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Home My WebLink About20140133.tiff STATE OF COLORADO John W.Hickenlooper,Governor Larry Wolk,MD,MSPH Executive Director and Chief Medical OfficereS-2.y ,o ) Dedicated to protecting and improving the health and environment of the people of Colorado .4r , 4300 Cherry Creek Dr.S. Laboratory Services Division r Denver,Colorado 80246-1530 8100 Lowry Blvd. RECEIVED ,876 Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department Located in Glendale,Colorado (303)692-3090 Public • JAN Qof d www.colorado.gov/cdphe 3 2014 Environment Weld County Clerk&Recorder y gaD COUNT,' 1402 N 17th Ave CO PM Greeley, CO 80631 January 7, 2014 Dear Sir or Madam: On January 10, 2014,the Air Pollution Control Division will publish a public notice for Whiting Oil and Gas Corporation—Wildhorse 18-1844H, in the The Greeley Tribune. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty(30)days from the date the public notice is published. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health&Environment APCD-SS-B 1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, • 24A-ek. Et/L3 Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure • 4P-teADA el: 2014-0133 4O Ge < ��; ,�� i_/$- c2f/7 STATE OF COLORADO John W.Hickenlooper,Governor Larry Wolk,MD,MSPH �oF, er e Executive Director and Chief Medical Officer N j + o Dedicated to protecting and improving the health and environment of the people of Colorado * as'0?* 4300 Cherry Creek Dr.S. Laboratory Services Division •1876 Denver,Colorado 80246-1530 8100 Lowry Blvd. Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department Located in Glendale,Colorado (303)692-3090 of Public Health www.colorado.gov/cdphe and Environment Website Title: Whiting Oil and Gas Corporation—Wildhorse 18-1844H—Weld County Released To: The Greeley Tribune On: January 7, 2014 Published: January 10, 2014 PUBLIC NOTICE OF A PROPOSED PROJECT OR ACTIVITY WARRANTING PUBLIC COMMENT Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Whiting Oil and Gas Corporation Facility: Wildhorse 18-1844H Oil and natural gas exploration and production facility Section 18,Township 9 north, Range 59 west Weld County The proposed project or activity is as follows: Oil and natural gas exploration and production The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.I.a (25 tpy in a non-attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application,the Division's analysis, and a draft of Construction Permits 13WE2345 and 13WE2343 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at www.colorado.gov/cdphe/AirPublicNotices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such comment must be submitted in writing to the following addressee: Michael Cleary Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South,APCD-SS-B 1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us STATE OF COLORADO pF'_CO� COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT Fe ; AIR POLLUTION CONTROL DIVISION - TELEPHONE: (303)692-3150 .('v�x„ * *1876 CONSTRUCTION PERMIT PERMIT NO: 13WE2345 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 Wildhorse 18-1844H, located in Section 18,Township 9N, Range 59W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Sep-1 004 Separator controlled by a 30' flare stack. 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 issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC)Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days(180) after issuance of this permit,compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, II.G.2). 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i)does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii)discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the AIRS ID: 123/9B9D Page 1 of 8 Wellhead Version 2012-1 Colorado Department of Public Health and Environment Air Pollution Control Division estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The following information for all permitted equipment except fugitive emissions from equipment leaks shall be provided to the Division within fifteen (15) days after issuance of permit. • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification,with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO, VOC CO Emission Type Sep-1 004 7.7 66.5 15.4 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. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 8. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) AIRS ID: 123/9B9D Page 2 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division Facility AIRS Pollutants Equipment Point Control Device Controlled ID Sep-1 004 Separator controlled by a 30' flare stack VOC PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the throughput shall be maintained by the applicant and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Process Parameter Annual Limit Equipment ID Point Sep-1 004 Natural gas flaring 19.71 MMscf/yr The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months'data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility,for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and AIRS ID number shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 11. Visible emissions shall not exceed twenty percent(20%)opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30%opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.1. &4.) 12. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.5.) 13. These sources are subject to the odor requirements of Regulation No. 2. (State only enforceable) OPERATING & MAINTENANCE REQUIREMENTS 14. Upon startup of 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 AIRS ID: 123/9B9D Page 3 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division 15. The owner or operator shall demonstrate compliance with Condition 12 using EPA Method 9 to measure opacity from the flare. (Reference: Regulation No. 1, Section II.A.5). Periodic Testing Requirements 16. On an annual basis,the operator shall complete a site specific extended gas analysis of the natural gas produced at this site that is routed to the flare in order to verify the VOC content (weight fraction) of this emission stream used in the permit application. Results of testing shall be used to determine site-specific emission factors using Division approved methods. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice(APEN)shall be filed: (Reference: Regulation No.3, Part A, II.C) a. Annually whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5)tons per year or more, above the level reported on the last APEN; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5)tons per year,whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed,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 AIRS ID: 123/989D Page 4 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division 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 applicant and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the applicant or applicant's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence,this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the applicant, or the Division revokes a permit,the applicant or owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By. ,i /1114(7 Michael Cleary Permit Engineer Permit History Issuance Date Description e5of8 Pa AIRS ID: 123/9B9D g Colorado Department of Public Health and Environment Air Pollution Control Division Issuance 1 This Issuance Issued to Whiting Oil and Gas Corporation AIRS ID: 123/989D 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/req ulations/airregs/100102agcccom monprovisionsreg.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 (lb/yr) reportable? Rate(lb/yr) Benzene 71432 A 7408 Yes 370 Toluene 108883 C 7336 Yes . 367 I 004 Ethylbenzene 100414 C 1582 Yes 79 Xylenes 1330207 C 3021 Yes 151 n-Hexane 110543 C 57536 Yes 2877 5) The emission levels contained in this permit are based on the following emission factors: Weight Emission Emission Percent of Factors Factors CAS# Pollutant Source Gas Uncontrolled Controlled 0.138 0.138 NOx — Ib/MMBtu Ib/MMBtu TCEQ 0.2755 0.2755 CO — Ib/MMBtu lb/MMBtu TCEQ VOC 48.21 36991 1849.6 Engineering Calculation 71432 Benzene 0.137 103 5.2 Engineering Calculation 108883 Toluene 0.134 102 5.1 Engineering Calculation 100414 Ethylbenzene 0.030 22 1.1 Engineering Calculation AIRS ID: 123/9B9D Page 7 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division Weight Emission Emission CAS# Pollutant Percent of Factors Factors Source Gas Uncontrolled Controlled Engineering 1330207 Xylenes 0.056 42 2.1 Calculation Engineering 110543 n-Hexane 1.063 800 40.0 Calculation Note: The uncontrolled VOC and HAP emissions for this point were calculated using the 04/30/2013 analysis of a gas sample collected from the Wildhorse 15-1844H well. The controlled VOC and HAP emissions factors for point 004 are based on the flare control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice(APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at(303)-692- 3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, n-Hexane, Total Haps PSD Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60, Appendixes Appendix A—Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX 9) An Oil and Gas Industry Construction Permit Self-Certification Form is included with this permit packet. Please use this form to complete the self-certification requirements as specified in the permit conditions. Further guidance on self-certification can be found on our website at: http://www.cdphe.state.co.us/ap/oilgaspermittinq.html AIRS ID: 123/9B9D Page 8 of 8 Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment Air Pollution Control Division Division Information Engineer: Michael Cleary Attainment Status Control Engineer: Chris Laplante PM10 Attainment . Review Date: 12/10/2013 PM2.5 Attainment Application Date: 06/25/2013 SOx Attainment NOx Attainment VOC Attainment Facility Information CO Attainment Permit No. 13WE2345 County# 123 Weld Potentially Located within EAC-determine attainment status of NOx and VOC AIRs Facility# 9B9D Point# 004 Facility Equipment ID SEP-1 Company Name: Whiting Oil and Gas Corporation Source Name:Wildhorse 18-1844H Source Location: Section 18.T9N,R59W SIC: 1311 Elevation(feet) 5026 New Permit Modification APEN X (CPI) (Issuance#) Required/Permit f xemot Transfer of APEN Ownership Exempt/Permit Fxemnl _ Notes Equipment Description This source vents natural gas from: a well head separator I Emissions from this source are: routed to an open-flame flare . Natural gas venting from a well head separator.Emissions from this source are routed to an open- flame flare. Emission Calculation Method EPA Emission Inventory Improvement Program Publication:Volume II,Chapter 10-Displacement Equation(10.4-3) Ex=Q*MW*Xx/C Ex=emissions of pollutant x Q=Volumetric flow rate/volume of gas processed MW=Molecular weight of gas=SG of gas*MW of air Xx=mass fraction of x in gas C=molar volume of ideal gas(379 scf/lb-mol)at 60F and 1 atm Throughput(O) 71.92 MMscf/yr I 8210.0 scf/hr 6.11 MMscf/mo MW 29.110 lb/lb-mot 0.002 MMscf/d mote% MW lbx/lbmol mass fraction E lb/hr lb/yr tpy Helium 0 4.0026 0.000 0.000 Helium 0.0 0 0.00 CO2 2.626 44.01 1.156 0.040 CO2 25.0 219308 109.65 N2 2.814 28.013 0.788 0.027 N2 17.1 149586 74.79 methane 56.179 16.041 9.012 0.310 methane 195.2 1710068 855.03 ethane 13.704 30.063 4.120 0.142 ethane 89.2 781786 390.89 propane 136 44.092 5.9965 0.206 propane 129.9 1137907 568.95 isobutane 1.51 58.118 0.8776 _ 0.030 isobutane 19.0 • 166531 83.27 n-butane 5.242 68.116 3.0465 0.105 n-butane 66.0 578117 289.06 isopentane 1 048 72.114 0.7558 0.026 isopentane 16.4 143413 71.71 n-pentane 1 424 /2.114 1.0269 (F 3b n-pentane 22.2 194867 97.43 cyclopenlane 0149 70.13 0.1045 0.004 cyclopentane 2.3 19829 9.91 n-Hexane 0.3520 86.18 0.3034 0.01042 n-Hexane 6.6 57565 28.78 cyclohexane 0 0440 84.16 0.0370 0.001 cyclohexane 0.8 7027 3.51 Otherhexanes 0.378 86.18 0.3258 0.011 Otherhexanes 7.1 61817 30.91 heptanes 0.52 100.21 0.5211 0.018 heptanes 11.3 98883 49.44 methylcyclohexane 0.08 98.19 0.0786 0.003 methylcyclohexane 1.7 14906 7.45 224-TMP 0 114.23 0.0000 0.000 224-TMP 0.0 0 0.00 Benzene 0.05 78.12 0.0391 , 0.00134 Benzene 0.8 7412 3,71 Toluene 0.042 92.15 0.0387 0.00133 Toluene 0.8 7344 3.67 Ethylbenzene 0.008 106.17 0.0085 0.00029 Ethylbenzene 0.2 1612 0.81 Xytenes 0.015 106.17 0.0159 0.00055 Xylenes 0.3 3022 1.51 C8+Heavies 0.215 399 415 0.8587 0.029 C8+Heavies 18.6 162956 81.48 VOC mass fraction: 0.4821 Total VOC Emissions(Uncontrolled) 1331.6 29.110 amual limit assuming 95%control 66.6 Notes monthly limit assuming 95%control(lb/mo.) 11309.5 Mole%,MW,and mass fractions from the Wildhorse 18-18444H gas analysis,dated04/30/13. Emissions are based on 8760 hours of operation per year I calculated the average MW of C8+based on the average MW on the analysis for the gas. • Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment Air Pollution Control Division • Flaring Information Equipment Description Flare to combust produced gas until pipeline is available at this wellhead facility. Manufacturer TBD Model TBD Serial Number TBD Gas Heating Value 1559 Btu/scf Throughput 112122.6564 MMBtu/yr j Combustion emission factor source: TCEQ 0.138 lb NOX/MMBtu 0.2755 lb CO/MMBtu 7.74 tpy NOX I 15.44ltpy CO I Emissions Summary 7.74 tpy NOX Uncontrolled/PTE 15.44 tpy CO 1331.604 tpy VOC {Controlled 66.580 tpV VOC Uncontrolled Scenario A tontrolled Total(lb/yr) Bin Reportable? Total(Ib/yr) Benzene 7412 A Yes 371 3.71 Toluene 7344 C Yes 367 3.67 Ethylbenzene 1612 C Yes 81 0.81 Xylenes 3022 _ C Yes 151 1.51 n-hexane 57565 C j Yes 2878 28.78 224-TMP 0 C No 0 0 Regulatory Applicability AQCC Regulation 1 This source is subject to the opacity requirements for flares in Section II.A.5:'No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30%opacity.' AQCC Regulation 2 Section 1.A applies to all emission sources."No person,wherever located,shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven(7)or more volumes of odor free air." AQCC Regulation 3 An APEN is required for this source because uncontrolled VOC emissions Part A: exceed two tons per year in an attainment area. A permit is required for this source because uncontrolled VOC emissions from this facility exceed five tons per year in an attainment area. Part B: This source is not subject to Section 111.0.2(Minor Source RACT)because it is not located in a nonattainment area. Is public comment Public Comment Required required? Facility Status This facility is a synthetic minor source of VOC/HAP for Title V applicability. This facility is a synthetic minor source of VOC for PSD applicability. Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment Air Pollution Control Division Emission Factors for Permit Uncontrolled NOX 215 lb/MMscf natural gas vented As reported on APEN by Operator CO 430 lb/MMscf natural gas vented EF lb/yr 95% VOC 37030 Ib/MMsd natural gas vented 36991 2660378 Benzene 103 lb/MMsd natural gas vented 103 7408 370 Toluene 102 lb/MMsd natural gas vented 102 7336 367 Ethylbenzene 22 lb/MMscf natural gas vented 22 1582 79 Xylenes 42 Ib/MMsd natural gas vented 42 3021 151 n-Hexane 800 lb/MMsd natural gas vented 800 57536 2877 224-TMP 0 Ib/MMsd natural gas vented 1849.6 C•.►r•II.• 5.2 NOX 215.1 lb/MMsd natura gas vented 5.1 CO 429.5 Ib/MMsd nature gas vented 1.1 0 1851.5 lb/MMscf nature gas vented 2.1 :enzene s«na ura gas vented 40.0 o uene • '+s na ura gas vented • enzene .1 • 's- na ura gas vented enes s na ura gas vented n-'exane 0 0 T 's na ura gas vented - r• 0 0 • T +s na ura gas vented STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT mow= AIR POLLUTION CONTROL DIVISION r ° TELEPHONE:(303)692-3150 . w */816* CONSTRUCTION PERMIT PERMIT NO: 13WE2343 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 Wildhorse 18-1844 Pad, located in Section 18,Township 9N, Range 59W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID One (1) 400 BBL fixed roof storage tank used to store produced PW-1 002 water. Emissions from this tank are routed to an enclosed combustor with a destruction efficiency of 95%. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S.(25-7-101 et seq),TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. This construction permit represents final permit approval and authority to operate this emissions source. Therefore, it is not necessary to self-certify. (Regulation 3, Part B, Section III.G.5). 2. 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. 3. Within one hundred and eighty days(180)after issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). AIRS ID: 123/9B9D/002 Page 1 of 8 Produced Water Tank SM/M Version 2012-1 Colorado Department of Public Health and Environment Air Pollution Control Division 4. This permit shall expire if the owner or operator of the source for which this permit was issued: (i)does not commence construction/modification or operation of this source within 18 months after either the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii)discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification,with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Emission Type Equipment ID Point NO, VOC CO PW-2 002 --- 0.7 Point 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 7. This source shall be limited to the following processing rate as listed below.Annual 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 Process Parameter Annual Limit Equipment ID Point PW-2 002 Produced water throughput 102,200 BBL/yr 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: 123/9B9D/002 Page 2 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division keep a compliance record on site or at a local field office with site responsibility,for Division review. 8. 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 9. The permit number and AIRS ID point number(e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 10. Visible emissions shall not exceed twenty percent(20%)opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. & 4.) OPERATING & MAINTENANCE REQUIREMENTS 11. Flares shall be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare, or by other convenient means approved by the Division, determine whether the flare is operating properly. 12. If a control device is used to comply with the emission limits of this permit, the following conditions must be met: a. Leakage of VOCs to the atmosphere must be minimized as follows: (i) Thief hatch seals shall be inspected for integrity annually and replaced as necessary. Thief hatch covers shall be weighted and properly seated. (U) 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. 13. 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. 14. The owner or operator shall monitor and document the proper operation of the control device. Time intervals between monitoring shall not exceed 14 days. Indications of improper operation for a flare include, but are not limited to, absence of pilot light, malfunction of electronic ignition, and/or presence of smoke. A check box is suitable for recording proper operation. Improper operation of a control device shall be further documented with a description of the problem and its corrective action, the date range the AIRS ID: 123/9B9D/002 Page 3 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division control was inoperable, and the produced water production through the battery during the downtime. If the owner or operator cannot document the date that the control equipment became inoperable then downtime shall be assumed to have started directly after the last documented monitoring event. During control device downtime, emissions shall be considered to be uncontrolled. 15. This source is not required to follow a Division-approved operating and maintenance plan COMPLIANCE TESTING AND SAMPLING Periodic Testing Requirements 16. The owner or operator shall demonstrate compliance with opacity requirements, using EPA Method 9 to measure opacity from the flare. (Reference: Regulation No. 1, Section I I.A.1 & 4) ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice(APEN)shall be filed: (Reference: Regulation No.3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more,whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5)tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed,or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 18. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC AIRS ID: 123/9B9D/002 Page 4 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division 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: 123/9B9D/002 Page 5 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division By: /' 47 Michael Cleary Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Whiting Oil and Gas Corporation AIRS ID: 123/9B9D/002 Page 6 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit.An invoice for these fees will be issued after the permit is issued.The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit(Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions.The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: http://www.cd p he.state.co.us/req u lations/airregs/100102agcccom monprovis 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) Benzene 71432 A 715 Yes 36 002 n-Hexane 110543 C 2248 Yes 112 5) The emission levels contained in this permit are based on the following emission factors: Point 002: Emission Factors CAS# Pollutant Uncontrolled Source lb/BBL Produced Water Throughput VOC 0.262 CDPHE 110543 n-Hexane 0.022 CDPHE 71432 Benzene 0.007 CDPHE 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 AIRS ID: 12319B9D/002 Page 7 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division Operating Permit Synthetic Minor Source of:VOC, n-Hexane, Total Haps PSD Synthetic Minor Source of:VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ectir.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.gov/cdphe/oilqaspermits AIRS ID: 123/9B9D/002 Page 8 of 8 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Whiting Oil and Gas Corporation Permit Number: 13WE2343 Source Location: Section 18 T9N R59W Equipment Description: One(1) 400 BBL Produced Water Tank AIRS ID: 123/9B9D/002 Date: 10/24/2013 Review Engineer: Michael Cleary Section 2 —Action Completed Grandfathered I Modification APEN Required/Permit Exempt X Initial Approval I 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 I No is the APEN signed with an original signature? X Yes I 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? June 25, 2013 Section 4—Source Description AIRS Point Equipment Description 002 One(1) 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? X Yes I No Is this tank located at a non-E&P, midstream or Yes X No downstream site? _ Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria Yes X No pollutant? • If"yes", for what pollutant? j PM10 CO Ozone Is this location in an attainment maintenance area for Yes X No any criteria pollutant? Page 1 If"yes", for what pollutant? (Note:These pollutants are subject to minor source PM,o CO Ozone RACT per Regulation 3, Part B,Section III.D.2) Is this source claiming exempt status for this source based on the fraction of oil in the stored water(less X Yes 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 002 CDPHE Condensate 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 002 102,200 BBL per year wastewater Basis for Permitted Emissions(Permit Limits) AIRS Point Process Consumption/Throughput/Production 002 102,200 BBL per year wastewater Does this source use a control device? X Yes No % Reduction AIRS Point Process Control Device Description Granted 002 01 Open Flare 95 Section 6—Emission Summary (tons per year) _ Point NO, VOC CO Single HAP Total HAP PTE: 002 13.4 1.12 (n-Hexane) 1.48 Uncontrolled point 002 13.4 1.12 (n-Hexane) 1.48 source emission rate: Controlled point 002 0.7 0.06 (n-Hexane) 0.08 source emission rate: Total APEN Reported 002 0.7 0.06(n-Hexane) 0.08 emissions: Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled Are the Controlled Emission Pollutant CAS# BIN Emission Rate emissions Rate Ir (lb/yr) reportable? ( Y) Benzene 71432 A 715 Yes 36 n-Hexane 110543 C 2248 Yes 112 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. Page 2 Section 8—Testing Requirements Will testing be required to show compliance with any emission rate or regulatory Yes X No standard? Section 9—Source Classification Is this a new previously un-permitted source? X Yes No What is this facility classification? True X Synthetic Major Minor Minor Classification relates to what programs? X ; Title V X PSD NA NSR MACT Is this a modification to an existing permit? Yes X No If"yes" what kind of modification? Minor Synthetic Major Minor Section 10—Public Comment Does this permit require public comment per CAQCC Regulation 3? Yes X No If"yes",for which pollutants?Why? For Reg. 3, Part B, IIl,C.1.a (emissions increase> 25/50 tpy)? Yes No For Reg. 3, Part B, III.C.1.c.ii (subject to MACT)? Yes No For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? 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 -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, 002 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 002 measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7)or more volumes of odor free air. Regulation 3 -APENs, Construction Permits, Operating Permits. PSD Part A-APEN Requirements Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: 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 002 which the area is attainment. (Applicant is required to file an APEN since emissions exceed 2 tons per year VOC) Part B—Construction Permit Exemptions Applicant is not required to obtain a permit since the stored produced water I contains less than one percent by volume crude oil on an annual average (Reg. 3, Part B, Section 11.D.1.n2) Page 3 Regulation 6 - New Source Performance Standards NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84. Is this source greater than 19,800 gallons (471 bbl)? No 002 Is this source subject to NSPS Kb? No NSPS OOOO: for storage vessels, constructed after 8/23/2011, with emissions greater than 6 tpy. Applicant is requesting a permit to establish a federally enforceable limit below 6tpy. Regulation 7-Volatile Organic Compounds 002 None Regulation 8-Hazardous Air Pollutants 002 None Section 13—Aerometric Information Retrieval System Coding Information Process Emission Pollutant/ Fugitive Control Point Process Description Factor CAS# (Y/N) Emission Factor Source (%) 0.262 lb/bbl V0C No CDPHE PS Memo 09-02 NA throughput Produced Water 0.007 lb/bbl 01 Storage Tanks throughput Benzene No CDPHE PS Memo 09-02 NA 002 0.0221b/bbl n-Hexane No CDPHE PS Memo 09-02 NA throughput SCC 40400215—Fixed Roof Tank, Produced Water,working+breathing+flashing losses Section 14—Miscellaneous Application Notes AIRS Point 002 Produced Water Storage Tanks The source is categorically exempt per Reg. 3 but the operator has requested a permit be issued to establish a federally enforceable limit below the 6 tpy limit in effort to avoid monitoring and reporting requirements of NSPS OOOO. State-Developed Emission factors are: Produced Water Tank Default County Emission Factors (lb/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 This source is not located in the 8-hour ozone non-attainment area (This part of Weld County is in attainment). Page 4 �1 ° ld 0 ,2 N O = gill o 'en O Q 2. 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