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Home My WebLink About20141184.tiff STATE OF COLORADO John W.Hickenlooper,Governor Larry Wolk,MD,MSPH of•cozo Executive Director and Chief Medical Officer Tr) Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr.S. Laboratory Services Division �.8r Denver,Colorado 80246-1530 8100 Lowry Blvd. Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department Located in Glendale,Colorado (303)692-3090 of Public Health www.colorado.gov/edphe and Environment Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 RECEIVED April 8, 2014 APR 1 1 2014 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On April 11,2014,the Air Pollution Control Division will publish a public notice for Whiting Oil and Gas Corporation—Razor 26-3524H, 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 & Environment APCD-SS-B 1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure -TW0L 12O,-)1C : Pc(mm)� CSI ,et+, im)n-up8) lb. / i `1 if • I' 2014-1184 STATE OF COLORADO John W.Hickenlooper,Governor Larry Walk, MD,MSPH 0*i cob., 'sCV Executive Director and Chief Medical Officer rc 'eo Dedicated to protecting and improving the health and environment of the people of Colorado `� ♦ y'-Y a 4300 Cherry Creek Dr.S. Laboratory Services Division 'ien` Denver,Colorado 80246-1530 8100 Lowry Blvd. Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department Located in Glendale,Colorado (303)692-3090 of Public Health www.colorado.gov/cdphe and Environment Website Title: Whiting Oil and Gas Corporation—Razor 26-3524H—Weld County Released To: The Greeley Tribune On: April 8, 2014 Published: April 11, 2014 PUBLIC NOTICE OF A PROPOSED PROJECT OR ACTIVITY WARRANTING PUBLIC COMMENT 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 26-3524H Exploration and production facility consisting of a single well, one separator with a 30' open flare stack, one 400 barrel produced water tank, and a crude oil loadout tank 13.4 miles north of Raymer, Colorado 80742 (Section 26, Township ION, Range 58W) Weld County The proposed project or activity is as follows: Operator proposes to permit an exploration and production facility consisting of a single well producing up to 690 barrels per day of crude oil with associated natural gas, one separator with a 30' flare stack(requested throughput of 93.8 MMscf per year separator vapors),one 400 barrel produced water tank(requested throughput of 87,600 barrels of produced water per year), and a crude oil truck loadout tank(requested throughput of 251,850 barrels of crude oil per year). 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.I.a (25 tpy in a non-attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application,the Division's analysis, and a draft of Construction Permit 13WE2481 E2481 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 www.colorado.gov/cdphe/AirPublicNotices. The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such comment must be submitted in writing to the following addressee: Kirk Bear Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B 1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us STATE OF COLORADO OF,'pCO Q COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT r Fri,L 54, AIR POLLUTION CONTROL DIVISION �, TELEPHONE: (303)692-3150 + t *" *1896• CONSTRUCTION PERMIT PERMIT NO: 1 3W E2481 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 26-3524H, located in Section 26, 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 Separator controlled by a 30' flare stack. Flare has a minimum SEP-1 003 combustion efficiency of 95%. The flare is not enclosed. 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 www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission(AQCC)Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days(180) after 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, II.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 AIRS ID: 123-9BAF-003 Page 1 of 7 Wellhead Version 2012-1 Colorado Department of Public Health and Environment Air Pollution Control Division months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The following information shall be provided to the Division within fifteen (15) days after issuance of permit. • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification,with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO, VOC CO Emission Type SEP-1 003 10.0 78.2 19.9 Point See"Notes to Permit Holder#4"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. 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 Control Device Pollutants Equipment ID Point Controlled SEP-1 003 Separator controlled by a 30' flare stack VOC, HAPs AIRS ID: 123-9BAF-003 Page 2 of 7 Colorado Department of Public Health and Environment Air Pollution Control Division 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 SEP-1 003 Associated gas flaring 93.8 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 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) OPERATING & MAINTENANCE REQUIREMENTS 14. Upon startup of this point, 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 15. The owner or operator shall demonstrate compliance with Condition 11 using EPA Method 9 to measure opacity from the flare. (Reference: Regulation No. 1, Section II.A.5). AIRS ID: 123-9BAF-003 Page 3 of 7 Colorado Department of Public Health and Environment Air Pollution Control Division Periodic Testing Requirements 16. 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 17. 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 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, orwhenevera different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 18. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted,then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide"final"authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization AIRS ID: 123-9BAF-003 Page 4 of 7 Colorado Department of Public Health and Environment Air Pollution Control Division to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the 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 applicant's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence,this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the 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. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Kirk Bear Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Whiting Oil and Gas Corporation AIRS ID: 123-9BAF-003 Page 5 of 7 Colorado Department of 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: http://www cdphe.state.co.ustreclulations/airreqs/1 001 02aqcccom monprovision sreq.pdf. 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Pollutant CAS# BIN Uncontrolled Reportable? Controlled Point (Ib/yr)(Ib/yr) benzene 71432 A 5801 yes 290 n-hexane 110543 C 56312 yes 2816 003 toulene 108883 C 5474 yes 274 xylene 1130207 C 2365 yes 118 5) The emission levels contained in this permit are based on the following emission factors: Emission Emission CAS# Pollutant Factors Factors Source Uncontrolled Controlled 33363 1668 VOC mass balance lb/MMscf lb/MMscf CO 0.276 0.276 TCEQ lb/MMBtu lb/MMBtu NOx 0.138 0.138 TCEQ lb/MMBtu lb/MMBtu 62 3 71432 benzene lb/MMscf lb/MMscf600 30 mass balance 110543 n-hexane lb/MMscf lb/MMscf58 3 mass balance 108883 toulene lb/MMscf lb/MMscf25 2 mass balance 1130207 xylene lb/MMscf lb/MMscf mass balance Note: The controlled VOC and HAP emissions factors for point 003 are based on the flare control efficiency of 95%. AIRS ID: 123-9BAF-003 Page 6 of 7 Colorado Department of Public Health and Environment Air Pollution Control Division 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692- 3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, HAPs PSD Synthetic Minor Source of: VOC, HAPs 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://ec fr.gpoacccss.QM/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60, Appendixes Appendix A—Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ —Subpart YYYY • MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX 9) An Oil and Gas Industry Construction Permit Self-Certification Form is included with this permit packet. Please use this form to complete the self-certification requirements as specified in the permit conditions. Further guidance on self-certification can be found on our website at: http://www.cdphe.state.co.us/ap/oilgaspermittinq.html AIRS ID: 123-9BAF-003 Page 7 of 7 Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment Air Pollution Control Division Division Information Engineer Kirk Bear I Attainment Status Control Engineer. Christopher Laptante PM10 Attainment Review Date- 03/13/2014 PM25 Attainment Application Date. 07/09/,2013 SOx Attainment NOx Attainment VOC Attainment Facility Information CO Attainment Permit No. 13WF2481 County 6 123 Weld AIRs Facility 6 `DAl Point# 003 Facility Equipment ID Separator Company Name. Whiting Oil and Ges Capaahcn Source Name- Razor 26-3524/I Source Location. Section 26.Township ION,Range 58W SIC 1311 Elevation(feet)4739 New Permit Modification APEN X (CPi) (Issuance#) Required/Permit Exempt Transfer of APEN Ownership Exempt/PermitF elnl Notes Equipment Description This source vents natural gas from- a well head separator Emissions from this source are. routed to an open fora Natural gas venting from a well head separator.Emissions from this source are routed to an open flare Emission Calculation Method EPA Emission Inventory Improvement Program Publication Volume II,Chapter 10-Displacement Equation(104-3) Es=0*MW'Xx/C Ex=emissions of pollutant s Q=Volumetric flow rate/volume of gas processed MW=Molecular weight of gas=SG of gas*MW of air Xx=mass traction of x in gas C=molar volume of ideal gas(379 scf/lb-mol)at 60F and 1 atm , ThraughPutMW h3 81 27 e40b/bmolr I 10708.3 scf/hr 3002 MMscf/0 I ]9]MMsd/mo mole% MW bx/Ibmol mass fraction E lb/hr Iblyr tpy Helium 0 40026 0.000 0.000 Helium 00 0 0.00 CO2 2 281 4401 1.004 0036 CO2 284 248464 124.23 N2 1 003 28.013 0281 0010 N2 7.9 69542 34.77 methane 59182 16041 9 8 493 0.341 methane 262 2349675 1174.84 ethane '4654 30063 4.405 0.158 ethane 1245 1090373 545.19 propane '113479 44.092 5.9432 0213 propane 187.9 1470971 73549 isobutane 1 402 58.118 08148 0.029 isobutane 23.0 201672 10084 n-butane 438§ 58.118 26653 0.096 n-butane /6.3 65967/ 32984 Isopentene 087 72.114 0694 0.023 isopentane 17.7 155284 7764 n-pentane 1 101 /2.114 0/954 0.029 n-pentane 225 1968/1 9844 cyclopentane 0 112 70.13 0.0785 0.003 cyclopentane 2.2 19441 9.72 n-Hexane 02640 86.18 0.2275 0.008 n-Hexane 64 56312 28.16 cvclohexane 00370 84.16 0.0311 0.001 cydohexane 0.9 7707 3.85 Other hexanes 0297 86.18 02560 0.009 Other hexanes 72 63350 3168 heptanes 0431 100.21 0.4319 0016 heptanes 12.2 106899 5345 methylceclohexane 008 98.19 0.0786 0.003 methylcyclohexane 2.2 19442 9.72 224-TMP 0 11423 0.0000 0000 224-TMP 00 0 000 Benzene 003 78.12 0.0234 0.001 Benzene 0.7 5801 2.90 Toluene 0024 92.15 0.0221 0.001 Toluene 06 5474 274 Elhylbenzene 0.003 106.17 0.0032 0000 Ethybenzene 0.1 788 0.39 Xylenes 0008 106.17 0.00% 0.000 Xylenes 03 2365 1.18 C8+Heavies 0 153 424';'E, 06484 0023 CB+Heavies 18.3 160475 80.24 VOC mass fraction 0.4546 Total VOC Emissions(Uncontrolled) 15663 27.840 annual limit assuming 95%control 78.3 Notes monthly limit assuming 95%control(lb/mo I 13302.5 Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment Air Pollution Control Division Flaring Information Eouipment Description Flare to combust produced gas until pipeline is available at this wellhead facility. Manufacturer Model 25 Flare Stack Serial Number Gas Heating Value 1539 Btu/sof Throughput 144365.895 MMBIu'yr Combustion emission factor source: AP-42'Chapter 13.5 0 491Itp NOlb NOXM1MBtu I 2671Itoy lb 0o MBtul Emissions Summary 4 9 tpy NOX Uncontrolled/PIE 26.7 toy CO 1566.3 ipy VOC Controlled 78.3 toy VOC Uncontrolled Scenano A Controlled Total(lb/yr) Bin Reportable? Total(lb/yr) Benzene 5801 A Yes 290 Toluene 5474 C Yes 274 Ethylbenzene 788 C No 39 Xylenes 2365 C Yes 118 n-hexane 56312 C Yes 2816 224-TMP 0 C No 0 Regulatory Applicability AQCC Regulation 1 This source is subject to the opacity requirements for flares in Section II.A.S'No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30%opacity.' AQCC Regulation 2 Section I.A applies to all emission sources."No person,wherever located,shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercal purposes it is a violation if odors are detected after the odorous air has been diluted with seven(7)or more volumes of odor free air." • AQCC Regulation 3 An APEN is required for this source because uncontrolled VOC emissions Part A. exceed two tons per year in an attainment area. A permit is required for this source because uncontrolled VOC emissions from this facility exceed five tons per year in an attainment area. Part B- This source is not subject to Section III D.2(Minor Source RACT)because it is not located in a nonattainment area. Is public comment Public Comment Required required? Facility Status This facility is a synthetic minor source of VOCiHAP for Title V applicability This facility is a synthetic minor source of VOC/HAP for PSI)applicability Emission Factors for Permit Uncontrolled NOX 104.7 blMMsct natural gas vented CO 569.4 b/MMscf natural gas vented VOC 33394.0 b/MMsd natural gas vented Benzene 61.8 b/MMscf natural gas vented Toluene 58.4 b/MMsd natural gas vented Ethylbenzene 8.4 dMMad natural gas vented Xylenes 25.2 b/MMsd natural gas vented n-Hexane 600.3 b/MMsd natural gas vented 224TMP 0.0 b/MMsd natural gas vented Controlled • NOX 104.7 IdMMscf natural gas vented CO 569.4 IbIMMsc natural gas vented xa 16697 lb/ rs natural gas vented enzene s na ural gas vented o ue e 5.na ural gas vented •-nzene s na ural gas vented enes iFl• p''s-na ural gas vented n- exane ALA)• a 's na ural gas vented 's na ural gas vented Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Whiting Oil and Gas Corporation Permit Number: 13WE2481 Source Location: Section 26, T10N, R58W Description Separator with a 30' flare stack AIRS ID: 123-9BAF-003 Date: 13 March 2014 Review Engineer: Kirk Bear Control Engineer Christopher 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 shall be granted "Final Approval" 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? 9 July 2013 Section 4—Source Description AIRS Point Equipment Description 003 Separator controlled by a 30'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? 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 003 Mass Balance 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 003 93.8 MMscf/yr Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 003 93.8 MMscf/yr 2013 Basis for Permitted Emissions(Permit Limits). AIRS Point Process Consumption/Throughput/Production 003 93.8 MMscf/yr Does this facility use control devices? X Yes No AIRS Point Process Control Device Description % Reduction Granted 003 01 30'flare stack 95 Section 6—Emission Summar, (tons per year) Point NOa VOC CO SOx PM10 Single Total HAP HAP PTE: 003 10.0 1564.8 19.9 --- --- 28.1 34.9 Controlled point 003 10.0 78.2 19.9 --- --- 1.4 1.8 source emission rate: TOTAL PERMITTED 003 10.0 78.2 19.9 --- --- 1.4 1.8 (TPY) Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled Are the Controlled Emission Pollutant CAS# BIN Emission Rate emissions (Iblyr) reportable? Rate(Iblyr) benzene 71432 A 5801 yes 290 toluene 108883 C 5474 yes 274 xylenes 1130207 C 2365 yes 118 n-hexane 110543 C 56312 yes 2816 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 X Yes No standard? If"yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method 003 01 VOC, State only requirement Site-specific gas HAPS analysis Page 2 Section 9—Source Classification 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 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 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 003 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 003 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 Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: 003 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 VOC) Part B—Construction Permit Exemptions 003 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 003 None Page 3 Regulation 7—Volatile Organic Compounds XII. VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS This facility is not located in the 8-hr ozone control area; therefore,this facility is 003 not subject to Section XII of this regulation. XVII STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS... This facility is an oil and gas operation that does not operate any equipment subject to Section XVII of this regulation. Regulation 8—Hazardous Air Pollutants 003 None Section 13—Aerometric Information Retrieval System Coding Information Point Process Process Description Emission Pollutant/ Fugitive Emission Factor Control Factor CAS# (Y/N) Source (%) SCC 40400152-Vapor collection losses 33363.0 VOC No Engineering 95 Ib/MMscf Calculation 0.138 NOx No TCEQ NA lb/MMBtu 0.276 CO No TCEQ NA Ib/MMBtu 01 Flare 62.0 benzene No Engineering 95 003 lb/MMscf Calculation 58.0 toluene No Engineering 95 Ib/MMscf Calculation 25.0 Engineering Ib/MMscf xylenes No Calculation 95 600.0 n-hexane No Engineering 95 Ib/MMscf Calculation SCC 31000205-Flares Section 14—Miscellaneous Application Notes AIRS Point 003 Flare Operator provided an extended gas analysis and emissions were calculated using EPA Emission Inventory Improvement Program Publication, Volume II, Chapter 10-Displacement equation (10.4-3) where: Ex= Q * MW`Xx/C Ex= emissions of pollutant x Q =Volumetric flow rate/volume of gas processed MW= Molecular weight of gas = SG of gas * MW of air Xx= mass fraction of x in gas C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm Page 4 O y' C V_ o v C Z c o ^ Q G a O w m G G. 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