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Home My WebLink About20142084.tiff STATE OF COLORADO John W.Hickenlooper,Governor Larry Wolk,MD,MSPH oF ooze Executive Director and Chief Medical Officer Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr.S. Laboratory Services Division .ten. Denver,Colorado 80246-1530 8100 Lowry Blvd. Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department Located in Glendale,Colorado (303)692-3090 of Public Health www.colorado.gov/edphe and Environment Weld County- Clerk to the Board 1150 O St PO Box 758 Greeley,CO 80632 June 20,2014 Dear Sir or Madam: On June 25,2014,the Air Pollution Control Division will publish a public notice for Whiting Oil and Gas Corporation—Razor 27K Production Battery, in 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, RECEIVED JUL 10 2014 Clara Gonzales WELD COUNTY Public Notice Coordinator COMMISSIONERS Stationary Sources Program Air Pollution Control Division Enclosure `To. Resltau) C z: PL(MM) at Leg) �- IV i4 1v4 L&-tek+,-sm) "1- l l !4 2014-2084 STATE OF COLORADO John W.Hickenlooper,Governor OF'COz' Larry Wolk,MD,MSPH Executive Director and Chief Medical Officer o; Dedicated to protecting and improving the health and environment of the people of Colorado l q o • •"+.+e.mw•i. * 4300 Cherry Creek Dr.S. Laboratory Services Division •rage' Denver,Colorado 80246-1530 8100 Lowry Blvd. Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department Located in Glendale,Colorado (303)692-3090 of Public Health www.colorado.gov/cdphe and Environment Website Title: Whiting Oil and Gas Corporation—Razor 27K Production Battery—Weld County Released To: Greeley Tribune On: June 20,2014 Published: June 25,2014 PUBLIC NOTICE OF A PROPOSED PROJECT OR ACTIVITY WARRANTING PUBLIC COMMENT Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Whiting Oil and Gas Corporation Facility: Razor 27K Production Battery Crude oil exploration and production site 13.4 miles north of Raymer, Colorado 80742 (NESW, Section 27,TION, R58W) Weld County The proposed project or activity is as follows: Operator requests to permit a crude oil storage battery consisting of twelve 400 barrel tanks with a 12 foot flare stack(requested through-put of 912,500 barrels crude oil/year) Operator requests to permit a 690 HP engine(requested through-put of 35.8 MMscf natural gas/year) Operator requests to permit a separator/flare(requested through-put of 87.6 MMscf separator vapors/year) The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.I.a (25 tpy in a non-attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application,the Division's analysis, and a draft of Construction Permit 14WE0405 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: Kirk Bear Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South,APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us STATE OF COLORADO OF 0` COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT :� \� AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 /8]6 f CONSTRUCTION PERMIT PERMIT NO: 14WE0405 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 exploration and production facility known as the Razor 27K Production Battery, located in the NESW, Section 27, T10N, R58W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID TK1 through 001 Twelve 400 barrel crude oil tanks TK12 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 of eighteen months or more; (iii) does not complete construction within a reasonable AIRS ID: 123-9C63-001 Page 1 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division 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 setf-certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The following information shall be provided to the Division within fifteen (15) days after issuance of permit. • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO VOC CO Emission Type TK1 through 001 0.5 5.0 2.9 Point TK12 See"Notes to Permit Holder°for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 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: 123-9C63-001 Page 2 of 8 Colorado Department of Public Health and Environment • Air Pollution Control Division Facility AIRS Pollutants Equipment Point Control Device Controlled ID TK1 through 001 Flare VOC TK12 PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Point Process Parameter Annual Limit Equipment ID TK1 through 001 Crude Oil Throughput 912,500 barrels TK12 Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 11. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. & 4.) 12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 13. 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.) 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 AIRS ID: 123-9C63-001 Page 3 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division 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. OPERATING & MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. The owner or operator shall demonstrate compliance with Condition 12, using EPA Method 22 to measure opacity from the flare. The observation period shall be a minimum of fifteen consecutive minutes. 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 ekisting 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: 123-9C63-001 Page 4 of 8 Colorado Department of Public Health and Environment • Air Pollution Control Division 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 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: 123-9C63-001 Page 5 of 8 Colorado Department of Public Health and Environment , Air Pollution Control Division • By: Kirk Bear Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Whiting Oil and Gas Corporation AIRS ID: 123-9C63-001 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.colorado.00v/cs/Satellite?c=Document C&childpagename=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 Rate Point Pollutant CAS# (Ib/yr) reportable? (Ib/yr) 001 Benzene 71432 274 Yes 14 001 n-Hexane 110543 1717 Yes 86 5) The emission levels contained in this permit are based on the following emission factors: Emission Factors Pollutant Uncontrolled Source lb/bbl NOx 0.068 AP-42 CO 0.37 AP-42 VOC 0.2213 E&P TANK n-Hexane 0.0019 E&P TANK Benzene 0.0003 E&P TANK Note: The controlled emissions for this point are based on the flare control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division.A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status AIRS ID: 123-9C63-001 Page 7 of 8 Colorado Department of Public Health and Environment .. Air Pollution Control Division • Requirement Operating Permit Synthetic Minor Source of: VOC, CO, HAPs PSD Synthetic Minor Source of: VOC MACT HH Major Source Requirements: Not Applicable 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 7777—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/oilqaspermits AIRS ID: 123-9C63-001 Page 8 of 8 1 Division Information Engineer: Kirk Bear Control Engineer: Christopher Laplante Review Date: 05/22/2014 Application Date: 02/13/2014 Facility Identifiers Permit No. 14WE0405 AIRS County# 123 Weld Facility# 9C63 Facility Type: exploration and production facility ❑Located in the 8-hour non-attainment area? O True Minor ® Synthetic Minor for: I✓ VOC r NOx r CO Administrative Information Company Name: Whiting Oil and Gas Corporation Source Name: Razor 27K Production Battery Source Location: NESW, Section 27, T10N, R58W SIC: 1311 Address 1: Whiting Oil and Gas Corporation Mailing Address Address 2: 333 Corporate Drive /,State Zip: Anothertown, ST, 00000 Name: Jed Smith Person To Phone: 303 390 1340 Contact Fax: 720 644 3636 Email: Jed.Smith@Whiting.com Requested Action Self Certification Required? Yes Issuance Number 1 Source Description: Oil and gas exploration and production facility known as the Razor 27K Production Battery, located in the NESW, Section 27,T10N, R58W,Weld County, Colorado. Point Name Type Control Action TK1 Newly 001 through Oil Tanks Flare reported TK12 source r 001 Twelve 400 barrel crude oil tanks Calculations Requsted Throughput 912,500 bbl Control Flare Efficiency 95.00%l Emissions Summary Table Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 0.2213 lb/bbl 101.0 tpy 5.0 tpy E&P TANK Benzene 0.00031b/bbl 274 lb/yr 14 lb/yr E&P TANK n-Hexane 0.0019 lb/bbl 1734 lb/yr 87 lb/yr E&P TANK Regulatory Review Section II.A.1 -Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20%opacity. This standard is based on 24 consecutive opacity readings taken at 15-second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A(July, 1992)) in all subsections of Section II. A and B of this regulation. Section II.A.5-Smokeless Flare or Flares for the Combustion of Waste Gases No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30%opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. Regulation 2—Odor Section I.A- No person,wherever located, shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7) or more volumes of odor free air. Regulation 6-New Source Performance Standards NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84. This source is not subject because each tank is less than 19,800 gallons(471 bbl) NSPS OOOO:for storage vessels in the natural gas production,transmission, and processing segments. This source is not subject because each tank emits less than 6 tpy VOC. Regulation 7—Volatile Organic Compounds XII. VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS (Applicant is not subject to the emission control requirements for condensate tanks since it is located in an attainment area.) XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS... (Applicant is currently subject to this since actual uncontrolled emissions are greater than 20 tpy of VOC.) • AIRS(County/Plant) 123/9C63 Permit No. 14WE0405 Date 5/22/2014 Controlled Controlled Actual Requested NCRP Emissions Emissions Ctrl. reportable Point# SCC Pollutant or CAS Uncontrolled Emission Factor Emisison Factor Source (tpy)' (tpy)' PTE(tpyy Eff% 001 VOC 02213 lb/bbl E&P TANK 5 101 95% Yes 001 Benzene 00001 lb/bbl E&P TANK 137 2738 95% Yes 001 n-hexane 00019 lb/bbl E&P TANK 86.7 1733.8 95% Yes STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION r TELEPHONE: (303) 692-3150 *1876 CONSTRUCTION PERMIT PERMIT NO: 14WE0406 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 exploration and production facility known as the Razor 27K Production Battery, located in the NESW Section 27, Township 10N, Range 58W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID One Caterpillar, Model G3508B, Serial Number RBK01278, natural gas-fired, turbocharged, 4SLB reciprocating internal combustion ENG-1 002 engine, site rated at 690 horsepower at 1400 RPM. This engine shall be equipped with an oxidation catalyst. This emission unit is used as a gas lift. This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Caterpillar, Model G3508B engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days after issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at 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 AIRS ID: 123-9C63-002 Page 1 of 17 Colorado Department of 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 for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The following information shall be provided to the Division within fifteen (15) days after issuance of permit. • 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 x ENG-1 002 6.6 4.7 13.3 Point See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. 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. AIRS ID: 123-9C63-002 Page 2 of 17 Colorado Department of Public Health and Environment • Air Pollution Control Division 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 CO, VOC, ENG-1 002 Catalytic Oxidizer Formaldehyde PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Equipment Point Process Parameter Annual Limit ID ENG-1 002 Fuel Consumption 35.8 MMscf/year Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 11. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control 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: 123-9C63-002 Page 3 of 17 Colorado Department of Public Health and Environment . Air Pollution Control Division 12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 14. This equipment is subject to the control requirements for natural gas-fired reciprocating internal combustion engines under Regulation No. 7, Section XVII.E (State only enforceable). The owner or operator of any natural gas-fired reciprocating internal combustion engine that is either constructed or relocated to the state of Colorado from another state after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Maximum' Engine Construction or Emission Standard in g/hp-hr HP Relocation Date NOx CO VOC <100HP Any N/A N/A N/A t100HP and January 1, 2008 2.0 4.0 1.0 <500HP January 1, 2011 1.0 2.0 0.7 2500HP July 1, 2007 2.0 4.0 1.0 July 1, 2010 1.0 2.0 0.7 1 Maximum engine horsepower is the nameplate rating of the engine and does not account for deration. MACT 7777 and NSPS JJJJ Requirements: • NSPS JJJJ is not currently adopted into Reg 6. Currently, NSPS JJJJ for any type of NG engine at any type of source is addressed in the notes to permit holder. • MACT 7777 for area sources: This portion of the MACT is notyet adopted into Reg P 9 8. Currently, these types of 7777 sources are addressed in the notes to permit holder 15. This source is subject to the requirements of: • Regulation No. 8, Part E , Subpart III.FFFF: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (RICE) of 40 C.F.R. Part 63, Subpart ZZZZ, and • Regulation No. 8, Part E, Subpart IA, National Emission Standards for Hazardous Air Pollutants for Source Categories: General Provisions, 40 CFR Part 63 including, but not limited to, the following: • Emission and Operating Limitations o 63.6600(b) - If you own or operate a new or reconstructed 4SLB stationary RICE with a site rating of more than 500 brake HP located at major source of HAP emissions you must comply with the following emission limitations (Table 2a, Subpart 7777 to Part 63): • reduce CO emissions by 93 percent or more; or AIRS ID: 123-9C63-002 Page 4 of 17 Colorado Department of Public Health and Environment Air Pollution Control Division • limit concentration of formaldehyde in the stationary RICE exhaust to 14 ppmvd or less at 15 percent O2. o 63.6600(b) - If you own or operate a new or reconstructed 4SLB stationary RICE with a site rating of more than 500 brake HP located at major source of HAP emissions you must comply with the following operating limitations (Table 2b, Subpart ZZZZ to Part 63): • maintain your catalyst so that the pressure drop across the catalyst does not change by more than 2 inches of water at 100 percent load plus or minus 10 percent from the pressure drop across the catalyst that was measured during the initial performance test; and • maintain the temperature of your stationary RICE exhaust so that the catalyst inlet temperature is greater than or equal to 450 °F and less than or equal to 1350 °F. • General Compliance Requirements o §63.6605(a) - You must be in compliance with the emission limitations and operating limitations in this subpart that apply to you at all times, except during periods of startup, shutdown, and malfunction. o §63.6605(b) - If you must comply with emission limitations and operating limitations, you must operate and maintain your stationary RICE, including air pollution control and monitoring equipment, in a manner consistent with good air pollution control practices for minimizing emissions at all times, including during startup, shutdown, and malfunction. • Testing and Initial Compliance Requirements o §63.6610(a) - You must conduct the initial performance test or other initial compliance demonstrations in Table 4 to Subpart ZZZZ of Part 63 that apply to you within 180 days after the compliance date that is specified for your stationary RICE in §63.6595 and according to the provisions in §63.7(a)(2). o §63.6615 - If you must comply with the emission limitations and operating limitations, you must conduct subsequent performance tests semiannually (as per Table 3 of Subpart 777Z to Part 63). After you have demonstrated compliance for two consecutive tests, you may reduce the frequency of subsequent performance tests to annually. If the results of any subsequent annual performance test indicate the stationary RICE is not in compliance with the CO or formaldehyde emission limitation, or you deviate from any of your operating limitations, you must resume semiannual performance tests. c §63.6625(a) - If you elect to install a CEMS as specified in Table 5 of this subpart, you must install, operate, and maintain a GEMS to monitor CO and either oxygen or CO2 at both the inlet and the outlet of the control device according to the requirements in paragraphs 63.6625(a)(1) through 63.6625(4) of Subpart ZZZZ to Part 63. o §63.6625(b) - If you are required to install a continuous parameter monitoring system (CPMS) as specified in Table 5 of this subpart, you must install, operate, and maintain each CPMS according to the requirements in §63.8. AIRS ID: 123-9C63-002 Page 5 of 17 Colorado Department of Public Health and Environment . Air Pollution Control Division o §63.6630(a) - You must demonstrate initial compliance with each emission and operating limitation that applies to you according to Table 5 of Subpart 7777 to Part 63. o §63.6630(b) - During the initial performance test, you must establish each operating limitation in Tables lb and 2b of Subpart 7777 to Part 63 that applies to you. o §63.6630(c) - You must submit the Notification of Compliance Status containing the results of the initial compliance demonstration according to the requirements in §63.6645. • Continuous Compliance Requirements Delete this entire section if the engine is not one of the following: o §63.6635(b) - Except for monitor malfunctions, associated repairs, and required quality assurance or control activities (including, as applicable, calibration checks and required zero and span adjustments), you must monitor continuously at all times that the stationary RICE is operating. o §63.6635(c) - You may not use data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities in data averages and calculations used to report emission or operating levels. You must, however, use all the valid data collected during all other periods. o §63.6640(a) - You must demonstrate continuous compliance with each emission limitation and operating limitation in Tables la and lb and Tables 2a and 2b of subpart 7777 of Part 63 that apply to you according to methods specified in Table 6 of Subpart 7777 of Part 63. o §63.6640(b) - You must report each instance in which you did not meet each emission limitation or operating limitation in Tables 1a and 1b and Tables 2a and 2b of Subpart 7777 of Part 63 that apply to you. These instances are deviations from the emission and operating limitations in this subpart. These deviations must be reported according to the requirements in §63.6650. If you change your catalyst, you must reestablish the values of the operating parameters measured during the initial performance test. When you reestablish the values of your operating parameters, you must also conduct a performance test to demonstrate that you are meeting the required emission limitation applicable to your stationary RICE. o §63.6640(d) - Consistent with §§63.6(e) and 63.7(e)(1), deviations from the emission or operating limitations that occur during a period of startup, shutdown, or malfunction are not violations if you demonstrate to the Administrator's satisfaction that you were operating in accordance with §63.6(e)(1). For new, reconstructed, and rebuilt stationary RICE, deviations from the emission or operating limitations that occur during the first 200 hours of operation from engine startup (engine burn-in period) are not violations. o §63.6640(e) - You must also report each instance in which you did not meet the requirements in Table 8 of Subpart 7777 to Part 63 that apply to you. • Notifications, Reports and Records AIRS ID: 123-9C63-002 Page 6 of 17 Colorado Department of Public Health and Environment Air Pollution Control Division o §63.6645(a) - If you own or operate a stationary RICE with a site rating of more than 500 brake HP located at a major source of HAP emissions you must submit all of the notifications in §§63.7(b) and (c), 63.8(e), (f)(4) and (f)(6), 63.9(b) through (e), and (g) and (h) that apply to you by the dates specified. o §63.6645(g) - If you are required to conduct a performance test, you must submit a Notification of Intent to conduct a performance test at least 60 days before the performance test is scheduled to begin as required in §63.7(b)(1). o §63.6645(h) - If you are required to conduct a performance test or other initial compliance demonstration as specified in Tables 4 and 5 of Subpart 777Z to Part 63, you must submit a Notification of Compliance Status according to §63.9(h)(2)(ii). • §63.6645(h)(1) - For each initial compliance demonstration required in Table 5 of Subpart ZZZZ to Part 63 that does not include a performance test, you must submit the Notification of Compliance Status before the close of business on the 30th day following the completion of the initial compliance demonstration. • §63.6645(h)(2) - For each initial compliance demonstration required in Table 5 of Subpart Z777 to Part 63 that includes a performance test conducted according to the requirements in Table 3 to this subpart, you must submit the Notification of Compliance Status, including the performance test results, before the close of business on the 60th day following the completion of the performance test according to §63.10(d)(2). o §63.6650(a) - You must submit each report in Table 7 of Subpart 7777 to Part 63 that applies to you. o §63.6655(a) - If you must comply with the emission and operating limitations, you must keep the records described in §63.6655(a)(1) through (a)(3), §63.6655 (b)(1) through (b)(3) and §63.6655 (c). o §63.6655(d) - You must keep the records required in Table 6 of Subpart Z777 of Part 63 to show continuous compliance with each emission or operating limitation that applies to you. o §63.6660(a) - Your records must be in a form suitable and readily available for expeditious review according to §63.10(b)(1). o §63.6660(b) - As specified in §63.10(b)(1), you must keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. o §63.6660(c) - You must keep each record readily accessible in hard copy or electronic form on-site for at least 2 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record, according to §63.10(b)(1). You can keep the records off-site for the remaining 3 years. • Other Requirements and Information o §63.6665 - Table 8 to this subpart shows which parts of the General Provisions in §§63.1 through 63.15 apply to you. AIRS ID: 123-9C63-002 Page 7 of 17 Colorado Department of Public Health and Environment • Air Pollution Control Division • OPERATING & MAINTENANCE REQUIREMENTS 13. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Periodic Testing Requirements 16. Point 002: This engine is subject to the periodic testing requirements of 40 C.F.R Part 63, Subpart 7777. 17. Point 002: This engine is subject to the periodic testing requirements as specified in the operating and maintenance (O&M) plan as approved by the Division. Revisions to your O&M plan are subject to Division approval. Replacements of this unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A. ADDITIONAL REQUIREMENTS 14. 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. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the altemative operating scenario outlined in this permit as Attachment A. The APEN shall include the specific manufacturer, model and AIRS ID: 123-9C63-002 Page 8 of 17 Colorado Department of Public Health and Environment Air Pollution Control Division serial number and horsepower of the permanent replacement engine, the appropriate APEN filing fee and a cover letter explaining that the owner or operator is exercising an alternative-operating scenario and is installing a permanent replacement engine. 15. 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 16. 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. 17. 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. 18. 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. 19. 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. 20. 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. AIRS ID: 123-9C63-002 Page 9 of 17 Colorado Department of Public Health and Environment Air Pollution Control Division • 21. 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. 22. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Kirk Bear Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Whiting Oil and Gas Corporation AIRS ID: 123-9C63-002 Page 10 of 17 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.colorado.00v/cs/Satellite?c=Document C&childpagename=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 Rate Point Pollutant CAS# (lb/yr) reportable? (Ib/yr) 002 Acetaldehyde 75070 378 Yes 378 002 Formaldehyde 50000 4787 Yes 479 5) The emission levels contained in this permit are based on the following emission factors: Emission Factors - Emission Factors— Source Uncontrolled Controlled NOx 1 g/hp-hr 1 g/hp-hr Manufacturer CO 28.57 q/hp-hr 2 g/hp-hr Manufacturer VOC 1.27 g/hp-hr 0.7 g/hp-hr Manufacturer Formaldehyde 0.36 g/hp-hr 0.036 g/hp-hr Manufacturer Acetaldehyde 0.0084 Ib/MMBTU 0.0084 lb/MMBTU AP-42 Emission factors are based on a Brake-Specific Fuel Consumption Factor of 7490 Btu/hp-hr, a site-rated horsepower value of 690, and a fuel heat value of 1265 Btu/scf. 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: AIRS ID: 123-9C63-002 Page 11 of 17 Colorado Department of Public Health and Environment Air Pollution Control Division Applicable Status Requirement Operating Permit Synthetic Minor Source of:VOC, CO, HAPs PSD Synthetic Minor Source of: VOC MACT HH Major Source Requirements: Not Applicable 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://ecfropoaccess.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 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/oilqaspermits AIRS ID: 123-9C63-002 Page 12 of 17 Colorado Department of Public Health and Environment Air Pollution Control Division ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES October 12, 2012 2. Alternative Operating Scenarios The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility-Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS, and the owner or operator shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with a compressor engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month period. "Permanent" is defined as in the same service for more than 90 operating days in any 12 month period. The 90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90 day total. The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit. All replacement engines are subject to all federally applicable and state-only requirements set forth in this permit(including monitoring and record keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5)years and made available to the Division upon request. The owner or operator shall maintain a log on-site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make them available to the Division upon request. 2.1.1 The owner or operator may temporarily replace an existing compressor engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other requirements applicable to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. AIRS ID: 123-9C63-002 Page 13 of 17 Colorado Department of Public Health and Environment. , Air Pollution Control Division 2.1.2 The owner or operator may permanently replace the existing compressor engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found at http://www.cdphe.state.co.us/ap/oilgaspermitting.html. This submittal shall be accompanied by a certification from the Responsible Official indicating that"based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7)calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol(ver March 2006 or newer) as found on the Division's web site at: http://www.colorado.gov/cs/Satellite/CDPHE-AP/CBON/1251596520270. Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year(whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year(8760), whichever applies. AIRS ID: 123-9C63-002 Page 14 of 17 • Colorado Department of Public Health and Environment • Air Pollution Control Division For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine will be subject to, the results of the test shall be converted to the appropriate units as described in the above-mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline. 2.3 Applicable Regulations for Permanent Engine Replacements 2.3.1 Reasonably Available Control Technology(RACT): Reg 3, Part B § II.D.2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and to NOX and SO2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr. For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating internal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOX: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (§60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State- Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified below: Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non- selective catalyst and air fuel controller to reduce emission. Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. AIRS ID: 123-9C63-002 Page 15 of 17 Colorado Department of Public Health and Environment - Air Pollution Control Division The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. Emission Standards: Section XVII.E—State-only requirements Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Construction or Emission Standards in G/hp-hr Max Engine HP Relocation Date NOx CO VOC January 1, 2008 2.0 4.0 1.0 100<Hp<500 January 1, 2011 1.0 2.0 0.7 July 1, 2007 2.0 4.0 1.0 500≤Hp July 1, 2010 1.0 2.0 0.7 The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. 2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean bum engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ requirements). However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, § I.B (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. 2.3.4 Reciprocating internal combustion engine(RICE) MACT: 40 CFR Part 63, Subpart 7777 A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart 7777. An analysis of the applicable monitoring, recordkeeping, and reporting AIRS ID: 123-9C63-002 Page 16 of 17 Division Information Engineer: Kirk Bear Control Engineer: Christopher Laplante Review Date: 05/28/2014 Application Date: 02/13/2014 Facility Identifiers Permit No. 14WE0406 AIRS County# 123 Weld Facility# 9C63 Facility Type: exploration and production facility ❑Located in the 8-hour non-attainment area? 0 True Minor Synthetic Minor for: r VOC r N0x r CO Administrative Information Company Name: Whiting Oil and Gas Corporation Source Name: Razor 27K Production Battery Source Location: NESW Section 27, Township 10N, Range 58W SIC: 1311 Address 1: Whiting Oil and Gas Corporation Mailing Address 2: 1700 Broadway, Suite 2300 Address State Zip: Denver, Colorado 80290 Name: Jed Smith Person To Phone: 303 390 1340 Contact Fax: 720 644 3636 Email: Jed.Smith@Whiting.com 'Requested Action Self Certification Required? Yes Issuance Number: 1 Source Description: Oil and gas exploration and production facility known as the Razor 27K Production Battery, located in the NESW Section 27,Township 10N, Range 58W,Weld County,Colorado. Point Name Type Control Action Catalytic Newly 002 ENG-1 Engine reported Oxidizer source t One(1)Acme,Model To Be Determined,Serial Number To Be Determined,natural gas-fired,naturally aspirated.4SLB reciprocating internal combustion engine,site rated at 0 horsepower at 0 RPM.This engine shall be equipped with an oxidation catalyst and air-fuel ratio control/non-selective catalytic reduction(NSCR)system and air-fuel ratio control/This engine is not equipped with emission controls.This 002 emission unit is used for natural gas compression• Engine Information Engine date of m 4/5/2013 Manufacturer: Caterpillar Model Number: G3508B Serial Number: RBK01278 RPM: 1400 Site-rated RPM: 1400 Engine Function Compression berating Mfg's Max.Rated Horsepower @ sea level: 690 Horsepower used for calcuations: 690 BSCF @ 100%Load(btu/hp-hr): 7490 Site-Rated BSCF @ 100%load(btu/hp-hr): 7490 Engine Type 4SLB Other Parameters Aspiration turbo-charged Electrical Generator Max Site Rating(kw) 0 Max hrsryr of Operation 8760 Calculations Fuel Use Rate @ 100%Load 4085.454545 scf/hr ACTUAL Annual Fuel Consumption MMscf/yr MAR PU I Lry I IAL Annual}uef Consumption 35.789 MMscf/yr REQUESTED Annual Fuel Consumption 35.789 MMscf/yr Fuel Heating Value 1265 btu/scf Emission Control Information Colorado Department of Public Health and Environment • • Air Pollution Control Division requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. 2.4 Additional Sources The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site; an engine that is being installed as an entirely new emission point and not as part of an AOS- . approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. AIRS ID: 123-9C63-002 Page 17 of 17 I This engine shall be equipped with an oxidation Emissions Summary Table Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source NOx 1.000 g/hp-hr 1.000 g/hp-hr 6.6 tpy 6.6 tpy Manufacturer CO 28.570 g/hp-hr 2.000 g/hp-hr 190.0 tpy 13.3 tpy Manufacturer VOC 1.270 g/hp-hr 0.700 q/hp-hr 8.4 tpy 4.7 tpy Manufacturer Formaldehyde 0.360 g/hp-hr 0.036 g/hp-hr 4787 lb/yr 479 lb/yr Manufacturer Acetaldehyde 0.008 lb/MMBTU 0.008 lb/MMBTU 376 lb/yr 378 lb/yr AP-42 Acrolein 0.005 lb/MMBTU 0.005 Ib/MMBTU 233 lb/yr 233 lb/yr AP-42 Benzene 0.000 Ib/MMBTU 0.000 Ib/MMBTU 20 lb/yr 20 lb/yr AP-42 Regulatory Requirements Ambient Air Impd Source is not required to model based on Division Guidelines/No NAAQS violations expected(see details MACT ZZZZ located at a(n) Reg 7)(VII.E Standards(g/hp- NOx: 0.0 CO: 0.0 VOC: 0.0 hr) Reg 7)VI.B (Ozone NAA No requirements) applies? MACT 7777(area Is this engine subject to MACT ZZZZ area source requirements? TBD source) NSPS JJJJ Is this engine subject to NSPS JJJJ? I TBD Note:JJJJ requriements are not currently included as permit conditions because the req has not been f AIRS(County/Plant) 123/9C63 Permit No. 14WE0406 Date 5/28/2014 Uncontrolled Emission Point# SCC Pollutant or CAS Factor 002 20200254 VOC 1.27 g/hp-hr 002 20200254 NOx 1 g/hp-hr 002 20200254 CO 28.57 g/hp-hr 002 20200254 Benzene 0 lb/MMBTU 002 20200254 Formaldehyde 0.36 g/hp-hr 002 20200254 Acetaldehyde 0.008 lb/MMBTU 002 20200254 Acrolein 0.005 Ib/MMBTU Controlled Controlled Actual Requested NCRP= Emissions Emissions Ctrl. reportable Emisison Factor Source (tpy)* (tpy)` PTE (tpy)* Eff% ? Manufacturer 4.7 8.4 44% Yes Manufacturer 6.6 6.6 0% Yes Manufacturer 13.3 190 93% Yes AP-42 20 20 0% No Manufacturer 479 4787 90% Yes AP-42 379 379 0% Yes AP-42 233 233 0% No • STATE OF COLORADO oFot() COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT �a �� AIR POLLUTION CONTROL DIVISION ' TELEPHONE: (303)692-3150 *ran• CONSTRUCTION PERMIT PERMIT NO: 14WE0410 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 exploration and production facility known as the Razor 27K Production Battery, located in the NESW Section 27, Township 10N, Range 58W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID SEP-1, 006 Separator controlled by a 12' flare stack. Flare has a minimum SEP-2 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, 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 AIRS ID: 123-9C63-006 Page 1 of 8 Colorado Department of Public Health and Environment • , Air Pollution Control Division time of the estimated completion date. The Division may grant extensions of the deadlineper Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, 9 9 III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The following information shall be provided to the Division within fifteen (15) days after issuance of permit. • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO, VOC CO Emission Type SEP-1, SEP-2 006 4.1 54.3 22.5 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. 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: 123-9C63-006 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, 006 Flare VOC SEP-2 PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Equipment Point Process Parameter Annual Limit ID SEP-1, 006 Gas Vented from Separator 87.6 MMscf SEP-2 Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 11. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. & 4.) 12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) OPERATING & MAINTENANCE REQUIREMENTS 13. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements AIRS ID: 123-9C63-006 Page 3 of 8 Colorado Department of Public Health and Environment r , Air Pollution Control Division 14. 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) Periodic Testing Requirements 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 15. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5)tons per year or more, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 16. Federal regulatory program requirements (i.e. PSD, NANSR 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 17. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. AIRS ID: 123-9C63-006 Page 4 of 8 , ' Colorado Department of Public Health and Environment Air Pollution Control Division 18. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self- Certify for Final Authorization section of this permit. 19. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 20. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 21. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 22. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 23. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Kirk Bear Permit Engineer AIRS ID: 123-9C63-006 Page 5 of 8 Colorado Department of Public Health and Environment C Air Pollution Control Division Permit History Issuance Date Description Issuance 1 This Issuance Issued to Whiting Oil and Gas Corporation AIRS ID: 123-9C63-006 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.colorado.gov/cs/Satellite?c=Document C&childpaaename=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 Are the Controlled AIRS Emissions emissions Emissions Point Pollutant CAS# (lb/yr) reportable? (Ib/yr) 006 Benzene 71432 4500 Yes 225 006 n-Hexane 110543 35020 Yes 1751 006 Toluene 108883 3200 Yes 160 006 Ethylbenzene 100414 740 Yes 37 006 Xylenes 1330207 980 Yes 49 5) The emission levels contained in this permit are based on the following emission factors: Point 005: Weight Emission Emission Pollutant Fraction of Factors Factors Source Gas(%) Uncontrolled Controlled lb/MMscf lb/MMscf NOx(lb/MMBTU) --- 0.068 0.068 AP-42 CO (lb/MMBTU) 0.37 0.37 AP-42 • VOC 37.0 24001.30 1200.06 Gas Analysis Benzene 0.079 51.53 2.57 Gas Analysis Toluene 0.055 36.47 1.82 Gas Analysis Ethylbenzene 0.013 8.40 0.42 Gas Analysis Xylenes 0.004 11.20 0.56 Gas Analysis n-hexane 0.176 400.20 20.01 Gas Analysis 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 AIRS ID: 123-9C63-006 Page 7 of 8 Colorado Department of Public Health and Environment • .. Air Pollution Control Division 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, CO, HAPs PSD Synthetic Minor Source of: VOC MACT HH Major Source Requirements: Not Applicable 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.p p0access.q Ov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60,Appendixes Appendix A—Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart 7777—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX 9) 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/cdpheThilqaspermits AIRS ID: 123-9C63-006 Page 8 of 8 i 4 Division Information Engineer: Kirk Bear Control Engineer: Christopher Laplante Review Date: 05/30/2014 Application Date: 02/13/2014 Facility Identifiers Permit No. 14WE0410 AIRS County# 123 Weld Facility# 9C63 Facility Type: exploration and production facility El Located in the 8-hour non-attainment area? O True Minor Synthetic Minor for: l✓ VOC f" NOx h+ CO Administrative Information Company Name: Whiting Oil and Gas Corporation Source Name: Razor 27K Production Battery Source Location: NESW Section 27, Township 10N, Range 58W SIC: 1311 Address 1: Whiting Oil and Gas Corporation Mailing Address Address 2: 1700 Broadway, Suite 2300 /,State Zip: Denver, Colorado 80290 Name: Jed Smith Person To Phone: 303 390 1340 Contact Fax: 720 644 3636 Email: Jed.Smith@WhitinR.com Requested Action Self Certification Required? Yes Issuance Number: 1 Source Description: Oil and gas exploration and production facility known as the Razor 27K Production Battery, located in the NESW Section 27,Township 10N, Range 58W, Weld County, Colorado. Point Name Type Control Action SEP-1, Newly 006 SEP 2 Separator Venting Flare reported source r = ' Separator controlled by a 40'flare stat.k.Flare has a minimum combustion efficiency of 95%. The flare is/is 006 not enclosed. Equipment Description This source vents natural gas from: a well head separator Emissions from this source are: routed to a flare Natural gas venting from a well head separator.Emissions from this source are routed to a flare. Calculations Fmission Calculation Method EPA Emission Inventory Improvement Program Publication:Volume II,Chapter 10-Displacement Equation(10.4-3) Ex=Q•MW•Xx IC Ex=emissions of pollutant x Q=Volumetric flow rateNolume 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(Q) 87.6 MMscf/yr 10000 scfmr MW 24.813 lb/lb-mol 0.24 MMscf/d mole% MW Ibx/lbmol mass fraction lb/hr lb/yr On' Helium 0.000 4.0026 0.000 0.000 0.00 0.00 0.00 CO2 2.377 44.01 1.046 0.042 27.60 241793.96 120.90 N2 1.733 28.013 0.485 0.020 12.81 112207.81 56.10 methane 68.022 16.041 10.911 0.440 287.90 2522003.77 1261.00 ethane 10.888 30.063 3.273 0.132 86.37 756563.40 378.28 propane 9.504 44.092 4.191 0.169 110.57 968570.24 484.29 isobutane 1.047 58.118 0.608 0.025 16.06 140644.33 70.32 n-butane 3.777 58.118 2.195, 0.088 57.92 507367.38 253.68 isopentane 0.743 72.114 0.536 0.022 14.14 123843.52 61.92 n-pentane 0.985 72.114 0.710 0.029 18.74 164180.17 82.09 cyclopentane 0098 _ 70.13 0.069 0.003 1.81 15885.28 7.94 n-Hexane 0.176 86.18 0.152 0.006 4.00 35057.75 17.53 cyclohexane 0.043 84.16 0.036 0.001 0.95 8364.48 4.18 Other hexanes 0.306 86.18 0.264 0.011 6.96 60952.68 30.48 heptanes 0.145 100.21 0.145 0.006 3.83 33584.89 16.79 me8rylcyclohexane 0.000 98.19 0.000 0.000 0.00 0.00 0.00 224-TMP 0.000 114.23 0.000 0.000 0.00 0.00 0.00 Benzene 0.025 78.12 0.020 0.001 0.52 4514.06 2.26 Toluene 0.015 92.15 0014 0.001 0.36 3194.86 1.60 Ethytbenzene 0.003 106.17 0.003 0.000 0.08 736.19 0.37 Xylenes 0.004 106.17 0.004 0.000 0.11 981.58 0.49 C8+Heavies 0.109 137.4837288 0.150 0.006 3.95 34637.19 17.32 V0C mass frac 0.367 Total VOC(uncontrolled) 1051.26 24.813 Notes Emissions are based on 8760 hours of operation per year. • Flaring Information Equipment Description Flare to combust produced gas until pipeline is available at this wellhead facility. Manufacturer TBD Model 12'Flare Stack Serial Number TBD Gas Heating Value 1389 Btu/scf Throughput 121676.4 MMBtu/yr VRU Information Equipment Description Engine to recompress gas to sales line. Make Model Requested Control 100.00% Annual Bypass Tim 50.00% Backup Flare Overall Control 95.00% Combustion emission factor source: AP-42:Chapter 13.5 0.068 jIb NOX/MMBtu 0.37 jIb CO/MMBtu Emissions Summary Table Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 24001.31 lb/MMscf 1200.07 lb/MMscf 1051.3 tpy 52.6 tpy Gas Analysis Nox 0.07 lb/MMBTU 0.07 lb/MMBTU 4.1 tpy 4.1 tpy AP-42 CO 0.37 lb/MMBTU 0.37 lb/MMBTU 22.5 tpy 22.5 tpy AP-42 Benzene 51.53 lb/MMscf 2.58 lb/MMscf 4514 lb/yr 226 lb/yr Gas Analysis n-Hexane 400.20 lb/MMscf 20.01 lb/MMscf 35058 lb/yr 1753 lb/yr Gas Analysis Toluene 36.47 lb/MMscf 1.82 lb/MMscf 3195 lb/yr 160 lb/yr Gas Analysis Xylenes 11.21 lb/MMscf 0.56 lb/MMscf 982 lb/yr 49 lb/yr Gas Analysis Ethylbenzene 840 lb/MMscf 0.42 lb/MMscf 736 lb/yr 37 lb/yr Gas Analysis Regulatory Applicability AQCC Regulation 1 This source is subject to the opacity requirements for flares in Section 11 A.5:No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30%opacity.' AQCC Regulation 2 Section I.A applies to all emission sources."No person,wherever located,shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven(7)or more volumes of odor free air." AIRS(County/Plant) 123/9C63 Permit No. 14WE0410 Date 5/30/2014 Uncontrolled Emission Point# SCC Pollutant or CAS Factor 005 31000205 VOC 24001.308 lb/MMscf 005 31000205 NOx 0.068 lb/MMBTU 005 31000205 CO 0.37 Ib/MMBTU 005 31000205 Benzene 51.53 lb/MMscf 005 31000205 n-Hexane 400.203 lb/MMscf 005 31000205 Toluene 36.471 Ib/MMscf 005 31000205 Ethylbenzene 8.404 Ib/MMscf 005 31000205 Xylenes 11.205 lb/MMscf • Controlled Controlled Actual Requested NCRP = Emissions Emissions Ctrl. reportable Emisison Factor Source (tpy)" (tpy)" PTE (toy)" Eff% ? Gas Analysis 52.6 1051.3 95% Yes AP-42 4.1 4.1 0% Yes AP-42 22.5 22.5 0% Yes Gas Analysis 225.7 4514.1 95% Yes Gas Analysis 1752.9 35057.8 95% Yes Gas Analysis 159.7 3194.9 95% Yes Gas Analysis 36.8 736.2 95% Yes Gas Analysis 49.1 981.6 95% Yes u 4 en O '°O _._. 0 _ D E m 4 0 p[ N v '=" O O W F -7' A N i y U O ti Q ` . E8 °‘ ''' '''' ')V b ". 3. 43I M p 0 O. > cE W U J T `C 000 ° o o y E a W d o o 23 z s P. 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