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Home My WebLink About20142766 A CDPHE COLORADO CO Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 11500 St PO Box 758 Greeley, CO 80632 September 2, 2014 Dear Sir or Madam: On September 5, 2014, the Air Pollution Control Division will publish a public notice for Whiting Oil and Gas Corporation - Redtail Gas Plant, 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 ft Environment APCD-SS-B1 4300 Cherry Creek Drive South RECEIVED Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, SEP 0 8 2014 COMMISSIONERSt. ta; Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure alpF Cpl CA o9. � -Lk:RPtxa.J de/N I ,.ta�t. W I.a.1 ,:. `j ' I o— g4 elk 2014-2766 CDPHE Public Notice Of A Proposed Project CO Or Activity Warranting Public Comment Website Title: Whiting Oil and Gas Corporation - Redtail Gas Plant - Weld County Released To: The Greeley Tribune On: September 2, 2014 Published: September 5, 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: Redtail Gas Plant natural gas processing plant NE 'A of Section 21, T10N R58W 14.9 mites North of Raymer, CO Weld County The proposed project or activity is as follows: The applicant proposes to build an expansion to an existing gas plant as well as modify the permits of some existing equipment. 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 13WE1450,13WE1130, 13WE3003, 13WE3004, 13WE3005, 13WE3006, 13WE3007, 13WE3008, 13WE3009, and 14WE0881 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 1 I A® „OLONADO llI3., STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT ,eoF co- * AIR POLLUTION CONTROL DIVISION iv, � TELEPHONE:(303)692-3150 `'taa,�m+'+, CONSTRUCTION PERMIT PERMIT NO: 13WE1450 Issuance 2 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 Redtail Gas Plant, located in the NE 1/4 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 TK-1, TK-2, Three (3) 400 BBL fixed roof storage tanks used to store TK-3 007 condensate. Emissions from these tanks are controlled by an enclosed 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 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, 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 AIRS ID: 123/9AD0 Page 1 of 11 Condensate Tank SM/M Version 2012-1 olo Depa e f li Health and Environment it Pollution Control Division application as it • p • 'f) ' s co tion fora 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) Monthly Limits: Facility AIRS Pounds per Month Equipment ID Point NO VOC CO Emission Type TK-1,TK-2,TK-3 007 --- 424.7 -- Point (Note: Monthly limits are based on a 31-day month.) The owner or operator shall calculate monthly emissions based on the calendar month. Facility-wide emissions of each individual hazardous air pollutant shall be less than 1,359 • lb/month. Facility-wide emissions of total hazardous air pollutants shall be less than 3,398 lb/month. Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO, VOC CO Emission Type TK-1,TK-2,TK-3 007 --- 2.5 — Point See'Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or AIRS ID: 123/9AD0 Page 2 of 11 t , olor Depa en f ill Health and Environment 4 •it Pollution Control Division at a local fieldt'I '' h ility ° 0 -i:,.ion re 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 Control Device Equipment ID Point Controlled TK-1, TK-2,TK-3 007 Enclosed 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 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 Process Parameter Annual Monthly Limit Equipment ID Point Limit (31 days) TK-1, TK-2, TK-3 007 Condensate throughput 182,500 15,500 BBUyr BBUmonth The owner or operator shall calculate monthly process rates based on the calendar month. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months'data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility,for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 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. This source is subject to the odor requirements of Regulation No.2. (State only enforceable) 11. 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: 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 AIRS ID: 123/9ADO Page 3 of 11 olo Depa e f li Health and Environment it Pollution Control Division is oper pe or ly w pplicable requirements of Section XVII. XVII.B.2.d.(i)All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto-igniter upon installation of the combustion device. 12. 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; 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. AIRS ID: 123/9AD0 Page 4 of 11 ll olor Depa en -f di Health and Environment Ait Pollution Control Division XVII.C.2. Cap,=,r. . m -r's`= utr ti ;_.rsto.- , 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. 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.C2.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 AIRS ID: 123/9AD0 Page 5 of 11 olor Depa e f li Health and Environment it Pollution Control Division 0 y January 1, 2015 XVII.C.2.b.(iii) Owners or operators are not required to monitor storage tanks and associated equipment that are unsafe,difficult,or inaccessible to monitor,as defined in Section XVII.C.1.e. XVII.C.2.b.(iv) STEM must include a certification by the owner or operator that the selected STEM strategy(ies) are designed to minimize emissions from storage tanks and associated equipment at the facility(ies), including thief hatches and pressure relief devices. XVII.C.3. Recordkeeping XVII.C.3. The owner or operator of each storage tank subject to Sections XII.D. or XVII.C. must maintain records of STEM, if applicable, including the plan, any updates, and the certification, and make them available to the Division upon request. In addition, for a period of two (2) years, the owner or operator must maintain records of any required monitoring and make them available to the Division upon request,including: XVII.C.3.a. The AIRS ID for the storage tank. XVII.C.3.b.The date and duration of any period where the thief hatch,pressure relief device, or other access point are found to be venting hydrocarbon emissions, except for venting that is reasonably required for maintenance,gauging,or safety of personnel • and equipment. XVII.C.3.c.The date and duration of any period where the air pollution control equipment is not operating. XVII.C.3.d. Where a combustion device is being used, the date and result of any EPA Method 22 test or investigation pursuant to Section XVII.C.1.d.(v). XVII.C.3.e. The timing of and efforts made to eliminate venting, restore operation of air pollution control equipment, and mitigate visible emissions. XVII.C.3.f. A list of equipment associated with the storage tank that is designated as unsafe, difficult, or inaccessible to monitor, as described in Section XVII.C.1.e., an explanation stating why the equipment is so designated, and the plan for monitoring such equipment. OPERATING & MAINTENANCE REQUIREMENTS 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.) AIRS ID: 123/9AD0 Page 6 of 11 olor Depa t en of •li Health and Environment �( w it Pollution Control Division COMPLIANCE TE :> e ; Initial Testing Requirements 14. 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. 15. Within one hundred and eighty days (180) after issuance of this permit, the owner or operator shall demonstrate compliance with no visible emissions requirement, 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.All) ADDITIONAL REQUIREMENTS 16. All previous versions of this permit are cancelled upon issuance of this permit. 17. A revised Air Pollutant Emission Notice(APEN)shall be filed: (Reference: Regulation No.3, Part A, II.C) a. Annually by April 30'"whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less,above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5)tons per year,whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed,or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 18. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). AIRS ID: 123/9AD0 Page 7 of 11 olo Depa e f li it PollutionHealthand Control DivisionEnvironment GENERAL TERMS 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 to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source,in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence,this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit,conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit,the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative,civil or criminal enforcement actions under Sections 25-7-115(enforcement),-121 (injunctions),-122 (civil penalties), -122.1 (criminal penalties), C.R.S. AIRS ID: 123/9AD0 Page 8 of 11 tii3s :u y olor. Depa en Wf di Health and Environment t it Pollution Control Division r 1. °s u By: Rebecca Vasil Permit Engineer Permit History Issuance Date Description Issuance 2 This Issuance Modification to permit to increase allowable throughput. Issuance 1 08/26/2013 First Issuance to Whiting Oil and Gas Corporation AIRS ID: 123/9AD0 Page 9 of 11 olo Depa e f li Health and Environment it Pollution Control Division Notes to Permit Holder e o 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 production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice(APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions.The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: http://www.colorado.cov/cs/Satellite?c=Document C&childpaaename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWraoper 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s)operate at the permitted limitations. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Point Pollutant CAS# (lb/yr) reportable? Rate(Ib/yr) Benzene 71432 600 YES 20 007 Toluene 108883 720 YES 40 Hexane 110543 11,400 YES 580 5) The emission levels contained in this permit are based on the following emission factors: Emission Factors Emission Factors Uncontrolled . Controlled CAS# Pollutant lb/BBL lb/BBL Source Condensate Condensate Throughput Throughput VOC 0.55 0.0275 Site Specific 110543 n-Hexane 0.063 0.00315 Site Specific 71432 Benzene 0.0033 0.000165 Site Specific 108883 Toluene 0.0040 0.0002 Site Specific Note: The controlled emissions factors for point 007 are based on the flare control efficiency of 95%. AIRS ID: 123/9AD0 Page 10 of 11 Ill olor c Depa. en f •' sail `°Health and Environment it Pollution Control Division 6) In accordance with - , -7- �t Po i o,: sion „- (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://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60,Appendixes Appendix A—Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX 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: www colorado.qov/cdphe/oilgasperm its AIRS ID: 123/9AD0 Page 11 of 11 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Whiting Oil and Gas Corporation Permit Number 13WE1450 Source Location: NE'/.of Section 21, T10N, R58W,Weld county(attainment) Equipment Description: 3-400bb1 condensate storage tanks AIRS ID: 123-9AD0-007 Date: June 3, 2014 Review Engineer: Rebecca Vasil Control Engineer: Chris Laplante Section 2—Action Completed Grandfathered Modification APEN Required/Permit Exempt X CP2 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? May 7th 2014 Section 4—Source Description AIRS Point Equipment Description 007 Three(3)above ground 400 bbl atmospheric condensate 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 007 Source may provide site-specific emission factors using gas sample,Sim and EPA tanks. Will need to calculate emission factors from Sim and EPA tanks. Did the applicant provide actual process data for the emission inventory? X Yes No Ba ,-p4i4fai to Emit(PTE) AIRS Point Process Consumption/Throughput/Production 007 182500 BBL per year )Bali's for Actual Emissi`ons'tteDorte t ng thisAPEN Fili inst(Reported to Inventoivt'; AIRS Point Process ConsumptionfThroughput/Production Data Year 007 182500 BBL per year NA Basisf'orPermitted Emissions(Permit Limits) AIRS Point Process Consumption/Throughput/Production 007 182500 BBL per year Does this source use a control device? X Yes No AIRS Point Process Control Device Description °h Reduction Granted 007 01 Flare 95 Section 6—Emission Summary(tons per year) Point NO, VOC CO Single HAP Total HAP PTE: 007 --- 50.3 — 5.7(Hexane) 6.36 Uncontrolled point 007 --- 50.3 — 5.7(Hexane) 6.36 source emission rate: Controlled point 007 — 2.5 — 0.29(Hexane) 0.325 source emission rate: Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled Controlled Emission Pollutant CAS# BIN Emission Rate erel•sle•a(lb/Yr) reportable? Rate(ib/Yr) _ Benzene 71432 A 600 Yes 20 n-Hexane 110543 C 11400 Yes 580 Toluene 108883 C 720 Yes 40 Note: Regulation 3, Part A, Section ll.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 VOC, Liquids Analyses 007 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? Yes X 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? X Yes No If"yes"what kind of modification? Minor X 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, 007 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 007 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 007 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) 007 Page 3 Restulatidn 6-Naw source Performance Standards NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84. 007 Is this source greater than 19,800 gallons(471 bbl)? No Is this source subject to NSPS Kb?No Source is not greater than 19,800 gallons Regulation 7-Volatile Oroarmqttintoounds XII.VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS (Applicant is not subject to the emission control requirements for condensate tanks 007 since it is located in an attainment area.) XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS... (Applicant is currently subject to this since actual uncontrolled emissions are greater than 20 tpy of VOC.) Regulation 8—Hazardous AirPalkitants - MACT EEEE: Organic Liquids Distribution 007 Pick one: • This source is not subject to MACT EEEE because it is not located at a major source of HAP. MACT HH 007 Pick one: • 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 (%) 0.55 V0C No Engineer Calculation 95 Ib/BBL 0.0033 Benzene/ No Engineer Calculation 95 01 E&P Condensate lb/BBL 71432 007 Storage Tanks 0.063 n-Hexane No Engineer Calculation 95 ib/BBI /110543 0.0040 Toluene/1 No Engineer Calculation 95 lb/BBL 08883 SCC 40400311 —Fixed Roof Tank,Condensate,working+breathing+flashing losses Section 14—Miscellaneous Application Notes AIRS Point 007 Condensate Storage Tanks - VOC: ((42.59*2000)/182,500)+((7,75*2000)/182,500)=0.55 Ib/BBL Benzene: ((0.264*2000)/182,500)+((0.033`2000)/182,500)=0.0033 Ib/BBL Toluene: ((0.321-2000y182,500)+((0.041*2000)/182,500)=0.0040 Ib/BBL n-Hexane: ((4.793*2000)/182,500)+((0.948`2000)/182,500)=0.063 lb/BBL The source will have to do an initial site specific sampling since the emission factors were calculated by using a composite gas analysis from areas close by and not actually at the gas plant. I spoke with the operator and they will accept the testing requirement in the permit. This source is not located in the 8-hour ozone non-attainment area(Weld County is in partial attainment). Therefore, the provisions of Regulation 7, Section XII do not apply to this source. 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 4 ae � {f STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT p4cot°R AIR POLLUTION CONTROL DIVISION I.. TELEPHONE:(303)692-3150 :1+t .: ♦I 87. CONSTRUCTION PERMIT PERMIT NO: 13WE 1 1 30 Issuance 2 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 Redtail Gas Plant, located in the NE '/ of Section 31, T10N R58W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID FUG-1 009 Equipment leaks (fugitive VOCs) from a natural gas processing plant. 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, 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 9 Fugitive SM/M Version 2012-2 olor Depa en li 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 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) Monthly Limits: Facility AIRS Pounds per Month Emission Type Equipment ID Point VOC FUG-1 009 2262 Fugitive (Note: Monthly limits are based on a 31-day month.) The owner or operator shall calculate monthly emissions based on the calendar month. Facility-wide emissions of each individual hazardous air pollutant shall be less than 1,359 lb/month. Facility-wide emissions of total hazardous air pollutants shall be less than 3,398 lb/month. Annual Limits: Facility AIRS Tons per Year Emission Type Equipment ID Point VOC FUG-1 009 13.3 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. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. AIRS ID: 123/9AD0 Page 2 of 9 IIolor Depa F en . , •li ' Health and Environment ' 'it Pollution Control Division The permit h. . I ,, „ .t.': .io onth r:;;: eep 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 analysis, 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. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 9. The fugitive emissions addressed by AIRS ID 009 are subject to the New Source Performance Standards requirements of Regulation No. 6, Part A, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution including, but not limited to, the following: • §60.5365 Applicability - The group of all equipment, except compressors, within a process unit for which you commence construction, modification or reconstruction after August 23, 2011 is an affected facility per§60.5365(f). • §60.5400 Standards - The group of all equipment, except compressors, within a process unit must comply with the requirements of§60.5400 and §60.5401. • §60.5410 - Owner or operator must demonstrate initial compliance with the standards using the requirements in §60.5410(f). • § 60.5415 - Owner or operator must demonstrate continuous compliance with the standards using the requirements in §60.5415(f). • § 60.5421 - Owner or operator must comply with the recordkeeping requirements of §60.5421(b). • § 60.5422 - Owner or operator must comply with the reporting requirements of paragraphs (b) and (c) of this section in addition to the requirements of§ 60.487a(a), (b), (c)(2)(i) through (iv), and (c)(2)(vii) through (viii). 10. The reciprocating compressors grouped with the fugitive emissions addressed by AIRS ID 009 are subject to the New Source Performance Standards requirements of Regulation No. 6, Part A, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution including, but not limited to, the following: • §60.5385(a) — Owner or operator must replace the reciprocating compressor rod packing according to either paragraph §60.5385(a)(1) or(2). (i) §60.5385(a)(1) - Before the compressor has operated for 26,000 hours. The number of hours of operation must be continuously monitored beginning upon initial startup of your reciprocating compressor affected facility, or October 15, 2012, or the date of the most recent reciprocating compressor rod packing replacement, whichever is later. (ii) §60.5385(a)(2) - Prior to 36 months from the date of the most recent rod packing replacement, or 36 months from the date of startup for a new AIRS ID: 123/9ADO Page 3 of 9 • olor Depa en li ealth and Environment it Pollution Control Division rJJ p for e r cking has not yet been replaced. • §60.5410 — Owner or operator must demonstrate initial compliance with the standards as detailed in §60.5410(c). • §60.5415—Owner or operator must demonstrate continuous compliance with the standards as detailed in §60.5415(c). • §60.5420 - Owner or operator must comply with the notification, reporting, and recordkeeping requirements as specified in §60.5420(a), §60.5420(b)(1), §60.5420(b)(4), and §60.5420(c)(3). 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 issuance of this permit, the owner or operator shall complete the initial extended gas analysis of gas samples that are representative of volatile organic compound (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas analysis 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 analysis OR 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 that are representative of volatile organic compounds (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas analysis shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. ADDITIONAL REQUIREMENTS 15. All previous versions of this permit are cancelled upon issuance of this permit. 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: 12319AD0 Page 4 of 9 '1 �'i olor , ,Depa en P .Ii "Health and Environment y it Pollution Control 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. 17. 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: 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 Page 5 of 9 olor epa en li ealth and Environment it Pollution Control Division 22. Each and ev io h 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. 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 2 This Issuance Updated component counts Issuance 1 8/16/2013 Issued to Whiting Oil and Gas Corporation AIRS ID: 123/9AD0 Page 6 of 9 olor Depa 'Ii 'Health and Environment ) ! en it Pollution Control Division s= i 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.gov/cs/Satellite?c=Document C&childpagename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&oaaename=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# (Ib/yr) reportable? (Ib/yr) Benzene 71432 233 No 81 Toluene 108883 260 Yes 91 009 Ethylbenzene 100414 41 No 14 Xylenes 1330207 55 No 19 n-Hexane 110543 4,437 Yes 1552 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 2573 0 982 0 Flanges 656 0 288 0 Open-ended Lines 0 0 0 0 Pump Seals 0 0 26 0 Valves 867 0 206 0 Other* 151 0 0 0 VOC Content(wt. 0.4039 1.0000 1.0000 1.0000 fraction) Benzene Content(wt. 0.0017 0.0000 0.0017 0.0000 fraction) Toluene Content(wt. 0.0019 0.0000 0.0019 0.0000 fraction) Ethylbenzene (wt. 0.0003 0.0000 0.0003 0.0000 fraction) Xylenes Content(wt. 0.0004 0.0000 0.0004 0.0000 AIRS ID: 123/9AD0 Page 7 of 9 olor Depa en li ealth and Environment it Pollution Control Division fraction) n-hexane Content(wt. 0.0324 0.0000 0.0324 0.0000 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): 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 analysis. 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 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.aov/ AIRS ID: 123/9AD0 Page 8 of 9 m olor Depa en' P .Ii Health° and Environment it Pollution Control Division 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: www.coloradomov/cdphe/oilqaspermits AIRS ID: 123/9AD0 Page 9 of 9 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 Redtail Gas Plant Permit No 13WE1130 AIRS 123/9AD0/009 Permit Engineer Rebecca Vasil Application Date 5/7/2014 Review Date 6/4/2014 Summary of Emissions VOC Benzene Toluene Ethylbenzne Xylenes n-Hexane (tpy) (lb/yr) (Ib/yr) (lb/yr) (Ib/yr) (Iblyr) Uncontrolled Requested Emissions 33.9 233 260 41 55 4,437 Controlled Requested Emissions 13.3 81 91 14 19 1,552 Reportable? I l Yes No No No Yes Total HAP,Uncontrolled(tpy) 2.5 • Total HAP,Controlled(tpy) I 0.9 Highest HAP,Uncontrolled(tpy) 2.2 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 0.4039 HAP Gas Light Oil Heavy Oil Water/Oil Light Oil 1.0000 Benzene 0.0017 0.0017 0.0000 0.0000 Heavy Oil 1.0000 Toluene 0.0019 0.0019 0.0000 0.0000 Water/Oil 1.0000 Ethylbenze 0.0003 0.0003 0.0000 0.0000 Xylene 0.0004 0.0004 0.0000 0.0000 n-Hexane 0.0324 0.0324 0.0000 0.0000 Comments/Notes: Enter Comments here Printed 9/2/2014 Page 1 or 1 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Whiting Oil and Gas Corporation Permit Number: 13WE3003 Source Location: NE 1/4 Sec. 21 T10N R58W, Weld County(attainment) Equipment Description: Plant flare with a minimum combustion efficiency of 95%. AIRS ID: 123-9AD0-013 Date: June 11,2014 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? May 7t°2014 Section 4—Source Description AIRS Point Equipment Description Flare is used for upsets and/or emergencies. This flare receives: purge gas, 013 emissions from electric compressor and amine blowdowns, and plant blowdowns. The 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 013 Site-specific(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(PTEI AIRS Point Process Consumption/Throughput/Production 013 24.6 mmscf/yr Basis for Actual Emissions Reported During this APEN Filing(Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 013 24.6 mmscf/yr NA Basis for Permitted Emissions(Permit Limits) AIRS Point Process Consumption/Throughput/Production 013 24.6 mmscf/yr Does this facility use control devices? X Yes No AIRS Point Process Control Device Description % Reduction Granted 013 01 Continuous-Pilot Plant Flare 95 Point NO„ VOC CO Single HAP Total HAP PTE: 008 0.80 50.63 4.37 1'31 1.31 (n-hexane) Uncontrolled point source 008 0.80 50.63 4.37 1.31 1.31 emission rate: (n-hexane) Controlled point source 008 0.80 2.57 4.37 0'065 0.065 emission rate: (n-hexane) Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled Controlled Emission Pollutant CAS# BIN Emission Rate emissions (iblyr) nporteble? Rate(iblyr) n-Hexane 110543 C 2615 Yes 131 Note: Regulation 3, Part A, Section Il.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? If"yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method 008 01 VOC, State only requirement Site-specific gas HAPS analysis • 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 I 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. IIl.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 013 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 013 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 013 Criteria Pollutants: Applicant is required to file an APEN since emissions exceed 2 tons per year VOC Part B—Construction Permit Exemptions 013 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 ll.D.3.a) Regulation 6-New Source Performance Standards 013 None Regulation 7—Volatile Organic Compounds 013 None Regulation 8— Hazardous Air Pollutants .. 013 None Page 3 Section 13—Aerometric Information Retrieval System Coding Information Point Process Process Description Emission Pollutant/ Fugitive Emission Factor Control Factor CAS# (Y/N) Source (%) 4116 Engineering Ib/MMscf V0C No Calculation 95 0.068 N0x No AP-42, NA 01 Flare Ib/MMBtu Table 13.5-1 013 0.37 CO No AP-42, NA lb/MMBtu Table 13.5-1 106.26 n-hexane No Engineering 95 lb/MMscf Calculation SCC 31000205-Flares Section 14—Miscellaneous Application Notes AIRS Point I 013 I Flare Emissions were calculated using: ((scf/hr) *(Ib/Ib-mol))/(379.4 scf/Ib-mol) = lb/hr (hr/yr)/2000 Ib/T) =TPY VOC= (50.63 TPY*2000 lb/T)/(24.6 mmscf/yr) =4116 Ib/mmscf NOx and CO(from AP-42, Chapter 13, Table 13.5-1 (NOx=0.068 Ib/mmbtu; CO=0.37 lb/mmbtu) Emission factors for HAPS are: To calculate emission factors, take the emissions(lb/yr)and divide it by total throughput(mmscf/yr). n-hexane=(2614 lb/yr)/24.6 mmscf/yr= 106.26 Ib/mmscf Emissions generated from the flare are: Uncontrolled Total(lb/yr) Controlled Total(lb/yr) NOx 1600 1600 VOC 101260 5140 CO 8740 8740 n-hexane 2614 130 An extended gas analysis was provided in the application dated 03/28/2013. The gas analysis was performed less than a year of submittal.An updated extended gas analysis will not be required. • Page 4 t iiv� i 1i$STATE OF COLORADO pF COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT F% . AIR POLLUTION CONTROL DIVISION ; TELEPHONE: (303)692-3150 .�4 *Ian CONSTRUCTION PERMIT PERMIT NO: 13WE3003 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 Redtail Gas Plant, located in the NE 1/4 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 Process flare (Tornado, SL 12-48-14-0.5-6-316L and serial number: TBD) controlling emissions from routine operations FLR-1A 013 including: purge gas, emissions from electric compressor and amine blowdowns, and plant blowdowns. The flare has a minimum 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 commencement of operation, 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). AIRS ID: 123/9AD0 Page 1 of 8 Wellhead Version 2012-1 Colorado Department of Public PollutionHealthand Control DivisionEnvironment 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 the flare shall be provided to the Division within fifteen (15) days after commencement of operation. • 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) Monthly Limits: Facility AIRS Pounds per Month Equipment ID Point NO, VOC CO Emission Type FLR-1A 013 136 436.5 742.3 Point (Note: Monthly limits are based on a 31-day month.) The owner or operator shall calculate monthly emissions based on the calendar month. Facility-wide emissions of each individual hazardous air pollutant shall be less than 1,359 lb/month. Facility-wide emissions of total hazardous air pollutants shall be less than 3,398 lb/month. AIRS ID: 123/9AD0 Page 2 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division i l 'E Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO, VOC CO Emission Type FLR-1A 013 0.8 2.6 4.4 Point 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. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 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 FLR-1A 013 Continuous- Pilot flare VOC, HAPs PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the 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 Monthly Limit Equipment Point Process Parameter Annual Limit (31 Days) ID FLR-1A 013 Natural gas flaring 24.6 MMSCF/yr 2.1 MMSCF/mo 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 AIRS ID: 123/9AD0 Page 3 of 8 Colorado Department of Public PollutionHealthand Control DivisionEnvironment 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. This source is subject to the odor requirements of Regulation No.2.(State only enforceable) 14. The owner or operator shall continuously monitor the process flare with a thermocouple to ensure the continuous presence of a pilot flame. 15. The owner or operator shall continuously monitor and record the total gas volume routed to the process flare using a flow meter to demonstrate compliance with the throughput and emission limits contained in this permit. OPERATING & MAINTENANCE REQUIREMENTS 16. 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 17. The owner or operator shall demonstrate compliance with opacity limits contained in this permit using EPA Method 9 to measure opacity from the flare.(Reference: Regulation No. 1, Section II.A.5). ADDITIONAL REQUIREMENTS 18. 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 Colorado Department 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 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. 19. 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 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 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. 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 AIRS ID: 123/9AD0 Page 5 of 8 DRAF' Colorado Department of Public PollutionHealthand Control DivisionEnvironment 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. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115(enforcement),-121 (injunctions),-122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Rebecca Vasil Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Whiting Oil and Gas Corporation AIRS ID: 12319AD0 Page 6 of 8 „ 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.us/requlations/airreqs/100102aecccommonprovis ionsreq.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. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Point Pollutant CAS# BIN (Ib/yr) reportable? Rate(Ib/yr) 013 n-hexane 110543 C 2,615 YES 131 5) The emission levels contained in this permit are based on the following emission factors: Gas Emission Emission Weight Factors Factors CAS# Pollutant Fraction of Uncontrolled Controlled Source Gas(%) 0.068 0.068 NOx lb/MMBtu lb/MMBtu AP-42 0.37 0.37 CO lb/MMBtu lb/MMBtu AP-42 VOC 19.0 4116 205.8 Engineering lb/mmscf lb/mmscf Calculation 110543 n-hexane 0.99 106.26 5.31 Engineering lb/mmscf lb/mmscf Calculation Note: The uncontrolled VOC and HAP emissions for this point were calculated using the analysis of a gas sample collected from several wells.The controlled VOC emissions factors are based on the flare control efficiency of 95%. AIRS ID: 123/9AD0 Page 7 of 8 D RA.F 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://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 XXXX)CK 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/oilaasoerrnittind.html AIRS ID: 123/9AD0 Page 8 of 8 $i r r m STATE OF COLORADO F CO-- COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT 4;:-:,:87:4 \ AIR POLLUTION CONTROL DIVISION $i TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 1 3WE3004 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 production facility, known as the Redtail Gas Plant, located in the NE 1/4 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 One (1) Zeeco hot oil heater, Model: GLSF14, Serial Number: H- HTR-1A 014 8801 with a total design heat input rate of 43.64 MMBtu/hr. This heater is fueled by natural gas. This heater is equipped with low NOx burners. 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 www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) after commencement of operation, 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 AIRS ID: 123/9AD0 Page 1 of 9 Multi-Unit Version 2008-1 Colorado Department of PublicPollution Health andControl EnviroDivisnmention Air 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 following information shall be provided to the Division within fifteen (15) days after commencement of operation. • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Monthly Limits: Facility AIRS Pounds per Month Emission Equipment ID Point NO, VOC CO PMl• PM2,5 Type HTR-1A 014 2144 617 1332 421 421 Point (Note: Monthly limits are based on a 31-day month.) The owner or operator shall calculate monthly emissions based on the calendar month. Facility-wide emissions of each individual hazardous air pollutant shall be less than 1,359 lb/month. Facility-wide emissions of total hazardous air pollutants shall be less than 3,398 lb/month. Annual Limits: Facility AIRS Tons per Year Emission Equipment ID Point PK,* PM2.5 NO, VOC CO Type HTR-1A 014 2.5 2.5 12.7 3.7 7.9 Point See °Notes to Permit Holder"for information on emission factors and methods used to calculate limits. AIRS ID: 123/9ADO Page 2 of 9 Ill ; _ �_ Colorado Department of Public Health and Environment Air Pollution Control Division Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. PROCESS LIMITATIONS AND RECORDS 7. This source shall be limited to the following maximum consumption, processing and/or operational rates as listed below. Monthly records of the actual process rate 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 Annual Monthly Equipment Point Process Parameter Limit Limit ID (31 days) HTR-1A 014 Combustion of natural gas as a fuel 375 31.85 MMscf/yr MMscf/month The owner or operator shall calculate monthly process rates based on the calendar month. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 8. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) AIRS ID: 123/9AD0 Page 3 of 9 1) RA.Fartment of Public Health and Environment •P31E"folorado Department Air Pollution Control Division 9. Visible emissions shall not exceed twenty percent(20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVIl.B.1.c shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1_ &4.) 10. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 11. This source is subject to the New Source Performance Standards requirements of Regulation No. 6, Part A Subpart Dc, Standards of Performance for. Small Industrial- Commercial-Institutional Steam Generating Units including, but not limited to, the following: a. The owner or operator of the facility shall record and maintain records of the amount of fuel combusted during each month (40 CFR Part 60.48c(g)). b. Monthly records of fuel combusted required under the previous condition shall be maintained by the owner or operator of the facility for a period of two years following the date of such record (40 CFR Part 60.48c(i)). In addition, the following requirements of Regulation No. 6, Part A, Subpart A, General Provisions, apply. c. At all times, including periods of start-up, shutdown, and malfunction, the facility and control equipment shall, to the extent practicable, be maintained and operated in a manner consistent with good air pollution control practices for minimizing emissions. Determination of whether or not acceptable operating and maintenance procedures are being used will be based on information available to the Division, which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. (Reference: Regulation No. 6, Part A. General Provisions from 40 CFR 60.11 d. No article, machine, equipment or process shall be used to conceal an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gases discharged to the atmosphere. (§ 60.12) e. Written notification of construction and initial startup dates shall be submitted to the Division as required under§60.7. f. Records of startups, shutdowns, and malfunctions shall be maintained, as required under§ 60.7. 12. Particulate matter emissions shall be limited as per: Regulation 6, Part B, II.C.2. OPERATING & MAINTENANCE REQUIREMENTS 13. This source is not required to follow a Division-approved operating and maintenance plan. • AIRS ID: 123/9ADO Page 4 of 9 s ar Colorado Department of Public Health and Environment y _ . .„. .. Air Pollution Control Division COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 14. No initial testing required. Periodic Testing Requirements 15. No periodic testing required. 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 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, 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 AIRS ID: 123/9AD0 Page 5 of 9 FColorado Department of Public PollutionHealthand ControlEnvironment Division 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,tY, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 21. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 22. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 23. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. • AIRS ID: 123/9AD0 Page 6 of 9 DIZAF Colorado Department of Pund me Airblic PollutiHealth acrid Division nt 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 9 :Pt_AsIElr_[Iolorado Department of Public Health and Environment Air Pollution Control Division Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division • of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: htto://www.colorado.aov/cs/Satellite?c=Document C&childoaoename=CDPHE- Main%2FDocument_C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapoer 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# (Ib/yr) reportable? (Ib/yr) 014 n-Hexane 110543 675 YES 675 5) The emission levels contained in this permit are based on the following emission factors: Emission Factors Uncontrolled CAS# Pollutant Ib/MMSCF Source Natural Gas Combusted PM10 13.26 Manufacturer PM25 13.26 Manufacturer NOx 67.32 Manufacturer CO 41.82 Manufacturer VOC 19.38 Manufacturer 110543 n-Hexane 1.8 AP-42 Table 1.4-3 Fuel heat value 1020 btu/scf was used to convert emissions factors from Ib/mmbtu to Ib/mmscf. AIRS ID: 123/9AD0 Page 8 of 9 k A. 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 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: htto://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 777Z—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXX( 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: www.colorado.gov/cd phe/oiloaspermits AIRS ID: 123/9AD0 Page 9 of 9 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Whiting Oil and Gas Corporation Permit'Number(s): 13W E3004 Redtail Gas Plant, NE 1/4 Section 21,T10N R58W(Weld County Source Location: attainment) Equipment Description: Natural gas-fired hot oil heater AIRS ID: 123/9AD0/014 Date: June 18, 2014 Review Engineer: Rebecca Vasil Control Engineer: Chris Laplante 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? May 7th 2014 Section 4—Source Description AIRS Point Equipment Description One(1)Zeeco hot oil heater, Model: GLSF14, Serial Number H-8801 with a total design 014 heat input rate of 43.64 MMBtu/hr. This heater is fueled by natural gas. This heater is equipped with low NOx burners. 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 PKo 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 Yes X No of Regulation 7, Sections XII and XVI may apply) Page 1 Section 5—Emission Estimate Information AIRS Point Emission Factor Source Emissions from the hot oil heater are based on manufacturer's guaranteed emission 014 factors for PM, NOx, CO and VOC. SO2 emissions and HAP emissions are based on AP- 42 Table 1.4-3. Did the applicant provide actual process data for the emission inventory? Yes X No Basis for Potential to Emit(PTEZ AIRS Point Process Consumption/Throughput/Production 014 Combustion of natural gas through the hot oil heater shall not exceed 852.7 MMSCF per year or 72.4 MMSCF per month. (Based on natural gas heat value of 964.4 btu/scf) Basis for Permitted Emissions(Permit Limits' AIRS Point Process Consumption/Throughput/Production 014 Combustion of natural gas through the hot oil heater shall not exceed 852.7 MMSCF per year or 72.4 MMSCF per month. Based on natural gas heat value of 964.4 btu/scf) Does this source use a control device? X Yes No AIRS Point Process Control Device Description Pollutant % Reduction Granted 014 01 None(LowNOx burner considered proms) N/A 0.0 Section 6—Emission Summary(tons per year) Facility, PTE Before Emissions Controls: • Point(process) TSP PM,e PM2,5 SO2 NO VOC CO Single Total HAP HAPs 014 — 2.48 2.48 0.11 12.62 3.63 7.84 0'34(n- 0.35 hexane) Controlled point source emission rate: Point(process) TSP PM,e PM2,5 SO2 NO VOC CO Single Total HAP HAPs 014 -- 2.48 2.48 0.11 12.62 3.63 7.84 0'34(n- 0.35 hexane) Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled p Controlled AIRS Point Pollutant CAS# BIN Emission Rate eawabrm Emission Rate (IbM) reportable? (lb)Yr) 014 n-Hexane 110543 C 675 YES 675 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? If"yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method 014 01 N/A None 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? Section 12—Aerometric Information Retrieval System Coding Information Point Process Process Description Emission Pollutant/ Fugitive Emission Factor Control Factor CAS# (Y/N) Source (%) 13.26 Manufacturer lb/MMSCF PMio No Estimate 0.0 fuel input 13.26 Manufacturer Ib/MMSCF PM25 No Estimate 0.0 fuel input 0.6 AP-42 Table Ib/MMSCF SO2 No 14-2 0.0 fuel input 43.64 MMBtu/hr Hot Oil 67.32 Manufacturer 01 Heater Ib/MMSCF NOx No Estimate 0.0 fuel input 014 41.82 Manufacturer Ib/MMSCF CO No Estimate 0.0 fuel input 19.38 Manufacturer Ib/MMSCF VOC No Estimate 0.0 fuel input 1.8 AP-42 Table Ib/MMSCF n-Hexane No 143 0.0 fuel input SCC 10300602—External Combustion Boiler: Commercial/Institutional: Natural Gas: 10- 100 MMBtu/hr Notes Important Conversion Factors: • Fuel heating value of 1020 Btu/SCF Page 3 Section 13—Miscellaneous Application Notes AIRS Point 014 43.64 MMBtu/hr Hot Oil Heater The heater is identified as HTR-1A(AIRS ID 014). The heater combusts natural gas and is equipped with low NOx burners. The heater is used to heat oil which is then used for regeneration in both the amine unit and dehydrator. The hot oil heater stack is routed to the atmosphere. The source used manufacturer guaranteed emission factors to estimate PM, NOx, VOC and CO. The source provided documentation of the manufacturer's emission factors. The manufacturer's emission factors are based on heat release so the emission factors are multiplied by the heater efficiency of 85%to then calculate emissions based on heat input of 43.64 MMBtu/hr. SO2 emissions and HAP emissions are based on AP-42, Table 1.4-2 and Table 1.4-3. AP-42 states that emission factors are based on a heat value of 1,020 btu/scf. Thus, the emission factors were converted to lb/MMbtu by dividing the values in Table 1.4-3 by 1,020 btu/scf. I confirmed that the emission estimates were correct. The hot oil heater is subject to the particulate emissions standard under Regulation 6, Part B, Section II.C.2. This hot oil heater is also subject to NSPS Dc because the unit is a steam generating unit that commenced construction after 6/9/1989 and that has a heat input capacity greater than 10 MMBtu/hr but less than 100 MMBtu/hr(60.40c(a)). Since the heater is only burning natural gas, the facility is only required to maintain fuel use records per 60.48c(g)and 60.48c(i). • Further, the total heater capacity at the facility is 43.64 MMbtu/hr;thus,the boiler, which is less than 250 MMBtu/hr, does not qualify as one of the listed sources in Regulation 3, Part D, Section II.A.24.a.(i)(V). Page 4 Ill A STATE OF COLORADO ff. co COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT F4:1 �� AIR POLLUTION CONTROL DIVISION _- ! TELEPHONE: (303) 692-3150 +- **, .18764 ' CONSTRUCTION PERMIT PERMIT NO: 13WE3005 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 Redtail Gas Plant, located in the NE '/< 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 One (1) Ethylene Glycol (EG), natural gas dehydration unit(Alco, FAB38-20B, serial number: 2012-8390-12)with a design capacity of 28.5 MMscf per day. This emissions unit is equipped with two DEHY-1 015 (2) Bear CX-5H Duplex electric-glycol pumps with a design capacity of 6 gal/min. This unit is equipped with a flash tank, reboiler and still vent. Emissions from the flash tank are routed to common fuel header for the facility. Emissions from the still vent are sent to a combustor. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S.(25-7-101 et seq),TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division)no later than fifteen days after 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 commencement of operation, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the AIRS ID: 123/9AD0 Page 1 of 9 Dehy SM/M Version 2012-1 D Co do p e o Public Health and Environment Air Pollution Control Division 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 fora 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) Monthly Limits: Facility AIRS Pounds per Month Emission Type Equipment ID Point NO. VOC CO DEHY-1 015 — 258' -- Point (Note: Monthly limits are based on a 31-day month.) The owner or operator shall calculate monthly emissions based on the calendar month. Facility-wide emissions of each individual hazardous air pollutant shall be less than 1,359 lb/month. Facility-wide emissions of total hazardous air pollutants shall be less than 3,398 lb/month. Annual Limits: Facility AIRS Tons per Year Emission Type Equipment ID Point NO VOC CO DEHY-1 015 ---• 1.5 -- Point See"Notes to Permit Holder for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. AIRS ID: 123/9AD0 Page 2 of 9 i ( Co{A. do t p e ° or 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. Compliance with the emission limits in this permit shall be demonstrated by running the Aspen HYSYS model version 7.3 or higher on a monthly basis using the most recent wet gas analysis and recorded operational values (including gas throughput, lean glycol recirculation rate, and other operational values specified in the O&M Plan). Recorded operational values, except for gas throughput,shall be averaged on a monthly basis for input into Aspen HYSYS and be provided to the Division upon request. 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 DEHY-1 015 Combustor VOC and HAPs 9. 100% of emissions that result from the flash tank associated with this dehydrator shall be recycled to the common fuel header. PROCESS LIMITATIONS AND RECORDS 10. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing 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 Annual Monthly Limit Equipment Point Process Parameter Limit (31 days) ID DEHY-1 015 Natural gas throughput 10,402 883 MMscf/yr MMscf/month The owner or operator shall calculate monthly process rates based on the calendar month. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months'data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility,for Division review. AIRS ID: 123/9AD0 Page 3 of 9 Co do p e o Public Health and Environment 1) Air Pollution Control Division 11. This unit shall be limited to the maximum lean glycol circulation rate of 3.0 gallons per minute. The lean glycol recirculation rate shall be recorded weekly in a log maintained on site and made available to the Division for inspection upon request. (Reference:Regulation No. 3, Part B, II.A.4) STATE AND FEDERAL REGULATORY REQUIREMENTS 12. The permit number and AIRS ID point number(e.g. 123/4567/890)shall be marked pn 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). 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. 15. This equipment is subject to the control requirements for glycol natural gas dehydrators under Regulation No. 7, Section XVII.D (State only enforceable). Beginning May 1, 2008, uncontrolled actual emissions of volatile organic compounds from the still vent and vent from any gas-condensate-glycol(GCG)separator(flash separator or flash tank), if present,shall be reduced by an average of at least 90 percent through the use of air pollution control equipment. This source shall comply with all applicable general provisions of Regulation 7,Section XVII. 16. OPERATING & MAINTENANCE REQUIREMENTS 17. 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 Testinq Requirements 18. With 180 days of commencement of operation the owner or operator shall demonstrate compliance with the opacity limits in this permit, using EPA Method 22 to determine the presence or absence of visible emissions."Visible Emissions"means observations of smoke for any period or periods of duration greater than or equal to one (1) minute in any fifteen (15)minute period during normal operation.(Reference:Regulation No.7,Section XVII.A.II) 19. The owner or operator shall complete the initial annual extended wet gas analysis testing required by this permit and submit the results to the Division as part of the self-certification process to ensure compliance with emissions limits. (Reference: Regulation No. 3, Part B, Section III.E.) 20. Within 180 days of commencement of operation, a source initial compliance test shall be conducted on emissions point 015 to measure the emission rate(s)for the pollutants listed below in order to demonstrate compliance with emissions limits in this permit. The test AIRS ID: 123/9AD0 Page 4 of 9 . . .a HHip Co ak.do if p e o Public Health and Environment Air Pollution Control Division 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) Volatile Organic Compounds using EPA approved methods. Periodic Testing Requirements 21. The owner or operator shall complete an extended wet gas analysis prior to the inlet of the EG dehydrator on an annual basis. Results of the wet gas analysis shall be used to calculate emissions of criteria pollutants and hazardous air pollutants per this permit and be provided to the Division upon request. 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 AIRS ID: 123/9AD0 Page 5 of 9 Co do p e o PubD lic PollutionHealthand Control DivisionEnvironment 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. 25. 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. 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, ttie 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 6 of 9 Co do p e o Public Health and Environment 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 9 D Co do 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.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions.The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: http://www.colorado.gov/cs/Satellite?c=Document C&childpagename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&paciename=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 Emission Are the Controlled AIRS Rate emissions Emission Point Pollutant CAS# BIN (lb/yr) reportable? Rate(Ib/yr) Benzene 71432 A 312 Yes 15 015 Hexane 110543 C 240 NO 12 5) The emission levels contained in this permit are based on information provided in the application and the HYSYS model.Compliance with emissions limits shall be demonstrated by estimating emissions with the HYSIS model. 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 AIRS ID: 123/9AD0 Page 8 of 9 rar Coido ar p e = o' Public Health and Environment , � � Air Pollution Control Division NSPS KKK Not Applicable 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60,Appendixes Appendix A—Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX 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: https://www.colorado.00v/pacific/cdphe/oil-and-qas-construction-perm it-self-certification AIRS ID: 123/9AD0 Page 9 of 9 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information • Company Name: Whiting Oil and Gas Corporation Permit Number: 13WE3005 Source Location: NE 1/4, Section 21,T10N, R58W,Weld County(attainment) Equipment Description: Ethylene Glycol dehydrator AIRS ID: 123-9ADO-015 Date: July 14, 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? May 7th 2014 Section 4—Source Description AIRS Point Equipment Description One(1) Ethylene Glycol (EG), natural gas dehydration unit(Alco, FAB38-20B, serial number: 2012-8390-12)with a design capacity of 28.5 MMscf per day. This emissions 015 unit is equipped with two (2) Bear CX-5H Duplex, electric-glycol pumps with a design capacity of 6 gal/min. This unit is equipped with a flash tank, reboiler and still vent. Emissions from the flash tank are routed to common fuel header for the facility. Emissions from the still vent are sent to a combuster. 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 PKo CO Ozone RACT per Regulation 3, Part B, Section III.D.2) Page 1 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) Section 5—Emission Estimate Information AIRS Point Emission Factor Source 015 HYSYS(Refer to Section 14 for calculations) Did the applicant provide actual process data for the emission inventory? X Yes No `" 'Basis for-Potential fo Emit(ITE) AIRS Point Process Consumption/Throughput/Production 015 10,402 MMSCF per year,3.0 gallons per minute glycol circulation rate Basis for Actual Emissions Reported During this APEN Filing(Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 015 10,402 MMSCF per year, 3.0 gallons per minute glycol circulation rate NA Basis for Permitted Emissions(Permit Limitst AIRS Point Process Consumption/Throughput/Production 015 10,402 MMSCF per year, 3.0 gallons per minute glycol circulation rate Does this source use a control device? X Yes No AIRS Point Process Control Device Description % Reduction Granted 015 01 Closed loop system to control flash tank vapors 100 015 02 Combustor to control still vent emissions 95 Section 6—Emission Summar/(tons per year) Point NO„ VOC CO Single HAP Total HAP PTE: 015 — 43.99 — 0.16(Benzene) 0.28 Uncontrolled point 015 — 43.99 — 0.16(Benzene) 0.28 source emission rate: Controlled point 015 — 1.52 — 0.007(Benzene) 0.01 source emission rate: Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled name Controlled Emission Pollutant CAS# BIN Emission Rate missions (Iblyr) repo,lable? Rate(Ib/yr) Benzene 71432 A 312 Yes 14.76 Toluene 108883 C 240 No 11.56 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 Page 2 015 01 VOC, Regulation No. 3, Part B., Section III.G.3 Stack Test HAPS 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? X Yes No If"yes"what kind of modification? Minor Synthetic X 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, 015 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 015 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 015 Applicant is required to file an APEN since emissions exceed2 tons per year VOC in an attainment area area for ozone. Part B—Construction Permit Exemptions 015 Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 50 TPY threshold(Reg. 3, Part B, Section II.D.3.a) Regulation 6-New Source Performance Standards 015 None Page 3 Regulation 7—Volatile°manic°°Compounds . Is this source subject to the control requirements of MACT HH? (Regulation 8-Hazardous Air Pollutants review). No 015 Is this source subject to the exemptions under MACT HH (i.e. throughput exemption less than 3 MMSCFD or benzene exemption of less than 1984 Ib/yr)? No This source is subject to review for the Regulation 7 control requirements. Section XII.H: 075 Is this source located in the non-attainment area? No This source is not subject to this regulation. Section XVII.D(State only enforceable). 015 Applicant is required to reduce VOC emissions from this dehydrator by at least 90%since uncontrolled VOC emissions are treater than the 15.0 TPY threshold. Regulation 8-Hazardous AirPollutants . - -MACT HH: If facility is MAJOR source for HAP(summation of HAPS of dehydrators and fugitives greater than 25 TPY total or 10 TPY single HAP),then all glycol dehydrators at this facility are subject to MACT HH. If facility is an area source of HAP,only TEG dehydrators are subject to MACT HH. 1.Is facility a production field facility per 63.761 (Refer to Section 14 for definition)? No 2.If facility is defined as a production facility, then is it a major source of HAPS when summing up dehydrator and flash tank emissions?No 015 3.If facility is NOT a production field facility(i.e. natural gas processing plant),then is it a major source of HAPS when summing all HAP emissions from ALL HAP emitting units? No 4.Is this facility considered MAJOR for HAPS?r No 5.Is this source subject to MACT HH?r No This facility is an area source of HAP. No area source requirements of HH apply to this EG or DEG dehydrator. Section 13—Aerometric Information Retrieval System Coding Information Point Process Process Throughput Emission Pollutant/ Fugitive Emission Control Description limit Factor CAS# (Y/N) Factor Source (%) 2.7 VOC No HYSYS 100 Glycol Ibs/mmscf Dehydrator 10'402 0.002 Benzene/ 01 (Flash MMSCF per Ibs/mmscf 71432 No HYSYS 100 tank) Year 0.0008 Toluene/ Ibs/mmscf 108883 No HYSYS 100 015 5.8 VOC No HYSYS 95 Glycol 10,402 ibs/mmscf 02 Dehydrator MMSCF 0.03 Benzene/ y per ibs/mmscf 71432 No HYSYS 95 (Still Vent) year 0.02 Toluene/ Ibs/mmscf 108883 No HYSYS 95 SCC 31000304-Glycol Dehydrators: Ethylene glycol: general Page 4 Section 14—Miscellaneous Application Notes AIRS Point 015 Glycol Dehydrator In order to determine emissions, the operator used HYSYS. The source assumed the inlet gas temperature of 162°F and pressure of 378 psig. The permitted glycol recirculation rate is 3.0 gallons per minute. The model was based off of a gas analysis. The gas analysis was performed greater than a year of submittal.An updated extended gas analysis will be required because: -This source is a new source and an actual sample was not available for emission calculations. A test performed at the source once constructed will provide an accurate emissions sampling. Flash Tank Uncontrolled Emission factors VOC = ((13.651)*2000)/(10402) =2.7 lb/mmscf Benzene=((0.008)*2000)/(10402) = 0.002 lb/mmscf Toluene=((0.00438)*2000)/(10402) =0.0008 lb/mmscf Still Vent Uncontrolled Emission factors VOC = ((30.341)*2000)/(10402) = 5.8 lb/mmscf Benzene= ((0.148)*2000)/(10402) = 0.03 lb/mmscf Toluene= ((0.115632)*2000)/(10402) = 0.02 lb/mmscf MACT HH includes requirements for both major and area sources of HAPs. The definition of major source for MACT HH (63.761) states: (3) For facilities that are production field facilities, only HAP emissions from glycol dehydration units and storage vessels with the potential for flash emissions shall be aggregated for a major source determination. For facilities that are not production field facilities, HAP emissions from all HAP emission units shall be aggregated for a major source determination. The following definitions from 63.761 are also needed to determine major source applicability: Production field facilities means those facilities located prior to the point of custody transfer Custody transfer means the transfer of hydrocarbon liquids or natural gas: after processing and/or treatment in the producing operations, or from storage vessels or automatic transfer facilities or other such equipment, including product loading racks, to pipelines or any other forms of transportation. For the purposes of this subpart, the point at which such liquids or natural gas enters a natural gas processing plant is a point of custody transfer. Natural gas processing plant(gas plant) means any processing site engaged in the extraction of natural gas liquids from field gas, or the fractionation of mixed NGL to natural gas products, or a combination of both. Based on the definitions above, this source qualifies as... Does this dehydrator have a reboiler?Yes If Yes, what is the reboiler rated? 5 mmbtu/hr Page 5 • ll STATE OF COLORADO O zotta COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT mew AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 . ry+ �1876� CONSTRUCTION PERMIT PERMIT NO: 13WE3006 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 Redtail Gas Plant, located in the NE 1/4 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 One (1) Ethylene Glycol (EG), natural gas dehydration unit (Alco, model: TBD, serial number TBD)with a design capacity of 70 MMscf per day. This emissions unit is equipped with two (2) Bear DEHY-2 016 CX-5H Duplex electric-glycol pumps with a design capacity of 18 gal/min. This unit is equipped with a flash tank, and still vent. Emissions from the flash tank are routed to common fuel header for the facility. Emissions from the still vent are sent to a combustor. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S.(25-7-101 et seq),TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division(the Division)no later than fifteen days after commencement of operation, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at https://www.colorado.aov/pacific/cdohe/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 commencement of operation, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the AIRS ID: 123/9AD0 Page 1 of 9 Dehy SM/M Version 2012-1 D Co do p e o Public Health and Environment Air Pollution Control Division 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 fora 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 commencement of operation. • 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) Monthly Limits: Facility AIRS Pounds per Month Equipment ID Point NO, VOC CO Emission Type DEHY-2 016 --- 1029 — Point (Note: Monthly limits are based on a 31-day month.) The owner or operator shall calculate monthly emissions based on the calendar month. Facility-wide emissions of each individual hazardous air pollutant shall be less than 1,359 lb/month. Facility-wide emissions of total hazardous air pollutants shall be less than 3,398 lb/month. AIRS ID: 123/9AD0 Page 2 of 9 Coj do s p,' e o Public Health and Environment Air Pollution Control Division Annual Limits: Facility AIRS Tons per Year Emission Type Equipment ID Point NO„ VOC CO DEHY-2 016 --- 6.0 Point See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 8. Compliance with the emission limits in this permit shall be demonstrated by running the Aspen HYSYS model version 7.3 or higher on a monthly basis using the most recent wet gas analysis and recorded operational values (including gas throughput, lean glycol recirculation rate, and other operational values specified in the O&M Plan. Recorded operational values,except for gas throughput,shall be averaged on a monthly basis for input into Aspen HYSYS and be provided to the Division upon request. 9. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID DEHY-2 016 Combustor VOC and HAPs 10. 100% of emissions that result from the flash tank associated with this dehydrator shall be recycled to the common fuel header. AIRS ID: 123/9ADO Page 3 of 9 Co do p e o Public PollutionHealthand ControlEnvironment Division PROCESS LIMITATIONS AND RECORDS 11. 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 Annual Monthly Limit Equipment Point Process Parameter .Limit (31 days) ID DEHY-2 016 Natural gas throughput 25,550 2,170 MMscf/yr MMscf/month The owner or operator shall calculate monthly process rates based on the calendar month. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months'data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility,for Division review. 12. This unit shall be limited to the maximum lean glycol circulation rate of 9.0 gallons per minute. The lean glycol recirculation rate shall be recorded weekly in a log maintained on site and made available to the Division for inspection upon request. (Reference: Regulation No. 3, Part B, II.A.4) STATE AND FEDERAL REGULATORY REQUIREMENTS 13. 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) 14. This source is subject to the odor requirements of Regulation No.2.(State only enforceable) 15. The flare covered by this permit is subject to Regulation No. 7, Section XVII.B General Provisions(State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed, have no visible emissions during normal operations, and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. The operator shall comply with all applicable requirements of Section XVII. 16. This equipment is subject to the control requirements for glycol natural gas dehydrators under Regulation No. 7, Section XVII.D (State only enforceable). Beginning May 1, 2008, uncontrolled actual emissions of volatile organic compounds from the still vent and vent from any gas-condensate-glycol(GCG)separator(flash separator or flash tank), if present,shall be reduced by an average of at least 90 percent through the use of air pollution control equipment. This source shall comply with all applicable general provisions of Regulation 7,Section XVII. AIRS ID: 123/9AD0 Page 4 of 9 CoAdo p e o Public Health and Environment ll Air Pollution Control Division OPERATING & MAINTENANCE REQUIREMENTS 17. 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 18. Within 180 days after commencement of operation the owner or operator shall demonstrate compliance with opacity limits in this permit, using EPA Method 22 to determine the presence or absence of visible emissions."Visible Emissions"means observations of smoke for any period or periods of duration greater than or equal to one (1) minute in any fifteen (15) minute period during normal operation. (Reference: Regulation No.7,Section XVII.A.II) 19. The owner or operator shall complete the initial annual extended wet gas analysis testing required by this permit and submit the results to the Division as part of the self-certification process to ensure compliance with emissions limits. (Reference: Regulation No. 3, Part B, Section III.E.) 20. Within 180 days after commencement of operation a source initial compliance test shall be conducted on emissions point 016 to measure the emission rate(s)for the pollutants listed below in order to demonstrate compliance with emissions 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) Volatile Organic Compounds using EPA approved methods. Periodic Testing Requirements 21. The owner or operator shall complete an extended wet gas analysis prior to the inlet of the EG dehydrator on an annual basis. Results of the wet gas analysis shall be used to calculate emissions of criteria pollutants and hazardous air pollutants per this permit and be provided to the Division upon request. 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 AIRS ID: 123/9AD0 Page 5 of 9 Co do p e o PubD lic PollutionHealthand Control DivisionEnvironment 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 II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 25. 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. 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 AIRS ID: 123/9AD0 Page 6 of 9 Coil:do • p." e o Public Health and Environment Air Pollution Control Division 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), -122.4 (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: 12319AD0 Page 7 of 9 Co do p e o Public PollutionHealthand ControlEnvironment 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: htto://www.colorado.00v/cs/Satellite?c=Document C&childoagename=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 Emission Are the Controlled AIRS Rate emissions Emission Point Pollutant CAS# BIN (Ib/yr) reportable? Rate(Ib/yr) Benzene 71432 A 11,097 YES 542 016 Toluene 108883 C 863 YES 43 5) The emission levels contained in this permit are based on information provided in the application and the HYSYS model. Compliance with emissions limits shall be demonstrated by estimating emissions with the HYSIS model. 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 NSPS KKK Not Applicable AIRS ID: 123/9AD0 Page 8 of 9 Coy, •do e.;p, ` e o Public Health and Environment Air Pollution Control Division 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http.//ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60,Appendixes Appendix A—Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX 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: https://www.colorado.00v/pacific/cdphe/oil-and-qas-construction-perm it-self-certification AIRS ID: 123/9AD0 Page 9 of 9 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Whiting Oil and Gas Corporation Permit Number: 13WE3006 Source Location: NE '/, Section 21, T10N, R58W,Weld County(attainment) Equipment Description: Ethylene Glycol dehydrator AIRS ID: 123-9AD0-016 Date: July 23, 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? May 7`"2014 Section 4—Source Description AIRS Point Equipment Description One(1) Ethylene Glycol (EG), natural gas dehydration unit(Alco, TBD, serial number: TBD)with a design capacity of 70 MMscf per day. This emissions unit is equipped with 016 two(2) Bear CX-5H Duplex, electric-glycol pump with a design capacity of 18 gal/min. This unit is equipped with a flash tank, and still vent. Emissions from the flash tank are routed to common fuel header for the facility. Emissions from the still vent are sent to a combustor. 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) Page 1 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) Section 5—Emission Estimate Information AIRS Point Emission Factor Source 016 HYSYS(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(PTEI AIRS Point Process Consumption/Throughput/Production 016 25,550 MMSCF per year,9.0 gallons per minute glycol circulation rate Basis for Actual Emissions Reported During this APEN Filing(Reported to Inventory), AIRS Point Process Consumption/Throughput/Production Data Year 016 25,550 MMSCF per year, 9.0 gallons per minute glycol circulation rate NA Basis for Permitted Emissions(Permit Limitst!' AIRS Point Process Consumption/Throughput/Production 016 25,550 MMSCF per year, 9.0 gallons per minute glycol circulation rate Does this source use a control device? X Yes No AIRS Point Process Control Device Description % Reduction Granted 016 01 Closed loop system to control flash tank vapors 100 016 01 Combustor to control still vent emissions 95 Section 6—Emission Summary(tons per year) Point NO. VOC CO Single HAP Total HAP PTE: 016 — 152.29 — 5.55(Benzene) 6 Uncontrolled point 016 — 152.29 — 5.55(Benzene) 6 source emission rate: Controlled point 016 --- 6.06 -- 0.27(Benzene) 0.29 source emission rate: Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled Are the Controlled Emission Pollutant CAS# BIN . Emission Rate emissions ��(l m (lb/yr) reportable? Benzene 71432 A 11,097 Yes 542 Toluene 108883 C 863 Yes 42.5 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 Page 2 L016 01 VOC,HAP, Regulation No. 3, Part B., Section III.G.3 Stack Test 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? X Yes No If"yes"what kind of modification? Minor Synthetic X 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, 016 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 016 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 016 Applicant is required to file an APEN since emissions exceed2 tons per year VOC in an attainment area area for ozone. Part B—Construction Permit Exemptions 016 Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 50 TPY threshold(Reg. 3, Part B, Section II.D.3.a) Regulation 6-New Source Performance Standards 016 None Page 3 Reoulatioh t Vc laHte Omarjc Comooands . . . "' Is this source subject to the control requirements of MACT HH? (Regulation 8-Hazardous Air Pollutants review). No 016 Is this source subject to the exemptions under MACT HH (i.e. throughput exemption less than 3 MMSCFD or benzene exemption of less than 1984 Ib/yr)? No This source is subject to review for the Regulation 7 control requirements. Section XII.H: 016 Is this source located in the non-attainment area? No This source is not subject to this regulation. Section XVII.D(State only enforceable). 016 Applicant is required to reduce VOC emissions from this dehydrator by at least 90%since uncontrolled VOC emissions are greater than the 15.0 TPY threshold. Reautatloh 8—Hazardous Air Pollutants: MACT HH: If facility is MAJOR source for HAP(summation of HAPS of dehydrators and fugitives greater than 25 TPY total or 10 TPY single HAP),then all glycol dehydrators at this facility are subject to MACT HH. If facility is an area source of HAP,only TEG dehydrators are subject to MACT HH. 1.Is facility a production field facility per 63.761 (Refer to Section 14 for definition)?No 2.If facility is defined as a production facility, then is it a major source of HAPS when summing up dehydrator and flash tank emissions?No 016 3.If facility is NOT a production field facility(i.e. natural gas processing plant),then is it a major source of HAPS when summing all HAP emissions from ALL HAP emitting units? No 4.Is this facility considered MAJOR for HAPS? r No 5.Is this source subject to MACT HH? r No This facility is an area source of HAP. No area source requirements of HH apply to this EG or DEG dehydrator. Section 13—Aerometric Information Retrieval System Coding Information Point Process Process Throughput Emission Pollutant/ Fugitive Emission Control Description limit Factor CAS# (Y/N) Factor Source (%) 2.46 VOC No HYSYS 100 Glycol lbs/mmscf 25,550 01 Dehydrator MMSCF 0.01 Benzene/ No HYSYS 100 (Flash MMSCF per lbs/mmscf 71432 tank) year 0.0005 Toluene/ No HYSYS 100 lbs/mmscf 108883 016 9.46 VOC No HYSYS 95 Glycol 25,550 lbs/mmscf 02 Dehydrator MMSCF per 0.42 Benzene/ No HYSYS 95 y lbs/mmscf 71432 (Still Vent) year 0.03 Toluene/ lbs/mmscf 108883 No HYSYS 95 SCC 31000304-Glycol Dehydrators: Ethylene glycol: general Page 4 Section 14—Miscellaneous Application Notes AIRS Point 016 Glycol Dehydrator In order to determine emissions, the operator used HYSYS. The source assumed the inlet gas temperature of 150°F and pressure of 389 psig. The permitted glycol recirculation rate is 9.0 gallons per minute. The model was based off of a gas analysis. The gas analysis was performed greater than a year of submittal. An updated extended gas analysis will be required because: -This source is a new source and an actual sample was not available for emission calculations. A test performed at the source once constructed will provide an accurate emissions sampling. Flash Tank Uncontrolled Emission factors VOC= ((31.472)*2000)/(70*365) = 2.46 lb/mmscf Benzene= ((0.128)*2000)/(70*365) = 0.01 lb/mmscf Toluene= ((0.0066)*2000)/(70*365) = 0.0005 lb/mmscf Still Vent Uncontrolled Emission factors VOC = ((120.821)*2000)/(70*365) = 9.46 lb/mmscf Benzene= ((5.420)*2000)/(70*365) = 0.42 lb/mmscf Toluene=((0.42486)*2000)/(70*365) = 0.03 lb/mmscf MACT HH includes requirements for both major and area sources of HAPs. The definition of major source for MACT HH (63.761) states: (3) For facilities that are production field facilities, only HAP emissions from glycol dehydration units and storage vessels with the potential for flash emissions shall be aggregated for a major source determination. For facilities that are not production field facilities, HAP emissions from all HAP emission units shall be aggregated for a major source determination. The following definitions from 63.761 are also needed to determine major source applicability: Production field facilities means those facilities located prior to the point of custody transfer Custody transfer means the transfer of hydrocarbon liquids or natural gas: after processing and/or treatment in the producing operations, or from storage vessels or automatic transfer facilities or other such equipment, including product loading racks, to pipelines or any other forms of transportation. For the purposes of this subpart, the point at which such liquids or natural gas enters a natural gas processing plant is a point of custody transfer. Natural gas processing plant(gas plant) means any processing site engaged in the extraction of natural gas liquids from field gas, or the fractionation of mixed NGL to natural gas products, or a combination of both. Page 5 s . STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT 9g AIR POLLUTION CONTROL DIVISION F'" TELEPHONE: (303) 692-3150 *,,%9P,1** 418764 CONSTRUCTION PERMIT PERMIT NO: 1 3WE3007 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 Redtail Gas Plant, located in the NE ' 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 Methyldiethanolamine (MDEA) natural gas sweetening system for acid gas removal with a design capacity of 35 MMSCF per day (make, model,serial number:TBD). This emissions unit is equipped with two (2) make, model: TBD, electric OR gas-injection amine recirculation pumps with a total design capacity of 167 gallons per AMINE-1 017 minute. This system includes a natural gas/amine contactor, a flash tank, and an oil-heated amine regeneration reboiler. The oil heater for the reboiler is covered under a separate point (AIRS Point 014). Flash tank emissions are re-routed to a common fuel header that feeds the entire facility. The still vent stream is controlled by a thermal oxidizer. 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-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 Page 1 of 9 Amine SMIM Version 2012-1 DCo do p e o Public PollutionHealthand Control DivisionEnvironment 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 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 commencement of operation. • 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) Monthly Limits: Facility AIRS Pounds per Year Equipment ID Point SO2 NOx VOC CO Emission Type AMINE-1 017 --- — 247 -- Point (Note: Monthly limits are based on a 31-day month.) The owner or operator shall calculate monthly emissions based on the calendar month. Facility-wide emissions of each individual hazardous air pollutant shall be less than 1,359 lb/month. Facility-wide emissions of total hazardous air pollutants shall be less than 3,398 lb/month. AIRS ID: 123/9AD0 Page 2 of 9 Ilik , OF. CIA do p e o Public Health and Environment ' , Air Pollution Control Division Annual Limits: Facility AIRS Tons per Year Equipment ID Point SO2 NOx VOC CO Emission Type AMINE-1 001 --- --- 1.5 --- Point See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 8. 100% of emissions that result from the flash tank associated with this amine unit shall be recycled to the common fuel header. 9. This concentration of Ucarsol AP-814 solvent in the lean amine stream shall not exceed 40% by weight on a monthly average basis. The operator shall measure and record the solvent concentration in the lean amine stream each week and calculate and record a calendar monthly average solvent concentration to demonstrate compliance with this condition. 10. 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 Amine-1 017 Thermal Oxidizer VOC and HAPs PROCESS LIMITATIONS AND RECORDS 11. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual natural gas processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) • AIRS ID: 123/9AD0 Page 3 of 9 D Co do p e o Public Health and Environment Air Pollution Control Division Process/Consumption Limits Facility AIRS Annual Monthly Limit Equipment Point Process Parameter Limit (31 days) ID AMINE-1 017 Natural gas throughput 12,775 1085 MMscf/yr MMscf/month The owner or operator shall calculate monthly process rates based on the calendar month. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months'data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility,for Division review. 12. This unit shall be limited to the maximum lean amine recirculation pump rate of 167 gallons per minute. The lean amine recirculation rate shall be recorded weekly in a log maintained on site and made available to the Division for inspection upon request. A pump stroke correlation may be used to demonstrate compliance with this condition. (Reference: Regulation No. 3, Part B, II.A.4) STATE AND FEDERAL REGULATORY REQUIREMENTS 13. 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) 14. Visible emissions shall not exceed twenty percent(20%)opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30%opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. &4.) 15. This source is subject to the odor requirements of Regulation No.2.(State only enforceable) 16. The amine unit addressed by AIRS point ID 017 is subject to the New Source Performance Standards requirements of Regulation No. 6, Part A, Subpart OOOO, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution including, but not limited to, the following: • §60.5365—Applicability and Designation of Affected Facilities o §60.5365(g)(3)-Facilities that have a design capacity less than 2 long tons per day (LT/D) of hydrogen sulfide (H2S) in the acid gas (expressed as sulfur) are required to comply with recordkeeping and reporting requirements specified in §60.5423(c)but are not required to comply with§§60.5405 through 60.5407 and • §§60.5410(g) and 60.5415(g). • §60.5423—Record keeping and reporting Requirements • AIRS ID: 123/9AD0 Page 4 of 9 It CoA$ do p e o Public Health and Environment Ill Air Pollution Control Division o §60.5423(c) -To certify that a facility is exempt from the control requirements of these standards,for each facility with a design capacity less that 2 LT/D of H2 S in the acid gas (expressed as sulfur)you must keep,for the life of the facility, an analysis demonstrating that the facility's design capacity is less than 2 LT/D of H2 S expressed as sulfur. OPERATING & MAINTENANCE REQUIREMENTS 17. 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 18. The owner or operator shall complete the initial sour gas analysis testing required by this permit and submit the results to the Division as part of the self-certification process to ensure compliance with emissions limits. (Reference: Regulation No. 3, Part B, Section III.E.) 19. Within 180 days after commencement of operation, a source initial compliance test shall be conducted on emissions point 017 to measure the emission rate(s)for the pollutants listed below in order to demonstrate compliance with emissions limits.. For NOx and CO, initial compliance test shall demonstrate compliance that emissions are below APEN reporting threshold of 2 tons per year per pollutant. 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. Volatile Organic Compounds using EPA approved methods. Carbon Monoxide using EPA approved methods. BTEX compounds and n-Hexane using EPA approved methods. Periodic Testing Requirements 20. The operator shall sample the inlet gas to the plant on an annual basis to determine the concentration of hydrogen sulfide (H2S) in the gas stream. The sample results shall be monitored to demonstrate that this amine unit qualifies for the exemption from the Standards of Performance for Onshore Natural Gas Processing: SO2 Emissions (§60.640(b)). ADDITIONAL REQUIREMENTS 21. A revised Air Pollutant Emission Notice(APEN)shall be filed:(Reference: Regulation No.3, Part A, II.C) AIRS ID: 123/9AD0 Page 5 of 9 Co do p e o Public Health and Environment Air Pollution Control Division • Annually by April 30 whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5)tons per year or more, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more,whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50%or five(5)tons per year,whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed,or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 22. 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 23. 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. • 24. 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. 25. 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 Page 6 of 9 , ,llj I�. Co .do Bp p- e o Public Health and Environment 3 Air Pollution Control Division 26. 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. 27. 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. 28. 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. 29. 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 9 DCo 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 Dmsion 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.00v/cs/Satellite?c=Document C&childoagename=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 Emission Are the Controlled AIRS Rate emissions Emission Point Pollutant CAS# BIN (Ib/yr) reportable? Rate(Ib/yr) Benzene 71432 A 15,120 YES 720 017 Toluene 108883 C 9,700 YES 460 n-Hexane 110543 C 7,500 YES 80 5) The emission levels contained in this permit are based on the following emission factors: Emission Emission Emission Factors Factors Factors Uncontrolled Uncontrolled Controlled Flash Gas Vent Gas Vent Gas CAS# Pollutant Stream Stream Stream Source Ib/MMscf Ib/MMscf Ib/MMscf Natural Gas Natural Gas Natural Gas Throughput Throughput Throughput ' VOC 8.57 4.55 0.23 Simulation 110543 n-Hexane 0.46 0.13 0.0063 Simulation 71432 Benzene 0.06 1.15 0.06 Simulation 108883 Toluene 0.03 0.73 0.04 Simulation Note: The controlled emissions factors are based on the thermal oxidizer control efficiency of 95% for the still vent stream. 100%capture and control is applied to the flash tank gas recycling to the plant fuel system header. AIRS ID: 123/9AD0 Page 8 of 9 iCo do s p e o 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 NSPS LLL Not Applicable 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60, Appendixes Appendix A—Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX 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: https://www colorado.qov/pacific/cdphe/oi I-and-qas-construction-perm it-self-certification AIRS ID: 123/9AD0 Page 9 of 9 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Whiting Oil and Gas Corporation Permit Number: 13WE3007 Source Location: NE 1/4 Section 21 T10N R58W,Weld County (Attainment) Equipment Description: Amine unit AIRS ID: 123/9AD0/017 Date: July 24th 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? July 23rd 2014 Section 4—Source Description AIRS Point Equipment Description Methyldiethanolamine(MDEA) natural gas sweetening system for acid gas removal with a design capacity of 35 MMSCF per day(make, model, serial number: TBD). This emissions unit is equipped with two (2) make, model: TBD, electric OR gas-injection 017 amine recirculation pump with a total design capacity of 167 gallons per minute. This system includes a natural gas/amine contactor, a flash tank, and a natural gas fired amine regeneration reboiler. Flash tank emissions are re-routed to a common fuel header that feeds the entire facility. The vent stream is controlled by a thermal oxidizer. 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? PM4o 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 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) Section 5—Emission Estimate Information AIRS Point Emission Factor Source 011 Some other Division-approved modeling program(Dow chemical) 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 017 12,775 mmscf per year, natural gas throughput, 167 gallons per minute lean amine circulation rate Basis for Actual Emissions Reported Durina this APEN Filing(Reported to knrentorvi AIRS Point Process Consumption/Throughput/Production Data Year 017 12,775 mmscf per year, natural gas throughput, 167 gallons per NA minute lean amine circulation rate Basis for Permitted'tmfssions(Permit Limits), AIRS Point Process Consumption/Throughput/Production 017 12,775 mmscf per year, natural gas throughput, 167 gallons per minute lean amine circulation rate Does this source use a control device? X Yes No AIRS Point Process Control Device Description %Reduction Granted 017 01 Flash tank emissions are re-routed to fuel header 100 017 02 Thermal Oxidizer 95 Section 6—Emission Summa (tons per year) Point NO, VOC CO Single HAP Total HAP PTE: 017 -- 83.57 7.56(Benzene) 16.16 Uncontrolled point 017 -- 83.57 7.56(Benzene) 16.16 source emission rate: Controlled point 017 --- 1.45 0.36(Benzene) 0.63 source emission rate: Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled theControlled Emission Pollutant CAS# BIN Emission Rate emissions (ib1Yr) revom°ie? Rate(ibtyr) Benzene 71432 A 15,120 Yes 720 Toulene 110543 C 9,700 Yes 460 n-Hexane 110543 C 7,500 No 80 Note: Regulation 3, Part A, Section 1I.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 Page 2 AIRS Point Process Pollutant Regulatory Basis Test Method 017 01 VOC, Regulation No. 3, Part B., Section III.G.3 Stack Test HAPS 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 and 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 017 taken at 15-second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A(July, 1992)) in all subsections of Section II.A and B of this regulation. 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 017 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 017 Criteria Pollutants: Applicant is required to file an APEN since emissions exceed 2 tons per year VOC Part B—Construction Permit Exemptions 017 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 ILD.3.a) Regulation 6-New Source Performance Standards NSPS LLL: Each sweetening (amine) unit and each sweetening unit followed by a sulfur recovery unit; manufacturer date after January 24, 1984. 017 Applicant is not subject to NSPS LLL Page 3 NSPS OOOO: Each sweetening (amine) unit and each sweetening unit followed by a sulfur recovery unit; manufacturer date after August 23,2011. Applicant is subject to NSPS 0000 017 This source will have a design capacity less than 2 long tons/day H2S in the acid gas based on the information submitted in the application.This source will be required by 60.5423(c) to keep for the life of the equipment an analysis demonstrating that the facility's design capacity is less than 2 LT/D of H2S expressed as sulfur. No other requirements apply. Regulation 7 Volatile Or tanib Compounds " 017 None Regulation 8--Hazardous Air Pollutants 017 None Section 13—Aerometric Information Retrieval System Coding Information Emission Pollutant/ Fugitiv Emission Control Point Process Process Description Factor CAS# (Y/N) Factor Source (°'o) 8.57 VOC No Process 100 Ibs/mmscf Simulator 0.06 Benzene/ No Process 100 Ibs/mmscf 71432 Simulator 01 Amine Unit(Flash Gas) 0.03 Toluene/ No Process 100 Ibs/mmscf 108883 Simulator 0.46 n-Hexane/ No Process 100 Ibs/mmscf 110543 Simulator 4.55 Process 017 Ibs/mmscf VOC No Simulator 95 1.15 Benzene/ No Process 95 Ibs/mmscf 71432 Simulator 02 Amine Unit(Vent Gas) 0.73 Toluene/ No Process 95 Ibs/mmscf 108883 Simulator 0.13 n-Hexane/ No Process 95 Ibs/mmscf 110543 Simulator SCC 31000305—Gas Sweetening; Amine process Emission factors include flash tank and still vent and that factors are based on natural gas processing of 12,775 MMScf/yr. Page 4 Section 14—Miscellaneous Application Notes AIRS Point 017 Amine Unit Uncontrolled emission factor calculations using 12,775 MMscf/yr Flash Gas Uncontrolled Emission Factors: VOC= (12.5 lb/hr)*(8760 hr/year)/(12775 MMSCF/yr) = 8.57 lb/mmscf Benzene=(0.0861 lb/hr)*(8760 hr/year)/(12775 MMSCF/yr) = 0.06 lb/mmscf Toluene=(0.048 lb/hr)*(8760 hr/year)/(12775 MMSCF/yr) = 0.03 lb/mmscf n-hexane= (0.673 lb/hr)*(8760 hr/year)/(12775 MMSCF/yr) = 0.46 lb/mmscf Vent Gas Emission Factors: VOC = (6.63 lb/hr)*(8760 hr/year)/(12775 MMSCF/yr) =4.55 lb/mmscf Benzene =(1.64 lb/hr)*(8760 hr/year)/(12775 MMSCF/yr) = 1.15 lb/mmscf Toluene = (1.06 lb/hr)*(8760 hr/year)/(12775 MMSCF/yr) = 0.73 lb/mmscf n-hexane=(0.184 lb/hr)*(8760 hr/year)/(12775 MMSCF/yr) = 0.13 lb/mmscf Vent Gas Controlled Emission Factors using only vent gas stream: VOC = ((6.63 lb/hr)*(8760 hr/year)/(12775 MMSCF/yr))* (1-0.95) = 0.23 lb/mmscf Benzene=((1.64 lb/hr)*(8760 hr/year)/(12775 MMSCF/yr))* (1-0.95) = 0.06 lb/mmscf Toluene= ((1.06 lb/hr)*(8760 hr/year)/(12775 MMSCF/yr))* (1-0.95) =0.04 lb/mmscf n-hexane= ((0.184 lb/hr)*(8760 hr/year)/(12775 MMSCF/yr))* (1-0.95) =0.0063 lb/mmscf Does this amine unit have a reboiler? No, instead it has a hot oil heater. Page 5 x STATE OF COLORADO I r_. �pf•Cpl, COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT ..PT‘- AIR POLLUTION CONTROL DIVISION - O � F TELEPHONE: (303)692-3150 ,�. sii -4.'1676# CONSTRUCTION PERMIT PERMIT NO: 13WE3008 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 Redtail Gas Plant, located in the NE Y 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 Two (2) 400 BBL fixed roof storage tanks used to store PW-1, PW-2 018 produced water. Emissions from these tanks are controlled by an enclosed 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 commencement of operation, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC)Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) after commencement of operation, 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 AIRS ID: 123/9AD0 Page 1 of 8 Produced Water Tank SM/M Version 2012-1 • olor Depa e f li Health and Environment it Pollution Control Division associated w' i i e ion f hod 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) Monthly Limits: Facility AIRS Pounds per Month Equipment ID Point NO„ VOC CO Emission Type PW-1, PW-2 018 --- 34 --- Point (Note: Monthly limits are based on a 31-day month.) The owner or operator shall calculate monthly emissions based on the calendar month. Facility-wide emissions of each individual hazardous air pollutant shall be less than 1,359 lb/month. Facility-wide emissions of total hazardous air pollutants shall be less than 3,398 lb/month. Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO VOC CO Emission Type NO. PW-1, PW-2 018 -- 0.2 --- 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. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or AIRS ID: 123/9ADO Page 2 of 8 olor Depa en f • 'Ii Health and Environment r'it Pollution Control Division I mss. t r at a local field- h -1"r... •.-2 =ility . • ion re -'M« 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 PW-1, PW-2 018 Enclosed Flare VOC and HAPs PROCESS LIMITATIONS AND RECORDS 8. 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 AIRS Annual Monthly Limit Equipment Point Process Parameter Limit (31 days) ID PW-1, PW-2 018 Produced water throughput 29,200 2480 BBUyr BBUmonth The owner or operator shall calculate monthly process rates based on the calendar month. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations shall be required. After the first twelve (12) months of operation, compliance with only the annual limitation shall be required. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months'data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility,for Division review. 9. 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 10. The permit number and AIRS ID point number(e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 11. Visible emissions shall not exceed twenty percent(20%)opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30%opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. &4.) AIRS ID: 123/9ADO Page 3 of 8 Depa e f li Health and Environment it Pollution Control Division 12. This source is Dolor m ulati .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.) 14. 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: CO 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. 15. 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. COMPLIANCE TESTING AND SAMPLING 16. No compliance requirements under this section. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice(APEN)shall be filed:(Reference: Regulation No.3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year,a change in actual emissions of five (5)tons per year or more, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more,whichever is less,above the level reported on the last APEN submitted; or AIRS ID: 123/9AD0 Page 4 of 8 olor ji' Depa en f li 'Health and Environment t it Pollution Control Division Fora as 4 a it a h • x pa,�P . g,;. sd pu If the emissions increase by 50% or five (5)tons per year,whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed,or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 18. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted,then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide"final"authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source,in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence,this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and AIRS ID: 123/9AD0 Page 5 of 8 Depa e f li Health and Environment it Pollution Control Division regulations ofDolor o QC 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. 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: 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 ,+ , �tl m' fl2Ln' t ei! atit d Yd.,tq olorDepaK en' -f • f.li Health and Environment it Pollution Control Division Notes to Permit Holder : ' -` e o r " •e 1) The permit holder is required to pay fees for the processing time for this permit.An invoice for these fees will be issued after the permit is issued.The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit(Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions.The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: http://www.colorado.gov/cs/Satellite?c=Document C&childpagename=CDPHE- Main%2F Document 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 Emission Are the Controlled AIRS Rate emissions Emission Point Pollutant CAS# BIN (Ib/yr) reportable? Rate(Ib/yr) Benzene 71432 A 204 NO 10.2 018 n-Hexane 110543 C 642 YES 32.1 5) The emission levels contained in this permit are based on the following emission factors: Point 018: Emission Factors Emission Factors CAS# Pollutant Uncontrolled Controlled Source Ib/BBL Produced Ib/BBL Produced Water Throughput Water Throughput VOC 0.262 0.0131 CDPHE 110543 n-Hexane 0.022 0.0011 CDPHE 71432 Benzene 0.007 0.00035 CDPHE Note: The controlled emissions factors for point 018 are based on the flare control efficiency of 95%. AIRS ID: 123/9AD0 Page 7 of 8 DepF f li Health and Environment it Pollution Control Division 6) In accordance withDolor - Po n (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 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 OOO-Subpart YYYY MACT 63.6580-63.8830 Subpart 7777-Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXX( 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: www.colorado.00v/cdohe/oiloasoermits AIRS ID: 123/9AD0 Page 8 of 8 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Whiting Oil and Gas Corporation Permit Number: 13WE3008 Source Location: NE 1/4 of Section 21 T10N R58W,Weld County(attainment) Equipment Description: 2-400bb1 produced water tank AIRS ID: 123-9AD0-018 Date: June 4, 2014 Review Engineer: Rebecca Vasil Control Engineer Chris Laplante Section 2—Action Completed X CP1 Modification APEN Required/Permit Exempt Final Approval 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? May 7`"2014 Section 4—Source Description AIRS Point Equipment Description 018 Two(2)above ground 400 bbl atmospheric produced water storage tank Are"flash"emissions anticipated from these tanks? X Yes No Is this tank located at an E&P site? Yes X No Is this tank located at a non-E&P, midstream or X Yes 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? PM1 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 Yes X No Rule? If so, submit Form APCD-105 Section 5—Emission Estimate Information AIRS Point Emission Factor Source 018 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 018 29,200 BBL per year wastewater Basis for Actual Emisai#i©ns Reported Dunne this APE(Ealing(Reported to loventorvt AIRS Point Process Consumption/Throughput/Production Data Year 018 29,200 BBL per year wastewater N/A Basis for Permitted Emissions(Permit Limits; AIRS Point Process Consumption/Throughput/Production 018 29,200 BBL per year wastewater Does this source use a control device? X Yes No AIRS Point Process Control Device Description %Reduction Granted 018 01 Flare 95 Section 6—Emission Summary(tons per year) Point NO, VOC CO Single HAP Total HAP PTE: 018 - 3.8 - 0.32 0.42 (Hexane) Uncontrolled point 018 - 3.8 - 0.32 0.42 source emission rate: (Hexane) Controlled point 018 - 0.2 - 0.016 0.021 source emission rate: (Hexane) Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled Art the Controlled Emission Pollutant CAS# BIN Emission Rate minions P�yrl reportable? Rate(lb/yr) Benzene 71432 A 204 No 10.2 n-Hexane 110543 C 642 Yes 32.1 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? X Yes 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, 018 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•u lation 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 018 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 Perms PSD. Part A-APEN Requirements 018 Criteria Pollutants: Applicant Is required to file an APEN since emissions exceed 2 tons per year VOC Part B—Construction Permit Exemptions 018 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 ILD.3.a) Regulation B-New Source Performance Standards 018 None • Regulation 7—=Volatile Organic Compounds 018 None Regulation 8—Hazardous Air Pollutants 018 None Section 13—Aerometric Information Retrieval System Coding Information Point Process Process Description Emission Pollutant/ Fugitive Emission Factor Control Factor CAS# (Y/N) Source (o/o) 6.2381 lb/1000 V0C No CDPHE PS 95 gallons Memo 09-02 throughput 0.1667 01 Produced Water Storage lb/1000 Benzene No CDPHE PS 95 018 Tanks gallons Memo 09-02 throughput 0.5238 Ib/1000 n-Hexane No CDPHE PS 95 gallons Memo 09-02 throughput SCC 40400315—Fixed Roof Tank, Produced Water,working+breathing+flashing losses Section 14—Miscellaneous Application Notes AIRS Point 018 Produced Water Storage Tanks State-Developed Emission factors are: Produced Water Tank Default County Emission Factors(Ib/bbl) VOC Benzene n-Hexane Adams,Arapahoe, Boulder, Broomfield, Denver, 0.262 0.007 0.022 Douglas, Jefferson, Larimer and Weld Garfield, Mesa, Rio Blanco and Moffat 0.178 0.004 0.010 Remainder of Colorado 0.262 0.007 0.022 State-Developed Emission factors in lb/1000 gal are: Produced Water Tank Default County Emission Factors (lb/1000 gal) VOC Benzene n-Hexane Adams,Arapahoe, Boulder, Broomfield, Denver, 6.2381 0.1667 0.5238 Douglas, Jefferson, Larimer and Weld Garfield, Mesa, Rio Blanco and Moffat 4.2381 0.0952 0.2381 Remainder of Colorado 6.2381 0.1667 0.5238 This source is not located in the 8-hour ozone non-attainment area(Weld County is in partial attainment). Page 4 4mD r x . , STATE OF COLORADO cc cote COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT tb ��g AIR POLLUTION CONTROL DIVISION ' n TELEPHONE: (303)692-3150 � ,'/ CONSTRUCTION PERMIT PERMIT NO: 13WE3009 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 Redtail Gas Plant, located in the NE 1/4 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 LOAD-1 019 Truck loadout of condensate. Emissions from the loadout are controlled by an enclosed 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 commencement of operation, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) after commencement of operation, 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 AIRS ID: 123/9AD0 Page 1 of 9 Condensate Loadout TM Version 2012-1 Co do p e o Public PollutionHealthand ControlEnvironment Division 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 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) Monthly Limits: Facility Pounds per Month Equipment ID AIRS Point Emission Type V0C LOAD-1 019 85 Point (Note: Monthly limits are based on a 31-day month.) The owner or operator shall calculate monthly emissions based on the calendar month. Facility-wide emissions of each individual hazardous air pollutant shall be less than 1,359 lb/month. Facility-wide emissions of total hazardous air pollutants shall be less than 3,398 lb/month. Annual Limits: Facility AIRS Tons per Year Equipment Point Emission Type ID V0C LOAD-1 019 0.5 Point See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record AIRS ID: 123/9AD0 Page 2 of 9 Co A do .! p e o Public Health and Environment n Air Pollution Control Division a 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. 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 LOAD-1 019 Enclosed Flare VOC and HAPs PROCESS LIMITATIONS AND RECORDS 7. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing 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 Monthly Limit AIRS Process Parameter Annual Limit (31 Days) Point 019 Condensate Loading 182,500 BBL 15,500 BBL The owner or operator shall calculate monthly process rates based on the calendar month. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 8. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III.E) 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) AIRS ID: 123/9AD0 Page 3 of 9 Co do p e o PublD ic PollutionHeuhoand ControlEnvironment Division 10. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 11. The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.E): a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. b. All compartment hatches (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. • c. The owner or operator shall inspect loading equipment and operations onsite at the time of inspections to monitor compliance with Condition 11 (a) and (b) • above. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. 12. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. OPERATING & MAINTENANCE REQUIREMENTS 13. 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.) 14. The owner or operator of a loadout at which vapor balancing is used to control emissions shall: a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks and return these vapors to the stationary source storage tanks. b. Include devices to prevent the release of vapor from vapor recovery hoses not in use. c. Install dry-break loading couplings to prevent hydrocarbon liquid loss during uncoupling from vehicles. d. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. e. Operate all recovery and disposal equipment at a back pressure less than the pressure relief valve setting of transport vehicles. AIRS ID: 123/9AD0 Page 4 of 9 gym„ g'. Co A do 9 p er o Public Health and Environment II Air Pollution Control Division f. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers shall be weighted and properly seated. g. 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 flashing, working and breathing losses are routed to the control device under normal operating conditions. h. 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 15. This source is not required to comply with any testing and sampling requirements. 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 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, 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 9 D Co do p e o Public Health and Environment Air Pollution Control Division 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 I construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 21. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 22. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 23. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. AIRS ID: 123/9AD0 Page 6 of 9 Co 4do m p, e o' Public Health and Environment 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 9 Co do p e o PubD lic 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: htto://www.colorado.00v/cs/Satellite?c=Document C&childpagename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=125159938964184pagename=CBONWraDoer • 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# BIN (Ib/yr) reportable? Rate(lb/yr) n-Hexane 110543 C 2834.39 YES 142 Benzene 71432 A 163.80 NO 9 019 Toluene 108883 C 743.56 YES 38 Ethylbenzene 100414 C 306.04 YES 16 Xylenes 1330207 C 321.46 YES 16 5) The emission levels contained in this permit are based on the following emission factors: Emission Factors- Emission Factors— Uncontrolled Controlled CAS Pollutant lb/1000 gal Source Lb/1000 gal Source loaded loaded VOC 2.62 AP-42 0.131 AP-42 108883 Toluene 0.097 Source 0.00485 Source 100414 Ethylbenzene 0.040 Source 0.002 Source 1330207 Xylenes 0.042 Source 0.0021 Source 110543 n-Hexane 0.37 Source 0.0185 Source 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) AIRS ID: 123/9AD0 Page 8 of 9 Co r do a p e „ o Public Health and Environment �.II laAir Pollution Control Division P (true vapor pressure) = 5.06 psia M (vapor molecular weight) = 36.09 Ib/Ib-mol T(temperature of liquid loaded) = 521 °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. Controlled emission factors are based on a flare 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, HAPS PSD Synthetic Minor Source of: VOC, HAPS 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60,Appendixes Appendix A—Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX 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: www.colorado.clov/cdphe/oilqaspermits AIRS ID: 123/9AD0 Page 9 of 9 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Whiting Oil and Gas Corporation Permit Number: 13WE3009 Source Name: Redtail Gas Plant Source Location: NE 1/.of Section 21, T10N, R58W,Weld county (attainment) Equipment Description: Truck loadout AIRS ID: 123-9AD0-019 Review Date: June 5, 2014 Review Engineer: Rebecca Vasil Chris Laplante 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? May 7th 2014 Section 4—Source Description AIRS Point Equipment Description 019 Truck Condensate 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? Yes X 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 an API gravity of 40 degrees or greater)per year or Yes X No 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 nonattainment area? Yes X No 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 019 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] Did the applicant provide actual process data for the emission inventory? X Yes No Basis for Potentlsl bo EmRYP fEi : ' AIRS Point Process Consumption/Throughput/Production 019 182,500 BBL per year condensate loaded ta,"""e "e" ^ 'no rteett-,,e.manto-rearttorreerserraetn tare too." i'a skno Rersaarted fu rbi t'ttlpletiottpliolity*Stirt-givtang AIRS Point Process Consumption/Throughput/Production 019 182,500 BBL per year condensate loaded Basis for Permitted Emissions(Permit Limits]', AIRS Point Process Consumption/Throughput/Production 019 182,500 BBL per year condensate loaded Does this source use a control device? Yes X No Section 6—Emission Summary(tons per year) Point NOa VOC CO Single HAP HAP PTE: 019 — 10.05 — 1.42 (n-hexane) 2.2 Uncontrolled point 019 — 10.05 — 1.42(n-hexane) 2.2 source emission rate: Permitted point source 019 — 0.50 - 0.07(n-hexane) 0.1 emission rate: Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled Emission E Pollutant CAS# BIN Emission Rate .mk.l� Controlledon. Rate mri (MO reportable? Benzene 71432 A 163.80 No 8.19 n-Hexane 110543 C 2834.39 Yes 141:72 Page 2 Toluene 108883 C 743.56 Yes 37.18 Xylenes 1130207 C 321.46 Yes 16.07 Ethylbenzene C 306.04 Yes 15.30 Note: Regulation 3, Part A, Section ll.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 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)? 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 019 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 019 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-APENSLConstruction 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 11.D.3.a) 019 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-Nevi Source Performance Standards 019 No applicable subpart.This facility is not a bulk gasoline terminal. Regulation 7—Volatile Oriic':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 019 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 019 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 (obo) Limit Source 2.62 01 Truck Condensate 182,500 lb/1,000 V0C No AP 42 95 019 Loadout BBL/yr gallon throughput SCC 40600132: Crude Oil: Submerged Loading (Normal Service) Page 4 Section 14—Miscellaneous Application Notes AIRS Point 019 Truck Condensate Loadout Units Basis S 0.6 Submerged loading: dedicated normal service based on source's description/drawings P 5.06 Psia Based on extended natural gas sample M 36.09 Lb/lb-mole Based on extended natural gas sample T 521 Deg R Based on source's knowledge of bulk liquid temperature L 2.61 Lb/10^3 gal Value is used to calculate annual emissions of VOC 1.10E-01 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 2.621b/10^3 gal 1.10E-01 lb/bbl Annual requested Throughput 7665000ga1/yr Annual requested VOC emissions 200851b/yr 10.05tpy • Page 5 i STATE OF COLORADO I , p4 Cpl COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT - p'°k8 AIR POLLUTION CONTROL DIVISION TELEPHONE: (303)692-3150 ,Za w° + •187B CONSTRUCTION PERMIT PERMIT NO: 14WE0881 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 Redtail Gas Plant, located in the NE 1/4 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 DUST-1 020 Fugitive dust emissions from haul roads from NGL, condensate, and 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 httos://www.colorado.aov/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 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 pa en li ealth and Environment it Pollution Control Division of eighteenDolor • (i n to 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 Point Emission Type ID TSP PMio FM2.5 DUST-1 020 17.1 4.8 0.5 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, ll.A.4) Process/Consumption Limits AIRS Process Parameter Annual Limit Point 020 Travel onsite of NGL, Condensate and 4,385 miles/yr • Water 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 olorl Depa en . P di Health and Environment II •it Pollution Control Division STATE AND FEDE G LTr'' ' -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, I I.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 evime it Pollutionalth ControlandEn Division nt 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 olor Depa en . P di Health and Environment 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 5 of 8 Depa en li ealth and Environment it Pollution Control Division Notes to Permit HolderDolor 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.gov/cs/Satellite?c=Document C&childpaqename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&panename=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 9.99 21.9 AP-42, Section 13.2.2 PM10 2.78 21.9 AP-42, Section 13.2.2 PM2.5 0.28 21.9 AP-42, Section 13.2.2 Emissions from this point are based on 4,385 vehicle miles traveled per year, an average vehicle weight of 30.3 tons and a silt content of 7.5%. 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 Pernik 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.qov/ AIRS ID: 123/9AD0 Page 6 of 8 olor Depa en Ii it PollutionHealthand ControlEnvironment Division Part 60: Standar. . - rfor e 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 777Z—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: https://www.co lorado.qov/pacific/cdphe/oil-and-gas-construction-perm it-selfcertification AIRS ID: 123/9AD0 Page 7 of 8 olor n Ii earth and Environment T Pollution Control Division TI SI ROL 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 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Whiting Oil and Gas Corporation Permit Number: 14WE0881 Source Name: Redtail Gas Plant Source Location: NE 1/4, Section 21,T10N R58W Weld County(attainment) Equipment Description: Fugitive Dust emissions AIRS ID: 123/9AD0/020 Review Date: July 31"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? May 7`" 2014 Section 4—Source Description AIRS Point Equipment Description 020 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? PKo 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 PKo 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)) 020 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(PTE) AIRS Point Process Consumption/Throughput/Production 020 4,385 miles/yr Basis for Actual Emissions Reported During this APEN Fitino(Reported to lnventorvl AIRS Point Process Consumption/Throughput/Production 020 4,385 miles/yr Baste for Perrnitted Emissions(Permits,.;;.,, AIRS Point Process Consumption/ThroughputiProduction 020 4,385 miles/yr Does this source use a control device? Yes X No Section 6—Emission Summary (tons per year) Point TSP PM13 PM2.5 PTE: 020 21.90 6.10 0.61 Uncontrolled point 020 21.90 6.10 0.61 source emission rate: Permitted point source 020 17.10 4.77 0.48 emission rate: Section 7—Testing Requirements Will testing be required to show compliance with any emission rate or regulatory Yes X No standard? Sectiop 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 Regulation 1 -Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide 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 020 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 020 None Regulation 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 020 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 ll.D.3.a) Regulation 6- New Source Performance Standards 020 No applicable subpart. This facility is not a bulk gasoline terminal. Regulation 7—Volatile Organic Compounds 020 None Regulation 8—Hazardous Air Pollutants 020 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 9.99 TSP Y AP-42 21.9 IbNMT 01 Fugitive Dust 4,385 2.78 PMic Y AP-42 21.9 020 Emissions miles/year IbNMT 0.28 IbNMT PM2.5 Y AP-42 21.9 SCC 31088801: Fugitive Haul Road Emissions Page 3 Section 14—Miscellaneous Application Notes AIRS Point 020 Truck Condensate Loadout AP-42 13.2.2, Equation 1a E= k(s/12)Aa*(W/3)^b 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 PM1O 1.5 0.9 0.45 PM2,5 0.15 0.9 0.45 TSP: (4.9*(7.5/12)1'0.7)*(30.3/3)"0.45 =9.99 IbNMT PM10: (1.5*(7.5/12)^0.9)* (30.3/3)^0.45=2.78 IbNMT PM2.5: (0.15*(7.5/12)^0.9) *(30.3/3)^0.45=0.28 IbNMT Uncontrolled Emissions: TSP: (9.99 IbNMT)*(4385miles/year)/2000=21.90 tpy PM10: (2.78 IbNMT)*(4385miles/year)/2000=6.10 tpy PM2.5: (0.28 IbNMT)*(4385miles/year)/2000=0.61 tpy Page 4 4 STATE OF COLORADO ,'^ COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT c' 1 AIR POLLUTION CONTROL DIVISION i' TELEPHONE: (303)692-3150 :i ` 0or.. .197ss CONSTRUCTION PERMIT PERMIT NO: 13WE1130 Issuance 2 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 Redtail Gas Plant, located in the NE '/ of Section 31, T10N R58W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID FUG-1 009 Equipment leaks (fugitive VOCs) from a natural gas processing plant. 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, 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 9 Fugitive SM/M Version 2012-2 olor Depa en li ealth n andControl EnvironmentDivision it Pollutio 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) Monthly Limits: Facility AIRS Pounds per Month Emission Type Equipment ID Point V0C FUG-1 009 2262 Fugitive (Note: Monthly limits are based on a 31-day month.) The owner or operator shall calculate monthly emissions based on the calendar month. Facility-wide emissions of each individual hazardous air pollutant shall be less than 1,359 lb/month. Facility-wide emissions of total hazardous air pollutants shall be less than 3,398 lb/month. Annual Limits: Facility AIRS Tons per Year Equipment ID Point VOC Emission Type FUG-1 009 13.3 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. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. AIRS ID: 123/9AD0 Page 2 of 9 olori Depa en P di Health and Environment it Pollution Control Division The permit h.� >,t - I c x -t.-t�= -io . f ... `.,- onth - eep 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 analysis, 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. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 9. The fugitive emissions addressed by AIRS ID 009 are subject to the New Source Performance Standards requirements of Regulation No. 6, Part A, Subpart OOOO, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution including, but not limited to, the following: • §60.5365 Applicability - The group of all equipment, except compressors, within a process unit for which you commence construction, modification or reconstruction after August 23, 2011 is an affected facility per§60.5365(f). • §60.5400 Standards - The group of all equipment, except compressors, within a process unit must comply with the requirements of§60.5400 and §60.5401. • §60.5410 - Owner or operator must demonstrate initial compliance with the standards using the requirements in §60.5410(f). • § 60.5415 - Owner or operator must demonstrate continuous compliance with the standards using the requirements in §60.5415(f). • § 60.5421 - Owner or operator must comply with the recordkeeping requirements of §60.5421(b). • § 60.5422 - Owner or operator must comply with the reporting requirements of paragraphs (b) and (c) of this section in addition to the requirements of§ 60.487a(a), (b), (c)(2)(i)through (iv), and (c)(2)(vii)through (viii). 10. The reciprocating compressors grouped with the fugitive emissions addressed by AIRS ID 009 are subject to the New Source Performance Standards requirements of Regulation No. 6, Part A, Subpart OOOO, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution including, but not limited to, the following: • §60.5385(a) — Owner or operator must replace the reciprocating compressor rod packing according to either paragraph §60.5385(a)(1) or (2). (i) §60.5385(a)(1) - Before the compressor has operated for 26,000 hours. The number of hours of operation must be continuously monitored beginning upon initial startup of your reciprocating compressor affected facility, or October 15, 2012, or the date of the most recent reciprocating compressor rod packing replacement, whichever is later. (ii) §60.5385(a)(2) - Prior to 36 months from the date of the most recent rod packing replacement, or 36 months from the date of startup for a new AIRS ID: 123/9AD0 . Page 3 of 9 Depa en Ii ealth and Environment it Pollution Control Division rDolor p for i e r cking has not yet been replaced. • §60.5410 — Owner or operator must demonstrate initial compliance with the standards as detailed in §60.5410(c). • §60.5415—Owner or operator must demonstrate continuous compliance with the standards as detailed in §60.5415(c). • §60.5420 - Owner or operator must comply with the notification, reporting, and recordkeeping requirements as specified in §60.5420(a), §60.5420(b)(1), §60.5420(b)(4), and §60.5420(c)(3). 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 issuance of this permit, the owner or operator shall complete the initial extended gas analysis of gas samples that are representative of volatile organic compound (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas analysis 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 analysis OR 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 that are representative of volatile organic compounds (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas analysis shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. ADDITIONAL REQUIREMENTS 15. All previous versions of this permit are cancelled upon issuance of this permit. 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 Page 4 of 9 olor -Depa - en P .li 'Health and Environment it Pollution Control Division Y For so itt.,;.... 00 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. 17. 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: 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: 123/9ADO Page 5 of 9 • olor Depa en li ealth and Environment it Pollution Control Division • 22. Each and ev io h 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. 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 2 This Issuance Updated component counts Issuance 1 8/16/2013 Issued to Whiting Oil and Gas Corporation AIRS ID: 123/9AD0 Page 6 of 9 olor Depa en + •Ii Health and Environment •it Pollution Control Division „ ` Notes to Permit Holder= m' - 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.gov/cs/Satellite?c=Document C&childpagename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&paoename=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# (lb/yr) reportable? (Ib/yr) Benzene 71432 233 No 81 Toluene 108883 260 Yes 91 009 Ethylbenzene 100414 41 No 14 Xylenes 1330207 55 No 19 n-Hexane 110543 4,437 Yes 1552 5) The emission levels contained in this permit are based on the following emission factors: Water/Oil Component Gas Service Heavy Oil Light Oil Service Connectors 2573 0 982 0 Flanges 656 0 288 0 Open-ended Lines 0 0 0 0 Pump Seals 0 0 26 0 Valves 867 0 206 0 Other* 151 0 0 0 VOC Content(wt. 0.4039 1.0000 1.0000 1.0000 fraction) Benzene Content(wt. 0.0017 0.0000 0.0017 0.0000 fraction) Toluene Content(wt. 0.0019 0.0000 0.0019 0.0000 fraction) Ethylbenzene (wt. 0.0003 0.0000 0.0003 0.0000 fraction) Xylenes Content(wt. 0.0004 0.0000 0.0004 0.0000 AIRS ID: 123/9AD0 Page 7 of 9 olor Depa en li ealth and Environment it Pollution Control Division fraction) n-hexane Content(wt 0.0324 0.0000 0.0324 0.0000 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): 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 analysis. 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 Applicable 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: htto://ecfr.opoaccess.Qov/ AIRS ID: 123/9AD0 Page 8 of 9 olor. Depa en li Health and Environment it Pollution Control Division 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. 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