRS ID: 123/9AD0 Page 7 of 12 olor Depa en f Ii Health and Environment it Pollution Control Division Fora it p If the emissions increase by 50% or five (5)tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed,or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 21. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Parts C and D). GENERAL TERMS AND CONDITIONS 22. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 23. If this permit specifically states that final authorization has been granted,then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide"final"authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 24. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 25. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 26. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence,this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and AIRS ID: 123/9AD0 Page 8 of 12 olor Depat en' efliii Health and Environment f it Pollution Control Division regulations of, 'A +*u 4 • Qa o LD 4„u{•QC ,, s;; luding failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit,the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 27. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 28. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Rebecca Vasil Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Whiting Oil and Gas Corporation AIRS ID: 123/9AD0 Page 9 of 12 olor Depa en f li it PollutionHealthand Control DivisionEnvironment Notes to Permit Holder e o e an . 1) The permit holder is required to pay fees for the processing time for this permit.An invoice for these fees will be issued after the permit is issued.The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit(Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions.The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.00v/pacific/cdohe/aocc-reqs 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. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Point Pollutant CAS# (lb/yr) reportable? Rate(lb/yr) Benzene 71432 710 YES 3 025 Toluene 108883 634 YES 3 Hexane 110543 4,484 YES 20 5) The emission levels contained in this permit are based on the following emission factors: Point 025: Process 01: VRU in operation Emission Factors Emission Factors CAS# Pollutant Uncontrolled Controlled Source lb/BBL Crude Oil lb/BBL Crude Oil Throughput Throughput VOC 0.2215 0.0 Source 110543 n-Hexane 0.0019 0.0 Source 71432 Benzene 0.0003 0.0 Source 108883 Toluene 0.00029 0.0 Source Note: The controlled emissions factors for process 01 are based on the VRU control efficiencies of 100%. AIRS ID: 123/9AD0 Page 10 of 12 r olor. .. . • -Depa r en'if , ill Health and Environment .. . ... ,.. . rx it Pollution Control Division Process 02: VRU n^,_-x =.� --do a r i L••—..ut 't`' ,,re Emission Factors Emission Factors • CAS# Pollutant Uncontrolled Controlled Source lb/BBL Crude Oil lb/BBL Crude Oil Throughput Throughput VOC 0.2215 0.011 Source 110543 n-Hexane 0.0019 0.0001 Source 71432 Benzene 0.0003 0.000012 Source 108883 Toluene 0.00029 0.00001 Source Note: The controlled emissions factors for process 02 are based on the flare control efficiencies of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692- 3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, 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.upouccess.gov Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60, Appendixes Appendix A—Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX AIRS ID: 123/9AD0 Page 11 of 12 olor Depa en f Ii Health and Environment it Pollution Control Division 9) A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at: http://www.colorado.aov/pacific/cdphe/air-permit-self-certification I AIRS ID: 123/9AD0 Page 12 of 12 STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT RW pF'c0 AIR POLLUTION CONTROL DIVISION `� '. TELEPHONE: (303) 692-3150 ,4k ,,,;^; !1876:' CONSTRUCTION PERMIT PERMIT NO: 14WE0894 Issuance 1 DATE ISSUED: ISSUED TO: Whiting Oil and Gas Corporation THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the Razor 21 Central Production Battery, located in the NWNE of Section 21, Township 10N, Range 58W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID RZ-LOAD- Truck loadout of crude. Emissions from the loadout are 1 026 controlled by a VRU. During VRU downtime emissions are routed to an open flare. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days after issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at https://www.colorado.gov/pacific/cdphe/other-air-permitting-notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) after 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. (Reference: Regulation No. 3, Part B, III.G.2). AIRS ID: 123/9AD0 Page 1 of 10 Condensate Loadout TM Version 2012-1 Co do p e o Public PollutionHealthand ControlEnvironment Division 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (I) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, I I I.F.4.) 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 (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Equipment Point Emission Type ID VOC RZ-LOAD-1 026 0.72 Point See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 6. Operator shall calculate monthly and annual rolling 12 month total emissions based on the volume production records required by this permit and the emission factors established in the "Notes to Permit Holder" for the two process control scenarios. AIRS ID: 123/9AD0 Page 2 of 10 Co do p e o Public Health and Environment Air Pollution Control Division 7. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID RZ-LOAD-1 026 VRU VOC and HAPs RZ-LOAD-1 026 Open Flare VOC and HAPs PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits AIRS Process Parameter Annual Limit Point 026 Crude Oil Loading 3,832,500 BBL The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. Operator shall monitor and record production volumes during both VRU operation and VRU downtime when emissions are routed to the flare. 10. Records shall be kept in either an electronic file or hard copy provided that they can be promptly supplied to the Division upon request. All records shall be retained for a consecutive period of three years. 11. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III.E) AIRS ID: 123/9AD0 Page 3 of 10 Co do Np rt e o Public PollutionHealthand ControlEnvironment Division STATE AND FEDERAL REGULATORY REQUIREMENTS 12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 13. The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.E): a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. b. All compartment hatches (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. The owner or operator shall inspect loading equipment and operations onsite at the time of inspections to monitor compliance with Condition 13 (a) and (b) above. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. 14. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. OPERATING & MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) 16. The owner or operator of a loadout at which emissions are controlled shall: a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. b. Include devices to prevent the release of vapor from vapor recovery hoses not in use. c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. d. Operate all recovery and disposal equipment at a back pressure less than the pressure relief valve setting of transport vehicles. e. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers shall be weighted and properly seated. f. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs shall be set to release at a pressure that will ensure AIRS ID: 123/9AD0 Page 4 of 10 Co do p e o Public Health and Environment Air Pollution Control Division flashing, working and breathing losses are routed to the control device under normal operating conditions. g. Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. COMPLIANCE TESTING AND SAMPLING 17. This source is not required to comply with any testing and sampling requirements. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, 'LC) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 19. 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 No. 3 Part D). AIRS ID: 123/9AD0 Page 5 of 10 D Co do p e o Public Health and Environment Air Pollution Control Division GENERAL TERMS AND CONDITIONS 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership , and the submittal of a revised APEN and the required fee. 21. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self- Certify for Final Authorization section of this permit. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This 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. AIRS ID: 123/9AD0 Page 6 of 10 .- Cox do I p e o Public Health and Environment III °€ Air Pollution Control Division By: Rebecca Vasil Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Whiting Oil and Gas Corporation AIRS ID: 123/9AD0 Page 7 of 10 Co do p e o Public PollutionHealthand Control DivisionEnvironment Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aacc-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. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Point Pollutant CAS# (Ib/yr) reportable? Rate(Ib/yr) n-Hexane 110543 4,484 YES 20 026 Benzene 71432 710 YES 3 Toluene 108883 634 YES 3 5) The emission levels contained in this permit are based on the following emission factors: Process 01: VRU in operation Emission Factors - Emission Factors— Uncontrolled Controlled CAS Pollutant lb/BBL loaded Source Lb/BBL loaded Source VOC 0.085 AP-42 0.0 AP-42 En En 71432 Benzene 0.0003 Ca9 0.0 Ca9 En En 108883 Toluene 0.0003 Ca9 0.0 Ca9 En En 110543 n-Hexane 0.0019 Ca9 0.0 Ca9 Note: The controlled emissions factors for process 01 are based on the VRU control efficiencies of 100 %. AIRS ID: 123/9AD0 Page 8 of 10 a w Col V.do m p,r " e. o Public Health and Environment e Air Pollution Control Division Process 02: VRU not in operation Emission Factors - Emission Factors— Uncontrolled Controlled CAS Pollutant lb/BBL loaded Source Lb/BBL loaded Source VOC 0.085 AP-42 0.0042 AP-42 En . En 71432 Benzene 0.0003 Calgc 0.00002 Cac En 108883 Toluene 0.0003 Eng. 0.00002 Cac 110543 n-Hexane 0.0019 Eng. 0.0001 Calgc Note: The controlled emissions factors for process 02 are based on the flare control efficiencies of 95%. The uncontrolled VOC emission factor was calculated using AP-42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L= 12.46*S*P*M/T S= 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) =2.8 psia M (vapor molecular weight) = 50 lb/lb-mol T(temperature of liquid loaded) = 520 °R The uncontrolled non-criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, 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 AIRS ID: 123/9AD0 Page 9 of 10 ]) Co do p e o Public Health and Environment lri Air Pollution Control Division Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX 9) A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at: http://www.colorado.aov/pacific/cdphe/air-permit-self-certification AIRS ID: 123/9AD0 Page 10 of 10 w" a � 39 �� wP STATE OF COLORADO a �j COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT .. �, AIR POLLUTION CONTROL DIVISION i'''�,�: ,b�, TELEPHONE:(303)692-3150 IN.`' P.,, .187G t: CONSTRUCTION PERMIT PERMIT NO: 14WE0895 Issuance 1 DATE ISSUED: ISSUED TO: Whiting Oil and Gas Corporation THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the Razor 21 Central Production Battery, located in the NWNE Section 21 T1 ON R58W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID RZ-FUG-1 027 Equipment leaks (fugitive VOCs) from a natural gas exploration and production facility. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days after issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at https://www.colorado.gov/pacific/cdphe/other-air-permitting-notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) after 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. (Reference: Regulation No. 3, Part B, III.G.2). 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period AIRS ID: 123/9AD0 Page 1 of 10 Fugitive SM/M Version 2012-2 olor Depa en li it PollutionHealth ControlandEnvironment Division of eighteen • (i n to c ction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Emission Type Equipment ID Point VOC RZ-FUG-1 027 8.1 Fugitive See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 7. The operator shall calculate actual emissions from this emissions point based on representative component counts for the facility with the most recent gas and liquids analyses, as required in the Compliance Testing and Sampling section of this permit. The operator shall maintain records of the results of component counts and sampling events used to calculate actual emissions and the dates that these counts and events were completed. These records shall be provided to the Division upon request. STATE AND FEDERAL REGULATORY REQUIREMENTS 8. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, AIRS ID: 123/9ADO Page 2 of 10 olor. rfDepa en''. P ..li 'Health and Environment it Pollution Control Division Sections XII. n ,, VI - .c r:, ii:ay:. , , , iii,e emi i - •s. (Reference: Regulation No. 1, Section II.A.1. & 4.) 9. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 10. This source is subject to Regulation No. 7, Section XVII.F. leak detection and repair requirements, which include but are not limited to: XVII.F.4. Requirements for well production facilities XVII.F.4.b. Owners or operators of well production facilities constructed before October 15, 2014, must identify leaks from components using an approved instrument monitoring method within ninety (90) days of the Phase-In Schedule in Table 4; within thirty (30) days for well production facilities subject to monthly approved instrument monitoring method inspections; or by January 1, 2016, for well production facilities subject to a one time approved instrument monitoring method inspection. Thereafter, approved instrument monitoring method and AVO inspections must be conducted in accordance with the Inspection Frequencies in Table 4. XVII.F.4.c. The estimated uncontrolled actual VOC emissions from the highest emitting storage tank (as defined in Regulation 7, Section XVII.A.15) at the well production facility determines the frequency at which inspections must be performed. Table 4—Well Production Facility Component Inspections Thresholds (per XVII.F.4.c) —Well Production Facilities Approved Instrument AVO with Storage Tanks Monitoring method Inspection Phase-In (tpy) Inspection Frequency Frequency Schedule > 0 and < 6 One time Monthly January 1, 2016 > 6 and < 12 Annually Monthly January 1, 2016 > 12 and < 50 Quarterly Monthly January 1, 2015 > 50 Monthly January 1, 2015 XVII.F.6 Leaks requiring repair: Leaks must be identified utilizing the methods listed in Section XVII.F.6. Only leaks detected pursuant to Section XVII.F.6. require repair under Section XVII.F.7. XVII.F.6.a. For EPA Method 21 monitoring, or other Division approved quantitative instrument based monitoring, at facilities constructed before May 1, 2014, a leak is any concentration of hydrocarbon above 2,000 parts per million (ppm) not associated with normal equipment operation, such as pneumatic device actuation and crank case ventilation, except for well production facilities where a leak is defined as any concentration of hydrocarbon above 500 ppm not associated with AIRS ID: 123/9AD0 Page 3 of 10 olor Depa en .li Health and Environment •it Pollution Control Division norma -n a ch atic .- actuation and crank case ventilation. XVII.F.6.c. For infra-red camera and AVO monitoring, or other Division approved non- quantitative instrument based monitoring, a leak is any detectable emissions not associated with normal equipment operation, such as pneumatic device actuation and crank case ventilation. XVII.F.6.e. For leaks identified using an approved instrument monitoring method or AVO, owners or operators have the option of either repairing the leak in accordance with the repair schedule set forth in Section XVII.F.7. or conducting follow-up monitoring using EPA Method 21 within five (5) working days of the leak detection. If the follow-up EPA Method 21 monitoring shows that the emission is a leak as defined in Section XVII.F.6., the leak must be repaired and remonitored in accordance with Section XVII.F.7. XVII.F.7. Repair and remonitoring XVII.F.7.a. First attempt to repair a leak must be made no later than five (5) working days after discovery, unless parts are unavailable, the equipment requires shutdown to complete repair, or other good cause exists. If parts are unavailable, they must be ordered promptly and the repair must be made within fifteen (15) working days of receipt of the parts. If shutdown is required, the leak must be repaired during the next scheduled shutdown. If delay is attributable to other good cause, repairs must be completed within fifteen (15) working days after the cause of delay ceases to exist. XVII.F.7.b. Within fifteen (15) working days of completion of a repair, the leak must be remonitored to verify the repair was effective. XVII.F.7.c. Leaks discovered pursuant to the leak detection methods of Section XVII.F.6. shall not be subject to enforcement by the Division unless the owner or operator fails to perform the required repairs in accordance with Section XVII.F.7. XVII.F.8. Recordkeeping: The owner or operator of each facility subject to the leak detection and repair requirements in Section XVII.F. must maintain the following records for a period of two (2) years and make them available to the Division upon request. • Documentation of the initial approved instrument monitoring method inspection for new well production facilities; • The date and site information for each inspection; • A list of the leaking components and the monitoring method(s) used to determine the presence of the leak; • The date of first attempt to repair the leak and, if necessary, any additional attempt to repair the leak; • The date the leak was repaired; • The delayed repair list, including the basis for placing leaks on the list; • The date the leak was remonitored to verify the effectiveness of the repair, and the results of the remonitoring; and AIRS ID: 123/9AD0 Page 4 of 10 y es olor Depa- ens.f P .li Health and Environment iiiif it Pollution Control Division f r A of 'Ln _ e • j� -� = a de- "� >ed as unsafe, difficult, or inaccessible to monitor, as described in Section XVII.F.5., an explanation stating why the component is so designated, and the plan for monitoring such component(s). XVII.F.9. Reporting: The owner or operator of each facility subject to the leak detection and repair requirements in Section XVII.F. must submit reports as specified in Section XVII.F.9. OPERATING & MAINTENANCE REQUIREMENTS 11. This source is not required to follow a Division-approved operating and maintenance plan. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 12. Within one hundred and eighty days (180) after commencement of operation or issuance of this permit, the owner or operator shall complete the initial extended gas analysis of gas samples and extended natural gas liquids analysis of liquids that are representative of volatile organic compound (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas and liquids analyses shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. The operator shall submit the results of the gas and liquids analyses and emission calculations to the Division as part of the self-certification process to ensure compliance with emissions limits. 13. Within one hundred and eighty days (180) after issuance of this permit, the operator shall complete a hard count of components at the source and establish the number of components that are operated in "heavy liquid service", "light liquid service", "water/oil service" and "gas service". The operator shall submit the results to the Division as part of the self-certification process to ensure compliance with emissions limits. Periodic Testing Requirements 14. On an annual basis, the owner or operator shall complete an extended gas analysis of gas samples and an extended natural gas liquids analysis of liquids that are representative of volatile organic compounds (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas and liquids analyses shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. ADDITIONAL REQUIREMENTS 15. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or AIRS ID: 123/9AD0 Page 5 of 10 olor Depa en li it Pollution Health ControlandEnvironment Division For so , itt' 0 pe mor ange in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 16. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 17. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 18. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self- Certify for Final Authorization section of this permit. 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. AIRS ID: 123/9AD0 Page 6 of 10 olor Depa en P •li °'Health and Environment it Pollution Control Division 21. Each and eve.€ ,_ • io • hi it i ial pa, eof 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: Rebecca Vasil Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Whiting Oil and Gas Corporation AIRS ID: 123/9AD0 Page 7 of 10 olor Depa en li Health and Environment it Pollution Control Division Il Notes to Permit Holder - - me o e a . 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: http://www.colorado.qov/cs/Satellite?c=Document C&childoaaename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s)operate at the permitted limitations. Uncontrolled Controlled Emission Are the Emission AIRS Rate emissions Rate Point Pollutant CAS# BIN (Ib/yr) reportable? (lb/yr) Benzene 71432 A 56 Yes 25 Toluene 108883 C 42 No 18 027 Ethylbenzene 100414 C 7 No 3 Xylenes 1330207 C 14 No 6 n-Hexane 110543 C 423 No 184 5) The emission levels contained in this permit are based on the following emission factors: Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 362 0 206 140 Flanges 1213 0 954 668 . Open-ended Lines 0 . 0 0 0 Pump Seals 0 0 4 0 Valves 393 0 269 259 Other* 48 0 0 0 VOC Content(wt. 0.4000 0.0000 1.0000 0.7500 fraction) Benzene Content(wt. 0.0008 0.0000 0.0008 0.0008 fraction) Toluene Content(wt. 0.0006 0.0000 0.0006 0.0006 fraction) Ethylbenzene(wt. 0.0001 0.0000 0.0001 0.0001 fraction) Xylenes Content(wt. 0.0002 0.0000 0.0002 0.0002 AIRS ID: 123/9AD0 Page 8 of 10 olor Depa , en P .li I'Health and Environment it Pollution Control Division fraction) n-hexane Content(wt. 0.0060 0.0000 0.0060 0.0060 fraction) *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms, hatches, instrument meters, polish rods and vents TOC Emission Factors (kg/hr-component): From Table 2-4 of U.S. EPA's 1995 Protocol for Equipment Leak Emission Estimates. Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 2.0E-04 7.5E-06 2.1E-04 1.1E-04 Flanges 3.9E-04 3.9E-07 1.1E-04 2.9E-06 Open-ended Lines 2.0E-03 1.4E-04 1.4E-03 2.5E-04 Pump Seals 2.4E-03 NA 1.3E-02 2.4E-05 Valves 4.5E-03 8.4E-06 2.5E-03 9.8E-05 Other 8.8E-03 3.2E-05 7.5E-03 1.4E-02 Source: EPA-453/R95-017 Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors listed in the table above with representative component counts, multiplied by the VOC content from the most recent gas and liquids analyses. Control efficiencies from TCEQ Leak Detection and Repair program has been used. Gas and light liquid valves, relief valves and compressor seals are at 75% control. Gas and light liquid flanges and gas and light liquid connectors are at 30% control. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, HAPs PSD Synthetic Minor Source of: VOC, HAPs MACT HH Area Source Requirements: Not Applicable NSPS KKK Not Applicable NSPS OOOO 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: AIRS ID: 123/9AD0 Page 9 of 10 olor Depa en li Health and Environment it Pollution Control Division http://ecfr.gpoacce, - I 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 7777-Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX 9) A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification. AIRS ID: 123/9ADO Page 10 of 10 i 1. STATE OF COLORADO S N 4�04•C0to COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION * TELEPHONE: (303)692-3150 .'t7ryjg,.- i7876. CONSTRUCTION PERMIT PERMIT NO: 14WE0896 Issuance 1 DATE ISSUED: ISSUED TO: Whiting Oil and Gas Corporation THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the Razor 21 Central Production Battery, located in NWNE of Section 21, T10N, R58W in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID RZ-DUST- Fugitive dust emissions from haul roads from crude oil, and 028 1 produced water truck loadouts. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days after commencement of operation, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at https://www.colorado.gov/pacific/cdphe/other-air-permitting-notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) after commencement of operation, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period AIRS ID: 123/9AD0 Page 1 of 8 Fugitive SM/M Version 2012-2 olor Depa en Ii Health and Environment it Pollution Control Division of eighteen - (i n to c ction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall 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 (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: • Facility AIRS Tons per Year Equipment Emission Type Point TSP PM2o PM2.5 ID RZ-DUST-1 028 35 9 --- Fugitive See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. PROCESS LIMITATIONS AND RECORDS 6. This source shall be limited to the following maximum vehicle miles travelled as listed below. Monthly records of the actual vehicle miles travelled shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits AIRS Process Parameter Annual Limit Point 028 Travel onsite of Crude Oil and Water 12,290 miles/yr transport trucks shall not exceed The owner or operator shall calculate monthly vehicle miles travelled based on records of truck trips traveled each 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 vehicle miles travelled each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. AIRS ID: 123/9AD0 Page 2 of 8 olor Depa en P li Health and Environment it Pollution Control Division STATE AND FEDE: . G T E NTS 7. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. 8. The particulate emission control measures listed on the attached page (as approved by the Division) shall be applied to the particulate emission producing sources as required by Regulation No. 1, Section III.D.1.b. OPERATING & MAINTENANCE REQUIREMENTS 9. This source is not required to follow a Division-approved operating and maintenance plan. ADDITIONAL REQUIREMENTS 10. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 11. 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 No. 3 Part D). AIRS ID: 123/9AD0 Page 3 of 8 olor Depa en li Health and Environment it Pollution Control Division GENERAL TERMS • 12. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 13. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self- Certify for Final Authorization section of this permit. 14. 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. 15. 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. 16. 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. 17. 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. 18. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. AIRS ID: 123/9AD0 Page 4 of 8 a olor „Depa ens P 'ill Health and Environment it Pollution Control Division " � a By: Rebecca Vasil Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to: Whiting Oil and Gas Corporation AIRS ID: 123/9AD0 Page 5 of 8 olor Depa en li Health and Environment it Pollution Control Division Notes to Permit Holder - ''" me' o e a . 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: http://www.colorado.aov/cs/Satellite?c=Document C&childpagename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper 4) The emission levels contained in this permit are based on the following emission factors: 5) Point 020: Uncontrolled Emission Control Pollutant Factors IbNMT (%) Source TSP 7.28 21.9 AP-42, Section 13.2.2 PM10 1.87 21.9 AP-42, Section 13.2.2 PM2.5 0.19 21.9 AP-42, Section 13.2.2 Emissions from this point are based on 12,290 vehicle miles traveled per year, an average vehicle weight of 28.3 tons and a silt content of 5%. Control % is based solely on natural precipitation. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN)associated with this permit is valid for a term of five years from the date it was received by the Division.A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, 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.cmoaccess.gov/ AIRS ID: 123/9AD0 Page 6 of 8 ... .. qua- 3. Ts olor Depa en Jf P .li WHealth and Environment it Pollution Control Division Part 60: Standar .JJJJ rfor - e r S '. ourc NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60,Appendixes Appendix A—Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX 9) A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification. AIRS ID: 123/9AD0 Page 7 of 8 olor Depa en li Health and Environment it Pollution Control Division ITI I ROT THE FOLLOWING PARTICULATE EMISSIONS CONTROL MEASURES SHALL BE USED FOR COMPLIANCE PURPOSES ON THE ACTIVITIES COVERED BY THIS PERMIT, AS REQUIRED BY THE AIR QUALITY CONTROL COMMISSION REGULATION NO.1, Section III.D.1.b. THIS SOURCE IS SUBJECT TO THE FOLLOWING EMISSION GUIDELINES: a. Haul Roads -No off-property transport of visible emissions shall apply to on-site haul roads,the nuisance guidelines shall apply to off-site haul roads. b. Transport Trucks -There shall be no off-property transport of visible emissions from transport trucks when operating on the property of the owner or operator. There shall be no off-vehicle transport of visible emissions from the material in the transport trucks when operating off of the property of the owner or operator. Control Measures 1. Unpaved haul roads shall be watered as often as needed to control fugitive particulate emissions, if natural precipitation is insufficient to prevent off property transport of fugitive emissions. AIRS ID: 123/9AD0 Page 8 of 8 Summary of Preliminary Analysis - NG RICE Company Name Whiting Oil and Gas Corporation Permit No. 14WE0889 Facility Name Razor 21 Central Production Battery AIRS 123/9AD0/021 Facility Location NWNE Section 21 T10N R58W Review Date 09/09/2014 Facility Equipment ID RZ-ENG-1 Permit Engineer Rebecca Vasil Requested Action New permit/newly reported emission Issuance No. 1 Emission Point Description One(1) Caterpillar, Model G3516, Serial Number JEF01264, natural gas-fired, turbo-charged,4SLB reciprocating internal combustion engine, site rated at 1311 horsepower.This engine shall be equipped with an oxidation catalyst and air-fuel ratio control. This emission unit is used as a gas lift compressor engine. Natural Gas Consumption Hours of Operation Requested (mmscf/yr) 83.31 PTE Calculated at(hpy) 8760 Requested(mmscf/m) 7.08 Permit limits calculated at(hpy) 8760 Fuel Heat Value(btu/scf) 1148 BSCF (Btu/hp-hr) 8328 Emission Factor Sources Uncontrolled Controlled NOx Manufacturer 0 VOC Manufacturer 0 CO Manufacturer 0 Formaldehyde Manufacturer o SOX AP-42;Table 3.2-2(7/2000);Natural Gas No Control TSP AP-42;Table 3.2-2(7/2000);Natural Gas No Control PM10 AP-42;Table 3.2-2(7/2000);Natural Gas No Control PM2.5 AP-42;Table 3.2-2(7/2000);Natural Gas No Control Other Pollutants Describe EF sources- HAPs etc. Describe EF sources- HAPs, etc. Point Summary of Criteria Emissions (tpy) Uncontrolled Controlled Proposed Control Requested Requested PTE Efficiency NOx 6.3 6.3 6.3 0.0% VOC 10.5 8.9 10.5 15.0% CO 36.5 6.2 36.5 83.0% SOx 0.0 0.0 0.0 0.0% TSP 0.5 0.5 0.5 0.0% PM10 0.5 0.5 0.5 0.0% PM2.5 0.5 0.5 0.5 0.0% Total HAPs* 0.0 0.0 6.2 74.9% *Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de minimus thresholds. PTE includes all HAPs calculated, even those below de minimus. Point Summary of Hazardous Air Pollutants Ib/yr) Uncontrolled Controlled Proposed Control HAP Name Requested Requested PTE Efficiency Formaldehyde 10634 1276 10634 88.0% Acetaldehyde 800 800 800 0.0% Acrolein 492 492 492 0.0% Methanol * 239 0.0% n-Hexane * 106 0.0% Benzene * * 42 0.0% Toluene * 39 0.0% *Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minimus Permitting Requirements Ambient Air Impacts Source is not required to model based on Division Guidelines Public Comment Public Comment Required MACT 7777 Missing or invalid entry information over 500 HP located at a(n)Area Source Reg 7 XVII.E NOx: 1.0 CO: 2.0 VOC: 0.7 Standards(g/hp-hr) Reg 7 XVI.B(Ozone NAA No requirements)applies? Is this engine subject to MACT 7777 area MACT 7777(area source) Yes source requirements? Is this engine subject to NSPS JJJJ? Yes NSPS JJJJ Note: JJJJ requriements are not currently included as permit conditions because the reg has not been adopted into Reg 6. Comments/Notes 0 Summary of Preliminary Analysis - NG RICE Company Name Whiting Oil and Gas Corporation Permit No. 14WE0890 Facility Name Razor 21 Central Production Battery AIRS 123/9AD0/022 Facility Location NWNE Section 21 T 10N R58W Review Date 09/18/2014 Facility Equipment ID RZ-ENG-2 Permit Engineer Rebecca Vasil Requested Action New permit/newly reported emission Issuance No. 1 Emission Point Description One (1) Caterpillar, Model G3508B, Serial Number RBK01312, natural gas-fired, turbo-charged,4SLB reciprocating internal combustion engine, site rated at 690 horsepower. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control.This emission unit is used as a gas lift compressor engine. Natural Gas Consumption Hours of Operation Requested (mmscf/yr) 43.42 PTE Calculated at (hpy) 8760 Requested(mmscf/m) 3.69 Permit limits calculated at(hpy) 8760 Fuel Heat Value(btu/scf) 1148 BSCF(Btu/hp-hr) 8247 Emission Factor Sources Uncontrolled Controlled NOx manufacturer 0 VOC manufacturer 0 CO manufacturer 0 Formaldehyde manufacturer 0 SOX AP-42;Table 3 2-2(7/2000);Natural Gas No Control TSP AP-42;Table 3.2-2(7/2000);Natural Gas No Control PM10 AP-42;Table 3.2-2(7/2000);Natural Gas No Control PM2.5 AP-42;Table 3 2-2(7/2000),Natural Gas No Control Other Pollutants Describe EF sources- HAPs etc. Describe EF sources-HAPs, etc. Point Summary of Criteria Emissions(tpy) Uncontrolled Controlled Proposed Control Requested Requested PTE Efficiency NOx 3.3 3.3 3.3 0.0% VOC 3.5 3.5 3.5 0.0% CO 18.1 3.3 18.1 82.0% SOx 0.0 0.0 0.0 0.0% TSP 0.2 0.2 0.2 0.0% PM10 0.2 0.2 0.2 0.0% PM2.5 0.2 0.2 0.2 0.0% Total HAPs* 0.0 0.0 2.7 73.8% `Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de minimus thresholds. PTE includes all HAPs calculated, even those below de minimus. Point Summary of Hazardous Air Pollutants Ib/yr) Uncontrolled Controlled Proposed Control HAP Name Requested Requested PTE Efficiency Formaldehyde 4397 440 4397 90.0% Acetaldehyde 417 417 417 0.0% Acrolein 256 256 256 0.0% Methanol * 125 0.0% n-Hexane * * 55 0.0% Benzene * * 22 0.0% Toluene * * 20 0.0% *Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minimus Permitting Requirements Ambient Air Impacts Source is not required to model based on Division Guidelines Public Comment Public Comment Required MACT 7777 Missing or invalid entry information over 500 HP located at a(n)Area Source Reg 7 XVII.E NOx: NA CO: NA VOC: NA Standards(g/hp-hr) Reg 7 XVI.B(Ozone NAA No requirements)applies? MALT 7777(area source) Is this engine subject to MACT 7777 area Yes source requirements? Is this engine subject to NSPS JJJJ? Yes NSPS JJJJ Note: JJJJ requriements are not currently included as permit conditions because the reg has not been adopted into Reg 6. Comments/Notes 0 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Whiting Oil and Gas Corporation Permit Number: 14WE0891 Source Location: NWNE Section 21 T10N R58W,Weld County(Attainment) Description Separator with a 40' flare stack AIRS ID: 123-9AD0-023 Date: September 18th 2014 Review Engineer: Rebecca Vasil Control Engineer Chris Laplante Section 2—Action Completed Grandfathered Modification APEN Required/Permit Exempt X CP1 Transfer of Ownership APEN Exempt/Permit Exempt Section 3—Applicant Completeness Review Was the correct APEN submitted for this source type? X Yes No Is the APEN signed with an original signature? X Yes No Was the APEN filled out completely? X Yes No Did the applicant submit all required paperwork? X Yes No Did the applicant provide ample information to determine emission rates? X Yes No If you answered "no" to any of the above, when did you mail an Information Request letter to the source? On what date was this application complete? April 24`h 2014 Section 4—Source Description AIRS Point Equipment Description 023 Separator controlled by a 40'flare stack. Flare has a minimum combustion efficiency of 95%. The flare is not enclosed. Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria Yes X No pollutant? If"yes", for what pollutant? PM,() CO Ozone Is this location in an attainment maintenance area for Yes X No any criteria pollutant? If"yes", for what pollutant? (Note: These pollutants are subject to minor source PM,() CO Ozone RACT per Regulation 3, Part B, Section III.D.2) Is this source located in the 8-hour ozone non- attainment region? (Note: If"yes" the provisions of Yes X No Regulation 7, Sections XII and XVII.C may apply) Page 1 Section 5—Emission Estimate Information AIRS Point Emission Factor Source 023 Site-specific using VOC weight fraction (Refer to Section 14 for calculations) Did the applicant provide actual process data for the emission inventory? X Yes No Basis for Potential to Emit(PTE) AIRS Point Process Consumption/Throughput/Production 023 35 mmscf/yr Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 023 35 mmscf/yr NA Basis for Permitted Emissions(Permit Limits' AIRS Point Process Consumption/Throughput/Production 023 35 mmscf/yr Does this facility use control devices? X Yes No AIRS Point Process Control Device Description % Reduction Granted 023 01 40'flare stack 95 Point NO„ VOC CO Single HAP Total HAP PTE: 023 --- 434 9.5 (n-hexane) 8.9 Uncontrolled point source 023 434 9.5 7 8.9 emission rate: (n-hexane) Controlled point source 023 21.7 9.5 035 (n- . 0.45 emission rate: hexane) Uncontrolled Are the Controlled Emission Pollutant CAS# Emission Rate emissions (lb/yr) reportable? Rate(lb/yr) Benzene 71432 1800 Yes 100 Toluene 108883 1280 Yes 64 Ethylbenzene 100414 300 Yes 14 Xylenes 1130207 400 Yes 20 n-Hexane 110543 14000 Yes 700 Section 8—Testing Requirements Will testing be required to show compliance with any emission rate or regulatory Yes X No standard? If"yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method Section 9-Source Classification • What is this facility classification? True X Synthetic Major Minor Minor Page 2 Classification relates to what programs? X Title V X PSD NA NSR X MACT Is this a modification to an existing permit? Yes X No If"yes"what kind of modification? Minor Synthetic Major Minor Section 10— Public Comment Does this permit require public comment per CAQCC Regulation 3? X Yes No If"yes",for which pollutants?Why? VOC, HAPS For Reg. 3, Part B, III.C.1.a (emissions increase> 25/50 tpy)? X Yes No For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)? Yes X No For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? X Yes No Section 11 —Modeling Is modeling required to demonstrate compliance with National Ambient Yes X No Air Quality Standards (NAAQS)? If"yes", for which pollutants?Why? NOx emissions are less than 40 TPY. AIRS Point Section 12— Regulatory Review Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide 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 023 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 023 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 3-APENs, Construction Permits, Operating Permits, PSD Part A-APEN Requirements 023 Criteria Pollutants: (Applicant is required to file an APEN since emissions exceed 2 tons per year VOC) Part B—Construction Permit Exemptions 023 Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 5.0 TPY threshold (Reg. 3, Part B, Section II.D.3.a) Regulation 6-New Source Performance Standards 023 None Regulation 7—Volatile Organic Compounds 023 None Regulation 8—Hazardous Air Pollutants 023 None Page 3 Section 13—Aerometric Information Retrieval System Coding Information Emission Pollutant/ Fugitive Emission Factor Control Point Process Process Description Factor CAS# (Y/N) Source (%) 24800 VOC No Engineering 95 lb/MMscf Calculation 0.068 AP-42, lb/MMBtu NOx No Table 13.5-1 NA 0.37 AP-42, lb/MMBtu CO No Table 13.5-1 NA 51.4 Benzene No Engineering 95 01 Flare lb/MMscf Calculation 023 36.6 Toluene No Engineering 95 lb/MMscf Calculation 8.6 Ethlybenzene No Engineering 95 lb/MMscf Calculation 11.4 Engineering lb/MMscf Xylenes No Calculation 95 400 n-hexane No Engineering 95 lb/MMscf Calculation SCC 31000205-Flares Section 14—Miscellaneous Application Notes AIRS Point 023 Flare Emissions were calculated using: ((scf/hr) *(Ib/Ib-mol))/(379.4 scf/lb-mol) = lb/hr*(hr/yr)/2000 lb/T) =TPY VOC = (434 TPY*2000 lb/T)/(35 mmscf/yr) =24800 lb/mmscf NOx and CO (from AP-42, Chapter 13, Table 13.5-1 (NOx=0.068 lb/mmbtu; CO = 0.37 lb/mmbtu) Emission factors for HAPS are: Benzene= (1800 Ib/yr)/35 mmscf/yr= 51.4 lb/mmscf Toluene= (1280 Ib/yr)/35 mmscf/yr= 36.6 lb/mmscf Ethylbenzene = (300 Ib/yr)/35 mmscf/yr=8.6 lb/mmscf Xylenes= (400 lb/yr)/35 mmscf/yr= 11.4 lb/mmscf n-hexane= (14,000 Ib/yr)/35 mmscf/yr=400 lb/mmscf An gas analysis was provided in the application dated 01/28/2014. The gas analysis was perfomed less than a year of submittal. An updated extended gas analysis will not be required because: -an extended gas analysis was performed within a year of this submittal and included with this package Page 4 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Whiting Oil and Gas Corporation Permit Number: 14WE0892 Source Location: NWNE Section 21 T10N R58W, Weld county (attainment) Equipment Description: 24-400bb1 produced water tanks AIRS ID: 123-9AD-024 Date: September 10 2014 Review Engineer: Rebecca Vasil Control Engineer: Chris Laplante Section 2—Action Completed Grandfathered Modification APEN Required/Permit Exempt X CP1 Transfer of Ownership APEN Exempt/Permit Exempt * If tank is a true minor source at a true minor facility, it may be granted "Final Approval"without first being issued an Initial Approval permit Section 3—Applicant Completeness Review Was the correct APEN submitted for this source type? X Yes No Is the APEN signed with an original signature? X Yes No Was the APEN filled out completely? X Yes No Did the applicant submit all required paperwork? X Yes No Did the applicant provide ample information to determine emission rates? X Yes No If you answered "no"to any of the above, when did you mail an Information Request letter to the source? On what date was this application complete? April 24, 2014 Section 4—Source Description AIRS Point Equipment Description 024 Twenty four(24) above ground 400 bbl atmospheric produced water storage tank Are"flash" emissions anticipated from these tanks? Yes X No Is this tank located at an E&P site? X Yes No Is this tank located at a non-E&P, midstream or Yes X No downstream site? Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria Yes X No pollutant? If"yes", for what pollutant? PM,o CO Ozone Is this location in an attainment maintenance area for Yes X No any criteria pollutant? If"yes", for what pollutant? (Note: These pollutants are subject to minor source PM10 CO Ozone RACT per Regulation 3, Part B, Section III.D.2) Page 1 Is this source claiming exempt status for this source based on the fraction of oil in the stored water(less Yes X No than 1% by volume crude oil on an average annual basis)? Are these produced water tanks located at a commercial facility that accepts oil production Yes X No wastewater for processing? Are these produced water tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)805 Rule? Yes X No If so, submit Form APCD-105 Section 5—Emission Estimate Information AIRS Point Emission Factor Source 024 CDPHE Produced Water Storage Tank Emission Factors; CDPHE Memo 09-02 Did the applicant provide actual process data for the emission inventory? X Yes No Basis for Potential to Emit(PTE) AIRS Point Process Consumption/Throughput/Production 024 1,460,000 BBL per year wastewater Basis for Actual Emissions Reported During this APEN Filing(Reported to Inventorvl AIRS Point Process Consumption/Throughput/Production Data Year 024 1,460,000 BBL per year wastewater NA Basis for Permitted Emissions(Permit Limits) AIRS Point Process Consumption/Throughput/Production 024 1,460,000 BBL per year wastewater Does this source use a control device? X Yes No AIRS Point Process Control Device Description % Reduction Granted 024 07 VRU Operating (91% of the time) 100 024 02 VRU down emissions to the flare 95 Section 6-Emission Summary(tons per wear) Point NO VOC CO Single HAP Total HAP PTE: 024 --- 191.3 - 16.06 21.17 (Hexane) Uncontrolled point 024 0.85 16.06 21.17 source emission rate: (Hexane) Controlled point 024 0.85 0.07 0.09 source emission rate: (Hexane) Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled Am the Controlled Emission Pollutant CAS# BIN Emission Rate emissions Ib/ r (lblyr) reportable? Rate( Y) Benzene 71432 A 10,220 Yes 45.3 n-Hexane 110543 C 32,120 Yes 142.3 Note: Regulation 3, Part A, Section II.B.3.b APEN emission reporting requirements for non-criteria air pollutants are based on actual emissions without credit for reductions achieved by control devices used by the operator. Page 2 Section 8—Testing Requirements Will testing be required to show compliance with any emission rate or regulatory Yes X No standard? If"yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method Section 9—Source Classification Is this a new previously un-permitted source? X Yes No What is this facility classification? True X Synthetic Major Minor Minor Classification relates to what programs? X Title V X PSD NA NSR X MACT Is this a modification to an existing permit? Yes X No If"yes"what kind of modification? Minor Synthetic Major Minor Section 10— Public Comment Does this permit require public comment per CAQCC Regulation 3? X Yes No If"yes", for which pollutants?Why? VOC, HAPs For Reg. 3, Part B, III.C.1.a (emissions increase>25/50 tpy)? X Yes No For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)? Yes X No For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? X Yes No Section 11 — Modeling Is modeling required to demonstrate compliance with National Ambient Yes X No Air Quality Standards (NAAQS)? If"yes", for which pollutants?Why? AIRS Point Section 12— Regulatory Review Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide 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, 024 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. Re•ulation 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 024 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. Page 3 Regulation 3-APENs, Construction Permits, Operating Permits, PSD Part A-APEN Requirements 024 Criteria Pollutants: (Applicant is required to file an APEN since emissions exceed 2 tons per year VOC) Part B—Construction Permit Exemptions 024 Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 5.0 TPY threshold(Reg. 3, Part B, Section II.D.3.a) Regulation 6-New Source Performance Standards 024 None R ulation 7—Volatile Organic Compounds 024 Regulation 7 Part B Section XVII Regulation 8—Hazardous Air Pollutants 024 None Section 13—Aerometric Information Retrieval System Coding Information Emission Pollutant/ Fugitive Emission Factor Control Point Process Process Description Factor CAS# (Y/N) Source (%) 0.262 Ib/BBL VOC No CDPHE PS 100 throughput Memo 09-02 01 Produced Water Storage 0.007 Ib/BBL Benzene No CDPHE PS 100 Tanks throughput Memo 09-02 0.022Ib/BBL n-Hexane No CDPHE PS 100 throughput Memo 09-02 024 0.262 lb/BBL VOC No CDPHE PS 95 throughput Memo 09-02 02 Produced Water Storage 0.007 lb/BBL Benzene No CDPHE PS 95 Tanks throughput Memo 09-02 0.022 lb/BBL n-Hexane No CDPHE PS 95 throughput Memo 09-02 SCC 40400315—Fixed Roof Tank, Produced Water,working+breathing+flashing losses Page 4 Section 14—Miscellaneous Application Notes AIRS Point 024 Produced Water Storage Tanks Total annual throughput: 1,460,000 BBUyr VOC controlled: Process 01: VRU operating 91% of the time 1,460,000* 91% = 1,328,600 BBL/yr 1,328,600 BBL/yr*0.262 lb/BBL* 100% = 0.0 Process 02: VRU downtime(emissions to flare) 1,460,000— 1,328,600 = 131,400 BBUyr 131,400 BBUyr*0.262 lb/BBL*95% = 1700 lb *1/2000 = 0.85 tpy Benzene controlled: Process 01: VRU operating 91% of the time 1,460,000 * 91% = 1,328,600 BBL/yr 1,328,600 BBUyr*0.007 lb/BBL* 100% = 0.0 Process 02: VRU downtime (emissions to flare) 1,460,000— 1,328,600 = 131,400 BBUyr 131,400 BBUyr*0.007 lb/BBL*95% = 40 lb *1/2000 = 0.02 tpy n-Hexane controlled: Process 01: VRU operating 91% of the time 1,460,000* 91%= 1,328,600 BBL/yr 1,328,600 BBL/yr*0.022 lb/BBL* 100% = 0.0 Process 02: VRU downtime (emissions to flare) 1,460,000— 1,328,600 = 131,400 BBUyr 131,400 BBUyr*0.022 lb/BBL*95% = 144 lb *1/2000 = 0.07 tpy Page 5 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Whiting Oil and Gas Corporation Permit Number: 14WE0893 Source Location: NWNE Section 21 T10N R58W, Weld County (Attainment) Equipment Description: 32-400bb1 crude oil tanks AIRS ID: 123/9AD0/025 Date: September 10th 2014 Review Engineer: Rebecca Vasil Control Engineer Chris Laplante Section 2—Action Completed Grandfathered Modification APEN Required/Permit Exempt X CP1 Transfer of Ownership APEN Exempt/Permit Exempt ` If tank is a true minor source at a true minor facility, it may be granted "Final Approval"without first being issued an Initial Approval permit `Grandfathered exemption is for any tanks in service prior to December 30, 2002 Section 3—Applicant Completeness Review Was the correct APEN submitted for this source type? X Yes No Is the APEN signed with an original signature? X Yes No Was the APEN filled out completely? X Yes No Did the applicant submit all required paperwork? X Yes No Did the applicant provide ample information to determine emission rates? X Yes No If you answered "no" to any of the above, when did you mail an Information Request letter to the source? On what date was this application complete? April 24, 2014 Section 4—Source Description AIRS Point Equipment Description 025 Thirty two (32) above ground 400 bbl atmospheric crude oil storage tank Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria Yes X No pollutant? If"yes", for what pollutant? PM10 CO Ozone Is this location in an attainment maintenance area for Yes X No any criteria pollutant? If"yes", for what pollutant? (Note: These pollutants are subject to minor source PM10 CO Ozone RACT per Regulation 3, Part B, Section III.D.2) Is this source located in the 8-hour ozone non- attainment region? (Note: If"yes" the provisions of Yes X No Regulation 7, Sections XII and XVII.C may apply) Page 1 Section 5—Emission Estimate Information AIRS Point Emission Factor Source 025 Source may provide site-specific emission factors using gas sample and E&P Tanks. Will need to calculate emission factors from E&P Tanks. Did the applicant provide actual process data for the emission inventory? X Yes No Basis for Potential to Emit(PTEI AIRS Point Process Consumption/Throughput/Production 025 2,372,500 BBL per year Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 025 2,372,500 BBL per year NA Basis for Permitted Emissions(Permit Limits) AIRS Point Process Consumption/Throughput/Production 025 2,372,500 BBL per year Does this source use a control device? X Yes No AIRS Point Process Control Device Description % Reduction Granted 025 01 VRU Operating (91% of the time) 100 025 0z VRU down emissions to the flare 95 Section 6—Emission Summary(tons per year) Point NO„ VOC CO Single HAP Total HAP PTE: 025 --- 262.75 --- 2.2 (Hexane) 2.9 Uncontrolled point 025 --- 262.75 --- 2.2 (Hexane) 2.9 source emission rate: Controlled point 025 --- 1.16 --- 0.01 (Hexane) 0.013 source emission rate: Uncontrolled Are the Controlled Emission Pollutant CAS# Emission Rate emissions Ib/ r (lb/yr) reportable? Rate( Y) Benzene 71432 710 Yes 3 Toluene 108883 634 Yes 3 n-Hexane 110543 4484 Yes 20 Section 8—Testing Requirements Will testing be required to show compliance with any emission rate or regulatory X Yes No standard? If"yes°, complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method VOC, Liquids Analyses 001 01 HAPS PS Memo 05-01 according to PS Memo 05-01 Page 2 Section 9—Source Classification Is this a new previously un-permitted source? X Yes No What is this facility classification? True X Synthetic Major Minor Minor Classification relates to what programs? X Title V X PSD NA NSR X MACT Is this a modification to an existing permit? Yes X No If"yes"what kind of modification? Minor Synthetic Major Minor Section 10—Public Comment Does this permit require public comment per CAQCC Regulation 3? X Yes No If"yes",for which pollutants?Why? VOC, HAPS For Reg. 3, Part B, III.C.1.a (emissions increase >25/50 tpy)? X Yes No For Reg. 3, Part B, III.C.1.c.ii (subject to MACT)? Yes X No For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? X Yes No Section 11 —Modeling Is modeling required to demonstrate compliance with National Ambient Yes X No Air Quality Standards (NAAQS)? If"yes", for which pollutants?Why? AIRS Point Section 12—Regulatory Review Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide 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, 025 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 025 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 3-APENs, Construction Permits, Operating Permits, PSD Part A-APEN Requirements 025 Criteria Pollutants: (Applicant is required to file an APEN since emissions exceed 2 tons per year VOC) Part B—Construction Permit Exemptions 025 Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 5.0 TPY threshold(Reg. 3, Part B, Section II.D.3.a) Regulation 6 - New Source Performance Standards NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84. 025 Is this source greater than 19,800 gallons (471 bbl)? No Is this source subject to NSPS Kb? No Source is not greater than 471 BBI Page 3 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 crude oil since it is located in an attainment area and they are crude oil tanks.) 025 XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS... (Applicant is currently subject to this since actual uncontrolled emissions am greater than 20 tpy of VOC.) Regulation 8—Hazardous Air Pollutants MACT EEEE: Organic Liquids Distribution Pick one: 025 • This source is not subject to MACT EEEE because it is not located at a major source of HAP. MACT HH Pick one: 025 • This source is not subject to MACT HH because it is not located at a major source of HAP. Section 13—Aerometric Information Retrieval System Coding Information Process Emission Pollutant/ Fugitive Control Point Process Description Factor CAS# (Y/N) Emission Factor Source (%) 0.2215 Ib/BBL V0C No E&P Tanks 100 throughput 0.0003 Benzene/ lb/BBI 71432 No E&P Tanks 100 01 E&P Crude Oil throughput Storage Tanks 0.0003 Toluene/ lb/BBI 108883 No E&P Tanks 100 throughput 0.0019 n-Hexane lb/BBI /110543 No E&P Tanks 100 throughput 025 0.2215 lb/BBL V0C No E&P Tanks 95 throughput 0.0003 Benzene/ lb/BBI 71432 No E&P Tanks 95 02 E&P Crude Oil throughput Storage Tanks 0.0003 Toluene/ lb/BBI 108883 No E&P Tanks 95 throughput 0.0019 n-Hexane lb/BBI /110543 No E&P Tanks 95 throughput SCC 40400311 —Fixed Roof Tank,Condensate,working+breathing+flashing losses Page 4 Section 14—Miscellaneous Application Notes AIRS 025 Crude Oil Storage Tanks Point Total annual throughput: 2,372,500 BBL/yr VOC controlled: Process 01:VRU operating 91%of the time 2,372,500*91%=2,158,975 BBL/yr 2,158,975 BBUyr'0.2215 lb/BBL' 100%=0.0 Process 02:VRU downtime(emissions to flare) 2,372,500—2,158,975=213,525 BBL/yr 213,525 BBUyr*0.22151b/BBL*95%=2364.78 lb *1/2000= 1.16 tpy Benzene controlled: Process 01:VRU operating 91%of the time 2,372,500*91%=2,158,975 BBUyr 2,158,975 BBL/yr*0.003 lb/BBL* 100% =0.0 Process 02:VRU downtime(emissions to flare) 2,372,500—2,158,975=213,525 BBL/yr 213,525 BBL/yr*0.00033 lb/BBL*95% =3 lb Toluene controlled: Process 01:VRU operating 91%of the time 2,372,500*91%=2,158,975 BBUyr 2,158,975 BBUyr*0.00029 lb/BBL* 100% =0.0 Process 02:VRU downtime(emissions to flare) 2,372,500—2,158,975=213,525 BBUyr 213,525 BBUyr*0.00029 Ib/BBL*95%=3 lb n-Hexane controlled: Process 01:VRU operating 91%of the time 2,372,500"91%=2,158,975 BBUyr 2,158,975 BBL/yr*0.2215 lb/BBL* 100%=0.0 Process 02:VRU downtime(emissions to flare) 2,372,500—2,158,975=213,525 BBL/yr 213,525 BBL/yr*0.0191b/BBL*95% =20 lb This source is not located in the 8-hour ozone non-attainment area(Weld County is in partial attainment). The statewide requirements of Regulation 7, Section XVII.C do currently apply to this source since actual uncontrolled emissions are greater than 20 tpy. Page 5 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Whiting Oil and Gas Corporation Permit Number: 14WE0894 Source Name: Razor 21 Central Production Battery Source Location: NWNE Section 21 T10N R58W,Weld County (Attainment) Equipment Description: Truck Loadout AIRS ID: 123/9AD0/026 Review Date: September 4`" 2014 Review Engineer: Rebecca Vasil Section 2—Action Completed X CP1 Modification APEN Required/Permit Exempt Final Approval Transfer of Ownership APEN Exempt/Permit Exempt Section 3—Applicant Completeness Review Was the correct APEN submitted for this source type? X Yes No Is the APEN signed with an original signature? X Yes No Was the APEN filled out completely? X Yes No Did the applicant submit all required paperwork? X Yes No Did the applicant provide ample information to determine emission rates? X Yes No If you answered "no" to any of the above, when did you mail an Information Request letter to the source? On what date was this application complete? April 24`" 2014 Section 4—Source Description AIRS Point Equipment Description 026 Truck Crude Oil Loadout Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria Yes X No pollutant? If"yes", for what pollutant? PM10 CO Ozone Is this location in an attainment maintenance area for Yes X No any criteria pollutant? If"yes", for what pollutant? (Note: These pollutants are subject to minor source PM10 CO Ozone RACT per Regulation 3, Part B, Section III.D.2) Is this source located in the 8-hour ozone non- attainment region?(Note: If"yes" the provisions of Yes X No Regulation 7, Sections XII and XVII.C may apply) Is this source located at an oil and gas exploration site? X Yes No Page 1 If yes, does this source load less than 10,000 gallons of crude oil per day on an annual average, splash fill less than 6750 bbl of condensate(hydrocarbons that have X Yes No an API gravity of 40 degrees or greater) per year or submerged fill less than 16,308 bbl of condensate per year? Is this source located at a facility that is considered a major source of hazardous air pollutant(HAP) Yes X No emissions? Will this equipment be operated in any NAAQS Yes X No nonattainment area? Does this source load gasoline into transport vehicles? Yes X No Section 5—Emission Estimate Information AIRS Point Emission Factor Source AP-42: Chapter 5.2, Equation 1 L = 12.46*S*P*M/T 026 L = loading losses in lb per 1000 gallons loaded S= Saturation Factor P=true vapor pressure of liquid loaded [psia] M =molecular weight of vapors [lb/lb-mole] T=temperature of bulk liquid loaded [deq. R] Did the applicant provide actual process data for the emission inventory? X Yes No Basis for Potential to Emit(PTE) AIRS Point Process Consumption/Throughput1Production 026 3,832,500 BBL per year crude loaded Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 026 3,832,500 BBL per year crude loaded NA Basis for Permitted Emissions(Permit Limits) AIRS Point Process ConsumptionIThroughput/Production 026 3,832,500 BBL per year crude loaded Does this source use a control device? X Yes No AIRS Point Process Control Device Description % Reduction Granted 026 01 VRU Operating (91% of the time) 100 026 02 VRU down emissions to the flare 95 Section 6—Emission Summary (tons per year) Point NO, VOC CO Single HAP HAP PTE: 026 --- 162.1 --- 2.24 (n-hexane) 2.91 Uncontrolled point 026 162.1 2.24 (n-hexane) 2.91 source emission rate: Permitted point source 026 0.72 0.01 (n-hexane) 0.013 emission rate: Page 2 Section 7— Non-Criteria/Hazardous Air Pollutants Uncontrolled Are the Controlled Emission Pollutant CAS # BIN Emission Rate emissions Ibl r (Ib/yr) reportable? Rate( y) Benzene 71432 A 710 Yes 3 n-Hexane 110543 C 4,484 Yes 20 Toluene 108883 C 634 Yes 3 Note: Regulation 3, Part A, Section II.B.3.b APEN emission reporting requirements for non-criteria air pollutants are based on potential emissions without credit for reductions achieved by control devices used by the operator. Section 8—Testing Requirements Will testing be required to show compliance with any emission rate or regulatory Yes X No standard? Section 9—Source Classification Is this a new previously un-permitted source? X Yes No What is this facility classification? True X Synthetic Major Minor Minor Classification relates to what programs? X Title V X PSD NA NSR MACT Is this a modification to an existing permit? Yes X No If"yes"what kind of modification? Minor Synthetic Major Minor Section 10— Public Comment Does this permit require public comment per CAQCC Regulation 3? Yes X No If"yes", for which pollutants?Why?VOC, HAPS For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)? X Yes No For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)? Yes X No For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? X Yes No Section 11 — Modeling Is modeling required to demonstrate compliance with National Ambient Yes X No Air Quality Standards (NAAQS)? AIRS Point Section 12—Regulatory Review Regulation 1 - Particulate, Smoke Carbon Monoxide and Sulfur Dioxide Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of 026 the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.1. &4.) Regulation 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 026 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. Page 3 Regulation 3-APENs, Construction Permits, Operating Permits, PSD Criteria Pollutants: (Applicant is required to file an APEN since emissions exceed 2 tons per year VOC) Part B—Construction Permit Exemptions Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 5.0 TPY threshold(Reg. 3,Part B, Section II.D.3.a) 026 Part B, III.D.2-RACT requirements for new or modified minor sources This section of Regulation 3 requires RACT for new or modified minor sources located in nonattainment or attainment/maintenance areas. This source is not located in the 8-hour ozone nonattainment area, but not the 1-hour ozone area. Since source is in attainment, RACT is not required. However, operator is using 0.6 saturation factor, which does satisfy RACT requirements. Regulation 6-New Source Performance Standards 026 No applicable subpart. This facility is not a bulk gasoline terminal. Regulation 7—Volatile Organic Compounds No sections apply. Per Regulation 7, Section VI.C, a terminal is defined as a petroleum liquid storage and distribution facility that has a daily average throughput of more than 026 76,000 liters of gasoline (20,000 gallons), which is loaded directly into transport vehicles. This facility is neither a terminal, nor a bulk plant per definitions in Reg 7, Section VI.C. Regulation 8—Hazardous Air Pollutants 026 None Section 13—Aerometric Information Retrieval System Coding Information Process/ Emission Process Emission Pollutant/ Fugitive Control Point Process Description throughput Factor CAS# (Y/N) Factor (%) Limit Source - Truck Crude Oil 3,832,500 0.085 01 Loadout BBL/yr lb/BBL VOC No AP-42 100 throughput Truck Crude Oil 3,832,500 0.085 02 Loadout BBUyr lb/BBL VOC No AP-42 95 throughput Truck Crude Oil 3,832,500 0.0003 Benzene 01 lb/BBL No Wt% 100 I Loadout BBL/yr 71432 throughput 0.0003 Truck Crude Oil 3,832,5OO Benzene 02 Loadout BBUyr lb/BBL 71432 No Wt% 95 throughput 026 Truck Crude Oil 3,832,500 0.0003 Toluene 01 Loadout BBUyr Ib/BBL 108883 No Wt% 100 throughput Truck Crude Oil 3,832,500 0.0003 Toluene 02 Loadout BBU r lb/BBL 108883 No Wt% 95 y throughput Truck Crude Oil 3,832,500 0.0019 n-Hexane 01 Loadout BBL/y lb/BBL 110543 No Wt% 100 y throughput Truck Crude Oil 3,832,500 0.0019 n-Hexane 02 Loadout BBU r lb/BBL 110543 No Wt% 95 y throughput SCC 40600132: Crude Oil: Submerged Loading (Normal Service) Page 4 Section 14— Miscellaneous Application Notes AIRS Point 026 Truck Condensate Loadout Units Basis S 0.6 AP-42 Table 5.2-1 P 2.8 Psia AP-42 Table 7.1.2 M 50 Lb/lb-mole AP-42 Table 7.1.2 T 520 Deg R Based on source's knowledge of bulk liquid temperature L 2.01 Lb/10^3 gal Value is used to calculate annual emissions of VOC 8.45E-02 Lb/bbl AP-42: Chapter 5.2 Equation 1 L = 12.46*S*P*M/T L= loading losses in lb per 1000 gallons loaded S = Saturation Factor P =true vapor pressure of liquid loaded [psia] M = molecular weight of vapors [lb/lb-mole] T =temperature of bulk liquid loaded [deg. R] L 2.01Ib/10^3 gal 8.45E-02lb/bbl Annual requested Throughput 160965000ga1/yr Annual requested VOC emissions 3239851b/yr 162.1 tpy Page 5 Colorado Department of Public Health Environment Air Pollution Control Division Summary of Preliminary Analysis - Fugitive Components Source Company Name Whiting Oil and Gas Corporation Facility Name Razor 21 Central Production Battery Permit No 14WE0895 AIRS 123/9AD0/027 Permit Engineer Rebecca Vasil Application Date 4/24/2014 Review Date 9/3/2014 Summary of Emissions VOC Benzene Toluene Ethylbenzne Xylenes n-Hexane (tpy) (lb/yr) (Iblyr) (Ib/yr) (lb/yr) (lb/yr) Uncontrolled Requested Emissions 19.3 56 42 7 14 423 Controlled Requested Emissions 8.1 25 18 3 6 184 Reportable? I I Yes No No No No Total HAP, Uncontrolled(tpy) 0.3 Total HAP,Controlled(tpy) I 0.1 Highest HAP, Uncontrolled(tpy) 0.2 n-Hexane Emission Factors Emission Factor Source: EPA-453/R-95-017,Table 2-4 Controls Control Efficiencies from TCEQ Leak Detection and Repair Programs • Stream VOC Fraction: Stream HAP Components(wt frac) Gas 0.4000 HAP Gas Light Oil Heavy Oil Water/Oil Light Oil 1.0000 Benzene 0.0008 0.0008 _0.0000 0.0008 Heavy Oil 0.0000 Toluene 0.0006 0.0006 0.0000 0.0006 Water/Oil 0.7500 Ethylbenze 0.0001 0.0001 0.0000 0.0001 Xylene 0.0002 0.0002 0.0000 0.0002 n-Hexane 0.0060 0.0060 0.0000 0.0060 Comments/Notes: Enter Comments here Printed 9/25/2014 Page 1 or 1 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Whiting Oil and Gas Corporation Permit Number: 14WE0896 Source Name: Razor 21 Central Production Battery Source Location: NWNE, Section 21,T10N R58W Weld County (attainment) Equipment Description: Fugitive Dust emissions AIRS ID: 123/9AD0/028 Review Date: September 3, 2014 Review Engineer: Rebecca Vasil Section 2—Action Completed X CP1 Modification APEN Required/Permit Exempt Final Approval Transfer of Ownership APEN Exempt/Permit Exempt Section 3—Applicant Completeness Review Was the correct APEN submitted for this source type? X Yes No Is the APEN signed with an original signature? X Yes No Was the APEN filled out completely? X Yes No Did the applicant submit all required paperwork? X Yes No Did the applicant provide ample information to determine emission rates? X Yes No If you answered"no" to any of the above, when did you mail an Information Request letter to the source? On what date was this application complete? April 29th 2014 Section 4—Source Description AIRS Point Equipment Description 028 Fugitive Dust Emissions Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria Yes X No pollutant? If"yes", for what pollutant? PM10 CO Ozone Is this location in an attainment maintenance area for Yes X No any criteria pollutant? If"yes", for what pollutant? (Note: These pollutants are subject to minor source PM10 CO Ozone RACT per Regulation 3, Part B, Section III.D.2) Is this source located in the 8-hour ozone non- attainment region? (Note: If"yes"the provisions of Yes X No Regulation 7, Sections XII and XVII.C may apply) Page 1 Section 5—Emission Estimate Information AIRS Point Emission Factor Source AP-42 13.2.2, Equation 1a E =k(s/12)^a*(W/3)^b E= emission factor(IbNMT (VMT=Vehicle Miles Travelled)) 028 k =constant from table 13.2.2-2 s=surface material silt content(%) a =constant from table 13.2.2-2 W=mean vehicle weight(tons) b= constant from table 13.2.2-2 Did the applicant provide actual process data for the emission inventory? X Yes No Basis for Potential to Emit(PTEI AIRS Point Process Consumption/Throughput/Production 028 12,290 miles/yr Basis for Actual Emissions Reported During this APEN Filing(Reported to Inventory) AIRS Point Process Consumption/Throughput/Production 028 12,290 miles/yr Basis for Permitted Emissions(Permit Limits) AIRS Point Process Consumption/Throughput/Production 028 12,290 miles/yr Does this source use a control device? Yes X No Section 6—Emission Summary(tons per year) Point TSP PM10 PM2.5 PTE: 020 44.75 11.50 1.15 Uncontrolled point 020 44.75 11.50 1.15 source emission rate: Permitted point source 020 34.95 8.98 0.90 emission rate: Section 7—Testing Requirements Will testing be required to show compliance with any emission rate or regulatory Yes X No standard? Section 8—Source Classification Is this a new previously un-permitted source? X Yes No What is this facility classification? True X Synthetic Major Minor Minor Classification relates to what programs? X Title V X PSD NA NSR MACT Is this a modification to an existing permit? Yes X No If"yes"what kind of modification? Minor Synthetic Major Minor Section 9—Public Comment Does this permit require public comment per CAQCC Regulation 3? X Yes No Page 2 If"yes", for which pollutants?Why?VOC, HAPs For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)? X Yes No For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)? Yes X No For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? X Yes No Section 11 —Modeling Is modeling required to demonstrate compliance with National Ambient Yes X No Air Quality Standards (NAAQS)? AIRS Point Section 12— Regulatory Review Re•ulation 1 - Particulate, Smoke Carbon Monoxide and Sulfur Dioxide Visible emissions shall not exceed twenty percent(20%) opacity during normal operation of 028 the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.1. &4.) Regulation 2—Odor 028 None Requlation 3 -APENs, Construction Permits, Operating Permits, PSD Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for each individual emission point in an attainment area with uncontrolled actual emissions of two tons per year or more of any individual criteria pollutant(pollutants are not summed)for which the area is attainment. (Applicant is required to file an APEN since emissions exceed 2 tons per year of criteria 028 pollutants) Part B—Construction Permit Exemptions Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 5.0 TPY threshold(Reg. 3, Part B, Section Il.D.3.a) Requlation 6 -New Source Performance Standards 028 No applicable subpart. This facility is not a bulk gasoline terminal. Requlation 7—Volatile Organic Compounds 028 None RIc ulation 8— Hazardous Air Pollutants 028 None Section 13—Aerometric Information Retrieval System Coding Information Process/ Emission Process Emission Pollutant/ Fugitive Control Point Process Description throughput Factor CAS# (Y/N) Factor (%) Limit Source 728 TSP Y AP-42 21.9 IbNMT 01 Fugitive Dust 12,290 1.87 PM10 Y AP-42 21.9 028 Emissions miles/year IbNMT 0.19 IbNMT PM2.5 Y AP-42 21.9 SCC 31088801: Fugitive Haul Road Emissions Page 3 Section 14—Miscellaneous Application Notes AIRS Point 028 Truck Condensate Loadout AP-42 13.2.2, Equation 1a E = k(s/12)Aa *(W/3)Ab E = emission factor(IbNMT (VMT=Vehicle Miles Travelled)) k= constant from table 13.2.2-2 s = surface material silt content(%) a=constant from table 13.2.2-2 W= mean vehicle weight(tons) b= constant from table 13.2.2-2 Empirical Constants Pollutant k a b TSP (PM) 4.9 0.7 0.45 PKo 1.5 0.9 0.45 PM2.5 0.15 0.9 0.45 TSP: (4.9*(5/12)^0.7) * (28.3/3)^0.45 =7.28 IbNMT PM10: (1.5*(5/12)A0.9) * (28.3/3)^0.45=1.87 IbNMT PM2.5: (0.15 * (5/12)A0.9) * (28.3/3)^0.45 =0.19 IbNMT Uncontrolled Emissions: TSP: (7.28 IbNMT)*(12290miles/year)/2000=44.75 tpy PM10: (1.87 IbNMT)*(12290miles/year)/2000= 11.50 tpy PM2.5: (0.19 IbNMT)*(12290miles/year)/2000= 1.15 tpy • Page 4 X O ° 9 0 > 0 C 0 .__.` c d N g s n ° - lv a aa, a - w •o 't t-• v• c O Jp w n� s E uZ7 m� 0` Men en c ° N V 'Ci c 0n1� ¢ 0 = o ... a L``n p Ccv - Qs tg 0 ... u IDe $ E y o, Ni W `° '�' W U 9 c co E o en 0 2 °' ° ° aL. 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